Telstra Group Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Telstra provides a detailed and specific account of its climate-policy lobbying activities, demonstrating a high level of transparency across all aspects of its engagement. It names a wide array of distinct policy processes it has acted on, including Australia’s National Climate Resilience and Adaptation Strategy, the Corporate Emissions Reduction Transparency (CERT) reporting framework under the NGER scheme, the Independent Review of Australian Carbon Credit Units (the “Chubb Review”), the Energy Security Board’s “Post-2025 Market Design | Final advice to Energy Ministers,” and its submissions to the Commonwealth Royal Commission into National Natural Disaster Arrangements. The company also discloses the mechanisms and targets of these efforts: it lodged formal written submissions to the CERT consultation, the Chubb Review and the Royal Commission, “was invited to participate in industry co-design workshops with the Clean Energy Regulator,” and “engaged with key policy makers in the Australian Government” during the SMARTer 2030 work, thereby identifying both the methods used and the government bodies addressed. Finally, Telstra sets out the concrete outcomes it is pursuing. For the CERT framework it advocates changes such as reporting “volumes of ACCUs purchased as a percentage of total supply” and inclusion of “Scope 3 commitments and progress”; for the Chubb Review it calls for “the need to address the deficiency of supply of ACCUs,” “longer lead times … to address changes which substantially increase ACCU demand,” and “an integrated approach … at a national level”; and in the ESB market-design debate it urges that any new reliability mechanism “focus specifically and explicitly on the dunkelflaute problem” rather than impose broader capacity obligations. By clearly connecting each lobbying activity to identifiable policy processes, describing the submissions, hearings and workshops used to influence named government bodies, and articulating specific amendments or design preferences it seeks, Telstra offers a comprehensive picture of its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Telstra discloses a clear internal framework that links its policy advocacy to its climate strategy, noting that "all our direct and indirect activities that influence policy" are governed by a four-stage approval process in which material must be signed off by "Function subject matter expert, Investor Relations, Legal, and Communications," with the "Sustainability group … included in the sign-off process for communications relating to Telstra’s Environment Strategy and Environment Policy." This structure shows that a defined body inside the External Affairs & Legal function reviews lobbying-related communications before they are issued, indicating oversight beyond the teams that actually conduct lobbying. The company states that these controls "ensure that information is accurate (i.e., consistent with our Environment Strategy and Environment Policy), authorised, and appropriately managed," demonstrating an explicit mechanism for aligning direct lobbying with its climate goals. For indirect lobbying it reports that it "recently conducted a review of our alignment with our key industry associations’ positions in relation to climate change" covering November 2019-June 2021, found “broad alignment,” and that it "will continue to monitor our memberships to ensure this alignment on climate change and energy policy remains the same," evidencing an ongoing process to manage trade-association positions. Telstra further reinforces intent with a “public commitment … to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the disclosure does not identify a specific named executive or board committee with ultimate oversight, nor does it publish a stand-alone, third-party audited climate-lobbying report, so transparency and accountability fall short of leading practice. Overall, this indicates strong governance covering both direct and indirect lobbying, but with limited public detail on board-level oversight and independent assurance.	3