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Viva Energy Group

ASX: VEAIndustry: Fuel Refining & RetailAuditor: KPMGFY2025Group: Group 1

GovernanceGovernance

AASB S2 paragraphs 5–7, Aus7.1

Governance body oversight and management's role

Reported

Board oversight

The Board of Viva Energy Group Limited strives to build sustainable value for shareholders while protecting the assets and reputation of the Company. Its functions include but are not limited to defining the Company's purpose and strategic objectives.

The Board is ultimately responsible for the oversight of climate-related matters, including the review and consideration of the potential impacts of climate-related risks and opportunities on the Company's strategy, how climate-related considerations are integrated into the Company's strategy and risk management systems, and how climate-related risks and opportunities are managed.

The Board is responsible for approving and overseeing the Company's strategy and major strategic investment decisions, including the strategy around the transition to new energies and climate-related capital allocations, ensuring that trade-offs between risks and opportunities are carefully evaluated. Climate-related risks and opportunities are embedded within the Company's strategic plan and Enterprise Risk Management (ERM) Framework. The Board's role is to ensure that the Company's strategic initiatives reflect these principles and address material climate-related risks and opportunities.

To support this oversight, management prepares analysis for Board review that aligns with the Company's strategic direction and ERM Framework and considers the nature of the Company's operations and the material climate-related risks and opportunities disclosed.

The Company's approach to monitoring and managing climate-related risks and opportunities is primarily overseen by the Board's standing Committees, including the Sustainability Committee and Audit and Risk Committee (ARC). The specific duties of the Board and its Committees are set out in its charters, available on the Company website.

Sustainability Committee

The Sustainability Committee is responsible for:

  • reviewing the performance of the Company in relation to climate-related matters, decisions and actions;
  • reviewing the Company's compliance with legal and regulatory obligations in relation to climate-related policies and procedures;
  • reviewing and considering for approval the objectives, targets and key performance indicators that will drive continuous improvement in climate-related performance;
  • monitoring any significant changes to the climate-related risk profile and business strategies.

The Sustainability Committee met four times during 2025 and each meeting involved climate-related discussions or decisions. Across the year, these topics included: developing the Company's decarbonisation strategy, pathways and transition planning; ongoing review of the Company's carbon emissions profile, reduction process and plans; progress against the Company's climate-related targets, and of the Geelong Refinery against Safeguard Mechanism requirements; a 6-monthly review of the Company's material climate-related risks and opportunities.

Audit and Risk Committee (ARC)

The ARC is responsible for overseeing and reviewing the Company's ERM Framework, including its strategies, policies, procedures and systems for managing risk and their effectiveness. The ARC oversees the implementation and effectiveness of the ERM Framework and related Group risk registers. The ARC performs a formal six-monthly review of the Group risk registers, which incorporate climate-related risks.

The ARC met six times during 2025. A standing Risk and Assurance Report was tabled at five ARC meetings during 2025, including updates on emerging climate-related government policy and regulatory risks. During the second half of 2025, the ARC received regular updates on progress towards mandatory climate-related disclosures, including a formal readiness assessment. The ARC and the Sustainability Committee had coordinated oversight of, and reviewed, management's preparations for AASB S2 reporting during 2025.

Remuneration and Nominations Committee

The Remuneration and Nominations Committee (RNC) assists the Board in evaluating and making recommendations in relation to remuneration arrangements for directors and senior management. The RNC also evaluates and makes recommendations to the Board in relation to Board renewal matters, including considering the mix of skills and experience necessary or desirable in the composition of the Board. The RNC ensures that the Company's remuneration framework is aligned with the Company's purpose, values, strategic objectives and risk appetite, which includes the consideration of climate-related risks and opportunities. The RNC met three times during 2025.

Board processes and structure

To stay informed about climate-related risks and opportunities, the Committee Chairs report to the Board following every Committee meeting. Any relevant decisions (determined by the Company's delegations of authority register) in relation to the climate-related risks and opportunities, including the setting of climate-related targets and climate-related investment decisions, are ultimately approved by the Board. The Board has access to the meeting minutes of all Committees, which include details of climate-related risks, opportunities and internal controls.

The Board considers climate-related risks and opportunities when overseeing the Company's strategy and performance against strategic objectives, by taking into account climate scenario analyses and identifying initiatives that support the energy transition, such as investments in renewable energy, low-carbon liquid fuels, and circular economy programs. The Board also sets the Company's emissions reduction ambitions and other policies that guide operational decision-making. This includes for example, the balance between pursuing climate-related opportunities and advancing the Company's own emissions reduction initiatives.

The Board aims to have Directors with the appropriate mix of skills, experience, expertise and diversity that are relevant to the Company's businesses and the Board's responsibilities, including the responsibility to monitor, manage and oversee climate-related risks and opportunities. The Board Skills and Experience Matrix outlines the skills and experience the Board aims to achieve in its membership. Experience in climate-related risk and opportunities is incorporated into a number of matrix categories, including strategy, risk, industry, capital management, environment and governance. This is regularly reviewed as part of the Board's succession planning, evaluation process and Director's self-assessment process, with the assistance of the RNC.

Time is allocated during Board and Committee meetings for ongoing education and professional development. These sessions are designed to provide Directors with knowledge and ongoing development to support them in performing their role, including to respond to the Company's climate-related risks and opportunities. Board briefings during 2025 were delivered by both senior management and external experts. Directors attended externally-led sessions on Australia's energy transition, the requirements on Directors of mandatory climate-related disclosures, and global trends in new energies.

Management-level governance

The Chief Executive Officer (CEO) is responsible for managing the Company and its business within levels of authority specified by the Board. A delegation of authority framework outlines matters that are delegated to the CEO and other members of senior management. The CEO may delegate aspects of his authority and power to the management team but remains accountable to the Board for the Company's performance. The CEO reports to the Board at regular Board meetings.

The Executive Leadership Team (ELT) and senior management are central in implementing the Company's governance framework. Their responsibilities also include implementing and monitoring controls and risk management procedures, managing climate-related risks, opportunities, targets and strategies and tracking progress against those strategies. Members of the ELT and senior management form various forums and decision-making bodies to oversee these responsibilities.

Controls and procedures for measuring the Group's GHG emissions and tracking progress against climate strategies are embedded within the ERM Framework and integrated across the business. Various internal functions are responsible for the day-to-day management of climate-related risks and opportunities, including customer-facing, operational and strategically focused teams including Strategy, Sustainability, Decarbonisation and Future Fuels, Carbon Solutions, Legal, Finance, Procurement, and Supply and Technical teams.

The Sustainability team is responsible for the continual update of the Company's climate-related risk and opportunity register, with input from subject matter experts throughout the business. Additional oversight of the register is facilitated by the CEO, Chief Financial Officer (CFO), and the Chief Strategy Officer.

Executive Remuneration

The Executive Remuneration Framework comprises total fixed remuneration, and variable short- and long-term incentives.

The short-term incentive (STI) program rewards executives on the execution of annual performance against a balanced scorecard of performance measures focused on financial (60%), a mix of individual personal and group objectives aligned with the Company's strategic goals (25%) and safety and environmental, social and governance (ESG) outcomes (15%). Certain 'strategic' and 'safety & ESG' measures are linked to the Company's climate-related risks and opportunities. Relevant metrics for 2025 included: sites with rooftop solar and electric vehicle (EV) chargers; open the New Energies / Hydrogen Service Station and commercialise position in hydrogen; complete front-end engineering design for plastics recycling; secure policy settings for low carbon fuel processing; establish sustainable aviation fuel import capability.

The long-term incentive (LTI) program is delivered as equity in the form of Performance Rights to executives. Vesting is conditional on assessment of achievement against a scorecard of performance conditions over a three-year performance period, covering both financial and strategic measures. The strategic component (15% of the scorecard) measures performance against strategic initiatives. The agreed strategic objectives for the 2025-2027 LTI include elements that relate to the Company's climate-related risks and opportunities: develop and deliver projects to achieve the Company's emission reduction targets and make meaningful progress on the Company's new energies and lower carbon agenda; and successfully transition the Coles Express business, stand up the retail organisation and make material progress on rebranding the stores and repositioning the offer.

On average, 9% of the total short-term incentives accrued in 2025 for the Executive Leadership Team were linked to climate-related considerations.

The 2023-2025 LTI included a 15% strategic component, with objectives relating to the Company's climate-related risks and opportunities as follows: develop and execute strategic options to grow non-fuel earnings; develop the Energy Hub at Geelong; develop and deliver projects to achieve the Company's emission reduction targets and make meaningful progress on the Company's new energies and lower carbon agenda; and successfully transition the Coles Express business, stand up the retail organisation and make material progress on rebranding the stores and repositioning the offer.

StrategyStrategy

AASB S2 paragraphs 10–11

Climate-related risks and opportunities

Reported

Assessing climate-related risks and opportunities

Our assessment relies on both quantitative and qualitative factors to identify and assess material climate-related risks and opportunities and their potential impacts on our business model and value chain. Our assessment draws on climate scenario analysis, our Enterprise Risk Management framework and governance processes, as well as inputs from internal and external subject matter experts. Through this work we continue to identify, assess, prioritise and monitor climate-related risks and opportunities.

Through our assessment, we identified the following as material climate related risk and opportunities for our business:

  • Transition risk (policy / legal) – Exposure to climate related government regulations that impose an additional cost of carbon.
  • Transition risk (market / technology) – The demand destruction of traditional fuels driven by technological advancements (electrification of the transport fleet and improved fuel efficiency) and consumer preferences.
  • Transition opportunities (market / technology) – Increased demand for low emission or alternative fuels such as biodiesel, renewable diesel and sustainable aviation fuel (SAF), as well as EV charging infrastructure, are opportunities to retain and diversify revenue sources.

We maintain ongoing oversight of a broad range of climate-related risks and opportunities. While many of these are not currently assessed as material, we anticipate that additional climate-related risks (including physical climate risks) and climate-related opportunities may emerge over time as internal priorities and external operating conditions evolve.

Transitional climate risks

Exposure to climate related government regulations that impose an additional cost of carbon

Description: Increasingly Australian climate regulations and policy commitments, such as the Safeguard Mechanism (SGM), increase compliance requirements and costs, and may adversely impact our business. The SGM is currently the Australian Government's primary mechanism for meeting its international emission reduction obligations. As the Geelong Refinery is a high-emitting facility, the SGM poses a significant risk to unrecovered cost increases in our business in both the short and long term. Future regulations that mandate emissions reductions for the Group may be strengthened over time, increasing the cost of compliance and influence the Group's investment decisions.

Potential consequence: Increased compliance / operational costs, additional capital required for decarbonisation investments. Higher operating costs impacting the competitiveness of our locally manufactured products. Whether the risk of any future government regulation or policy eventuates or is material to the business will depend on the nature and application of the regulations.

This is classified as a transitional risk (policy/legal). Time horizons identified: short term, medium term and long term.

A reduction in demand for hydrocarbon fuel products

Description: It is anticipated that a combination of Government policy, improved fuel efficiency of vehicles and access to new technologies will result in displacement of existing gasoline, diesel and jet fuel sales over the medium to long term. The rate of this displacement is expected to vary across segments. The pace and timing of the transition will have a direct impact on the investment returns for new fuel infrastructure, and our ability to align our strategy with this transition will determine how effectively we adapt our infrastructure and operations to address this risk.

Potential consequence: Financial – reduced sales of traditional fuels, resulting in reduced revenue, and potentially lower margin contribution and obsolete assets and infrastructure.

This is classified as a transition risk (market/technology). Time horizons identified: short term, medium term and long term.

Transitional climate opportunities

Increased demand for low-carbon liquid fuels (LCLFs)

Description: LCLFs will play an important role in decarbonising the fuel pool by providing a drop-in replacement alternative for hard to abate sectors, important for key sectors including mining, aviation and long haul transport where electrification will be difficult or expensive. Government policy (both demand-side and supply-side) will be a key driver of LCLF uptake in Australia. As LCLFs are a drop-in fuel replacement, they are highly compatible with existing terminal and supply chain infrastructure. The Group's opportunity in LCLFs relates to both the manufacture and the supply of these products, with the Geelong Refinery central to the LCLF manufacturing opportunity.

Potential consequence: Financial – increased sales of LCLFs, resulting in retaining and increasing revenue. Reputational – through manufacturing and distribution of LCLFs, we may have the opportunity to strengthen our reputation as a credible contributor to the energy transition and respond to growing stakeholder expectations for low-emissions fuel solutions.

This is classified as a transition opportunity (market/technology). Time horizons identified: short term, medium term and long term.

Physical risks consideration

Our risk assessment identified a range of other climate-related risks and opportunities which are currently not reasonably expected to affect the Group's prospects. This includes an assessment of the Group's direct exposure to physical climate risks, which at this stage are not assessed as posing a material risk to our business or assets under any scenario or time horizon. We note that the Geelong Refinery, the Group's largest asset, is exposed to a risk of more frequent and severe extreme wind and storm events, which have the potential to interrupt power supply and processing reliability.

Time horizon definitions

Our scenario analysis was undertaken across three time frames:

  • Short term = Beyond 2025 and up to 2030: Considers short-term external developments, including emerging government policies, uptake of emerging technologies, and shifts in customer demand. Takes into account the Group's budget and operational planning through to 2030.
  • Medium term = Beyond 2030 and up to 2040: Considers more significant structural changes in energy systems, investment patterns, and regulatory frameworks. While the Group may be able to respond to these changes, doing so is likely to involve substantial capital expenditure. Policy settings may also significantly change over this time period, requiring ongoing flexibility in decision-making.
  • Long term = Beyond 2040 and up to 2050: Considers possible long-term structural developments and end state pathways associated with decarbonisation and broader transitions across our economy and industries.

We initially conducted a climate risk and opportunity scenario assessment in 2024, evaluating results across three timeframes: short term (2030), medium term (2040) and long term (2050). During 2025 we reviewed this modelling and resilience assessment to ensure it remained relevant and aligned with the latest insights on climate-related impacts across the Group's operations, business model, and strategy.

AASB S2 paragraph 13

Business model and value chain

Reported

Business model and value chain

We source crude oil (domestic and international) for domestic refining, and refined products from international refineries. We refine crude oil into usable products – including petrol, diesel, jet fuel and specialty products. We transport refined product to bulk storage fuel terminals by pipe or ship. Terminals are typically located near major metropolitan, industrial and mining centres (closer to end customers). We sell bulk fuel products directly to commercial customers. Fuel and convenience items are sold to retail customers through a nation-wide network of retail & convenience sites. The value chain stages are: 1. Procurement/Supply, 2. Domestic Refining, 3. Primary Distribution, 4. Storage, 5. Secondary Distribution, 6. Fuels Marketing, spanning the Energy & Infrastructure, Commercial & Industrial and Convenience & Mobility business units.

Concentration of climate-related risks and opportunities in the business model and value chain

For the transition risk relating to government regulations that impose an additional cost of carbon, the value chain and business line(s) affected are: Direct Operations for Energy & Infrastructure business (Geelong Refinery).

For the transition risk relating to a reduction in demand for hydrocarbon fuel products, the value chain and business line(s) affected are: Downstream for all business lines.

For the transition opportunity relating to increased demand for low-carbon liquid fuels (LCLFs), the value chain and business line(s) affected are: Downstream for Commercial & Industrial.

With around 90% of the Group's Scope 1 and 2 emissions originating from the Geelong Refinery, the refinery is central to the Group's decarbonisation strategy and to its long-term contribution to Australia's energy transition. The Geelong Refinery is also the Group's largest source of GHG emissions, accounting for 98% of the Group's Scope 1 emissions in 2025, and is most likely to be exposed to changing government policy.

Our risk assessment indicates that 100% of the Group's assets and business activities are vulnerable to climate-related risks and aligned with climate-related opportunities in some way, with climate-related impacts applying across the entirety of the business rather than being confined to a discrete subset of activities or assets.

AASB S2 paragraph 14

Strategy and decision-making

Reported

Energy and Decarbonisation Transition Plan

Viva Energy supplies approximately 25% of Australia's transport fuel needs through the Geelong Refinery and fuel importation. Our transition plan is designed to support the commercial viability of our business across the short, medium and long term, and to ensure we remain an active contributor through the energy transition. It comprises four key pillars:

  • Our energy transition – Reducing operational emissions through direct abatement, renewable energy procurement, and use of environmental offsets.
  • Supporting our customers – Delivering new energy solutions including LCLF imports, EV charging, and hydrogen refuelling infrastructure to meet our customer's requirements.
  • LCLF manufacturing – Advancing co-processing at the Geelong Refinery (a scalable, low-cost pathway to LCLFs) and planning for future dedicated LCLF production.
  • Energy transition value – Establishing an investment framework that supports sustainable shareholder returns through the transition.

In the short term, we plan to focus on establishing the foundations required to support scaled growth and adaptability throughout the energy transition, including building organisational and workforce capability to understand and respond to climate-related risks and opportunities. A key enabler will be securing appropriate settings under the renegotiated Fuel Security Services Payment (FSSP) during 2026. Other key government policy dependences include the regulation of market instruments we utilise as part of our transition plan, including the ACCUs scheme and Large-scale Generation Certificates (LGC) market.

Our transition plan needs to be flexible, and able to respond to the phased transition under Australia's Net Zero Plan and the climate-related scenarios, balancing readiness with flexibility as technologies scale and market signals strengthen. It assumes Australia will face increasing climate regulation, and the growth in medium to long-term demand for lower-emission fuel sources.

Our energy transition (Geelong Refinery)

During 2025, we primarily met our obligations under the Safeguard Mechanism (SGM) through the surrendering of ACCUs. We recognise that additional mitigation pathways will be required to strengthen the ability to achieve our decarbonisation strategy. The upcoming SGM review will help us shape this strategy. Our Scope 1 climate target aligns directly with the SGM.

We continue to identify and advance additional opportunities to reduce emissions at the refinery, including progressing electrification projects and improving energy efficiency across existing equipment and processes. Individual decarbonisation initiatives are assessed and prioritised based on their technical and financial viability. In 2025, we delivered emissions reduction projects across our operations, including during the Residue Catalytic Cracking Unit (RCCU) maintenance program.

The site's emissions profile means that most of the refinery's emissions do not currently have a viable reduction pathway in the short term - coke production accounts for around 30% of the refinery's emissions and cannot be displaced while the RCCU is in operation; combustion of refinery fuel gas accounts for around 30% of the site's total emissions. In the short to medium term, our key focus will be on reducing the volume of natural gas used to produce steam at the Geelong refinery, the most immediate and commercially viable abatement opportunity. Further emissions reduction at the Geelong Refinery will require cost-effective, technically mature solutions that enable direct abatement, as well as an upgraded grid connection to support greater electrification, and stable long-term policy settings.

Commercial & Industrial / Supply Chain

Our Scope 1 GHG emissions within our supply chain are largely in relation to our nation-wide terminal operations, and our Liberty Rural fleet. As these emissions are geographically dispersed, with no single point source, they present unique challenges for direct abatement opportunities. We continue to monitor emerging technologies and are working closely with our terminal partners to develop a pipeline of potential decarbonisation projects.

Convenience & Mobility

In 2024, our Convenience & Mobility business commenced a multi-year direct action program designed to reduce emissions across our retail network. To date, rooftop solar systems have been installed at 264 retail sites across Australia, delivering a total solar generation capacity of approximately 8,281 kW. The rooftop solar rollout, along with associated canopy LED lighting upgrades, are an essential part of our decarbonisation plan for the Convenience & Mobility business. Once complete, the estimated total emissions reduction associated with the solar program and LED lighting upgrades is 13.4k tonnes CO2e (tCO2-e) per year by 2029.

Supporting our customers

We continue to support our customers by expanding access to new energy solutions (including LCLF imports, EV charging, and hydrogen refuelling infrastructure). In 2025, our complex distribution networks were used to establish the ongoing delivery of sustainable aviation fuel (SAF) and renewable diesel (RD) into regional Australia. Examples during 2025 include: R30 renewable diesel trial with the Australian Defence Force; agreement to supply SAF to RAAF Base East Sale; supply of RD to the Formula 1 Australian Grand Prix 2025; marine biofuel trial with Royal Caribbean Group; supply of RD to Rio Tinto's Pilbara iron ore operations (reducing Rio Tinto's Scope 1 emissions by about 27,000 tonnes); and supply of SAF to Virgin Australia flights from Proserpine.

We continue to deploy EV charging into our retail network, including Australia's first truck-length, pull-through ultrafast EV charging bays. In June 2025, we launched the nation's first publicly accessible renewable hydrogen refuelling station at Corio, Geelong, using a 2.5 MW electrolyser and recycled water, incorporating ultra-fast battery-electric charging infrastructure for trucks and buses and traditional diesel supply.

In December 2025, we opened the Ultra Low Sulphur Gasoline (ULSG) plant at the Geelong Refinery, a $400 million project including a $150 million contribution from the Australian Government.

LCLF manufacturing

Increased demand for LCLFs represents a material climate-related opportunity, spanning both manufacture and supply. The Geelong Refinery provides an important platform for co-processing (our most scalable, low-cost pathway to LCLF manufacture) as well as plans for future dedicated LCLF production. In December 2024, the Geelong Refinery commenced co-processing used cooking oil through the RCCU, followed by tyre pyrolysis oil and soft plastic pyrolysis oil in May 2025. Scaling co-processing and dedicated LCLF production will require significant upfront investment in engineering and infrastructure readiness. To support investment decisions in LCLF manufacturing, three elements are critical: reliable feedstock supply chains, proven technology maturity, and a well-established end market. We will continue to make measured, disciplined investments in LCLF manufacturing while Government policy continues to evolve.

Investment framework

Investment in the energy transition is inherently complex and requires balancing the need to reduce our own emissions with the need to support our customers through their transition. In the short term, smaller-scale emissions reduction investments will play a critical role in testing climate-related opportunities, laying the groundwork to invest in new assets and processes for larger, scalable projects anticipated in medium to long term. Given the significant capital investment required, the Group will continue to regularly assess its investment program, adjusting the pace of investment in line with government policy enablers, technology developments and commercial returns. Capital investment decisions must balance emissions-reduction objectives and identified climate risks and opportunities with the disciplined allocation of capital across the Group's broader growth priorities.

Progress against previous plans

In 2021, the Company announced its commitment to reduce carbon emissions across its operations over the medium and long term, in relation to Scope 1 and 2 emissions, with voluntary targets set to guide decarbonisation approach (net zero Scope 1 and 2 emissions across non-refining operations by 2030, and a 10% reduction in emissions intensity at the Geelong Refinery by 2030). As part of a broader decarbonisation strategy review, the Company revised these climate targets in 2025 to ensure alignment with strategy, business model and the evolving external environment, given significant business model changes since 2021 (notably the establishment of the Convenience & Mobility business) and substantial reforms to Australian policy and regulatory landscape, including changes to the SGM.

Risk mitigation efforts (from risk and opportunity assessment)

For the government regulation/cost of carbon risk: Current and direct risk mitigation efforts include surrendering ACCUs to meet SGM obligations. In 2025, we invested $20 million in a series of capital projects at the Geelong Refinery aimed at reducing emissions where commercially viable, expected to deliver an estimated annual reduction of 29 kt Scope 1 emissions. We undertake regular monitoring, stakeholder engagement and policy advocacy in relation to potential future climate related policy and regulation. Future and indirect risk mitigation efforts include implementing electrification projects and improving energy efficiency of existing equipment and processes, reviewed and prioritised based on technical and financial viability.

For the reduction in demand for hydrocarbon fuel products risk: current and direct mitigation efforts include monitoring LCLF and EV uptake, policy developments and technology cost curves; New Energies and Future Fuels teams assess emerging technologies and alternative fuel options; establishing new supply chains for LCLFs across Australia and piloting LCLF manufacture at the Geelong Refinery; opening Australia's first renewable hydrogen refuelling station; advancing EV charging offering across retail network; actively monitoring climate policy developments and working closely with commercial customers to understand strategic and operational plans.

For the LCLF opportunity: we have established a dedicated Future Fuels Team responsible for monitoring emerging technologies, assessing diversified product offerings, and identifying viable alternatives; advancing plans to expand the production, distribution and sale of LCLFs.

AASB S2 paragraphs 15–21

Financial position, financial performance and cash flows

Partial
Partial disclosure: Relief from quantification is repeatedly and explicitly claimed for anticipated financial effects due to high measurement uncertainty; only limited current-period figures ($3.5m compliance cost, $2.2m LCLF contribution) are quantified. No explicit disclosure of inputs/assumptions distinguishing single amount vs range basis is provided beyond the scenario cost ranges reported separately under resilience.

Current financial effects

The Group incurred net compliance costs under the SGM in FY2025 amounting to $3.5 million. The Geelong Refinery currently holds Trade-Exposed Baseline-Adjusted (TEBA) status under the SGM, which reduced our cost exposure in 2025. While the current financial impact of the SGM is not considered material to the Group's financial statements, it is the risk of increasingly demanding climate-related regulations and policies (and the resulting rise in compliance costs) in addition to the current SGM regulations that is regarded as a material anticipated risk for the Group.

In 2025 the Company continued to see resilience in the Australian fuel market. There continues to be growth in fuel usage despite signs of increased uptake of low-carbon liquid fuels (LCLFs) and EVs. The Australian fuel pool grew from 58.1 billion litres in 2024 to 58.9 billion litres in 2025. The total number of registered passenger vehicles in Australia has increased from 15.6 million vehicles in 2024 to 15.99 million vehicles in 2025. Petrol and diesel vehicles remain at 94% of the market share, with the remaining made up of hybrids (4%) and EVs (2%). This risk did not have a material impact on the Group's financial position, performance and cash flows in 2025.

The opportunity presented by LCLFs remains in its early stages, with current investment limited in scale and financial contributions still minor, $2.2 million in 2025. Our supply, together with volumes identified through publicly available information, represented less than 0.05% of the total fuel market in Australia in 2025.

Anticipated financial effects

The Federal Government is scheduled to review the SGM in FY2026–27, creating uncertainty regarding potential changes to the scheme. The financial implications of the future SGM and how these compliance costs will impact the Group's income statement, balance sheet and cash flows in the future is currently unknown. Any estimates for future SGM cost consider three major factors – the eligibility of the Group's TEBA status, the forecast increases to future ACCU prices, and the impact of any future direct abatement initiatives at the refinery. The level of measurement uncertainty involved in estimating the effects of these factors on our cost of SGM compliance is so high that the resulting quantitative information would not be useful. In addition, the cost to the Group of any future climate policy is unknown, and therefore currently unable to be quantified. The risk of heightened climate-related regulatory requirements is expected to lead to increases in our compliance costs in the medium to long term, as well as potentially large capital expenditures to reduce emissions which may not be recoverable from the market. In the medium to long term, the level of capital investment capable of generating positive returns is expected to decline.

While the current financial impact of the decline in demand for fuel is not currently considered material, it is the risk of increasing fuel displacement in the medium to long term that is regarded as a potential material risk for the Group. With the average age of passenger vehicles at over 11 years, it will take time for the combined effects of improved fuel efficiency and EVs to materially impact the gasoline pool. While there remains a level of measurement uncertainty involved in quantifying the financial impacts of this risk in the medium to long term, analysis suggests that these trends will have a material impact on the Group's revenue from hydrocarbon fuel sales, future product mix, infrastructure investment, and asset planning decisions over the medium to long term. As a result of these uncertainties and the interdependencies between fuel demand and broader economic drivers, it is not currently possible to quantify a range that reliably supports the anticipated financial impacts of this transition risk.

With existing investments in the processing, distribution and sale of LCLFs, the Group is well positioned to benefit from this opportunity as supporting infrastructure continues to mature. Future government policy settings and evolving customer demand will play a key role in shaping the growth trajectory of LCLFs. Given the current uncertainty in both areas, the potential future financial impact of this opportunity cannot yet be reliably quantified. At this stage, we are unable to reliably estimate capital expenditure for anticipated investments in supply chains or LCLF manufacturing. Given the current uncertainty in market uptake, policy settings, and funding pathways, capital requirements cannot yet be quantified with reasonable accuracy.

The financial impact of future weather events at the Geelong Refinery is difficult to estimate due to uncertainty in climate projections beyond 2030 and the variability of key factors such as prevailing refining margins, lost throughput during shutdowns, and the duration and timing of the interruption. These factors can fluctuate significantly, limiting the ability to forecast future financial impacts with any certainty. As a result, no sustained or cumulative deterioration in earnings, balance-sheet values or cash-flow forecasts has been identified in relation to physical climate risks.

AASB S2 paragraph 22

Climate resilience and scenario analysis

Reported

Business resilience to climate-related risks and opportunities

Climate scenario analysis plays an important role in identifying and assessing our material climate risks and opportunities, as well as the resilience of our business model and strategy. Our scenario analysis assesses the broader business operations, with a particular focus on our refinery operations in Geelong, Victoria.

Our scenario analysis incorporates scenarios based on the projections of various external data sources. Transitional risks and opportunities were assessed relying on the scenarios of the International Energy Agency (IEA) and data from the Australian Energy Market Operator (AEMO) to provide Australian specific information for the gas and electricity sectors. Physical climate risks were assessed based on scenarios from the Intergovernmental Panel on Climate Change (IPCC) Sixth Assessment Report on Climate Change (2021). These sources informed our scenarios, representing a range of potential global outlooks and energy transition pathways.

We initially conducted a climate risk and opportunity scenario assessment in 2024, evaluating results across three timeframes: short term (2030), medium term (2040) and long term (2050). During 2025 we reviewed this modelling and resilience assessment to ensure it remained relevant and aligned with the latest insights on climate-related impacts across the Group's operations, business model, and strategy.

Scenarios used

  • Transition climate scenarios (IEA & AEMO): Low Warming Scenario – ambitious scenarios that limit global warming to 1.5ºC above pre-industrial levels, consistent with Australia's Climate Change Act (2022). High Warming Scenario – scenarios most aligned with current global progress in emissions reduction, assuming no changes to current policy settings, associated with a projected temperature increase of more than 2.5ºC.
  • Physical climate scenarios (IPCC): Shared Socioeconomic Pathway (SSP) 1-2.6 – a low emissions scenario likely to keep global warming below 2ºC relative to pre-industrial levels, aligned to Paris Agreement commitments, which would substantially reduce the projected increases in extreme weather events. SSP5-8.5 – a high emissions scenario, assuming no additional climate policy, under which emissions almost double by 2050, with changes in the climate system intensifying, including increasing heat extremes, severe drought, extreme rainfall, flooding and fire weather.

Our scenario analysis was undertaken across three time frames (short term = beyond 2025 up to 2030; medium term = beyond 2030 up to 2040; long term = beyond 2040 up to 2050), noting the rate of change across different fuel types is a major consideration, with passenger vehicles (gasoline demand) expected to transition at a different pace than transport vehicles utilising diesel and jet fuels.

Under all pathways, we continue to see that the Group has a role in both: (1) Security of supply – ensuring fuel and energy supply remains safe, reliable and efficient, and secure as the energy transition progresses; and (2) Energy transition – developing, commercialising and delivering low carbon liquid fuels and alternatives to support customers through the energy transition.

Short term resilience

Our analysis indicates that the Group's operations demonstrate resilience under both scenarios. Increased demand for LCLFs offsets the risk of declining demand for hydrocarbon fuel products under both low and high warming scenarios, as LCLF functions as a transition fuel rather than creating new demand or additional sales growth. The New Vehicle Efficiency Standard (NVES) is not expected to have a material impact on the Group's position under either scenario, as the expected age profile of the Australian passenger fleet limits its influence on short-term demand for hydrocarbon fuel products. Across both scenarios, the Group is expected to be exposed to some cost of compliance in relation to government climate policy, though the cost of this compliance is highly uncertain given the variability and interdependency of measurement inputs, such as emissions forecasts, future application of unknown policy, and forecast ACCU prices, making the ultimate impact too uncertain to quantify.

The Geelong Refinery is currently required to comply with the SGM and is the Group's largest source of GHG emissions (accounting for 98% of the Group's Scope 1 emissions in 2025). For scenario analysis purposes, we projected the future emissions profile at the refinery based on assumed feedstock volume and quality over a five year period, and considered variables including the potential impact of direct abatement investment, the future application of TEBA and a range of forecast ACCU prices.

Under the low warming scenario, we assumed maximum direct abatement reduction of emissions at the refinery, considering a range of potential ACCU prices and TEBA eligibility outcomes. Based on these hypothetical assumptions, the associated short-term compliance costs to the Group under the low warming scenario are estimated to range from $57.4 million to $105.2 million cumulatively to 2030.

Under the high warming scenario, we assumed no further direct abatement is achieved at the refinery. Applying the same range of potential ACCU prices and TEBA eligibility outcomes, the associated short-term compliance costs under the high warming scenario are estimated to range from $63.1 million to $112.8 million cumulatively to 2030.

Medium and long term resilience

Our analysis suggests that the Group's operations demonstrate medium-term resilience under both scenarios. However, this exposure is expected to increase over time, driven by anticipated regulatory expansion, technological developments and changes in consumer preferences. Over the medium and long term horizons, impacts under both low and high warming scenarios did not result in any immediate re-rating of existing risk ratings established through our broader risk management processes.

The assessment of climate-related risks and opportunities over these timeframes is inherently complex due to the unpredictable nature and uncertainty of market trends and policy developments. Furthermore, the long-term scenario analysis contemplates a future in which our business in its current form (including the Geelong Refinery) may no longer be viable. The medium to long-term impacts under either scenario cannot, therefore, be quantified with any degree of certainty at this stage.

We will continue assessing climate-related risks and opportunities to inform our business strategy and long-term planning, particularly as key decisions, such as the Fuel Security Services Payment (FSSP) negotiations, are finalised. Our strategy focuses on building a flexible foundation to support adaptation to changes in decarbonisation and climate policy, regulatory frameworks, and demand for traditional fuels.

Capacity to adjust

In relation to capital allocation, our current approach to managing climate-related risks is largely focused on purchasing ACCUs to meet regulatory obligations under the SGM. The upcoming SGM review in 2026 and 2027 will also shape our future decarbonisation strategies once finalised. While climate change poses potential risks to existing operations and infrastructure, we are well positioned to adapt our infrastructure and operations to capture emerging opportunities. We have been investing in opportunities to repurpose our existing infrastructure for LCLFs, co-processing and electrification solutions, positioning the business to respond to customer demand as it emerges. Our strategy, planning, and capital allocation approach is designed to enhance our business resilience and long-term performance. Maintaining our strategic flexibility is critical to navigating a range of possible future scenarios.

Risk ManagementRisk Management

AASB S2 paragraphs 24–26, Aus26.1

Processes for identifying, assessing and managing climate-related risks

Reported

Climate-related risk management

Our Group is exposed to climate-related risks, across multiple time horizons. In order to identify, assess and manage these risks, we apply our Enterprise Risk Management (ERM) Framework, along with our risk management policies and procedures. The ERM Framework is designed to ensure that appropriate systems are in place to identify material risks that may impact the Group's business, understand their potential financial impact, and implement effective internal control systems to limit exposure. It also establishes clear responsibilities for managing these risks, and articulates the Company's risk appetite.

Our ERM Framework and related Risk Registers enable us to consider our climate-related risks alongside other key categories of risk such as compliance and regulatory risks, Health, Safety, Security and Environment (HSSE) risks, and data and systems risks. The Risk Registers undergo regular reviews to account for changes in our internal and external environments, as well as the likelihood and impact of each identified risk.

The ERM Framework guided our detailed analysis of specific climate-related risks. Risk analysis aims to understand the nature of risk and its characteristics, including the level of risk for the Group. This process involves examining uncertainties, sources, consequences, likelihood, scenarios, and the effectiveness of existing controls. Each risk is then assigned a rating based on this evaluation. We applied the ERM Framework's risk assessment criteria and rating scale to determine the likelihood and consequence of each identified climate-related risk across the Group's operations. This analysis enables integration and comparison with other Group-wide risk assessments.

Climate-related opportunities are considered as part of our approach to mitigating emerging risks, including impacts associated with declining demand for hydrocarbon fuel products.

Under the ERM Framework, climate-related risks are reviewed and updated annually. Risks are also assessed throughout the year, when material changes occur in regulatory, economic, or physical climate factors. Risk assessments are undertaken at a Group-level, using publicly available geospatial data sets to analyse business and asset-specific data, including indicators such as rainfall, flood inundation, fire weather index and historic cyclone wind speed, recognising the increasing levels of uncertainty in the data over time. These datasets inform evaluations of physical climate risks based on our operational locations. We apply this data under the two climate scenarios and ERM Framework parameters to determine the likelihood and consequences of climate-related physical risks. Climate-related transition risks are assessed using various scenario indicators covering policy and legal, technology, and market risks.

The ERM Framework is aligned with the principles of ISO Risk Management Guidelines ISO 1300:2018. Our risk management system is embedded throughout the organisation, from the Board level, where there is oversight of risk strategy and policy-setting, to day-to-day operational activities, over which management has primary responsibility. The Audit and Risk Committee and the Sustainability Committee have primary oversight of Lines 2 and 3 of the 'three lines model', which is the foundation of the Group's risk oversight and governance approach.

Metrics & TargetsMetrics and Targets

AASB S2 paragraphs 29–31

Climate-related metrics

Reported

Greenhouse gas emissions

The Group applies the operational control approach to establish its organisational boundary for the reporting of Scope 1 and 2 GHG emissions, in line with obligations under the National Greenhouse and Energy Reporting Scheme (NGERS). Viva Energy Group Limited maintains operational control over its controlled entities.

Direct GHG emissions from sources that are owned or controlled by businesses and operations within the Group's organisational boundary are reported as the Group's Scope 1 GHG emissions. GHG emissions from the generation of purchased electricity consumed by these businesses and operations are reported as the Group's location-based Scope 2 GHG emissions. Scope 3 emissions are the indirect GHG emissions that occur across the value chain and arise from activities not directly controlled by the Company; these are voluntarily reported.

Breakdown of Total Scope 1, 2 & 3 GHG emissions (1 January 2025 to 31 December 2025)

CategoryEmissions (tCO2-e)
Purchased goods and services (Scope 3)6,260,174
Upstream transportation and distribution (Scope 3)675,232
Business travel (Scope 3)6,795
Employee commute (Scope 3)10,290
Our operations (Scope 1)994,660
Purchased electricity for our operations (Scope 2)361,366
Use of sold products (Scope 3)41,970,442
Franchises (Scope 3)1,402
Downstream transportation and distribution (Scope 3)101,073

Upstream activities represent 14% and Viva Energy (Scope 1 and 2) represent 3% of the diagram breakdown; downstream activities represent 83% of total Greenhouse Gas emissions.

These emissions represent the Group's gross GHG emissions. The Group's climate targets are based on net GHG emissions and incorporate the use of ACCUs and LGCs.

Scope 1 – method and measurement

The Group's Scope 1 GHG emissions have been prepared in accordance with obligations under NGERS, ensuring methodologies, emissions factors and operational control reporting boundaries are applied in a way that is consistent with legislative requirements and aligns with recognised Australian emission measurement and reporting standards. The Geelong Refinery is the Group's largest source of GHG emissions, accounting for 98% of the Group's Scope 1 emissions in 2025. The refinery's Scope 1 GHG emissions are calculated based on: direct measurement of energy consumption (pressure and flow indicators into furnaces, calibrated to industry standards); calculations of refinery coke combusted using calibrated flow and pressure instrumentation; and quantities from invoices for natural gas import and crude oil/feedstock. A combination of Method 1 (default method, based on national average estimates) and Method 2 (facility specific method using industry sampling practices and Australian or equivalent standards) emissions factors are used to convert energy quantities to reportable GHG emissions. Method 2 emission factors are used for the site's largest fuel gas consuming furnaces; Method 1 emission factors are employed for minor fuel gas streams and non-gas energy.

2025 performance: During 1H2025, energy efficiency and emissions intensity at the refinery was broadly consistent with 2024. The largest event impacting emissions intensity during this period was the month-long maintenance event of CDU3, which reduced site feedstock consumption by 24% without a corresponding decrease in site emissions (4%). Energy and emissions performance in 2H2025 was impacted by the RCCU Turnaround (late July to mid-October 2025); as the RCCU is the site's most emission-intensive unit, its shutdown resulted in a significant reduction in the refinery's emissions intensity. Cracker coke yield, and therefore emissions from coke combustion, were lower in 2025 compared with 2024 due to a lighter (lower-carbon) average feed quality to the unit, estimated to have resulted in an emissions decrease of approximately 25,000 tCO2-e in 2025 compared with 2024. In October, the new ULSG plant was brought online; emissions associated with this new unit are expected to be largely offset by energy efficiency initiatives delivered on the RCCU during the 2025 Turnaround. The ULSG plant, together with the site's newly electrified catalyst cooler air blower, is expected to increase the site's ongoing electrical load by approximately 12%.

Scope 2 – method and measurement

The Group's Scope 2 GHG emissions have also been prepared in accordance with NGERS obligations. In addition to mandatory location-based Scope 2 emissions reporting, in 2025 the Group also commenced reporting market-based Scope 2 emissions on a voluntary basis. The majority of Scope 2 emissions were reported using metered electricity consumption data based on invoices received from utility providers. For some smaller facilities, Scope 2 emissions were estimated using a cost-allocation methodology based on tenancy space, representing 0.1% of total reported Scope 2 emissions. Emissions factors were sourced from the Department of Environment, Climate Change and Water's Australian National Greenhouse Accounts Factors, with 2024-25 data applied for 1H2025 and 2025-26 data applied to 2H2025.

2025 performance: The Group's Scope 2 emissions (calculated by location-based reporting) increased by 0.4% during 2025. Market-based emissions of 390,684 tCO2-e are reported for the first time in 2025, utilising a specific residual mix emission factor of 0.81 regardless of location, with any renewable component based on actual procurement of renewable energy through the surrender of Large Generation Certificates (LGCs). This methodology was adopted to ensure that Viva Energy Hub and EV electricity use is correctly offset with renewable energy certificates, to support Net Zero climate claims under the Clean Energy Regulator's legislative framework.

Scope 3

The Group's Scope 3 emissions arise from activities across the value chain, representing GHG emissions that occur outside the Company's ownership and direct control. The Group has elected to voluntarily disclose its Scope 3 emissions and has applied the transitional relief available under AASB S2 for this reporting period.

In 2025, the Group recorded a 6.2% increase in total Scope 3 emissions compared with 2024, with a total reported footprint of 49,025,408 tCO2-e. The most significant contributing category was Category 11 (use of sold products), representing approximately 85% of total Scope 3 emissions, equivalent to 41,970,442 tCO2-e.

Transition risks

Our risk assessment indicates that 100% of the Group's assets and business activities are vulnerable to climate-related risks in some way, with climate-related impacts applying across the entirety of the business rather than being confined to a discrete subset of activities or assets.

Physical risks

Our risk assessment indicates that 100% of the Group's assets and business activities are vulnerable to climate-related risks in some way; climate-related impacts apply across the entirety of the business rather than being confined to a discrete subset of activities or assets. For example, the Group has identified a material climate-related risk associated with a reduction in demand for hydrocarbon fuel products, which is expected to impact all business lines over the medium to long term.

Opportunities

Our risk assessment indicates that the Group's assets and business activities are aligned with climate-related opportunities in some way, with increasing demand for LCLFs and other new energies solutions providing opportunities across the Group's entire business model and value chain, from LCLF manufacturing at the Geelong Refinery, to the supply of LCLFs and other new energies to both commercial and retail customers.

Capital deployment

In 2025, the amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities by the Group was $32.4 million (exclusive of Government Grants). This 2025 investment relates to emissions reductions initiatives, new energies infrastructure, repurposing assets for the storage and supply of LCLFs, and co-processing opportunities. For example, in 2025 we received Government funding to repurpose an existing tank at our Pinkenba terminal for the storage and handling of neat SAF. We invested $85.5 million in 2025 (excluding Government contributions) to increase sulphur recovery and improve air quality emissions from fuel use through our ULSG plant at the Geelong Refinery.

Internal carbon prices

When developing new business cases for infrastructure projects that may directly or indirectly impact the Group's GHG emissions, we assess projected changes in energy consumption across electricity, natural gas, and fuel use, converted into metric tonnes of GHG emissions. To quantify the associated carbon cost, the Group applies published ACCU and renewable certificate prices:

  • For natural gas and liquid fuel consumption, the midpoint between Reputex and Government Guaranteed price of ACCUs is applied. In 2025 ACCU prices ranged from $33 to $35.50 per ACCU, with an average price of $34.25 per ACCU.
  • For electricity consumption, internal carbon pricing uses the midpoint of Reputex's published high and low case predictions. In 2025 the predicted LGC price ranged from $6.25/MWh to $10/MWh with an average price of $8.13/MWh.

This approach enables a consistent and transparent valuation of emissions impacts within project evaluations and supports capital allocation decisions aligned with the Group's decarbonisation strategy.

Remuneration

Certain 'strategic' and 'safety & ESG' measures within the STI program are linked to the Company's climate-related risks and opportunities. On average, 9% of the total short-term incentives accrued in 2025 for the Executive Leadership Team were linked to climate-related considerations. The 2025-2027 LTI strategic component (15% of the scorecard) also includes objectives relating to climate-related risks and opportunities, including delivering projects to achieve the Company's emission reduction targets and progress on new energies and lower carbon agenda.

AASB S2 paragraphs 33–36, Aus37.1

Climate-related targets

Reported

Climate-related targets

In 2021, the Company announced its commitment to reduce carbon emissions across its operations over the medium and long term, in relation to Scope 1 and 2 emissions. Voluntary climate related targets were set at that time, business unit specific, targeting net zero Scope 1 and 2 emissions across non-refining operations by 2030, and a 10% reduction in emissions intensity at the Geelong Refinery by 2030.

As part of a broader decarbonisation strategy review, the Company revised its climate targets in 2025 to ensure they remain aligned with strategy, business model and the evolving external environment. Our revised climate targets reflect two transition pathways: Scope 1 – the Geelong Refinery will deliver emissions reductions in line with Safeguard 2030 baseline reductions; Scope 2 – Viva Energy will procure 40% of its required electricity from renewable energy by 2030.

Scope 1 emissions target / SGM requirements

The Geelong Refinery will deliver emissions reductions in line with Safeguard 2030 baseline reductions. The Group is required to meet this target under law (the National Greenhouse and Energy Reporting Act 2007) and related regulation (National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015).

  • Reduce refinery feedstock emissions intensity to 0.138 tCO2/kL feedstocks (approximately 95% of Refinery Scope 1 emissions). This is the expected Safeguard baseline for 2030, delivered through a combination of offsets and emission reduction investments at the refinery, representing a reduced emissions intensity of 14% compared to the FY2018-22 average (base period).
  • Reduce electricity generation emissions intensity to 0.501 tCO2/MWh generated (approximately 5% of refinery Scope 1 emissions). This is the expected Safeguard baseline for 2030, representing a reduced emissions intensity of 42% vs FY2018-22 average.

The Geelong Refinery is the Group's largest source of GHG emissions, accounting for 98% of the Group's Scope 1 emissions in 2025. As a SGM facility, the Geelong Refinery's emissions reduction target is set by the scheme's mandated baseline decline, currently applying the Trade-Exposed Baseline Adjusted (TEBA) discounted baseline decline rate; the Geelong Refinery currently qualifies as a TEBA facility, but its baseline decline would increase if its TEBA eligibility changes in the future. Australia's net zero goal and emissions reduction commitments, including the SGM, form part of Australia's commitment to the Paris Agreement.

Pathways to achieving Scope 1 target

The Scope 1 target is a net GHG emissions target. To meet SGM obligations, ACCUs will be surrendered annually to address the gap between actual emissions intensity and the refinery's 2030 baseline target. In the year ended 30 June 2025, the Group's Scope 1 refinery emissions were 1,061,314 tCO2-e, resulting in a SGM liability of 106,587 tCO2-e for the period. To meet its 2025 SGM compliance obligations, the Group will retire 106,587 ACCUs in February 2026, at a cost of $3.5 million. The retirement of these ACCUs allowed the Group to meet refinery feedstocks emissions intensity of 0.149 tCO2-e/kL and refinery electricity generation emissions intensity of 0.785 tCO2-e/MWh generated.

We have begun investing in emissions reduction initiatives at the Geelong Refinery, including the Packinox project completed in 2023 ($17.8 million capital investment generating approximately 14,000 tonnes of emissions abatement). Energy efficiency projects totalling $13 million were also implemented during the 2025 RCCU turnaround and are expected to reduce annual Scope 1 emissions by 29kt. Performance against forecast abatement outcomes will be monitored and reported. Any future major emissions-reduction investments at the refinery are constrained by operational requirements and can only be implemented during the planned 2030 Turnaround, meaning associated abatement benefits would be realised only after 2030. The SGM is regulated and administered by the Clean Energy Regulator. Our progress against this target will be monitored internally and reported accordingly.

Scope 2 emissions target

Viva Energy will procure 40% of its annual required electricity from renewable energy by 2030. This is a voluntary, gross target (renewable-energy procurement target rather than an emissions-reduction target), reframed from the prior emissions-reduction formulation to take a more proactive and strategic approach to managing Scope 2 emissions. This target has not been validated by a third party. Progress against the target will be monitored internally using MWh data and reported accordingly.

Pathways to achieving Scope 2 target

To support its decarbonisation pathway and net zero ambitions, the Group purchases Large Generation Certificates (LGCs) to cover a portion of energy consumption, received monthly through a Power Purchase Agreement (PPA), with a further 20,000 LGCs secured annually under an external forward agreement. Renewable electricity is sourced from a range of suppliers, including through a 10-year PPA with renewable energy generator ACCIONA Energía, providing renewable electricity from the Mt Gellibrand Wind Farm near Colac, Victoria. In 2025, LGCs voluntarily surrendered by the Group for the Viva Energy Hub and EV charging infrastructure represented 621 MWh, or 0.1% of the Group's electricity usage. Remaining LGC holdings will be retained as inventory and surrendered progressively from 2028 to support achievement of the Scope 2 emissions target and ongoing compliance with the Renewable Energy Target (RET). LGCs will be surrendered at the end of each year.

2050 ambition

The Company's ambition is to achieve Net Zero Scope 1 and 2 emissions across all operations by 2050. Achievement will depend on several external factors, including the long-term planning and future of the Geelong Refinery, a framework that supports customers' own energy transitions, and supportive and stable government policy.

Carbon Credits

Elements of the Group's decarbonisation strategy and climate targets rely on the use of Australian Carbon Credit Units (ACCUs) and Safeguard Mechanism Credits (SMCs). While the Group does not currently hold any SMCs, these credits are expected to play a role in future compliance strategies as the SGM evolves. Both ACCUs and SMCs may be used to achieve the same regulatory compliance outcome (reduction or removal of one tonne of CO2-e upon surrender to the Clean Energy Regulator, subject to eligibility requirements). The Group intends to utilise ACCUs, alongside LGCs, as part of its broader decarbonisation pathway.

As at 31 December 2025, the Group holds a diversified portfolio of ACCUs comprising approximately 30% technology based units and 70% nature based units, with the balance comprising other eligible methodologies. These ACCUs include both emissions reduction and removal credits and are eligible for compliance use under the SGM, based on current CER guidance. The Group's ACCU inventory includes credits issued under two sunset methods, Human Induced Regeneration and Avoided Deforestation, both of which remain eligible for SGM compliance under current CER guidance. Non-generic technology-based projects, such as landfill gas, have also been evaluated and confirmed as suitable methods for future compliance use.