This scorecard provides a detailed breakdown of InfluenceMap's assessment of Santos'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 Santos, 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 Santos's company profile - is accessible via the buttons on the right hand side of the page.
A summary of Santos'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 | No, does not meet criteria |
| Sub-Indicator | Score |
|---|---|
| Accuracy of Direct Climate Policy Engagement Disclosure | No, does not meet criteria |
| Accuracy of Indirect Climate Policy Engagement Disclosure | No, does not meet criteria |
A summary of Santos'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 |
|---|---|
| December 2022 | 5/14 (36%) |
| February 2024 | 5/14 (36%) |
| April 2025 | 5/14 (36%) |
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 Santos'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)?
Santos' disclosure of its positions and engagement activities on climate policies is limited to 3 policies, without stating its positions or engagement activities. Despite disclosing broad engagement with key legislation including Australia's Future Made in Australia Bill and Sustainable Finance Taxonomy in its 2024 Annual Report, published February 2025, Santos does not appear to disclose its specific engagement activities or position on the policies.
It has also excluded its engagement with 2 climate-related policies in Australia from 2023 which it had also not included in its previous disclosure: the Future Gas Strategy and the Senate Standing Committees on Environment and Communications' Inquiry into the Middle Arm Sustainable Development Precinct.
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)?
Santos has disclosed a list of its industry association memberships, but it excludes its membership to Australian Institute of Petroleum and the International Emissions Trading Association. Santos does not include details of each association's specific climate-policy engagement.
Therefore, Santos does not appear to have disclosed an account of its industry associations' positions and engagement activities. For example, Santos did not disclose on the Australian Energy Producers engagement on the Future Made in Australia in June 2024, the Australian Pipelines and Gas Association's comments on the Climate Change Authority's 2024 Issues paper in May 2024 or the Business Council of Australia's comments on APH's Inquiry into nuclear power generation in Australia in November 2024.
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 Santos'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 Santos'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?
Santos has published annual reviews of its climate policy engagement from 2020 to 2025. While Santos did not publish a review in 2023, its March 2024 review covered the 2023 calendar year. Similarly, its April 2025 review covers the 2024 calendar year.
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?
Santos appears to have assessed the alignment of its association’s top-line positions on climate change policy, rather than an analysis of its associations’ detailed climate policy engagement activities against science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement.
Santos has disclosed a methodology for assessing alignment with its industry associations against the company's own climate policy positions, which includes: recognition of the scientific consensus of climate change, support for Paris Agreement temperature goals, and support for Net Zero emissions by 2050 or earlier. The company states the evidence it assesses includes the association’s publicly available documentation on their climate positions, its climate policy, and its position on Net Zero. Where such policies do not exist, public submissions and statements in addition to recent internal developments are sought to seek evidence of respective positions.
The company states that industry associations are determined to either ‘align’, ‘not align’ or be ‘neutral’ following assessment of the associations’ publicly available documentation on their climate positions, their climate policy, and their position on Net Zero. Santos has also provided evidence behind the assessment of each industry association.
Santos states that it assesses ’support for Paris Agreement temperature goals’ but this appears limited to an assessment of top-line statements. The company does not appear to assess the alignment of each of its association's detailed advocacy activities against science-aligned policy pathways to deliver 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?
Santos has disclosed a framework for addressing potential cases of misalignment with its industry associations, including some escalation strategies. The company states it will be ‘guided by the nature of the misalignment and the benefits of membership’ and may take the following actions: remain a member and seek to influence change constructively and positively in areas where there are different views; and/or in the case of significant misalignment that cannot be reconciled, Santos may review its level of participation or end the membership.
However, there are no deadlines attached to this framework for industry associations that do not reform misaligned climate policy engagement practices.
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)?
Santos 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 misalignment 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 2024 and 2025 Santos’ CEO has repeatedly advocated for new exploration and production, infrastructure, investments or other systems that will risk locking in unabated fossil gas, misaligned with IPCC pathways for limiting warming to 1.5°C. Examples can be seen in the CEO’s AGM address in April 2025, an article in The Australian in March 2025, and an Australian Financial Review article in March 2024.
At the time of this assessment, Santos’ InfluenceMap Organization Score was 45%, indicating misalignment between its detailed climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. Santos also has an engagement intensity of 17% which indicates active, obstructive climate policy engagement. Please see the Santos’ profile in the LobbyMap database 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?
Santos 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?
Santos has assessed 11 industry associations and did not identify any cases of misalignment. The company identified 8 cases of ‘alignment’ including associations such as Australian Energy Producers (formerly APPEA) and International Gas Union (IGU). Santos also found 3 associations to be ‘neutral’ including Alaska Oil and Gas Association (AOGA), Resource Development Council of Alaska (RDC), and the Australian Resources and Energy Employer Association which are not yet covered by the InfluenceMap database.
Santos did not include key industry associations actively engaged on climate policy within the scope of the review, including Australian Institute of Petroleum and the International Emissions Trading Association (IETA).
InfluenceMap analysis indicates that the company has at least 4 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). These include Australian Energy Producers, Australian Institute of Petroleum, and Australian Industry Greenhouse Network. Santos also has at least 4 memberships to industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+). These include the Business Council of Australia, Australian Pipelines and Gas Association, International Gas Union, and IETA.
As Santos did not identify any cases of misalignment or partial misalignment, it has not identified the above 8 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 below for further details on the company’s industry association memberships.
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?
Santos has included some evidence of action to address cases of misalignment with its industry associations. Santos states that it discontinued its membership of the Chamber of Minerals and Energy of Western Australia but did not provide further details. The company also stated that it has engaged with associations deemed to be ‘neutral’ to promote the development of climate-related policy positions that support the goals of the Paris Agreement and align with Santos’ climate policy and energy positions. This engagement included advancing Santos’ climate policies through working groups.
For example, the company states that it proactively engaged with Alaskan Oil and Gas Association and the Resource Development Council of Alaska seeking to influence their public position on climate and their associated advocacy. Santos also stated that following proactive engagement, the PNG Chamber of Resources and Energy was assessed as aligned in the 2025 review after being considered neutral in the company's 2024 review.
However, Santos does not appear to have shown evidence of action to address other key 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 Santos'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 |
|---|---|---|
| International Emissions Trading Association (IETA) | C | Partially Aligned |
| Business Council of Australia | C- | Partially Aligned |
| International Gas Union | C- | Partially Aligned |
| Australian Pipelines and Gas Association | D+ | Partially Aligned |
| Australian Industry Greenhouse Network | D | Misaligned |
| Australian Institute of Petroleum | D | Misaligned |
| South Australian Chamber of Mines and Energy (SACOME) | D | Misaligned |
| Asia Natural Gas and Energy Association (ANGEA) | E+ | Misaligned |
| Australian Energy Producers (Formerly APPEA) | E+ | Misaligned |
