BlueScope Steel Ltd

BlueScope Steel Ltd has established a structured process to manage the alignment of its indirect lobbying through industry associations, chiefly via its Industry Associations Governance Standard, which "details the principles which guide our membership and how we assess alignment between the public policy positions of the industry association and BlueScope's position as stated in public documents." Under this Standard, "at least once a year, a nominated BlueScope representative will assess the public policy positions taken by industry associations on matters of significance to the company, specifically: ... climate change and energy," and "an annual summary of these assessments is reported to the Board's RSC." These steps demonstrate a clear mechanism for reviewing and reporting on the climate-related positions of key associations, and high-level outcomes have been published, noting that they "did not find any material differences" between BlueScope and its associations. However, the company does not disclose a comparable governance process or oversight mechanism for its direct lobbying or government engagement beyond stating that activities are "guided by Our Bond and our Political Contributions Standard." We found no evidence of a formal review cycle, board sign-off, or a named individual responsible for ensuring its direct lobbying aligns with its climate policy, indicating that governance for direct climate lobbying is not clearly articulated.