Para 6. Governance: board oversight and management’s role
An entity must identify the body or individual responsible for climate-related oversight, and disclose how their mandate, skills, information cadence, transaction-decision integration, and target oversight reflect that responsibility. Para 6(b) covers the management-level position or committee that handles day-to-day climate management, and how it integrates with other internal controls.
Standard text (verbatim, IFRS S2 Para 6)
To achieve this objective, an entity shall disclose information about:
(a) the governance body(s) (which can include a board, committee or equivalent body charged with governance) or individual(s) responsible for oversight of climate-related risks and opportunities. Specifically, the entity shall identify that body(s) or individual(s) and disclose information about:
(i) how responsibilities for climate-related risks and opportunities are reflected in the terms of reference, mandates, role descriptions and other related policies applicable to that body(s) or individual(s);
(ii) how the body(s) or individual(s) determines whether appropriate skills and competencies are available or will be developed to oversee strategies designed to respond to climate-related risks and opportunities;
(iii) how and how often the body(s) or individual(s) is informed about climate-related risks and opportunities;
(iv) how the body(s) or individual(s) takes into account climate-related risks and opportunities when overseeing the entity’s strategy, its decisions on major transactions and its risk management processes and related policies, including whether the body(s) or individual(s) has considered trade-offs associated with those risks and opportunities;
(v) how the body(s) or individual(s) oversees the setting of targets related to climate-related risks and opportunities, and monitors progress towards those targets (see paragraphs 33-36), including whether and how related performance metrics are included in remuneration policies (see paragraph 29(g)).
(b) management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities, including information about:
(i) whether the role is delegated to a specific management-level position or management-level committee and how oversight is exercised over that position or committee;
(ii) whether management uses controls and procedures to support the oversight of climate-related risks and opportunities and, if so, how these controls and procedures are integrated with other internal functions.
The Board has ultimate responsibility for the Group’s response to climate change. Climate strategy is overseen by the Sustainability Committee of the Board (meeting four times a year) and by the Safety, Health & Environment Committee (meeting six times). The Audit & Risk Committee receives quarterly climate-risk updates from the Group Risk Officer. The Group’s Climate Action Plan is subject to a non-binding shareholder advisory vote at the Annual General Meeting. [IFRS S2.6(a)(i), (iii)]
Board skills. Four of eleven directors have direct climate, energy-transition, or critical-minerals expertise. A formal skills matrix is included in the corporate governance statement. The Board commissioned an external climate-governance review in the prior year; recommendations were adopted in full. [IFRS S2.6(a)(ii)]
Major-transaction oversight. All capex commitments above CU 250m must include a climate-risk net-present-value sensitivity that tests the project economics under three scenarios (SSP1-2.6, SSP2-4.5, SSP5-8.5) over the life-of-mine plus 10-year residual liability period. Five capex projects above this threshold were assessed in the period; one was deferred and re-scoped on transition-risk grounds. The Group divested its thermal-coal portfolio in 2018 following a Board-led strategic review. [IFRS S2.6(a)(iv)]
Target oversight. The Board reviews progress against the 50% net-emissions reduction target by 2030 (Para 33–36), planned decarbonisation capex of CU 5–6 billion to 2030, and remuneration linkage (15% of executive long-term incentives weighted to climate KPIs). [IFRS S2.6(a)(v); 29(g)]
Management. The Chief Executive chairs the Apex Climate Committee. Two Centres of Excellence (GHG Emissions Reduction; Biodiversity and Nature) sit under the COO. Site managing directors are accountable for site-level adaptation plans approved at the Apex Committee. [IFRS S2.6(b)(i)–(ii)]
Illustrative governance structure.
Cohort findings: what reporters typically skip on Para 6
Typically skipped. Counts of deferred or re-scoped capex projects on climate-risk grounds. Most mining disclosures describe Board oversight in principle but do not surface the specific decisions that prove the principle.
What good looks like. Explicit capex thresholds with NPV sensitivity, count of decisions affected, divestment history, advisory-vote outcome, and clear remuneration linkage with named percentages.
Para 7. Avoiding governance duplication with IFRS S1
Para 7 permits — but does not require — integrating climate governance with broader sustainability governance under IFRS S1’s B42(b) integration permission. The disclosure should be explicit about the integration choice and surface the climate-specific governance elements that survive integration as a separate, named list.
Standard text (verbatim, IFRS S2 Para 7)
In preparing disclosures to fulfil the requirements in paragraph 6, an entity shall avoid unnecessary duplication in accordance with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) (see paragraph B42(b) of IFRS S1). For example, although an entity shall provide the information required by paragraph 6, if oversight of sustainability-related risks and opportunities is managed on an integrated basis, the entity would avoid duplication by providing integrated governance disclosures instead of separate disclosures for each sustainability-related risk and opportunity.
Climate-related governance is integrated with the Group’s broader sustainability-related governance under IFRS S1, consistent with the management of climate, water, tailings, biodiversity, and community-related risks through the same Board committees and Apex committees. [IFRS S2.7; IFRS S1 B42(b)]
Climate-specific elements surfaced directly in this Climate Action Plan rather than in the broader Sustainability Report include: the CU 250m capex-NPV-sensitivity threshold, the 15% climate weighting of executive Long-Term Incentive Plans, the advisory shareholder vote on the Climate Action Plan, and the dedicated Centres of Excellence for GHG emissions reduction and biodiversity management.
Disclosure approach consistent with IFRS S1 paragraph B42(b).
Cohort findings: what reporters typically skip on Para 7
Typically skipped. An explicit list of the climate-specific elements that survive integration. The mining sector has more candidate elements than most (advisory vote, CoEs, NPV threshold, decommissioning provisioning) and surfacing them is what makes the integration credible.
What good looks like. A specific list of climate-only governance elements that the integration does not absorb.
Para 10. Climate-related risks and opportunities: identification, classification, time horizons
The entity must describe its identified climate-related risks and opportunities, classify each risk as physical or transition, specify the time horizon over which each could affect the entity, and define what ‘short, medium, long term’ mean in the entity’s planning context. Time-horizon definitions must link to actual strategic-decision horizons.
Standard text (verbatim, IFRS S2 Para 10)
An entity shall disclose information that enables users of general purpose financial reports to understand the climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects. Specifically, the entity shall:
(a) describe climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects;
(b) explain, for each climate-related risk the entity has identified, whether the entity considers the risk to be a climate-related physical risk or climate-related transition risk;
(c) specify, for each climate-related risk and opportunity the entity has identified, over which time horizons (short, medium or long term) the effects of each climate-related risk and opportunity could reasonably be expected to occur;
(d) explain how the entity defines ‘short term’, ‘medium term’ and ‘long term’ and how these definitions are linked to the planning horizons used by the entity for strategic decision-making.
The Group identifies climate-related risks and opportunities at the operating-site level, the commodity-portfolio level, and the value-chain level. Each is classified as physical or transition, and mapped to a time horizon aligned with the life-of-mine planning cycle (short: 1–3 years; medium: 3–10 years; long: 10–30 years plus residual liability post-closure). [IFRS S2.10(a)–(d)]
| Risk / opportunity | Type | Time horizon |
|---|---|---|
| Site-level water stress and water-availability risk for arid-region operations | Physical | Short to long |
| Acute physical exposure: tropical cyclone, monsoon flooding, wildfire | Physical | Short to long |
| Tailings storage facility extreme-rainfall risk | Physical | Short to long-and-residual |
| Carbon-pricing exposure on Scope 1 emissions in regulated jurisdictions | Transition | Short to medium |
| Demand-side commodity-mix shift (steelmaking technology, EV adoption) | Transition | Medium to long |
| Critical-minerals demand growth (lithium, copper, nickel) | Opportunity | Short to long |
| Low-carbon-product premiums (Copper Mark, low-carbon aluminium, EAF-feed iron ore) | Opportunity | Medium to long |
The long-term horizon includes a residual-liability period extending up to 50 years past final mine closure for tailings, water, and rehabilitation provisioning purposes. [IFRS S2.10(d)]
Illustrative risk universe drawn from sector practice.
Cohort findings: what reporters typically skip on Para 10
Typically skipped. The post-closure residual-liability horizon. Many mining disclosures stop at the operating-life horizon and do not address the period during which tailings, water, and rehabilitation liabilities accrue physical-risk exposure.
What good looks like. A horizon definition that extends through closure and residual-liability period for the asset classes that warrant it (notably tailings).
Para 13. Effects of climate-related risks and opportunities on the business model and value chain
Disclose the current and anticipated effects of climate-related risks and opportunities on the business model and value chain, and where in the value chain those risks and opportunities are concentrated — by geography, facility, asset type. Concentration disclosure is the load-bearing element; high-level narrative without geography or asset specificity does not satisfy the standard.
Standard text (verbatim, IFRS S2 Para 13)
An entity shall disclose information that enables users of general purpose financial reports to understand the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain. Specifically, the entity shall disclose:
(a) a description of the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain;
(b) a description of where in the entity’s business model and value chain climate-related risks and opportunities are concentrated (for example, geographical areas, facilities and types of assets).
The Group’s business model spans extraction (14 operating mines), processing (5 facilities), transport infrastructure (4 ports and rail networks), and customer end-use through the Scope-3 value chain (steel, aluminium, copper, lithium, iron ore). Climate-related risks and opportunities concentrate differently at each step. [IFRS S2.13(a)–(b)]
Concentration of climate-related risks.
| Value chain segment | Concentration |
|---|---|
| Mining operations | 3 of 14 sites in elevated physical-exposure regions (water stress, cyclone, wildfire); 22% of FY production from these 3 sites |
| Tailings storage facilities | 11 active TSFs; 3 classified elevated extreme-rainfall risk; CU 290m PPE carrying amount across the 3 |
| Processing facilities | 1 of 5 in tropical-cyclone-exposed coastal location; CU 410m PPE |
| Port and rail infrastructure | 1 port and 80 km of coastal rail in sea-level-rise exposure zone; CU 200m PPE |
| Commodity mix (forward-looking transition risk) | Iron ore 31% revenue (medium transition risk via steelmaking technology); copper 28% (low transition risk, growing demand); aluminium 16% (medium); lithium 9% (low transition risk, growing demand); other 16% |
| Customer end-use (Scope-3) | Steel-makers 38% of Scope-3 emissions footprint; auto OEMs 18%; construction sector 22% |
Anticipated effects. Site-level physical exposure drives operating-cost increases, production-day losses, and capex-pull-forward in the operating sites identified. Commodity-mix exposure shapes long-term portfolio strategy: critical-minerals growth offsets demand decline in transition-vulnerable commodities. [IFRS S2.13(a)]
Illustrative concentration figures.
Cohort findings: what reporters typically skip on Para 13
Typically skipped. The Scope-3-customer-industry breakdown. Mining disclosures often describe the commodity portfolio but stop short of the customer-industry concentration that determines transition exposure.
What good looks like. Concentration table covering operating sites, processing, infrastructure, commodity mix, and customer end-use.
Para 14. Strategy and decision-making, including transition plan
Disclose how the entity has responded to and plans to respond to climate-related risks in its strategy and decision-making — including business-model changes, direct and indirect mitigation and adaptation efforts, and any transition plan with its assumptions and dependencies. Disclose how the entity is resourcing these activities and progress against prior-period plans.
Standard text (verbatim, IFRS S2 Para 14)
An entity shall disclose information that enables users of general purpose financial reports to understand the effects of climate-related risks and opportunities on its strategy and decision-making. Specifically, the entity shall disclose:
(a) information about how the entity has responded to, and plans to respond to, climate-related risks and opportunities in its strategy and decision-making, including how the entity plans to achieve any climate-related targets it has set and any targets it is required to meet by law or regulation. Specifically, the entity shall disclose information about:
(i) current and anticipated changes to the entity’s business model, including its resource allocation, to address climate-related risks and opportunities (for example, plans to manage or decommission carbon-, energy- or water-intensive operations; resource allocations resulting from demand or supply-chain changes; resource allocations arising from business development through capital expenditure or research and development; and acquisitions or divestments);
(ii) current and anticipated direct mitigation and adaptation efforts (for example, through changes in production processes or equipment, relocation of facilities, workforce adjustments, and changes in product specifications);
(iii) current and anticipated indirect mitigation and adaptation efforts (for example, through working with customers and supply chains);
(iv) any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity’s transition plan relies;
(v) how the entity plans to achieve any climate-related targets, including any greenhouse gas emissions targets, described in accordance with paragraphs 33-36.
(b) information about how the entity is resourcing, and plans to resource, the activities disclosed in accordance with paragraph 14(a).
(c) quantitative and qualitative information about the progress of plans disclosed in previous reporting periods in accordance with paragraph 14(a).
The Group’s strategic response is structured around operational decarbonisation, portfolio rebalancing toward energy-transition commodities, and customer engagement on Scope-3 emissions. [IFRS S2.14(a)]
Business model changes (Para 14(a)(i)). The Group has divested its thermal-coal portfolio (completed); is investing CU 5–6 billion through 2030 in operational decarbonisation; is growing copper and lithium production (target 1 Mt mined copper by 2028; 60 kt lithium carbonate capacity by 2028). Two open-pit operations in elevated-physical-exposure regions are scheduled for accelerated closure.
Direct mitigation and adaptation (Para 14(a)(ii)). Renewable-electricity contracting (78% in current period; target >90% by 2030); fleet electrification at three operating sites; site-level adaptation (water-supply diversification, drainage and pumping upgrades, cyclone-design uplift on infrastructure).
Indirect mitigation (Para 14(a)(iii)). Customer partnerships: CU 200–350m co-investment with steelmaker customers on EAF feedstock and decarbonisation; participation in Copper Mark and equivalent low-carbon certifications; collaboration with auto OEMs on critical-minerals supply-chain transparency.
Transition plan (Para 14(a)(iv)). 50% net Scope 1+2 emissions reduction by 2030 (vs. 2018 baseline); long-term net zero by 2050. Key assumptions: renewable-electricity costs continue current decline; customer demand for low-carbon commodities grows in line with steel and auto sector commitments; permitting timeframes for new energy-transition projects (lithium, copper) remain workable; carbon-credit markets evolve to support residual-emission management. Key dependencies: government policy continues to support critical-minerals development; technology pathways (hydrogen, CCUS) become commercially viable post-2030; permitting processes for tailings facilities accommodate climate-adapted design standards.
Resourcing (Para 14(b)). CU 589m decarbonisation capex in current period; CU 5–6 billion cumulative target to 2030.
Progress against prior-period plans (Para 14(c)). 5 Mt CO2e abatement achieved year-on-year; 3.6 Mt CO2e of committed projects in execution; renewable-electricity share increased from 71% to 78%; thermal-coal divestment completed prior period.
Illustrative response framework drawn from sector practice.
Cohort findings: what reporters typically skip on Para 14
Typically skipped. Permitting-pathway dependencies. Mining transition plans often describe the technology pathways (electrification, hydrogen, EAF) but rarely the permitting and regulatory dependencies that determine timing.
What good looks like. Explicit dependencies on permitting, technology cost curves, and policy continuity, with named regulatory references where applicable.
Para 15–21. Anticipated financial effects on financial position, performance and cash flows
Disclose how climate-related risks and opportunities have affected financial position, performance, and cash flows for the reporting period (current effects), and anticipated effects over short, medium, and long term. Para 19-21 permit qualitative-only disclosure where quantification is not separately identifiable, measurement uncertainty is too high, or the entity lacks skills and resources — but the qualitative substitute must explain the omission and identify affected line items.
Standard text (verbatim, IFRS S2 Para 15–21)
An entity shall disclose information that enables users to understand:
(a) the effects of climate-related risks and opportunities on the entity’s financial position, financial performance and cash flows for the reporting period (current financial effects);
(b) the anticipated effects of climate-related risks and opportunities on the entity’s financial position, financial performance and cash flows over the short, medium and long term (anticipated financial effects).
Specifically, an entity shall disclose quantitative and qualitative information about:
(a) how climate-related risks and opportunities have affected its financial position, financial performance and cash flows for the reporting period;
(b) the climate-related risks and opportunities identified in paragraph 16(a) for which there is a significant risk of a material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements;
(c) how the entity expects its financial position to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities, taking into consideration:
(i) its investment and disposal plans, including plans the entity is not contractually committed to;
(ii) its planned sources of funding to implement its strategy;
(d) how the entity expects its financial performance and cash flows to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities.
In providing quantitative information, an entity may disclose a single amount or a range.
In preparing disclosures about the anticipated financial effects of a climate-related risk or opportunity, an entity shall:
(a) use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort;
(b) use an approach that is commensurate with the skills, capabilities and resources that are available to the entity for preparing those disclosures.
An entity need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity if the entity determines that:
(a) those effects are not separately identifiable; or
(b) the level of measurement uncertainty involved in estimating those effects is so high that the resulting quantitative information would not be useful.
In addition, an entity need not provide quantitative information about the anticipated financial effects of a climate-related risk or opportunity if the entity does not have the skills, capabilities or resources to provide that quantitative information.
If an entity determines that it need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity applying the criteria set out in paragraphs 19-20, the entity shall:
(a) explain why it has not provided quantitative information;
(b) provide qualitative information about those financial effects, including identifying line items, totals and subtotals within the related financial statements that are likely to be affected, or have been affected, by that climate-related risk or opportunity;
(c) provide quantitative information about the combined financial effects of that climate-related risk or opportunity with other climate-related risks or opportunities and other factors unless the entity determines that quantitative information about the combined financial effects would not be useful.
Climate-related risks and opportunities have current and anticipated effects on the Group’s financial position, financial performance, and cash flows. Quantitative information is disclosed as ranges under Para 17. [IFRS S2.15–17]
Current financial effects (Para 16(a)). Decarbonisation capex deployed: CU 589m. Site-level adaptation capex: CU 96m. Closure-and-rehabilitation provision uplift attributable to climate: CU 21m. Operating-cost increase from extreme-weather event at one open-pit site: CU 14m. Critical-minerals revenue increment year-on-year: CU 280m (organic growth in copper and lithium).
Significant risk of material adjustment (Para 16(b)). Three operating-mine CGUs are flagged for impairment-indicator review: two for physical-risk-driven operational-continuity uncertainty under SSP5-8.5 (CU 720m carrying amount; potential impairment range CU 50–280m if accelerated closure becomes likely); one for transition-risk-driven demand decline under aggressive-mitigation scenario (CU 410m; potential impairment range CU 40–160m).
Anticipated effects on financial position (Para 16(c)). CU 5–6 billion cumulative decarbonisation capex through 2030; CU 220m cumulative physical-risk adaptation capex through 2030. Closure-and-rehabilitation provision is expected to grow CU 50–110m cumulative through 2030 reflecting climate-adjusted assumptions.
Anticipated effects on financial performance and cash flows (Para 16(d)). Short term (1–3 years): incremental decarbonisation capex CU 700–900m per year; critical-minerals revenue growth CU 300–600m per year incremental. Medium term (3–10 years): operating-cost increases from carbon pricing on Scope 1 (jurisdictions with regulated emissions) CU 90–280m cumulative; incremental low-carbon-product revenue (low-carbon aluminium, EAF-grade iron ore, certified copper) CU 800m–1.4bn cumulative. Long term (10–30 years): residual physical-risk-driven impairment range CU 0.5–1.6bn cumulative; cumulative critical-minerals demand growth CU 4–9bn revenue uplift.
Para 17 use of range. Range disclosure used given commodity-price volatility, scenario-input uncertainty, and technology-cost-curve uncertainty.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 15–21
Typically skipped. The closure-and-rehabilitation provision uplift attributable to climate. This is among the largest single line items affected by climate physical risk in mining and is rarely surfaced in front-of-book climate disclosure.
What good looks like. Range disclosure for both downside (impairment, provisioning) and upside (critical-minerals growth, low-carbon-product premium) channels, with explicit cross-reference to IAS 36 and IAS 37.
Para 22. Climate resilience: scenario analysis disclosure ★
Para 22 requires the entity to assess and disclose how resilient its strategy and business model are to climate-related changes, using climate-related scenario analysis. The standard calls for a ‘diverse range’ of scenarios including one aligned with the latest international climate agreement, with disclosure covering scenario inputs, key assumptions, time horizons, and the entity’s capacity to adapt. This is the load-bearing strategy paragraph.
Standard text (verbatim, IFRS S2 Para 22)
An entity shall disclose information that enables users of general purpose financial reports to understand the resilience of the entity’s strategy and business model to climate-related changes, developments and uncertainties, taking into consideration the entity’s identified climate-related risks and opportunities. The entity shall use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances (see paragraphs B1-B18). In providing quantitative information, the entity may disclose a single amount or a range. Specifically, the entity shall disclose:
(a) the entity’s assessment of its climate resilience as at the reporting date, which shall enable users to understand:
(i) the implications, if any, of the entity’s assessment for its strategy and business model, including how the entity would need to respond to the effects identified in the climate-related scenario analysis;
(ii) the significant areas of uncertainty considered in the entity’s assessment of its climate resilience;
(iii) the entity’s capacity to adjust or adapt its strategy and business model to climate change over the short, medium and long term, including:
(1) the availability of, and flexibility in, the entity’s existing financial resources to respond to the effects identified in the climate-related scenario analysis, including to address climate-related risks and to take advantage of climate-related opportunities;
(2) the entity’s ability to redeploy, repurpose, upgrade or decommission existing assets;
(3) the effect of the entity’s current and planned investments in climate-related mitigation, adaptation and opportunities for climate resilience;
(b) how and when the climate-related scenario analysis was carried out, including:
(i) information about the inputs the entity used, including:
(1) which climate-related scenarios the entity used for the analysis and the sources of those scenarios;
(2) whether the analysis included a diverse range of climate-related scenarios;
(3) whether the climate-related scenarios used for the analysis are associated with climate-related transition risks or climate-related physical risks;
(4) whether the entity used, among its scenarios, a climate-related scenario aligned with the latest international agreement on climate change;
(5) why the entity decided that its chosen climate-related scenarios are relevant to assessing its resilience to climate-related changes, developments or uncertainties;
(6) the time horizons the entity used in the analysis;
(7) what scope of operations the entity used in the analysis (for example, the operating locations and business units used in the analysis);
(ii) the key assumptions the entity made in the analysis, including assumptions about:
(1) climate-related policies in the jurisdictions in which the entity operates;
(2) macroeconomic trends;
(3) national- or regional-level variables (for example, local weather patterns, demographics, land use, infrastructure and availability of natural resources);
(4) energy usage and mix;
(5) developments in technology;
(iii) the reporting period in which the climate-related scenario analysis was carried out (see paragraph B18).
The Group assessed the resilience of its strategy and business model by running site-level scenario analysis on every operating mine, processing facility, and key port and rail asset, and commodity-portfolio analysis on the demand side. Coverage is 100% of operating sites and 100% of development projects. [IFRS S2.22; B1–B18]
| Scenario | Source | Key assumptions | Time horizon | Physical risk magnitude | Transition risk magnitude | Resilience implication |
|---|---|---|---|---|---|---|
| Aggressive mitigation | NGFS Net Zero 2050 + IPCC SSP1-2.6 | Aggressive electrification of energy and transport; carbon pricing CU 130/t by 2030 in regulated jurisdictions; rapid steelmaking technology transition (EAF-led) | 2030 / LOM (life-of-mine) | Mild on operations; tailings residual-liability assumptions stable | Elevated (carbon-pricing exposure on Scope 1; demand decline in legacy commodities; permitting risk for new projects) | Critical-minerals demand growth offsets legacy-commodity decline; scope 1+2 net-zero-by-2050 trajectory remains viable; CU 5–6bn decarbonisation capex sufficient |
| Current pledges | NGFS NDC + IPCC SSP2-4.5 | NDC pathway; gradual transition; physical-risk-frequency continues to rise | 2030 / LOM | Moderate by 2030; elevated by 2040 | Moderate (gradual carbon-pricing introduction; technology transition slower) | 3 of 14 sites flagged for adaptation capex; 14–26 production-day-loss per year by 2040 at the 3 sites without adaptation; 4–10 with planned CU 220m adaptation |
| Limited action | NGFS Current Policies + IPCC SSP5-8.5 | Little new climate policy; physical hazards dominate; carbon pricing limited to existing jurisdictions | 2030 / LOM-and-residual | Severe (water-stress, cyclone, extreme-rainfall events on tailings; operating-continuity stress) | Low regulatory but elevated litigation and reputational; commodity demand stable but shifting | Production-day-loss range expands to 8–18 per year at the 3 sites with planned adaptation; tailings-facility resilience uplift required at additional 4 facilities; closure-and-rehab provision uplift CU 50–110m cumulative |
Resilience assessment. Under aggressive-mitigation, the Group’s portfolio is positioned for energy-transition demand: copper, lithium, aluminium and iron ore (for EAF feedstock) all see growing demand. Under SSP5-8.5, physical-risk impacts on operating sites and tailings facilities require incremental capex but do not threaten Group viability. The exit strategy from one specific site (Site C, thermal-coal-adjacent operation) is being accelerated in part due to compounding physical-risk exposure (drought, wildfire) and is reflected in the FY accounting impairment review. Significant areas of uncertainty: permitting timelines for energy-transition commodities, customer-side technology-transition pace (steelmaking EAF, EV battery chemistry), tailings-regulation evolution under physical-risk pressure. [IFRS S2.22(a)(ii)–(iii); IAS 36 cross-reference]
Scope of operations. 100% of operating sites, 100% of development projects, full demand-side commodity-portfolio analysis. Reporting period: bi-annual refresh completed in current period.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 22
Typically skipped. The link to impairment. Mining-sector physical-risk disclosure tends to stop at scenario narrative (‘we ran SSP-RCP analysis’), without pulling that analysis through into the IAS 36 impairment indicators or accelerated decommissioning provisions. The reader cannot assess whether the financial statements reflect the physical-risk view in the front-of-book.
What good looks like. Side-by-side scenario table with explicit linkages: production-day impact, capex implications, impairment indicators, decommissioning timing. Para 22(a)(i) language about implications for strategy and business model is satisfied only when those linkages are made.
Para 25. Risk management: processes for identifying, assessing, prioritising and monitoring climate-related risks
Disclose the processes the entity uses to identify, assess, prioritise, and monitor climate-related risks (and separately, opportunities) — including data sources, scope of operations covered, scenario-analysis use in identification, materiality criteria, and how climate-risk processes integrate into the overall risk-management framework. Disclose any process changes from the prior reporting period.
Standard text (verbatim, IFRS S2 Para 25)
To achieve this objective, an entity shall disclose information about:
(a) the processes and related policies the entity uses to identify, assess, prioritise and monitor climate-related risks, including information about:
(i) the inputs and parameters the entity uses (for example, information about data sources and the scope of operations covered in the processes);
(ii) whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related risks;
(iii) how the entity assesses the nature, likelihood and magnitude of the effects of those risks (for example, whether the entity considers qualitative factors, quantitative thresholds or other criteria);
(iv) whether and how the entity prioritises climate-related risks relative to other types of risk;
(v) how the entity monitors climate-related risks;
(vi) whether and how the entity has changed the processes it uses compared with the previous reporting period;
(b) the processes the entity uses to identify, assess, prioritise and monitor climate-related opportunities, including information about whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related opportunities;
(c) the extent to which, and how, the processes for identifying, assessing, prioritising and monitoring climate-related risks and opportunities are integrated into and inform the entity’s overall risk management process.
Climate-related risks are identified, assessed, prioritised, and monitored through the Group’s enterprise Risk Management Framework, the site-level operational risk register, and the corporate-development capital-allocation process. [IFRS S2.25]
Identification. Every operating site, processing facility, port, and major rail asset screened bi-annually against twelve physical hazards. Pre-feasibility-stage projects screened at resource-definition. Inputs: public hazard datasets (national flood / drought / wildfire registers); third-party climate data; site-level historical incident logs; tailings-facility-specific monitoring datasets.
Use of scenario analysis. Scenario outputs (Para 22) feed mine-life-of-mine plans and capex prioritisation. Sites with modelled SSP2-4.5 mid-century hazard intensity exceeding operational-continuity threshold flagged for next capex cycle.
Assessment. Quantitative thresholds: production-day-loss above 5% per year; modelled water availability below process-demand; bushfire return-interval below 25 years for a sensitive site; tailings-facility freeboard below extreme-rainfall design requirement. Qualitative: site criticality to flowsheet, redundancy, host-community considerations, permitting complexity.
Prioritisation. Climate-related physical risk is a Tier 1 strategic risk; transition risk is Tier 2.
Monitoring. Site-level early-warning systems (fire, flood, extreme weather); quarterly Group Operational Risk Committee review; annual independent technical review of top-three-exposure sites’ adaptation plans; continuous reporting of incident triggers to the Board.
Process changes. Tailings-facility freeboard threshold added in the current period in line with Global Industry Standard on Tailings Management. Bi-annual cadence (was annual) introduced for processing-facility screening.
Integration. Climate-risk results feed the corporate-planning cycle, the LOM-planning process, and the capital-allocation committee. Tailings-facility risk feeds the IAS 37 closure-and-rehabilitation provisioning cycle.
Illustrative process drawn from sector practice.
Cohort findings: what reporters typically skip on Para 25
Typically skipped. The post-closure residual-liability dimension. Mining disclosures focus on operating-period risk and stop at site closure; the post-closure period is where physical-risk events compound onto provisioned liabilities.
What good looks like. Scenario analysis and risk monitoring extending through closure plus residual-liability periods, with named technical review at the highest-exposure sites and explicit linkage to provisions and impairment.
Para 29(a). Greenhouse gas emissions: Scope 1, 2, 3 (with financed-emissions limitation 29A-C)
Disclose absolute gross GHG emissions in CO2-equivalent for Scope 1, 2, and 3, measured per the GHG Protocol Corporate Standard. For Scope 1 and 2, disaggregate consolidated group from associates, joint ventures, and unconsolidated subsidiaries. For Scope 2, disclose location-based emissions plus contractual-instrument detail. For Scope 3, disclose categories per the GHG Protocol Value Chain Standard, with additional financed-emissions detail for asset managers, banks, and insurers (Para 29A-C optional limitation applies).
Standard text (verbatim, IFRS S2 Para 29(a))
Greenhouse gases. The entity shall:
(i) disclose its absolute gross greenhouse gas emissions generated during the reporting period, expressed as metric tonnes of CO2 equivalent, classified as:
(1) Scope 1 greenhouse gas emissions;
(2) Scope 2 greenhouse gas emissions;
(3) Scope 3 greenhouse gas emissions;
(ii) measure its greenhouse gas emissions in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) unless the entity is required, in whole or in part, by a jurisdictional authority or an exchange on which it is listed to use a different method for measuring its greenhouse gas emissions;
(iii) disclose the approach it uses to measure its greenhouse gas emissions, including:
(1) the measurement approach, inputs and assumptions the entity uses;
(2) the reason why the entity has chosen those;
(3) any changes the entity made to the measurement approach, inputs and assumptions during the reporting period and the reasons for those changes;
(iv) for Scope 1 and Scope 2 greenhouse gas emissions, disaggregate emissions between:
(1) the consolidated accounting group;
(2) other investees excluded from paragraph 29(a)(iv)(1) (associates, joint ventures and unconsolidated subsidiaries);
(v) for Scope 2 greenhouse gas emissions, disclose its location-based Scope 2 greenhouse gas emissions, and provide information about any contractual instruments that is necessary to inform users’ understanding of the entity’s Scope 2 greenhouse gas emissions;
(vi) for Scope 3 greenhouse gas emissions disclose:
(1) the categories included within the entity’s measure of Scope 3 greenhouse gas emissions, in accordance with the Scope 3 categories described in the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011);
(2) additional information about the entity’s financed emissions (which are part of Category 15 greenhouse gas emissions), if its activities include asset management, commercial banking or insurance. Paragraphs 29A-29C govern an optional limitation of Category 15 to financed emissions.
The Group’s gross greenhouse-gas emissions for the reporting period, measured per the GHG Protocol. [IFRS S2.29(a)]
| Scope | Emissions (MtCO2e) | YoY change |
|---|---|---|
| Scope 1 (mining and processing direct emissions) | 26.5 | −6% |
| Scope 2 (market-based) | 4.2 | −14% (renewable-electricity scale-up) |
| Scope 2 (location-based) | 13.6 | −4% |
| Scope 3 Cat. 11 (use of sold products — steel-makers, auto OEMs, construction) | 574.6 | 0% (commodity-mix shift compensates for reduced thermal-coal sales) |
| Scope 3 other categories (Cat. 1, 4, 5, 6 operational supply chain and logistics) | 17.1 | −3% |
Approach. Scope 1 measured per GHG Protocol with site-level monitoring at all 14 mines and 5 processing facilities; emissions covered under Safeguard Mechanism / EU ETS / equivalent regulation: 84% of Scope 1 (Para 29(a)(iii) note: regulatory coverage). Scope 3 Category 11 calculated using sold-tonnage × commodity-specific use-emission factors (steel using BF/BOF route, EAF route weighted; aluminium using semis-conversion factors; copper using end-use weighted average).
Disaggregation. Scope 1+2 disaggregated: 96% consolidated; 4% other investees (joint ventures, including non-operated lithium and aluminium assets).
Scope 3 categories included. Categories 1, 4, 5, 6, 11. Category 15 (financed) not material to the operator business model.
Sectoral context. Scope 3 Cat. 11 dominates the footprint (94% of total emissions). Scope 1 reduction strategy (renewable-electricity, fleet electrification, smelter abatement) addresses 5–6% of total; the larger lever is customer-side technology transition (EAF steelmaking, low-carbon aluminium).
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(a)
Typically skipped. Honest framing of the Scope 3 Cat. 11 dominance. Many mining disclosures lead with operational-emissions reduction targets (the smaller lever) and bury Scope 3, leaving the impression that the Group’s decarbonisation strategy addresses most of the footprint when it does not.
What good looks like. Scope 3 reported in full; the Scope 1 vs. Scope 3 ratio surfaced and explained; regulatory-coverage share of Scope 1 disclosed; commodity-mix detail behind Scope 3 Cat. 11.
Para 29(b). Climate-related transition risks: assets and business activities vulnerable
The amount and percentage of assets or business activities vulnerable to climate-related transition risks. Vulnerability must be defined against named transition-risk drivers (carbon pricing, technology shifts, demand decline, regulation tightening) under specified scenarios. Without a defined threshold and named scenario, the percentage figure is unverifiable.
Standard text (verbatim, IFRS S2 Para 29(b))
Climate-related transition risks. The amount and percentage of assets or business activities vulnerable to climate-related transition risks.
The Group discloses the production volume, revenue exposure, and PPE carrying amount classified as vulnerable to climate-related transition risks under each scenario. Vulnerability is defined as exposure to commodity demand decline, carbon-pricing on Scope 1, or technology-substitution risk where modelled NPV impact under the scenario exceeds 10% relative to central case. [IFRS S2.29(b); 30]
| Commodity / asset | SSP1-2.6 PPE (CU m) | SSP2-4.5 PPE (CU m) | SSP5-8.5 PPE (CU m) | Dominant transition driver |
|---|---|---|---|---|
| Iron ore (BF/BOF-grade) | 3,400 | 1,200 | 350 | Steelmaking technology shift to EAF |
| Coking coal | 1,800 | 620 | 180 | Demand decline as EAF scales |
| Aluminium (carbon-intensive smelters) | 700 | 180 | 50 | Carbon pricing; renewable-electricity transition |
| Copper / lithium / nickel (non-vulnerable; growing) | 0 | 0 | 0 | Energy-transition demand growth |
| Other (borates, diamonds, TiO2) | 300 | 100 | 20 | Niche end-use demand |
Critical-minerals (copper, lithium, nickel) are not in the vulnerable set; under aggressive-mitigation scenarios these grow rather than decline. Para 30: vulnerability assessment uses end-use demand modelling; sensitive to steelmaking transition assumptions and to copper-demand assumptions in EV growth pathways.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(b)
Typically skipped. Commodity-by-commodity transition vulnerability. Mining disclosures often describe transition risk at the Group level without specifying which commodities and which technology-transition pathways drive the exposure.
What good looks like. Commodity-level disaggregation; explicit named transition drivers (steelmaking technology, carbon pricing, EV demand); separate disclosure of non-vulnerable energy-transition commodities.
Para 29(c). Climate-related physical risks: assets and business activities vulnerable ★
The amount and percentage of assets or business activities vulnerable to climate-related physical risks. The most-skipped disclosure across every first-wave reporter cohort globally — about a third to a half of reporters either omit the quantitative figure or substitute a qualitative hedge. The amount-and-percentage form is the load-bearing element; vulnerability threshold, scenario, and time horizon must be disclosed alongside. Iris unpacks the four definitional ambiguities buried in the standard’s amount-and-percentage language in a separate Para 29(c) deep-dive.
Standard text (verbatim, IFRS S2 Para 29(c))
Climate-related physical risks. The amount and percentage of assets or business activities vulnerable to climate-related physical risks.
The Group discloses operating sites and PPE carrying amount vulnerable to climate-related physical risks under each scenario, by site type and dominant hazard. [IFRS S2.29(c); 30]
| Site type | Sites flagged | PPE under SSP2-4.5 (CU m) | PPE under SSP5-8.5 (CU m) | Dominant hazard |
|---|---|---|---|---|
| Open-pit mining | 2 of 9 | 720 | 1,080 | Drought, water stress, extreme heat |
| Processing facility | 1 of 5 | 410 | 610 | Tropical cyclone, riverine flood |
| Tailings storage facility | 3 of 11 | 290 | 460 | Extreme rainfall (overtopping risk) |
| Port and rail infrastructure | 1 of 4 | 200 | 300 | Coastal flood, sea-level rise |
Vulnerability defined as exposure exceeding the site’s operational-continuity threshold under the named scenario (production-day-loss above 5% per year modelled, or hazard intensity above the engineering design margin). Tailings facilities are treated separately because residual-liability horizon extends post-operations. The figure is gross. Planned adaptation capex of CU 220m to 2030 is expected to remove 2 of the 7 flagged sites under SSP2-4.5 and reduce production-loss exposure at the others.
Illustrative figures. Continuuiti’s Climate Risk service produces this metric for any portfolio of sites.
Cohort findings: what reporters typically skip on Para 29(c)
Typically skipped. Tailings storage facilities. The mining-sector pattern is to disclose vulnerable mines and processing facilities and treat tailings as a separate environmental-and-safety topic, not as Para 29(c) vulnerable assets. This understates the carrying amount at risk because tailings facilities are often the largest single PPE concentration on a mining balance sheet and the most exposed to chronic and acute physical hazards.
What good looks like. Site-type disaggregation including tailings; gross-of-adaptation framing; threshold disclosed; production-share context next to carrying-amount; explicit treatment of post-closure residual liability.
Para 29(d). Climate-related opportunities: assets aligned with opportunities
The amount and percentage of assets or business activities aligned with climate-related opportunities. The opportunity-side counterpart to Para 29(b) and 29(c). Disclosure should pair the quantitative figure with revenue, capacity, or other operational metrics that contextualise the alignment claim.
Standard text (verbatim, IFRS S2 Para 29(d))
Climate-related opportunities. The amount and percentage of assets or business activities aligned with climate-related opportunities.
The Group discloses production volume, revenue, and PPE carrying amount aligned with climate-related opportunities, defined as production of energy-transition commodities and low-carbon-product variants. [IFRS S2.29(d); 30]
| Commodity / opportunity | PPE (CU m) | Revenue (CU m) | Trajectory |
|---|---|---|---|
| Copper | 6,400 | 9,800 | Target 1 Mt mined copper by 2028 |
| Lithium | 2,800 | 1,200 | Target 60 kt carbonate capacity by 2028 |
| Aluminium (hydro-based) | 1,900 | 4,400 | Low-carbon premium under expansion |
| Iron ore (EAF-feedstock-grade) | 1,300 | 3,200 | EAF-aligned customer partnerships |
Alignment defined per the Group’s Climate Action Plan and the IEA Energy Technology Perspectives transition pathways. Copper is the largest contributor by both PPE and revenue. Para 30 reasonable-and-supportable: classification depends on customer end-use mix; aluminium and iron-ore alignment shifts as customer technology transitions.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(d)
Typically skipped. Customer-end-use-conditional alignment. Mining disclosures often classify aluminium or iron ore as ‘aligned’ without specifying the customer-technology assumption.
What good looks like. PPE and revenue figures together; growth trajectory; named alignment framework; customer-technology assumption explicit.
Para 29(e). Capital deployment toward climate-related risks and opportunities
The amount of capital expenditure, financing, or investment deployed toward climate-related risks and opportunities. Disclosure should disaggregate by category (mitigation, adaptation, opportunity) and ideally by sub-portfolio. The figure must reconcile with the entity’s strategy and decision-making disclosures (Para 14) and target-progress disclosures (Para 33-36).
Standard text (verbatim, IFRS S2 Para 29(e))
Capital deployment. The amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.
Capital deployment toward climate-related risks and opportunities during the reporting period: [IFRS S2.29(e)]
| Category | Amount (CU m) | Risk vs. opportunity |
|---|---|---|
| Site-level physical-risk adaptation capex (water, drainage, fire, cyclone-design) | 96 | Physical risk |
| Tailings facility resilience uplift (overtopping freeboard, monitoring) | 34 | Physical risk |
| Operational decarbonisation capex (electrification, renewables, abatement) | 589 | Transition risk |
| Closure-and-rehabilitation provision uplift attributable to climate | 21 | Physical risk (long-tail liability) |
| Critical-minerals development capex (lithium, copper) | 1,840 | Opportunity |
The CU 96m physical-risk adaptation capex covers water-supply diversification at two open-pit sites, drainage and pumping upgrades at one processing facility, cyclone-design uplift at one port. The Group has committed CU 220m of physical-risk adaptation capex through 2030. The CU 21m closure-and-rehabilitation provision uplift attributable to climate reflects management’s revision of the discount rate, the timing of rehabilitation activities, and the assumed water and weather conditions during rehabilitation, in light of updated SSP-RCP scenario inputs.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(e)
Typically skipped. The closure-and-rehabilitation provision uplift attributable to climate. Mining disclosures often report adaptation capex on operating sites but do not disclose the climate-driven re-measurement of long-tail provisions.
What good looks like. All five buckets; explicit cross-reference to IAS 37; multi-year commitment line for adaptation capex linked to the Para 29(c) site list.
Para 29(f). Internal carbon prices
Disclose whether and how the entity applies an internal carbon price in decision-making (investment, transfer pricing, scenario analysis), and the per-tonne price used. Disclosure should distinguish between prices applied to operational decisions and prices used in strategic and scenario contexts. Sectors with material own-emissions exposure typically apply different prices for different decision contexts.
Standard text (verbatim, IFRS S2 Para 29(f))
Internal carbon prices. The entity shall disclose:
(i) an explanation of whether and how the entity is applying a carbon price in decision-making (for example, investment decisions, transfer pricing and scenario analysis);
(ii) the price for each metric tonne of greenhouse gas emissions the entity uses to assess the costs of its greenhouse gas emissions.
The Group applies an internal carbon price across investment evaluation, decarbonisation-project economics, and acquisition due diligence. [IFRS S2.29(f)]
| Application | Price (CU per tonne CO2e) | Notes |
|---|---|---|
| Capital-investment decisions over CU 250m | 150 (central) / 250 (high) | Risk-adjusted; applied to LOM-projected Scope 1+2 emissions |
| Decarbonisation project NPV | 120 | Used to value abatement contributions of decarbonisation capex |
| Acquisition due diligence | 180 | Includes potential carbon-pricing exposure on Scope 1 in regulated jurisdictions |
Carbon prices are reviewed annually. The central capex price was increased from CU 130 to CU 150 in the current period to align with strengthened NGFS Net Zero 2050 carbon-price trajectories. The Group has applied carbon pricing to capital decisions since 2018 (initial price CU 60).
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(f)
Typically skipped. The history of price evolution. Disclosing how the price has changed over multiple years is the proof that the discipline is real and the price is calibrated.
What good looks like. Central-and-high price; multi-year history; alignment to external scenario carbon-price trajectories.
Para 29(g). Remuneration: climate-linked executive compensation
Disclose whether and how climate-related considerations factor into executive remuneration, and the percentage of executive compensation in the current reporting period that is climate-linked. The percentage should reconcile with the climate KPIs disclosed under Para 33-36 and the governance-oversight disclosures under Para 6(a)(v).
Standard text (verbatim, IFRS S2 Para 29(g))
Remuneration. The entity shall disclose:
(i) a description of whether and how climate-related considerations are factored into executive remuneration (see also paragraph 6(a)(v));
(ii) the percentage of executive management remuneration recognised in the current period that is linked to climate-related considerations.
Climate-related considerations factored into executive remuneration: [IFRS S2.29(g); 6(a)(v)]
| Component | % of variable remuneration linked to climate | Notes |
|---|---|---|
| Group CEO short-term incentive | 15% | Tied to Scope 1 reduction milestones and decarbonisation capex deployment |
| Group CEO Long-Term Incentive Plan | 20% | Tied to 2030 net-emissions reduction target and renewable-electricity share |
| Site managing directors | 10–25% | Site-specific decarbonisation and physical-risk adaptation milestones |
| Other executive committee average | 10–15% | Function-specific weighting |
Aggregate: 14% of executive management remuneration recognised in the current period is linked to climate-related considerations. The Compensation Committee of the Board reviews linkage annually.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(g)
Typically skipped. Site-level executive linkage. Group-level CEO and CFO climate weighting is now common; site-managing-director or business-unit-head linkage is rarer and more meaningful for execution.
What good looks like. Per-role disclosure, including site-level executives, with named milestones and trajectory.
Para 32. Industry-based metrics
Disclose industry-based metrics associated with the entity’s business model and activities. The standard refers entities to the SASB Industry-Based Guidance (IBG) on implementing IFRS S2 — applicability is per industry. The IBG metrics complement (not replace) the cross-industry Para 29 disclosures; both must be reconciled where they overlap.
Standard text (verbatim, IFRS S2 Para 32)
An entity shall disclose industry-based metrics that are associated with one or more particular business models, activities or other common features that characterise participation in an industry. In determining the industry-based metrics that the entity discloses, the entity shall refer to and consider the applicability of the industry-based metrics associated with disclosure topics described in the Industry-based Guidance on Implementing IFRS S2.
The Group applies IBG industry-based metrics for Metals and Mining (vol-10, EM-MM). Physical-risk-relevant metrics reported below; GHG- and energy-side metrics reported in transition disclosure. [IFRS S2.32]
| Metric | Value |
|---|---|
EM-MM-110a.1(1) Gross global Scope 1 emissions |
26.5 MtCO2e |
EM-MM-110a.1(2) % covered under emissions-limiting regulations |
84% |
EM-MM-130a.1(1) Total energy consumed (GJ) |
284,000 TJ |
EM-MM-130a.1(2/3) % grid electricity / % renewable |
61% grid; 78% renewable (of grid) |
EM-MM-140a.1(1) Total water withdrawn (megalitres) |
78,400 ML |
EM-MM-140a.1, regional % water withdrawn in High / Extremely High Baseline Water Stress regions |
34.2% (26,810 ML) |
EM-MM-140a.1(2) Total water consumed |
52,180 ML |
EM-MM-140a.1, regional consumption % consumed in High / Extremely High water-stress regions |
38.6% |
EM-MM-140a.2 Number of incidents of non-compliance with water-quality permits |
2 (both minor; remediated within 90 days) |
The Metals and Mining IBG has limited explicit physical-risk metrics; water management is the closest proxy for chronic physical risk in mining-relevant geographies. The Group supplements the IBG-aligned metrics with the Para 29(c) cross-industry disclosure (above) covering all twelve physical hazards across all operating sites.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 32
Typically skipped. Regional disaggregation. Many mining reporters disclose total water withdrawal and total water consumption but omit the water-stress regional overlay required by EM-MM-140a.1.
What good looks like. Both totals and water-stress-region-specific portions, both for withdrawal and consumption, plus brief narrative on which sites contribute most to the water-stress portion.
Para 33–36. Climate-related targets: quantitative and qualitative
Disclose the quantitative and qualitative climate-related targets set to monitor strategic progress, including any targets required by law or regulation. For each target: the metric, objective, scope, period, base, milestones, absolute-vs-intensity classification, and how the latest international climate agreement informed it. Performance against targets must be disclosed; for GHG targets, gases covered, scopes, gross-vs-net classification, and any planned use of carbon credits with verification scheme detail.
Standard text (verbatim, IFRS S2 Para 33–36)
An entity shall disclose the quantitative and qualitative climate-related targets it has set to monitor progress towards achieving its strategic goals, and any targets it is required to meet by law or regulation, including any greenhouse gas emissions targets. For each target, the entity shall disclose:
(a) the metric used to set the target;
(b) the objective of the target (for example, mitigation, adaptation or conformance with science-based initiatives);
(c) the part of the entity to which the target applies;
(d) the period over which the target applies;
(e) the base period from which progress is measured;
(f) any milestones and interim targets;
(g) if the target is quantitative, whether it is an absolute target or an intensity target;
(h) how the latest international agreement on climate change, including jurisdictional commitments that arise from that agreement, has informed the target.
An entity shall disclose information about its approach to setting and reviewing each target, and how it monitors progress against each target, including:
(a) whether the target and the methodology for setting the target has been validated by a third party;
(b) the entity’s processes for reviewing the target;
(c) the metrics used to monitor progress towards reaching the target;
(d) any revisions to the target and an explanation for those revisions.
An entity shall disclose information about its performance against each climate-related target and an analysis of trends or changes in the entity’s performance.
For each greenhouse gas emissions target the entity shall disclose:
(a) which greenhouse gases are covered by the target;
(b) whether Scope 1, Scope 2 or Scope 3 greenhouse gas emissions are covered by the target;
(c) whether the target is a gross greenhouse gas emissions target or net greenhouse gas emissions target. If the entity discloses a net greenhouse gas emissions target, the entity is also required to separately disclose its associated gross greenhouse gas emissions target;
(d) whether the target was derived using a sectoral decarbonisation approach;
(e) the entity’s planned use of carbon credits to offset greenhouse gas emissions to achieve any net greenhouse gas emissions target, including
(i) the extent to which, and how, achieving any net greenhouse gas emissions target relies on the use of carbon credits;
(ii) which third-party scheme(s) will verify or certify the carbon credits;
(iii) the type of carbon credit, including whether the underlying offset will be nature-based or based on technological carbon removals, and whether the underlying offset is achieved through carbon reduction or removal;
(iv) any other factors necessary for users to understand the credibility and integrity of the carbon credits the entity plans to use.
The Group has set the following climate-related targets. [IFRS S2.33–36]
| Target | Metric | Objective | Scope | Period | Base year | Milestones | Absolute / intensity | Paris-aligned? |
|---|---|---|---|---|---|---|---|---|
| Net Scope 1+2 emissions reduction | tCO2e | Mitigation | Group operations | 2030 | 2018 | FY27 -28%; FY29 -42% | Absolute (-50% net) | Yes |
| Gross Scope 1+2 emissions reduction | tCO2e | Mitigation | Group operations | 2030 | 2018 | FY27 -20%; FY29 -30% | Absolute (-35% gross) | Yes (Paris-pathway-consistent) |
| Net Scope 1+2 emissions | tCO2e | Long-term net zero | Group operations | 2050 | 2018 | FY30 -50% net; FY40 -80% net | Absolute (net zero) | Yes |
| Renewable electricity share | % | Mitigation enabler | Group operations | 2030 | n/a | FY27 80%; FY29 88% | Absolute (>90%) | n/a |
| Decarbonisation capex deployment | CU billion cumulative | Mitigation enabler | Operations | 2030 | n/a | FY27 CU 2.5bn; FY29 CU 4.5bn | Absolute (CU 5–6bn) | n/a |
| Critical-minerals production | kt or Mt | Opportunity | Copper, lithium | 2028 | n/a | FY26 0.85 Mt Cu; FY27 0.95 Mt Cu | Absolute (1 Mt copper; 60 kt lithium) | n/a |
Validation and review (Para 34). Net-emissions reduction target Paris-aligned per IEA Net Zero Emissions scenario; SBTi validation in progress. Targets reviewed annually by Sustainability Committee; non-binding shareholder advisory vote on the Climate Action Plan at AGM. Methodology revisions: in the prior year, Scope 1 baseline restated for divestment of thermal-coal portfolio (2018 baseline reduced accordingly).
Performance (Para 35).
| Target | 2025 | 2024 | 2023 | Base year | Status |
|---|---|---|---|---|---|
| Net Scope 1+2 (-50% net by 2030) | -14% | -10% | -6% | 2018 baseline | On track |
| Gross Scope 1+2 (-35% gross by 2030) | -10% | -7% | -4% | 2018 baseline | On track |
| Net Scope 1+2 (net zero by 2050) | -14% | -10% | -6% | 2018 baseline | On track |
| Renewable electricity share (>90% by 2030) | 78% | 70% | 62% | n/a | On track |
| Decarbonisation capex deployment (CU 5–6bn by 2030) | CU 1.4bn cumulative | CU 0.8bn cumulative | CU 0.3bn cumulative | 0 (2022) | On track |
| Critical-minerals production (1 Mt copper, 60 kt lithium by 2028) | Cu 0.7 Mt; Li first production | Cu 0.55 Mt | Cu 0.4 Mt | n/a | On track |
GHG-target detail (Para 36). All seven Kyoto-Protocol gases (CO2, CH4, N2O, HFCs, PFCs, NF3, SF6) included in measurement. Targets net of carbon credits up to 10% by 2050; for the 2030 milestone, no more than 5% of reduction may come from carbon credits. Credits will be nature-based (reforestation, soil-carbon) or technology-based (CCUS); third-party verification by Verra or equivalent. Sectoral decarbonisation approach used for primary commodities (steel, aluminium pathways).
Illustrative target set.
Cohort findings: what reporters typically skip on Para 33–36
Typically skipped. Carbon-credit policy detail. Mining ‘net zero’ targets often hide significant reliance on carbon credits or omit the specific limit (% of reduction from credits) that Para 36(e) requires.
What good looks like. Net AND gross targets; carbon-credit limit by year; nature-based vs. technology-based split; named verification scheme; explicit baseline restatement disclosure for divestments.
Commentary