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Strategy and decision-making

AASB S2 paragraph 14

How the entity has responded and plans to respond to climate-related risks and opportunities in its strategy and decision-making, including its climate-related transition plan, how it plans to achieve any targets, and how it is resourcing those plans.

What the standard requires
  • 14(a)(i)Current and anticipated changes to the business model, including resource allocation
  • 14(a)(ii)–(iii)Direct and indirect mitigation and adaptation efforts
  • 14(a)(iv)Climate-related transition plan, including key assumptions and dependencies
  • 14(b)How the entity is resourcing those plans
  • 14(c)Quantitative and qualitative progress against prior disclosures

Company disclosures (45)

Electric & Gas Utilities

Index: 14(a)–(c) map to sections 12, 12.1, 13, 14.2 and 17.2.

Transition plan (pp.108–109). The 2025 Climate Transition Action Plan (CTAP) was approved by the Board and received majority support in a non-binding Say on Climate vote at the 2025 Annual General Meeting. It sets an ambition of 12 GW of new renewable and firming capacity by the end of 2035 (6 GW targeted by FY30); coal exit by the end of FY35; Scope 1 and 2 reductions against FY19 of 17% (FY24–FY26), 19% (from FY27) and 52% (FY35), then net zero following coal closure; and an ambition of net zero Scope 1, 2 and 3 by 2050. Updated plans are expected in 2028.

Resourcing (pp.109–110). About $10 billion of balance sheet capital across the transition, heavily weighted toward firming. Expected capital allocation to climate solutions: 79% (FY27–30), 63% (FY31–35), 69% (FY27–35).

Dependencies and assumptions (p.141). Third-party coal closures and grid decarbonization; stable supportive policy; unlocking non-market barriers; investment appetite; demand growth; electrification uptake; affordability; technology costs; offsets; macroeconomic conditions.

Mitigation and adaptation (14.2). Physical climate considerations are built into asset risk management, maintenance and capital planning (p.125). Customer offerings include EV solutions, flexible load products and a virtual power plant (p.128).

Progress (p.109). Annual Scope 1 and 2 reduction target outperformed each year FY24–FY26.

Asset & Wealth Management
Partial disclosure: No explicit transition plan (with key assumptions/dependencies), resourcing detail, indirect mitigation efforts with customers/suppliers, or progress against prior-period plans is disclosed; content is limited to current mitigation actions and strategic implications for each identified risk/opportunity.

Mitigation and adaptation efforts by risk/opportunity

Physical risk: Physical climate‑related events impacting the value of assets due to geographical location

Credit lending policy at AMP Bank incorporates climate change within acceptable security requirements. Any lending outside of policy requires higher delegation approval and is subject to stringent review to assess credit risk. Scenario analysis is partially integrated into the S&I strategic asset allocation process, leveraging external climate modelling criteria, incorporating considerations for physical and transition risk.

Transition risk: Emerging climate regulations and compliance obligations

Ongoing focus on compliance with climate‑related disclosure regimes, reinforcing transparency and credibility in managing regulatory risks. Strengthen ESG governance and compliance processes.

Transition risk: Investee companies and sectors fail to adapt to clean technology disruption and decarbonisation trends

Improving climate risk data and ongoing review of ESG integration into investment management processes.

Opportunities strategy implications

Monitor and review current ESG and sustainability themed investment options on a regular basis. Monitor market developments for new investment opportunities.

Implications on strategy and business model

Our business strategy includes actions which mitigate against climate (and other) risks including but not limited to:

  • Partial integration of climate considerations into the S&I strategic asset allocation process and providing specialist sustainable investment offerings more broadly.
  • Assessment of investments within our wealth management businesses that are likely to benefit from the energy transition.
  • Restricting our business lending activity to avoid potentially high‑risk sectors.

As we continue to mature our approach to climate scenario analysis to better inform how we integrate and manage climate‑related risks across our businesses, operations and value chain, we are actively exploring ways to embed sustainability into our business model and business activities by continuing integration of ESG considerations across lending and investment offerings, strengthening sustainability governance of emerging compliance requirements and enhancing climate‑related disclosures. These actions strengthen AMP's long‑term resilience and position our business to respond to emerging regulatory expectations, stakeholder demands, and market opportunities associated with climate change.

Fuel Refining & Retail

3.1 Strategy overview

Ampol's purpose is "powering better journeys, today and tomorrow", supported by its strategy to maintain and build strength in its core business while developing a platform to grow and evolve as customers navigate the energy transition. Ampol has continued to make progress across three pillars of its corporate strategy: (1) enhance the foundations of its integrated value chain and market position in transport fuels with a focus on maximising the value of Lytton and delivery of productivity improvements; (2) expand from the rejuvenated fuels platform by growing and segmenting its convenience retail offer, including the proposed acquisition of EG Australia (subject to ACCC approval) and rollout of U-GO and premium store formats; and (3) evolve the energy offer for customers by building foundations for the transport energy transition, focusing on EV charging and exploring lower carbon liquid fuels importation/domestic production.

Ampol uses 'signposts' to monitor the pace of the transition and calibrate strategy and capital allocation proactively. In 2025, Ampol's market signposts suggested the pace of transition to lower carbon liquid fuels has been slower than previously expected and is expected to be for the foreseeable future. In response, Ampol adapted its corporate strategy to: continue focusing on out-of-home EV charging and lower carbon liquid fuels where it believes it can deliver value; exit retail electricity and divest corresponding assets in Australia and New Zealand; announce the proposed acquisition of EG Australia (subject to ACCC approval) to provide a larger platform for EV charging network and the U-GO offering; and adopt a "wait and watch" stance on hydrogen given uncertain commercial viability as a transport fuel at scale in the medium term.

3.2 Climate transition planning

Released in 2021, the Future Energy and Decarbonisation Strategies outlined how Ampol planned to transition its existing assets, operations and business model to achieve net zero for its operations and build a climate-resilient business. Ampol's climate transition planning is integrated into its corporate strategy focusing on:

  • decarbonising Ampol's operations by addressing emissions associated with Scope 1 and 2 by setting an ambition to achieve net zero operational emissions (Scope 1 and 2) on an absolute basis across its Australian operations by 2040, supported by operational emissions reduction targets for 2025 and 2030;
  • responding to climate-related risks and opportunities by leveraging core assets/capabilities to establish positions in new energy products and services; and
  • contributing to the transition through industry collaboration, policy consultation and investment in scaling capabilities for future transport energy solutions.

These climate considerations are embedded into day-to-day operations through the business planning cycle, where business units plan initiatives to achieve business unit climate-related targets, measured via the performance scorecard and overseen by the Decarbonisation PRB. Business units provide resources to perform, monitor and report internally on decarbonisation initiatives. Pursuit of climate-related opportunities is predominately resourced through Energy Solutions operations across Australia and New Zealand, with a separate budget allocated for Energy Solutions operations and capital expenditure.

Enhance the core business – Decarbonise Ampol's operations

  • Ampol has defined a non-linear pathway to meeting its voluntary 2040 net zero ambition, including energy efficiency and upgrade projects, behind the meter solar panels, network rationalisation, renewable electricity procurement and grid decarbonisation. The pathway assumes Lytton will no longer operate as a traditional refinery by 2040, reducing Scope 1 and 2 emissions by approximately 800,000 tCO2e against the base year.
  • Ampol's operational emissions reduction hierarchy prioritises avoidance, reduction and replacement (in that order), assessed on a least cost abatement basis, over other decarbonisation approaches including offsets such as ACCUs.
  • Ampol prioritises physical abatement opportunities at Lytton refinery based on the most economically efficient outcome; Ampol was required to surrender 47,589 ACCUs for the 2024-25 reporting period to ensure compliance with the baseline decline rate (as modified by any TEBA facility determination).

Expand from the rejuvenated fuels platform – Respond to Ampol's climate-related risks and opportunities

  • Convenience Retail segmentation strategy, including rollout of value-oriented unstaffed offer, U-GO; and
  • expanded product and convenience offerings to support EV customers due to increased dwell times at retail sites.

Evolve the energy offer for customers – Respond to Ampol's climate-related risks and opportunities

  • Ampol plans to continue growing out-of-home EV charging networks across the retail network and complementary destinations through collaborations with third parties, expanding its B2B e-mobility proposition including extension of Ampol Card to include EV charging in Australia, launch of Z Energy new business charging card and online portal, and conducting pilots for business customers transitioning to lower carbon transport solutions.

Evolve the energy offer for customers – Contributing to the energy transition

  • exploring lower carbon liquid fuels including a potential production facility at Lytton refinery (Brisbane Renewable Fuels project, BRF), dependent on Australian Government policy settings;
  • evaluating a lower carbon liquid fuels co-processing facility at Lytton;
  • working with industry peers, investors and customers to develop the import supply chain for early adoption of lower carbon liquid fuels; and
  • participating in the Australian and New Zealand Climate Leaders Coalitions on reducing emissions from heavy haul transport and building domestic SAF demand.

Key assumptions and dependencies

Key assumptions include technological advancements and increased renewable energy in the Australian grid, underpinned by government policy supporting grid decarbonisation to meet the NDC submitted under the Paris Agreement. Dependencies include: strong collaboration with customers and industry peers to develop lower carbon solutions matching customer needs; participation in industry associations/climate coalitions for technical collaboration and policy advocacy; and development of domestic climate policy supportive of investment in decarbonisation activities and aligned with international climate policy.

3.2.1 Operational decarbonisation pathway to 2040

The diagram sets out Ampol's current operational decarbonisation pathway to 2040, including forward-looking information subject to uncertainties and dependencies, showing categories of emissions reduction projects/programs (2024 baseline excl. Lytton refinery, U-GO conversions, energy efficiency projects, renewable electricity/PPAs, grid decarbonisation, carbon credits) and Ampol's current expectations of emissions reductions these will deliver in total out to 2040.

Mitigation and adaptation efforts – Risk 1 (Reduced demand for traditional fuel products)

Ampol is committed to ensuring long-term resilience and meeting customer needs now and in future, balancing near-term customer service with investment in the future to enable transition to lower carbon products. Ampol's strategy is designed to be adaptive to climate policy, regulatory change and market signposts; the Board reviews strategic signposts twice a year and management reviews them quarterly. During 2025 Ampol unveiled its segmentation strategy for retail businesses, including U-GO, an unstaffed offer expected to be resilient as fuel volume declines accelerate due to lower cost to operate. The segmentation strategy enables the Ampol Foodary network to include EV charging as demand evolves. Ampol is diversifying earnings streams via EV chargers, lower carbon liquid fuels supply chain development, and non-fuel convenience retail sales, with 494 public DC charging bays and 338 workplace chargers deployed cumulatively to end of 2025. For heavy, long haul and aviation transport, Ampol is undertaking pilots exploring RD and SAF supplied through its import supply chain, exploring co-processing renewable feedstocks at Lytton to produce a blend of up to 5% RD, and investigating the BRF project (dependent on suitable long-term policy settings, with active dialogue with Government). Ampol has several levers to manage its portfolio as volumes decline including network and asset rationalisation, productivity enhancements, network segmentation, and margin and capital management, and in the medium to long term may participate in industry consolidation and infrastructure sharing.

Mitigation and adaptation, transition planning efforts – Risk 2 (Climate policy and regulatory uncertainty)

Ampol actively engages with governments and regulatory bodies to advocate for balanced policy outcomes supporting secure, reliable and affordable transport energy during the energy transitions, including engagement on policy/regulatory frameworks to support a lower carbon liquid fuels manufacturing industry in Australia. Ampol maintains a market presence in direct and secondary carbon markets to ensure access to units for Z Energy's NZ ETS surrender obligations. Ampol's strategy and capital allocation is designed to be adaptive to climate policy, regulatory and market signposts; the Board reviews strategic signposts and climate-related policy developments are reviewed as part of Decarbonisation PRB governance arrangements.

Strategic response – Opportunity 1 (EV charging)

Ampol's Convenience Retail network enables a premium public EV charging experience with differentiated amenities, and the retail segmentation strategy caters for EV charging customers with longer dwell times. Ampol has extended its EV charging network to third party sites through strategic alliances including with Stockland and Mirvac. Ampol intends to continue rollout of on-the-go charging across its retail network and third-party sites with investment in deployment to keep pace with anticipated demand based on regulatory settings and market signposts. Ampol's business charging offer is supported by its public network, integration with back-to-base charging, and a trial card offer encompassing EV charging and fuel; Ampol will continue to work with business customers to support fleet transition.

Strategic response – Opportunity 2 (Co-processed and lower carbon liquid fuels)

A key initiative Ampol is exploring is production of lower carbon liquid fuels at Lytton refinery, and in the medium term, co-processing of renewable feedstock alongside crude oil derived products at Lytton. A combination of Ampol's existing infrastructure and capabilities (e.g. Lytton) and broader distribution network with established channels to market and customer relationships can play a pivotal role in creating a national lower carbon liquid fuels ecosystem. To be viable, Ampol believes long-term policy settings supporting uptake of lower carbon liquid fuels will be key, including appropriate recognition of such fuels under formal emissions accounting methodologies.

Progress against previous plans

Ampol has progressed towards its climate-related targets and has updated its 2040 ambition and 2030 interim targets from 2026 (see Section 4 Metrics and targets, and Section 4.8.1 Target setting process and review approach).

Oil & Gas Producers

Transition plan (page 55). Beach does not maintain a stand-alone climate-related transition plan. Committed targets, actions and resources to enable the transition to a lower-carbon economy are described in the Sustainability Report. Beach states it is on track to achieve both 2030 targets, primarily through its investment in Moomba CCS.

Effects on strategy and decision making.

  • Physical Risk 1 (page 44): no effect in the short or medium term. Until indications of a sustained increase in the frequency or severity of weather events are observed, no resources will be deployed on mitigation or adaption efforts.
  • Transition Risk 1 (page 46): the approach to carbon management will be reviewed annually from FY26, and investment decisions consider the cost of carbon.
  • Transition Risk 2 (page 48): no changes to strategy or decision making are expected beyond what is considered in climate resilience testing.
  • Transition Risks 3 and 4 (pages 49–50): not currently affecting strategy or decision making.
  • Transition Risk 5 (page 51): Safeguard Mechanism uncertainty is captured in investment decisions where sensitivities on carbon liabilities are considered. Opportunity 1 (page 53): where appropriate, CCS is considered in well and facility designs.

Resourcing (page 43). Deploying additional capital or dedicated resources for mitigation or adaption is conditional on changes in risk profiles and supported by project economics and capital allocation processes.

Diversified Metals & Mining

Targets and plan (pp. 58–59). Medium-term target: cut operational GHG emissions (Scopes 1 and 2, operated assets) by at least 30% by FY2030 from a FY2020 baseline; long-term goal: net zero by CY2050. BHP says it is on track for FY2030 and expects progress to be non-linear. Its second Climate Transition Action Plan (CTAP 2024) was published in August 2024, with some assumptions since updated.

Actions and dependencies (pp. 55–61).

  • Renewable electricity through PPAs (80% of electricity at operated assets is renewable). A key dependency is whether contracted PPAs deliver renewable electricity in line with future consumption.
  • Fugitive methane abatement at BMA.
  • Electrification of mining equipment and locomotives through proof-of-concept trials, with deployment not expected until after FY2030.
  • Structural abatement for net zero by CY2050 is described as uncertain (p. 61).

Value chain (pp. 62–63). Steelmaking (13 steelmakers), shipping and direct suppliers (top 500 by spend).

Resourcing and portfolio. Capital allocation is through the Capital Allocation Framework (p. 64); at least US$4 billion (incremental, nominal) of further operational decarbonization spend is anticipated in the 2030s (p. 57). BHP plans to cease mining at Mt Arthur Coal in June 2030 (p. 75).

Progress. The FY2026 social value scorecard milestone to complete the Escondida Boiler Diesel Displacement project was not met (construction delays, p. 58).

Strategy and pathway (p. 180). Decarbonization commitments are anchored by two mid-term 2030 targets (steelmaking and non-steelmaking) and a long-term 2050 net zero goal, underpinned by the Capital Allocation Framework. BlueScope takes a dual-stream approach, combining near-term asset optimization with longer-term technology evolution, and calls its pathway indicative. Achieving the 2050 goal depends on five enablers: ironmaking technologies at commercial scale, firmed large-scale renewable energy, competitively priced green hydrogen, economic raw materials, and supportive and consistent policies. The Board considered strategic projects underpinning the Company's climate transition plan (p. 177).

Actions (pp. 181, 184). Near term: the EAF at New Zealand Steel (hot commissioning July 2026) and the North Star debottlenecking program. Longer term: Project NeoSmelt, a pilot facility in Kwinana, Western Australia focused on proving the feasibility of DRI and ESF technology. Non-steelmaking (about eight percent of GHG emissions): energy and process efficiencies. BlueScope also engages governments, customers, suppliers and communities.

Resourcing (p. 193). In FY2021 BlueScope committed up to $150M over five years to projects supporting the 2030 targets and longer-term decarbonization ambitions, with total estimated spend of approximately $300–$400M to 2030; FY2026 investment under this program was $139M, net of grants received for New Zealand's EAF.

Food & Grocery Retail

Transition plan (p. 56). The Group's first Climate Transition Plan (CTP), released in August 2026, covers risks and opportunities, emissions reduction and resilience in its own operations, decarbonization and resilience across the value chain, internal and external mobilization, and nature and circularity. Key assumptions: more control over emissions reduction in its own operations than in the value chain; emissions projections based on internal growth forecasts; acquisitions and divestments may require re-baselining of targets. Dependencies and limitations: capital allocation beyond the corporate planning horizon is uncertain; delivery depends on regulation, technology, supplier engagement, consumer behavior, government policy, energy market reforms and enabling infrastructure; business growth may increase absolute emissions.

Responses and resourcing (pp. 46–56). 100% renewable electricity (onsite solar and large-scale generation certificates), an Origin Energy alliance deploying rooftop solar and Battery Energy Storage Systems (BESS) without Group capital, energy efficiency projects, refrigerant transition, a supplier engagement target and a FLAG target (pp. 46, 54). A decarbonization plan with funded programs toward near-term Scope 1 and 2 targets has annual capital and expenditure projections embedded in corporate plans and budgets; the refrigeration ambition is a move to lower-GWP or natural refrigerants by the end of 2050 (p. 56).

Transition plan (p.380). For paragraph 14(a)(iv) the report states the Group has no standalone climate-related transition plan and points to pp.98–117 for strategy, goals, targets, actions, assumptions and dependencies.

Strategy and resourcing (p.98). The strategy supports the transition to net zero by 2050 and climate resilience, managing climate risk across the portfolio and physical risk across operations. It is resourced primarily through existing business activities and planning and allocation processes; internal capital expenditure, operating expenditure and investments specifically deployed to climate were assessed as not material for separate quantitative disclosure (p.380).

Financed emissions (pp.99–115). Goals and targets are pursued by working with customers, rebalancing toward less emissions-intensive customers and, in some sectors, reducing exposure. Actions (p.101) include energy-efficient and electric vehicle lending, more renewables lending, ceasing thermal coal lending by 2030 and running off international shipping exposures. The Bank has no intention of reducing housing or commercial property lending to meet goals (pp.103, 105) and may miss goals, including housing, commercial property and aluminium, if the grid does not decarbonize as expected (p.99).

Operations (p.116). Scope 1 and 2 emissions are down 96% since 2014 (FY14 location-based vs FY26 market-based); 527 electric vehicles are 24% of the Australia and New Zealand fleet.

Pharmaceuticals & Biotechnology

Responses are in the "Adaptation measures" row of each risk table (pp. 146–149).

  • Heat stress (p. 146): backup energy generation at key assets, controlled energy load shedding, ability to prioritize cool and cold storage; anticipated asset upgrades to reduce reliance on backup generation.
  • Extreme weather (p. 147): site emergency response plans, contingency and secondary suppliers, alternative supply routes assessed in business continuity planning; anticipated asset maintenance (roof leaks, flood protection such as bunds) and investment in alternative supply routes.
  • Carbon pricing (p. 148): partners with top suppliers and assists them in setting science-aligned emissions targets; supplier due diligence to consider decarbonization commitments.
  • Customer expectations (p. 149): sustainability strategy with Healthier Environment commitments; assessing the lifecycle of key products.
  • Transition plan, under Metrics and Targets (p. 151): five abatement levers (new site design, electrification, energy efficiency, renewable energy, fuel switch). Some levers depend on factors beyond CSL's control, such as regulator review and approval of manufacturing processes (p. 152).
  • Resources (p. 153): capital allocation assessed case by case; capital spending on key initiatives such as energy efficiency projects and electrification of end-of-life equipment is immaterial; renewable energy procurement costs below $1 million.

Company index: 14(a)–(c), pp. 145–149.

Software & IT Services
Partial disclosure: The transition plan is not yet finalized (p. 87). No key assumptions or dependencies are disclosed. The capacity to adjust or adapt strategy and planned resource allocation are described as content of the finalized plan. Resourcing is a short statement with no amounts.

Resourcing (p. 81). Resource allocation is not expected to be materially changed in the short term. Resources will be required to address climate-related risks and opportunities but are not expected to be significant. Future resource allocation will be fine-tuned as part of the financial assessment process and completion of the transition plan.

Mitigation and adaptation efforts (pp. 82–83). Weather risk: flood mitigants installed at one flood prone location, review of flood risk in potential new locations, heat-management measures including dedicated cooling and refreshment rooms, negotiating solar panels at existing premises, and NABERS ratings to assess new tenancies. Customer behavior: engaging top customers and suppliers on sustainability expectations, customer surveys, and training for frontline sales. Opportunities: discussions with vendors on low carbon solutions, sales training, and integrating AI capabilities.

Transition plan (p. 87). The Group is in the process of finalizing a transition plan outlining the pathway to reach climate-related targets once set. Once finalized it will be substantiated by science-based targets, including decarbonization levers, and will include details on the Group's capacity to adjust or adapt strategy over the short, medium and long term, along with planned resource allocation. The initial decarbonization strategy focuses on renewable energy across all sites and influencing key vendors and customers.

Infrastructure & Facilities Services

Transition plan (pp. 69–71). Business Unit plans inform a Group pathway to 2050: Scope 1 and 2 reductions of 50% by 2032 and net zero by 2050 against an FY20 baseline of 346,684 tCO2-e; FY26 emissions were 28% below it. The 2032 target is expected to come from five levers: grid decarbonization, light and heavy vehicle fleet transition, plant electrification and asphalt efficiencies. Beyond 2032 the pathway relies on technologies expected to mature, including hydrogen or ambient-temperature asphalt production and battery-electric heavy vehicles at scale. The residual 10% is to be covered by offsets that may be procured in the 2040s, subject to the 90% reduction.

Assumptions and dependencies (p. 71). Pace of technology and alternative fuel adoption; supply chain availability and feasibility of alternative fuel fleets and charging infrastructure; demand for Downer's services; customer co-investment; and the Australian Government achieving 82% renewable electricity generation by 2030.

Efforts and resourcing (pp. 59, 69, 71, 76). FY26 initiatives abated 902 tCO2e (renewable energy consumption), 3,953 (fleet removal and conversion), 532 (production processes) and 561 (fixed assets). Indirect efforts include supplier engagement, the CDP Supply Chain Program and lower-emissions products Reconophalt and BioBind. Resources: the Group Sustainability and Environment team, IBM Envizi, external advisors and an Investment Committee applying funding thresholds.

Food & Grocery Retail
Partial disclosure: No transition plan is disclosed: the report says it is not disclosing a formal plan for F26 (p. 43) and is developing one (p. 49), so the key assumptions and dependencies in paragraph 14(a)(iv) are not given. The report describes mitigation and adaptation initiatives but no current or anticipated changes to the business model or resource allocation (14(a)(i)) beyond existing planning processes, and gives no amounts for resourcing. No indirect mitigation or adaptation efforts, such as working with customers or suppliers, are described (14(a)(iii)). No progress against previously disclosed plans is reported; the report says this is its first year of applying AASB S2 (p. 30).

Strategy and targets (p. 34). The strategy is structured around reducing emissions, physical risk preparedness, and establishing effective data and reporting capabilities, with two targets: net zero Scope 2 market-based emissions by 2030 and net zero Scope 1 and Scope 2 emissions by 2050.

Mitigation and adaptation (pp. 35, 37–38). Physical: site design to building codes, fire extinguishers, hose reels or sprinkler systems, backup generators at some sites, and insurance. Energy: progressing the target of sourcing 100% renewable electricity by 2030, a phased approach to long-term Power Purchase Agreements, on-site solar, and energy efficiency projects such as refrigeration upgrades. Carbon tax: a progressive refrigerant upgrade plan to lower Global Warming Potential alternatives, and progress on the Scope 2 target.

Resourcing (p. 34). Through existing operational and capital planning processes, with investment decisions incorporated into the broader business planning and capital allocation framework. Transition risk activities are primarily resourced through the energy optimization strategy; physical risk adaptation through existing property, supply chain and risk management functions.

Transition plan (pp. 43, 49). The Group states it is not disclosing a formal climate transition plan for the year ended 28 June 2026 (p. 43) and is developing one to formalize these projects and inform a Group-wide gross emission reduction pathway (p. 49).

Iron Ore Mining

Transition plan (p. 81). The transition plan has two interrelated objectives: reducing emissions rapidly and profitably, and developing solutions to drive decarbonization globally. The operational pathway has three workstreams (power supply, mobility and system optimization) that support the Real Zero Target.

Workstreams (p. 82). Power supply: build and operate an off-grid renewable system of 1.5 GW of solar, 900 MW of wind, 4-5 GWh of battery storage and 660 km of transmission lines. Mobility: deploy electric heavy mining equipment and charging infrastructure with original equipment manufacturers. System optimization: an AI-enabled integrated mining and power optimization model. Each gives FY26 progress, FY27 plans and key dependencies, such as approvals and technology readiness.

Other solutions (p. 83). Green Metal, critical minerals (including the Alta Copper acquisition) and a US$680 million Board-approved investment to expand renewable power capacity in the Pilbara.

Resourcing (p. 84). 2026 capital expenditure: Pilbara Decarbonisation Program US$848m, Energy Segment US$88m, Green Metal US$122m, Critical Minerals US$120m. In the short to medium term, capital deployment is expected to remain broadly consistent with existing guidance, including the previously announced US$6.2 billion Pilbara Decarbonisation Program investment. A long-term carbon price of A$97.92 per tCO2-e is applied to Australian operations and investments.

Diversified REIT

Net Zero Plan

GPT's Net Zero Plan provides a framework for emissions reduction and resilience. We conduct portfolio and asset-level climate risk reviews, supported by adaptation plans, to identify and manage both transition and physical risks. These reviews inform development design, capital allocation and operational decisions across the asset lifecycle so that our assets and operations remain viable in a changing climate.

Our Net Zero Plan focuses on emissions sources under our direct control while also addressing resilience to climate-related transition and physical risks and identifying opportunities across our portfolio and supply chain. Where possible, we focus first on reducing and eliminating emissions through renewable electricity procurement, energy efficiency, electrification, and the use of low-carbon materials and processes. To date, residual emissions have been addressed through offsets that meet our offset quality criteria.

Measure: Corporate Emissions (corporate office electricity, proportion of base building emissions, flights, accommodation, services and consumables); Building Operations (emissions from gas, refrigerants, diesel, electricity, water and waste); Upfront Embodied Carbon (where feasible, measure emissions from construction materials and processes); Resilience (undertake climate risk reviews and asset adaptation plans addressing physical and transition risks).

Reduce and eliminate: Corporate – improve office energy efficiency, use renewable electricity, consider demand for carbon neutral buildings and impacts of consumables. Building Operations – continuous refinement to enhance operational efficiencies of buildings, 100% on-site and off-site renewable electricity procurement, electrification of assets (where feasible), transition to use of low Global Warming Potential refrigerants. Embodied Carbon – adopt design and construction efficiencies that reduce project and asset carbon emissions, where feasible select low embodied carbon materials for construction projects, supply chain collaboration. Resilience – integrate adaptation measures at acquisition, redevelopment, and major capital works projects; grid transition readiness such as demand-side flexibility programs and electric vehicle infrastructure in asset design; long-term renewable energy supply contracts to reduce cost and volatility exposure; sustainable finance frameworks contribute access to diverse debt markets.

Offset: Offset residual emissions to achieve net zero after aiming to reduce and eliminate emissions where feasible. Preference offsets that meet key quality criteria, providing long-lasting carbon sequestration or emission avoidance. Secure offsets that meet quality and cost criteria.

Disclose: Independently validate and disclose outcomes and processes.

GPT has maintained carbon neutral outcomes for all material Scope 1 and 2 emissions where we have principal decision-making authority: Corporate operations – carbon neutral 2011-2024 with 2025 certification in review. Building operations – All operationally controlled base buildings carbon neutral since end 2024 (this includes all GPT wholly owned and managed assets, and excludes assets acquired during CY2025). Embodied carbon in developments – Australia's first certified "Climate Active" carbon neutral development delivered in 2022 and GWOF's 51 Flinders office development due for completion in 2026.

Our approach enables us to adapt as risks or opportunities materialise, including with regard to:

  • Capital allocation considerations: Climate-related matters are considered in our investment proposal assessments.
  • Operational adaptation: We incorporate updated climate modelling and resilience standards into redevelopment cycles and day-to-day operations.
  • Responding to market preferences: We acknowledge and consider customer demand for low-carbon, energy efficient buildings.
  • Insurance and financial instruments: We monitor climate-related risks and opportunities which may impact insurance availability and premiums, and debt/pricing terms.

GPT's approach to energy and decarbonisation

GPT is focused on five key areas which assist to advance our decarbonisation:

  • Energy efficiency: Monitor energy consumption, optimise building systems to maximise efficiency while maintaining occupant comfort; establish site-specific goals reviewed and monitored through audits and assessments; training and support provided to employees; consider design for efficiency in new developments and plan for lifecycle upgrades.
  • On-site solar photovoltaics (PV): Installed on some GPT-owned assets, mostly in Retail and Logistics assets that provide large rooftops and daytime loads; manage renewable energy certificates with the Clean Energy Regulator in alignment with the GHG Protocol market-based carbon accounting practice.
  • Offsite renewable electricity: Central to our approach, including a focus on renewable base building electricity contracts; GPT manages its own renewable energy certificate registry with the Clean Energy Regulator.
  • Electrification: By electrifying our buildings, where feasible, we aim to reduce the use of fossil fuels by upgrading heating systems at lifecycle and development opportunities; continue to review feasibility of electrification and its benefits for tenants and decarbonisation goals.
  • Low global warming potential (GWP) refrigerants: Target use in heating, ventilation and cooling systems by monitoring supplier contracts and ongoing equipment maintenance.

We have established several Smart Energy Hubs in Office and Retail assets to provide demand management programs that include on-site solar generation, batteries and LoadFlex processes to adjust our demand profile in response to market events.

Indirect mitigation efforts (working with tenants and supply chain)

Many of GPT's tenants and partners have their own net zero and wider sustainability initiatives, and our carbon neutral buildings play a role in their actions. We provide some tenants with energy services, including solar arrays, embedded networks and renewable energy contracts to reduce their footprint. GPT has additional opportunities in our supply chain and other business relationships in considering climate and nature-related impacts and opportunities, such as through project design and materials selection considerations which require planning and due diligence across the development process.

Approach to offsets

GPT engages with certain offset programs to facilitate our Net Zero Plan and to assist to mitigate unavoidable biodiversity impacts from development. GPT uses carbon offsets to compensate for residual emissions that are challenging or not currently feasible to eliminate, including gas for heating, refrigerants, waste and landfill. GPT has secured a supply of offsets which includes offsets that meet the Australian regulatory scheme and are certified Verified Carbon Units, focusing on these offsets that facilitate renewable energy generation with consideration to offset quality criteria (including additionality, permanence, measurability). In addition to these offsets GPT has proactively purchased carbon offsets through its 'Restoring Country for Climate' partnership with Greenfleet, since 2019. This project is working to restore 1100 hectares of cleared land to legally protected native forest in south-east Queensland, and this land is owned by the Kabi Kabi People's Aboriginal Corporation. During 2025, the project sequestered 105,575 tonnes of carbon dioxide equivalent (CO2-e).

Progress against previous plans

Climate vulnerability assessments have been completed for all GPT owned assets, supporting resilience in day-to-day operations and capital planning. We added on-site solar to reach 15.5MW and continued to drive efficiency, with energy intensity down 15 per cent since 2019. Our wholly owned and managed office and retail assets maintained carbon neutral operations, and upfront embodied carbon forms part of design considerations in new developments. Since 2022, 459 hectares of legally protected native forest has been planted through our 'Restoring Country for Climate' project with Greenfleet.

Partial disclosure: No formal transition plan has been established (p. 69), so no key assumptions or dependencies are disclosed (14(a)(iv)), and with no targets there is nothing on how targets will be achieved (14(a)(v)). No changes to the business model are described, and the report says climate has not been a primary driver of strategic decision-making (p. 68). Resourcing (14(b)) is stated in general terms (capital towards solar, lighting and site-specific infrastructure, and planned investments in efficiency, renewables and fleet transition) with no amounts. No progress against earlier plans is reported (14(c)); this is the first annual reporting period applying AASB S2 (p. 73).

Integration (pp. 61, 68). Climate-related considerations "are in the early stages of being integrated" into planning and investment decision-making and have "not to date been a primary driver of broader strategic decision-making". The actions taken "are at an early stage of development".

Initiatives (pp. 68–69, Table 3). Energy audits; an HVAC upgrades program completed across Australian stores; LED lighting rollout underway in Australia and the UK/EU; fit-for-purpose store design, for example elevated floor levels in flood-prone areas; rooftop solar (Australian sites, selected stores in Singapore, all stores in Slovenia); EV charging at selected Australian sites; Australian corporate fleet transitioning to plug-in hybrid vehicles; renewable energy procurement arrangements in Ireland and Northern Ireland; review of procurement and supplier practices for upstream emissions exposure.

Transition plan (pp. 69, 74). The report says "a formal transition plan has not yet been established". A gap analysis against the Transition Plan Taskforce (TPT) framework has been undertaken and the entity intends to use it to develop a formal plan. It will review its carbon pricing position "as it formalises a Transition Plan in FY27".

Resourcing (pp. 64, 70). In FY26 capital continued to go to solar installations, lighting upgrades and site-specific infrastructure improvements; planned investments focus on energy efficiency, renewable energy and fleet transition.

Mineral Sands

While Iluka has strategic initiatives, including a Climate Change Work Program, that seek to address and manage the risks and opportunities, it does not have a climate-related transition plan and does not have specific emissions reductions targets.

(R) Increased energy costs: Energy costs associated with grid-connected energy, diesel and natural gas are a key component of Iluka's overall cost structure. Policy decisions in Australia regarding both the roll-off of fossil fuel generation and ambitions for greater renewable energy penetration on the Wholesale Energy Market and National Electricity Market have resulted in less predictable and higher energy costs. Iluka's strategy for managing energy costs in 2025 focused on ensuring security of supply of coal for the SR kilns at North Capel concurrently with pursuing renewable energy opportunities. In the short-term, Iluka has retained sufficient quantities of coal to meet its operational requirements at North Capel. The Group's current priority is to develop a comprehensive energy strategy that includes evaluation of new/emerging renewable energy options and alternative power supply opportunities across the Iluka portfolio. This work will be undertaken internally and accordingly no further funding has been allocated at present for this risk. The Group will continue to identify opportunities to manage energy supply and cost escalation risk as part of its business-as-usual activities.

(R) Increased safeguard compliance costs: The trajectory of domestic policies on carbon pricing is uncertain from 2030 onwards, limiting the ability to measure impacts beyond the short-term reliably to inform strategic responses. The emissions from Iluka's SR kilns are hard to abate as required technologies are yet to prove to be commercially viable. Accordingly, in the short- to medium-terms, Iluka will continue to acquire Australian Carbon Credit Units (ACCU) to meet its safeguard compliance obligations. Iluka will continue to monitor progression of Australian Government climate-related policy and advocate its position, including monitoring eligibility for trade-exposed, baseline-adjusted status under Safeguard Mechanism. Purchases of ACCUs will be funded via working capital.

(R) Decarbonisation technology not commercially feasible: Commercial availability of alternative technologies (e.g. green hydrogen, biochar and tyre-derived fuels) is an option to adapt to rising safeguard compliance and energy costs. Iluka's ambition to be net zero by 2050 incorporates an assessment of commercial feasibility. Decision-making regarding Iluka's response to climate-related risks is informed by the use of a Marginal Abatement Cost Curve (MACC), plotting decarbonisation opportunities on the basis of cost to abate a tonne of CO2. Iluka is also integrating the Technical Readiness Level (TRL) and the Commercial Readiness Index (CRI) in the evaluation of decarbonisation projects – standard benchmarking tools adopted by the Australian Renewable Energy Agency (ARENA). Iluka progressed studies and assessments of various technologies as part of the 2025 Climate Change Work Program. In 2025, Iluka's strategy in response to this risk focused on: short-term potential substitutes for coal (tyre-derived fuels and biochar) in the SR kilns; long-term potential substitutes for coal (NewGenSR® technology); and emerging decarbonisation solutions, including electrification of existing fossil-fuel-reliant processes. Outcomes of existing studies indicate deployment of these alternative technologies is dependent on their commercial feasibility (scale and price). In the short-term, Iluka will continue to monitor the commercial viability of these alternatives; no further funding has been allocated for 2026.

(R) Increased severity and frequency of extreme rainfall events / (R) Increase in frequency of extreme temperature days: Iluka will continue to embed climate resilience considerations into its existing risk management systems, including engineering and design, asset integrity, water management, logistics and emergency management. This includes: designs of future developments informed by climate risk assessment; ongoing review and maintenance of surface water plans considering climate projection data; landform designs informed by climate projections; tailings management system aligned to ANCOLD guidelines and design considering climate projections; logistics management (port maximisation plans; mitigation plans with logistics providers); ongoing review and maintenance of site emergency management and asset management plans together with annual emergency management training; maintaining on-site back-up power generators and generator mitigation plans; managing levels of heavy mineral concentrate (HMC) at processing sites to enable continued supply; engagement with critical infrastructure providers to manage continuity of power supply; and continuous review of health and safety processes and procedures within Iluka's HSEC framework and system.

(O) Increased demand for rare earth oxides: Iluka considers the global transition toward electrification, including the growth of electric vehicles and renewable energy technologies, as a major structural driver of rare earths demand. This presents a significant opportunity for the Group, particularly through development of the Eneabba refinery and Iluka's mineral sands deposits containing monazite and xenotime rare earth assemblages. Iluka's short-term strategy for its rare earths business consists of: continuing construction and commissioning of the Eneabba refinery pursuant to the terms of its loan arrangement with Export Finance Australia; securing customer offtake contracts on sustainable pricing terms; investigating and executing third-party feed source opportunities for the Eneabba refinery; and continuing the feasibility study into rare earths metallisation.

(O) Increased deployment of renewable energy generation: As the global transition to net zero accelerates, increasing deployment of renewable energy technologies is expected to place downward pressure on long-term renewable energy costs. Iluka has entered into Power Purchase Agreements (PPAs) for all three of its mineral sands mining operations (Cataby, Jacinth-Ambrosia and Balranald). In 2025, Iluka completed renewable energy studies for North Capel and Eneabba; identified and assessed opportunities to improve pumping efficiency at Cataby and Jacinth-Ambrosia; and evaluated the InPipe HydroXS® system, a micro-hydropower technology designed to recover energy by converting pressure differentials within pressurised water pipelines into electricity. Future plans are currently focused on internal work to assess and identify the most suitable renewable energy solutions for Eneabba, guided by the outcomes of the options analysis undertaken in 2025. No further funding has been allocated to manage this risk at present.

Net zero ambition and Climate Change Work Program

Iluka has the ambition to be net zero by 2050 where technology is viable, available and commercially feasible. This ambition recognises that the commercial and technical viability of technology required to decarbonise its Scope 1 and 2 emissions is central to Iluka's climate resilience in the context of the global transition to net zero. Iluka does not have specific emissions reduction targets. In 2025, Iluka was guided by its Climate Change Work Program, the purpose of which was to identify and assess the feasibility of mitigation and abatement opportunities. This program does not constitute a formal transition plan. Work program priorities and outcomes are reviewed and approved by the SusCo on an annual basis, and progress on initiatives is updated to the SusCo on a bi-annual basis.

For 2025, the Climate Change Work Program targets were qualitative in nature. The ultimate purpose of the work program targets is to identify opportunities to mitigate Scope 1 GHG emissions from Iluka's North Capel operations, being the Group's most material source of Scope 1 emissions, followed by Scope 2 mitigation opportunities via assessing incremental energy efficiency opportunities at Cataby and Jacinth-Ambrosia and renewable energy evaluations. The targets apply for 2025 and there were no interim targets. Given the targets are exploratory in nature, they were not specifically aligned to international or jurisdictional agreements or commitments on climate change. No revisions were made to the targets during the year.

2025 Climate Change Work Program outcomes:

  • Energy efficiency: Iluka reviewed several energy-efficiency proposals at Cataby and Jacinth-Ambrosia. Opportunities were identified, however current conditions mean most options are not yet commercially viable; Iluka will continue to monitor these opportunities.
  • Renewable energy: Evaluations for North Capel and Eneabba were both completed; further work to refine suitable renewable energy options for Eneabba will be considered for future years.
  • Alternative fuels: A preliminary trial using tyre-derived fuel confirmed material handling characteristics are suitable for further assessment; additional work will proceed when operational timing is appropriate. Initial biochar test work at North Capel showed potential for partial coal replacement in the SR process; further work is required to validate outcomes at scale. Given the paused status of North Capel's kiln operations, decarbonisation activities relating to alternative fuels will be progressed when operational readiness allows.
  • Technology step-change: Independent reviews of the NewGenSR® development plan were completed and will guide future planning; no further development work is scheduled for 2026.

Strategic response (p. 39). The continued development of the capital platform, including the reinsurance program, is a key element of the inherent strategic response to increasing natural perils risks. From FY24 a five-year strategic reinsurance arrangement provides up to $4 billion of volatility protection for natural perils losses alongside whole-of-account quota share arrangements. In FY26 natural perils reinsurance coverage was extended to the RACQ Insurance (RACQI) portfolio and whole-of-account quota share arrangements were increased by 2.5%.

Transition plan (pp. 39–41). The IAG Climate Action Plan (CAP) has two action areas: Innovate (mitigation; Targets 1 to 4) and Educate (adaptation; Targets 5 to 7). Three targets (5, 6, 7) were added and RACQI was included in scope. Initiatives include renewable energy procurement, a low-emissions tool of trade fleet, property energy efficiency, fuel switching, carbon removal offsets for residual emissions in FY30, natural hazard risk education and awareness, and supplier engagement. Assumptions and dependencies are tabled by target (p. 41), for example the external availability and cost of alternative fuels and technology, and the expiry profile of vehicle leases.

Resourcing (p. 44). Activities are primarily managed and funded through business-as-usual activities. CAP delivery is supported by renewable electricity contracts, energy attribute certificates and low emissions vehicles. No amounts are given.

Decarbonization plan (pp. 70–72). The Group has established a plan to decarbonize its operations and is working toward net-zero direct scope 1 and scope 2 (market-based) emissions by 2030 through renewable energy procurement, on-site solar power generation, store and warehouse energy efficiency, reducing energy consumption where possible and fleet rationalization. Stated assumption: continued optionality to procure renewable energy through contracts with its energy providers (p. 72). In FY2026 68% of energy needs came from renewables (82% in June 2026) and solar sites rose to 42 (FY2025: 36) (p. 72).

Mitigation measures (pp. 61–63). Physical risk (CRRO 1): geographic diversification, omni-channel sales and fulfillment, flood risk assessments in store network planning, a short Weighted Average Lease Expiry (WALE) of less than 3 years, water deluge kits across all HDC sites, insurance and business continuity plans. Transition risk (CRRO 3): the Ethical Sourcing Policy requires suppliers to measure, monitor and reduce emissions; 321 suppliers were asked to complete the Ethical Sourcing Questionnaire and 254 responded.

Resourcing (p. 69). Resources are allocated through annual budgeting processes overseen by the Group CFO. Other funding and resource allocation is not separately identifiable or already in budgeted operating expenditures; as at 30 June 2026 no financially material capital or operational expenditure is planned to address CRROs.

Residential & Property Development

Transition plan (pp. 83, 85). Regional climate transition plans (Mission Zero Roadmaps) aim to meet Net Zero by 2025 for Scopes 1 and 2 (market-based) and Absolute Zero by 2040, without carbon offsets, for Scopes 1, 2 and 3. Five key steps: a decarbonization investment strategy; phasing out diesel and gas in operations; 100 percent renewable electricity before 2030; collaboration with supply chain partners, tenants and residents.

Pathway to Absolute Zero (p. 83). The Australian Government's commitment to net zero is expected to underpin the pathway. Significant cross-sector collaboration and industry-wide investment are required. The rate of sector-wide decarbonization depends on how and when the Built Environment Sector Plan is translated into enforceable policy settings.

Responses (pp. 77–81). The Climate Related Risk Assessment (CRRA) process (p. 77); the Weather Scenario Planning Tool (p. 79); new commercial developments planned fossil fuel free and electrification of selected Australian office assets (p. 80); lower embodied carbon procurement (p. 81).

Budgeting (p. 85). Carbon price considerations are built into Development and Construction project emissions forecasting and budgeting.

Progress (p. 85). The first milestone, Net Zero for Scopes 1 and 2 by FY25, and the 100 percent renewable electricity by 2030 goal were achieved. Outside the Sustainability Report, the Annual Report says climate transition plans are being updated (pp. 6, 20).

Food & Grocery Retail
Partial disclosure: The climate statements do not mention a climate-related transition plan, so no key assumptions or dependencies of one are given (14(a)(iv)). How the targets will be achieved is stated in one sentence in section 4 (p. 61): energy efficiency initiatives and REC purchases through Power Purchase Agreements and LGCs, with no quantified levers (14(a)(v)). Beyond the measures listed, no current or anticipated changes to the business model or resource allocation are described and no resourcing amounts are given (14(a)(i), 14(b)). For the physical risks the report says no material climate-specific capital expenditure, financing or investment was deployed in FY26 (p. 62); for energy and fuel costs it says no additional financing or investment was deployed because many upgrades were part of existing planning and budgets (p. 64). Progress is reported only for the two targets (p. 68).

Targets and how they are to be met (p. 61). Metcash is committed to net-zero Scope 1 and 2 GHG emissions by 2040, with interim targets of reducing Scope 1 and 2 net emissions by 42% from a 2024 baseline by 2030 and sourcing 100% renewable electricity by 2025 for all operationally controlled sites in Australia (excluding Superior Foods). To meet them, Metcash implements energy efficiency initiatives and purchases Renewable Energy Certificates (REC) through Power Purchase Agreements and Large Generation Certificates (LGCs).

Direct mitigation and adaptation (pp. 63–64). Physical risk: diversified suppliers and logistic routes, contingency plans for alternate freight modes, inventory buffers, insurance coverage, and Mega DCs generally located where bushfire or extreme flooding is of lower risk. Energy and fuel costs: energy efficiency improvements, logistics network optimization, fleet transition to hybrid and electric vehicles, cost pass-through, and refrigerant plant upgrades aligned with business-as-usual asset replacement cycles.

Indirect efforts and resourcing (pp. 61, 65). Implementation strategies for the opportunity include proactive communication with the supplier network, supporting suppliers with inbound freight and prioritizing capital investment in distribution centers and logistics infrastructure. Costs of mitigation and adaptation measures represent normal business operations and are not material.

Diversified REIT

Strategy (p. 74). The sustainability strategy, This Changes Everything (developed in 2014), has five pillars: embodied carbon reduction; all-electric products and electrifying the office portfolio; solar and 100% renewable electricity; customer collaboration; and high-quality offsets for residual emissions.

Transition plan (p. 87). The goal is net positive across Scope 1, 2 and 3 emissions by 2030, with absolute emissions reduction as the primary lever and offsets for residual emissions only. The report says the target is a net outcome, not a commitment to specific gross reductions by a fixed date. Net positive Scope 1 and 2 is already achieved for assets under the NGERS operational control boundary. For Scope 3 the plan lists renewables and electrification (100% renewable electricity for the managed portfolio, an all-electric office portfolio targeted by 2030, residential and industrial solar), design and procurement (carbon content of materials, lower-carbon products, recycled content, retaining structural elements, waste reduction) and offsets.

Dependencies (pp. 75, 87–88). Grid decarbonization, low-carbon material availability, supplier capability, customer behavior, and the cost and integrity of high-quality offsets.

Resourcing (p. 89). Mirvac's share of capital deployed on office electrification in FY26 was $4m. Other climate-related expenditure is not separately identified.

Thermal Coal Mining

Transition plan (pages 103, 118). No voluntary climate-related targets have been set. The transition plan is focused on Safeguard Mechanism emissions reduction and compliance obligations for Bengalla Mine: monitoring and forecasting emissions against the baseline, incorporating anticipated compliance costs into mine planning and capital allocation decisions, acquiring and surrendering ACCUs for baseline exceedances, and investigating feasible operational abatement. The Board approves the strategy on a three-year rolling basis and the Enterprise Decarbonisation Working Group conducts the actions. No large-scale operational abatement opportunity has been identified as currently technically and economically feasible, so ACCU use is expected to continue in the short term.

Risk responses (pages 108–116). Fixed-term contracts and direct engagement with key logistics suppliers (CR1); customer engagement, term contracts (CR2); engagement with community, government and industry regulatory bodies (CR3); investigating fuel management, efficiency and methane pre-drainage projects; a soil carbon sequestration investment (CR4); water management preparation and expected rainfall delays in mine planning (CR5).

Resourcing and business model (pages 120, 126). No capital expenditure, financing or investment was deployed directly toward the management of climate-related risks. The Group does not currently consider that material changes to its overall business model are required.

Software & IT Services
Partial disclosure: The Climate Transition Plan had not been finalized or adopted at 30 June 2026 (p. 82), so the key assumptions and dependencies in paragraph 14(a)(iv) are not given, and the report does not describe how the Scope 1 and Scope 2 net zero target will be achieved (14(a)(v)). Resourcing is limited to naming an external adviser (p. 82) and the Head of Energy as lead for the plan (p. 70), with no amounts for the activities described (14(b)). No progress against previously disclosed plans is reported (14(c)); the report says this is the first annual reporting period (p. 66).

Integration into strategy (p. 76). Climate analysis informs five areas: site selection and design (site-specific flood, heat, water, access and utility due diligence); capital allocation and development (climate factors in funding requests and business cases; grid, water and planning constraints inform sequencing and project scope); operations and resource efficiency (PUE, WUE, metering, advanced cooling); energy, customers and transition (residual energy exposure, grid connections, renewable procurement, the FY27 Climate Transition Plan); and risk, governance and monitoring (annual CRRO and resilience review).

Measures by CRRO (pp. 77–81). Examples include flood-resilient design, waterproofing and bunding (CRR1); minimizing water-dependent cooling in suitable new developments (CRR2); evaluating renewable electricity procurement and power purchase arrangements (CRR3); and giving customers energy, emissions, water and sustainability information (CRO1). FY26 capital expenditure across the development program was approximately $3.2 billion (p. 77).

Transition plan (p. 82). Development of a Climate Transition Plan began in FY26 with an external adviser and covers the target and boundary, emissions trajectories, interim targets, priority decarbonization levers with associated capital and operating expenditure, and the potential role of carbon credits. As at 30 June 2026 it was not finalized or adopted; finalization is expected during FY27.

Nickel Mining & Processing

Transition plan and Decarbonisation targets Nickel Industries is committed to a 50% reduction in carbon intensity by 2035 and achieving net-zero emissions by 2050, using 2022 as a baseline.

Actions taken during the current period towards this commitment include:

Fleet Electrification: Fleet electrification and energy efficiency initiatives focus on reducing diesel use, Scope 1 emissions and operating costs by deploying electric mobile equipment where feasible. At Hengjaya Mine, the electric truck fleet expanded from 8 units in 2024 to 37 units, lowering diesel consumption and haulage energy intensity. RKEF deployed additional electric equipment, including 20 loaders, 4 excavators and 1 forklift.

Greenhouse gas emissions reduction target: Nickel Industries has established a GHG emissions reduction target and identified a range of potential pathways that may support achievement of that target. A key part of this transition is the Group's move from investing in RKEF refineries into HPAL projects, which produce MHP for use in the electric vehicle supply chain. The HPAL technology has been implemented to process nickel ores with lower emissions and energy requirements, utilising power from the captive waste heat boiler system from the acid plant, which can provide up to 40% of power needs. This technology processes limonite nickel ore, moved through a slurry pipeline instead of conventional truck transportation. The commissioning of the ENC HPAL project in 2026 is expected to deliver material reductions in carbon emissions intensity. At 31 December 2025 the Group had acquired a 44% interest for $1,012.0 million.

Solar and Battery: The Group is a participant in the solar project in the IMIP that will supply ENC with renewable power, which achieved financial close on 23 January 2026. This project consists of 262MWp photovoltaic and 80MWh battery energy storage system (BESS). The electricity offtake power purchase agreement includes a 25-year fixed rate tariff with no escalation.

The installation of a solar energy system at Hengjaya Mine, now supplying approximately 20% of the site's electricity needs, was complemented by EV haul trucks and electric loaders. Through Oracle Nickel, the Group transitioned to the use of recycled furnace gas for industrial processes, reducing reliance on coal and further lowering its carbon footprint.

Other forms of carbon reduction such as carbon credits are also being considered but are not currently being used.

Climate risk and opportunity integration into business strategy Nickel Industries operates in a sector with elevated exposure to physical and transition climate-related risks, which may affect the resilience of operations, value-chain continuity and long-term competitiveness. The Group has undertaken preliminary assessments to understand how these risks could influence its business and broader strategic position. As part of this work, Nickel Industries has identified a number of potential decarbonisation pathways and considered them at a high level for strategic and risk assessment purposes. The Group expects to continue evaluating climate-related risks and transition considerations and to progressively assess their relevance to longer-term strategy as external conditions and internal capabilities evolve. Any future integration of climate considerations into strategy will be subject to further analysis and decision-making in subsequent reporting periods.

Mitigations by risk (potential mitigations, extracted from risk tables) include: evaluation and improvement of heat-sensitive infrastructure and processes (HVAC/load management, heat exchangers, process insulation/controls, work-rest cycles); working with the IMIP industrial park operator on elevated foundations, dikes, roads, zoning restrictions, mangrove and coral reef restoration for sea level rise; studies into tailings facility effectiveness and improvements, elevating electrical infrastructure and backup power, equalisation basins, stormwater separation, elevating/strengthening haul roads for flooding; early warnings, safety drills, backup power, wind-resistant infrastructure, cyclone-resilient architecture, modular refinery units, dry-stacking tailings placement, expansion of solar captive microgrids with battery storage, investigation of direct-to-sulfate refining technology, dewatering & classification technology for extreme weather/cyclones; slope clearing limits, retaining buffers, slope drains/retaining walls, movement monitoring, InSAR & LiDAR geotechnical monitoring, reduced stripping ratios, reuse of landslide debris for infrastructure, for landslide risk; and for downstream value chain risk, enquiring with customers on climate risk assessments and considering further customer diversification and alternative logistics.

Electric & Gas Utilities

Transition plan (pp.177–178). The plan is organized around three strategic objectives; the 2025 Climate Transition Action Plan (CTAP) outlines the ambition to lead the energy transition.

  • Deliver reliable energy through the transition: exiting coal-fired generation is the most significant single emissions reduction step; Eraring Power Station operations were extended to 30 April 2029, which Origin says is not expected to affect the 2030 targets or 2050 ambition. A helicopter-based methane monitoring trial was run (p.177).
  • Accelerate renewable and cleaner energy: Origin aims to grow renewables and storage from 2.8 GW operational at 30 June 2026 to 4–5 GW by 2030. In FY26, 1 GW of the 1.8 GW of owned and contracted batteries committed began commercial operations, rising to 1.3 GW with Mortlake from 11 August 2026 (p.178).
  • Unrivalled customer solutions: Origin Loop grew to about 1.6 GW across more than 409,000 connected services; 2,841 EVs under management (p.178).

Resourcing (p.178). $742 million of capital expenditure, financing and investment was deployed towards climate-related risks and opportunities in FY26, with capital investment made with regard to emissions targets through the capital allocation framework.

Uncertainties for the targets and ambition (pp.181–182). Timing of new renewables and transmission, NEM demand, permitting and approvals, community concerns, asset retirement timing and policy certainty.

Consumer & Mortgage Lending

Physical risk - strategy and decision-making

Current and anticipated changes to Business Model and resource allocation: There is no material impact on the Group's financial outcomes in the short term arising from acute physical risks. The Group anticipates that, over the medium to long term, adjustments to its lending portfolio may be required to address the increasing severity and likelihood of acute physical events. These adjustments are expected to include enhanced integration of climate-related risk metrics into credit assessment policies and portfolio monitoring processes. In addition, an increase in hardship requests may place additional demands on customer contact and servicing centres. The Group will invest in the acquisition of external data to support and enrich assessment and analysis of physical risk impacts. Resource allocation continues to prioritise internal funding and leverage existing human resources to implement these measures.

Direct mitigation and adaptation efforts: The Group supports customer financial resilience through hardship assistance programs. Measures, such as SMS engagement following natural disaster events, are implemented to offer hardship support and mitigate potential credit risk. To ensure operational continuity, all employees have access to resources and technology that enable remote working. The Group anticipates in its forward-looking strategy to incentivise property-level resilience upgrades to include: installing flood barriers; elevating homes in flood-prone areas; supporting retrofits for bushfire resilience; and reinforcing roofs to withstand cyclones.

Indirect mitigation and adaptation efforts: Current mitigation efforts include active monitoring of geographic concentration of the lending portfolio to reduce exposure to areas vulnerable to insured and uninsured perils and reduce concentration risk. Portfolio assessment by specific peril and risk banding are prepared to monitor exposure. Mitigations that could be adopted include annual insurance verification of borrowers, including protecting against specific physical risks as part of the loan conditions. The Group anticipates adaptation measures to include ongoing refinement of underwriting processes to incorporate climate-related risk indicators into property valuation models to steer lending towards more resilient assets.

Climate-related transition plan and key assumptions: Pepper Money's forward-looking strategy includes continued integration of climate considerations into risk governance and credit decision-making. The Group anticipates that physical risk impacts will increase in the long term based on the current lending profile. Dependencies include the availability of reliable climate risk data that can be used to inform credit risk assessment practices.

Achievement of climate-related targets: At this time, the Group has not established quantitative targets specifically in relation to physical climate risks.

Transition risk - strategy and decision-making

Pepper Money monitors transition risks arising from evolving climate policies and changes in consumer preferences, notably the increased adoption of EVs, energy efficient housing, and tightening regulatory standards. The Group's approach encompasses direct measures embedded in products and risk frameworks, and indirect measures that build organisational resilience, capability, and ecosystem readiness.

Current and anticipated changes to Business Model and resource allocation: During the current reporting period, no material changes to the Group's Business Model or resource allocation have been required. The Group has considered the growing transition toward EVs as an emerging preference. At present, these trends are not expected to have a material impact on the Group's operations. The Group continues to monitor the relative value trajectory of ICE vehicles compared with EVs to inform future lending strategies and credit risk settings. Any resource requirements associated with these initiatives are expected to be met through internal funding and existing workforce capacity.

Current mitigation and adaptation:

  • Sector exposure monitoring: Borrowers' employment industries are mapped using ANZSIC classifications to identify segments with heightened transition sensitivity.
  • Portfolio stress testing: Targeted stress tests consider scenarios of elevated cash rates and inflation linked to carbon pricing and policy shifts, assessing impacts on Net interest income, Corporate interest expense and Operating expense.
  • EV financing: EVs represent 15% of total vehicles financed in CY2025 (based on number of EV loans excluding hybrids originated in CY2025).
  • Internal assessment: Strengthening data, modelling and reporting capabilities to assess business resilience and to evaluate future transition pathways.

Anticipated mitigation and adaptation:

  • Residual value protection: Defending against asset value deterioration through guaranteed future value programs for both ICE and EVs.
  • Risk appetite and limits: Formal exposure limits for transition vulnerable sectors and asset types, with periodic reviews and escalation triggers.
  • Funding strategy alignment: Exploration of investor demand (e.g., labelled tranches when feasible) to diversify and stabilise funding under climate-linked macro volatility.
  • Industry engagement: Ongoing participation in industry forums such as Australian Finance Industry Association and Risk Management Association to anticipate adaptation pathways including vehicle standards and building energy requirements.
  • Product innovation: Product development to expand on sustainable financing such as financing rooftop solar installations, energy-efficient home construction loans, and retrofit solutions for existing properties.
  • Servicing and customer support: Proactive outreach to borrowers in transition exposed industries (using ANZSIC mapping) with budgeting tools, hardship pathways, or tailored restructuring options. Provide information hubs on policy impacts to help customers plan asset choices and household upgrades.
  • Internal capability building: Training staff on the impact of transition risks and emerging policy drivers.

Climate-related transition plan and key assumptions: The Group assumes increasing regulatory and market preference for low-emission assets, particularly EVs, over the medium to long term. Dependencies include the pace of EV adoption, infrastructure development, and government incentives. Pepper Money's approach to climate-related transition risk is first to understand the impact that can be reasonably expected before committing to formal transition plans. Product teams continue to look for opportunities to develop new products that cater to consumer demand now with the added impact of climate considerations on change in preference. Internally, Pepper Money will continue to monitor downstream customer exposure to industries vulnerable to transition risk through regular review and reporting using ANZSIC codes.

Achievement of climate-related targets: The Group has not set greenhouse gas emissions targets, as its operations have a low direct emissions profile.

Investment in climate-related mitigation, adaptation and opportunities

The Group is prioritising investment of internal resources to strengthen resilience against climate-related risks. Key initiatives include: enhancing credit assessment frameworks to incorporate climate-related considerations in evaluating loan security; developing new lending products designed to promote financing of energy-efficient assets; and exploring funding mechanisms and incentives to support the expansion of sustainable financing initiatives.

Climate transition plan (pp. 9–10). The climate transition plan is aligned to the net zero by 2050 target and the interim targets of a 25% reduction in net Scope 1 and 2 emissions by 2030 (from 2019 levels) and Sustainable Aviation Fuel (SAF) equal to 10% of jet fuel consumption by 2030. Three pillars sit under a mitigation hierarchy: fleet and operational improvements, SAF, and carbon markets. With SAF not yet available at scale, carbon credits currently represent the largest component of the pathway to the interim net target; because fleet renewal, operational efficiency and SAF cannot eliminate all gross emissions, credits are expected to play a significant and enduring role and targets are set on a net basis. Fleet renewal replaces the legacy fleet over the next decade (p. 21). Activities are resourced through existing expenditure and capital allocation frameworks, and the Chief Sustainability Officer leads oversight and execution (p. 10).

Assumptions and dependencies (p. 37). By pillar for 2030 and 2050, for example airspace collaboration and aircraft entering service in line with the fleet plan, supportive SAF policy and global supply growth, and robust compliance carbon markets. If not realized as expected, the cost, pace or feasibility of the plan may be affected.

Resourcing (p. 19). The $400 million Qantas Climate Fund, established in 2023 with Airbus, deployed $36 million in 2025/26; the Group and Airbus have together committed $126 million.

How we respond - physical risk

  • Pricing and underwriting appetite: Given that most insurance policies renew annually, QBE can regularly adjust pricing and underwriting appetite in response to emerging risks. The Catastrophe Accumulation Management team provides technical catastrophe pricing for a large number of property policies. QBE aims to regularly refresh its pricing factors using up-to-date catastrophe modelling, reflecting current accumulations, reinsurance costs, and required return on capital.
  • Portfolio optimisation: QBE continues to refine its portfolio to improve risk-adjusted returns and reduce earnings volatility. This includes targeted reviews of property exposures in higher-risk regions, improved diversification and continual refinement of policy terms, supported by enhanced analytical tools and modelling capabilities.
  • Catastrophe modelling capability: QBE continues to enhance its understanding of the potential impact of climate change on specific perils and regions through catastrophe modelling and climate scenario analysis. The Catastrophe Modelling Research team continues to strengthen QBE's in-house capability to validate and customise models, including for potential climate-related impacts.
  • Reinsurance: In the short term, QBE manages the volatility of natural catastrophe claims through a comprehensive Group catastrophe reinsurance program. QBE also continues to explore alternative capital solutions, including the recent launch of a catastrophe bond.

How we respond - transition risk (underwriting)

  • Relevance of core products: QBE core product coverage (such as property damage, third-party liability and business interruption) address fundamental insurable risks that persist across technology shifts and are underpinned by regulatory and contractual demand.
  • Pricing and underwriting approach: The predominantly annual nature of our policies enables regular changes in pricing, terms and conditions, and portfolio adjustment in response to changing risk profiles and market conditions.
  • Risk appetite and exclusions: QBE's Environmental & Social Risk Framework includes underwriting controls on specific high-emitting activities, limiting exposure to the most vulnerable segments under transition scenarios.
  • Leveraging opportunities: The transition is expected to create demand for insurance solutions that will support new and evolving technologies. QBE is actively seeking to capture these growth opportunities.

How we respond - transition risk (investment)

  • Diversified asset allocation: QBE's investment portfolio is diversified across asset classes and geographies, which limits concentration in transition-sensitive sectors.
  • Policy exclusions: Direct investments in specific high-emitting activities are restricted under QBE's Environmental & Social Risk Framework.
  • Corporate credit portfolio management: Consideration of transition risk will be incorporated into in-house corporate credit analysis from 2026.
  • External manager selection and due diligence: External managers are evaluated to ensure that climate-related risks are appropriately integrated into their investment approach, and transition risk analyses provided by these managers are reviewed to confirm that such risks are identified and managed.
  • Ongoing scenario analysis and monitoring: Transition risk scenario analysis is conducted across major public asset classes.

How we respond - opportunities

QBE continues to monitor and evaluate possible climate solution investments as part of its investment strategy. This includes assessing emerging opportunities in both public and private markets that align with QBE's return objectives and sustainability commitments.

QBE's Transition Plan includes actions to enhance capabilities and scale insurance solutions in response to growth opportunities.

Transition Plan

QBE has prepared a Climate Transition Plan that sets out its strategic ambition, implementation approach and key metrics to support the transition to a net-zero economy. We recognise the important role that QBE can play in facilitating the climate transition, through how we manage our own operations, invest our assets, select the risks and companies that we underwrite, and manage our supply chains. The Transition Plan articulates the actions QBE will take to support the transition whilst managing its climate-related risks and opportunities, and is structured around three areas: (1) Ambition; (2) Implementation and engagement strategy; (3) Metrics and targets.

Our climate ambition

To support the transition to a net-zero economy QBE is: taking action in our underwriting business; taking action in our investment portfolio; targeting net-zero operational emissions by 2030.

Implementation and engagement strategy

Underwriting: Scaling insurance solutions that facilitate the transition, including products and services that support climate change mitigation. Integrating climate risks and opportunities into decision-making by continuing to embed positions on energy sectors into underwriting appetite, implementing an assessment of in-scope customers' transition maturity, and deepening understanding of higher-emitting portfolios to better understand transition risks and identify opportunities to support customers' transition.

Investments: Financing the transition through investment in climate solutions. Continuing to incorporate climate risk and decarbonisation pathways into investment due diligence for in-house managed corporate issuers and external managers.

Operations and supply chain: Taking actions to decarbonise our operations; embedding emissions reduction measures into our supply chain.

Advocating for climate resilience: Advocating for policies that support climate resilience.

Ambition intent, scope

Underwriting: We frame our ambition around taking meaningful actions, rather than achieving a fixed emissions target. As a re/insurer and asset owner, we focus our influence on positive action by directing capital and insurance to support our customers and communities to navigate the transition to a net-zero economy. Our ability to make progress depends on sustained action across the economy, including from governments, and on the availability of reliable data from customers and investees. The scope of 'taking action' is set out in the content of the Transition Plan.

Operations: We define our ambition as a 2030 GHG emissions target that is specific, measurable, and time-bound. It is based on emissions reduction initiatives we consider feasible given our current operational footprint and profile. Scope 1, Scope 2, and selected Scope 3 (specifically Categories 3 and 6) emissions.

Applying our Transition Plan in the United States: Actions taken in the United States, and other relevant jurisdictions, will be done in compliance with applicable laws and regulations. All actions and underwriting decisions for customers in the United States will be based on an ordinary insurance business purpose, which may include the application of sound actuarial risk and underwriting principles. This will guide our approach to collecting data from customers, suppliers and investees and making decisions.

Implementation roadmap

2025: Developed QBE's Climate Transition Plan.

2026: Underwriting: commence assessment of transition maturity of in-scope customers (phased approach); develop implementation plan to scale 'insuring the transition' products and services; implement data uplift and phased analysis of emissions intensity of higher-emitting portfolios. Investments: baseline current portfolio alignment based on the Net Zero Investment Framework (NZIF) methodology; assess possibility of introducing an alignment target; assess possibility of broadening scope of climate solutions; invest $200 million in climate solutions annually through to 2030; limit the Scope 1 and 2 WACI of the public corporate debt portfolio to 20% below the WACI of the market benchmark.

2027: Underwriting: operationalise implementation plan for 'insuring the transition' products and services.

By 2030: Operations and supply chain: achieve net-zero operational ambition; 70% of QBE's global strategic suppliers to have publicly defined emissions reduction targets.

Advocacy and engagement: Develop and execute an advocacy strategy in response to QBE's assessment of climate-related risks and opportunities.

We acknowledge that key factors that will guide our approach to net zero often lie outside our direct influence. Achieving our climate ambition is dependent on factors across our value chain including our investees, insurance customers and suppliers, as well as market and industry factors such as supportive policy frameworks, regulatory environment and technology advancements. Accordingly, the Transition Plan will be reviewed and refined over time to reflect developments in data, methodologies, public policy settings and market conditions.

Key actions and dependencies - Underwriting

Scaling insurance solutions that facilitate the transition, including products and services that support climate change mitigation: The energy sector is going through significant transformation, driven primarily by investment in transition technologies. QBE recognises the opportunity to support this change through enhancing existing capabilities, complementing the Sustainable Energies Unit. During 2026, QBE will work to establish an implementation plan for scaling this opportunity with initial efforts focusing on renewable power generation given its broad relevance across QBE's portfolio. QBE will also explore opportunities to accelerate and expand its role in the growth of new technologies and extend global reach through growing existing underwriting, deploying new products and services, and enhancing underwriting and risk-engineering expertise across global teams. Details of the implementation plan will be finalised in 2026. Dependencies: The growth potential for insurance solutions that support the climate transition depends on the availability, effectiveness, and future scale of transition technologies. The commercial and economic viability of insuring transition technologies remains subject to uncertainty due to the emerging nature of these markets.

Continuing to embed our positions on energy sectors into underwriting appetite, implementing our assessment of in-scope customers' transition maturity: Since 2019, QBE has embedded its thermal coal position into underwriting, and since 2022, has applied its Environmental & Social Risk Framework to manage key environmental and social risks. QBE's positions include exclusions and enhanced due diligence requirements for fossil fuel sectors including thermal coal, oil, gas, oil sands and Arctic drilling. These positions are reviewed biennially, with refreshed positions to take effect from 1 January 2026. In 2026, QBE will commence the roll-out of the customer transition maturity assessment process for in-scope customers. The assessment will consider customers' emissions performance and, where relevant, additional factors such as decarbonisation goals. QBE will engage with customers assessed as low transition maturity and/or their brokers, and reassess these customers annually. If after three years the customer continues to be assessed as low maturity, QBE will consider if there are justifications for the customer's position and decide whether to decline or continue to provide insurance services. The assessment will be rolled out in phases, starting with the top 50 in-scope customers by gross written premium. In-scope customers are: (i) oil and gas customers who generate >60% revenue from oil and gas extraction (threshold reduced to >30% from 1 January 2040); and (ii) customers who generate >30% revenue from oil sands and Arctic drilling.

Deepening our understanding of higher-emitting portfolios to better understand our transition risks and identify opportunities to support customers' transition: QBE is prioritising the analysis of the current and forecast GHG emissions intensity of selected high-emitting portfolios, including analysis of the levers available to the sector to accelerate decarbonisation, implemented through a phased approach based on materiality of emissions, feasibility of measurement and level of QBE's influence. Levers available depend on the pace and scale of transition technology deployment, enabling government measures, and customers developing and implementing credible transition plans.

Customer engagement activities in 2025: Since 2023, QBE has set a target to engage annually with at least 50 priority customers, which it continued to achieve in 2025. Engagement activities included monitoring the priority customers cohort; reviewing public disclosures against recognised climate disclosure frameworks; engaging with priority customers at renewal in collaboration with brokers; and monitoring customer emissions and disclosure developments. Information collected is not used to determine individual customer premiums.

Key actions and dependencies - Investments

Financing the transition through investment in climate solutions: QBE has set a target to allocate at least $200 million to climate solutions investments annually from 2026 through to 2030, guided by defined climate solutions criteria and the same return and risk appetite standards applied across the broader investment portfolio. Dependency: sufficient and ongoing supply of eligible climate solution investments.

Continuing to incorporate climate risk and decarbonisation pathways into investment due diligence for in-house managed corporate issuers and external managers: Credit assessments and due diligence include consideration of emissions intensity, climate risks, and alignment with net-zero pathways, progressively embedding new datasets and scenario insights.

Continuing to engage with our highest corporate emitters and external managers: QBE will engage annually with the top 20 corporate issuers by Scope 1 and 2 carbon intensity based on enterprise value including cash (EVIC) in in-house managed investment grade corporate credit and high yield portfolios, as well as external managers as part of the annual due diligence process, to gather insights on emissions, climate risks, net-zero alignment and planned improvements. QBE will not make individual investment and divestment decisions solely on the basis of transition maturity.

Monitoring the carbon intensity of our public corporate debt portfolio: QBE has set a target to limit the Scope 1 and 2 WACI of its public corporate debt portfolio to 20% below the WACI of its market benchmark, expanding scope to encompass high yield debt and emerging market debt. Investment selection excludes issuers in thermal coal and oil and gas sectors, in accordance with QBE's Environmental & Social Risk Framework.

Advancing the climate alignment of our portfolio: In 2026, QBE will baseline the net-zero alignment of its investment portfolio and consider whether to formalise an alignment target.

Key actions and dependencies - Operations and supply chain

Taking actions to decarbonise our operations: Planned decarbonisation initiatives focus on phasing out gas heating and progressing energy-efficiency upgrades in owned and leased offices, as well as maintaining renewable electricity sourcing; transitioning fleet vehicles to more fuel-efficient alternatives including hybrid options; and limiting air travel emissions. Priority is placed on reducing in-scope emissions. Carbon removal certificates will be sourced to neutralise emissions that remain after implementing reduction measures. The cost of emissions reduction initiatives, carbon avoidance and removal certificates and renewable electricity certificates will be funded through QBE's internal carbon price mechanism. Dependencies include cooperation from landlords, fleet transition feasibility, and ongoing availability of high-quality renewable energy contracts and certificates.

Embedding emissions reduction measures into our supply chain: QBE has introduced a target for 70% of global strategic suppliers to have publicly defined emissions reduction targets by the end of 2030. QBE will engage strategic suppliers through tailored outreach and capability-building resources, embed sustainability considerations into sourcing and supplier management processes, and pursue collaboration and knowledge sharing with suppliers that have established commitments.

Advocating to build climate resilience: Our own analysis of QBE's climate resilience has deepened understanding of the complex challenges climate change poses to communities and customers. Building greater resilience requires a collaborative effort across a broad network, including governments, regulators, communities, the financial sector, and other key stakeholders. Through industry memberships, QBE advocates for stronger community resilience measures, more effective climate-related policy settings and industry guidance. QBE also engages with trade associations and industry bodies to progress initiatives that support climate resilience.

Progress against previous targets

In 2021, QBE established interim targets for 2025, progress on which is disclosed in the 'Metrics and targets' section. This year, QBE has revised the scope of its ambition and updated associated targets, which will take effect from 2026.

Capital deployed towards climate-related risks and opportunities

Climate-related risks and opportunities are managed as part of business-as-usual activities and are resourced through existing budgets across the Group. Other than investments in climate solutions, the Group did not identify material direct expenditure attributable solely to the delivery of climate-related initiatives during the reporting period.

Diversified Metals & Mining

Strategic response and transition plan

Our Climate Action Plan (CAP) remains at the heart of our strategy, guiding our strategy to grow production of materials essential for the energy transition, decarbonise our operations, and support our partners in reducing value chain emissions. It also reflects our commitment to a just transition for the communities where we work and to grow responsibly in a changing world.

Our updated 2025 CAP provides an overview of our climate change strategy, commitments, targets, and forward-looking plans. It builds on our 2022 CAP and reflects our commitment to transparency, disciplined investment and long-term value creation. The 2025 CAP was approved by shareholders at our 2025 AGM.

Our ambition is to grow total production by ~3% per year on a copper equivalent basis, while targeting a 50% reduction in our net Scope 1 and 2 emissions by 2030 (relative to 2018 levels) and reaching net zero by 2050.

We have updated our capital expenditure guidance to principally reflect the slower pace of commercially viable technology development that we, our industry, and the world has experienced in hard-to-abate sectors. Pre-2030 abatement is therefore expected to be predominantly delivered through low-capital solutions and proven technologies.

Our pathway to a 50% reduction in our Scope 1 and 2 emissions by 2030 primarily relies on commercially available solutions such as renewable energy contracts and is contingent on advancing viable solutions for our Pacific Aluminium smelters (BSL and Tomago), where discussions are progressing but are finely balanced.

Key assumptions and dependencies

Our pathway to 2030 target is contingent on individual project investment decisions as well as obtaining necessary government and regulatory approvals. The net zero pathway is contingent on individual project investment decisions as well as obtaining necessary government and regulatory approvals. Any delay in concluding discussions with government or delivering repowering projects may impact our ability to meet our 2030 target within this decade.

Actions underway (mitigation)

  • Grow in production of materials essential for the energy transition.
  • Develop low-emissions technologies for minerals and metals processing, refining and smelting.
  • Transition to low-emissions mining vehicles or fuel supply.
  • Reduce emissions from our own operations.
  • Partner to decarbonise our value chains.
  • Actively engage on climate change and energy policy aligned with net zero ambition.
  • Increase renewable power.
  • Invest in a portfolio of high-integrity voluntary and compliance carbon credits.
  • Community engagement and social investment.
  • Embed just transition principles in our decarbonisation strategy.
  • Enhance our physical resilience to a changing climate, supporting the viability of our assets, our people and communities.

Indirect mitigation and adaptation (customers and suppliers)

We continue advancing our climate commitments by working closely with customers, suppliers and partners to decarbonise the steel, aluminium, shipping and procurement value chains. We work with more than 20,000 suppliers across complex multi-layered supply chains, prioritising engagement with 50 of our highest-emitting suppliers. Decarbonisation criteria are embedded in our evaluation processes for new sourcing in high-emission categories.

Resourcing

We are transitioning delivery of decarbonisation projects to our product groups and assets, while central oversight (RTEC team, Decarbonisation Office) continues for emissions reductions tracking and investment strategy review. In the medium term, we will invest up to $10 billion (in real terms) annually in sustaining, replacement and growth capital.

Progress against previous plans

In 2025, we continued to implement our CAP, progressing toward our 2030 target and 2050 net-zero ambition. Achievements included: finalising the Jinbi PPA; continued procurement of renewable energy and storage for BSL; started a battery swap electric haul truck trial at Oyu Tolgoi; completed construction and commissioning of Évolys™; commenced construction and commissioning of the Yarwun Hydrogen Calcination Pilot; and made strong progress on nature-based solutions, enabling more than 500,000 hectares of high-integrity projects. Challenges and lessons learnt included the BlueSmelting™ demonstration plant showing that industrial-scale deployment would require significant capital investment that is not yet commercially viable, and delays to Pilbara renewables and self-generated renewable diesel scale-up.

Oil & Gas Producers

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.

Retail REIT

Mitigation and adaptation measures (direct)

Rainfall, hailstorms and flooding

  • Emergency response procedures are documented for each destination, supported by regular training and evacuation drills.
  • Destinations liaise regularly with police and local emergency services and conduct joint emergency exercises.
  • Wet weather contingency plans are in place to mitigate hazards such as leaks, slips and falls.
  • Routine roof inspections are conducted to clear leaf debris from box gutters, reducing water-related risks.
  • Flood mitigation strategies include relocation of critical equipment from low-lying, high-risk areas and widening of stormwater drains.
  • Climate Change Adaptation Plans are prioritised for destinations most exposed to climate-related physical risks including, but not limited to, rainfall, hailstorms and flooding.
  • Maintenance of comprehensive insurance coverage for property damage, business interruption and personal injury.

Bushfire

  • Emergency response procedures are documented for each destination, supported by regular training and evacuation drills.
  • Destinations liaise regularly with police and local emergency services and conduct joint emergency exercises.
  • Hazard reduction activities, such as back burning, are carried out on a risk-based assessment.
  • Climate Change Adaptation Plans are prioritised for destinations most exposed to climate-related physical risks, including bushfire risk.
  • Based on a risk assessment, some destinations have generators to maintain power to essential services should power be disrupted.
  • Maintenance of comprehensive insurance coverage for property damage, business interruption and personal injury.

Policy and regulatory change

  • Monitor emerging regulations and industry trends.
  • Incorporate cost benefit analysis of replacing end-of-life equipment with more energy-efficient alternatives into strategic capital planning processes.
  • Implement advanced building analytics, upgrade to LED lighting across all destinations, and replace plant and equipment at end of life.
  • Use sustainable development and design principles to address potential changes to building standards and reduce embodied carbon in construction.
  • Include sustainable practices within tenancy design guidelines to support business partner alignment with environmental objectives.
  • Waste management plans focused on reducing organic material sent to landfill.
  • A Group target to achieve net zero emissions (scope 1 and 2) for wholly-owned Westfield destinations by 2030 (the "net zero target"), with strategies to extend net zero emissions across all destinations.

Stakeholder expectations (indirect)

  • Monitoring trends and stakeholder expectations to support alignment with emerging requirements and industry standards.
  • Internal verification of external communications, incorporating review and approval by subject matter experts across the business.
  • Independent third-party assurance of key environmental data.
  • Regular monitoring and disclosure of progress towards the Group's net zero (scope 1 and 2) emissions target for wholly-owned destinations.
  • Regular engagement with investors, lenders, joint venture partners and business partners about climate-related topics to seek feedback, share insights and remain informed on emerging themes.
  • Quarterly meetings with joint venture partners to discuss and align on future investment opportunities.
  • Implementation of an Australian Sustainability Reporting Standards (ASRS) reporting plan, supported by internal governance structures.

Opportunities implementation strategies

  • Enhance engagement with customers and communities: In 2025, Westfield Kotara commenced a trial of a new EV operating model to inform future opportunities. Following completion of the trial, the potential to introduce EV charging facilities across additional destinations will be evaluated. Implementation will be informed by EV adoption across Australia and New Zealand, duration and changes to government incentives, technology evolution, and implementation costs and expected costs for future upgrades.
  • Support business partner transition to a low-carbon economy: There are 28 Westfield destinations with an embedded electricity network where the Group has the ability to procure and surrender renewable energy certificates on behalf of business partners. Engagement and discussions with business partners are ongoing.

Transition plan – Net zero strategy

The Group's net zero strategy is guided by understanding the key contributors to the Group's emissions. This has informed the approach and strategic priorities. Currently, of the total portfolio's scope 1 and 2 emissions, 94% are scope 2 emissions from the use of electricity, predominantly for air conditioning, lighting and vertical transport. The remaining 6% are scope 1 emissions relating to the consumption of gas for heating, fuels for emergency back-up power generation and refrigerants in air conditioning units. The net zero strategy has three principles, each with key dependencies, including market conditions, counterparty risk, and regulatory requirements:

  1. Optimise centre efficiency – Operational teams are focused on increasing centre efficiency and reducing demand for energy, supported by three initiatives: Next Gen Building Analytics (a centralised team analyses building management systems alongside other data sets to identify opportunities to optimise energy efficiency and drive plant and equipment improvements); implementation of LED lighting across the portfolio; and replacing plant and equipment (heating, ventilation and air conditioning, and building management systems) with newer, more efficient technology.
  2. Generate and procure renewable energy certificates – Using renewable energy reduces scope 2 emissions. There are on-site solar installations at nine Westfield destinations with a total solar generation capacity of 12.2MW. Viable opportunities for on-site solar installations are continually assessed, considering electrical infrastructure to support solar connectivity, access to significant sunlight, economic viability, and council development and approval requirements. Renewable energy certificates created by companies generating renewable electricity through solar, wind and/or hydro projects are purchased to account for electricity use. To account for electricity emissions from Queensland (excluding Westfield Helensvale), New South Wales, the Australian Capital Territory, Western Australia and Victorian destinations, the Group has energy agreements to purchase Large-scale Generation Certificates (LGCs) verified by the Australian Government's Clean Energy Regulator, which will progressively account for more electricity emissions supporting net zero scope 2 emissions by 2030. The Group's electricity supply agreement in New Zealand provides New Zealand Electricity Certificates that account for 100% of the electricity emissions from New Zealand Westfield destinations, in place since 2022. Opportunities to purchase renewable energy certificates for remaining Westfield destinations continue to be explored.
  3. Address residual emissions – There will be residual scope 1 emissions remaining even after abatement efforts and efficiency optimisation initiatives have been implemented; these currently account for 6% of total portfolio scope 1 and 2 emissions. Residual scope 1 emissions will be addressed through engaging construction contractors to use diesel alternative equipment and replacing end-of-life equipment with low global warming alternatives. Any scope 1 emissions remaining after operational initiatives will be monitored and additional measures considered, which may include the use of offsets; however, no decision has been made regarding the types of offsets that may be used. The Group is currently exploring the implementation of environmental feasibilities which are presently considered more relevant to the business than the adoption of a carbon price, however this approach will continue to be assessed.

While the net zero target relates to wholly-owned Westfield destinations, strategies are implemented to reduce scope 1 and 2 emissions across the total portfolio, and emissions are tracked portfolio wide.

Healthcare Providers
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.

Metallurgical Coal Mining

The Group has strengthened its strategic approach to climate-related risks and opportunities through the implementation of our Decarbonisation Plan, which now serves as the foundation of the company's broader climate transition strategy. The Plan has already begun shaping decision-making by setting clear emissions intensity reduction objectives, identifying potential investment areas, and embedding climate considerations into operational and capital planning processes. Its direction was further reinforced by the scenario analysis conducted in 2025, which provided deeper insight into how material climate-related risks and opportunities may evolve across different time horizons and policy pathways.

Strategic Risk & Action responses

Technology and Innovation (CR3): In 2025, the Group examined opportunities related to reducing fuel usage across its fleets, assessing viability and identifying technologies with future potential. These efforts are strengthened by the Group's longstanding investment in Low Emission Technology Australia (LETA), a specialist fund dedicated to advancing large-scale deployment of emissions-reducing technologies across critical industries. By maintaining an active role in technology evaluation, the Group reduces the risk of being left behind by breakthrough solutions, ensures access to proven technologies, and strengthens its ability to align with evolving policy requirements and stakeholder expectations. This approach also provides flexibility to adapt as steel-making processes evolve, mitigating the risk that demand for metallurgical coal is eroded by technological change in end-use markets.

Methane Capture (CR1): SWC Gas-to-Electricity Project is the most advanced decarbonisation initiative in the Group's portfolio and forms a cornerstone of its emissions reduction strategy. With support from state government investment programs, the project involves capturing methane released from coal seams prior to mining and converting it into on-site power generation. By preventing fugitive methane emissions and displacing grid electricity, the project has the potential to deliver a reduction in Scope 1 and 2 emissions. In addition to decarbonisation, the initiative enhances energy security by providing a reliable on-site supply of electricity. The project also delivers important governance and reputational benefits, addressing policy and legal risks under the Safeguard Mechanism and demonstrating a clear commitment to emissions reduction. As the project progresses, the Group is also evaluating options to expand drainage capacity and to explore flaring and other beneficial uses of captured gas beyond on-site power generation.

Fugitive Emissions Accounting (CR1): Method 2 reporting will improve the transparency and accuracy of fugitive emissions accounting and is a critical focus of the Decarbonisation Plan, reflecting the fact that fugitive emissions currently account for almost half of the Group's Scope 1 emission profile. The Group is undertaking drainage studies, gas testing, and advanced data development to ensure compliance with the National Greenhouse and Energy Reporting Scheme (NGERS) and to provide more data for mitigation, reporting and carbon accounting. At the same time, the Group is working closely with the Australian Government to address regulatory uncertainties in gas drainage accounting for open-cut mining.

Scope 2 Reductions (CR1, CR2): The final component of the Decarbonisation Plan addresses Scope 2 emissions reduction. The Group's strategy is to align with Queensland's Energy Roadmap 2025 and generation mix – achieving emissions reductions through the increasing percentage of green energy which makes up grid supplied electricity. Opportunities under investigation include behind-the-meter solar generation at PTM and IPC, which would provide clean, reliable power directly to operations, and the potential use of green Power Purchase Agreements (PPAs) to complement these efforts with longer-term price and supply certainty. Although Scope 2 emissions only account for around 10% of the Group's operational emissions footprint (excluding Scope 3), reductions in this category are technically possible and will assist in strengthening the Group's standing with investors, insurers, and workforce stakeholders. In addition to these measures, the Group will continue to purchase certified ACCUs (or SMCs) as required to offset residual emissions, ensuring full compliance with government standards.

Risk Management Embedding

Building on the identification of material climate-related risks and opportunities, the Group has embedded their management into its Enterprise Risk Management Framework (ERMF) to strengthen overall business resilience. The ERMF provides a structured process for assessing, prioritising, and monitoring climate-related risks and opportunities alongside broader strategic and operational risks. Assessments are undertaken using established methodologies, including the Group's Risk Appetite Statement and Risk Matrix, to determine materiality and evaluate the potential financial consequences for the business.

To ensure that financial implications remain current, the Group maintains a dedicated Scenario Analysis and Financial Impacts Register. This register captures the quantified financial effects of identified climate risks and opportunities across different scenarios and time horizons, and its outputs feed directly into the Climate Risk Register.

Capital Allocation & Progress to Date

The Group has established clear plans and allocated the necessary resources to support the activities set out in the Group's Climate Strategy. Annual budgets include operating costs to progress the relevant studies and monitor technology developments. This is across both the decarbonisation work stream and Stanmore NextGen Pty Ltd, which assesses potential commercial partnerships and opportunities to further the Group's objectives. The annual budgeting process also captures future capital requirements. When an opportunity has been endorsed it will go into the project pipeline for further assessment, delivery and reporting.

Emerging Considerations

Under global decarbonisation pathways, emerging steelmaking technologies such as hydrogen-based Direct Reduced Iron (DRI) and Electric Arc Furnaces (EAF) are expected to play an increasing role in reducing emissions across the steel sector. While these processes may gradually alter the long-term composition of steel production, current market outlooks indicate continued reliance on blast-furnace operations, particularly in growth regions such as India and Southeast Asia. Industry analysis by Wood Mackenzie projects that global seaborne metallurgical coal demand will increase from around 330Mt in 2025 to approximately 375Mt by 2050. The Group remains well positioned within this evolving context, with a portfolio focused on premium, low-impurity metallurgical coal that supports lower-emission blast-furnace operations. The Group continues to monitor technology adoption rates and policy developments to ensure its strategy remains aligned with future market dynamics.

Diversified REIT

Strategy (p. 189). Four pillars of the Sustainability Strategy carry the climate strategy: Decarbonization, Resilience, Circularity and Social impact. Decarbonization seeks a practical, 1.5°C-aligned pathway to net zero across operations and the value chain.

Transition plan (p. 189). The 2023 Climate Transition Action Plan (key actions, pathways, assumptions and dependencies) is now integrated into the Climate Report rather than being a separate publication.

Actions (pp. 188–191). Renewable electricity procurement (voluntary green power and LGCs from the Energy Bay arrangement, which runs to 2030), onsite renewable generation, electrification and energy efficiency, and lower-carbon materials such as low-carbon concrete, electric arc furnace steel, lower-carbon reinforcing steel and sustainable timber solutions. Residual Scope 1 emissions are offset with ACCUs.

Dependencies for the 2030 target (p. 191). Electricity grid decarbonization, cost and availability of lower-carbon materials and services, the ability of suppliers, contractors and tenants to decarbonize and supply reliable data, stability of climate-related policy and market settings, and portfolio mix. The decarbonization forecast uses the AEMO Slower Growth model (p. 199).

Resourcing (p. 186). No separate pool of capital is allocated to climate initiatives, and the share of capital allocated to climate-related risks and opportunities cannot be separately identified.

Responses by CRRO (pp. 27–32). Reinsurance: a five-year aggregate cover and optimization of structure, attachment points and limits. Underwriting: address-level pricing, aggregate exposure guardrails and enhanced climate forecasting. Claims: Trans-Tasman surge capacity. Disaster management: a staged $25 million jobs and investment package over FY23–FY28 (p. 31). Opportunities: motor insurance for drivers of electric and hybrid vehicles, Digital Insurer, and an annual commitment of 5% of AAI Limited shareholder funds to social impact and lower-carbon impact investments (p. 32).

Climate Transition Plan (pp. 37–38). The Plan, released in the FY25 Climate-related Disclosure Report, is summarized: net-zero Scope 1 and 2 by end FY30 from an FY20 baseline; RE100 commitment of 100% renewable electricity in 2025; and a financed emissions intensity target for listed equities and corporate bonds. Implementation covers major procurement suppliers (50 suppliers; 74% publicly disclose Scope 1 and 2), claims panel builders and motor mobility suppliers, engagement with 100% of external investment managers each year, and fossil fuel exclusions under the Sensitive Sector Standard, met in FY26.

Assumptions and resourcing (pp. 32, 39). The net-zero target assumes competitive renewable electricity products and ongoing supply of hybrid and electric vehicles through FY30. Capital is deployed through business-as-usual activities and existing budgets, not allocated separately to CRROs.

Telecommunications

Index (p. 215): Climate strategy, p. 186; Climate transition plan, p. 200.

Strategy (pp. 186, 199). Sustainability, including climate, is an integral part of the Connected Future 30 strategy. No significant changes to strategy or business model are anticipated in the short to medium term in response to climate-related risks or opportunities (p. 199).

Transition plan (pp. 200–201). Telstra used over 1,000GWh of electricity in Australia in FY26, so its transition depends on grid decarbonization. Three primary activities: absolute emissions reduction of its own operations; enabling decarbonization of the electricity network; supporting suppliers to decarbonize. It commits to net-zero across scope 1, 2 and 3 by 2050, with interim 2030 reductions of 70 percent (scope 1+2) and 50 percent (scope 3) from an FY19 baseline. Assumptions and dependencies: growth; grid decarbonization, assuming Australia meets the 82 percent national renewable energy target by 2030 (otherwise more reduction activity or renewable energy certificates); energy efficiency and decommissioning; scope 3 based on key suppliers' commitments.

Resourcing and adaptation (pp. 190, 200). Nearly $22 million was invested in FY26 in dedicated energy efficiency and decommissioning, and since 2017 Power Purchase Agreements have supported renewable energy projects worth $1.6 billion. Adaptation includes seasonal preparedness, lifecycle battery replacement and automatic transfer units.

Infrastructure & Facilities Services

Current and anticipated adaptation and mitigation efforts, by risk/opportunity

Disruption risk from acute and chronic climate events (Physical Risk): Commercial arrangements – the Group intends to maintain a disciplined contracting approach to limit its financial exposure to climate-related events. Customer engagement – the Group routinely works with customers on emergency planning and risk mitigation. Enhance weather planning and early warning – the Group is improving operational planning to consider changing weather patterns, using climate data to schedule works outside peak bushfire seasons or relocate equipment ahead of forecasted floods. Supply chain readiness – continued proactive engagement with subcontractor partners to enable ongoing availability of resourcing, including during disaster recovery periods. Business continuity and safety management – reviewing work locations and infrastructure to identify potential mitigation measures for longer-term physical vulnerabilities, through safety management systems and processes.

Transitioning in step with climate policies and market expectations (Transition Risk): Alignment with climate policy trajectories – the Group actively monitors government policy developments, industry roadmaps and its key customers' climate strategies, treating potential policy changes as a strategic factor in deciding which markets to focus on. Decarbonising operations – the Group has a climate transition plan that outlines its emission reduction plan and alignment with climate policy. Maintain a diversified portfolio – the Group operates across various industries, reducing reliance on any single segment.

Supply chain disruption (Physical and Transition Risk): Diversify and localise our supplier base – the Group aims to reduce geographic concentration risk by procuring from and partnering with national service providers that are geographically diversified. For example, in 2025 the Group executed a multiyear strategic partnership with Coates, allowing access to emergency equipment hire across Australia. Contractual indexing and pass-through mechanisms – for example, road surfacing contracts are typically indexed to bitumen price indices. Innovate with alternative materials – the Group works with suppliers to implement lower-carbon alternative materials, such as high-recycled-content asphalt mixes. Supplier engagement on resilience.

Supporting energy transition build-out, operations and maintenance (Opportunity): Invest in capabilities for new energy markets – continue to build in-house expertise in power transmission, distributed energy and renewable asset maintenance. Expand service offerings – increase capability to support customers in planning and executing end-to-end transition projects, leveraging cross-organisational enterprise expertise across defence, telecommunications and electricity network operation and maintenance and renewables.

Supporting our customers in decarbonisation, climate adaptation and response to extreme weather events (Opportunity): Collaborate closely with our customers – proactively engage to identify, propose and offer solutions to facilitate resilience and transition. Leverage Ventia's Operations Centre (VOC) for emergencies – VOC is a 24/7 Operations Centre that coordinates field teams and has been enhanced to mobilise rapid responses to climate-related emergencies (floods, heatwaves, bushfires) across different service lines under a unified command.

Climate transition plan

The Group aims to support business growth and resilience through decarbonisation of its operations. The Group's climate transition plan establishes an approach for it to achieve its goals and targets, incorporating emissions reduction targets aligned with climate science as validated by the SBTi in 2024. The Group's 2030 SBTi emissions reduction target is informed by the 1.5°C goal of the Paris Agreement, and the Group's net zero ambition is informed by the less than 2°C goal of the Paris Agreement. The plan distinguishes between targets supported by specific planned actions and ambitions requiring additional planning and evaluation. The climate transition plan focuses on two key pillars – building resilience within the Group's core business and its ambition for decarbonisation of its own operations.

Building resilience within the core business:

  • Expand capability and work in energy and renewables as a core growth pillar as part of the Group's 2025–2029 strategy. The Group acquired PowerNet on 1 July 2025, supporting strategic positioning and regional capabilities in Southeast Australia. In 2025, revenue from energy and renewables services was $387.4 million, up 32% on 2024. The Group has plans to develop a Strategic Capability Plan for Energy (including Renewables) in 2026, to be implemented between 2026–2028, outlining the people, skills, structures and enabling systems required to support sustainable growth.
  • Maintain a diversified portfolio. The Group's strategy focuses on improving and growing its core business, while exploring close-to-core opportunities that align with its strengths and risk appetite. The strategy identifies opportunities across all existing sectors, with no anticipated increase in exposure to transition risk-concentrated segments.
  • Embed climate considerations in business processes and tools. A Strategic Activity Filter for business decisions was introduced in September 2025 with integrated climate risk and opportunity considerations, used by Management when the Group is pursuing new initiatives. In 2025, the Group became a partner of the Supply Chain Sustainability School in Australia, ahead of the relaunch of the platform in February 2026, providing learning materials on sustainability topics including energy, carbon and climate adaptation.

Ambition for decarbonisation in our operations:

  • By 2030, achieve a 42% absolute gross emission reduction target for Scope 1 and Scope 2 GHG emissions (market-based) from a 2021 base year – on track, 22.4% reduction achieved to date, delivered through initiatives across fleet, corporate properties and operations.
  • By 2030, ambition to achieve a 51% reduction in Scope 3 GHG emissions intensity (GEVA) from Purchased Goods and Services from a 2021 base year – tracking behind, with Scope 3 emissions increasing from 2021 to 2025 due to the spend-based measurement method correlating to revenue growth. Improvements to Scope 3 inventory data implemented in 2025. An indicative Scope 3 emissions reduction pathway was mapped; the goal was retained, however significant additional work is required and there remains a risk it may not be achieved in the preferred time horizon.
  • By 2050, ambition to achieve a 90% absolute gross GHG emissions reduction and net zero emissions for Scope 1, 2 and 3 GHG emissions – supported by the plan to achieve reductions in Scope 1, 2 and 3 emissions by 2030; the energy transition is anticipated to provide a potential lever to decarbonise the services sector; more robust planning is required to define the Group's net zero pathway.

Scope 1 and 2 emissions reduction plans (progress 2021-2025, planned 2026-2030, potential 2030-2050): In 2025, the Group achieved a reduction of Scope 1 and 2 emissions (market-based) of 11,306 tCO2-e or 22.4% from its 2021 baseline of 50,531 tCO2-e. Actions include: Mobile Plant and Equipment – retired 1,278 aged light vehicles, 13.0% EV or hybrid light vehicles, efficiencies through idling reduction/driver training, EV charging infrastructure commenced at select sites; planned to retire a further 100–500 vehicles and modernise fleet by 2030; net zero levers include lower emissions fleet technologies, transition of heavy vehicles, residual emissions offset. Stationary Plant – generator emissions reductions (Tier 4 standards, battery storage, hybrid generators); planned strategic partnership with suppliers for low-carbon equipment, pilot HVO diesel, electrification of property/facilities; net zero levers include lower-carbon fuel sources, grid interconnection, residual offset. Purchased Energy – reduced emissions 3,758 tCO2-e or 59%, on-site solar consumption of 891,787kWh since 2021, 31.2% renewable electricity in 2025; planned to reduce energy consumption, remaining electricity to be 100% renewable by 2030 through on-site solar and Greenpower procurement; net zero lever of 100% renewable electricity.

Scope 3 GHG emissions reduction plan: Category 1 Purchased Goods and Services represents over 80% of total Scope 1, 2 and 3 inventory for 2025. Progress 2021-2025: Scope 3 intensity (GEVA) reduced by 9.6% from the 2021 baseline, while Scope 3 and Category 1 absolute emissions increased by 27.9% and 37.9% respectively; surveyed over 100 suppliers; increasing adoption of alternatives to carbon-intensive materials. Potential 2026-2030: implementing lower-carbon solutions such as lower-carbon road pavement solutions, strategic supplier partnerships to deliver electric and lower-emissions equipment, improved accuracy of supply chain emissions data moving from spend to hybrid carbon accounting. Potential 2030-2050: engagement with suppliers for lower-carbon solutions including strategic supplier partnerships, residual emissions offset.

Assumptions and dependencies for Scope 1, 2 and 3 pathways: business changes (no M&A assumed beyond growth); technology availability (availability of suitable electric/lower-emissions vehicles in line with the Australian New Vehicle Efficiency Standard schedule, fully electric light commercial vehicles at scale by 2028, improving whole-of-life costs); government climate policy and action (continued government support for net zero by 2050 and intermediate 2030/2035 targets, renewable energy target, electrification initiatives, NVES); collective action across the value chain (Scope 3) (reliance on customers, suppliers and stakeholders viewing climate action as a value driver, supplier data provision); business growth (growth risks growing the emissions inventory, assumption included in reduction pathways); pathway to net zero (continued advancement/commercial viability of lower-emissions technologies, alternative fuel availability, continued government policy); offsetting (residual emissions considered for offset only once 90% absolute reduction achieved across combined Scope 1,2,3, not anticipated before 2045, viability considered in light of external and regulatory frameworks). The Group reviews the appropriateness of these assumptions and dependencies at least annually.

To deliver on the target and goals, the Group is resourced with a central sustainability team, working with the CGSC and the cross-functional CWG, to support the business in planning, implementing and monitoring its emissions reduction plans.

Fuel Refining & Retail

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.

Capital allocation (pp. 74–75). An internal carbon price has been applied since 2014 in capital expenditure assessments, mergers and acquisitions analysis and corporate planning: $48.10 per metric tonne of CO2e in 2026, rising to $144.60 (2026, real) by 2050. In July 2026 the Mt Holland expansion was approved (Wesfarmers' share of capital expenditure about $645 million to $715 million, nominal, excluding capitalized interest).

Mitigation and adaptation (pp. 65–78). Each division has emissions reduction and net zero targets and a transition pathway. Group Scope 1 and 2 (market-based): 1,622 ktCO2e (sum of divisional baselines), 802 in 2026 and 700 residual in 2030 (down 57%), via industrial process abatement, grid decarbonization, fuel switching and fleet electrification, and renewable electricity. WesCEF is rolling out tertiary nitrous oxide abatement (about 115,000 tCO2e a year) and replacing a sodium cyanide incinerator. Physical risk measures include business continuity plans, flood and drainage controls, backup generators, supplier diversification and insurance.

Resourcing (p. 75). Climate expenditure is generally within divisional operating budgets and capital programs, not tracked separately.

Dependencies (pp. 78–79). WesCEF's 2050 net zero target depends on low-emissions technologies including CCS, supportive policy and government funding. Scope 3 follows a managed momentum approach with five priority areas.

Thermal Coal Mining

Transition plan (page 75). Whitehaven does not have a formal climate-related transition plan. It continues to assess and pursue site-based decarbonization opportunities with prospects for economic viability and technical feasibility. Pending further advancement, the focus is site-based initiatives to mitigate Scope 1 emissions and carbon credits to meet Safeguard Mechanism obligations. At present, available operational abatement technologies are not expected to deliver the required emissions reduction in a technically feasible and economically viable manner to meet those obligations.

Levers (pages 75–77). Table 8 lists levers, including goaf sealing at Narrabri and electrified dig units (both implemented) and a proposed 26 MW Narrabri Solar Farm (FY30–FY40, subject to final investment decision and Board approval). In New South Wales, 100% of Scope 2 emissions are offset through Climate Active-certified carbon-neutral electricity; from January 2026 it is 100% GreenPower renewable energy. About $5.6m contributed to Low Emission Technology Australia since 2020.

Decisions and capital (pages 60, 63, 91). Climate-related factors are incorporated into major acquisition and investment decisions (page 60). The April 2024 Daunia and Blackwater acquisition advanced the goal to grow in metallurgical coal, now 57% of FY26 revenue (page 63). FY26 capital invested toward mitigating climate-related risks was $21m, mainly water management infrastructure (page 91).

Software & IT Services
Partial disclosure: No formal climate-related transition plan exists (p. 211), so the key assumptions and dependencies in paragraph 14(a)(iv) are not given, and with no targets there is nothing on how targets will be achieved (14(a)(v)). Resourcing (14(b)) is described as embedded within business-as-usual operations and immaterial, with the one amount being the approximate $3.5–19.5m of R&D investment aligned to the regulatory opportunity (p. 216). No progress against previously disclosed plans is reported (14(c)); this is the first reporting period, in which the report adopts relief for comparatives (p. 209).

Pathway (p. 211). The Net Zero Carbon ambition (global operations Net Zero Carbon, products supporting customers to reduce emissions) is intended to provide strategic direction rather than represent a formal climate target. WiseTech says it does not have a formal climate-related transition plan but a high-level pathway, with low-carbon electricity and electrification of remaining fossil fuel usage as the primary levers.

Actions (pp. 211, 214, 216, 219). The Sydney HQ moved to 100% renewable electricity in FY25 and the Chicago site during FY26; low-carbon electricity (renewables or nuclear linked) will be procured for other sites where practicable. In FY26 WiseTech decided to discontinue carbon offsets (p. 211). Data center locations are expected to be consolidated after the e2open acquisition (p. 214). Energy consumption of pre-existing operations decreased following the move to a co-located data center in Australia and the transition from leased offices to co-working spaces (p. 219). Features responding to the regulatory opportunity include shipment-level emissions quantification (p. 216).

Resourcing (p. 216). Resourcing for climate-related activities is embedded within business-as-usual operations and immaterial; capital expenditure deployed toward climate-related risks is not material. Business activities aligned to the opportunity of climate-related regulation represented investment of approximately $3.5–19.5m in FY26, 1–5% of R&D investment.

Oil & Gas Producers

Woodside's climate strategy is integrated throughout our company strategy: our aspiration to thrive through the energy transition by developing a low-cost, lower-carbon, profitable, resilient and diversified portfolio.

Our climate strategy contains two key elements: reducing our net equity Scope 1 and 2 GHG emissions; and investing in products and services for the energy transition.

Reducing our net equity Scope 1 and 2 GHG emissions is supported by three levers: avoiding emissions in design; reducing emissions in operations; and offsetting the remainder with carbon credits.

Investing in products and services for the energy transition is also supported by three levers: assessing investments for their resilience to the energy transition; diversifying our products and services; and supporting our customers and suppliers to reduce their emissions.

These levers are further supported by our work to promote global measurement and reporting – including our own publication of transparent disclosures.

Woodside published a Climate Transition Action Plan and 2023 progress report in February 2024. Progress against this plan relevant to 1 January to 31 December 2025 is outlined in this report. Woodside is a signatory to global decarbonisation initiatives, including the World Bank's Zero Routine Flaring Initiative, UNEP's OGMP 2.0, and the Oil and Gas Decarbonisation Charter (OGDC).

Reducing net equity Scope 1 and 2 GHG emissions

GHG emissions reduction at facilities can be achieved through the way they are designed ('design out emissions') or by changes to the way they are operated after construction ('operate out emissions').

Efficient operations: The emissions efficiency of Woodside's current operations, measured as Scope 1 and 2 GHG emissions per unit of production (kg CO2-e/boe) compares well to the global average efficiency data provided by the IEA. Woodside's 2025 actual performance was 27% better (or, 12.4 kg CO2-e/boe) than the benchmark comparator.

Asset decarbonisation plans: Our operated production assets identify opportunities to reduce GHG emissions via asset decarbonisation plans. The main opportunities include energy efficiency and process optimisation measures, flaring and fugitive methane reduction, and electrification such as the use of renewables and batteries. As these opportunities are studied and matured, and if they are safe, technically viable and have an abatement cost of <US$80/t CO2-e they are considered for inclusion into business plans. At the end of 2025, projects which are expected to deliver approximately 50% of the GHG emissions reduction benefits of currently identified opportunities over the remaining facility life have commenced. In 2025, Woodside achieved record low flaring performance at KGP with flared quantities less than 10% of their peak in 2013, reducing GHG emissions by 62 kt CO2-e compared to the originally budgeted plan.

Focus on methane: Management of methane emissions receives particular focus within our asset decarbonisation plans. In 2024, Woodside joined the OGMP 2.0. During 2025, Woodside submitted its implementation plan to UNEP which has confirmed it meets the requirements as a "Gold Standard Pathway". This methane emissions management plan includes improving our ability to measure methane emissions, taking action to reduce them where identified, transparent reporting of data, and supporting the adoption of best practice across industry and regulation. As part of the plan, we have also set a five year (to 2029) intensity target to maintain methane emissions intensity below 0.2% of production by volume at operated assets.

Large scale abatement: Electrification, hydrogen fuelling and CCUS are all methods for reducing GHG emissions from our electrical and mechanical turbines, which for a typical LNG facility account for a range of 75–85% of facility GHG emissions. During 2025, engineering work on the leading opportunity at the Pluto facility was completed. Hydrogen fuelling of turbines had emerged as the leading opportunity, with hydrogen generated from natural gas auto thermal reforming with CCS. Engineering studies confirmed that unit abatement costs remain several times higher than Woodside's US$80/t CO2-e carbon price (real terms 2024). While there is no further technical work to progress at this time, Woodside is continuing to pursue policy advocacy, technology development and market engagement.

Carbon credits: Woodside uses carbon credits to offset gross equity Scope 1 and 2 GHG emissions that are above our net GHG emissions reduction target trajectory and to meet regulatory requirements in a given year. We prioritise abatement at facilities before we use carbon credits as offsets. As at 31 December 2025, Woodside continues to manage a portfolio of more than 20 million carbon credits sourced from projects registered under established carbon crediting schemes, including the ACCU Scheme, Verra, Gold Standard and the Climate Action Reserve. Woodside currently uses a mix of avoidance and removal type carbon credits, with the current approach seeking to increase the proportion of land-based, removal carbon credits over time.

Investing in products and services for the energy transition

Woodside expects sustained demand for natural gas through the energy transition in the decades ahead. We also expect growing demand for new energy products (such as hydrogen and hydrogen derivatives like ammonia) and lower-carbon services (like CCS). Each new investment is tested against the hurdle rates in our Capital Allocation Framework. Analysis includes explicit consideration of the resilience of an investment to the energy transition – including scenario analysis, risks and opportunities, and Scope 1, 2 and 3 GHG emissions. We further inform this analysis through direct engagements with customers. We have representative offices in Japan, China, Korea, Singapore and the United Kingdom.

Themes heard from customers in 2025 included: decarbonisation remains an important priority and has to be delivered alongside energy security and affordability; LNG and natural gas are a key linkage between energy security and decarbonisation goals; markets for new energy products and lower-carbon services are taking longer to develop than originally anticipated; each region has its own set of unique opportunities and challenges through the energy transition; energy policy and market settings need to contribute to the reliability and long term security of LNG supply.

Our analysis of this expected demand is a driver for our recent LNG investments including the Scarborough Energy Project and Louisiana LNG, as well as our Beaumont New Ammonia project, which started production in 2025 and is planning to commence the use of CCS in 2026. Beaumont New Ammonia is expected to account for $2.35 billion (inclusive of final completion payment) of our $5 billion Scope 3 investment target, and 1.6 Mtpa of our 5 Mtpa Scope 3 emissions abatement target.

Progress against prior plans

Cumulative expenditure against our Scope 3 investment target reached $2.6 billion at the end of 2025, up from $2.46 billion at the end of 2024. This is due to expenditure on Neosmelt, Beaumont New Ammonia Phase 2 assessment, and select CCS opportunities in Asia Pacific. Woodside delivered its 2025 net equity Scope 1 and 2 GHG emissions reduction target, achieved through a combination of underlying emissions performance at our facilities and the use of carbon credits.

Food & Grocery Retail

Net zero transition (pp. 68–69). The Group is working toward net zero emissions by 2050, aligned to Science Based Targets Initiative (SBTi) validated targets for Scope 1, 2 and 3. Delivery programs manage material transition risks and climate-related opportunities.

Direct mitigation (pp. 70–71). Scope 1 and 2: 100% renewable electricity (achieved 31 December 2025), low-emissions refrigerants with reduced leak rates, and EVs for the last-mile home delivery fleet. In F26: 25 stores added to transcritical CO₂ refrigeration and 178 electric home delivery trucks on the road, up 103 since F25.

Indirect mitigation (pp. 69, 73). Scope 3 actions: collaborate, innovate and invest, advocate and educate. The fourth annual value chain emissions program had 75 suppliers.

Resourcing (p. 74). $111 million invested in F26 on initiatives driving the overall strategy and progress toward Scope 1 and 2 targets. Annual investment of $100 million to $120 million (capex and opex) is required for F27 to F30, funded from operational cash flows and debt facilities.

Assumptions and dependencies (pp. 68, 70, 76). Scope 3 targets rely on cross-sector collaboration and progress by suppliers, industry and government, and are based on assumptions about supplier commitments, behavior and performance, government policy and regulation, and technology availability and costs. A full home delivery fleet transition relies on regional infrastructure investment and EV availability.

Engineering & Construction

Climate transition plan (pp. 46–47). Two focus areas: supporting customers to decarbonize, and reducing Scope 1 and 2 emissions to net zero by FY2030. Sustainability-related work rose from about 30% of the portfolio in FY2020 to 69% in FY2026 (aspiration: 75% of revenue by the end of FY2026). Scope 1 reductions came from consolidating offices and worksites, efficiency measures and fleet changes; Scope 2 reductions mostly from renewable electricity and Renewable Energy Certificates. Carbon credits are expected from FY2029 for residual emissions. The roadmap chart (p. 47) prints no values.

Assumptions and dependencies (pp. 46–47, 53). The roadmap reflects current intentions and assumptions about future business activity and decarbonization opportunities. Most remaining Scope 1 emissions are difficult or disproportionately expensive to abate, and some residual Scope 2 is expected where renewable energy access is limited. Targets are subject to the external operating environment and market conditions.

Responses and resourcing (pp. 42–45). Direct and indirect efforts are set out for each CRRO, for example business continuity and emergency response through R3 and HSE (CRRO 3). Resourcing is named per CRRO (Sustainability, Growth, R3 and HSE functions). No capital was directly deployed against any CRRO in FY2026; over five years the strategy included $100m invested over three years to organically grow capabilities (p. 42).

Thermal Coal Mining
Partial disclosure: Describes direct mitigation efforts, decarbonisation collaborations and resourcing, but does not disclose a formal climate-related transition plan with key assumptions and dependencies, nor quantitative/qualitative progress against previously disclosed plans; no emissions reduction targets have been set.

Climate change is a core performance category within Yancoal's Planet pillar of the P4 Change 4 Tomorrow Strategy, and we continue to manage climate-related risks and opportunities (CRROs) as part of our broader strategic and risk management approach.

Our capital allocation processes incorporate an assessment of factors such as coal demand outlook, regulatory developments and carbon cost implications.

Operational emissions remain a key focus area within the Yancoal P4 Change 4 Tomorrow Sustainability Strategy. Scope 1 emissions are released into the atmosphere as a direct result of an activity, or series of activities at a facility. Our predominant Scope 1 emissions are fugitive emissions released during the extraction of coal and diesel fuel combustion. Scope 2 emissions primarily result from the consumption of purchased electricity.

One of our primary environmental challenges involves addressing fugitive emissions. In response to this critical issue, we have embarked on several investigations across our operations to identify technologies and processes that can reduce fugitive emissions and whether there are parts of Yancoal's business that will still have significant fugitive emissions due to a lack of available technology in the medium to long term.

We are also focused on diesel emissions, another significant contributor to our operational carbon footprint. Supplier engagement also forms part of our approach. Sustainability workshops with key suppliers continue to explore emissions reduction opportunities and emerging technologies. Yancoal also remains a participant in Caterpillar's Pathways to Sustainability program, which provides industry insights on potential future energy transition pathways.

We continue to work towards reducing Scope 1 and Scope 2 absolute emissions across our operations including, where technically and economically feasible, targeting fugitive and diesel consumption based emissions. We are working to map and define our Scope 3 emissions profile.

We continued to invest in rehabilitation, progressive closure planning and engagement with equipment manufacturers to explore potential decarbonisation pathways, including fleet efficiency, electrification and low-carbon fuels. Over time, these initiatives will support cost-effective emissions reduction in line with our regulatory obligations.

During 2025, we advanced fleet decarbonisation planning with Caterpillar, applying optimisation modelling at one of our open-cut operations to quantify and test efficiency improvement options. The four-step technical assessment covered: baseline emissions' analysis; short-term operational optimisation; route and cycle-time calibration; and decarbonisation opportunity simulations. The next phase will run scenario analyses for key enabling infrastructure and models that could support decarbonisation pathways, including implications for equipment selection, maintenance processes and energy consumption.

At Moolarben, work to improve cooling-system performance progressed, with a modified fan hub and updated controller and software installed in 2025, indicating a further reduction of around 2% in fuel-burn. Fuel-calibration optimisation also continued during 2025, following trials in 2024 that achieved an approximate 2% reduction in fuel burn; updated calibration settings were rolled out across both MTW and Moolarben.

A group-wide strategy and Cost-Out Program was implemented with major OEMs to continuously analyse condition-monitoring reports, focused on achieving full lifecycle from critical components and extending component life.

A strategic collaboration with one of our OEM providers continued, including a structured learning and capability-building program designed to equip teams with skills needed to support emerging transition technologies that align with evolving industry demands.

We do not currently have emissions reduction target(s); emissions target(s) will be considered as part of our Sustainability Strategy.