Climate Policy Engagement Overview: Whitehaven Coal appears to be broadly opposed to ambitious action on climate change, albeit with relatively low engagement on specific climate-related policy. Whitehaven Coal does not appear to support the transition of the energy mix, showing strong support for a sustained role for coal in the energy mix.

Top-line Messaging on Climate Policy: Whitehaven Coal's top-line communications are mixed, however they have become more positive in 2021-22. In its 2022 Sustainability Report, published in September 2022, Whitehaven Coal supported the goals of the Paris Agreement, including limiting temperature rise to well below 2°C, and aspiring towards 1.5°C. Whitehaven Coal has previously appeared unsupportive of ambitious action on climate change in line with the IPCC. In its 2019 and 2020 Sustainability Reports, Whitehaven Coal appeared to prioritize energy security and economic development over emissions reductions.

Despite this improvement however, Whitehaven Coal appeared to call for slower implementation of Australia's net-zero by 2050 target, calling for “sensible and incremental” policy change in its 2022 Sustainability Report. Similarly, in the same report, Whitehaven . Coal CEO Paul Flynn appeared to call for “sensible” energy policy and emphasized the need to maintain competitiveness of Australian industry in climate-related policymaking.

Engagement with Climate-Related Regulations: Whitehaven Coal appears to have limited transparency regarding its engagement with specific climate-related regulations in 2022. Past evidence of engagement has been largely negative. In an April 2021 response to a Parliamentary Inquiry on the regulation of Australia's export industries, Whitehaven Coal appeared to oppose renewable subsidies in Australia. However, in its 2021 Sustainability Report, published in August 2021, the company also appeared to support general greenhouse gas emissions regulations.

Positioning on Energy Transition: Whitehaven Coal is continuing to strongly support a sustained role for coal in the energy mix. In its 2022 Sustainability Report, published in September 2022, Whitehaven Coal stated that coal is needed in the just transition as an affordable, secure and reliable energy source, and that it will play an important role in the ongoing energy crisis. Additionally, in an April 2021 response to a Parliamentary Inquiry on the regulation of Australia's export industries, Whitehaven Coal supported a significant role for coal in the energy mix for decades, including new projects, and opposed moves to accelerate the energy transition by phasing out financial support for the coal sector. In its 2020 Sustainability Report, the company also supported New South Wales’ 2020 Strategic Statement on Coal Exploration and Mining, which advocates a long-term role for coal for “many decades” and new areas for exploration and mining.

Whitehaven Coal's leadership also advocates strongly in favor of coal's role in the energy mix. In its 2022 Sustainability Report, published in September 2022, CEO Paul Flynn supported the continued role of coal in the energy mix, emphasizing its use in providing energy security as a “secure, reliable and affordable” energy source. Flynn also called for “sensible” policy that reflects coal as having a central role in development in Australia. In response to Queensland's decision to remove a ten-year freeze on coal royalties, Flynn opposed the policy change in a July 2022 Sydney Morning Herald article, stating that “It is clearly not a royalty, it’s a tax”. Flynn also appeared to suggest that Whitehaven Coal would be engaging with the New South Wales government on its own coal royalty policies, and stated that the company would make sure the state "understands the critical role the resources sector plays". Further, in October 2021, Chairman Mark Vaile called for continued investment in fossil fuels (including coal) for decades, emphasizing the risks to energy security of moving away from coal as part of Australia's net-zero push.

Industry Association Governance: Whitehaven Coal has disclosed its membership to some industry associations which are actively lobbying on climate change policy. However, the company has not published a dedicated review assessing climate policy alignment with its associations, nor has it disclosed how it is engaging with these groups on climate change. Whitehaven Coal has strong links to several industry associations that have actively opposed meaningful climate change policy in Australia, including sitting on the board of directors of the Minerals Council of Australia, Queensland Resource Council, and the NSW Minerals Council. Whitehaven Coal also sits on the executive committee of the World Coal Association (WCA) which has actively promoted coal in the global energy mix.