Santos is one of Australia’s largest producers of oil and gas, and is pursuing massive expansion plans consistent with the failure of the Paris Agreement.

According to the International Energy Agency (IEA), reaching net zero emissions by 2050 means no new oil and gas production can proceed. The United Nations Environment Programme (UNEP) has also confirmed that limiting global warming to 1.5°C in line with the Paris Agreement means “global fossil fuel production must start declining immediately and steeply.”

It is abundantly clear that achieving these climate goals and a stable climate future leaves no room for the expansion of the oil and gas industry. Despite this, Santos is pursuing massive new oil and gas projects consistent with the failure of these goals, and many Australian financial institutions continue to support Santos and its climate-wrecking projects.

Almost every super fund in Australia invests members’ retirement savings in Santos, and at least 27 Australian and international banks—including ANZ, CommBank, NAB and Westpac—have provided finance to the company. Many of these financial institutions claim to support the Paris Agreement and net zero emissions by 2050, yet continue to support a company pursuing plans consistent with the failure of these goals.

Santos is undermining a stable climate future by pursuing new oil and gas projects. Our super funds and banks must stop investing in Santos and its climate-wrecking projects and plans now.


Tell your super fund to stop investing in Santos and its climate-wrecking expansion plans

The super funds failing to rule out investment in Santos

Almost every single Australian super fund invests in Santos, using members’ retirement savings to support its climate-wrecking projects and plans. A handful of super funds have either substantially divested from, have some form of exclusion on, or have plans to phase out oil and gas producers, meaning that we are starting to see a trickle of divestment from Santos. However, this divestment is not happening at the scale nor pace commensurate with the climate crisis we face, and all super funds need to exclude companies like Santos from their portfolios altogether.

Of Australia’s biggest 30 super funds by assets under management (AUM), only one has implemented an exclusion on oil and gas producers, meaning the rest of these funds are using members’ retirement savings to support Santos’ massive expansion plans. Worse still, several super funds have voted against shareholder proposals calling on Santos to wind up its oil and gas production in line with the climate goals of the Paris Agreement.

We have also calculated and presented the below funds’ investments in Santos as a proportion of each fund’s total allocation to Australian listed equities (shares listed on the Australian stock market), as this allows for direct comparison between funds. Other data points, such as investment exposure as a proportion of the total fund, or dollar value of investments in these companies are incomparable because funds have different allocations to Australian listed equities and different amounts of money in the investment pool.

Has your super fund failed to rule out investment in Santos? Check the list below and take action!

Investment exposure to Santos and proxy voting behaviour of Australia’s biggest super funds by assets under management

wdt_ID Fund Investment option profiled Investment exposure (% of Australian Equities) Voted against wind up resolution in 2021? Total Members Total Assets Under Management
1 AustralianSuper Balanced 0.20 Against 2,468,216 244.90
2 Commonwealth Super Corp PSS Default 0.92 Not disclosed 675,701 244.80
3 Australian Retirement Trust (formed after the merger between QSuper and Sunsuper) Balanced Pool 0.98 Against* 2,074,452 235.10
4 Aware Super High Growth 1.16 Abstain 1,123,049 153.60
5 AMP MySuper 1970's 1.32 Not disclosed 1,150,081 118.90
6 MLC (owned by IOOF) MySuper Growth 1.54 Against 1,049,985 109.70
7 BT Financial Group BT Panorama 0.45 Against 1,005,020 109.20
8 UniSuper Balanced 1.38 Against 497,959 102.60
9 Colonial First State FirstChoice Wholesale Growth 2.14 Against 846,980 96.90
10 REST Core Strategy 2.25 Against 1,846,992 67.00

Holdings information as at 31 December 2021.

*Proxy voting information pertaining to Australian Retirement Trust reflects the combined voting behaviour of QSuper and Sunsuper, prior to the merger. Both funds voted against the Santos ‘Capital Protection’ resolution in 2021.

Methodology and sources


The scope of our analysis covers Australia’s largest 32 super funds by assets under management, according to APRA’s June 2021 fund-level superannuation statistics, Table 1 and Table 2. Where mergers between super funds have occurred since June 2021, the single merged entity is listed on the table (noting the previous fund name/s) and occupies only one position on the table, unless the merged funds remain as standalone brands with standalone policies. We identified:

  • Each fund’s investment exposure to Santos, as a proportion of its total allocation to Australian equities in its default (or largest, by AUM) investment option as at 31 December 2021, and;
  • How each fund voted on the Market Forces-coordinated ‘Capital Protection’ shareholder proposal at the annual general meeting (AGM) of Santos in 2021.

Where a fund’s total allocation to Australian equities for 31 December 2021 was not disclosed or not apparent from its holdings disclosures, the option’s disclosed strategic asset allocation (or the most recent actual asset allocation, if available) was used to calculate the fund’s exposure to Santos, as a proportion of Australian listed equities.

The information in the above table pertains to 23 of Australia’s largest 32 funds, for the following reasons:

  • QSuper and Sunsuper have recently merged to form Australian Retirement Trust;
  • HUB24 and Netwealth do not have investment options comparable to the rest of those captured in the study;
  • CommBank Group Super and Macquarie do not disclose total or strategic allocation to Australian equities, nor is this information apparent from its holdings disclosure. We therefore did not have enough information to analyse these funds’ investments in Santos as a proportion of Australian listed equities, and;
  • IOOF, OnePath and StateWide are yet to disclose their full list of investment holdings.
  • NGS Super has implemented an exclusion on oil and gas producers and publicly divested from companies captured by that exclusion, including Santos.

Where a fund’s proxy voting disclosure reads ‘Split,’ this means that the fund has voted some of its shares in different ways on the relevant proposal, for example some shares for and some against, or some abstaining and some against.


Portfolio holdings disclosures for all funds are effective as at 31 December 2021, and were sourced from each fund’s website (see below). Proxy voting information was sourced from Proxy Insight (a subscription service), or from each fund’s own proxy voting disclosure. Total allocation to Australian equities calculated from portfolio holdings disclosure unless noted below.

The banks financing Santos’ climate-wrecking business plans

Since 2018, a number of domestic and international banks—including ANZ, CommBank, NAB and Westpac—have either loaned to, or arranged finance for, Santos and its climate-wrecking projects and plans. All of Australia’s big four banks claim to support the goals of net zero emissions by 2050 and the Paris Agreement. However, all four of these banks have also loaned money to Santos, enabling the company to pursue oil and gas production projects consistent with the failure of these global climate goals.

Has your bank loaned to, or arranged finance for, Santos since 2018? Check out the list below and take action!

Banks that have loaned to, or arranged finance for, Santos since 2018

  • ABN Amro
  • ANZ
  • Bank of China
  • Bank of Communications
  • China Construction Bank
  • China Everbright Bank
  • Citigroup 
  • Commonwealth Bank of Australia
  • Credit Suisse
  • DBS Bank
  • First Commercial Bank
  • Goldman Sachs
  • Industrial & Commercial Bank of China (ICBC)
  • ING
  • Intesa San Paolo
  • Mega International Commercial Bank
  • Mizuho Bank
  • Morgan Stanley
  • MUFG Bank
  • National Australia Bank (NAB)
  • Natixis
  • Royal Bank of Canada
  • State Bank of India
  • Sumitomo Mitsui Banking Corporation (SMBC)
  • UBS Australia
  • United Overseas Bank
  • Westpac

Please note: This list was last updated on 30 August 2022. Banks listed in bold took part in August 2022 corporate refinancing. 


Send a message to the banks financing Santos and tell them to stop funding climate failure

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Planning for climate catastrophe: the climate-wrecking projects and expansion plans Santos is pursuing

Santos is pursuing massive new oil and gas projects consistent with the failure of the Paris Agreement, including the dangerous and destructive Narrabri gas project in the Pilliga Forest, New South Wales (NSW). Santos has recently undergone a merger with Oil Search to make the combined business one of the 20 largest companies on the Australian Securities Exchange (ASX). This new fossil fuel giant has one main aim: produce more oil and gas. In fact, Santos is pursuing major new projects that would increase its production by at least 17% from 2020 to 2030, despite the urgent need for fossil fuel production to begin declining in line with global climate goals.

Beyond clearly contravening the IEA’s key conclusion that there is no room for new oil and gas production projects in the pathway to net zero emissions by 2050, a number of independent analyses of new oil and gas production projects being pursued by Santos reveals how significantly out of line they are with global climate goals. Carbon Tracker, for example, identified the proposed Dorado project as incompatible with the International Energy Agency’s (IEA) Sustainable Development Scenario (SDS)—a pathway that only aims to reach net zero emissions by 2070—let alone a net zero by 2050 scenario. The Dorado project is but one of several examples of Santos’ reckless pursuit of fossil fuel projects that undermine global climate goals.

Santos plans to drill 850 gas wells throughout the Pilliga Forest and surrounding farmland near Narrabri, NSW. The company is still desperately pursuing this toxic project, despite years of opposition from local Gomeroi Traditional Owners and farmers, as well as former Chief Scientist Penny Sackett, who has confirmed the project is inconsistent with the Paris Agreement and net zero by 2050.

Santos has even gone so far as to submit an application to the National Native Title Tribunal, in an attempt to extinguish Gomeroi Traditional Owner native title rights over the Pilliga. The Narrabri project makes it clear that Santos will stop at nothing in the pursuit of climate-wrecking gas, including trashing Indigenous cultural heritage.

Community members voicing opposition to the Narrabri gas project in NSW, 2014. Image courtesy of the Lock the Gate Alliance

Community members voicing opposition to the Narrabri gas project in NSW, 2014.
Image courtesy of the Lock the Gate Alliance

Santos has committed approximately $1.8 billion on the Barossa gas project, a massive new proposed gas field 300km North of Darwin, Northern Territory (NT). If the project goes ahead, Santos will transport gas from the Barossa field to an existing LNG processing facility in Darwin.

The extremely high carbon dioxide (CO2) content of Barossa gas is three times greater than the Darwin LNG plant can handle, leading energy experts to state that the Barossa to Darwin LNG project looks like it’s shaping up to become “…a CO2 emissions factory with an LNG by-product.”

Traditional Owners are suing Barossa’s financiers to try to stop the project, as “some Tiwi Islander and Larrakia elders fear the project will have detrimental impacts on their sea country and marine life.”

The Dorado oil and gas project is yet another proposed offshore oil and gas field, off the coast of Western Australia (WA). Santos has committed approximately $1.5 billion to Dorado, a joint venture with Carnarvon Petroleum of which Santos owns 80%.

Santos has announced Australia’s second-largest oil reserve discovery in the past five years at the Dorado field and intends to go ahead with the project despite the clear science confirming it is out of line with the Paris and net zero by 2050 climate goals.

The P’nyang gas field is located in the Western Province of Papua New Guinea. Despite being operated by ExxonMobil, Santos owns a 38.5% stake in the project. If the P’nyang project were to go ahead this decade, it could bring Santos’ 2030 production up to a massive 58% above its (combined Santos and Oil Search) 2020 baseline.

Trashing the environment and endangering lives

Santos has a history of causing environmental and social damage due to unsafe business practices. In 2013, Santos was responsible for an oil spill in Channel Country, Queensland, where a leak from a burst well head spilled 250,000 litres of oil into the surrounding environment over a five-day period. However, the Queensland Government’s Environment Department failed to prosecute Santos over the company’s environmental recklessness, despite having enough evidence to do so. Santos has also been responsible for several oil spills within the Great Barrier Reef World Heritage Area, and failed to report one of these spills for eight months, despite a requirement to report spills within five days.

Looking forward, Santos continues to shirk responsibility for the emissions from its climate-wrecking business activities. The company has a target to reduce its emissions by 26-30% (by 2030). However, this target only accounts for ‘scope 1 and 2’ (or ‘operational’) emissions, despite these only accounting for roughly 15% of the company’s overall emissions. Much of the remaining 85% of Santos’ emissions—its ‘scope 3’ emissions—come from customers burning its oil and gas for energy use. The chart (Figure 1) shows Santos’ deplorable 2030 emissions reduction targets have almost no impact on the company’s estimated emissions pathway, which is actually expected to increase due to its increasing production plans.

New Hope Corp's New Acland coal mine, February 2016

Figure 1: The estimated impact of Santos’ 2030 emissions reduction target vs. its estimated emissions profile

Santos’ claim of support for the Paris climate goals appears misleading, in light of the fact that the company’s increased production plans are likely to see its emissions increase over the next five to ten years. Taking Santos’ own production projections—applying conservative assumptions where required and assuming Santos fully implements its emissions targets—our analysis shows that Santos’ annual emissions are likely to sit more than 25% above a combined Santos and Oil Search 2020 baseline through 2026-2029, before falling back to 10% above 2020 levels in 2030 (assuming the P’nyang LNG project does not commence by then).

Santos has also been taken to court over its dodgy climate claims. It has been alleged, in an Australian Federal Court case, that Santos engaged in misleading and deceptive conduct by claiming to have a “…clear and credible pathway to achieve net zero emissions by 2040,” but failing to “…disclose that it has firm plans to increase its greenhouse gas emissions by developing new or existing oil and gas projects.”

New Hope Corp's New Acland coal mine, February 2016

A decommissioned coal seam gas (CSG) well in the Pilliga, NSW. Image courtesy of the Lock the Gate Alliance.

In 2001, an explosion at Santos’ Moomba gas plant killed one worker and injured three others. Santos pleaded guilty to three counts of “…failing to ensure its employees were safe from injury and risk to health,” but was fined a mere $105,000 for this horrific event. The company was also found responsible for another death in 2009, where a contractor was struck in the head and killed whilst working on Santos’ Pilliga site. The company pleaded guilty to this death, too, yet was fined only $120,000.

Santos pleaded guilty to breaching workplace safety laws after another explosion at its Moomba plant in 2004. This explosion caused a mercury gas leak, putting 13 workers on site at risk of “…serious harm or fatality,” several of which had to run through the toxic gas cloud to escape the explosion site. Santos was fined $84,000 (plus court costs) for this breach, after a long-running court case.

More recently, an engineering fault resulted in a Santos oil rig swinging uncontrollably from a crane and nearly crushing several workers to death.


Australia’s five biggest super funds failing on key climate promises

MEDIA RELEASE Wednesday 15 March, 2023: A new report by Market Forces finds Australia’s five biggest super funds are greenwashing and exposing themselves to legal risk by failing to effectively engage with companies expanding fossil fuels. Managing more than $1...

Page last updated March 2022. Unless otherwise specified, all currencies are in AUD.


The information provided by Market Forces does not constitute financial advice. The information is presented in order to inform people motivated by environmental concerns and take actions based on those concerns. Market Forces is organising data for environmental ends.

The information and actions provided by Market Forces do not account for any individual’s personal objectives, financial situation or needs. It should not be used, relied upon, or treated as a substitute for specific professional advice.

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