CDI 2024 Climate Statement (re-release)

CDL Investments New Zealand Limited | 1

CLIMATE
STATEMENT
2024
Prestons Park, Marshlands, Christchurch

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INTRODUCTION
Company Overview
Statement of Compliance
Disclaimer
3
3
3
GOVERNANCE
Board of Directors
Overview of Governance and Management
Appropriate Skills and Competencies
4
5
5
STRATEGY
Current Climate Impacts
Current Transition Impacts
Current Physical Impacts
Current Climate-Related Financial Impacts
Climate Risk Management
Scenario Analysis
Time Frames
Climate-Related Risk And Opportunities
Integration into Overall Risk Management Process
Transition Planning
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6
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7
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10
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METRICS AND TARGETS
Greenhouse Gas Emissions
Assurance of GHG Emissions
Greenhouse Gas Reduction Target
Risk and Opportunity Exposure
Internal Metrics
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13
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APPENDICES
Appendix 1: Risk Assessment Methodology
Appendix 2: Climate Scenarios
Appendix 3: Risk and Opportunities Register
Appendix 4: Greenhouse Gas Inventory
Appendix 5: KPMG Limited Assurance
Appendix 6: Toit
ū Certification
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18
22
30
36
CONTENTS
COMPANY OVERVIEW
CDL Investments New Zealand Limited (referred to hereon as CDI) has been
developing residential sections across New Zealand for nearly three decades.
Recognising the challenges posed by climate change, CDI continually reviews
its operations and those of its contractors to implement climate-positive
practices, promoting the development of sustainable communities.
CDI published its first mandatory climate-related disclosures in FY23 in
alignment with the Aotearoa New Zealand Climate Standards (NZ CS) issued
by the External Reporting Board (XRB). While the XRB’s standards require
entities to disclose how they identify, assess, and manage climate-related
risks, they do not mandate specific internal risk management requirements.
This has given CDI the flexibility to develop a risk management approach that
integrates climate risk into CDI’s risk management processes and procedures
to align with CDI pursuing sustainability in its business strategy.
DISCLAIMER
The statements within this Climate Statement are published by CDL
Investments NZ Limited (hereon referred to as CDI) on their website
1
on 29th
April, 2025, for the climate-related disclosures period of 1 January 2024 to
31st December 2024. The Statement outlines CDI’s strategy for developing
scenario analyses, its understanding of and response to climate-related risks
and opportunities, and its current and anticipated impacts from climate
change. Climate change presents an ongoing challenge, characterised by
changing and significant risks and uncertainties and these are expected to
develop over time. The Statement includes estimates and assumptions about
future changes driven by climate change and their potential impacts on the
CDI business. These estimates and assumptions rely on early and evolving
assessments of present and forward-looking information, statements and
opinions, such as climate-related scenarios, science- based and industry-
based targets, and forecasts, all of which include uncertainties about CDI’s
future strategies and its operating environment and how it will transition to
a more climate-resilient future.
The above-mentioned risks and opportunities could cause results,
performance or events to differ materially from those expressed or implied
in the Statement. Factors outside of CDI control, such as changes to general
economic and political conditions, technological, governmental, consumer,
and market factors, may also impact actual results, performance or
achievement of stated climate-related targets, metrics and aspirations.
CDI has made every effort to provide a reasonable basis for these forward-
looking statements and is committed to developing its strategic response
to a changing climate. However it gives no representation, guarantee,
warranty or other assurance about outcomes expressed or implied and
actual outcomes may differ. The following Statement is for information
purposes only and nothing in this report should be interpreted as financial,
legal, tax or other advice or guidance.
INTRODUCTION
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES
Adoption Provision 2Anticipated financial impacts
Adoption Provision 4Scope 3 GHG emissions
Adoption Provision 7Analysis of trends
Adoption Provision 8Scope 3 GHG emissions assurance
STATEMENT OF COMPLIANCE
CDI is a climate-reporting entity under the Financial Markets Conduct Act
2013. This Climate Statement has been prepared in compliance with the
Aotearoa New Zealand Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3)
published by XRB in December 2022. CDI has elected to use the following
NZ CS 2 adoption provisions:
Reference
1. https://cdlinvestments.co.nz/corporate_profile/
DESLEIGH JAMESON
INDEPENDENT DIRECTOR
BOARD CHAIR
JANIE ELR
ICK
INDEPENDENT DIRECTOR
AUDIT COMMITTEE CHAIR
Highlands Drive, Richmond, Tasman District
Land Acquisition
Land Development
Commercial
Planning and ConsentsConstruction
DesignConsentingBuildAsset Management
Compliance and TitlingSales
CDI Value Chain
28th April 2025

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GOVERNANCE
Reference
2. CDI’s Constitution specifies a minimum number of three directors and a maximum
number of nine directors at any one time. Two directors must ordinarily be living in
New Zealand. In line with the NZX Main Board Listing Rules, CDI is required to have
at least two Independent Directors.
APPROPRIATE SKILLS AND COMPETENCIES
CDI’s Board does not currently have a director with specialist knowledge
of climate issues although several directors are aware of sustainability
frameworks. To expand its knowledge, a workshop with Toit
ū Envirocare
was held in 2023 to provide the Audit Committee with a better understanding
of climate risks and opportunities. The Board believes that it has a
sufficient number of directors who have knowledge and experience of risk
management generally and who are able to assess and deal with risk and
risk management.
Engagement with consulting firm WSP New Zealand Limited (referred to
hereon as WSP) has also allowed for further upskilling through workshops
dedicated to CDI-specific risks and opportunities (refer to appendix 3).
In FY24, CDI on-boarded a Sustainability Advisor to support with preparing,
monitoring, assessing and reducing the potential impact that CDI’s
activity may have on the climate and wider environment. As a team,
CDI's Sustainability Advisor, Development Managers, General Manager
and CEO will:
• Monitor and assess climate and environmental impact
• Report on impacts and progress against sustainability targets
• Manage and implement the sustainability strategy
and associated goals and targets
CDI’s sustainability advisor will also provide feedback and workshops
for the CDI governance bodies specific to CDI’s operations during FY25
to increase competency across the Company.
Photo
BOARD OF DIRECTORS
CDI Board of Directors is the governing body responsible for oversight of
climate-related risks and opportunities for CDI. Along with Management,
their role in assessing and managing risks and opportunities is as follows:
• CDIs Board has ultimate responsibility for overseeing the management
of risks and opportunities, including those that are climate-related
• The Board of CDI is committed to integration of Sustainability
across key aspects of its business
• The Board as a whole has oversight of the current sustainability
strategy and identifying issues relating to ESG. The Board oversees
progress against CDI climate-related goals and ensure measurement
and progress against targets
• For FY24, climate-related risks and opportunities are considered
in future decision making and forming of the sustainability strategy
Governing BodyDescriptionProcesses Around Informing Governing Body
Board Responsible for oversight of climate-related risks and opportunities for CDI.
This includes management of reviewing performance against sustainability
strategy and targets.
2
Board meetings are generally held quarterly, with additional
meetings convened when required.
Audit committeeSupports the Board in carrying out responsibilities and assists the Board by
considering various business risks. The Audit Committee is comprised with a
majority of Independent Directors and has an Independent Director (who is
not the Board Chair) as Chair.
The Audit Committee meets at least twice a year and its
proceedings are reported back to the Board.
ManagementTeam responsible for day-to day management of CDI operations and
implementation of CDI strategy. This includes identifying climate-related
risks, and materiality and scenario analysis for climate-related risks
and opportunities.
Generally meets monthly, with additional meetings as required.
Reports back to the Audit committee and Board.
OVERVIEW OF GOVERNANCE AND MANAGEMENT
Day-to-day management is delegated to the Chief Executive Officer and
senior management. The levels of authority are approved by way of a
Delegated Authorities Manual, which is reviewed annually by the Audit
Committee and ultimately approved by the Board.
Processes for informing the governing body of climate-related risks
and opportunities are detailed in the table below:
Tram Valley Road, Swanson, Auckland
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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STRATEGY
Although geographically broad within New Zealand, CDI competes in a
narrow sector of the economy namely the property market for residential
sections. The market is competitive with several different participants in
each geographic market. A failure to meet the market or remain competitive
could affect CDI’s operational and financial position as it loses sales and
market share to its competitors, thus affecting its revenues and potentially
its ability to make necessary investments in its business for the future.
To mitigate market risks, we monitor market trends and pricing and develop
strategies to respond to changing market conditions. We regularly speak
with our land agents to ensure that our service delivery and sections remain
attractive and competitive in the marketplace, and we make changes
where necessary.
Climate impact is expected to affect the property sectors in a variety of
ways. It is imperative to review our operations and developments to see
how they will be impacted and whether we can make climate-positive
improvements. Our locations are likely to be affected by climate change
in some way. Severe weather incidents have the potential to affect our
operations with impacts to the land and development works themselves
as well as access to and from our developments.
CURRENT CLIMATE IMPACTS
The following section summarises key climate impacts that were
identified and their impact on CDI for FY24.
CURRENT TRANSITION IMPACTS
These are impacts related to the transition to a low emissions,
climate-resilient future and encompass regulatory, legal, reputational,
market and technology change.
For FY24, CDI has identified no material impacts.
CURRENT PHYSICAL IMPACTS
These are impacts driven by physical climate-related events such
as extreme weather events or flooding.
For FY24, CDI has identified no material impacts.
CURRENT CLIMATE-RELATED
FINANCIAL IMPACTS
As there were no identified transitional or physical impacts for FY24,
we have determined there were no climate-related financial impacts
for CDI in FY24.
CLIMATE RISK MANAGEMENT
CDI is strengthening its approach to climate risk management and transition
planning in alignment with the Aotearoa New Zealand Climate Standards
issued by the External Reporting Board (XRB). CDI has undertaken a climate
risk assessment to identify and assess physical and transition risks across
its operations. The accompanying climate risk and opportunities register
appendix 3 consolidates information on key risks and opportunities,
including scenario analysis, risk rating criteria, relevant time horizons,
and potential adaptation or responses to these. Appendix 2 outlines
methodology used to develop this.
SCENARIO ANALYSIS
As 2023 is our base year, our FY23 scenario analysis was narrative-driven on
a basic level internally, using data from the International Panel on Climate
Change (IPCC) 5th and 6th Assessment Reports and the AR6 Synthesis
Report: Climate Change 2023
3
which was published by the IPCC in March
2023 to provide some metrics and key assumptions. We also had regard to
the Climate Change scenarios for New Zealand published by the National
Institute of Water and Atmospheric Research (NIWA)
4
including their New
Zealand findings from the IPCC 5th Assessment Report.
5
We have also
referred to the Ministry for the Environment’s “Aotearoa New Zealand
climate change projections” guidance.
6
For FY24, CDI additionally engaged consulting firm WSP to refine these
climate scenarios (appendix 2) and identify material physical and
transition climate-related risks and opportunities. These have been
assessed through a series of qualitative and quantitative risk assessment
approaches including workshops, a survey, and physical exposure and
impact assessments (appendix 1). The scenarios used include ‘Orderly’
1.5°C scenario, a ‘Disorderly’ 2.0°C scenario and a ‘Hot House’ >3.0°C
scenario. They are briefly described below, with more detail in appendix 2.
Reference
3. https://www.ipcc.ch/report/sixth-assessment-report-cycle/
4. https://niwa.co.nz/our-science/climate/information-and-resources/clivar/scenarios
5. https://niwa.co.nz/sites/niwa.co.nz/files/NZCCC%20Summary_IPCC%20AR5%20NZ%20Findings_
April%20 2014%20WEB.pdf
6. https://environment.govt.nz/assets/publications/Climate-Change-Projections-Guidance-FINAL.pdf
Reference
7. See appendix 2 for further information on the conditions associated with this scenario.
CLIMATE-RELATED RISKS AND OPPORTUNITIES
CDI’s climate risk and opportunities register provides strategic direction on
integrating climate-related risks into business risk management, financial
decision-making and transition planning. This provides CDI with a framework
for embedding climate risk considerations into strategic decision-making
for aligning its business model with a low-emissions, climate resilient future.
CDI’s Management Team is responsible for the day-to-day identification,
assessment and management of climate-related risks as well as the
implementation of appropriate controls, processes and policies to manage
such risks. Below is a summary of key risks and opportunities identified
during our FY24 assessment. The risk register captures information on the
climate-related physical and transition risks and opportunities that CDI has
identified as relevant. The following sections summarise the key risks and
opportunities for CDI. Further information can be found in appendix 3.
Physical Risks and Opportunities
The physical risk assessment documented the exposure for each of CDI’s
26 sites to geohazard risks, including landslides, flooding, sea level rise
and coastal inundation and erosion, as well as climate variables such as
temperature, rainfall and wind. These have been identified using the a
‘Hot House’ >3.0°C scenario.
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The following tables summarises the risk of each climate-related geohazard
and climate variables for CDI's entire portfolio. The overall portfolio risk
rating was determined based on the risk ratings for individual sites.
RiskFloodingCoastal InundationCoastal ErosionLandslidesSea Level Rise
No Risk77%100%100%85%100%
Low Risk23%0%0%11%0%
Moderate Risk0%0%0%0%0%
High Risk0%0%0%4%0%
Overall Portfolio Risk RatingLow RiskLow RiskLow RiskLow RiskLow Risk
Short-termMedium-termLong-term
present–20302031–20402041–2050
TIME FRAMES
For the scenario analysis, the selected timeframes have been chosen to
align with the NZGBC sector scenario guidance and to align with CDI business
planning and investment timeframes. Scenario analysis time horizons are
as follows:
<2.0°C Disorderly scenario
A world where global warming was limited to
2.0 degrees Celsius above preindustrial levels,
as policies to reduce greenhouse gas emissions
are introduced after 2030. There is a rapid and
concerted effort to reach net zero 2050 goals.
>3.0°C Hot House world scenario
A world where global warming reaches 3 degrees
Celsius above preindustrial levels by 2100, due
to no additional policies introduced to reduce
greenhouse gas emissions.
1.5°C Orderly scenario
A world where global warming was successfully
limited to 1.5 degrees Celsius above preindustrial
levels, as ambitious goals and policies to reduce
greenhouse gas emissions are immediately and
effectively implemented.
Worsleys Road, Cashmere, Christchurch
Low Risk: Where all/the majority of properties had a no risk/low risk rating with only 1 or 2 properties with a higher risk rating.
High Risk: Where >50% of properties had a high risk rating.
Moderate Risk: Where >50% of properties had a moderate risk rating and/or >15% of properties had a high risk rating.
Climate-Related Geohazards
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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STRATEGY
– CONTINUED
CategoryRiskRisk RatingTime Horizon(S)
GeohazardFlooding
Short; Medium; Long
GeohazardCoastal Inundation
Short; Medium; Long
GeohazardCoastal Erosion
Short; Medium; Long
GeohazardLandslides
Short; Medium; Long
GeohazardSea Level Rise
Medium
Climate variable – TemperatureVery Hot Days
Medium
Climate variable – TemperatureHot Days
Medium
Climate variable – TemperatureHottest Day
Medium
Climate variable – TemperatureColdest Day
Medium
Climate variable – WindStrong Wind
Medium
Climate variable – RainfallDrought
Medium
Climate variable – RainfallDry Days
Medium
Climate variable – RainfallHeavy Rainfall
Medium
Climate variable – RainfallTotal Rainfall
Medium
Climate variable – RainfallRainy Days
Medium
Climate variable – RainfallVery Rainy Days
Medium
CategoryRisk StatementRisk RatingTime Horizon(S)
Policy and regulatory
Regulatory and compliance changes, reporting requirements, or new policies,
result in increased costs for CDI.
Short; Medium
Policy and regulatory Increase in taxes and rates to pay for strengthening infrastructure.
Medium
Policy and regulatory
Rising energy costs due to increased demand on the electricity grid
driven by decarbonisation.
Short; Medium; Long
Technology
Risk of uncertainty and costs associated with investing in new technology
(e.g. EV charging or solar panels) when continual updates or retrofitting is needed.
Short; Medium
LiabilityLegal risks for assets that are not climate resilient.
Medium; Long
Liability
Penalties or litigation associated with insufficient
disclosure of material climate risks.
Short; Medium
LiabilityIncreasing insurance costs or unavailability.
Medium; Long
Market
Failure to meet sustainability goals or consumer, client, and investor
expectations for decarbonisation and sustainable innovation.
Short; Medium; Long
Market
Prioritisation of circular economy/low waste alternatives puts pressure
on supply chain for CDI’s new commercial builds.
Medium; Long
Market
Market uncertainty driven by physical climate change impacts and
associated regulatory changes.
Short; Medium; Long
Reputation
Emissions reduction targets are seen as insufficiently ambitious or reluctance
to disclose targets or solutions results in ‘green hush’ accusations.
Short; Medium
Physical
Limited availability of land for development/constraints on the areas CDI
can invest in or develop.
Medium
CategoryOpportunity StatementOpportunity RatingTime Horizon(S)
Market
Exploring potential for sustainable finance deals from banks (lower interest rates)
(e.g. via partners targeting environmental building certifications).
Medium; Long
Resilience Supply chain optimisation.
Short; Medium
Resilience Increasing resilience of sites to extreme weather events.
Medium; Long
Reputation
Being a fast follower of lower carbon technologies or services positively
impacts reputation.
Medium
ReputationAttract and retain staff whose personal values align with climate goals.
Medium
Products and services Providing lower emission or alternative sources of energy.
Medium
Resource efficiency Using lower emission modes of transport.
Short; Medium
Resource efficiency Reducing water use.
Medium; Long
Transitional Risks
Transitional Opportunities
Physical Risks
Iona Block, Havelock North, Hawke's Bay
Photo
LowHighModerate
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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STRATEGY
– CONTINUED
INTEGRATION INTO OVERALL
RISK MANAGEMENT PROCESS
The Board has a risk management framework that includes a list of material
business risks for CDI. The framework is reviewed and updated regularly as
risks to the business evolve and change.
The Audit Committee recommends to the Board whether CDI’s processes
for managing risk are sufficient and any incident of fraud or other failure
of internal controls. The CEO and other members of the management team
review, update and take ownership of the day-to-day management and
operation of CDI risk management framework and associated policies.
When forming the risk assessment and risk and opportunities register,
the existing risk-rating criteria was used to determine risk ratings and
incorporate climate-risks into current risk management. This includes
financial, reputational, portfolio and work delay impacts. This approach
allows climate-risks to be considered alongside other risks an opportunities
which in turn supports the climate-related risk disclosures required by
the XRB.
In most cases, climate-related risks are an extension of our existing risks.
Potential impacts of climate change are considered to present strategic,
financial, operational, asset, and reputational risks for CDI.
Our controls for those risks have been improved to include consideration
of climate change impacts. For example, a new control to address
climate-related impacts includes an annual review of CDI’s climate-related
risks and opportunities to ensure risk management is relevant and
addressing key areas to transition CDI into a more climate-resilient state.
TRANSITION
PLANNING
While CDI already addresses climate-related risks and opportunities in
many of it’s current procedures and risk management, there will still be
potential adaptation and mitigation action that could be undertaken as
we transition to a climate-resilient future. This section covers transition
plan aspects which have been identified as key areas to prioritise in CDI’s
strategy, and considers what may change to address climate-related risks
and opportunities identified.
Potential actions or controls to adapt to specific risks and opportunities
can be found in appendix 3.
Strategic PriorityCommentaryPotential Actions
Capturing Scope 3
emissions
CDI recognises that transition planning must incorporate a shift
to a lower-emissions economy to support the goals of the Paris
Climate Agreement to keep global warming under 1.5°C.
To support impactful emissions reduction, we must first
understand our entire emissions profile, as this is likely to
make up majority of our emissions.
Our direct emissions profile is relatively low compared to the
scope of our works, therefore our focus will be on capturing
our scope 3 emissions and engaging with our suppliers.
This opportunity is most relevant for all climate scenarios
as engaging with the supply chain to obtain information
for scope 3 emissions in FY25 will be important under
climate-related disclosures.
This is also an important metric to understand our impact
and disclose on meaningful positive impact.
Changing regulation
and compliance
With new regulations, requirements and policy across the
industry to support the movement to a climate-resilient future,
CDI plans on staying ahead of these regulations and investigating
methods that we can provide a meaningful contribution to an
industry-wide movement.
Regular reviews of frameworks both internally and externally.
Review processes and procedures and update where
needed to align with new regulations and frameworks.
Merge sustainability strategy with the current business
strategies in place to allow for a more seamless transition
to climate-resilient operations.
Capital allocation
and financial impact
As a business, it is important to understand the impact that
climate-related changes have on business operation, our
developments, and suppliers. While we are still early in our
reporting journey, one of CDI’s focus areas will be to understand
our capital allocation to climate-related mitigation and adaptation,
how much of this are new initiatives vs standard procedures and
where we can invest in a more resilient future.
Actively include and weight climate-related factors and resilience
as part of assessment and due diligence. Assign financial impacts
to climate-related risks and opportunities to better understand
how the business operation and assets are being impacted.
Consider any changes required to be made to site design to aid
in increasing resiliency and financial implications of this (if any).
Investigate internal incentivisation to promote sustainability
in the CDI workplace.
Highlands Drive, Richmond, Tasman District
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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METRICS
AND TARGETS
GREENHOUSE
GAS EMISSIONS
CDI started measuring our greenhouse gas emissions in 2023 and this has
formed our base year which has been accredited with Toitū Envirocare
Carbon Reduce certification.
This covers Scope 1, Scope 2 and selected Scope 3 emissions. The GHG
emissions data covered our direct emissions and indirect emissions,
including: refrigerants, composting, air travel, purchased energy, transmission
and distribution (T&D) losses for purchased energy, fuel emissions (rental and
other cars), office waste, water supply and recycling for the reporting period
(January 1, 2023 through December 31, 2023). The programme requirements
that applied are in accordance with ISO 14064-1:2018.
References
8. https://ghgprotocol.org/standards-guidance This includes: The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (revised edition); the Greenhouse Gas Protocol: GHG
Protocol Scope 2 Guidance: An amendment to the GHG Protocol Corporate Standard; and the Greenhouse Gas Protocol: Corporate Value Chain (Scope 3) Accounting and Reporting Standard.
9. In 2023 refrigerant emissions were estimated using a default leakage approach, which was changed to the top-up usage method in 2024.
10. Market-based emissions are calculated as 1.66tCO
2
e nominally the same as location-based as no Renewable Energy Certificates have been purchased.
11. CDI has elected to disclose in FY24 a partial scope 3 emissions footprint (as required by the Toit
ū programme, where quantifiable data is available).
Where data is not yet available, Adoption Provision 4: Scope 3 GHG emissions in the NZ Climate Standard 2 is applied for the remaining material Scope 3 items in our value chain.
GHG SubcategoryISO CategoryDescriptionFY23 tCO
2
e FY24 tCO
2
e
Scope 1: Direct Emissions14.1910.80
1Mobile combustion (including company owned or leased vehicles)12.1910.80
1Fugitive emissions (from use of refrigerants in air-conditioning)
9
2.000
Scope 2: Indirect Emissions from Purchased Electricity1.411.65
2Imported electricity consumption (location-based)
10
1.411.60
2Imported electricity for EVs (location-based)
10
00.05
Scope 3: Indirect Emissions from Value Chain
11
33.5830.94
C14Purchased goods and services – potable water supply (only)0.06<0.0
C34
Fuel and energy-related activities – transmission and distribution (T&D)
losses from purchased electricity and offsite EV charging
0.120.12
C54Waste generated in operations – disposal of solid waste – landfilled0.671.72
C54
Waste generated in operations – solid waste not landfilled
– recycling and composting
0.110.29
C63
Business travel – transport (non-company owned vehicles)
– air travel, rental vehicles and taxi
32.6228.81
Total49.1843.39
GREENHOUSE GAS REDUCTION TARGET
Currently CDI have not set targets for the Greenhouse Gas Inventory as
it is still in development, with the expectation for it to change over the
next year as scope 3 emissions are added, and other data collection and
measurement practices are improved.
As FY23 was our base year for inventory development, we have set an
internal interim target to allow us to measure progress year-on-year.
We set an annual target of 2% absolute reduction on the total FY23
emissions footprint and have exceeded this for FY24 as we measured a
13% decrease. It should be noted that this is largely as a result of changing
emissions factors year-on-year. Further information on the CDI Greenhouse
Gases Inventory and associated KPMG assurance and Toit
ū Certification
can be found in appendices 5 and 6 respectively.
Given the outcome of this, we can expect to set more ambitious targets
going forward, and can include the wider scope 3 emissions profile during
target-setting.
RISK AND OPPORTUNITY EXPOSURE
While we have been able to develop a risk assessment and rating criteria
for physical and transitional risks and opportunities, CDI have not yet
quantified exposure of assets to individual risks and opportunities.
We are still in the early stages of developing accurate reporting procedures
and are currently finalising methodology and implementing processes to
accurately disclose this information. As part of CDI’s transitional planning,
we aim to engage with external consultants to assist us with understanding
this process.
Lucas Terrace, Nelson
INTERNAL METRICS
Transition risks, physical risks, and climate-related opportunities metrics
relate to disclosure of climate-related risks and opportunities for the current
reporting period. Capital deployment covers investment made now to
address these risks and opportunities in the future, while remuneration and
performance metrics such as greenhouse gas emission reduction targets,
relate to incorporation of climate considerations into management practices.
Our capital deployment (table below) showcases our transition to being able
to accurately disclose the information in this Statement as we have invested
in upskilling, external assurance, and external consultation to develop and
peer review our climate-related risks and opportunities.
We have achieved this accreditation for our second year (FY24) and
the following table shows progress made against the 2023 base year.
We have had an overall reduction in emissions, however, it should
be noted that some of these reductions are a result of changing
our organisation boundary approach from an “equity share” to
“operational control” approach to better reflect our business activity.
For the reporting period 1 January 2024 to 31 December 2024 our
greenhouse gas emission inventory was prepared in accordance
with the GHG Protocol Standards.
8
ASSURANCE OF GHG EMISSIONS
KPMG have provided limited assurance over the reported Scope 1, 2 and 3
emissions for the 2024 reporting period as contained in appendix 4. This
assurance engagement was undertaken in accordance with New Zealand
Standard on Assurance Engagements 1 (NZ SAE 1) Assurance Engagements
over Greenhouse Gas Emissions Disclosures and International Standard on
Assurance Engagements (New Zealand) 3410 Assurance Engagements on
Greenhouse Gas Statements (ISAE (NZ) 3410) issued by the New Zealand
Auditing and Assurance Standards Board (Standard). See KPMG’s opinion
which includes the scope of their work in appendix 5.
Description of ActivityExpenditure
Resourcing for Greenhouse Gas Inventory Development$12000
Assurance of Greenhouse Gas Inventory$15,750
Climate Scenario and Risk Register Development$34,100
As this is CDI’s first year disclosing climate-related financial impacts, internal
emissions price and associated business sustainability strategy (including
incentives, KPIs and other targets) have not yet been fully developed. With
further engagement with the CDI board, external consultants, and suppliers,
CDI will be able to set up KPI’s and both external/internal targets and
incentives to help us to progress with our sustainability journey.
CDI Greenhouse Gas Emissions Summary for FY23 and FY24
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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APPENDIX 1:
RISK ASSESSMENT METHODOLOGY
A semi-quantitative risk assessment was conducted by external
consulting firm WSP New Zealand Limited to assess climate-related
risks and opportunities.
PHYSICAL RISK ASSESSMENT
Physical risks were assessed by combining geospatial analysis with a
consequence-based approach. Using Geographic Information System (GIS)
software, CDI’s sites were overlaid with climate-related geohazard data
sourced from local government entities, the Institute of Geological and
Nuclear Sciences (GNS), and the National Institute of Water and Atmospheric
Research (NIWA). Exposure levels were classified as ‘no exposure,’ ‘low
exposure,’ or ‘high exposure’ based on the percentage of each site
intersecting with geohazard zones.
To translate exposure into risk, vulnerability thresholds were developed
based on CDI’s operational context, considering factors such as land damage,
project delays, and economic impacts. These thresholds were then applied to
a standardised risk matrix to determine qualitative risk ratings for each site.
Through this modelling, each property is assigned a qualitative physical risk
rating across these variables, helping to prioritise which of CDI’s sites require
the most assessment or action.
Reference
1. Property and construction sector release climate scenarios for New Zealand
TRANSITIONAL RISK
CDI’s previous FY23 climate disclosures identified transitional climate risks
and opportunities. These risks and opportunities were built on for FY24,
along with an additional preliminary list identified by external consultant
WSP. The updated CR&Os were then given a preliminary rating by low,
medium or high priority.
WSP prepared a list of additional climate-related risks and opportunities
that drew from the Property and Construction sector scenarios
1
and input
from WSP’s Property & Buildings Sustainability Specialists.
Through workshops held with WSP and a survey sent to CDI participants,
these risks and opportunities were reviewed, refined and prioritised against
climate scenarios, risk rating criteria and relevant time horizons developed
between CDI and WSP based on relevance to CDI operations.
APPENDIX 2:
CLIMATE SCENARIOS
Policy and RegulationMarket ChangesTrends
• Regulators and local authorities respond with
changing requirements and guidelines around
land development causing rezoning
• Regulatory changes target recyclable materials
and a circular economy
• Energy and carbon caps for buildings phased
in rapidly
• Building owners must take steps to decarbonise
and disclose performance
• Lead times and cost for low-carbon materials
increase in near term (2030) but decrease again
by 2040
• Shift to modular and circular building design
and prioritisation of existing building re-use and
refurbishment and adaptation rather than new
builds from 2025 onwards
• More demand for energy efficient buildings
and additional public transport
• Rising insurance premiums for properties or
land exposed to climate-related physical risks
• Residential property demand will continue out to
2050 section sizes reducing over time as council
plans become operative
• Increase demand for local shopping and service
precincts even outside of larger urban areas
• Whole of life carbon emissions reductions for
buildings at 90% by 2050
• Energy grid shifts rapidly from fossil fuels almost
reaching 100% renewable by 2050
• Investor and tenant and customer expectation to
meet 1.5 degree reduction targets leads to restricted
access to capital and differential interest rates from
lenders and limitations on government funding
• Cost of carbon increases to $250 per tonne of
CO
2
-equivalent
• More emphasis on circular business models
and reliance on local suppliers
1.5°C ORDERLY SCENARIO
A world where global warming was successfully limited to 1.5 degrees Celsius above preindustrial levels,
as ambitious goals and policies to reduce greenhouse gas emissions are immediately and effectively implemented.
This is the most optimistic scenario but is not guaranteed and the effects of global warming will continue to be felt. For New Zealand, this will mean that there will
still be extreme weather events and increase in rainfall intensity, which require coordinated infrastructure responses. The range of annual average temperatures
across Aotearoa are between 0.3°C and 1.2°C warmer by 2030, between 0.6°C and 2.1°C warmer by 2050, and between 0.7°C and 4.6°C warmer by 2090. Further,
more hot days – days when maximum daily temperatures are over 25 ̊C will occur for most of New Zealand, with the north and east North Island projected to
experience the most change.
Key Drivers for Change
Enabling regulations | Reduced implementation costs | Increased availability of technology | Low-emissions fuel and materials | International trade requirements
Business resilience | Customer expectations for low-emissions services
Prestons Park, Marshlands, Christchurch
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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APPENDIX 2:
CLIMATE SCENARIOS
– CONTINUED
2.0°C DISORDERLY SCENARIO
A world where global warming was limited to 2 degrees Celsius above preindustrial levels, as policies to reduce
greenhouse gas emissions are introduced after 2030. There is a rapid and concerted effort to reach net zero 2050 goals.
This scenario assumes that the property and construction sectors are slow to decarbonise, but fast movers get the opportunity to utilise materials, capital
and knowledge ahead of late movers who are disadvantaged when demand peak after 2030.
Policy and RegulationMarket ChangesTrends
• Abrupt policy and market changes for property
and construction post 2030
• Immediate mandatory changes in building energy
and carbon requirements from 2030
• Steep increase in carbon price 2030–2050
at $250 per tonne
• Rising construction and retrofit costs
• Restricted resource availability and
disruptions to supply chain
• Suburban development pushed to previously
rural areas
• Declining property values and rising
insurance premiums
• Surge of capital to enter the market around
2030, incentivising rapid innovation
• Spatial planning inconsistent with managed
retreat causing uncertainty for property sector
around potential abandoned assets
• Demand for electricity surges 2030 onwards
in response to electrification
• Residential property demand high beyond
2050 exacerbated by forced retreat
• Increase in extreme weather events and increased
vulnerability to assets and infrastructure
• Crowding in urban centres
• Expected delays or shifts and supply constraints
for energy as energy sector has delayed response
to decarbonise
Key Drivers for Change
Mitigation regulations post 2040 | International trade requirements post 2040 | Business response to acute weather events
Policy and RegulationMarket ChangesTrends
• No further decarbonisation policies are enacted
• No incentives for behaviour change
• Mandates put in place to conserve energy once
critical functions are threatened
• Any regulatory changes are slow and focus
on adaptation
• No innovation in terms of building and
construction technologies
• Assets becoming stranded, reduction in suitable
land for development
• Social and response services and critical
infrastructure put under severe pressure
• Carbon price remains low at $35 per tonne
by 2050
• Increased rates to fund additional protection
measures
• Emissions continue to rise beyond 3.0 degrees
• Immigration rates increase along with population
growth created food and housing insecurity
• Social cohesion weakens due to factors such
as heat stress
• Limited transition risks but extreme physical
climate risks and costs
3.0°C HOT HOUSE SCENARIO
A world where global warming reaches 3 degrees Celsius above preindustrial levels by 2100,
due to no additional policies introduced to reduce greenhouse gas emissions.
This scenario assumes that the wider environment is seriously degraded with continued global warming intensifying the global water cycle, resulting in more
dramatic climate events (wet and dry), more variable or extreme events such as storms, cyclones or hurricanes, a reduction in the ability of land and ocean
carbon sinks to absorb emissions and further global mean sea-level rise and other detrimental effects on the land and ocean environments.
Key Drivers for change
Adaptation regulations post 2050 | International trade requirements post 2040 | Business response to acute weather events
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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APPENDIX 3:
RISK AND OPPORTUNITIES REGISTER
Risk StatementRisk CategoryRisk DescriptionAnticipated Impacts
Relevant Time
Horizons
Risk Rating:
1.5 ̊C Scenario
Risk Rating:
2 ̊C Scenario
Risk Rating:
3 ̊C Scenario
Planned/Current ActionsPotential Actions Identified by CDI
Regulatory and compliance
changes, reporting requirements,
or new policies, result in increased
costs for CDI.
Policy and
regulatory
Changes in government regulations, reporting requirements, and policies, including
stricter environmental regulations, pose a risk of increased operational costs for CDI.
For example, there is uncertainty surrounding to what extent climate change will be
addressed in upcoming changes to the Resource Management Act (RMA). Increased
environmental obligations in the future could include other new policies encouraging
or requiring emissions reductions.
Higher regulatory and compliance costs may reduce profitability, strain financial
resources, and increase operational complexity for CDI. Elevated costs for partners
and customers could impact business relationships and market competitiveness.
Compliance with existing and future sustainable certification requirements from
investors or regulatory bodies could also raise costs for CDI, its partners, and customers.
Short; Medium
Current actions taken to address this risk include engagement with external
consulting firms to assist in meeting current regulations and reporting
requirements. Onboarding of an internal sustainability resource to improve
current systems and procedures for reporting going forward.
Potential actions include continued monitoring of legislation and
proposed changes.
Commitment from Board of Directors to set targets and incentivise
progress on transitioning.
Increase in taxes and rates to pay
for strengthening infrastructure.
Policy and
regulatory
Rising taxes, development contributions, and targeted rates to fund infrastructure
improvements could increase costs for CDI’s land investments. Targeted rates imposed
on end users could deter potential buyers of CDI’s sections, impacting marketability.
Regional variation in targeted rates adds complexity to investment decisions.
Increased taxes and rates may reduce the profitability of CDI’s investments and limit
buyer demand. This could lead to reduced returns and slower rates. Regional variations
in targeted rates increases complexity and could impact CDI’s acquisition decisions.
Medium
Hiring a finance accountant to focus on improving CDI's current procedures
to account for changing taxes and rates.
Submit on changes to council rates or consenting regulations and
maintain relationships with councils where developments are planned
for advanced notice of upcoming changes.
Rising energy costs due to
increased demand on the electricity
grid driven by decarbonisation.
Policy and
regulatory
New Zealand’s electricity grid is expected to be increasingly pressured as transportation
and industry decarbonises (e.g. increasing numbers of electric vehicles).
Higher demand for electricity can put pressure on constrained networks leading
to increased failures and outages. Added pressure on the grid may also increase
energy costs.
Short; Medium;
Long
CDI have a very low energy consumption. While we still make efforts to
identify opportunities for reduction, we have not identified this as a key
risk to contribute to transition planning.
Implementing suitable services in residential and retail precinct areas
and establishing a good foundation for these developments to support
(e.g. EV charging stations).
Investigation of solar or water-reuse for commercial development and
future residential developments.
Progress could be measured through percentage of developments with
solar/renewable resources and potentially financial impacts (positive or
negative) of these changes.
Risk of uncertainty and costs
associated with investing in new
technology (e.g. EV charging or
solar panels) when continual
updates or retrofitting is needed.
Technology The rate of change for new technology may require frequent retrofits or upgrades.
For example, buildings may require costly additions like solar panels not accounted
for in the original design, further escalating expenses. EV charging or on-site batteries
may also require frequent upgrades as technology progresses.
Frequent updates and unforeseen retrofitting or upgrade costs would strain
CDI’s financial resources and reduce asset value.
Short; Medium
Planning for solar retrofits/charging infrastructure/battery storage
in new developments. However, new builds are already designed for
energy efficiency.
Monitor and investigate new technologies that may be useful to CDI's operations.
Undertake external assessments of new technologies through an established
partner or third party organisation.
Engagement with suppliers and contractors to investigate opportunities
for collaboration with investment into new technology ad build upgrades
into Capex programme.
Legal risks for assets that
are not climate resilient.
LiabilityAssets that are not climate-resilient, such as those in flood prone areas, pose legal risks
if adequate due diligence and mitigation measures are not implemented. Insufficient
engineering solutions or planning to address climate risks may result in legal issues.
Legal risks associated with non-climate-resilient assets could result in increased costs
for litigation, compliance, and mitigation efforts as well as reputational damage.
Medium; Long
Conducting site due diligence/climate change risk assessments prior to
purchase. Our current assessments cover many of the identified climate-risks.
Consider Green Star building accreditation for developments and commercial
premises and future residential builds.
Seek external assessment of climate-related risks prior to land purchase
decision. Measurement for progress could be through percentage of
portfolio assessed for climate exposure or that include resilience attributes.
Penalties or litigation associated
with insufficient disclosure of
material climate risks.
LiabilityCompanies that do not adequately address or communicate climate risks may face legal
challenges for failing to comply with disclosure requirements.
Legal challenges and penalties related to inadequate climate risk management
and disclosure could result in financial losses, reputational damage, and increased
scrutiny from regulators and investors.
Short; Medium
Complying with the climate-related disclosure regime and obtaining external
advice as necessary.
Documenting and assess climate-related risks and opportunities and review
with external assistance.
Continue to monitor changes to disclosure and legislation and seek internal
advice as needed.
Increasing insurance costs or
unavailability
LiabilityAs the frequency of severe weather events increases, CDI’s commercial properties may
face higher insurance premiums, stricter terms, or potentially unavailability of coverage.
This could necessitate exploring alternative risk management options like self-insurance.
Higher insurance costs or reduced coverage options could put strain on CDI’s
financial resources, impact property valuations, and require additional risk
management measures, potentially affecting overall operational stability.
Medium; Long
Ongoing review of CDI's property portfolio with identification of potential
improvements (sometimes with external input).
Incorporate climate-related physical exposure and insurance availability
into land purchasing decisions.
Collate climate-related risks to prepare for adaptation.
Investigate self-insurance.
Investigate the viability of alternative insurance products e.g. parametric cover.
Failure to meet sustainability goals
or consumer, client, and investor
expectations for decarbonisation
and sustainable innovation.
Market Growing consumer, client and investor demand for decarbonisation and sustainable
innovation creates a risk if CDI cannot meet these expectations. Single-issue investors
with strict sustainability criteria may disengage if their expectations are unmet, and
the complexity and costs of implementing sustainability initiatives creates further
challenges.
Unmet sustainability expectations could result in reputational damage, reduced
investor confidence, and loss of funding opportunities. Additionally, resource
diversion to address sustainability gaps could delay other initiatives, impacting
long term organisational growth.
Short; Medium;
Long
Onboarding an internal sustainability resource to improve current systems
and procedures.
Reporting on climate risks and impacts.
Setting realistic sustainability interim targets to track progress while
inventory is being developed and improved.
Communicate factual information about CDI's activities to the public
to set realistic expectations.
Investigate new decarbonisation opportunities across the portfolio and
identify ways to demonstrate what is being done currently to reduce
onsite emissions.
Investigate green building certification where relevant.
Measurement may be through investor confidence relating to ESG scores.
Prioritisation of circular
economy/low waste alternatives
puts pressure on supply chain for
CDI’s new commercial builds.
Market Prioritising circular economy practices and low-waste alternatives may increase
supply chain pressure for CDI’s new commercial builds.
Circular economy adoption may lead to higher costs, supply chain challenges,
and varying risks across business areas. While building partners have not yet
passed on costs, future increases are likely.
Medium; Long
Most site work is contracted out, moving a lot of our ability to improve
systems being through engagement and influence as a client.
Hiring an internal sustainability professional to engage with suppliers/
contractors and to advise on best building practices for circular economy.
Investigate and agree on reuse/alternative use of site materials where
practical between CDI and contractor.
Participate in pilot projects.
Investigate and specify low-waste construction techniques and materials
in construction/development contracts.
• Measure embodied emissions of developments.
• Engage an external consultancy to research and investigate
improvements/feasibility in this area.
Market uncertainty driven by
physical climate change impacts
and associated regulatory changes.
Market Increases in the frequency and severity of physical climate change impacts and
regulatory changes create market uncertainty, leading to rising costs, delays in
development, and challenges in maintaining profitability. Increased structural costs
and obligations add to the financial risks, making long term planning complex.
Uncertainty and rising costs may reduce profitability, delay project timelines,
and strain financial resources.
Short; Medium;
Long
Developing a risk register incorporating climate-related risks and
opportunities to allow for adaptation and mitigation.
Adjusting the timing of developments to meet current demand.
Work with external consultants to develop sufficiently robust forecasts
to mitigate the risk of market uncertainty.
Continue work on transitioning panning to mitigate anticipated impacts.
Emissions reduction targets are
seen as insufficiently ambitious or
reluctance to disclose targets or
solutions results in ‘green hush’
accusations.
ReputationNot setting or setting emissions reduction targets that are perceived as insufficiently
ambitious, could damage CDI’s reputation, especially among investors who prioritise
climate action.
Failure to disclose ambitious targets and solutions could reduce investor confidence,
limiting funding opportunities.
Short; Medium
CDI have implemented internal interim targeting which will allow for progress
tracking until our emissions inventory and impact are better quantified.
This target development and certification of our emissions profile have
been certified through external organisation Toitū for FY23 and are currently
awaiting certification for FY24.
Engagement with suppliers and value chain to understand expectations.
Ensure transparency when developing and disclosing sustainability targets
in the coming years.
Limited availability of land for
development/constraints on the
areas CDI can invest in or develop.
Physical Chronic climactic changes and increases in the frequency and extremity of acute
weather events may have a widespread impact across various regions of New Zealand,
limiting the land available to CDI for acquisition or development.
Acute weather events would likely hasten changes to land contours and structures to
varying degrees. This could render some land or part of land unviable for development
as intended. CDI could be forced to look for alternative ways to use the remainder of its
land portfolio or in the most extreme circumstances divest completely.
Medium
CDI has due diligence in place to manage this risk and associated
climate-related impacts.
Adjusting the timing of developments to meet current demand.
Annual review of our processes and procedures ensure we are aware
of changing risks and changing market conditions.
LowHighModerate
Transitional Climate-Related Risks
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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20 | CDL Investments New Zealand Limited
APPENDIX 3:
RISK AND OPPORTUNITIES REGISTER
– CONTINUED
Opportunity Statement
Opportunity
Category
Opportunity DescriptionAnticipated Impacts
Relevant
Time
Horizons
Opportunity
Rating:
1.5°C Scenario
Opportunity
Rating:
2°C Scenario
Opportunity
Rating:
3°C Scenario
Planned/Current ActionsPotential Actions Identified by CDI
Exploring potential for sustainable
finance deals from banks (lower
interest rates) (e.g. via partners
targeting environmental building
certifications).
Market CDI has the potential to secure sustainable finance deals, such as green loans with
lower interest rates, by collaborating with partners targeting environmental building
certifications. While CDI has not yet required loans, exploring the option in the future
could provide a cost-effective funding source for environmentally focused projects.
Sustainability-linked loans could offer reduced interest rates, thus saving on costs
for CDI, and could open up more access to capital.
Medium; Long
No current actions.Speak to bankers and solicit proposals for green finance, or similar for land
purchases and other development work.
Supply chain optimisation. Resilience CDI could establish best practice for procurement and update its policies on supply
chain sustainability.
Optimising supply chains and engaging with suppliers on sustainability holds
considerable potential to both lower associated carbon emissions and improve
resilience to market changes and supply chain disruptions.
Short; Medium
Compiling information to pass onto CDI's major suppliers. Going forward,
we will continue engagement with suppliers to understand where they are
in sustainability journey and capability to supply additional climate-related
information for future projects.
This opportunity is most relevant for all scenarios as engaging with the supply
chain to obtain information for scope 3 emissions in FY25 will be important
under climate-related disclosures.
Make optimisation of supply chain a contractual requirement with targets/KPIs
to be set and incentives to be agreed.
Getting ahead of the curve and optimising the supply chain will positively
impact preparing for disruptions and reducing GHG emissions. However, given
CDI's size and the extent of its supply chain, the effort may not be far-reaching.
Our impact will be determined by percentage of key suppliers that have been
engaged with and are reporting on climate-related impacts.
Increasing resilience of sites
to extreme weather events.
Resilience CDI could assess and improve the ability of its sites to respond rapidly to and recover
from weather events such as flooding, storms, and drought. CDI could assess its sites'
dependencies on external networks – such as power and transport grids – and mitigate
the risk of relying on insufficiently invested in infrastructure or the possibility of supply
disruptions, e.g. by installing batteries in developments to supplement existing power
supply networks or to create/promote resiliency within a development of suburb. This is
an opportunity that CDI could start to explore as part of future subdivision designs.
Improving CDI sites’ resilience to extreme weather events could improve customer
safety, facilitate continued operations through difficult conditions, and reduce damage
to the sites. This could help enhance CDI’s reputation, attract customers to the brand,
and generate more revenue.
Medium; Long
Reflecting on learnings from previous builds to allow for
sustainable design to be considered earlier in development.
Investigate on site renewable and battery back-up for commercial premises
and assess the site dependency on external networks.
• Actively include and weight climate-related factors and
resilience as part of assessment and due diligence.
• Undertake resiliency surveys of its land holdings where
development works have not yet started.
• Consider any changes required to be made to site design
to aid in increasing resiliency.
Being a fast follower of lower
carbon technologies or services
positively impacts reputation.
ReputationCDI could become a fast follower of technologies or services with lower emissions and
other environmental impact. This could include certifications, such as Toit
ū’s Carbon
Reduce certification scheme. CDI could also introduce sustainability requirements for
development agreements, e.g. Homestar for residential properties (but there is no
current appetite for this).
CDI’s reputation could improve, attracting more customers to the brand and
demonstrating to investors the company’s ability to adapt and be ahead of the curve.
Medium
There is currently little enquiry from customers regarding CDI's
climate reporting of reduction strategy and adoption of new
technology related to this. However CDI continue to be transparent
in disclosing our strategy and engagement with suppliers and
industry partners.
Consider pilots of new technology or accreditation at specific development
sites to see if they attract a higher return.
Require third party contractors to outline what technologies they
are adopting and create targets or KPIs for use where applicable.
Investigate and potentially test new technologies (where relevant)
to see whether benefits can be derived.
Consider partnerships with existing contractors or other industry parties
to test/implement new technologies.
Attract and retain staff
whose personal values align
with climate goals.
ReputationEstablishing, making progress on, and communicating sustainability commitments to
staff could make CDI more attractive as an employer.
CDI’s status as a preferred employer could be bolstered by an association with
sustainability, supporting the brand and its reputation. This could improve recruitment,
retention, and staff satisfaction.
Medium
Upskill the board in climate-related risks and opportunities.Upskilling existing employees in climate-related information, assessments
and impacts.
Include climate and sustainability knowledge as a skill set for future
recruitment.
Providing lower emission or
alternative sources of energy.
Products and
services
CDI could install renewable energy infrastructure and facilitate future use of alternative
energy sources at its sites. This could take the form of providing for a future solar
panel installation/infrastructure as part of a linear park or requirements to ensure that
residential developments are designed in such a way to as to provide space to allow
alternative energy solutions to be accommodated. While policy direction is not clear on
these issues, this is potentially an opportunity that CDI can start to explore as part of
future subdivision designs.
Builders and customers of the developments could reduce their carbon emissions
from energy use, reduce energy costs, and increase their resilience to power supply
disruptions and fluctuations in energy prices. This could increase the attractiveness
of CDI sites for both customers and investors.
Medium
Assessment of existing commercial property for solar
or other renewable energy options.
Reassess existing commercial premises for solar suitability and incorporating
solar into commercial building design.
• Incorporate solar panels into commercial building design.
• Incentivise section purchasers with a discount if they adopt alternative
energy solutions.
• Explore alternative energy technologies with a view to incorporating them
where possible.
Measurement of progress in this opportunity could be measured as percentage
of renewable energy being used or associated reductions in emissions.
Using lower emission modes
of transport.
Resource
efficiency
As part of CDI’s GHG emissions measurements, it noted that the largest contribution
to its GHGs was transport (road and air). CDI has already started transitioning to some
lower emissions and electric vehicles and is looking at additional options. CDI staff
could examine opportunities to reduce travel needs and opt for lower-emissions travel
options where possible (e.g. bus or car instead of flying).
Use of more efficient and lower emissions transport would result in a reduction
of direct emissions and a reduction of operating and fuel costs for CDI.
Short; Medium
Given CDI's size, this opportunity is not likely to have a large
impact when compared to other more far-reaching opportunities.
CDI leased fleet is being converted to lower-emissons vehicles
that are fit for purpose.
CDI locations are not always suitable for sustainable travel, however where
we are able to, we will opt for use of EV/HEV for rental, uber and taxi.
CDI are already very small and reducing flights any further would
be difficult when balancing against key business travel. Investigation going
forward will look into offsets and alternative ways to reduce business travel.
Investigation into incorporating charging infrastructure into
development design.
Reducing water use.Resource
efficiency
CDI could implement water-saving measures in its operations and opt for
machinery and appliances with lower water use when upgrading or repairing assets
to reduce water consumption. CDI’s developments can provide opportunities for
customers to reduce their water use, such as by incorporating greywater solutions
for commercial buildings.
With increasing demand for water and higher infrastructure costs forecast, a reduction
in water consumption could result in reduced operating costs for the business. In the
face of climate variability in water supply, reduced water demand can make CDI and its
customers more resilient to fluctuations in price and availability of water.
Medium; Long
Similarly to energy use for CDI, water usage is difficult to
make direct meaningful reductions when using shared spaces
and having a small workforce.
Most meaningful change is likely to be seen through our engagement
and influence in our developments.
Include measures to monitor and reduce water use by contractors
into contracts.
Incorporate water saving/reuse measures as part of development design.
Incorporate water saving/reuse measure as part of scheme plan design (where
allowable). Implement contractual measures to measure and reduce water use.
LowHighModerate
Transitional Climate-Related Opportunities
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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22 | CDL Investments New Zealand Limited
APPENDIX 4:
GREENHOUSE GAS INVENTORY
For the reporting period 1 January to 31 December, 2024 CDI’s emissions
have been measured and the greenhouse gas emission inventory (GHG
inventory) prepared in accordance with the GHG Protocol Standards
1
and
ISO 14064-1:2018 standard.
GHG SubcategoryISO CategoryDescriptionFY23 tCO
2
e FY24 tCO
2
e Data Source & Collection Methodology
Scope 1: Direct Emissions14.1910.80
1
Mobile combustion
(including company owned or leased vehicles)
12.1910.80
Actual usage from company vehicle
fuel card data (Kms)
1
Fugitive emissions
(from use of refrigerants in air-conditioning)
2
2.000
Calculated using HVAC service records
via property manager (Kg) (no refrigerant
leakage/top-ups in 2024)
Scope 2: Indirect Emissions from Purchased Electricity1.411.65
2
Imported electricity consumption
(location-based)
1.411.60
Actual usage from 3rd party supplier
data, supplier invoices and electrical
onsite sub-metering (kWh)
2Imported electricity for EVs (location-based)
3
00.05
Actual usage from company vehicle
charging account data (kWh)
Scope 3: Indirect Emissions from Value Chain
4
33.5830.94
C14
Purchased goods and services
– potable water supply (only)
0.06<0.0
Calculated from office water use on bills
supplied via property manager (m
3
)
C34
Fuel and energy-related activities
– transmission and distribution (T&D)
losses from purchased electricity and
offsite EV charging
0.120.12
Calculated as a portion of imported
electricity consumption (kWh)
C54
Waste generated in operations
– disposal of solid waste – landfilled
0.671.72
Calculated from waste contractor data,
based bin weight proportion supplied via
development manager (tonnes)
C54
Waste generated in operations – solid waste
not landfilled Recycling and Composting
0.110.29
Calculated from waste contractor data,
based bin weight proportion supplied via
development manager (tonnes)
C63
Business travel – transport (non-company
owned vehicles) – air travel, rental vehicles
and taxi
32.6228.81
Calculated using spend based methodology
for international and domestic flights and
taxi travel ($) and mileage for rental car
travel (Km)
Total49.1843.39
Table 1: CDI’s GHG emissions 2024.
References
1. https://ghgprotocol.org/standards-guidance This includes: The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (revised edition);
the Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to the GHG Protocol Corporate Standard; and the Greenhouse Gas Protocol: Corporate Value Chain (Scope 3)
Accounting and Reporting Standard.
2. In 2023 refrigerant emissions were estimated using a default leakage approach, which was changed to the top-up usage method in 2024.
3. Market-based emissions are calculated as 1.66tCO
2
e nominally the same as location-based as no Renewable Energy Certificates have been purchased.
4. CDI has elected to disclose in FY24 a partial scope 3 emissions footprint (as required by the Toit
ū programme, where quantifiable data is available). Where data is
not yet available, Adoption Provision 4: Scope 3 GHG emissions in the NZ Climate Standard 2 is applied for the remaining material Scope 3 items in our value chain.
Reference
5. https://environment.govt.nz/assets/publications/Measuring-Emissions-2024/Measuring-emissions_Detailed-guide_2024_ME1829.pdf
CDI emissions intensity: emissions intensity is operating revenue (gross tCO
2
e/$millions) = 0.88
COMPARISON TO TARGETS AND BASE YEAR
2023 is the base year and was the first year of GHG inventory reporting for
CDI. Further work commenced in 2024 to scope suitable targets and metrics
for emissions reduction. Targets will be set in 2025.
There was a decrease in emissions between the base year and 2024 of
5.79tCO
2
e (13 per cent) largely as a result of changing emissions factors
year-on-year. Business travel and mobile combustion are currently the
highest sources of emissions for CDI making up the majority of CDI’s
emissions footprint. These emissions generating activities, including air
travel, leased company vehicles and rental cars, have not significantly
changed or decreased over the past year.
ORGANISATIONAL BOUNDARY
AND CONSOLIDATION APPROACH
Organisational boundaries have been set in accordance with the GHG
Protocol methodology and ISO 14064-1:2018 standards.
CDI has only one subsidiary (CDL Land New Zealand Limited) which is its
principal operating and land-owning subsidiary and is included in CDI’s
organisational GHG reporting boundary. This includes direct operational
emissions from active land developments and vacant commercial properties
not yet leased. As CDI subcontracts out all development activities such
as earthworks, there are no direct (scope 1 and 2) emissions in 2024 for
active land developments.
In the 2024 reporting period an "operational approach" was applied to
the organisational boundary and GHG inventory. The previous base year
(2023) inventory reported used an "equity share" approach. This change
was made in keeping with the GHG Protocol reporting standards to better
reflect the nature of the property development operations; direct control
over sources of emissions; industry practice; and alignment with parent
company methodology and reporting.
In line with the operational control approach, exclusions from the inventory
include where CDI is the owner of commercial premises (warehouses and
retail centres) that are leased out under tenancy agreements. CDI does
not currently build or own any residential premises.
BASE YEAR RECALCULATION
CDI has used 2023 as the base year for GHG inventory, accredited by
Toit
ū and reported in the climate-related disclosures within the 2023
Annual Report. This was the first year of measurement also deemed a
representative post-COVID year.
To ensure accurate, transparent, and consistent reporting of GHG
emissions, supporting the organisation's sustainability goals and
compliance with regulatory requirements CDI have a GHG inventory
base year recalculation policy. It outlines the events and conditions that
trigger a base year recalculation or a change in the nominated base year.
To enable tracking progress towards GHG targets, base year emissions
inventory will be recalculated to account for significant changes, if these
changes lead to an increase/decrease in emissions of greater than 5 per
cent of the total inventory (the significance threshold), in accordance
with the GHG Protocol guidance. Changes to organisational boundary;
structure (include acquisitions, divestitures or mergers and/or outsourcing
or insourcing emitting activities); calculation methodology; and/or data
errors may trigger the recalculation of base year emissions.
On review there is no change required to the 2023 base year. Despite a
change to the consolidation approach and organisational boundary
this reporting period, this did not result in exceeding the significance
threshold to require a base year recalculation.
CALCULATIONS AND EMISSION FACTORS
Reports, invoices and data are received from the relevant data source/
supplier and the relevant emission factors are applied to calculate the
emissions. The calculation approach used for quantifying this emissions
inventory is based on: emissions = activity data x emissions factor.
All emissions were calculated using Toit
ū e-manage platform with emissions
factors and Global Warming Potentials provided by Toit
ū. Global Warming
Potentials (GWP) from the IPCC fifth assessment report (AR5) are the primary
GWP conversion however some emissions factors are from (AR4). If emission
factors have been derived from recognised publications approved by the
programme, which still use earlier GWPs, the emission factors have not been
altered from as published. Where applicable, unit conversions applied when
processing the activity data have been disclosed. There are systems and
procedures in place that will ensure applied quantification methodologies
will continue in future GHG emissions inventories.
SOURCE OF EMISSIONS FACTORS
Emissions factors are sourced from NZ Government publications where
possible or other reputable peer reviewed sources. Emissions, as
recommended by Toit
ū. Most emissions factors and GWP are sourced
from the Ministry for the Environment, Measuring emissions: A guide for
organisations (2024)
5
, which uses the GWPs published in the IPCC Fifth
Assessment Report (AR5). Below are the exceptions where emission
factors used are from different sources:
• Recyclable materials: Turner et al. (2015) Greenhouse gas emission
factors for recycling of source-segregated waste materials. Resources,
Conservation and Recycling (AR4).
• Electricity distributed T&D losses (market-based): New Zealand Energy
Certificate System. Administered and developed by Certified Energy,
New Zealand (AR6).
• Air passenger transport (spend-based): Market Economics Limited
(2023). Consumption Emissions Modelling, report prepared for Auckland
Council (AR4).
Summary:
Total 2024 emissions = 43.39tCO
2
e
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

CDL Investments New Zealand Limited | 25

24 | CDL Investments New Zealand Limited
APPENDIX 4:
GREENHOUSE GAS INVENTORY
– CONTINUED
METHODS, ASSUMPTIONS AND UNCERTAINTIES
• Scope 1 – this category captures emissions directly generated by CDI’s
owned or controlled sources. Data is collected from various sources:
fuel card data to track mobile combustion emissions from company
vehicles; refrigerant liabilities are based on installed equipment in use.
Data quality is high.
• Scope 2 – indirect emissions from purchased energy within CDI’s
operational control. Data is gathered from electricity suppliers, invoices,
and on-site electrical sub-metering for unsold or unleased, vacant
sites, and via property managers to calculate electricity emissions
(and estimate distribution loss emissions). Data quality is high and
uncertainty is low.
• Scope 3 – includes some indirect emissions from products and services
(1), T&D losses from electricity (3), waste landfilled, recycling and
composting (5), business travel (6). Waste and recycling data comes
from service providers, with calculations of emissions from landfilled,
recycled or composted (including plastics/glass aluminium, cardboard
and food scraps). Business travel emissions are tracked – air travel and
taxi emissions are primarily calculated using spend data from invoices
(relatively high uncertainty) and usage from rental cars from invoices
and supplier reports (high data quality). Measurement has also
commenced this year for additional scope 3 emissions categories and
will be reported next year including supplier spend data (1 and 2), staff
commute (7), and leased assets (13).
See more in table 2 Emissions calculation methods, data quality and sources.
ESTIMATIONS
CDI has an estimations policy which is reviewed annually and methodology
by which estimations are made across data sets within the GHG inventory.
CDI reports on a calendar year basis, meaning December data is typically
unavailable at the time of data audit and assurance in time for required
reporting timeframes.
Where December estimates are made, where feasible a year-on-year growth
rate method is applied as there can be changes in emissions trends year
on year due to national and global economic changes and seasonal market
changes. In most cases data from the full year prior is used as a proxy
multiplied by the percentage change experienced with the current year to
date (11 months) for each emission source (electricity, waste, water, petrol,
diesel, and some travel (e.g. taxi), with the exception of rental car and flight
data which includes actual travel undertaken for the full year.
Estimations within data sets are infrequent, but may be required for
incomplete sets such as where a water meter is unavailable or invoicing
occurs across reporting months or years and so is apportioned.
EXCLUSIONS FROM REPORTED GHG EMISSIONS
Following requirements of GHG protocol, and significance criteria for
inclusion within the CDI inventory defined organisation boundary and as
required by the Toit
ū accreditation programme the following emissions
scopes are included:
• All direct emission sources that contribute more than one per cent
of category 1 and 2 emissions
• Some scope 3 emission subcategories in accordance with the
criteria (based on Toit
ū accreditation requirements)
CDI have adopted the Toit
ū significance criteria which is aligned with
GHG Protocol requirements, and assesses materiality for inclusion in the
inventory based on magnitude; level of influence; risk or opportunity; sector
specific guidance; outsourcing; employee engagement; and intended use
and users (includes availability of data sets). Exclusions are specific to each
emission source and are based on the CDI agreed significance criteria.
Reasonable effort has been made to source GHG emissions data within the
business’s capacity and available resourcing (with some estimations used).
CDI is in early maturity for our GHG inventory, given that FY23 was our first
reporting period (and base year). Prioritisation of initiatives have meant
certain scope 3 operational emission categories have been excluded from
our FY24 reporting.
6
We plan to expand on our inventory in FY25.
Reference
6. CDI has elected to disclose in FY24 a partial scope 3 emissions footprint (as required by
the Toit
ū programme, where quantifiable data is available). Where data is not yet available,
Adoption Provision 4: Scope 3 GHG emissions in the NZ Climate Standard 2 is applied for
the remaining material Scope 3 items in our value chain.
Emission Source Reason for Exclusion
Scope 3 Category
6
Purchased goods and services (1)
Such as civil engineering, pre-erection work, sewerage services,
electrical, plumbing and other installation work, residential and
non-residential building and construction
Availability and influence: 3rd party data availability and quality is currently low. Spend-based
measurement has commenced, due to resourcing this will be reported in subsequent years.
We do not currently have activity level information on our suppliers’ emissions profiles
(excludes potable water supply).
Capital goods (2)
Including land holdings and commercial premises
Availability: Measurement has commenced, due to resourcing this will be reported in subsequent years.
Upstream transportation and distribution (4)Not relevant – no direct freight transportation used.
Employee commuting (7)Availability: Measurement has commenced – will report in subsequent years.
Upstream leased assets (8)Not relevant – no leased assets apart from support office (emissions included in other scope categories).
Downstream transportation and distribution (9)Not relevant – no distribution of products (sections) after point of sale.
Processing of sold products (10)Not relevant – sections are not processed after point of sale.
Use of sold products (11)Based on initial screening this needs further exploration.
End of life treatment of sold products (12)Based on initial screening this needs further exploration.
Downstream leased assets (13)Availability: information from tenanted commercial properties will be sourced and reported
in subsequent years.
This includes any existing crop growing and cattle grazing by tenants of land purchased for
future development. Unable to source or access sufficient landholding tenant related data
– de minimus for most sources.
Franchises (14)Not relevant – no franchises.
Investments (15)Land acquisitions are not included as purchases of land do not have an associated carbon footprint,
(Noting that if 'land and new buildings' were purchased, these would have an associated carbon footprint
due to embodied emissions associated with construction activity and would fall within Category 2 scope).
No other investments to disclose.
Table 2: Rationale for exclusion of emission sources.
Kewa Road, Albany, Auckland
CONTROLS, ASSURANCE AND ACCREDITATION
Internal checks are conducted for data accuracy, completeness, and
consistency. Where possible GHG data is cross-referenced with operational
data (e.g. energy use) to remove errors. Going forward data will be
reconciled quarterly. Inventory roles are delineated between providers
of data, data entry, quality control (sample checks) and review of data
for monitoring and reporting.
KPMG have provided limited assurance over the reported Scope 1, 2 and 3
emissions for the 2024 reporting period (their opinion, which includes the
scope of their work, is included in appendix 5).
For the 2024 reporting period CDI has received Carbon Reduce certification
from Toit
ū.
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

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26 | CDL Investments New Zealand Limited
APPENDIX 4:
GREENHOUSE GAS INVENTORY
– CONTINUED
References
7. Indicative data quality rating:
*** high quality (low uncertainty, usage data, complete records, no or minor estimation, verified, or direct calculation),
**moderate quality (proxy data, conversion required with higher uncertainty, mostly complete records, some estimation),
*low quality (high uncertainty, partial records only, or fully estimated).
8. Indicative data quality rating:
*** high quality (low uncertainty, usage data, complete records, no or minor estimation, verified, or direct calculation),
**moderate quality (proxy data, conversion required with higher uncertainty, mostly complete records, some estimation),
*low quality (high uncertainty, partial records only, or fully estimated).
9. The market-based emission factor consists of national grid factor from MfE and residual mix factor from BraveTrace,
using the latest aligned 12-month period available (updates are released on different cycles).
10. Indicative data quality rating:
*** high quality (low uncertainty, usage data, complete records, no or minor estimation, verified, or direct calculation),
**moderate quality (proxy data, conversion required with higher uncertainty, mostly complete records, some estimation),
*low quality (high uncertainty, partial records only, or fully estimated).
CategoryEmissions ActivityCalculation MethodData SourceData UncertaintyData Quality Rating
10
Business travel Air travel, taxi and rental
car, usage by CDI employees
for business purposes.
Volume-basedInvoice records of fuel
consumed provided by
suppliers.
It is assumed that data is
complete and accurate when
received from suppliers.
**
Distance-based Report and invoice records with
distance travelled by fuel type
used in vehicles, as provided by
car rental company.
It is assumed the data sources
are complete and accurate.
Rental car data is sourced from
supplier customer activity data.
Some estimation required due
to change in supplier mid-year.
***
Fuel and energy
related activities
Electricity losses that
are attributable to
the transmission and
distribution 'T and D'
of electricity.
Location-based Invoice records provided by
electricity suppliers, and report
from 3rd party supplier.
It is assumed data is complete
and accurate. All source data
is derived from our supplier’s
reports. Where invoices
have not been received,
consumption is estimated
based on historical usage.
***
Purchased goods
and services
Potable water supply
from CDI offices (only).
Volume-basedInvoices and rates bills from
utility providers based on water
meters where available.
It is assumed data is
complete and accurate.
Most source data is derived
from supplier records.
Some estimation required
due to billing frequency.
**
Waste generated
in operations
Waste to landfill, recycling
and compost diverted, from
CDI office and commercial
premises fit out.
Weight-basedBased on waste collector
supplier records based on bin
weights or estimates of volume
of bins collected.
It is assumed data is complete
and accurate. Proportion of
building and floor applied.
All source data is derived from
supplier records (some volume
conversions applied).
**
Table 3: Emissions calculation methods, data quality and sources (continued).
CategoryEmissions ActivityCalculation MethodData SourceData UncertaintyData Quality Rating
7
Transport
energy (mobile
combustion)
Consumption of liquid fuels
for transport purposes
(diesel and petrol) by
leased fleet vehicles.
Volume-basedInvoice records of fuel
consumed provided by
suppliers.
It is assumed that data is
complete and accurate when
received from suppliers.
***
Leakage of
refrigerants
(fugitive emissions)
Refrigerants used
in commercial air
conditioning units.
Top up methodService records of refrigerant
top-up amounts. Refrigerant
liabilities determined based on
the HVAC refrigerant capacity
and type.
It is assumed that data is
complete and accurate when
received from suppliers/
maintenance records.
***
Table 3: Emissions calculation methods, data quality and sources.
SCOPE 1 CDI’S DIRECT OPERATIONAL EMISSIONSSCOPE 3 CDI’S INDIRECT SUPPLY CHAIN EMISSIONS
CategoryEmissions ActivityCalculation MethodData SourceData UncertaintyData Quality Rating
8
Electricity
consumption
Electricity used by CDI’s
portion of office space, and
unsold, unleased, or vacant
commercial properties.
Location-based
(and market-based
respectively).
9
Invoice records provided by
electricity suppliers, and
report from 3rd party supplier.
It is assumed that data is
complete and accurate when
received from suppliers.
Most source data is derived
from supplier’s reports.
December data is estimated
due to proximity to year-end.
***
SCOPE 2 CDI’S INDIRECT EMISSIONS FROM THE CONSUMPTION OF PURCHASED ELECTRICITY
Iona Terraces, Havelock North, Hawke's Bay
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

CDL Investments New Zealand Limited | 29

28 | CDL Investments New Zealand Limited
APPENDIX 4:
GREENHOUSE GAS INVENTORY
– CONTINUED
Reference
11. The market-based emission factor consists of national grid factor from MfE and residual
mix factor from BraveTrace, using the latest aligned 12-month period available (updates
are released on different cycles).
SubcategoryActivitySourcePublisher and publication
Scope 1: Mobile combustion
(including company owned or leased vehicles)
Petrol premiumGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 1: Mobile combustion
(including company owned or leased vehicles)
Petrol regularGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024 MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 2 Imported electricityElectricity (location-based)Government-published emission factorsNew Zealand Ministry for the Environment, 2024 MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 2 Imported electricityElectricity (market-based)Government-published emission factorsNew Zealand Ministry for the Environment, 2024 MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
11
Scope 3: Fuel and energy related activities
– transmission of energy
Electricity distributed T&D losses
(location-based)
Government-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Fuel and energy related activities
– transmission of energy
Electricity distributed T&D losses
(market-based)
Industry publication or dataNew Zealand Energy Certificate System. Administered and developed by Certified Energy, New Zealand.
Scope 3: Business travel transport
(non-company owned vehicles)
Air passenger transport
(spend-based)
Private company/consultantMarket Economics Limited (2023). Consumption Emissions Modelling, report prepared for Auckland Council.
Scope 3: Business travelRental car average (petrol, diesel, hybrid, EV)Government-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Business travelTaxiGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Business travelEV chargingGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024 MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Business travelEV charging (T&D losses)
Toit
ū derivedToitū Envirocare. Emission factor derived internally. Wellington, New Zealand, based on the MfE electricity T&D losses factor.
Scope 3: Waste generated in operations
– disposal of solid waste – landfilled
Waste landfilled no LFGR
Office waste
Government-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Waste generated in operations
– recycling process
Recycling - cardPeer-reviewed journal or literatureTurner et al. (2015) Greenhouse gas emission factors for recycling of source-segregated waste materials. Resources, Conservation and Recycling. 2015, Pages 186–197.
Scope 3: Waste generated in operations
– recycling process
Recycling – commingledPeer-reviewed journal or literatureTurner et al. (2015) Greenhouse gas emission factors for recycling of source-segregated waste materials. Resources, Conservation and Recycling. 2015, Pages 186–197.
Scope 3: Waste generated in operations
Disposal of solid waste – not landfilled
CompostingGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Scope 3: Purchased goods and services Water supplyGovernment-published emission factorsNew Zealand Ministry for the Environment, 2024. MfE Guidance for Voluntary Greenhouse Gas Reporting. Wellington, New Zealand.
Table 4: Emission factor sources.
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

CDL Investments New Zealand Limited | 31


© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited,
a private English company limited by guarantee. All rights reserved.

Document classification: KPMG Public

Independent Limited Assurance
Report to CDL Investments New
Zealand Limited

Conclusion
Our limited assurance conclusion has been formed on the basis of the matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable assurance engagement or an audit,
nothing has come to our attention that would lead us to believe that, in all material respects, the scope 1, 2
and 3 gross greenhouse gas emissions, additional required disclosures of scope 1, 2 and 3 gross greenhouse
gas emissions and scope 1, 2 and 3 gross greenhouse gas emissions methods, assumptions and estimation
uncertainty disclosures included in Appendix 4 of the 2024 Climate Statement on pages 22 to 29 (GHG
disclosures) are not fairly presented and prepared in accordance with the Aotearoa New Zealand Climate
Standards (NZ CSs) issued by the External Reporting Board (the criteria) for the period 1 January 2024 to 31
December 2024.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to CDL Investments New Zealand
Limited’s GHG disclosures for the period 1 January 2024 to 31 December 2024.
Our assurance engagement does not extend to the following:
• Climate-related disclosures on pages (pages 1-21, 36-37); and
• Any comparative GHG information and GHG Emissions Intensity metrics (referenced throughout)
We have not performed any procedures with respect to the other information.
Criteria
The criteria used as the basis of reporting are the Aotearoa New Zealand Climate Standard (NZCS) 1 Climate
Related Disclosures (NZCS1), NZCS 2 Adoption of Aotearoa New Zealand Climate Standards (NZCS2) and
NZCS 3 General Requirements for Climate-related Disclosures (NZCS3), collectively the Aotearoa New Zealand
Climate Standards' (NZ CSs) issued by the External Reporting Board (XRB).
As permitted by the NZCS1 para. 24(a), the standards that CDL Investments New Zealand Limited’s greenhouse
gas emissions are measured in accordance with are the World Resources Institute and World Business Council
for Sustainable Development’s Greenhouse Gas Protocol standards and guidance (collectively, the GHG
Protocol):

© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited,
a private English company limited by guarantee. All rights reserved.

Document classification: KPMG Public

Independent Limited Assurance
Report to CDL Investments New
Zealand Limited

Conclusion
Our limited assurance conclusion has been formed on the basis of the matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable assurance engagement or an audit,
nothing has come to our attention that would lead us to believe that, in all material respects, the scope 1, 2
and 3 gross greenhouse gas emissions, additional required disclosures of scope 1, 2 and 3 gross greenhouse
gas emissions and scope 1, 2 and 3 gross greenhouse gas emissions methods, assumptions and estimation
uncertainty disclosures included in Appendix 4 of the 2024 Climate Statement on pages 22 to 29 (GHG
disclosures) are not fairly presented and prepared in accordance with the Aotearoa New Zealand Climate
Standards (NZ CSs) issued by the External Reporting Board (the criteria) for the period 1 January 2024 to 31
December 2024.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to CDL Investments New Zealand
Limited’s GHG disclosures for the period 1 January 2024 to 31 December 2024.
Our assurance engagement does not extend to the following:
• Climate-related disclosures on pages (pages 1-21, 36-37); and
• Any comparative GHG information and GHG Emissions Intensity metrics (referenced throughout)
We have not performed any procedures with respect to the other information.
Criteria
The criteria used as the basis of reporting are the Aotearoa New Zealand Climate Standard (NZCS) 1 Climate
Related Disclosures (NZCS1), NZCS 2 Adoption of Aotearoa New Zealand Climate Standards (NZCS2) and
NZCS 3 General Requirements for Climate-related Disclosures (NZCS3), collectively the Aotearoa New Zealand
Climate Standards' (NZ CSs) issued by the External Reporting Board (XRB).
As permitted by the NZCS1 para. 24(a), the standards that CDL Investments New Zealand Limited’s greenhouse
gas emissions are measured in accordance with are the World Resources Institute and World Business Council
for Sustainable Development’s Greenhouse Gas Protocol standards and guidance (collectively, the GHG
Protocol):



• Scope 1 emissions have been measured in accordance with The Greenhouse Gas Protocol: A Corporate
Accounting and Reporting Standard (revised edition)
• Scope 2 emissions have been measured in accordance with The Greenhouse Gas Protocol: GHG Protocol
Scope 2 Guidance: An amendment to the GHG Protocol Corporate Standard
• Scope 3 emissions have been measured in accordance with The Greenhouse Gas Protocol: Corporate
Value Chain (Scope 3) Accounting and Reporting Standard.
As a result, this report may not be suitable for another purpose.
Standards we followed
We conducted our limited assurance engagement in accordance with New Zealand Standard on Assurance
Engagements 1 (NZ SAE 1) Assurance Engagements over Greenhouse Gas Emissions Disclosures and
International Standard on Assurance Engagements (New Zealand) 3410 Assurance Engagements on
Greenhouse Gas Statements (ISAE (NZ) 3410) issued by the New Zealand Auditing and Assurance Standards
Board (Standard). We believe that the evidence we have obtained is sufficient and appropriate to provide a
basis for our conclusion.
Our responsibilities under the Standard are further described in the ‘Our responsibility’ section of our report.
Key Matters
Key matters are those matters that, in our professional judgement, were of most significance in undertaking our
assurance engagement over the GHG disclosures for the period 1 January 2024 to 31 December 2024.
Our procedures were undertaken in the context of and solely for the purpose of our assurance conclusion on the
GHG disclosures and we did not reach a separate conclusion on each individual key matter.
Key Matter Procedures to address the Key Matter
Determination and selection of the organisational boundary
Refer to Organisational boundary and
Consolidation approach section, page 23,
within the accompanying GHG disclosures.
In establishing the organisational boundary,
an approach for consolidating GHG emissions
is selected. As included in the disclosure, the
organisational boundary has been changed in
2024 to an operational control approach, the
base year previously used an equity share
approach.
We have focused on this area as a key audit
matter as there is complexity and judgement
on where to draw the organisational
boundary, due to multiple approaches being
allowed, and impacts of changing the
boundary. The organisational boundary also
provides the frame for what is included within
each emission category. Therefore, changes
to the boundary can have a pervasive impact
on the overall footprint.
Our assurance procedures included:
• Inquiring with relevant staff, the legal VP and
sustainability manager, to understand and assess the
appropriateness of the change in organisational boundary
against the requirements of the GHG protocol.
• Comparing the accompanying disclosures in respect of
the change in boundary to the criteria.
• Assessing against the GHG protocol reporting standards
whether the change in organisational boundary requires
a
base year recalculation, and the appropriateness of
managements base year recalculation policy.


INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES
APPENDIX 5:
KPMG LIMITED ASSURANCE

CDL Investments New Zealand Limited | 33

32 | CDL Investments New Zealand Limited



Other Matter – Prior year comparatives not assured
The GHG disclosures for the period 1 January 2023 to 31 December 2023 were not subject to our limited
assurance engagement and, accordingly, we do not express a conclusion, or provide any assurance on such
information.
Our conclusion is not modified in respect of this matter.
How to interpret limited assurance and material misstatement
A limited assurance engagement is substantially less in scope than a reasonable assurance engagement in
relation to both the risk assessment procedures, including an understanding of internal control, and the
procedures performed in response to the assessed risks.
Misstatements, including omissions, within the GHG disclosures are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the relevant decisions of the intended users taken on
the basis of the GHG disclosures.
Inherent limitations
GHG quantification is subject to inherent uncertainty because of incomplete scientific knowledge used to
determine emission factors and the values needed to combine emissions of different gases.
Use of this assurance report
Our report is made solely for CDL Investments New Zealand Limited. Our assurance work has been undertaken
so that we might state to CDL Investments New Zealand Limited those matters we are required to state to them
in the assurance report and for no other purpose.
Our report is released to CDL Investments New Zealand Limited and its shareholders on the basis that it shall
not be copied, referred to or disclosed, in whole or in part, without our prior written consent. No other third party
is intended to receive our report.
Our report should not be regarded as suitable to be used or relied on by anyone other than CDL Investments
New Zealand Limited for any purpose or in any context. Any other person who obtains access to our report or a
copy thereof and chooses to rely on our report (or any part thereof) will do so at its own risk.
To the fullest extent permitted by law, none of KPMG, any entities directly or indirectly controlled by KPMG, or
any of their respective members or employees accept or assume any responsibility and deny all liability to
anyone other than CDL Investments New Zealand Limited for our work, for this independent assurance report,
and/or for the opinions or conclusions we have reached.
Our conclusion is not modified in respect of this matter.
CDL Investments New Zealand Limited’s responsibility for the GHG
disclosures
The Management of CDL Investments New Zealand Limited are responsible for the preparation and fair
presentation of the GHG disclosures in accordance with the criteria. This responsibility includes the design,
implementation and maintenance of such internal control as Management determine is relevant to enable the
preparation of the GHG disclosures that are free from material misstatement whether due to fraud or error.
The Management of CDL Investments New Zealand Limited are also responsible for selecting or developing
suitable criteria for preparing the GHG disclosures and appropriately referring to or describing the criteria used.
Our responsibility
We have responsibility for:
•planning and performing the engagement to obtain limited assurance about whether the GHG
disclosures are free from material misstatement, whether due to fraud or error;
•forming an independent conclusion based on the procedures we have performed and the evidence we
have obtained; and
•reporting our conclusion to CDL Investments New Zealand Limited.
Summary of the work we performed as the basis for our conclusion
A limited assurance engagement performed in accordance with the Standard involves assessing the suitability in
the circumstances of CDL Investments N ew Zealand Limited’s use of NZ C Ss as the basis for the preparation of
the GHG disclosures, assessing the risks of material misstatement of the GHG disclosures whether due to fraud
or error, responding to the assessed risks as necessary in the circumstances, and evaluating the overall
presentation of the GHG di sclosures.

We exercised professional judgment and maintained professional scepticism throughout the engagement. We
designed and performed our procedures to obtain evidence about the GHG disclosures that is s ufficient and
appropriate to provide a basis for our conclusion.
Our procedures selected depended on the understanding of the GHG disclosures that is sufficient and
appropriate to provide a basis for our conclusion. The procedures we performed were based on our
professional judgment and included inquiries, observation of processes performed, inspection of documents,
analytical procedures, evaluating the appropriateness of quantification methods and reporting policies, and
agreeing or reconciling with underlying records.
In undertaking limited assurance on the GHG disclosures the procedures we primarily performed were:
•obtaining, through inquiries, an understanding of CDL Investments New Zealand Limited’s control
environment, processes and information systems relevant to the preparation of the GHG disclosures.
We did not evaluate the design of particular control activities, or obtain evidence about their
implementation;
•inquiring with relevant staff regarding any matters that arose in the application of the selected boundary
in establishing the emissions inventory;
•performing walkthroughs of key processes and data sets;
•agreeing a selection of GHG emissions data to relevant underlying source documents and re-performed
emission factor calculations for a limited number of items;
•considering the presentation and disclosures of the GHG emissions and explanatory notes against the
requirements of the NZ CSs.
The procedures performed in a limited assurance engagement vary in nature and timing from, and are less in
extent than for a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited
assurance engagement is substantially lower than the assurance that would have been obtained had a
reasonable assurance engagement been performed.
Our independence and quality management
This assurance engagement was undertaken in accordance with NZ SAE 1. NZ SAE 1 is founded on the
fundamental principles of independence, integrity, objectivity, professional competence and due care,
confidentiality and professional behaviour.
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

CDL Investments New Zealand Limited | 35

34 | CDL Investments New Zealand Limited



We have complied with the independence and other ethical requirements of Professional and Ethical Standard 1
International Code of Ethics for Assurance Practitioners (including International Independence Standards) (New
Zealand) (PES 1) issued by the New Zealand Auditing and Assurance Standards Board, which is founded on
fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and
professional behaviour.
The firm applies Professional and Ethical Standard 3 Quality Management for Firms that Perform Audits or
Reviews of Financial Statements, or Other Assurance or Related Services Engagements (PES 3), which requires
the firm to design, implement and operate a system of quality control including policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
We have also complied with Professional and Ethical Standard 4 Engagement Quality Reviews (PES 4) which
deals with the appointment and eligibility of the engagement quality reviewer and the engagement quality
reviewer’s responsibilities relating to the performance and documentation of an engagement quality review.
Our firm has also provided other services to the group in relation to a statutory audit of the financial statements,
taxation compliance and taxation advisory services to CDL Investments New Zealand Limited. Subject to certain
restrictions, partners and employees of our firm may also deal with CDL Investments New Zealand Limited on
normal terms within the ordinary course of trading activities of the business of CDL Investments New Zealand
Limited. These matters have not impaired our independence as assurance providers of CDL Investments New
Zealand Limited for this engagement. The firm has no other relationship with, or interest in, CDL Investments
New Zealand Limited.
As we are engaged to form an independent conclusion on the GHG disclosures prepared by CDL Investments
New Zealand Limited, we are not permitted to be involved in the preparation of the GHG disclosures as doing so
may compromise our independence.
The engagement partner on the assurance engagement resulting in this independent assurance report is Geoff
Lewis.



KPMG
Auckland
28 April 2025
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES

CDL Investments New Zealand Limited | 37

36 | CDL Investments New Zealand Limited
APPENDIX 6:
TOITU CERTIFICATION
INTRODUCTION
STRATEGY
GOVERNANCE
METRICS AND TARGETS
APPENDICES
This is to certify that
Please refer to the annual statement on www.toitu.co.nz for further details.
Toitū carbonreduce is an annual certification programme and this certificate only remains valid with an annual surveillance audit.
WWW.JAS-ANZ.ORG/REGISTER
Certified by Enviro-Mark Solutions Limited (Trading as
Toitū Envirocare)
Billy Ziemann— Certifier
CDL Investments New Zealand Limited
is Toitū carbonreduce organisation certified.
Toitū carbonreduce certified means measuring emissions to ISO 14064-1:2018 and
Toitū requirements; and managing and reducing against Toitū requirements.
Date issued: 28 April 2025 | Valid until: 31 January 2027
Certificate Number: 2024024J | Certification Status: Certified Organisation
Company Address: Level 7, 23 Customs Street East, Auckland, 1010, New Zealand
Level of Assurance: Limited for all categories
Certification Year Auditor: KPMG
Certification Year Assurer: Toitū Envirocare

38 | CDL Investments New Zealand Limited