Although [the company has] room for improvement—a point we raised in our engagements—[it] has made significant progress and commitments on disclosure, primarily regarding Scope 1 and 2 emissions. Santos…has embraced carbon capture technology and aligned its reporting with the TCFD’s framework. [The company has] also committed to being carbon neutral by 2050. Disclosure about Scope 3 emissions, which are indirect to a company and focus on its customers’ carbon footprint, is more nascent and, we believe, needs more time to mature before being mandated as the proposal outlined. We viewed as too prescriptive the request to disclose details of the companies’ exploration and capital expenditures. Disclosing proprietary details of a company’s acquisition or development of reserves could give its competitors an advantage.