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CSL Limited

ASX: CSLIndustry: Pharmaceuticals & BiotechnologyAuditor: Deloitte Touche TohmatsuFY2026Group: Group 1
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GovernanceGovernance

AASB S2 paragraphs 5–7, Aus7.1

Governance body oversight and management's role

Reported

Governance bodies and management (p. 143). The Board holds primary responsibility for defining climate-related strategic objectives and risk appetite. The Audit and Risk Management (ARMC) sub-committee oversees material climate-related risks and opportunities, target setting and progress, and reviews and approves climate-related targets, including the science-based target. The Human Resources and Remuneration Committee (HRRC) oversees executive remuneration, including climate-related considerations for short-term incentives. The Corporate Governance and Nomination Committee (CGNC) reviews a Board skills matrix that includes one Director with climate-related risk and opportunity skills.

Global Leadership Team (GLT) members are accountable for the transition plan, managing climate-related risks and opportunities and reporting target performance to the ARMC. The Chief Financial Officer's team oversees assessment of financial impacts; the Chief Operating Officer's team, transition plan delivery; and the Group General Counsel's team, biannual reporting to the ARMC. A Sustainability Disclosure Steering Committee oversees report preparation.

Frequency and controls (p. 144). ARMC: climate-related risks and opportunities at 2 of 6 meetings, target performance at 2 of 6. Controls include Enterprise Risk Management Framework integration, internal verification of climate data and external assurance over climate data and metrics.

Company index: 6(a), 6(b), p. 143.

StrategyStrategy

AASB S2 paragraphs 10–11

Climate-related risks and opportunities

Reported

The report identifies two physical risks, two transition risks and one opportunity that could reasonably be expected by external stakeholders to affect CSL's prospects. It states that CSL has assessed them as not material and discloses them to provide transparent and useful information (p. 145).

ItemCategoryTime horizon
Physical risk 1: increased heat stress impacts operations, either through energy disruptions or increased energy demand (p. 146)Acute and chronicMore pronounced over the medium- to long-term
Physical risk 2: extreme weather events damage parts of CSL's value chain, reducing operational capacity (p. 147)AcuteMore pronounced over the medium to long term
Transition risk 1: increased carbon pricing may increase costs of materials, logistics and energy pricing (p. 148)Market and technologyMore pronounced over the medium to long term
Transition risk 2 and Opportunity 1: increase climate leadership and ambitions to meet customer expectations (p. 149)Market and reputationMore pronounced over the medium to long term

Time horizons (p. 145): short term up to 2030, medium term 2030–35, long term 2035–50, each with a stated rationale (the science-based near-term targets; business strategy and operational planning; net-zero climate scenarios and where physical impacts are most pronounced).

Company index: 10(a)–(d), pp. 146–149.

AASB S2 paragraph 13

Business model and value chain

Reported

Each risk table has a "Current and potential impacts and location in the business model and value chain" row.

  • Physical risk 1, heat stress (p. 146): black-outs and brown-outs could interrupt operations and create quality issues for temperature-controlled products; extreme heat increases energy used for cool and cold storage. Financial impacts anticipated to be most pronounced across cool- and cold-store facilities in America and Europe.
  • Physical risk 2, extreme weather (p. 147): damage to facilities, plasma donor centers, sites and third-party logistics suppliers disrupts supply of products; impacts anticipated to be more pronounced in Europe and America.
  • Transition risk 1, carbon pricing (p. 148): higher costs of products and services procured; exposure expected to be concentrated across the plasma collection network and energy-intensive manufacturing, including plasma fractionation, and manufacturing facilities in Australia and North America over the short to medium term.
  • Transition risk 2 and Opportunity 1 (p. 149): failure to meet customer expectations could reduce or block market access; meeting them could help secure wider market access. More pronounced in European markets in the short term.

Value chain scope (p. 145): 17 owned sites representing greater than 90% of total fixed asset value, excluding leases and impairments, plus value chain workshops on the upstream and downstream supply chain.

Company index: 13(a)–(b), p. 145 and pp. 2–3.

AASB S2 paragraph 14

Strategy and decision-making

Reported

Responses are in the "Adaptation measures" row of each risk table (pp. 146–149).

  • Heat stress (p. 146): backup energy generation at key assets, controlled energy load shedding, ability to prioritize cool and cold storage; anticipated asset upgrades to reduce reliance on backup generation.
  • Extreme weather (p. 147): site emergency response plans, contingency and secondary suppliers, alternative supply routes assessed in business continuity planning; anticipated asset maintenance (roof leaks, flood protection such as bunds) and investment in alternative supply routes.
  • Carbon pricing (p. 148): partners with top suppliers and assists them in setting science-aligned emissions targets; supplier due diligence to consider decarbonization commitments.
  • Customer expectations (p. 149): sustainability strategy with Healthier Environment commitments; assessing the lifecycle of key products.
  • Transition plan, under Metrics and Targets (p. 151): five abatement levers (new site design, electrification, energy efficiency, renewable energy, fuel switch). Some levers depend on factors beyond CSL's control, such as regulator review and approval of manufacturing processes (p. 152).
  • Resources (p. 153): capital allocation assessed case by case; capital spending on key initiatives such as energy efficiency projects and electrification of end-of-life equipment is immaterial; renewable energy procurement costs below $1 million.

Company index: 14(a)–(c), pp. 145–149.

AASB S2 paragraphs 15–21

Financial position, financial performance and cash flows

Reported

Each risk table has a "Financial effects" row (pp. 146–149). For all four, current effects are stated as no material impact on financial position, financial performance or cash flows for financial year 2026, and management concluded that no material adjustment to carrying amounts of assets and liabilities is expected within the next financial year.

ItemAnticipated effect stated
Physical risk 1 (heat stress)Indicative $3 million per annum in the short to medium term, described as financially immaterial; "nominal and manageable" over the medium to long term (p. 146)
Physical risk 2 (extreme weather)Median estimated annual cost of $7 million over the medium to long term at direct sites; not expected to be material at Group level in the short term. A footnote says a 1-in-100-year flood could cause materially higher impacts in that year (p. 147)
Transition risk 1 (carbon pricing)Around $25 million per annum, less than 1% of total operating expenses (p. 148)
Transition risk 2 and Opportunity 1Assessed qualitatively; measurement uncertainty is such that a quantitative estimate would not be useful; not assessed over the medium to long term (p. 149)

Where effects could be quantified, the report says they are not, individually or in aggregate, financially material across any time horizon (p. 145).

Company index: 15(a)–(b), pp. 146–149; 16(a)–(d), pp. 150–151.

AASB S2 paragraph 22

Climate resilience and scenario analysis

Reported

Scenarios (p. 150). Scenario analysis was conducted in the reporting period. Transition risks used the Network for Greening the Financial System (NGFS) Net Zero 2050 scenario (1.5°C low emissions, high transition risk). Physical risks used a high emissions scenario anticipating 4°C global warming by 2100, developed by the Intergovernmental Panel on Climate Change (IPCC): Shared Socioeconomic Pathway (SSP) 5–8.5. Transition risks were not assessed under the high emissions scenario, nor physical risks under the low emissions scenario, as they were determined unlikely to be material. The scenarios were selected to stress-test CSL's business: a worst case for physical risks, and consistent with the Paris Agreement aligned to a less than 2°C pathway for transition risks. Quantitative physical climate data covers 17 operational sites, with qualitative narrative for the wider value chain (p. 151).

Resilience (p. 150). Under the high emissions scenario, where quantifiable, financial effects of physical risks were found not to be material and CSL's strategy and business model are assessed to be resilient. Under the low emissions scenario, financial effects of transition risks were found not to be material. Areas of uncertainty and key assumptions are listed for each scenario. An overall assumption is that no strategic responses or controls beyond those deployed or planned by 2030 are considered.

Company index: 22(a), 22(b), pp. 150–151.

Risk ManagementRisk Management

AASB S2 paragraphs 24–26, Aus26.1

Processes for identifying, assessing and managing climate-related risks

Reported

The process to identify, assess, prioritize and monitor climate-related risks and opportunities is built on, and informed by, enterprise risk management processes (p. 145).

  • Identification: an initial list came from internal data sources, the corporate risk register and prior climate risk and opportunity assessments. The 2022 assessment was the baseline, updated through targeted stakeholder engagement and further analysis of physical risk exposure. The latest assessment covered the value chain, including manufacturing facilities, laboratories, warehouses and logistics.
  • Prioritization: enterprise risk management matrix criteria, in line with other business risks: qualitative (reputation impact, regulatory exposure, environmental and people harm) and, where possible, quantitative (financial thresholds), considering likelihood and impact to give a risk rating. The same approach was applied to opportunities. Scenario analysis was used to understand likelihood and impact and to validate the risks and opportunities identified.
  • Monitoring: under the Enterprise Risk Management Framework alongside other operational risks; site physical risks in site-level risk registers; functional departments manage enterprise risks and opportunities, with GLT members accountable.

Company index: 25(a)–(c), p. 145.

Metrics & TargetsMetrics and Targets

AASB S2 paragraphs 29–31

Climate-related metrics

Partial
Partial disclosure: Scope 3 emissions are not in the Sustainability Report. It states that, in this first year of reporting under AASB S2, CSL applied the transitional reliefs for reporting Scope 3 emissions and comparative figures (p. 142), and that it voluntarily disclosed Scope 3 emissions in the Healthier Environment section of the Annual Report. That section (p. 35, outside the Sustainability Report) gives a total Scope 3 figure of 1,281 (Metric kilotonnes CO2 -e (KT)) for 25–26. The company index lists 29(a)(i)–(v) and says it is not a comprehensive summary of AASB S2 requirements.

Scope 1 and 2 (p. 152).

GHG emissions (MtCO2e)FY2026FY2025FY2024
Scope 1134,731134,810132,840
Scope 2 (market based)103,482151,590215,090
Total of gross Scope 1 and market-based Scope 2 GHG emissions238,213286,400347,930
Gross location-based Scope 2 GHG emissions213,156229,250248,620

Calculated in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004), using an operational control approach; no changes in measurement calculations or assumptions for Scope 1 and 2 (p. 155).

Other metrics (pp. 152–153). Physical: 41% of modeled sites (7 of 17) exposed, 0% (0 of 17) vulnerable. Transition: projected carbon cost 2030/business unit revenue ($ today) of $22 million for CSL Behring, $3 million for CSL Seqirus, negligible for CSL Vifor. Opportunities: 100% of assets and business activities aligned to the near-term science-based target. Capital: spending on key transition plan initiatives immaterial; renewable energy procurement below $1 million. Carbon price: no shadow internal carbon price in decision making. Remuneration: 5% of the GLT's total short-term incentive (STI) metric linked to sustainability, with the two emissions target objectives comprising 1.65% of total remuneration (p. 144).

Company index: 29(a)(i)–(v), pp. 151–154; 29(b)–(e), pp. 152–153; 29(f), p. 153; 29(g), p. 144.

AASB S2 paragraphs 33–36, Aus37.1

Climate-related targets

Reported

Target (p. 151). Reduce absolute Scope 1 and 2 greenhouse gas emissions by 42% by FY2030 against an FY2021 baseline. It is a gross market-based target validated by the Science Based Targets initiative (SBTi) and applies to the Operational Control boundary. The report says it takes into account the objectives of the Paris Agreement, and CSL intends to adhere to the latest international agreement on climate change (p. 152). Cross-industry standards were used because no decarbonization target standards or frameworks were identified for its sector. CSL is not relying on carbon offsets or carbon credits for the short term (2030), excluding renewable energy credits. Gases covered: CO2, CH4, N2O, HFCs, SF6 and PFCs.

Progress (p. 152), reviewed biannually by the ARMC against projections. The target was validated in FY25 and the FY21 baseline aligns to the updated and validated target baseline.

GHG emissions targetUnitsCurrent year FY2026Base year FY2021Progress to date
42% absolute gross Scope 1 and 2 GHG emissions by FY2030mtCO2e238,213331,20528%

Five abatement levers support the target and CSL does not anticipate a linear reduction to 2030 (p. 151). The Scope 3 target is not set out in this report, which refers readers to the Healthier Environment section on p. 34 (p. 151).

Company index: 33(a)–(h), 34(a)–(d), 35, pp. 151–153; 36(a)–(d), pp. 154–155; 36(e), p. 151.