Santos Limited
GovernanceGovernance
Governance body oversight and management's role
The Board oversees Santos’ strategy and approves Santos’ strategic objectives annually. The Board monitors performance against the strategic objectives and plans throughout each year. Our approach to climate change is integral to our corporate strategy and supported by our Climate Transition Action Plan which sets out our response to our climate-related risks and opportunities.
The Board’s oversight of climate is supported by the following committees that meet at least three times a year:
- The Safety and Sustainability Committee supports the Board in overseeing Santos’ Climate Policy, including monitoring and reviewing climate-related targets set by the Board, and monitoring and reviewing performance and material risks and opportunities, including climate. Santos’ climate-related risks and opportunities form part of our company strategy and Climate Transition Action Plan (CTAP), which is reviewed regularly by the Safety and Sustainability Committee.
- The Audit and Risk Committee is responsible for assessing the effectiveness of the Risk Management Framework and that management is operating with due regard to Santos’ Risk Appetite Statement. This includes responsibility for assessing the effectiveness of the Risk Management Framework in identifying, monitoring and managing material climate-related risks. Santos’ Risk Appetite Statement supports the consideration of climate and requires that emissions are considered in decision-making processes. It defines tolerance to material risk in relation to our current strategic objectives. It provides transparency of the associated risks when reviewing a particular decision or transaction and in the conduct of operational activities. The Risk Appetite Statement is reviewed at least annually for ongoing alignment with strategic objectives. This enables risks and associated controls and risk management actions to be considered in our decision-making and enables a portfolio-wide focus on the delivery of the Company emissions reduction targets.
- The People, Remuneration and Culture Committee is responsible for the oversight of the remuneration policy and formulation of remuneration recommendations to the Board for the Executive Leadership Team and the Company more broadly. Since 2019, the Short-Term Incentive has included performance metrics that reward Key Management Personnel (KMP) for achieving sustainability and climate outcomes. In 2025, the Company Scorecard weighting for climate-related targets remained at 17.5 per cent (consistent with 2024) and included metrics relating to emissions intensity reduction and key decarbonisation projects. This further strengthens the link between climate considerations, and the outcomes of performance pay.
- The Nomination Committee assists the Board with succession planning. It proposes candidates for consideration by the Board to fill casual vacancies or additions to the Board, and devises criteria for Board membership, which includes experience with climate and energy transition.
Committee cross-memberships support consideration of climate issues with all four committees having specific climate-related responsibilities.
Management's role
Our strategy and CTAP are based on managing climate-related risks and leveraging climate-related opportunities. The CEO and Executive Leadership Team are responsible for delivering the strategy and goals approved by the Board. They are supported by their teams who monitor and assess trends and changes in Australian and international energy markets, and assess and model a range of energy mix scenarios based on varying market demand and policy and technology drivers. This analysis informs portfolio and asset reviews of our business and strategy. These teams are responsible for the implementation of appropriate controls and processes for climate-related risks to be overseen and effectively managed. To enable effective cross-functional communication on issues related to climate change and sustainability, Santos’ governance processes include meetings across a range of business groups and Executive Leadership Team meetings to enable conformance with the SMS and track delivery against plans and targets.
StrategyStrategy
Climate-related risks and opportunities
Santos summarises its physical and transition risks and opportunities in a table (pages 72–84), each classified as a transition risk (Political, legal, regulatory / Litigation and disputes / Reputational / Market / Technology) or physical risk, with a time horizon marked S (Short 0-1 yrs), M (Medium 1-5 yrs) or L (Long 5-30 yrs) for each.
Risks/opportunities identified include:
- Transition risk 1: Climate policy
- Transition risk 2: Climate-related litigation
- Transition risk 3: Environmental and/or shareholder activism
- Transition risk 4: Human capital
- Transition risk 5: Carbon emissions expectations
- Transition risk 6: Access to capital markets
- Transition risk 7: Reduced demand for products
- Transition risk 8: Transition technologies not scalable
- Transition risk 9: Failure to achieve emissions reduction targets
- Transition opportunity 1: Transition technologies
- Transition opportunity 2: Low carbon fuels
- Physical risk 1: Flooding in the Cooper Basin
Assessment of time horizons is consistent with internal planning horizons (One year Budget, Five-year plan and long-term plans) used to support decision-making (Short term 0-1 years, Medium term 1-5 years, Long term 5-30 years).
Santos uses climate-specific scenarios to support the identification of transition and physical climate-related risks and opportunities. Assessment includes the relative impact of Santos’ transition scenarios on each climate-related risk and opportunity and physical climate-related risks identified through scenario analysis and assessed as material.
Information base: Climate-specific scenario analysis is used to support the identification of climate-related risks and opportunities through our strategy process, long-term plans, major project design and resilience testing for reporting purposes. Physical risk scenario analysis has been integrated into regional business unit risk reviews for operated assets and used to support the identification of physical climate risks impacting material non-operated joint venture assets.
Business model and value chain
The risk tables (pages 72-84) each contain a 'Summary of impact to business model and value chain' for every identified transition and physical risk/opportunity, describing where in the business model and value chain the risk or opportunity is concentrated, for example:
- Transition risk 1 (Climate policy): affects the Australian domestic gas business and GLNG, including ability to develop future growth projects and meet supply commitments.
- Transition risk 7 (Reduced demand for products): affects Santos' oil, gas, LNG and related products sold under short, medium and long-term contracts.
- Transition risk 8 (Transition technologies not scalable): concentrated in the Midstream and Energy Solutions business unit, our decarbonisation business, with CCS hubs located in Western Australia, Northern Australia and Moomba.
- Physical risk 1 (Flooding in the Cooper Basin): concentrated in Cooper Basin operations, including wider infrastructure such as third-party roads and pipelines that could impact supply chain and transport of product to point of sale.
Each risk/opportunity also includes a 'Relevant metrics' section identifying the specific assets or business activities where the risk/opportunity is concentrated, e.g. '$2,539 million Exploration and evaluation assets (11 per cent)' for policy risk; '$2,034 million assets (9 per cent)' for Cooper Basin flooding, being the portion of Cooper Basin's oil and gas assets and decarbonisation assets as a percentage of total oil and gas assets and decarbonisation assets; '$4,833 million assets (22 per cent)' for transition technologies, being the portion of WA and QLD & NSW oil and gas assets as a percentage of total oil and gas assets.
The portfolio resilience section notes: 'Key to our resilience is our unique combination of low-cost, long life natural gas and liquids assets, CCS capability, potential low carbon fuels supply and nature-based solutions project optionality.'
The Santos' portfolio map (page 93) illustrates the future change in climate exposure across operated and non-operated assets under SSP5-8.5 by 2050 by region: Northern Australia and Timor-Leste, Western Australia, Cooper Basin, Queensland and New South Wales, Alaska, and Papua New Guinea, each with region-specific climate hazards.
Strategy and decision-making
Santos continues to invest in our core assets to deliver the critical fuels the world needs to meet global energy demand into the 2040s. Our strategy is focussed on our three horizon strategy: backfilling, sustaining and decarbonising Santos’ existing operations, continuing to build and grow through disciplined development of upstream resources, infrastructure and a commercial third-party carbon management business, and investing in the potential technologies needed to develop the low carbon fuels of the future as markets evolve.
We are seeking to meet our emissions reduction targets in line with our emissions hierarchy of avoid, reduce and offset. We prioritise avoidance and reduction of greenhouse gas emissions as a key lever towards decarbonising our business. However, we recognise that carbon credits are likely to be required to offset hard-to-abate emissions from both our own operations and the wider economy.
Climate Transition Action Plan (CTAP)
Santos’ CTAP represents our response to managing climate-related risks and leveraging climate-related opportunities. It outlines our current plan for decarbonising and transforming our business, and is founded on our emissions hierarchy of avoid, reduce and offset.
The CTAP is integral to Santos’ three-horizon strategy: backfill, sustain and decarbonise, build and grow, and low carbon fuels. Our reduction targets are guided by our emissions hierarchy of avoid, reduce and offset. For hard-to-abate emissions, Santos continues to build and invest in a portfolio of projects including multiple CCS facilities and nature-based projects with the potential to deliver carbon credits. We continue to look to the future at new technologies that may enable large-scale emissions abatement (such as DAC), as well as the supply of low carbon fuels, as market demand evolves.
It is expected that investment in our transition activities will initially focus on commercial decarbonisation and carbon management services, laying the foundation to support increased investment in low carbon fuels projects as technologies and customer demand evolve.
We have established internal capabilities to address our climate-related risks; and core expertise in the design, execution, delivery and operation of technological and nature-based carbon sequestration methods. Santos’ CTAP has been created with the intent of leveraging these capabilities.
The CTAP structure comprises: Operational efficiencies, Carbon solutions, Value chain collaboration, and Low carbon fuels hubs, underpinned by Carbon capture and storage. Key CCS projects: Moomba CCS (phase 1 online, phase 2 concept development in progress, 1.7 Mtpa >> up to ~10 Mtpa), Bayu-Undan CCS (phase 1, ~6.3 Mtpa), Western Australia CCS (phase 1 – Reindeer CCS, ~1 Mtpa), plus other CCS opportunities and potential technology development including DAC (commercial scale) and Synthetic Gas.
Updating our CTAP
Santos’ CTAP will continue to evolve to incorporate changes in the global energy transition environment. Our disciplined economic and commercial criteria are applied to inform investment decisions and create value for shareholders. Our CTAP is reviewed regularly by the Safety and Sustainability Committee, in line with Santos’ corporate planning process. Annual reduction targets are included in the Company Scorecard. Updates to our CTAP seek to reflect the progress of our initiatives and further evolutions of our strategy, including in response to developments in technology, global energy markets, government policies and customer demand.
Key assumptions and dependencies
Our CTAP includes current projections that are necessarily based on assumptions, contingencies and commercial judgement. The estimates included do not take into account customer demand or any future sell-downs and acquisitions, partnering arrangements and infrastructure funding. Our CTAP is over a forward-looking period to 2040. It is important to recognise that markets are dynamic, emerging and still evolving, based on factors including developments in technology, science, markets, policy and experience over time. Future dates are target dates based on current understanding, not forecasts.
Direct and indirect mitigation/adaptation efforts, resourcing and progress
Annual investment in CTAP projects: $136m in 2025 (Enabling projects $98m, Operational efficiencies $16m, Carbon capture and storage $20m, Other $2m); $290m in 2024; $265m in 2023. CTAP expenditure in 2025 was lower than in the previous two years, reflecting the completion of Moomba CCS. Over the next five years, potentially up to $500 million to $1 billion could be invested in operational efficiency projects, other CCS and low carbon fuels hubs (depending on working interest, customer demand and value accretion) and nature-based projects which have the potential to generate carbon credits. Investments must meet Santos’ economic hurdles.
Detailed progress on delivering the CTAP is provided across Operational efficiencies (design-out, operate-out initiatives with specific project examples and emissions savings), Carbon capture and storage (Moomba CCS captured 84 per cent of available CO2e in 2025 and has stored 1.57 million tonnes of CO2e; Bayu-Undan and Western Australia CCS progress), Low carbon fuels (Moomba low carbon fuels hub advantages, synthetic gas studies with Tokyo Gas, Osaka Gas and Toho Gas, geothermal exploration licences GELs 655, 656 and 658), Direct air capture (CarbonAssist™ trial with CSIRO), Carbon solutions/nature-based projects (Markham Valley Afforestation Reforestation project, Alaska Native landowner collaboration, Waddy-Brae-Fairview Springwater Regeneration project, Summer Hills and Broandah Soil Carbon projects), Value chain collaboration with customers (joint study on low carbon fuels, MOU with South Australian Government) and suppliers (LNG vessel sub-cooling technology, ~5 ktCO2e savings and $1.7 million in fuel savings; engagement with ~170 most relevant suppliers each year).
Santos also incurs costs in addressing climate-related risks and opportunities, which are not included in the capital allocation metric, as it is either operational in nature or capital spend that is immaterial or not separately identifiable from wider spend having both climate and non-climate purposes. An example is asset maintenance and major project expenditure.
Financial position, financial performance and cash flows
Current financial effects
For each identified transition and physical risk, the report states 'Current financial impact: Not material' and 'Quantification methodology: We have not identified any material financial impacts in the current reporting period that are directly attributable to this risk' (applies to Transition risks 1-7, 9 in various forms).
Exception: Physical risk 1 (Flooding in the Cooper Basin) - Current financial impact: Santos’ flood related costs in 2025 were $21.9 million, related to flood preparations and response, well and facility re-instatement, road repair, logistics and operations support. An insurance claim related to these flood costs has been submitted by Santos. In 2025, an initial $4 million payment was received.
Transition risk 8 (Transition technologies not scalable) / risk 9 / opportunities 1 and 2: In 2025, Santos’ CTAP activities and associated capital expenditure was $136 million. Santos’ CTAP represents the combined financial impact across multiple climate-related risks and opportunities (cross-over with Transition risk 8, Transition risk 9, Transition opportunity 1 and Transition opportunity 2). It is not possible to reliably allocate Santos’ CTAP investments to individual climate-related risks and opportunities in a way that would be meaningful to users of this report. Santos’ CTAP capital expenditure represents actual costs incurred in the reporting period.
Transition risk 1 (Climate policy): A nominal short-term net SGM (Safeguard Mechanism) liability is estimated at approximately $24 million in 2026, based on a carbon price of $37.33 per tonne of carbon dioxide equivalent (tCO2e).
Anticipated financial effects
For most risks, 'Anticipated financial impact: Not quantifiable' with quantification methodology explaining significant uncertainty (e.g. variety of asset developments and jurisdictions, complexity of stakeholder priorities, uncertainty in future demand).
Exception - Transition risk 1 (Climate policy): the theoretical cost of Santos’ anticipated medium-term net SGM liability is estimated to range from approximately $21 million to $65 million per annum. This range reflects the inherent uncertainty in future carbon price assumptions. The upper end applies Santos’ 2030 carbon price assumption of $71.19 per tCO2e, consistent with the Commonwealth Government’s Cost Containment Measure. The lower end uses the average ACCU spot price for December 2025 of $23.44 per tCO2e.
Transition risk 7 (Reduced demand for products): 2025 Brent price sensitivity: ~$400 million in free cash flow from operations for every $10 increase in Brent oil prices.
Transition risk 8/9 and opportunities 1/2: Over the short to medium term, we anticipate $500 million to $1 billion could be invested in operational efficiency projects, other CCS and low carbon fuels hubs and nature-based projects with the potential to generate carbon credits, depending on working interest, customer demand and value accretion.
Significant judgements, estimates and assumptions (Section 1): The identification and assessment of climate-related risks and opportunities was considered using all reasonable and supportable information available without undue cost or effort. Where management has made significant judgements, estimates and assumptions this has been disclosed within the report. The estimation of anticipated financial effects is influenced by the assumptions and investments underpinning Santos’ long-term plans. We expect this information to evolve over time in line with Santos’ strategy. Where Santos has not been able to quantify the anticipated financial effect due to measurement uncertainty then an explanation is provided and qualitative information is provided about those financial effects, including identifying line items, totals and subtotals within the related financial statements that are likely to be affected, or have been affected, by that climate-related risk or opportunity.
Quantification approach: Anticipated financial impact is based on our five year plan and long-term plan where financial quantification can be measured with reasonable certainty. These plans form part of our corporate planning process and provide a reasonable basis for reporting anticipated financial impact. In contrast, the potential financial impact of climate scenarios is assessed and reported as part of our resilience testing. Where Santos has been unable to disclose quantitative information, the reasons for this are detailed and qualitative information provided where available. Where quantification is not separately identifiable we have provided quantitative information about the combined financial effects of that climate-related risk and opportunity with other climate-related risks and opportunities, unless the combined financial effects are considered not useful as measurement uncertainty is too high.
Climate resilience and scenario analysis
Santos has performed an analysis of our exposure, impacts and potential mitigating responses to both transition and physical climate-related risks and opportunities. We test our strategy and business model to determine our resilience to a range of potential climate future states. Santos evaluates the resilience of our portfolio with reference to both quantitative and qualitative factors.
Approach to scenario analysis
Climate scenarios are possible outcomes across the temperature, technological and behavioural spectrum. They are not forecasts, but potential future climate states, based on sets of assumptions around changes in global behaviour, including energy supply and demand. Different climate scenarios are used for transition and physical resilience testing.
Transition scenario analysis
Three scenarios used: IEA 2025 Net Zero by 2050 Scenario (IEA NZE 2025) - temperature rise limited to 1.5 degrees Celsius; S&P Global Commodity Insights Renaissance Scenario (S&P Renaissance 2025) - temperature rise limited to 1.9 degrees Celsius; IEA 2025 Stated Policies Scenario (IEA STEPS 2025) - temperature to rise 2.4 degrees Celsius. Santos’ portfolio has been tested to assess resilience through the energy transition, under both current policy settings and in accelerated transition scenarios, using after-tax cashflow from the long-term plans (LTP) as a measure of resilience, evaluated with reference to short (0-1 years), medium (1-5 years) and long-term (6-10 years) time horizons, consistent with internal budget and planning horizons. This analysis was undertaken in late 2025 and early 2026.
A carbon price is applied to Australian assets operating under the Australian Safeguard Mechanism and to assets where Santos has made a voluntary net-zero commitment. Commodity price assumptions derived from IEA STEPS, IEA NZE and S&P Renaissance scenarios.
Resilience conclusion: Our portfolio remains cashflow positive in the medium to long-term across the range of climate scenarios, including the IEA NZE scenario which is aligned to Paris Agreement climate goals. This demonstrates resilience of our strategy and business model. Cashflows include decarbonisation initiatives when incorporated into our long-term plans and include a carbon price to support our 2030, 2040 and 2050 emissions reduction targets. This approach is further supported by our ability to repurpose existing infrastructure and depleted reservoirs to develop CCS hubs adjacent to our operated assets. Cashflow remains positive across all relevant timeframes under IEA NZE, S&P Renaissance and IEA STEPS.
Physical risk scenario analysis
Santos conducted a climate scenario analysis on its operated and non-operated assets in 2023. Over 2024 and 2025 Santos assessed its resilience to physical climate-related risks. Santos engaged Deloitte to support identification of physical climate-related risks, using the latest climate models published by the IPCC and downscaled by NASA to a 25km resolution. Three climate scenarios used: SSP1-2.6 (1.8 degrees Celsius by 2100), SSP2-4.5 (2.7 degrees Celsius by 2100), and SSP5-8.5 (4.4 degrees Celsius by 2100). Scenario analysis was performed over three time frames comparing future climate trends in 2030, 2050 and 2070 to current conditions.
Physical resilience testing is performed by regional business units at least annually. Regional business units apply Santos’ Risk Matrix to determine inherent and residual financial risk ratings for physical climate hazards, considering potential financial impacts to revenue, operating costs and capital expenditure and controls/mitigations in place.
Capacity to adjust / adapt
Regional business units continue to monitor the potential impact of physical risks and determine whether there is any need for changes to operational controls or further adaptation action in the future. Physical climate-related risks are actively managed by regional business units through existing controls and adaption measures across the short to medium term, including weather monitoring, emergency response plans, trained personnel, factoring weather assumptions into production planning and budgets, regular inspection/maintenance, critical spares inventory, and supply chain continuity plans.
Significant areas of uncertainty / limitations
Santos’ scenario analysis necessarily relies on a number of assumptions, both internal (asset working interests, commercial arrangements, timing of investment decisions, project maturity, technology risk and market) and external (assumed changes to macroeconomic assumptions and conditions under each scenario and government policy). A change in any of these assumptions could impact the results of, and conclusions drawn from, scenario analysis. Santos notes that both the IEA and S&P Global acknowledge their scenarios represent potential pathways – not definitive pathways. Climate projections are based on assumptions about future greenhouse gas emissions and other policy choices, of which timing and impact are uncertain. Cascading and compounding climate risks were not assessed due to limited climate model data on their occurrence and associated uncertainty.
Risk ManagementRisk Management
Processes for identifying, assessing and managing climate-related risks
Santos takes an enterprise approach to risk management and operates under one Risk Management Framework for all risks, including climate-related risks. Our Risk Management Framework requires the identification and management of risks to be embedded in business activities and provides requirements and guidance on the tools and processes to manage risks. To support the consideration of climate, Santos maintains a Risk Appetite Statement, that enables emissions to be considered in decision-making processes and is reviewed at least annually for ongoing alignment with strategic objectives.
Value chain
Our risk identification process is enterprise-wide and considers risks from a wide range of stakeholders such as government and capital markets, and includes the identification of significant events that impact our operations (e.g. extreme weather). Our scope considers upstream (suppliers) and downstream (customers), non-operated joint venture arrangements, as well as our own operated joint ventures.
Non-operated joint venture arrangements
For non-operated joint ventures, we have defined critical expectations and requirements for participation and operation. We have joint venture representatives who work closely with our joint venture partners to reduce the risk of misalignment in joint venture activities. We have identified our material non-operated joint venture arrangements based on production volume to support the consideration and engagement on climate-specific risks and opportunities.
Role of scenario analysis
Climate-specific scenario analysis is used to support the identification of climate-related risks and opportunities through our strategy process, long-term plans, major project design and resilience testing for reporting purposes. Physical risk scenario analysis has been integrated into regional business unit risk reviews for operated assets and used to support the identification of physical climate risks impacting our material non-operated joint venture assets. Whilst our physical scenario analysis does not extend beyond Santos’ operational boundary, it has been used to inform the identification of risks to supply chains and transport of product to the point of sale.
Major suppliers and customers
We have a diverse supplier base with flexibility to source from multiple suppliers. We also have a diverse customer base and can sell product to alternative customers. To support climate-specific risk identification we have identified our major suppliers and customers based on dollar value and requested information to understand their management of climate-related risks and opportunities. We expect that information may initially be limited in some areas.
Climate risk assessment and prioritisation
To assess climate-related risks (as for all risks assessed through the Risk Management Framework), we use internal stakeholder engagement and current and emerging threat reviews. We use qualitative and semi-quantitative criteria through a Risk Matrix, which considers the likelihood (by reference to timeframes) and severity of potential impacts by estimating the worst-case scenario in terms of damages and financial loss. This assessment results in the definition of a risk level that informs the prioritisation of climate-related risks (and all other risks), which are reviewed annually with risk owners for alignment with Santos’ enterprise-wide risks. This assists Santos in prioritising and understanding the significance of climate-related risks in relation to other risks.
Climate risk monitoring
The ongoing monitoring of climate-related risks is embedded into business activities through the SMS, which sets the mandatory requirements for how we manage and operate the business. This includes a Risk Management and Assurance Operating Standard that sets out the detailed requirements and tools to identify and manage risks. Risk owners must assess climate-related risks, considering potential impacts across assets and communities and verify the effectiveness of controls in managing these risks. Executive management and the Audit and Risk Committee regularly review the enterprise-wide risks, new or emerging risks, and the risk controls and mitigations that management has put in place in relation to those risks. To support climate-specific monitoring, climate-related risks and opportunities are summarised in our Climate Risk Register, which is used to monitor current and emerging climate-related risks and opportunities. There have been no major changes to our risk management process from the prior year.
Integration with overall risk management framework
Santos’ Risk Management Framework provides the overarching framework for managing risks, including climate-related risks. Santos’ climate-related risks are linked to enterprise and material business risks, which ensures climate-related risks are managed throughout the business in accordance with our Risk Management Framework. Santos’ climate-related opportunities form part of our company strategy and CTAP. This ensures our climate-related opportunities are managed through half-yearly review of our CTAP by the Safety and Sustainability Committee.
Approach to vulnerability - challenges and limitations
The term ‘vulnerable’ is not defined under AASB S2 climate reporting standards. Our approach has been to seek to identify the assets or business activities in the financial report that we currently view as most vulnerable to each climate-related risk and assumes unmitigated response. There are inherent limitations in assessing whether, when and how climate-related risks may eventuate and therefore in determining what assets or business activities could be vulnerable to such risks. Similarly, the term ‘aligned’ is not defined under AASB S2 climate reporting standards and therefore we have adopted a consistent approach for our assessment of assets or business activities aligned with climate-related opportunities as climate-related risks.
Metrics & TargetsMetrics and Targets
Climate-related metrics
Greenhouse gas emissions
Emissions methodology
Santos has elected to apply the equity share approach as its primary organisational boundary for all greenhouse gas (GHG) emissions. Under the equity share approach, a company accounts for GHG emissions from operations according to its share of equity in the operation. Santos’ operated Australian Scope 1 and 2 greenhouse gas emissions are independently audited each year prior to submission of the annual NGER Report. Santos primarily adopts the prescribed emissions factors under Method 1 (default method) in the NGER Determination. Emissions for Santos’ Alaskan operations are reported to the United States Environmental Protection Agency (“US EPA”) pursuant to Title 40 (40 CFR 98) of the Code of Federal Regulations Part 98 (“US EPA Code”). Emissions calculated in accordance with the NGER Determination and US EPA Code for the 2025 year use global warming potential (GWP) values from the IPCC Fifth Assessment Report (AR5). GWP values from the IPCC Sixth Assessment Report (AR6) are used in the calculation of emissions in other areas. There were no changes in measurement approach in the current period.
Santos’ Scope 3 emissions have been calculated in accordance with the Scope 3 measurement framework within AASB S2. Santos has considered all of the 15 categories in the GHG Protocol and determined which of the Scope 3 categories are relevant to the business model. The material Scope 3 categories comprise approximately 96% of Santos equity share Scope 3 emissions and include Category 1 (purchased goods and services), Category 10 (processing of sold products) and Category 11 (use of sold products). Other non-material Scope 3 categories are aggregated and reported as Other Upstream or Other Downstream.
Emissions data
Santos’ equity share gross emissions were 3.81 million tonnes of carbon dioxide equivalent (MtCO2e). This included 3.55 MtCO2e Scope 1 and 0.26 MtCO2e Scope 2 (location-based). 67% of Scope 1 and 2 GHG emissions are in Australia (NGER), 1.8% from Alaska (US EPA Code), and the remainder calculated under the GHG Protocol, primarily PNG (30%). Santos’ equity share gross emissions reflect emissions after CO2e has been captured and stored by Moomba CCS operations.
Santos’ Scope 3 equity share gross emissions were 28.4 MtCO2e.
Scope 1 equity share greenhouse gas emissions
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Equity share emissions (MtCO2e) | 3.55 | 4.12 | 4.60 | 4.86 | 4.69 |
| Consolidated accounting group | 2.97 | 3.54 | NPR | NPR | NPR |
| Other investees | 0.58 | 0.58 | NPR | NPR | NPR |
| Equity share intensity (ktCO2e/mmboe) | 46 | 47 | 50 | 47 | 51 |
Scope 2 equity share greenhouse gas emissions
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Equity share emissions | 0.26 | 0.26 | 0.21 | 0.21 | 0.22 |
| Consolidated accounting group | 0.26 | 0.26 | NPR | NPR | NPR |
| Other investees | 0.00 | 0.00 | NPR | NPR | NPR |
Scope 1 and 2 equity share greenhouse gas emissions
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Equity share emissions (MtCO2e) | 3.81 | 4.38 | 4.81 | 5.07 | 4.91 |
| Consolidated accounting group | 3.23 | 3.80 | NPR | NPR | NPR |
| Other investees | 0.58 | 0.58 | NPR | NPR | NPR |
| Equity share intensity (ktCO2e/mmboe) | 44 | 50 | 52 | 49 | 53 |
Scope 3 equity share greenhouse emissions
| Category | 2025 (MtCO2e) |
|---|---|
| Category 1: Purchased goods and services | 2.1 |
| Category 10: Processing of sold products | 4.3 |
| Category 11: Use of sold products | 20.8 |
| Other upstream | 0.7 |
| Other downstream | 0.4 |
| Total | 28.4 |
Supplementary data (not part of mandatory AASB S2 reporting, provided for comparison):
Scope 1 total operated greenhouse gas emissions
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Scope 1 total operated emissions (MtCO2e) | 3.61 | 4.44 | 5.50 | 5.87 | 6.40 |
Methane emissions (OGCI, total operated)
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Methane emissions (MMSm3) | 22.23 | 23.76 | 28.51 | NPR | NPR |
Scope 2 total operated greenhouse gas emissions
| 2025 | 2024 | 2023 | 2022 | 2021 | |
|---|---|---|---|---|---|
| Scope 2 total operated emissions | 0.79 | 0.80 | 0.60 | 0.57 | 0.61 |
Scope 3 greenhouse emissions
| Category | 2025 | 2024 | 2023 |
|---|---|---|---|
| Category 1: Purchased goods and services (total operated) | 3.3 | 3.1 | 5.5 |
| Category 10: Processing of sold products (equity share) | 4.3 | 4.2 | 4.3 |
| Category 11: Use of sold products (equity share) | 20.8 | 21.3 | 21.8 |
| Other upstream (total operated) | 0.8 | 0.9 | 1.0 |
| Other downstream (equity share) | 0.4 | 0.4 | 0.4 |
| Total | 29.7 | 29.9 | 33.0 |
Methane emissions contributed to approximately 12 per cent of total operated Scope 1 emissions in 2025. 2025 methane emissions breakdown: Fugitives 43%, Flare 29%, Vent 24%, CO2 removal 5%, Fuel 0%. In 2025, across operated sites, methane intensity was 0.16 per cent, compared to 0.19 per cent in 2023 and 0.16 per cent in 2024.
Capital deployment
Annual investment in Climate Transition Action Plan projects: $136m in 2025 (Enabling projects $98m, Operational efficiencies $16m, Carbon capture and storage $20m, Other $2m); $290m in 2024; $265m in 2023. Our current carbon planning price assumption projects a carbon price of $63 per tonne of carbon dioxide equivalent (real 2025) in 2030. Over the next five years, potentially up to $500 million to $1 billion could be invested in operational efficiency projects, other CCS and low carbon fuels hubs and nature-based projects.
Transition risks
Each transition risk in the risk tables includes a 'Vulnerability metric' showing amount and percentage of assets vulnerable, e.g.:
- Climate policy: $2,539 million Exploration and evaluation assets (11 per cent)
- Climate-related litigation: $2,539 million Exploration and evaluation assets (11 per cent)
- Environmental/shareholder activism: $2,539 million Exploration and evaluation assets (11 per cent)
- Human capital: Nil
- Carbon emissions expectations: $136 million CTAP (4 per cent)
- Access to capital markets: $382 million expense (10 per cent)
- Reduced demand for products: 6 mmboe of sales volume (7 per cent)
- Transition technologies not scalable: $4,833 million assets (22 per cent)
- Failure to achieve emissions reduction targets: $4,833 million assets (22 per cent)
Physical risks
Physical risk 1 (Flooding in the Cooper Basin) Vulnerability metric: $2,034 million assets (9 per cent), calculated as the portion of Cooper Basin’s oil and gas assets and decarbonisation assets as a percentage of total oil and gas assets and decarbonisation assets.
Opportunities
Transition opportunity 1 (Transition technologies) Alignment metric: $254 million assets (1 per cent), being the portion of Santos’ technology-based decarbonisation assets as a portion of total decarbonisation assets and total oil and gas assets. Transition opportunity 2 (Low carbon fuels) Alignment metric: $4,483 million of revenue (88 per cent), being the portion of Santos’ gas derived revenue, including LNG, as a percentage of total product revenue in the reporting period.
Internal carbon prices
Our economic analysis processes consider the greenhouse gas emissions from all projects and the impact that a carbon price would have on our business. Where applicable, a carbon price is included in Santos’ economic modelling of projects, along with sensitivity testing to assess the impact of carbon pricing on all emissions. Santos applies the same stringent economic criteria to CTAP projects at FID, including internal rate of return and payback period, as we do to traditional gas and liquids projects. Our current carbon planning price assumption projects a carbon price of $63 per tonne of carbon dioxide equivalent (real 2025) in 2030.
Remuneration
Since 2019, the Short-Term Incentive has included performance metrics that reward Key Management Personnel (KMP) for achieving sustainability and climate outcomes. In 2025, the Company Scorecard weighting for climate-related targets remained at 17.5 per cent (consistent with 2024) and included metrics relating to emissions intensity reduction and key decarbonisation projects. This further strengthens the link between climate considerations, and the outcomes of performance pay.
Climate-related targets
The Board, supported by the Safety and Sustainability Committee, oversees the setting and monitoring of targets, including emissions reduction ambitions, targets and metrics related to climate-related risks and opportunities through the annual strategy-setting process. Reviewing and monitoring of targets is addressed at least annually through performance updates to the Safety and Sustainability Committee.
Targets table (summarised)
| Target | Detail/Base period | Metric | Progress at 31 Dec 2025 | Planned use of carbon credits |
|---|---|---|---|---|
| Reduce emissions across Cooper Basin/Queensland by >5% | Set 2018, 2016-17 fixed baseline of 5,875 kt gross operated CO2e | At least 295,000 tonnes reduction by year-end 2024 | Completed 2022 | Not applicable - completed before AASB S2 |
| Grow LNG exports to at least 4.5 Mtpa | Set 2018 | Over 4.5 Mtpa LNG exports by year-end 2024 | Completed 2021, maintained | Not applicable |
| Assess/invest in CCS | Set 2018 | FIDs on Moomba CCS by year-end 2024 | Completed 2021 | Not applicable |
| Reduce Scope 1 and 2 emissions by 30% | Set Feb 2022, applies to entire post-Oil Search merger portfolio, absolute and equity share basis | Net equity Scope 1 and 2 emissions of 4.1 MtCO2e or less by year-end 2029 | Reduced by 2.49 Mt from 2019-20 baseline (42% reduction), target achieved | Net target including planned use of carbon credits; gross target expected to range 4.6 to 5.6 MtCO2e |
| Reduce Scope 1 and 2 emissions intensity by 40% | Set Feb 2022, 2019-20 baseline of 55 ktCO2e/mmboe (adjusted to 68.4% equity for Bayu-Undan/Darwin LNG) | 33 ktCO2e/mmboe or less by year-end 2029 | Net emissions intensity approx. 39 ktCO2e/mmboe, 73% achievement | Gross intensity target expected to range 40 to 50 ktCO2e/mmboe |
| Reduce customers' emissions (Scope 3) by ≥1.5 MtCO2e p.a. | Set 2022 | 1.5 MtCO2e p.a. or greater by year-end 2029 | Working with customers to identify opportunities | Not applicable |
| Achieve near-zero methane emissions | Set 2023 | <0.20% methane intensity (gross operated methane/marketed natural gas) by 1 Jan 2030 | 0.16% in 2025 (2024: 0.16%, 2023: 0.19%) | Not applicable |
| Achieve zero routine flaring | Set 2023 | Routine flaring eliminated by 1 Jan 2030 where economically viable | Progressing zero routine flaring plan | Not applicable |
| Net-zero Scope 1 emissions | Set 2021 | Net-zero by year-end 2039 | CTAP provides potential pathway; continuing 2030 progress | Net target; gross target expected to range 6.1 to 7.1 MtCO2e |
| Store ~14 Mt (gross) third-party CO2e p.a. | Set 2024 | 13.65 million tonnes p.a. (gross) by 31 Dec 2040 | 0.41 million tonnes sequestered at Moomba CCS in 2025 | Not applicable |
| Net-zero Scope 2 emissions | Changed from 2040 to 2050 in 2024 | Net-zero by year-end 2049 | Aligns with planned decarbonisation of electricity grids | Gross target that does not include planned use of carbon credits; carbon credits not currently expected to be required |
Quantitative targets are absolute metrics, except for 'Target to reduce Scope 1 and 2 emissions intensity by 40 per cent' and 'Achieve near-zero methane emissions', which are intensity targets. Santos’ targets have not been derived using a sectoral decarbonisation approach, as the Science Based Targets Initiative currently does not publish a sector decarbonisation approach for the oil and gas sector.
Santos is building an inventory of carbon credits through external acquisitions and internal generation. This includes externally-purchased ACCUs and SMCs, externally-purchased credits from internationally-recognised registries Santos currently works with, self-generated carbon credits through nature-based projects, and internally-generated SMCs and ACCUs, including those acquired through Moomba CCS. Santos uses carbon credits to reduce emissions in line with compliance obligations and to meet voluntary targets, once all feasible options to avoid and reduce these emissions have been achieved, including abatement through Moomba CCS. Santos remains compliant with its compliance obligations under the Safeguard Mechanism.
Methane emissions intensity metric calculation and target aligns with the OGCI’s ‘Aiming for Zero’ initiative, of which Santos is a signatory. Zero routine flaring aligns with the World Bank’s Zero Routine Flaring initiative, of which Santos is an endorser.
Building a commercial carbon storage business: Santos aims to build and operate a commercial carbon storage business, safely and permanently storing approximately 14 Mt (gross) of third-party CO2e per annum by 2040, equivalent to around 56% of Santos’ 2025 equity Scope 3 emissions from the combustion and use of products (categories 10 & 11). By 2030, target is 1.5 Mt of third-party CO2e per annum from the supply of low carbon fuels and carbon management services. Santos aspires longer-term to store more carbon than it emits (Scope 1, 2, and equivalent Scope 3 emissions).
Since 2018, Santos has published an annual Climate Report; the 2030 emissions target was reached in 2025 (42% reduction), ahead of schedule.