New Zealand King Salmon Investments Limited logo

FY25 Climate-Related Disclosures

ESG28 May 2025NZKConsumer Staples

1
Climate-Related

Disclosures FY25

Contents
Introduction ............................................3

Governance .............................................8

Strategy .................................................13

Risk Management....................................22

Metrics and Targets .................................24

Glossary and Appendix .............................32

Independent Assurance Report ..................37

Cover image: Te Pangu, Tory Channel/Kura Te Au

Ngāmahau, Tory Channel/Kura Te Au

2

New Zealand King SalmonClimate-Related Disclosures FY25 — ContentsContents

Introduction
3New Zealand King SalmonClimate-Related Disclosures FY25 — IntroductionContents

Introduction
New Zealand King Salmon Investment Limited’s

Climate-Related Disclosures

New Zealand King Salmon Investments Limited (NZKS) is pleased to present its

second Climate-Related Disclosure (CRD) in accordance with the Aotearoa New

Zealand Climate Standards. NZKS is a climate-reporting entity under the Financial

Markets Conduct Act 2013. This report covers the period from 1 February 2024 to 31

January 2025 (FY25).

NZKS introduced a new purpose statement in FY25; ‘Towards a Healthier

Tomorrow’. This broad and aspirational purpose acknowledges that health is at

the core of the company and our efforts focus on five key dimensions: healthy

environments, healthy economies, healthy communities, healthy relationships

and healthy kai. A focus on broader sustainability can be seen across all these

dimensions, including fish health projects, supporting community initiatives,

working on the optimisation of the whole fish in our operations and investment in

better understanding climate risks.

‘Healthy Environments’ as a key dimension illustrates NZKS’ continued focus on

its climate journey by understanding its carbon footprint and the current and

anticipated impact of the changing climate on operations. NZKS acknowledge

that climate-related disclosures are only one part of the sustainability journey, but

it is an important tool in communicating how NZKS is measuring its impact and

addressing climate risks and opportunities.

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Towards

a Healthier

Tomorrow

4New Zealand King SalmonClimate-Related Disclosures FY25 — IntroductionContents

As a primary sector organisation fundamentally reliant on
the natural environment, climate change can significantly

influence NZKS’ trajectory. As a business, NZKS takes

a proactive approach to identifying and addressing

climate-related risks, evidenced by the completion of the

hydrological mapping of freshwater sites to enable better

future asset planning. Additionally, the NZKS ensilage

plant has been fully implemented during FY25, reducing

landfill impact with the ensilage plant output subsequently

being processed by a third party into liquid fertiliser or

biogases that can be used to create electricity.

NZKS understands that being in the business of growing

a food source will always have an environmental impact

but do continuously seek to identify opportunities to

minimise the footprint of our operations. In saying this

though, NZKS acknowledges the opportunity it has as

the world’s largest King salmon farmer, producing a

premium, nutritious and low-carbon animal protein.

1

The

aquaculture sector in New Zealand has been identified by

the New Zealand Government as a growth sector and as

consumer demand grows for healthy, low-carbon protein

alternatives NZKS is focused on expanding to meet that

demand. NZKS maintains a commitment to responsible

and sustainable growth as it continues to expand, with

the Blue Endeavour pilot underway and planning work

to support a greenfields site ongoing with a view to

accommodate higher future production volumes.

1

thinkstep-anz. (2023). LCA Report – King Salmon from New Zealand. Wellington: thinkstep-anz.

This disclosure details NZKS’ strategic approach to

identifying risks and opportunities from climate change

and acknowledges that the maturity of our sustainability

reporting will continue to evolve as we deepen our

understanding of climate-related risks and opportunities.

During FY25, NZKS has looked at our operations with a

sustainability lens and sought to embed Environmental,

Social and Governance (ESG) principles throughout

the company strategy. Applying these principles and

strategically focusing on climate risk, ensures that NZKS

becomes a more resilient and sustainable business.

5New Zealand King SalmonClimate-Related Disclosures FY25 — IntroductionContents

Statement of Compliance
These climate-related disclosures comply with the Aotearoa

New Zealand Climate Standards, and the November

2024 Amendment, issued by the XRB External Reporting

Board. In preparing NZKS’ Climate-Related Disclosures, the

Board and Management have elected to use the following

Adoption Provisions

2

:

Adoption provision 2: Anticipated financial impacts

This adoption provision exempts NZKS from disclosing its

anticipated financial impacts of climate-related risks and

opportunities in its first or second reporting period.

This adoption provision also includes exemption from:

a. Paragraph 15 (c) of NZ CS 1, where NZKS is

required to disclose a description of the time

horizons over which the anticipated financial

impacts of climate-related risks and

opportunities could reasonably occur.

b. Paragraph 15 (d) of NZ CS 1, where NZKS is

required to explain why it is unable to disclose

quantitative information for paragraph 15 (b)

of NZ CS 1.

Adoption provision 6: Comparatives for metrics

This adoption provision exempts NZKS from complying

with the disclosure requirement in Paragraph 40 of NZ CS

3. Paragraph 40 of NZ CS 3 requires that for each metric

disclosed in the current reporting period an entity must

disclose comparative information for the immediately

preceding two reporting periods. This adoption provision

allows for an entity in its second reporting period, to provide

one year of comparative information for each metric. NZKS

has disclosed comparative data for the preceding period

being FY24.

Adoption provision 7: Analysis of trends

This adoption provision exempts NZKS from disclosing an

analysis of the main trends evident from a comparison of

each metric from previous reporting periods to the current

reporting period, referenced in NZ CS 3, clause 42, in its first

or second reporting period.

2

Aotearoa New Zealand Climate Standard 2 Adoption of Aotearoa New Zealand Climate Standards (NZ CS 2). Incorporates amendments to 27 November 2024.

6New Zealand King SalmonClimate-Related Disclosures FY25 — IntroductionContents

Disclaimer
NZKS has used reasonable efforts in the preparation of this

CRD to provide accurate information, but cautions reliance

being placed on representations that are necessarily

subject to significant risks, uncertainties or assumptions.

This report contains forward looking statements, including

climate-related metrics, climate scenarios, targets,

assumptions, estimated climate projections, forecasts,

statements of NZKS’ future intentions, estimates and

judgements that may not evolve as predicted. These

statements necessarily involve assumptions, forecasts and

projections about NZKS’ present and future strategies and

NZKS’ future operating environment. Such statements

are inherently uncertain and subject to limitations,

particularly as inputs, available data and information are

likely to change. NZKS has used its best efforts to provide

a reasonable basis for forward-looking statements and is

committed to progressing our response to climate-related

risks and opportunities over time but is constrained by

the novel and developing nature of this subject matter.

Climate-related risk management and reporting of metrics

and targets is an emerging area, and often uses data

and methodologies that are developing and uncertain.

Climate-related forward-looking statements may therefore

be less reliable than other statements NZKS may make in

its annual reporting.

We have based these statements on our current knowledge

as of May 2025. There are many factors that could cause

NZKS’ actual results, performance or achievement of

climate-related metrics (including targets) to differ

materially from that described, including economic and

technological viability, as well as climatic, government,

consumer, and market factors outside of NZKS’ control.

Nothing in this report should be interpreted as capital

growth, earnings or any other legal, financial, tax or other

advice or guidance.

Mark Dewdney

Chair

28 May 2025

Paul Munro

Chair - Audit, Finance & Risk Committee

28 May 2025

Ruakākā, Queen Charlotte Sound/Tōtaranui

7New Zealand King SalmonClimate-Related Disclosures FY25 — IntroductionContents

Governance
8New Zealand King SalmonClimate-Related Disclosures FY25 — GovernanceContents

Governance
Board oversight of climate-related risks

and opportunities

The NZKS Board of Directors (the Board) maintain direct

responsibility and oversight of risks and opportunities,

including those related to climate change. At each Board

meeting, Management reports on climate-related matters

to ensure the Board remains informed and can set the

direction of Management response to climate-related

risks and opportunities. Several Board Directors are also

members of Chapter Zero New Zealand, a global network

of board directors committed to acting on climate change.

This ensures that the Board is exposed to and aware of

external trends and best practice relating to climate

risk and governance. In FY25, several Directors have

completed further education to expand their knowledge

on sustainability. As NZKS enters its second year of climate

reporting the Board has maintained clear visibility of the

reporting process, and the subsequent management of

risks and opportunities.

To manage climate-related matters, the Board delegates

part of its responsibilities to the Audit, Finance and

Risk Committee (AFRC). For FY26 this Committee will

become the Audit, Finance, Risk and Project Development

Committee. The AFRC assumes the key responsibility for

overseeing the CRDs and reporting back to the Board.

The AFRC also supports the Board by performing reviews

of NZKS’ primary business risks and its risk management

policy. The AFRC meets on a quarterly basis and hold

additional meetings as required in response to new data,

analysis or risk identification.

To ensure appropriate risk management is in place and

relative to the level of risk that has been assessed, the

Board receives reports and briefings from the AFRC. In

FY25 the Board completed an internal risk appetite review,

which provides a risk reference framework for Management

and the AFRC to consider when forming risk management

responses. The Board has access to all reports presented

by Management for both Committee and Board meetings.

During Board meetings, Directors also have the opportunity

to discuss and understand Management’s response to

how risks, including climate-related matters, are being

addressed. This supports appropriate risk oversight by

the Board. During FY25 the Board received briefings

and updates on various climate-related matters, which

included:

• A review of the Greenhouse Gas (GHG) emissions

inventory and trends across the period.

• Hydrological mapping for each freshwater site was

presented across two meetings. The meetings included

the external experts who prepared the reports, allowing

the Board to ask specific questions on these reports.

• An update on the sustainability risk review, led by

Management, outlining how risks changed — or

remained the same — following the formalisation of

climate risks in FY24.

• General updates on the consultations that related to

the climate-reporting disclosures and Management’s

view on the various proposed changes.

The Fish Farming Committee (FFC), also supports

the Board in its oversight of climate-related risks and

opportunities, through the identification of the risk and

opportunities specific to fish farming operations. This

approach supports the ongoing focus on improving fish

health and performance and farming strategies. Climate

change and the associated risk is a critical consideration of

this committee. Specific internal reporting delivered by the

FFC to the Board relates to:

• Consideration of water temperature on sea farms and

resultant interactions;

• Progress on the breeding programme and specifically

thermotolerance;

• Harvest progress during summer at NZKS sea farms;

and

• Fish welfare indicators.

9New Zealand King SalmonClimate-Related Disclosures FY25 — GovernanceContents

Tools and mechanisms
The Board uses the following mechanisms to provide oversight of Management in relation to

climate-related risks and opportunities, and to set objectives for climate-related issues:

Risk Management Framework:

Annual reviews of the NZKS Risk Management

Framework are conducted to ensure alignment with

the climate-related considerations and stay up to

date with indicators and the latest climate science.

In FY25 risks have been reviewed and reassessed

and are referenced in the NZKS FY25 Annual Report

released in late March 2025.

Reporting:

Review of the Enterprise Performance Report, which

includes a section on sustainability, carbon emissions,

an overview of any significant movements in

emissions and other general sustainability matters.

Risk Matrix Tools:

Ensuring that key climate risks identified in risk

matrix reviews are reported to the Audit, Finance

and Risk Committee and addressed appropriately.

When GHG emission reduction targets are set, this

committee will also be responsible for overseeing the

reporting and progress on this. In FY25, the focus was

on continuing to work through understanding the

emissions profile including working with a third party

to identify any decarbonisation projects. External

assurance for GHG emissions was undertaken for

FY25 across Scope 1, 2 and 3.

Remuneration:

Specific sustainability remuneration metrics for the

Senior Leadership Team, under the existing Short-Term

Incentive (STI) scheme have been under consideration

by the People and Performance Committee (for FY26

this committee will become the People, Performance

and Safety Committee). Currently remuneration has

not been aligned specifically to climate-related risks

and opportunities or sustainability metrics, however,

as the commercial viability and performance of NZKS

is inherently linked to advancing the sustainability

agenda the existing incentive structure for the Senior

Leadership Team does by default reflect achievement

and progress in sustainability. As trends emerge from

multiple years of disclosure and analysis, STIs linking

to climate-related risks and opportunities and specific

metrics will be considered.

Policy:

Annual reviews are conducted of relevant policies.

Management is in the process of reviewing a specific

sustainability policy that will be delivered in FY26 and

which supports the new NZKS strategy.

NZKS Strategy:

The Board was involved in the establishment of a

company strategy refresh during FY24, that was

refined and finalised in FY25 to deliver the new

purpose statement, “Towards a Healthier Tomorrow”.

Sustainability is a central consideration in this whole

of company strategy. In FY25 the sustainability

team continued to ensure an ESG focus in the Board

approved work plan.

10New Zealand King SalmonClimate-Related Disclosures FY25 — GovernanceContents

Management’s role in assessing and
managing climate-related risks and

opportunities

The Board delegates climate-related responsibilities to

the NZKS Executive and monitors this through specific

mechanisms such as a standing agenda item at Board

meetings and ensuring relevance of internal policies

outlined previously. The Executive comprises the Chief

Executive Officer, the Chief Financial Officer and relevant

General Managers. This Executive group is assigned the

responsibility for advancing the company strategy, which

includes sustainability, and the oversight of climate-related

risks and opportunities in the business.

The Executive is supported by the sustainability team

who is tasked with overseeing the implementation of

sustainability-related parts of the strategy across the

business as well as regular reviews of the business’ climate-

related risks and opportunities. The sustainability team in

FY25 includes the:

• Head of Finance & Sustainability

• Sustainability Manager; and the

• Sustainability Finance Manager.

This core sustainability team work together closely and

meet frequently to specifically discuss the sustainability

work programme. This team also meets twice a year with

the Chief Financial Officer and the General Manager who

oversee the risk register to review and amend climate-

related risks and opportunities as required. This team

reports through to the Board on any key sustainability

developments and any newly identified risks, assisting the

Board in fulfilling its responsibilities related to identifying,

assessing, monitoring, and managing climate-risk. The

sustainability team provides updates to the Board and

AFRC at every Board meeting, involving various levels of

Management in the process (refer to Governance structure

on page 12).

The sustainability team also leads the internal Sustainability

Committee. This committee is made up of the Chief

Executive Officer, Chief Financial Officer, relevant General

Managers and other key team members across the

business, who join project discussions as required. This

often includes NZKS’ Research & Development Manager

and Head of New Product Development. The Sustainability

Committee meets multiple times a year and is responsible

for assessing internal sustainability projects and reporting

on any projects or sustainability initiatives delivered in

the business. The sustainability team is also responsible

for preparing the sustainability section of the Enterprise

Performance Report that is reported through to the

Board. During FY25, the sustainability team has brought

in an internal consultant to help evolve the reporting

and modelling of the climate risks to enhance the

understanding of key risks and related metrics, as well as

commencing work on establishing an appropriate internal

methodology to quantify the potential financial impact

from climate change. This is important to ensure focus is

placed on the most significant risks.

11New Zealand King SalmonClimate-Related Disclosures FY25 — GovernanceContents

Audit, Finance &
Risk Committee

(meets at a minimum

quarterly)

• Ensures risks are managed in

accordance with NZKS risk

management framework.

This includes key climate

risks being brought to the

committee for detailed

review annually

• Oversees NZKS’ reporting

requirements including

climate-related disclosures

as well as the broader ESG

work programme

Fish Farming Committee

(meets as required)

• Responsible for the identification of the risks and opportunities specific

to the fish farming operations and review of the management of these

risks

• Focused on the ongoing improvement in fish health and farming

strategies

People & Performance Committee

(meets quarterly)

• Responsible for making recommendations to the Board as to its size

and composition to ensure that the Company has access to the

most appropriate balance of skills, qualifications, experience, and

background to effectively govern the Company

• Responsible for making recommendations with respect to executive

incentive remuneration plans having regard to financial and non-

financial goals and how these align with Company strategy and

performance objectives

Executive Team

(reports to all Board meetings and AFRC meetings)

Includes Chief Executive Officer, Chief Financial Officer and relevant General

Managers

• Responsible for implementation of strategy across the business and

oversight of the climate risks and opportunities

Core Sustainability Team

Includes Head of Finance & Sustainability, Sustainability Manager,

Sustainability Finance Manager

• Responsible for preparation of carbon inventory and preparation of

climate-related disclosures

• Responsible for supporting the Executive in driving the sustainability

strategy in the business and reporting through to Executive and Board on

sustainability projects

• Supporting the Executive with the identification and review of NZKS’

climate-related risks and opportunities

Sustainability Committee

(meets ~6 times annually)

• Responsible for overseeing and reporting on sustainability projects and

initiatives across the business

Other

• Key team members across all aspects of the business, including finance,

aquaculture and strategy, provide practical and pragmatic support and

advice to the sustainability governance structure as required

• External independent advisers also provide support where required

Board Oversight

Management

Main Climate Reporting

Committee

Supporting Committees

• Approves NZKS strategy including supporting strategies e.g

Sustainability Strategy

• Ensures Board skills, size and composition are fit for purpose

• Reviews and supports management processes in relation to the

risks and opportunities of the business including climate risks

NZKS Board

(meets ~10 times annually)

• Supports the development and implementation of climate-

related metrics and targets to enable the Board to effectively

review and monitor the progress of the Company in future years

• Reviews remuneration policies and short term incentive schemes

of Senior Leadership

Key Management Roles reporting to

Executive Management

Governance structure for climate-related responsibilities

An outline of the Governance structure and the frequency of updates and

monitoring on key climate-related responsibilities is provided below.

12New Zealand King SalmonClimate-Related Disclosures FY25 — GovernanceContents

Strategy
13New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Strategy
NZKS has continued to use the same

climate-related risk assessment framework

and climate scenarios as the previous

reporting period (31 January 2024).

This internal framework and the scenarios used, support

NZKS’ understanding of the potential climate-related

risks and opportunities that may impact operations, and

how certain climate indicators may change under the

various scenarios. Risks determined not identified pre

FY24 were subsequently included in the enterprise risk

register to ensure appropriate Board and Management

review and consideration. The combination of internal

risk considerations, alongside climate scenarios allows for

proactive management of these risks.

The climate-related risk assessment framework established

in FY24 was based on workshops with various internal

stakeholders and ranked the risks using the NZKS risk matrix

to identify risks that were of a priority nature i.e., the risks

that may have a significant impact on NZKS’ operations. A

further workshop considered these risks and opportunities

over the NZKS risk assessment time horizons and how risk

and opportunities may differ under the various climate

scenarios. This assessment was considered again in FY25 by

Management. As there have been no significant operational

changes and no other significant impacts on the business in

relation to these risks, the identified risks and opportunities

have not changed.

The climate scenarios used for both FY24 and FY25 were

built on the foundation of The Aotearoa Circle’s ‘Climate-

related risk scenarios for the 2050s’, specific for the Marine/

Seafood Industry in addition to, a scenario from the

Network for Greening the Financial System. They have been

adapted by NZKS to make them more specific for the risks

and opportunities identified by the business. The scenario

frameworks used also align to the scenarios used

by other Climate Reporting Entities (CREs) in the

aquaculture industry.

In FY25, NZKS became a partner to The Aotearoa Circle. This

enabled the involvement and active collaboration with key

stakeholders in the seafood industry to help the development

of the Seafood Nature, Climate and Te Ao Māori Scenarios.

This is an ongoing project that will be finalised in FY26. The

process is facilitated by an external sustainability advisory

firm and involved multiple workshops and meetings. As this

scenario work is an ongoing project it has not been utilised in

the current reporting. The outcome of this work is expected

to be refined and tailored to NZKS, for use in future climate-

related disclosures. NZKS does not expect updated scenarios

to change how the business currently responds or assesses

climate-related risks or opportunities. Rather, the intent is

to ensure alignment with the wider industry and to consider

any new risks or opportunities that may not yet have

been identified. Based on the scenario work to date, NZKS

does not see the currently disclosed risks or opportunities

materially changing.

14New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

A description and specific characteristics of each
scenario considered are detailed in the table below.

Scenario

Kahawai 2050

“Orderly transition”

Disorderly

“Delayed transition”

Mako 2050

“Intense and severe outcomes”

DescriptionThis scenario describes a 2050 world that has succeeded

in implementing the Paris Agreement (net zero by 2050).

The NZ Government has implemented legislation that

has acted as key drivers in the country’s transformation.

By mid-century, New Zealand’s aquaculture and fisheries

sectors have become carbon-neutral, powered by new

technologies. New Zealand’s marine governance system

becomes more flexible and collaborative, enhancing

the resilience of aquaculture operators. Due to the

transparency, sustainability and social equity of our

marine governance and food production systems, New

Zealand enjoys a strong comparative advantage in the

global marketplace.

This scenario describes a world where annual emissions

have not started decreasing until 2030. The slow initial

response has required strong national and global policies

to limit warming to below 2°C. The commercialisation

of lower carbon technology is only emerging in response

to the later legislative changes, meaning a slower

decarbonisation pathway for business in New Zealand.

Actions taken by businesses affected by climate change

are reactive rather than proactive, which means solutions

are more expensive.

This scenario describes a 2050 world where change

moves rapidly through the marine domain, a failure to

curb emissions has meant significant climate disruption.

The consequences of climate change have increased

the stressors on the environment and in turn increased

economic pressures on businesses that rely on the

environment for survival. Government policies are slow to

change and the costs of adaptation to climate change is

prohibitive to some businesses and industries.

Policy Ambition1.5ºC (<2ºC) 2ºC>3ºC

RCP/SSP

Combination Used

RCP 2.6

SSP1

RCP 2.6

SSP2

RCP 8.5

SSP3

Physical Risk SeverityLow - ModerateModerateExtreme

Policy ReactionImmediate and smoothDelayed - strong policies once implementedLagging, minimal change from current policy

Technology ChangeFast ChangesSlow/ Fast ChangeSlow Changes

Global Population8.5b8.26b11b

Marine Bio-Physical

Impacts (To 2050)

+0.8ºC coastal sea surface temperature+0.8ºC coastal sea surface temperature+1.5ºC coastal sea surface temperature

+0.23 m sea level rise+0.23 m sea level rise+0.28 m sea level rise

8.0 pH ocean acidification8.0 pH ocean acidification7.94 pH ocean acidification

1% decline in dissolved oxygen1% decline in dissolved oxygen2% decline in dissolved oxygen

15New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

These scenarios enable a level of comparability to other
aquaculture businesses as they have been used by others in

the sector when assessing climate risks and opportunities.

For the purposes of the climate scenario analysis, the time

scale is longer term. For internal risk assessment, NZKS have

used nearer term, time horizons. However, NZKS climate

risks and opportunities have been informed by the above

climate scenarios. NZKS has used the time horizons as the

broader NZKS enterprise risks, to support the appropriate

prioritisation of climate-related risks by the Board and

Management. Under all scenarios the level of uncertainty

increases over the longer term, as the effects of climate

change become more evident, yet the outcomes are

increasingly uncertain.

Time Frames:

A comprehensive examination of the value chain from

hatchery to distribution was completed to determine the

potential physical and transition risks from changes to the

climate. The climate risk assessment included locations

and operations that are deemed important and material

to NZKS, including hatcheries in Takaka and Tentburn,

sea farms in Tory Channel, Queen Charlotte Sound, and

Pelorus Sound, as well as the Nelson-based processing site.

The climate risk assessment was predominantly limited to

New Zealand and focused on logistics operations under

NZKS’ control. Transitional risks considered the broader

supply chain in the context of export markets, consumer

preferences and government policies, as exports form a

significant part of the NZKS business.

The value chain was reassessed for FY25 and was

considered to remain appropriate. One operational

change for FY26 will be the Blue Endeavour pilot farms

becoming operational. In the value chain assessment, the

pilot farms will fall under the sea farm locations. There is

no expectation that the additional farm will change the

currently identified sea farm risks. However, the additional

water space may mitigate the risk of livestock being held

across only one channel in the warmer summer months.

This mitigation of risk cannot be fully assessed until the

pilot is completed.

The climate scenarios informed the assessment of

NZKS’ climate-related physical and transition risks and

opportunities. NZKS note that climate-related risks and

opportunities are dynamic and as such this section does

not (and does not purport to), set out all the climate-

related risks and opportunities that may affect NZKS. This

is due to the risks and opportunities either being unknown,

or currently assessed as lower priority based on internal risk

assessments. All risks have been reviewed to ensure they

have remained relevant for FY25. A key evolving risk which

has been highlighted in the NZKS FY25 Annual Report, is

access to suitable water space. This specific risk is noted

Scenario Analysis

Time Scale

Risk Assessment

Time Horizon

Short term2025 to 20301-3 years

Medium

term

2031 to 20504-10 years

Long term2051 to 2100>10 years

Risk/Opportunity LevelAction

High

Highest priority for

Management effort to

mitigate or eliminate

MediumMonitor closely

LowMaintain awareness

under the regulatory and legal section of the climate-

related risk/opportunity table on pages 17-19 and is a key

consideration in an uncertain regulatory environment.

The table outlines the material, current and anticipated

physical and transition climate-related risks and

opportunities, identified and agreed by the Board

and Management. NZKS has determined risks as material

if they have been identified as priority 1 or 2 on NZKS’ risk

matrix. The table also discloses the current financial impact

in relation to the identified physical and transition risks and

opportunities. NZKS has utilised the exemption available

and has not disclosed the anticipated financial impact of

the identified physical and transition risks.

16New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Climate-Related
Risk/Opportunity

Current ImpactAnticipated Impact

Risk Assessment Time Horizon

Management Responses Identified to Date

1-3

years

4-10

years

>10

years

Marine heatwaves

cause more

persistent high

summer sea

temperatures

(Physical Risk)

There has been no physical

impact on the business during

FY25 from this risk.

There was no material

financial impact in FY25 in

relation to this risk.

Warming waters are expected

under all scenarios. Expectation on

increased capital expenditure for

additional water space requirements

and research and development

expenditure on thermotolerance.

Prolonged warming waters may

contribute to elevated mortality

by providing the environment for

additional stressors to impact

the livestock in the water, such as

bacteria, algae blooms etc.

Management is investing in thermotolerance, which is a long-term

breeding project to increase resilience of salmon in warmer water

temperatures.

Management is allocating significant capital to the Blue Endeavour open

ocean pilot to provide additional water space for NZKS to farm in the

medium/long-term.

More frequent

and longer dry

spells and drought

(Physical Risk)

There has been no physical

impact on the business during

FY25 from this risk.

There was no material

financial impact in FY25 in

relation to this risk.

There is an increased risk of drought

and water restrictions at multiple

production sites.

Management has conducted a hydrology mapping exercise on the two

freshwater sites to better understand the risks of drought. This enables better

planning and use of capital to mitigate risks in the medium/long-term.

Management has considered improvements around water recirculation

and is actively working on a Recirculating Aquaculture Systems (RAS)

project in the short-term for the Tentburn site. Freshwater planning is also

being undertaken by the aquaculture team in determining the medium to

long term projects. Water use improvements at the current processing site

are being considered, however Management’s key focus is understanding

this risk on a greenfield site.

Coastal and

estuarine

flooding:

increasing

persistence,

frequency and

magnitude

(Physical Risk)

There has been no physical

impact on the business during

FY25 from this risk.

There was no material

financial impact in FY25 in

relation to this risk.

There is expected to be an increase

of flooding at freshwater sites,

which may cause damage to

infrastructure.

Management has conducted a hydrology mapping exercise on the two

freshwater sites to better understand the risk of floods. This enables better

planning and use of capital to mitigate risks in the medium/long-term.

Management has mitigated short-term flooding risk by improvements to

culverts at Tentburn. Management is also investigating other capital spend

options to decrease flood risk as part of resilience planning. All future

business cases for capital expenditure now take into account the hydrology

reports to ensure new projects are built at an appropriate level to mitigate

the impacts of a flood.

HighMediumLow

17New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Climate-Related
Risk/Opportunity

Current ImpactAnticipated Impact

Risk Assessment Time Horizon

Management Responses Identified to Date

1-3

years

4-10

years

>10

years

Increased storm

and extreme

wind events

(Physical Risk)

There has been no physical impact on the business

during FY25 from this risk.

There was no material financial impact in FY25 in

relation to this risk.

As storms become more frequent

and severe, there is a potential

risk that sea farm assets, roading

networks, and potentially other key

infrastructure may be affected,

adversely impacting the NZKS supply

chain from harvest to distribution.

NZKS has alternate routes to get harvest from

seawater sites and domestic/export logistics has

experience in moving goods when routes are closed.

Regulatory and

legal

(Transition

Risk and

Opportunity)

The nature of this risk and opportunity is that there

is always a current impact on the business that must

be considered. In FY25 outside standard consent

processes and current compliance obligations, there

have been some additional opportunities identified.

There was the opportunity to mitigate future risks in

relation to offshore renewable energy infrastructure,

which was done via a submission to parliament on

the Offshore Renewable Energy Bill. Depending on

Management’s next steps in relation to renewable

energy infrastructure, the ongoing consideration of

this risk area would fall under the ‘new and emerging

technology’ risk/opportunity section of this analysis.

There was no material financial impact in FY25 in

relation to this risk or opportunity.

Yet to be determined, future

regulatory requirements around

resource consents including

monitoring and reporting

obligations.

Alternatively, the regulatory

environment could be an

opportunity as salmon is a low

carbon protein, which may be seen

as an industry for the Government /

Councils to support via more flexible

resource consent conditions.

NZKS is actively involved in regional processes led

by industry groups including being a part of active

discussions on the Marlborough Environment Plan.

NZKS is also actively focussing on engaging with

wider stakeholders of the business such as iwi, NGOs,

central and local government.

The regulatory and legal environment is being

actively monitored by NZKS. Current management

focus is on the short-medium term, as – like

any transitional risk – it is an evolving space and

outcomes can be difficult to predict. Management

processes therefore need to remain flexible to adapt

quickly to new frameworks.

Financial

(Transition Risk)

There has been no impact on the business in relation

to this risk/opportunity during FY25.

There was no material financial impact in FY25 in

relation to this risk.

Potential increased costs to the

business, such as freight costs,

introduction of carbon taxes /

regulations, insurances and

reporting obligations. Increase in

the need for capital expenditure for

business resilience to mitigate the

effect of climate change.

Management is investigating options and

viability of moving air freight to sea freight to reduce

carbon emissions.

Management proactively manages NZKS’ risk-based

insurance programme.

Management understands that capital expenditure

is likely to be required to support the business

in adapting to a lower emission business, this is

currently being considered in future capital planning.

HighMediumLow

18New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Climate-Related
Risk/Opportunity

Current ImpactAnticipated Impact

Risk Assessment Time Horizon

Management Responses Identified to Date

1-3

years

4-10

years

>10

years

New and

emerging

technology

(Transition Risk

and Opportunity)

There has been no impact on

the business in relation to this

risk or opportunity during FY25.

There was no material financial

impact in FY25 in relation to

this risk or opportunity.

NZKS expects improvements

in technology will provide the

opportunity to become more

efficient and therefore reduce

carbon intensity measures. NZKS

will continue to assess the risks and

opportunities of adopting emerging

technology as part of future capital

investment decisions.

Management is exploring potential projects, such as a greenfield

processing site to drive lower emissions and adoption of more efficient

technologies.

As part of the decarbonisation pathway work undertaken in FY25,

Management identified potential new and emerging technologies that

they will continue to monitor closely. This will enable NZKS to identify

opportunities early and mitigate the risk of being slow to adapt compared

to others in the industry.

Market access/

consumer

demands

(Transition Risk

and Opportunity)

There has been no impact on

the business in relation to this

risk or opportunity during FY25.

There was no material financial

impact in FY25 in relation to

this risk or opportunity.

There is potential risk around

increased regulation on packaging,

entry requirements and tariffs to

gain access to export markets.

Alternatively, this could be an

opportunity as salmon is a low

carbon protein, which may be seen

as a preferred import product.

Consumer preference may also

move to a lower carbon protein

choice.

This is currently monitored by Management to identify any market

access /consumer changes that may impact on operations. Management

utilise resources such as New Zealand Trade and Enterprise (NZTE) to stay

informed on the changing regulatory environments overseas.

Reputational

(Transition Risk

and Opportunity)

There has been no impact on

the business in relation to this

risk or opportunity during FY25.

There was no material financial

impact in FY25 in relation to

this risk or opportunity.

An increased focus on the climate

space has the ability to be both a

risk and an opportunity for NZKS,

depending on how stakeholders

interpret climate-related disclosures

and other ESG actions.

NZKS has prepared this report which sets out its CRDs.

NZKS continues to achieve third-party certifications such as the Best

Aquaculture Practices (BAP) certification, which supports the company’s

commitment to responsible operational practices and therefore it’s

reputation as a trusted operator.

Management is committed to better understanding its GHG emissions

and how to practically implement carbon reduction projects identified

in FY25.

HighMediumLow

19New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Financial Impacts
Management have assessed that there is no material

current financial impact in relation to any climate-related

risks disclosed in the previous table. In assessing and

quantifying the current financial impact attributable to

climate change, Management determine what component

of cost exceeding forecasts can be attributed directly to

climate-related risks or opportunities, and is therefore not

related to other seasonal, Management, or operational

decisions or challenges. This assessment can be difficult and

is often judgement-based. NZKS is working to improve the

tracking of these costs and the development of an internal

climate risk attribution methodology, to enable easier

reporting for years where climate-risks do have a material

impact on operations. Before climate-related disclosures

were required, NZKS experienced impacts that could have

been attributed partially to climate risks. Management

is using these impacts to support the formation of the

financial impact methodology. Examples of the impacts

include elevated mortality occurrences and increased

freight costs due to road closures.

NZKS has elected to not disclose the anticipated financial

impacts in relation to the physical and transition risks

identified. However, during FY25, Management commenced

work on developing systems and models that allow for this

to be carried out in future financial periods. It is important

to note that there is currently no prescribed methodology

available for this.

At a high level, NZKS will assess the anticipated financial

impact of an event based on two key considerations:

1. Financial magnitude of event, in terms of maximum

potential financial impact; and

2. Probability of event occurring on an annual basis.

The potential financial impact of a risk materialising is

based on first looking at actual historical data from an

event occurring and then adjusted for any mitigations or

business model changes that would make the data no

longer representative of that risk. Where the risk event

has not occurred previously, the financial cost has been

calculated from looking at the impact of the event on

current and future production, along with any other

financial impacts due to repair or remediation. Where there

is no ability to determine specific cost or financial impact

due to the range of variables, an estimate range has been

used to ensure each risk is considered appropriately. This

is a pragmatic and efficient approach to quantification of

financial risk and allows for focus on risks that are

more significant.

Probability is the second key consideration in calculating

anticipated financial impact. Where possible, as a first step,

specific data would be utilised to support this, however it

is often not possible to obtain a specific probability. The

second step is to look at frequency of event over the past

decade and consider whether this is likely to continue

at the same rate or increase under the different climate

scenarios. Again, research can provide some guidance, but

specific probabilities are inherently difficult to determine

with precision. Lastly, in assessing probability, a Management

thought discussion will be conducted with relevant key

stakeholders who have experience in the areas of risks to

look at the possible occurrence over the next 30 years and

this is then converted into an annual probability estimate.

The finalisation of this internal methodology to quantify

climate risks, will be a key focus of FY26. As with any

methodology that relies on historical data and significant

judgements in relation to the future, the expectation is that

the anticipated financial impact disclosure would be

disclosed as a financial range, and would be caveated with

the limitations that are inherent with judgments being made.

20New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Transition Plan
The identified climate-related risks and opportunities

have been integrated into broader business planning and

capital allocation decisions, to ensure that NZKS is taking

proactive steps towards transitioning to a lower carbon

future and to mitigate potential risks to the business.

The current Management response to the identified risks

and opportunities do not differ significantly under the

various climate-related scenarios. This is due to the current

Management response either being the most commercially

viable option available to NZKS and/or limited optionality

available to mitigate the risk. Or further information is

required to fully form a Management response to the

climate-related risk or opportunity.

Due to the long term nature of the climate scenarios, it is

expected the Management response will change over time,

as the anticipated climate impacts become clearer and

definitive information is more readily available.

The climate risk assessment undertaken annually will

continue to utilise the scenarios to consider plausible future

risks and opportunities to ensure NZKS response is more

proactive than reactive, within the various limitations on

the business.

As noted in the Governance section, the current business

strategy supports an increased focus on sustainability and

risk management. When projects are presented to the

Board seeking approval of capital expenditure, there is a

deliberate focus on sustainability outcomes and emissions

reductions. As part of capital allocation decisions, ESG is

also considered as an input into a project’s hurdle rate (i.e

with all other variables being held consistent the better

the ESG outcome would generate a lower hurdle rate -

therefore improving the prioritisation of the project). This

embedding of sustainability has also created a focus on

making the business more resilient to climate and broader

ESG risks and allows for early identification of potential

opportunities for NZKS.

21New Zealand King SalmonClimate-Related Disclosures FY25 — StrategyContents

Risk Management
22New Zealand King SalmonClimate-Related Disclosures FY25 — Risk ManagementContents

Risk Management
NZKS employs a structured risk

management approach that utilises

a 5x5 matrix of consequence severity

and likelihood.

The risk management framework enables the Board and

Management to assess various business and climate-related

risks, potentially impacting our operations, environment and

communities. This allows the business to take appropriate

steps to mitigate and manage these risks effectively.

NZKS utilises the risk assessment framework to rate and

compare climate-related risks against other business risks.

There is a bi-annual review of sustainability risks within the

NZKS risk framework by the sustainability team and risk

leaders. There is also an annual workshop with the Chief

Executive Officer, Chief Financial Officer, relevant senior

leaders, and the sustainability team, to reassess and update

the climate-related risks and opportunities, to ensure the full

defined value chain is considered. This also supports NZKS’

continued commitment to sustainability, transparency, and

responsible business practices.

The risk rating system used for wider business risks is also

employed for climate-related risks, considering the likelihood

and severity of their associated consequences. The risks

are prioritised based on their severity and categorised into

priorities 1-4. Those rated as priority 1 require immediate

action, where possible, to proactively manage risk and limit

exposure. The climate-related risks that have been rated

priority 1 or 2 from the climate-risk workshops have been

condensed and included in the Company’s overall enterprise

risk register. This ensures climate-related risks are considered

in the same way as other business risks.

Communication & FeedbackMonitoring & Risk Review

Scope and Boundaries Established

Risk Identification

Risk Assessment

Risk Management

Risk Management Process

23New Zealand King SalmonClimate-Related Disclosures FY25 — Risk ManagementContents

Metrics and Targets
24New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

NZKS recognises the importance of
monitoring and mitigating GHG emissions.

In FY24, NZKS undertook a comprehensive assessment

and reporting exercise of its Scope 1, 2 and 3 GHG

emissions with reference to the Greenhouse Gas Protocol,

and set FY24 as the baseline for future target setting

and evaluation. FY25 GHG emissions build on this prior

foundation.

NZKS emissions profile

NZKS measures its GHG emissions in accordance with the

requirements of the ‘Greenhouse Gas Protocol – A Corporate

Accounting and Reporting Standard’. As reporting of

climate-related metrics and targets is an emerging area,

often the data and methodologies used are developing and

uncertain. NZKS reports its GHG emissions in tonnes of CO

2


equivalents (tCO

2

e), in compliance with the requirements

set by the Aotearoa New Zealand Climate Standards. There

has also been guidance from the following sources:


Greenhouse Gas Protocol – Corporate Value Chain

(Scope 3) Accounting and Reporting Standard

•Gre

enhouse Gas Protocol -Technical Guidance for

Calculating Scope 3 Emissions (version 1.0)

Metrics and Targets

Emission factors utilised in FY25 have been from the

following sources:

•Ministry for the Environment (MfE) 2024 ‘Measuring

Emissions: A guide for organisations’ (NZ)

•Department for Environment Food & Rural Affairs

(DEFRA) 2024 ‘Greenhouse gas reporting: conversion

factors’ (UK)

•Department of Climate Change, Energy,

the Environment and Water (DCCEEW) -

Hydrofluorocarbon refrigerants – global warming

potential values and safety classifications (Australia,

202

4)

•Environmental Product Declaration (EPD) product

specific emission factors for similar items to products

purchased (2023)

•Motu Economic and Public Policy Research

‘Consumption-based greenhouse gas emissions input-

output model’ (2007)

•Supplier specific emission factors for feed (2023, 2024

&

2 025)

The emission factor sources are based on global warming

potentials (GWPs) varying from AR4-AR6.

NZKS boundary

NZKS applies the financial control approach when

calculating emissions. Determination of control follows the

same approach taken when consolidating New Ze

aland

King Salmon Investments Limited for financial statement

purposes. Organisational boundaries were applied with

reference to the methodology described by the GHG

Protocol. NZKS has financial control over all the entities

that comprise New Zealand King Salmon Investments

Limited Group. Emissions in NZKS control are Scope

1

and Scope 2 emissions and are identified from across the

entire NZKS operations - hatcheries, sea farms, processing

operations, distribution and offi

ce areas.

The current GHG Protocol guidance suggests leases that

have the characteristics of operating leases are reported as

Scope 3, ‘Category 8: Upstream leased assets’ for reporting

entities with a financial control approach. However,

consistent with the principles of NZ IFRS 16 Leases, NZKS

recognises lease assets in the statement of financial

position as a right of use asset and has determined that,

during the lease period, NZKS has the right to control the

use of the asset as well as the right to substantially all of

the related economic bene

fits and therefore have included

the related emissions in Scopes 1 and 2.

Emissions from sources over which NZKS does not have

financial control, but forms part of the NZKS value chain,

are included as Scope 3 indirect emissions.

25New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

immaterial, and the uncertainty associated with this
estimation is high.

•Category 13 - Downstream leased assets: No specific

data available and NZKS does not lease out any

significant assets. Therefore the estimated impact is

immaterial.

•Category 14 - Franchises: Not applicable due to no

franchised business.

•Category 15 - Investments: Not applicable.

Metrics and Targets

NZKS’ total GHG emissions and GHG emission intensities

for FY25 are disclosed in the tables below. The emissions

are the total GHG emissions measured in accordance with

the Greenhouse Gas Protocol guidance. Methodologies,

assumptions, and estimation uncertainties in preparing the

GHG emissions are set out in the Appendix. Scope 1, Scope 2

and Scope 3 GHG emissions for FY25 are subject to limited

assurance by PwC. Refer to the PwC assurance report on

page 38 to 43 for further details.

Emissions sources excluded

The basis for exclusion of emissions from NZKS GHG

emissions calculations in FY25 are either that they are:


Not applicable to NZKS operations, or


Not material in the context of the GHG inventory (not

greater than 5% of a particular scope of emissions), or


Not technically feasible or cost effective to be

quantified with accuracy at present

Estimates and assumptions were applied in situations

where there was a lack of available data.

The below outlines the categories excluded and the

reasoning for this:


Category 7 - Employee commuting: Information is not

tracked, estimated impact is immaterial to overall

emissions based on estimates.


Cat

egory 10 - Processing of sold products: Partial

exclusion. Emissions from processing of sold offal into

fish meal are included in Category 10. Emissions from all

other types of further processing are excluded, due to

the unknown nature of these processes and insufficient

data, or the volumes being deemed insignificant.

Data quality challenges mean that the uncertainty

associated with this estimation is high.


Cat

egory 11 - Consumer use of sold product: As

no specific data is available, we have estimated

emissions based on assumed cooking techniques and

sold weights, however at present the emissions are

ScopeFY25 tCO

2

e

FY24 tCO

2

e

(restated)

A

Yo Y %

(decrease)/

increase

A

% of total

emissions

FY25

A

Scope 1

B

2,4082,434(1.1%)2.84%

Scope 25285250.6%0.62%

Total Scope

1 and 2

2,9362,959(0.8%)3.46%

Scope 3

B,C

81,99978,2574.8%96.54%

Total Scope

1, 2 and 3

84,93581,2164.6%100%

Absolute GHG emissions by Scope

A

No assurance by PwC is provided for the FY24 tCO

2

e, the YOY % (decrease)/

increase and the % of total emissions FY25.

B

For FY25 NZKS determined that fuel consumed by barging contractors previously

reported as Scope 1 was outside of its operational boundary. This has resulted in

a reclassification between Scope 1 and Scope 3 emissions of 1,185 tCO

2

e for the

previously disclosed balance in FY24.

C

Subsequent to the FY24 CRD being released a calculation error within the carbon

emissions software was identified by NZKS. The result of this error resulted in

FY24 Scope 3 disclosure being understated by 2,229 tCO

2

e and the FY24 Scope 2

disclosure being understated by 10 tCO

2

e.

The FY24 Scope 1 and Scope 3 emissions and Total Scope

1 and 2 and Total Scope 1, 2 and 3 emissions have been

restated to reflect the correction of the calculation error

and reclassification identified in footnote B and C.

26New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

Intensity indicators
FY25 -

Liveweight

(tCO

2

e/t)

FY24 -

Liveweight

(tCO

2

e/t)

Yo Y %

(decrease)/

increase

FY25 - G&G

(tCO

2

e/t)

FY24 - G&G

(tCO

2

e/t)

Yo Y %

(decrease)/

increase

Scope 1,2 & 3 emissions per

tonne (tCO

2

e/t)

11.0311.46(3.75%)12.5313.03(3.84%)

Scope 1 & 2 emissions per

tonne (tCO

2

e/t)

0.380.42(9.52%)0.430.47(8.51%)

GHG emissions Intensity

In FY25 Scope 1 and 2 emissions comprised 3.46% of the

NZKS total GHG inventory. At an absolute level, Scope

1 and 2 GHG emissions stayed relatively flat from the

prior year, with a decrease in emissions of 0.8%. This was

achieved through operational efficiencies and improving

organisational awareness of emissions, rather than specific

decarbonisation projects. These emissions were generated

in the context of both harvest volumes and sales volumes

increasing by 9% and 12% respectively in FY25, as disclosed

in NZKS’ Annual Report.

The largest source of Scope 1 emissions is attributable to

fuel consumption across sea farm operations at 73%. Scope

2 emissions are mainly driven by electricity consumed at the

Tentburn hatchery and Nelson processing site.

Scope 3 emissions at 96.54% of total emissions, is made

up of primarily upstream freight emissions; driven by the

airfreight related to the sale of predominantly fresh product

to export markets (53% of Scope 3), and the purchased

goods and services emissions via the purchase of salmon

feed (26% of Scope 3). The increase in Scope 3 as a

percentage from prior year, is mainly attributable to the

increased airfreight emissions.

From an emissions intensity perspective, there has been

an improvement across all metrics for FY25, based on

emissions increasing at a smaller percentage than the

overall increase to biomass harvested (liveweight and G&G)

compared to the FY24 period.

NZKS, as an exporter of a low carbon protein has plans

to expand though increased harvest production in the

medium term via expansion into open ocean salmon

farming. Currently NZKS’ Blue Endeavour open ocean pilot

is in progress with the first harvest expected in FY27. If

the pilot phase goes well and harvest volumes grow, it is

expected that NZKS’ absolute emissions will increase. NZKS

intend to dedicate effort into understanding steps that can

be taken to improve NZKS’ emissions intensity indicators, so

that the business becomes more carbon efficient. Therefore,

to have a flat Scope 1 and 2 in FY25 with the increased

harvest is a positive for NZKS, and highlights that the

future growth of the business does not necessarily coincide

with a proportionate increase in Scope 1 and 2 emissions.

27New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

Targets
For FY25, NZKS has not set absolute, or intensity GHG

emission reduction targets from the FY24 base year. The

limitations for NZKS around setting targets in a meaningful

way is outlined in more detail below. Overall, the decision to

not set targets, was primarily based on the inability to build

a robust, actionable reduction plan that Management could

accurately measure against. The decarbonisation options

considered either were already occurring and had minimal

impact, did not have enough GHG reduction potential to

make the time or cost to build a specific target appropriate

for external disclosure reasonable or the information required

to appropriately set a target were not available.

The decision to not set reduction targets was mainly driven

from the decarbonisation report commissioned in FY25, with

third party energy consultants. The focus for that report

was kept to Scope 1 and 2 emissions, as in general, Scope 1

and 2 are the emission sources generally considered easier

to quantify and control. This is because they are directly or

indirectly attributable to an entity’s operations.

In this report, various options were identified as having the

potential to create a decarbonisation pathway for NZKS.

The options ranged from smaller incremental changes such

as swapping out Halogen lighting for LED bulbs, through to

major changes and advances in renewable or sustainable

fuels. To assess the viability of the decarbonisation options

a marginal abatement cost calculation (MAC) was used to

determine whether a project should proceed.

Management assessed these opportunities and outside

some of the shorter-term projects, the options identified

were not reasonable to pursue at this time due to extremely

high MACs. This is reflective of the technology, or renewable

resource, not being commercially available at scale,

and as such the cost to implement and operationalise

these options sits well above the acceptable range for

commercial entities. Although the options identified did

not allow for immediate decarbonisation projects to be

implemented, they did provide other benefits. This included

broadening Management’s understanding of future

decarbonisation potential and put in place thinking that

could support these projects in the future.

The largest, longer-term opportunity identified in the

report related to the use of renewable diesel. This would

replace current diesel consumption, which is the largest

Scope 1 emission for NZKS. At present the MAC cost for

alternative diesel, combined with supply constraints, makes

this currently not a viable option. The decarbonisation

assessment highlighted renewable diesel as one of the

larger future opportunities for NZKS. This had not previously

been a major longer-term consideration for NZKS, however,

carrying out this work has enabled a new focus on key

alternative fuels and technologies in New Zealand. This will

allow these decarbonisation options to be realised as soon

as it’s a commercially viable option for NZKS.

A greenfield processing factory was also considered as

a key driver in GHG emission reductions. This project is

acknowledged as active, and the expectation is it will lead

28New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

to a reduction in the intensity of emissions. This expectation
is based on the current site being old and close to end-

of-life, and due to the layout of the site, processes are

not optimised for emission related efficiencies. Due to the

availability of information based on the stage of the project,

and important considerations that need to be made that

would affect the emission reduction options available,

Management is not able to meaningfully determine a

reduction target for this project.

Despite the challenges of high abatement costs driven by a

lack of commercially available options for some of the larger

opportunities, NZKS is making practical decarbonisation

steps where possible. This includes the shorter-term LED

lighting opportunity identified. This option has already been

implemented prior to the receiving of the decarbonisation

report and is a significant way though completion and

is being done on a replacement basis. The other projects

that have been identified in relation to energy use around

aquaculture sites have limited GHG reduction potential

for the cost associated, but will continue to be reassessed

annually to ensure nothing has changed in the business, or

a change in the availability of commercially viable solutions

that could allow NZKS to deliver the GHG reductions in a

commercially reasonable way.

Where possible, NZKS is continuing to maintain awareness

of risks and opportunities that may affect future

decarbonisation projects. For example, when Management

aimed to better define the costs associated with a

renewable energy option for the sea farms, they consulted

with external legal counsel to assess potential consent-

related challenges. This identified the potential impact of

the Offshore Renewable Energy Bill on NZKS’ operations.

This resulted in NZKS making a submission to this Bill.

The submission was to highlight and attempt to prevent

unintended consequences that may have prevented NZKS

generating its own renewable energy on farm. The ability to

generate renewable energy on sea farm sites from offshore

solar and wind is a key decarbonisation option for NZKS.

Therefore, it is important to be aware of potential impacts

to operations, and be proactive where possible to reduce

possible future risks.

NZKS is committed to better understanding its

environmental impact and as part of this, Management

continues to better understand current operational

practices, which may identify further opportunities to

reduce NZKS’ emissions profile or other non GHG emission

reduction impacts. Positive sustainability projects that

have had an impact in FY25, include the ensilage facility

and kidney line project. The ensilage plant commissioning

is complete and is fully functional. This project removes

organic waste from landfill and in turn reduces NZKS

waste to landfill carbon emissions. The kidney line project,

identified in FY25, highlighted the opportunity to capture

the kidney line earlier in the processing of fish at the

factory. This was then put into further processing to

become a key ingredient in nutrient-rich fish meal for

non-salmon applications. This outcome is far more positive

compared to being captured at the end of the process in

the trade waste, which is an expensive and not optimised

use of this remaining raw material.

29New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

In relation to Scope 3 emissions, NZKS do not intend to set
any immediate reduction targets. This is mainly due to the

reliance on third parties and the rapidly evolving external

landscape, where measurement benchmarks and standards

are continuing to evolve, making it difficult to meaningfully

report against targets. As Scope 3 emissions account

for over 95% of NZKS emissions, NZKS acknowledge

this provides the largest potential for overall emissions

reductions and will remain an ongoing focus in the short

term. In FY25 the NZKS’ focus has included engaging

with key freight suppliers to discuss the use of Sustainable

Aviation Fuel and working with feed companies to better

understand the emissions related to salmon feed. As this

space continues to mature a broader understanding of

various stakeholder requirements outside large suppliers

is continuing to be better considered, i.e. large customer

expectations and sustainability objectives. This ongoing

work will allow NZKS to plan future projects with a

sustainability lens in a more strategic, focussed way.

In terms of intensity targets, NZKS is still maturing in its

understanding of the drivers of emissions. This makes it

challenging to set an accurate intensity reduction target

that is based off a robust, documented reduction plan.

However, this year, NZKS managed to increase production

but keep Scope 1 and 2 emissions stable. Further work

is required by Management to better understand the

correlation between emissions and harvest and sales

volumes. To improve that understanding in FY26, the

carbon inventory will be split not just by category and

location but also by supplier, which may provide better

insights to support intensity target setting. Another

consideration for FY26, is the potential for the Blue

Endeavour pilot project to skew emission intensity metrics

as it will not be operated in an optimised way. This is due to

certain expenditure on the Blue Endeavour operations only

being commercially viable once the pilot is proved out and

operations are at commercial scale. To attempt to mitigate

this skewing of metrics, Management intends to try and

isolate Blue Endeavour related operations’ GHG emissions,

so intensity indicators can be disclosed from both a

business-as-usual production sites perspective, and with

the inclusion of Blue Endeavour operations. There have been

no Blue Endeavour related emissions in the FY25 period.

30New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

Other Climate-Related Metrics
As required by Aotearoa Climate Reporting Standards, NZKS

has also considered other metrics outside the specific GHG

emission disclosure requirements in relation to Scope 1, 2,

and 3.

NZKS’ value chain extends from egg to plate, it is fully

interconnected. Management therefore considers that

business activities are combined. This is aligned with

Management’s assessment of the business as one cash-

generating unit for financial reporting purposes. Therefore,

like other aquaculture entities and given the nature of the

business and in the absence of mitigation, up to 100% of

business activities are vulnerable to the climate-related

physical risks identified above; and up to 100% of our

business activities are also vulnerable to the transition

risks identified. The same can be said for any opportunities

identified.

As noted in the transition plan section of this document,

the identified climate risks and opportunities have been

integrated into broader business planning and capital

allocation decisions. No specific financing has been

obtained in relation to climate risks and opportunities.

NZKS currently does not have a set internal carbon price,

instead considering each decarbonisation project on

broader benefits and risk mitigation as discussed earlier.

As NZKS continues on a decarbonisation assessment and

implementation pathway, setting an internal carbon price

is something that may be considered in the future.

As discussed in the Governance section, there is no

remuneration that has been aligned specifically to

climate-related risks and opportunities. The existing

incentive structure for the Senior Leadership Team is

cognisant of achievement and progress in sustainability

and as trends emerge from multiple years of disclosure and

analysis, STIs linking to specific climate-related risks and

metrics will be possible.

There are no other specific industry metrics or key

performance indicators identified or used in measuring or

managing climate-related risks and opportunities outside

those already disclosed.

31New Zealand King SalmonClimate-Related Disclosures FY25 — Metrics and TargetsContents

Glossary and Appendix
32New Zealand King SalmonClimate-Related Disclosures FY25 — Glossary and AppendixContents

Glossary
AFRC

Audit, Finance & Risk Committee

AR4

Fourth Assessment Report from the IPCC

AR6

Sixth Assessment Report from the IPCC

BAP

Best Aquaculture Practices

CRD

Climate-related disclosures

ESG

Environmental, Social and Governance

EPD

Environmental Product Declarations

G&G

Gilled and gutted

GHG

Greenhouse gas

GWP

Global warming potential

IPCC

Intergovernmental Panel on Climate Change

LCA

Life Cycle Assessment

Liveweight

Weight of harvested

fish before gilling and

gutting, in tonnes

NGOs

Non-governmental organisations

NZ CS 1

Aotearoa New Zealand Climate Standard 1

Climate-related Disclosures

NZ CS 2

Aotearoa New Zealand Climate Standard 2

Climate-related Disclosures

NZ CS 3

Aotearoa New Zealand Climate Standard 3

Climate-related Disclosures

NZKS

New Zealand King Salmon Investments Limited

NZTE

New Zealand Trade and Enterprise

RCP

Representative Concentration Pathway

SSP

Shared Socio-economic Pathways

STI

Senior Leadership Short

Term Incentive

tCO

2

e

Tonnes of CO

2

equivalents

W

TT

Well-to-tank

33New Zealand King SalmonClimate-Related Disclosures FY25 — Glossary and AppendixContents

ScopeCategory
GHG emissions

source

Data sourced

Calculation methodology, assumptions,

uncertainty (qualitative)

Source of emission

factors

Scope 1

Stationary /

mobile combustion

Fossil fuels used

across business

Supplier dataFuel-based method. Low uncertainty.MfE (2024)

Fugitive emissionsRefrigerant used in

refrigeration systems

Maintenance recordsTop-up method.

Considers top-ups on equipment (including leased assets) on NZKS sites.

Low uncertainty.

MfE (2024), DCCEEW

(2024)

Scope 2

ElectricityElectricity

consumption

Supplier dataLocation-based method. Low uncertainty. Picton usage estimated based on percentage of lease

outgoings applied to activity data (~7% of scope 2).

MfE (2024)

Scope 3

Category 1:

Purchased goods

and services

FeedEmission factors

provided by supplier.

General ledger used

for quantities.

Sup

plier-specific method. High uncertainty.

Supplier-specific feed emission factors reflect specific cradle-to-gate emissions and are specific

to the feed composition purchased by NZKS. The emission factors are developed by feed

suppliers and based on their life cycle assessments. NZKS have a lesser degree of knowledge

and influence on suppliers’ data source quality and collection processes. NZKS rely on suppliers’

methodologies which include complex models, assumptions, estimations. These data challenges

contribute to higher uncertainty. In preparing the LCA, suppliers use internationally recognised

standards and relevant product environmental footprint category rules. In applying the

standards, suppliers use primary and secondary data sources, including databases, to prepare

the calculations. Adjustments are made relevant to the circumstances of NZKS i.e. feed origin

and composition specific to NZKS feed, geographic validity and transport distances to NZKS

sites. Suppliers apply technical expertise in selecting critical methods, estimates, assumptions

and judgements in preparing the LCA models, such as the assessment of Life Cycle stages and

climate change impacts, the allocation method (economic allocation) and selection of GWPs .

Emissions factors are updated on an annual basis and due to changes in estimates and

assumptions in the calculation, this could lead to significant va riation in Scope 3 emissions

between feed suppliers and over time.

Feed suppliers (2023,

2024 & 2025)

Appendix: GHG methodologies, assumptions, and estimation uncertainties

GHG emission quantification is inherently uncertain because of incomplete scientific knowledge

used to determine emission factors and the values needed to combine emissions of different gases.

34New Zealand King SalmonClimate-Related Disclosures FY25 — Glossary and AppendixContents

ScopeCategory
GHG emissions

source

Data source

Calculation methodology, assumptions,

uncertainty (qualitative)

Source of emission factors

Scope 3

Category 1:

Purchased goods

and services

PackagingGeneral ledgerAverage-data method. Purchases based on general ledger reports. Low uncertainty.DEFRA (2024)

Purchased salmon

and petfood

ingredients

General ledgerAverage-data method. Purchases and third-party manufacturing based on general

ledger reports. Medium uncertainty due to generic nature of emission factors, due to

unavailability of relevant emission factors. In relation to purchased petfood inputs, a

generic food emission factor has been used.

Similar products environmental

product disclosure (EPD, 2023)

and DEFRA (2024) for third party

manufacturing.

All other

consumables, raw

materials and other

expenditure

General ledgerSpend-based method. High uncertainty as emission factors is applied to a broad

category of spend and not based on specific activity data or supplier specific

emission factors.

Motu (2007), with annual inflation

applied

Category 2: Capital

goods

Purchase or

construction of

capital items

General ledgerSpend-based method, emissions recognised when asset capitalised in general ledger.

High uncertainty as emission factors are applied to a broad category of spend and

not based on specific activity data or supplier specific emission factors.

Motu (2007), with annual inflation

applied

Category 3: Fuel-

and energy-related

activities not included

in Scope 1 or Scope 2

Electricity

transmission and

distribution losses

(T&D)

Supplier dataAverage-data method. Emissions from T&D losses estimated based on scope 2 data.

Low uncertainty.

MfE (2024)

Electricity and fuel

well-to-tank (WTT)

Supplier dataAverage-data method. Emissions from WTT losses are estimated based on scope 1 &

2 data. Low uncertainty.

DEFRA (2024)

Category 4:

Upstream transport

and distribution

Transport of items

between internal

locations by third

parties (road and

sea transport)

Transport of finished

goods to consumer

(air, road and sea

transport)

Supplier dataFuel-based method. Low uncertainty.

Distance-based method. Medium uncertainty as all distances were estimated,

assuming direct routes between origin and destination location for all modes of

transport. Distance information was sourced from a generic internet search. In

addition, mass data, was estimated where not provided by suppliers (road freight).

MfE (2024), DEFRA (2024)

Transport of

feed (sea)

Supplier dataSupplier-specific method. Suppliers provide freight emission factor, multiplied with

quantities purchased from general ledger. Low uncertainty.

Feed suppliers (2024)

35New Zealand King SalmonClimate-Related Disclosures FY25 — Glossary and AppendixContents

ScopeCategory
GHG emissions

source

Data source

Calculation methodology, assumptions,

uncertainty (qualitative)

Source of emission factors

Scope 3

Category 4:

Upstream transport

and distribution

Transport of

packaging

(air, road and sea)

Transport of

purchased

salmon (sea)

General ledger data with

distance assumptions based

on supplier location

Distance-based method. Medium uncertainty as all distances were

estimated, assuming direct routes between origin and destination location

for all modes of transport. Distance information was sourced from a

generic internet search. In addition, mass data, was estimated from internal

accounting system.

DEFRA (2024), MfE (2024)

Transport of all other

goods purchased

General ledgerSpend-based method for freight paid on all remaining purchased goods

that have not been identified separately above. High uncertainty as

emission factors are applied to a broad category of spend and not based on

specific activity data or supplier specific emission factors.

Motu (2007), with annual inflation

applied

Category 5: Waste

generated in

operations

Waste - landfillSupplier dataAverage-data method. Low uncertainty.MfE (2024)

Category 6: Business

travel

Air travel, car rentals

and hotels and

accommodation

Supplier dataDistance-based method used for air travel using emission factors with

radiative forcing factors and car rentals. Nights-stayed method was used

for hotels and accommodations. Low uncertainty.

MfE (2024), DEFRA (2024)

Category 8: Upstream

leased assets

Fuel & electricity

used in leased assets

N/ADue to the inability to split data these emissions have been captured in

Scope 1 and Scope 2.

Category 9:

Downstream

transportation and

distribution

Travel from retailer

to end consumer

AssumptionsDistance-based method. High uncertainty as a distance of five kilometres

by car was assumed for the transportation from the retailer to the end-

customer.

DEFRA (2024), MfE (2024)

Category 10:

Processing of sold

products

Processing of salmon

block into meal

Internal sales data,

assumptions

Average-data method. High uncertainty.Feed suppliers (2024)

Category 12: End of

life treatment of sold

products

LCA Report – King Salmon

from New Zealand

(thinkstep-anz. (2023)),

internal sales data

Waste-type specific method. High uncertainty as waste quantities were

estimated, assuming 0% flesh waste and 30% inedible overall waste from

whole fish, and 10% overall waste from all other products. Assumed all

waste goes to landfill without gas recovery.

MfE (2024)

36New Zealand King SalmonClimate-Related Disclosures FY25 — Glossary and AppendixContents

Independent Assurance Report
37New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

Independent Assurance Report
To the Directors of New Zealand King Salmon Investments Limited

Limited Assurance Report on New Zealand

King Salmon Investments Limited’s

Greenhouse Gas (GHG) Disclosures

Our conclusion

We have undertaken a limited assurance engagement on

the gross GHG emissions, additional required disclosures of

gross GHG emissions, and gross GHG emissions methods,

assumptions and estimation uncertainty (the GHG

Disclosures), as outlined within the Scope of our Limited

Assurance Engagement section below, included in the

Climate-Related Disclosures report (the Climate Disclosures

report) of New Zealand King Salmon Investments Limited

(the Company) and its subsidiaries (the Group or NZKS) for

the year ended 31 January 2025.

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 GHG

Disclosures are not fairly presented and are not prepared, in

all material respects, in accordance with the Aotearoa New

Zealand Climate Standards (NZ CSs) issued by the External

Reporting Board (XRB), as explained on page 6 of the

Climate Disclosures report.

Scope of our limited assurance engagement

We have undertaken a limited assurance engagement over

the following GHG Disclosures on pages 25, 26 and 34 to

36 of the Climate Disclosures report for the year ended 31

January 2025:


gross GHG emissions:

— Scope 1 GHG Emissions on page 26;

— Scope 2 GHG Emissions (calculated using the

location-based method) on page 26; and

— Scope 3 GHG Emissions on page 26;


additional r

equired disclosures of gross GHG emissions

on pages 25, 26, and 34 to 36; and

•gr

oss GHG emissions methods, assumptions and

estimation uncertainty on pages 26, and 34-36.

Our assurance engagement does not extend to any

other information included, or referred to, in the Climate

Disclosures report on pages 4 to 24 and 27 to 33. The

comparative information for the year ended 31 January

2024 disclosed in the Group’s Climate Disclosures report is

not covered by the assurance conclusion expressed in this

report. We have not performed any procedures with respect

to the excluded information and, therefore, no conclusion is

expressed on it.

Key Matters to the GHG assurance engagement

In this section we present those matters that, in our

professional judgement, were most significant in

undertaking the assurance engagement over the GHG

Disclosures. These matters were addressed in the context of

our assurance engagement, and in forming our conclusion.

We did not reach a separate assurance conclusion on each

individual key matter.

38New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

Description of the key matterHow our assurance engagement addressed the key matter
Accuracy of Scope 3 feed emissions

GHG

emissions from feed (included in Scope 3 - Category 1: Purchased goods and services)

are 26% of the total Scope 3 GHG emissions for the year ended 31 January 2025.

The Group uses the supplier-specific method to measure emissions from feed as explained on

page 34. The Group relies on their suppliers’ Life Cycle Assessments (LCA) to provide cradle-

to-gate emission factors specific to their feed composition.

We

engaged directly with the suppliers to understand the methods, estimates and

assumptions made in the LCA models because:

•The Group has a lesser degree of knowledge and influence over information prepared by

their suppliers, not having visibility over controls or processes over information prepared by

their suppliers.

•The LCAs prepared by the suppliers and used in calculating the emission factors

are not publicly available.

The LCAs have not undergone independent assurance or

verification; and

•Critical selections and assumptions are used, which can vary significantly between feed

suppliers and over time, such as the choice of LCA framework, use of primary or secondary

data, and allocation methods.

Consequently, this required a significant level of attention in our assurance engagement.

To evaluate the emissions factors applied to feed, we enquired directly with the Group’s two

largest feed suppliers to understand:

•The selection of standards and product environmental footprint category rules and how

they determined they provided an appropriate basis for their methodology in preparing

their emissions factors.

•Our understanding confirmed that the suppliers had identified, and had access to,

primary and secondary data sources, including databases, to prepare the calculations

that were relevant to NZKS.


Through these enquiries, the feed suppliers demonstrated the basis upon which they

prepared their emissions factors in accordance with the standards and applied that

methodology to the circumstances of the Group.

•We also gained an understanding of the assumptions applied and considered the

differences in those adopted by the suppliers.

We considered whether disclosures by the Group in the Appendix fairly present the

complexities and uncertainties involved in the suppliers’ calculations.

39New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

Description of the key matterHow our assurance engagement addressed the key matter
C

ompleteness of excluded Scope 3 emission sources

T

he Group excluded emission sources that are not applicable, not material, or, where

insufficient data or the unknown nature of d ownstream processes meant that it was not

technically feasible or cost effective for emissions to be quantified with accuracy.

Determining that the emission sources excluded on page 26 were appropriately justified, and

that the reported emission sources were materially complete, required a significant level of

a

ttention in our assurance engagement due to:

•The scale of the business and different types of

activities included in the Group’s operational

boundary including hatcheries, sea farms, processing operations, distribution and office

areas, increased the extent of procedures we were required to perform.

•The Group’s use of estimates and assumptions, which were applied in situations where there

is a lack of available data.

•The estimation uncertainties arising from downstream activities where the nature of

processes and cooking techniques beyond the Group’s point of sale which are unknown

(Category 10 Processing of sold products and Category 11 Use of sold products).

To evaluate the estimates and assumptions made by the Group in excluding Scope 3

emissions, we:

•Enquired with management on their operational and organisation boundary and their

operating activities to gain an understanding of emission sources and management’s

assessment of materiality.

•Obtained management’s assessment of their boundary and value chain and assessed;


the approach the Group used to identify and quantify applicable and material

Scop

e 3 GHG emission sources was sufficient; and



assump

tions used in the excluded emission quantification process were appropriate

in the cir

cumstances.


Wher

e necessary, we developed an independent estimate of excluded emissions to

quantify the risk of material omission.

40New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

Emphasis of matter
We draw attention to the disclosure ‘NZKS boundary’ on page 25 which explains how

the Group has classified certain emissions from leased assets within the Scope 1 and

Scope 2 reported emissions. In our judgement, this disclosure is of such importance

that it is fundamental to the users’ understanding of the GHG Disclosures. Our

assurance conclusion is not modified in respect of this matter.

Other matter - comparative information

The comparative GHG Disclosures (that is, GHG Disclosures for the year ended 31

January 2024) have not been subject to assurance. As such, these disclosures are not

covered by our assurance conclusion.

Directors’ responsibilities

The Directors of the Company are responsible on behalf of the Company for the

preparation and fair presentation of the GHG Disclosures in accordance with NZ CSs.

This responsibility includes the design, implementation and maintenance of internal

controls relevant to the preparation of GHG Disclosures that are free from material

misstatement whether due to fraud or error.

Inherent Uncertainty in preparing GHG Disclosures

As discussed on page 34 of the Climate Disclosures report, the 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.

Our independence and quality management

This assurance engagement was undertaken in accordance with NZ SAE 1 New

Zealand Standard on Assurance Engagements 1 Assurance Engagements over

Greenhouse Gas Emissions Disclosures (NZ SAE 1), issued by the External Reporting

Board (XRB). NZ SAE 1 is founded on the fundamental principles of independence,

integrity, objectivity, professional competence and due care, confidentiality and

professional behaviour.

We have also complied with the following professional and ethical standards and

accreditation body requirements:

•Professional and Ethical Standard 1: International Code of Ethics for Assurance

Practitioners (including International Independence Standards) (New Zealand);


Pr

ofessional and Ethical Standard 3: Quality Management for Firms that Perform

Audits or Reviews of Financial Statements, or Other Assurance or Related Services

Engagements; and


Professional and Ethical Standard 4: Engagement Quality Reviews.

In our capacity as auditor and assurance practitioner, our firm also provides audit

services. Our firm carries out other assignments in the areas of other services relating

to treasury advisory. The firm has no other relationship with, or interests in, the Group.

41New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

Assurance practitioner’s responsibilities
Our responsibility is to express a conclusion on the GHG Disclosures based on the

procedures we have performed and the evidence we have obtained. NZ SAE 1 requires

us to plan and perform the engagement to obtain the intended level of assurance

about whether anything has come to our attention that causes us to believe that

the GHG Disclosures are not fairly presented and are not prepared, in all material

respects, in accordance NZ CSs, whether due to fraud or error, and to report our

conclusion to the Directors of the Company.

As we are engaged to form an independent conclusion on the GHG Disclosures

prepared by management, we are not permitted to be involved in the preparation of

the GHG information as doing so may compromise our independence.

Summary of work performed

Our limited assurance engagement was performed in accordance with NZ SAE 1,

and ISAE (NZ) 3410 Assurance Engagements on Greenhouse Gas Emissions. This

involves assessing the suitability in the circumstances of the Group’s use of NZ CSs as

the basis for the preparation of the GHG Disclosures, assessing the risks of material

misstatement of the GHG Disclosures whether due to fraud or error, responding

to the assessed risks as necessary in the circumstances, and evaluating the overall

presentation of the GHG Disclosures.

A limited assurance engagement is substantially less in scope than a reasonable

assurance engagement in relation to both the risk assessment procedures, including

an understanding of internal control, and the procedures performed in response to

the assessed risks.

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. In undertaking

our limited assurance engagement on the GHG Disclosures, we:

•Obtained, through enquiries, an understanding of the Group’s control

environment, processes and information systems relevant to the preparation

of the GHG Disclosures. We did not evaluate the design of particular control

activities, or obtain evidence about their implementation;

•Evaluated the Group’s organisational and operational boundaries to assess

completeness of GHG sources;

•Evaluated whether the Group’s methods for developing estimates are appropriate

and had been consistently applied. Where we considered it to be appropriate, we


tested, on a limited sample basis, the data on which the estimates are based. In

some instances, we separately developed our own estimates against which to

evaluate the Group’s estimates;

•Undertook site visits at Group’s head office and fish processing site to assess the

completeness of the emissions sources and to inspect source data;

•Tested a limited number of items to, or from, supporting records, as appropriate;

42New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

• Assessed a limited number of emission factor sources and reperformed a limited
number of emissions calculations for mathematical accuracy;

• Performed analytical procedures on particular emission categories by

comparing the expected GHGs emitted to actual GHGs emitted and made

inquiries of management to obtain explanations for any significant differences

we identified; and

• Considered the presentation and disclosure of the GHG Disclosures.

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 we

performed a reasonable assurance engagement and does not enable us to obtain

assurance that we would become aware of all significant matters that we otherwise

might identify. Accordingly, we do not express a reasonable assurance opinion on

these GHG Disclosures.

Inherent limitations

Because of the inherent limitations of an assurance engagement, together with the

internal control structure, it is possible that fraud, error or non-compliance may occur

and not be detected.

Who we report to

This report is made solely to the Company’s Directors, as a body. Our work has been

undertaken so that we might state those matters which we are required to state

to them in our assurance report and for no other purpose. To the fullest extent

permitted by law, we do not accept or assume responsibility to anyone other than the

Company and the Company’s Directors, as a body, for our procedures, for this report,

or for the conclusions we have formed.

The engagement partner on the engagement resulting in this independent assurance

report is Victoria Ashplant.

For and on behalf of:

PricewaterhouseCoopers

Auckland

28 May 2025

43New Zealand King SalmonClimate-Related Disclosures FY25 — Independent Assurance ReportContents

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