Contact Energy Ltd – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Strong	Contact Energy discloses a structured process to keep its policy advocacy aligned with its climate strategy. It states that "we review and monitor the climate policy positions of our trade associations for consistency with the Paris Agreement goals and ensure that our direct lobbying is similarly consistent," and sets out an escalation pathway whereby if positions "could not be reconciled, Contact would consider whether continued membership of the association was incompatible with its own position and may withdraw from the association." Oversight responsibilities are clearly allocated: "Contact’s engagements are managed by the Head of Regulatory and Government Relations," while "The Chief Corporate Affairs Officer (CCO, a member of our executive) provides governance oversight of public policy engagements… and ensures that those trade associations are aligned with our stakeholder engagement principles, our Tikanga, and our public commitments." Monitoring occurs through “a stakeholder engagement register, direct feedback… and by attending key meetings,” indicating an ongoing mechanism rather than an ad-hoc review. Employees are required to follow the lobbying policy and "Compliance with this policy will be periodically monitored by Corporate Affairs," with whistle-blowing routes for breaches. This demonstrates strong governance of both direct and indirect lobbying and names accountable executives, yet the company does not disclose a publicly available, in-depth climate-lobbying alignment audit or independent review, so the transparency of outcomes and board-level sign-off are less clear. View Sources	B

Overall Assessment

Analysis

Score

Strong

Contact Energy discloses a structured process to keep its policy advocacy aligned with its climate strategy. It states that "we review and monitor the climate policy positions of our trade associations for consistency with the Paris Agreement goals and ensure that our direct lobbying is similarly consistent," and sets out an escalation pathway whereby if positions "could not be reconciled, Contact would consider whether continued membership of the association was incompatible with its own position and may withdraw from the association." Oversight responsibilities are clearly allocated: "Contact’s engagements are managed by the Head of Regulatory and Government Relations," while "The Chief Corporate Affairs Officer (CCO, a member of our executive) provides governance oversight of public policy engagements… and ensures that those trade associations are aligned with our stakeholder engagement principles, our Tikanga, and our public commitments." Monitoring occurs through “a stakeholder engagement register, direct feedback… and by attending key meetings,” indicating an ongoing mechanism rather than an ad-hoc review. Employees are required to follow the lobbying policy and "Compliance with this policy will be periodically monitored by Corporate Affairs," with whistle-blowing routes for breaches. This demonstrates strong governance of both direct and indirect lobbying and names accountable executives, yet the company does not disclose a publicly available, in-depth climate-lobbying alignment audit or independent review, so the transparency of outcomes and board-level sign-off are less clear.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Strong	Contact Energy provides a generally clear picture of the substance of its climate-policy engagement. It names several identifiable policies or initiatives it has worked on, including the Climate Change Commission’s 2021 Consultation Draft, the New Zealand Emissions Trading Scheme (where it advocates an accelerated NZU price path), the proposed New Zealand Battery Project, and the Commission’s target of 95 % renewable electricity by 2035. The company discloses one concrete lobbying channel by publishing a written submission addressed to “Dr. Roderick Carr, Chair of the Climate Change Commission,” and indicates that it also pursues its positions through industry bodies such as the Sustainable Business Council, the New Zealand Initiative and ERANZ, although it does not spell out further mechanisms or the specific government audiences reached through those associations. Contact is explicit about the outcomes it seeks: it wants “clear and enduring policy” to underpin investment, supports “an accelerated price path for NZUs,” favours targeted subsidies for industrial electrification, and opposes the forced closure of high-emission geothermal fields while proposing Non-Condensable Gas reinjection as an alternative. Together, these disclosures demonstrate strong transparency on the policies addressed and the positions taken, even though the company gives only limited detail on the range of lobbying methods and targets it employs beyond its formal submission.	B