thl releases FY25 Climate Statements
Tourism Holdings Limited
470 Oruarangi Road, Māngere,
Auckland 2022
PO Box 4293, Shortland Street,
Auckland 1140, New Zealand
www.thlonline.com
9 October 2025
NZX | ASX | MEDIA RELEASE
TOURISM HOLDINGS LIMITED (thl)
FY25 CLIMATE STATEMENTS
Tourism Holdings Limited (NZX:THL, ASX:THL, “thl” or “the Company”) advises that it has published its Climate
Statements for FY25. A copy is attached with this announcement.
ENDS
Authorised by:
Grant Webster
CEO, Tourism Holdings Limited
For further information contact:
Media:
Grant Webster
thl Chief Executive Officer
Direct Dial: +64 9 336 4255
Mobile: +64 21 449 210
Investors and Analysts:
Amir Ansari
General Manager – Investor Relations & Group Planning
Direct Dial: +64 9 336 4203
Mobile: +64 21 163 8053
About thl (www.thlonline.com)
thl is a global tourism operator listed on the NZX and ASX (code: THL) and is the largest commercial RV rental operator
in the world. In New Zealand/Australia, thl operates rental brands (Maui, Britz, Apollo, Mighty, Hippie, Cheapa Campa),
manufacturing (Action Manufacturing, Apollo), retail brands (Talvor, Kea, Winnebago, Adria, Coromal, Windsor), retail
dealerships (RV Super Centre, Apollo RV Sales, George Day, Camperagent), travel technology (Triptech) and tourism
attractions (Kiwi Experience and the Discover Waitomo Group, which includes Waitomo Glowworm Caves, Ruakuri Cave,
Aranui Cave and The Legendary Black Water Rafting Co.). In North America, thl operates the Road Bear RV, El Monte RV,
CanaDream, Britz and Mighty rental brands. In UK and Europe, thl operates the Just go, Apollo and Bunk Campers rental
brands.
---
CLIMATE-RELATED
DISCLOSURES 2025
FY25 CLIMATE
STATEMENTS
CONTENTS
ABOUT THESE CLIMATE STATEMENTS 3
INTRODUCTION FROM CHAIR & CEO 5
GOVERNANCE 6
Governance body oversight 8
Management’s role 9
STRATEGY 10
About thl 10
At a glance 11
Creating value 12
Global future-fit sustainability programme 13
Current climate-related impacts 14
Climate scenarios 16
Scenario narratives 18
Overview of thl’s scenario analysis process for FY25 22
CLIMATE-RELATED RISKS AND OPPORTUNITIES 23
Low-emissions fleet transition risk 25
Regulatory compliance risk 26
Fleet investment return risk 27
Decarbonisation demand-driven Risk 28
Climate impact on booking patterns risk 29
Mobile housing and emergency response opportunity 30
Transition plan – Changing Gear 31
METRICS AND TARGETS 34
Future-Fit Business Benchmark 34
GHG emissions 36
GHG target 40
Climate metrics 41
Emissions intensity 41
Vulnerability to transition risks 41
Vulnerability to physical risks 42
Climate-related opportunities 42
Capital deployment 43
Internal emissions price 43
Remuneration 43
APPENDIX 1: GLOSSARY OF TERMS 44
APPENDIX 2: NZ CS CONTENT INDEX 46
APPENDIX 3: GHG METHODS AND ASSUMPTIONS 50
Independent Assurance Report to tourism holdings limited 58
Appendix 1 includes a glossary of commonly used terms, acronyms and icons
referenced throughout this report.
ABOUTINTRODUCTION2thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
ABOUT THESE CLIMATE STATEMENTS
The Directors of Tourism Holdings Limited (thl) are pleased to present to shareholders
the thl Climate Statements for thl and its controlled entities (together, the Group) for the
year ended 30 June 2025 (FY25). FY25 marks thl’s fourth year of climate disclosures and
our second year of mandatory disclosures as a climate reporting entity captured by the
New Zealand Financial Markets Conduct Act 2013. These Climate Statements include our
mandatory climate-related disclosures for the reporting period from 1 July 2024 to 30 June
2025 and cover four thematic areas: governance; strategy; risk management; and metrics
and targets.
These climate-related disclosures comply with the Aotearoa New Zealand Climate
Standards (NZ CS) 1, 2 and 3, issued by the External Reporting Board (XRB). An index table
of the disclosures in this CRD is provided in Appendix 2.
We report on progress since the FY24 Climate Statements, including work done to
continue to mature and develop existing disclosure areas such as climate scenarios and
the greenhouse gas (GHG) inventory reporting informed by feedback from our auditors
and external advisors, as well as the general feedback published by the New Zealand
Financial Markets Authority (NZ FMA) following the end of the first year of mandatory
climate disclosures.
Two new mandatory disclosures are included this year, following the end
of FY24 adoption provisions:
•
Current financial impacts – see pages 14-15.
•
Transition planning – see pages 31-33.
In November 2024, the XRB amended NZ CS 2, extending adoption provisions available
for FY25. thl has chosen to apply the following provisions for this FY25 report, meaning
these Climate Statements do not cover these aspects of NZ CS:
•
Adoption provision 2: Anticipated financial impacts – see page 23.
•
Adoption provision 6: Comparatives for metrics (partial – reporting on one year) –
see page 34.
•
Adoption provision 7: Analysis of trends – see page 34.
Disclaimer
This report sets out thl’s maturing approach to scenario analysis, as well as our current
understanding of and response to our climate-related risks and opportunities and our
initial understanding of the current and anticipated impacts of climate change. These
disclosures reflect thl’s current understanding as at October 2025 in respect of the
12 months ended 30 June 2025.
These Climate Statements contain disclosures that rely on early and developing
assessments of current and forward-looking information, incomplete and estimated
data, and our related judgements, opinions and assumptions. We have sought to
provide accurate information in respect of the year ended 30 June 2025, but we caution
reliance being placed on representations that are necessarily subject to significant
risks, uncertainties and/or assumptions. Climate change is an evolving challenge, with
high levels of uncertainty and significant data challenges, particularly over long-term
horizons. Descriptions of the current and anticipated impacts of the climate on thl and
its subsidiaries are therefore necessarily estimates only.
In particular, these statements contain forward-looking statements and opinions such
as potential impacts; climate scenario narratives; targets; forecasts; potential global
responses to climate change; government policy; regulatory developments; development
of various technologies; future plans, strategies and objectives of management; and
statements of thl’s current intentions.
Forward-looking statements and opinions are based on historical experience, internal
business data, external sources and various other factors that thl believes are reasonable
in the circumstances and based on our current understanding. These statements and
opinions necessarily involve assumptions, forecasts and projections about our present
and future strategies and the environment in which we will operate in the future. They
reflect thl’s current views on future events and are subject to change due to known and
unknown risks, uncertainties, assumptions, estimates and other factors that are, in many
cases, beyond thl’s control, particularly as to inputs, available data and information that is
likely to change.
Risks and opportunities described in this report and thl’s strategies to achieve our targets
may not eventuate or may be more or less significant than anticipated. Many factors can
affect thl’s actual results, performance or achievement of climate-related targets (or other
metrics), and these may differ materially from what is described in this report, including
due to economic and technological viability and government, consumer and market
factors outside of thl’s control.
INTRODUCTION3thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETSABOUT
Accordingly, while thl has made efforts to fairly present these climate-related disclosures,
thl gives no representation, guarantee, warranty or assurance about the future business
performance of thl or that the outcomes expressed or implied in any forward-looking
statement made in this document will occur. Actual outcomes may differ materially from
those expressed or implied in this document. thl does not accept any liability for any
loss arising directly or indirectly from any use of the information contained in this report,
whether in respect of thl and/or its subsidiaries.
thl expects that some forward-looking statements made in this document may be
amended, updated, recalculated and restated in future documents as the quality and
completeness of its data and methodologies continue to evolve and improve. thl does
not represent that:
•
those statements and opinions will not change or will remain correct after publishing
this report, or
•
it will revise or update those statements and opinions if events or circumstances change
or unanticipated events happen after publishing this report.
This disclaimer should be read along with the methodologies, assumptions, uncertainties
and limitations contained in this report. This report is not an offer document and does not
constitute an offer or invitation or investment recommendation to distribute or purchase
securities, shares or other interests. Nothing in this report should be interpreted as capital
growth, earnings or any other legal, financial, tax or other advice or guidance. For detailed
information on our financial and sustainability performance, please refer to our Integrated
Annual Report, available at www.thlonline.com/financialinvestorinformation.
ABOUTINTRODUCTION4thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
INTRODUCTION FROM CHAIR & CEO
As we present our FY25 Climate Statements, we reflect on a year
of meaningful progress and evolving challenges. This marks our
second year of climate-related disclosure under the mandatory
regime introduced by the NZ FMA. Our commitment to
transparency and accountability in managing climate-related
risks and opportunities remains.
A key milestone this year is the development of our transition plan, Changing Gear.
Progress made against metrics and targets is monitored via regular reporting to the
HSSC. The plan outlines our strategic approach to supporting the shift to a low-emissions
economy. It sets out the actions, timelines and dependencies that guide our efforts, and
it reflects actions underway and our understanding of the pathways available to reduce
emissions and build long-term resilience across our operations.
In FY25, our GHG inventory saw a notable reduction, largely driven by softer market
conditions resulting in lower unit sales in our manufacturing and retail businesses.
While this contributed to a temporary decline in emissions, we do not expect this trend
to continue as market conditions stabilise. Our focus remains on identifying emissions
reductions and efficiencies that are decoupled from sales volumes.
Climate change continues to have an impact on our business – and our business, in turn,
has a role to play in addressing it. The tourism and transportation sectors, which are
central to our operations, are particularly exposed to both physical and transition risks.
Extreme weather events can disrupt access to tourist destinations and bookings, while
regulatory developments introduce strategic uncertainty. At the same time, shifting
customer preferences and emerging opportunities in mobile resilience are shaping
our long-term planning and investment decisions.
One of the most complex challenges we face is transitioning our fleet to low-emissions
vehicles. As a technology taker, we depend on original equipment manufacturers (OEMs)
to develop suitable zero or low-emissions chassis for our recreational vehicles. The current
lack of cost-effective, long-range, low-emissions technology remains a significant barrier
– particularly in light of macroeconomic headwinds, economic conditions and slowing
momentum on regulation in some regions.
Despite these challenges, we remain proactive. We are continuing to engage with
OEMs globally, exploring pilot programmes for low-emissions vehicles and closely
tracking developments in fleet technology. Our Future Fleet workstream is focused
on seeking to identify practical, time-appropriate and cost-effective pathways to
transition our global fleet.
As we navigate these complexities, our focus is clear: to build a resilient and sustainable
business that can thrive in a low-emissions future. We remain committed to continuous
improvement, transparency and collaboration as we work towards our climate goals.
We appreciate you taking the time to read our FY25 Climate Statements. Your insights
and feedback are important to us as we continue to evolve our approach. If you have ideas,
questions or suggestions, we welcome you to get in touch at info@thlsustainability.com.
Cathy Quinn ONZM Grant Webster
CHAIR CEO
08 October 2025
CATHY QUINN ONZM
CHAIR
GRANT WEBSTER
CEO
ABOUT5thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETSINTRODUCTION
GOVERNANCE
thl’s Board
1
is ultimately responsible for setting and overseeing
thl’s strategic direction and overseeing Group-wide risks and
opportunities, including those relating to climate change. Climate
governance is embedded across the organisation, with clear roles
and responsibilities at Board, executive and operational levels.
Two Board subcommittees play a central role in climate oversight:
•
The Audit and Risk Committee (ARC) oversee thl’s risk management frameworks,
assurance engagements and compliance of disclosures.
•
The Health, Safety and Sustainability Committee (HSSC) provides oversight
of sustainability strategy, including climate-related initiatives, setting of targets
and performance.
These subcommittees are supported by thl executives and senior management and
receive regular reports from thl’s new Climate Working Group (CWG). Following each
subcommittee meeting, the relevant Chair provides a verbal update to the full Board,
providing regular engagement and oversight.
thl’s CWG, established in FY25, plays a central role in overseeing the development and
implementation of the CWG Work Plan – thl’s internal work plan to manage progress on
climate-related initiatives, including the various workstreams that enable thl to meet all
disclosure requirements under NZ CS (see Figure 2).
Figure 1 illustrates the governance, management and operational structures involved in
addressing climate-related risks and opportunities within thl.
1. Refer to the governance section in the thl Integrated
Annual Report 2025 from page 96 for a list of Board
members and Board subcommittee composition.
ABOUTINTRODUCTION6thl CLIMATE-RELATED DISCLOSURES 2025STRATEGYAPPENDIXMETRICS AND TARGETSGOVERNANCE
RRN
OPERATIONAL
MANAGEMENT
BOARD
The thl Board holds overall responsibility for strategic direction and Group-wide risks and opportunities, including climate-related transition and physical risks
and opportunities. The Board receives updates from its subcommittees and senior management on climate-related risks and opportunities and the setting of and
performance against targets. The Board also approves and signs off on thl’s climate-related disclosures.
The RQA function is
responsible for overseeing
and integrating key
functions within
thl including ERM;
Health, Safety, and
Wellbeing (HSW); Policy
Development; and Internal
Audit. This function
manages an integrated
risk framework, maintains
compliance with relevant
standards and drives
continuous improvement
across the organisation.
The RQA Lead oversees
the ERM framework
and reports key risks up
to ARC.
thl’s Risk Owners are members of thl’s executive team with management responsibility for risks
within their operational or support function. The ERM framework is implemented at this level,
with all risks discussed at executive ‘Front & Centre’ meetings and concerns escalated to Senior
Executive (or ARC as required). Risk Owners implement controls and share relevant information
and initiatives with their business function.
Risk Owners
The ARC oversees thl’s Enterprise Risk Management (ERM) framework and the
management of Group-wide risks and opportunities, including climate-related
transition and physical risks and opportunities. It reviews climate-related
disclosures for compliance with standards, engages assurance practitioners
and recommends approval of climate-related disclosures to the Board.
Heath, Safety, and Sustainability Committee (HSSC)
thl
BOARD
thl’s operational and support functions contribute to ERM by identifying and escalating
risks, supporting Risk Owners in implementing controls through adherence to policies and
procedures and performing directed activities. They also provide timely and accurate data
or reporting to support visibility and inform decision-making.
Operational Teams
Audit and Risk Committee (ARC)
Risk, Quality, Assurance
(RQA) Function
The CWG is a cross-
functional group set up
to develop and embed
elements of all workstreams
under the CWG Work Plan
throughout the business
and meet CRD reporting
requirements.
This working group oversees
the measurement and
response of climate and
carbon related initiatives.
The full working group
receives monthly updates
on progress and challenges
and provides strategic
guidance and regular
reporting to the Board
and subcommittees
on climate-related
workstreams.
Climate Working
Group (CWG)
The thl HSSC oversees thl’s sustainability strategy as set out in our global
future-fit sustainability programme (see page 13), including climate-related
initiatives. It monitors development and progress against metrics and
targets, greenhouse gas inventories, and thl’s transition plan on behalf of
the Board.
Figure 1: thl’s climate governance structure
thl’s CEO and CFO oversee the Risk, Quality, Assurance Function and Climate Working Group.
Acting as the key interface between the Board and business operations, they are responsible
for strategic risks and opportunities, including those related to climate change, and for
monitoring risk management progress across the organisation.
Chief Executive Officer (CEO) and Chief Financial Officer (CFO)
ABOUTINTRODUCTION7thl CLIMATE-RELATED DISCLOSURES 2025STRATEGYAPPENDIXMETRICS AND TARGETSGOVERNANCE
Governance body oversight
The Board receives regular updates on climate-related risks and opportunities (CR&Os)
through structured governance channels. The ARC and HSSC each convene at least three
times annually, with climate-related matters as standing agenda items and management
providing updates on CR&Os, emissions data and regulatory developments. Following
each subcommittee meeting, the respective Chair provides a verbal update to the full
Board on discussion points and recommendations at the subsequent Board meeting.
These sessions keep the Board consistently informed and engaged in climate governance.
In addition to the Board subcommittee members, these meetings are attended by
the Chief Executive Officer (CEO), Chief Financial Officer (CFO), Deputy CFO (DCFO)
(in respect of Board and ARC meetings only), Company Secretary (CoSec) and other senior
management on invitation.
Table 1: thl Board and subcommittee meetings
BoardBoard subcommittees
Audit and Risk
Committee
Health, Safety and
Sustainability Committee
Number of independent
Board members attending
543
Executive members
attending
CEO, CFO, DCFO,
CoSec, Executive
Director
CEO, CFO, DCFO,
CoSec
CEO, CFO, CoSec
Minimum meetings to
be convened annually
under Charter
633
Number of meetings
convened in FY25
1486
Climate-related skills and competencies
The Board sees that members’ skills and competencies in climate-related matters are
developed and maintained through regular briefings, as well as workshops and external
advisory engagements such as with EY Climate Change and Sustainability Services.
The Board and subcommittees are also supported by the CWG, which brings subject
matter expertise and operational insight into climate-related issues.
Several of thl’s Directors bring experience from other climate reporting entities, and a
number are members of Chapter Zero New Zealand, enhancing the Board’s collective
understanding. Climate-related matters are regularly discussed at ARC and HSSC meetings.
Strategic oversight
We review our climate scenarios annually, with the CWG considering and recommending
any updates to thl’s CR&O’s, which are approved by the HSSC. These CR&Os are mapped to
thl’s strategic risks within thl’s enterprise risk management framework and are considered
as potential drivers and/or objectives of those strategic risks. Strategic risks are regularly
reported to the ARC via the RQA, with the ARC subsequently reporting to the Board.
thl’s strategic planning, capital allocation, and business planning processes all take into
consideration relevant strategic risks and opportunities. The Board maintains ultimate
oversight and decision-making responsibility in these areas.
When developing transition strategies and preparing climate-related disclosures, thl takes
into consideration its overall strategic direction and CR&Os. Our transition strategies and
climate-related disclosures are reviewed annually by the HSSC and ARC, before being
approved by the Board.
Metrics, goals and remuneration
The Board, through the HSSC, oversees the development and approval of climate-related
metrics and targets. These include the 23 Break-Even Goals under the Future-Fit Business
Benchmark as well as GHG emissions, financial impacts and transition milestones.
In FY19, the Board endorsed the adoption of the Break-Even Goals for internal decision-
making. Five Break-Even Goals have been prioritised based on materiality and impact and
are addressed through targeted workstreams in thl’s global sustainability programme.
We conduct an annual self-assessment health check of our progress against the 23 Break-
Even Goals, which is published in thl’s Integrated Annual Report.
As set out in our FY24 Climate Statements, thl previously set an absolute carbon reduction
target to reduce our Scope 1 and 2 emissions by 50.4% by end of FY32 from a FY20
baseline. However, as explained in more detail in the GHG emissions targets section on
page 40, in FY25, we have undertaken a review of this target to reflect the changes to our
business since thl’s merger with Apollo on 30 November 2022 and refinement to our GHG
emissions accounting approach, reflected in our FY24 GHG emissions inventory. Our new
carbon reduction target is an absolute reduction of Scope 1 and 2 emissions by 50.4% by
end of FY32 from a FY24 baseline.
We acknowledge that our updated GHG emissions reduction target represents
approximately 1% of thl’s baseline year total GHG emissions inventory, as it applies only to
Scope 1 and Scope 2 emissions. While thl has a desire to set a Scope 3 target, we believe
doing so is not currently feasible given the lack of a viable pathway to reduce vehicle
chassis emissions (for example, approximately 85% of FY24 Scope 3 GHG emissions)
and uncertainty regarding the timing and availability of technology and supporting
infrastructure. This prevents us from making commitments that would reflect a science-
aligned target covering our full GHG inventory at this time. Nonetheless, we remain
committed to progressing reductions towards our updated target and being transparent
about the limited contribution of this target to our overall footprint.
Progress made against metrics and targets is monitored via regular reporting to the HSSC.
Any material updates are highlighted in verbal updates to the Board who also have access
to HSSC papers and minutes. The Board reviews full-year results as part of the process for
preparation and release of thl’s Integrated Annual Report and Climate Statements.
In FY25, thl’s Remuneration and Nomination Committee (a Board subcommittee)
reaffirmed its decision not to include climate-related performance metrics in executive
remuneration on the basis that there are not yet substantive targets for the business,
particularly in relation to Scope 3 emissions, where emissions reduction is significantly
constrained by the limited availability of suitable zero or low-emissions chassis and
charging network infrastructure.
ABOUTINTRODUCTION8thl CLIMATE-RELATED DISCLOSURES 2025STRATEGYAPPENDIXMETRICS AND TARGETSGOVERNANCE
Management’s role
In FY25, thl established the CWG – a cross-functional team of executives and senior
managers from Sustainability, Climate, Finance and Strategy, including the CEO, CFO,
Deputy CFO, CoSec, Head of Sustainability, Head of Risk, Quality and Assurance, and
GM Finance – which is coordinated by the Climate-Related Disclosures Manager.
These roles are embedded within thl’s organisational structure and, through the CWG,
are responsible for developing and embedding elements of all workstreams within the
CWG Work Plan (Figure 2) throughout the business.
A core delivery team meets regularly to progress actions from the full working
group, Board and subcommittees. This team develops and implements initiatives,
coordinates data and activities across the business, provides monthly updates to the
CWG and thl Management Steering Committee and contributes to regular Board and
subcommittee papers.
In April 2025, the CWG held a dedicated workshop with the HSSC to review and seek
feedback on work to inform the Climate Statements and the progress on elements of
the internal CWG Work Plan. Topics included climate scenarios, risks and opportunities,
financial impacts, GHG inventory, metrics and targets, and the transition plan.
Members of the CWG act as risk champions for CR&Os, monitoring internal and external
developments and providing subject matter expertise to Risk Owners, who identify and
implement controls and report through thl’s ERM framework (see page 24).
Figure 2: FY25 CWG Work Plan workstreams
Governance and Programme Management
Climate Scenarios, Risks and Opportunities
Current and Anticipated Impacts (including Financial Impacts)
Greenhouse Gas Emissions and Assurance
Metrics and Targets
Transition Planning
Climate Disclosures and Reporting
ABOUTINTRODUCTION9thl CLIMATE-RELATED DISCLOSURES 2025STRATEGYAPPENDIXMETRICS AND TARGETSGOVERNANCE
STRATEGY
About thl
thl is a leading interconnected global operator in the RV industry with comprehensive
integration across the build (manufacturing), rental and sales segments. We operate
across New Zealand, Australia, North America, UK and Europe. Our rentals business
remains the cornerstone of thl, providing the largest contribution to earnings. This
vertically integrated model sets us apart from our global competition, and in the
Australasian markets where we are fully integrated, this has historically enabled thl to
deliver a better return on funds employed.
We have decades of experience constructing durable vehicles specifically designed
for the rental market that maximise returns from the rental phase and for the strategic
optimisation of value on sale. Our business model generates profit at each stage – during
the build, through the rental phase and on the sale of each RV – to extract the greatest
value from each RV throughout its lifecycle.
This lifecycle approach is central to thl’s value creation model (see page 12), which
integrates operational excellence, customer experience and financial performance across
each stage of the RV journey.
ABOUTINTRODUCTION10thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
BUILD/BUY
Action Manufacturing and its
subsidiaries deliver innovative,
durable and high-quality vehicle
bodies and trailers, catering to
the RV, ambulance, refrigerated
transport, logistics and mobile
health sectors.
SOUTHERN
AFRICA
Franchise
JAPAN
Franchise
RENTAL FLEET
2,586
RENTAL FLEET
2,449
RENTAL FLEET
653
RENTAL FLEET
2,876
NZ
UK
+ IRE
AU
USA
+ CAN
RV rentals
New and ex-rental
RV sales
RV and commercial
manufacturing
Tourism attractions
and activities
Digital tourism app
RV rentals
New and ex-rental RV sales
RV manufacturing
Digital tourism app
RV rentals
Ex-rental RV sales
RV rentals
Ex-rental RV sales
Digital tourism app
TOTAL RENTAL FLEET
8,564
LOCATIONS
LOCATIONS
LOCATIONS
LOCATIONS
CREW
CREW
CREW
CREW
4
18
17
21
158
619
1,125
606
TOURISM
A range of award-winning adventure
experiences and flexible touring
options – from Black Water Rafting to
the Kiwi Experience travel network to
free independent travel with our app-
based travel platform CamperMate.
SELL
Our network of sales dealerships
offers a wide range of quality new
and used motorhomes, campervans
and caravans, after-sales and
service options and extensive retail
ranges – everything the lifetime RV
owner needs.
RENT
We are a global leader in recreational
vehicle brands, offering enriching
experiences for travellers worldwide.
Our diverse range of brands provide
opportunities to embrace the RV lifestyle,
with options tailored to meet the needs
and preferences of different demographics.
thl AS AT 30 JUNE 2025
AT A GLANCE
ABOUTINTRODUCTION11thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
CREATING VALUE
OUR RESOURCESBUSINESS MODELOUR IMPACTS AND OUTCOMES
OUR PURPOSE
OUR VALUES
Creating
unforgettable
journeys
Do the right thing
Be curious
Be happy to
Enjoy the ride
INFRASTRUCTURE
Our multinational operations,
facilities and equipment
Our global systems and
technology
KNOWLEDGE
Our knowledge, skills and RV
expertise from our vertically
integrated build/buy-rent-sell
model
NATURE
The natural resources,
ecosystems and destinations
on which we depend
RELATIONSHIPS
Our partners, industry
relationships and community
connections
OUR CREW
Our talented crew and
commitment to our core
values
FINANCIAL
Our investors and access to
capital
RENT
BUILD/BUY
SELL
ACTIVE GOVERNANCE AND RISK MANAGEMENT
•
Revenue, growth and financial returns.
•
Worldwide, world-class RV products and services.
•
Guest travel and tourism experiences.
•
Vertically integrated, multinational global RV business.
•
Climate impacts and carbon emissions from our fleet and operations.
•
Transition plan to address climate-related risks and opportunities.
•
Impacts of our products in communities and destinations guests visit.
•
Promoting regenerative travel that positively impacts destinations.
•
The sensitive ecosystems in which we operate in Waitomo, New Zealand.
•
Resources used by our fleet and operations – fuel, energy and water
– and the emissions and waste our activities generate.
•
New fleet, technology, product design and development innovation.
•
Action to address our greatest climate and carbon challenge – the
emissions from our vehicle fleet.
•
Strong, long-term supplier relationships in RV and tourism sectors.
•
Complex global supply chain has social, environmental and
economic impacts.
•
Global network of sites and infrastructure expanded manufacturing
facilities, equipment and operations.
•
Future-fit branch action plans to manage impacts of water, energy,
waste and emissions, and positive impacts on communities as well
as congestion and potential impacts from freedom camping.
•
Technologies and systems to manage complexity and growth.
•
Deep connections in tourism and RV industry.
•
Social licence to operate at our sites and where products are used.
•
Responsible travel partnerships and programmes in each region.
•
Working with suppliers to improve supply chain transparency, risks,
sustainability performance and circularity.
•
Crew engagement and wellbeing.
•
Healthy and safe workplaces.
•
People Promise to provide the tools, skills and identity to succeed.
•
Fostering a diverse and inclusive culture.
•
Building our cultural capability.
ABOUTINTRODUCTION12thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Our global future-fit sustainability programme
CLIMATE & CARBON STRATEGY
DECARBONISING OUR BUSINESS
FUTURE FLEET PROGRAMME
TRANSITIONING TO A LOW-CARBON FLEET
SUSTAINABLE PROCUREMENT
OUR GLOBAL FRAMEWORK AND
CIRCULAR ECONOMY PILOTS
THRIVE
SUPPORTING OUR CREW, CREATING
A HEALTHY CULTURE AND BUILDING
CULTURAL CAPABILITY
ACCELERATE
PARTNERSHIPS FOR POSITIVE IMPACTS
IGNITION
CREATING FUTURE-FIT BRANCHES
• Operational GHGs
• Product GHGs
• Renewable energy
• Product GHGs
• Products repurposed
• Sustainable procurement
• Products repurposed
• Employee health
• Living wage
• Fair employment terms
• Employee discrimination
• Employee concerns
• Community health
• Natural resources
• Operational encroachment
• Community health
• Product communications
• Product concerns
• Product harm
• Renewable energy
• Water use
• Operational emissions
• Operational GHGs
• Operational encroachment
• Operational waste
GOALS
GOALS
GOALS
GOALS
GOALS
GOALS
Global future-fit sustainability programme
At thl, we take a science and systems-based approach to
addressing our sustainability impacts, guided by the 23 Break-
Even Goals of the Future-Fit Business Benchmark. Our global
sustainability programme is focused on our priority future-fit goals.
Progress on our future-fit sustainability journey and annual future-
fit health check is shared in our Integrated Annual Report 2025
found at www.thlonline.com and www.thlsustainability.com.
In FY25, we developed our first transition plan, Changing
Gear, which responds to our material climate-related risks and
opportunities. Developing our transition plan reflects the core
assumptions of our business model and builds on existing work
that is integral to thl’s strategy, including Future Fleet and non-
tourism revenue.
Our transition plan work programme sits within our global future-
fit sustainability programme and supports thl’s broader value-
creation model by embedding climate resilience and long-term
sustainability into our operational and strategic decision-making.
See pages 31-33 for further detail on our transition plan.
Our global future-fit sustainability programme is well established
and integrated across our business strategy, plans and operational
activities. Future-fit progress and goals are considered at all levels
– from our site-based actions to business strategy and capital
investment decisions – and are an integral part of business plans.
Elevating our approach to working with a future-fit mindset and
methodology across all business operations has been a focus
in FY25. We identified the key integration points for future-fit
impact and have put in place mechanisms to support consistently
applying future-fit decision-making in our planning, projects,
processes and training.
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Current climate-related impacts
Climate change continues to intensify globally, with increasingly frequent and severe
weather events, shifting policy landscapes and evolving consumer expectations. These
changes are reshaping the operating environment for tourism and transportation
providers, including thl.
As a business with operations across diverse geographies and a reliance on physical
infrastructure and mobile assets, thl is exposed to both physical and transition climate-
related risks. Extreme weather events can disrupt customer access to destinations
and rental bookings, while regulatory developments – particularly those related to
low-emissions transport – introduce strategic uncertainty. At the same time, changing
2. While this event occurred outside this reporting period, it is reported here because the financial impact occurred in FY25, with RVs being used for temporary accommodation.
customer preferences and emerging opportunities in mobile resilience are influencing
long-term planning and investment decisions.
In response, thl has undertaken a qualitative assessment to identify climate-related
events and impacts observed in FY25 followed by a quantitative assessment of events
that potentially had a material impact. Table 2 summarises these impacts, which reflect
physical, and transition impacts relevant to thl’s business model. During FY25, thl worked
with WSP New Zealand Limited to develop a methodology for quantifying the financial
impacts resulting from climate impacts to thl’s business. This represents a progression
from the prior use of the adoption provision under NZ CS 2 clause 10. None of the of the
impacts identified for FY25 were considered to be material.
Table 2: Current climate-related impacts on our business
ImpactDescriptionFY25 financial impact
Methods and assumptions for determining
financial impact
Physical
impacts
of climate
change on
our business
Acute weather
events (thl has
not assessed
the extent to
which these
are related to
climate change
but has simply
included all
acute weather
events in FY25)
Each year, acute weather events cause disruption to
the regions thl operates in. These events continue
to increase in frequency and severity and can have
a positive impact on RV rentals as well as a negative
impact on operations.
Notable events causing some disruption to thl’s
global operations and/or customers in FY25:
•
Canada: Jasper wildfire (July 2024), hailstorms
(August 2024)
•
US: Southern California wildfires (January 2025),
Hurricane Debby (August 2024), Hurricane Helene
(September 2024), Hurricane Milton (October 2024)
•
UK/Ireland/Europe: Heavy wind event (January 2025)
•
Australia: NSW flooding (August 2024), Queensland/
Cairns flooding (January 2025), Cyclone Alfred
(March 2025), WA fires (April 2025)
•
New Zealand: Wairoa flooding (June 2024)
2
.
Impacts of the events:
•
Temporary site closures
•
Vehicle relocations
•
Booking cancellations
•
Booking changes (dates, duration, drop-off locations)
•
Minor repairs and cleaning
•
Non-tourism bookings for temporary accommodation.
Some events have resulted in
additional costs due to disrupted
operations, and some events
have resulted in additional non-
tourism revenue. The individual and
collective impact of the additional
revenue and costs associated with
these events is not material in the
current reporting period.
Each event is qualitatively assessed individually based on
the impact to operations, assets, bookings and finances.
A financial lens is then applied to quantitatively estimate
the financial impact and assess materiality of the event.
Events initially assessed as individually immaterial are
reviewed by the CWG and subsequently approved by the
HSSC. This process checks that any material events or
issues are identified before being reported collectively as
an estimated financial impact.
Material events undergo a more detailed quantitative
assessment using actual data from across the business
to quantify the level of impact. These events are also
reviewed by the CWG and approved by the HSSC
to confirm their materiality before being disclosed
individually or collectively.
All events are assessed for potential ongoing impacts
that may affect materiality over time (i.e. changes to
future bookings or ongoing non-tourism revenue).
In FY25, no events of material significance have occurred.
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ImpactDescriptionFY25 financial impactApproach to determining financial impact
Transition
impacts
from the
transition
to a low-
emissions,
climate-
resilient
future
Regulation The regulatory and policy landscape for emissions
reduction and low-emissions vehicles is evolving rapidly
across our key markets, with significant uncertainty in
2025. The changes have been most significant in the
US where federal climate policies and zero-emissions
vehicle actions are being walked back at pace.
The most notable regulatory shifts were in California,
with the pause then recall of the California Air Resources
Board’s zero-emissions vehicle adoption requirements
of the Advanced Clean Fleets regulation and federal
action to remove the waiver for the Advanced Clean
Trucks regulation.
No material financial impacts in
FY25. Monitoring and engagement
part of business as usual and the
Future Fleet workstream.
We continue to monitor regulations and policy targets
for the phase-out of internal combustion engine (ICE)
vehicles and emissions reduction regulations in each
region where we operate.
TechnologyProgress towards zero-emissions vehicles continues but
the pace is slowing due to macroeconomic headwinds,
economic conditions and slowing momentum on
regulation, particularly in North America. Growth in
zero-emissions truck models has flattened from FY24.
In FY25 many original equipment manufacturers (OEMs)
have delayed or scaled back plans for electric vehicles
and battery manufacturing. China continues to be a
leader in electric vehicle development.
OEMs and fleets are also showing a shift towards a more
gradual transition and broader range of technologies
to reduce emissions, including hybrids and renewable
fuels, and a focus on technologies to increase efficiency
to reduce emissions. It is likely these technologies may
play a greater role in the transition to low-emissions
vehicles in the more immediate term.
No material financial impacts in
FY25. There was no additional
funding in Future Fleet and low-
emissions vehicle pilots in FY25.
Monitoring and engagement
part of business as usual and
the Future Fleet workstream.
This is calculated based on actual spend on Future Fleet
and low-emissions vehicle pilots in the financial year.
We continue to seek to work with RV manufacturers
and industry bodies on a global basis to influence
OEM chassis suppliers to improve the adoption of
low-emissions vehicles.
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Climate scenarios
We have continued to mature our climate-related scenarios over the last year, including
completing our annual review and update of our chosen climate scenarios in line with
the NZ CS. thl has selected scenarios developed by the Network for Greening the
Financial System (NGFS) because thl is a global business – the global coverage and
integrated assessment of risks makes the NGFS scenarios relevant and appropriate to
our multinational operations. The Aotearoa Circle’s transport and tourism sector climate
change scenarios, which thl contributed to the development of, were also considered
in thl’s scenario analysis, specifically in the impact and materiality assessment. These
scenarios, tailored to the New Zealand transport and tourism sectors, were informed by
the core assumptions used in the NGFS scenarios and were considered appropriate for
assessing risks and opportunities for New Zealand operations.
This year, we have developed expanded narratives for each scenario, reflecting insights
from the FMA review report. The narratives reflect core considerations for thl’s business
strategy, build/buy-rent-sell model, tourism operations and climate-related risks and
opportunities (CR&Os). The scenarios create a picture of potential plausible futures for
thl to explore different potential climate-related drivers and risks and opportunities
that may arise under each scenario. To make the scenarios relevant at an industry and
entity level, the narratives focus on five drivers, which include global trends, policy and
regulation, market conditions, technology transition for a low-emissions fleet, and travel
trends. These reflect the key drivers that impact thl’s material CR&Os.
We are starting to integrate the use of climate-related scenarios into our business
strategy, beginning with our transition planning work in FY25. We used our updated
climate scenarios to stress test thl’s strategy and business model response to CR&Os
under each scenario. As part of the scenario analysis and transition planning work, the
CWG and HSSC also reviewed our material CR&Os and concluded that these have not
changed. In FY24 a comprehensive review of thl’s CR&Os was undertaken through
workshops with the Executive Team and Board (see thl’s FY24 Climate Statements).
As we applied the scenarios to transition planning, we determined the need for the
inclusion of a new fourth scenario (aligned to the NGFS Too Little, Too Late - Fragmented
World scenario). Including the new Fragmented World scenario alongside the current
Delayed and Disorderly Transition scenario enables thl to test strategic resilience
using different assumptions regarding transition pathway timing, global and regional
alignment, and intensity of transition risk.
Time horizons
thl reviews its longer-term strategy annually and then implements through a triannual
planning process (every four months) to create shorter-term focus for priority projects
and allocate business resources. The short, medium and long-term scenario timeframes
remain the same as FY24, aligning with thl planning timeframes, and are based on years
rather than temperature targets:
Short-term (0–2 years)
•
Short-term: up to 24 months, 2025–2027 (aligning with our strategic review timeframes)
Medium-term (2–10 years)
•
Medium-term: 2–10 years, 2027–2035
Long-term (10+ years)
•
Long-term: over 10 years, 2035 onwards.
Scenario archetypes
In FY25, thl considered four temperature-aligned climate scenarios. These draw from the
core assumptions used in the NGFS scenarios, which are based on the widely used Shared
Socioeconomic Pathways and are informed by The Aotearoa Circle tourism and transport
sector climate change scenarios. The key assumptions underlying each of thl’s scenarios
are contained in Table 3.
Delayed and
Disorderly Transition
Orderly –
Net Zero 2050
Hothouse World –
Current Policies
Fragmented
World
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3. For carbon dioxide (CO₂) removals, the NGFS includes both technology and forestry-based carbon removals and does not separate trends between the two.
Table 3: Scenario archetypes
Scenario descriptionAn orderly scenario with global
alignment, modest progress
becomes more ambitious in 2030
to achieve net-zero emissions
reduction by 2050.
Rapid transition occurs around
2030 and creates intense disruption
through the early 2030s as markets
and countries transition to a low-
emissions future.
Delayed and divergent policy ambition
globally, leads to slower progress and
higher physical and transition risks.
A Hothouse World scenario with
extreme physical risks.
Global temperature
increase by end of
the century
+1.4°C+1.7°C+2.4°C+3°C
Policy response Gradual and smooth.Delayed and disorganised.Very delayed then fragmented.None – current policies only.
Transition riskHigh in early 2030s.Very high from 2030 to 2035.Low then high in 2040s.Low.
Physical riskLower long-term risk.Medium to high.High.Extreme.
Technology changeRapid and even.Slow to 2030 then fast and disruptive.Slow, increasing mid to late 2030s but
fragmented.
Slow.
Carbon price Steady, then steeper rise. Initially low then sharp increase,
highly volatile.
Low then increasing, highly variable.Remains low.
Carbon dioxide
removals
3
Medium-high use.Medium use. Low to medium use.Low use.
Macroeconomic factorsShort-term intensive pressure
due to steeply increasing carbon
prices, energy costs and disruptive
technology through the 2030s.
Economic downturn due to abrupt
devaluations, stranded assets and rise
in energy prices, from 2035 then slowly
recovers in 2040s.
Economic downturn due to negative
impacts of physical risk, carbon price
remains lower, oil prices increase
by 2050.
Economic downturn from physical
impacts, increase in climate-related
migration.
Consumer behaviourPreference shifts to low carbon
transport, green technology
widely available.
Slow shift with barriers to transition,
disruptive changes towards low carbon
options from 2030.
Slow shift in customer behaviour,
emissions increase by late 2030s
variable by regions.
Slow shift, climate movement
considered radical.
Energy pathwayHigh expected annual energy
investments until 2040, highest
share of non-biomass renewables
in primary energy mix by 2050.
Expected annual energy investments
same as Hothouse World until 2030,
investments exceed the Orderly
scenario after 2040, with non-biomass
renewables most of the primary
energy mix by 2050.
High regional variation, renewable
energy increases over the 2030s but
at a slower rate than in the Delayed
and Disorderly scenario, non-biomass
renewables increase through 2040s
to be most of the primary energy mix
by 2050.
Same as Delayed and Disorderly
scenario until 2030 for expected annual
energy investments, dropping through
2050 and with the lowest share of non-
biomass renewables in primary energy
mix by 2050.
Data sources used to
construct scenario
NGFS: Net Zero 2050
Aotearoa Circle: Fully Charged
(transport) and Orderly (tourism).
NGFS: Delayed Transition
Aotearoa Circle: Short Detour
(transport) and Disorderly (tourism).
NGFS: Fragmented WorldNGFS: Current Policies
Aotearoa Circle: Bypass to Breakdown
(transport) and Hothouse (tourism).
Delayed and
Disorderly Transition
Orderly –
Net Zero 2050
Hothouse World –
Current Policies
Fragmented
World
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Technology transition
Disruption driven by regulation, market conditions and the development of decarbonisation
technologies, and infrastructure creates short-term challenges, including supply chain
pressures, price volatility and significant supply constraints. This results in elevated levels
of competition for new technologies, creating short-term risk and potential stranded asset
exposure between 2030 and 2035. Progress on medium to heavy-duty fleet deployments
rapidly scale from 2030.
Travel trends
Customer preferences shift towards low-carbon transport as green technologies become
more accessible. As low-emissions travel options mature, more travellers seek to reduce
their climate impact, driving demand for sustainable transport. This shift creates pressure
on the tourism sector, particularly where decarbonising aviation and long-distance travel
remains challenging.
Climate change impacts intensify in many regions through the 2030s, with travel and
tourism activities and destinations increasingly impacted by extreme events such as
wildfires, storms and floods. In response, communities and destinations place greater
emphasis on climate risk and resilience, leading to significant investment in both climate
adaptation and mitigation.
Scenario narratives
Orderly – Net Zero 2050 – +1.4°C
4
Based on NGFS Net Zero 2050 | The Aotearoa Circle transport sector Fully Charged and tourism sector
Orderly – Hiahia
Steady and coordinated global transition occurs to limit negative effects
of net-zero CO₂ emissions by 2050
Climate commitments are globally aligned. Short-term progress is modest then becomes
ambitious from 2030. Well-paced decarbonisation of electricity supply, renewable energy
scales and innovative technologies evolve to tackle hard-to-abate emissions. Carbon
prices increase gradually and the use of carbon tax revenue for effective investment
in green technology limits global output losses to 0.5% in 2030. Transport and energy
sectors have largely decarbonised by 2050.
Policy and regulation
Global alignment of commitments, progress is modest between 2025 and 2029, then
becomes more ambitious from 2030 to meet timeframes for action to limit global
warming to 1.5°C. Regulatory changes help drive rapid technology development
between 2030 and 2035 as major markets move at pace to progress transition pathways.
Transition risks are greatest during this period, with disruption and increased volatility.
This stabilises after 2035 as markets adjust, and new low-carbon economies establish.
Market conditions
Customers and investors increasingly demand businesses respond to impacts of
climate change and decarbonise in response to more ambitious policies from 2030.
This drives new disruptive low-carbon technologies, electrification and renewable
energy expansion. There is high demand and competition for low-emissions technologies,
and the carbon price increases. Transition risks in the transport sector are highest in
the early 2030s as regulation and policy changes create technology and supply chain
deployment challenges.
4. While thl has included this scenario in compliance with NZ CS 1, we acknowledge that current global emissions trajectories and recent
temperature records suggest that limiting warming to 1.5°C is becoming increasingly challenging.
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Technology transition
Investment in low-emissions technologies and renewables occur but progress is slow
and uneven. Reliance on fossil fuels continues during the 2020s. In 2030, demand for low-
emissions vehicles spikes due to stricter regulations and increased consumer demand,
creating significant pressure on supply chains. This leads to intense competition for new
technologies and resources. Progress on light-duty vehicles leads initially, with medium
to heavy-duty fleet deployments at scale occurring by the mid-2030s. Delays in grid and
renewables upgrades result in more expensive and accelerated electrification during the
2030s, disrupting supply and placing significant pressure on infrastructure.
Travel trends
Customer demand for climate action gradually builds over the 2020s then rapidly
heightens in the 2030s. Customers increasingly seek out businesses that have focused
on decarbonisation. This creates challenges for the travel industry, which has proved
hard to decarbonise. Physical impacts of climate change have intensified, impacting
destinations and communities with increasing frequency and severity. These changes
begin to influence customer travel choices. Long-haul travel is expensive due to increased
risk of disruption due to weather events and high-insurance costs. International travel is
increasingly a luxury service. A growing number of conscious travellers across regions are
choosing not to fly to reduce their carbon impact.
Policy makers procrastinate on strengthening climate policies in the short-term,
and a series of devastating climate-related disasters across multiple regions
trigger public and political pressure resulting in a rapid, disorderly shift in
climate policy
The pace and scale of action vary among countries and regions. Global emissions
continue to increase then begin declining rapidly from 2030 onwards. The decarbonisation
of transport, energy and industry moves at pace, but by 2050, there is some way to go for
energy sector decarbonisation, including for buildings.
Policy and regulation
Global progress on aligned commitments is delayed and lacks coordination and
cooperation. Country variation in policy ambition and response is high, resulting in
uneven progress. Emissions continue to rise, and global temperatures increase. In
2030, a series of devastating climate-related disasters across multiple regions creates
a tipping point as countries recognise the need to act swiftly and decisively to address
rising emissions and climate change impacts. The sudden wake-up call creates a wave
of new stronger climate policies, but the rapid pace of implementation causes significant
disruption and market volatility.
Market conditions
Prior to 2030, markets have not priced in climate risks, and the energy sector relies
heavily on fossil fuels. The unanticipated change in mitigation policy sets off shockwaves
through the global economy with a speedy reallocation of capital from polluting to green
sectors. This leads to an abrupt devaluation of polluting firms and stranded assets. There
are rapid market shocks as governments and industries race to respond to the rapid
regulatory changes and intensifying demand for action to address climate impacts. An
economic downturn occurs, with financial turmoil and depressed demand, and the real
economy is severely affected. Energy prices rise sharply with the sudden implementation
of climate policy.
Scenario narratives CONTINUED
Delayed and Disorderly Transition – +1.7°C
Based on NGFS Delayed Transition | The Aotearoa Circle transport sector Short Detour and tourism sector
Disorderly – Pokanoa.
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Technology transition
Investment in low-emissions technologies and renewables varies across regions, while
fossil fuel reliance continues. Transition progress occurs later and is slow and fragmented,
creating high risks due to disruption, price volatility and supply chain challenges.
Deployment of zero-emissions vehicle technologies and infrastructure occurs but faces
slow progress and high costs, with regulatory differences and market demand influencing
investment levels. This leads to complexity, uncertainty and delays and creates significant
regional disparities in technology and infrastructure deployment. The transport sector
struggles to decarbonise, remaining a major source of emissions by 2050.
Travel trends
The physical impacts of climate change intensify, impacting destinations and communities
with increasing frequency and severity. This impacts customer travel choices and concern
about travel disruption. Long-haul travel becomes more expensive due to increased risk of
disruption due to weather events and high insurance costs, making international travel an
expensive product. Some travellers choose not to fly due to climate impacts, but this is not
a widespread trend across all regions.
Globally, there is little alignment on climate policies and commitments,
coordination and collaboration are lacking and progress is slow
Some countries set net-zero targets and others follow current policies only. Countries with
net-zero targets achieve only slow and delayed partial progress (up to 80%). Divergent
climate policies lead to an uncoordinated transition. This undermines the development
and deployment of new technologies and places additional strain on global supply chains.
Travel trends are increasingly influenced by growing concern over extreme weather events
by the 2040s. A late and uncoordinated transition fails to limit physical climate risks.
Policy and regulation
There is a lack of global alignment on climate policies, and progress on commitments
is slow. Countries set different levels of policy ambition, creating uncertainty and
fragmented progress. Some regions continue to move towards their net-zero
commitments, while climate policies are walked back in other major markets. Many
regions fall behind, and although some countries make progress, they fail to meet their
2050 net-zero targets. Emissions continue to rise, and global temperatures increase.
Frequent and severe extreme weather events occur. Chronic climate impacts such as
sea-level rise begin to increase and gradually intensify later in the century.
Market conditions
Severe and acute disasters hit a region of the world and lead to destruction of assets and
lower productivity, spreading globally through trade and financial linkages. Transition
impacts vary across regions, with supply chains and global market conditions remaining
highly volatile. Regional economic downturns and market shocks occur frequently.
There are significant impacts for real financial asset valuations, with considerable regional
differences. Prices increase, particularly for commodities. Acute and severe climate-related
events intensify, impacting communities. The cost of support for disaster responses
increases massively.
Fragmented World – +2.4°C
Based on NGFS Fragmented World.
Scenario narratives CONTINUED
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Market conditions
Costs increase significantly as natural resources are depleted, disrupting supply chains.
Global financial crises are frequent, causing worsening climate change impacts and rising
global tensions and conflict. National economies struggle to respond to rising costs and
impacts on supply chains, infrastructure and communities.
Globally, commodities including fossil fuels, become increasingly hard to source as
government protectionist actions are introduced to protect resources. Scarcity and price
shocks occur regularly, slowing economies and negatively impacting market conditions
globally. Worsening environmental conditions in many regions impact social systems,
housing and health, and climate migration increases.
Technology transition
Reliance on fossil fuel continues and emissions continue to rise, mostly unabated.
Investment in low-emissions technology and renewable energy is costly and limited.
Competition for resources intensifies. There is little consumer and investor demand to
address climate change. Climate change actions are increasingly considered to be radical.
Travel trends
Travel demand becomes constrained by severe economic pressures. Extreme weather
events and geopolitical instability severely reduce demand for some destinations and
impact customer confidence to travel internationally. Severe weather causes frequent
damage and disruptions to transport and infrastructure, making travel difficult and
extremely expensive. The desire for international travel remains high but disruptions
due to climate change and geopolitical instability make the risk and cost prohibitive
for most people.
Global climate policy ambition dwindles then becomes unrealised, only currently
implemented policies remain and many countries withdraw from the Paris
Agreement by 2030
Emissions continue to grow, leading to an average 3°C of warming by the end of the
century. This level of warming degrades living conditions in many parts of the world and
results in irreversible impacts like sea-level rise. Economies remain reliant on fossil fuels
to power consumption patterns and material-intensive production. Physical risks lead to
strong negative impacts on GDP, with economic costs diverging significantly after 2040.
The frequency and severity of climate events increase rapidly from the 2040s as tipping
points are breached. Access to capital and insurance becomes extremely difficult in
some regions.
Policy and regulation
A lack of policy ambition and progress globally over the 2020s means the economic costs
of acute and chronic climate change significantly impact GDP in most regions by 2040.
Global cooperation breaks down and geopolitical tension increases. Nationalistic and
protectionist actions negatively impact efforts to address climate change.
The Earth’s climate systems reach tipping points through the 2040s, causing climate-
related migration and increased global instability. Physical risks from climate change
become irreversible. Chronic physical risks include sea-level rise and significant drought
conditions in some regions. Acute extreme weather events, extreme heat, wildfires and
flooding are more widespread and severe.
Hothouse World – Current Policies – +3°C
Based on NGFS Current Policies | The Aotearoa Circle transport sector Bypass to Breakdown and tourism sector
Hothouse – Wharewera.
Scenario narratives CONTINUED
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Overview of thl’s scenario analysis process for FY25
For FY25, the annual review and development of thl’s climate scenarios was led by our new CWG. An overview of the process is set out in Table 4.
Table 4: thl’s scenario and analysis review process
XRB guidance FY25 scenario review actions
Engage stakeholders
– establish effective
group and clear
mandate
•
CWG was established with a clear mandate to progress work
on CR&Os.
•
Scenario analysis in FY25 builds on prior work (see FY24 Climate
Statements) and reflects XRB and FMA guidance.
•
The HSSC reviewed and validated the updated scenario
narrative content.
•
Board reviewed and approved scenario analysis based on
recommendation from the HSSC and through the approval of
the annual Climate Statements.
Define the problem
– how could climate
change plausibly
affect thl?
•
The focal question considered during scenario analysis and
transition planning: What might impact thl’s ability to operate
and generate sustainable revenues, reduce its assets, increase
its liability or challenge its ability to finance itself?
Identify driving
forces and critical
uncertainties
•
Drivers and critical uncertainties reviewed, reflecting updated
NGFS guidance, including referencing the geopolitical shifts
in Europe and the US, which may reduce the likelihood of an
immediate and smooth orderly transition.
•
The review considered World Economic Forum Global Risks
Report 2025, The Aotearoa Circle transport and tourism sector
scenario drivers and ongoing work from regional Future
Fleet scans.
5
Select temperature
outcomes and
emissions pathways
•
The updated NGFS (Phase V) Scenarios and The Aotearoa
Circle transport and tourism sector scenarios were reviewed
to confirm the selected temperature outcomes and pathways
align with guidance.
•
External peer review of scenarios selected for alignment with
NGFS and The Aotearoa Circle scenario pathways.
XRB guidance FY25 scenario review actions
Draft narratives
and quantify
•
Scenario narratives were updated to be more entity-specific
and to define and differentiate the driving forces and critical
uncertainties within each scenario.
•
A fourth scenario was included, based on NGFS Too Little Too Late
– Fragmented World scenario.
Check quality
and review
•
CWG provided input and reviewed the updated scenarios for FY25,
including development of a new scenario.
•
Validation of updated scenarios narratives and inclusion of new
scenario during HSSC workshop to confirm approach.
•
External peer review by WSP New Zealand Limited and feedback
on updated scenarios for better alignment with FMA and XRB
guidance.
•
Board reviewed and approved scenario analysis based on
recommendation from the HSSC and through the approval of the
annual Climate Statements.
Assess strategic
resilience
•
Draft scenarios were used in transition planning workshops to
assess strategic resilience for thl’s strategy and business model.
•
Transition planning identified the need to add a new scenario
aligned with the NGFS Too Little, Too Late – Fragmented
World scenario.
•
Scenario insights informed the development of the transition plan
and work programme.
5. In FY23, thl commissioned consultants (specialists in climate, energy and transport) to undertake a global Future Fleet scan of trends across thl’s operating regions. They were asked to explore global climate trends, the speed of regulatory change
in the phase-out of ICE vehicles, opportunities for grants, research in edge technology and infrastructure readiness. This research informed the assessment of potential climate impacts on thl’s business model and thl’s Future Fleet programme. In
FY24, thl undertook research on each country of operation – Future Fleet regional scans – to further inform the Future Fleet programme. The Future Fleet scans are reviewed annually by thl to check for the latest knowledge and data. Insights
from the FY25 scans has informed our FY25 review of the climate scenarios and the subsequent review of our material climate-related risks and opportunities and the Transition Plan.
ABOUTINTRODUCTION22thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
CLIMATE-RELATED RISKS AND OPPORTUNITIES
As the impacts of climate change become more tangible, so too do the risks and
opportunities they present. Some are already influencing how we operate, while others
are likely to emerge over time as the climate, policy landscape and market expectations
continue to evolve.
Understanding the most material climate-related risks and opportunities (CR&Os) is
critical to informing our strategic planning, risk management and investment decisions.
These insights are considered in our governance processes, helping us to remain
responsive and accountable as conditions change.
Through scenario analysis, internal workshops and engagement with stakeholders, we
have taken a closer look at where we might be exposed across all areas of our value chain
(with no exclusions) and across each of our short-, medium- and long-term time horizons
(see page 16) – and where we might be able to lead. In FY25, our six material CR&Os have
remained unchanged.
We have:
•
four transition risks
•
one physical risk
•
one opportunity – spanning both the transition to a low-emissions economy and
physical impacts from climate change.
These are shown in Figure 3 and detailed in the following pages.
In FY25, thl worked with WSP New Zealand Limited to begin developing the methods and
assumptions that will be used to quantify the anticipated financial impacts of our CR&Os.
As this work is ongoing, thl has chosen to utilise Adoption provision 2 under NZ CS 2,
which provides a temporary exemption from disclosing the anticipated financial impacts
of CR&Os. This decision reflects the complexity and evolving nature of assessing financial
impacts and allows thl additional time to develop robust methodologies and internal
capabilities to support high-quality, decision-useful disclosures in future periods.
Figure 3: CR&Os over time horizons
Risk/Opportunity typeRisk/Opportunity
Short-Term (0-2 Years)
2025-2027
Medium-Term (2-10 Years)
2027-2035
Long-Term (>10 Years)
2035 onwards
Transition risk
Risk of lack of supply of cost effective, long range, low
emissions technology suitable for thl RVs.
Transition risk
Risk of rapid regulatory change and requirements for
legal compliance.
Transition risk
Risk of investment in Future Fleet not being economically feasible
due to failure in delivering an appropriate return on funds employed.
Transition risk
Risk of trend away from carbon intensive travel leading
to a reduction in customer demand.
Physical risk
Risk of changes in booking patterns due to physical
climate impacts.
Opportunity for increased demand for mobile housing
and emergency vehicles.
Transition /
Physical opportunity
ABOUTINTRODUCTION23thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Figure 4: Annual CR&Os review process
Review previous
year’s climate
scenarios
and update
with current
knowledge
or changes to
assumptions.
Assess CR&Os
materiality.
Analyse
impacts and
potential risks
or opportunities
under each of
the scenarios.
Update current
years’ list of
material CR&Os
including risk
assessment for
individual risks.
Map CR&Os to
thl’s Strategic
risks in the
risk register,
updating risk
detail to reflect
climate-specific
information.
Review previous
year’s list of
CR&Os for any
new or changes
to risks.
Reviewed by
CWG, agreed
by HSSC and
approved by thl
Board.
Updates to risks
are reported in
Annual Climate
Statements.
ERM framework
thl applies a structured ERM framework to identify, assess, and manage risks across its
global operations. thl’s CR&Os are integrated into this same ERM structure as drivers and
objectives within thl’s strategic risk categories.
In FY25, thl reviewed its ERM function and established a new RQA function to strengthen
its integration with other core functions – specifically Health, Safety and Wellbeing; Policy;
and Internal Audit. This evolution supports consistent standards and controls across thl’s
global network, reinforcing a more cohesive and adaptive approach to risk management
that supports regulatory compliance, operational resilience and strategic foresight in a
dynamic environment.
Under the revised ERM framework, risks are considered within an overarching strategic
risk category, with objectives, impacts and controls managed within each relevant
operational or functional area. This approach acknowledges that, while risks may have
multiple drivers or causes, the management controls and impacts are often shared.
Previously, thl’s ERM took a driver-centric approach, listing a specific risk for each driver,
which created inefficiencies and limited the consolidation of shared learnings and
controls. In the revised structure, climate-related drivers are not treated as stand-alone
risks but are embedded within the management and objectives of strategic risks. Each
climate-related risk or opportunity is mapped to the applicable strategic risk category
within thl’s ERM.
In FY26, thl plans to continue building momentum by embedding standards and controls
in the business and monitoring this consistently through the implementation of a new
global assurance programme.
Risk identification, assessment and management
Risks at thl are identified through scheduled reviews, operational triggers and scenario
analysis. Changes to existing risks or the emergence of new ones are typically driven by
external factors or operational shifts. These are discussed and agreed upon at Executive
Front and Centre meetings and reported to the ARC.
Each risk is assigned to a Risk Owner, an Executive Leader of the relevant operational or
functional area. The Risk Owner is responsible for:
•
qualitative risk assessment
•
defining risk objectives and appetite statements
•
establishing indicators, controls and assurance methods
•
ongoing monitoring and reporting.
Under the new structure, thl no longer uses static risk ratings (i.e. high, medium, low).
Instead, we apply a dynamic approach that adjusts the risk status based on the current
operating context. This involves qualitatively assessing and prioritising thl’s strategic risk
categories based on risk indicators – practical thresholds or conditions indicating whether
the business is operating within acceptable limits. These indicators are supported by clear
escalation protocols and management guardrails. Each risk is managed with defined
objectives and control measures and is documented in thl’s central risk register.
Risk Owners provide regular updates on risks as part of their regular Executive Front
and Centre meetings. Under the new structure, this includes risk appetite indicators and
tolerance levels for each risk category and a review and escalation process. All strategic
risks categories are reported in regular updates from the RQA team to the ARC, including
the status of all risks and any that fall outside appetite.
Alongside this regular process, thl specifically reviews our CR&Os through our annual
climate-related scenario review process (see page 22), identifying changes or new risks
and opportunities for consideration across different time horizons. Materiality is assessed
annually for inclusion in thl’s strategic risks and to pull these out specifically for climate-
related disclosure reporting.
The updated scenarios and CR&Os are considered and agreed by the CWG and the HSSC.
Any new risks are mapped to thl’s strategic risks, which are updated to reflect any climate-
related considerations in thl’s risk register. This process is shown in Figure 4. This year’s
review determined that thl’s material CR&Os remain the same for FY25 and include both
transition and physical risks and opportunities. Our CR&Os are considered in our strategic
risks, which are regularly monitored and reported to the ARC. The thl Board reviews the
CR&Os at least annually as part of our climate-related disclosure process.
ABOUTINTRODUCTION24thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Anticipated impacts
The lack of supply of suitable zero or low-emissions chassis
suitable for conversion into RVs remains a challenge across all
markets. This continues to be a material transition risk for thl in
all regions and is occurring now. This is likely to be exacerbated
by stalling momentum in some regions and challenges for
automotive manufacturing from tariffs, protectionism and
geopolitical instability impacting global supply chains, fuel prices
and consumer confidence. thl is a technology taker and takes an
agnostic approach that considers all low-emissions technology
options. The progress required by OEMs for a suitable chassis
remains slow and is likely to become increasingly challenging
in the short to medium-term with the current macroeconomic
conditions and regulatory uncertainty.
Capital deployment
thl made no significant capital deployment in FY25 in relation
to this risk. Since FY23, the thl Board has approved recurring
annual capital expenditure on our Future Fleet electric RV pilot
programme. To date, the total aggregate spend is estimated as
$2,588,000 (gross).
Changing Gear transition plan
•
Future Fleet workstream.
•
Non-tourism revenue workstream.
Management response – transition plan actions
•
Continue to proactively engage OEMs globally. As a technology
taker, we are reliant on industry progress for suitable models.
•
Action Manufacturing continues to lead the investigation and
work on pilots for low-emissions vehicles, taking a ‘small bets
often’ approach, and embedding circular design principles
and exploring more sustainable materials and components to
support more efficient and lower-emissions vehicle design.
•
Actively track progress on low-emissions fleet developments
and new technologies globally.
•
Engage with industry on low-emissions vehicle transition
progress and initiatives to address challenges such as charging
infrastructure, including as a member of the RV Industry
Association in North America.
•
Prepare annual technology-agnostic Future Fleet scans for each
region, tracking transition tipping points and timeframes.
Low-emissions fleet transition risk
Risk of lack of supply of cost-effective, long-range, low-emissions technology suitable for thl RVs.
TYPE
Transition risk
VALUE CHAIN
Build/Buy
Rent
Sell
REGION
All regions
SCENARIO
Orderly (Greatest)
Delayed Disorderly
Fragmented World
STRATEGIC RISK CATEGORY
Product viability
Supply chain (operational procurement)
ABOUTINTRODUCTION25thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Regulatory compliance risk
Risk of rapid regulatory change and requirements for legal compliance.
Anticipated impacts
This continues to be a material transition risk for thl in all regions.
In FY25, the regulatory environment was increasingly complex
and uncertain, particularly in the North American markets. The
likelihood of smooth and rapid regulatory change towards more
ambitious low-emissions vehicle policies has become less likely
in the short-term.
Regulatory compliance is moving at a different pace across the
world, with some operating regions having phase-out target dates
for ICE vehicles that are earlier than others. If supply constraints fail
to improve over time, this will pose a significant challenge for thl as
regulations come into force.
There is a risk that thl may experience challenges during the
transition phase for zero-emissions regulations, including supply
chain constraints, or as customer expectations change rapidly in
some or all regions. Risks could increase due to potential breaches
of suddenly changing regulation. Lack of supply of suitable cost-
effective fleet that meet low-emissions vehicle standards remains
a material risk, but the potential timing around this risk is now later
in the medium-term. Current fleet availability may be impacted
as OEMs respond to regulations requiring increasing numbers of
low-emissions vehicles to be sold. The pace of regulatory change in
phasing out ICE vehicles could lead to stranded assets as thl may
find it difficult to on-sell ICE vehicles.
Capital deployment
thl made no significant capital deployment in FY25 in relation to
this risk beyond funding for Future Fleet scan work and regular
GHG reporting work embedded in business-as-usual processes.
Changing Gear transition plan
•
Future Fleet workstream.
•
Operational efficiency and climate resilience workstream.
Management response – transition plan actions
•
Continue to track and monitor climate and carbon-related
regulatory developments in each region.
•
Future Fleet scans include tracking regulation related to ICE
vehicle phase-out timing and emissions standards.
•
Progress work on pathway maps for transitioning fleet to low
emissions as part of Future Fleet.
•
Proactively prepare for changes in regulation relating to climate
and emissions reporting standards.
•
Monitor and progress energy and emissions actions at thl sites
through the Ignition future-fit programme.
•
Report on our Scope 1, 2 and 3 emissions annually with
assurance and aligned to the GHG protocols.
TYPE
Transition risk
VALUE CHAIN
Build/Buy
Rent
Sell
Tourism
REGION
All regions
SCENARIO
Orderly (Greatest)
Delayed Disorderly
Fragmented World
STRATEGIC RISK CATEGORY
Product viability
Property (ability to operate)
Planning and forecasting
Business continuity
ABOUTINTRODUCTION26thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Anticipated impacts
The transition to zero or low-emissions vehicles may not be
commercially viable if customers are unwilling to cover the
higher associated costs of these vehicles. This is a global risk and
continues to be a material transition risk for thl in all regions.
Global economic megatrends and a lack of economically viable
low-emissions technology within the timeframes required to
transition could create a negative impact on return on funds
employed. With greater financial pressures in the short-term,
capital allocation for Future Fleet may be delayed or insufficient.
Increasing costs to meet changing regulations could negatively
impact commercial operations and our ability to forecast and
invest in low-emissions Future Fleet.
Capital deployment
thl made no significant capital deployment in FY25 in relation to
this risk beyond funding for Future Fleet pilots and research and
development and Future Fleet scan work embedded in business-
as-usual processes.
Changing Gear transition plan
•
Future Fleet workstream.
•
Non-tourism revenue workstream.
Management response – transition plan actions
•
Capital allocation secured for low-emissions vehicle pilots and
fleet research and development.
•
Maximise use of funding incentives to support developments
and pilots where available.
•
Future Fleet scans in each region tracking changes in total cost
of ownership, price parity with ICE vehicles.
•
Monitoring resale market trends for low-emissions vehicles in
each region as part of Future Fleet.
Fleet investment return risk
Risk of investment in Future Fleet not being economically feasible due to failure in delivering an appropriate return on funds employed.
TYPE
Transition risk
VALUE CHAIN
Rent
Sell
REGION
All regions
SCENARIO
Orderly (Greatest)
Delayed Disorderly
Fragmented World
STRATEGIC RISK CATEGORY
Planning and forecasting
Funding (capital funding)
Impairment
ABOUTINTRODUCTION27thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Anticipated impacts
Customer demand changes in response to carbon-intensive
travel is a risk for all regions over the longer-term. This may
impact international tourism to long-haul destinations from
Europe, including Australia and New Zealand, more so than in
North America. This appears less likely to occur in the short to
medium-term.
Actively tracking changing customer expectations and
travel trends is a core part of thl’s commercial and marketing
strategies. Industry data and information on how concerns
regarding carbon-intensive travel are impacting traveller
behaviour, intent and decisions is starting to appear but is not
currently widely or readily available. Some data on the impacts
of climate-related events is becoming available. However, this
is more directly related to physical risks from climate change
impacting customer booking patterns.
Capital deployment
thl made no significant capital deployment in FY25 in relation to
this risk beyond funding for commercial and market research work
embedded in business-as-usual processes.
Changing Gear transition plan
•
Travel and tourism demand forecasting workstream.
•
Non-tourism revenue workstream.
•
Operational efficiency and climate resilience workstream.
Management response – transition plan actions
•
Continue to monitor and scan for industry data on travel trends
for customer concerns regarding carbon-intensive travel.
•
Gather insights on customer trends related to climate-related
events (see climate impact on booking patterns risk).
•
Develop data strategy and embed climate-related travel trends
data within our market research strategies.
•
Explore potential for industry partnerships to improve data on
climate impacts on travel and tourism.
•
Communicate progress of Ignition future-fit action plans tracked
with carbon impact reports.
Decarbonisation demand-driven Risk
Risk of trend away from carbon-intensive travel leading to a reduction in customer demand.
TYPE
Transition risk
VALUE CHAIN
Rent
Tourism
REGION
All regions
SCENARIO
Orderly (Greatest)
Delayed Disorderly
STRATEGIC RISK CATEGORY
Rental/tourism market size
Market share
Product viability
ABOUTINTRODUCTION28thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Anticipated impacts
Changes in booking patterns are a global risk. Patterns are
expected to be impacted over time as regions experience
changing climate trends. We are actively monitoring and
responding to impacts on our guests from extreme climate-
related events, including wildfires, prolonged heatwaves and
flooding (see current impacts – page 14).
Climate impacts create disruption and may make some
destinations less accessible or attractive to tourists. Booking
patterns could become more unpredictable and reactive in
response to these events. Increasing costs such as insurance,
greater disruption from extreme events impacting destinations
creating less favourable environmental conditions or geopolitical
factors could influence travel patterns. Customers may not wish
to travel to certain countries due to the risk of extreme climate
events and therefore may choose other destinations that are less
impacted, which could potentially create opportunities across the
thl network.
Capital deployment
thl made no significant capital deployment in FY25 in relation
to this risk beyond funding for market research and business
development for non-tourism revenue streams embedded in
business-as-usual processes.
Changing Gear transition plan
•
Travel and tourism demand forecasting workstream.
•
Operational efficiency and climate resilience workstream.
Management response – transition plan actions
•
As a global leader in tourism, thl keeps a watching brief on
global travel trends and travel booking patterns.
•
Refresh current data on climate change projections and impacts
on travel and tourism for each region.
•
Embed gathering data and insights on climate-related travel
trends within our market research strategies.
•
Develop approach to consider climate impact exposure for new
locations as part of Ignition programme.
Climate impact on booking patterns risk
Risk of changes in booking patterns due to physical climate impacts.
TYPE
Physical risk
VALUE CHAIN
Rent
Tourism
REGION
All regions
SCENARIO
Hothouse World (Greatest)
Fragmented World
Delayed Disorderly
STRATEGIC RISK CATEGORY
Rental/tourism market size
Product viability
Pricing
ABOUTINTRODUCTION29thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Anticipated impacts
As regions experience more frequent extreme weather events,
tourism operations may be impacted, which may require thl’s
fleet and operations to be relocated. Tourism activities may be
disrupted, and there may be greater demand for temporary mobile
housing for non-tourism uses to manage these events. This creates
an opportunity to grow non-tourism activity revenue and support
emergency response by providing temporary accommodation for
communities and emergency workers in impacted areas.
thl has the opportunity to provide a source of mobile
accommodation and support services for displaced populations
due to a sudden event. Increased demand for mobile
accommodation in the wake of extreme weather events
and the transition to a low-emissions future is considered a
global opportunity.
Capital deployment
thl made no significant capital deployment in relation to this
opportunity in FY25 beyond funding for standard non-tourism
business development work embedded in business-as-usual
processes, as the flexibility of our current rentals fleet enables
RVs to be reallocated to non-tourism needs.
Changing Gear transition plan
•
Non-tourism revenue workstream.
Management response – transition plan actions
•
Non-tourism revenue strategy is in place, building on
prior experience.
•
Provision of non-tourism mobile accommodation solutions
to support those impacted by extreme events.
•
Continue to explore and develop pilots and partnerships to
develop mobile health and emergency shelter applications.
Mobile housing and emergency response opportunity
Opportunity for increased demand for mobile housing and emergency vehicles.
TYPE
Physical opportunity
Transition opportunity
VALUE CHAIN
Build/Buy
Rent
REGION
All regions
SCENARIO
Hothouse World (Greatest)
Fragmented World
Delayed Disorderly
STRATEGIC RISK CATEGORY
Market share
Rental/tourism market size
Product viability
Planning and forecasting
Service delivery (Customer experience)
ABOUTINTRODUCTION30thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Transition plan – Changing Gear
The purpose of transition planning is to set thl’s long-term direction and strategic actions
to address our material climate-related risks and opportunities (CR&Os) and support our
business model, strategy and finance to move towards a low-carbon, resilient future.
In FY25, thl developed our transition plan, Changing Gear. This is not a new or stand-alone
plan. It reflects actions that have been inherent to thl strategy for several years that have
now been formalised in the transition plan. The actions identified in the transition plan are
integrated in thl’s business strategy and business plans.
Transition planning is an opportunity to align and integrate managing CR&Os within
business strategy, operations, products and services and see they feed through into
internal capital deployment and funding decision-making processes. We believe our
transition plan supports thl to remain flexible and respond effectively to regional
variations in climate impacts, technology readiness and regulation and policy changes.
Members of the Executive Leadership Team and CWG participated in transition planning
workshops in FY25. External consultants were engaged to facilitate transition plan
development aligned to the transition planning guidance from XRB. The Transition Plan
has been approved by the HSSC and the ARC and will be recommended to the Board for
final sign-off at the same time as these Climate Statements.
As part of developing the transition plan, thl considered the strategic intent and
foundational assumptions that underpin the thl business model and strategy and tested
how these assumptions might be challenged under different climate scenarios. As we
applied thl’s climate scenarios to stress test strategy resilience under different scenarios,
the need for a new additional scenario was identified to reflect different disorderly
transition risks.
Transition plan implementation
The development of thl’s first transition plan builds on and extends existing work integral
to thl’s strategy, including our Future Fleet scans and pilots to support low-emissions
fleet transition planning, carbon emissions reporting and tracking progress on site and
country/business group future-fit action plans and advancing non-tourism revenue streams.
Our climate transition plan is based on four core workstreams (Figure 5) aligned with thl
business strategy and the build/buy-rent-sell business model. These four workstreams
reflect the strategic options and management responses currently under way or that
may be considered in the future to respond to thl’s CR&Os, and management actions
that support thl’s response to climate change, including adaptation, mitigation and
decarbonisation plans.
The CR&Os identified as part of our climate scenario process are mapped against these
workstreams, which focus on actions thl intends to take in the short-term and the
identification of potential signals and trigger points thl intends to monitor to support
future decision-making in the long-term.
Each of these workstreams, along with thl’s CR&Os (as part of thl’s strategic risks), play
a role in thl’s capital deployment and funding decisions. The thl Board holds ultimate
authority over these decisions and will consider various factors such as current and
anticipated returns on capital, future outlook and alignment with thl’s strategic direction.
These workstreams inform the setting and review of thl’s longer-term strategy and
feeding into our regular shorter-term planning processes, including thl’s assessment of
priority projects and allocation of business resources.
Leadership for progress on each workstream is integrated within our core business
functions, led by the Executive Leader for the function or region. Coordination of the
transition plan work programme is embedded within our global future-fit sustainability
programme to further support integration and operationalising actions and tracking
progress. We will continue to evolve our transition planning over time as we make
progress or regulatory settings change.
Changing Gear – Transition Plan Workstream
Leverage demand forecasting and
climate projections to enhance RV
rental and tourism resilience
•
Market research
•
Demand forecasting
•
Industry partnerships
•
Adaptation plans
Chief Commercial Officer
Explore non-tourism revenue
opportunities to enhance resilience and
diversify revenue
•
Non-tourism solutions
•
Non-tourism revenue
•
New fleet types as appropriate
•
Design and manufacturing capability to
support revenue diversification
Chief Commercial Officer
Implement pathways to a low-emissions
fleet, focusing on cost and timing
effectiveness
•
Future Fleet scans
•
Fleet pilots and partnerships
•
Fleet planning flexibility
•
Fleet value retention
•
Design and manufacturing future-fit
initiatives
Chief Executive Officer
Optimise energy and emissions
performance at sites through the
Future-Fit Ignition programme
•
Location climate risk and resilience
assessment
•
Location risk management
•
Operational efficiency and emissions
reduction action
COO each region
Travel & tourism
demand forecasting
Future FleetNon-tourism revenue
Operational efficiency
& climate resilience
01020304
Figure 5: Changing Gear – transition plan workstreams
ABOUTINTRODUCTION31thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Workstream Two
Future Fleet
Action Manufacturing leads work to
explore and pilot low-emissions vehicle
options, including ongoing electric RV
pilots such as the Britz Evolve trial, and
engagement with international chassis
vendors. The team is taking a technology-
agnostic approach, supported by Board-
approved capital, to enable flexibility and
responsiveness as viable solutions emerge.
Action Manufacturing plays a central
role in thl’s transition plan and future-fit
sustainability strategy from designing
lower-emissions vehicles, embedding
emissions reduction future-fit practices
into production processes and exploring
more sustainable materials and
components.
This workstream supports climate
resilience in thl’s strategy by identifying
and progressing practical, time-
appropriate and cost-effective pathways
in each region for transitioning thl’s global
fleet to zero or low-emissions vehicles.
Changing Gear – aspects of strategy
Workstream One
Travel & tourism
demand forecasting
This workstream supports thl’s climate
resilience by anticipating how and where
demand for thl’s products and services
may shift to and supports decision-making
around whether to adapt offerings,
redeploy assets, pursue new opportunities
or markets, or divest from certain locations
or product offerings.
As the frequency and severity of climate
change impacts on destinations grows,
climate change considerations are likely
to increasingly influence when, where
and how people travel. Factors that could
influence traveller decisions include
concerns regarding physical climate
impacts and shifting customer preferences
towards lower-emissions travel.
In some regions, tourism demand may be
more affected by extreme weather events,
leading to changes in demand driven by
safety concerns, disrupted travel plans and
increased last-minute cancellations. We
already track and assess current impacts of
extreme events on customers. The timing
and scale of climate-related impacts on
travel trends will vary across the regions
where thl operates, and travel and tourism
demand patterns will vary across regions,
markets and customer segments.
Identifying and integrating climate-related
trend data and insights as part of thl’s
market research to support planning is
intended to support decision-making as
part of our commercial strategy.
thl is intending to develop transition
pathways to guide the timing and planning
for the shift towards a low-emissions
vehicle fleet globally. This work reflects the
diversity of thl’s operating regions, which
span multiple countries with varying zero-
emissions vehicle policies, infrastructure
maturity and customer expectations.
Annual Future Fleet scans track and map
progress of region-specific fleet transition
pathways. The scans focus on tracking
a range of signals, including technology
availability, regulation, emissions standards,
infrastructure expansion, customer
demand and vehicle depreciation trends.
Future Fleet scans are conducted annually
and insights from the scans inform fleet
planning procurement timelines, capital
planning and fleet composition decisions
across thl’s global operations.
Our focus is on maintaining flexibility
in the existing fleet while developing
scalable transition strategies that respond
to regulation, infrastructure, customer
readiness and technology availability
across key markets. Active engagement
with regional automotive bodies, industry
forums and low-emissions chassis vendors
is a priority to enable thl to move quickly
when new vehicle platforms become
available and cost-competitive.
0102
ABOUTINTRODUCTION32thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
Workstream Four
Operational efficiency
& climate resilience
approaches to integrate physical climate
risk and emissions data into facility
planning and investment decisions is
a consideration. This includes scoping
location-level climate risk scans for
exposure to hazards such as flooding, fire
and extreme heat as part of the future-fit
branch location assessment. This aims to
support consideration of physical climate
risks in property decisions, infrastructure
investments and broader business
continuity planning.
It is intended that the future-fit branch
new location assessment framework will
be revised to include climate resilience
alongside energy efficiency and emissions
reduction performance to support
informed long-term decisions about
relocations or reinvestment in sites.
This workstream supports thl to become
a climate-resilient business by evolving
consideration of emissions performance
and climate risks and resilience into
decision-making and investments.
Workstream Three
Non-tourism revenue
manufacturing capabilities are diversified
beyond traditional tourism vehicles to a
wider range of commercial and specialist
vehicles such as freight trucks, ambulances
and electric refrigeration trailer units.
This workstream supports thl business
strategy climate resilience by diversifying
revenue stream from product offerings
beyond tourism into new markets such as
emergency mobile accommodation and
specialist vehicles.
This workstream builds on work underway
to support non-tourism demand and
pursue non-tourism revenue models
and commercial opportunities, including
those related to temporary mobile
accommodation and other commercial
vehicle solutions.
Demand for emergency response vehicles
and mobile accommodation is expected to
grow, with climate-related extreme events
becoming more frequent and severe.
We continue to build relationships with
government and emergency response
agencies to explore how our vehicles can
meet evolving needs. We intend to focus
on expanding and maturing pilot projects
into scalable offerings, strengthening
supplier engagement to prioritise lower-
emissions inputs and developing our
capability in sustainability, circularity and
emissions reduction.
thl has the manufacturing capability to
supply both tourism and non-tourism
customers in Australia and New Zealand
with mobile infrastructure, fit-for-purpose
temporary accommodation and a range
of commercial vehicle solutions. Our
This workstream focuses on infrastructure
resilience and emissions performance
of thl’s locations globally, building
on progress made with the Ignition
programme to guide efforts to improve
operational efficiency and reduce
emissions from high-impact activities and
locations. Future-fit action plans are in
place for our branches, and progress on
emissions reduction is tracked through
carbon impact reports at a site and
country/business group level.
The action plans focus on reducing the
impacts of high-emissions activities
through targeted upgrades, energy
efficiency, renewables planning,
operational process improvements and
crew training and engagement.
This also involves work developing
renewable energy roadmaps to plan for
where renewable energy installation or
clean energy procurement is viable and
cost-effective. Renewable energy maps
can also support planning for future
energy requirements associated with fleet
electrification for Future Fleet transition
pathways. Developing appropriate
0304
ABOUTINTRODUCTION33thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCEAPPENDIXMETRICS AND TARGETSSTRATEGY
METRICS AND TARGETS
FY24 marked thl’s first compulsory
reporting year under the NZ CS and the
first year we reported on specific metrics
used to measure and manage climate-
related risks and opportunities (CR&Os)
(beyond GHG emissions data). FY24 was
also the first full year of GHG emissions
data for the global business, following
the thl/Apollo merger in November 2022
and the inclusion of an extended Scope 3
inventory.
In line with NZ CS 2 Adoption provision 6,
this disclosure presents FY25 metrics
alongside FY24 comparatives only. From
FY26 onwards, we will report metrics in
accordance with the usual requirements of
the NZ CS (i.e. with comparatives covering
the two preceding years). We have chosen
to use Adoption provision 7 as while we
have begun some work to understand
trends following the Apollo merger
and other changes to the business, we
anticipate we will be able to provide more
detail on trend analysis in FY26.
We continue to evolve our methodologies
and approach to the climate-related
metrics we report on as thl grows and
industry approach matures, with a focus
on maintaining relevance and usefulness.
Any material changes to the calculation
methods have been documented and
explained. Where applicable and practical,
metrics from the preceding year have been
updated to reflect the revised approach to
enable year-on-year comparison.
Future-Fit Business Benchmark
In addition to thl’s specific GHG emissions
reduction target (see page 40), thl remains
committed to our future-fit journey and
to addressing our priority future-fit goals,
guided by the 23 Break-Even Goals of
the Future-Fit Business Benchmark. Our
global future-fit sustainability programme
focuses on our high-priority goals and is
well established and integrated across our
business strategy, plans and operational
activities. These goals are considered to be
system-level goals rather than industry-
level goals as they consider cross-sector
value chains and interconnected systems.
They are not timebound but are designed
to guide long-term, systemic sustainability
transformation. thl considers that these
priority goals are important to giving
effect to our global sustainability strategy
and progressing the actions set out in our
transition plan.
From the 23 Break-Even Goals, we
identified five high-priority goals to tackle
our biggest sustainability challenges. These
are being progressed through targeted
workstreams in the global sustainability
work programme (see page 13):
•
BE01: Energy is from renewable sources
•
BE04: Procurement safeguards the
pursuit of future-fitness
•
BE06: Operations emit no greenhouse
gases
•
BE18: Products emit no greenhouse
gases
•
BE19: Products can be repurposed
The Future-Fit Business Benchmark does
not prescribe timeframes for achieving
these goals. thl has been tracking progress
against these goals since 2019 in our annual
health check reported in our Integrated
Annual Report, but we have not set
specific dates for achieving these. Specific
actions are managed through the global
sustainability programme, and in FY25,
relevant actions have been aligned and
integrated into the transition plan.
Of these BE goals, three directly support
thl’s efforts to reduce GHG emissions
across energy use, operations and
product lifecycles.
ABOUTINTRODUCTION34thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
•
BE01: Energy is from renewable sources
This goal relates to the transition
to renewable energy across thl’s
operations. Our current focus is on
operational energy efficiency (electricity,
gas, fuel), and progress on renewable
electricity for sites. Progress varies by
region and is considered in country and
branch action plans and impact reports.
Energy efficiency and renewable energy
initiatives are embedded in thl’s future-
fit action plans (the Ignition workstream)
and country-level sustainability work
plans, as well as our transition plan.
We regularly review renewable energy
progress and options to purchase or
produce renewable energy for our sites.
This year, the Adelaide branch co-located
on the Camperagent site, which has solar
power installed. thl has not currently
set a target date for this goal. We do not
currently report on global metrics for
renewables for all energy sources under
BE01. We understand what is required
to achieve this goal for our sites globally
and, while we have made some progress,
we recognise we have more work to do,
and this will take time. In FY25, work to
develop renewable energy pathways
for each region was identified as part
of in our transition plan’s Workstream
Four: Operational efficiency and
climate resilience.
•
BE06: Operations emit no
greenhouse gases
This goal focuses on an absolute
reduction of GHG emissions from thl’s
direct operations and energy use.
We report our operational emissions
annually (including Scope 1, Scope 2, and
selected Scope 3 activities - see Table
5). In FY25 there has been an increase
of 8% in our operational emissions, as
explained further on page 36 and 51.
This is influenced by factors such as
site relocations and increased rental
activity. While thl has not specifically
considered the extent to which this goal
contributes to limiting warming to 1.5°C,
thl’s Scope 1 and 2 emissions reduction
target (see page 40) contributes to
this goal and allows thl to measure
progress. No offsets are applied to this
goal, and at this stage, no timeframe
has been set for this goal. We continue
to implement future-fit action plans to
reduce operational emissions for our
branches globally. Site-level reduction
efforts are ongoing and monitored
through carbon impact reports. Our Kiwi
Experience buses are a large contributor
to our Scope 1 operational emissions. We
are working to reduce this through fuel-
efficient driving and routes and offering
smaller group tours. We have improved
our understanding of the work required
to progress this goal for our operations
globally, and are progressing actions
to reduce operational emissions, while
also recognising there are still gaps and
more work required to progress this
goal. In FY25, work developing emissions
reduction pathways for each region has
been identified as part of our transition
plan’s Workstream Four: Operational
efficiency and climate resilience.
•
BE18: Products emit no
greenhouse gases
This goal focuses on an absolute
reduction of GHG emissions from
thl’s sold products. We report our
emissions from use of sold products
annually (Category 11- see Table 5). In
FY25 the figures show a decrease of
35%. As explained further on page 36,
this decrease relates to sales volumes
and changes to assumptions rather
than any specific actions to reduce
these emissions (e.g. design changes
or product efficiency improvements).
No offsets are applied to this goal, and
currently, no specific timeframe has
been set for this goal. We have not
specifically considered the extent to
which this goal contributes to limiting
warming to 1.5°C. This is thl’s most
challenging Break-Even Goal, as it is
dependent on transitioning to a zero-
emissions vehicle fleet. Achievement
of this goal relies on the advancement
of suitable low-emissions vehicle
technology that is not currently readily
available. We acknowledge we have
not yet made measurable progress on
this goal due to the lack of availability of
suitable low or zero emission vehicles.
We continue to track transition progress
in each region where we operate with
annual Future Fleet scans for tipping
points for technology, regulation,
infrastructure and funding. Progress
remains slow as we are a technology
taker, but we continue engaging
suppliers and OEMs globally on progress
for low-emissions vehicles suitable for
RV use. Action Manufacturing continues
pilot opportunities, including our second
electric-RV pilot and working with Hato
Hone St John on electric ambulance
pilots. Action Manufacturing subsidiary
Transcold NZ is now the official channel
for Addvolt – industry-leading plug-in
electric systems for refrigerated vans,
trucks, trailers and containers. Future
Fleet is a core workstream in our
transition plan Changing Gear.
Progress against all 23 Break-Even
Goals (including our priority goals) is
summarised annually in the future-fit
health check, which has been published
since FY19 and is available on pages
32–33 of the Integrated Annual Report
2025 available at www.thlonline.com or
www.thlsustainability.com.
ABOUTINTRODUCTION35thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
GHG emissions
We continue to monitor, manage and
report our GHG emissions (Scope 1, 2 and 3)
across our operations and value chain.
As disclosed in last year’s report, thl reset
its GHG emissions baseline year as FY24.
This change was a result of our expanded
GHG inventory (carbon footprint) following
the thl/Apollo merger in late 2022, the
inclusion of an extended Scope 3 inventory
and a shift from an equity share approach
to our emissions to an operational
control approach, which moved all of our
customers’ journey emissions from Scope
1 to Scope 3. The FY24 baseline provides
a more relevant, accurate basis for future
comparisons.
We have accordingly revised our existing
Scope 1 and 2 GHG emissions reduction
targets to account for the changes to
thl’s GHG emissions baseline year. Our
new absolute reduction target is a 50.4%
reduction in our Scope 1 and 2 emissions
from the FY24 baseline by the end of FY32
6
– see page 40 for details.
In FY25, thl’s total GHG emissions inventory
(Scope 1, 2 and 3) was a total of 798,079
tCO₂e, representing a 26% decrease
(-286,265 tCO₂e) compared to FY24
(1,084,341 tCO₂e)
7
. Scope 3 continues to
account for the largest share of emissions
(>99%), with the top three categories being:
•
Category 11: Use of sold products –
i.e. emissions from vehicles driven
by our customers
•
Category 13: Downstream leased assets
– i.e. emissions from leased vehicles
driven by our customers
•
Category 1: Purchased goods
and services.
The reduction in total GHG emissions for
FY25 is primarily driven by a reduction
in total Scope 3 emissions, reflecting
challenging market conditions that saw
fewer units sold to customers across both
the manufacturing and retail businesses
from FY24. As market conditions stabilise,
thl anticipates that sales volumes will
increase and associated emissions will
therefore also increase in future years.
Nonetheless, we remain focused on
identifying emissions reductions and
efficiencies that are not directly tied
to sales volumes.
Additionally, Scope 3 Category 11: Use of
sold products saw an adjustment to the
expected life expectancy assumptions
applied to the sold RV units to improve
the accuracy of regional differences in
fleet turnover and usage patterns, which
reduced the emissions associated with
the remaining life of the vehicle. This
change is explained further in Appendix 3.
Combined Scope 1 and 2 emissions also
decreased modestly by 2% compared
to FY24. However, total operational
emissions (including Scope 1 and 2 and
selected Scope 3 activities) increased
by 8%, influenced by factors such as site
relocations and increased rental activity.
Building on improvements made in FY24,
thl has continued to enhance the accuracy
and consistency of its GHG inventory in
FY25. This includes refining data quality
and reducing reliance on assumptions. thl
remains committed to regularly reviewing
its calculation methods and assumptions
to keep alignment with the best available
data and evolving industry practices.
thl is also committed to reducing
emissions across the full value chain,
including Scope 3. We believe that
our sustainability initiatives, including
energy efficiency improvements,
renewable energy adoption and supply
chain engagement, are making an
impact. However, the emissions from
our customers’ journeys and the use of
motorhomes and other vehicles that
we sell (use of sold products) remain
our largest challenge. We aim to be
a leader and to transition our fleet to
lower-emissions technologies, but as
a technology taker, thl is significantly
constrained by the limited availability of
suitable zero or low-emissions chassis
and charging network infrastructure.
We continue to proactively explore
transition pathways through our Future
Fleet scans and intend to revisit developing
a Scope 3 emissions reduction target at
the time when more viable options are
available to reduce vehicle emissions. We
continue to focus on optimising existing
technologies and improving operational
efficiencies to achieve emissions
reductions elsewhere in our inventory.
The following pages provide a breakdown
of these results. Appendix 3 outlines
the reporting approach, methods
and assumptions applied and the
key uncertainties that influence our
emissions profile.
6. We acknowledge that our updated GHG emissions reduction target represents approximately 1% of thl’s baseline year total GHG emissions inventory, as it applies only to Scope 1 and Scope 2 emissions. While thl has a desire to set a Scope
3 target, we believe doing so is not currently feasible given the lack of a viable pathway to reduce vehicle chassis emissions (approximately 85% of FY24 Scope 3 emissions) and uncertainty regarding the timing and availability of technology
and supporting infrastructure. This prevents us from making commitments that would reflect a science-aligned target covering our full GHG inventory at this time. Nonetheless, we remain committed to progressing reductions towards
our updated target and being transparent about the limited contribution of this target to our overall footprint.
7. In FY25, thl has focused on data quality improvements. Through this continuous improvement process, a double-counting error was identified in the FY24 GHG inventory. Specifically, rental fleet distance data had been counted across
both Scope 1 and Scope 3 activities, resulting in an overstatement of 479 tCO₂e in Scope 1 transport fuel emissions and an overstatement of 118 tCO₂e in Scope 3 fuel and energy-related (Category 3) emissions. These figures have been
corrected in this report to see accurate reporting and comparison.
ABOUTINTRODUCTION36thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
a thl’s operational GHG emissions refer to the emissions directly associated with the
day-to-day activities of our organisation, over which we have most control and
influence. It includes all Scope 1 and 2 and any Scope 3 indirect emissions that occur
in thl’s value chain that are closely related to operational activities, being business
travel (Category 6), relocation costs (Category 4), waste (Category 5), employee
commuting (Category 7) and consumables such as tyres, batteries and water
(within Category 1).
b thl’s value chain emissions encompass a broader range of Scope 3 emissions,
including all indirect emissions that occur both upstream and downstream in the
value chain. This includes (but is not limited to) emissions from customer journeys
(within Category 13), purchased goods and services (Category 1) and the use of sold
products (Category 11).
c thl’s GHG intensity figure is calculated using thl’s operational GHG emissions and
total revenue for FY25. All numbers are subject to rounding.
Independent assurance provider Ernst & Young Limited provided reasonable assurance
over thl’s FY25 Scope 1 and 2 emissions sources and limited assurance over Scope 3
emissions. Refer to the EY GHG assurance on page “Independent Assurance Report to
tourism holdings limited” on page 58.
8. See footnote 7, page 36.
9. In FY25, Planet Price software updates enabled thl to further categorise and report Scope 3 spend based emissions
sources against each of the GHG Protocol Scope 3 categories (in FY24 Climate Statements, all figures were applied to
Category 1 – Purchased Goods and Services). For comparability, we have reallocated the assured figures from FY24
using this categorisation function in Planet Price.
Table 5: Summary of total organisational GHG emissions
Figures rounded to the nearest tonne (tCO₂e)
ScopeCategoryFY25
FY24
(baseline)
8,9
Percentage
change
Scope 1Direct emissions3,9294,081
8
-4%
Scope 2Electricity consumption
(location-based)
2,4512,4032%
Scope 3 Category 1Purchased goods and
services
9
54,61956,305-3%
Scope 3 Category 2Capital goods
9
20,91318,07816%
Scope 3 Category 3Fuel- and energy-related
activities
9
1,3261,156
8
15%
Scope 3 Category 4Upstream transportation
and distribution
9
4,0632,94238%
Scope 3 Category 5Waste generated in
operations
9
3,4422,53236%
Scope 3 Category 6Business travel
9
1,5571,5183%
Scope 3 Category 7Employee commuting3,5253,528>1%
Scope 3 Category 11Use of sold products562,186858,748-35%
Scope 3 Category 12End-of-life treatment of
sold products
5,89420,450-71%
Scope 3 Category 13Downstream leased assets134,170112,59919%
Total Scope 13,9294,081-4%
Total Scope 22,4512,4032%
Total reported Scope 3791,6961,077,857-27%
Total798,0761,084,341-26%
Operational GHG emissions
a
14,65113,6198%
Value Chain GHG emissions
b
783,4251,007,722-27%
GHG intensity (tCO₂e per million dollars
of revenue)
c
15.6314.776%
ABOUTINTRODUCTION37thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
Figure 7: FY25 Operational Emissions
Total (tCO₂e)
14,651
Figure 8: FY25 Value Chain Emissions
Measured Scope 3 – Total (tCO₂e)
783,425
Total (tCO₂e)
798,076
Figure 6: FY25 Total Group-Wide
GHG Emissions by Scope (tCO₂e)
Scope 1
3,929
Scope 2
2,451
Measured
Scope 3
8,271
Sold Products
568,080
Downstream
leased
assets
134,170
Purchased
goods and
services
52,956
Other
28,219
Scope 3
791,696
99.2%
Scope 1
3,929
0.5%
Scope 2
2,451
0.3%
ABOUTINTRODUCTION38thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
Figure 10: Group-Wide Measured Scope 3 GHG Emissions by Category (tCO₂e)Figure 12: FY25 Total Group-Wide GHG Emissions by Business Unit (tCO₂e)
Total Scope 1, 2 and Measured Scope 3
Figure 9: FY25 Total Group-Wide GHG Emissions by Country (tCO₂e)
Scope 1, 2 and Measured Scope 3
Figure 11: FY25 Total Customer Journey GHG Emissions by Country (tCO₂e)
Measured Scope 3
17%
FY25 Total
●
New Zealand265,162
●
Australia243,052
●
United States of America179,508
●
Canada69,933
●
United Kingdom
and Ireland
40,420
Total798,076
33%
5%
30%
22%
9%
FY25 Total
●
Use of sold products562,186
●
Downstream leased assets134,170
●
Purchased goods
and services
54,619
●
Capital assets20,913
●
End-of-life treatment of
sold products
5,894
●
Upstream transportation
and distribution
4,063
Employee commuting3,525
Waste generated in
operations
3,442
Business travel1,557
Fuel- and energy-related
activities
1,326
Total791,695
17%
7%
71%
3%
FY25 Total
●
United States of America45,444
●
Australia39,451
●
New Zealand26,962
●
Canada17,751
●
United Kingdom
and Ireland
2,402
Total132,011
34%
2%
30%
13%
Total
●
Self drive experience
(rentals)
411,347
●
Manufacturing204,085
●
Dealerships181,381
Tourism1,104
Group support services*158
Total798,076
* includes Digital
52%
23%
26%
20%
1% 1%
ABOUTINTRODUCTION39thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
GHG target
In FY25, thl updated our Scope 1 and 2
emissions reduction targets to reflect
our updated baseline year of FY24. The
FY24 baseline year (1 July 2023 – 30 June
2024) replaces the previous FY20 baseline,
which no longer provides a meaningful
comparison due to changes in reporting
methodology, specifically the shift from an
equity share approach to an operational
control approach, which moved all of our
customers’ journey emissions from Scope
1 to Scope 3, as well as changes to business
geography, scale and operations following
the Apollo/thl merger in 2022.
The FY24 baseline provides a more
meaningful and relevant basis for future
comparisons. If thl reported against the
original FY20 baseline following these
changes, Scope 1 and 2 emissions would
reduce materially (-93%), but largely
because customer journey emissions are
no longer being reported within Scope 1,
which would present a misleading
picture. Even excluding customer journey
emissions, comparing Scope 1 and 2
emissions against FY20 would also not
be useful for readers, as it would show
a material increase (48%) due to the
incorporation of Apollo.
thl’s updated target is to reduce absolute
Scope 1 and 2 GHG emissions from our
FY24 baseline by 50.4% by the end of
FY32
10
. We acknowledge this updated
target represents approximately 1% of our
total emissions
11
.
This target was based on the adjusted
FY24 baseline of 6,484 tCO₂e (Scope 1:
4,081 tCO₂e; Scope 2: 2,403 tCO₂e) and
was developed using the Science Based
Targets initiative (SBTi) tools, which are
widely recognised for their scientific rigour
and alignment with the global goal of
limiting warming to 1.5°C. Over 99% of our
baseline year total footprint is in Scope 3
(91% relates to the rental and sale of ICE
vehicles). thl has not yet set a Scope 3
target, due to the current lack of a viable
pathway to transition our fleet, however
our Future Fleet workstream continues
to explore viable alternatives to ICE
engines. Because our Scope 3 emissions
contribute more than 40% of our footprint,
but are not yet included in our emissions
reduction target, thl’s updated target does
not currently meet the requirements for
a SBTi-certified science aligned target,
and we have not submitted this target
for formal SBTi validation.
0
1000
2000
3000
4000
5000
6000
7000
8000
FY32FY31FY30FY29FY28FY27FY26FY25FY24
tCO₂e
Scope 1Scope 2Reduction target
Figure 13: Progress to date against revised Scope 1 and 2 Emissions Target
(FY24 Baseline)
Progress against the target
From the FY24 baseline, Scope 1 and 2
emissions have decreased by 2% in FY25.
This reduction is driven by several factors,
including reduced operational activity
in some parts of the business driven by
lower customer demand. Globally, we
continue to prioritise energy efficiency
through our future-fit branch action
plans. In particular our North American
businesses (comprising the US and
Canada) have achieved reductions in
electricity consumption through site
and equipment upgrades that deliver
improved energy performance.
Comparative Analysis:Scope 1 and 2 emissions
FY24 Baseline Scope 1 and 2 (tCO₂e)6,484
FY25 Scope 1 and 2 (tCO₂e)6,380
Difference (tCO₂e)-104 (-2% decrease)
10. thl is not currently using GHG emission offsets to support this target and we have not set any interim targets.
11. We acknowledge that our updated GHG emissions reduction target represents approximately 1% of thl’s baseline year
total GHG emissions inventory, as it applies only to Scope 1 and Scope 2 emissions. While thl has a desire to set a Scope
3 target, we believe doing so is not currently feasible given the lack of a viable pathway to reduce vehicle chassis
emissions (for example, approximately 85% of FY24 Scope 3 emissions) and uncertainty regarding the timing and
availability of technology and supporting infrastructure. This prevents us from making commitments that would
reflect a science-aligned target covering our full GHG inventory at this time. Nonetheless, we remain committed to
progressing reductions towards our updated target and being transparent about the limited contribution of this target
to our overall footprint.
ABOUTINTRODUCTION40thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
Climate metrics
Emissions intensity
Description:
thl uses a revenue-based GHG emissions intensity metric – operational emissions per NZD million
revenue. This approach enables consistent comparison across thl’s global operations.
FY25 Result
15.63 tCO₂e/$ million revenue (NZD).
FY24 Result
14.77 tCO₂e/$ million revenue (NZD).
Note: This figure has been restated based on
changes to the FY24 GHG emissions inventory.
Analysis of change
The increase in emissions intensity is driven by higher global rental activity, site relocations and
data improvements, including consistency and more granular data, which reduced reliance on
assumptions.
There have been no changes to how this metric is calculated in FY25. Any changes to how the
GHG emissions are calculated are explained in Appendix 3.
Calculation approach
Emissions intensity is calculated by dividing
total operational emissions by total revenue
(as reported in the Integrated Annual Report).
There have been no changes to how this
metric is calculated in FY25. Any changes to
how the GHG emissions are calculated are
explained in Appendix 3.
Limitations to approach
This metric is influenced by external factors
beyond operational efficiency such as market
demand and pricing. Because thl’s business
units define activity differently, an alternative
single emissions intensity metric is difficult to
apply consistently. Despite its limitations, this
revenue-based approach is commonly used
by climate-reporting entities and remains
the most suitable method for comparing
emissions intensity across thl’s diverse
operations and with other organisations.
Vulnerability to transition risks
Description:
In order to assess thl’s vulnerability to transition risk the following metric is used:
•
A percentage of thl sites (covering sales, rentals and manufacturing) in regions with
legislation for ICE vehicle phase-out dates before 2040.
This metric was chosen because these business units cover a significant proportion of our total
revenue. It highlights where thl may have potential challenges, particularly related to our low-
emissions fleet transition and regulatory compliance risks.
FY25 Result
52% of thl’s sales, rental and manufacturing
sites (25 of 48) were exposed to this
transition risk.
FY24 Result
54% of thl’s sales, rental and manufacturing sites
(28 of 52) were exposed to this transition risk.
Note: This figure has been restated based on
changes to the calculation method since FY24.
Analysis of change
Between FY24 and FY25, there has been a decrease in the percentage of thl’s rentals, sales
and manufacturing sites in regions with legislation for ICE vehicle phase-out dates before
2040. This decrease is a result of site closures rather than regulatory changes.
Calculation approach
This is calculated as the number of
manufacturing, sales and rental branches
that are in regions that have ICE vehicle
phase-out dates before 2040. It only
includes sites operating at the end of the
reporting period.
thl continues to refine definitions and
calculation processes to enable year-on-year
comparison. In FY25, a review of this metric
included thl’s manufacturing locations
as these would also be impacted by the
changing regulation related to ICE vehicles.
The FY24 result has been updated to include
these locations for comparability.
The FY24 calculation of the number of sites
impacted by this transition risk included
New Zealand, however there is not currently
ICE phase-out legislation in place. The
New Zealand Government has committed
to a target as a signatory to the Global Drive
to Zero Memorandum of Understanding.
In FY25, the review of locations with phase-
out targets in place has been updated to only
include locations where phase-out regulations
apply or are underway.
Limitations to approach
A limitation of this method to be considered
in the future is the potential for regions or
states without current ICE phase-out dates
setting policies and regulations. thl cannot
predict which regions will abruptly change
targets and policies. Changes may occur with
changing governments and their different
policy agendas.
ABOUTINTRODUCTION41thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
Vulnerability to physical risks
Description:
In order to assess thl’s vulnerability to physical risk, the following metric is used:
•
A percentage of thl’s rental branches impacted by acute climate-related weather
events during the reporting year.
This metric was chosen because the key physical risk relates to the impact of climate on
booking patterns, which is more applicable to thl’s rental operations.
thl acknowledges that many of its locations are situated in regions prone to weather patterns
intensified by climate change such as heatwaves and wildfires and that these will vary
significantly depending on the year in question. For this metric, acute climate-related events
are defined as extreme weather occurrences such as hurricanes, floods and wildfires that
disrupt normal business operations, assets or customer experiences. Examples include site or
destination closures, rerouting, cleaning or repairs, and damage to vehicles or buildings.
FY25 Result
31% of rental branches (11 of 35) were impacted
by acute climate-related weather events in
FY25 and are therefore considered vulnerable
to physical risk. This included events in
Australia (Queensland), US (California
branches), Canada (Alberta and British
Columbia branches) and UK and Ireland
(all branches).
FY24 Result
47% of rental branches (17 of 36) were
impacted by acute climate-related weather
events in FY24 and are therefore considered
vulnerable to physical risk. This included
events occurring in Australia (Queensland,
Victoria and New South Wales), New Zealand
(Auckland), US (California), Canada (Alberta
and British Columbia) and UK and Ireland
(all branches).
Analysis of change
There has been a decrease in the percentage of thl’s rental branches impacted by acute
weather events between FY24 and FY25. This reflects the inherent unpredictable nature of
acute weather events, both in frequency and severity.
Calculation approach
Vulnerability is determined by identifying the
number of rental branches impacted by acute
extreme weather events such as wildfires,
flooding, hail and heatwaves that disrupted
normal operations, assets or customer
experiences such as site closures, rerouting,
repairs or damage in the current financial year.
thl continues to refine its definitions and
calculation processes to support year-on-year
comparison. In FY25, the process matured
through integration with standard business
reporting and regional operational reviews.
This enabled more precise identification of
rental locations and events that adversely
impacted operations, assets or customers.
Limitations to approach
thl does not attempt to attribute these
events directly to climate change. Instead,
all weather-related events that affected
operations are included.
While some branches may also face
chronic physical risks such as sea-level
rise, temperature shifts, assessing these
would require a location-specific climate
risk assessment, which has not yet been
conducted.
Climate-related opportunities
Description:
In order to assess thl’s alignment with climate-related opportunities, the following metric
is used:
•
Total hire days in the reporting year from RVs used for mobile housing or service
delivery in relation to acute weather events such as flooding and cyclones/hurricanes.
This metric directly relates to thl’s mobile housing and emergency response opportunity. It is
used to compare year-on-year demand changes related to RV hires for non-tourism purposes
attributable to climate-related events.
FY25 Result
All thl’s global rental businesses are aligned
to support the demand for RVs in response to
acute weather events, subject to availability.
In FY25, approximately 3,600 hire days
were attributed to demand arising from
such events.
FY24 Result
All thl’s global rental businesses are aligned
to support the demand for RVs in response to
acute weather events, subject to availability.
In FY24, approximately 12,000 hire days
were attributed to demand arising from
such events.
Analysis of change
There has been a 70% decrease in the number of hire days attributed to demand arising from
acute weather events between FY24 and FY25. This reflects the inherent unpredictable nature
of acute weather events, both in frequency and severity.
In FY24, thl RVs were used in the post event response and recovery from Cyclone Gabrielle in
New Zealand, flooding in AU and hurricanes and wildfires in the US. In FY25, significant events
included the post event response and recovery from flooding events in NZ and AU, hurricanes
in the US, and wildfires in AU.
Calculation approach
The number of RV hire days allocated to this
opportunity was provided by thl Commercial
and Operational Leads.
Limitations to approach
A limitation of this method is the need to
understand which vehicle allocations are
made to specifically climate-related events.
ABOUTINTRODUCTION42thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
Capital deployment
Description:
Measured as the gross capital deployed in the financial year towards projects or initiatives
with a material capital outlay such as Future Fleet pilot projects or other investments such
as site enhancements for emissions reductions, energy efficiency or climate adaptation and
resilience. This does not include business-as-usual expenses associated with labour or ongoing
market research and business development.
The thl Board has approved ongoing capital expenditure on our Future Fleet programme that
can achieve a negative return on funds employed to trial EVs and other low-carbon vehicle
technologies (as outlined on page 32) at a rate of up to NZD2 million p.a. To date, thl has
conducted two pilot trials of electric RVs within its rental fleet.
FY25 Result
In FY25, there was no material funding
towards addressing CR&Os. Funds were
allocated for site enhancements as part
of the Waitomokia site development.
However, this is difficult to quantify the
proportion attributable to climate-related
enhancements.
FY24 Result
In FY24, thl deployed NZD960,000 (gross)
towards addressing CR&Os. This was for the
pilot of electric RVs in NZ.
Analysis of change
There has been a decrease in the gross capital deployed between FY24 and FY25.
Following the capital investment of $960,000 in electric RV pilot trails in FY24, thl continues to
evaluate the data collected as part of its research and development to understand travel habits
and patterns as part of our Future Fleet workstream.
In FY25, there was no material funding allocated due to limited technological advances in the
EV (mid-range space) over the past year. thl closely monitors this and intends to invest further
as technologies develop.
Calculation approach
The method used was the capital expenditure
on Future Fleet pilot projects excluding
other investment such as travel for research
and development.
Other capital deployment was also assessed
for significant capital outlay.
All figures are converted to NZD.
Limitations to approach
There is some uncertainty about the sum that
is recoverable such as from the sale of electric
RVs.
Internal emissions price
Description:
thl’s internal emissions price is based on the social cost of carbon (SCC) – an estimate of the
impact of each additional tonne of carbon emissions.
FY25 Result
In FY25, thl adopted the internal emissions
price of the US EPA value of NZD86 (USD51)
per tCO₂e.
FY24 Result
In FY24, thl adopted the internal emissions
price of the US EPA value of NZD86 (USD51)
per tCO₂e.
Analysis of change
There has been no change between FY24 and FY25.
Calculation approach
thl uses AI software Planet Price to set
an internal proxy price for environmental
externalities, including carbon. Planet Price
uses the US Environmental Protection Agency
(EPA) value as the SCC as it is based on
comprehensive, peer-reviewed methodologies
and reflects the latest climate science and
socioeconomic projections, providing a
balanced and credible estimate. The SSC
value is based on a 3% future discount rate (a
method used to compare the value of future
impacts to those experienced today), which
may be revisited in coming years, leading to
an increased value.
Limitations to approach
The EPA SCC is tailored to US policy contexts
and may not fully reflect environmental,
economic or social conditions in other
countries where thl operates.
Using the fixed 3% discount rate influences
how future damages are valued today. Some
jurisdictions or climate economists argue for
lower rates to better reflect intergenerational
equity, which would result in a higher SCC.
Remuneration
Description:
thl does not currently consider CR&Os within management remuneration. In FY25, thl’s
Remuneration and Nomination Committee (a Board subcommittee) reaffirmed its decision
not to include climate-related performance metrics in executive remuneration on the basis
that there are not yet substantive targets for the business, particularly in relation to Scope 3
emissions, where emissions reduction is significantly constrained by the limited availability
of suitable zero or low-emissions chassis and charging network infrastructure.
Analysis of change
There has been no change between FY24 and FY25.
ABOUTINTRODUCTION43thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYAPPENDIXMETRICS AND TARGETS
APPENDIX 1: GLOSSARY OF TERMS
Commonly referred terms
Changing Gearthl’s transition plan.
Climate
Statements
thl’s report detailing the company’s mandatory climate-related
disclosures complying with the NZ CS.
Climate-related
risks and
opportunities
Risks and opportunities associated with climate change that can
impact the business. Can be related to the physical or transition
impacts of climate change.
Climate Working
Group (CWG)
thl’s cross-functional group set up to develop and embed
elements of all workstreams under the CWG Work Plan throughout
the business and meet climate-related disclosure reporting
requirements.
CWG Work Planthl’s internal work plan developed to provide structure and business
alignment to climate-related disclosure initiatives.
ERM frameworkA structured framework used to identify, assess and manage risks
across the organisation.
Future Fleetthl workstream focused on transitioning the vehicle fleet to zero or
low-emissions vehicles.
Future-Fit
Business
Benchmark
A sustainability framework that includes a set of future-fit break-
even goals designed to guide long-term, systemic sustainability
transformation.
Greenhouse gas
(GHG) emissions
The release of gases which trap heat in the atmosphere,
contributing to global warming. Categorised as Scope 1, 2
and 3 emissions.
Internal
Combustion
Engine (ICE)
Vehicle
A vehicle engine powered by burning fossil fuels (petrol or diesel).
MaterialityThe threshold for what information is significant enough to impact
stakeholder decisions.
Original
Equipment
Manufacturer
(OEM)
A company that makes vehicles or equipment used by others for
further production or modification.
Operational
Emissions
thl’s internal categorisation of GHG emissions. Includes GHG
emissions directly associated with thl’s day-to-day activities, over
which we have the most control and influence. Such as all Scope
1 and 2, and any Scope 3 indirect emissions closely related to
operational activities – see page 37.
OpportunitiesPositive outcomes that may arise from climate action such as improved
efficiency, cost savings, adoption of low-emissions technologies, new
products and services, and enhanced value chain resilience. Can be
related to the physical or transition impacts of climate change.
Physical risksRisks or opportunities arising from the physical impacts of climate
change, including acute events such as extreme weather and
chronic changes such as temperature shifts, sea-level rise and
altered precipitation patterns.
Scenario analysisA process of analysing potential future scenarios to understand
the resilience of the business model and strategy under different
climate-related conditions.
Scope 1, 2, 3GHG Emissions categories
Scope 1: Direct emissions from owned or controlled sources
Scope 2: Indirect emissions from purchased energy
Scope 3: All other indirect emissions upstream and downstream
activities across the value chain.
tCO₂eTonnes of carbon dioxide equivalent.
Technology takerthl is reliant on external innovation and market readiness to enable
the adoption of the latest technology and adapt its business
processes. thl depends on OEMs to develop suitable zero or low-
emissions chassis for our RVs.
Transition planA strategic long-term plan that considers the actions, timelines
and dependencies that support thl‘s transition to a low-emissions,
climate resilient future.
Transition risksRisks or opportunities linked to the shift towards a low-emissions,
climate-resilient economy, including changes in policy, regulation,
technology, markets and reputation.
Value Chain
Emissions
thl’s internal categorisation of GHG emissions. Includes GHG
emissions released throughout the thl’s supply chain such as Scope
3 activities not captured under Operational Emissions.
ABOUTINTRODUCTION44thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Frequently used acronyms
ARC Audit and Risk Committee
CR&Os Climate-related Risks and
Opportunities
CWG Climate Working Group
ERMEnterprise Risk Management
HSSC Health, Safety and Sustainability
Committee
ICEInternal Combustion Engine
NGFSNetwork for Greening the
Financial System
NZ CSAotearoa New Zealand Climate
Standards
NZ FMA New Zealand Financial Markets
Authority
OEM Original Equipment
Manufacturer
RQARisk, Quality and Assurance
RVRecreational Vehicle
thlTourism Holdings Limited
XRBExternal Reporting Board
Reference guide to symbols used throughout this document
AspectReference symbols
Timeframe
See page 16.
Short-term (0–2 years)
Medium-term (2–10 years)
Long-term (10+ years)
Risk or opportunity type
When identifying risks and
opportunities, thl has adopted
the definitions used by the XRB
in NZ CS – see page 44.
Transition risk
Physical risk
Transition opportunity
Physical opportunity
Value chain
See pages 11-12.
Rent
Build/Buy
Tourism
Sell
thl’s operating regions
See page 11.
UK
&
IR
NZ
CAUS
AU
Global (Group-wide)
AustraliaUK and Ireland
Canada
New Zealand
US
thl’s climate scenarios
See pages 16-22.
Delayed and
Disorderly Transition
Orderly
Hothouse World
Fragmented World
(new in FY25)
thl’s transition plan workstreams
See pages 31-33.
Travel and tourism
demand forecasting
Future Fleet
Operational efficiency and
climate resilience
Non-tourism revenue
ABOUTINTRODUCTION45thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Subheading Clause Disclosure Page
Governance: To enable primary users to understand both the role an entity’s governance body plays in overseeing climate-related risks and climate-related opportunities, and the role
management plays in assessing and managing those climate-related risks and opportunities.
Disclosures7athe identity of the governance body responsible for oversight of climate-related risks and opportunities;6
7ba description of the governance body’s oversight of climate-related risks and opportunities (see paragraph 8); 6-9, 23-24
7ca description of management’s role in assessing and managing climate-related risks and opportunities (see paragraph 9).9, 23-24
Governance
body oversight
8athe processes and frequency by which the governance body is informed about climate-related risks and opportunities;6-8
8bhow the governance body ensures that the appropriate skills and competencies are available to provide oversight of climate-related risks
and opportunities;
8
8chow the governance body considers climate-related risks and opportunities when developing and overseeing implementation of the entity’s strategy;8
8dhow the governance body sets, monitors progress against and oversees achievement of metrics and targets for managing climate-related risks and
opportunities, including whether and if so how, related performance metrics are incorporated into remuneration policies (see also paragraph 22(h)).
8
Management’s
role
9ahow climate-related responsibilities are assigned to management-level positions or committees, and the process and frequency by which
management-level positions or committees engage with the governance body;
7, 9
9bthe related organisational structure(s) showing where these management-level positions and committees lie; 7
9cthe processes and frequency by which management is informed about, makes decisions on, and monitors, climate-related risks and opportunities.9, 23-24
Strategy: To enable primary users to understand how climate change is currently impacting an entity and how it may do so in the future. This includes the scenario analysis an entity has
undertaken, the climate-related risks and opportunities an entity has identified, the anticipated impacts and financial impacts of these, and how an entity will position itself as the global
and domestic economy transitions towards a low-emissions, climate-resilient future.
Disclosures11aa description of its current climate-related impacts (see paragraph 12);14-15
11ba description of the scenario analysis it has undertaken (see paragraph 13);16-22
11ca description of the climate-related risks and opportunities it has identified over the short, medium, and long-term (see paragraph 14);23-30
11da description of the anticipated impacts of climate-related risks and opportunities (see paragraph 15); 25-30
11ea description of how it will position itself as the global and domestic economy transitions towards a low-emissions, climate-resilient future state
(see paragraph 16).
31-33
Current impacts
and financial
impacts
12aits current physical and transition impacts;14-15
12bthe current financial impacts of its physical and transition impacts identified in paragraph 12(a); 14-15
12cif the entity is unable to disclose quantitative information for paragraph 12(b), an explanation of why that is the case.N/A
APPENDIX 2: NZ CS CONTENT INDEX
ABOUTINTRODUCTION46thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Subheading Clause Disclosure Page
Scenario
analysis
undertaken
13An entity must describe the scenario analysis it has undertaken to help identify its climate-related risks and opportunities and better understand
the resilience of its business model and strategy. This must include a description of how an entity has analysed, at a minimum, a 1.5 degrees Celsius
climate-related scenario, a 3 degrees Celsius or greater climate-related scenario, and a third climate-related scenario (see paragraph 11(b)).
16-22
Climate-related
risks and
opportunities
14ahow it defines short, medium and long-term and how the definitions are linked to its strategic planning horizons and capital deployment plans;16
14bwhether the climate-related risks and opportunities identified are physical or transition risks or opportunities, including, where relevant, their sector
and geography;
23, 25-30
14chow climate-related risks and opportunities serve as an input to its internal capital deployment and funding decision-making processes.31
Anticipated
impacts and
financial
impacts
15athe anticipated impacts of climate-related risks and opportunities reasonably expected by the entity;25-30
15bthe anticipated financial impacts of climate-related risks and opportunities reasonably expected by an entity;AP2, 23
15ca description of the time horizons over which the anticipated financial impacts of climate-related risks and opportunities could reasonably be
expected to occur;
AP2, 23
15dif an entity is unable to disclose quantitative information for paragraph 15(b), an explanation of why that is the case.AP2, 23
Transition plan
aspects of its
strategy
16aa description of its current business model and strategy;10-13
16bthe transition plan aspects of its strategy, including how its business model and strategy might change to address its climate-related risks and
opportunities;
13, 31-33
16cthe extent to which transition plan aspects of its strategy are aligned with its internal capital deployment and funding decision-making processes.13, 31
Risk Management: To enable primary users to understand how an entity’s climate-related risks are identified, assessed, and managed and how those processes are integrated into
existing risk management processes.
Disclosures18aa description of its processes for identifying, assessing and managing climate-related risks (see paragraph 19);23-24
18ba description of how its processes for identifying, assessing, and managing climate-related risks are integrated into its overall risk management processes;24-30
19athe tools and methods used to identify, and to assess the scope, size, and impact of, its identified climate-related risks;24
19bthe short-term, medium-term, and long-term time horizons considered, including specifying the duration of each of these time horizons;23
19cwhether any parts of the value chain are excluded;23
19dthe frequency of assessment;24
19eits processes for prioritising climate-related risks relative to other types of risks.24
ABOUTINTRODUCTION47thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Subheading Clause Disclosure Page
Metrics and Targets: To enable primary users to understand how an entity measures and manages its climate-related risks and opportunities. Metrics and targets also provide a basis upon
which primary users can compare entities within a sector or industry.
Disclosures21athe metrics that are relevant to all entities regardless of industry and business model (see paragraph 22);34-43, 50-57
21bindustry-based metrics relevant to its industry or business model used to measure and manage climate-related risks and opportunities;34-43, 50-57
21cany other key performance indicators used to measure and manage climate-related risks and opportunities;34-43
21dthe targets used to manage climate-related risks and opportunities, and performance against those targets (see paragraph 23).40
Metric
categories
22agreenhouse gas (GHG) emissions: gross emissions in metric tonnes of carbon dioxide equivalent (CO₂e) classified as (see paragraph 24):
(i) scope 1;
(ii) scope 2 (calculated using the location-based method);
(iii) scope 3;
37
22bGHG emissions intensity;37, 41
22ctransition risks: amount or percentage of assets or business activities vulnerable to transition risks;41
22dphysical risks: amount or percentage of assets or business activities vulnerable to physical risks;42
22eclimate-related opportunities: amount or percentage of assets, or business activities
aligned with climate-related opportunities;
42
22fcapital deployment: amount of capital expenditure, financing, or investment deployed toward climate-related risks and opportunities;43
22ginternal emissions price per metric tonne of CO₂e used internally by an entity;43
22hremuneration: management remuneration linked to climate-related risks and opportunities in the current period, expressed as a percentage,
weighting, description or amount of overall management remuneration (see also paragraph 8(d)).
8, 43
Targets23athe timeframe over which the target applies;40
23bany associated interim targets;40
23cthe base year from which progress is measured;40
23da description of performance against the targets; 40
23efor each GHG emissions target:
(i) whether the target is an absolute target or intensity target;
(ii) the entity’s view as to how the target contributes to limiting global warming to 1.5 degrees Celsius;
(iii) the entity’s basis for the view expressed in 23(e) (ii), including any reliance on the opinion or methods provided by third parties;
(iv) the extent to which the target relies on offsets, whether the offsets are verified or certified, and if so, under which scheme or schemes
40
ABOUTINTRODUCTION48thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Subheading Clause Disclosure Page
GHG emissions24aa statement describing the standard or standards that its GHG emissions have been measured in accordance with;50
24bthe GHG emissions consolidation approach used: equity share, financial control, or operational control;50
24cthe source of emission factors and the global warming potential (GWP) rates used or a reference to the GWP source;51
24da summary of specific exclusions of sources, including facilities, operations or assets with a justification for their exclusion.50, 52-27
Assurance of GHG emissions
25Part 7A of the Financial Markets Conduct Act 2013 requires that the disclosure of an entity’s GHG emissions as required by Aotearoa New Zealand
Climate Standards are the subject of an assurance engagement. This Standard requires that this assurance engagement is a limited assurance
engagement at a minimum.
58-60
26aGHG emissions: gross emissions in metric tonnes of CO₂e classified as (see paragraph 22(a)):
(i) scope 1;
(ii) scope 2 (calculated using the location-based method).
(iii) scope 3;
58-60
26badditional requirements for the disclosure of GHG emissions (see paragraph 24);58-60
26dGHG emissions methods, assumptions and estimation uncertainty (see NZ CS 3 General Requirements for Climate-related Disclosures
paragraphs 52 to 54).
58-60
ABOUTINTRODUCTION49thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
APPENDIX 3: GHG METHODS AND ASSUMPTIONS
In FY25, we have prepared thl’s GHG inventory in accordance with the requirements of the
NZ CS and measured using the Greenhouse Gas Protocol for this purpose.
Operational and reporting boundaries
There have been no significant changes to the organisational and reporting boundaries
from FY24, with thl continuing to report all material and previously disclosed emissions
sources under an operational control consolidation approach, accounting for all material
GHG emissions from operations over which it has control.
However, several locational changes have occurred in FY25, with permanent site closures,
amalgamation of sites and site moves. Emissions are accounted for each operational
location within the reporting year.
Data approach and uncertainty
In FY24, thl prioritised the principle of completeness to capture all material applicable
sources of emissions. In FY25, thl continued to use this as the basis of preparation for the
FY25 inventory and focused on continuous improvements for improving accuracy around
data sources and assumptions.
thl’s FY25 GHG emissions inventory has been prepared prioritising the use of direct
and accurate activity data sources. In some cases, due to the availability, complexity or
cost of obtaining data, assumptions have been applied – typically selecting the highest
reasonable estimate from a credible range. Third-party data (for example, invoices or
vendor reports and those from Planet Price and Sphera) is assumed to be complete and
accurate unless otherwise indicated.
Table A3.1 provides an overview of the calculation methods, assumptions, limitations,
uncertainty and exclusions across different categories and activities within the GHG
inventory. Further detail on methods and assumptions can be made available on request.
While every effort is made to achieve accuracy, GHG emissions reporting inherently
involves uncertainty relating to procedures, measurement, calculations and assumptions
made. This can arise from:
•
scientific uncertainty – limitations in how emissions are measured or understood
•
estimation uncertainty – the need to use assumptions when complete or precise data is
not available.
Where possible, Scope 1 and 2 emissions are calculated with a relatively high degree
of certainty using direct activity data such as supplier invoices, receipts and odometer
readings along with country/state-specific emissions factors. Some uncertainty remains
where assumptions are required (refer to Table A3.1).
Scope 3 emissions involve greater complexity due to the wide range of upstream and
downstream activities. These estimates rely on multiple assumptions related to data
sourcing, coding, calculations and emissions factor application. Categories with higher
levels of uncertainty include:
•
Category 1: Purchased goods and services
•
Category 7: Employee commuting
•
Category 11: Use of sold products
•
Category 12: End-of-life treatment of sold products.
GHG inventory exclusions
GHG emissions sources included in thl’s FY25 GHG inventory were determined
using a systematic approach to identify all relevant GHG emissions sources within
the organisational boundary and category. They were then evaluated based on thl’s
assessment of relevance, materiality, stakeholder expectation, data availability and
quality in conjunction with the level of influence thl has over the emissions source. For an
emissions source to be excluded from the thl GHG emissions inventory, it must meet all
the below criteria:
•
It is immaterial to the category (thl considers any emissions source that is over 5%
respectively of Scope 1, 2 or 3 by category to be of material significance to the GHG
inventory).
•
It is not required to be reported by legislation or thl internal reporting standards.
•
It is not considered to be material to stakeholders or core to thl’s business/products.
•
thl has not reported it before (for consistency, thl reports on historically reported
emissions even if they are no longer material).
•
thl does not have sufficient data available on which to make a reasonable estimate.
•
thl has very limited influence over it (for example, emissions sources that are considered
to be our customers’ or suppliers’ Scope 3 emissions sources).
All emissions sources that meet the exclusion criteria have been reviewed by key internal
stakeholders.
In addition to the specific emissions sources excluded, a small quantity of operational
emissions have been excluded for FY25 relating to thl’s Melbourne Group Support Team.
This team moved into a shared working space in May 2025. The emissions associated with
this temporary office-based activity such as energy for heating/cooling, general office use,
water and waste are considered de minimis to the overall footprint and fall outside thl’s
operational control, given the short duration (less than two months) and shared nature of
the space. The business is assessing a permanent location for these operations. Therefore,
this exclusion is intended to be reviewed in FY26 or at the time when a permanent
location for these operations is found.
ABOUTINTRODUCTION50thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Emissions factors and global warming potential (GWP) conversion rates
For most emissions sources reported in thl’s FY25 GHG emissions inventory, the relevant
emissions factor is selected from supplied libraries in the SpheraCloud: Sustainability &
Safety Management Solutions software (Sphera). These libraries are developed using the
GWP conversion rates and emissions factors for relevant sources:
thl operating
locationSource libraryVersion dateGWP rate
UK and
Ireland
Department for Energy Security and Net
Zero and Department for Business, Energy &
Industrial Strategy, Emissions Factors: 2025
June 2025IPCC AR5
AustraliaDepartment of Climate Change, Energy, the
Environment and Water, National Greenhouse
Accounts Factors: 2024
June 2025IPCC AR5
New ZealandMinistry for the Environment, Emissions
Factors: 2025
June 2025IPCC AR5
USUnited States Environmental Protection
Agency, GHG Emissions Factors Hub: June 2024
June 2024IPCC AR5
CanadaEnvironment and Climate Change Canada,
Emissions Factors and Reference Values: 2024
May 2025IPCC AR6
GlobalInternational Energy Agency, Emissions
Factors: 2024
September 2024IPCC AR5
Country-specific emissions sources are used in the first instance where available,
otherwise UK datasets have been used as a proxy.
Some specific emissions factor datasets are used for specific emissions sources or
calculations:
•
thl-specific emissions factors are derived for customer journey (Scope 3), motorhome
relocations (Scope 1) and use of vehicles sold (Scope 3) based on fleet lists/sales data and
the above emissions factor databases.
•
Watershed Comprehensive Environmental Data Archive database – sourced through
Planet Price licence (global). These are industry-specific, spend-based emissions factors
used in calculating Scope 3 Category 1: Purchased goods and services.
In addition to the potential impact on accuracy based on the approach taken to quantify
the GHG inventory (see page 50), there is an additional potential source of inaccuracy that
arises from using Planet Price and Sphera’s inbuilt emissions factor libraries. thl relies on
the respective library owners to maintain these databases with timely, accurate and up-
to-date emissions factors.
Some of the underlying data sources for these libraries are updated around June each
year. As a result, there may be a lag between the release of updated emissions factors and
their incorporation into the Sphera libraries used by thl. This timing difference may lead to
the use of outdated emissions factors in the GHG inventory.
To mitigate this risk, thl has manually updated the emissions factors used for Scope 1 and
Scope 2 emissions sources to reflect the most current data available. For FY25, this manual
update has been applied to emissions factors relevant to Australia and New Zealand.
Changes from FY24
In FY25, thl made several updates to improve the accuracy and relevance of its GHG
emissions inventory. These changes reflect our commitment to continuous improvement
and better alignment with operational realities across our global business.
General data and process improvements
As thl continues to integrate newer business units into its global GHG inventory, we have
focused on improving data consistency and completeness across regions. This includes
aligning reporting processes, enhancing data quality controls and applying standardised
methodologies to support global comparability. These ongoing efforts contribute towards
a more robust and unified emissions profile across the business and reduce the number of
required assumptions used in calculating the GHG inventory.
Scope 1: Direct emissions
We updated our methodology for calculating transport fuel emissions. For non-RV
vehicles and RV movements not linked to the customer journey (relocations and
operational use), we shifted from a distance-based approach to a volume-based method
using more direct data sources. This change improves accuracy and enhances stakeholder
confidence in the reported data. Australia and New Zealand served as pilot regions,
with plans to extend this approach to other thl regions in FY26.
Scope 3 Category 1: Purchased goods and services
We improved the quality of emissions reporting by enhancing how data related to spend
categories is captured and coded. More granular line item data is now used to calculate
emissions, and updates to our Planet Price analytics platform have enabled us to report
emissions across all 15 Scope 3 categories under the GHG Protocol – previously, data was
applied only to Category 1.
Scope 3 Category 11: Use of sold products
We refined our assumptions to better reflect how RVs are used across different regions.
This included updating estimates for vehicle life expectancy and odometer readings at the
point of sale, using RV-specific data and thl’s operational experience. The new approach
accounts for regional differences in fleet turnover and usage patterns, improving the
accuracy of our Scope 3 estimates. The impact of this change was a decrease in use phase
emissions per vehicle and reduced potential inaccuracies, which could cause double
counting or higher uncertainty.
Note on comparability
As part of our ongoing efforts to improve data quality and relevance, thl continues to
review and update assumptions where more accurate sources are available. The changes
applied in FY25 reflect more regionally sensitive and operationally aligned estimates.
As a result, comparisons with prior years should be made with caution, as the updated
methodology may influence reported emissions figures.
ABOUTINTRODUCTION51thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Table A3.1: Calculation methods, assumptions, limitations, uncertainty and exclusions by emissions activity
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 1: Direct
emissions
•
Transport fuels
associated with
company vehicles
(non-rental) and
leased coaches.
•
Transport fuels
associated with
RV operational
movements (off-site
storage, repairs and
maintenance).
•
Transport fuels
associated with RV
relocations (between
branches, vehicle
swap-overs).
•
Stationary fuels used
for site heating and
cooling, and laundry
and cooking facilities.
•
Stationary fuels (LPG, natural gas etc.): Quantities are
from invoices, supplier reports or meter readings. Some
estimates have been made for months with missing data
(e.g. the invoice was not available at time of inventory
preparation) and proxies have been used to estimate for
small sites with no data (US licensee locations and AU
agency locations).
•
Transport fuels (petrol/diesel): Quantities are from
invoices, receipts, supplier reports or meter readings.
From FY25, volume base approach has also been applied
for Australia and New Zealand relocation and operational
RV movements, with an assumption applied for the
volume of fuel that is related to the customer journey
(Scope 3 Category 13).
•
Other RV relocation and operational movements
(relocations, vehicle storage, external maintenance and
repair): As has been done previously for Canada, US and
UK/Ireland, most operational distances are calculated
using odometer readings or distances determined
from scheduling reports and work orders. Small local
movements not tracked through formal reporting have
been calculated using regional and/or branch-specific
assumptions based on average distances and volume of
regular movements of motorhomes while not on lease.
Where specific odometer reporting is not available,
distances have been calculated using suggested routes
from Google Maps. Operational motorhome movement
distances are not included in the customer journey
emissions (reported under Scope 3 Category 13). We
anticipate that this approach will no longer be used
from FY26 as we shift these regions to the volume-based
approach described above.
•
Stationary fuels (LPG, natural
gas etc.): All activity data is
reliant on supplier invoices and
meter readings being accurate.
The calculation of emissions
where proxy data has been used
(e.g. US licensee locations) may
not reflect actual quantities
used.
•
Transport fuels (petrol/
diesel): All activity data is
reliant on supplier invoices and
odometer readings (northern
hemisphere) being accurate.
The calculation of emissions
from transport fuels relies on
estimates of fuel consumption
rates and emissions factors that
have inherent uncertainties
associated with their calculation.
•
Operational motorhome
movements (relocations,
vehicle storage, external
maintenance and repair):
Where possible, actual trips
and distances travelled are
used. A small portion of the
quantity of movements relies on
operational assumptions. Where
distances are not available,
these have been calculated from
online sources that may not
reflect actual routes/distances
taken. This is not considered to
be a significant difference. The
thl custom emissions factors for
customer journeys have been
used (based on a weighted
average of vehicles owned by
thl, specific to each country).
•
CO₂ in welding gas excluded as is
de minimis and not core to business
activity (less than 5% of combined
Scope 1 and 2 emissions).
•
Refrigerant gas losses from air
conditioning/on-site refrigeration
excluded as is de minimis and
not core to business activity
(less than 5% of combined Scope 1
and 2 emissions).
•
Refrigerant gas losses from non-RV
fleet excluded as is de minimis and
not core to business activity (less
than 5% of combined Scope 1 and
2 emissions).
ABOUTINTRODUCTION52thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 2: Electricity
consumption
(location-based)
•
Purchased electricity
used for general
operations, heating
and cooling, laundry
and cooking facilities.
•
Uses location-based methodology. Quantities are from
invoices, supplier reports or meter readings. Some
estimates have been made for months with missing data
(e.g. the invoice was not available at time of inventory
preparation) and proxies used to estimate for small sites
with no access to data (US licensee locations and AU
agency locations).
•
All activity data is reliant on
supplier invoices and meter
readings being accurate. The
calculation of emissions where
proxy data has been used (e.g.
US licensee locations) may not
reflect actual quantities used.
Scope 3 Category 1:
Purchased goods
and services
•
Tyres and batteries
purchased.
•
Water consumption.
•
All purchased goods
and services not
otherwise captured
within the GHG
emissions inventory.
•
For items that we have historically reported on (water,
batteries and tyres), we have used volumes purchased
from invoices.
•
For all other purchased items, total GHG emissions are
calculated based on spend data (sourced from finance
teams), analysed through the Planet Price software, which
categorises spend by industry. Not all data provided to the
software had complete information, so manual coding by
high-level knowledge of key suppliers (top 80% of spend
or over NZD100K) was applied. As this process matures
through experience and improving the source data, it
is expected the certainty of data mapping will improve.
While efforts have been made to avoid double counting
(emissions captured elsewhere in the inventory), there
may be some instances of double counting given the
volume of data.
•
The GHG inventory for Scope 3 Category 1 timeframe is
offset from thl’s financial year period by one month due to
thl aiming to collect robust and quality data for the final
month of the period ahead of disclosing GHG emissions
with a more comprehensive Scope 3 inventory.
•
AI-based data analytics software
(Planet Price) codes the data
by associated industry. It is
assumed that invoices have
been entered into thl financial
systems accurately. There
is significant uncertainty in
emissions factors used for
purchased goods and services
as these are based on New
Zealand industry sector
averages despite goods being
purchased from different
regions. There may also be
some inaccuracy in the industry
mapping made by the software
and in the assumptions made
due to limited data availability.
Efforts have been made to
improve accuracy through
manual coding for significant
gaps and reviewing the AI
mapping. There may also be
some double counting in this
category for emissions sources
captured elsewhere in the
inventory, although efforts have
been made to avoid this.
•
Products sold/purchased intra-
company (from one businesses unit
to another) are captured elsewhere in
the inventory.
Scope 3 Category 2:
Capital goods
•
Capital goods
purchased.
•
Calculated using the same Planet Price approach
documented in Scope 3 Category 1.
•
Per Scope 3 Category 1.
Scope 3 Category 3:
Fuel- and energy-
related activities
•
Well-to-tank and
transmissions and
distribution losses
associated with Scope
1 and 2 emissions.
•
The volume of fuels and energy consumed as per Scope
1 and 2 based on invoices, receipts supplier reports or
meter readings is used.
•
For distance-based fuel sources, conversion is applied
assuming average fuel efficiency per vehicle type.
•
Some conversions are applied
using average vehicle fuel
efficiency data, which may not
be accurate for specific vehicles.
•
Well-to-tank, and transmission and
distribution losses associated with
the customer journey (Scope 3
Category 13) or other transport fuels
in the upstream or downstream
value chain (Scope 3).
ABOUTINTRODUCTION53thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 3 Category 4:
Upstream
transportation
and distribution
•
Motorhome
relocation (ferries and
transporting drivers).
•
Other upstream
transport, freight
and delivery costs
associated with
receiving or moving
vehicles and other
goods across the
global businesses.
•
Calculated using scheduling information and supplier
invoices based on ferry bookings and other relocation
costs. Some distances travelled are calculated based on
assumed trips using Google Maps.
•
A custom thl emissions factor for ferries has been applied,
assuming the average rental vehicle is equivalent to the
weight of a standard 4-Berth motorhome.
•
Other transport, freight and delivery calculated using
the same Planet Price approach documented in Scope 3
Category 1. Includes instances RVs are transported by ship
or other modes.
•
Uncertainty arises from
calculating distances from
online sources that may not
reflect actual routes/distances
taken. This is not considered to
be a significant difference.
•
A custom thl-specific emissions
factor (based on thl average
motorhome weights and
country-specific emissions
factors) is applied to emissions
associated with motorhomes
transported on ferries. There are
some limitations in accuracy
of this calculation due to these
assumptions.
Scope 3 Category 5:
Waste generated in
operations
•
Waste to landfill or
energy.
•
Plywood to biofuel.
•
Tyres and batteries
recycle.
•
Other waste streams.
•
Calculated using data from suppliers. Where weight
data is not available, conversions have been applied to
estimate the weight per bin (0.2 kg/l) where activity data
is shown by the number of bins collected. Some invoices
show service charge only, so the number of pick-ups is
assumed.
•
Some estimates have been made for locations that do not
have waste data (e.g. municipal waste collection or the
invoice was not available at time of inventory preparation)
and proxies have been used to estimate for small sites
with no data (US licensee locations and AU agency
locations).
•
Tyres and batteries recycled are calculated based on
the number of tyres and batteries purchased. A 1:1 ratio
purchase to recycling is assumed.
•
Other waste streams are calculated using the same
Planet Price approach documented in Scope 3 Category 1.
•
Waste data based on invoices
showing number of bins
collected was converted
using an estimated weight
per volume. There is potential
for inaccuracy based on
this approach.
•
The calculation of emissions
where proxy data has been
used (e.g. US licensee locations)
may not reflect actual
quantities used.
•
Wastewater excluded as is de minimis
and is not core to business activity
(less than 5% of combined Scope 3
emissions).
•
Recycling, compost and other waste
diversion excluded as are de minimis
and not core to business activity
(less than 5% of combined Scope 3
emissions).
Scope 3 Category 6:
Business travel
•
Air travel.
•
Crew personal vehicle
mileage claims.
•
Other business travel
(taxis, rental cars).
•
Number of trips and distances travelled by air is sourced
from supplier reports or booking information. Where
distances are not provided, these are calculated using
online airline mileage between arrival and departure
destinations.
•
Crew personal vehicle mileage is calculated using
distances from expense claims.
•
Other less common modes of business travel are
calculated using the same Planet Price approach
documented in Scope 3 Category 1. This includes taxis and
rental cars.
•
Uncertainty arises from
calculating distances from
online sources that may not
reflect actual routes/distances
taken. This is not considered to
be a significant difference.
ABOUTINTRODUCTION54thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 3 Category 7:
Employee commuting
•
Crew travel in private
vehicles (ICE and
Electric), public
transport, carpooling,
and active modes.
•
Working from Home.
•
Calculations are based on internal survey data and
estimates the average regular commute per transport
mode and average work patterns for crew at each location
(i.e. distance travelled, number of days per week working
in office/branch) and multiplies this by the headcount per
location and workdays each month (adjusted for leave
taken).
•
There may be some uncertainty
in these figures as survey data
relies on accurate responses
from crew and the survey
did not achieve a 100%
response rate.
•
Additionally, the approach
does not fully account for
variation in crew numbers
across the year, the distribution
of leave throughout the year
and changes to normal travel
(mode or distance) that occur
throughout the year.
•
Not applied to agency or licensee sites.
These are operated by non-thl crew.
Scope 3 Category 8:
Upstream leased
assets
All upstream assets are captured under regular business operations (Scope 1 and 2) or through procurement in Scope 3
Category 1. See further detail on data, calculation, assumptions and limitations under Scope 3 Category 1.
•
Lifecycle emissions with thl non-
owned vehicles used and leased
buildings excluded as thl’s use of
these represents only a very small
portion of the asset’s total lifespan. As
a lessor, thl’s focus is on the emissions
generated during the lease/use term,
which can be directly influenced
and managed. The emissions
associated with the manufacturing or
construction phase are spread over
the entire lifetime of the asset and are
not solely attributable to the lease/
use period.
Scope 3 Category 9:
Downstream
transportation
and distribution
•
Downstream transport,
freight and delivery
associated with sold
vehicles and other
goods across the
global businesses.
•
Assumed vehicles sold are driven from the lot in most
cases and therefore associated emissions are captured
under Scope 3 Category 11.
•
Any sold units not driven from the lots or other freight
and delivery are captured through spend data and
calculated using the same Planet Price approach
documented in Scope 3 Category 1.
•
Per Scope 3 Category 1.
Scope 3 Category 10:
Processing of sold
products
Not applicable – thl does not currently sell intermediate products.
ABOUTINTRODUCTION55thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 3 Category 11:
Use of sold products
•
New, trade-in and ex-
rental RVs, including
motorhomes,
campervans, caravans,
truck campers and 4x4
campers.
•
Commercial vehicles,
including ambulances,
delivery vans and other
special-use vehicles.
•
Truck bodies, trailers
and refrigeration units.
•
Products sold through
gift shops, retail stores
and workshops.
•
The quantity of vehicles and products sold is sourced from
sales reports. Assumptions are applied around how the
vehicles and products are used after sale (including rates
of fuel consumption and lifetime mileage, daily use, life
expectancy, and the intended use). Fuel uplift has been
calculated for towable products (caravans and trailers) to
estimate the GHG emissions associated with using these
products sold. These assumptions have been informed by
industry and OEM data in the first instance before using
industry reports and other research sources to estimate
weights, fuel efficiency, fuel type refrigerant type and
quantities.
•
Relies heavily on assumptions-
based approach around how
(and for how long) vehicles
and products sold are used,
maintained and disposed
of. There is uncertainty with
the fuel uplift calculation for
towable products. Any change
to these assumptions could
result in a material change
to the emissions from this
category.
•
These assumptions may
not fully reflect real-world
usage patterns, which could
lead to overestimation or
underestimation of emissions
associated with the use phase
of sold products. To address this,
thl has applied a conservative
approach where assumptions
are used, aiming to reflect
the higher end of the expected
emissions impact associated
with the use of sold products.
•
Some thl-specific emissions
factors (conversions of country-
specific emissions factors) have
been applied to account for
factors specific to vehicles or
products sold by thl. Products
sold in the retail store rely on
accurate mapping to industry-
specific emissions factors by
Planet Price AI software, which
applies assumption-based rules
to spend data and may have
some inaccuracies.
•
Products sold/purchased intra-
company (from one businesses unit
to another) are captured elsewhere in
the inventory.
•
Waste, water and other consumables
associated with use of RVs (sold
or leased) and other vehicle sales
excluded as do not generate direct
emissions associated with thl’s
products/core business activity.
There are no Scope 1 or 2 emissions
associated with this during the direct
use of thl’s sold products. Customers’
lifestyle and purchasing habits are
not controlled by and are unlikely
to be influenced by thl or thl’s sold
products. These are not considered to
be a material source of emissions for
thl’s sold products.
•
Refrigerant gas losses from air
conditioning/ refrigeration in sold
RVs and commercial vehicles
(not including refrigerated truck
units) excluded as are de minimis
and not core to business activity.
Refrigerant losses are a result of a
damaged system (managed through
maintenance and servicing) and are
not emitted while in use.
•
Ongoing maintenance and vehicle
consumables associated with sold
products and vehicles excluded as
is likely de minimis and not core
to business activity. There are no
Scope 1 or 2 emissions associated
with this during the direct use of
thl’s sold products. Customers’
maintenance and servicing habits
are not controlled by and are unlikely
to be influenced by thl or thl’s sold
products. These are not considered to
be a material source of emissions for
thl’s sold products.
ABOUTINTRODUCTION56thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
CategoryIncluded sourcesMethod and assumptionsLimitations and uncertaintyExclusions
Scope 3 Category 12:
End-of-life treatment
of sold products
•
Refrigerant top-ups.
•
Refrigerants in sold
vehicles, refrigeration
units and living
equipment.
•
Disposal of products
sold through gift
shops, retail stores
and workshops.
•
The quantity of vehicles and products sold is sourced from
sales reports. Assumptions are applied around how the
vehicles and products are disposed of at the end of life.
•
Vehicle parts are assumed to be recycled or inert in
landfill.
•
Refrigerant types and quantities are assumed based on
OEM data or on best-practice guidance documentation
from government agencies.
•
Refrigerant top-ups assumes that all refrigerants will be
lost (likely an overly conservative approach).
•
Relies heavily on assumptions-
based approach around how
vehicles and products sold are
disposed of (and the materials/
associated emission types),
which may not be accurate in
all thl regions.
•
Vehicle parts excluded as assumed to
be recycled or inert in landfill.
•
Products sold/purchased intra-
company (from one businesses unit
to another) are captured elsewhere
in the inventory.
Scope 3 Category 13:
Downstream
leased assets
•
Customer journey,
including transport
fuels, and energy
consumed (electricity
and LPG).
•
Refrigerant losses
from dash and house
air conditioning units
and refrigerators.
•
Calculated using thl RV fleet and customer bookings data
to determine distances travelled and number of hire days.
•
The distance travelled does not include any relocations or
operational movements by thl crew and contractors.
•
An estimated per-hire-day quantity of LPG and electricity
consumed as part of the rental experience is calculated
based on a real-life test of a thl 4-Berth motorhome. It is
assumed that all motorhomes consume a similar daily
quantity.
•
A custom thl emissions factor has been applied based
on average fleet type and fuel efficiency of the vehicles.
Where data has not been available, assumptions have
been made around fuel types and fuel efficiency.
•
Refrigerant types and quantities and loss rates are
assumed based on OEM data or on best-practice
guidance documentation from government agencies.
•
Emissions factors for customer
journeys are based on a
weighted average of vehicles
owned by thl, specific to each
country. Distance-based
calculation approaches
inherently do not account
for individual driving habits,
which impacts the quantity of
associated emissions.
•
For consumables associated
with customer journeys (use
of LPG and electricity), an
assumptions-based approach
has been used that may not
reflect actual quantities used.
•
Operational motorhome
movements have been
subtracted from customer
journeys. The methods
associated with these
calculations have some
uncertainties as described
above under Scope 1.
•
Waste, water and other consumables
associated with use of RVs (sold
or leased) and other vehicle sales
excluded as do not generate direct
emissions associated with thl’s
products/core business activity.
There are no Scope 1 or 2 emissions
associated with this during the direct
use of thl’s sold products. Customers’
lifestyle and purchasing habits are
not controlled by and are unlikely
to be influenced by thl or thl’s sold
products. These are not considered to
be a material source of emissions for
thl’s sold products.
Scope 3 Category 14:
Franchises
The franchisees use thl branding but are not otherwise operationally part of the thl Group. They fall outside of thl’s operational control consolidation approach. The
operations are small scale and expected to be de minimis.
Scope 3 Category 15:
Investments
Most investments are business units operated by thl and are included elsewhere in the inventory. In FY25, there is one investment (Caravansaway) not captured
fully – thl owns a 25% share and does not have operational control (placing it outside of the reporting boundary under the operational consolidation approach).
Caravansaway operates in a shared location with Brisbane RV (therefore Caravansaway’s Scope 1 and 2 emissions are reported in this inventory, but Scope 3 emissions
are not).
ABOUTINTRODUCTION57thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
INDEPENDENT ASSURANCE REPORT TO TOURISM HOLDINGS LIMITED
Limited assurance conclusion - Scope 3 GHG emissions
Based on our limited assurance procedures performed and the evidence we have
obtained, nothing has come to our attention that causes us to believe that thl’s
consolidated gross Scope 3 Greenhouse Gas (“GHG”) emissions, related additional required
disclosures of gross GHG emissions and gross GHG emissions methods, assumptions
and estimation uncertainty, within the scope of our limited assurance engagement (as
outlined below) included in thl’s Climate Statement for the year ended 30 June 2025
(“Climate Statement”) are not fairly presented and not prepared, in all material respects,
in accordance with the Aotearoa New Zealand Climate Standards (“NZ CS”) issued by the
External Reporting Board (XRB).
Reasonable assurance opinion - Scope 1 and Scope 2 (location based only) GHG
emissions
In our opinion, thl’s consolidated gross Scope 1 and 2 (location based only) GHG emissions,
related additional required disclosures of gross GHG emissions and gross GHG emissions
methods, assumptions and estimation uncertainty, within the scope of our reasonable
assurance engagement (as outlined below) included in thl’s Climate Statement for the
year ended 30 June 2025, are fairly presented and prepared, in all material respects,
in accordance with Aotearoa New Zealand Climate Standards (“NZ CS”) issued by the
External Reporting Board (XRB).
Scope
Ernst & Young Limited (“EY”) has undertaken an assurance engagement, to issue a:
Limited assurance report on Tourism Holdings Limited’s (the “Company” or “thl”):
•
Consolidated gross Scope 3 GHG emissions on page 37;
•
Related additional requirements for the disclosure of consolidated GHG emissions on
pages 50 to 51;
•
Related GHG emissions methods, assumptions and estimation uncertainty on pages 53
to 57;
Reasonable assurance report on thl’s:
•
Consolidated gross Scope 1 and Scope 2 (location-based) GHG emissions on page 37;
•
Related additional requirements for the disclosure of consolidated GHG emissions on
pages 50 to 51;
•
Related GHG emissions methods, assumptions and estimation uncertainty on pages 52
to 53;
included in the Climate Statement for the year ended 30 June 2025 (the “Subject Matter”
or “GHG Disclosures”). The reported amounts and disclosures relate to the Company and
its subsidiaries as explained in the Climate Statement.
Our assurance engagement does not extend to any other information included, or
referred to, in the Climate Statement on pages 5 to 36 or pages 38 to 45.
We have not performed any assurance procedures with respect to the excluded
information and, therefore, no conclusion is expressed on it.
Criteria applied by thl
In preparing the GHG Disclosures, thl applied NZ CS (the “Criteria”). In applying the
Criteria the methods and assumptions used are described on pages 50 to 57 of the
GHG Disclosures, as are the estimation uncertainties inherent in the methods and
assumptions used.
Key matters
In this section we present those matters that, in our professional judgement, were most
significant in undertaking the assurance engagement over the GHG Disclosures. These
matters were addressed in the context of our assurance engagement, and in forming our
opinion and conclusion. We did not reach a separate assurance opinion or conclusion on
each individual key matter.
ABOUTINTRODUCTION58thl CLIMATE-RELATED DISCLOSURES 2025GOVERNANCESTRATEGYMETRICS AND TARGETSAPPENDIX
Key matter: estimation of vehicle fuel consumption
Why significantProcedures to address key matter
As explained on page 52, vehicle fuel consumption was estimated by thl in the
estimation of mobile GHG emissions from a number of material emissions sources. The
fuel consumption estimate contained two main components being fuel efficiency and
vehicle distance travelled or expected to be travelled. Where these inputs had to be
estimated there was significant judgment required in assessing the estimated amounts.
In estimating the fuel efficiency component, thl used in-house and industry research
to develop a range of vehicle weight, fuel type and fuel efficiency values by vehicle
type and country of location, taking into account the fact that thl’s vehicles have been
modified for tourism use and so are likely heavier than unmodified equivalents. These
assumptions and the associated uncertainties are disclosed on pages 52 and 56.
In estimating the distance travelled, where actual distance data was not available, thl
used the following approaches:
•
For US and Canada Scope 1 Operational Activities – GIS mapping tools and resulting
management estimates
•
For Scope 3 Use of Products Sold – expected vehicle lifetime mileage less mileage at
the date of sale.
In evaluating thl’s estimation method for calculating fuel consumption, we:
•
Gained an understanding of the calculation method, assumptions and estimation
uncertainties:
•
Assessed alignment of the method used against the measurement approaches in the
GHG Protocol;
•
Evaluated whether the fleet characteristics thl used for the basis of fuel consumption
estimates were consistent with the fleet used in the reporting period.
•
Assessed the reasonableness of the fuel efficiency estimates used by thl against
external evidence for similar vehicles and taking into account the nature of thl’s vehicles.
•
Considered the reasonableness of management’s distance assumptions and whether
odometer distance records used in the estimation were appropriate
•
Assessed the application of the estimation method, including limited sample checks
of the calculation of fuel consumption and considering the use of relevant inputs.
•
Considered the appropriateness of disclosures related to the methods, assumptions
and estimation uncertainties included on pages 52 to 56.
thl’s responsibility
The Directors are responsible, on behalf of the Company for the preparation and fair
presentation of the GHG Disclosures in accordance with NZ CS. This responsibility includes
establishing and maintaining internal controls, maintaining adequate records and making
estimates that are relevant to the preparation of the GHG Disclosures, such that they are
free from material misstatement, whether due to fraud or error.
EY’s responsibility
Our responsibility is to express an assurance conclusion on the GHG Disclosures based on
the procedures we have performed and the evidence we have obtained.
Our engagement was conducted in accordance with New Zealand Standard on
Assurance Engagements 1 Assurance Engagements over Greenhouse Gas Emissions
Disclosures (“NZ SAE 1”) and in accordance with the International Standard for Assurance
Engagements (New Zealand): Assurance Engagements on Greenhouse Gas Statements
(“ISAE (NZ) 3410”). Those standards require that we plan and perform this engagement
to obtain limited or reasonable assurance about whether the GHG disclosures have been
prepared, in all material respects, in accordance with the Criteria. The nature, timing and
extent of the procedures selected depend on our judgment, including an assessment of
the risk of material misstatement, whether due to fraud or error.
We believe that the evidence obtained is sufficient and appropriate to provide a basis for
our assurance conclusions.
As we are engaged to form an independent conclusion on the GHG Disclosures prepared
by management, we are not permitted to be involved in the preparation of the GHG
information as doing so may compromise our independence.
Ernst & Young provides audit and other assurance-related services to thl. Partners and
employees of our firm may deal with thl on normal terms
within the ordinary course of trading activities of the business of thl. We have no other
relationship with, or interest in, thl.
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Our independence and quality management
We have complied with the independence and other ethical requirements of NZ SAE 1
Assurance Engagements over Greenhouse Gas Emissions Disclosures issued by the
External Reporting Board (XRB) and the Professional and Ethical Standard 1 International
Code of Ethics for Assurance Practitioners (including International Independence
Standards) (New Zealand) issued by the New Zealand Auditing and Assurance Standards
Board, which are 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, which requires the firm to design, implement and
operate a system of quality management including policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and
regulatory requirements.
Description of procedures performed
We have performed an engagement including both limited and reasonable assurance.
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 obtained in a reasonable assurance engagement. Our limited
assurance procedures were designed to obtain a lower level of assurance on which to base
our conclusion and do not provide all the evidence that would be required to provide a
reasonable level of assurance. Our limited assurance procedures did not include testing
controls or performing procedures relating to checking aggregation or calculation of data
within IT systems.
A limited assurance engagement consists of making enquiries, primarily of persons
responsible for preparing the report and related information and applying analytical and
other relevant procedures. Our limited assurance procedures included:
•
Obtaining, through inquiries, an understanding of thl’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;
•
Evaluating whether thl’s methods for developing estimates are appropriate and had
been consistently applied. Our procedures did not include testing the data on which
the estimates are based or separately developing our own estimates against which to
evaluate thl’s estimates;
•
Testing a limited number of items to, or from, supporting records, as appropriate;
•
Performing analytical procedures on particular emission categories by comparing the
expected GHGs emitted to actual GHGs emitted and made inquiries of management to
obtain explanations for any significant differences we identified; and
•
Considering the presentation and disclosure of the GHG disclosures.
A reasonable assurance engagement involves performing procedures to obtain a higher
level of evidence about the quantification of emissions and related information in the GHG
disclosures. A reasonable assurance engagement also includes:
•
Considering internal controls relevant to thl’s preparation of the GHG disclosures.
•
Assessing the suitability in the circumstances of thl’s use of the Criteria;
•
Evaluating the appropriateness of quantification methods and reporting policies used,
and the reasonableness of estimates made by thl’s and
•
Evaluating the overall presentation of the GHG Disclosures.
We also performed such other procedures as we considered necessary in the
circumstances.
Although we considered the effectiveness of management’s internal controls when
determining the nature and extent of our assurance procedures, our assurance
engagement was not designed to provide assurance on internal controls.
Inherent uncertainties
The GHG quantification process is subject to scientific uncertainty, which arises because
of incomplete scientific knowledge about the measurement of GHGs. Additionally, GHG
procedures are subject to estimation uncertainty resulting from the measurement and
calculation processes used to quantify emissions within the bounds of existing scientific
knowledge.
Use of our assurance report
We disclaim any assumption of responsibility for any reliance on this assurance report to
any persons other than thl, or for any purpose other than that for which it was prepared.
The engagement partner on the engagement resulting in this independent assurance
conclusion is Pip Best.
Ernst & Young Limited Auckland
08 October 2025
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