This scorecard provides a detailed breakdown of InfluenceMap's assessment of BHP's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of BHP, accessible via the buttons on the right hand side of the page.
The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:
In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and BHP's company profile - is accessible via the buttons on the right hand side of the page.
A summary of BHP's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
| Indicator | Score |
|---|---|
| Accuracy of Climate Policy Engagement Disclosure | Partial, meets some criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | Yes, meets criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | No, does not meet criteria |
A summary of BHP's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.
The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.
| Date of Review | Score |
|---|---|
| June 2023 | 6/14 (43%) |
| September 2024 | 6/14 (43%) |
This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.
The tables below provide: (1) a breakdown of BHP's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?
BHP has published a broadly complete account of its positions and engagement activities on specific climate-related policies, but excludes 1 material evidence of direct climate policy engagement identified by InfluenceMap's database.
BHP's advocacy page includes links to its direct advocacy on climate policy from 2022 to April 2025, including the Australian Climate Change Authority's 2024 Issues paper, Australia's Electricity and Energy Sector Plan and Carbon Leakage Review. It also disclosed its 2023-24 and 2024-25 Pre-Budget Submissions to the Treasury of Australia.
However, BHP has excluded its engagement on Australia's Future Made in Australia Bill 2024, despite engaging on the policy in a July 2024 consultation submission.
Enel has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.
BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses. It also contains sorting options for most recent, and most relevant.
Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?
BHP has disclosed a complete list of its industry association memberships. However, the company has not disclosed a recent account of its industry associations' positions and engagement activities, with its last full disclosure published over two years prior to InfluenceMap's assessment. BHP has therefore excluded key instances of recent engagement with specific climate-related policies by its industry associations.
For example, the Minerals Council of Australia advocated against the introduction of a climate trigger into Australia's EPBC Act in July 2024 comments to the Nature Positive (Environment Information Australia) Bill 2024 Public Hearing
See Appendix A below for details of the company's industry association memberships.
Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.
Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.
This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.
The Review Score is split into seven indicators, which fall within one of three categories:
Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?
Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?
The table below provides an overview of BHP's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.
| Review Process | Review Assessment (Direct) | Review Assessment (Indirect) |
|---|---|---|
| Monitor & Review | Identify & Assess | Identify & Assess |
| Alignment Assessment Method | Act | Act |
| Framework for Misalignment |
The tables below provide: (1) a breakdown of BHP's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.
Has the company established an annual monitoring and review process to ensure that all of its direct and/or indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?
BHP has explicitly committed to publishing a full review of its industry associations’ climate policy engagement every two years, with a progress update on addressing areas of misalignment in the intervening years, including any relevant findings from its real-time monitoring of industry associations. BHP has published three full reviews in 2017, 2019 and 2023, alongside three review updates in 2018, 2020 and 2024.
Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.
Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?
BHP has disclosed a clear methodology to assess alignment with its industry associations based on its 2020 Global Climate Policy Standards, which it links in its 2023 full review. In these Standards, BHP states that an important part of its climate strategy is enhancing the global policy response “including advocacy for policy that will enable a ‘well below 2°C’ world.” The company’s Global Climate Policy Standards broadly include: advocacy on climate policy underpinned by the goals of the Paris Agreement; constructive and targeted advocacy on ‘Paris-aligned' national emissions reduction targets, least-cost policies, cost-benefit analysis, and policies to support the development of pre-commercial, low emissions technologies; and balanced, fact-based, focused, and technology-neutral advocacy on climate policy.
BHP also explained what would constitute a finding of alignment, material misalignment, or non-material misalignment. In considering whether an identified misalignment was material or not, BHP will consider 3 things: the nature of the misalignment, the nature of the policy issue, and the consistency or trajectory of the industry association’s advocacy. BHP has also provided a clear explanation behind the evaluation of each industry association.
BHP has assessed the alignment of its industry associations against the company’s own climate policy positions. However, its own climate policy positions appear to be partially misaligned with the 1.5°C goal of the Paris Agreement. For example, BHP states that policy advocacy should target least cost solutions including carbon pricing, market mechanisms, and technology-neutral policy frameworks. Technology neutral approaches to energy policy are misaligned with IPCC recommendations on the transition of the energy mix; this narrative is often used to oppose policy that promotes solely alternatives to fossil fuels. Instead, it promotes consumer choice, market solutions, and minimal government intervention. Additionally, supporting market-based mechanisms over policy-based mechanisms to address climate change reduces the climate ambition of climate-based initiatives.
As a result, the company has not assessed its associations’ climate policy engagement activities against science-based benchmarks for delivering the 1.5°C goal of the Paris Agreement.
Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.
The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.
Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?
BHP has disclosed a clear and detailed framework for addressing potential misalignments, including escalation strategies and timelines. The company’s website states that its preference is to engage with the relevant association and seek a change in its advocacy.
However, if BHP is unable to convince an association to change its advocacy it lists several steps it may take including: publicizing the material misalignment, imposing conditions on its membership such as requesting that the associations’ advocacy does not represent the views of BHP, and/or suspending or terminating its membership.
BHP provides more detail on this framework in its ‘Principles for participating in industry associations’ document (May 2023), including different escalation strategies depending on the level of benefit given by the industry association, and the materiality of the misalignment. In particular, BHP states that if it does derive sufficient benefit from the association and the identified misalignment is material, it will reassess its membership and make a decision on its ongoing membership within a reasonable period (being no longer than 12 months).
Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.
Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?
BHP has not undertaken a review of the alignment of its own climate policy engagement activities. As such, the company has not identified any cases of potentially misaligned advocacy between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
For example, in a December 2023 consultation submission to Australia’s Carbon Leakage Review, BHP appeared to caution against the introduction of an EU-style carbon border adjustment mechanism in Australia, emphasizing potential risks to Australia’s export competitiveness.
At time of this assessment, BHP's Organization Score metric was 66%, indicating partial misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see BHP’s profile in the LobbyMap databased for additional details on the company's real-world climate policy engagement activities.
Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.
Sasol published a detailed review of its direct climate policy engagement in August 2023. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. The company has not updated its review in 2024.
As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
BHP has not undertaken a review of the alignment of its own climate policy engagement activities. As such, the company has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.
Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.
As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.
Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
BHP assessed 15 industry associations in its 2023 review, which were selected based on level of membership fees and/or whether they were covered by InfluenceMap’s database.
Of these 15 industry associations, BHP found alignment with 10 associations and some non-material misalignment with 5 associations: Canadian Chamber of Commerce (CCC), Minerals Council of Australia, NSW Minerals Council, Queensland Resources Council, US Chamber of Commerce. BHP did not find any cases of material misalignment. See ‘Alignment Assessment Method’ above for more detail on BHP’s assessment criteria.
In its 2023 review update, published in September 2024, the company provided an update on the 5 associations it found non-material misalignments with. The company ceased its membership to the CCC and US Chamber, and does not appear to have upgraded the assessment status of the 3 other associations.
InfluenceMap analysis indicates that the company has at least 5 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database), including the Minerals Council of Australia, Mining Association of Canada, New South Wales Minerals Council, and Queensland Resources Council, and the South Australia Chamber of Mines and Energy. It is also a member of at least 4 industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).
Although BHP finds evidence of some non-material alignment with the above 5 associations, it did not identify misalignment with associations like the Mining Association of Canada, and its 4 partially aligned associations. As a result, it has not identified all key cases of misalignment and partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database.
See Appendix A for further details on the company’s industry associations.
Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.
Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?
In its 2023 review update, published in September 2024, BHP states that it reviewed the five non-material misalignments it identified in its 2023 industry association review. BHP notes that it ceased membership to the Candian Chamber of Commerce and US Chamber of Commerce, though it does not specify that this was due to misalignments on climate policy. BHP has retained membership to the New South Wales Minerals Council, Minerals Council of Australia and Queensland Resources Council, stating that all associations have made progress in addressing the non-material misalignments identified in the company’s 2023 review.
On its corporate website, BHP provides additional examples of action to address misalignments at the US Chamber of Commerce (2017), Mining Association of Canada (2019), and the Minerals Council of Australia (2021). BHP has previously terminated its membership to the World Coal Association in 2018, and suspended its membership to the Queensland Resources Council in 2020 following its ‘Vote Greens Last’ advertising campaign.
However, BHP does not appear to have shown evidence of action to address all specific cases of misalignment and partial misalignment with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.
Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.
Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.
Yes, meets criteria
Partial, meets some criteria
No, does not meet criteria
The table below provides a ranking of BHP's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.
Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:
The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.
As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.
| Industry Association | InfluenceMap Performance Band | InfluenceMap Assessment |
|---|---|---|
| Carbon Market Institute | B+ | Aligned |
| Confederation of Indian Industry (CII) | B- | Partially Aligned |
| Brazilian Institute of Mining (IBRAM) | C | Partially Aligned |
| Business Council of Australia | C- | Partially Aligned |
| Chamber of Minerals and Energy of Western Australia (CME) | C- | Partially Aligned |
| Energy Users Association of Australia (EUAA) | D+ | Partially Aligned |
| Queensland Resources Council (QRC) | D+ | Partially Aligned |
| Mining Association of Canada (MAC) | D+ | Partially Aligned |
| Business Council of Canada | D+ | Partially Aligned |
| Minerals Council of Australia (MCA) | D | Misaligned |
| South Australian Chamber of Mines and Energy (SACOME) | D | Misaligned |
| NSW Minerals Council | E | Misaligned |
