Carbon Disclosure Project Report 2008 Australia & New Zealand

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1 Carbon Disclosure Project Report 2008 Australia & New Zealand On behalf of 385 investors with assets of $US57 trillion Joanne Saleeba Andrew Gray Andrew.Gray@gsjbw.com Robert Clancy rclancy@csf.com.au

2 Carbon Disclosure Project 2008 Carbon Disclosure Project 2008 This report and all of the public responses from corporations are available to download free of charge from The contents of this report may be used by anyone providing acknowledgement is given. 2 CDP Members 2008 CARBON DISCLOSURE PROJECT MEMBERS 2008 ABRAPP - AssociaÁão Brasileira das Entidades Fechadas de PrevidÍncia Complementar Brazil Aegon N.V. Netherlands APG Investments Netherlands ASN Bank Netherlands ATP Group Denmark AXA Group France Banco Real Brazil BlackRock U.S. BP Investment Management Limited United Kingdom Caisse de dèpùt et placement du QuÈbec Canada Caisse des DÈpÙts France California Public Employees Retirement System U.S. California State Teachers Retirement System U.S. Calvert Group U.S. Canada Pension Plan Investment Board Canada Catholic Super Australia CIBC Canada Ethos Foundation Switzerland Folksam Sweden Fortis Investments Belgium Generation Investment Management United Kingdom ING Netherlands KLP Insurance Norway Legg Mason, Inc. U.S. London Pensions Fund Authority United Kingdom Merrill Lynch & Co.,Inc. U.S. Mitsubishi UFJ Financial Group (MUFG) Japan Morgan Stanley Investment Management U.S. Morley Fund Management United Kingdom National Australia Bank Limited Australia Neuberger Berman U.S. Newton Investment Management Limited United Kingdom Pictet Asset Management SA Switzerland Rabobank Netherlands Robeco Netherlands SAM Group Switzerland Schroders United Kingdom Signet Capital Management Switzerland Sompo Japan Insurance Inc. Japan Standard Chartered PLC United Kingdom Sun Life Financial Inc. Canada Swiss Reinsurance Company Switzerland The Ethical Funds Company Canada The RBS Group United Kingdom The Wellcome Trust United Kingdom Zurich Cantonal Bank Switzerland

3 CDP Signatories 2008 CDP Signatories investors with assets of over $US57 trillion were signatories to the CDP6 information request dated 1st February 2008 including 1 : Abax Global Capital United Kingdom Aberdeen Asset Managers United Kingdom ABRAPP - AssociaÁão Brasileira das Entidades Fechadas de PrevidÍncia Complementar Brazil Acuity Funds Canada Aegon N.V. Netherlands Aeneas Capital Advisors U.S. AGF Management Limited Canada AIG Investments U.S. Alberta Teachers Retirement Fund Canada Alcyone Finance France Allianz Group Germany Altshuler Shacham Ltd Israel AMP Capital Investors Australia ANBID - National Association of Brazilian Investment Banks Brazil APG Investments Netherlands ASB Community Trust New Zealand ASN Bank Netherlands ATP Group Denmark Australia and New Zealand Banking Group Limited Australia Australian Ethical Investment Limited Australia Australian Reward Investment Alliance (ARIA) Australia Aviva PLC United Kingdom AXA Group France Baillie Gifford & Co. United Kingdom Banco Sweden Banco Bradesco S.A. Brazil Banco do Brazil Brazil Banco Itaú Holding Financeira Brazil Banco Pine S.A. Brazil Banco Real Brazil Banco Santander, S.A. Spain Banesprev Fundo Banespa de Seguridade Social Brazil Bank Sarasin & Co, Ltd Switzerland Bank Vontobel Switzerland BankInvest Denmark Barclays Group United Kingdom BBC Pension Trust Ltd United Kingdom Beutel Goodman and Co. Ltd Canada BlackRock U.S. BMO Financial Group Canada BNP Paribas Investment Partners France Boston Common Asset Management, LLC U.S. BP Investment Management Limited United Kingdom Brasilprev Seguros e PrevidÍncia S/A. Brazil British Coal Staff Superannuation Scheme United Kingdom British Columbia Investment Management Corporation (bcimc) Canada BT Financial Group Australia BVI Bundesverband Investment und Asset Management e.v. Germany CAAT Pension Plan Canada Caisse de dèpùt et placement du QuÈbec Canada Caisse des DÈpÙts France Caixa Beneficente dos Empregados da Companhia Siderurgica Nacional - CBS Brazil Caixa de PrevidÍncia dos Funcion rios do Banco do Nordeste do Brasil (CAPEF) Brazil Caixa EconÙmica Federal Brazil Caixa Geral de DepÛsitos Portugal California Public Employees Retirement System U.S. California State Teachers Retirement System U.S. California State Treasurer U.S. Calvert Group U.S. Canada Pension Plan Investment Board Canada Canadian Friends Service Committee Canada CARE Super Pty Ltd Australia Carlson Investment Management Sweden Carmignac Gestion France Catherine Donnelly Foundation Canada Catholic Super Australia CCLA Investment Management Ltd United Kingdom Central Finance Board of the Methodist Church United Kingdom Ceres U.S. CERES-FundaÁão de Seguridade Social Brazil Cheyne Capital Management (UK) LLP United Kingdom China Investment Corporation China Christian Super Australia CI Mutual Funds Signature Advisors Canada CIBC Canada Citizens Advisers, Inc. U.S. Clean Yield Group, Inc. U.S. ClearBridge Advisors, Socially Aware Investment U.S. Close Brothers Group PLC United Kingdom Colonial First State Global Asset Management Australia Columbia Management U.S. Comite syndical national de retraite Btirente Canada Commerzbank AG Germany Companhia de Seguros AlianÁa do Brasil Brazil Connecticut Retirement Plans and Trust Funds U.S. Co-operative Financial Services (CFS) United Kingdom Credit Agricole Asset Management France Credit Suisse Switzerland Daegu Bank South Korea Daiwa Securities Group Inc. Japan Deutsche Bank Germany Development Bank of Japan Japan Development Bank of the Philippines (DBP) Philippines Dexia Asset Management France DnB NOR Asset Management Norway Domini Social Investments LLC U.S. Economus Instituto de Seguridade Social Brazil ELETRA - FundaÁão Celg de Seguros e PrevidÍncia Brazil Environment Agency Active Pension Fund United Kingdom Epworth Investment Management United Kingdom Erste Bank der oesterreichischen Sparkassen AG Austria Ethos Foundation Switzerland Eureko B.V. Netherlands Eurizon Capital SGR Italy Evli Bank Plc Finland F&C Management Ltd United Kingdom FAELCE FundaÁão Coelce de Seguridade Social Brazil FAPERS FundaÁão Assistencial e Previdenci ria da Extensão Rural do Rio Grande do Sul Brazil FAPES FundaÁão de Assistencia e Previdencia Social do BNDES Brazil FÈdÈris Gestion d Actifs France First Affirmative Financial Network U.S. First Swedish National Pension Fund (AP1) Sweden FirstRand Ltd. South Africa Fishman & Co. Israel Five Oceans Asset Management Pty Ltd Australia 1 Not all 385 signatory investors are listed as some did not wish to be identified publicly. 3

4 Carbon Disclosure Project 2008 Florida State Board of Administration (SBA) U.S. Folksam Sweden Fondaction Canada Fonds de RÈserve pour les Retraites FRR France Fortis Investments Belgium Forward Funds / Sierra Club Funds U.S. Fourth Swedish National Pension Fund, AP4 Sweden FRANKFURT-TRUST Investment Gesellschaft mbh Germany Frater Asset Management South Africa Front Street Capital Canada Fukoku Capital Management Inc Japan FUNCEF - FundaÁão dos Economi rios Federais Brazil FundaÁão AMPLA de Seguridade Social - Brasiletros Brazil FundaÁão Atlntico de Seguridade Social Brazil FundaÁão Banrisul de Seguridade Social Brazil FundaÁão Codesc de Seguridade Social - FUSESC Brazil FundaÁão Corsan - dos Funcion rios da Companhia Riograndense de Saneamento Brazil FundaÁão São Francisco de Seguridade Social Brazil FundaÁão Vale do Rio Doce de Seguridade Social - VALIA Brazil FUNDI GUA - FundaÁão de PrevidÍncia da Companhia de Saneamento e Ambiental do Distrito Federal Brazil Gartmore Investment Management Ltd United Kingdom GEAP FundaÁão de Seguridade Social Brazil Generation Investment Management United Kingdom Genus Capital Management Canada Gjensidige Forsikring Norway GLG Partners LP United Kingdom Goldman Sachs & Co. U.S. Governance for Owners United Kingdom Groupe Investissement Responsable Inc. Canada Guardian Ethical Management Inc Canada Guardians of New Zealand Superannuation New Zealand Hang Seng Bank Hong Kong Harrington Investments U.S. Harvard Management Company U.S. Hazel Capital LLP United Kingdom Health Super Fund Australia Henderson Global Investors United Kingdom 4 Hermes Investment Management United Kingdom HESTA Super Australia Hospitals of Ontario Pension Plan (HOOPP) Canada Housing Development Finance Corporation Limited (HDFC Ltd.) India HSBC Holdings PLC United Kingdom I.B.I. Investments House Ltd. Israel IDEAM -Integral DÈvelopment Asset Management France Ilmarinen Mutual Pension Insurance Company Finland Industrial Bank China Industry Funds Management Australia ING Netherlands Inhance Investment Management Inc Canada Insight Investment Management (Global) Ltd United Kingdom Instituto Infraero de Seguridade Social - INFRAPREV Brazil Insurance Australia Group Australia Interfaith Center on Corporate Responsibility U.S. Investec Asset Management United Kingdom Jarislowsky Fraser Limited Canada JPMorgan Asset Management U.S. Jupiter Asset Management United Kingdom KBC Asset Management NV Belgium KCPS and Company Israel KfW Bankengruppe Germany KLP Insurance Norway Kyobo Investment Trust Management Co., Ltd. South Korea La Banque Postale Asset Management France LBBW - Landesbank Baden-W rttemberg Germany Legal & General Group PLC United Kingdom Legg Mason, Inc. U.S. Libra Fund U.S. Light Green Advisors, LLC U.S. Living Planet Fund Management Company S.A. Switzerland Local Authority Pension Fund Forum United Kingdom Local Government Superannuation Scheme Australia Lombard Odier Darier Hentsch & Cie Switzerland London Pensions Fund Authority United Kingdom Macif Gestion France Macquarie Group Limited Australia Maine State Treasurer U.S. Man Group PLC United Kingdom Maple-Brown Abbott Limited Australia Maryland State Treasurer U.S. Meeschaert Gestion PrivÈe France Meiji Yasuda Life Insurance Company Japan Merck Family Fund U.S. Meritas Mutual Funds Canada Merrill Lynch & Co.,Inc. U.S. Midas International Asset Management South Korea Mirae Investment Asset Management South Korea Mistra, Foundation for Strategic Environmental Research Sweden Mitsubishi UFJ Financial Group (MUFG) Japan Mitsui Sumitomo Insurance Co.,Ltd. Japan Mizuho Financial Group, Inc. Japan Monte Paschi Asset Management SGR S.p.A Italy Morgan Stanley Investment Management U.S. Morley Fund Management United Kingdom Motor Trades Association of Australia Superannuation Fund Pty Ltd Australia Munich Re Group Germany Natcan Investment Management Canada Nathan Cummings Foundation, U.S. National Australia Bank Limited Australia National Bank of Kuwait Kuwait National Grid Electricity Group of the Electricity Supply Pension Scheme United Kingdom National Grid UK Pension Scheme Trustee Ltd United Kingdom National Pensions Reserve Fund of Ireland Ireland Natixis France Nedbank Group South Africa Needmor Fund U.S. Nest Sammelstiftung Switzerland Neuberger Berman U.S. New Alternatives Fund Inc. U.S. New Jersey Division of Investment U.S. New Jersey State Investment Council U.S. New Mexico State Treasurer U.S. New York City Employees Retirement System U.S. New York City Teachers Retirement System U.S. New York State Common Retirement Fund (NYSCRF) U.S. Newton Investment Management Limited United Kingdom NFU Mutual Insurance Society United Kingdom

5 CDP Signatories 2008 NH-CA Asset Management South Korea Nikko Asset Management Co., Ltd. Japan Nissay Asset Management Corporation Japan Norfolk Pension Fund United Kingdom Norinchukin Zenkyouren Asset Management Co., Ltd Japan North Carolina State Treasurer U.S. Northern Ireland Local Government Officers Superannuation Committee (NILGOSC) United Kingdom Northern Trust U.S. Oddo & Cie France Old Mutual PLC United Kingdom Ontario Municipal Employees Retirement System (OMERS) Canada Ontario Teachers Pension Plan Canada Opplysningsvesenets fond (The Norwegian Church Endowment) Norway Oregon State Treasurer U.S. Orion Energy Systems, Inc. U.S. Pax World Funds U.S. Pension Fund for Danish Lawyers and Economists Denmark Pension Plan of the Evangelical Lutheran Church in Canada Canada PETROS - The FundaÁão Petrobras de Seguridade Social Brazil PGGM Netherlands Phillips, Hager & North Investment Management Ltd. Canada PhiTrust Active Investors France Pictet Asset Management SA Switzerland Portfolio 21 Investments U.S. Portfolio Partners Australia Porto Seguro S.A. Brazil PREVI Caixa de PrevidÍncia dos Funcion rios do Banco do Brasil Brazil Prudential PLC United Kingdom PSP Investments Canada QBE Insurance Group Limited Australia Rabobank Netherlands Railpen Investments United Kingdom Rathbones / Rathbone Greenbank Investments United Kingdom Real Grandeza FundaÁão de PrevidÍncia e AssistÍncia Social Brazil REDEPREV-FundaÁão Rede de PrevidÍncia Brazil Rei Super Australia Rhode Island General Treasurer U.S. RLAM United Kingdom Robeco Netherlands Rock Crest Capital LLC U.S. Royal Bank of Canada Canada SAM Group Switzerland Sanlam Investment Management South Africa Santa FÈ Portfolios Ltda Brazil Savings & Loans Credit Union (S.A.) Limited. Australia Schroders United Kingdom Scotiabank Canada Scottish Widows Investment Partnership United Kingdom Second Swedish National Pension Fund (AP2) Sweden Seligson & Co Fund Management PLC Finland SERPROS Fundo Multipatrocinado Brazil Service Employees International Union Benefit Funds U.S. Seventh Swedish National Pension Fund (AP7) Sweden SH Asset Management Inc. South Korea Shinhan Bank South Korea Shinkin Asset Management Co., Ltd Japan Shinsei Bank Japan Signet Capital Management Ltd Switzerland Skandia Nordic Division Sweden SNS Asset Management Netherlands SociÈtÈ GÈnÈrale France Sompo Japan Insurance Inc. Japan SPF Beheer bv Netherlands Standard Chartered PLC United Kingdom Standard Life Investments United Kingdom State Street Corporation U.S. Storebrand ASA Norway Sumitomo Mitsui Financial Group Japan Sumitomo Trust & Banking Japan Sun Life Financial Inc. Canada Sustainable World Capital U.S. Svenska Kyrkan, Church of Sweden Sweden Swedbank Sweden Swiss Reinsurance Company Switzerland Swisscanto Holding AG Switzerland TD Asset Management Inc. and TD Asset Management USA Inc. Canada Teachers Insurance and Annuity Association College Retirement Equities Fund (TIAA-CREF) U.S. Telstra Super Australia Tempis Capital Management South Korea Terra fondsforvaltning ASA Norway TfL Pension Fund United Kingdom The Bullitt Foundation U.S. The Central Church Fund of Finland Finland The Collins Foundation U.S. The Co-operators Group Ltd Canada The Daly Foundation Canada The Dreyfus Corporation U.S. The Ethical Funds Company Canada The Local Government Pensions Insitution (LGPI)(keva) Finland The RBS Group United Kingdom The Russell Family Foundation U.S. The Shiga Bank, Ltd. Japan The Standard Bank of South Africa Limited South Africa The Travelers Companies, Inc. U.S. The United Church of Canada - General Council Canada The Wellcome Trust United Kingdom Third Swedish National Pension Fund (AP3) Sweden Threadneedle Asset Management United Kingdom Tokio Marine & Nichido Fire Insurance Co., Ltd. Japan Trillium Asset Management Corporation U.S. Triodos Bank Netherlands Tri-State Coalition for Responsible Investing U.S. TrygVesta Denmark UBS AG Switzerland Unibanco Asset Management Brazil UniCredit Group Italy Unitarian Universalist Association U.S. United Methodist Church General Board of Pension and Health Benefits U.S. Universities Superannuation Scheme (USS) United Kingdom Vancity Group of Companies Canada VÂrdal Foundation Sweden Vermont State Treasurer U.S. VicSuper Pty Ltd Australia Victorian Funds Management Corporation Australia Visão Prev Sociedade de Previdencia Complementar Brazil Wachovia Corporation U.S. Walden Asset Management, a division of Boston Trust and Investment Management Company U.S. West Yorkshire Pension Fund United Kingdom WestLB Mellon Asset Management (WMAM) Germany Winslow Management Company U.S. XShares Advisors U.S. YES BANK Limited India York University Pension Fund Canada Youville Provident Fund Inc. Canada Zurich Cantonal Bank Switzerland 5

6 Carbon Disclosure Project 2008 Message from the Australia and New Zealand Partners Investor Group on Climate Change As major developed economies move toward the introduction of legislation for carbon reduction, more advanced corporate disclosure on carbon performance and its implications through the business supply chain is urgently needed. Because of their exposure to industries across these economies, institutional investors need companies to understand and transparently disclose their carbon footprints. It is critical that strategies to deal with both the associated risks and opportunities for businesses arising from climate change are developed and are clearly communicated. Effective reporting is vital. Analysis of the Carbon Disclosure Project questionnaire responses provides investors with a unique understanding of how Australian and New Zealand companies are responding to climate change and preparing their operations for a low emissions economy. Accurate carbon disclosure is necessary for investment decision making. Although the responses by companies to the Carbon Disclosure Project have generally strengthened in 2008 compared to 2007, much more action is needed. As global greenhouse gas emissions continue to soar and scientific indicators increasingly point towards outcomes that are beyond predicted worst case scenarios, institutional investors and the companies they own have a significant part to play in avoiding catastrophic climate change impacts. Bob Welsh Chair 6

7 Goldman Sachs JBWere Goldman Sachs JBWere is proud to continue its support of the third Carbon Disclosure Project (CDP) in Australia and New Zealand. In 2008, the CDP has again partnered with the Investor Group on Climate Change (IGCC) to survey Australian and New Zealand listed companies, expanding the reach of the survey this year from ASX100 to ASX200 companies. The CDP is a clear example of the forward march of climate change in the minds of companies and investors alike. As a national Carbon Pollution Reduction Scheme is implemented in Australia, carbon emission disclosures will become even more significant for corporations. This project is also an important step towards creating the information flows necessary to allow the assessment of environmental, social and governance considerations in mainstream Australasian equity research. We would like to thank those organisations that have taken the time to respond to this survey. Craig Drummond Co-Chief Executive Officer Stephen Fitzgerald Co-Chief Executive Officer Catholic Super Catholic Super has recognised the significant risk a changing global climate poses to its members investments. For this reason it was the first Australian financial institution to sign-up to the Carbon Disclosure Project (CDP) and remains a foundation member of this vital international initiative and the Investor Group on Climate Change. The CDP provides the world's largest institutional investor collaboration on the business implications of climate change. The Project represents an efficient process whereby many institutional investors collectively sign a single global request for disclosure of information on greenhouse gas emissions. The CDP has now developed as an important longitudinal study into greenhouse gas emissions over 1900 companies globally at a time when emissions trading is about to be introduced in Australia and New Zealand. Catholic Super remains as determined as ever to foster and promote the CDP in an effort to gather as much relevant information as is possible for quantifying and assessing the level of risk facing us over the medium and long term. It is heartening to see the number of companies responding to the CDP questionnaire rising each year and we thank those who have taken the time and care in returning this critically important information to the CDP and the investors behind it. Frank Pegan Chief Executive Officer Thank you! IGCC, Goldman Sachs JBWere and Catholic Super recognise the time and effort it takes for companies to respond to the CDP questionnaire and would like to thank every one that has done so this year. This information is important to investors as it assists them to understand how companies in which they invest will be impacted by climate change and by the government and community response to climate change. It also assists investors to understand how companies are managing and mitigating the risks associated with climate change and harnessing the opportunities. We would particularly like to thank those companies that have allowed their responses to be made publicly available. CDP responses that are publicly available can be can be downloaded from Although the formal response period has lapsed we strongly encourage ASX200 and NZX50 companies that have not submitted a response to the CDP6 questionnaire to do so. We would also encourage other listed companies, of any size, to volunteer a response to the CDP questionnaire. We look forward to receiving many more responses in future years. 7

8 Carbon Disclosure Project 2008 Executive Summary The responses from corporations are available to download at As both Australian and New Zealand markets move towards the implementation of an emissions trading scheme and as the physical impacts of climate change are experienced, the financial implication will become clear. These can be both direct and indirect. For example drought and the carbon cost will have direct impacts. Changes to land use planning laws to account for rising sea levels and increasing supply chain costs will be indirect but still potentially material. Investors will be assessing climate change risks and opportunities and the resulting financial implications in the investment analysis of investee and potential investee companies. This assessment will include both quantitative analysis of companies exposure to a cost on greenhouse gas emissions and qualitative analysis of other climate change risks and opportunities and business response to these issues. To be able to undertake this assessment investors require access to investment relevant, accurate, consistent and comparable information from companies on climate change risks and opportunities for their business, their greenhouse emissions profile and their emissions management and reduction strategies. 8

9 Executive Summary The CDP provides the framework and the mechanism through which investors can obtain this information from companies. For the third year, the Investor Group on Climate Change along with Goldman Sachs JBWere and Catholic Super facilitated the expansion of the CDP to the largest companies in Australia and New Zealand. Through the CDP a growing number of Australian and New Zealand companies are responding to the investment community. CDP6 Response rate This year the response rate for both Australian (ASX100) and New Zealand (NZX50) companies increased significantly. Australia Almost three quarters of ASX100 companies, or 72%, answered the CDP questionnaire, representing a jump of 26% compared to CDP5. This response rate compares favourably with the global average 2 of 61%.The response rate for the largest companies in the ASX100 i.e. the ASX50 was even higher at 82%. This year, the highest response rate for any category of ASX100 companies i.e. by market capitalisation or exposure, was for those companies identified as greenhouse intensive. 86% of companies identified as greenhouse intensive answered the CDP6 questionnaire. While this is the third year that ASX100 companies have been included in the CDP information request, it was the first time the CDP information request was expanded to the ASX200. The percentage of companies that comprise the second (or smaller) 100 companies in the ASX200, referred to as the ASX200 (ex100), that answered the CDP6 questionnaire was relatively low at 23%. Nevertheless, the investors behind CDP would like to acknowledge the efforts of the ASX200 (ex100) companies that responded given that most of these companies were recipients of the CDP questionnaire for the first time and that companies that comprise the ASX200 (ex100) are significantly smaller than companies in the ASX100, and often do not have dedicated investor relations or climate change/sustainability representatives to facilitate engagement on and completion of the CDP information request. New Zealand The most dramatic increase in the number of companies answering the CDP questionnaire was from NZX50 companies, with an upward shift of 32%. This year 50% of NZX50 companies answered the CDP questionnaire compared to 38% last year. The percentage of NZX10 answering the CDP questionnaire increased from 50% to 70%. The most striking response rate for any listing or category of companies i.e. by market capitalisation or exposure, was for those NZX50 companies categorised as exposed to other climate change risks. 88% of NZX50 companies identified as exposed to other climate change risk, such as physical risks or risks through their supply chain or customer base answered the CDP6 questionnaire. Notwithstanding the significant increase in NZX50 companies answering the CDP questionnaire, the response rate is still significantly lower than for ASX100 companies and is also below the global average response rate of 61%. This is concerning for investors in the New Zealand market and will lead to the potential for unpriced or incorrectly priced climate change risks and opportunities. Almost three quarters of ASX100 companies, or 72%, answered the CDP questionnaire, representing a jump of 26% compared to CDP5. Despite the relatively low response rate, investors behind CDP would like to acknowledge the efforts the ASX200 (ex100) companies have made in responding to the CDP6 information request. The most dramatic increase in number of companies answering the CDP questionnaire was from NZX50 companies, with an upward shift of 39% from 38% in CDP5 to 50% in CDP6. 2 Excluding India and China. With the inclusion of India and China average response rate for the entire CDP geographical and sector listings is 57 percent. 9

10 Carbon Disclosure Project 2008 This year, every company in the ASX100 that completed the CDP questionnaire identified some risks from climate change. By not adequately providing information on company specific exposure, companies are transferring a large portion of the risk assessment process from within their control to the purview of the investor. Adaptation to climate change risks is not being sufficiently considered by most companies. The percentage of respondents providing some or all of the requested greenhouse gas emissions data was one of the areas of improvement in CDP6. 10 Analysis of responses Rather than assess each question as was the case in last year s report, this year s report focuses on key questions and trends highlighted through responses to the CDP6 questionnaire. To allow for comparison with responses from last year and due to their relatively low response rate, ASX200 (ex100) company responses have not been assessed in detail in this report although signatories still have access to those responses and will undertake their own analysis. Risks This year, every company in the ASX100 that completed the CDP questionnaire identified some risks from climate change. Most companies indicated that at least some of the identified risks from climate change had the potential to result in exposure for their company. Given the development and imminent implementation of emissions trading schemes in both New Zealand and Australia, along with other complementary regulatory and policy measures the analysis in this report focuses on company exposure to regulatory risk. In particular, 91% of ASX100 respondents and 72% of NZX50 respondents consider their company to be exposed to regulatory risks. The percentage of both ASX100 and NZX50 respondents that consider their company to be exposed to regulatory risks is higher than the global average 3 of 70% of respondents. One of the key features of responses to the question on regulatory risk is the difficulty respondents seemed to have translating the various regulatory measures they identified into actual exposure for their company. Responses tended to focus on explaining the regulatory measures related to climate change but were less likely to explain how these risks translated into exposure for their company. In particular, few respondents provided company specific details on the impacts of regulatory measures to which the company is exposed, the level of exposure(s) on either a qualitative 3 Excluding China and India (significant, not significant or high, medium, low) or a quantitative (dollar impact) basis, or the level of exposure compared to their sector and/or economy as a whole. By not adequately providing information on company specific exposure, including the level (qualitative or quantitative) of exposure, companies are transferring a large portion of the risk assessment process from within their control to the purview of the investor. It was notable that respondents tended to provide more satisfactory responses to the question on physical risks, where they were better able to outline potential exposure for their company. In a new question this year, companies were asked about their risk management system for climate change risks. The large majority of companies indicated they had undertaken action to manage the general and regulatory risks and/or adapt to the physical risks that had been identified. Most respondents provided an outline of the actions their company had undertaken to mitigate regulatory and general risks including a range of emissions reduction actions. A smaller number provided an outline of their actual risk management system including actions undertaken to manage risks. Few respondents (16% of ASX100 respondents and 12% of NZX50 respondents) covered all of these elements. It was notable that only a very small number of companies mentioned actions they had taken to adapt to the physical risks that had been identified. The most commonly mentioned action undertaken to adapt to the physical impacts of climate change was greater water conservation and the development of water recycling facilities. The limited response from companies regarding adaptation could present significant investment risk in the longer-term and is potentially of concern to large long-term investors. Superannuation funds in particular, may be left with some residual risk in the longer-term if the companies do not put adequate risk management systems in place now.

11 Executive Summary Greenhouse gas emissions disclosure The percentage of respondents providing some or all of the requested greenhouse gas emissions data was one of the areas of improvement in CDP6. 79% of ASX100 respondents provided some emissions data. This was higher than the global average 4 of 71% of respondents. There is still room for further improvement from New Zealand companies with just less than two-thirds, or 60%, providing some or all of the requested emissions data. Respondents to the CDP questionnaire were responsible for million tonnes or 17% of total emissions (excluding agricultural emissions) in Australia and for 7.12 million tonnes or 19% of total emissions (excluding agricultural emissions) in New Zealand. The divergences in the fundamentals of reporting across responding companies including reporting periods and boundaries create difficulties for investors using the emissions data in their analysis. In addition there remain questions over the completeness and accuracy of the emissions data reported. Greater disclosure on these issues is required if investors are to confidently rely on the emissions data. However, it is clear from responses that companies are actively seeking to improve the quantity and quality of emissions data that they collect and report. For many companies, this is likely to be further enhanced through the obligations imposed under mandatory greenhouse gas and energy reporting schemes which will underpin the emissions trading schemes in Australia and New Zealand. Emissions reduction Having recognised that regulatory measures are likely to lead to exposure for their company most respondents to the CDP6 were undertaking activities to reduce their greenhouse gas emissions and in doing so, their risk exposure. Specifically, 71% of ASX100 respondents and 64% of NZX50 respondents listed or explained a range of activities they were undertaking to reduce their greenhouse gas emissions, particularly in the area of energy efficiency and renewable energy. While companies were clearly taking action to reduce their greenhouse gas emissions, the lack of formal structure in the emissions reduction programs was notable and was evidenced by: a lower number of respondents with emissions reduction plans; a lack of overall quantitative emissions reduction targets to guide the plans; an almost complete absence of targets specific to the activities mentioned; and difficulties in indicating or quantifying investment in emissions reduction. This lack of formal structure may be an indication to investors that companies are not integrating emissions reduction or other climate change mitigation activities within the core risk management or business management and planning processes. The indication that companies are yet to integrate issues around greenhouse gas emissions within their core business management and planning processes was also borne out in response to questions on planning for future capital expenditure and investment planning. This year, only 41% of ASX100 respondents and 32% of NZX50 respondents indicated they forecast their company s future emissions and/or energy use. The most salient feature highlighted by questions on how the costs of future emissions are factored into capital expenditure planning and how these considerations have made an impact on investment decisions was the large number (> 50%) of respondents that did not answer the question. The majority of Australian and New Zealand respondents are actively pursuing emissions reduction in their company. Responses to several CDP6 questions indicated that companies are yet to integrate greenhouse gas emissions and climate change issues within their core business management and planning processes. The balance sheet of every company will be impacted either directly through a cost on emissions or indirectly though increased costs for energy and energy intensive inputs. 4 Excluding China and India 11

12 Carbon Disclosure Project 2008 Investors will consider a range of factors, such as a credible mitigation strategy, when assessing the impact of an emissions trading scheme on the value of a company. Given that the global carbon market is expected to be worth billions of dollars investors will be expecting more companies to develop strategies to harness opportunities from this emerging market. Emissions trading Not only is emissions trading one of the key near term impacts associated with climate change for companies recognised as a driver of regulatory risk by 77% of CDP6 respondents it is also one of the few risks associated with climate change that can be more readily translated to a quantitative impact on the financial position. The impact on the financial position will be felt by all companies either directly through a cost on emissions or indirectly though increased costs for energy and energy intensive inputs. Despite some greater certainty around the design of emissions trading schemes in New Zealand and Australia there are still a significant number of variables that limit the ability of investors to accurately model the valuation impacts on listed companies. These include: the absence of mid-term (2020) national emissions reduction targets and trajectories for those targets makes it difficult for investors to forecast the carbon price; the form of transitional assistance is not certain and cannot be accurately estimated without more detailed data; and the extent to which a company can pass through emissions costs to their customers is variable. Given these uncertainties it is difficult to model with any accuracy the actual impacts of the New Zealand or Australian emissions trading schemes on company value. However, taking a base case of exposure to direct costs for scope 1 emissions and indirect costs for electricity (equal to 100% of the emissions costs i.e. 100% pass through from electricity generators) a number of respondents to CDP6 are facing significant potential underlying carbon exposure as illustrated in Chart 1.1. However, the details of the emissions trading schemes will be crucial for investors. These details will determine whether the inherent underlying carbon exposure translates into the final outcomes from the scheme. For example, those companies undertaking activities that are emissions intensive trade exposed (and have limited ability to increase their prices) are likely to be provided transitional assistance in the form of free permits for the emissions generated by these activities 5 while those undertaking activities that are not trade exposed may be able to pass through costs to some degree to recoup some or all of the costs of carbon. Investors will also consider a range of other factors when assessing the impact of an emissions trading scheme on the value of a company. For example, credible risk mitigation and emissions reduction strategies as well as the extent to which an emissions intensive company may be better positioned than its competitors in addressing climate change risks will influence the ultimate valuation impact for a company. Given the relatively small number of companies with significant exposure to emissions trading, it is not surprising that less than one third, or 31% of ASX100 respondents, and 20% of NZX50 respondents indicated they had some strategy for or were participating in emissions trading, CDMs or JI projects. This is fairly consistent with the global average 6 of 29% of respondents that had some strategy for or were participating in emissions trading, CDMs or JI projects. However, given that the global carbon market is expected to be worth billions of dollars (currently valued at in excess of $US64 billion by the World Bank) investors will be expecting more companies to develop (and disclose) strategies to participate in and harness opportunities from this emerging market % or 60% compensation is proposed under the Australian Government Green Paper depending on the emissions intensity of the activity. 6 Excluding China and India

13 Executive Summary Chart 1.1: Underyling carbon risk potential cost of emissions at A$20/tonne as a percentage of 2007 EBITDA AWC 22.9 WOW 2.1 TLS 1.9 BSL 22.2 SKL 1.9 WHS 0.2 OST 21.1 FRE 1.8 TCL 0.2 CEN 11.2 AGK 1.1 SGP 0.2 QAN 10.3 SGM 1.0 NWS 0.1 BLD 9.8 MGK 0.9 IAG 0.1 ORI 7.9 GFF 0.8 KIP 0.1 RIO 7.8 LLC 0.7 COH 0.1 PPX 6.8 TOL 0.6 BBG 0.1 STO 6.0 IFF 0.6 AIA 0.1 WPL 5.9 LNN 0.6 ANZ 0.1 LEI 4.5 CCL 0.6 TEL 0.1 ORG 4.1 SIP 0.5 MFT 0.1 FBU 4.1 IOF 0.5 AMP 0.1 CTX 3.9 BBI 0.4 NAB 0.1 BHP 3.7 FGL 0.4 MOF 0.0 AMC 13.5 GPT 0.3 ASX 0.0 SAN 3.4 CSL 0.3 CPU 0.0 WES 3.1 CPA 0.3 CBA 0.0 LGL 2.9 VPG 2.8 DOW 2.6 NCM 2.3 CFX 0.3 AXA 0.3 DXS 2.3 TAH 2.1 WMC 0.0 PPT 0.0 QBE 0.0 Note: The chart attempts to measure underlying carbon risk only; calculated as each company's carbon emissions multiplied by a carbon price of A$20/ tonne and expressed as a percentage of EBITDA*. The details of the emissions trading scheme, such as the levels of transitional assisitance, emissions cap, trajectory and carbon price are likely to result in the actual cost incurred by companies being different to this (possibly significantly in some cases). (*For Banks profit before tax is used, for Insurance Companies an equivalent measure of pre tax core operational earnings is used) 13

14 Carbon Disclosure Project 2008 The Goldman Sachs JBWere Climate Disclosure Leadership Index constituent companies demonstrated leadership in disclosure across a range of investment relevant climate change issues. Goldman Sachs JBWere Climate Leadership Index The companies selected for the Goldman Sachs JBWere Climate Disclosure Leadership Index have demonstrated leadership in disclosure to the investment community, via CDP, across a range of investment relevant climate change issues. Overall, Australian and New Zealand responses to CDP6 indicate that many companies are embracing the challenges presented by climate change that they understand and are mitigating the risks and are pursuing opportunities. From the ASX100 and NZX50 respondents to CDP6 the following companies were selected for the Goldman Sachs JBWere CLI. New in CDP6 ASX Auckland International Airport Babcock & Brown Billabong International Commonwealth Property Office Fund CSL Downer EDI Leighton Holdings Lion Nathan News Corporation Stockland Wesfarmers Woolworths Remaining in the index from last year AGL Energy Australia and New Zealand Banking Group BHP Billiton Boral Coca-Cola Amatil Fosters Group Insurance Australia Group Lend Lease Corporation Mirvac Group National Australia Bank Perpetual Rio Tinto Telecom Corporation of New Zealand Telstra Corporation Transurban Group Westpac Banking Warehouse Group 14

15 Contents Message from the Australia & New Zealand Partners 6 Executive Summary 8 1 Overview Background to CDP CDP Australia & 21 New Zealand 2 Response to CDP Global Response & Key Trends Response from 28 Australian and New Zealand Companies 3 Goldman Sachs JBWere 36 Climate Leadership Index 4 Analysis of ASX100 and 40 NZX50 Responses 5 Focus on Emissions 62 Trading Appendices Appendix A 73 CDP6 Geographical & Sector Listings Appendix B 74 CDP6 Questionnaire Appendix C 80 Australia & New Zealand response rate Appendix D 81 Company Listing & Breakdown for Analysis Quotes used in this report Throughout this report quotes have been taken from company responses to illustrate points made in the report. Unless otherwise indicated, the selection of quotes does not correlate with the overall quality of individual responses. 15

16 1Carbon Disclosure Project 2008 The Carbon Disclosure Project CDP s mission is to facilitate a dialogue between investors and corporations, supported by high quality information from which a rational response to climate change will emerge. 16

17 1. The Carbon Disclosure Project 1.1 Background to CDP The Carbon Disclosure Project is the largest investor coalition in the world: more than 385 investors, with a combined asset base of some $US57 trillion, signed CDP s sixth annual request for information in 2008 (CDP6). The CDP annual information request, sent to the Chair of the Board of the world s largest companies by market capitalization, covers four principal areas. These are: 1) Management s views on the risks and opportunities that climate change presents to the business; 2) Greenhouse gas emissions accounting; 3) Management s strategy to minimise risk, capitalise on opportunity and reduce emissions; and 4) Corporate governance with regard to climate change. The CDP6 information request can be viewed in Appendix A. The responses from companies to CDP s annual requests for corporate data provide investors with vital information regarding the current and future impact of climate change on their portfolios, and represent an important resource in relation to investment decisions. The fact that CDP s requests are made on behalf of investors serves to raise the awareness of senior management that climate change is a business issue that requires serious strategic focus. After six consecutive years of growth, CDP currently operates in more than 20 countries, with new operations launched in China, Korea, Latin America, the Netherlands and Spain during For a full list of countries and the partners that support CDP in each region please see Appendix B. CDP has also entered into key strategic relationships with Merrill Lynch and PWC which will support growth over the next three years. CDP6 Signatory Location by Region Africa (1%) 2. Asia (8%) 3. Australasia (7%) 4. Europe (47%) North America (27%) 6. South America (10%) The Carbon Disclosure Project is vital, and we ve got to get everybody to participate in it. Bill Clinton former U.S. President 4 Iceland Norway Sweden Canada Denmark Finland UK Germany Netherlands China Switzerland Japan USA Spain France Italy Thailand Taiwan Korea Mexico India Malaysia Hong Kong Singapore Indonesia Brazil South Africa Australia Chile New Zealand Argentina 17

18 Carbon Disclosure Project 2008 Before CDP we had no comprehensive data on corporate greenhouse gases. But with CDP policy makers, investors and companies themselves can take better informed decisions. Fredrik Reinfeldt Swedish Prime Minister The Carbon Disclosure Project is an excellent tool for increasing the exchange of climate information between companies and their institutional investors. Bendt Bendtsen Danish Minister for Economic and Business Affairs We are pleased to report that CDP received a record number of company responses to its 2008 annual request more than 1,500 in total. This demonstrates an increasing understanding by the world s largest corporations of the importance of climate change and its relation to business strategy and shareholder value. Analysis of this year s responses shows an advance in greenhouse gas emissions accounting since CDP is currently conducting further research into how investors use CDP data in order to improve understanding of the investment community s requirements. The results to date show signatory investors using company responses to CDP in: Company engagement; Qualitative checking; Sell-side research; Filing of shareholder resolutions; and Creation of new products and indices. Some of the other activities and initiatives in which CDP is active are summarised below. Supply chain initiatives This year more than 2,000 additional companies were brought into CDP s system through our new supply chain initiatives. More than 30 companies, including Tesco, HP, Kellogg and Vodafone now use the CDP system to collect climate change relevant data from their supply chains. This represents a significant achievement by the corporate community, demonstrating how collaboration is key to better understanding of climate change and its impacts on procurement. Government activity Carbon disclosure has assumed heightened importance on the political agenda and the CDP process has received support from political leaders globally. Internationally, the UK government is considering mandatory disclosure for all British companies and the US administration is under mounting pressure to establish more ambitious reduction targets. The US Environmental Protection Agency is currently exploring the development of a mandatory greenhouse gas reporting program and it is expected the new administration will usher in a US wide regulatory emissions trading scheme. This will change the face of carbon finance and trading and attract hundreds of new companies into the carbon market which is already valued at in excess of $64 billion by the World Bank. Government and public sector organisations also understand the importance of measuring their own carbon risks and emissions. More than 30 cities in the USA are currently working together to report through the CDP system, a development that will yield a much better understanding of how cities, responsible for 75% of total global emissions, are preparing for the low carbon economy. CDP is also working with government departments in the UK including the Foreign and Commonwealth Office and the Office of Government Commerce in HM Treasury to understand supply chain emissions, risks and opportunities. 18

19 1. The Carbon Disclosure Project Climate Disclosure Standards Board The recently established, international Climate Disclosure Standards Board (CDSB), for which CDP acts as Secretariat, aims to promote and advance climate change related disclosure in mainstream reports through the development of a global framework for corporate reporting on climate change. By working with preparers and users of information, their advisors, regulators and public interest groups, CDSB aims to develop a framework that will elicit comprehensive, consistent and comparable information for investors. This will offer greater certainty on disclosure requirements for corporations, and thereby provide an influential model for use by national regulators. Rather than creating an entirely new standard, CDSB aims to support, harmonize and strengthen existing climate change related reporting initiatives and standards by bringing together and enhancing best practices in the form of a single consistent framework that can be used for disclosure in mainstream reports. CDP in the future CDP is continuously working to improve the quality and quantity of reporting on climate change. CDP is also improving its online reporting system and providing extensive guidance on what should be measured and reported. CDP will refine its offering to investors through the provision of more bespoke data to service the requirements of individual investment institutions. CDP is also working to expand the availability of its information through professional data distribution channels. CDP plans to continue its expansion around the globe and aims to launch operations in Russia, Ireland and Israel in CDP has recently launched a new project working with banks to better understand the opportunities, risks and liabilities with relation to climate change across their client base, including the lending and private equity portfolios. CDP is also developing strategic relationships with a range of organisations to develop CDP s work and reach in the future. CDP is working towards a unified global business response to climate change and, through its associations with investors, corporations, governments and the public sector, will continue to help catalyse a sustainable, low carbon economy. The Carbon Disclosure Project is independent and impartial, it is a clear and transparent mechanism for anyone to see our carbon footprint and to judge our performance at reducing it. Sir Terry Leahy Tesco PLC, Chief Executive The specialist focus of the Carbon Disclosure Project provides a suitably rigorous structure for an overview of a company s response to climate change, and the survey template is a very helpful management tool for us to assess climate-related risks and opportunities in our own business. It also allows us to benchmark our practices against peers. Sir Tom McKillop Chairman, Royal Bank of Scotland Group 19

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