Telstra Group Ltd

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.