BHP GROUP | Climate accounting and audit at BHP GROUP

Status
18.67% votes in favour
AGM date
Previous AGM date
Proposal number
15
Resolution details
Company ticker
BHP
Lead filer
Resolution ask
Conduct due diligence, audit or risk/impact assessment
ESG theme
  • Environment
ESG sub-theme
  • Net Zero / Paris aligned
Type of vote
Shareholder proposal
Filer type
Shareholder
Company sector
Materials
Company HQ country
Australia
Resolved clause
Shareholders request that BHP include information in its audited financial statements which conflicts with the accounting standards applicable to BHP.

By adhering to the ask of this resolution, our company is expected to include the following in the notes to its financial statements: – Scenarios and assumptions: Explain which scenarios have been used and the quantitative assumptions they include. Explain and justify any deviations from commonly used scenarios, such as the IEA or the Network for Greening the Financial System Net Zero by 2050 scenarios. This includes detail on 1.5°C overshoot and key variances in commodity price assumptions. – Results: Disclose how the transition and physical risks affect asset valuation and impairments, provisions and credit losses in the different climate scenarios. Provide results by commodity. It is also expected that the audit report demonstrates the auditor has assessed the impacts of climate-related matters, ensured the veracity of the scenario(s) selected and identified inconsistencies between the financial statements and other information, such as climate change disclosures.
Whereas clause
Our company ‘believe[s] the world must pursue the aims of the Paris Agreement’ and it aims to ensure its ‘capital expenditure plans are not misaligned with the Paris Agreement’s aim to pursue efforts to limit global warming to 1.5°C’.23 Despite this, and against investor expectations, our company does not adequately consider climate change in its audited financial statements. In the 2022 CA100+ Net Zero Company Benchmark, our company’s 2021 financial statements and audit report were reviewed for the provisional Climate Accounting and Audit assessment.24 Our company met one of the seven assessment criteria. The audit report25 in our company’s 2022 financial statements discloses qualitative information regarding climate change, which may meet one further criteria, leaving five criteria unmet. This exclusion of climate risks from our company’s financial reporting and audit “reduces an investor’s ability to make investment, engagement and voting decisions”
Supporting statement
[Our company’s value is sensitive to climate change]
Our company states it “is exposed to a range of transition risks that could affect the execution of our strategy or our operational efficiency, asset values and growth options, resulting in a material adverse impact on our financial performance, share price or reputation, including litigation. The complex and pervasive nature of climate change means transition risks are interconnected with and may amplify our other risk factors”.27 Changing weather patterns and more extreme weather events, driven by climate change, also directly confront our company’s business operations.

[Consistent with investor expectations]
In 2020, investor groups representing over US$103 trillion AUM globally issued a letter seeking that companies reflect climate-related risks in financial reporting.30 Subsequently, the Institutional Investors Group on Climate Change (IIGCC) outlined its ‘unequivocal’ expectation that companies and auditors will deliver ‘Paris-aligned accounts’, defined as “accounts that properly reflect the impact of getting to net zero emissions by 2050 for assets, liabilities, profit and losses”.31 IIGCC expects directors to: affirm that the Paris Agreement goals were considered in preparing the accounts; explain, in the Notes, how critical accounting judgements are consistent with NZE by 2050 (or if these assumptions are not used, why not); present results of sensitivity analysis around Paris-aligned assumptions; state any implications for dividend paying capacity of Paris-alignment. IIGCC also expects companies to account for any inconsistency between its narrative reporting on climate risks and the assumptions made in accounting. CA100+’s Net Zero Benchmark assesses whether company accounting disclosures and practices adequately reflect climate change risk, and the global movement towards NZE GHG emissions by 2050 or sooner. The CA100+ initiative – representing more than 700 global investors managing AUM $68 trillion – expects that ‘net zero aligned’ companies and auditors will provide investors with oversight of how accelerating decarbonisation, in line with the 2050 trajectory, will affect a company’s financial position and profitability.32 Some investors are already expressing their expectations around reflection of climate in company financial statements and audits in their voting decisions.

[Consistent with accounting standards]
Existing Australian and global accounting standards set an expectation that climate-related risks are integrated into financial statements. The Australian Accounting Standards Board (AASB) Practice Statement 2, Making Materiality Judgements, is clear that ‘information is material if omitting it or misstating it could influence decisions that users make on the basis of financial information about a specific reporting entity’.34 Therefore, and as the AASB/AUASB noted in 2019, investor statements on the importance of climate-related risks to their decision-making will often render these risks ‘material’ to a company, requiring them to be reflected in financial statements.35 Our company considers climate change to be ‘a material governance issue and a strategic issue’.36 In 2020, the International Financial Reporting Standards (IFRS) board issued an implementation document explaining how elements of 12 separate IFRS standards may introduce requirements to make climate disclosures in financial statements.37 Finally, if Australia develops sustainability-related reporting requirements that are aligned with the ISSB [Draft] IFRS S2 Climate-related Disclosure standard,38 the AASB has stated these will ‘supplement and complement’ information provided in financial statements.39 Consequently this shareholder resolution is a complementary extension of the anticipated sustainability standards. ACCR urges shareholders to vote for this proposal.

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