Rio Tinto Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Rio Tinto discloses its climate-policy lobbying in a highly transparent manner. It names multiple specific measures it has engaged on, including the Australian Government’s “Safeguard Mechanism Reform Consultation” (August 2022 and January 2023), the “Guarantee of Origin Scheme” consultation, the “Technology Investment Roadmap” discussion paper, reforms to the “Environment Protection and Biodiversity Conservation Act 1999,” and New Zealand’s “Reforming the New Zealand Emissions Trading Scheme: Proposed Settings.” The company also sets out how it engages: it submits formal responses through the Australian Department of Climate Change, Energy, the Environment and Water’s consultation hub, emails submissions to the New Zealand Ministry for the Environment, and influences policy indirectly by holding board positions and committee seats in bodies such as the National Mining Association, the Business Council of Australia and the International Emissions Trading Association. These descriptions identify both the mechanisms used—written submissions, consultations, board and committee advocacy, monthly industry meetings—and the precise policymaking targets they are directed at. Rio Tinto is equally explicit about what it wants to achieve. It argues for “resetting baselines to remove aggregate headroom,” supports “facility-specific production-adjusted baselines” and “inter-temporal flexibility” within the Safeguard Mechanism, calls for “Strong National Environmental Standards” and “reduced complexity and duplication” in EPBC approvals, seeks “more flexibility beyond the proposed 12-month vintage requirement for surrendering units” in the Guarantee of Origin Scheme, and backs a staged approach to reforming the NZ ETS to protect trade-exposed industries. By clearly naming the policies, explaining the channels of influence, and detailing the specific legislative or regulatory changes it is pressing for, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Rio Tinto discloses a defined governance process that covers both its own advocacy and its participation in industry associations, indicating strong oversight of climate-related lobbying. The company states that "Climate change is a material and strategic topic for Rio Tinto and is therefore part of ongoing discussion and analysis at the most senior levels of management and the Board" and that "The Board approves our overall strategy, our policy positions and the Climate Change Report," showing that direct lobbying positions require board sign-off. Oversight responsibility is clearly assigned: "The Chairman is the Board member responsible for our overall approach to climate change" while "Our Chief Legal Officer, Governance and Corporate Affairs is accountable to the climate policy engagement, governance," demonstrating named individuals with accountability. For indirect lobbying, Rio Tinto explains that "We review the climate advocacy of our industry associations each year, publish this review on our website and consider it when we decide whether to renew our membership," and the Sustainability Committee "reviews industry association engagement," highlighting a recurrent, disclosed mechanism to assess alignment and the possibility of changing or ending memberships. The review explicitly examines "the policy positions and advocacy of the industry association" and their consistency with the "goals of the Paris Agreement," which shows a formal process to ensure alignment with the companys climate commitments. However, the disclosure does not describe a stand-alone, publicly available climate-lobbying audit that covers both direct and indirect activities in detail, nor does it indicate use of third-party assurance, so the transparency, while robust, is not fully comprehensive.	3