Steel & Tube Holdings Limited logo

Steel & Tube - Climate Statement - FY24

ESG29 October 2024STUMaterials

Company Announcement
30 October 2024








Steel & Tube Holdings Limited, PO Box 58880, Botany, Auckland 2163, New Zealand

P +64 4 570 5000 www.steelandtube.co.nz


Steel & Tube Climate Statement FY24


Steel & Tube Holdings Limited (NZX: STU) has published its Climate Related Disclosures for the financial year

ended 30 June 2024, as attached. This is available on the company website at:

www.steelandtube.co.nz/sustainability#disclosures

.


This report reflects the first disclosures prepared in accordance with the Aotearoa New Zealand Climate

Standards. The report seeks to provide stakeholders with an understanding of the potential implications of

climate change on Steel & Tube’s business, and the actions that it is taking to identify and manage climate-

related risks and opportunities.


ENDS


For media or investor enquiries, please contact: Jackie Ellis Tel: +64 27 246 2505 or

email: jackie@ellisandco.co.nz



For further information please contact:

Mark Malpass

Steel & Tube CEO

Tel: +64 27 777 0327

Email: mark.malpass@steelandtube.co.nz

Richard Smyth

Steel & Tube CFO

Tel: +64 21 646 822

Email: richard.smyth@steelandtube.co.nz

---

STEEL & TUBE HOLDINGS LIMITED
2024

C L I M AT E

R E L AT E D

DISCLOSURES

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Steel&Tube Climate-related Disclosures

Introduction

Steel & Tube offers one of New Zealand’s most comprehensive

ranges of steel products, services, and solutions. Steel & Tube’s

group activities involve processing and distributing steel and

metal products. Our purpose is to make life easier for our

customers. We aim to maximise the role of steel in fostering

a sustainable, low-emission society, while simultaneously

expanding our business and delivering value to our

shareholders.

Steel & Tube has a dual pathway strategy; building a diversified

and resilient business (Continue to Strengthen the Core)

while capitalising on new avenues of growth (Grow High

Value Products and Services). Strengthening the core involves

building on the strong business foundation we have established,

to deliver best-in-class customer experiences, operational

efficiency, and a strong financial performance. We will grow

our business by expanding our offering and investing in new

products and services that provide high value to our customers.

Steel & Tube considers sustainability and emissions before

acquiring new businesses or introducing new products and

services.

Steel & Tube is strategically positioning itself to adapt to a future

of low emissions by working to reduce our direct emissions

and understand the impact of our products, and how we

can reduce our product carbon footprint. We support New

Zealand’s goal of achieving net-zero emissions by 2050. In 2022

we joined the Sustainable Business Council, and in 2024 our

Group Sustainability Manager became a board member of the

Sustainable Steel Council, further solidifying our commitment

to minimising our environmental footprint through active

collaboration with industry peers.

Transitioning to a low-emission economy presents both

opportunities and challenges and we acknowledge that climate

change could significantly alter our core business operations

and activities. Steel is an infinitely recyclable material, and with

the upcoming installation of New Zealand Steel’s Electric Arc

Furnace, our product will only increase its circularity in the

coming years. Our work over the last two years to conduct

scenario analysis and identify key climate risks and opportunities

has laid the groundwork for developing our climate change

strategy and transition plan that will continue to evolve in the

years to come. In FY24, we completed the second phase of

our climate risk assessment, and over FY25 we are working to

embed transition planning into our business.

Due to uncertain technological changes, economic factors and

environmental changes, our strategies are subject to change.

Steel & Tube cautions reliance on forward-looking statements

that are necessarily less reliable than other statements. Steel &

Tube gives no representation, warranty, or assurance that actual

outcomes or performance will be consistent with statements

made in this report. We do not accept any liability whatsoever

for any loss arising directly or indirectly from any use of the

information contained in this report. Nothing in this report

constitutes financial, legal, tax or strategic growth guidance

or advice.


Susan Paterson

Chair

John Beveridge

Director

29th October 2024

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Steel&Tube Climate-related Disclosures

Statement of Compliance

Steel & Tube is a climate-reporting entity under the Financial

Markets Conduct Act 2013. These climate-related disclosures

comply with the Aotearoa New Zealand Climate Standards

(NZ CS 1, 2 and 3) issued by the External Reporting Board (XRB).

This report contains Steel & Tube’s first climate statement in

accordance with the Aotearoa New Zealand Climate Standards

and covers the financial year 1 July 2023 to 30 June 2024.

All figures and commentary relate to the full year ended

30 June 2024, unless otherwise indicated.

Steel & Tube has chosen to use the first-time adoption

provisions set out in NZ CS 2 as follows:

+

Adoption provision 1: Current financial impacts

Provides an exemption for an entity from disclosing in its

first reporting period the financial costs of (a) the physical

impact of climate change, and (b) the transition to a low

carbon economy.

+

Adoption provision 2: Anticipated financial impacts

Provides an exemption for an entity from disclosing in its

first reporting period the anticipated financial impacts

of climate-related risks and opportunities it reasonably

expects.

+

Adoption provision 3: Transition planning

Exempts an entity from disclosing in its first reporting

period the transition plan aspects of its strategy and the

extent to which these are aligned with its internal capital

deployment and funding decision-making processes.

+

Adoption provision 4: Scope 3 GHG emissions

Exempts an entity from disclosing in its first reporting

period greenhouse gas (“GHG”) emissions in metric

tonnes of carbon dioxide equivalent classified as Scope 3.

+

Adoption provision 5: Comparatives for Scope 3 GHG

emissions

Allows an entity to not disclose comparatives for the

previous two reporting periods.

+

Adoption Provision 7: Analysis of trends

Provides an exemption to entities from disclosing an

analysis of main trends evident from a comparison of each

metric from previous reporting periods to the current

reporting period.

Transition planning

During FY25, work has commenced on our transition plan.

This plan will be based on the findings from the climate risk

assessment and scenario analysis detailed in the following

pages.

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Steel&Tube Climate-related Disclosures

Governance

Board Oversight

Steel & Tube’s board of directors has overall responsibility

and oversight for Steel & Tube’s strategy, which includes

addressing climate-related risks and opportunities. The board

is supported in this by Steel & Tube’s Audit & Risk Committee.

Steel & Tube’s directors are responsible for their ongoing

education and staying informed about climate-related issues.

The board utilises climate-related expertise from within Steel

& Tube, and externally when required. From FY25, the board

has delegated oversight of climate risks, opportunities and

reporting to the Audit & Risk Committee. The board retains

overall responsibility for climate strategy. The board also

relies on management to keep them informed of changes and

developments on climate change issues and sustainability.

The board is responsible for the oversight of climate-related

disclosures.

Sustainability and climate performance are standing topics for

discussion at board meetings, with key updates reported at six

board meetings in FY24 and is also a key matter for discussion

at the annual board strategy day.

Steel & Tube has been measuring performance on internal

Environmental, Social and Governance (ESG) metrics and

targets since 2022 after its first materiality assessment. These

metrics and targets were approved by the board and cover

a range of performance indicators including GHG emissions.

Performance across these internal ESG metrics and targets are

reviewed by the board on a quarterly basis. Climate-related

performance is not currently incorporated into renumeration

policies.

Management’s Role

The board delegates climate-related responsibilities to various

management-level positions and oversight groups. The Chief

Executive Officer (CEO) leads the management and delivery

of the company’s strategy, and delegates management of

sustainability and climate-related matters to the Chief Financial

Officer (CFO) and Group Sustainability Manager. Steel &

Tube’s Group Sustainability Manager reports to the CFO and

works across the group to ensure the implementation of

decarbonisation projects and other strategic sustainability

initiatives.

The Group Sustainability Manager chairs Steel & Tube’s

Climate Risk Steering Group and provides sustainability

recommendations and updates to the board at least six times

a year. The Climate Risk Steering Group, which comprises of

senior leaders, leads an annual review of climate-related risks

and opportunities and recommendations are made to the

board. Using these various sources of information, the board

is enabled to make informed decisions and guide the company

towards sustainable practices.

The Sustainability Manager meets monthly with the CEO

and CFO to discuss sustainability initiatives in progress,

performance on Scope 1, 2 and 3 emissions and any

developments in identified climate-related risks and

opportunities. The Sustainability Manager also attends the

Health, Safety & Sustainability Engagement meetings held

every six weeks and involving site managers, operations

managers and area managers across the company. The

Sustainability Manager reports relevant insights and feedback

from these meetings up to the CEO and CFO.

Board

• Oversees Steel & Tube’s strategy, which includes climate-

related risks and opportunities, and monitors overall

performance against climate metrics and targets

Management

• CEO is responsible for leading, managing and delivering on

Steel & Tube’s strategy, including its sustainability strategy

• The Climate Risk Steering Group is chaired by the Group

Sustainability Manager, and reports to and informs the CEO

and board of climate-related risks and opportunities

Group

• Group Sustainability Manager ensures there is appropriate

visibility and ownership/operational management of

climate-related risks and opportunities, including engaging

and consulting with the business to drive decarbonisation

initiatives

• Group Financial Controller oversees financial impacts of

climate-related risks and opportunities

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Steel&Tube Climate-related Disclosures

Strategy

Current Impacts

Steel & Tube has analysed how our business is currently

impacted by physical and transition aspects of climate change.

The main impacts are from weather events disrupting our

business activities and those of our customers, and a potential

shift in demand towards materials with lower embodied

carbon.

Physical Impacts

In early 2023, Steel & Tube witnessed first hand the

susceptibility of New Zealand to severe weather conditions,

with the flooding in Auckland and Northland, and the impact

of Cyclone Gabrielle across much of the North Island, in

particular the Hawkes Bay. These physical climate-related

events caused extensive damage to infrastructure and supply

chains. Economic repercussions included disaster recovery

costs and lost productivity. These repercussions were felt

strongly by many businesses in the upper North Island

and, to a lesser extent, the rest of New Zealand. Despite

these challenges, Steel & Tube experienced only minor

disruptions to its operations. The company was able to extend

support to its employees and customers affected by these

extreme weather events. We have continued to strengthen

our business continuity planning in FY24, which includes

emergency responses for each site for different civil defense

scenarios.

Transition Impacts

Steel & Tube is one of New Zealand’s leading distributors

and processors of steel, metal and related products and our

customers range from food and dairy processors, engineers

and fabricators to manufacturers, builders and construction

companies. We are aware that customers within these

segments either currently have or are beginning to develop

embodied carbon targets for their projects (e.g. Green Star

Building requirements). In other cases, end-user demands

are driving requests for products that meet low-carbon

specifications. A growing awareness of the impact of emissions

and desire to reduce embodied carbon in the building sector

in particular has created a shift in demand towards materials

with lower embodied carbon. This trend could potentially lead

to a loss of customers, revenue and, to a lesser extent, market

share for Steel & Tube if we do not have the correct mix of

product offering that meets low-carbon requirements.

Sustainability features as one of Steel & Tube’s four strategic goals; to deliver positive outcomes for

our business, our people, our communities, and our planet. In alignment to this goal, over FY23 and

FY24, Steel & Tube has undertaken a two-phased climate risk assessment, conducted scenario analysis,

and taken steps towards developing a transition plan. A description of the climate risk assessment and

scenario analysis work undertaken is provided in the “Approach to scenario analysis section” on page 6.

6
Steel&Tube Climate-related Disclosures

Approach to Scenario Analysis

Over the course of 2023 and 2024, Steel & Tube engaged Deloitte to assist with conducting a

climate risk assessment and scenario analysis workshops to build our scenario narratives.

The initial output was the development of our climate scenario architecture, agreement on the

strategic time horizons for testing our exposure to climate risks and hazards and a climate risk &

opportunities register, containing our identified and rated physical and transition risks.

We chose the Network for Greening the Financial System (NGFS) scenarios for our analysis

primarily due to the availability of regional or country-specific data for New Zealand, and

the inclusion of temperature pathways necessary for compliance with NZ CS 1. The scenario

architecture and narratives were developed internally, adopting NGFS narratives for Net Zero

2050, Delayed Transition, and Hothouse - Current Policies. Additionally, we incorporated a

broader set of climate scenarios from the SSP (Shared Socioeconomic Pathway) Scenarios, the

Intergovernmental Panel on Climate Change (IPCC) and qualitative descriptions, population

demographics and socio-economic assumptions.

The time horizons for these scenarios were determined on the basis of Steel & Tube’s asset and

product design life, its asset management regime, and its longer-term business strategy. The

warming scenarios and time horizons adopted by Steel & Tube provide a means of stress testing

the exposure and vulnerability of Steel & Tube’s assets, operations and people to the effects of

climate change over time and under different scenarios.

Risk and Scenario Time Horizons

Steel & Tube’s Climate Scenarios

Short-termPresent day to 2030Orderly – Net Zero by 2050 (1.4°C)

Medium-term2030 to 2050Disorderly – Delayed Transition (1.6°C)

Long-term2050 to 2100Hothouse – Current Policies (3°C+)

Steel & Tube conducted its scenario analysis as a standalone process, and we have not

undertaken any modelling. An explanation of the sources of data is provided in the Appendix 1.

A staged approach was taken to develop board knowledge and understanding, with full board

engagement during the introduction of climate-related disclosures. This culminated in board

approval of the climate risk assessments and scenario narratives.

The Climate Risk Steering Committee participated in a scenario analysis workshop to define

“how climate change could plausibly affect our business model and strategy, what should we

do and when”. This information was then used by the group to identify our driving forces, using

the STEEP analysis (social, technological, economic, environmental, and political categories) as

provided by the XRB Staff Guidance on Entity Scenario Development. The output of the analysis

for each climate scenario was consolidated and scenario narratives were drafted.

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Steel&Tube Climate-related Disclosures

Our Climate Scenario Architecture

OrderlyDisorderlyHothouse

IPCC SSP SSP 1 – 1.9, 1.4°CSSP 1 – 2.6, 1.8°CSSP 5 – 8.5, 4.4°C

NIWA RCPRC P 1.9RCP 2.6RCP 8.5

NFGS

Scenarios

Orderly – Net Zero by 2050

Global Warming limited to 1.5°C by the end of 2100

Disorderly – Delayed Transition

Global warming limited to 2°C by the end of 2100

Hothouse – Current Policies

Global warming reaches 3°C of warming by the end of 2100

Policy Ambition1.4°C1.6°C3 °C+

Policy ReactionImmediate and smoothDelayedNone – current policies

Technology ChangeFast changeSlow/fast changeSlow change

CDR (carbon dioxide

removal)

Medium-high useLow-medium useLow use

Regional Policy VariationMedium variationHigh variationLow variation

Shor t-term

(Present day – 2030)

Early implementation of climate change regulation and

policies. Clear market signals encourage steel makers to

drive enhanced resilience through strategic products,

competitive pricing and strict screening.

Physical Risks: Low

Transition Risks: High

Delayed implementation of policies and mixed market

signals make it difficult for steel makers to meet

demands and needs. Increased exposure to reputation

damage.

Physical Risks: Low

Transition Risks: Low

Current policies – limited ambition. Limited to no

investment in infrastructure resilience and extreme

exposure to climate impacts results in credit and liquidity

risk.

Physical Risks: Low

Transition Risks: Low

Medium-term

(2030 – 2050)

Ambitious decarbonisation goals and policies are

introduced immediately, and emissions decline rapidly

and steadily to achieve net zero by 2050.

Physical Risks: Low

Transition Risks: Medium

Significant decarbonisation is delayed until the mid-

2030s. There is a high transition risk as New Zealand

rushes to meet net zero by 2050 goals and moderate

physical risk exposure due to delayed action.

Physical Risks: Medium

Transition Risks: High

No additional policies are introduced to curb emissions,

and emissions continue to rise. Warming reaching >3°C.

There are limited transition risks but extreme physical

climate risks.

Physical Risks: High

Transition Risks: Low

Long-term

(2050 -2100)

Net zero achieved. Relatively low weather impacts.

Physical Risks: Low

Transition Risks: Low

Extended period of policies due to delayed/disorderly

transition.

Higher impacts felt.

Physical Risks: Medium

Transition Risks: Low

Impacts are creating large GDP destruction. Still no

policies.

Physical Risks: High

Transition Risks: Low

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Steel&Tube Climate-related Disclosures

Description of Scenario Narratives

The following section provides a summarised overview of the three scenario narratives developed and utilised by Steel & Tube in FY24. These narratives aim to illustrate the critical

uncertainties and assumptions regarding how Steel & Tube’s operating context might evolve over time under various potential futures. Although they are shaped by a scenario architecture

that makes specific assumptions about how context evolves over time, they remain qualitative and exploratory in nature. Climate scenarios are not predictive, nor are they forecasts or

representations of preferred options.

Orderly

In response to increasing global pressure to combat climate

change, the global community attempts to meet its obligations

under the Paris Agreement by implementing stringent policies

mandating the use of sustainable materials in construction.

These policies prioritise materials with lower carbon

footprints, pushing the construction industry to adopt greener

alternatives. Steel & Tube must navigate these regulations

while maintaining competitiveness. Public awareness and

concern about climate change has surged, influencing

customer preferences. Consumers and businesses alike are

demanding more sustainable products, with rapid investigation

and research conducted for alternative materials and low

emission methods for producing steel. Steel, traditionally

seen as a high-carbon material, faces scrutiny not only from

the construction market, but also from the new potential

workforce who factor in environmental impact in their choice

of employment. Although the higher carbon content of steel

has a negative perception, there is also growing recognition of

the durability and circularity of steel, presenting an opportunity

for Steel & Tube to reposition its products. The economic

landscape is shaped by fluctuating access to finance, driven

by banks and insurance companies prioritising sustainable

investments. Financial entities restrict access to funding unless

high-emitting companies have a verifiable transition plan.

Companies with strong environmental credentials find it easier

to secure funding. Additionally, technological advancements

in alternative materials like wood and synthetics are increasing,

posing both a threat and an opportunity for Steel & Tube.

Disorderly

The political landscape is chaotic, with inconsistent and

rapidly changing policies. Governments are struggling to

balance economic growth with climate commitments, leading

to unpredictable regulations. Steel & Tube faces a volatile

environment where sudden policy shifts can disrupt operations

and strategic planning. Public opinion is fragmented. While

a significant portion of the population demands immediate

and drastic action on climate change, others are resistant due

to economic concerns. This division creates a challenging

market where customer preferences are highly variable and

difficult to predict. Steel is often criticised for its embodied

carbon, but its durability and recyclability still hold appeal for

certain segments. Increased weather events demonstrate

the durability and reliability of steel products, but a disruptive

supply chain causes issues for procurement. The economic

environment is unstable, characterised by fluctuating access

to finance and insurance. Banks and insurance companies are

increasingly wary of high-carbon industries, leading to sporadic

and unpredictable financing conditions and excessive delays

due to fluctuating lending criteria. Technological advancements

in alternative materials are progressing unevenly, creating both

opportunities and threats for Steel & Tube.

Hothouse

In this scenario, global efforts to mitigate climate change

have largely failed, leading to severe and frequent climate

impacts. Governments are overwhelmed by the immediate

need to address climate disasters, resulting in reactive and

fragmented policies. Steel & Tube must navigate a landscape

where regulations are inconsistent and often focused on short-

term crisis management rather than long-term sustainability.

Society is experiencing significant stress due to the impacts of

climate change. Public opinion is polarised; while some demand

urgent action, others are more concerned with economic

survival. Customer preferences are shifting rapidly, with a

growing demand for materials that can withstand extreme

weather conditions. Steel, known for its strength and durability,

is increasingly valued, but its environmental impact remains

a concern. The economic environment is highly unstable,

characterised by frequent disruptions due to climate-related

events. Access to finance is erratic, with banks and insurance

companies becoming increasingly risk-averse. Technological

advancements in alternative materials are slow and uneven, as

resources are diverted to immediate climate response efforts.

Steel & Tube faces a challenging market where adaptability and

resilience are key.

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Steel&Tube Climate-related Disclosures

Climate-related Risks and Opportunities

Steel & Tube has identified a number of anticipated climate-related risks and opportunities over defined time horizons. The tables below outline the material climate-related risks and

opportunities that Steel & Tube has identified together with their anticipated impacts.

The timeframes identified below over which we estimate that risks or opportunities could eventuate are not currently linked to our strategic planning timelines or capital deployment plans.

However, climate-related risks and opportunities are considered in this section covering decisions on significant capital expenditure and potential acquisitions.

DescriptionTimeframeAnticipated Impacts

Physical Risk:

Business disruption from extreme weather

Extreme weather events could result in damage to assets,

business interruption and operational delays. These weather

events may also impact on customer projects with delays and

reduced demand for steel

Short-term

Medium-term

Long-term

Increased extreme weather events could:

• Cause damage to buildings and worksites

• Close or damage transportation routes necessary for our people to come to work, and to deliver and receive goods

• Disrupt supply chains nationwide, with associated costs

• Reduce revenue due to an inability to deliver customer orders

• Cause customers to pause or delay projects, resulting in decreased demand for Steel & Tube’s products

• Increase the cost of insurance, repairs, maintenance and asset replacement

• Increase capital expenditure to upgrade properties to a climate-resilient standard

Physical Opportunity:

Increased demand for steel as a resilient construction

material

Steel is a highly resilient, strong and sustainable construction

material and offers a number of advantages in a future where

climate change and extreme weather events are more likely

Short-term

Medium-term

Long-term

• Increased demand for steel in new build and rebuild projects, particularly for essential infrastructure, coastal

protection and port rebuilds

• Increased demand for building products, such as roofing, that are corrosion resistant

10
Steel&Tube Climate-related Disclosures

DescriptionTimeframeAnticipated Impacts

Transition Risk & Opportunity:

Growing customer preference for building products with

lower embodied carbon

Steel has relatively higher embodied carbon than other

building products. New technologies to decarbonise steel are

still in very early stages

Short-term

Medium-term

Long-term

• Customers seeking to meet embodied carbon targets and requirements, turning to alternative building products

• Short/medium term - global investment in low-emissions steel production, as mills invest in Electric Arc Furnaces

and R&D for low embodied carbon steel production

Transition Opportunity:

Decarbonisation of the energy sector

Transition away from fossil fuel energy sources such as coal to

more sustainable energy for example solar and wind

Short-term

Medium-term

• Increased demand for steel as an essential component in the construction of alternative energy projects

• Decarbonisation of the energy sector creates demand for steel products for i.e. wind turbines, steel ground

mounted solar arrays

Transition Risk:

Increased regulation and compliance

Introduction of new climate-related regulation or policies

that affect customer projects and/or the company and/or

directors

Short-term

Medium-term

Associated risks include:

• Potential fines and litigation for directors due to failure to comply with climate-related disclosures

• Perceived greenwash resulting in litigation

• Reduced demand for steel due to low embodied carbon policies in construction projects

Transition Risk:

Global supply chain disruption

Increasing geopolitical tensions, supply and demand

disruption, and carbon border adjustment mechanisms

Short-term

Medium-term

Steel & Tube sources 50-60% of its products from global steel mills. Global supply chain disruption could:

• Reduce access to offshore steel mills and product

• Increase the cost of accessing steel globally

• Lead to lost sales where stock is unavailable

• Increased costs associated with international freighting

11
Steel&Tube Climate-related Disclosures

Risk Management

Steel & Tube has undertaken a stand-alone climate risk assessment to identify, assess, and manage

climate-related risks. This end-to-end risk assessment process involved several key steps.

A series of workshops were held to establish the scope and boundary of the climate change risk

assessment, and included Steel & Tube’s Climate Risk Steering Group consisting of members of

the Senior Leadership Team (SLT) and key internal subject matter experts. This group identified

and rated Steel & Tube’s climate risks and assessed and validated the results.

The climate risk assessment took into consideration the methodology provided by the

Ministry for Environment’s National Climate Change Risk Assessment Framework, which

offers a structured approach to identifying and assessing climate change risks at a national

level. The company also referred to ISO 14091-2021, a standard that provides guidelines for

assessing physical risks and opportunities associated with climate change. Additionally, Steel

& Tube utilised the methodology for identifying and rating transition risks and opportunities

that is recommended by the Task Force on Climate-related Financial Disclosures (TCFD). This

comprehensive approach ensured a robust and thorough climate risk assessment, aligning with

international best practices and standards.

Risks are assessed over timeframes that are in line with our scenario time horizons (present day

to 2030 for short term, 2030 – 2050 for medium term and 2050 – 2100 for long term).

The scope of our climate risk assessment encompassed all aspects of Steel & Tube, its subsidiaries,

our suppliers, upstream transportation, and one step down the supply chain to our direct

customers. No parts of our value chain are excluded from this assessment.

At a minimum, a comprehensive climate risk assessment will be carried out every three years.

Annually, a list of top risks and opportunities will be reviewed by the SLT and presented to the

board to determine if further action is necessary.

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Steel&Tube Climate-related Disclosures

Metrics and Targets

Metric Categories

Metrics and targets are used to quantitatively measure an organisation’s sustainability

performance.

+

Scope 1 emissions we directly control. For Steel & Tube, this includes vehicle fuel and

stationery combustion

+

Scope 2 purchased electricity from the grid

As previously noted, Steel & Tube has opted to use NZ CS 2 Adoption provision 4, providing

an exemption from disclosing our Scope 3 emissions in FY24. Although we have historically

reported some of our Scope 3 emissions, previously this has been based on incomplete data.

A full description of our GHG emissions methods, assumptions and estimation uncertainty are

included in Appendix 2.

Table of Emissions

All figures are in tCO2e (Tonnes of Carbon Dioxide Equivalent). Our baseline year for GHG

emissions is 2023.

Emissions CategoryFY22FY23FY24

Total Scope 1 & 21,857 1,886 1,702

Scope 11,239 1,523 1,393

Stationery Combustion10 9 8

Vehicle Fleet1,229 1,514 1,385

Scope 2618363309

Electricity Consumption618363309

Our reported FY22 and FY23 Scope 1 and 2 emissions published in August 2023 were measured

in accordance with the Ministry for the Environment’s Measuring Emissions: A Guide for

Organisations: 2022. We have since applied each version of the MFE Emission Factor books to

our corresponding financial year (eg. FY22 emissions apply MFE 2022 Emission Factors, FY23

emissions apply MFE 2023 Emission Factors and FY24 emissions apply MFE 2024 emission factors).

Explanatory Comments

Scope 1: In May 2024, Steel & Tube acquired 20 trucks and 8 trailers, and as a result emissions that

were previously accounted as Scope 3 Category C9 (Downstream Transportation and Distribution)

are now accounted as Scope 1 – Vehicle Fleet.

Scope 2: The emission factor for Scope 2 electricity consumption in FY23 and FY24 was significantly

lower than the FY22 emission factor, this has resulted in a reduction in the tCO2e amount when

comparing FY23 and FY24 to FY22.

GHG Emissions Intensity

Steel & Tube measures Scope 1 & 2 emissions intensity by tonnes sold (kgCO2e per tonne sold).

Emissions Intensity – Tonnes SoldFY22FY23FY24

Scope 1 & 211.0812.7714.74

Additional Metric Categories

Our work to assess the amount or extent of assets or business activities vulnerable to climate-

related risks (and aligned to opportunities), including the methodology and metrics to quantify,

is ongoing and is not included in this first year of reporting.

Steel & Tube does not currently apply an internal carbon emissions price. Steel & Tube is

currently determining how climate-related risks and opportunities serve as an input to its

internal capital deployment and funding decision-making processes.

Ta r g e t s

Steel & Tube has not currently set any climate-related targets, but we are working towards

developing meaningful targets over FY25 as we continue to investigate appropriate metrics that

are industry specific and a transition plan to support our ambitions to achieve any targets.

13
Steel&Tube Climate-related Disclosures

Appendix 1: Scenario Analysis and Climate Risk

Assessment Methodologies

Overview of Scenario Analysis

Scenario analysis is a process for identifying and assessing the potential implications of a range

of plausible future states under conditions of uncertainty. Scenarios are hypothetical constructs

and not designed to deliver precise outcomes or forecasts. Instead, scenarios provide a way

for organisations to consider how the future might look if certain trends continue or certain

conditions are met (TCFD Guidance, 2017).

Steel & Tube’s Climate Risk Assessment (CRA) analysis provides insight into plausible future risk

profiles in terms of Steel & Tube’s exposure and vulnerability to the effects of climate change,

and how these evolve over time and under different global warming scenarios.

Our operational boundary for our scenario analysis and CRA was determined to be two tiers

upstream (i.e. to the steel mill) and one tier downstream (i.e. the direct customer) of our value

chain.

Methodology

For the purposes of our CRA, we adopted the shared socioeconomic scenarios (SSP) provided by

the Intergovernmental Panel on Climate Change Sixth Assessment Report (IPCC AR6) to assess

Steel & Tube’s evolving risk profile.

The SSPs build upon the Representative Concentration Pathways (RCPs) from the IPCC Fifth

Assessment Report (IPCC AR5). We use the RCP scenarios (that are aligned to the SSP scenarios)

from the IPCC AR5 for climate metrics that had not yet been developed within the IPCC AR6

models.

For the purpose of assessing Steel & Tube’s transition risks, we have referenced the scenarios provided by the Network for Greening the Financial system, which include the Orderly,

Disorderly and Hot House World as described below:

Orderly Net Zero by 2050

An ambitious scenario that limits global warming to 1.5°C

through stringent climate policies and innovation, reaching net

zero CO2 emissions around 2050. Some jurisdictions such as

the US, EU and Japan reach net zero for all greenhouse gases

by this point. This scenario assumes that ambitious climate

policies are introduced immediately. Carbon Dioxide Removal

(CDR) is used to accelerate the decarbonisation but kept to

the minimum possible and broadly in line with sustainable

levels of bioenergy production. Net CO2 emissions reach zero

around 2050, giving at least a 50% chance of limiting global

warming to below 1.5°C by the end of the century, with no or

low overshoot (< 0.1°C) of 1.5°C in earlier years. Physical risks are

relatively low.

Disorderly Delayed Transition

Assumes global annual emissions do not decrease until 2030.

Strong policies are then needed to limit warming to below 2°C.

Negative emissions are limited. This scenario assumes new

climate policies are not introduced until 2030 and the level of

action differs across countries and regions based on currently

implemented policies, leading to a “ fossil recovery” out of the

economic crisis brought about by COVID 19. The availability of

CDR technologies is assumed to be low pushing carbon prices

higher than in Net Zero 2050. As a result, emissions exceed

the carbon budget temporarily and decline more rapidly

than in well below 2°C after 2030 to ensure a 67% chance of

limiting global warming to below 2°C. This leads to both higher

transition and physical risks than the Net Zero 2050 and below

2°C scenarios.

Hothouse Current Policies

Assumes that only currently implemented policies are

preserved, leading to high physical risks. Emissions grow until

2080 leading to about 3°C of warming and severe physical risks.

This includes irreversible changes like higher sea level rise. This

scenario can help central banks and supervisors consider the

long-term physical risks to the economy and financial system if

we continue on our current path to a “hot house world”.

14
Steel&Tube Climate-related Disclosures

Appendix 2: GHG Methodologies, Assumptions and

Estimation Uncertainties

Methodology

Our Greenhouse Gas (GHG) inventory is prepared in accordance with the Greenhouse Gas

Protocol: A Corporate Accounting and Reporting Standard; and Greenhouse Gas Protocol:

Corporate Value Chain (Scope 3) Accounting and Reporting Standard. All metrics are prepared

using the ‘operational control’ consolidation approach.

Our emission factors are sourced from the Ministry for the Environment, as described in Table A.

Steel & Tube ensures the accuracy and relevance of our greenhouse gas (GHG) emissions

reporting by annually updating our emission factors in alignment with the latest releases from

the Ministry for the Environment (MfE). Each year, MfE publishes updated emission factors in

their guides for organisations, such as:

• A Guide for Organisations: 2022 Summary of Emission Factors

• A Guide for Organisations: 2023 Summary of Emission Factors

• A Guide for Organisations: 2024 Summary of Emission Factors

By incorporating these updated factors, we maintain consistency with national standards

and reflect the most current data available. This practice enhances the reliability of our GHG

inventories and supports our commitment to transparent and accurate environmental reporting.

We do not rely on estimations for our Scope 1 and 2 GHG emissions reporting. All reported data

is based on direct measurements and verified sources, ensuring the highest level of accuracy

and reliability in our emissions disclosures.

Emissions Type

Emission

Source & FactorEmissions Activity

Calculation

MethodologyData Source(s) Assumptions, Limitations & Uncertainties

Scope 1Natural Gas

(MfE)

Natural gas used for water

heating on site

Location-based

method

Consumption data in kWh is provided by our

power management company, using invoiced

data from retailers

Low uncertainty on data quality from supplier,

medium uncertainty from emission factors not

being site-specific

Scope 1LPG (MfE)LPG used in forklifts and other

onsite equipment

Fuel-based methodAutomated usage report from main supplier,

consumption data collected from invoices for

other suppliers

Low uncertainty - reports are automatic from

the supplier, manually entered quantity volumes

are low

Scope 1 Fleet Vehicle Fuel

(MfE)

Fuel used in vehicle fleetFuel-based methodPrior to May 2024, there were two sources of

fuel reporting separate fleet managers, however

our fuel reporting is now consolidated into one

report from one source

Low uncertainty - reports are automatic from the

supplier. Where an operator has purchased fuel

on their Steel & Tube Procurement card, this is

captured in a separate report.

Scope 2 Grid sourced

electricity (location

based) (MfE)

Electricity sourced from the grid

to our sites

kWh-used methodUsage report from supplier dashboardLow uncertainty - reports are sourced directly

from the supplier and do not use averages or

assumptions

Ta b l e A

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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