Climate-Related Disclosures FY24
Climate-Related
Disclosures FY24
CONTENTS
Introduction .................................................3
Governance ..................................................7
Strategy ......................................................12
Risk Management........................................19
Metrics and Targets ......................................21
Glossary .....................................................26
Appendix ....................................................27
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Contents
INTRODUCTION
Contents
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
NZKS is a climate-reporting entity under the Financial
Markets Conduct Act 2013. The reporting period covered
by this report is for the 12 months from 1 February 2023
to 31 January 2024 (FY24).
NZKS is proud to produce a healthy, nutritious, and
high-quality protein, and firmly believes that farmed
salmon has a key role to play in sustainable and
resilient food systems. As a primary sector company,
NZKS is fundamentally dependent on the natural
environment. NZKS is well versed in adapting its
business to a changing climate, and is also mindful of
the importance of maintaining a high-level of focus on
this. NZKS’ ability to adapt and look to the risks and
opportunities that climate change may bring is integral
to the future resilience of the business and is something
that Management acknowledges and is focussed on.
Management also acknowledges the business’s own
operations, as with any activity, have an impact on the
environment, and is continually looking at how it can
Introduction
New Zealand King Salmon Investments
Limited (‘NZKS’) is pleased to release its first
Climate-Related Disclosures (‘CRDs’) prepared
in accordance with the requirements of the
Aotearoa New Zealand Climate Standards.
reduce the environmental impact within operational
constraints. NZKS has the intention to grow operations
as Management believes the future world will require
more nutritious, lower carbon protein alternatives. NZKS
understands that with growth comes the potential for
increased emissions but is committed to grow in
a responsible and sustainable way.
NZKS acknowledges that it is only at the beginning of
its sustainability reporting journey but with the business
now steadied and producing positive results, NZKS has
been able to increase its focus on creating a resilient,
sustainable business. A key project delivered as part of
this, was building the base year of carbon emissions for
Scope 1, 2 and 3 emissions. This has been a significant
undertaking from Management. NZKS’ refreshed strategy
is also supporting the business to embrace Environmental,
Social and Governance (ESG) principles and ingrain these
in our corporate culture to guide decision making and
performance assessment.
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
IntroductionContents
Adoption provision 1: Current financial impacts
This adoption provision exempts NZKS from disclosing
the current financial impacts of its physical and transition
impacts identified in NZ CS 1 paragraph 12 (a). The
adoption provision also exempts NZKS from paragraph
12 (c) of NZ CS 1, where NZKS is required to explain why
it is unable to disclose quantitative information.
Adoption provision 2: Anticipated financial impacts
This adoption provision exempts NZKS from disclosing its
anticipated financial impacts of climate-related risks and
opportunities in its first reporting period.
This adoption provision also includes exemption from:
a. Paragraph 15 (c) of NZ CS 1, where NZKS is required to
disclose a description of the time horizons over which
the anticipated financial impacts of climate-related
risks and opportunities could reasonably occur.
b. Paragraph 15 (d) of NZ CS 1, where NZKS is required
to explain why it is unable to disclose quantitative
information for paragraph 15 (b) of NZ CS 1.
Adoption provision 3: Transition planning
This adoption provision exempts NZKS from disclosing
the following in its first reporting period:
a. The transition plan aspects of its strategy, including
how its business model and strategy might change to
address its climate-related risks and opportunities; and
b. The extent to which transition plan aspects of
its strategy are aligned with its internal capital
deployment and funding decision-making processes.
Adoption provision 5: Comparatives for
Scope 3 GHG emissions
This adoption provision exempts NZKS from disclosing the
comparative information for Scope 3 GHG emissions.
Adoption provision 6: Comparatives
for metrics
This adoption provision exempts NZKS from disclosing
comparative information for metrics disclosed in NZKS’
first reporting period.
Adoption provision 7: Analysis of trends
This adoption provision exempts NZKS from disclosing
an analysis of the main trends evident from a comparison
of each metric from previous reporting periods to the
current reporting period (NZ CS 3 paragraph 42).
Statement of Compliance
These climate-related disclosures comply with the Aotearoa New Zealand
Climate Standards issued by the External Reporting Board. In preparing
NZKS’ climate-related disclosures, the Board and Management have elected
to use the following Adoption Provisions:
Disclaimer:
NZKS has used reasonable efforts in the preparation
of this CRD to provide accurate information, but
cautions reliance being placed on representations that
are necessarily subject to significant risks, uncertainties
or assumptions. This report contains forward looking
statements, including climate-related metrics, climate
scenarios, targets, assumptions, estimated climate
projections, forecasts, statements of NZKS’ future
intentions, estimates and judgements that may not
evolve as predicted. These statements necessarily
involve assumptions, forecasts and projections about
NZKS’ present and future strategies and NZKS’ future
operating environment.
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
IntroductionContents
Such statements are inherently uncertain and subject
to limitations, particularly as inputs, available data
and information are likely to change. NZKS has used its
best efforts to provide a reasonable basis for forward-
looking statements and is committed to progressing our
response to climate-related risks and opportunities over
time but is constrained by the novel and developing
nature of this subject matter. Climate-related risk
management is an emerging area, and often uses data
and methodologies that are developing and uncertain.
Climate-related forward-looking statements may
therefore be less reliable than other statements NZKS
may make in its annual reporting.
We have based these statements on our current
knowledge as at 28 May 2024. There are many factors
that could cause NZKS’ actual results, performance
or achievement of climate-related metrics (including
targets) to differ materially from that described,
including economic and technological viability, as well
as climatic, government, consumer, and market factors
outside of NZKS’ control. Nothing in this report should
be interpreted as capital growth, earnings or any other
legal, financial tax or other advice or guidance.
Paul Munro
Audit, Finance & Risk
Committee Chair
28 May 2024
Mark Dewdney
Chair
28 May 2024
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
IntroductionContents
GOVERNANCE
Contents
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Board oversight of climate-related
risks and opportunities
The Fish Farming Committee, established in 2022, also
supports the Board in its oversight of climate-related
risks and opportunities by the identification of the risk
and opportunities specific to the fish farming operations
and focussing on the ongoing improvement in fish health
and farming strategies. Climate is a risk well considered
by this Committee. For example it reports on the water
temperature of sea farms, the thermotolerance project
and summer progress of NZKS sea farms, including
frequent updates on fish welfare over the higher risk
months to the Board.
To help the Board and Management in making informed
climate-related risk and opportunity decisions, NZKS will
seek external specialist advice when required. External
independent advisers have provided support with the
greenhouse gas (‘GHG’) emission inventory work, and for
the purposes of informing short, medium and long-term
scenario planning around the physical and transition risks
and opportunities of climate change on NZKS operations.
A number of the Board Directors are also members
of Chapter Zero New Zealand, which is hosted by the
Institute of Directors New Zealand.
Governance
The NZKS Board of Directors (the ‘Board’)
maintains direct responsibility and oversight of
climate-related risks and opportunities for NZKS,
including those related to climate change.
The Board is presented at each board meeting with
Management reports on climate-related matters to
ensure the Board remains informed and has oversight
over the management of climate-related risks
and opportunities.
To manage climate-related matters, the Board delegates
part of its responsibilities to the Audit, Finance & Risk
Committee (‘AFRC’) where the committee assumes the
key responsibility for overseeing the CRDs and reports
through to the Board. The AFRC currently also supports
the Board by performing reviews of NZKS’ primary
business risks and its risk management policy. The AFRC
meets on a quarterly basis at a minimum and will hold
additional meetings when required. In the first year of
CRD adoption the Board has maintained a high level of
involvement in this space and has been involved in full
oversight of the implementation of the CRDs.
During FY24 the Board participated and received
updates on various climate-related matters during
board meetings, specifically:
— CRD presentation and update from external
consultants
— A review of the emissions footprint
— Management-led climate risk and opportunity
workshops including how these risks and Management
responses may change over varying scenarios
— Climate-related disclosure readiness analysis
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
GovernanceContents
Risk Management
Framework:
Annual reviews are
conducted of the NZKS
Risk Management
Framework to ensure
alignment with the
evolving climate-
related considerations.
Strategy:
The Board was involved in the
establishment of the refreshed
company strategy where
building a sustainable future
is a key pillar. This pillar has
informed the sustainability
strategy that was developed
in FY24. This strategy covers
the broader ESG space but
also supports the sustainability
workplan which has a
focus on key sustainability
projects, including carbon
reduction workplans.
Managing climate-related
risks and opportunities for
the Company:
Ensuring the key climate risks in
the risk matrix reviews are held and
reported to the Audit, Finance &
Risk Committee. This also includes
overseeing the setting of the
metrics and targets in relation to
NZKS’ emissions inventory. FY24’s
focus was on building the base
year for Scope 1, 2 and 3 emissions
so no metrics and targets were
identified for this reporting period.
The intention is for targets to be
established in the financial year
ending 31 January 2025 (FY25) to
manage material climate-related
risks and opportunities and that
these targets are monitored and
reported on, including performance
against targets. External assurance
of NZKS’ emissions will be engaged
for FY25.
Policy:
Annual reviews are
conducted of relevant
policies such as the
Remuneration Policy.
Management also
intend to create a
sustainability policy in
FY25 that supports the
sustainability strategy.
The Board uses the following mechanisms to provide oversight
of Management in relation to the climate-related risks and
opportunities; including setting objectives for climate-related issues.
As NZKS develops its emissions inventory base year these will
also be the tools used to set climate-related targets.
Remuneration:
Sustainability remuneration
metrics for the Senior
Leadership Short Term
Incentive (STI) scheme have
been considered by the
People and Performance
Committee. For FY24, as
the sustainability space is
maturing, no remuneration
has been aligned specifically
to sustainability metrics.
The intention is to evolve
the STI scheme to include
sustainability once metrics
and targets have been
clearly defined and these are
currently under development
by NZKS Management.
9
Governance
Contents
New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Management’s role in assessing and managing
climate-related risks and opportunities
The Board assigns climate-related responsibilities to
the NZKS Executive. This is via mechanisms such as a
standing agenda item at board meetings on progress as
well as the policies outlined above.
The Executive; being the Chief Executive Officer and the
Chief Financial Officer and relevant General Managers,
have been delegated by the Board the responsibility for
the sustainability strategy and the oversight of climate-
related risks and opportunities in the business. The
Executive, with the support of the sustainability team,
is tasked with overseeing the implementation of the
strategy across the business as well as regular reviews
of the business’ climate-related risks and opportunities.
The sustainability team consists of the Head of
Finance & Sustainability, Sustainability Manager and
Sustainability Finance Manager. The core sustainability
team meets on a frequent, ad-hoc basis to discuss the
sustainability work programme. This team also meets
twice a year with the Chief Financial Officer and the
General Manager who oversee the risk register to review
and amend climate-related risks and opportunities if
required. This team reports through to the Board on any
key sustainability developments and any newly identified
risks, assisting the Board in fulfilling its responsibilities
related to identifying, assessing, monitoring, and
managing climate risk. The sustainability team
provides updates to the Board and AFRC at every
board meeting as a standing agenda item, involving
various levels of Management in the process (refer
to Goverance structure overleaf).
The sustainability team also heads up the internal
Sustainability Committee. This committee is made
up of the Chief Executive Officer, Chief Financial
Officer, relevant General Managers and other key
team members across the business, who will join
when required, for project discussions, such as NZKS’
Research & Development Manager and head of New
Product Development. The Committee meets every
six weeks and is responsible for assessing internal
sustainability projects, such as waste minimisation
and packaging changes. As the metrics and targets
set by the sustainability strategy are defined this will
be the key committee that these are reported through
to as well as progress on NZKS’ carbon footprint.
An outline of the organisation structure and the
frequency of updates and monitoring on key climate-
related responsibilities is provided in the Goverance
structure overleaf.
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
GovernanceContents
Governance structure for climate-related responsibilities
NZKS Board
(meets ~ 10 times annually)
• Approves NZKS strategy including supporting
strategies e.g Sustainability Strategy
• Ensures Board skills, size and composition are fit
for purpose
• Reviews and supports management processes
in relation to the risks and opportunities of the
business including climate risks
Fish Farming Committee
(meets as required)
• Responsible for the identification of the risks and opportunities
specific to the fish farming operations and review of the
management of these risks
• Focussed on the ongoing improvement in fish health and farming
strategies
Audit, Finance
& Risk Committee
(meets at a minimum quarterly)
• Ensures risks are managed
in accordance with NZKS risk
management framework. This
includes key climate risks being
brought to the committee
for detailed review annually
• Oversees NZKS’ reporting
requirements including
climate-related disclosures
as well as the broader
ESG work program
Sustainability Committee
(meets every six weeks)
• Responsible for overseeing and reporting on
sustainability projects and initiatives across
the business
People & Performance Committee
(meets quarterly)
• Responsible for making recommendations to the Board as to its
size and composition to ensure that the Company has access to
the most appropriate balance of skills, qualifications, experience,
and background to effectively govern the Company
• Responsible for making recommendations with respect to
executive incentive remuneration plans having regard to financial
and non-financial goals and how these align with Company
strategy and performance objectives
Executive Team
Includes Chief Executive Officer, Chief Financial Officer
and relevant General Mangers (reports to
all Board meetings and AFRC meetings)
• Responsible for implementation of strategy across
the business and oversight of the climate risks
and opportunities
Core Sustainability Team
Includes Head of Finance & Sustainability,
Sustainability Manager, Sustainability Finance
Manager
• Responsible for preparation of carbon inventory
and preparation of climate-related disclosures
• Responsible for supporting the Executive in
driving the sustainability strategy in the business
and reporting through to Executive and Board on
sustainability projects
• Supporting the Executive with the identification
and review of NZKS’ climate-related risks and
opportunities
Key Management Roles reporting to
Executive Management
Board Oversight
Management
Main Climate Reporting
Committee
Supporting Committees
• Supports the development and implementation of climate
related metrics and targets to enable the Board to effectively
review and monitor the progress of the Company in future years
• Reviews remuneration policies and short term incentive schemes
of Senior Leadership
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
GovernanceContents
STRATEGY
Contents
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Strategy
In May 2023, NZKS enlisted the assistance of a
sustainability advisory firm and conducted a
comprehensive climate-related risk assessment,
including scenario analysis.
The assessment involved collaborative workshops
with internal stakeholders; including the Acting Chief
Executive Officer, Chief Financial Officer, General
Manager Aquaculture, General Manager Processing
and other relevant roles. Outcomes from the workshop
included establishing the scope and boundaries of the
risk assessment. This included determining value chain
inclusions, time horizons, frequency of assessment,
and identifying key risk areas.
The physical and transition risks and opportunities for
NZKS were identified in an initial workshop and ranked
using the NZKS risk matrix to identify the risks that
were of a priority nature i.e., the risks that may have
a significant impact on NZKS’ operations. A further
scenario analysis workshop worked through the risks
and opportunities over the varying time spans as well
as a baseline scenario and the two Aotearoa Circle
Marine scenarios. The purpose of this assessment was
to ensure a comprehensive understanding of the potential
climate risks and opportunities affecting NZKS and how
NZKS may react to the varying scenarios. The findings
from the assessment were incorporated into the overall risk
management framework.
NZKS determined that the two scenarios used in NZKS’
climate-related risk assessment (based on the Aotearoa
Circle Marine Sector scenarios) and the Disorderly scenario
from the Network for Greening the Financial System
were the most appropriate to use. This will enable some
level of comparability to other aquaculture businesses
as these scenarios are what other aquaculture business’
have utilised when assessing their climate risks and
opportunities. For the purposes of the broader scenario
analysis the scenario time horizons used are:
Scenario Time Horizons
Short-termToday to 2030
Medium-term2031 to 2050
Long-term2051 to 2100
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
StrategyContents
ScenarioKahawai 2050 “Orderly Transition”Disorderly "Delayed Transition"Mako 2050 “Intense and Severe Outcomes”
DescriptionKahawai, a relatively abundant coastal finfish which
transition through several stages of life development,
collaborating to avoid danger, and well known to fight
hard when caught. This scenario describes a 2050 world
that has succeeded in implementing the Paris Agreement
(net zero by 2050).
Delayed transition assumes annual emissions do not
decrease until 2030. Strong policies are needed to limit
warming to below 2°C. Negative emissions are limited.
Mako are a fast, aggressive, and unpredictable shortfin shark
species. This scenario describes a 2050 world where change
moves rapidly through the marine domain, a failure to curb
emissions means that humanity and nature are facing the
consequences of significant climate disruption.
Policy Ambition1.5ºC (<2ºC)2ºC>3ºC
RCP/SSP Combination
Used
RCP 2.6
SSP1
RCP 2.6
SSP2
RCP 8.5
SSP3
Physical Risk SeverityLow — ModerateModerateExtreme
Policy ReactionImmediate and smoothDelayed — strong policies once implementedLagging, minimal change from current policy
Technology ChangeFast ChangesSlow/ Fast ChangeSlow Changes
Global Population8.5b8.26b11b
Marine Bio-Physical
Impacts (to 2050)
+0.8ºC coastal sea surface temperature+0.8ºC coastal sea surface temperature+1.5ºC coastal sea surface temperature
+0.23 m sea level rise+0.23 m sea level rise+0.28 m sea level rise
8.0 pH ocean acidification8.0 pH ocean acidification7.94 pH ocean acidification
1% decline in dissolved oxygen1% decline in dissolved oxygen2% decline in dissolved oxygen
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
StrategyContents
NZKS’ assessment of climate-related scenarios was
used to inform considerations of physical and transition
climate risks and opportunities, which may increase
in impact and uncertainty over longer time horizons.
Using the above context from the climate-related
scenarios, NZKS has assessed its climate-related risks and
opportunities across three key time horizons that have the
most significant actual or potential financial impact on
business operations and are in line with the current risk
management framework.
Climate-related risks and opportunities
Time Horizons
Short-term1 — 3 years
Medium-term4 — 10 years
Long-term>10 years
The climate risk assessment included locations and
operations that are deemed important and material
to NZKS, including hatcheries in Takaka and Tentburn,
sea farms in Tory Channel, Queen Charlotte Sound, and
Pelorus Sound, as well as the Nelson-based processing
site. A comprehensive examination of the value chain from
hatchery to distribution was carried out, to determine
the potential impact of climate-induced physical and
transitional changes. This was mainly limited to New
Zealand and focused on logistics operations under NZKS’
control. Transitional risks involved considering the broader
supply chain in the context of export markets, consumer
preferences and government policies as exports form a
significant part of the NZKS business.
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New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
StrategyContents
Risk/ OpportunityCurrent and Anticipated Impact DescriptionManagement Response
Time
Horizon
Current Impact: Anticipated Impact:
Marine heatwaves
cause more persistent
high summer
sea temperatures
(Physical Risk)
NZKS currently have
fallowed three sea
farm sites.
Regardless of scenario, warming waters are expected.
Expectation on increased capital expenditure for
additional water space requirements and research
& development expenditure on thermotolerance.
Management is investing in thermotolerance work, which is a long-term
breeding project to increase resilience of salmon in warmer water temperatures.
Management is allocating significant capital to the Blue Endeavour open
ocean site to provide additional water space for NZKS to farm in the medium/
long-term.
All time
horizons
More frequent and
longer dry spells and
drought
(Physical Risk)
NilThere is an increased risk of drought and therefore
water restrictions at multiple sites.
Management has commenced work to have a hydrology mapping exercise
performed on the two freshwater sites to better understand the risks of drought.
This will enable better planning and use of capital to mitigate risks in the
medium /long-term.
Management has considered improvements around water recirculation and
is actively monitoring the situation in the short term. In the medium to long
term, Management intends to implement a water recirculation programme for
freshwater sites and investigate how this could be implemented into a potential
future greenfield processing site.
Medium/
Long-term
Coastal and estuarine
flooding: increasing
persistence, frequency
and magnitude
(Physical Risk)
In FY24 NZKS directed
capital expenditure to
the culvert infrastructure
at the Tentburn site due
to increased frequency
and magnitude of tidal
impacts on the culvert.
There is expected to be an increase of flooding
at freshwater sites, which may cause damage
to infrastructure.
Management have commenced work to have a hydrology mapping exercise
performed on the two freshwater sites to better understand the risks of floods.
This will enable better planning and use of capital to mitigate risks in the
medium /long-term.
Management has mitigated short-term flooding risk via capital expenditure on
the culvert at Tentburn. Management is also investigating other capital spend
options as part of resilience planning.
Medium/
Long-term
The material climate-related risks and opportunities
identified and agreed by NZKS Board and Management
are outlined below. NZKS has determined risks that are
identified as priority 1 or 2 (on a scale of 1-4) are material.
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
StrategyContents
Risk/ OpportunityCurrent and Anticipated Impact DescriptionManagement Response
Time
Horizon
Current Impact: Anticipated Impact:
Regulatory and legal
(Transition Risk/
Transition Opportunity)
Consent renewals Yet to be determined future regulatory requirements
around resource consents including monitoring and
reporting obligations.
Alternatively, the regulatory environment could be an
opportunity, as salmon is a low carbon protein, which
may be seen as an industry for the government /councils
to support via more flexible resource consent conditions.
NZKS is actively involved in regional processes led by industry groups including
being a part of active discussions on the Marlborough Environment Plan. NZKS is
also actively focussing on engaging with wider stakeholders of the business such
as iwi, NGOs, central and local government.
The regulatory and legal environment is being actively monitored by NZKS.
Current management focus is on the short-medium term, as with any
transition risk, it is an evolving space and can be difficult to predict outcomes
so management processes need to be able to be flexible to work within new
frameworks quickly.
Medium/
Long-term
Financial
(Transition Risk)
NilPotential increased costs to the business; such as
freight costs, introduction of carbon taxes /regulations,
insurances and reporting obligations. Increase in the need
for capital expenditure for business resilience to mitigate
the effect of climate change.
Management is investigating options for the potential future need to move air
freight to sea freight to reduce carbon emissions.
Management proactively manages NZKS’ risk-based insurance programme.
Management understands that capital expenditure is likely to be required to
support the business in adapting to a lower emission business so this is already
being considered in future capital planning.
Medium/
Long-term
Increased storm and
extreme wind events
(Physical Risk)
Nil in FY24 but noting in
FY23 that a key transport
route to get harvest
to processing was taken
out following a storm
for a few weeks and a
longer, alternative route
was required.
As storms become more frequent and severe there is a
potential risk that sea farm assets, roading networks and
potentially other key infrastructure may be affected and
adversely impact on the NZKS supply chain from harvest
to distribution.
NZKS has alternate routes to get harvest from seawater sites and domestic/
export logistics has experience in moving goods when routes are closed.
All time
horizons
New and emerging
technology
(Transition Risk/
Opportunity)
NilNZKS expect improvements in technology will provide
the opportunity to become more efficient and therefore
reduce carbon intensity measures. NZKS will continue to
assess the risks and opportunities of adopting emerging
technology as part of future capital investment decisions.
Management is exploring potential projects, such as a greenfield processing
site, to assess lower emission and more efficient technologies.
Medium/
Long-term
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
StrategyContents
Risk/ OpportunityCurrent and Anticipated Impact DescriptionManagement Response
Time
Horizon
Current Impact: Anticipated Impact:
Market access/
consumer demands
(Transition Risk/
Opportunity)
NilThere is potential risk around increased regulation on
packaging, entry requirements and tariffs to gain access
to export markets.
Alternatively this could be an opportunity as salmon is a
low carbon protein this may be seen as a preferred import
product. Consumer preference may also move to a lower
carbon protein choice.
This is currently a watching brief for NZKS. Management is utilising resources
such as NZTE to stay on top of changing regulatory environments overseas.
Medium/
Long-term
Reputational
(Transition Risk/
Opportunity)
NilAn increased focus on the climate space has the ability
to be both a risk and opportunity for NZKS depending
on how stakeholders interpret climate-related disclosures
and other ESG actions.
NZKS has prepared this report which sets out its initial CRDs.
NZKS continues to achieve third-party certifications such as the Best
Aquaculture Practices (BAP) certification to support our reputation as a
company with responsible operational practices.
Management is also committed to better understanding potential carbon
reduction targets, and is being supported by a third-party emissions
reduction adviser.
All time
horizons
This climate-related risk and opportunity assessment and
scenario analysis discussed above has been integrated
into the broader business planning and capital allocation
decisions, to ensure that NZKS is taking proactive steps
towards transitioning to a lower carbon future and
mitigating potential risks to the business.
As noted in the Governance section, the refreshed strategy
has supported an increased focus on sustainability and
risk management, in which the climate-related risks and
opportunities are considered. This has led to an increased
focus on sustainability outcomes and/or emission
reductions in business cases for capital expenditure that
are presented to the Board for approval. As part of future
capital allocation decisions, ESG is also considered as
an input into a projects hurdle rate (i.e with all other
variables being held consistent the better the ESG outcome
would generate a lower hurdle rate — therefore improving
the prioritisation of the project). It has also created an
increased focus on ensuring the business is resilient to
climate and broader ESG risks, as well as understanding the
potential opportunities for NZKS. Examples of this include
commissioning of hydrology assessments of freshwater
sites, a project initiated to understand emission
reductions across the business, understanding how
technology can better assist in maximising fish feeding
efficiency, and monitoring the changing export landscape
via means such as engaging with NZTE. NZKS intends
to establish a more formalised plan to show how the
business will transition towards a low-emission, climate
resilient future state in FY25 but Management believes
some positive first steps have been taken in building this
into the current business model and strategy.
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
StrategyContents
RISK
MANAGEMENT
Contents
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New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Risk Management
NZKS employs a structured risk management
approach that utilises a 5x5 matrix of
consequence severity and likelihood.
The risk management framework enables the Board and
Management to assess various business and climate-related risks
potentially impacting our operations, environment and communities.
This allows the business to take appropriate steps to mitigate and
manage these risks effectively.
NZKS utilises the risk assessment framework to rate and compare
climate-related risks against other business risks. There is a bi-
annual review of sustainability risks within the NZKS risk framework
by the sustainability team and the risk leaders. There is also an
annual workshop with the Chief Executive Officer, Chief Financial
Officer, relevant senior leaders, and the sustainability team to
reassess and update the climate-related risks and opportunities to
ensure the full defined value chain is considered. This also supports
NZKS’ continued commitment to sustainability, transparency, and
responsible business practices.
The risk rating system used for wider business risks is also employed
for climate-related risks, taking into account the likelihood and
severity of their associated consequences. The risks are prioritised
based on their severity, and categorised into priorities 1-4. Those
rated as priority 1 require immediate action, where possible, to
proactively manage risk and limit exposure. The climate-related
risks that have been rated priority 1 or 2 from the climate-risk
workshops have been condensed and included in the Company’s
overall enterprise risk register. This ensures climate-related risks
are considered in the same way as other business risks.
Communication
and Feedback
Monitoring and
Risk Review
Scope and Boundaries Established
Risk Identification
Risk Assessment
Risk Management
Risk Management Process
20
Risk Management
Contents
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
METRICS
AND TARGETS
Contents
21
New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Metrics and Targets
NZKS recognises the significance of monitoring
and mitigating GHG emissions. Historically, Life
Cycle Assessments (LCA) undertaken on New
Zealand farmed King salmon have been utilised
by NZKS to support the understanding of the
Company’s carbon footprint in relation to the
farming of salmon.
NZKS notes that there are limitations to utilising
industry wide LCAs as they do not give as much detail
as company specific carbon emission reporting. As part
of the adoption of the Aotearoa New Zealand Climate
Standards, NZKS has now undertaken a comprehensive
assessment and reporting exercise of its GHG emissions
in accordance with the Greenhouse Gas Protocol to form
the carbon emission base year for FY24. NZKS engaged
EY to perform certain agreed upon procedures on the
emissions data collation process to ensure that sufficient
processes were in place before the required assurance
of emissions data in FY25.
22
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
Metrics and TargetsContents
— Department for Environment Food & Rural
Affairs (DEFRA) 2022 ‘Greenhouse gas reporting:
conversion factors’ (UK)
— DEFRA 2021 ‘Greenhouse gas reporting: conversion
factors’ (UK), for items not included in their
2022 report.
— Enviromental Product Declaration (EPD) information
for similar items to products purchased
— Motu factors
— Feed suppliers
The emission factor sources are based on global warming
potentials (GWPs) varying from AR4-AR6.
NZKS boundary
NZKS applies the financial control approach when
calculating emissions. This is based on the same approach
taken when consolidating New Zealand King Salmon
Investments Limited for financial statement purposes.
Organisational boundaries were applied with reference
to the methodology described by the GHG Protocol.
To ensure a complete and accurate assessment of
all relevant operations, all of the investments of New
Zealand King Salmon Investments Limited have been
included in the financial control scope of the emissions
inventory. Emissions are identified across the entire
NZKS operation being at hatcheries, sea farms,
processing operations, distribution and office areas.
Emissions sources excluded
Specific emission sources have been identified and
excluded from the NZKS GHG emissions calculation in
FY24. These sources are either not applicable to NZKS
operations or are relevant but are either not material
in the context of the GHG inventory (greater than
5% of overall emissions), material to stakeholders,
and/or not technically feasible or cost effective to be
quantified at present.
— Category 7: Employee commuting. Information is
not tracked; estimated impact is immaterial.
— Category 10: Processing of sold products. Not
applicable.
— Category 11: Consumer use of product. No specific
data available, estimated impact is immaterial.
— Category 13: Downstream leased assets. No specific
data available, estimated impact is immaterial.
— Category 14: Franchises. Not applicable.
— Category 15: Investments. Not applicable.
NZKS emissions profile
NZKS’ first detailed carbon emissions reporting
has been completed for the full FY24 financial
reporting period and forms the base year of
data. Accordingly, there are no comparatives
available.
NZKS measures its GHG emissions in accordance with
the requirements of the ‘Greenhouse Gas Protocol –
A Corporate Accounting and Reporting Standard’. NZKS
reports its GHG emissions in tonnes of CO2 equivalents
(tCO
2
e), in compliance with the requirements set by
the GHG Protocol.
There has also been guidance from the following
sources:
— Greenhouse Gas Protocol – Corporate Value Chain
(Scope 3) Accounting and Reporting Standard
— Greenhouse Gas Protocol – Technical Guidance for
Calculating Scope 3 Emissions (version 1.0)
Emission factors utilised in FY24 have been from the
following sources:
— Ministry for the Environment (MfE) 2023 ‘Measuring
Emissions: A guide for organisations’ (NZ)
— Department of Climate Change, Energy, the
Environment and Water 2022 ‘Australian National
Greenhouse Accounts Factors’ (Australia)
23
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
Metrics and TargetsContents
Scope 1 and 2 emissions make up a small portion
of the NZKS footprint, with fuel being the largest
emission source in this area.
The use of fuel is predominantly from sea farm
operations. The main Scope 3 emission sources
include upstream freight and purchased goods and
services. The most material driver of the upstream
freight emissions is derived from getting product
to various export markets, and the majority of
purchased goods and services emissions is from
salmon feed.
NZKS, as an exporter of a low carbon protein
1
has
harvest growth initiatives in the medium term with
projects such as open ocean salmon farming being
commenced. The expectation is that NZKS’ absolute
emissions will increase as harvest volumes increase.
Therefore, to allow for a more comparable year
on year metric, NZKS has used an intensity metric
of tonne CO
2
e per tonne G&G salmon harvested/live
weight salmon harvested.
This has been done over Scope 1,2 & 3 as well as
Scope 1 & 2 only. The intensity metric over tonne
of live weight is a metric utilised by others in the
aquaculture industry.
Metrics and Targets
NZKS’ total GHG emissions in FY24 were
78,976 tCO
2
e with measured Scope 3 emissions
making up ~95% of all emissions. The table
shows NZKS’ emissions by scope and as a
percentage of total Group emissions.
ScopeFY24 total emissions tCO
2
e
Scope 13,6194.6%
Scope 25150.6%
Scope 374,84294.8%
Total emissions78,976100%
Intensity indicatorsLiveweight G&G*
Scope 1,2 & 3
Emissions per tonne
(tCO
2
e/tonne)
11.1512.67
Scope 1 & 2
Emissions per tonne
(tCO
2
e/tonne)
0.580.66
*G&G (gilled and gutted salmon)
FY24 GHG emissions
1 New Zealand farmed salmon sold domestically has a lower carbon footprint
compared to the global average for other animal proteins. LCA Report –
King salmon from New Zealand. Wellington: thinkstep-anz (2023).
NZKS is committed to sustainability practices and is
working towards setting emission reductions targets
in FY25. A base year has been established and the
understanding of the NZKS emissions profile continues
to improve. In lieu of having a base year of carbon
emission data, NZKS has focussed its sustainability
efforts on areas in which the business has some
control and can be linked to a reduction in emissions.
In FY24 key emission reduction projects have focussed
on reducing waste streams. An ensilage facility has
commissioned and is anticipated to be fully operational
in FY25. This will remove organic waste from landfill
and in turn reduce NZKS’ waste to landfill carbon
emissions. There have also been other reduction projects
that support NZKS’ focus on carbon reduction and
sustainability. This includes the trialling of hand dryers
in non-food safety locations, replacing paper towels,
and in the processing site the replacement of light bulbs
with LED light bulbs. In addition, there has been a focus
on electricity reduction behaviours, such as turning
lights off on weekends and switching off containers
when not in use.
The specific electricity focus at the processing site level
has reduced electricity usage by ~180,000 kWh in the
12 months to March 2024 (compared to an original
baseline period of October 2021 to January 2022)2.
2 Based on data from a project undertaken in conjunction with Emsol Limited
24
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
Metrics and TargetsContents
With the FY24 base year of data and full emissions
profile now available, emissions targets will be
developed in FY25. Waiting for the base year to be
established ensures that the metrics and targets are
both achievable and meaningful to the company.
During FY25 there will also be work around
determining and subsequently disclosing on
the following:
— Metrics relating to the amount or percentage of
assets or business activities vulnerable to climate-
related physical or transition risks
— Metrics relating to the amount or percentage of
assets or business activities aligned with climate-
related opportunities
— How capital has been deployed in the business
relating to climate-related risks and opportunities.
NZKS notes that there has been specific capital
expenditure relating to climate-related risks and
opportunities across the business in FY24. This
includes investment in culvert improvements at the
Tentburn site, the ensilage plant and the transition
from diesel to electricity at Takaka as part of a
power upgrade on header tanks.
NZKS currently does not have an internal carbon
emission price. As NZKS matures in this space this is
something that may be considered in the future.
As discussed in the Governance section, NZKS is not
yet in the position to link remuneration through to
sustainability metrics and targets in a meaningful way.
No assurance has been provided over GHG emissions in
FY24. Agreed upon procedures were performed in FY24
to assess the methodologies and assumptions in NZKS’
carbon inventory collation processes. This provides
NZKS Board & Management comfort that the same
methodology can be used for FY25 when assurance
is required for GHG emissions. In the event that the
assurance process in FY25 identifies any inconsistency
with the FY24 base line data, NZKS will restate the
baseline data in its FY25 CRD reporting.
25
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
Metrics and TargetsContents
Glossary
AFRC
Audit, Finance & Risk Committee
AR4
Fourth Assessment Report from the IPCC
AR6
Sixth Assessment Report from the IPCC
BAP
Best Aquaculture Practices
CRD
Climate-Related Disclosures
ESG
Environmental, Social and Governance
EPD
Environmental Product Declaration
G&G
Gilled and gutted salmon
GHG
Greenhouse gas
GWP
Global warming potential
IPCC
Intergovernmental Panel on Climate Change
Liveweight
Weight of harvested fish before gilling and
gutting, in tonnes.
NGOs
Non-governmental organisations
NZ CS 1
Aotearoa New Zealand Climate Standard 1
Climate-related Disclosures
NZ CS 2
Aotearoa New Zealand Climate Standard 1
Climate-related Disclosures
NZ C S3
Aotearoa New Zealand Climate Standard 1
Climate-related Disclosures
NZKS
New Zealand King Salmon Investments Limited
NZTE
New Zealand Trade and Enterprise
RCP
Representative Concentration Pathway
SSP
Shared Socio-economic Pathways
STI
Senior Leadership Short Term Incentive
tCO
2
e
tonnes of CO2 equivalents
WTT
Well-to-tank
26
New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24
Metrics and TargetsContents
ScopeCategory
GHG emissions
source
Data sourceCalculation methodology, assumptions, uncertainty (qualitative)Source of emission factors
Scope 1Stationary / mobile
combustion
Fossil fuels used
across business
Supplier dataFuel-based method. Low uncertainty.MfE (2023)
Fugitive emissionsRefrigerant used
in refrigeration
systems
Maintenance recordsTop-up method.
Considers top-ups on equipment on NZKS sites. Low uncertainty.
MfE (2023)
Scope 2ElectricityElectricity
consumption
Supplier dataLocation-based method. Low uncertainty.MfE (2023)
Scope 3Category 1: Purchased
goods and services
FeedEmission factors provided by supplier.
General ledger used for quantities.
Supplier-specific method. Low uncertainty.Feed suppliers
PackagingGeneral ledgerAverage-data method. Weights and composition purchased based
on general ledger reports. Low uncertainty.
DEFRA (2023)
Consumables, raw
materials and other
spend
General ledgerSpend-based method. Uncertainty as emission factors are applied
to a broad category of spend and not based on specific activity
data or supplier specific emission factors.
Motu (2007), with annual
inflation applied
Purchased
finished goods
and third party
manufacturing
General ledgerAverage-data method. General ledger reports provide the weight
of goods purchased and manufactured. Some uncertainty due to
generic nature of emission factors, due to availability of relevant
emission factors.
Similar products’ EPD
and DEFRA (2023) for
third party manufacturing
WaterGeneral ledger – supplier invoicesAverage-data method. Low uncertainty.MfE (2023)
Category 2:
Capital goods
Purchase or
construction of
capital items
General ledgerSpend-based method, emissions recognised when asset capitalised
in general ledger. Uncertainty as emission factors are applied to a
broad category of spend and not based on specific activity data or
supplier specific emission factors.
Motu (2007), with annual
inflation applied
Appendix: GHG methodologies, assumptions and estimation uncertainties
27
New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Metrics and TargetsContents
ScopeCategory
GHG emissions
source
Data sourceCalculation methodology, assumptions, uncertainty (qualitativeSource of emission factors
Scope 3
(continued)
Category 3:
Fuel-and energy-related
activities not included
in Scope 1 or Scope 2
Transmission and
distribution losses
(T&D)
Supplier dataAverage-data method. Emissions from T&D losses estimated based
on kilowatt hour (kWh) data used in scope 2. Some uncertainty
due to availability of specific T&D data.
MfE (2023)
WTTSupplier dataAverage-data method. Low uncertainty.DEFRA (2022)
Category 4: Upstream
transport and
distribution
Transport of items
between locations
and to consumer
Supplier dataFuel-based method and distance-based method (dependent on
supplier). Uncertainty exists due to the requirement to make small
average based assumptions during the point of calculation to
account for data gaps in distance travelled and weight delivered
as and when needed.
MfE (2023), DEFRA (2022)
Freight on feedSupplier dataSupplier-specific method. Suppliers provide freight emission factor
which is overlaid onto quantities purchased from general ledger.
Low uncertainty.
Supplier provided
emission factor
Freight on
packaging
General ledger data with
distance assumptions
Distance-based method. Uncertainty exists due to the requirement
to make small average based assumptions during the point of
calculation to account for data gaps in distance travelled as and
when needed.
DEFRA (2022), MfE (2023)
Freight on all other
goods purchased
excluding feed and
packaging
General ledgerSpend-based method for freight paid on purchased goods.
Uncertainty as emission factors are applied to a broad category
of spend and not based on specific activity data or supplier specific
emission factors.
Motu (2007), with annual
inflation applied
Category 5: Waste
generated in operations
Waste across
operations
Supplier data and internal reportsDependent on waste stream either an average-data method or
waste-type-specific method was employed.
Uncertainty exists for trade waste and sump clearing GHG
emissions due to assumptions required on density of fish waste
and emission factor availability for wastewater.
MfE (2023)
28
New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Metrics and TargetsContents
ScopeCategory
GHG emissions
source
Data sourceCalculation methodology, assumptions, uncertainty (qualitativeSource of emission factors
Scope 3
(continued)
Category 6:
Business travel
Air travel, car
rentals and
hotels and
accommodation
Supplier dataDistance-based method used for air travel and car rentals.
Nights-stayed method was used for hotels and accommodations.
For rental cars that did not have distance measured, it was
assumed that for each day of hire 50 km was travelled.
Assumptions also made on vehicle age and size.
Air travel distance provided by travel provider, with emissions
calculated on an economy class ticket. Travel classified by
domestic, short-haul and long-haul.
Room nights were provided by travel provider. If a specific country
emission factor was not available for a room night, a similar
locations factor was used.
MfE (2023)
Category 8: Upstream
leased assets
Fuel & electricity
used in leased
assets
N/ADue to ability to split data these emissions have been captured
in Scope 1 and Scope 2.
Category 9:
Downstream
transportation
and distribution
AssumptionsDistance-based method. A distance of five kilometres was assumed
for the transportation from the retailer to the end-customer.
Small average based assumptions made within the calculation to
account for data gaps in weight delivered as and when needed.
DEFRA (2022), MfE (2023)
Category: 12 End
of life treatment
of sold products
Life Cycle Assessment (LCA) of farmed
King salmon from New Zealand (thinkstep
anz – 2023), internal sales data
Average-data method. LCA (2023) waste habits used as an
assumption for consumer waste for whole fish. All other products
have a different assumed waste percentage. Uncertainty given
lack of quality data on consumer waste habits and emission factor
data availability.
MfE (2023)
29
New Zealand King Salmon Investments Limited Climate-Related Disclosures FY24
Metrics and TargetsContents
Data sourced from publicly available filings. Our datasets may not be complete. Automated analysis can produce errors. If you believe any data on this page is incorrect, please contact us at hello@nzxplorer.co.nz. For informational purposes only. Not investment advice.
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