Westpac Banking Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Westpac Banking Corporation provides a detailed picture of its climate-policy engagement. It names multiple identifiable policy processes it has worked on, including the Australian Government Treasury’s consultation on a mandatory climate-related financial-disclosure framework, APRA’s Climate Vulnerability Assessment, APRA’s draft prudential practice guide CPG 229 on climate-risk management, its contribution to the national sustainable-finance taxonomy led by the Australian Sustainable Finance Institute, and advocacy through the Australian Business Roundtable for Disaster Resilience and Safer Communities for stronger “better policy and funding for resilience and adaptation.” The bank is equally explicit about how it seeks to influence these measures: it takes part in formal government and regulator consultations, submits written feedback, participates in Australian Banking Association working groups, engages directly with APRA, and advocates through industry coalitions such as the Business Roundtable and the Australian Industry Energy Transitions Initiative. Finally, Westpac spells out the outcomes it is pursuing—shaping the final design of APRA’s Climate Vulnerability Assessment, securing guidance in CPG 229 that aligns with its risk-management practices, achieving government adoption of a coherent national taxonomy, and increasing public funding and policy support for community resilience and adaptation—demonstrating clear positions and concrete regulatory changes it wants to see. Taken together, these disclosures show a comprehensive level of transparency about the policies it lobbies, the mechanisms it employs, and the specific results it is seeking.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Westpac Banking Corp demonstrates a moderate level of governance in managing its climate-related lobbying activities. The company discloses that its "Position Statement and Action Plan has been reviewed by the Environment, Social, Governance and Reputation (ESGR) Committee, which is an executive level committee and chaired by our CEO," and that the Board has oversight of its climate change response. Additionally, the company states that it "continues to review our membership of industry associations and their advocacy activity with regards to climate change in line with our Industry Association Principles," which indicates some level of monitoring of indirect lobbying. However, while the company outlines a governance structure involving multiple committees, such as the ESGR Committee and the Stakeholder Advisory Council, and mentions that "we aim to identify and collaborate with industry groups on initiatives that align with our principles," there is no explicit evidence of a detailed process for ensuring alignment of both direct and indirect lobbying with its climate goals. Furthermore, while the Board and its committees receive updates on climate-related matters, the disclosures do not provide specific mechanisms or criteria for assessing and enforcing alignment of lobbying activities. The company also does not disclose a comprehensive lobbying audit or review that evaluates alignment with climate-related goals. This indicates that while governance structures are in place, the processes for monitoring and managing lobbying alignment remain underdeveloped or undisclosed.	2