Steel & Tube Climate Statement - FY25
STEEL & TUBE HOLDINGS LIMITED
2025
C L I M AT E
R E L AT E D
DISCLOSURES
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Steel & Tube Climate-related Disclosures
Introduction
Steel & Tube is pleased to present its second climate-related disclosures, prepared in accordance with the External
Reporting Board’s (XRB) Aotearoa New Zealand Climate Standards (NZCS).
At Steel & Tube, our commitment to sustainability is embedded in everything we do. Climate change presents both
challenges and opportunities, and we are actively responding by aligning our operations with New Zealand’s 2050 net-
zero emissions target. Our FY25 climate-related disclosures reflects a focused approach to identifying opportunities to
reduce emissions across our value chain and a meaningful review of our material climate-related risks and opportunities.
We recognise the critical role of steel in the transition to a low-emissions and circular economy. Through strategic
procurement, we are supporting the shift to low-emission steelmaking, including sourcing from suppliers investing in
renewable energy and electric arc furnace technologies. The commissioning of New Zealand Steel’s Electric Arc Furnace
(EAF) marks a significant milestone in this journey, enabling access to locally produced, low-carbon steel. Our scope 3
emissions reporting is still in development, but we look forward to sharing our progress in this space in the future.
Circularity remains central to our sustainability strategy. Steel’s durability and recyclability make it a cornerstone of
sustainable construction, and our acquisition of Perry Metal Protection (a market leading galvanising business) has further
strengthened our ability to deliver long lasting solutions that can extend the life of steel by up to seven times - supporting
more sustainable outcomes across the built environment.
We continue to collaborate across the sector, contributing to initiatives like the Sustainable Steel Council’s Roadmap
to Net Carbon Zero, and embracing innovation and partnership as we work toward a more sustainable future for New
Zealand. In FY25, we began an exploratory journey into transition planning, the output of which will inform our response
to our material risks and opportunities over the short, medium, and long-term.
These climate-related disclosures have been approved by the board and are signed on behalf of Steel & Tube Holdings
Limited by Susan Paterson, board Chair and Karen Jordan, chair of the Audit & Risk Committee.
Susan Paterson
Chair
Karen Jordan
Audit & Risk Committee Chair
30 October 2025
1DUNEDIN
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PALMERSTON NORTH
1NEW PLYMOUTH
2INVERCARGILL
1NELSON
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WELLINGTON
9AUCKLAND
HAWKES BAY
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TAURANGA
HAMILTON
3CHRISTCHURCH
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WHANGAREI
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Steel & Tube Climate-related Disclosures
Statement of Compliance
Steel & Tube is a climate-reporting entity under the Financial
Markets Conduct Act 2013. These climate-related disclosures
comply with the NZCS standards 1, 2 and 3 issued by the XRB
and cover the financial year 1 July 2024 to 30 June 2025. All
figures and commentary relate to the full year ended 30 June
2025, unless otherwise indicated.
The information outlined in climate-related disclosures
should not be considered a prediction of future financial or
non-financial performance. These statements are subject
to a range of known and unknown risks, uncertainties, and
assumptions, many of which lie outside of our control. Due
to uncertain technological changes, economic factors and
environmental changes, our strategies are subject to change.
Steel & Tube cautions reliance on forward-looking statements
that are necessarily less reliable than other statements. Steel
& Tube gives no representation, warranty, or assurance that
actual outcomes or performance will be consistent with
statements made in this report. We do not accept any liability
whatsoever for any loss arising directly or indirectly from any
use of the information contained in this report. Nothing in
this report constitutes financial, legal, tax or strategic growth
guidance or advice.
Steel & Tube has chosen to use the following Adoption
Provisions available to second-year Climate Reporting Entities:
+
Adoption provision 2: Anticipated financial impacts
Provides an exemption for an entity from disclosing the
anticipated financial impacts of climate-related risks and
opportunities it reasonably expects.
+
Adoption provision 4: Scope 3 GHG emissions
Exempts an entity from disclosing in its first and second
reporting period greenhouse gas (“GHG”) emissions in
metric tonnes of carbon dioxide equivalent classified as
Scope 3.
+
Adoption provision 5: Comparatives for Scope 3 GHG
emissions
Comparatives for Scope 3 GHG emissions - Allows an
entity to not disclose comparatives for the previous two
reporting periods.
+
Adoption Provision 8: Scope 3 GHG emissions assurance
Provides an exemption for entities from the requirement
to include Scope 3 GHG emissions in the scope of their
assurance engagement in relation to accounting periods
ending on or after 31 December 2025.
4
Steel & Tube Climate-related Disclosures
Governance
Board Oversight
Steel & Tube’s Board of Directors maintains overall
responsibility for the company’s strategy, which includes
addressing climate-related risks and opportunities. The board
is supported in this role by the Audit & Risk Committee.
Steel & Tube’s directors are responsible for their ongoing
education and staying informed about climate-related issues.
The board draws on internal climate-related expertise and
engages external specialists when required to ensure effective
oversight.
The Group Sustainability Manager chairs the climate risk
steering group and provides regular sustainability updates and
recommendations to the board, with reporting occurring at
least six times per year. The steering group, comprising senior
leaders, conducts an annual review of climate-related risks
and opportunities. Recommendations from this review inform
board decision-making and support the company’s strategic
direction toward sustainable practices.
Since 2022, Steel & Tube has measured performance against
internal Environmental, Social and Governance (ESG) metrics
and targets, following its first materiality assessment. These
metrics, approved by the board, include indicators such as
greenhouse gas emissions. The board reviews performance
quarterly. As of FY25, climate-related performance metrics
are not incorporated into remuneration policies.
Management’s Role
The board delegates climate-related responsibilities to various
management-level positions and oversight groups. The Chief
Executive Officer (CEO) leads the management and delivery
of the company’s strategy, and delegates management of
sustainability and climate-related matters to the Chief Financial
Officer (CFO) and Group Sustainability Manager. Steel &
Tube’s Group Sustainability Manager reports to the CFO and
works across the group to ensure the implementation of
decarbonisation projects and other strategic sustainability
initiatives.
Steel & Tube undertook a comprehensive climate risk
assessment across 2023 and 2024. In FY25, the climate risk
steering group participated in an internal risk and opportunity
review workshop, facilitated by the Group Sustainability
Manager. This workshop involved a systematic review of the
company’s top 10 material transition risks and opportunities
to evaluate risk ratings and business responses. The outcomes
were reviewed by the CEO and the Audit & Risk Committee
and subsequently approved by the board. The resulting risk
and opportunity tables, presented in the following pages,
also informed the FY25 transition planning workshop.
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Steel & Tube Climate-related Disclosures
Governance structure for climate-related responsibilities
Board Oversight
Steel & Tube’s board of directors
(meets 9 times annually)
• Approves Steel & Tube’s overall strategy, including
oversight of ESG and sustainability
• Ensures board skills, size and composition are fit for
purpose
• Reviews and supports management processes in
relation to risks and opportunities of the business
including climate risk
• Supports the development and implementation of
internal ESG related metrics and targets to enable the
board to effectively review and monitor the progress of
the company over time
• Delegates oversight of climate risks, opportunities and
reporting to the Audit & Risk Committee but retains
overall responsibility for climate strategy
Main Climate Reporting Committee
Audit & Risk Committee
(meets 3 times annually)
• Assists the board in discharging its oversight duties
• Ensures risks are managed in accordance with Steel &
Tube’s enterprise risk management framework which
includes key climate risks and opportunities being
brought to the committee and reviewed annually
• Oversees Steel & Tube’s reporting requirements
including climate-related disclosures
• Makes recommendations to the board on climate
related risks and opportunities after reviewing
recommendations by the Climate Risk Steering Group
Management
Leadership Team
• The CEO is responsible for leading, managing and
delivering on Steel & Tube’s strategy, including
its sustainability strategy, and is supported by the
Leadership Team
• The CEO and CFO attend all board and Audit & Risk
Committee meetings
• CEO & CFO meet monthly with the Group Sustainability
Manager to discuss progress on sustainability initiatives
and GHG emissions performance
Group Sustainability Manager
• Reports to the CFO, responsible for development
of Steel & Tube’s GHG inventory, leading group
sustainability and decarbonisation initiatives and
preparing climate-related disclosures
• Chairs the Climate Risk Steering Group and facilitates
annual review of key climate-related risks and
opportunities
Climate Risk Steering Group
• Chaired by the Group Sustainability Manager, consists
of the CFO and relevant General Managers
• Meets 2-3 times a year, reviews material climate-related
risks and opportunities, participates in transition
planning
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Steel & Tube Climate-related Disclosures
Strategy
Business model and strategy
Steel & Tube offers one of New Zealand’s most comprehensive
ranges of steel products, services and solutions, and we are
continuing to grow, by adding high-value offerings for our
customers.
With 35 sites located across New Zealand, Steel & Tube
group activities involve processing and distributing a wide
range of steel and metal products, including fastenings,
fire reticulation, chain & rigging, stainless steel, aluminium,
engineering steel, and processed plates and sheets. We also
offer custom steel solutions for projects such as roofing,
ComFlor decking, and reinforcing. This year, we have added
market leading galvanizing services to our offer.
Our dual pathway strategy focuses on two areas:
• Core strength
• Growth of High Value Products and Services
Risk Management
Identifying, assessing, and managing climate-related risks
The purpose of our risk management process is to identify,
analyse and prioritise uncertainty to improve the quality of
decisions we make.
A description of our climate risk assessment process is
contained on the following pages. Steel & Tube’s first
comprehensive climate risk assessment was conducted with
the assistance of Deloitte in 2023. Our intention is to conduct
an in-depth risk assessment approximately every three years,
with reviews of material risks and opportunities occurring
annually. All parts of our value chain were included in our risk
assessment. Details of our risk methodologies and frameworks
are included in the appendices.
Steel & Tube’s risk management policy is available in the
governance section of our website. It details Steel & Tube’s
approach to understanding and managing risk within the
business. Our climate risk assessment was conducted in
alignment with our risk management policy. A climate risk and
opportunity register was developed and is reviewed annually.
7
Steel & Tube Climate-related Disclosures
Approach to Scenario Analysis
As described in our year one climate-related disclosures,
Steel & Tube engaged Deloitte over 2023 and 2024 to assist
with conducting a climate risk assessment and a scenario
analysis workshop to help build our climate scenario
narratives.
The core purpose of the scenario analysis was to consider
“how climate change could plausibly affect our business model
and strategy, what should we do and when”. This information
was then used by the group to identify our driving forces,
using the STEEP analysis (social, technological, economic,
environmental, and political categories) as provided by the
XRB Staff Guidance on Entity Scenario Development.
The output of our climate risk assessment and scenario
narrative workshops provides insight into plausible futures risk
profiles, in terms of Steel & Tube’s exposure and vulnerability
to the effects of climate change, and how these evolve over
time and under different global warming scenarios.
Our scenario architecture references several scenarios to
assess how Steel & Tube may be impacted by both physical
and transition risks and opportunities, across its strategic time
horizons.
For the purposes for assessing our physical risk due to climate
hazards, we adopted the shared socioeconomic scenarios
(SSP) provided by the Intergovernmental Panel on Climate
Change Sixth Assessment Report (IPCC AR6). For assessing
transition risks, we have used the scenarios provided by the
Network for Greening the Financial system, which include
the Orderly, Disorderly and Hot House World. An overview of
our climate scenario architecture and narratives is detailed on
pages 8-10.
Time horizons
The time horizons relating to our climate scenarios were
determined on the basis of Steel & Tube’s asset and product
design life, its asset management regime, and its longer-term
business strategy. The warming scenarios and time horizons
adopted by Steel & Tube provide a means of stress testing the
exposure and vulnerability of Steel & Tube’s assets, operations,
and people to the effects of climate change over time and
under different scenarios. The timeframes identified below,
over which we estimate that risks or opportunities could
eventuate, are not currently linked to our strategic planning
timelines or capital deployment plans. However, climate-
related risks and opportunities identified in the following
sections are considered in the decision-making process for
significant capital expenditure and potential acquisitions.
Specific time horizons relating to anticipated impacts of
climate-related risks and opportunities are outlined for
identified transition risks and opportunities on page 11 and
physical risks and opportunities on page 15.
Risk and Scenario Time HorizonsSteel & Tube’s Climate Scenarios
Short-termPresent day to 2030Orderly – Net Zero by 2050 (1.4°C)
Medium-term2030 to 2050Disorderly – Delayed Transition (1.6°C)
Long-term2050 to 2100Hothouse – Current Policies (3°C+)
Scenario Analysis
8
Steel & Tube Climate-related Disclosures
Orderly scenario narrative
In response to increasing global pressure to combat
climate change, the global community attempts to meet
its obligations under the Paris Agreement by implementing
stringent policies mandating the use of sustainable materials
in construction. These policies prioritise materials with lower
carbon footprints, pushing the construction industry to
adopt greener alternatives. Steel & Tube must navigate these
regulations while maintaining competitiveness.
Public awareness and concern about climate change has
surged, influencing customer preferences. Consumers and
businesses alike are demanding more sustainable products,
with rapid investigation and research conducted for alternative
materials and low emission methods for producing steel. Steel,
traditionally seen as a high-carbon material, faces scrutiny
not only from the construction market, but also from the
new potential workforce who factor in environmental impact
in their choice of employment. Although the higher carbon
content of steel has a negative perception, there is also
growing recognition of the durability and circularity of steel,
presenting an opportunity for Steel & Tube to r
eposition its products.
The economic landscape is shaped by fluctuating access to
finance, driven by banks and insurance companies prioritising
sustainable investments. Financial entities restrict access to
funding unless high-emitting companies have a verifiable
transition plan. Companies with strong environmental
credentials find it easier to secure funding. Additionally,
technological advancements in alternative materials like
wood and synthetics are increasing, posing both a threat
and an opportunity for Steel & Tube.
Orderly Scenario
IPCC SSP/RCP scenarioSSP 1 - RCP 2.6
NFGS ScenariosOrderly – Net Zero by 2050
Global Warming limited to 1.5°C by the end of 2100
Policy Ambition1.4°C
Policy ReactionImmediate and smooth
Technology ChangeFast change
CDR (carbon dioxide removal) Medium-high use
Regional Policy VariationMedium variation
Shor t-term
(Present day – 2030)
Early implementation of climate change regulation and policies. Clear market signals
encourage steel makers to drive enhanced resilience through strategic products,
competitive pricing, and strict screening.
Physical Risks: Low
Transition Risks: High
Medium-term
(2030 – 2050)
Ambitious decarbonisation goals and policies are introduced immediately, and emissions
decline rapidly and steadily to achieve net zero by 2050.
Physical Risks: Low
Transition Risks: Medium
Long-term
(2050 -2100)
Net zero achieved. Relatively low weather impacts.
Physical Risks: Low
Transition Risks: Low
9
Steel & Tube Climate-related Disclosures
Disorderly scenario narrative
The political landscape is chaotic, with inconsistent and
rapidly changing policies. Governments are struggling
to balance economic growth with climate commitments,
leading to unpredictable regulations. Steel & Tube faces a
volatile environment where sudden policy shifts can disrupt
operations and strategic planning.
Public opinion is fragmented. While a significant portion
of the population demands immediate and drastic action
on climate change, others are resistant due to economic
concerns. This division creates a challenging market where
customer preferences are highly variable and difficult to
predict. Steel is often criticised for its embodied carbon,
but its strength, durability and recyclability still hold
appeal for certain segments. Increased weather events
demonstrate the durability and reliability of steel products,
but a disruptive supply chain causes issues for procurement.
The economic environment is unstable, characterised
by fluctuating access to finance and insurance. Banks
and insurance companies are increasingly wary of high-
carbon industries, leading to sporadic and unpredictable
financing conditions and excessive delays due to fluctuating
lending criteria. Technological advancements in alternative
materials are progressing unevenly, creating both
opportunities and threats for Steel & Tube.
Disorderly Scenario
IPCC SSP/RCP scenarioSSP 2 – RCP 4.5
NFGS ScenariosDisorderly – Delayed Transition
Global warming limited to 2°C by the end of 2100
Policy Ambition1.6°C
Policy ReactionDelayed
Technology ChangeSlow/fast change
CDR (carbon dioxide removal) Low-medium use
Regional Policy VariationHigh variation
Shor t-term
(Present day – 2030)
Delayed implementation of policies and mixed market signals make it difficult for
steel makers to meet demands and needs. Increased exposure to reputation damage
Physical Risks: Low
Transition Risks: Low
Medium-term
(2030 – 2050)
Significant decarbonisation is delayed until the mid-2030s. There is a high transition
risk as New Zealand rushes to meet net zero by 2050 goals and moderate physical risk
exposure due to delayed action.
Physical Risks: Medium
Transition Risks: High
Long-term
(2050 -2100)
Extended period of policies due to delayed/disorderly transition.
Higher impacts felt
Physical Risks: Medium
Transition Risks: Low
10
Steel & Tube Climate-related Disclosures
Hothouse scenario narrative
In this scenario, global efforts to mitigate climate change
have largely failed, leading to severe and frequent climate
impacts. Governments are overwhelmed by the immediate
need to address climate disasters, resulting in reactive
and fragmented policies. Steel & Tube must navigate a
landscape where regulations are inconsistent and often
focused on short-term crisis management rather than
long-term sustainability.
Society is experiencing significant stress due to the impacts
of climate change. Public opinion is polarised; while some
demand urgent action, others are more concerned with
economic survival. Customer preferences are shifting
rapidly, with a growing demand for materials that can
withstand extreme weather conditions. Steel, known for
its strength and durability, is increasingly valued, but its
environmental impact remains a concern. The economic
environment is highly unstable, characterised by frequent
disruptions due to climate-related events.
Access to finance is erratic, with banks and insurance
companies becoming increasingly risk-averse.
Technological advancements in alternative materials are
slow and uneven, as resources are diverted to immediate
climate response efforts. Steel & Tube faces a challenging
market where adaptability and resilience are key.
Hothouse Scenario
IPCC SSP/RCP scenarioSSP 2 – RCP 4.5
NFGS ScenariosHothouse – Current Policies
Global warming reaches 3°C of warming by the end of 2100
Policy Ambition3 °C+
Policy ReactionNone – current policies
Technology ChangeSlow change
CDR (carbon dioxide removal) Low use
Regional Policy VariationLow variation
Shor t-term
(Present day – 2030)
Current policies – limited ambition. Limited to no investment in infrastructure
resilience and extreme exposure to climate impacts results in credit and liquidity risk.
Physical Risks: Low
Transition Risks: Low
Medium-term
(2030 – 2050)
No additional policies are introduced to curb emissions, and emissions continue to
rise. Warming reaching >3°C. There are limited transition risks but extreme physical
climate risks.
Physical Risks: High
Transition Risks: Low
Long-term
(2050 -2100)
Extended period of policies due to delayed/disorderly transition.
Higher impacts felt.
Physical Risks: High
Transition Risks: Low
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Steel & Tube Climate-related Disclosures
Risks, opportunities and impacts
Current climate-related impacts
Management assessed that no material climate-related
impacts occurred within FY25 in relation to any of the
disclosed transition or physical risks in the tables on pages
12, 13 and 15. Steel & Tube will continue assess climate-
related impacts as they arise and will disclose if material.
Transition planning
Over FY25, Steel & Tube has leveraged its understanding
of material climate-related risks and opportunities to
define what success looks like under various climate
scenarios and to identify potential pathways to achieve
our envisioned future.
The central question guiding the Climate Risk Steering
Group throughout transition planning was: “How might
we deliver on our purpose in a way that is low emissions,
climate resilient, and financially sustainable?”
With this question in mind—and informed by our identified
risks and opportunities—we used tools and guidance from
the XRB to explore strategic options across our value chain.
This process included identifying ‘least regret’ options,
clarifying key uncertainties and triggers, and mapping
potential actions over time. A summary of the outcomes
from this transition planning process, including the
strategic options under consideration, is presented in
the ‘Table of Transition Risks, Impacts, and Opportunities’
on page 12.
Transition risks and opportunities
identification
Transition risks and opportunities were identified and
rated using the Taskforce for Climate-related Financial
Disclosure’s (TCFD) recommended methodology, applying
the TCFD’s four risk categories of Market, Reputation,
Policy and Legal and Technology to identify the risks arising
as global and local economies decouple from fossil fuels,
and TCFD’s five categories for identifying the opportunities
that present for Steel & Tube, relating to a decarbonising
economy, including resource efficiency and cost savings,
the adoption and utilisation of low emission energy sources,
the development of new products and operations,
and building supply chain resilience.
Transition risk and opportunity rating
methodology
The identified transition risks were rated using a modified
urgency criteria derived from the National Climate Change
Risk Assessment (NCCRA) and the UK Committee on
Climate Change’s rating methodologies. The urgency
criteria were modified by introducing a temporal element
to further define the level of urgency and to provide
context for transition risk rating purposes.
In 2025, Steel & Tube’s climate risk steering group
participated in an internal workshop to systematically
review all risks and opportunities at a high level and review
the ratings of material risks and opportunities.
As a result of the review workshop, minor rating changes
were recommended which were reviewed by the CEO and
the Audit & Risk Committee and approved by the board.
Our 2025 review of Steel & Tube’s climate-related risk and opportunities affirms that the most material short-term risks and opportunities relate to the transition to a low-emissions
economy, the potential impact of physical risks and opportunities remains low in the short term. We note that in 2025 our material risks and opportunities remain largely unchanged,
with only minor changes to risk ratings and descriptions of risks and opportunities which were reviewed by the Audit & Risk committee and approved by the board.
Transition Risk RatingTransition Opportunity RatingTime Horizon
Action needed now – impact in 2-5 years
Opportunity presents itself now
– impact in 2-5 years
Short term
(Present Day – 2030)
Action needed – impact in 10-15 years
Action needed to prepare for maximising
opportunity – impact in 5-10 years
Medium-term
(2030 – 2050)
Research priority – impact in 10-15 years
Research to be done on potential opportunity –
impact in 10-15 years
Sustain current action – impact in 15-20 years Sustain current action – impact in 15-20 years
Watching brief – impact in 20-30 years Watching brief – impact in 20-30 years
Long-term (2050 – 2100)
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Steel & Tube Climate-related Disclosures
Table of transition risks, impacts and opportunities
New Zealand’s transition to a low emissions future presents both opportunities and
challenges for Steel & Tube. The following table is a summary of these transition risks
and opportunities that we have identified as material to our business.
Description & Risk Rating
Most impacted
Scenario/Time HorizonAnticipated Impacts Strategic options
Embodied carbon
Risk that an increasing availability of green steel alternatives
on like-for-like products could result in customer defection and
loss of revenue and market share
Orderly / Short term• Customers seeking to meet embodied carbon
targets turn to suppliers with the lowest carbon
steel available
• Educating customers and specifiers on climate,
circularity, and embodied carbon
• Increasing product durability and lifespan
(e.g., through galvanizing)
• Sourcing higher-strength steel and encourage
low-carbon design, advocate for Environmental
Product Declarations (EPDs) from mills
Opportunity as decarbonising technology develops in steel
production in New Zealand, as well as increased renewable grid
energy reducing scope 2 emissions for the mill, resulting in
local steel products becoming more competitive due to lower
carbon GWP (Global Warming Potential) ratings
Orderly / Short term• Global investment in low-emissions steel
production, as mills invest in Electric Arc Furnaces
and research and development for low embodied
carbon steel production
Transitioning economy
Risk that carbon prices increase, resulting in loss of market
share or narrowed margins, if Steel & Tube is unable to
decarbonise steel products
Orderly / Medium-term
Disorderly / Long-term
• An increasing carbon price would require Steel &
Tube to either pass the cost of embodied carbon
on to the customer, or incur the cost of offsetting
the embodied carbon, reducing gross profits
• Strengthening relationships with local suppliers to
prioritise local procurement
• Expanding sourcing from low-carbon mills and
broadening our low-carbon product range
• Positioning Steel & Tube as the preferred partner
for energy infrastructure projects with
a sustainable supply chain
There is an opportunity presented by the decarbonisation
of the energy sector, resulting in increased demand for steel
products, generating greater demand and revenue
Orderly / Short term• Decarbonisation of the energy sector creates
demand for steel as an essential component in
the construction of alternative energy projects i.e.
wind turbines, steel ground mounted solar arrays
Market demand & technology
Risk that competitors introduce new non steel, lower
embodied emissions products that have similar characteristics
to steel. This could result in a loss of revenue and market share
Orderly / Medium-term• Reduced demand for steel due to low embodied
carbon policies in construction projects
• Promoting the strength and circularity benefits of
steel products
• Building relationships with specifiers and
contractors to drive demand for low-carbon steel
products, enabling bulk purchasing
• Diversifying our supply chain and product range
to include more low-carbon steel options
Opportunity for increased demand in Steel & Tube products
as steel can be used to construct climate resilient structures
with greater structural integrity, which mitigates the impact of
climate hazards
Disorderly / Long-term• Increased revenue for high value strength
products
13
Steel & Tube Climate-related Disclosures
Decarbonisation reporting
Risk of exposure to fines and litigation brought by market
regulators and/or shareholders due to Steel & Tube’s progress
on decarbonisation being inadvertently overstated, or
misinterpreted, and labelled as greenwashing
Orderly / Short-term
Disorderly / Medium-
term
• Potential fines and litigation for directors due to
failure to comply with climate-related disclosures
• Perceived greenwashing resulting in litigation
• Collaborating with our supply chain and steel
sector to accelerate decarbonisation and
strengthen the quality of data
• Focus on material emission sources, develop a
diverse and efficient freight network, including
electric and low-emissions vehicles, and freight
consolidation
• Increasing automation and robotics in
operations, and partnering for renewable energy
solutions (e.g., solar)
There is an opportunity to reduce Scope 2 GHG emissions
via onsite generation and/or other practical initiatives with
measurable verifiable impacts
Orderly / Medium-term
Disorderly / Long-term
• Reduced operational energy cost and associated
scope 2 emissions, increased energy security
Supply chain & circularity
Risk that Steel & Tube faces increasing monitoring and
compliance costs due to value chain emissions reporting
mandates and the need to step up compliance checks on
steel mills in order to validate emissions data integrity
Orderly / Short-term• Increased operational costs to remain compliant • Exploring downstream integration (selling,
galvanising, and recycling steel) for greater
supply chain control
• Considering acquisition or development of
recycling capabilities
• Continuing education and advocacy with
mills and suppliers on the need for reporting
emissions and decarbonisation
There is an opportunity to add new value adding services
to customers that contribute to the circular economy of steel
such as steel recycling, recovery, or protection
Disorderly / Long-term• Potential increase in revenue for new services
and increase in market size
14
Steel & Tube Climate-related Disclosures
Physical risk rating methodology
Steel & Tube’s subject matter experts were engaged to
identify risks presenting as a result of each climate hazard,
by risk area. They were also required to identify the risk
receptor, or the asset, service, or person (staff/customer)
impacted by the risk. Risks were categorised under high-
level risk type categories; and to provide a risk statement,
which described the consequence of the risk on the
receptor (the risk transmission channel).
Each risk dimension is assigned a unique identifier number,
to facilitate a materiality analysis and final risk ranking.
The results of the climate risk assessment were run through
Deloitte’s quant model to determine the most material risks
by climate hazard, Risk Type, Risk Area and Risk Receptor.
Climate risk is rated on the basis of exposure and
vulnerability. Vulnerability is a function of sensitivity
and adaptive capacity.
1
CClliimmaattee RRiisskk RRaattiinngg DDe effiinni itti ioonn
⚫ Extreme exposure and
vulnerability
Extremely likely to be adversely affected because the receptor
is extremely exposed and sensitive to the presenting hazard,
with a very low capacity to adapt
⚫ High exposure and
vulnerability
Highly likely to be adversely affected because the receptor is
highly exposed and sensitive to the presenting hazard, with a
minor capacity to adapt
⚫ Moderate exposure and
vulnerability
Highly likely to be adversely affected because the receptor is
moderately sensitive to the presenting hazard, with a
moderate capacity to adapt
⚫ Low exposure and
vulnerability
Minor likelihood of being adversely affected because the
receptor has minor exposure and sensitivity to the presenting
hazard, with a high capacity to adapt
⚫ Very low exposure and
vulnerability
Negligible likelihood of being adversely affected because the
receptor has negligible exposure and sensitivity to the
presenting hazard, with an extreme capacity to adapt
TTrraanns si ittiioonn RRiisskk RRaattiinngg TTiimmee HHoorriizzoonn TTrraanns si ittiioonn OOppppoorrttuunniittyy RRaattiinngg
⚫ Action needed now—
impact in 2-5 years
Short term (Present Day—2030)
⚫ Opportunity presents itself now—
impact in 2-5 years
⚫ Action needed—
impact in 10-15 years
Medium-term (2030-2050)
⚫ Action needed to prepare for maximis-
ing opportunity—impact in 5-10 Years
⚫ Research priority—
impact in 10-15 years
⚫ Research to be done on potential
opportunity—impact in 10-15 years
⚫ Sustain current action—
impact in 15-20 years
⚫ Sustain current action —
impact in 15-20 years
⚫ Watching brief—
impact in 20-30 years
Long-term (2050-2100)
⚫ Watching brief—
impact in 20-30 years
Operations
+
Risk
Receptors
People
+
Risk
Receptors
Transition
Risks
Transition risks
• Reputation
• Regulatory & legal
• Market
• Technology
Transition opportunities
• Market
• Energy source
• Resource efficiency
• Resilience
• Products and operations
Physical risks & opportunities
• Acute
• Chronic
Assets
+
Risk
Receptors
The chart below provides a simplified representation of the
scope and boundary of Steel & Tube’s climate risk assessment.
Physical opportunities
Opportunities were identified by climate hazard across
the People, Assets and Operations areas. A ratings matrix
was not applied to physical opportunities.
The chart below provides a simplified representation of
the scope and boundary of Steel & Tube’s climate risk
assessment.
Physical risks and opportunities
identification
The physical boundaries of our risk assessment were
determined to be the operational boundary and tier 2
upstream (i.e. to the steel mill) and tier 1 downstream
(i.e. direct to the customer) value chain.
Our risk and opportunity areas were determined as
comprising People, Assets and Operations.
A range of climate hazards were identified. The material
hazards were assessed to be coastal inundation, extreme
weather events, increasing number of hot days, and fluvial
and pluvial flooding.
Exposure
x
Sensitivity
+
Adaptive capacity
=
CLIMATE RISK
Climate Risk RatingDefinition
Extreme exposure and
vulnerability
Extremely likely to be adversely affected because the receptor
is extremely exposed and sensitive to the presenting hazard,
with a very low capacity to adapt
High exposure and
vulnerability
Highly likely to be adversely affected because the receptor is
highly exposed and sensitive to the presenting hazard, with a
minor capacity to adapt
Moderate exposure
and vulnerability
Highly likely to be adversely affected because the receptor is
moderately sensitive to the presenting hazard, with a moderate
capacity to adapt
Low exposure and
vulnerability
Minor likelihood of being adversely affected because the
receptor has minor exposure and sensitivity to the presenting
hazard, with a high capacity to adapt
Very low exposure and
vulnerability
Negligible likelihood of being adversely affected because
the receptor has negligible exposure and sensitivity to the
presenting hazard, with an extreme capacity to adapt
15
Steel & Tube Climate-related Disclosures
Table of physical risks, impacts and opportunity
The following table is a summary of Steel & Tube’s material physical climate risk types,
impacts and aggregated risks over the time horizons and scenarios defined on pages 8-10.
The indicators in the climate risk rating columns represent the range of rated risks under
those risk types and the time horizons for which those risks occur.
1
1
A singular risk rating indicates that most, if not all, of the risks identified over that time horizon have the same climate risk rating. Multiple risk ratings indicates that the risks under that time horizon have a range of risk ratings.
Material Risk TypeImpactTime Horizon
Orderly
Climate Risk Rating
Disorderly
Climate Risk Rating
Hot House
Climate Risk Rating
Description of
Anticipated Impacts
Mitigation Strategy and
Opportunity Response
Impaired site access
Operational delays
and revenue loss
Short-term
• Lack of access to site results in inability to
receive, receipt or despatch product
• Freight networks and possible road damage
delays incoming goods and deliveries
• Increased operational costs associated with
freight disruption, holding incoming stock
• Flooding could potentially impact potable
water supply
• Possible risk of injury to employees onsite in
the event of a flash weather or climate hazard
event
• Reputation damage if climate event occurs
and response is not perceived to be
adequate or loss of revenue opportunities
due to excessive delays in supplying product
In the short-term, management ensures
that emergency response and business
continuity planning covers responses to
events that would impair access to sites
and review these processes on regularly
scheduled basis, diverting orders to
nearby regions and collaborating with
freight networks.
Monitor available climate data in the
medium to long term to look for
opportunities to relocate sites that are in
higher risk areas.
Maintain diversity of freight supply chain
to strengthen continuity in the event of
climate events.
Medium-term
Long-term
Flooding of
workspaces
Health risks and
associated revenue
loss
Short-term
Medium-term
Long-term
Impaired site access
due to flooding
Operational cost
escalation and
margin loss
Short-term
Medium-term
Long-term
Flooding, which
causes personal asset
damage and loss
Staff turnover,
productivity loss,
remediation and/or
replacement costs of
assets
Short-term
• Increase in time off for workforce affected
by personal asset damage and loss, in turn
causing increased wellness spend, alongside
productivity losses and a negative impact on
the organisation’s reputation
• Increased product write-offs due to salt spray
and/or saltwater ingress for sites in coastal
areas, increased operational cost in installing
racking or protection for product
• Increased asset replacement or repair due to
extreme weather events, increase product
write-offs
• Delays to operations if critical assets
damaged during weather event such as
forklifts
Continue to maintain flexible working
arrangements to cover staff who are
impacted by weather events (e.g. remote
working), availability of EAP (Employee
Assistance Programme) services to all
staff
Monitor product located in coastal areas
for early detection of damage due to
sea spray, in medium to long term utilise
opportunity to relocate sites away from
coastal areas Maintain diversified asset
suppliers and service providers to ensure
assets can be repaired or replaced quickly
Medium-term
Long-term
Extreme weather
causes asset/and or
product damage
Remediation and/or
replacement costs
Short-term
Medium-term
Long-term
16
Steel & Tube Climate-related Disclosures
Metrics and Targets
Metric Categories
Steel & Tube primarily uses Greenhouse Gas (GHG)
emissions as a measure of our climate-related performance.
In 2024 we engaged Deloitte to assist with developing
a methodology to quantify our transition risks and
opportunities. We have further work to undertake in this
area to enable more descriptive disclosures. We currently
estimate the percentage of assets or business activities
exposed to transition risks at 48%.
GHG emissions and intensity
Steel & Tube’s Scope 1 & 2 greenhouse gas inventory is
measured in accordance with the Greenhouse Gas Protocol
Corporate Standard. We have obtained assurance to a
“limited” level by KPMG in accordance with the XRB’s New
Zealand Standard on Assurance Engagements 1: Assurance
Engagements over Greenhouse Gas Disclosures. The
assurance report is available on pages 22-25.
+
Scope 1 emissions we directly control. For Steel & Tube,
this includes vehicle fuel and stationary combustion
+
Scope 2 purchased electricity from the grid
Explanatory comments
During FY25, we assessed the completeness and accuracy
of our systems for calculating our Greenhouse Gas (GHG)
emissions. As part of this review, we updated our processes
for uploading data into our emissions reporting platform
and included smaller volume fuel transactions to improve
the completeness of our reporting. These enhancements
led to changes in our disclosed FY23 and FY24 emission
figures compared to what was previously reported in FY24.
These changes are not considered material, as they did not
exceed our significance threshold of 5% of total Scope 1
and Scope 2 emissions, as outlined in our GHG
recalculation policy.
Steel & Tube acquired the trade and assets of Perry Metal
Protection, Grating and Waikato Sandblasting on 1 May
2025. This acquisition is considered a structural change
according to our GHG recalculation policy and we will
disclose the details on the recalculation in our FY26 climate-
related disclosures. We have excluded the two months of
Perry’s scope 1 & 2 emissions in FY25 (May to June 2025)
- their emissions will be included in our FY26 disclosure
(using the “all-year/year after adjustment” approach
allowed by the GHG Protocol - see Appendices for details).
Table of Emissions
All figures are in tCO2e (tonnes of carbon dioxide
equivalent). Our baseline year for GHG emissions is FY23.
Steel & Tube measures scope 1 & 2 emissions intensity by
tonnes sold (kgCO2e per tonne sold).
Emissions CategoryFY23FY24FY25
Total Scope 1 & 21,9 2 51,8792,458
Scope 11,5571,4422,062
Stationery Combustion8 8 4
Vehicle Fleet1,5491,434 2,058
Scope 2368437396
Electricity Consumption368437396
Emissions intensity
– kgCO2e per tonne soldFY23FY24FY25
Scope 1 & 213.1316.2624.78
Analysis of trends
Steel & Tube’s only source of scope 1 stationery combustion
emissions relates to the natural gas consumed at our
Ōtāhuhu site which is used to heat the hot water for
showers. The reduction of from FY24 to FY25 is due
to decreased levels of personnel onsite, subsequently
requiring less hot water.
Our scope 1 vehicle fleet emissions have increased due to
the expansion of our truck fleet in FY25. Overall, our diesel
consumption has increased by 42% from FY24 to FY25.
In line with best practice and our GHG recalculation policy,
we have retrospectively applied the 2024 MfE emission
factor to our FY24 emissions. As a result, we have restated
our FY24 Scope 2 emissions. The impact of this restatement
exceeds our 5% materiality threshold and is therefore
disclosed accordingly.
17
Steel & Tube Climate-related Disclosures
Metrics and Targets
Ta r g e t s
Steel & Tube has not set climate-related targets in FY25.
While we have consistently reported Scope 1 and Scope 2
emissions over recent years, we are currently focused on
developing a comprehensive Scope 3 emissions inventory,
including emissions associated with our recent acquisition.
Our business strategy prioritises growth through organic
investment and mergers and acquisitions in directly
adjacent sectors. As a result, the scope, boundaries, and
activities of our operations continue to evolve, making it
challenging to set meaningful and realistic climate-related
targets at this stage.
We believe that establishing a full and accurate emissions
profile will better inform our transition planning and help
identify credible decarbonisation opportunities across our
value chain. This will support the development of targets
that are both ambitious and achievable.
Vulnerability to physical risks
The amount or percentage to which Steel & Tube’s people,
assets and operations are exposed to our identified physical
risks and opportunities has not currently been quantified.
As we continue developing our methodology and approach
for understanding the anticipated financial impacts of our
physical risks and opportunities, we will be able to disclose
these estimates in the future. At present, it is difficult
to quantify the percentage or amount of our assets or
business activities that are vulnerable to physical risks
because of the wide range of variables and factors involved
with regional-specific climate modelling.
Internal carbon price and capital deployment
Steel & Tube does not apply an internal carbon emissions
price. Steel & Tube is working towards determining how
climate-related risks and opportunities serve as an input
to our internal capital deployment and funding decision-
making processes.
18
Steel & Tube Climate-related Disclosures
Appendices
Risk and opportunities: materiality, assumptions, and
limitations
The climate risk and opportunities identification
and assessment leveraged global data provided by
Intergovernmental Panel on Climate Change’s (IPPC) that
has been downscaled by the New Zealand’s National
Institute of Weather and Atmospheric Research (NIWA)
to provide regional data for the purpose of assessing
New Zealand’s exposure and vulnerability to climate
change hazards.
The data sets provide multiple global warming scenarios
and we adopted three of these scenarios to test the
exposure and vulnerability of Steel & Tube’s assets,
operations and people, at multiple strategic time horizons.
The global warming scenarios adopted by Steel & Tube
include those provided by the IPCC in its AR5 report,
referred to as Representative Concentration Pathways
(RCPs); and the IPCC’s Shared Socio-Economic Pathways
scenarios (SSPs) described in its AR6 report. The scenarios
adopted for the purpose of Steel & Tube’s first pass climate
risk assessment include SSP1-2.6, SSP2-4.5 and SSP5-8.5.
The delay between the publication of the IPPC’s Sixth
Assessment Report in 2021 (AR6) and the downscaling
of IPPC climate data to provide more granular detail for
New Zealand meant that Steel & Tube’s OCCRA climate
risk assessment was required to use NIWA data based on
climate model simulations from the Intergovernmental
Panel on Climate Change (IPCC) Fifth Assessment Report.
Risk assessment methodology
The risk assessment process described on pages 11-15 is
consistent with the Ministry for the Environment’s National
Climate Risk Assessment Framework methodology, and
with ISO 14091:2021 by assessing the identified risks in
terms of their exposure, sensitivity, and adaptive capacity.
This process enables us to develop climate scenarios
depicting Steel & Tube’s future state exposure to
climate risk.
Climate scenarios illustrate what the future might look like
under differing degrees of climate change. They are not
predictions about what will happen, but rather hypotheses
about what could happen in the short to long term.
The global warming futures are evaluated against the
scenarios provided by the IPCC. We applied the RCP
scenarios (that are aligned to the SSP scenarios) from
the IPCC AR5 for climate metrics that have not yet been
developed within the IPCC AR6 models at the time of our
initial risk assessment.
Quantification of transition risks
Steel & Tube engaged Deloitte in 2024 to support with
quantifying S&T’s financial exposure to its material climate
risks, and to determine its response as part of its transition
planning. This process involved the Climate Risk Steering
Group, key internal SME’s and went through the following
modelling process:
1. Obtain NGFS scenario model drivers and variables
2. Develop the indicative steel price paths and steel
demand profiles to undertake scenario analysis
3. Overlay Steel & Tube specific demand and cost drivers
for each product segment
4. Apply Steel & Tube price elasticity analysis for each
product segment to derive the expected demand for
each product as steel prices rise
5. Analyse the outputs for each temperature scenario.
6. Quantify the transition risk.
Scenario analysis – limitations and assumptions
Scenario analysis is a process for identifying and assessing
the potential implications of a range of plausible future
states under conditions of uncertainty. Scenarios are
hypothetical constructs and not designed to deliver
precise outcomes or forecasts. Instead, scenarios provide
a way for organisations to consider how the future might
look if certain trends continue or certain conditions are
met (TCFD Guidance, 2017). Steel & Tube’s climate risk
assessment analysis and scenario narratives provides insight
into plausible future risk profiles in terms of Steel & Tube’s
exposure and vulnerability to the effects of climate change,
and how these evolve over time and under different global
warming scenarios.
For the purposes of scenario analysis for our initial climate
risk assessment, we adopted the shared socioeconomic
scenarios provided by the IPCC AR6 report to assess our
evolving risk profile. There are three SSPs and RCPs which
were utilised for our risk assessment, namely SSP1-2.6;
SSP2-4.5 (relating to a 2-degree warming future meeting
current climate targets and pledges) and SSP5-8.5 and
RCP8.5 (relating to a 4-degree warming future with limited
effort to mitigate GHG emissions). These scenarios are
related to plausible futures where moderate mitigation
leads to meeting the current targets and pledges under
the Paris Agreement, and a global inaction future at the
high end of the risk spectrum.
19
Steel & Tube Climate-related Disclosures
ICCP Scenarios
SustainabilitySSP 1 – 2.6
This future poses moderate challenges to mitigation and moderate challenges to adaptation. Population growth stabilises toward the end of
the century; current social, economic, and technological trends continue; global and national institutions make slow progress toward achieving
sustainable development goals. This scenario provides a 67% chance of limiting global warming to below 2ºC to around 1.6ºC.
Middle of the RoadSSP 2 – 4.5
This future poses high challenges to mitigation and high challenges to adaptation. Population growth continues with high growth in developing
countries; there is an emphasis on national issues due to regional conflicts and nationalism; economic development is slow and fossil fuel
dependent; there are weak global institutions and little international trade. Under this scenario we see a temperature rise of 2.5ºC – 2.7ºC
Fossil-fueled
Development
SSP 5 – 8.5
This scenario depicts a worst-case scenario, where very little effort has been deployed to mitigate global warming. Current C0
2
emissions levels
roughly double by 2050. Under this scenario, economic growth continues to be driven by fossil fuel combustion and energy-intensive lifestyles.
By 2100, the average global temperature has increased by 4.4ºC. This future poses high challenges to mitigation and low challenges to adaptation.
Under this scenario, global surface temperatures reach between 3.2ºC and 5.4ºC.
Appendices
For the purpose of assessing Steel & Tube’s transition risks, we have referenced the scenarios provided by the Network for Greening the Financial system, which include the Orderly,
Disorderly and Hot House World as described below:
Orderly Net Zero by 2050
An ambitious scenario that limits global warming to
1.5°C through stringent climate policies and innovation,
reaching net zero CO2 emissions around 2050. Some
jurisdictions such as the US, EU and Japan reach net
zero for all greenhouse gases by this point. This scenario
assumes that ambitious climate policies are introduced
immediately. Carbon Dioxide Removal (CDR) is used to
accelerate the decarbonisation but kept to the minimum
possible and broadly in line with sustainable levels of
bioenergy production. Net CO2 emissions reach zero
around 2050, giving at least a 50% chance of limiting
global warming to below 1.5°C by the end of the century,
with no or low overshoot (< 0.1°C) of 1.5°C in earlier years.
Physical risks are relatively low.
Disorderly Delayed Transition
Assumes global annual emissions do not decrease until
2030. Strong policies are then needed to limit warming to
below 2°C. Negative emissions are limited. This scenario
assumes new climate policies are not introduced until
2030 and the level of action differs across countries and
regions based on currently implemented policies, leading
to a “ fossil recovery” out of the economic crisis brought
about by COVID 19. The availability of CDR technologies is
assumed to be low pushing carbon prices higher than in
Net Zero 2050. As a result, emissions exceed the carbon
budget temporarily and decline more rapidly than in well
below 2°C after 2030 to ensure a 67% chance of limiting
global warming to below 2°C. This leads to both higher
transition and physical risks than the Net Zero 2050
and below 2°C scenarios.
Hothouse Current Policies
Assumes that only currently implemented policies are
preserved, leading to high physical risks. Emissions grow
until 2080 leading to about 3°C of warming and severe
physical risks. This includes irreversible changes like higher
sea level rise. This scenario can help central banks and
supervisors consider the long-term physical risks to the
economy and financial system if we continue on our
current path to a “hot house world”.
20
Steel & Tube Climate-related Disclosures
GHG Methodologies, Assumptions and
Estimation Uncertainties
Organisational boundary and scope
The organisational boundaries used for this report include
all operating entities wholly owned by Steel & Tube
Holdings Limited, including Perry Metal Protection,
Perry Grating and Waikato Sandblasting. GHG emissions
for these entities are calculated based on an operational
control approach, using the methodology described in
the GHG Protocol, and relate to the financial period FY25
(1 July 2024 to 30 June 2025).
Operational boundaries
Steel & Tube’s GHG emissions as per the GHG Protocol:
• Scope 1 includes all direct emissions occurring from Steel
& Tube’s operations, most notably from the combustion
of vehicle fuel (diesel, petrol, LPG). This inventory
excludes fugitive emissions from refrigerant as we have
assessed this category to be immaterial.
• Scope 2 covers emissions from the generation of
purchased electricity consumed at Steel & Tube’s
operated sites.
As previously noted, Steel & Tube has opted to use NZ
CS 2 Adoption provision 4, providing an exemption from
disclosing our scope 3 emissions in FY25. Although we
have historically reported some of our scope 3 emissions,
previously this has been based on incomplete data. Scope 3
Categories emissions inventory development will continue
in FY26. Exclusions are reviewed annually and may be
included in future disclosures if they become material or
applicable.
Base year recalculation approach
On 1 May 2025, Steel & Tube acquired the trade and assets
of Perry Metal Protection, Perry Grating and Waikato
Sandblasting, and as such this acquisition will trigger a base
year recalculation. Our FY23 base year recalculation will be
presented in our FY26 climate-related disclosure when the
emissions for Perry’s are reported.
Steel & Tube has opted to use the “All-year/year after
adjustment” approach in regards to structural changes as
allowed by the GHG Protocol Corporate Standard (see
“Base year recalculation methodologies for structural
changes - Appendix E to the GHG Protocol Corporate
Accounting and Reporting Standard - Revised edition).
Emission factors
Our Greenhouse Gas (GHG) inventory is measured in
accordance with The Greenhouse Gas Protocol:
A Corporate Accounting and Reporting Standard (revised
edition) and The Greenhouse Gas Protocol: GHG Protocol
Scope 2 Guidance: An amendment to the GHG Protocol
Corporate Standard. Our emission factors are sourced from
the Ministry for the Environment, as described in Table A
below. Steel & Tube ensures the accuracy and relevance of
our greenhouse gas (GHG) emissions reporting by annually
updating our emission factors in alignment with the latest
releases from the Ministry for the Environment (MfE).
As the MfE tends to release updated emission factor
workbooks towards the end or start of Steel & Tube’s
financial year, we have applied updated 2024 emission
factors retroactively to our FY24 emissions. This has
resulted in the comparative years emissions changing
from what was reported in 2024.
The following MfE factor books apply to the following
financial years:
• FY23 emissions: 2023 Emission Factors Workbook
• FY24 emissions: 2025 Emission Factors Workbook
• Y25 emissions: 2025 Emission Factors Workbook
21
Steel & Tube Climate-related Disclosures
Emissions
Ty p e
Emission
Source & FactorEmissions Activity
Calculation
MethodologyData Source(s) Assumptions, Limitations & Uncertainties
Scope 1Natural Gas
(MfE)
Natural gas used for water
heating on site
Location-based
method
Consumption data in kWh is provided by our
power management company, using invoiced
data from retailers
Low uncertainty on data quality from supplier,
medium uncertainty from emission factors not
being site-specific
Scope 1LPG (MfE)LPG used in forklifts and other
onsite equipment
Fuel-based methodAutomated usage report from main supplier,
consumption data collected from invoices for
other suppliers
Low uncertainty - reports are automatic from
the supplier, manually entered quantity volumes
are low
Scope 1 Fleet Vehicle Fuel
(MfE)
Fuel used in vehicle fleetFuel-based methodPrior to May 2024, there were two sources of
fuel reporting separate fleet managers, however
our fuel reporting is now consolidated into one
report from one source
Low uncertainty - reports are automatic from the
supplier. Where an operator has purchased fuel
on their Steel & Tube Procurement card, this is
captured in a separate report.
Scope 2 Grid sourced
electricity (location
based) (MfE)
Electricity sourced from the grid
to our sites
kWh-used methodUsage report from supplier dashboardLow uncertainty - reports are sourced directly
from the supplier and do not use averages or
assumptions
GHG Methodologies, Assumptions and
Estimation Uncertainties
22
Steel & Tube Climate-related Disclosures
Assurance Opinion
© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Document classification: KPMG Public
Independent Limited
Assurance Report to Steel &
Tube Holdings Limited
Conclusion
Our limited assurance conclusion has been formed on the basis of the
matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable
assurance engagement or an audit, nothing has come to our attention
that would lead us to believe that, in all material respects, the scope 1
and 2 gross greenhouse gas emissions, additional required disclosures
and associated methods, assumptions and estimation uncertainty
disclosures within pages 15 (excluding Emissions intensity), 20 and 21
(GHG disclosures) are not fairly presented and prepared in accordance
with the Aotearoa New Zealand Climate Standards (NZ CSs) issued by
the External Reporting Board (the criteria) for the period 1 July 2024 to
30 June 2025.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to Steel
& Tube Holdings Limited’s (the Client) GHG disclosures for the period 1 July 2024
to 30 June 2025.
Below are the locations of the GHG disclosures subject to assurance:
NZ CS 1-3 requirement:
2025 Climate Related Disclosures
reference:
NZ CS 1 22 (a)
Table of emissions excluding Emissions
intensity (Page 16)
NZ CS 1 24 (a) Metrics and targets (Page 16)
NZ CS 1 24 (b to d)
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 52
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 53
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 54
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
Our conclusion on the GHG disclosures does not extend to any other information
included, or referred to, in the Climate Related Disclosures or other information that
accompanies or contains the Climate Related Disclosures and our assurance report
(other information). We have not performed any procedures with respect to the
other information.
Criteria
The criteria used as the basis of reporting include the NZ CSs. As disclosed on page
15 of the Climate Related Disclosures, the greenhouse gas emissions have been
measured in accordance with the World Resources Institute and World Business
Council for Sustainable Development’s Greenhouse Gas Protocol standards and
guidance, specifically for each scope:
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting
Standard (revised edition)
• Additionally, Scope 2 emissions have been measured in accordance with The
Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to
the GHG Protocol Corporate Standard
As a result, this report may not be suitable for another purpose.
© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Document classification: KPMG Public
Independent Limited
Assurance Report to Steel &
Tube Holdings Limited
Conclusion
Our limited assurance conclusion has been formed on the basis of the
matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable
assurance engagement or an audit, nothing has come to our attention
that would lead us to believe that, in all material respects, the scope 1
and 2 gross greenhouse gas emissions, additional required disclosures
and associated methods, assumptions and estimation uncertainty
disclosures within pages 15 (excluding Emissions intensity), 20 and 21
(GHG disclosures) are not fairly presented and prepared in accordance
with the Aotearoa New Zealand Climate Standards (NZ CSs) issued by
the External Reporting Board (the criteria) for the period 1 July 2024 to
30 June 2025.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to Steel
& Tube Holdings Limited’s (the Client) GHG disclosures for the period 1 July 2024
to 30 June 2025.
Below are the locations of the GHG disclosures subject to assurance:
NZ CS 1-3 requirement:
2025 Climate Related Disclosures
reference:
NZ CS 1 22 (a)
Table of emissions excluding Emissions
intensity (Page 16)
NZ CS 1 24 (a) Metrics and targets (Page 16)
NZ CS 1 24 (b to d)
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 52
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 53
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 54
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
Our conclusion on the GHG disclosures does not extend to any other information
included, or referred to, in the Climate Related Disclosures or other information that
accompanies or contains the Climate Related Disclosures and our assurance report
(other information). We have not performed any procedures with respect to the
other information.
Criteria
The criteria used as the basis of reporting include the NZ CSs. As disclosed on page
15 of the Climate Related Disclosures, the greenhouse gas emissions have been
measured in accordance with the World Resources Institute and World Business
Council for Sustainable Development’s Greenhouse Gas Protocol standards and
guidance, specifically for each scope:
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting
Standard (revised edition)
• Additionally, Scope 2 emissions have been measured in accordance with The
Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to
the GHG Protocol Corporate Standard
As a result, this report may not be suitable for another purpose.
23
Steel & Tube Climate-related Disclosures
Assurance Opinion
© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Document classification: KPMG Public
Independent Limited
Assurance Report to Steel &
Tube Holdings Limited
Conclusion
Our limited assurance conclusion has been formed on the basis of the
matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable
assurance engagement or an audit, nothing has come to our attention
that would lead us to believe that, in all material respects, the scope 1
and 2 gross greenhouse gas emissions, additional required disclosures
and associated methods, assumptions and estimation uncertainty
disclosures within pages 15 (excluding Emissions intensity), 20 and 21
(GHG disclosures) are not fairly presented and prepared in accordance
with the Aotearoa New Zealand Climate Standards (NZ CSs) issued by
the External Reporting Board (the criteria) for the period 1 July 2024 to
30 June 2025.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to Steel
& Tube Holdings Limited’s (the Client) GHG disclosures for the period 1 July 2024
to 30 June 2025.
Below are the locations of the GHG disclosures subject to assurance:
NZ CS 1-3 requirement:
2025 Climate Related Disclosures
reference:
NZ CS 1 22 (a)
Table of emissions excluding Emissions
intensity (Page 16)
NZ CS 1 24 (a) Metrics and targets (Page 16)
NZ CS 1 24 (b to d)
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 52
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 53
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 54
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
Our conclusion on the GHG disclosures does not extend to any other information
included, or referred to, in the Climate Related Disclosures or other information that
accompanies or contains the Climate Related Disclosures and our assurance report
(other information). We have not performed any procedures with respect to the
other information.
Criteria
The criteria used as the basis of reporting include the NZ CSs. As disclosed on page
15 of the Climate Related Disclosures, the greenhouse gas emissions have been
measured in accordance with the World Resources Institute and World Business
Council for Sustainable Development’s Greenhouse Gas Protocol standards and
guidance, specifically for each scope:
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting
Standard (revised edition)
• Additionally, Scope 2 emissions have been measured in accordance with The
Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to
the GHG Protocol Corporate Standard
As a result, this report may not be suitable for another purpose.
Standards we followed
We conducted our limited assurance engagement in accordance with New Zealand
Standard on Assurance Engagements 1 (NZ SAE 1) Assurance Engagements over
Greenhouse Gas Emissions Disclosures and International Standard on Assurance
Engagements (New Zealand) 3410 Assurance Engagements on Greenhouse Gas
Statements (ISAE (NZ) 3410) issued by the New Zealand Auditing and Assurance
Standards Board (Standard). We believe that the evidence we have obtained is
sufficient and appropriate to provide a basis for our conclusion.
Our responsibilities under the Standard are further described in the ‘Our
responsibility’ section of our report.
Other Matter – Prior year comparatives not assured
The GHG disclosures for the years ended 30 June 2023 and 30 June 2024 were not
subject to our limited assurance engagement and, accordingly, we do not express a
conclusion, or provide any assurance on such information.
Our conclusion is not modified in respect of this matter.
How to interpret limited assurance and material
misstatement
A limited assurance engagement is substantially less in scope than a reasonable
assurance engagement in relation to both the risk assessment procedures, including
an understanding of internal control, and the procedures performed in response to
the assessed risks.
Misstatements, including omissions, within the GHG disclosures are considered
material if, individually or in the aggregate, they could reasonably be expected to
influence the relevant decisions of the intended users taken on the basis of the GHG
disclosures.
Inherent limitations
GHG quantification is subject to inherent uncertainty because of incomplete
scientific knowledge used to determine emission factors and the values needed to
combine emissions of different gases.
Use of this assurance report
Our report is made solely for Steel & Tube Holdings Limited. Our assurance work
has been undertaken so that we might state to Steel & Tube Holdings Limited those
matters we are required to state to them in the assurance report and for no other
purpose.
Our report should not be regarded as suitable to be used or relied on by anyone
other than Steel & Tube Holdings Limited for any purpose or in any context. Any
other person who obtains access to our report or a copy thereof and chooses to rely
on our report (or any part thereof) will do so at its own risk.
To the fullest extent permitted by law, none of KPMG, any entities directly or
indirectly controlled by KPMG, or any of their respective members or employees
accept or assume any responsibility and deny all liability to anyone other than Steel
& Tube Holdings Limited for our work, for this independent assurance report, and/or
for the opinions or conclusions we have reached.
Our conclusion is not modified in respect of this matter.
Steel & Tube Holdings Limited’s responsibility for the
GHG disclosures
The Directors of Steel & Tube Holdings Limited are responsible for the preparation
and fair presentation of the GHG disclosures in accordance with the criteria. This
responsibility includes the design, implementation and maintenance of such internal
control as The Directors determine is relevant to enable the preparation of the GHG
disclosures that are free from material misstatement whether due to fraud or error.
The Directors of Steel & Tube Holdings Limited are also responsible for selecting or
developing suitable criteria for preparing the GHG disclosures and appropriately
referring to or describing the criteria used.
24
Steel & Tube Climate-related Disclosures
Assurance Opinion
© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Document classification: KPMG Public
Independent Limited
Assurance Report to Steel &
Tube Holdings Limited
Conclusion
Our limited assurance conclusion has been formed on the basis of the
matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable
assurance engagement or an audit, nothing has come to our attention
that would lead us to believe that, in all material respects, the scope 1
and 2 gross greenhouse gas emissions, additional required disclosures
and associated methods, assumptions and estimation uncertainty
disclosures within pages 15 (excluding Emissions intensity), 20 and 21
(GHG disclosures) are not fairly presented and prepared in accordance
with the Aotearoa New Zealand Climate Standards (NZ CSs) issued by
the External Reporting Board (the criteria) for the period 1 July 2024 to
30 June 2025.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to Steel
& Tube Holdings Limited’s (the Client) GHG disclosures for the period 1 July 2024
to 30 June 2025.
Below are the locations of the GHG disclosures subject to assurance:
NZ CS 1-3 requirement:
2025 Climate Related Disclosures
reference:
NZ CS 1 22 (a)
Table of emissions excluding Emissions
intensity (Page 16)
NZ CS 1 24 (a) Metrics and targets (Page 16)
NZ CS 1 24 (b to d)
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 52
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 53
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 54
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
Our conclusion on the GHG disclosures does not extend to any other information
included, or referred to, in the Climate Related Disclosures or other information that
accompanies or contains the Climate Related Disclosures and our assurance report
(other information). We have not performed any procedures with respect to the
other information.
Criteria
The criteria used as the basis of reporting include the NZ CSs. As disclosed on page
15 of the Climate Related Disclosures, the greenhouse gas emissions have been
measured in accordance with the World Resources Institute and World Business
Council for Sustainable Development’s Greenhouse Gas Protocol standards and
guidance, specifically for each scope:
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting
Standard (revised edition)
• Additionally, Scope 2 emissions have been measured in accordance with The
Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to
the GHG Protocol Corporate Standard
As a result, this report may not be suitable for another purpose.
Our responsibility
We have responsibility for:
• planning and performing the engagement to obtain limited assurance about
whether the GHG disclosures are free from material misstatement, whether
due to fraud or error;
• forming an independent conclusion based on the procedures we have
performed and the evidence we have obtained; and
• reporting our conclusion to Steel & Tube Holdings Limited.
Summary of the work we performed as the basis for our
conclusion
A limited assurance engagement performed in accordance with the Standard
involves assessing the suitability in the circumstances of Steel & Tube Holdings
Limited’s use of the criteria as the basis for the preparation of the GHG disclosures,
assessing the risks of material misstatement of the GHG disclosures whether due to
fraud or error, responding to the assessed risks as necessary in the circumstances,
and evaluating the overall presentation of the GHG disclosures.
We exercised professional judgment and maintained professional scepticism
throughout the engagement. We designed and performed our procedures to obtain
evidence about the GHG disclosures that is sufficient and appropriate to provide a
basis for our conclusion.
Our procedures selected depended on the understanding of the GHG disclosures
that is sufficient and appropriate to provide a basis for our conclusion. The
procedures we performed were based on our professional judgment and included
inquiries, observation of processes performed, inspection of documents, analytical
procedures, evaluating the appropriateness of quantification methods and reporting
policies, and agreeing or reconciling with underlying records.
In undertaking limited assurance on the GHG disclosures the procedures we
primarily performed were:
• Obtaining, through inquiries and inspection, an understanding of the
Client’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.
• Assessing the appropriateness of the selected organisational boundary
against the criteria, our understanding of the Client and where applicable
external sources.
• Evaluating, through inquiries, the application of the selected boundary to
the emissions inventory. This included evaluating the completeness of
emissions sources selected for disclosure.
• Inspecting the activity data and agreeing a limited number of items to
supporting records.
• Agreeing a limited number of emissions factors to external source material.
• Recalculating a limited number of emissions to confirm the mathematical
accuracy of calculations.
• Considered the presentation and disclosure of the GHG disclosures
against the requirements of the criteria.
The procedures performed in a limited assurance engagement vary in nature and
timing from, and are less in extent than for a reasonable assurance engagement.
Consequently, the level of assurance obtained in a limited assurance engagement is
substantially lower than the assurance that would have been obtained had a
reasonable assurance engagement been performed.
Our independence and quality management
This assurance engagement was undertaken in accordance with NZ SAE 1. NZ
SAE 1 is founded on the fundamental principles of independence, integrity,
objectivity, professional competence and due care, confidentiality and professional
behaviour.
We have complied with the independence and other ethical requirements of
Professional and Ethical Standard 1 International Code of Ethics for Assurance
Practitioners (including International Independence Standards) (New Zealand) (PES
1) issued by the New Zealand Auditing and Assurance Standards Board, which is
founded on fundamental principles of integrity, objectivity, professional competence
and due care, confidentiality and professional behaviour.
25
Steel & Tube Climate-related Disclosures
Assurance Opinion
© 2025 KPMG, a New Zealand Partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Document classification: KPMG Public
Independent Limited
Assurance Report to Steel &
Tube Holdings Limited
Conclusion
Our limited assurance conclusion has been formed on the basis of the
matters outlined in this report.
Based on our limited assurance engagement, which is not a reasonable
assurance engagement or an audit, nothing has come to our attention
that would lead us to believe that, in all material respects, the scope 1
and 2 gross greenhouse gas emissions, additional required disclosures
and associated methods, assumptions and estimation uncertainty
disclosures within pages 15 (excluding Emissions intensity), 20 and 21
(GHG disclosures) are not fairly presented and prepared in accordance
with the Aotearoa New Zealand Climate Standards (NZ CSs) issued by
the External Reporting Board (the criteria) for the period 1 July 2024 to
30 June 2025.
Information subject to assurance
We have performed an engagement to provide limited assurance in relation to Steel
& Tube Holdings Limited’s (the Client) GHG disclosures for the period 1 July 2024
to 30 June 2025.
Below are the locations of the GHG disclosures subject to assurance:
NZ CS 1-3 requirement:
2025 Climate Related Disclosures
reference:
NZ CS 1 22 (a)
Table of emissions excluding Emissions
intensity (Page 16)
NZ CS 1 24 (a) Metrics and targets (Page 16)
NZ CS 1 24 (b to d)
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 52
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 53
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
NZ CS 3 54
GHG methodologies, assumptions and
estimation uncertainties (Pages 20 and 21)
Our conclusion on the GHG disclosures does not extend to any other information
included, or referred to, in the Climate Related Disclosures or other information that
accompanies or contains the Climate Related Disclosures and our assurance report
(other information). We have not performed any procedures with respect to the
other information.
Criteria
The criteria used as the basis of reporting include the NZ CSs. As disclosed on page
15 of the Climate Related Disclosures, the greenhouse gas emissions have been
measured in accordance with the World Resources Institute and World Business
Council for Sustainable Development’s Greenhouse Gas Protocol standards and
guidance, specifically for each scope:
• The Greenhouse Gas Protocol: A Corporate Accounting and Reporting
Standard (revised edition)
• Additionally, Scope 2 emissions have been measured in accordance with The
Greenhouse Gas Protocol: GHG Protocol Scope 2 Guidance: An amendment to
the GHG Protocol Corporate Standard
As a result, this report may not be suitable for another purpose.
The firm applies Professional and Ethical Standard 3 Quality Management for Firms
that Perform Audits or Reviews of Financial Statements, or Other Assurance or
Related Services Engagements (PES 3), which requires the firm to design,
implement and operate a system of quality control including policies or procedures
regarding compliance with ethical requirements, professional standards and
applicable legal and regulatory requirements.
We have also complied with Professional and Ethical Standard 4 Engagement
Quality Reviews (PES 4) which deals with the appointment and eligibility of the
engagement quality reviewer and the engagement quality reviewer’s responsibilities
relating to the performance and documentation of an engagement quality review.
Our firm has also provided other services to the Client that are related to our role as
the Client’s auditors, such as financial statement audit and half year review of the
interim consolidated financial statements. Subject to certain restrictions, partners
and employees of our firm may also deal with the Client on normal terms within the
ordinary course of trading activities of the business of the Client. These matters
have not impaired our independence as assurance providers of the Client for this
engagement. The firm has no other relationship with, or interest in, the Client.
As we are engaged to form an independent conclusion on the GHG disclosures
prepared by Steel & Tube Holdings Limited, we are not permitted to be involved in
the preparation of the GHG disclosures as doing so may compromise our
independence.
The engagement partner on the assurance engagement resulting in this
independent assurance report is Laura Youdan.
KPMG
Auckland
30 October 2025
Data sourced from publicly available filings. Our datasets may not be complete. Automated analysis can produce errors. If you believe any data on this page is incorrect, please contact us at hello@nzxplorer.co.nz. For informational purposes only. Not investment advice.
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