Climate Change Related Disclosure Report

NZX AND MEDIA RELEASE
18 November 2025

Napier Port publishes fifth Climate Change Related
Disclosure Report


Napier Port (NZX.NPH) today publishes its fifth annual Climate Change Related Disclosure Report,
seeking to provide stakeholders with an understanding of the potential financial implications of climate
change on the business.

Our Climate Change Related Disclosure Report, independent emissions limited assurance report, and
our Sustainability Strategy are available at: www.napierport.co.nz/investor-centre/.

For more information:

Investors Media
Kristen Lie Chris Lonergan
Chief Financial Officer Communications Manager
DDI: +64 6 833 4405 DDI: +64 6 833 4521
E: kristenl@napierport.co.nz E: chrisl@napierport.co.nz

About Napier Port
Napier Port is New Zealand’s fourth largest port by container volume. We are the gateway for Hawke’s
Bay and lower North Island’s exports and operate a long-term infrastructure asset that supports the
regional economy. Our strategic purpose is to collaborate with the people and organisations that have
a stake in helping our region grow. View Napier Port’s investor centre:
https://www.napierport.co.nz/investor-centre/

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PERIOD ENDED 30 SEPTEMBER 2025

CONTENTS
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+Contentss1s2s3s4
This report is prepared in compliance with the Aotearoa New Zealand Climate Standards
(NZ CS) 1- Climate Related Disclosures, 2 - Adoption of Aotearoa New Zealand Climate
Standards, and 3 - General Requirements for Climate-related Disclosures.
The New Zealand External Reporting Board (XRB) in December 2022 issued the NZ CS,
which are effective for reporting periods commencing on or after 1 January 2023. These
new mandatory climate standards are based on the Taskforce on Climate-Related Financial
Disclosures (TCFD) framework which this report also adheres to. Napier Port has not
applied any of the adoption provisions that are permitted under NZ CS 2.
This report also adheres to the International Financial Reporting Standards (IFRS) S2 -
Climate-related Disclosures standards (IFRS S2).
The currency used in this report is the New Zealand dollar (NZD) which is also the functional
currency used in the Napier Port Holdings Group financial statements. This report also
follows the same reporting period as the financial statements.
Introduction
This is the fifth climate change related disclosure report produced by Napier Port Holdings Limited (Napier Port) which seeks to
provide stakeholders an understanding of the potential financial implications of climate change on its business. The first three
years’ reports were primarily based on the recommendations of the TCFD, while the fourth report focused on compliance with
the NZ CS framework for the first time.
The focus of the fifth report is to continue to comply with the NZ CS framework and to incorporate, where relevant, updates to
Napier Port’s Climate Change Risk Assessment (CCRA), and to adhere with IFRS S2.
Napier Port’s sustainability journey is one of continuous improvement and the people of Napier Port are committed to improving
its environmental, social and economic performance by identifying and managing risks and finding opportunities to use our
resources more efficiently.
Napier Port expects to further develop and improve its climate change related disclosures as we gather more information and
knowledge and continue to deliver against our sustainability strategy.
Important information for readers: Quantifications in this
report of financial impacts of climate change are estimates
and are not intended to constitute earnings guidance. No
representation is made as to their accuracy, completeness or
reliability. These risks and opportunities may not eventuate
and, if they do, the actual impact may differ materially from
these estimates. Other material risks and opportunities may
exist or eventuate that are not included within this report.
Stephen Moir
Director
Vincent Tremaine
Director
18 November 2025
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Governance
P4
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Risk Management
P6
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Strategy
P8
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Metrics and Targets
P20
2025 CLIMATE CHANGE DISCLOSURE REPORT
P3P2

The Napier Port Board of Directors are
ultimately responsible for identifying the
principal risks faced by Napier Port and taking
reasonable steps to ensure that appropriate
internal controls and monitoring systems
are in place to manage and, to the extent
reasonably possible, reduce the impact
of these risks, including material climate-
related risks. The Board reviews Napier
Port’s Risk Management Policy annually.
The Board also considers climate-related
risks and opportunities when overseeing
the implementation of Napier Port’s strategy
and its decisions on major transactions and
considers any trade-offs associated with
those risks and opportunities.
The Audit and Risk Management Committee
supports the Board in this function by
ensuring that management is implementing
Napier Port’s overall risk management
framework and policy and monitoring
corporate risk assessments and ensuring that
risk controls are implemented. The Audit and
Risk Management Committee reviews Napier
Port’s overall risk management framework
on a six-monthly basis and the Committee
proceedings are reported back to the Board.
The Health, Safety and Sustainability
Committee (HSSC) reviews annually a
Climate Change Risk Assessment (CCRA)
inclusive of a climate-related risk register
specifically for the management of climate-
related risks and opportunities. This is part
of the HSSC’s wider role to identify and
consider relevant environmental, social
and governance (ESG) matters to provide
strategic guidance and feedback to the
Board and management on Napier Port’s
ESG related strategies, policies, frameworks,
initiatives, performance and reporting.
The HSSC meets at least three times
per year to review progress on the
implementation of Napier Port’s Sustainability
Strategy, the assessment of climate-related
risks and opportunities documented within the
CCRA, and progress and track achievements
against climate-related metrics. The
Committee proceedings are reported back to
the Board.
The Board maintains a director skills matrix,
which includes a specific category for
sustainability expertise. The skills matrix is
an important recruitment consideration when
a new director is being considered to join the
Board. The Corporate Governance Statement
found within the 2025 Annual Report (page
72) shows the Director skills matrix and the
attendance at HSSC meetings.
As climate-related issues, including the new
Aotearoa New Zealand Climate Standards,
are rapidly evolving, directors are continuing
to develop their knowledge, including by
attending courses and presentations.
The Chief Executive and Senior Management
Team are responsible for ensuring that risks
to the business, including climate-related
risks and opportunities, are identified and
evaluated, effective responses and control
activities developed, and appropriate
monitoring and timely re-evaluation
RISK MANAGEMENT POLICY
• Provides the overarching framework for identifying, assessing, managing and
monitoring risk at Napier Port, including climate-related risks.
• Objectives of the policy include ensuring that Napier Port operates in a
sustainable manner and protects the Port environment in accordance with
its sustainability strategy.
HEALTH, SAFETY AND
SUSTAINABILITY COMMITTEE
• Oversees the development of Napier Port’s ESG strategy and
ESG workplan and monitor progress.
• Make recommendations and report to the Board on material ESG
matters requiring governance decisions.
• Acts as a formal forum for free and open communication between
the Board and management with respect to ESG matters.
• Facilitate a common and aligned Board understanding of what is
within the scope of ESG matters.
• Ensure an appropriate framework is maintained for the
management of ESG related risks; and
• Oversee and reviews underlying ESG reporting processes.
CHIEF EXECUTIVE AND SENIOR MANAGEMENT TEAM
• The Chief Executive and senior management team are
responsible for ensuring that risks to the business, including
climate-related risks, are identified and evaluated, effective
responses and control activities developed, and appropriate
monitoring and timely re-evaluation conducted, in accordance
with Napier Port’s Risk Management Policy.
• The Chief Financial Officer, working with senior management, updates Napier Port’s
overall risk management framework and reports to the Audit and Risk Management
Committee on a six-monthly basis.
• The General Manager – Assets and Infrastructure has overall responsibility for the
development and implementation of the sustainability strategy, including assessment
of climate-related risks, and reports on progress to the HSSC.
KEY STAFF TASKED WITH RISK MANAGEMENT ACTIVITIES
(FROM INFRASTRUCTURE, FINANCE AND OPERATIONS TEAM)
• Provide support with identifying, monitoring and assessing climate
change risks and ensuring appropriate management actions are
taken in relation to them.
• Responsible for maintaining the safety, performance and capability of Napier Port’s
infrastructure assets and plant and equipment over their projected economic lives.
• Maintain long term asset management plans.
BOARD OF DIRECTORS
• The Board is ultimately responsible for identifying the principal risks faced by
Napier Port and taking reasonable steps designed to ensure that appropriate
internal controls and monitoring systems are in place to manage and, to the
extent possible, reduce the impact of these risks, including material climate-
related risks.
• The Board receives reports and recommendations from, and has access
to management reports provided to, the Audit and Risk Management
Committee, in relation to Napier Port’s overall risk management framework,
and reviews the Risk Management Policy annually.
• The Board is also responsible for setting the strategic direction of Napier
Port. This includes ensuring that the environmental, social and governance
risks and opportunities in Napier Port’s sustainability strategy, including
climate-related risks and opportunities, are integrated into the Group’s
long-term strategy and investment decision making.
• The Board receives reports and recommendations from and has access
to management reports provided to the HSSC, and reviews the HSSC
Charter annually.
Figure 1. Governance of climate-related risks at Napier Port
AUDIT AND RISK
MANAGEMENT COMMITTEE
• Ensures that management is implementing Napier Port’s
overall risk management framework and policy.
• Monitors corporate risk assessments and ensures internal
controls are implemented.
• Reports to the Board whether Napier Port’s overall risk
management framework and processes are sufficient.
• Responsible for overseeing the assessment of financial and
economic impacts within the disclosures that relate to the
expected physical and transitional impacts of climate change.
• Overall responsibility for the relevant internal controls
and external review and audit processes in relation to the
preparation of the Climate Change Related Disclosure Report.
conducted in accordance with Napier Port’s
Risk Management Policy.
The General Manager – Assets and
Infrastructure has overall responsibility for
the development and implementation of
the sustainability strategy, including the
assessment of climate-related risks and
opportunities and reports on progress to the
HSSC.
Board and management utilise external
advice and expertise for climate-related
issues where appropriate.
Remuneration policies for the CEO and
Senior Management Team are outlined in the
Governance Statement in the 2025 Annual
Report (page 77), and for the CEO and
certain executives includes remuneration
linked to the achievement of sustainability
strategy related objectives.
The different levels of responsibilities and
the supporting Risk Management Policy that
governs the management of climate-related
risks at Napier Port are illustrated in figure 1.
s1
Governance
NZ CS requirements:
• Describe the board’s oversight of climate-related risks and opportunities
• Describe management’s role in assessing and managing climate-related
risks and opportunities
P4
2025 CLIMATE CHANGE DISCLOSURE REPORT
P5

Napier Port’s Risk Management Policy
provides the overarching framework for
identifying, assessing, managing and
monitoring risk at Napier Port, including
climate-related risks and opportunities. Each
Napier Port business unit is responsible
for establishing and maintaining risk
documentation to monitor and report risks that
threaten achievement of business objectives.
The Chief Executive and Senior Management
Team are responsible for ensuring that risks
to the business are identified and evaluated,
that effective responses and control activities
are developed, and appropriate monitoring
and timely re-evaluation is conducted. The
Chief Financial Officer, working with senior
management, updates the Napier Port
enterprise risk register, drawing on business
units’ documentation, and reports this
register to the Audit and Risk Management
Committee at least on a six monthly basis.
An output of the CCRA process is a
climate-related risk register specifically for
the management of climate-related risks
and opportunities. Napier Port has also
benchmarked this against recommendations
of the NZ CS, IFRS S2 and the TCFD for
identifying and assessing climate-related
risks.
Napier Port’s Assets & Infrastructure team
which includes environmental & sustainability
subject matter experts, supported by others
as required, are tasked with staying up-to-
date with the latest climate-related research,
facilitating regular risk assessments and
performing detailed climate change analysis.
The Board and Management of Napier Port
are also continually monitoring developments
to existing and emerging regulatory
requirements related to climate change as
part of their risk assessment processes.
In November 2020, Envirolink, Gisborne
District Council, and Hawke’s Bay Regional
Council collaborated to commission a
review of climate change projections and
their impacts on the Tairawhiti (Gisborne)
and Hawke’s Bay regions. This was
conducted by the National Institute of Water
and Atmospheric Research (NIWA)
1
and
was used as the basis for the scenario
analysis contained within our original 2021
financial year report. For our subsequent
reports, Napier Port has incorporated
new data from various sources including
the Intergovernmental Panel on Climate
Change (IPCC)
2
, and the recently released
2025 Hawke’s Bay Climate Change Risk
Assessment. These data sources have a
direct or indirect impact on the identification
of Napier Port’s key climate related risks
and helps to determine potential shifts in
sea levels, wind patterns, temperatures, and
extreme weather events. These data inputs
enable us to analyse a range of potential
future scenarios and assess how they may
affect Napier Port’s assets, operations,
financial plans, and business model.
Future climate projections strongly depend on
estimates for future global mean temperature
rise resulting from greenhouse gas
concentrations. In turn, those concentrations
depend on global greenhouse gas emissions
that are driven by factors such as economic
activity, population changes, technological
advances and policies for mitigation and
sustainable resource use. Napier Port
now uses the IPCC’s more recent Sixth
Assessment Report (IPCC AR6) as its basis
for future climate change modelling and
projections. The IPCC AR6 refers to Shared
Socioeconomic Pathways (SSPs)
3
for future
projected socioeconomic global changes
used to derive greenhouse gas emissions
scenarios based on different climate policies.
SSPs are a set of scenarios that describe
different ways society might develop and how
these changes could affect future greenhouse
gas emissions. Each SSP is based on a
distinct narrative about global trends –
including sustainable development, regional
rivalry, growing inequality, and fossil fuelled
development.
For the IPCC global scale SSP modelling to
be useful for Napier Port’s CCRA process the
results need to be downscaled to a Hawke’s
Bay regional level. Complete regional climate
s2
Risk
Management
projections for Hawke’s Bay have now been
released by NIWA and subsequently adapted
into an accessible format by the Ministry for
the Environment (MfE).
Napier Port’s climate-related risk assessment
process now considers the below three SSP
scenarios based on the downscaled data that
is available.
• SSP1-2.6 is the ‘green growth’ pathway
where global warming is limited to a range
of between 1.3 and 2.4 degrees by 2100.
• SSP2-4.5 is the ‘middle of the road’
pathway where socio-economic factors
follow their trends, with no significant
change in reducing current temperature
rise projections and global warming could
increase to within a range of 2.1 to 3.5
degrees by 2100.
• SSP3-7.0 represents the ‘regional rivalry’
pathway where rising nationalism and
regional conflicts lead countries to focus
more on domestic or regional issues.
Environmental policies receive little global
attention, causing serious damage in some
areas. Global warming could increase to
within a range of 2.8 to 4.6 degrees by
2100.
These three scenarios were chosen to align
with NZ CS, which requires three scenarios to
be analysed:
• one where global temperature increase
is limited to 1.5 degrees Celsius (with an
emissions pathway aligned to SSP1-2.6),
• another where the temperature is 3
degrees Celsius or greater (aligned to
SSP3-7.0),
• a third scenario of the reporting company’s
choice. Napier Port has chosen a scenario
which looks to limit global temperature
increases to a range between 2.1 and 3.5
degrees Celsius (aligned to SSP2-4.5).
The reason for choosing this pathway is
that SSP2-4.5 has been recognised by
members of the climate science community
as a most likely pathway to eventuate out
of the five SSPs
4
.
For climate-related risk management, we
believe a medium to long-term horizon is
appropriate. This time frame is aligned with
the economic lives of our infrastructure
assets and Napier Port’s asset management
plan. As a result, we have used the following
timeframes to assess the likelihood of
climate-related risks and opportunities
occurring under each scenario: Short-term
0-20 years (using SSP scenarios up until
2040); Medium-term 20-70 years (using SSP
scenarios up until 2070); and Long-term 70
plus years (using SSP scenarios up until
2100).
In accordance with Napier Port’s Risk
Management Policy, we assess the
significance of each identified climate-related
risk using a likelihood and consequence
matrix. The climate-related risk register
assesses the likelihood of risks occurring
during the short-term, medium-term and
long-term timeframes outlined above,
to recognise the longer-term nature of
climate-related risks. This varies from the
overall risk management framework which
assesses the likelihood of a risk occurring
based on whether it is probable to occur
within the next 12 months. For both,
the consequence of the identified risk is
assessed based on the potential level of
impact on our people, assets/infrastructure,
operations and systems, environment,
reputation and financial planning. Based
on the likelihood and consequence, levels
of risk are categorised as either very high,
high, moderate or low. This allows us to
determine the appropriate response for
each issue identified. Climate-related risks
and opportunities are assessed annually
to ensure they continue to reflect material
changes in our knowledge, business strategy,
and operating environment.
Napier Port’s CCRA includes parts of its
value chain outside the operational control
of its business. This includes climate change
impacts affecting our key local growers and
upstream transportation links. However, there
are parts of the value chain that are excluded
based on immateriality and/or data collection
complexity. For further value chain inclusions
and exclusions, refer to the scope 3 tables
found in the metrics and targets section of
this report.
During 2025, using the process described
above, we updated our Climate Change
Risk Assessment – looking at infrastructure
resilience, trade forecasting, land levels,
weather conditions, emergency preparedness
and habitat modification. The current
assessment has identified 69 climate-
related physical and transition risks and 24
opportunities. An overview of the top physical
and transition impacts is contained in our
strategy disclosures section.
Climate-related risks and opportunities are
assessed annually to ensure they continue
to reflect material changes in our knowledge,
business strategy, and operating environment.”
NZ CS requirements:
• Describe the organisation’s processes for identifying and assessing climate-
related risks (for both transition risks and physical risks)
• Describe the organisation’s processes for managing climate-related risks
• Describe how processes for identifying, assessing and managing climate-related
risks are integrated into the organisation’s overall risk management
P6
2025 CLIMATE CHANGE DISCLOSURE REPORT
P7

s3
Strategy
NZ CS requirements. An entity must disclose:
• A description of its current climate-related impacts
• A description of the scenario analysis it has undertaken
• A description of its climate-related risks and opportunities
it has identified over the short, medium and long-term
• A description of the anticipated impacts of climate-
related risks and opportunities
• A description of how it will position itself as the
global and domestic economy transitions towards
low emissions, climate resilient future state
Our Purpose
INPUTS
What we rely on to operate our business
OUR STRATEGY
How we use these inputs to create outcomes
Together we build a thriving region
by connecting you to the world
Strategic Pillars
Embedded
Our Foundation
Relationships
Our strong relationships with stakeholders
– cargo owners, shipping lines, transport
partners, local community, iwi – give us our
social licence to operate and grow.
Skills and knowledge
Our deep expertise in port operations and
logistics, and the creation of technology
solutions for our business and our customers.
People
Our motivated and engaged workforce, who
have pride in their work keeping the cargo
flowing across our wharves.
Financial
Financial capital provided by our
shareholders and debt funders.
Physical assets
Our assets and infrastructure, including port
land, wharves, sea defences, dredged shipping
areas, marine and heavy plant fleet, and inland
ports.
Natural environment
The marine and natural environment and how
we work within it alongside stakeholders and
our community is fundamental to our business.
OUTCOMES
What we aim to create
Community
We enhance our local community by being a
good corporate citizen, providing employment
and supporting community and iwi initiatives.
Environment
We support the maintenance and
enhancement of our marine environment and
our environmental stewardship and impact.
People
We provide purposeful and safe employment
and development opportunities for our people.
Financial
We provide economic returns to our
financial capital providers.
Infrastructure
We maintain and add to our infrastructure for
the benefit of current and future generations.
Economic
We enable and enhance our regional economy,
including significant industries, businesses and
individual operators.
The diagram below depicts Napier Port’s strategy and how we create value for all stakeholders.
Our Purpose
Strategy drives everything we do at Napier Port: how
we manage and operate our assets, how we provide
innovative solutions to customers, and how we partner
with our suppliers and operate within our community
and environment.
This year we undertook a comprehensive strategy
refresh process to prepare for the challenges and
opportunities we could face over the next decade –
looking out to 2035.
Our purpose remains the same: Together, we build a
thriving region by connecting you to the world.
Our four pillars have been enhanced and refocused to:
• Growing our Port Plus+ - Grow value for
customers and ourselves.
• Delivering Excellence to the Core - Profitable,
sustainable business operations.
• Building Alliances - Achieving more together
and where it matters the most; and
• Learning and Leading Port - Adopting
technology and embracing innovation.
Sustainability and future climate resilience is a core
part of Napier Port’s business model and is integrated
into our strategy. Sustainability principles are
continually being embedded throughout all areas of
our business.
Our business is also exposed to climate-related risks
outside our port gate, including transport links and
the impact of climate change on our community and
customers. We work collaboratively with relevant
territorial authorities and community groups, sharing
information and developing solutions, to deliver a more
resilient business and region.
Napier Port recognises that climate change is currently
impacting the way we operate, as outlined on the
following pages.
Refreshing Our
Strategic Framework
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2025 CLIMATE CHANGE DISCLOSURE REPORT
P9

Napier Port also has a focus on improving work practices which reduce fuel usage
across its mobile fleet of assets which in turn has contributed to a reduction in future
carbon emissions. Examples of successfully implemented work change initiatives
include:
Reducing fuel usage of tugs:
Tug boats are the largest single consumer group of fuel at Napier Port,
consuming between 11,500 – 14,500 litres of fuel per month on average.
With the next tug replacement not expected in the short term, more efficient
tug operating practices have been put into operation to reduce the carbon
footprint of our tug fleet of 3 vessels.
These initiatives include:
• Prioritising the use of the most fuel efficient tug whenever possible;
• Switching to synthetic shorelines to reduce the amount of pushing
required by tugs during berthing manoeuvres; and
• Reducing the number of moves required during a vessel visit.
It is estimated the outcome of these operational initiatives has contributed
approximately 198 tCO2e in reduced fuel emissions to date.
1
Reducing container operations fuel usage:
Key initiatives actioned in this area include:
• Reductions in the amount of engine idle time across the forklift and light
vehicle fleet. This has been achieved from insights generated from our
integrated Internet of Things (IOT) system which highlighted an elevated
engine idle time across our container operations fleet and a positive
change in operator behaviour;
• Terminal optimisation and planning changes to reduce transit distances
i.e. the distances a forklift needs to travel between a container stack and
the vessel loading point;
• Machine deployment optimisation lowering emissions through use of
optimum machine e.g. smaller, lower emitting machinery can be used
for moving empties (empty container handlers) and reserving the use of
large machinery (reachstackers) for full containers. This has created an
opportunity to further reduce fuel usage by an approximate 10 litres per
hour on an empty container handler vs legacy reachstacker machine.
Terminal optimisation and machine deployment initiatives are interim
measures being utilised until the new autonomous electric vehicle operating
model is delivered.
2
The impacts of severe weather events such as extreme rainfall and tropical cyclones
(like Cyclone Gabrielle) can have an adverse impact on our insurance renewal
programme for our material damage and business interruption policies. As a result
of Cyclone Gabrielle trading losses incurred by Napier Port, policy premiums and
insurance capacity have been negatively affected, however the direct financial impact
on insurance is not determinable.
Current impacts of climate change
Current physical climate impacts
Tropical Cyclone Gabrielle in February
2023 caused widespread flooding and
property damage to the Hawke’s Bay region.
Although the physical impact on Napier Port’s
infrastructure was not significant, it was a
reminder of the devastating impact severe
weather events can have and the potential
consequential effects arising from this.
Flooding and infrastructure damage outside
the port gate resulted in decreased cargo
being exported from the region via our port.
Such losses represented millions of dollars of
lost earnings for Napier Port. There were no
physical climate impacts to disclose in 2025.
Current transition climate impacts –
Including impacts on Napier Port’s
business model and value chain
As part of its asset management programme,
Napier Port continues to assess how it can
utilise technological advancements and
alternative equipment choices to shift its
fuel intensive heavy equipment and marine
fleet assets towards lower emission and
more energy efficient options. However, in
most cases the procurement of ‘greener’
equipment carries additional cost premiums
when compared with the traditional internal
combustion engine equivalent. For example,
Napier Port introduced five new Eco
Reachstackers into the container handling
mobile plant fleet during 2025 and each carry
a capital cost premium of approximately
15% over the price of the base model
reachstacker.
Napier Port will continue to consider a broad
range of objectives including the financial
implications and its obligations as a lifeline
asset and significant regional infrastructure
as it considers pathways and the timeframes
it adopts to transition its mobile plant
equipment and marine assets.
Capital expenditures will be financed
according to its long-term planning and from
its general balance sheet. Additionally, Napier
Port has established a Sustainable Finance
Framework to source forms of sustainable
financing to fund eligible sustainability
expenditures and assets where the criteria
is met.
During 2025 Napier Port commenced a
transformation project which will significantly
change the operating model within its
container terminal and is one of the key
emissions reduction enablers to help Napier
Port meet its 2050 net zero emissions
commitment.
This project will see the introduction of
battery electric autonomous truck and
trailers to undertake horizontal transport of
containers within the boundary of Napier
Port. The project is expected to be completed
during 2027. Once completed the project is
expected to significantly reduce overall diesel
fuel usage and carbon emissions across
our mobile plant fleet, while also lowering
annual maintenance costs as our container
handling forklifts will be used more in line with
their intended design due to shorter travel
distances.
During 2025 Napier
Port commenced
a transformation
project which will
significantly change
the operating model
within its container
terminal and is one
of the key emissions
reduction enablers
to help Napier Port
meet its 2050 net
zero emissions
commitment.”
Terminal
optimisation and
machine deployment
initiatives are interim
measures being
utilised until the new
autonomous electric
vehicle operating
model is delivered.”
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2025 CLIMATE CHANGE DISCLOSURE REPORT
P11

Physical Risks
Climate change related effects result in several risks to Napier Port infrastructure, due to its coastal location and susceptibility to sea level
rise. All our tangible assets are susceptible to physical risks today, including from acute weather and natural disaster events. Climate change
modelling indicates that higher temperatures will increase the likelihood of extreme weather events that may affect operations and damage
infrastructure and there will be ongoing impacts of sea-level rise, extreme rainfall, and intensifying tropical cyclones which may cause coastal
inundation, erosion and flooding. Napier Port’s breakwater and sea defence asset (our largest infrastructure asset with a net book value of
$161m in 2025) is the most exposed to the impacts of climate change and accordingly forms an important part of our assessment of future
physical climate risks.
The physical impacts of climate change considered most material to Napier Port are described below:
i) Increase in sea level
One of the major and most certain
consequences of increasing concentrations
of atmospheric greenhouse gases and
associated warming is the rising sea level.
SSP scenario modelling has confirmed the
pace of sea level rising is also accelerating.
Interim guidance on the use of sea level
rise projections from the Ministry for the
Environment
5
recommends using data from
the NZSeaRise research programme, which
uses SSP sea level data on a localised scale
across New Zealand. These projections
include not only sea level rise (SLR) (relative
to 2005), but also vertical land movement
(VLM), from satellite data, at 2km spacing
across all of NZ’s coastlines. By combining
both SLR and VLM, we can understand
relative sea level rise (RSLR).
There are three sites in NZSeaRise within
the Napier Port footprint and these sites are
reported subsiding at an average rate of
2.83mm/year (2.7-3.0mm/year). When this
rate of VLM is combined with the various
rates of SLR, dependent upon the emissions
scenario, overall RSLR is higher.
With sea levels continuing to rise, even
under low emission scenarios, there is high
confidence in the increased frequency and
severity of coastal flooding
6
.
In respect of extreme coastal flooding, in
the short term (2040), there is no difference
seen between different SSP pathways
and inundation risk remains manageable.
However, projected temporary inundation in
a one in one-hundred-year event shows the
previously identified northern log yard areas
experiencing greater levels of inundation
corresponding with escalating temperature
over time. This trend expands under all SSPs
in 2070, and eventually, in 2100 under all
SSPs, coastal flooding projections show a
large portion of the Napier Port site could be
potentially impacted during a one in one-
hundred-year event.
Furthermore, as sea levels rise, high-energy
waves that strip sediment can reach higher
up the shoreline and cause erosion
7
. Due
to the nature of Napier Port, being built
directly on the coast, coastal erosion could
cause loss of usable land area and damage
to existing infrastructure if not prepared for.
Among the three beach areas within the
port boundaries, risk exposure is materially
present within the two easternmost stretches.
Whilst these areas undergo continuous
natural movements due to wave action,
these areas serve as natural sea defences,
safeguarding critical structures and
operational zones from potential inundation.
In 2025, the establishment of a rock bag
revetment structure was completed in the
eastern beach area between the Plant
Services workshop and eastern Security hut
providing protection for infrastructure against
coastal erosion. Climate-related risks such
an anticipated rise in RSLR, coupled with
heightened cyclone/rainfall intensity, are
expected to increase erosion forces in this
area. In the long-term a more substantial hard
structure may be required in this and other
similar areas to provide long-term protection.
Risk Driver: Increase in Sea Level (RSLR)
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeMedium to Long-term
Financial Implications
Fortification of eastern boundary sea defences: $6-100 million (depending on the extent of engineered structure – can
range from flexible rock bag solutions to establishing a land based breakwater sea defence)
Methodology
Potential financial impact is estimated capital expenditure required, based on current civil construction costs in today’s
money
Risk Mitigation
• Northern log yards may eventually need to be further developed to raise the level of pavement
• Ensure the western reclamation area is developed to levels to meet future extreme sea levels due to climate change
• Detailed investigation and potential design of sea defences to provide long-term protection in the eastern beach area
where a more substantial hard structure may be required in these areas and other similar areas in the long term
For Napier Port, a warmer world in 2100
consistent with the SSP3-7.0 scenario would
result in potential physical impacts on our
infrastructure, create uncertainties as to how
our region would be affected and be required
to adapt, and what our business may look
like as a result. The transition impacts of
climate change caused by strong climate
action policy will also create a mix of risks
and opportunities for our business. We have
identified and assessed these risks and
opportunities, undertaking analysis of the
potential impacts for our business.
The physical and transition risks included
below are from Napier Port’s latest CCRA
and are rated very high, in accordance with
the risk management policy and specific
climate-related timeframes noted above. This
assessment is based on the likelihood of the
risk occurring (likely or almost certain) and
consequence (greater than $5 million), in at
least the SSP3-7.0 scenario in the medium
to long-term. Under SSP2-4.5 (3 degrees or
lower scenario), these risks are also present,
although they would manifest themselves at
a later date.
From the analysis undertaken, at this
stage, we do not consider that the effects of
climate change materially change our overall
strategy. Sustainability will continue to be
embedded into our ways of working as we
continue to collaborate to look after people,
planet and place, including completing
the actions contained in our sustainability
strategy.
The more financially material infrastructure
improvement actions are required over
the medium to long-term to ensure that
we continue to have a resilient and agile
infrastructure network. Planning to address
this is being embedded within our overall
infrastructure masterplan. In the short-term,
we will continue to complete more detailed
investigations of climate-related effects and
ensure these are considered in Napier Port’s
master planning process.
To support our sustainability strategy action
plan implementation we include climate-
change considerations within Napier Port’s
procurement processes and policies. This
involves consideration of alternative lower
emission options related to plant and
equipment procurement and, in the case
of more significant investment business
cases, emission scenario and financial
analysis including the consideration of
shadow emission pricing. Work in these two
respective areas continues to progress as
new information comes to hand.
Future impacts of climate change
2025 CLIMATE CHANGE DISCLOSURE REPORT
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ii) Extreme rainfall events
Climate change is expected to result in an
increase in the frequency and intensity of
extreme rainfall events. The NIWA report
notes that short duration rainfall events have
the largest relative increases compared with
longer duration rainfall events. Rainfall depths
for 1-in-50 year and 1-in-100 year events
are projected to increase across the SSP
scenarios and future time periods
8
.
Napier Port has seen minor issues with storm
water management in recent years due to
extreme rainfall events that the systems were
not designed for. The storm water system
will be further compromised by sea level
rise with more outlets likely to be below sea
level which impacts the system’s ability to
discharge effectively resulting in backing
up of storm water. This is likely to result in
inundation if the extreme rainfall coincides
with extreme sea levels. Detailed modelling
is to be completed to better understand the
system capacity both currently and under
future scenarios so appropriate plans can be
put in place. Likely options include additional
drainage networks or pumping stations.
Risk Driver: Extreme Rainfall Events
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeLong-term
Financial Implications$5-$10 million
Methodology
Potential financial impact is estimated capital expenditure required based on the installation of two pumping stations
and current civil construction costs in today’s money
Risk Mitigation
• Modelling of the stormwater system capacity under future scenarios
• Assess capacity of the outer breakwater drain under future scenarios and increased frequency of drain cleaning
• Likely mitigation options could include additional drainage works or pumping stations
iii) Tropical Cyclones
Tropical cyclones are predicted to be more
severe under all temperature scenarios, yet
there is still a large amount of uncertainty
on the changes in frequency of tropical
cyclones
9
. Potential damage caused by
tropical cyclones can be quantified using
the power dissipation index (PDI), which
considers maximum sustained wind speeds,
and the distance/time the cyclone has
travelled. Projections for future severity of
cyclones aligned with SSP findings show
increases across all scenarios, with the
greatest increase in PDI seen in SSP3-7.0
(19%).
The implications of Cyclone Gabrielle
provided insight into the susceptibility of
Napier Port’s breakwaters and sea defences
to damage. Anticipated synergies between
relative sea level rise and the amplification
of cyclone PDI appear to forecast an uptick
in the magnitude of damage sustained per
event. Such powerful weather events have
the potential to dislodge or displace the
Risk Driver: Increase Tropical Cyclones
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeMedium to Long-term
Financial Implications$10-$15 million
Methodology
Potential financial impact is estimated capital expenditure planned plus potential enhancements in the medium term,
based on current civil construction costs for shore protection in today’s money
Risk Mitigation
• The akmon unit “top-up” program is embedded within the Asset Management Plan and the post cyclone breakwater
reinstatement works was completed during 2025 at a total cost of $2.5 million
armour units (akmons) that help protect the
breakwater structure.
With a projected increase in cyclone PDI
for storms arriving at Napier, proactive
maintenance through a program of continual
akmon renourishment is required, not only for
dissipating wave energy and upholding the
structural integrity of the breakwater itself, but
also for the protection of the infrastructure
sheltered behind it.
Transition Impacts
The transition impacts of climate change caused by strong climate action policy are also a mix of risks and opportunities for our business.
Government regulation to encourage a shift to a low carbon economy (like the Aotearoa New Zealand Emission Reduction Plan) may result in:
• increased fuel costs particularly for Napier Port’s mobile plant;
• requirements to invest in new technologies, equipment and supporting infrastructure to move away from diesel powered plant; and
• policies to increase the use of rail which may require additional infrastructure investment and changes to Napier Port’s operating model.
The transition impacts considered most material to Napier Port are:
i) Government Regulation to Encourage a Shift to a Low Carbon Economy Resulting in Higher Fuel Costs
Government policy may increase emissions taxes on fuel by greater amounts to encourage the significant reduction in emissions required to
achieve net zero emissions by 2050. This will likely increase diesel fuel costs and operating costs for Napier Port which is currently reliant on
diesel fuel to power tugs, mobile harbour cranes, and container handling equipment. By way of illustration using 2025 data, a $0.20 per litre
increase in the cost of diesel would increase operating costs by approximately $0.5 million per annum.
The higher fuel costs may encourage the shift to alternative fuels throughout the region which may ultimately reduce the fuel imported through
Napier Port and the revenue that this generates.
Risk Driver: Government Regulation to Encourage a Shift to a Low Carbon Economy Resulting in Higher Fuel Costs
ScaleHigh to Very High
LikelihoodModerate risk in short term. Almost certain in medium to long term
TimeframeShort to Medium term
Financial ImplicationsUnknown impact and timing
Risk Mitigation
• Ensure fuel price escalation risk is considered in forecasting
• Implementation of sustainability strategy actions to reduce dependence upon and quantities consumed of diesel fuel
ii) Government Regulation to Encourage
Shift to Alternative Fuels
Combined with the above it is highly likely
there will be government policy to either
ban, limit the procurement of, or otherwise
disincentivise the use of, internal combustion
engine powered machines and encourage
a shift towards machines powered by
renewable and low emission energies (e.g.
electricity, hydrogen). It is expected that
import restrictions will precede any outright
ban of diesel equipment, which will provide
some time to adapt.
Napier Port is expected to transition in a
planned orderly way with emission reduction
pathways under development as part of the
wider sustainability strategy and through
targeted emission reduction plans. The
transition triggers are likely to be a mix of
fuel and other price pressures, investment
cycles, the availability of alternative energy
equipment able to deliver comparable
operational capability and resilience.
The development of the required
infrastructure is expected to occur over a
longer period and require additional capital
investment.
Our Electrical Master Plan outlines a pathway
to meet future electrical demand. There are,
however, numerous policy risks which may
affect the electrification programme:
• A ban on the importation of diesel
equipment within a short timeframe
may result in the need to accelerate
infrastructure investment, uneconomically
extending the lifetime of existing plant or
affecting expansion aspirations;
• An early ban in the importation of diesel
equipment may result in effective and
reliable alternative low emission options
not being readily available;
• Policy that results in dramatic increase
in fuel price may result in earlier than
expected move to an electric fleet. If
electrical infrastructure is not available,
continued use of internal combustion
engine powered equipment may result in
higher than desired operating costs.
Failure to consider transitional climate-related
risks throughout an asset’s lifecycle during
procurement may lead to stranded assets in
the future whereby either the fuel required
to operate them is either unavailable or cost
prohibitive or equipment becomes technically
obsolete and unserviceable. In particular,
key plant such as tugs and mobile harbour
cranes have operating lives of up to 30 years.
To manage this transition risk, Napier Port’s
Procurement Policy requires consideration
of ESG factors alongside economic factors
in significant expenditure and procurement
decisions. Additionally, our approach to asset
management ensures periodic reviews are
undertaken to evaluate aspects such as
remaining useful life, and the residual value
of key assets potentially impacted by climate-
related pressures.
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Risk Driver: Government Regulation to Encourage Shift to Alternative Fuels
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeMedium to Long-term
Financial Implications
Unknown impact and timing
The 2025 net book value of diesel powered plant held by Napier Port is $49 million
Potential electrical infrastructure upgrades: $25 to $35 million
Risk Mitigation
• Consider flexibility in electrical infrastructure development as part of the Electrical Master Plan
• Consider future fuel cost risk and other ESG matters in equipment purchasing and investment business cases
• Consider equipment that can be retro-fitted in investment decision making process
• Regularly assess the remaining life and residual value of key equipment because of climate-related changes
iii) Rail
Rail transport typically has significantly
lower emissions per tonne compared to
road freight, and provides other benefits, in
particular reducing the number of trucks on
New Zealand’s roads. In the short-term, a
lack of national and regional rail infrastructure
is and will remain a major hindrance to a
significant step change in the use of rail.
Risk Driver: Government Regulation to Encourage Increased Use of Rail
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeLong-term
Financial Implications$10-$15 million
Financial ImplicationsPotential financial impact is a high-level estimate of capital expenditure required, in today’s money
Risk Mitigation
• Changes to Napier Port’s operational layout in line with existing provisions in the Master Plan to increase our on-port
rail infrastructure
• Further consideration of climate change related effects will be included in Napier Port’s master planning process
iv) Commercial and regional climate impacts
Napier Port’s performance is strongly linked
to the strength and resilience of the Hawke’s
Bay regional economy. With around 80% of
Napier Port’s cargo made up of exports—
predominantly from local primary industries—
it is important to understand how climate
change could affect these sectors and, by
association, future port activity.
Whilst the extent of potential impact is not
conclusive, climate change is expected to
influence land-based production by affecting
the quantity, quality, and types of crops and
forestry products that can be grown and
harvested. Increased weather variability
is likely to cause greater year-to-year
fluctuations in yields, while long-term changes
in temperature, rainfall, and sea level will
In the medium term, it is likely that road
transport will continue or accelerate the
adoption of green energy technology to
reduce their emissions.
In the long-term (70+ years), it is expected
that New Zealand’s rail network will be
effectively emission free, running on
alternative fuels such as hydrogen for long
haul routes or potentially a fully electrified
network, which may result in a significant
uptake of rail. A significant increase in cargo
transported by rail would require changes
in Napier Port’s operational layout and
associated infrastructure investment.
alter the regional suitability for different
commodities.
Acute hazards such as flooding, landslides,
and coastal inundation, alongside shifting
pest and disease pressures, will pose
additional risks to agricultural, horticultural,
and forestry operations
10
. Rising sea levels
may also gradually reduce the area of land
available for primary industries in low-
lying parts of the region – especially after
considering managed retreat for residential
activities.
Forestry, agriculture and horticulture are
all significant primary industries within the
Hawke’s Bay region accounting for around
9% of regional GDP and 12% of the regional
workforce
11
. Napier Port plays an important
role within these industries, by connecting
suppliers with international customers.
These sectors are vulnerable to the impacts
of climate change (i.e. potential increases
in rainfall intensity, mean temperatures
and drought severity). While changes in
production may not directly affect Napier
Port, there is a significant indirect risk to
revenue should these industries suffer from
the effects of a changing climate. While
these risks are significant, they can be partly
managed through proactive adaptation—
such as changing crop types, improved land
management, and resilient infrastructure.
a) Forestry
The Hawke’s Bay region supports
approximately 165,000 hectares of plantation
forest, dominated by Pinus radiata, the
country’s primary commercial timber species.
In 2025, around 2.7 million tonnes of logs
were exported through the Port of Napier
and logs make up approximately 66% of total
exported cargo by weight.
Gradual shifts in climate, coupled with
rising atmospheric CO
2
concentrations,
are projected to provide moderate gains
in forestry productivity for some sites by
increasing photosynthesis and extending the
growing season.
12
Warmer temperatures
can also increase the rate of organic matter
decomposition and nitrogen mineralisation,
improve soil fertility and support tree growth.
13
However, benefits may be offset by the
increasing frequency and severity of extreme
weather events, such as storms, high
intensity rainfall, flooding, and landslides.
14

Such hazards pose a significant risk to
plantation forests by damaging tree stands,
increasing erosion and sedimentation,
compromising access roads and harvesting
infrastructure, and raising operational costs.
As climate risks intensify, adaptive forest
management practices and infrastructure
planning will be required to maintain
productivity and protect asset value across
the region’s forestry sector. The anticipated
climate change effects on the Hawke’s
Bay forestry industry are linked to SSPs as
outlined in the table below. However, the
future financial implications of these climate
impacts are still to be determined.
Table - The anticipated climate change effects
on the Hawke’s Bay forestry industry under
different SSPs.
15
Forestry
SSP1-2.6
• Increased productivity due to longer growing season and increased CO2 availability
• Some drought stress but manageable
• Fire risk elevated but moderate
• Landslide and flood risk low, localised slips still possible
• Extreme weather events infrequent but isolated windthrow damage possible
SSP2-4.5
• Drought stress increase particularly for east-facing slopes
• Fire risk increases
• Increased CO2 may partially offset losses
• Pest and disease pressure increases with warmer winters
• More frequent landslides, flooding of forest roads and culverts
• Increased frequency of storms/strong wind events causing windthrow and localised damage
SSP3-7.0
• Productivity declines, particularly on shallow or lower quality soils
• Pest incursions increase
• Reduced economic viability of dry sites
• Higher risk of severe erosion, landslides, flood damage and damage from more frequent severe storms/cyclones
2025 CLIMATE CHANGE DISCLOSURE REPORT
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Risk Driver: Drought - commercial and regional climate impacts
ScaleHigh to Very High
LikelihoodAlmost certain
TimeframeMedium to Long-term
Financial Implications
$15-$20 million
Trade loss exposure estimated as 15%-25% of annual (TEU) exports
Methodology
Potential financial impact is an estimate of the annualised impact on trade volume in today’s dollars assuming a
complete loss of current refrigerated container trades without replacement by other substitute produce
Risk Mitigation
• Napier Port has limited direct control in managing this risk. Napier Port will keep an active interest in potential
impacts and how that might change export volumes, shipping patterns and changes in exports through our ongoing
engagement with cargo customers, and in our master planning process
Transition Opportunities
Addressing climate change potentially offers various chances for growth and improvement. These include the opportunity for Napier Port to
become more resource-efficient, using cleaner energy sources, creating innovative service offerings, and enhancing supply chain resilience.
Opportunities may include a reduction in recurring expenses over the long term or additional revenue streams from requirements for ships to
use shore power while in port and opportunities to partner in the supply chain to provide low carbon or zero emission solutions for customers.
Additionally, climate change might create new opportunities as crops dynamically shift, allowing the horticulture sector to cultivate new thermally
resistant species and varieties. Napier Port considers that if climate change alters the primary sector, crop substitution opportunities will become
available.
b) Horticulture
The top five horticultural crops in Hawke’s
Bay are apples, wine grapes, squash, peas
and beans, and onions. In 2025, apples made
up around 7% of exported cargo managed by
Napier Port.
Projected temperature increases are
expected to negatively affect growth rates
and growing seasons, as well as crops’ ability
to take up water, likely resulting in damaged
crops or reduced quality.
16

Adaptation will require a combination of short-
and long-term strategies to maintain the
region’s horticultural productivity. Growers are
already investing in improved water storage
and irrigation efficiency, trialling new crop
varieties better suited to warmer conditions,
and strengthening on-orchard resilience to
extreme weather events through protective
infrastructure and improved drainage.
Continued investment in research, water
storage, coordinated biosecurity measures,
and proactive land-use planning will be
critical to ensure the sector remains viable as
climate risks intensify.
17
Climate effects on the Hawke’s Bay
horticulture industry are linked to SSPs
outlined in the table below. However, the
future financial implications of these climate
impacts are still to be determined.
Table - The anticipated climate change effects
on the Hawke’s Bay horticulture industry
under different SSPs.
18
Horticulture
SSP1-2.6
• Longer growing seasons may benefit some crops (such as apples and grapes)
• Increased disease and pest pressure
• Water availability relatively stable if effective water management and moderate rainfall changes
• Fewer frost days impacting crops that need winter chilling
• Occasional extreme rainfall events may cause local flooding and soil erosion
SSP2-4.5
• Significant increase in summer heatwaves; possible heat stress and sunburn damage to fruit crops (pip fruit, grapes, berries)
• More droughts place pressure on irrigation
• Higher pest and disease risks
• Reduced winter chilling may lower fruit set for pip fruit and stone fruit
• More frequent extreme weather events, including storms and heavy rainfall, may damage orchards and infrastructure
SSP3-7.0
• Frequent extreme heat events damage fruit quality and yields
• Severe water scarcity due to prolonged droughts
• Major winter chill deficits for pip fruit and stone fruit
• Increased pest/disease burden, including subtropical pests
• Market quality and export reliability are at risk
• Severe storms and extreme rainfall events could cause significant crop losses, flooding, erosion, and infrastructure damage
c) Agriculture
Drought, in particular, has been highlighted as one of the key risks for Hawke’s Bay, with some of the largest increases to the annual number
of days of soil moisture deficit compared to other parts of the country
19
. The largest impact is expected to be in the meat industry due to the
sector’s strong dependence on reliable water availability and consistent pasture growth makes it particularly vulnerable to climate variability and
long-term changes in rainfall patterns, drought frequency, and temperature extremes. Increased droughts coupled with occasional heavy rainfall
could have major adverse effects on soil stability.
Climate effects on the Hawke’s Bay sheep and beef farming industry are linked to SSPs outlined in the table below.
Table - The anticipated climate change effects on the Hawke’s Bay agriculture industry under different SSPs.
20
Agriculture
SSP1-2.6
• Pasture growth may show slight improvement due to longer growing seasons and increased CO2 availability
• Water availability relatively stable if effective water management and moderate rainfall changes
• Slight drought stress but manageable
• Landslide and flood risk low, localised slips are still possible, which can reduce pasture availability
• Livestock productivity remains stable or slightly improved
SSP2-4.5
• Increased frequency and duration of droughts causing intermittent pasture shortages
• Greater variability in pasture growth, dry summers reducing feed availability
• Increased irrigation demand stresses water supplies
• Higher heat stress causes reduction in weight gain, fertility and increased susceptibility to disease for livestock
• Soil degradation risk increases due to more frequent drought and overgrazing during feed shortages
SSP3-7.0
• Frequent severe droughts causing major pasture deficits
• Water scarcity substantial
• Significant heat stress to livestock, causing reduced growth rates, disease, fertility and increased mortality
• Soil erosion and land degradation reduces carrying capacity
• Significant declines in overall livestock numbers
Key adaptation priorities for sheep and beef
farming include enhancing pasture resilience
through drought-tolerant forage species and
regenerative grazing, securing water via
improved storage, rainwater harvesting, and
efficient irrigation, and protecting livestock
welfare with shade, shelter, and heat- or
disease-resilient breeds.
21
The meat industry is a significant exporter
through Napier Port and drought therefore
poses a risk to revenue in the medium term
and almost certainly in the long term. In 2025,
meat made up 4% of Napier Port’s exported
cargo.
2025 CLIMATE CHANGE DISCLOSURE REPORT
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s4
Metrics and Targets
NZ CS requirements. An entity must disclose:
• The metrics that are relevant to all entities regardless of industry and
business model
• Industry-based metrics relevant to its industry or business model
used to measure and manage climate-related risks and opportunities
• Any other key performance indicators used to measure and
manage climate-related risks and opportunities; and
• The targets used to manage climate-related risks and
opportunities, and performance against those targets.
Greenhouse Gas (GHG)
Emissions Methodology
Napier Port has been measuring their GHG
emissions for several years which have been
reported in the 2025 Annual Report (page
48) and on the Napier Port website. These
emissions are classified under the following
categories:
Scope 1 – Direct GHG emissions occurring
from sources that are owned or controlled by
the company.
Scope 2 – Indirect GHG emissions occurring
from the generation of purchased electricity,
heat and steam consumed by the company.
Scope 3 – Emissions that occur because of
the company’s activities, but from sources not
owned or controlled by the company.
Since our initial report in 2021, we have
continued to refine the GHG inventory and
collect the associated data to expand the
scope of our reported emissions which
helped to establish our baseline year in
2022. From 2022 onwards Napier Port’s
reported emissions have been independently
assured as part of GHG limited assurance
engagements. During 2025 Napier Port has
added additional Scope 3 emissions that
have not been previously reported. These
can be identified along with the reasoning for
their inclusions in Table 1.
EY has provided limited assurance on
behalf of the Office of the Auditor General
on our 2025 GHG disclosures for the first
time (2022 – 2024 GHG disclosures were
How Napier Port
calculates emissions
Napier Port uses BraveGen as our GHG
emission management software. Data
is collected and uploaded monthly into
BraveGen by Napier Port staff. Emission
calculations are then based on multiplying
activity data (e.g. litres of fuel or kilowatt-hour
(kWh) electricity) by an emissions factor (EF).
The primary source of Scope 1 and Scope 2
EFs for calculating emissions data is obtained
from the Ministry for the Environment (MfE),
Measuring Emissions Guide 2025. This
edition uses Global Warming Potential (GWP)
values with a 100 year time horizon sourced
from the IPCC Fifth Assessment Report.
Scope 3 EFs are sourced from a range
of guidelines and the significant ones are
outlined below.
• MfE Measuring Emissions Guide 2025
• Market Economics (M.E.), ‘Table 5
Consumption Emissions Modelling’, March
2023
• UK Government GHG Conversion Factors
for Company Reporting (2025)
• AusLCI Carbon Emissions Factors
All these international guidelines directly or
indirectly use GWP values with a 100 year
time horizon sourced from the IPCC Fifth or
Fourth Assessment Report.
The latest relevant EF guidance available at
the end of each reporting period is used for
our full year GHG emissions reporting.
Restatement of Prior Year
Emissions
To provide consistency and comparability
across reporting periods Napier Port has
restated previously reported emissions for the
2024 comparative period. Earlier reporting
periods were not restated as the adjustments
are deemed immaterial and have no material
impact on the baseline year.
The restatement relates to transferring tenant
electricity from Scope 2 emissions and
disclosing it as part of Scope 3 emissions
under category 13 (Downstream leased
assets). There is no change to 2024 total
emissions because of the comparative
restatement.
The following table summarises the impact of
the restatement*:
Emissions Category
2024 Previously
Reported (tCO
2
e)
2024 Restated
(tCO
2
e)Change (%)
Scope 16,7856,7850%
Scope 21,012979-3.4%
Scope 39439763.5%
Total8,7408,7400%
*The restated 2024 emissions have not been subject to assurance procedures.
Napier Port Emission
Scope Boundary
The GHG emissions sources included in
our inventory were identified with reference
to the methodology in the GHG Protocol.
GHG emission sources are reported on a
comparable basis, while adding further scope
3 emission sources where they are within our
boundary, the emissions data is considered
to be material and the data is available. For
example, increased capital project activity
together with additional supplier supplied
data during 2025 has led to the inclusion
of additional scope 3 emission category
measures for capital goods and purchased
goods and services.
Organisational boundaries were set with
reference to the methodology described in
the GHG Protocol standards. Within the GHG
Protocol, Napier Port has elected to use an
operational control consolidation approach
to account for emissions. Accordingly, Napier
Port’s joint ventures are excluded due to
a lack of operational control over them i.e.
Napier Port does not have ultimate authority
to implement or change any operating
policies relating to the joint ventures. These
joint ventures are treated as Scope 3 –
Category 15 Investments but have been
deemed immaterial.
Table 1 on the following page outlines
the emission sources included in Napier
Port’s inventory, including the data source,
methodology and the assessed level of data
quality.
independently verified by Toitū Envirocare).
The 2025 unqualified GHG disclosures limited
assurance report can be found on page 32
and on our website at:
www.napierport.co.nz/sustainability/
climate-change-related-disclosure-report
Napier Port has measured its GHG emissions
in accordance with the Greenhouse Gas
Protocol: A Corporate Accounting and
Reporting Standard (2004) and the Corporate
Value Chain (Scope 3) Accounting and
Reporting Standard (together the “GHG
Protocol”).
Napier Port is also a participant in the NZ
Ports Environmental and Sustainability Group
(NZ Ports) which has established a common
approach to measuring and reporting on
carbon emissions that would fairly represent
comparable industry climate-related risks
and opportunities. An essential part of NZ
Ports work was the creation of Scope 3
GHG Emissions: Preliminary guidance for
New Zealand Ports (NZ Ports Scope 3
guidance). The NZ Ports Scope 3 guidance
relies heavily on the GHG Protocol and the
Corporate Value Chain (Scope 3) Accounting
and Reporting Standard. This guidance was
finalised during 2025 and used by Napier
Port in assessing its 2025 scope 3 emissions
inventory.
P20
2025 CLIMATE CHANGE DISCLOSURE REPORT
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Table 1- Emissions Category Inventory:
ScopeEmissions CategorySub CategoryActivityData SourceData Collection UnitMethodology, Data Quality, Uncertainty (Qualitative)
New Emissions
Included from 2025
Scope 1
Mobile Combustion
Diesel fuel for:
- Mobile plant (cranes, forklifts & trucks)
- Floating plant (tugs and pilot vessel)
- Light Vehicles
Invoice/Fuel records from
provider
LitresFuel based method. Accurate records from billing system. Low uncertaintyNo
Scope 2
Purchased Electricity
Electricity consumption (excluding tenant
electricity disclosed under category 13)
Invoice/Billing data from
supplier
kWh
Location based method. Sub metering used for billing. High quality data and low
uncertainty due to complete invoice sets.
No
Scope 3
Purchased Goods &
Services
(Category 1)
Water supply
Water consumption at all Napier Port
sites that operate within organisational
boundary
Invoice data from Napier City
Council
K/litres
Average data method. Assume all water usage use is captured on invoices. Accurate
records from billing system. Low uncertainty
No
Suppliers spend -
opex
Napier Port spend on operational/material
opex
Supplier spend records$
Basic Spend based method. Higher level of uncertainty as calculation based on spend.
Emission factors are adjusted for CPI. Emissions for suppliers with annual spend $30,000
and less was calculated using an average across the supplier emission factors used . This
category also includes GHG emissions associated with maintenance of capital goods.
Approach to emissions calculation was based on NZ Ports Scope 3 Guidance which was
finalised during 2025.
Ye s
Capital Goods
(Category 2)
Construction Projects
(Napier Port
Transformation
project)
Emissions generated from diesel fuels,
materials, freight, and waste through
significant construction project work by
contractors at Napier Port
Monthly work reports from
project contractors
Diesel: Litres
Freight: Tonne-Km
Materials: Steel: Tonnes,
Cement: Kg, Concrete: m
3

Project specific method used for Civil works part of the project. Involves collecting annual
data on fuel, electricity, and waste/materials associated with the project (excluding any
electricity or fuel already captured in Scope 1 & Scope 2) and multiplying them by material
based emission factors. High quality data and lower uncertainty due to data received
directly from contractor. Approach to emissions calculation was based on NZ Ports
Scope 3 Guidance which was finalised during 2025.
Ye s
Other Construction
Projects
(based on materiality)
Emissions generated from other material
construction projects
Contractor spend records$
Basic Spend based method. Higher level of uncertainty as calculation based on spend.
Emission factors are adjusted for CPI. Approach to emissions calculation was based on
NZ Ports Scope 3 Guidance which was finalised during 2025.
Ye s
Suppliers spend
- high value fixed
assets
Napier Port spend on high value fixed
assets
Supplier spend records$
Basic Spend based method. Higher level of uncertainty as calculation based on spend.
Emission factors are adjusted for CPI. Approach to emissions calculation was based on
NZ Ports Scope 3 Guidance which was finalised during 2025.
Ye s
Fuel and energy related
activities
(Category 3)
Fuel - Well to Tank
Emissions generated from the production
& distribution of scope 1 diesel and petrol
Invoice/Fuel records from
Fuel provider
Litres
Fuel based method. Accurate records from billing system. Medium uncertainty as EFs are
UK based. Approach to emissions calculation was based on NZ Ports Scope 3 Guidance
which was finalised during 2025.
Ye s
Electricity T&D losses
Transmission and distribution losses
associated with Scope 2
Invoice/Billing data from
supplier
kWh
Average data method. Accurate records from billing system. Sub metering used for billing.
Low uncertainty
No
Upstream transportation &
distribution
(Category 4)
Freight as a Service
Out of region cargo coming into Napier
Port via rail and road
Monthly rail freight TEU
reports from relevant
departments & Kiwirail
tkm (net tonne kilometres)
Distance based method. Medium to low uncertainty. Using MfE emission factor multplied
by calculated tkm. Data accuracy has improved with the use of Kiwirail TEU weight
information this year.
No
Waste generated in
operations
(Category 5)
Emissions associated with end-of-life
waste disposal to landfill.
Monthly reports from Waste
Management
Tonnes
Average data method. Assumed weights correct. Low uncertainty. Waste to landfill with
gas recovery EFs are used.
No
Business Travel
(Category 6)
International air travel
Air New Zealand Emissions
reports
tCO2e
Distance based method. High quality data and low uncertainty due to accuracy of reports
provided by airline
No
Domestic air travel
Employee Commuting
(Category 7)
Emissions from the use of personal
vehicles to commute to and from work
Manual data collection.
Survey completed by staff,
average distance is from
suburb using GIS mapping.
pkm
Average data method. Higher level of uncertainty due to calculation assumptions e.g. an
assumption has been made that people are commuting 5 days per week (for all available
working days). For those that have not completed the survey, it is assumed 75% drive a
petrol car and 25% diesel. High/medium uncertainty.
No
Downstream Leased
Assets
(Category 13)
Electricity onsold to Napier Port tenants
Electricity records from sub-
metering of tenant sites at
Napier Port
kWh
Average data method. High quality data and low uncertainty due to complete invoice sets.
Note - Tenant emissions were reported as part of Scope 2 purchased electricity in 2024.
Accordingly the 2024 Scope 3 comparative has been restated.
Ye s
2025 CLIMATE CHANGE DISCLOSURE REPORT
P23P22

Table 2 – Emission Inventory Exclusions:
ScopeEmissions CategoryActivityReason for Exclusion
Scope 1
Fugitive Emissions
Refrigerant used by:
Office buildings
Vehicles
Calculated to be immaterial. Less than 5% of total emissions.
High uncertainty.
Scope 3
Electricity (scope 2) -
Well to Tank
(Category 3)
Emissions generated from the production
& distribution of scope 2 electricity
Calculated to be immaterial. Less than 5% of total emissions.
Indirect GHG emissions
from transportation
(Category 4)
Fuel use associated with freight, couriers
and post of the port’s cargo
Calculated to be immaterial and is based on transport operator
spend. High uncertainty. Less than 5% of total emissions.
Indirect GHG emissions
from products used by
the organisation
(Category 5)
Waste to composting from own operations
Only applies where Napier Port has contractual ownership over any
waste sent for composting. Calculated to be immaterial. Less than
5% of total emissions.
Processing of recycled waste from own
operations
Calculated to be immaterial - less than 5% of total emissions
Wastewater treatment from own operations
and third parties operating at Napier Port
Calculated to be immaterial. Medium to high data uncertainty. Less
than 5% of total emissions
Business Travel
(Category 6)
Fuel use in rental vehicles
Fuel use in taxis
Accommodation associated with business
travel
Calculated to be immaterial. Less than 5% of total emissions
Employee Commuting
(Category 7)
Energy used by employees while working
from home
Immaterial emission source. Less than 5% of total emissions
Use of sold products
(Category 11)
Visiting vessels fuel use while within Port
boundary
Unclear emissions boundary. Very high uncertainty and no
easy way to quantify due to inaccessible data. Excessive cost/
resource commitment associated with following any internationally
recognised methodology.
Fuel use by visiting trucks and rail (within
Port boundary)
Trucks - immaterial emissions source. Less than 5% of total
emissions. Also high uncertainty in data. Rail - already included in
freight emissions.
Downstream leased
assets (Category 13)
Leased land
Emissions from activities on leased land estimated to be immaterial.
Less than 5% of total emissions.
Investments
(Category 15)
Applies to financed emissions and
the downstream impacts of Longburn
Intermodal Freight Hub
Share of JVs scope 1 & 2 emissions are immaterial. Less than 5%
of total emissions
Scope 3
Not deemed to be relevant to Napier Port
Upstream leased assets
(Category 8)
Leased buildings and assets where a port
entity is a tenant (electricity, fuel and gas) if
not included in Scope 1 & 2
Not relevant. Napier Port does not lease any upstream assets.
Processing of sold
products
(Category 10)
Processing of wholesale products sold
in the reporting year by downstream
companies
Not relevant. Napier Port is not in the business of processing
wholesale goods and onselling them.
End of life treatment of
sold products
(Category 12)
Rendering wasteNot relevant. Napier Port does not engage in this activity.
Franchises
(Category 14)
Applies to franchise operationsNot relevant. Napier Port does not have any franchise operations.
Additional Scope 3 categories are not
reported where they are not relevant or
material to our business or where there is
a lack of data. These excluded categories
were determined after Napier Port conducted
a materiality assessment across all the
emission categories. In accordance with NZ
CS 3 an emissions source is considered to be
material if omitting it could reasonably expect
to influence decisions primary users make
which are based on Napier Port’s climate
related disclosures. Furthermore, materiality
is entity-specific, based on the nature,
magnitude, or both, of the items to which the
information relates. Visiting ship emissions,
in particular, was considered as part of
Category 11 (Use of Sold Products) but we
have concluded it should be excluded as part
of Napier Port’s scope 3 emissions inventory.
This is due to the underlying data currently
being inaccessible and the excessive
cost/resource commitment required to
follow any internationally recognised
calculation methodology.
Napier Port have applied an emissions
exclusion materiality threshold of less
than 5% of total emissions, for any single
source emission or in aggregate. The
excluded scope 3 categories are shown
in Table 2 below:
P24
2025 CLIMATE CHANGE DISCLOSURE REPORT
P25

Industry Based Metrics
Napier Port measures and reports total
Tonnes of Carbon Dioxide Equivalents
(tCO2e), and tCO2e per tonne of cargo
as our industry based metrics as they
are considered to be most relevant to our
business activity and the entire New Zealand
port industry, whether significant container
operations exist or not.
Napier Port is currently using an internal
shadow emissions price per tCO2e when
undertaking emission scenario and financial
analysis when assessing procurement and
business case opportunities. The central base
price used is aligned to the central region
carbon shadow price as developed by New
Zealand Treasury (2025: $101/tCO2e, 2024:
$100/tCO2e), 2023: $96/tCO2e) however
this may be varied depending on the analysis
being undertaken.
Capital Deployment
Napier Port undertakes long term planning
including infrastructure master planning and
financial models to capture its current plans
and forecasts. Financial forecasts incorporate
future climate related spending plans where
identified and quantifiable, and in the cases
where future spend is considered probable
but not yet reasonably quantified, general
capital provisions are incorporated into
forecasts and reviewed periodically.
To date, Napier Port has had limited
expenditure directly and solely related to
climate-related risks and opportunities. It
recently undertook capital works to reinstate
sections of its sea defences that experienced
some damage during Cyclone Gabrielle in
2023 and to deploy rock bag protection to its
eastern beach area to protect against future
GHG Emissions Reporting
In 2025, our total carbon emissions were 18,037 tCO2e which was an increase of 106% from 8,740 tCO2e tonnes in 2024 and an increase of
107% from 8,712 tCO2e tonnes in 2023. This is principally due to the inclusion of new Scope 3 emissions categories for the first time which
is discussed below. As 2024 and 2023 total emissions are similar, any 2024 versus 2025 trend analysis also applies to 2023 unless stated
otherwise.
This is shown in figure 1 below.
2025 scope 1 emissions (tCO2e) were 7,110
tonnes, up 325 tonnes from the 6,785 tonnes
recorded in 2024. Higher container volumes
due to a favourable growing season have
resulted in increases in crane, forklift, truck
and stationary energy (diesel generators)
fuel usage. Partially offsetting this increase
were reduced marine emissions due to
smaller vessels calling this year which
require less marine tug assistance with
berthing. Additionally, fewer secondary vessel
movements were required also decreasing
marine tug requirements. Prioritising the
use of our more fuel-efficient tug, Kaweka,
wherever possible continues to add positively
to the minimisation of marine emissions.
Our purchased electricity (scope 2) emissions
increased to 1,161 tonnes from 979 tonnes in
2024. This increase has occurred despite a
13% reduction in electricity consumed during
the year. The main factor behind the increase
was the 39% increase in the Ministry for the
Environment (MfE) purchased electricity
emission factor used by Napier Port in each
reporting year. These emission factors are
used to convert electricity consumption into
tCO2e. This follows an equivalent reduction in
the electricity emission factor used in 2024 of
38% when compared with the emission factor
used in 2023.
Scope 3 emissions increased to 9,766 tonnes
from 976 tonnes in 2024. The increase was
primarily due to the reporting of Scope 3
emissions that have not been disclosed
previously. These include:
• GHG Protocol Category 1: Emissions from
purchased goods and services, including
any capitalised maintenance spend on
capital goods
• GHG Protocol Category 2: Capital Goods:
Emissions from construction projects and
high value assets
• GHG Protocol Category 3: Fuel and energy
related activities (Fuel-Well to Tank):
Emissions generated from the production &
distribution of scope 1 diesel and petrol
No data for these categories is included
for reported 2024 emissions due to its
unavailability. These three categories have
Figure 2: Carbon Emissions tCO2e Per Tonne
0.0040
0.0035
0.0030
0.0025
0.0020
0.0015
0.0010
0.0005
20212022 2023 2024 2025
site and infrastructure damage from erosion.
The combined cost of these projects was
$3.3m and were completed during 2025.
Additionally, Napier Port is currently in
the process of renewing elements of
its mobile plant fleet with lower emitting
replacements. This will see some diesel
powered plant being replaced by battery
electric or lower emissions emitting plant.
In addition, Napier Port is continuing its
programme of replacing port site lighting
with LED equivalents. The value of spend
on such projects during 2025 was $3.7
million. These projects are in progress and
are expected to see increased levels of
investment in the next financial year.
collectively contributed 8,550 tonnes of the
overall 8,790 tonnes increase in 2025 (97%
of the total increase). However, on a like
for like basis (excluding the new category
inclusions), Scope 3 emissions increased by
3%, and total emissions increased by 8.5%.
Our ‘per cargo tonne’ intensity metric
increased 103% to 0.00356 tCO2e/tonne in
2025, from 0.00175 tCO2e/tonne in 2024, as
shown in the below chart. This is primarily
attributable to the impact of including the new
scope 3 emissions described above which
increased the total emissions base by 97%
while there was a 1.5% increase in annual
cargo tonnage for the year. On a like for like
basis (excluding the new category inclusions),
the intensity of total emissions increased
by 6.9% as a result of container activity
increasing relative to bulk cargo, including the
51.3% increase in other container movements
which do not contribute to total cargo tonnes
measure, and the MfE electricity emission
factors increasing significantly without any
corresponding change in cargo activity.
Figure 1: Total Carbon Emissions tCO2e
20,000
18,000
16,000
14,000
12,000
10,000
8,000
6,000
4,000
2,000
20212022 2023 20242025
Scope 1Scope 2Scope 3Scope 3 (New)
P26
2025 CLIMATE CHANGE DISCLOSURE REPORT
P27

Key insights into our carbon footprint and our 2025 emissions are represented by the charts below:
1) Total emissions broken down by scope
9
7
9
9
7
6
6
,
7
8
5
tCO2e
2024
9
4
7
1
,
4
8
7
6
,
2
7
8
tCO2e
2023
3) Scope 2 emissions broken down by top emission sources
7% of Napier Port’s total 2025 emissions related to scope 2 emissions (2024: 11%, 2023: 9% to 17%) which arise from purchased electricity
off the national electricity grid. Consistent with 2024, the top emission sources within this category are powering reefer containers, operational
wharf and site lighting towers, and tug shore power and related infrastructure.
tCO2e
2025
9
,
7
6
6
7
,
1
1
0
1
,
1
6
1
2) Scope 1 emissions broken down by top emission sources
Scope 1 emissions produced by mobile plant and marine assets contribute 39% of Napier Port’s total 2025 emissions (down from 78% in 2024).
Stationary energy had the highest usage increase during the year (16%). More generators were required due to container terminal planning
changes which relocated some refrigerated (‘reefer’) container stacks closer to the vessels but provided no immediate access to a powered
substation, hence generators were needed to be utilised.
The make-up of Scope 1 emissions is represented in the charts below:
Scope 1
(tCO2e)
2024
6
3
6
8
3
6
1
,
1
5
8
2
,
3
7
4
1
,
7
8
2
1
,
1
2
6
1
7
0
1
,
9
6
1
2
,
4
0
6
6
1
6
Scope 1
(tCO2e)
2023
7
0
7





9
6
7








1
,
2
9
3























2
,
4
2
8









1
,
7
1
5
Scope 1
(tCO2e)
2025
ForkliftCrane
Light Vehicles/
Trucks
Marine Plant
(Incls Tugs)
4) Scope 3 emissions broken down by top emission sources
54% of Napier Port’s total 2025 emissions related to scope 3 emissions which is increased from 11% in 2024. Breaking down the scope 3
emissions data further, 30% of total scope 3 emissions are attributable to purchased goods and services, 24% is attributable to construction
projects, 17% is attributable to fuel usage – well to tank, and 16% relates to purchase of high value assets. These are categories which have
been included in 2025 for the first time. The remaining 13% of Scope 3 emissions had small movements when compared with 2024 and 2023,
other than container rail freight (category 4) which increased by 228 tCO2e (87%). Out of the 87% increase only 28% contributed to the change
in methodology while the rest was due to an increase in TEUs during the year. This was partly due to obtaining more accurate TEU weight
information from Kiwirail in 2025, rather than using internally calculated weight estimates.
^ Landfill with gas recovery *T&D = transmission and distribution *tkm = tonne-kilometre
78
Waste^ /Water
Supply
397
Employee
commuting
70
Air travel
137
Electricity T&D*
losses kWh
265
Container Freight
- diesel tkm*
59
Waste^ /Water
Supply
431
Employee
commuting
73
Air travel
118
Electricity T&D*
losses kWh
262
Container Freight
- diesel tkm*
33
Tenant electricity
Stationary
Energy
49
Tenant electricity
(2025 inclusion)
2,932
Purchased goods &
services (2025 inclusion)
1,585
Purchase of high value
assets (2025 inclusion)
2,376
Construction projects
(2025 inclusion)
1,657
Well to Tank - Fuel
(2025 inclusion)
51
Waste^ /Water
Supply
97
Air travel
442
Employee
commuting
88
Electricity T&D*
losses kWh
489
Container Freight
- diesel tkm*
Scope 3
(tCO2e)
2024
4
3
1
7
3
1
1
8
2
6
2
3
3
5
9
Scope 3
(tCO2e)
2023
2
6
5
7
8
3
9
7
7
0
1
3
7
Scope 1
Scope 2
(location based)
Scope 3
Scope 3
(tCO2e)
2025
4
4
2
5
1
9
7
8
8
4
9
4
8
9
2
,
9
3
2
1
,
5
8
5
2
,
3
7
6
1
,
6
5
7
P28
2025 CLIMATE CHANGE DISCLOSURE REPORT
P29

References:
1. Climate change projections and impacts for Tairawhiti and Hawke’s Bay – Prepared for Envirolink,
Gisborne District Council and Hawke’s Bay Regional Council – November 2020;
2. Hawke’s Bay Regional Council (2025). Hawke’s Bay climate change risk assessment. Climate Action
Joint Committee.
3. 2021 IPCC Sixth Assessment Report.
4. Aotearoa New Zealand climate change projections guidance: Interpreting the latest IPCC WG1 report
findings. Prepared for the Ministry for the Environment, Report number CR 501, 51p. Bodeker, G.,
Cullen, N., Katurji, M., McDonald, A., Morgenstern, O., Noone, D., Renwick, J., Revell, L., & Tait, A.
(2022).
5. Interim guidance on the use of new sea-level rise projections. Wellington: Ministry for the Environment
(2022).
6. Climate Change 2022: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to
the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. IPCC AR6, WGII,
Chapter 11. Cambridge University Press. Lawrence, J., et al. (2022).
7. Coastal erosion, global sea-level rise, and the loss of sand dune plant habitats. Frontiers in Ecology
and the Environment, 3(7), 351-404. Feagin, R. A., Sherman, D. J., & Grant, W. E. (2005), and Future
changes in built environment risk to coastal flooding, permanent inundation and coastal erosion
hazards. Journal of Marine Science and Engineering, 9(1011). Stephens, S. A., Paulik, R., Reeve, G.,
Wadhwa, S., Popovich, B., Shand, T., & Haughey, R. (2021).
8. Climate change projections and impacts for Tairawhiti and Hawke’s Bay – Prepared for Envirolink,
Gisborne District Council and Hawke’s Bay Regional Council – November 2020 (page 14).
9. Coupled atmosphere-ocean simulations of contemporary and future South Pacific cyclones.
EGUsphere. Williams, J., Behrens, E., Morgenstern, O., Gibson, P. B., & Teixeria, J. C. M. (preprint,
2023).
10. WIRES Climate Change. Climate change and Aotearoa New Zealand, 6(6), 559-583. Hopkins, D.,
Campbell-Hunt, C., Carter, L., Hingham, J. E., & Rosin, C.
11. Hawke’s Bay Regional Council (2025). Hawke’s Bay climate change risk assessment. Climate Action
Join Committee.
12. (i) Impacts of Climate Change on Land-based Sectors and Adaptation Options. Stakeholder Report to
the Sustainable Land Management and Climate Change Adaptation Technical Working Group, Ministry
for Primary Industries. Clarke et al.
(ii) Forest resilience and tipping points at different spatio-temporal scales: approaches and challenges.
Journal of Ecology, 103(1), 5-15. Reyer et al.
13. Modelling spatial variation in radiata pine slenderness (height/diameter ratio) and vulnerability to wind
damage under current and future climate in New Zealand. Frontiers in Forests and Global Change, 6.
Watts et al, (2018).
14. Hawke’s Bay Regional Council (2025). Hawke’s Bay climate change risk assessment. Climate Action
Join Committee.
15. Napier Port, 2025 Climate Change Risk Assessment (page 33).
16. New Zealand kiwifruit growers’ vulnerability to climate and other stressors. Regional Climate Change.
Cradock-Henry, N. A. (2017), 17
17. MPI: Impacts of climate change on land-based sectors and adaption options - Chapter 6: Horticulture
18. Napier Port, 2025 Climate Change Risk Assessment (page 34).
19. Climate change projections and impacts for Tairawhiti and Hawke’s Bay – Prepared for Envirolink,
Gisborne District Council and Hawke’s Bay Regional Council – November 2020 (page 15).
20. Napier Port, 2025 Climate Change Risk Assessment (page 35).
21. MPI: Impacts of climate change on land-based sectors and adaption options - Chapter 4: Sheep and
Beef.
Setting Targets -
Decarbonising Napier Port
Napier Port is committed to decarbonisation
and reaching net zero greenhouse gas
emissions by 2050. Our initial Emissions
Reduction Strategy illustrates incremental
progress over time aligned to the removal
of technological and economic adoption
barriers. Consequently, Napier Port is not
able to set any realistic short or medium
time-bound reduction targets at this time.
Achievable reduction targets will be set once
the appropriate asset masterplans have been
refreshed to incorporate the feasible emission
reduction technologies required to achieve
the ultimate net zero by 2050 outcome.
Our sustainability strategy includes placing
a focus on climate action and energy and
supporting national net zero 2050 targets.
As a result, our initial Emissions Reduction
Strategy was developed, providing a
framework for possible adoption of low
emission technology and to establish a high-
level pathway for Napier Port to reach net
zero by 2050.
At a high level, the strategy aims to:
• Focus on the reduction of diesel
consumption given it is the primary source
of our current emissions
• Align investment in low emissions
technology with
• Our asset renewal program
• Any future transformation of Napier Port
container terminal operating modes
• The availability of emerging technology
• Grow our electrical infrastructure through
potential electrical capacity upgrades.
• Establish a decision-making framework
that considers low emission technologies
and incorporates emission considerations
in investment or business development
decisions
This strategy framework will continue to
be further developed and involves further
investigations into the viability of alternative
fuel sources and the array of new low
emissions technology.
Current emission reduction initiatives
integrated within our business:
• The operation of eight Eco Reachstackers
within the forklift fleet (up from three in
2024)
• A continual program of light retrofitting with
low energy consumption LED alternatives
to our light towers and storage sheds
• Replacement of clear lite cladding systems
to reduce the need for interior lighting
during daylight hours
• Deliberate deployment prioritisation of
lower fuel consuming tugs
• Reduction in unproductive usage (idle)
hours across our container handling mobile
plant through the leveraging of IOT data
and technology systems
• Procurement policy commitments to
consider and evaluate renewable energy
technologies and outcomes as a step
within the procurement of higher value
assets.
Napier Port recently adopted a Sustainable
Finance Framework to support progressive
action towards the implementation of its
sustainability strategy. This framework
positions Napier Port to access sustainable
loans and/or bonds to finance investment
into eligible assets. Napier Port’s Sustainable
Finance Framework has been independently
reviewed by Sustainable Fitch, a global
provider of independent ESG research and
opinions specialising in sustainable finance,
and its Second-Party Opinion confirmed
that Napier Port’s Sustainable Finance
Framework has ‘Good’ alignment with global
sustainable finance standards.
Napier Port has recently renewed its banking
facilities including the incorporation of
sustainable loan provisions in accordance
with its recently established Sustainable
Finance Framework. This means
that as Napier Port invests in eligible
assets, including those related to clean
transportation, pollution prevention and
control and energy efficiency, it receives
financial support from its lenders to do so.
Underpinning our existing Emissions
Reduction Strategy and supporting our wider
Sustainability Strategy, Napier Port currently
has the following initiatives underway,
each with the potential to support the
decarbonisation of our operation:
• Progressing a decarbonisation and
alternate energies assessment to evaluate
in further detail, potential future pathways
of reaching net zero emissions. It will
evaluate currently available renewable
energy alternatives, their wider adoption
for use, and the whole-of-life cost and
impact to integrate into our operations.
Aligned with broader industry momentum
and appreciating economic factors, a key
output is expected to be the delivery of a
more detailed action plan for progressing
decarbonisation within our operations.
• Developing a comprehensive energy
transformation strategy. This will
consolidate earlier strategy documents and
will look to:
• establish baseline energy loads upon
which a series of transition pathways will
be modelled representing varying levels
of ambition,
• define ways in which Napier Port could
meet its Net Zero targets, while also
providing practical guidance on the
timing and scale of future electrical
investments,
• assess energy and financial market
dynamics, by including guidance on
participation in wholesale energy
purchasing.
• Entering long-term collaboration
arrangements with energy partners such
as the Energy Efficiency and Conservation
Authority (EECA) to identify, implement and
promote energy efficiency and renewable
energy opportunities
• The adoption of battery electric powered
truck and trailer units as substitutes
for heavy plant undertaking horizontal
transport in our container terminal
operation
• The adoption of battery electric forklifts for
use within our Port Pack operation
• Partnering with equipment suppliers to
evaluate proof of concept renewable
energy alternative equipment.
Napier Port’s Sustainability Strategy and
Action Plan is available on our website at:
www.napierport.co.nz/investor-centre/
2025 CLIMATE CHANGE DISCLOSURE REPORT
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INDEPENDENT LIMITED ASSURANCE REPORT
TO THE SHAREHOLDERS OF NAPIER PORT HOLDINGS LIMITED
Under section 461ZH(3) of the Financial Markets Conduct Act 2013, the Auditor-General is the assurance practitioner of Napier Port Holdings
Limited and its subsidiaries (the Group). The Auditor-General has appointed me, Pip Best, using the staff and resources of Ernst & Young
Limited, to carry out a limited assurance engagement, on his behalf, on the greenhouse gas (GHG) emissions information (GHG disclosures)
disclosed in the Group’s 2025 Climate change related disclosure report (Climate Statement), for the year ended 30 September 2025.
Exclusion of Scope 3 emission source - Use of sold products (visiting vessel emissions)
Description of key matterHow we addressed this matter
In considering which emissions to include in its reporting, the Group
is required to consider if material emission sources are included
within its value chain. Scope 3 GHG emissions from vessels visiting
the Port, including emissions from their fuel use, are a source of
emissions which required consideration in this assessment of whether
they should be reported under the GHG Protocol’s Scope 3 – Use of
sold product emissions category.
The Group has elected not to disclose these emissions, with the
reasons for this decision explained on page 24 including:
•lack of access to data to perform a reasonable estimate of the
emission, and
•cost and resourcing required to follow an internationally recognised
calculation methodology.
If these emissions were included in the reporting amounts, it is likely
that they would be significant to the overall reported GHG emissions
amounts. As a result, the judgment involved in excluding these
emissions and the disclosure of the reasons for this were a focus of
our procedures.
In assessing the exclusion of Scope 3 – Use of sold products
emissions (emissions from visiting vessel fuel use), we:
•Gained an understanding of the process taken by
Management to identify and assess emissions sources
within its value chain.
•Reviewed Scope 3 emissions reported by the Port’s peers
domestically and internationally and investigated the
existence of applicable methodologies for calculating this
emissions source.
•Received management representation on the reasons for
the exclusion of this emissions sources.
•Considered the appropriateness of the reasons for
exclusion against NZ CS disclosure requirements and
available guidance.
•Reviewed the adequacy of the disclosures related to the
exclusion in the GHG disclosures.
Spend-based methods used in measurement of Scope 3 - Purchased goods and services and Capital goods
Description of key matterHow we addressed this matter
As disclosed on page 22 and 23 of the Climate Statement, the
Group measured elements of the GHG emissions from Scope
3 – Purchased goods and services and Capital goods using the
spend-based calculation method per the GHG Protocol. The Scope
3 emissions calculated using the spend-based calculation method
make up approximately 36% of the Group’s total GHG emissions and
approximately 66% of Scope 3 emissions for the period ended 30
September 2025. This method estimates emissions by multiplying the
cost of the applicable items with sector specific average spend-based
emission factors.
This approach carries an inherent uncertainty which may result in
significant differences between estimated and actual emissions.
Future changes to the calculation method or assumptions could
lead to material changes and restatements of previously reported
amounts.
In performing our procedures we:
•Gained an understanding of the spend-based calculation
method, assumptions and estimation uncertainties through
enquiries of management.
•Considered the alignment of the Group’s methodology with
the GHG Protocol.
•Considered the reasonableness of the selected emission
factors and their application.
•Reviewed the sector categorisation of the Group’s
expenditures on goods and services and capital goods.
•Considered the adequacy of the disclosures related to
the calculation method, assumptions and uncertainties in
estimating this emission source, included on pages 22 and
23 of the Climate Statement.
Scope of the engagement
The GHG disclosures below are within the scope of our limited
assurance engagement:
•The gross emissions, in metric tonnes of carbon dioxide equivalent,
classified as Scope 1, Scope 2 (calculated using the location-based
method) and Scope 3, on page 28.
•The statement describing that GHG emissions have been measured
in accordance with The Greenhouse Gas Protocol: A Corporate
Accounting and Reporting Standard (revised edition) and the
Corporate Value Chain (Scope 3) Accounting and Reporting
Standard, on page 20.
•The approach used to consolidate GHG emissions (operational
control), on page 21.
•The sources (or references to sources, where applicable) of
emission factors and the global warming potential rates used, on
pages 20.
•The summary of specific exclusions of Scope 1, Scope 2
(calculated using the location-based method) and Scope 3 GHG
emissions, emissions sources, including facilities, operations or
assets with a justification for their exclusion, on page 24.
•The description of the methods and assumptions used (including
the rationale for doing so, where applicable) to calculate or estimate
Scope 1, Scope 2 (calculated using the location-based method) and
Scope 3 GHG emissions, and the limitations of those methods, on
pages 20, 22 and 23.
•The description of any uncertainties relevant to the Group’s
quantification of its Scope 1, Scope 2 (calculated using the location-
based method) and Scope 3 GHG emissions, including the effects
of these uncertainties on GHG disclosures, on pages 22 to 23.
•The explanation for base year GHG emissions restatements (where
applicable) relating to Scope 1, Scope 2 (calculated using the
location-based method) and Scope 3 GHG emissions, on page 21.
The Group has stated on page 2 that the Climate Statement adheres
to the Task Force on Climate-Related Financial Disclosures (TCFD)
framework and International Financial Reporting Standards (IFRS)
Sustainability Disclosure Standard S2 Climate-related Disclosures
(IFRS S2) issued by the International Sustainability Standards Board
(ISSB) as well as complying with the Aotearoa New Zealand Climate
Standards (NZ CS). We have not been engaged to provide any
assurance in addition to the scope explained above, and so we do
not provide any assurance that the Climate Statement adheres to the
TCFD framework or IFRS S2.
Conclusion
Based on the procedures we have performed and the evidence we
have obtained, nothing has come to our attention that causes us to
believe that the Group’s GHG disclosures within the scope of our
limited assurance engagement for the year ended 30 September
2025, are not fairly presented and prepared, in all material respects, in
accordance with Aotearoa New Zealand Climate Standards, issued by
the External Reporting Board.
Other matters
Certain elements of the comparative information, being the 2021 GHG
disclosures on page 26 and the restated 2024 Scope 2 and Scope
3 – Downstream leased assets GHG disclosures on page 21, have
not been subject to assurance. As such, they are not covered by our
assurance conclusion.
Other elements of the comparative information, being the 2022 - 2024
GHG disclosures on pages 26, 28 and 29 were assured by Toitū
Envirocare in the firm’s own capacity. Toitū Envirocare expressed
unmodified reports dated 14 November 2022, 01 November 2023 and
01 November 2024 respectively.
Key matters
Key matters are those matters that, in our professional judgement,
were of most significance in carrying out this limited assurance
engagement on GHG disclosures for the current year.
Key matters were addressed in the context of our limited assurance
engagement on GHG disclosures, and in forming our conclusion
thereon. We do not provide a separate conclusion on these matters.
The key matters are described on the following pages:
A member firm of Ernst & Young Global LimitedA member firm of Ernst & Young Global Limited
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A member firm of Ernst & Young Global Limited
The board of directors’ responsibilities
Subparts 2 to 4 of the Financial Markets Conduct Act 2013 set out
requirements for a climate reporting entity in preparing a Climate
Statement, which includes proper record keeping, compliance with the
climate-related disclosure framework and subjecting it to assurance.
The Aotearoa New Zealand Climate Standards have been issued
by the External Reporting Board as the framework that applies for
preparing and presenting a Climate Statement. The board of directors
of the Group are therefore responsible for preparing and fairly
presenting a Climate Statement for the year ended 30 September
2025, in accordance with those standards.
The board of directors are also responsible for the design,
implementation, and maintenance of internal control relevant
to preparing the Climate Statement that is free from material
misstatement, whether due to fraud or error.
Our responsibilities
Section 461ZH of the Financial Markets Conduct Act 2013, requires
the GHG disclosures included in the Group’s Climate Statement to be
the subject of an assurance engagement.
NZ CS1 Climate-related disclosures, paragraph 25 requires such
an assurance engagement at a minimum to be a limited assurance
engagement, and paragraph 26 specifies the scope of the assurance
engagement on GHG disclosures.
To meet this responsibility, we planned and performed procedures
(as summarised below), to provide limited assurance in accordance
with New Zealand Standard on Assurance Engagements 1 Assurance
Engagements over Greenhouse Gas Emissions Disclosures, and
International Standard on Assurance Engagements (NZ) 3410
Assurance Engagements on Greenhouse Gas Statements, issued by
the New Zealand Auditing and Assurance Standards Board.
Summary of Work Performed
The procedures we performed were based on our professional
judgement and included enquiries, 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.
Given the circumstances of the engagement, in performing the
procedures listed above:
•We obtained, through enquiries, an understanding of the Group’s
control environment, processes and information systems relevant to
the preparation of the Scope 1, Scope 2 and Scope 3 disclosures.
We did not evaluate the design of particular control activities or
obtain evidence about their implementation.
•We obtained, though enquiries, an understanding of the Group’s
process for identifying emissions sources within its operational
boundary or value chain and how materiality of the excluded
emission sources was determined. We evaluated the appropriate
disclosure of any excluded material emission sources.
•We evaluated whether the Group’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 the Group’s estimates.
•We performed analytical procedures on particular emission
categories by comparing the expected GHG emissions to recorded
GHG emissions and made inquiries of management to obtain
explanations for any significant differences we identified.
•We evaluated the appropriateness of the emission factors applied in
the Scope 1, Scope 2 and Scope 3 measurement process.
•We evaluated the overall presentation and disclosure of the Scope
1, Scope 2, and Scope 3 disclosures.
•We obtained director representation.
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.
We believe that the evidence obtained is sufficient and appropriate to
provide a basis for our limited assurance conclusion.
Inherent limitations
As outlined on pages 22 and 23, GHG quantification is subject to
inherent uncertainty because of incomplete scientific knowledge used
to determine emissions factors and the values needed to combine
emissions of different gases.
Other information
The Group’s Climate Statement contains information other than the
GHG disclosures and the assurance report thereon. The board of
directors is responsible for the other information.
Our assurance engagement does not extend to any other information
included, or referred to, in the the Group’s Climate Statement
on pages 01 to 21 and 25 to 31, and therefore, no conclusion is
expressed thereon. We read the other information identified above
and, in doing so, consider whether the other information is materially
inconsistent with the GHG disclosures, or our knowledge obtained
in the assurance engagement, or otherwise appears to be materially
misstated.
Where such an inconsistency or misstatement is identified, we are
required to discuss it with the board of directors and take appropriate
action under the circumstances, to resolve the matter. There are no
inconsistencies or misstatements to report.
Independence and quality management
We complied with the Auditor-General’s independence and other
ethical requirements, which incorporate the 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. PES 1 is founded on
the fundamental principles of integrity, objectivity, professional
competence and due care, confidentiality and professional behaviour.
These principles for example, do not permit us to be involved in the
preparation of the current year’s GHG information as doing so would
compromise our independence.
We have also complied with the Auditor-General’s quality management requirements, which
incorporate the requirements of 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) and Professional and Ethical Standard 4 Engagement Quality
Reviews issued by the New Zealand Auditing and Assurance Standards Board (PES 4). PES 3
requires our 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. PES 4 deals with an engagement quality
reviewer’s appointment, eligibility, and responsibilities.
In addition to this engagement, we have carried out assignments in the areas of financial
statement audit, interim financial statements review, agreed-upon procedures and other
assurance engagements which are compatible with those independence requirements. Other
than this engagement and these assignments, we have no relationship with or interests in the
Group.
Pip Best
Ernst & Young Limited
On behalf of the Auditor-General
Auckland, New Zealand
18 November 2025
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