Explicit deep search closed 10 of 38 RAP gaps — 28 ASX 100 companies still show no reliable public plan

Asked:
go deeper target the companies where you find nothing and explicit search for them

A targeted follow-up to the ASX 100 Reconciliation Action Plan inventory. On 2 September 2026 the 38 companies previously marked “no plan located” each received two additional search passes with six company-specific query patterns per pass — exact names and tickers, RAP wording and all four stages, First Nations terminology, annual and sustainability reports, Reconciliation Australia, archives, former names and brands. New reliable plan-related evidence emerged for 10 companies; 28 remain unresolved.

What the funnel cannot say

Whitehaven Coal yielded the clearest newly recovered historical edition — a Stretch RAP covering January 2018 to December 2020 — plus a launch announcement for its inaugural RAP. whitehavencoal.com.au
For most of the eight confirmed companies the RAP is evidenced only through an annual report, sustainability report or official page — the standalone RAP PDF itself remains missing, e.g. AGL's confirmation sits inside its 2025 annual report. agl.com.au
Bendigo & Adelaide Bank states it is developing and launching an Innovate RAP, but no existing edition was located in either pass. bendigoadelaide.com.au
Evolution Mining reports a “Reconciliation Plan” aligned with Reconciliation Australia's RAP framework; it stays in scope review rather than being counted as an endorsed RAP. yourir.info

The 10 companies with new reliable evidence

Each card names the exact validation outcome and whether a standalone RAP document was actually located. RAP performance reports and annual/sustainability-report references are not standalone RAP documents.

Whitehaven Coal LimitedWHC
Existing or historical RAP evidence
Standalone RAP located? Historical edition evidenced — Stretch RAP, Jan 2018 – Dec 2020, plus inaugural RAP launch
Reconciliation Action Plan (RAP) — whitehavencoal.com.au (2 sources, pass 1, pass 2)
Stretch Reconciliation Action Plan (RAP) January 2018 – December 2020 — whitehavencoal.com.au (3 sources, pass 1, pass 2)
AGL Energy LimitedAGL
Existing or historical RAP evidence
Standalone RAP located? No — confirmed in annual/sustainability reporting only
Confirmed existing RAP; standalone plan not located — agl.com.au (2 sources, pass 2)
Mineral Resources LimitedMIN
Existing or historical RAP evidence
Standalone RAP located? No — confirmed in annual/sustainability reporting only
Confirmed endorsed Innovate RAP; standalone plan not located — clients3.weblink.com.au (1 source, pass 2)
PLS Group LimitedPLS
Existing or historical RAP evidence
Standalone RAP located? No — confirmed in annual/sustainability reporting only
Reconciliation Action Plan (RAP) — pls.com (1 source, pass 1, pass 2)
Rio Tinto LimitedRIO
Existing or historical RAP evidence
Standalone RAP located? No — confirmed in annual/sustainability reporting only
Australian Reconciliation Action Plan (RAP) — riotinto.com (1 source, pass 1, pass 2)
Woodside Energy Group LimitedWDS
Existing or historical RAP evidence
Standalone RAP located? No — RAP performance reports located; underlying plan confirmed
2023 Reconciliation Action Plan (RAP) Report — woodside.com (1 source, pass 1)
2024 Reconciliation Action Plan (RAP) Report — woodside.com (1 source, pass 1)
Woolworths Group LimitedWOW
Existing or historical RAP evidence
Standalone RAP located? No — confirmed via official page or company report
Innovate Reconciliation Action Plan (RAP) — woolworthsgroup.com.au (1 source, pass 1)
Reconciliation Action Plan (RAP) — woolworthsgroup.com.au (1 source, pass 1, pass 2)
Worley LimitedWOR
Existing or historical RAP evidence
Standalone RAP located? No — confirmed via official page or company report
Australian Reconciliation Action Plan (RAP) — company-announcements.afr.com (1 source, pass 1)
Bendigo & Adelaide Bank LimitedBEN
RAP announced / in development
Standalone RAP located? No existing edition located
Financial Inclusion Action Plan — bendigobank.com.au (1 source, pass 2)
Innovate Reconciliation Action Plan (RAP) — bendigoadelaide.com.au (2 sources, pass 1, pass 2)
Evolution Mining LimitedEVN
Reconciliation Plan — scope review
Standalone RAP located? Not automatically an endorsed RAP — keep in scope review
Reconciliation Plan — yourir.info (1 source, pass 2)

The 28 companies still unresolved

For these companies no reliable public RAP evidence was located in these searches. That is a statement about what the search found, not a claim that no RAP exists.

A2M A2 Milk Company Limited
ALQ Als Limited
ANZ Anz Group Holdings Limited
ALL Aristocrat Leisure Limited
BSL Bluescope Steel Limited
CMM Capricorn Metals Limited
CGF Challenger Limited
APE Eagers Automotive Limited
FPH Fisher & Paykel Healthcare Corporation Limited
FMG Fortescue Limited
GMD Genesis Minerals Limited
GGP Greatland Resources Limited
360 Life360 Inc
LNW Light & Wonder Inc
NEM Newmont Corporation Registered
NST Northern Star Resources Limited
PRU Perseus Mining Limited
RMS Ramelius Resources Limited
RMD Resmed Inc
SEK Seek Limited
SIG Sigma Healthcare Limited
SHL Sonic Healthcare Limited
TLX Telix Pharmaceuticals Limited
TCL Transurban Group Limited
SOL Washington H. Soul Pattinson And Company Limited
WGX Westgold Resources Limited
WTC Wisetech Global Limited
XRO Xero Limited

Full deep-search audit table

TickerCompanyDeep-search outcomeFindingRAP stageBest sourceSourcesPasses
AGLAgl Energy LimitedConfirmed existing RAP; standalone plan not locatedConfirmed existing RAP; standalone plan not locatedagl.com.au2pass 2
BENBendigo & Adelaide Bank LimitedRAP in development/announced; no existing edition locatedFinancial Inclusion Action Planbendigobank.com.au1pass 2
BENBendigo & Adelaide Bank LimitedRAP in development/announced; no existing edition locatedInnovate Reconciliation Action Plan (RAP)Innovatebendigoadelaide.com.au2pass 1, pass 2
EVNEvolution Mining LimitedReconciliation Plan aligned to RAP framework; review scopeReconciliation Planyourir.info1pass 2
MINMineral Resources LimitedConfirmed endorsed Innovate RAP; standalone plan not locatedConfirmed endorsed Innovate RAP; standalone plan not locatedInnovateclients3.weblink.com.au1pass 2
PLSPls Group LimitedConfirmed inaugural RAP; standalone plan not locatedReconciliation Action Plan (RAP)pls.com1pass 1, pass 2
RIORio Tinto LimitedConfirmed historical RAP; standalone plan not locatedAustralian Reconciliation Action Plan (RAP)riotinto.com1pass 1, pass 2
WHCWhitehaven Coal LimitedExisting/historical RAP located or confirmedReconciliation Action Plan (RAP)whitehavencoal.com.au2pass 1, pass 2
WHCWhitehaven Coal LimitedExisting/historical RAP located or confirmedStretch Reconciliation Action Plan (RAP) January 2018 – December 2020Stretchwhitehavencoal.com.au3pass 1, pass 2
WDSWoodside Energy Group LimitedRAP performance report located; underlying plan confirmed2023 Reconciliation Action Plan (RAP) Reportwoodside.com1pass 1
WDSWoodside Energy Group LimitedRAP performance report located; underlying plan confirmed2024 Reconciliation Action Plan (RAP) Reportwoodside.com1pass 1
WOWWoolworths Group LimitedExisting RAP confirmed on official pageInnovate Reconciliation Action Plan (RAP)woolworthsgroup.com.au1pass 1
WOWWoolworths Group LimitedExisting RAP confirmed on official pageReconciliation Action Plan (RAP)woolworthsgroup.com.au1pass 1, pass 2
WORWorley LimitedHistorical RAP confirmed in company reportAustralian Reconciliation Action Plan (RAP)company-announcements.afr.com1pass 1
A2MA2 Milk Company LimitedNo reliable RAP evidence located after explicit deep search
ALQAls LimitedNo reliable RAP evidence located after explicit deep search
ANZAnz Group Holdings LimitedNo reliable RAP evidence located after explicit deep search
ALLAristocrat Leisure LimitedNo reliable RAP evidence located after explicit deep search
BSLBluescope Steel LimitedNo reliable RAP evidence located after explicit deep search
CMMCapricorn Metals LimitedNo reliable RAP evidence located after explicit deep search
CGFChallenger LimitedNo reliable RAP evidence located after explicit deep search
APEEagers Automotive LimitedNo reliable RAP evidence located after explicit deep search
FPHFisher & Paykel Healthcare Corporation LimitedNo reliable RAP evidence located after explicit deep search
FMGFortescue LimitedNo reliable RAP evidence located after explicit deep search
GMDGenesis Minerals LimitedNo reliable RAP evidence located after explicit deep search
GGPGreatland Resources LimitedNo reliable RAP evidence located after explicit deep search
360Life360 IncNo reliable RAP evidence located after explicit deep search
LNWLight & Wonder IncNo reliable RAP evidence located after explicit deep search
NEMNewmont Corporation RegisteredNo reliable RAP evidence located after explicit deep search
NSTNorthern Star Resources LimitedNo reliable RAP evidence located after explicit deep search
PRUPerseus Mining LimitedNo reliable RAP evidence located after explicit deep search
RMSRamelius Resources LimitedNo reliable RAP evidence located after explicit deep search
RMDResmed IncNo reliable RAP evidence located after explicit deep search
SEKSeek LimitedNo reliable RAP evidence located after explicit deep search
SIGSigma Healthcare LimitedNo reliable RAP evidence located after explicit deep search
SHLSonic Healthcare LimitedNo reliable RAP evidence located after explicit deep search
TLXTelix Pharmaceuticals LimitedNo reliable RAP evidence located after explicit deep search
TCLTransurban Group LimitedNo reliable RAP evidence located after explicit deep search
SOLWashington H. Soul Pattinson And Company LimitedNo reliable RAP evidence located after explicit deep search
WGXWestgold Resources LimitedNo reliable RAP evidence located after explicit deep search
WTCWisetech Global LimitedNo reliable RAP evidence located after explicit deep search
XROXero LimitedNo reliable RAP evidence located after explicit deep search

Method: explicit deep search run 2026-09-02 over the 38 ASX 100 constituents (constituent list: fnarena.com) previously marked “no plan located” in the full inventory; two passes per company, six company-specific query patterns per pass covering names, tickers, RAP stages, First Nations/Indigenous terminology, reports, Reconciliation Australia, archives and former names. 42 result rows: 14 validated findings across 10 companies and one explicit no-evidence row for each of 28 companies. Search-result contamination was manually constrained by exact company and domain checks; unrelated hits (e.g. other organisations' annual reports) were rejected. Results are not exhaustive; “unresolved” means no reliable public evidence was located in these searches. RAP performance reports and annual/sustainability-report mentions are counted as evidence of a plan, not as the standalone RAP document. Supporting-source counts and headline totals come from the deep-search result set as recorded.

This report was generated automatically by Keenable SELECT at a user's request, from publicly available web sources linked herein. Keenable does not review, verify, or endorse its contents and makes no representation as to accuracy, completeness, or timeliness; AI-based extraction may contain errors. Nothing in this report is investment, legal, financial, or other professional advice. All trademarks and referenced content remain the property of their respective owners; no affiliation or endorsement is implied. To report an error, rights concern, or request removal: legal@keenable.ai.

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