Our approach

We are a member of a large number of organisations, ranging from community bodies, chambers and business councils relevant to the communities and regions we operate in, as well as industry-related representative bodies known as ‘industry associations’.

Santos is a member of these organisations so that we can:

• gain an understanding of communities, regions and economies where we operate
• understand how we can contribute positively and effectively with stakeholders
• enhance technical knowledge, share learnings and develop standards within industry
• engage in policy development.

Our memberships allow us a forum to listen, debate, seek alignment and promote the key interests of communities and industry organisations. In addition to our policy positions, this advocacy is also guided by our support for the Paris Agreement where it acknowledges the need to balance emissions reduction with “the imperatives of a just transition of the workforce and the creation of decent work and quality jobs in accordance with nationally defined development priorities.[1]”

[1] United Nations Framework Convention on Climate Change. Paris Agreement: unfccc.int/process-and-meetings/the-paris-agreement/.

Santos engages with all levels of government in relation to our projects, operations, maintaining energy supply and reducing our carbon footprint. In Australia, this includes engagement in business forums and events where Santos pays for membership and/or attendance.

Santos believes it is important for us to engage in the discussion about the world’s energy future and the role we can play through our natural gas portfolio and our emerging low carbon fuels business.

We manage fundraising requests from Australian political parties under rules set out in an operating standard and we:

• do not make cash donations to political parties or candidates
• declare payments made for attending political events and memberships of political party business forums in accordance with applicable legislation.

In Alaska, we do not engage in fundraising for political parties through the corporate treasury. Being involved in political party business programs in a bipartisan manner is an appropriate and important way for the business community and Santos to contribute transparently to the political process, and to help ensure the stability of democratic systems. This helps foster stable policy, regulation and taxation for business, which in turn generates investment, jobs and greater prosperity for the communities we operate in. These programs have transparent membership fees and services.

Santos is a member of the following Australian national political party business forums:

• Federal Labor Business Forum (Federal ALP)
• Australian Business Network (Federal Liberal Party)
• National Policy Forum (Federal National Party).

From time-to-time, specific events such as Budget or Budget-reply events or policy launch events are also held. Individual members of parliament or candidates also host business events featuring guest speakers who are generally ministers or shadow ministers. Participation in these events often requires payment of an attendance fee not covered by the fees paid for membership of the business forums. Attendance and representation of Santos at a political event is regulated by the SMS and CEO approval is required in accordance with the Delegation of Authority.

Given there is no public funding of Commonwealth election campaigns, there is an expectation by the major political parties that the corporate sector will engage through the above transparent mechanism. The involvement of a wide range of companies in this process helps to ensure that funding of the democratic process is received from multiple sources and wide-ranging policy positions and interest, so that no single interest unduly influences the political process.

Santos is not a member of state-based political party business forums and considers individual event requests on a case-by-case basis where there is a clear business reason. Federal, State and Territory Electoral Commissions in Australia publish reported payments through transparency registers and electronic disclosure systems.

Santos recognises the scientific consensus of climate change assessed by the IPCC. We support the objective of the Paris Agreement to limit global temperature rise to less than 2 degrees Celsius and pursue efforts to limit the temperature increase to 1.5 degrees Celsius.

Through direct engagement with policy makers and indirect engagement through our industry association memberships, Santos advocates for environmentally, socially and economically effective and responsible energy and carbon policies that are aligned with our Climate Policy.

Santos actively works with, and provides input to, governments and stakeholders in the design of climate regulation. We do this in pursuit of decarbonisation goals, striving for a policy and regulatory framework that supports lowest-cost abatement and innovation and investment in low emissions technologies, while continuing to provide access to reliable and affordable energy in Australia and Asia.

In 2024, this included direct engagement with, and/or submissions made, to government agencies on the following topics:

• development of the Australian Sustainable Finance Taxonomy
• Alaska’s proposed emissions reduction Projects on State Land Regulations
• Future Made in Australia (Guarantee of Origin) Bill 2024.

These submissions were assessed against our Climate Policy for consistency with the Company’s public positions.
Santos similarly assesses the climate policy positions of the industry associations of which we are a member. Where an association is neutral or unaligned to Santos’ climate policies, the Company will make its views known to the association by working proactively to influence alignment. This includes promoting the goals of the Paris Agreement, recognition of the scientific consensus of climate change and support for net-zero emissions by 2050 or earlier.

In 2024, out of the 11 associations assessed, we found that eight were aligned with Santos’ climate policy positions and three were neutral. Organisations assessed as aligned include the PNG Chamber of Resources and Energy which was previously determined as neutral prior to Santos’ engagement across 2024 in assisting develop its approach to climate change.

Building on this, we will continue working with the Alaska Oil and Gas Association, and Resource Development Council of Alaska to align their climate policies to our own. The remaining neutral body, the Australian Resources and Energy Employer Association, is appropriate to be classified accordingly given the focus of its activities and advocacy is not climate or environmental matters.

We integrate human rights advocacy into our business practices by focusing on Indigenous rights and community engagement, fair labour practices, responsible supply chain management and external security arrangements. Our approach reflects a broad commitment to ethical corporate behaviour and sustainable development.

Our commitment to sustainability and corporate responsibility includes integrating human rights considerations across our operations. We recognise potential human rights risks associated with our environmental footprint, interactions with Indigenous communities, labour practices and broader social issues throughout our activities.

Human rights commitment and policy

Our company has implemented a Human Rights and Modern Slavery Policy. Santos is committed to support and respecting the protection of international recognised human rights as set out in the United Nations International Bill of Human Rights and works to align to the UN Guiding Principles on Business and Human Rights and the Voluntary Principles for Security and Human Rights in our practices and procedures.

Respect for Indigenous rights

We operate in regions that overlap with traditional lands of Indigenous communities, particularly in Australia, Alaska and Papua New Guinea. The Company has a specific focus on respecting the rights of these communities by:

• consulting with Indigenous peoples on land use
• acknowledging their connection to the land
• identifying suitable commercial opportunities to partner with Indigenous businesses and employment and upskilling of local Indigenous people.

We collaborate with local Indigenous groups so that our projects benefit these communities economically and socially, while also respecting cultural heritage and environmental stewardship.

Supply chain management

We are committed to fostering a supply chain that respects human rights. Key due diligence measures encompass supplier assessments, deep-dives and advanced counterparty screening through Compliance Catalyst. These efforts are overseen by our internal Modern Slavery Working Group, which monitors processes, identifies additional risks and opportunities.

Workplace rights and safety

Santos prioritises the rights of its workers by:

• fostering diversity and inclusion
• upholding fair labour practices, including no tolerance for discrimination, harassment and exploitation
• focusing on potential human rights impacts from security arrangements – both public and privately provided.

Our operations are aligned with Occupational Health and Safety (OHS) standards and labour laws across the regions in which we operate, reinforcing our commitment to a safe and equitable workplace as part of our human rights advocacy.

Transparency and accountability

We engage in transparent reporting on human rights impacts through our Sustainability Reports and Modern Slavery Statements. The Company tracks our progress and performance on human rights issues and shares this information publicly. This includes efforts to address risks of modern slavery within our operations and supply chains.

Grievance mechanisms

Santos maintains internal processes and an external grievance mechanism for individuals who work for or with us, including the community at large, to facilitate reporting of potential breaches of our Code of Conduct, including in relation to human rights concerns. Reporting can be made anonymously.