GrainCorp Ltd

The company discloses only limited information on how it governs its engagement with policymakers, stating that "GrainCorp will not use Company funds, property, goods or services as a contribution to a political party or candidate" and that any payments of "legitimate fees for approved GrainCorp attendees to participate in, or attend as observers, those political events which are assessed to be of relevance to GrainCorp, its industry or operations" must be "approved by the Chairman and the MD and CEO." This reveals a basic approval mechanism for political-event spending, indicating some oversight at the highest executive level; however, we found no evidence of a broader governance framework that monitors or aligns the company's direct or indirect lobbying with its climate strategy, no description of regular reviews or audits, no published assessment of trade-association positions, and no reference to climate-related lobbying objectives. Consequently, the disclosure suggests only a limited governance process focused narrowly on political donations rather than a comprehensive system for managing climate-related lobbying activities.