New Zealand King Salmon Investments Limited logo

Climate-Related Disclosures FY24

ESG28 May 2024NZKConsumer Staples

Climate-Related
Disclosures FY24

CONTENTS
Introduction .................................................3

Governance ..................................................7

Strategy ......................................................12

Risk Management........................................19

Metrics and Targets ......................................21

Glossary .....................................................26

Appendix ....................................................27

2

New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24

Contents

INTRODUCTION
Contents

3

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.

4

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.

5

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

6

New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24

IntroductionContents

GOVERNANCE
Contents

7

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

8

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.

10

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

11

New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24

GovernanceContents

STRATEGY
Contents

12

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

13

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

14

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.

15

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.

16

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

17

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.

18

New Zealand King Salmon Investments Limited — Climate-Related Disclosures FY24

StrategyContents

RISK
MANAGEMENT

Contents

19

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.

Other issuers discussed similar conditions around this time

Matched by meaning across NZX announcement text, not keywords — based on our semantic index of announcement bodies.