Data#3 Limited
GovernanceGovernance
Governance body oversight and management's role
The Board, the Audit and Risk Committee (ARC) and the Executive Management Team (EMT) have oversight of the Group's approach to sustainability related matters, supported by the Sustainability Working Group (p. 78).
Board (p. 79). Has ultimate responsibility for overseeing strategy, business plans, annual budgets and the risk management approach, and considers climate-related impacts in each. On climate change its responsibilities include setting risk appetite, approving a corporate strategy incorporating any material climate-related risks and opportunities, and approving and monitoring major capital expenditure, acquisitions and divestitures. The ARC and EMT report to it on sustainability at least twice a year. A skills matrix that references sustainability is updated annually.
ARC (p. 79). Oversees the risk management policy, framework and systems and reviews sustainability and climate risks reporting processes. Meets at least four times a year, at least two including sustainability reporting, risk and strategy discussion.
Management (p. 80). The EMT sets Group strategy, incorporating any material climate-related risks and opportunities. The Sustainability Working Group (EMT members and others) assists with the materiality assessment, sustainability strategy, a transition plan, and metrics and targets, reporting at least twice a year. Performance against specific sustainability goals is not factored into executive remuneration during this transition period.
StrategyStrategy
Climate-related risks and opportunities
Process (p. 80). Performed by external advisors with input from the Sustainability Working Group: a large panel of climate-related risks and opportunities was screened using peer review and risk modeling, narrowed down after internal evaluation, and prioritized by risk and opportunity management ratings and timeframe.
| Type | Risk or opportunity | Description (pp. 82–83) | Timeframe |
|---|---|---|---|
| Transition risk | Changing customer behavior | Customers' procurement preferences and requirements shift in response to climate change faster than Data#3 can adapt, reducing demand and revenue | Medium term |
| Physical risk | Weather risk | Infrastructure, operations and workforce affected by more frequent and severe weather events, including flooding and prolonged hot weather | Short, medium and long term |
| Opportunity | Stronger competitive advantage | Outperforming competitors by adopting sustainable practices and investing in climate-friendly technologies | Short, medium and long term |
| Opportunity | Development of new products or services | Novel offerings that address climate-related challenges or opportunities, involving investment in research and development | Short, medium and long term |
For strategic decision-making, consistent with business planning and budgeting cycles, short term is 1 - 2 years, medium term is 3 - 5 years and long term is beyond 5 years (p. 81). Separate horizons are used for scenario modeling (section 5.1.1, p. 81).
Business model and value chain
Value chain (p. 77). Upstream, the Group depends on key suppliers, key distributors and third party logistics and freight providers (predominately Australia, then the US, Singapore, UK among others). Downstream, it sells to customers and uses third party logistics providers (Australia and the Pacific Islands (Fiji, PNG)). The Group states it has assessed its own operations and its value chain (p. 76).
Where risks and opportunities sit (pp. 82–83). The risk and opportunity table lists value chain stages covered: changing customer behavior (Operations, Downstream); weather risk (Operations); stronger competitive advantage (Operations, Downstream); development of new products or services (Operations, Downstream).
Effects named in the scenario analysis (pp. 84–85). High emissions scenario: flood risk sensitivity for the Brisbane office in particular, heat waves affecting labor productivity and business interruption in warehouses (power loss or blackout), and higher insurance premiums. Low emissions scenario: more abrupt and unpredictable changes in customer behavior. All scenarios: early engagement to support decarbonization of the value chain.
Strategy and decision-making
Resourcing (p. 81). Resource allocation is not expected to be materially changed in the short term. Resources will be required to address climate-related risks and opportunities but are not expected to be significant. Future resource allocation will be fine-tuned as part of the financial assessment process and completion of the transition plan.
Mitigation and adaptation efforts (pp. 82–83). Weather risk: flood mitigants installed at one flood prone location, review of flood risk in potential new locations, heat-management measures including dedicated cooling and refreshment rooms, negotiating solar panels at existing premises, and NABERS ratings to assess new tenancies. Customer behavior: engaging top customers and suppliers on sustainability expectations, customer surveys, and training for frontline sales. Opportunities: discussions with vendors on low carbon solutions, sales training, and integrating AI capabilities.
Transition plan (p. 87). The Group is in the process of finalizing a transition plan outlining the pathway to reach climate-related targets once set. Once finalized it will be substantiated by science-based targets, including decarbonization levers, and will include details on the Group's capacity to adjust or adapt strategy over the short, medium and long term, along with planned resource allocation. The initial decarbonization strategy focuses on renewable energy across all sites and influencing key vendors and customers.
Financial position, financial performance and cash flows
Approach (p. 81). From FY2026 the Group initiated an annual process to assess the impact of climate related risks and opportunities on its current and anticipated future financial position, business prospects, financial performance and cash flows, to be refined over future reporting periods. The initial high level assessment, based on best estimates, available data and current analysis, is noted in the table.
| Risk or opportunity (pp. 82–83) | Anticipated financial effects |
|---|---|
| Changing customer behavior | Decreased revenue due to inability to meet customer requirements or demand for products and services. Financial impact unable to be calculated |
| Weather risk | Reduced revenue from supply chain and service provider disruption, increased cost due to loss of product stock, increased costs for building repair, maintenance and insurance. Anticipated financial impact due to increased costs varies from $1-$2m |
| Stronger competitive advantage | Increased revenue due to higher demand for low carbon IT equipment. Financial impact unable to be calculated |
| Development of new products or services | Increased revenue due to market preference for energy efficient products. Financial impact unable to be calculated |
Anticipated financial effects are subject to significant measurement uncertainty: with limited data to forecast the effects of the transition plan on consumer behavior, there is a wide range of potential outcomes over the medium to long term (p. 78).
Climate resilience and scenario analysis
An initial climate scenario analysis was performed in FY2026 at group level, covering all operating sites, with an external expert. Transition risks use NGFS (Network for Greening the Financial System) scenarios and physical risks use IPCC (Intergovernmental Panel on Climate Change) scenarios (pp. 83–84).
| Scenario (pp. 84–86) | Stated assumptions | Transition / physical risk |
|---|---|---|
| Very Low emissions (NGFS – Net Zero 2050 & IPCC 1.5C World) | Warming below 1.5°C, global net-zero CO2 around 2050, ambitious policy action begins immediately | Transition significantly elevated / physical relatively low |
| Low emissions (NGFS – Delayed transition & IPCC SSP1-2.6) | Emissions flat until around 2030, then substantial and rapid policy intervention to limit warming below 2°C | Transition and physical both higher than very low |
| High emissions (NGFS – Current Policies & IPCC SSP5-8.5) | No policies beyond those already implemented, continued growth in global emissions until around 2080, warming of approximately 3-4°C by 2100 | Transition low / physical high |
Modeling horizons (p. 81): physical baseline 1985, then 2030, 2050 and 2090; transition baseline 2025, then 2030, 2040 and 2050. Executive management considers the results when determining whether to revise or refine strategy or business planning, and the analysis will be reviewed annually (pp. 83–84). A summary table (p. 86) shows sensitivity rating levels by scenario and time horizon.
Risk ManagementRisk Management
Processes for identifying, assessing and managing climate-related risks
Process (pp. 79–80). Climate-related risks and opportunities were screened from a large panel based on peer review and risk modeling, narrowed down after internal evaluation, and prioritized by risk and opportunity management ratings (likelihood of occurring and consequences) and the timeframe in which they would likely materialize (p. 80). A risk register database is maintained, and risks including climate-related risks are prioritized in a consistent manner using an internally developed risk management system (p. 79).
Approach (p. 87). A structured approach uses inputs and parameters such as historical climate data, predictive models and market research analytics, and management uses climate-related scenario analysis. Opportunities are identified and assessed using similar processes.
Integration and review (p. 87). The processes are integrated into the overall risk management framework and reviewed regularly in line with other items in that framework. Additional reviews would be triggered by a material change to business function, acquisitions or divestments, strategic and long-term planning, or significant related regulatory changes.
Metrics & TargetsMetrics and Targets
Climate-related metrics
FY26 GHG emissions (p. 87). The Group's total absolute gross GHG emissions, measured in tonnes of carbon dioxide equivalent (tCO2-e):
| Emissions scope | GHG Emissions (tCO2-e) with Location-based Electricity |
|---|---|
| Scope 1 | 42 |
| Scope 2 | 410 |
| GHG Emissions | 452 |
Method (pp. 77, 87–88). Measured under the GHG Protocol Corporate Accounting and Reporting Standard, using the operational control approach for the organizational boundary. Scope 2 uses the location-based method. Global Warming Potential (GWP) values are from IPCC's Sixth Assessment Report (AR6), and four gases are considered relevant: CO2, CH4, N2O and HFCs. Scope 1 uses actual refrigerant top-up data where available for a proportion of the portfolio, otherwise area-based estimates. Scope 2 uses utility invoices, with proxy data or area-based estimates where data is missing. The report notes inherent uncertainty from reliance on third party activity data and emission factors (p. 78).
Climate-related targets
Initial target (p. 87). The report states: the initial targets are for Data#3 to commit to reduce scope 1 and 2 GHG emissions by 63% by 2035 from a 2025 baseline year, with decarbonization levers focused on the substitution of scope 2 fossil fuels for renewable electricity.
| Detail | As stated |
|---|---|
| Metric | Scope 1 and 2 GHG emissions |
| Reduction | 63% |
| Target year | 2035 |
| Baseline year | 2025 |
| Decarbonization levers | Substitution of scope 2 fossil fuels for renewable electricity |
Related statements. The transition plan outlines the pathway to reach climate-related targets once set and, once finalized, will be substantiated by science-based targets in line with the framework from Science Based Targets Initiative (p. 87). The Sustainability Working Group recommends and develops metrics and targets and reviews progress (p. 80). Time horizons used for setting metrics and targets are short term (1 - 2 years), medium term (3 - 5 years) and long term (beyond 5 years) (p. 81).