BlueScope Steel Ltd

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BlueScope Steel provides a highly transparent picture of its climate-policy lobbying. It names several specific measures it has worked on, including the reform of Australia’s Safeguard Mechanism, the Federal Government’s review of carbon-leakage risks and future Carbon Border Adjustment Mechanism, the Future Gas Strategy, consultations on electricity-system development and green-metals policies, and the co-investment framework for the Glenbrook electric arc furnace in New Zealand. The company also explains how it communicates its views, detailing “one-on-one meetings, written submissions, participation in round-table discussions, and site visits for policymakers” with the Australian Federal and State Governments, regular engagement with New Zealand ministers and officials through an official working group, and additional advocacy via industry bodies such as the Australian Industry Group, the Australian Industry Greenhouse Network and ResponsibleSteel™. Finally, BlueScope is explicit about what it wants to achieve: it sought “improvements to the SGM, to accommodate the expected timing of iron and steelmaking decarbonisation,” backs a “well-designed Carbon Border Adjustment Mechanism” to prevent carbon leakage, and pursues policy support and public funding for large-scale projects like the Glenbrook EAF and the No.6 blast-furnace reline so that domestic steelmakers are “not disadvantaged relative to import competitors.” These disclosures collectively demonstrate a comprehensive level of transparency regarding the company’s climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	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 BlueScopes 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 Boards 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, limiting the strength of its overal governance.	2