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In recognition of RIAA’s and IGCC’s significant and overlapping membership bases and engagement in issues relevant to this consultation, we have co-developed this submission.

We welcome the Government’s focus on efforts to facilitate private investment in important projects, many of which will be required for the Australian economy to transition to net-zero carbon emissions. In addition, the Future Made in Australia (FMiA) initiative underscores the government's vital role in shaping a sustainable finance agenda, a perspective long championed by both RIAA &IGCC.

It is also an opportunity for the finance sector and government to work together to harness capital toward sustainable economic, environmental and social outcomes, ensuring the energy transition creates decent work and does not leave individuals, workers, regions or communities behind. The energy transition and FMiA additionally offer a significant opportunity to advance broader government priorities – such as reducing inequality and improving social outcomes – by ensuring underrepresented communities are active participants and beneficiaries.

We welcome the Community Benefit Principles Draft Public Guidance as a key opportunity for the Australian Government to set minimum standards for the projects which can avail themselves of the FMIA benefits, particularly so for non-climate sustainability factors. Without proper safeguards, a streamlined pathway focused on project delivery may increase the risks in these areas which have varying legal obligations and quality of engagement and adoption.

For Australian institutional investors to support, scale and accelerate the types of projects intended under this program, proponents must be set up for success and able to derisk their projects in line with established industry expectations. RIAA’s research consistently shows that institutional investors consider non-climate sustainability factors in their decision making processes, and that doing so mitigates significant long-term social, environmental and governance risks to assets and portfolios. In the early phases of the Future Made in Australia agenda, the Government is effectively stepping into the role traditionally played by institutional investors by providing derisking support. This makes it essential that project recipients meet standards that reflect leading practice investor expectations to remain eligible for, and deserving of, these benefits. Appropriate attention to long-term non-financial risks at the early stage of FMIA-supported projects will have material benefits for the projects, investors and the economy.

Summary of recommendations

RIAA and IGCC make the following key recommendations to strengthen the effectiveness of the draft guidance to ensure alignment with established investor expectations, mitigate long-term risks to projects and support the intent of the community benefits principles:

• ‍Recommendation 1: Projects receiving FMiA finance are subject to conditions, such as workforce, training and apprenticeships quotas/metrics, and local content requirements, as appropriate. FMiA finance should be awarded against a standardised set of community benefits principles to reduce complexity.‍
• Recommendation 2: Community Benefits Principles should be set in alignment with international best practice for interoperability in reporting and ease of screening for investors with global portfolios. ‍
• Recommendation 3: Explicitly reference existing industry guidance across the minimum requirements, threshold requirements, and additional information sections. This will help ensure consistency, clarity, certainty and alignment with recognised leading practice.‍
• Recommendation 4: Incorporate key industry resources relevant to institutional investors within the final guidance where well-established frameworks that support the community benefit principles exist.‍
• Recommendation5: Require Community Benefit Principles 3 and 4 to meet minimum standards consistent with the Dhawura Ngilan Business and Investor Guide, ensuring culturally appropriate engagement and stronger protection of First Nations rights and cultural heritage.‍
• Recommendation 6: Include a minimum requirement under Community Benefit Principle 3 for proponents to undertake an assessment of nature‑ and biodiversity‑related risks and ensure projects support the protection and restoration of nature, using existing industry guidance and standards.‍
• Recommendation 7: Coordinate FMiA financed projects with the Net Zero Economy Authority(NZEA) to ensure transition planning is streamlined and representative relative community needs. ‍
• Recommendation 8: FMiA finance should come with public disclosure on why projects were selected and the benefits they bring to communities, as well as their relevance to the national interest framework.

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