Sanford Limited/Announcement
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FY24 Sustainability Report

ESG30 January 2025SANConsumer Staples

Sanford Ltd
22 Jellicoe Street, Auckland 1010

PO Box 443, Shortland Street, Auckland 1140

www.sanford.co.nz

30 January 2025


FY24 Sustainability Report


Sanford Limited (Sanford) is pleased to present its FY24 Sustainability Report, which includes

Sanford’s first mandatory Climate-Related Disclosure (CRD) prepared in accordance with the

Aotearoa New Zealand Climate Standards.


Sanford’s FY24 Sustainability Report provides stakeholders with a view of its sustainability

performance, activities and outlook.


A copy of the report is also available on Sanford’s website at sanford.co.nz/investors.



For further information, please contact:

Paul Alston

Chief Financial Officer

palston@sanford.co.nz

021 918 033

---

Sustainability
Report

FY24

Sanford Limited’s FY24 Sustainability Report provides our
stakeholders with a view of our sustainability performance,

activities and outlook.

About this Report

Sanford has, during FY24, reviewed our

approaches for sustainability reporting to ensure

that balance is maintained. The result is the

creation of this report, which includes Sanford’s

first mandatory Climate-related Disclosure.

This report is available on Sanford’s website

sanford.co.nz/investors.

Period and Scope:

This report covers our sustainability

performance and activities for the 12-month

period from 01 October 2023 to 30 September

2024 (FY24), corresponding with Sanford

Limited’s financial year. This report focuses

on the performance of Sanford Limited,

operationally controlled entities and joint

ventures and operations.

Readers are cautioned to review the disclaimer

on page 12 of this report which applies to

Sanford’s climate-related disclosures and the

broader content of this report.

Contents

Sustainability at Sanford2

Sanford’s Sustainability Framework4

What Matters Most – Material Topics6

Sustainability in Action8

Climate-related Disclosure12

Aotearoa New Zealand Climate

Standards (NZ CS1, CS2 and CS3)

Disclosure Reference Table

30

1Sustainability Report FY24 |

Sustainability at Sanford
We understand that our operations can have

environmental, social and economic outcomes

and that our business and operational decisions

can influence those now and into the future.

Sanford’s first ‘triple bottom line’ sustainability

report was issued in 2000 which measured our

business performance in these areas being

environmental, social and economic. Since then

the scope of our sustainability reporting has

evolved through sustainable development reports,

integrated reports, the application of G4

Sustainability Frameworks and subsequently

the Global Reporting Initiative (GRI) standards

for the structured reporting of sustainability

topics and integration of sustainability strategy

within our overall business strategy.

FY24 marks an inflection point in this approach,

as our business grapples with increasing external

reporting demand and seeks to achieve the right

balance of resource allocation to those reporting

tasks and progress within our organisation. In this

reporting year, we have chosen to channel

our resources to material areas where the

sustainability gains have the best chance of

success. The outcome is for the Sustainability

Report to be separated from our financial

reporting, and includes our mandatory climate-

related disclosures.

Sustainable Seafood

The term sustainable seafood,

or sustainability, is used a lot

in reference to the fishing

and aquaculture sectors;

it can mean different things

to different people. At Sanford,

we consider sustainable

seafood to be seafood that

is good for the planet,

people and business.

At Sanford, we consider sustainable seafood to be

seafood which is sourced from operations which:

• Are harvested or farmed in a manner that

provides for today’s needs while allowing

species and associated species to reproduce

in productive habitats and ecosystems

• Minimise harmful environmental impacts

• Assure good and fair working conditions

for those involved

• Are managed and regulated appropriately

as part of a well-functioning resource

management regime.

Sustainability extends into many aspects of

Sanford’s business and across the domains of

people, place and performance – aligning with the

traditional sustainability pillars of environmental,

social and economic. Sanford’s sustainability

framework is founded across those pillars and

based on engagement work throughout the

breadth of Sanford’s stakeholder community

to identify and prioritise the most important,

or most material, topics relevant for our business

and our stakeholders. Our sustainability framework

(see next page) outlines those sustainability

pillars, material topics, Sanford’s future vision

by material topic, key performance indicators

(KPIs) per material topic and alignment with the

United Nations’ Sustainable Development Goals

(UN SDG).

3Sustainability Report FY24 | 2| Sanford Limited

Pillar
Performance and Operational Excellence

Pursue excellence across all functions and operations to drive business success,

increasing value and return for shareholders.

Place – Oceans,

Environment,

Ecosystems

Strive to demonstrate safeguarding

the environment, maximising

resource utilisation and minimising

Sanford’s footprint.

People, Customers,

Community

Aim to deliver outcomes for Sanford’s people,

for the consumers of Sanford’s products, and the

communities in which Sanford operates.

Material

Topics and

Focus Areas

Maximising

productivity and

$/kg returns from

the harvest.

Demonstrating

responsible

leadership – across

ethics, conduct,

transparency and

governance.

Adapting practices to

a changing climate.

Responsible risk

management.

Sustainable

management

of fish stocks.

Environmental

protection and

ocean health.

Reducing

operational

emissions

footprint.

Health, safety

and wellbeing

of Sanford’s

workforce.

Talent

attraction,

development

and retention.

The food

safety and

quality of

Sanford’s

products.

Relationships

with community

and iwi.

VisionExecution of strategy

to deliver better value

outcomes, improved

business margins

and financial

performance.

Being recognised as a

business that governs

with clearly defined

values for the good of

all stakeholders.

Deploying appropriate

and measured

responses to direct

and indirect climate

impacts across

strategy, investment

planning and

operations.

Clear identification

and prioritisation

of risks, enabling

the considered

deployment of

required mitigations

to manage those risks

to acceptable levels.

Fisheries’

stocks from

which

Sanford’s

harvests

continue

to be

maintained at

levels which

can sustain

ongoing

utilisation and

ecosystem

health.

Methods most

likely to ensure

and enable the

protection of

ocean health,

water quality,

sensitive

habitats and

threatened

species.

Reduction

of Scope 1

and Scope 2

carbon

emissions

intensity by

at least 5%

from a FY20

baseline by

FY30.

Workplaces

that protect

Sanford’s

people from

the risk of harm

and support

their wellbeing

through the

use of

initiatives,

behaviours

and cultures.

Workplace

conditions

and

behaviours

that support

staff

attraction,

development

and retention.

Leader in

providing safe,

high-quality

marine-sourced

products that

deliver on

customers’

expectations.

Respected

by local

communities

and iwi, with

established and

deep strategic

relationships

that create value

for Sanford,

its partners

and the

community.

Key

Performance

Metrics

Profitability and

productivity by

operational division.

Supplier code of

conduct adoption.

Number of climate

adaptation measures

delivered.

Number of risks

rated as ‘extreme’.

Risk mitigation

and measurement

deployment for

high-rated risks.

Percentage of

harvest with

no known

sustainability

issues.

Incidental

by-catch of

seabirds and

marine

mammals.

Percentage of

fully functional

processing and

support facility

environmental

permits.

Progress

towards FY30

emissions

target.

TRIFR*

Incident

investigations.

Action plan

closure.

Core people

process

completion.

Number of

quality-related

customer

complaints.

Provision of

targeted and

meaningful

support.

UN SDG

Alignment

Sanford’s Sustainability Framework

* Total Recordable Incident Frequency Rate

5Sustainability Report FY24 | 4| Sanford Limited

Material TopicScopeKey Policies and Management
Performance

and

Operational

Excellence

Maximising $/kg

of our harvest

(profitability and

productivity)

The economic productivity of our business,

enhancing our ability to provide returns to

shareholder investors, contribute towards local

and regional economies and job creation, including

our impact on the New Zealand economy.

· Overall business strategy

· Board Charter; Audit, Finance

and Risk Committee Charter

Responsible

leadership

– ethical

conduct,

transparency,

governance

Our leadership values, consideration of all

stakeholders in decision-making, approach to

business conduct, openness and ethics – within

our business processes and dealings with others

including our people, suppliers, customers,

regulators, community groups and others.

· Company Constitution, Board Charter

· Sanford Code of Conduct

· Code of Ethical Behaviour

· Continuous Disclosure Policy

· Protected Disclosures

(Whistleblower) Policy

Adapting to a

changing climate

Our business’s response to the changes brought

about as a result of climate change – across the

physical environment, the fisheries, marine water

and habitat quality, policy, markets, customers

and consumers.

· Sustainability Policy

· Overall business strategy

Risk managementHow we manage, mitigate, eliminate, control

and accept risks across the value chain of our

business – from our inwards materials, our

farming, harvesting, catching, processing and

storage operations to the customers, markets and

end consumers who consume those products.

· Risk management approach

· Audit, Finance and Risk

Committee Charter

Place –

Oceans,

Environment,

Ecosystems

Sustainable

management

of fish stocks

The direct impact of our operations on fish stocks

and fishery biomass, inclusive of our position as

fisheries quota owner to support the science-

based sustainable management and utilisation of

fishery resources.

· Fisheries Compliance Policy

· Sanford’s policy against shark finning

· Operational practices

implementation

Environmental

protection and

ocean health

The positive and negative effects of our operations

at land and sea on coastal and marine

environments in terms of water quality, habitats,

and threatened and protected species.

· Sustainability Policy

· ISO14001 Environmental

Management System

Reducing carbon

footprint and

emissions

Our direct emissions footprint from those activities

over which we have operational control, as well as

our indirect emissions footprint, both upstream

and downstream, within our value chain – and the

potential impact of those collective emissions on

climate change.

· Sustainability Policy

· Emissions-reduction target

People,

Customers,

Community

Health, safety

and wellbeing

of our people

The health and safety of our employees, share

fishers, contractors, and visitors to our sites and

on our vessels. The wellbeing of our employees

and share fishers.

· Health, Safety and Wellbeing Policy

· Health and safety management

system deployment

· Wellbeing initiatives, assistance

programmes

· People Safety and Health

Committee Charter

Talent attraction,

development

and retention

All Sanford’s permanent and temporary

employees and share fishers.

· Learning and Development Policy

· Remuneration Policy

Food safety and

quality

All food products we sell, including fresh

and frozen seafood, foodservice, wholesale,

consumer and ingredients.

· Food Safety and Quality Policy

· Food Safety System Certification

(FSSC22000)

· Regulatory and internal

audit systems

Community and

iwi relationships

Our relationships and collaborative approach with

communities and iwi living close to our operational

sites or activities; the effects of our activities on

those communities including fishing, growing,

processing, job creation, and support initiatives.

· Operational practices

Material Topics, Scope, Policies and Management

What Matters Most –

Sanford’s Material Topics

Sanford’s Approach

We have evaluated, prioritised, responded to and reported on

material topics in our annual report since 2014. We’ve re-engaged

with stakeholders on materiality over a two- to four-yearly cycle,

or when there is a significant shift within our external or internal

operating environment. We last undertook detailed materiality

engagement with our stakeholders during 2022.

7Sustainability Report FY24 | 6| Sanford Limited

Quality Complaints Breakdown
FY24FY23

Wrong product20%9%

Labelling error14%9%

Foreign material12%12%

Packaging12%3%

Quality defects10%41%

Date coding error8%2%

Weight control8%4%

Other4%3%

Temperature abuse4%0%

Bone4%0%

Under-delivered2%7%

Parasites2%3%

Product grading error0%3%

Product missing0%4%

Total number of justified quality complaints5071

Our commitment to continuous improvement

is further reflected in our audit performance.

This year, the number of key topics identified

in the Ministry of Primary Industries Performance-

based Verification audits was reduced from 37 in

FY23 to 28 in FY24. This 24% decrease highlights

our successful implementation of enhanced

quality control processes, systems and our ability

to address and resolve issues more efficiently

without using extra resources.

We have also embraced new technologies such

as INNOVA tablets to report quality inspections

on a single platform. This has enabled us to

zone in on defects and understand where

improvements are required.

Food Safety and Quality

As we review FY24, our Food Safety and Quality

Department highlights several achievements

that reflect Sanford’s dedication to these essential

principles. Ongoing efforts to enhance our quality

management system have yielded positive results,

emphasising our role in ensuring product safety

and quality.

Since July 2020, our Food Safety and Quality

Management System has undergone a significant

transformation, moving from a reactive approach

– primarily relying on testing and complaint

management – to a proactive strategy. This has

been instrumental in preventing issues before

they arise and has resulted in yearly reductions

in customer complaints, improving our performance

in regulatory and certification audits. Contained

within this reset from 2020, we continue to drive

change by focusing on ‘FAST, COLD, CLEAN +

LABELLING’ as our key success factors.

There has been a substantial reduction in

customer complaints in recent years. In FY21

we recorded 119 substantiated complaints.

In FY23, we recorded 71 substantiated complaints.

Through diligent quality management and

proactive measures, we reduced this number

to 50 substantiated complaints in FY24. This figure

reflects a 30% decrease from last season and a

58% decrease from FY21 to FY24. This reduction

highlights our emphasis on early detection and

resolution of potential issues.

Food safety and maintaining high-quality standards are crucial

for both our customers and our company. These elements are

critical for safeguarding consumer health, enhancing customer

satisfaction and building trust. Our commitment to delivering

safe and reliable products is not just a regulatory requirement

but also the cornerstone of our reputation and success. Quality

management supports us to meet and exceed customer

expectations, prevent issues before they arise and maintain

the economic viability of our business.

Sustainability in Action

We navigated regulatory changes this year.

Of note are:

• Allergen Declaration Transition: In February 2024,

we transitioned to new allergen declaration

requirements on our labels. This regulatory

change was managed without any disruptions,

and we have documented this transition in our

Management of Change records.

• Food Safety System Certification (FSSC 22000),

Version 6 Transition: We also successfully

transitioned from FSSC Version 5.1 to Version 6,

with the final changes implemented in April

2024. This transition involved key updates in

labelling, food defence, food fraud mitigation,

loss, waste activities and fostering a robust food

safety and quality culture.

As we look ahead, we aim to continue to refine our

processes, embrace new technologies and uphold

the highest standards of quality and safety. Our goal

is to further enhance our quality management

system and drive customer satisfaction.

9Sustainability Report FY24 | 8| Sanford Limited

Efficiency Approach to Reduce
Carbon Emissions for Sanford’s Fleet

Accessing and undertaking fishing activities

in deepwater locations requires large vessels,

long voyages and significant quantities of energy.

Battery technology is not ready as a replacement

for liquid fuels for these uses. These vessels

represent significant invested capital, have long

lifespans, and have limited potential for transfer

to alternative or renewable energy systems.

Lags in technology development delays the

fisheries sector’s ability to transition to low

carbon fuels at scale. As a result, Sanford’s

pathway to reduce emissions across our fleet

is to initially focus on reducing fuel costs

and emissions. One significant investment in

this approach is an upgrade that has been

implemented to the San Enterprise during

dry-docking in August/September 2024.

Efficiency upgrades being delivered for the

San Enterprise include a new propeller and

thrust nozzle design. Also, the electrical system

upgrades to provide for shore power connections

(to run the ship’s systems on mains-grid electricity

rather than diesel generator when berthed at

dock) create efficiencies. Sanford acknowledges

the assistance of the Energy Efficiency and

Conservation Authority (EECA) with those

elements of the efficiency upgrades. Other

associated fuel-efficiency upgrades being

deployed are an auxiliary generator upgrade,

replacing the primary fixed-speed-drive

refrigeration compressor with a variable-speed-

drive unit and economiser which will result in a

reduction of over 30% in energy demand for the

on-board refrigeration unit.

Sanford estimates the emissions-reduction

potential from the propeller and nozzle upgrades

alone to be around 500 tCO

2

e each and every

year that the San Enterprise is fishing.

Sustainability in Action

Sanford’s Whole Value Chain Emissions

Profile – FY24 (Scopes 1, 2 and 3)*

S

c

o

p

e


1


a

n

d


2

S

c

o

p

e


3

7

8

.

3

%

2

1

.

7

%

Sanford’s Whole Value

Chain Emissions Profile

Emissions

(tCO

2

e)

%% of Whole

Value Chain

Emissions

Scope 1

Direct emissions

(includes fuel,

refrigerants from

owned assets) 53,346 21.2

Scope 2

Indirect emissions

from electricity 1,354 0.5

Scope 3

Purchased goods

and services 108,899 43.3

Capital goods

15,838 6.3

Fuel- and energy-

related activities 13,210 5.3

Upstream

transportation and

distribution (freight

paid for by Sanford) 23,382 9.3

Waste generated

from operations 1,093 0.4

Downstream

transportation and

distribution (freight

of products paid

by others) 1,403 0.6

Use of sold products

(e.g. further

processing and

cooking of seafood) 14,356 5.7

End-of-life treatment

of sold products 18,500 7.4

* Operational Scope 1 and 2 emissions, as defined by the GHG Protocol

** Tonnes of carbon dioxide equivalent

251,381 tCO

2

e** (FY24)

▼ 2.3% on FY20

Sanford’s Operational Emissions Profile

(F Y24)*

Emissions

(tCO

2

e)%%

Wildcatch

46,96585.9

Mussels

4,9669.0

Salmon

2,5474.7

Other (head office, etc.)

2220.4

* Operational Scope 1 and 2 emissions, as defined by the GHG Protocol

** Reduction on recalculated baseline emissions excluding inshore

contributions for like-for-like comparison, referenced on page 24

54,700 tCO

2

e (FY24)

▼ 12.4% on FY20**

Large-scale commercial fisheries operations are challenged

when it comes to emissions reductions.

11Sustainability Report FY24 | 10| Sanford Limited

Climate-related Disclosure
In preparing this climate statement, Sanford has applied the following adoption provisions available

under NZCS2:

• Adoption provisions 1 and 2: Current and anticipated financial impacts of climate-related risks

and opportunities.

• Adoption Provision 3: Transition planning. As required by NZ CS2, a description of progress towards

transition plan disclosure can be found within the strategy section of this statement.

• Adoption Provision 6: Comparative information for prior two reporting periods for each metric.

• Adoption Provision 7: Analysis of trends for each metric from previous reporting periods.

In reviewing this disclosure, readers are cautioned to consider the nature of changing environmental

conditions along with the scale and nature of uncertainties in the science of understanding changes to

the climate. Those climatic changes in turn lead to consequential changes within marine environments,

and further consequential changes to biological and ecological processes occurring within that

environment. The scale of the uncertainty in scientific understanding increases with each of the steps

from physical climate forecasts to marine physical responses, and then again to the ensuing biological

and ecological responses. Readers of this disclosure should consider those uncertainties when

evaluating representations.

This report contains forward-looking statements including metrics, targets and statements of future

intent. These statements necessarily involve assumptions, judgements, opinions, forecasts and

projections of the environment in which Sanford will operate in the future, each of which is subject

to levels of uncertainty. While Sanford has applied its expertise, industry knowledge and collective

experience to arrive at the conclusions and disclosures contained within this statement, these statements

are influenced by the uncertainty of the underlying assumptions, and scientific understanding of

consequential and cumulative climate factors influencing marine environments and marine biological

process. The forward-looking climate-related statements within this disclosure may therefore be less

reliable than other statements within Sanford’s other reporting. Sanford disclaims to the fullest extent

possible any liability arising from the use of this report. Nothing in this report should be inferred to be

capital growth, earnings, or any form of financial or legal guidance or advice.

This statement has been approved by the Board on behalf of Sanford Limited on 29 January 2025.

Sir Robert McLeod David Mair

Chair Managing Director

Statement of Compliance

Sanford Limited (Sanford) is a climate-reporting entity under

the Financial Markets Conduct Act 2013. This statement represents

Sanford’s first mandatory climate-related disclosure in compliance

with the Aotearoa New Zealand Climate Standards (NZCS) issued

by the External Reporting Board (XRB). Unless otherwise indicated,

data, information and commentary relate to the financial year ended

30 September 2024 (FY24), and the reporting currency is the

New Zealand Dollar (NZD).

Please refer to page 30 for the Aotearoa New Zealand Climate Standards Climate-related Disclosure

Reference Table.

1. Sanford and Climate Change

Climate change is shaping the world. It is influencing the oceans where the seafood we harvest grows,

the markets we buy goods from and sell into, and the behaviours of our customers and consumers.

With long-standing harvesting and farming operations which are reliant on the natural world, Sanford has

had to adapt its operations over time to the changing nature of the oceans and weather conditions – it’s a

part of the very nature of fishing and marine farming. However, Sanford now faces a further challenge of

more wide-reaching accelerated change and unpredictability driven by climate change. We are focused

on responding to those changes.

New Zealand seafood products, and their low emissions footprint relative to other animal proteins,

1,2,3


are well placed to be established as a low-carbon source of nutrition for the global community.

Many of our operations require 365 days per year of care, attention and attendance to ensure we make

the most of the incumbent growing conditions and maintain the assets that allow us to safely and

efficiently harvest and grow seafood. In doing so, Sanford’s teams must deal with the changes in

conditions that the weather and climate bring – our fishers and farmers have learnt over time to ensure

that their primary operations are guided by the natural environment and its changing conditions. More

recently, our teams have experienced more frequent and persistent surface-water-warming events that

have led to algae blooms, more prevalent La Niña/El Niño events affecting growing conditions, more

frequent rainfall-driven harvest closures for mussel farms, along with significant acute climatic events

causing rainfall, flooding and slips which close roads and key supply routes.

While Sanford’s teams experience, observe and adapt to weather and marine conditions and their

impacts, forecasting longer-term climate induced potential changes quickly becomes increasingly

complex within the biophysical marine domain. Forecasting fisheries- and aquaculture-related

responses to climate change is challenged by the complexity of linked and nested systems. Changing

atmospheric conditions have an impact on the oceans and seas through changes to wave conditions,

surface-water temperatures, coastal and ocean currents, and ocean chemistry. Those varied oceanic

conditions can lead to changes in marine primary production, as well as in the biological responses of

fish, shellfish and other marine ecology. Scientific understanding of climate related effects across those

nested systems (atmospheric > oceanic > marine ecological) is still evolving. Looking into the future,

those systems test and challenge existing assumptions, knowledge and expertise.

The outcome means that when Sanford looks into future scenarios, as required under the climate-related

disclosure regime, a significant level of uncertainty must be acknowledged and accepted – a level

which might be greater than for many businesses in other sectors. Sanford considers the integration

of climate change-related considerations into our business strategy as a vital and necessary step

in ensuring that we are able to continue our 150+year heritage of providing beautiful seafood to

New Zealand and the world into the future.

1.

mpi.govt.nz/dmsdocument/57172/direct

2.

mpi.govt.nz/dmsdocument/48526/direct

3.

deepwatergroup.org/the-carbon-footprint-of-nz-wild-caught-seafood/

13Sustainability Report FY24 | 12| Sanford Limited

2. Governance
Board Oversight

Sanford’s Board of Directors is responsible for the oversight of risks and opportunities for Sanford,

including those related to climate change. The Board maintains responsibility for overseeing climate

change progress, and is provided with information on material climate-related matters at regular

meetings via management reports. During FY23 and FY24, the following in-depth climate-related

discussions were held with the Board:

• June 2023 – Overview of climate science and potential effects on our marine environment; review

of Sanford’s emissions footprint and emissions-reduction target; distribution of Institute of Directors’

Climate Governance survey.

• July 2023 – Climate-related Disclosure (CRD) overview and requirements, outcomes of management’s

climate risk and opportunity prioritisation workshop, outcomes of management’s future climate

scenario analysis workshop, review of climate risk prioritisation processes and outcomes; decision

that Sanford’s governance forum for climate-related topics is to be the Board.

• November 2023 – Review and approval of voluntary climate-related disclosures as part of Annual

Report 2023.

• November 2024 – Review of climate-related disclosure processes, revision to emissions-reduction

target, review of climate-related risks and opportunities, and review of draft climate-related disclosure.

• January 2025 – Confirmation of climate-related disclosure for issuance.

Skills and Competencies of the Governance Group in Relation to Climate Change

The Board reviews its performance, composition and structure on a regular basis and, with the support

of the Nominations Committee, plans for changes in Board composition to ensure skills and experience

are suitable to achieve the Board’s strategic and functional purpose. This includes climate change skills

and competencies.

Integration of Climate-related Risks and Opportunities into Strategy

Climate events have consistently been the number one priority risk for Sanford since 2016 when we first

disclosed publicly our top 10 enterprise-level business risks. This prominence within our risk register

means that climate-related risks and opportunities are considered by management and the Board in the

development and execution of our business strategy. In setting our strategic direction and business

planning, the Board considers regular updates on climate-related risks and opportunities from

management reports (see diagram below). In turn, divisional leads provide regular updates to executives

in relation to climate-related operational impacts. These channels have provided the foundation for

climate risk management strategies to be built into our business strategy.

On an annual basis, the Board reviews business targets and ambition for the forthcoming year, along with

progress against targets for the year prior, inclusive of targets relating to climate mitigation and climate

adaptation (see Metrics and Targets section below). During FY24, the executive team and the Board had

visibility of target progress indicators for the business, updated quarterly. Due to an internal emissions

accounting system upgrade which took place during FY24, Scope 1 and 2 carbon emissions progress

indicators were only available at year end. Climate performance metrics are not currently explicitly

incorporated into our remuneration policies or incentives.

Management’s Role in Assessing and Managing Climate-related Risks and Opportunities

The Board delegates to the Managing Director (MD) responsibility to manage the business to deliver on

strategy. The MD (along with the executive team) thereby holds accountability for the inclusion and

delivery of actions relating to climate change into risk management, business planning, business

processes and capital allocation within the overall budgets and financial delegations set by the Board.

The executive team is responsible for performing analyses and preparing annual reporting of climate-

related risks and opportunities, along with the identification of associated metrics and targets. During

December 2022, management co-ordinated in-depth climate risk workshops with a wide cross-functional

team from within Sanford, together with future climate scenario analysis to highlight and review risks,

opportunities and to stress-test our business model against those future climate potentials. Management

has discretion, within the limits of approved budgets and delegated financial authority, to utilise external

expertise to support those processes.

Board and Management Responsibilities in Relation

to Climate-related Risks and Opportunities

Board

Sanford’s Board

Sets strategic direction, reviews and approves strategic goals, operational plans and budgets. Reviews risk

assessment policies and controls and establishes the appropriate levels of risk appetite, including those related

to climate change. Sets risk management framework. Reviews, endorses and monitors progress against climate-

related risks, metrics, targets and disclosure. In addition to reporting from the AFRC (see below), the Board receives

updates at each meeting (about eight per year) on key sustainability and climate change issues and trends via

management reports from the executive team. Reviews remuneration policies and incentive schemes.

Audit, Finance and Risk Committee (AFRC)

A committee of the Board established to assist the Board in fulfilling oversight responsibilities in relation to financial

management and related reporting, including the review of overall systems for risk management across Sanford,

including climate risk as appropriate.

Nominations Committee

A committee of the Board established to assist the Board in fulfilling oversight responsibilities in relation to Board

composition and structure, including in relation to sustainability and climate-related expertise.

Executive

Managing Director and Executive Team

Manages the business to deliver on strategy. Applies the risk management framework. Accountability for including

actions and commitments relating to climate change into risk management, business planning, budgeting and

business processes. Identifies and monitors climate-related risks and opportunities and provides management

reports on those risks and opportunities to the AFRC and Board. Divisional leads engage directly with executives

on the operational impacts of climate-related risks and opportunities. Executive team allocates capital towards

climate-related mitigation and responses within the overall budget set by the Board.

Promotes a positive risk awareness

culture within the business. Monitors

processes for risk reviews, and reports

the same to the AFRC and Board

as relevant.

Reviews monthly sustainability

updates which include sections

on climate change policy,

regulation, trends, and

operational impacts.

Organises, facilitates and leads

climate scenario evaluation

and climate-related risk and

opportunity workshops.

Engages third-party experts to

assist when appropriate, such

as audits, climate research and

disclosure support.

General Managers

Responsible for ensuring that climate-related impacts and risks within each business unit are managed,

monitored and escalated appropriately.

Implements and acts on risk mitigation

strategies approved by the Board, MD

and executive team.

Monitors emerging and

developing risks, including those

relating to climate. Manages risk

reporting and monitoring of

residual risk levels. Climate-

related risks primarily overseen

by the GM Sustainability with

oversight of climate-related risks

reported and monitored by the

Group Risk Manager.

Manages the collection of data

to support tracking of metrics

internally or with external

assistance. Tracks climate-

relevant research, trends

and regulation.

Operations

Operations

All Sanford’s employees are empowered to be responsible for risk management. The Sanford Enterprise Risk

Assessment Guide provides the structural guidance at the operational level around risk tolerance and

notification levels using a scaled basis (very low or low rated events notified to supervisor/manager, medium-

rated events notified to GMs and managers, high-rated events notified to executives and GMs, and extreme-

level events notified to the MD, executive and Board).

As part of ongoing operations, management tracks and monitors proxies for climate impact, such as

water temperatures and dissolved oxygen concentrations in Big Glory Bay, Greenshell mussel condition

in Pelorus Sound and other major growing areas, water quality parameters, rainfall runoff-generated

harvest closures for marine farms, and catch rates for wild harvest species. This monitoring typically

occurs monthly. Although monitoring and measurement of these parameters is currently performed as

part of normal operations, these are yet to be collated into any specific ‘climate impact’ reporting metrics.

15Sustainability Report FY24 | 14| Sanford Limited

3. Strategy
Our Business Strategy

Sanford’s vision is to be New Zealand’s seafood leader for quality, value and reputation. We are

a vertically integrated seafood business with operations across wildcatch fisheries and aquaculture.

Sanford harvests wild and farmed seafood, converts that seafood into desirable products and sends

them through a supply chain to customers nationally and internationally. We last revised our business

strategy during 2022. A description of that strategy can be found in the publicly accessible Sanford

Annual Reports for FY22 and FY23.

4

During FY24, Sanford commenced reviewing strategic priorities

with a strong focus on improving cash flows and value outcomes.

Transition Planning

Sanford continues to work towards further development of our transition plan including its integration

into the FY25 business strategy review. An emissions-reduction plan has been developed alongside

our revised emissions-reduction target and is intended to be further developed during FY25.

Current Climate Impacts

Sanford’s operational activities have been affected by the following climate-related impacts in FY24:

Current physical impacts

Acute and extreme weather impacts

• Acute and extreme weather events impact Sanford’s operations and can affect our ability to service

our customers. Although not experienced in FY24, extreme events such as the flooding and rainfall

in the Nelson-Marlborough region during August 2022 led to temporary run-off water-quality-related

harvest closures for some marine farming areas and damage to marine farm infrastructure, combined

with the temporary closure of key road networks used to transport goods, materials and staff to and

from sites in the area.

• Climate-related events are also impacting our wildcatch harvesting operations with more extreme

weather events in the Southern Ocean, reducing the available fishing days for scampi fishing vessels

in areas surrounding the Auckland Islands.

• Changes in the Antarctic ice shelf are periodically increasing marine hazards, as well as changing

seasonality for our toothfish operations.

• Flooding events have affected road connections along key supply routes for Sanford’s materials

and products.

Climate driven changes in water temperature, chemistry and quality

• A recent ‘triple-dip’ La Niña climatic pattern which persisted through 2020, 2021 and 2022 contributed

towards marine physical process changes that act to reduce phytoplankton production and/or

accelerate algae blooms in key aquaculture farming areas, thereby affecting mussel growth rates.

• Those same La Niña-related marine physical processes contributed to significant marine heatwave

conditions being present in many coastal water bodies around New Zealand over the same 2020 to

2022 time period, with corresponding effects on phytoplankton density and population structure as

well as dissolved oxygen levels in upper surface-water layers. This contributed to a slight increase

in salmon mortalities being experienced during FY22 at the Big Glory Bay salmon farm.

• These events, along with climate-related risk assessments, prompted further deployment of mitigation

approaches during FY22, FY23 and FY24 at the Big Glory Bay salmon farm. This included deploying

additional pens to reduce stocking densities, more intensive monitoring of harmful algal, and greater

deployment of aeration and oxygenation equipment to improve fish health, welfare and resilience to

stress factors aggravated by climate change.

Current transition impacts

• Our stakeholders desire for, and increasing regulation in support of, greater clarity and understanding

of climate-related impacts on operations has resulted in Sanford’s teams spending more time

reviewing, investigating and improving adaptation tools for managing climate-related impacts.

• Sanford is an indirect participant in the New Zealand Emissions Trading Scheme (ETS). Fuel suppliers

surrender ETS units on our behalf for fuel purchasing, directly impacting Sanford’s cost base.

• Cost structures for some key inputs for our business units, in particular the cost of feed ingredients

required for farmed salmon, are susceptible to variability as a consequence of climatic impacts –

even if specific core ingredient sources are not directly affected.

Looking Ahead – Scenario Analysis

Sanford undertook a climate scenario analysis exercise in 2022 of which the Board had oversight, to

assist in forecasting climate-related risks and opportunities over the short, medium and long term, as

well as to test the resilience of our business strategy and model. The initial scenario analysis process

and 2024 review are described under the Climate Risk Treatment and Integration section below.

Three future climate scenarios were analysed, each of which represents an alternative potential future

(limited warming within +2.0°C, warming >4.0°C, and a divergent net-zero scenario where warming is

limited to 1.5°C through the deployment of strict and disordered policy approaches). Selection of those

scenarios was made to (a) ensure consistency of scenario approach across the New Zealand seafood

sector, and (b) add the divergent net-zero scenario, as it represents quite a different potential future not

captured within the Aotearoa Circle scenarios, one in which a strong and divergent policy approach is

used to successfully deliver emissions reductions. Sanford did not undertake its own specific modelling

in the development of those scenarios.

The boundary for the scenario analysis was at Sanford Group level, inclusive of all entities and

subsidiaries. The assessment accounted for direct operations as well as those within our direct value

chain (one step removed from Sanford), and upstream and downstream such as direct suppliers,

partners and customers. Time horizons relevant for the analysis were discussed and agreed on by

participants during the initial workshop in light of our business processes and strategy-setting practices.

Time horizons utilised for the scenario analysis and associated climate risk and opportunity

materiality were:

Time intervalYearsRelevant business process

Short term

1 – 5 years2023 – 2027Operational planning timeframes relevant for biological cycles

such as seed to harvest planning (mussels, salmon).

Medium term

6 – 10 years2028 – 2032Sanford’s strategic goals and targets typically set over these

timeframes, i.e. to 2030. More certainty of climatic impact and

policy settings across/during these timeframes.

Long term

10+ years2032+Longer-term strategy planning. Lifespan-relevant timeframe for

significant assets such as property and vessels.

4.

sanford.co.nz/investors/reports-1/company-reports/

17Sustainability Report FY24 | 16| Sanford Limited

Climate
scenarios

Kahawai 2050

“Orderly transition”

Divergent Net Zero

“Disorderly transition”

Mako 2050

“Intense and severe

outcomes”

Scenario

definition

source

Aotearoa Circle Marine Domain

“Kahawai” scenario (seafood

sector specific)

theaotearoacircle.nz/

reports-resources/marine-

scenarios-report

Network for Greening the

Financial System “Divergent

Net Zero” scenario

data.ene.iiasa.ac.at/ngfs/

(access terms and conditions

may apply)

Aotearoa Circle Marine Domain

“Mako” scenario (seafood

sector specific)

theaotearoacircle.nz/

reports-resources/marine-

scenarios-report

Scenario

description

Kahawhai, 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 and is likely to

keep warming below 2°C over

the course of the century.

Climate-related risks are

predominantly transitional

with cascading impacts on

governance and market

structures. This scenario

favours sustainable economic

growth but there is pressure

on business for agility and

flexibility to meet evolving

consumer preferences.

Global fisheries’ abundance

declines by around 10% but

New Zealand fares better than

most, with relative stability in

marine primary production

and increased catch potential

through advances in scientific

understanding and

management of fisheries.

Divergent Net Zero scenario

reaches net-zero emissions

around 2050 but with higher

transition costs due to

divergent policies being

introduced across sectors

leading to a rapid phase-out of

oil use. Climate-related risks

are dominated by transitional

events with substantial

carry-through to governance,

markets, and consumer

behaviour. Economic impacts

(modelled via GDP) are

significant and severe,

especially in the near-term.

Carbon price impacts are

severe but not equal across

all sectors. Fisheries’ resources

decline globally, but

New Zealand fares better

than most. Due to lagging

technology and long-life assets

in the marine sector, fisheries

and marine aquaculture

remain largely reliant on

fossil-energy sources and are

thereby affected more than

most by carbon price impacts

and adverse sentiment.

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.

Climate-related risks are

predominantly physical with

cascading economic and

market impacts. This scenario

constrains adaptive resilience

in the face of deteriorating

marine ecosystems due to

weak global co-operation.

Fisheries operators must spend

a longer time at sea, travel

further, and incur greater

energy effort to harvest

fisheries. Warm-water species

begin migrating south

intermittently, while some

treasured inshore species

extend towards the south too

– with associated changes in

commercial fisheries’

allocations derived from quota.

Despite biological challenges,

food production is prioritised

by governments and many

regulatory roadblocks are

removed as nations seek to

shore-up food supplies. Marine

GO-engineering efforts are

underway as attempts to

weaken the level of warming

grow. Business resilience

planning becomes increasingly

necessary to secure affordable

capital from financiers.

Scenario analysis

end point

20502050, Net Zero2050

Climate policy

Immediate, smooth,

predictable

Strict and disorderedLagging, absent and/or

ineffective

2050 carbon

price estimate

(USD2010/tCO

2

e)

USD180USD700USD55

Climate

scenarios

Kahawai 2050

“Orderly transition”

Divergent Net Zero

“Disorderly transition”

Mako 2050

“Intense and severe

outcomes”

Transition risk

severity

(technology

and policy)

ModerateHighLow

Physical risk

severity

Low – mediumMedium – highExtreme

Representative

Concentration

Pathway (RCP)/

Shared

Socioeconomic

Pathway (SSP)

RCP 2.6

SSP 1

RCP 2.6

SSP 2

RCP 8.5

SSP 3

Global warming

average

<2

o

C1.5

o

C>=4

o

C

Climate impacts

(to 2050)

+0.7

o

C air temperature+0.7

o

C air temperature+1.0

o

C air temperature

Global population

(2050)

~8.5b~11.0b

Marine

biophysical

impacts

(to 2050)

+0.8

o

C coastal sea-surface

temperature

+0.8

o

C coastal sea-surface

temperature

+1.5

o

C coastal sea-surface

temperature

+0.23 m sea-level rise+0.20 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 oxygenNot specified in scenario

definition. For scenario analysis

purposes, physical marine and

fishery impacts assumed to be

consistent with the “Kahawai”

scenario.

2% decline in dissolved oxygen

Fishery

production

Net global reduction in primary

production (-2%). Some

fluctuation in species

distributions, some of which

impact fisheries management

Net global reduction in marine

primary production (-5%).

Greater uncertainty in fishery

stock location, migration, and

biological responses

NZ resource

and fishery

management

Regulation becomes more

flexible or makes use of

existing settings to allow for

flexibility (variation in catch,

addition of new species).

Decisions with high near-term

costs are taken to improve

long-term sustainability and

resilience.

Reactive responses by fishery

managers to changing

circumstances. Initial public

distrust and reduced

reputation give way to support

for primary sectors and their

role in national food security

and self-sufficiency.

Global

production in

seafood sector

124 MT Aquaculture

71 MT Fisheries

n/a160 MT Aquaculture

80 MT Fisheries

Climate Scenarios

Assumption on carbon sequestration from afforestation and nature-based solutions are not included.

19Sustainability Report FY24 | 18| Sanford Limited

Priority risk and
opportunity

Scenario descriptionKahawai 2050DivergentMako 2050Anticipated impact*Anticipated impact*Management responses Management responses

identified to dateidentified to date

Time horizon

ShortMed.LongShortMed.LongShortMed.Long

PHYSICAL

Risk

More frequent and severe

extreme weather events

impacting Sanford’s ability to

conduct operations and

service customers

Increased rainfall-related mussel harvest

closures, increases in weather-related

‘non-fishing’ days

Supply chain disruption (road closures,

flooding etc.) delay production and

customer deliveries

• Strategic allocation of geographically

diverse farm locations and quota

holdings

• Strategic investment in R&D, and

facilities for climate-resilient seed stock

for farms (e.g. SPATNZ)

• Direct monitoring of climate-relevant

water variables in key growing locations

• Allocation of capital towards climate

mitigation initiatives such as aeration

plant at Big Glory Bay

• Participation in sector-wide climate

adaptation pathway planning initiatives

via Aotearoa Circle

• Planned (FY25+) review of business

processes for capital expenditure to

provide structural response to reduce

climate risks and impact

• Recognition of the need for future

strategic response to identified

regulatory risks and anticipated

impacts on market preferences

Risk and/or

opportunity

Shifts in the distribution or

production capacity of

wildcatch fisheries due to

chronic climate-driven forces

Catch entitlement adjustment

(up or down)

Changed spawning behaviour or

success (positive and/or negative)

Increased by-catch rates

Risk

Adverse changes in water

temperature, chemistry and

quality, impacting the welfare

and/or productivity of farmed

species

SalmonSalmonSalmon

Increases in mortality

Changes (positive and negative)

in growth rates

Increased susceptibility of fish to

disease or stressors

MusselsMusselsMussels

Increased biofouling on shell and

on grow-out lines

Reduction in wild spat availability

and seed retention

TRANSITIONAL

Risk

Current and emerging

climate-related regulation

of the seafood sector

Increased compliance costs impacting

bottom line

Reduced operational flexibility (geography

and procedurally) leads to productivity

decline

Risk

Increased operational

costs due to climate-related

effects on core operational

inputs (e.g. fuel, packaging,

salmon feed)

Margins pressure as costs flow through

to sales expectation. Potential to lose

competitiveness in international markets

Fishing vessels spend more time tied up

(reduced asset utilisation if fuel costs rise

and cannot be passed on)

Risk and/or

opportunity

Changing consumer

preferences around

seafood and subsequent

impacts on the market

Changed demand for seafood (increase

for low-carbon foods, decrease for sectors

perceived as lagging in transition) – both

of which are applicable for seafood

Alternative proteins (cell culture or

similar) challenge traditional proteins

in marketplace

Climate-related Risks and Opportunities

During scenario analysis workshops, participants prioritised climate-related risks and opportunities

from an initial long list developed during an earlier workshop. To assess the materiality of these risks

and opportunities, the workshop utilised Sanford’s Risk Assessment Guide (SRAG) to allocate High,

Moderate or Low materiality ratings across each time horizon and scenario. The results of this activity

are shown in the table below.

Key

RatingActionSanford’s Risk Assessment Guide equivalence (2022)

High

Highest priority for management effortsExtreme

Moderate

Should be closely monitoredHigh

Low

Requires a level of monitoringLow

* In the absence of mitigation

Table 1: Climate-related risk and opportunities

Sanford integrates sustainability considerations into our capital expenditure decisions where relevant.

For example, we evaluated new hybrid diesel-electric propellers as part of upgrading our fishing fleet

and implemented oxygenation and aeration enhancements on our salmon farms.

21Sustainability Report FY24 | 20| Sanford Limited

4. Sanford Risk Management Processes
Risk management is directed and governed via Sanford’s Enterprise Risk Management Policy

and Enterprise Risk Management Framework, which are aligned with the ISO 31000:2018

Risk Management Guidelines. The Policy covers all value chain activities and requires that our

risk management processes consider all internal and external stakeholders that have an impact

on our operations. Sanford’s Risk Management Process (Figure 1 below) aims to support the

achievement of business objectives while also maintaining compliance with legal and regulatory

obligations. Our risk management approach follows a decentralised structure, where individual functions

and divisions are directly responsible for their own risk management, with the Group Risk Manager

co-ordinating internal communication of risks and maintaining the risk register, and the Board

of Directors being responsible at the enterprise level. The Group Risk Manager role is currently held

by the General Counsel.

Our risk management processes utilise Sanford’s Risk Register and Risk Criteria Guide which

defines the tools to assess the scope, size and impact of risks for our business. The criteria utilise a

‘Risk = Likelihood x Impact’ approach, where standard definitions are identified for impact (across five

impact categories from negligible to extreme, with example impacts per category being defined across

the following domains: assets, customer, environment, financial, health/safety, projects, legal, operations,

people, reputation and technology) and also for likelihood (across five categories ranging from ‘rare’ to

‘almost certain’).

Risk Management Process

Establish the content

Monitor and Review

Communicate and Consult

Identify risks

Treat risks

Assess risks

(Analyse and evaluate risks)

Climate Risk Treatment and Integration

Sanford’s initial climate risk prioritisation and scenario analysis process was performed as a stand-alone

exercise during late calendar year 2022, and involved a wide cross-functional and diverse group of

senior leaders within Sanford and consisted of two workshops facilitated by external specialists (Beca).

Specialists from across our executive team, operations, finance, communications, people, fisheries

science, and supply chain functions contributed to the process.

Risks were identified during initial workshops in late 2022, and then reviewed during 2024 against

Sanford’s Risk Criteria Guide (as described above):

• Risk Prioritisation Workshop – 28 November 2022. Identification of the highest-ranked priority risks

and opportunities

• Climate Scenario Analysis Workshop – 12 December 2022. Testing of the six-highest ranked priority

risks and opportunities under Sanford’s three future climate scenarios

• Reviews of risk ratings and criteria – 07 to 15 May 2024. Review of climate risk descriptions, ratings,

mitigations and metrics by operations leads for select risks.

We anticipate to review our Risk Management Process for climate-related risks on an annual basis.

To focus efforts towards the most material climate-related risks and opportunities, following the

prioritisation process, the three top-ranked physical and transitional climate-related risks/opportunities

respectively were selected for further consideration in terms of response, remediation and mitigation.

The specific risks and opportunities are shown in Table 1: Climate-related risks and opportunities, per

pages 20-21. Those priority climate risks, along with responses and mitigations, are reviewed on a

yearly basis.

Climate risks are integrated within the enterprise-wide Risk Register collectively. Climate risks are

aggregated as a single representative risk and then prioritised alongside the other (non-climate-related)

enterprise risks. Climate risk is currently the number one ranked risk on Sanford’s enterprise-wide

Risk Register. The top 10 enterprise risks are reported to, reviewed, and rankings/responses discussed

by the Board at least annually.

To identify climate-related risks, Sanford’s teams employ the following tools and methods:

• Active monitoring of water quality conditions (temperatures, dissolved oxygen, algal populations)

at salmon aquaculture sites

• Shellfish monitoring programmes to review shellfish condition

• Monitoring climate-driven growth and yield forecasts for salmon and mussels

• Regularly review fisheries’ harvests, catch per unit effort, by-catch rates, weather-related delays,

and fuel costs to optimise operations.

Figure 1. Risk Management Process. (Source: Sanford Enterprise Risk Management Framework, November 2023).

23Sustainability Report FY24 | 22| Sanford Limited

ScopeCategoryFY24FY23Base year
FY20

1

Direct emissions (fuel, refrigerants) (tCO

2

e)53,346 56,16559,999

2

Indirect emissions from electricity, location based (tCO

2

e)1,3541,4932,423

3

Indirect emissions from value chain, upstream and downstream

(tCO

2

e) (measured Scope 3 categories described below)

196,681184,386194,774

Sanford’s Group intensity metrics*

Scopes 1, 2 and 3 emissions per $ revenue (tCO

2

e/thousand$)0.500.470.63

Scopes 1, 2, and 3 emissions per greenweight tonne (GWT)

harvested (tCO

2

e/tonnes GWT)

2.312.352.31

Scopes 1 and 2 emissions per GWT harvested (tCO

2

e/tonnes GWT)0.910.870.85

Wildcatch division intensity metrics

Scope 1 and 2 emissions per GWT harvested (tCO

2

e/tonnes GWT)1.611.431.49

Mussels division intensity metrics

Scope 1 and 2 emissions per GWT harvested (tCO

2

e/tonnes GWT)0.190.190.18

Salmon division intensity metrics

Scope 1 and 2 emissions per GWT harvested (tCO

2

e/tonnes GWT)0.500.600.46

Details and Assumptions in GHG Inventory

We measure our impact and emissions in accordance with Sanford’s GHG Reporting Policy, which

follows the GHG Protocol. Key details from that policy are shown in the table below:

* FY20 - Base-year emissions were audited by Toitū Envirocare and represents actual emissions, noting the adjustments to the base year data as

detailed below. These adjustments ensure like-for-like comparison across the disclosed years.

FY20 to FY23 emission, revenue and harvest data has been adjusted to exclude a material business change being the sale of the inshore business

in FY23. Sanford retains the inshore related quota shares and leases the Annual Catch Entitlement (ACE) going forward (further information is

disclosed in the FY24 Annual Report at note 20).

Sanford Group’s harvest represents total harvest (excluding inshore harvest) from Sanford and third parties’ harvesting under Sanford’s quota

or contract; this data therefore includes fishing partner harvest tonnage.

Wildcatch intensity (Scope 1 and 2) for fishing operations (excluding the inshore business) are based on GWT caught by Sanford-owned vessels

and processed at sea or at Sanford’s land-based operations.

Mussels’ intensity (Scope 1 and 2) for farming operations based on GWT harvested by Sanford-owned vessels and Sanford’s mussel processing sites.

Our systems do not have the full capability to itemise all Scope 3 emissions categories by business division; accordingly, Scope 3 emissions are

included in the Group intensity metrics only.

5. Metrics and Targets

Greenhouse Gas Emissions:

DetailApproach, assumption, basis

Annual measurement period

01 October to 30 September, following our financial year cycle

Base emissions measurement

year

FY20: 01 October 2019 to 30 September 2020

Base-year assurance

FY20 emissions assurance provided by Toitū Envirocare following ISO 14064-1

assurance standard

Base-year recalculation

approach

The following events shall trigger a recalculation of the FY20 base year to ensure like-for-

like comparisons: structural changes to our business, substantial changes by third parties

to emissions factors, or discovery of significant errors or a number of cumulative errors that

exceed a 5% materiality threshold. Organic growth or decline does not trigger recalculation.

Base-year recalculation

At the conclusion of FY23, Sanford’s direct North Island inshore operations ceased

with two vessels being sold along with the rights to fish for a period of 10 years.

That constituted a material change to the business as defined by Sanford’s base-year

recalculation approach. The emissions associated with these operations essentially

moved from Sanford’s Scope 1 and 2 emissions to Scope 3 category 13 emissions.

Consolidation approach

Operational control basis, as defined by the GHG Protocol

Organisational boundaries

All of Sanford’s New Zealand and Australian operations, including joint ventures and

investments. Sanford’s GHG inventory covers all direct (Scope 1 and 2) and material indirect

(Scope 3) emissions categories – see definition below for the Scope 3 emissions boundary.

Exclusions

The following entities, which Sanford had an interest in during the period, are excluded from

our GHG emissions inventory: Two Islands Co NZ Limited (50% ownership, sold during

FY24), Barnes Oysters Limited (14.29% ownership), Primestone Nominees (75% ownership,

closed during FY23), New Zealand Japan Tuna Company Limited (46.74% ownership), Area

B Compliance Limited (26.9% ownership), Bluff Oyster Management Company Limited

(15.79% ownership), Sugarloaf Port Company Limited (12.19% ownership).

Data quality and uncertainties

Sanford utilises the BraveGen tool for emissions inventory collation and reporting.

All activity data is reliant on supplier invoice accuracy and other data input. Ultimate

emissions data is the result of both those input data and the source uncertainty of, and

system input of, external emissions factors and spend-based factors. Sanford self-

assesses the data sources for quality as follows: High – actual usage data from supplier

or internal systems; Medium – a mixture of actual data activity and data estimations; and

Low – high use of estimates and assumptions. Sanford’s emissions data is assessed as

follows: Scope 1 and 2 data quality – High, Scope 3 data quality – Low.

Scope 3 emissions boundary

Scope 3 emissions GHG Protocol categories are screened (last screening FY21)

and subject to a 1% materiality threshold measured across all Scope 3 categories.

This resulted in Scope 3 categories C1, C2, C3, C4, C5, C9, C11 and C12 being deemed

material categories (and all others being deemed immaterial categories). C15 is included

as it represented joint-venture North Island Mussel Ltd operations during FY24.

A cumulative exclusion threshold for Scope 3 is set at 5% (the cumulative exclusions

do not exceed this value).

Emissions factors

Emissions factors used in Sanford’s inventory are based on the latest information

deployed within the third-party-maintained BraveGen software system’s emission factor

library which utilises those available from:

New Zealand Ministry for the Environment

DEFRA (Department for Environment, Food, and Rural Affairs, UK)

Auckland Council spend-based factors (consumption emissions modelling)

National Greenhouse Account factors (Australian National Greenhouse Accounts

Factors (dcceew.gov.au))

California Air Resources Board (arb.ca.gov/resources/documents/high-gwp-refrigerants).

And in the absence of those, relevant sector information is utilised.

For key emissions-intensive suppliers’ specific emissions, factors direct from suppliers’

own data, analysis, and life-cycle assessment studies are utilised.

Emissions factors use the Global Warming Potential (GWP100) basis unless otherwise listed.

Gases included in inventory

All Kyoto Protocol greenhouse gasses: CO

2

, CH

4

, N

2

O, HFCs, PFCs, SF

6

.

Recalculations implemented

in FY24

Scope 3 category 1 component contractor vessel fuel calculation approach changed for

FY24 based on greenweight caught by these vessels and emissions-intensity EU standard

(Energy transition of fishing fleets: Opportunities and challenges for developing countries).

25Sustainability Report FY24 | 24| Sanford Limited

Climate Metrics
Business activities vulnerable to physical and transition risks

Sanford has assessed that, given the nature of our business, collectively, and in the absence of mitigation:

up to 100% of our business activities are vulnerable to the climate-related physical risks identified

above; and up to 100% of our business activities are also vulnerable to the transition risks identified.

Capital deployment towards climate-related risks and opportunities

During FY24, Sanford continued it’s investment in equipment and systems to reduce some of the

identified climate-related risks, including implementing oxygenation and aeration systems at Big Glory

Bay to improve the resilience of salmon during periods of challenging water-quality conditions,

pen-cleaning machinery to improve through-pen water flows, and fuel-efficiency upgrades for the

San Enterprise deepwater fishing vessel. The total amount of spend across these initiatives during FY24

was NZ $3.3 million.

Business activities aligned with climate-related opportunities

Two climate-related opportunities are identified in the priority risk and opportunity table (see pages

20-21), being ‘shifts in the distribution or production capacity of wildcatch fisheries’ (which may be a

risk and/or an opportunity, applicable for the wildcatch segment) and ‘changing consumer preferences

around seafood’ (which may be a risk and/or an opportunity applicable to the entirety of Sanford’s

product portfolio). In the case of fisheries’ stocks, scientific understanding is not yet developed to a

sufficient level to identify the quantum of shift for each specific fishery. However, in an overall sense

New Zealand fisheries stocks are likely to be in a better position than global peers due to geographic

location benefits where displaced cold-water species are replaced by other warm-water species.

5


It is currently not possible to determine a percentage of activity aligned with this opportunity, within

our available data, but we are looking to improve this over the course of FY25.

In the case of changing consumer preferences towards seafood, this increases in demand for low-carbon

nutrition and protein represent an opportunity for seafood (per benchmaking in life-cycle assessment

studies). While significant barriers for further emissions reductions for the sector (technology, asset

lifespan, geographies etc.) represent a similar scale of downside risk towards consumer preferences.

Accordingly, 100% of Sanford’s activities are considered as aligned with that opportunity, although there

is an equivalent level of business risk present also. Over time, and as consumer behaviours in this space

develop, Sanford anticipates that it will be possible to refine both the opportunity and risk profile towards

a greater level of precision.

Other metrics

Sanford does not utilise an internal emissions pricing schedule at present, and management

remuneration is not linked to climate-related risk.

Ta r g e t s

In our 2023 Annual Report, we disclosed three climate-related targets:

• Reduction of 25% absolute Scope 1 and 2 emissions by FY30 from a FY20 baseline

• Deliver on six business projects in support of emissions reductions in FY24

• Implement seven climate-adaptation measures and projects within the business in FY24

(six internal, one external).

Progress Towards Targets in FY24

5.

Cheung W et al., 2019. Future scenarios and projections for fisheries on the high seas under a changing climate.

IIED Working Paper. IIED London.

6.

NZX, New Zealand’s Exchange Announcement Overview

Target for FY24Progress in FY24

Reduction of 25%

absolute Scope 1 and 2

emissions by FY30 from

a FY20 baseline

Achieved to date

Sanford achieved a 12.4% reduction in absolute Scope 1 and 2 emissions in FY24 relative to

an adjusted FY20 baseline. A number of projects contributed to this significant reduction, such

as efficiency upgrades on deepwater vessels, transition to plug-in hybrid electric vehicle fleet,

and phasing of coal use.

The FY20 baseline and subsequent years were adjusted for the purposes of target measurement

for FY24 to remove the contributions from the North Island inshore fishery assets, which were

sold at the commencement of FY24 as part of the Moana transaction.

6

The adjustment is made

to ensure ‘like for like’ year-on-year comparisons following material business changes.

The FY30 emissions-reduction target has been reviewed during FY24 and replaced with a new

intensity-based target (see below).

Deliver on six business

projects in support of

emissions reductions

in FY24

Achieved

During FY24, Sanford delivered the following projects in support of emissions reductions across

the business:

• Completed San Enterprise deepwater vessel fuel-efficiency upgrade works

• Achieved an on-time and on-budget status for new diesel-electric Scampi vessel build project

(San Koura Rangi)

• Delivered a hybrid (with battery energy storage) feed barge to Big Glory Bay salmon farm

• Upgraded generators and compressors used for aeration and oxygenation support at

Big Glory Bay salmon farm to more fuel-efficient models

• Upgraded and rolled out a business-wide emissions measurement software system

• Engaged with fuel suppliers and marine-sector participants on future marine fuels collaborations.

Seven climate-

adaptation measures

and projects

implemented and

completed within the

business in FY24

(six internal,

one external)

Partially Achieved

During FY24, the following business-adaptation projects were implemented and completed:

• Integration of climate risk planning into Sanford’s overall Enterprise Risk Management

frameworks

• Contribution towards the completion and implementation of seafood sector-wide climate-

adaptation pathways. Facilitated by the Aotearoa Circle, this project resulted in the

implementation of climate-adaptation pathways for the deepwater trawl wildcatch,

salmon aquaculture, and mussel aquaculture sectors

• Review of emissions factors utilised within Sanford’s emissions reporting software

and accounting system to ensure all factors use the same Global Warming Potential

(GWP100) basis

• Review and determination of percentage of business activities vulnerable to climate-related

risks and opportunities for climate-related disclosure purposes.

The following business-adaptation projects were partially (not fully) achieved during FY24:

• Review of internal capital expenditure processes and systems to account for climate risks

• Completion of a climate transition plan for Sanford (this is now anticipated to occur during

FY25). Sanford made progress towards its transition plan in FY24, including developing

its emissions-reductions plan and revised emissions-reduction target

• Determination of the current and anticipated financial impacts of climate-related risks

and opportunities.

27Sustainability Report FY24 | 26| Sanford Limited

2030 Emission-reduction Target
Sanford has reviewed and replaced its absolute Scope 1 and 2 GHG emission-reduction target during

FY24. This revision has been prompted by changes in a combination of internal and external factors and

assumptions which supported the prior target. It has become apparent that in setting the prior target,

some key assumptions – including those relating to the domestic availability and cost of sustainable

marine fuels (blendable, drop-in-diesel replacements), and policy settings to support these – are

unlikely to be realised before the FY30 target date. Sanford is also anticipating volume growth which

means an absolute emissions reduction target will be difficult to achieve. Accordingly, the earlier

absolute reduction FY30 target is no longer considered viable. As a result, we have adopted a new

intensity-reduction FY30 target as follows:

• >=5% reduction in GHG intensity (tCO

2

e / greenweight tonne harvested) for Scope 1 and 2 GHG

emissions by FY30 from a FY20 baseline.

Sanford considers it is important to retain an intensity-reduction target, because, although Sanford’s

absolute Scope 1 and 2 emissions had reduced by 12.4% in FY24 compared to the FY20 baseline

(excluding inshore contributions) Sanford’s FY24 Scope 1 and 2 emissions intensity (tCO

2

e/GWT)

increased by 7% compared to the FY20 base. We experience an increase in Scope 1 and 2 emissions

intensity per greenweight tonne relative to FY20 in each of FY21, FY22 and FY23 as harvest activity in

both the wildcatch and mussels divisions reduced. During FY24, harvest activity decreased due to lease

of inshore Annual Catch Entitlement as did the year-on-year absolute Scope 1 and 2 emissions (Figure 2).

Sanford’s modelling for the updated intensity target assumes some limited harvest volume growth across

aquaculture operations and relatively unchanged harvest volumes compared to prior periods for the

wildcatch division, as well as successful deployment of energy-efficiency projects across the business.

In the absence of an applicable Science Based Targets initiative (SBTi) sector pathway which

appropriately covers the fisheries and aquaculture sectors,


Sanford does not currently consider

that our target is able to be referenced with a pathway which limits global warming to 1.5

o

C. In addition

the lack of an applicable sector pathway, is due to:

• The nature of more than 85% of Sanford’s Scope 1 and 2 emissions being ‘hard to abate’ (i.e. those

emissions derived from high capital value and long-life assets, where technological decarbonisation

solutions are lagging – e.g. large deepwater fishing vessels).

• The existing lack of policy support, logistics and infrastructure for domestic and price-competitive

sustainable marine fuel deployment in New Zealand at scale prior to FY30.

Sanford’s emissions-reduction pathway does not currently assume the use of offsets.

Progress towards achieving our revised GHG emissions-reduction target is indicated below:

The trend showing Sanford’s whole value-chain emissions intensity based on economic output ($ revenue)

is indicated below:

Sanford has been successful at gaining value from the harvest, leading to a reduction in Scopes 1, 2

and 3 emissions intensity per $ revenue from FY20 to FY23. However, in FY24, the increase in intensity

reflected a growth in Scope 3 emissions (Figure 3). Sanford’s challenge is to ensure the deployment of

efficiency projects, fuel changes and behavioural change projects internally to deliver further emissions

reductions as the harvested GWT grows.

Key risks that have potential to affect our ability to reduce emissions effectively and achieve our new

intensity target include:

• Volume growth through production efficiency gains in the mussels and salmon sectors to deliver

lower Scope 1 and 2 emissions intensity across the portfolio of seafood – risks to that growth include

hatchery production and associated biological system performance.

• Sanford’s pathway requires that emissions mitigation actions are taken, such as efficiency

improvement projects like recent propeller and nozzle upgrades, auxiliary generator upgrades,

and boiler enhancements on some of our largest deepwater vessels. The availability and cost of

finance to fund these projects represent a risk to achieving the target.

• ‘Hard to abate’ emissions from our vessel fleet dominate Sanford’s Scope 1 emissions profile.

Figure 2: Graph showing progress against absolute emissions and Sanford’s revised GHG emissions-intensity target

10,000

20,000

30,000

40,000

50,000

60,000

0.04

0.06

1.00

0.08

Absolute Scope 1 and 2 emissions (tCO

2

e)

Excluding inshore business

Emissions intensity (tCO

2

e/GWT)

FY20FY21FY22FY23FY24FY25FY26FY27FY28FY29FY30

-12.4% reduction

on FY20 absolute emissions

Intensity target -5%

Absolute Scope 1 and 2 emissions (tCO

2

e)

Scope 1 and 2 emissions intensity (tCO

2

e/GWT)

0.35

0.40

0.45

0.50

0.55

0.60

0.65

Emissions intensity (tCO

2

e/$000's revenue)

FY20FY21FY22FY23FY24

Figure 3: Graph showing Scopes 1, 2 and 3 emissions intensity per sales revenue

Scopes 1, 2 and 3 emissions intensity (excluding inshore business)

29Sustainability Report FY24 | 28| Sanford Limited

Aotearoa New Zealand Climate Standards (NZ CS1, CS2 and CS3)
Disclosure Reference Table

ObjectiveCategory Page Reference in Report

Governance6-7. Disclosures

8. Governance body oversight

9. Management’s role

14-15

14-15

14-15

Strategy10. Disclosure objective

11. Disclosures

12. Current impacts and financial impacts

13. Scenario analysis undertaken

14. Climate related risks and opportunities

15. Anticipated impacts and financial impacts

16. Transition plan aspects of its strategy

16-17

16-17

16, 17, 24, 26

18-19

20-21

17

16

Risk management17. Disclosure objective

18. Disclosures

19. Disclosures

15, 22, 23

15, 22, 23

15, 22, 23

Metrics and targets20. Disclosure objective

21. Disclosures

22. Metric categories

23. Targets

24. GHG emissions

24-29

24-29

24-29

24-29

24-29

Assurance of GHG

emissions

25 and 26. Assurance of GHG emissionsN/A prior to 27th Oct 2024 requirement

NZ CS 3 Requirements40-42. Comparative metrics

44-46. Consistency

47-50. Restatement of comparatives

49. Methods and assumptions and data and

estimation uncertainty

51. Scenario analysis methods and assumptions

52-54. GHG emissions methods, assumptions, and

estimation uncertainty

24

24

17


17

17-21


24-25

55-56. Statement of compliance12

30| Sanford Limited

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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