South32 Disclosure Scorecard

Detailed assessment of South32's climate policy engagement disclosure

Date of Assessment - November 2024

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of South32'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 South32, 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:

  • Accuracy of Climate Policy Engagement Disclosures: An assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
  • Robustness of Corporate Climate Policy Engagement Review & Misalignment Management Processes: An assessment of the quality and robustness of a company's process to identify, report on, and address specific cases of misalignment between its climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

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 South32's company profile - is accessible via the buttons on the right hand side of the page.

Accuracy of Climate Policy Engagement Disclosure: Summary

A summary of South32'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.

IndicatorScore
Accuracy of Climate Policy Engagement DisclosurePartial, meets some criteria
Sub-IndicatorScore
Accuracy of Direct Climate Policy Engagement DisclosureYes, meets criteria
Accuracy of Indirect Climate Policy Engagement DisclosureNo, does not meet criteria

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Summary

A summary of South32'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 ReviewScore
September 20223/14 (21%)
September 20234/14 (29%)
August 20245/14 (36%)

Accuracy of Climate Policy Engagement Disclosure: Scorecard

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 South32'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)?

South32

South32 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.

The company disclosed its government consultation responses to specific climate-related policies in its 2023 and 2024 Sustainable Development Reports, including the Australian Government's Safeguard Mechanism reforms and Western Australia's Domestic Gas Policy. South32 does not appear to have excluded any material evidence of climate policy engagement

Best Practice

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)?

South32

South32 has disclosed a complete list of its industry association memberships. However, the company's disclosure on its industry associations is limited to top-line climate statements without reference to specific climate policies. South32 has therefore excluded key instances of 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 Environment Protection and Biodiversity Conservation Act in July 2024 comments to a Senate Inquiry into the Nature Positive Bill 2024.

See Appendix A below for details of the company's industry association memberships.

Best Practice

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.

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Scorecard - 5/14 (36%)

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 South32's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.

Review ProcessReview Assessment (Direct)Review Assessment (Indirect)
Monitor & ReviewIdentify & AssessIdentify & Assess
Alignment Assessment MethodActAct
Framework for Misalignment

The tables below provide: (1) a breakdown of South32's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.

Review Process

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?

South32

South32 has published a review on an annual basis since 2019.

Best Practice

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?

South32

South32 has disclosed a clear explanation of its assessment methodology, stating that it assesses the climate policy engagement activities of its industry associations against its own climate change positions as listed in its Sustainable Development Report 2024. These positions include support for the Paris Agreement; principle-based carbon price mechanisms; public advocacy that is aligned to the Paris Agreement; and technology-neutral energy policy that balances energy reliability and emissions reductions. South32 also states that it does not support advocacy from industry associations on energy coal expansion or subsidies, and on fossil gas expansion or subsidies where a transitional role for fossil gas in the energy transition is not recognized.

South32 has assessed the alignment of its industry associations against the company’s own climate policy positions, including top-line statements and more detailed positions on the energy mix. Although these positions include support for advocacy that is aligned to the objectives of the Paris Agreement, it is not clear if/how South32 has defined the alignment of its associations' detailed climate policy engagement activities against science-aligned benchmarks for delivering the 1.5°C goal of the Paris Agreement.

In addition, South32 does not clearly disclose what constitutes a finding of alignment and misalignment against these criteria. Despite this, the company did include explanations behind the assessment of each industry association.

Best Practice

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?

South32

South32 has disclosed a clear framework for addressing misalignment, including an escalation strategy. The company has stated that it will inform the association's leadership of the misalignment, explore opportunities for alignment, advocate an alternative view, and terminate membership if the misalignment is material and outweighs benefits of membership.

However, the company has not provided any deadlines for industry associations which do not amend misaligned practices.

Best Practice

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.

Review Assessment (Direct - Company)

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)?

South32

Although South32 states that it is committed to conducting advocacy that is aligned with the objectives of the Paris Agreement, it does not appear to have 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 an August 2023 consultation submission to the Inquiry into Western Australia’s (WA) Domestic Gas Policy, South32 appeared to promote the need for additional fossil gas supply to the WA domestic gas market. While the company supported the eventual displacement of fossil gas with renewables, it did not appear to emphasize the need for a continued role of fossil gas to be accompanied with clear conditions on the need for CCS or methane emission abatement, and did not specify clear timelines for this transition that are in line with IPCC guidance.

At the time of this assessment, South32’s Organization Score metric was 54%, indicating partial misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see South32's profilein the LobbyMap database for additional details on the company's real-world climate policy engagement activities.

Best Practice

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?

South32

South32 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.

Best Practice

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.

Review Assessment (Indirect - Industry Associations)

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?

South32

South32 has assessed 13 industry associations in its review. It did not include key industry associations actively engaged on climate policy within the scope of the review, for example, the Carbon Market Institute.

The company finds 9 industry associations to be aligned, 2 to be partially aligned (NSW Minerals Council, Queensland Resources Council) and 2 to be misaligned (Asociación Colombiana de Minería, National Mining Association).

InfluenceMap analysis indicates that the company has at least 3 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, National Mining Association (NMA) and Queensland Resources Council (QRC). It is also a member of 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+), including the Minerals Council South Africa, Australian Aluminium Council, Business Council of Australia and Chamber of Minerals and Energy of Western Australia.

Although South32 identified partial misalignment with QRC and misalignment with NMA it did not identify misalignment with Minerals Council of Australia, 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.

Best Practice

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?

South32

South32 has shown some evidence of action to address cases of misalignment with its industry associations. In its 2024 review, South32 stated that it ceased to be a member of the NSW Minerals Council following the August 2024 sale of its Illawarra Metallurgical Coal assets, having previously noted that the association’s advocacy on energy coal required ongoing monitoring and discussion. However, the termination of this membership appears to be based on purely operational changes. South32 likewise indicated that it is engaging with the National Mining Association, Asociación Colombiana de Minería and the Queensland Resources Council over inconsistencies with its climate change positions, as per the process outlined in the company’s Approach to Industry Associations, but did not provide any specific details on these engagements.

As a result, the company 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.

Best Practice

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.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: South32's Industry Association Memberships

The table below provides a ranking of South32'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:

  • Aligned = Performance Band A+ to B
  • Partially Misaligned = Performance Band B- to D+
  • Misaligned = Performance Band D to F
  • Low Engagement = Performance Band N/A

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.