4. Investment in Australia's export industries


Investors take into account a range of factors when making investment decisions. An emerging theme in international investment markets is an increasing focus on climate-related financial risks. This can be seen through growing attention from global fund managers, governments, financial institutions and superannuation funds on the need to incorporate climate-related risks into decision making. In addition, investors are also calling for climate change-related disclosures, to inform their decision making on investments.
The responsibilities of directors, trustees and fund managers in identifying and managing climate related financial risks is a related concern, particularly regarding legal liabilities if climate risks are not appropriately identified and managed.
These issues may impact on future investment in Australia’s export industries, particularly as many countries look towards reaching a net zero emissions target by 2050. At the same time, demand for (and investment in) Australia’s resource exports may remain strong throughout this transition, particularly in developing regions such as South East Asia.
This chapter discusses the issues investors take into consideration, and the impact of climate-related risk factors on those choices. Superannuation funds, a significant proportion of the investment pool in Australia, have specific requirements and additional issues to consider, and this chapter explores those, before reflecting on the impacts of changing investment trends on Australia’s export industries.

An international focus on climate-related investment risks

Australia’s economy was described as being ‘heavily connected to and reliant on international capital markets.’1 As such, global investment trends, regulatory changes and policy developments can impact on investment in Australia, including Australia’s export industries.
One such global shift put forward by inquiry participants was consideration of climate-related risks by governments, global investors, and international financial institutions. This was explained by Institutional Shareholder Services Environmental, Social and Governance (ISS ESG), which pointed to ‘strong momentum globally for responsible investment indictors such as climate change to be considered as material financial risks that must be managed by investors.’2
Specifically, ISS ESG listed three global trends regarding climate change that were impacting investment. Firstly, ISS ESG noted an increased focus on climate action by countries and regions including China, the United States (US) and the European Union (EU). Secondly, a ‘large push towards transparency by a number of international actors’ regarding climate change, including in EU legislation, and activities by the Financial Stability Board (FSB) and the International Organisation of Security Commissions on disclosure of climate related risk. Finally, it highlighted a ‘broad push by financial actors to act on climate change’, which included asset managers, asset owners, insurers and banks.3
Chartered Accountants Australia and New Zealand (CAANZ) similarly pointed to international developments regarding climate-related financial risks:
Governments and international governance bodies in the US, the United Kingdom (UK), Europe and New Zealand are all making significant commitments towards managing climate related risk and achieving net zero carbon emissions under more-ambitious time frames. …. Earlier this month, the chair of the FSB provided a road map for addressing climate related financial risks for endorsement by the G20, of which Australia is a member. These international developments demonstrate the degree to which climate related risks have become a central concern in regulatory oversight and how robust systems of disclosure are essential both to market signalling and to help to transition economies on the path to decarbonisation.4
Ethical Partners Funds Management (Ethical Partners) further emphasised that Australia’s economy ‘does not operate in isolation’, and that decisions about climate and other ESG issues are being made by ‘global reinsurers, export partners and corporates’ value chains’, which impact on Australian companies and their shareholders.5
The Investor Group on Climate Change (IGCC) also highlighted the influence of global financial institutions:
… over the last decade, global financial institutions, central banks and national financial regulators have been increasingly warning of the financial risks of climate change. They are now requiring a proactive response from financial institutions and companies to manage climate-related financial risks to ensure financial stability. … These regulator signals on climate risk cannot be ignored by any entity, including investors.6
The IGCC further outlined that some of the world’s largest investors were paying increased attention to climate change risks:
BlackRock, the world’s largest asset manager, has made many public statements on the risks and opportunities involved with climate change, including highlighting the financial impact of climate-related write-downs in the energy sector and the regulator focus on climate risk in the global financial system. Other globally significant investors such as State Street Global Advisers and JP Morgan Asset Management have described climate change as a clear risk to their investment portfolios.7

Investor advisory services

The issue of decisions being influenced by activist shareholders was considered in the previous chapter. A related issue is that of investors acting together on advice received from proxy firms and other organisations. The ACCC explained how competition issues could arise when large proxy groups have controlling interests across a number of different companies:
competition issues can arise where either common ownership or proxy advisors might start to have controlling impacts across different firms, and that's the focus that we've had before as to whether there might be a lessening of competition from that element.8
For instance, Mr Ron Boswell AO noted that:
I've sought very senior advice on this. I'm advised that, under the concerted practices provisions, you don't have to meet—you don't have to all turn up at the golf club and meet—but, if everyone arrives at the same decision at the same time, it is an offence under section 45 [of the Competition and Consumer Act 2010].9
On the question of coordinated movements from investor advisory groups, the Australian Competition and Consumer Commission noted:
We'd really be looking for specific instances where that commonality is causing competition issues for us to deal with. The fact that there might be a coordination of advocacy effort I don't think in itself would raise issues that we're able to deal with under the Competition and Consumer Act.10
The Australian Council of Superannuation Investors argued that, since there are no arrangements between their members affecting competition or restricting dealings , section 45 of the Competition and Consumer Act does not apply to their work.11

Climate-related risk disclosure

CAANZ stated that demand from international and domestic investors for climate change-related disclosures had been increasing. CAANZ continued:
It's part of a global trend we are seeing which is calling for more information to enable investors to better understand the climate risk associated with the organisations, and, likewise for the organisations, through presenting this information, better understand the associated risks for their business and, therefore, how they will manage and address them internally.12
The Department of the Treasury (Treasury) advised that climate change disclosure was a focus for regulators internationally, and that the steps Australian regulators had taken in this regard was in line with this trend. In particular, regulators (including in Australia) were looking towards the Task Force on Climate-related Financial Disclosures (TCFD) guidelines. Treasury continued:
The focus … on global trends in the regulatory space is that the regulators are a number addressing a number of issues. One is to improve the disclosure around climate change risks in the corporate sector to improve the quality, consistency and breadth of climate change disclosure. Broadly, the regulators are doing that in line with the TCFD guidelines that were released in 2017. Those guidelines are being used by the corporate sector in Australia, and the Australian Securities and Investments Commission (ASIC) has been working with the corporate sector to encourage them to make sure that their climate disclosures are pretty much in line with the TCFD recommendations.13
Treasury continued that the take-up of the TCFD’s recommendations, particularly among the large companies in Australia had been ‘pretty good’ and was ‘comparable to what's going on overseas.’14
Principles of Responsible Investment (PRI) similarly pointed to guidance from ASIC for Australia’s listed companies regarding climate risk disclosure, in line with the voluntary framework developed by the TCFD. However, the PRI highlighted that this reporting is not mandatory, which may create a ‘gap’ in the regulatory environment which could act ‘as a disincentive for investment’. To address this, the PRI recommended:
… that climate risk related regulation and rules should be introduced on a mandatory, rather than ‘recommendation’ basis. Disclosure obligations of Australian companies should be aligned with the disclosure requirements contained in the TCFD framework.15
The IGCC and Market forces similarly recommended that the Australian Government make climate risk disclosure mandatory.16 The IGCC considered that this would:
… reduce regulatory burden by providing clarity for investors and companies, and [create] better consistency and alignment with global financial markets and regulatory frameworks.17
The IGCC listed a number of jurisdictions that had ‘signalled their intention to implement or are currently legislating mandatory climate risk disclosure regimes.’ This included the US, the UK, New Zealand and Hong Kong.18
The Centre for Policy Development (CPD) likewise stated that mandatory disclosures would support greater consistency in terms of disclosing and responding to climate-related financial risks.19 The CPD added that ‘several of the Australian regulators have stressed in their public commentary that it’s only a matter of time before that sort of disclosure becomes mandatory here as well.’20
ASIC advised that legislative change would be required to mandate climate-related disclosures, and as such it was a decision for the Australian Government.21

Superannuation investment decisions

Australia’s superannuation system is comprised of $3 trillion worth of assets.22 Industry Super Australia (ISA) advised that this system ‘plays an important role in funding and stabilising the broader Australian economy’, and is based on trustees having the ‘discretion to build diverse portfolios that are in the financial interests of members’.23
The Australian Council of Superannuation Investors (ACSI) advised that ‘superannuation funds have an obligation to act in the best financial interests of their beneficiaries’. Part of this obligation was described by ACSI as having an understanding of ‘global and local policy signals and [taking] measured action to manage risk and realise opportunity.’24
ACSI outlined how its members make investment decisions, which included consideration of climate change as a financial risk:
The investment decisions of institutional investors, such as whether or not to invest in Australia’s export industries, are based on an assessment of long-term financial risk and likely returns. Climate change represents one of the biggest financial risks across the market and one of the biggest drivers in how business will evolve into the future.25

Regulatory requirements

The Association of Superannuation Funds of Australia (ASFA) stated that the obligation on superannuation funds to act in the best interests of their members was prescribed in the legislative and regulatory framework established by government. ASFA also pointed to recent legislative requirements relating to delivering outcomes and generating returns:
More recently the government has implemented legislation requiring funds to stipulate how they deliver member outcomes on a broad range of issues, including risk adjusted investment returns. Funds who fail to deliver are subject to additional scrutiny from the regulator and must develop action plans to remediate investment performance or consider alternative courses of action, such as mergers.26
The Maritime Union of Australia outlined how the Australian Prudential Regulation Authority (APRA)’s regulatory oversight pertains to the superannuation industry, including on climate change financial risks:
APRA’s mandate is to ensure that, under all reasonable circumstances, financial promises made by APRA-regulated institutions such as superannuation funds are met within a stable, efficient and competitive financial system. APRA is seeking to ensure that APRA-regulated institutions are managing the risks and opportunities that may arise from a changing climate, in line with APRA’s approach to other types of risks.27
ACSI emphasised the requirements on superannuation trustees to manage climate risk in their investment decisions:
… institutional investors and superannuation trustees will not satisfy their fiduciary duty (under ss 52(2)(b) and (c) of the Superannuation Industry Supervision Act 1993 (Cth)) if they fail to adequately understand and manage climate risk in their investment decisions. 28

Legal considerations

In addition to legal and regulatory guidance for superannuation funds to manage climate change risks, legal developments were also highlighted. Market Forces quoted a legal opinion from Noel Hutley SC and James Mack from 2017, which was updated in 2021, which:
… confirms that superannuation trustees have similar obligations to ‘act prudently and in the best financial interests of a beneficiary’. Relevantly, ‘in order to comply with obligations under the superannuation law, a superannuation trustee needs to ensure its processes, structures and expertise are responsive to the financial risk posed by climate change.’29
ACSI also pointed to this legal opinion and stated that it:
… makes clear that it is insufficient for superannuation trustees to simply identify and disclose on climate risks - they must also plan and take action in response to the relevant risks.30
Lime Financial Planning (LFP) pointed to a legal case involving REST Superannuation, who ‘chose to settle out of court when challenged with the idea they had not adequately considered the risks of climate change on the portfolio of a 25-year-old and their investment horizon.’ Since this settlement, LFP advised that REST Superannuation had:
… substantially changed their portfolio structure and announced a net zero target by 2050 within their portfolio … [REST Superannuation] did not act out of fear of reputation damage, but because they knew inaction would constitute a breach of the Superannuation Industry Supervision Act 1993. Since this action a number of super funds are making similar changes, citing the same rationale.31
PRI stated that this case highlighted ‘the risk of litigation and damages for failing to meet the necessary standard of care in failing to adequately identify and manage climate related risks’.32

Divestment from the coal industry

The Department of Industry, Science, Energy and Resources (DISER) relayed anecdotal reports from industry outlining that ‘some pension, superannuation and equity funds – here and overseas – are divesting from coal.’33 Market Forces similarly advised that ’10 of the largest 40 super funds have confirmed they have divested from thermal coal mining companies’.34
ISA outlined that it ‘it is in the interests of shareholders, lenders and regulators’ to identify, disclose and act upon risks generated by climate change. As a result, ISA stated that:
… many superannuation funds are taking steps to protect the long-term value of their portfolios partly by adjusting or exiting their exposure to companies whose impacts on the climate are judged to present risks that are harmful to the interests of members.35
New Hope Group outlined its experience with divestment:
Superannuation funds have also made a big deal out of divesting their shares in coal companies, largely to pacify the vocal minority of activists. In New Hope Group’s case, we have seen superannuation funds and major investment firms take a small position in the company only to sell the shares in a very public announcement to create the perception of being a responsible investor.36
In contrast, ASFA advised that there was ‘significant ongoing investment by superannuation funds in the resource and energy sector.’ At the same time, ASFA stated that superannuation investment had a long-term focus which impacted its investment decisions:
In terms of how trustees implement their ESG strategies, given superannuation is a long-term investment—effectively you are investing on behalf of members who hold that investment for 40 or 50 years before retirement—they are looking at the long-term growth and return profile of the asset, the risks around that and whether they are going to generate the required performance on that asset to provide the returns that they're seeking for their members.37
ACSI stated that its focus was ‘not about immediate divestment from particular industries’38 and that in fact ‘a lot of long term investors are keen to be working with companies to really support a long-term transition rather than divesting from companies.’39 The Responsible Investment Association Australasia (RIAA) similarly advised that ‘engagement, not divestment, is the preferred approach for most institutional investors including superannuation funds and fund managers.’40
ISA emphasised the importance of superannuation funds and institutional investors maintaining independence and discretion over investment decisions. In light of this, ISA recommended that the Committee:
… reaffirm that how superannuation funds invest the savings of millions of workers across regional and urban Australia should be a matter for trustees to decide in keeping with their existing fiduciary obligations.41

Responsibilities of directors, trustees and fund managers

The IGCC outlined that there is clear guidance for directors and trustees relating to climate risk:
In response to the growing understanding of how climate risks threaten the stability of the financial system, clear guidance about the duty of directors and trustees to respond has emerged from regulators in most major financial centres, including Australia.42
Market Forces agreed and added that:
The physical risks of climate change and the inevitable energy transition present major financial risks for Australian companies. Under Australian law, these risks must be considered, disclosed and managed. Failing to do so presents legal risks for trustees, directors and companies.43
The Australian Council of Trade Unions (ACTU) further outlined that regulatory guidance provided clear fiduciary duties on directors and trustees to consider climate change risks:
The guidance of financial regulators and legal opinions are increasingly clear about the fiduciary duty of directors and trustees to respond to climate risk and Australian regulators have made increasingly direct statements to this effect. These statements are consistent with guidance from equivalent bodies in other national economies, with many moving towards mandatory climate risk disclosure regimes and comprehensive emissions mitigation policy frameworks.44
ACSI similarly stated that ASIC and APRA had ‘reinforced the position that directors and trustees have a fiduciary duty to consider climate risks in their decisions’:
ASIC is increasing scrutiny, and expects companies to have appropriate governance structures in place to manage the risks, as well as providing the market with reliable and useful information on the company's exposure to material climate-related risks and opportunities. Likewise, APRA has recently published draft guidance which reiterates the financial risk caused by climate change, and the need for investors to establish robust risk identification, monitoring and management plans.45
The legal obligations on directors and trustees to consider climate-related financial risks was also evident in other jurisdictions. The Commonwealth Climate and Law Initiative (CCLI) highlighted Canada, Singapore, South Africa and the UK as examples of countries where ‘directors and trustees who fail to consider or appropriately manage climate-related financial risks are at risk of breaching their statutory and fiduciary duties and exposing themselves to liability.’46
The CCLI also outlined the risk of climate change litigation for companies:
Liability risks are those arising from the risk of climate litigation. In climate litigation cases, people and organisations seek compensation for losses they have suffered, or protection from losses they may suffer, against defendants that cause climate harms or fail to respond to climate risks … Businesses which are making significant contributions to global warming face liability risks, notwithstanding whether they are, and have a reputation as, 'legitimate and law-abiding' businesses.47
The Australian Banking Association emphasised that directors are obliged to consider both their legal liabilities and expectations of shareholders:
Directors are not just driven by fear of litigation—that is one of the things that have to be taken into account by any responsible director—but are primarily driven and motivated by 'what is the best thing for my business, what is the best thing for my customers and what is the best thing for my shareholders, because if I get those three things right, I'm going to be a board director of a very successful business'. Protecting your customers and your shareholders from unnecessary risks that are foreseeable and actionable is one of those responsibilities that, I think, board directors take very seriously.48

The Hutley opinion

As well as pointing to prudential guidance regarding the consideration of climate change as a financial risk, the ACTU pointed to a legal opinion known as the ‘Hutley opinion’:
A memorandum of opinion prepared by Noel Hutley, Senior Counsel and Sebastian Hartford-Davis (the “Hutley opinion”) was made public by the CPD and Future Business Council in 2016 and which was updated again in 2019. This opinion found a clear duty of care for Australian company directors in relation to climate change and that they should manage those risks with due diligence.49
The CPD advised that ‘the key conclusions of the 2016 Hutley opinion have been endorsed by Australia’s financial regulators and reflected in practical guidance by legal advisers, governance bodies, business groups and other standard setters.’50 Supporting this, CAANZ and CPA Australia stated that ‘ASIC has endorsed the conclusions reached in the Hutley Opinion.’51
In addition, the CPD advised that it had released a further supplementary opinion to the Hutley opinion in April 2021, which ‘emphasised that the benchmark for directors continues to rise, and highlighted particular risks around ‘greenwashing’ as scrutiny of corporate climate-related targets and commitments grows’.52

Impact of changing investment trends on Australia’s exports

The IGCC outlined that Australia’s economy was ‘highly emissions intensive’, which may be a disincentive to foreign investors looking for safe, long term investments:
… as an economy we are very heavily exposed to the transition away from fossil fuels .... Because we are highly emissions intensive, global capital is going to defer investment away from us anyway because they can get better returns at lower risk in other jurisdictions.53
Other climate-related factors that the IGCC considered may deter investors from investing in Australian industry included: Australia’s vulnerability to ‘the physical risks of climate change’ and the absence of a ‘long-term policy framework’ and ‘adequate climate risk disclosures.’ The IGCC added that emissions reduction targets also serve as a signal to investors ‘about the direction of the economy and also the preparedness of jurisdictions to address climate risk.’54
The CPD similarly stated:
The impacts of climate change and measures to reduce emissions rapidly will continue to have a profound impact on businesses and reshape global trade and investment, creating major risks and opportunities. … As an export oriented and emissions-intensive economy, Australia is highly exposed to these trends. A proactive and sophisticated response by firms, investors, regulators and policymakers should be unsurprising.55
Ethical Partners advised that it viewed some parts of the resources industry as more favourable than others in terms of investment, due to the changing global context:
Ethical Partners also currently has around $500 million invested in the resources industry, in areas such as steel, copper, iron ore, nickel and lithium, in companies that have tremendous opportunities in the energy transition that is taking place globally. For some companies in the resources space, such as fossil fuels, it has been difficult to justify long-term favourable valuations, in a world that is rapidly changing.56
Woodside Energy similarly acknowledged that while ‘some investors are adjusting their portfolios away from oil and gas’, it was not ‘experiencing any impediment to funding as it continues to demonstrate strong ESG credentials.’57
Ethical Partners also outlined how it approached its investment decisions in relation to ESG concerns, with divestment only an option as a ‘last resort’:
… working with companies to encourage them to manage these risks and find new opportunities is always our first preference. Voting is a well-respected shareholder tool that is only used when companies are not making the necessary changes to maintain their financial strengths through the energy transition we see globally. Divestment is our last resort, but we would much rather see the companies adapt, and to see an orderly and just transition to a low-carbon economy with continued employment opportunities and operational capacity.58

Consumer demand and investment performance

The RIAA stated that there was a growing awareness among investors and consumers of ESG issues, which is driving growth in ‘responsible investing.’59 The RIAA also highlighted its 2020 consumer research, which found that:
Nine in 10 Australians believe our finance sector has a role to play in generating positive social, environmental, and economic outcomes for the country highlighting the central role of responsible and ethical investing in helping the business and finance sectors better meet the needs of clients, customers, staff, and communities they are engaging with.60
The RIAA stated that ‘responsible investments provide better risk adjusted returns over the long-term’ when compared with ‘mainstream benchmarks.’61 ACSI stated that this was ‘supported by significant evidence, with a number of studies demonstrating that incorporation of ESG issues can lead to better outcomes from an investment perspective.’62
Market Forces also advised that research had ‘found that investment in renewable power generated higher total returns relative to fossil fuels in all assessed portfolios.’63 LFP agreed and further stated:
From an investment perspective, fossil fuels have not been and are not going to be a worthwhile investment venture for the growth, let alone preservation of capital. An investor who removed fossil fuels from their portfolio in 2011 would have had a significant increase in their 10 year returns. This is not the influential motives of activists, but investors are looking to worthwhile investments that will grow not degrade their wealth.64
ACSI similarly advised that ‘investor focus on ESG is a risk management tool and has the aim of improving investment returns.’65 The ACTU further cautioned that:
The impact of not adjusting to the shifting sentiment of the global economy, one that is moving quickly towards a zero-emissions environment, is to put Australian jobs and the retirement savings of all workers at risk.66

Risk of stranded assets

The CCLI stated that asset stranding was a transition risk facing Australia’s export industries. It defined stranded assets as ‘environmentally unsustainable assets which suffer from unanticipated or premature write-downs, devaluations, or conversion to liabilities.’67
The RIAA highlighted that investors and financial institutions were giving increased attention to resources companies in order to manage the risks associated with a transitioning economy, including stranded assets:
Institutional investors, insurers and banks are acting to manage the downside risk arising from the policies and actions of Australia’s export nations and the likelihood of holding stranded assets in investment portfolios; assets that run at a loss and/or need to be written as a bad debt/investment and ultimately negatively impacting member benefits.68
Ethical Choice Investments highlighted stranded assets as an increasing financial risk related to investment in the resources industry and highlighted a recent decision by AGL Energy:
As technology and demand shifts, legacy equipment, plant, and investments become less-profitable sooner than anticipated causing major assets to be devalued or written off causing major investor losses. In February of this year AGL Energy reduced the value of its assets, which includes Australia’s largest holding of coal power plants, by $2.7 billion – more than a third of the company’s total value.69
In contrast, Whitehaven Coal stated:
The restriction of funding for the coal industry is not a product of credit risk for the banks. These are profitable relationships. The notion of stranded assets is a fallacy here in Australia, where the average term of corporate debt is between four and five years.70
The Queensland Resources Council (QRC) argued against the idea of the coal and gas industries being stranded assets:
QRC wishes to highlight a fundamental issue with the narrative that Queensland’s coal or gas industries are ‘uninsurable’ or will soon become ‘stranded assets’. The reality is that the resources industry is not only providing many of the building blocks for low-emission technologies – the ‘new-economy’ minerals like aluminium, copper, cobalt, zinc, and lithium – but also the industry is proving to be adept as an early adopter of these new low-emission technologies like electric vehicles, hydrogen fuel cells and batteries.71

Future demand for Australia’s exports

DISER provided an overview of the expected future composition of Australia’s major export industries:
The future composition of Australia’s export industry is likely to be a combination of existing major industries and emerging ones. Opportunities in both are being explored to continue Australia’s economic prosperity in the export space. While our traditional export strengths in resources and energy will continue to be significant contributors, Australia will also seek opportunities in the manufacturing, science and technology sectors.72
DISER further outlined that there was a ‘positive outlook for Australia’s mineral exports through to 2025-26’:
Australia will continue to be a global supplier of resources required for energy and economic development … Resources and energy export earnings are expected to increase to $296 billion for 2020-21, before falling to around $288 billion for 2021-22 and then remaining steady until 2025-26.73
This was attributed to ‘the expectation of global economic recovery over the next few years coming out of the COVID-19 pandemic.’ DISER also expected the outlook to ‘be partly fuelled by government stimulus measures, and more robust supply chains across the world’s major economies.’74
The Reserve Bank of Australia (RBA) explained its forecasts in value terms for coal exports out to 2023, which were:
… broadly in the range of the last few years. For coking coal it's a little lower. For thermal it's broadly in the range. In volume terms, for thermal coal we're looking at a bit of a pick-up over the next couple of years. It's not a surge by any means, but we do have a pick-up in thermal coal export volumes reflected in our in our forecasts over the next couple of years.75
Treasury added that ‘DISER’S June 2021 forecasts expect world trade and Australian exports of thermal coal to be higher in 2023 compared with 2021.’76
To provide a long-term view of demand for Australia’s energy exports, DISER drew attention to some of the scenarios listed in the International Energy Agency’s World Energy Outlook (WEO)—notably the Sustainable Development Scenario (SDS) and the Stated Policies Scenario (STEPS).
Aligned with the Paris Agreement goals, the WEO’s SDS ‘maps out a way to meet sustainable energy goals in full, requiring rapid and widespread changes across all parts of the energy system.’77 Under this scenario:
... global gas demand falls by 12 per cent between 2019 and 2040 and global coal demand falls by 66 per cent in the same period. To a lesser degree, this trend for coal continues in the Asia-Pacific where coal demand reduces by 33 per cent between 2019 and 2030, then a reduction of 43 per cent to between 2030 and 2040. In the Scenario, demand for coal in India falls by 23 per cent from 2019 to 2030 and in China it falls by 32 per cent in the same period. The Scenario assumes that in Southeast Asia between 2019 and 2030, coal demand falls by 31 per cent and natural gas increases to 31 per cent. Between 2030 and 2040, gas continues to increase while coal demand falls further.78
Yancoal Australia stated that even under the SDS, ‘international demand for high calorific Australian thermal coal remains strong’, and is a ‘significant component of the energy mix and will continue to be so until 2040 (and beyond).’79
While DISER acknowledged that the ‘SDS sets out one possible pathway for the transformation of the energy sector,’80 it also pointed to the WEO’s STEPS. Global demand for energy depicted in this scenario ‘reflects the impact of existing policy frameworks and today’s announced policy intentions.’81 According to STEPS:
… global demand for natural gas increases out to 2040. While there are reductions in global demand for coal, increases in demand are seen in the Asia-Pacific until 2030, with demand remaining strong until 2040. Demand for coal from India increases 21 per cent while China falls 3 per cent to 2030. In Southeast Asia, coal demand increases 28 per cent to 2030 and natural gas increases by 47 per cent. Growth for these two commodities continues in Southeast Asia to 2040.82
In line with the energy demand projections of WEO’s STEPS, New Hope Group stated that ‘despite the reduced dependence of coal as a power source in Australia, thermal coal still continues to be in demand across South East Asia.’83 Whitehaven Coal further elaborated that:
… it is widely acknowledged that the future of coal will be closely linked to the development of the many emerging economies across Asia, where thermal and metallurgical (coking) coal remains essential to support growth… The Asia Pacific region is set to drive growth in coal demand, led by South East Asia, which is forecast to experience growth of nearly 30 per cent over the next decade.84
In contrast, the National Australia Bank (NAB) cautioned that demand from South-East Asia may not be enough to offset declines in demand for thermal coal from elsewhere:
While it was previously expected that growing demand in South-East Asia would offset some decline in demand from China, Japan and South Korea, policy changes flagged in Vietnam, Indonesia, the Philippines and Bangladesh suggest demand for thermal coal is declining.85
Mr John Cochrane stated that coal was going to continue to be used for the next two to three decades:
All the forecasts I've seen say that coal will continue and will continue to be the biggest source of increase in carbon emissions for the next 20 or 30 years. If Australia doesn't sell it, somebody else will. You're in a competitive world market.86
The Australian Petroleum Production and Exploration Association (APPEA) highlighted that under every scenario modelled by the International Energy Agency, ‘natural gas remains an important part of a cleaner energy future.’87 Woodside agreed and advised that demand for Liquefied Natural Gas (LNG) will continue to grow even under ‘Paris compliant scenarios.’88
Market Forces stated that the biggest driver of changes in demand for Australia’s resource exports was efforts by its major trading partners to reach net zero by 2050:
In the last two years, some of Australia’s most important trading partners set net-zero emissions targets including Japan (by 2050), South Korea (2050) and China (2060). In 2019/20, these three countries accounted for approximately 74 per cent of Australia’s thermal coal exports and 85 per cent of LNG exports by volume.89
The Australasian Centre for Corporate Responsibility (ACCR) and Ethical Partners argued that demand for coal will decline in coming decades:
… New South Wales (NSW) Treasury found that ‘global coal demand is projected to decline over the next forty years’, which will ‘negatively impact productivity growth in the absence of NSW transitioning these workers into similarly productive industries’. Similarly, the Australian National Outlook 2019—a collaborative report between the Commonwealth Scientific and Industrial Research Organisation and NAB—projected that in a ‘cooperative global context’, global coal demand would decline by approximately 70 per cent by 2060.90
When questioned what the impact on Australia’s exports will be if some of the world’s highest emitting countries do not meet their targets of net zero by 2050, the CPD stated:
… even if countries don't make 100 per cent of their stated targets, if they get halfway there their demand for some of these commodities will drop by much more than the amount that they buy from us. So it's not necessarily guaranteed that Australia would be the lowest-cost or preferred supplier. They may be able to service their needs from their own domestic resources.91
Investment NSW stated that ‘the coal mining industry is likely to remain an important employer in certain regional communities in NSW for some decades’, but that ‘differing understandings and assessments of future demand for coal’ was impacting investment in the sector. To address this, Investment NSW recommended consideration of ‘tools that could be provided to investors to help them to make well-informed assessments of risk in export industries.’92

Risks and opportunities of a transitioning economy

How Australia’s export industries and broader economy will ‘transition’ towards net zero by 2050 was discussed by many inquiry participants. The IGCC stated that this transition was accelerating due to a range of factors:
The global transition to net zero emissions is accelerating, and Australian export industries are already exposed to this through the policy changes and capital shifts in key trading markets. This shift is being accelerated by the falling costs of many zero emissions technologies, the deployment of green economic stimulus by governments and changing consumer preferences in key markets.93
The IGCC added that Australia’s export industries could not avoid the impact of this transition, but that Australia could ‘seek to ensure this transition occurs in an orderly manner’.94
ACSI similarly stated that Australia had ‘much to lose from an unplanned and disorganised transition to a low carbon economy’:
It is estimated that the likely damage to Australia’s economy of leaving climate change risks unchecked is a reduction in GDP of 6 per cent by 2070, equivalent to $3.4 trillion in present value terms, and 880,000 jobs lost. An orderly, just and equitable transition to a low-emissions economy (including our export market) will cause much less disruption to Australian industry and communities than the damage caused by inaction.95
Market Forces emphasised that ‘the global shift to decarbonise the economy is largely beyond the control of the Australian Government.’ Reflecting this, Market Forces considered that the Government should assist the ‘diversification of regional economies and [prepare] them for the inevitable decline of the fossil fuel industry.’96
The ACCR and Ethical Partners also considered that while risk mitigation or adaptation ‘may be possible’ for some businesses, overall the decline of carbon intensive industries was ‘entirely predictable.’ The ACCR further stated that ‘federal and state governments carry significant responsibility to support the just transition of our economy and communities, particularly those most reliant on the fossil fuel industry.’97
Further detail on the impact of climate change and decarbonisation on the economy was provided by the CPD, which advocated for a national policy response to decarbonisation:
… structural change driven by climate impacts and decarbonisation will create major challenges, risks and opportunities for many Australian businesses and regions. These require a comprehensive national policy response that identifies a whole-of-economy strategy; an overarching framework and road map for decarbonisation; and, very importantly, support for effective transition planning in key regions and industries.98
Other inquiry participants highlighted future opportunities for Australia’s resources exports. Investment NSW, for example, highlighted that the role of thermal coal in any transition:
This transition will take some time to complete and the rate of this transition is uncertain. During this transition, thermal coal will remain a vital energy source for many countries. NSW will continue to supply coal to other countries during the global transition to a low carbon economy.99
Ethical Partners also advised that there were opportunities for resources companies as part of a transition towards a net zero economy:
There are great opportunities in the resources sector as we move towards low-carbon technologies. There are lots of transition metal opportunities. There are lots of resource opportunities. But, because we are pro jobs and pro community, we would like to see an early and orderly transition to protect those communities and jobs.100
DISER pointed to many resource companies that were looking to reduce their emissions over coming years:
Australian resources companies are announcing policies to reduce emissions in the next 10 years, with a number looking to achieve net zero by 2050. Companies across the coal, oil and gas sectors, in particular, are adopting policies to adapt to global pressures on emissions to limit financial impact restrictions and to maintain capital investment and access to insurance products. Rio Tinto completed the sale of all its coal assets in 2018, BHP has committed to selling its thermal coalmines over the next few years and Glencore has committed to a managed decline of its coal business as part of its ambition to be a net-zero-total-emissions company by 2050.101
CMAX Advisory urged the Committee to ‘acknowledge the continued role resources and mining businesses will play in Australia’s economic success and the process of decarbonising the economy.’ In particular, CMAX Advisory pointed to the industry’s role in investing in ‘technological solutions’, such as carbon capture and storage, and through meeting ‘demand for resources like rare earth minerals … due to use in renewable technologies.’102
Financial risks associated with the transition to net zero by 2050 were highlighted by Market Forces. In particular, Market Forces pointed to the RBA’s 2019 Financial Stability Review103, which stated:
Transition risk will be greatest for banks that lend to firms in carbon-intensive industries and to individuals or businesses that are reliant on these firms. Other financial institutions investing in carbon-intensive industries, such as superannuation and investment funds, are also exposed to the risk that climate change will diminish the value of their investments. This could occur both through direct investments in carbon intensive industries, or indirect investments in banks that lend to these industries.104
The Commonwealth Bank of Australia (CBA) outlined its approach to assisting high emitting companies to transition to a net-zero future:
… the approach that we're taking at CBA is how we truly lean into the transition and help the country and all of our clients transition … We're an important source of capital and distributing capital to the areas that are going to allow the country to be as prosperous as it can be with minimal downside and risks. Our job will be to work out how to allocate that appropriately with strong engagement with all of our clients, understanding what their transitions are, understanding how their businesses need to evolve, understanding the enablers that enable that business and the new technologies to evolve, and ensuring that we are being constructive around helping them do that.105
APRA advised that the timing of any transition is ‘uncertain’, as ‘it will be a product of the way in which governments around the world change or don't change policies.’ At the same time, when asked if it considered that there was a risk that the coal sector could close in the next three to five years, APRA stated that ‘that would be a very rapid change if it were to come about.’106 Despite this, APRA explained:
What can change, though, much more quickly is the economics of the industry. As government policies change, as prices change, as investment demand changes, economics can change rapidly, and what can be a viable company one day can be rapidly impacted by, as I said, changes to government policy, changes to market prices, et cetera.107
The RBA outlined how even short-term loans could be impacted by risks associated with longer term policy changes:
… if a bank were writing a loan—even if this were a five-year loan and that loan was written to a producer of thermal coal—and if there were some expectation that there could be changes in the demand for thermal coal because of international policy considerations, even beyond that five-year horizon period, that would change the value of the assets of the coal producer today. So, even if they were still producing coal over the next five years, they could find that their assets diminish and, at the end of that five-year period, there could be difficulty for that institution to roll over its debt. So a bank today, even if they're writing only a five-year loan, could see risks that come from policy changes beyond that five-year horizon.108
New export opportunities for Australia were also highlighted, in areas such as renewable energy-driven export commodities109, hydrogen, and science and technology110. The ISS ESG further stated that investors were looking at the ‘opportunities associated with proactive action on climate change’, and that the United Nations had estimated that ‘achieving the Sustainable Development Goals could open up US$12 trillion in new market opportunities and create 380 million new jobs.’111
The IGCC also emphasised that that investors were looking for these new markets:
Australia also has significant natural and strategic advantages to produce and capitalise on the existing and new export products that will be in growing demand as part of an emissions-constrained world, such as green steel, green hydrogen and many critical raw materials. While seeking to manage climate risk, institutional investors are also hungry to capitalise on these opportunities to find market value and continue to generate sustainable returns for their beneficiaries and clients.112

Committee comment

Investment in Australia’s export industries is a crucial driver of Australia’s economic prosperity. Any changes in investment trends, whether domestically or internationally, are therefore of the upmost importance to Australian businesses, exporters, the Government and this Committee.
The Committee acknowledges the increasing focus from a range of international actors on climate-related financial risks for investments. Large global asset managers such as BlackRock are looking to address climate risk in their investment portfolios. Governments around the world are committing to reaching net zero emissions by 2050, leading some jurisdictions to consider policies such as carbon border tariffs, or a greater focus on renewable energy. Global institutions and forums, including the G20, are also paying increased attention to the importance of considering climate change in any risk management framework.
Investors are also increasingly calling for greater disclosure by companies regarding climate risks, in order to make better informed investment decisions. The Committee heard calls from some inquiry participants to make such disclosure mandatory in Australia and understands steps towards this have been taken in other jurisdictions.
Australia’s superannuation industry, like investors globally, is increasingly incorporating climate-related risk considerations into its investment decisions. This is particularly the case given that superannuation investments tend to have a long-term focus. The Committee was concerned to hear reports that superannuation funds were totally divesting from the resources industry. The Committee would urge superannuation funds to work with companies wherever possible before making divestment decisions. Resources companies seeking to transition to low-emissions approaches will play an important role in the global move to a lower-emissions future, but only with the support of investors.
The Committee believes that there is a need for greater clarity about how shareholder activism, especially when based on the advice of proxy advisory organisations, interacts with consumer and competition law in Australia. Noting the different understandings of this evident within the inquiry, the Committee thinks it appropriate that formal advice on this question is provided by the ACCC.
The risk of legal liability if climate-related financial risks are not appropriately identified and managed is a key concern of directors, trustees, fund managers and companies. The Committee heard that the fiduciary duties on these parties in relation to considering climate change risks was becoming increasingly clear, with guidance from Australia’s financial regulators, as well as legal opinions and cases.
It is clear that the global shift towards greater incorporation of climate-related risks into investment decision making will impact on Australia’s exports, which are currently dominated by the resources sector. Issues such as the potential for asset stranding, the current and expected future performance of investments in different sectors and changing consumer and investor preferences will continue to pose challenges and opportunities for Australia’s exports.
The Committee considers that investment decisions are best made by the private sector. At the same time, the Government can play a key role in providing clear market signals, through prudential guidance and market forecasts, to assist with investor and business decision making. This is already occurring to a large extent through Australia’s financial regulators including APRA, ASIC and the RBA. The Committee heard that a whole-of-economy plan for an economic transition towards the goal of net zero by 2050 could further assist in business and investment planning.
The Committee heard a range of views regarding the role of coal and other resources in a transition towards net zero. Given the global and interconnected nature of the economy, many decisions regarding the future of Australia’s resource exports may be outside of Australia’s control. Notwithstanding, the Committee was pleased to hear examples of resources companies working to reduce their emissions and demonstrating strong environmental, social and governance credentials.
The Committee acknowledges and supports the integration of climate-related considerations in investor decision making. At the same time, the Committee urges export businesses, investors, and the Government to collaborate in order to ensure Australia can successfully and profitably transition towards a lower emissions future.


Recommendation 10

The Committee recommends that the Australian Government continue to work with its global counterparts on developing and promoting global standards regarding the reporting and disclosure of climate risks, recognising that clarity for investors and the resources sector alike is vital.

Recommendation 11

The Committee recommends that the Australian Competition and Consumer Commission undertake a formal investigation into whether finance and insurance firms, in denying finance or insurance coverage to lawful sectors of the Australian economy such as the resources industry, have breached the concerted practices provisions of the Competition and Consumer Act 2010.

Recommendation 12

The Committee recommends that, pending the results of the Australian Competition and Consumer Commission’s investigation recommended above, the Australian Government consider options to ensure that viable, profitable and lawful businesses can access reasonably-priced finance and insurance services.

Recommendation 13

The Committee recommends that the Australian Government identify and invest in opportunities for Australia’s exports as part of the global transition towards a net zero economy.
Mr George Christensen MP
1 December 2021

  • 1
    Mr Tom Arup, Director, Strategic Programs, Investor Group on Climate Change, (IGCC) Committee Hansard, Canberra, 28 July 2021, p. 19.
  • 2
    Institutional Shareholder Services (ISS) Environmental, Social and Governance (ESG), Submission 46, p. 5.
  • 3
    Ms Viola Lutz, Executive Director and Head of ISS ESG Climate Solutions, ISS, Committee Hansard, Canberra, 27 July 2021, p. 55.
  • 4
    Mrs Karen McWilliams, Business Reform Leader, Chartered Accountants Australia and New Zealand (CAANZ), Committee Hansard, Canberra, 27 July 2021, p. 50.
  • 5
    Mrs Robyn Parkin, Head of Sustainability, Ethical Partners Funds Management (Ethical Partners), Committee Hansard, Canberra, 28 July 2021, p. 9.
  • 6
    IGCC, Submission 35, p. 5.
  • 7
    IGCC, Submission 35, p. 9.
  • 8
    Mr Scott Gregson, ACCC, Committee Hansard, 3 September 2021, p. 21.
  • 9
    Mr Ron Boswell AO, Committee Hansard, 3 September 2021, p. 25.
  • 10
    Mr Scott Gregson, ACCC, Committee Hansard, 3 September 2021, p. 20.
  • 11
    Australian Council of Superannuation Investors, Submission 40.1, p. 1.
  • 12
    Mrs McWilliams, CAANZ, Committee Hansard, Canberra, 27 July 2021, p. 54.
  • 13
    Mr Warren Tease, Department of the Treasury (Treasury), Committee Hansard, Canberra, 13 August 2021, p. 3.
  • 14
    Mr Tease, Treasury, Committee Hansard, Canberra, 13 August 2021, p. 3.
  • 15
    Principles of Responsible Investment (PRI), Submission 56, p. 9.
  • 16
    IGCC, Submission 35, p. 3 and Market Forces, Submission 61, p. 5.
  • 17
    IGCC, Submission 35, p. 3.
  • 18
    IGCC, Submission 35, p. 7.
  • 19
    Dr Travers McLeod, Chief Executive Office (CEO), Centre for Policy Development (CPD), Committee Hansard, Canberra, 28 July 2021, p. 40.
  • 20
    Dr McLeod, CPD, Committee Hansard, Canberra, 28 July 2021, p. 36.
  • 21
    Ms Cathie Armour, Commissioner, Australian Securities and Investments Commission (ASIC), Committee Hansard, Canberra, 13 August 2021, p. 17.
  • 22
    Industry Super Australia (ISA), Submission 49, p. 3.
  • 23
    ISA, Submission 49, p. 3.
  • 24
    Ms Louise Davidson, CEO, Australian Council of Superannuation Investors (ACSI), Committee Hansard, Canberra, 28 July 2021, p. 1.
  • 25
    ACSI, Submission 40, p. 1.
  • 26
    Mr Julian Cabarrus, Director, Policy Operations, Member Engagement and External Relations, Association of Superannuation Funds of Australia (ASFA), Committee Hansard, Canberra, 27 July 2021, p. 20.
  • 27
    Maritime Union of Australia, Submission 50, p. 11.
  • 28
    ACSI, Submission 40, p. 4.
  • 29
    Market Forces, Submission 61, pages 19-20.
  • 30
    ACSI, Submission 40, p. 4.
  • 31
    Lime Financial Planning, Submission 39, pages 3-4.
  • 32
    PRI, Submission 56, p. 13.
  • 33
    Department of Industry, Science, Energy and Resources (DISER), Submission 54, p. 8.
  • 34
    Market Forces, Submission 61, p. 25.
  • 35
    ISA, Submission 49, p. 2.
  • 36
    New Hope Group, Submission 10, p. 3.
  • 37
    Mr Cabarrus, ASFA, Committee Hansard, Canberra, 27 July 2021, p. 22.
  • 38
    Ms Davidson, ACSI, Committee Hansard, Canberra, 28 July 2021, p. 1.
  • 39
    Ms Davidson, ACSI, Committee Hansard, Canberra, 28 July 2021, p. 3.
  • 40
    Responsible Investment Association Australasia (RIAA), Submission 11, p. 5.
  • 41
    ISA, Submission 49, p. 4.
  • 42
    IGCC, Submission 35, p. 5.
  • 43
    Market Forces, Submission 61, p. 4.
  • 44
    Australian Council of Trade Unions (ACTU), Submission 14, p. 3.
  • 45
    ACSI, Submission 40, p. 4.
  • 46
    Commonwealth Climate and Law Initiative (CCLI), Submission 42, p. 21.
  • 47
    CCLI, Submission 42, p. 6.
  • 48
    Ms Anna Bligh, CEO, Australian Banking Association (ABA), Committee Hansard, Canberra, 27 July 2021, p. 5.
  • 49
    ACTU, Submission 14, p. 4.
  • 50
    CPD, Submission 31, p. 2.
  • 51
    CAANZ and CPA Australia, Submission 15, p. 9.
  • 52
    CPD, Submission 31, p. 2.
  • 53
    Mr Erwin Jackson, Director, Policy, IGCC, Committee Hansard, Canberra, 28 July 2021, p. 20.
  • 54
    Mr Jackson and Mr Arup, IGCC, Committee Hansard, Canberra, 28 July 2021, pages 20-21.
  • 55
    CPD, Submission 31, pages 4-5.
  • 56
    Mr Nathan Parkin, Investment Director, Ethical Partners, Committee Hansard, Canberra, 28 July 2021, p. 9.
  • 57
    Woodside Energy, Submission 29, p. 3.
  • 58
    Mrs Parkin, Ethical Partners, Committee Hansard, Canberra, 28 July 2021, p. 9.
  • 59
    RIAA, Submission 11, p. 2.
  • 60
    RIAA, Submission 11, p. 2.
  • 61
    RIAA, Submission 11, p. 2.
  • 62
    Ms Davidson, ACSI, Committee Hansard, Canberra, 28 July 2021, p. 1.
  • 63
    Market Forces, Submission 61, p. 27.
  • 64
    Lime Financial Planning, Submission 39, p. 3.
  • 65
    Ms Davidson, ACSI, Committee Hansard, Canberra, 28 July 2021, p. 1.
  • 66
    ACTU, Submission 14, p. 2.
  • 67
    CCLI, Submission 42, p. 8.
  • 68
    RIAA, Submission 11, p. 5.
  • 69
    Ethical Choice Investments, Submission 28, p. 3.
  • 70
    Mr Paul Flynn, Managing Director and CEO, Whitehaven Coal, Committee Hansard, Canberra, 25 June 2021, p. 2.
  • 71
    Queensland Resources Council (QRC), Submission 65, p. 4.
  • 72
    DISER, Submission 54, p. 5.
  • 73
    DISER, Submission 54, p. 5.
  • 74
    DISER, Submission 54, p. 5.
  • 75
    Dr Bradley Jones, Head, Economic Analysis Department, Reserve Bank of Australia (RBA), Committee Hansard, Canberra, 13 August 2021, p. 29.
  • 76
    Treasury, Submission 16.1, p. 1.
  • 77
    International Energy Agency (IEA), ‘World Energy Model: Report – October 2020’, www.iea.org/reports/world-energy-model, viewed 15 September 2021.
  • 78
    DISER, Submission 54, pages 5-6.
  • 79
    Yancoal Australia, Submission 21, p. 3.
  • 80
    DISER, Submission 54.1, p. 2.
  • 81
    IEA, ‘World Energy Model: Report Extract – Stated Policies Scenario’, www.iea.org/reports/world-energy-model/stated-policies-scenario, viewed 15 September 2021.
  • 82
    DISER, Submission 54, p. 5.
  • 83
    New Hope Group, Submission 10, p. 3.
  • 84
    Whitehaven Coal, Submission 48, p. 4.
  • 85
    National Australia Bank (NAB), Submission 60, p. 3.
  • 86
    Mr John Cochrane, private capacity, Committee Hansard, Canberra, 3 September 2021, p. 31.
  • 87
    Australian Petroleum Production and Exploration Association (APPEA), Submission 62, p. 4.
  • 88
    Woodside Energy, Submission 29, p. 1.
  • 89
    Market Forces, Submission 61, p. 12.
  • 90
    Australasian Centre for Corporate Responsibility (ACCR) and Ethical Partners, Submission 22, p. 4.
  • 91
    Mr Phillips, CPD, Committee Hansard, Canberra, 28 July 2021, p. 40.
  • 92
    Investment New South Wales (NSW), Submission 13, p. 3.
  • 93
    IGCC, Submission 35, p. 3.
  • 94
    IGCC, Submission 35, p. 3.
  • 95
    ACSI, Submission 40, p. 2.
  • 96
    Market Forces, Submission 61, p. 4.
  • 97
    ACCR and Ethical Partners, Submission 22, p. 12.
  • 98
    Dr McLeod, CPD, Committee Hansard, Canberra, 28 July 2021, p. 35.
  • 99
    Investment NSW, Submission 13, p. 3.
  • 100
    Mrs Parkin, Ethical Partners, Committee Hansard, Canberra, 28 July 2021, p. 10.
  • 101
    Mr Paul Trotman, Head of Division, Resources Division, DISER, Committee Hansard, Canberra, 13 August 2021, p. 31.
  • 102
    CMAX Advisory, Submission 8, p. 5.
  • 103
    Market Forces, Submission 61, p. 17.
  • 104
    RBA, Financial Stability Review, October 2019, p. 58, www.rba.gov.au/publications/fsr/2019/oct/pdf/financial-stability-review-2019-10.pdf, viewed 23 September 2021.
  • 105
    Mr Andrew Hinchliff, Group Executive, Institutional Banking and Markets, Commonwealth Bank of Australia, Committee Hansard, Canberra, 3 September 2021, p. 12.
  • 106
    Mr Wayne Byres, Chair, Australian Prudential Regulation Authority (APRA), Committee Hansard, Canberra, 13 August 2021, p. 9.
  • 107
    Mr Byres, APRA, Committee Hansard, Canberra, 13 August 2021, p. 9.
  • 108
    Dr Jonathan Kearns, Head, Financial Stability Department, RBA, Committee Hansard, Canberra, 13 August 2021, pages 28-29.
  • 109
    ACSI, Submission 40, p. 6.
  • 110
    DISER, Submission 54, p. 6.
  • 111
    ISS ESG, Submission 46, pages 5-6.
  • 112
    IGCC, Submission 35, p. 3.

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