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Sonic Healthcare Limited

ASX: SHLIndustry: Healthcare ProvidersAuditor: PricewaterhouseCoopersFY2026Group: Group 1
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GovernanceGovernance

AASB S2 paragraphs 5–7, Aus7.1

Governance body oversight and management's role

Reported

Oversight (pp. 164–165). The Board is responsible for setting strategic direction and overseeing its implementation, including identifying and managing climate-related risks and opportunities, per the Board Charter. The Risk Management, Audit, and Remuneration and Nomination committees support it; their responsibilities are in charters reviewed annually, and the Audit Committee oversees climate-related disclosures and assurance of climate-related data. The Board receives a management update on climate-related matters at least annually (one in FY2026), approves climate targets and monitors progress at least annually. Trade-offs are assessed against the risk appetite statement; no major transaction in FY2026 required consideration of climate-related trade-offs. Board members self-assessed their climate-related competencies; the Board was found to collectively cover all relevant skills.

Remuneration (p. 165). Half of the qualitative portion of the short-term incentive was tied to sustainability and climate-related goals, representing 4.4% of total executive management remuneration; the amount linked specifically to climate-related goals cannot be isolated.

Management (p. 166). The CEO and Managing Director holds overall executive accountability; day-to-day implementation is delegated to the Group Chief Medical Officer, working with the Chief Sustainability Officer and a dedicated sustainability function. Controls follow enterprise risk management policies.

StrategyStrategy

AASB S2 paragraphs 10–11

Climate-related risks and opportunities

Reported

Four items are identified (pp. 169–176):

ItemTypePage
Risk 1: Impact of extreme weather intensificationPhysical (acute and chronic)169
Risk 2: Impact of patients being unable to access services due to extreme weatherPhysical (acute)171
Risk 3: Impact of carbon pricing across the value chainTransition173
Opportunity 1: Increased need for healthcare services due to climate-related health trendsOpportunity175

Descriptions. Risk 1: physical damage to facilities and inventory, and higher energy costs from more extreme temperatures. Risk 2: floods, bushfires, severe storms and extreme heat may disrupt patient access to services and logistics. Risk 3: carbon pricing may raise operating costs directly (carbon taxes) and indirectly (electricity prices, supply chain cost pass-through). Opportunity 1: more heat-related illness, respiratory conditions, infectious diseases and other climate-sensitive health outcomes may increase demand.

Time horizons. The graphics mark medium-term and long-term for all four items; the text for Risks 1 and 2 and Opportunity 1 also describes short-term effects. Short-term is 1–2 years, medium-term 3–5 years and long-term 6 years and beyond, tied to annual business planning, capital allocation and investment planning, and the long-range strategic outlook respectively (p. 168).

AASB S2 paragraph 13

Business model and value chain

Reported

Business model (p. 160). Pathology/clinical laboratory services in Australia, New Zealand, the United Kingdom, the United States of America, Germany, Switzerland, Belgium, Poland and Liechtenstein; in Australia also diagnostic imaging, occupational health, general practice medical centers and skin cancer clinics.

Value chain (pp. 161–162). Upstream: procurement of medical supplies and equipment. Core operations: sample collection, testing and diagnostics. Downstream: delivery of results to healthcare providers and patients, and waste treatment and disposal by external providers.

Where risks and opportunities arise (p. 163). Physical infrastructure and sites (thousands of sites; parts of the network exposed to extreme weather), logistics and transport, suppliers and procurement (global suppliers of specialized reagents, equipment and utilities), customers, and communities and environment.

Concentration. Upstream scope 3 emissions account for approximately 80% of Sonic's current emissions footprint, concentrating carbon pricing risk in the supply chain (p. 173). The largest potential physical impacts arise at a small number of facilities (p. 169); scenario analysis did not identify a material concentration of physical climate risk by geography or service line (p. 183).

Effects. For Risk 2, climate events are not expected to materially affect the business model, growth drivers or long-term strategy (p. 171).

AASB S2 paragraph 14

Strategy and decision-making

Partial
Partial disclosure: No formal transition plan exists (p. 181), so no key assumptions or dependencies are disclosed (14(a)(iv)). Sonic has no active climate-related targets (pp. 166, 184), so there is no description of how targets will be achieved (14(a)(v)). No amounts are given for resourcing (14(b)). Future physical-risk mitigation and adaptation are described as building on existing practices rather than a fundamental change in approach (p. 170). Not found: progress against plans disclosed in earlier periods (14(c)), other than progress against the previous interim emissions target (p. 184).

Transition plan (p. 181). Sonic does not currently have a formal, detailed climate transition plan but is in the foundational stages of developing one. In the interim it continues to implement climate mitigation and adaptation initiatives. It recognizes the importance of transition plans for a credible, science-aligned pathway to reduce scope 1, 2 and 3 GHG emissions.

Responses in strategy and decisions. Carbon pricing risk is not expected to fundamentally alter strategy; the importance of reducing emissions, and so carbon price exposure, is considered in medium- to long-term planning and capital allocation (p. 173). Group-level responses include incorporating carbon emission and energy efficiency factors in assessing business initiatives and strategic investment decisions, electrifying the vehicle fleet, increasing on-site renewable electricity generation where feasible and the use of renewably sourced electricity, and engaging suppliers on emission reductions (p. 175). Physical-risk responses include geographic diversification, business continuity and disaster recovery plans, and insurance (pp. 170, 172). Investments underway include expanding on-site solar generation, improving energy efficiency and progressing the vehicle fleet transition (p. 180).

Resourcing (pp. 183–184). Capital for climate-related emission reduction activities is deployed through business-as-usual operational and capital expenditure programs and is not reported as a discrete line item.

AASB S2 paragraphs 15–21

Financial position, financial performance and cash flows

Partial
Partial disclosure: No dollar amount or range is given for any current or anticipated financial effect. A reason for not quantifying is given only for Risk 3 over the medium to long term (significant uncertainty, p. 174) and Opportunity 1 (limited robust data, p. 176), plus a general statement in section 1.3 (p. 159). The report cites no paragraph 19 to 21 relief by number and gives no combined financial effects. Not found: how financial position is expected to change given investment and disposal plans and planned sources of funding (paragraph 16(c)), beyond the general statements on financial strength and capital allocation on p. 180.

For all four items the report states that there were no material financial effects in the current period and that no material adjustment to the carrying amounts of assets and liabilities is expected within the next annual reporting period (pp. 169–176).

ItemAnticipated effects describedBasis stated
Risk 1, extreme weather (pp. 169–170)Medium to long term: higher baseline operating costs and additional capital expenditure; not anticipated to be materialHistorical cost data, forecasts of incremental energy consumption and a quantitative assessment of site exposure
Risk 2, patient access (pp. 171–172)Temporary revenue loss, operating costs and a short-term impact on operating cash flows; not anticipated to be materialHistorical experience of service disruption and recovery
Risk 3, carbon pricing (pp. 173–174)Short term: immaterial cost increases. Medium to long term: cannot be reliably estimatedA nominal, jurisdiction-specific carbon price (footnotes 2 and 3, p. 179) and a high-level assessment of supplier cost pass-throughs
Opportunity 1, demand (pp. 175–176)Gradual, indirect upside (likely higher revenues and profits if demand rises); not quantitatively estimatedQualitative, limited robust data

Line items named for Risk 3: energy and utilities expense, cost of purchased goods and services, property, plant and equipment, and operating and investing cash flows (p. 174).

AASB S2 paragraph 22

Climate resilience and scenario analysis

Reported

Scenario analysis (pp. 177–179). Two scenarios, with an external climate risk consultancy, covering all operating geographies and business units.

Lower warmingHigher warming
SourcesNetwork for Greening the Financial System 'Net Zero 2050'; IPCC Representative Concentration Pathway 2.6 / Shared Socio-Economic Pathway 1-2.6IPCC Representative Concentration Pathway 8.5 / Shared Socio-Economic Pathway 5-8.5; Network for Greening the Financial System 'Current Policies'
OutcomeIncrease limited to 1.5° C by 20503+° C by 2100
Primary useAssess transition impactsAssess physical impacts
Carbon price (A$)2030 A$364 – A$401; 2040 A$566 – A$868; 2050 A$803 – A$1,3342030 A$16 – A$38; 2040 A$15 – A$34; 2050 A$15 – A$31

Horizons: short-term (to 2030), medium-term (to 2040), long-term (to 2050). The lower warming scenario is aligned with the latest international agreement on climate change. Management determined the FY2025 analysis remains suitable for FY2026 (p. 167).

Resilience (pp. 180–181). No immediate need for material changes to strategy or business model was identified. Sonic says it has the capacity to adjust and adapt over the short, medium and long term, citing strengths including geographic diversification, financial strength and adaptive assets. Uncertainties named: climate science and modeling, transition progress, policy and regulation, data availability and quality, and technology and external factors.

Risk ManagementRisk Management

AASB S2 paragraphs 24–26, Aus26.1

Processes for identifying, assessing and managing climate-related risks

Reported

Framework (p. 167). An enterprise-wide Risk Management Framework prioritizes and manages climate risks alongside other material business risks. The Risk Appetite Statement incorporates climate-related considerations and is reviewed at least annually by the Board's Risk Management Committee. The processes were unchanged from the previous reporting period.

Identification (p. 167). Continuous monitoring of climate trends plus a structured risk-identification process that also captures emerging opportunities. Inputs: internal data (business plans, financial models, operational, asset and facility data, insurance, emissions and energy data, scenario analysis outputs) and external information (regulatory developments, climate science and emissions trajectory data, technology and market trends, stakeholder sentiment, legal developments, peer disclosures).

Scenario analysis (p. 167). The FY2025 analysis (two scenarios, all major operating geographies and business units) supported identification and assessment of risks and opportunities.

Assessment and prioritization (pp. 167–168). Likelihood and severity are estimated using a Risk Assessment Matrix combining qualitative and quantitative factors. Ratings are benchmarked against Board-approved risk appetite and tolerance criteria so risks are ranked consistently. Opportunities are assessed and prioritized with the same framework. Monitoring is ongoing within enterprise risk management processes (p. 168).

Metrics & TargetsMetrics and Targets

AASB S2 paragraphs 29–31

Climate-related metrics

Partial
Partial disclosure: Scope 3 is not disclosed (relief C4(b)) and no comparatives are given (relief C3), pp. 159, 182. The report says upstream scope 3 is approximately 80% of the current emissions footprint (p. 173) but gives no scope 3 figure. The table covers the consolidated accounting group only; no figures are given for other investees (29(a)(iv)(2)); the report says the share of non-controlled investees is reported within scope 3 category 15 (p. 182), which is omitted. Transition risk (29(b)) is a percentage of operating expenditure with no amount. For physical risk (29(c)) figures are given for assets only; the report says quantifying business activities as a proportion is not considered appropriate (p. 183). Opportunities (29(d)) are said to be relevant across the entirety of the Group's operations, with no amount or percentage. No amount for capital deployment (29(e)). The remuneration percentage (29(g)) appears only in the Governance section, as 4.4% for sustainability and climate-related goals combined (p. 165).

FY2026 Scope 1 and 2 emissions (p. 182). Absolute (gross); no offsets were used.

EmissionstCO2e (consolidated accounting group)
Scope 135,058
Scope 2 (location-based)82,029
Total Scope 1 and 2 (location-based)117,087
Scope 2 (market-based)59,983

Method (pp. 181–182). Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004), operational control approach, all seven major GHGs. Scope 2 market-based is reported voluntarily. 67,081 MWh of RECs were acquired and retired in FY2026. Methods were enhanced in FY2026 (IPCC AR6 GWP values, updated refrigerant charge and leakage assumptions, expanded screening approaches).

Other metrics (pp. 183–184). Transition: approximately 44% of operating expenditure is potentially subject to carbon cost pass-through. Physical: $2,193 million, 15.5% of total non-current assets of $14,179 million (freehold land and buildings and right-of-use assets for leased premises). Capital deployed: not separately identified. Internal carbon price: none introduced.

AASB S2 paragraphs 33–36, Aus37.1

Climate-related targets

Partial
Partial disclosure: No current target is disclosed, so none of the paragraph 33 to 36 details are given for a target in force: metric, objective, part of the entity covered, period, base period, milestones, absolute or intensity basis, gases, scopes, gross or net basis, third-party validation or review process. The 34.2% and 11.1% figures relate to the previous interim commitment on a basis that excludes LADR, so they are not a consolidated result. The report says it will disclose its approach to monitoring progress, including the metrics used and the basis for any revisions, once updated targets are finalized (p. 184).

Status (pp. 165–166, 184). In FY2026 Sonic commenced a reset of its GHG emissions target base year from FY2021 to FY2026. It is re-establishing its emissions and climate targets and says it "does not have active climate-related targets in place for performance monitoring under AASB S2 at this time". Reasons given include data integrity and FY2021 being materially affected by the COVID-19 pandemic (pp. 165–166). The Board is overseeing development of updated targets in line with science-based guidance and requires emissions targets to be science-aligned, consistent with a 1.5° C pathway under the Paris Agreement.

Previously stated targets (p. 184). Net zero greenhouse gas emissions by 2050; reduce scope 1 and 2 (market-based) emissions by 43% by 2030 against the FY2021 base year.

Progress against the previous interim commitment (p. 184). At 30 June 2026, scope 1 and 2 (market-based) emissions, calculated like-for-like excluding the LADR acquisition (completed on 1 July 2025), had reduced by 34.2% against the FY2021 base year and 11.1% against FY2025. The report says this excludes LADR and does not represent consolidated scope 1 and 2 emissions for FY2026.

Next steps (pp. 166, 184). The reset covers a revised baseline, scope coverage, and metrics and governance arrangements for monitoring. Sonic expects to reinstate its net zero by 2050 commitment and interim targets in its November 2026 Sustainability Impact Report.