Pepper Money
GovernanceGovernance
Governance body oversight and management's role
Pepper Money's governance framework embeds climate-related risks and opportunities within its broader corporate governance structure. The Board holds the ultimate responsibility for overseeing these climate-related risks and opportunities including setting strategic direction, approving climate-related targets (if any) and metrics, and monitoring performance against any approved targets to ensure alignment with the Group's strategy and risk appetite.
To discharge these responsibilities, the Board delegates specific climate-related oversight to Committees as outlined in their Charters:
- The Board Environmental, Social and Governance Committee ("BESG Co") is responsible for providing oversight and feedback on the preparation of climate-related financial disclosures including proper verification and sign-off. BESG Co further oversees climate risk assessments and the integration of identified risks and opportunities into the Group's strategy.
- The Board Audit and Risk Committee ("BARC") monitors the identification, assessment, and management of material climate-related risks within Pepper Money's RMF.
- The Board Remuneration and Nomination Committee ("RemCo") ensures that the Group's Executive remuneration framework incorporates any ESG-related performance measures approved by the Board and assists the Board in the consideration and potential implementation of climate-related targets for remuneration.
BESG Co and BARC work together to provide a consistent and integrated approach to climate governance across the Group. BESG Co focuses on assisting the Board on strategic alignment and meeting climate-related disclosure obligations, while BARC assists the Board in respect to climate-related risk identification and management within the RMF. Insights from BARC's climate risk assessments inform BESG Co's oversight of disclosures and strategic integration, allowing for climate-related risks and opportunities to be addressed holistically across governance, risk, and compliance processes. This collaboration is reinforced through information sharing between the two Committees, as well as cross membership of the Committees by Directors.
Through these Committees, and via updates and papers, the Board ensures that any material climate-related risks and opportunities identified by the BARC or BESG Co are integrated into the Group's strategic planning, major transactions, and enterprise risk management processes. The Board also reviews and approves mandatory climate-related financial disclosures to confirm compliance with regulatory requirements. While climate-specific targets are not currently in place, the Board has approved other ESG-related metrics, detailed in the Environmental, Social and Governance ("ESG") Report 2025, which is included as part of the Group's 2025 annual reporting suite.
Board composition, expertise, skills and training
The Board comprises predominantly independent Non-Executive Directors who bring a diverse mix of experience, skills and perspectives. To ensure the Board collectively maintains the capabilities required for effective oversight, a Board Skills Matrix is used to map key competencies.
In 2025, Pepper Money enhanced its directors' climate-related knowledge and competencies through in-depth briefings by external experts and updates from the internal ESG Working Group. To support informed decision-making, the BESG Co and the BARC receive specialist presentations on material topics, including global sustainability trends, regulatory developments and technical climate-related matters. This process assists the Board in determining whether appropriate skills and capabilities are in place or need to be developed to oversee strategies addressing climate-related risks and opportunities.
Climate updates and strategic integration
Pepper Money's governance framework ensures that climate-related opportunities and risks are considered at both Board and Management levels.
The BESG Co meets at least three times annually, convening four times in 2025. At each meeting, Management provided structured updates covering climate governance, scenario analysis, material risk assessment, and developments in disclosure standards. Over 2025, particular focus was given to the anticipated implementation of AASB S2 and its implications for reporting and strategic positioning.
The Board is informed of climate-related opportunities and risks when there are material developments or matters requiring its attention, through referrals from the BESG Co and Management. This ensures that climate considerations are embedded in the Board's strategic oversight and decision-making processes. The Board's Charter states that the Board is responsible for evaluating trade-offs associated with climate-related risks and opportunities, particularly in the context of strategic planning, major transactions, and long-term value creation.
In 2025, the Board and Board Committees reviewed and updated their relevant charters to include climate-related considerations and matters. The BARC Charter includes climate-related risk as a formal consideration, and the BARC works with BESG Co to incorporate any identified climate risks into enterprise-wide processes. Both Committees review and update risk policies when there are material changes or developments that warrant updates, to ensure alignment with evolving climate-related risks and regulatory expectations.
Summary of the climate-related agenda items at CY2025 BESG Co meetings:
- Q1: Externally presented education session for Directors on climate-related disclosure, regulatory requirements and Director's duties. Review and update of BESG Co Charter to better reflect climate-related roles and responsibilities. Oversight of Management-level ESG (including climate-related) roles and responsibilities.
- Q2: Progress update on BESG Co Charter. Update from ESG Working Group on impact pathways, scenario analysis, Scope 1 and 2 emissions, and assurance timeline for climate-related disclosures.
- Q3: Endorsement of updated BESG Co Charter. External audit update on climate reporting assurance. Assessment of climate-related risks and opportunities, including materiality assessment on key value chain activities, time horizon determinations, scenario modelling and selection. Acquisition of third-party climate data. Integration of climate-related risk assessment into the Group's Risk Management Framework.
- Q4: Reviewed and approved climate risk quantification approach. Received a regulatory update on climate matters. Discussed draft Sustainability Reporting.
Management's role and accountability
Pepper Money has established a Management Environmental, Social and Governance Committee ("MESG Co"), chaired by the Group's Chief Financial Officer ("CFO"), which is responsible for implementing ESG strategies, including climate-related risks and opportunities. MESG Co's functions also include reviewing Pepper Money's environmental, social and sustainability priorities and commitments. The MESG Co meets four times annually in accordance with the MESG Co Charter.
The MESG Co is made up of Executives from across the business who bring extensive experience within their respective areas and deep knowledge of the Group. The collective expertise ensures that the Committee is well-equipped to oversee the implementation of strategies designed to respond to climate-related risks and opportunities within their different areas of the business.
To support its oversight role, MESG Co receives presentations and updates from the ESG Working Group at each meeting. The MESG Co facilitates the integration of climate-related risks and opportunities into the Group's operating framework and monitors progress against established priorities and commitments. MESG Co reports to the Board through the BESG Co, providing updates via formal papers and presentations at BESG Co meetings.
Incentives and remuneration
Pepper Money does not currently set climate-specific targets, and Executive remuneration policies do not directly reflect climate-related risks or opportunities. Broader ESG performance measures are incorporated into Short-Term Variable Remuneration ("STVR") for all eligible employees. For the CFO, 15% of STVR outcomes is allocated to the delivery of ESG AASB S2 reporting. Refer to the Remuneration Report 2025, for details on Pepper Money's Executive Remuneration Framework.
The BESG Co, in conjunction with the RemCo, will oversee the integration of climate-related considerations (if any) into Executive remuneration policies including the setting of targets related to climate-related risks and opportunities and monitoring progress towards those targets.
StrategyStrategy
Climate-related risks and opportunities
Pepper Money has identified the following climate-related risks that could be reasonably expected to affect the Group's prospects:
- Extreme weather events – Physical.
- Macro-economic transition risk – Transition.
An increase in frequency and severity of extreme weather events across insured (bushfire, flood, cyclone and storms) and uninsured perils (coastal inundation and coastal erosion) may impact the security underpinning each mortgage or asset finance loan contract, particularly where a shortfall in insurance is present impacting the borrower's ability to repay the loan liability. Transition risks will have a broader impact on the economy by driving up implied carbon prices placing upward pressure on key macro-economic variables such as inflation and cash rates that can impact Pepper Money's profitability. These outcomes could reasonably be expected to be more material in the medium to long term time horizons.
Time horizons
Pepper Money has defined the time horizons based on when the climate-related factors could reasonably be expected to occur. As at 31 December 2025, the following time horizons were identified:
- Short term (0 – 12 months) – the operational Budget is approved by the Board annually with specific focus on targets and deliverables in the oncoming year.
- Medium term (1 – 5 years) – aligns to the Group's strategic plan horizon of 5 years.
- Long term (up to 25 years) – aligns with the maturity of Pepper Money's Mortgage business segment and allows for meaningful outcomes of climate-related physical risk impacts in the scenarios to develop.
Information base used to identify risks and opportunities
In 2025, Pepper Money undertook a climate risk materiality assessment to better understand how climate-related risks and opportunities could influence its Business Model, operations, and financial performance over the defined time horizons. The assessment was designed to identify the most relevant climate-related risks and opportunities across the group's Value Chain, define time horizons aligned with the Group's planning cycles, and evaluate the potential impacts under a range of plausible climate scenarios.
Pepper Money's assessment commenced with an impact pathway analysis across five key Value Chain activities identified that support the Group's Business Model and drive financial performance: Mortgage lending portfolio; Asset Finance (vehicle/equipment) lending portfolio; Loan servicing and operations; Funding (debt and equity investors); Corporate functions and employees.
For each of these activities, relevant climate-related risk factors were identified, including physical risks such as severe weather events, and macro-economic transition risks driven by shifts in policy, regulation, market expectations and stakeholder sentiment. Potential opportunities were also considered, including the growing demand for climate mitigation financing. Management was engaged to validate the relevance and implications of identified risks and opportunities.
For each identified climate-related risk or opportunity, the Group assessed its potential significance by evaluating both the likelihood of occurrence and the magnitude of impact across financial, customer, regulatory, operational and reputational dimensions. These assessments were conducted leveraging the Group's existing RMF. Financial impacts were assessed over short, medium, and long term horizons, aligned with Pepper Money's strategic planning periods. The assessment reflected both quantitative insights using data available to the Group, and qualitative considerations where Management judgement was applied. The assessment process was performed by the ESG Working Group, and with the endorsement of the MESG Co and the process and outcomes approved by the BESG Co.
Pepper Money currently finances sustainable assets, including electric vehicles ("EVs"). At this time, no climate-related opportunities were assessed as material in CY2025.
Business model and value chain
Physical risk - Business Model and Value Chain effects
Lending portfolio and customers: The Group expects extreme weather events to have minimal impact on its Australian Residential Mortgages portfolio and the Asset Finance portfolio, and its customers in the short to medium term. Concentration risk is minimal due to the geographic dispersion of customers and asset locations. More material impacts are expected in the long term, specifically the impacts to downstream customers if climate events become more severe and the rate of occurrence increases. Assets subject to high risk climate factor exposures have a higher risk of damage from acute physical events which, depending on the appropriate level of insurance coverage, can have an impact on the borrowers' ability to repay their loan, giving rise to probability of default and loss given default. This can impact the Group's ability to recover the debt outstanding on the security on the loan.
Business Model: Pepper Money expects that the impact of physical risks will be insignificant on the Business Model – earning income through the provisioning of lending and servicing activities – in the short to medium term but expects changes to credit assessment policies and portfolio monitoring in the long term to minimise the impact of physical risks.
Operating offices: Physical risks have less impact on the Group's business operations as the geographical locations of the Group's offices are less susceptible to acute physical risks resulting in severe damage. Pepper Money has adequately reduced the disruption to operations through the development and implementation of its business continuity plan ("BCP") that enable and support employees to conduct business operations remotely, as part of the work from home option.
The Group's operating locations include: Australia; New Zealand; The Philippines. In CY2025, the Philippines office was subject to three typhoon events and the impact was minimal. These events did not cause major disruptions to Pepper Money's operations as a result of business resilience measures including activation of the BCP for the Manila office, work from home directions and emergency guidance, 'work from home' assessments and ergonomic set-ups, real-time updates through corporate communications channels, and check-ins with affected employees including allowances for compassionate leave and flexible work schedules.
Transition risk - Business Model and Value Chain effects
Changes in consumer preferences toward more sustainable housing or assets, including increased adoption of EVs, are not expected to materially affect Pepper Money's ability to provide financing. The Group anticipates continuing to support lending activity across asset classes that evolve in line with consumer demand. Based on information available in the current reporting period and across the relevant time horizons, there is insufficient evidence to indicate that the carrying value of security properties or existing internal combustion engine ("ICE") vehicle collateral will be significantly affected by shifts in consumer preference.
As market expectations and climate policies evolve toward a lower carbon economy, certain industries may be more susceptible to transition related risks. Management considers that these risks are most likely to affect the Group's downstream borrowers through potential impacts on the industries in which they are employed or operate, which may in turn influence their borrowing capacity and ability to meet repayment obligations.
To assess this exposure, Pepper Money has analysed borrowers' employment industries using Australia and New Zealand Standard Industrial Classification ("ANZSIC") codes to identify the proportion of borrowers operating within sectors considered vulnerable to transition risk. As at 31 December 2025, the proportion of borrower's employment industry deemed vulnerable to transition risk:
| Proportion of segment lending AUM % | Mining | Agriculture, Forestry and Fishing | Electricity, Gas and Water Services | Total exposure to industries with heightened transition risk |
|---|---|---|---|---|
| Mortgages | 0.83% | 0.45% | 0.51% | 1.79% |
| Asset Finance | 2.07% | 2.17% | 1.62% | 5.86% |
The rate of transition to a lower carbon economy, including potential changes to carbon pricing, may influence inflationary pressures and, consequently, cash rate settings across the short, medium and long term. These macro-economic impacts may reasonably be expected to affect Pepper Money's Business Model and Value Chain, including the Group's capacity to generate new originations in a higher cash rate environment, the Net interest income earned on lending assets, increased Corporate interest expense, and inflation-driven cost pressures on Operating expense.
Where risks and opportunities are concentrated
Australian Commercial Real Estate and New Zealand Mortgages are 7% and 4% (total 11%) of Total Mortgages Lending AUM at December 2025 and deemed not to be material in this assessment. The Group's primary financial exposure continues to arise from its lending activities and the credit performance of borrowers, rather than from the underlying security asset type, particularly in vehicle financing.
Strategy and decision-making
Physical risk - strategy and decision-making
Current and anticipated changes to Business Model and resource allocation: There is no material impact on the Group's financial outcomes in the short term arising from acute physical risks. The Group anticipates that, over the medium to long term, adjustments to its lending portfolio may be required to address the increasing severity and likelihood of acute physical events. These adjustments are expected to include enhanced integration of climate-related risk metrics into credit assessment policies and portfolio monitoring processes. In addition, an increase in hardship requests may place additional demands on customer contact and servicing centres. The Group will invest in the acquisition of external data to support and enrich assessment and analysis of physical risk impacts. Resource allocation continues to prioritise internal funding and leverage existing human resources to implement these measures.
Direct mitigation and adaptation efforts: The Group supports customer financial resilience through hardship assistance programs. Measures, such as SMS engagement following natural disaster events, are implemented to offer hardship support and mitigate potential credit risk. To ensure operational continuity, all employees have access to resources and technology that enable remote working. The Group anticipates in its forward-looking strategy to incentivise property-level resilience upgrades to include: installing flood barriers; elevating homes in flood-prone areas; supporting retrofits for bushfire resilience; and reinforcing roofs to withstand cyclones.
Indirect mitigation and adaptation efforts: Current mitigation efforts include active monitoring of geographic concentration of the lending portfolio to reduce exposure to areas vulnerable to insured and uninsured perils and reduce concentration risk. Portfolio assessment by specific peril and risk banding are prepared to monitor exposure. Mitigations that could be adopted include annual insurance verification of borrowers, including protecting against specific physical risks as part of the loan conditions. The Group anticipates adaptation measures to include ongoing refinement of underwriting processes to incorporate climate-related risk indicators into property valuation models to steer lending towards more resilient assets.
Climate-related transition plan and key assumptions: Pepper Money's forward-looking strategy includes continued integration of climate considerations into risk governance and credit decision-making. The Group anticipates that physical risk impacts will increase in the long term based on the current lending profile. Dependencies include the availability of reliable climate risk data that can be used to inform credit risk assessment practices.
Achievement of climate-related targets: At this time, the Group has not established quantitative targets specifically in relation to physical climate risks.
Transition risk - strategy and decision-making
Pepper Money monitors transition risks arising from evolving climate policies and changes in consumer preferences, notably the increased adoption of EVs, energy efficient housing, and tightening regulatory standards. The Group's approach encompasses direct measures embedded in products and risk frameworks, and indirect measures that build organisational resilience, capability, and ecosystem readiness.
Current and anticipated changes to Business Model and resource allocation: During the current reporting period, no material changes to the Group's Business Model or resource allocation have been required. The Group has considered the growing transition toward EVs as an emerging preference. At present, these trends are not expected to have a material impact on the Group's operations. The Group continues to monitor the relative value trajectory of ICE vehicles compared with EVs to inform future lending strategies and credit risk settings. Any resource requirements associated with these initiatives are expected to be met through internal funding and existing workforce capacity.
Current mitigation and adaptation:
- Sector exposure monitoring: Borrowers' employment industries are mapped using ANZSIC classifications to identify segments with heightened transition sensitivity.
- Portfolio stress testing: Targeted stress tests consider scenarios of elevated cash rates and inflation linked to carbon pricing and policy shifts, assessing impacts on Net interest income, Corporate interest expense and Operating expense.
- EV financing: EVs represent 15% of total vehicles financed in CY2025 (based on number of EV loans excluding hybrids originated in CY2025).
- Internal assessment: Strengthening data, modelling and reporting capabilities to assess business resilience and to evaluate future transition pathways.
Anticipated mitigation and adaptation:
- Residual value protection: Defending against asset value deterioration through guaranteed future value programs for both ICE and EVs.
- Risk appetite and limits: Formal exposure limits for transition vulnerable sectors and asset types, with periodic reviews and escalation triggers.
- Funding strategy alignment: Exploration of investor demand (e.g., labelled tranches when feasible) to diversify and stabilise funding under climate-linked macro volatility.
- Industry engagement: Ongoing participation in industry forums such as Australian Finance Industry Association and Risk Management Association to anticipate adaptation pathways including vehicle standards and building energy requirements.
- Product innovation: Product development to expand on sustainable financing such as financing rooftop solar installations, energy-efficient home construction loans, and retrofit solutions for existing properties.
- Servicing and customer support: Proactive outreach to borrowers in transition exposed industries (using ANZSIC mapping) with budgeting tools, hardship pathways, or tailored restructuring options. Provide information hubs on policy impacts to help customers plan asset choices and household upgrades.
- Internal capability building: Training staff on the impact of transition risks and emerging policy drivers.
Climate-related transition plan and key assumptions: The Group assumes increasing regulatory and market preference for low-emission assets, particularly EVs, over the medium to long term. Dependencies include the pace of EV adoption, infrastructure development, and government incentives. Pepper Money's approach to climate-related transition risk is first to understand the impact that can be reasonably expected before committing to formal transition plans. Product teams continue to look for opportunities to develop new products that cater to consumer demand now with the added impact of climate considerations on change in preference. Internally, Pepper Money will continue to monitor downstream customer exposure to industries vulnerable to transition risk through regular review and reporting using ANZSIC codes.
Achievement of climate-related targets: The Group has not set greenhouse gas emissions targets, as its operations have a low direct emissions profile.
Investment in climate-related mitigation, adaptation and opportunities
The Group is prioritising investment of internal resources to strengthen resilience against climate-related risks. Key initiatives include: enhancing credit assessment frameworks to incorporate climate-related considerations in evaluating loan security; developing new lending products designed to promote financing of energy-efficient assets; and exploring funding mechanisms and incentives to support the expansion of sustainable financing initiatives.
Financial position, financial performance and cash flows
Current financial effects
Physical risk: For the year ended 31 December 2025, one Asset Finance customer was impacted by a flood event, which resulted in $0.1 million residual loss to Pepper Money. The Group has not identified any other matters that are expected to result in a material adjustment to the current year's carrying values of assets or liabilities, nor any matters that are expected to have a material impact on the Group's income statement within the current annual reporting period.
Transition risk: For the year ended 31 December 2025, Pepper Money did not experience any material impact on its financial position, financial performance, or cash flows directly attributable to transition risks. There is insufficient evidence to indicate that the carrying amounts of the Group's assets were subject to material adjustment during the current reporting period as a result of transition risk factors.
Current and anticipated financial effects from physical risk ($ million)
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| Financial position (Loans and Advances) | (0.1) | 0 – (0.1) | 0 – (0.5) | 0 – (1.3) |
| Financial performance (Loan loss expense) | (0.1) | 0 – (0.1) | 0 – (0.5) | 0 – (1.3) |
| Cash flow (Funding cash flow) | (0.1) | 0 – (0.1) | 0 – (0.5) | 0 – (1.3) |
Pepper Money has elected to disclose these outcomes as a range, where the probability of loss arising from severe weather events extends from zero up to the estimated expected credit loss (gross loss before income tax).
Current and anticipated financial effects from transition risk ($ million, gross impact before income tax)
| Current (Actual) | Short Term (NDC) | Medium Term (NDC) | Long Term (NDC) | |
|---|---|---|---|---|
| Financial position | – | – | – | – |
| Financial performance (Net interest income, Operating expenses and Corporate interest expense) | – | – | (1.0) – (2.0) | (0.9) – (1.7) |
| Cash flow (Operating cash flow) | – | – | (1.0) – (2.0) | (0.9) – (1.7) |
Short term macro-economic assumptions are aligned with Pepper Money's Expected Credit Loss ("ECL") models as represented in the financial statements (Note 8(B)(c)). The results have a marginal positive impact on financial performance and cash flow, however deemed immaterial.
Anticipated financial effects
Australian Residential Mortgages (physical risk): Using the RCP4.5 scenario, which represents the anticipated case, Pepper Money has assessed the potential exposure of its portfolio to physical climate-related risks caused by severe weather events. Based on this analysis, a very small proportion of properties are expected to be at high risk and vulnerable to physical impacts in the medium to long term. The financial effect in the short term is immaterial. In the medium to long term the pre-tax loss experience in the high range is estimated to be $(1.3) million.
Asset Finance (physical risk): Based on the small proportion of assets in very high risk areas and the low likelihood of severe damage, Pepper Money estimates the current and anticipated financial effects from the Asset Finance portfolio exposure to severe weather events to be immaterial. Whilst hail, which is covered under storm risk assessment, is expected to cause damage, the Group has not received any hardship requests due to hail events. There is insufficient evidence to suggest that a credit loss should be anticipated.
Transition risk: Under the NDC scenario adopted from the NGFS, transition risk is assessed as low due to gradual implementation of climate policies and slower technological change. This results in relatively stable macro-economic conditions, especially in the short term with inflation and unemployment remaining relatively benign. In the medium to long term, there is moderate to severe physical risk that results in reductions in economic growth. The modelling indicates: inflationary pressure increases marginally over the medium to long term which directly impacts other Operating expenses; cash rate target increases marginally over the medium to long term, which directly increases Corporate interest expense and is negatively correlated to Net interest income through increased cost of funding; short term financial impacts are immaterial; medium to long term impacts are primarily driven by modest uplift in inflation and cash rate targets thus increasing Operating expenses and Corporate interest expense. The high range of impact incorporates the additional effect from Net interest margin compression arising from cash rate target increase, based on historical sensitivities applied adjusted for rate of change.
Key assumptions and limitations (physical risk)
- Forward-looking assessments present challenges due to uncertainty of climate models and inherent limitations in data quality, coverage and reliability.
- Physical risk assessment was conducted on approximately 98.3% of Australian Residential loans, based on available and valid GNAF ID.
- RCP4.5 reflects moderate emissions and policy action, consistent with anticipated climate pathways.
- Estimates are based on current property exposure data and scenario assumptions; actual outcomes may vary.
- Due to the variable nature of extreme weather events these results are subject to significant uncertainty.
Key assumptions (transition risk)
- NDC scenario reflects gradual policy adoption and limited disruption to economic fundamentals.
- Physical risks embedded in the scenario cannot be separately excluded.
- Estimates rely on historical correlations and scenario assumptions, which may not fully capture future market dynamics.
Climate resilience and scenario analysis
A climate-related scenario analysis was performed to understand and evaluate the potential impacts of physical risks and transition risks reasonably expected to impact the Group's prospects, using a range of possible scenarios. The analysis was performed on CY2025 actuals with anticipated impacts forecasted in the selected time horizons to evaluate the resilience of the Group's Business Model and Value Chain.
Scope and methodology
- The scenario analysis was conducted across the Group's consolidated operations and business units.
- Scenarios were based on publicly available data from authoritative sources and purchased data reflecting regional climate projections relevant to Pepper Money.
- The analysis considered extreme scenarios typically characterised as: high transition risk / low physical risk; and low transition risk / high physical risk, reflecting the inverse relationship between emissions reduction requirements and warming outcomes.
The scenario analysis was reviewed and approved by the Group's Board and Management ESG Committees during CY2025, focusing on scenario selection, assumptions inputs, and modelled outputs. Ongoing annual reviews will be conducted to update implications of climate-related uncertainties and integrate findings into the Group's strategic planning cycle.
Scenario selection
| Scenario 1 (High transition risk / Low physical risk) | Scenario 2 (Intermediate) | Scenario 3 (Low transition risk / High physical risk) | |
|---|---|---|---|
| NGFS (transition risks) | Net Zero 2050 | NDC | Current Policies |
| RCP (physical risks) | RCP 2.6 | RCP 4.5 | RCP 8.5 |
Application and financial stress testing
For transition risk, macro-economic indicators derived from NGFS scenarios were applied to stress the Group's financial position, financial performance, and cash flows. Key business drivers assessed include: Originations; Net interest income; Operating expense; Corporate interest expense. Observed changes in macro-economic indicators were compared against historical trends to estimate scenario outcomes over selected time horizons.
For physical risk, additional portfolio-level analysis was performed to model potential loan loss impacts under various physical risk scenarios, using separately acquired exposure data (based on Finity Consulting Pty Ltd's models for expected credit loss).
Integration into strategy
Outputs from this analysis inform decision-making and risk management guardrails, ensuring the Group remains resilient under a range of plausible climate futures. These findings are embedded into strategic planning and reviewed annually.
Scenario analysis outcomes
Scenario 1 (Net Zero 2050 / RCP 2.6)
A pathway that is contingent on global warming levels being below 1.5 degrees, climate policies are introduced early and become gradually more stringent, shifts in customer behaviour are noted due to the preference for sustainable products.
- Short Term: Physical risk exposure: low. Transition risk exposure: low to medium. Governments and regulatory bodies will continue to introduce more rigorous emissions standards. Demand for 'eco' friendly and 'low carbon' products grow. The projected impact from an increase in carbon pricing will place upward pressure on inflation and consequently cash rate targets. The Group may experience marginal disruption on new originations but is predicted to have very little impact on volume. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.1) million from physical risk and between $(0.9) million to $(1.4) million from transition risk.
- Medium Term: Physical risk exposure: low. Transition risk exposure: medium to high. As climate change intensifies, more frequent and severe physical events may transpire increasing impact to the group's lending assets in high risk areas. Demand for 'eco' friendly or 'low carbon' products will steadily increase. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.1) million from physical risk and between $(1.3) million to $(4.4) million from transition risk.
- Long Term: Physical risk exposure: low. Transition risk exposure: medium to high. Strong momentum in the transition towards low-carbon products and global climate mitigation efforts will slow the rate of climate change, somewhat stabilising physical risks. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.2) million from physical risk and $(1.9) million to $(8.4) million from transition risk. Whilst the result is the highest degree of impact in this scenario analysis the Group is well-positioned to manage the transition in the long term and will have strategies in place to mitigate and adapt.
Scenario 2 (NDC / RCP 4.5)
An intermediate and most probable baseline scenario forming the 'anticipated' case.
- Short Term: Physical risk exposure: low to medium. Transition risk exposure: low to medium. The Group will notice the initial signs of regulatory changes. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.1) million from physical risk and zero impact from transition risk.
- Medium Term: Physical risk exposure: medium. Transition risk exposure: medium. More concrete regulatory frameworks will be in place, requiring the group to implement compliance measures. There will be some pressure that increased carbon pricing will impose on higher inflation and cash rate target. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.5) million from physical risk and between $(1.0) million to $(2.0) million from transition risk.
- Long Term: Physical risk exposure: medium. Transition risk exposure: medium. There will be a broader transition towards a low carbon economy, requiring increased adaption measures by the Group, but this is not expected to significantly change the Business Model or disrupt the Value Chain activities. Under this scenario the Group's profit before tax is expected to be reduced by up to $(1.3) million from physical risk and between $(0.9) million to $(1.7) million from transition risk.
Scenario 3 (Current Policies / RCP 8.5)
High emissions in the absence of government policies to combat climate change.
- Short Term: Physical risk exposure: low to medium. Transition risk exposure: low. Governments remain divided on climate action leading to a lack of coordinated action on emissions reductions. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.1) million from physical risk and $(0.3) million from transition risk.
- Medium Term: Physical risk exposure: medium to high. Transition risk exposure: low. A lack of robust climate-related policies from governments will keep transition risks low. Physical climate change impacts intensify posing higher risk specifically to lending assets. Under this scenario the Group's profit before tax is expected to be reduced by up to $(0.3) million from physical risk and $(0.3) million from transition risk.
- Long Term: Physical risk exposure: high to very high. Transition risk exposure: low to medium. Governments focus on short term adaptation measures as opposed to decarbonisation, keeping transition risks relatively low. The Group becomes increasingly vulnerable to physical climate risks. Under this scenario the Group's profit before tax is expected to be reduced by up to $(1.8) million from physical risk and $(0.6) million from transition risk.
Significant areas of uncertainty
There are areas of uncertainty on the extent, pace and impact of climate change on Pepper Money's business operations. Scenario analysis has been conducted on a broad spectrum of scenarios to ensure a range of potential physical and transition impacts are considered. There is regulatory policy uncertainty on emissions reduction targets, both globally and domestically, which may result in ongoing changes to targets and regulation. Policy changes may involve changes to regulatory reporting demands on the financial services sector. Changes to consumer behaviour across mortgage lending and asset finance products are also highly uncertain. There is uncertainty on the frequency and locations of severe climate events that may impact Pepper Money's operations and business prospects.
Capacity to adjust or adapt strategy and Business Model
The Group's strategy and Business Model, including its mitigation and adaptation plans are currently based on the most probable scenario (Scenario 2). The ESG Working Group, MESG Co and BESG Co periodically evaluate the Group's strategy to incorporate climate-related considerations.
Resources and flexibility: The Group has invested in climate-related data acquisition to enhance risk quantification and portfolio assessment across its lending activities. In addition, the Group has committed resources to learning and development initiatives to build internal expertise for assessing and reporting on climate-related risks and opportunities. Resource allocation is subject to periodic review, and the Group retains flexibility to adjust budgets as required. As disclosed in Note 5 of the Group's financial statements for the year ended 31 December 2025, the Group has access to additional financing through committed credit facilities should its response to climate-related risks require further funding. The Group also maintains the ability to deploy excess corporate cash to meet such requirements.
Redeploying, repurposing, and upgrading assets: Over the short to medium term, the Group does not anticipate a material requirement to redeploy, repurpose, or upgrade its physical assets, as it primarily occupies leased office space within multi-tenant buildings and has limited influence over energy sources. The Group has assessed potential impacts on the value of lending assets and found no evidence of material deterioration in the short to medium term. Over the long term, the Group will continue to evaluate its lending portfolio and may adjust its exposure to assets that no longer align with its strategic objectives or climate resilience criteria.
Risk ManagementRisk Management
Processes for identifying, assessing and managing climate-related risks
Integration into the Group's Risk Management Framework
Climate-related factors are integrated into Pepper Money's enterprise RMF and reflected in the Group's Risk Appetite Statement ("RAS"). A process was undertaken to identify, assess and prioritise climate-related risks and opportunities across the Group's operations during the reporting period. This process was embedded into the Group's enterprise risk management approach and supported by governance oversight through the Board and relevant Committees.
Prioritisation of climate-related risks was undertaken using the Group's risk matrix evaluation framework, applying criteria such as likelihood, magnitude of impact, and alignment with strategic objectives. Risks identified through the materiality assessment and scenario analysis were incorporated into existing risk categories, including credit, regulatory, operational, strategic, and reputational, and documented for ongoing governance oversight.
Monitoring of climate-related risks occurs through Pepper Money's established RMF processes and governance structures, which include ongoing risk reviews, escalation protocols, and reporting to the Board and Board Committees. These processes ensure that climate-related risks are tracked, assessed for changes in exposure, and escalated in line with the Group's risk appetite and governance requirements.
Operational accountability continues to follow the Three Lines of Accountability model:
- The First Line, comprising business units and operational teams, accountable for ownership and management of climate-related risks and opportunities within their day-to-day activities.
- The Second Line, Risk and Compliance, accountable for the RMF, providing tools and guidance for climate risk assessment, and independently monitoring the effectiveness of controls.
- The Third Line, Internal Audit, provides independent assurance to the Board and its committees on the adequacy of climate risk governance and control effectiveness. External auditors also contribute to the Third Line by providing assurance on financial statements and selected regulatory requirements.
Processes for identifying and assessing climate-related risks and opportunities
Pepper Money's approach to climate-related risk management commenced with an assessment of its consolidated operations and Value Chain activities, including mortgage lending, asset finance, loan servicing, funding arrangements, and corporate functions. The Group used a combination of internal portfolio data, external climate datasets, and scenario frameworks to inform its analysis.
Climate-related risks were recognised as drivers of existing risk categories, including credit, regulatory, operational, strategic, and reputational, and were identified through a Climate Risk Materiality Assessment. This assessment evaluated both physical risks, such as bushfire, flood, and cyclone, and transition risks, such as regulatory changes, carbon pricing, and shifts in consumer preferences.
The process applied both qualitative and quantitative techniques, using the Group's risk matrix to assess likelihood and impact across financial, regulatory, operational, customer, employee and reputational dimensions. Physical risk exposure was modelled at property level using geospatial data and RCP scenarios, while transition risk impacts were assessed through macro-economic modelling using NiGEM scenarios. Pepper Money applied three scenarios from the NGFS Phase V framework to assess potential climate-related risks and opportunities across short term (1 year), medium term (5 years), and long term (25 years) horizons.
Pepper Money has established processes to identify climate-related opportunities using the same approach applied for risk identification, namely, the Climate Risk Materiality Assessment and scenario analysis. These processes are designed to consider how shifts in policy, technology, and market preferences under different climate pathways could create opportunities for Pepper Money to support customers and enhance long-term resilience.
Governance of climate-related opportunities is embedded within Pepper Money's existing oversight structure. The BESG Co has reviewed and endorsed the approach to identifying and prioritising opportunities, ensuring that these considerations are integrated into strategic planning and risk management processes. While no material climate-related opportunities were identified during the reporting period, the framework remains in place to capture and assess potential opportunities in future periods.
As this is Pepper Money's first reporting period aligned to AASB S2, there have been no prior period processes for comparison.
Metrics & TargetsMetrics and Targets
Climate-related metrics
Greenhouse gas emissions
Pepper Money has calculated its Scope 1 and 2 emissions in accordance with the GHG Protocol – A Corporate Accounting and Reporting Standard (2004).
Setting the organisational boundary: Pepper Money has selected the Operational Control approach to determine its organisational boundary for the calculation of Scope 1 and 2 emissions. The Group applies the operational control approach when defining its GHG emissions boundary, which requires entities to report emissions from facilities where they have the authority to implement operating, health and safety, or environmental policies. As a non-bank lender, the Group does not exercise day to day operational authority over financed or secured assets, and therefore reports only those emissions it can directly influence – such as those arising from offices, data centres and corporate activities.
Scope 1 emissions
Approach, inputs and assumptions:
- Generation of electricity, heat or steam: Pepper Money has determined that there is no material emissions generated in this category. Pepper Money does not own any assets that directly produce emissions through generation of electricity, heat or steam. Pepper Money has engaged each office location to confirm that all energy is purchased from assets not owned by the Group. Purchased energy has been included in Scope 2 emissions.
- Fugitive Emissions: Pepper Money has collected registers of all refrigerants containing air-conditioning units and refrigerators that are owned or operationally controlled by the Group. Refrigerant capacity and types were obtained from air-conditioning unit and refrigerator model specifications to support calculation of emissions (if any). Pepper Money has relied on the actual top-up approach to calculate the amount of refrigerants that were released during 2025. Pepper Money obtained confirmations from office or building managers that no refrigerant top ups occurred in 2025 for any identified air-conditioning units or refrigerators.
- Transportation of materials, products, waste, and employees: Pepper Money has determined that there is no material emissions assigned with this category. Pepper Money does not own or control any company vehicles. Emissions from employee commuting are indirect and categorised as Scope 3.
As this is Pepper Money's first reporting period aligned to AASB S2, there have been no changes in methodological approach.
Pepper Money reports zero Scope 1 emissions for the consolidated Group:
| Scope 1 Emissions Category | Scope 1 t-CO2e |
|---|---|
| Fugitive Emissions | – |
| Total | – |
Scope 2 emissions
Approach: The Group has collated electricity invoice information from each office to determine the amount of kilowatt ("kW") usage occurred across the reporting period. Where offices did not have specific electricity invoices, building management was contacted to provide the Group with metered electricity usage. Calculations were conducted using the location-based approach which multiplies the kWh of electricity by the emissions factor for the geographic location. The following emissions factors were used: For office locations in Australia, emissions factors were obtained from the National Greenhouse Gas Accounts Factors 2025 released by the Department of Climate Change, Environment, Energy and Water ("DCCEEW"). For the New Zealand office, the emissions factor was obtained from the New Zealand Ministry of the Environment. For the Manila office in the Philippines, Pepper Money has estimated an emissions factor by taking an average of emissions factors released by Governments of 3 comparable countries (Vietnam, Malaysia and Thailand). This approach was undertaken as the Philippines Government does not release endorsed emissions factors.
Inputs: Electricity usage (kWh) for each office; Emissions factors from the National Greenhouse Account Factors 2025 (Australia); the Measuring Emissions Guide 2025 (New Zealand); the Department of Climate Change, Ministry of Natural Resources and Environment (Vietnam); the Energy Commission (Malaysia) and the Thailand Greenhouse Gas Management Organization (Thailand).
Assumption: The Group has applied electricity usage on a pro-rata day-count convention for invoices with periods that included both December 2024 and January 2025. The estimated portion for December 2024 was excluded. Not all monthly electricity usage invoices for 2025 were available at the time of reporting. In these instances, the Group calculated an average daily rate for each location based on available data and aggregated across a 12-month basis. As the Philippines does not have a government endorsed emissions factor for the local grid, Pepper Money has estimated the emissions factor based on comparable countries.
Justification: Pepper Money believes that the approach, inputs, and assumptions are reasonable given: they reflect the best estimate of indirect electricity-related emissions given the information available; and the Group did not purchase or engage in specific contractual instruments for the purpose of acquiring energy in the reporting period.
Pepper has calculated its Scope 2 emissions as follows:
| Scope 2 Emissions Category | Scope 2 t-CO2e |
|---|---|
| Indirect Electricity Usage | 678.18 |
| Total | 678.18 |
Scope 3
The Group has applied transition relief from disclosing Scope 3 greenhouse gas emissions, which includes, if the entity participates in asset management, commercial banking or insurance activities, the additional information about its financed emissions.
Transition risks
As at 31 December 2025, the proportion of borrower's employment industry deemed vulnerable to transition risk:
| Proportion of segment lending AUM % | Mining | Agriculture, Forestry and Fishing | Electricity, Gas and Water Services | Total exposure to industries with heightened transition risk |
|---|---|---|---|---|
| Mortgages | 0.83% | 0.45% | 0.51% | 1.79% |
| Asset Finance | 2.07% | 2.17% | 1.62% | 5.86% |
(ANZSIC codes are not known for 53% of Mortgage borrowers and 47% of Asset Finance borrowers. Borrowers with unknown ANZSIC codes are included in calculations to determine the exposures to industries vulnerable to transition risk.)
Physical risks
Australian Residential Mortgages loan exposure to physical risk as at 31 December 2025 ($ million):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| High Risk | 2.3 | 3.1 | 6.6 | 9.5 |
| Medium Risk | 26.7 | 26.0 | 31.2 | 35.6 |
| Very Low / Low Risk | 8,929.8 | 8,929.6 | 8,921.0 | 8,913.7 |
Proportion of Australian Residential Mortgages AUM as at 31 December 2025 (%):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| High Risk | 0.0% | 0.0% | 0.1% | 0.1% |
| Medium Risk | 0.3% | 0.3% | 0.3% | 0.4% |
| Very Low / Low Risk | 99.7% | 99.7% | 99.6% | 99.5% |
Asset Finance bushfire exposure as at 31 December 2025 (assets with highest 5% of bushfire risk score):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| AUM $ million | 215.0 | 215.0 | 280.6 | 369.4 |
| Proportion of Lending AUM | 3.3% | 3.3% | 4.4% | 5.7% |
Asset Finance flood exposure as at 31 December 2025 (highest 5% of flood risk scores):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| AUM $ million | 275.8 | 275.8 | 326.2 | 323.8 |
| Proportion of Lending AUM | 4.3% | 4.3% | 5.1% | 5.0% |
Asset Finance cyclone exposure as at 31 December 2025 (highest 5% of cyclone risk scores):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| AUM $ million | 305.2 | 305.2 | 323.3 | 393.4 |
| Proportion of Lending AUM | 4.7% | 4.7% | 5.0% | 6.1% |
Asset Finance storm exposure as at 31 December 2025 (highest 5% of storm risk scores):
| Current (Actual) | Short Term (RCP 4.5) | Medium Term (RCP 4.5) | Long Term (RCP 4.5) | |
|---|---|---|---|---|
| AUM $ million | 145.5 | 145.5 | 135.2 | 110.1 |
| Proportion of Lending AUM | 2.3% | 2.3% | 2.1% | 1.7% |
Opportunities
At this time, no climate-related opportunities were assessed as material in CY2025.
Capital deployment
Not separately quantified in the report beyond narrative descriptions of investment in climate-related data acquisition and learning and development initiatives (see Strategy 22 for related narrative).
Internal carbon prices
Pepper Money has not set an internal carbon price in the reporting period.
Remuneration
Executive remuneration policies do not directly reflect climate-related risks or opportunities. For the Chief Financial Officer, 15% of STVR outcomes is allocated to the delivery of ESG AASB S2 reporting.
Climate-related targets
Pepper Money has not set any targets in this reporting period. The Group has not set greenhouse gas emissions targets, as its operations have a low direct emissions profile. At this time, the Group has not established quantitative targets specifically in relation to physical climate risks. While climate-specific targets are not currently in place, the Board has approved other ESG-related metrics, detailed in the ESG Report 2025.