Preparing for Mandatory Carbon reporting webinar questions

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1 Please note the following are responses made immediately after the webinar on 22 nd May - it is not formal guidance / should not be regarded as such (please treat as verbal response to webinar and suggest you do not circulate on to others). Defra are about to issue guidance on mandatory GHG reporting (as soon as the new regulations have been laid in Parliament). This guidance should be referred to when available. Draft of the guidance has also been circulated with this note. QUESTION Does GHG reporting have to match the GRI reporting? Is mandatory reporting of GHG a precursor to a greater carbon trading scheme covering all emissions? Is it a requirement to always report 3 - tco2e figures? (i.e. base year, previous year and intensity) What happens when the acquired company has previously used a different methodology for its emissions? Do these need to be aligned? Can you explain how the web based tool will work? What about double accounting? Example, if you work in an serviced office. Do you count that in your report or not as the landlord might report this Defra gives country by country guidance on the emission factors for electricity? Does the rule of de minimis come in with emissions which are not material If the spreadsheet is being replaced, will the web ANSWER No its not a requirement although GHG reporting can contribute to a GRI or wider report and existing reporting may help you meet the new mandatory requirement Not directly related (not known to be) The requirement is to report the current year, the prior year (after year one) and an intensity metric (we assume for both the current and comparative period). You do not have to report a baseline year but we expect many companies will adopt the first year as their baseline. It would be confusing if a company were using more than one methodology. It would be logical that if an acquired business uses a different methodology then the GHG reporting is brought in to line with that of the acquirer. If the acquired business is deemed to have a more appropriate methodology then we would expect the acquirer to restate its GHG reporting to the new methodology and explain this. Ideally they should be aligned for transparency and consistency, also this would be simpler for the company to use the same methodology throughout the company. However, they could use differing methods as long as this is explained in their report. The regulations require a company to state which methodology(ies) have been used. The tool will ask a series of filtering questions about which factors you need and will then generate an excel output with just the factors requested. There is still the option to view all the factors if required. You need to decide if you are responsible for the emissions this is the central point for you. Double counting is a concern but is less critical in this instance (as there is no direct aggregation of different companies figures for formal use) The Defra/DECC conversion factors provide a list of electricity factors for other countries. MR does not specifically direct you. You need to select your methodology (and in turn different methodologies address materiality etc). Please also refer to Defra guidance to be published soon The tool generates an excel output file which can

2 tool be available off line? Do greyfleet emissions need to be considered in the reporting For companies with global operations where there are problems finding suitable emission factors for the CO2e calculations would it be acceptable to use, say, UK factors but state that this was the case. Aside from materiality, uncertainty of data may be also be an issue with reporting. Will this be addressed by the guidance document? One of the concerns is that reported data may not be complete and it would be difficult to see if any emissions had been omitted or overlooked e.g. fugitive emissions from refrigeration. This questions the need for independent checking by GHG competent persons of the reported emissions prior public reporting. Do we know when regulation is likely to be passed please? You mentioned regulations are going through parliamentary approval, do we know any details as to dates please? Should emissions from Joint Ventures and Franchisees be reported? Who reports the emissions where a utility is supplied from a landlords main supply? The Landlord or the tenant? be saved or printed. There is also the option to view the full set of the factors offline. This comes back to the responsible for discussion. Greyfleet (employees using their own vehicles for business travel) may be deemed to be scope 3 emissions. Others may take a different view and treat as scope 1 (fuel consumed for direct business). In any event under MR the question is is the business responsible for these emissions. Some stakeholders would put forward a strong argument that they are as it is the business that is requiring the employee to make these journeys in the course of carrying out its business. No. Defra already provides international emission factors for electricity. For certain countries. The emissions per kwh of electricity will very significantly, depending on the grid average of the country. GHG Protocol and other sources also are worth consulting The guidance does suggest that assurance over the GHG reporting is useful. This can be a useful tool to mitigate the risk of error. Where a known uncertainty exists we would expect companies to be transparent and explain why this is the case and the likely impact (ie over what quantum of the total emissions). We would suggest that companies saying that they do not have much certainty over their emissions could be seen to be sending a message that says they do not have much control over a possible significant cost to their business, and therefore should not be considered a short cut. There is also a comply or explain provision expected. Agreed there is an important role for internal and/or external independent checking of data and systems - and this is especially important in the formative stages of developing your data collection and management systems (and in deed will continue to be important as systems are added to). As per presentations from Paul and Bekir errors can easily be made and internal and external checks are invaluable.. Regulations are to be laid in Parliament within the wider BIS Narrative reporting regs Estimated that these will be laid in next few weeks Depends on your approach that you decide to follow - Paul and Bekir provided some examples of different approaches. GHG Protocol provides guidance on this. Depends on whoever decides they are responsible for emissions. You can apportion the landlord s utility data for the building for the area you use. For instance if you use 2 floors of a 10 storey building, you could assume that 20% of utility consumption

3 We are an American company based in the UK. Are we expected to report the figures for just the UK site or is it for the entire company? The first reporting year requires data from before the regulations actually take effect - this seems to be retrospective application of legislation? I work in an SD role for one of the c. 100 companies 1st affected with a FY end date of 30/9. It's getting very close to our Corp Comms Dept. deadline for laying out the ARA...please can you I encourage DEFRA & BIS to get these Regs agreed (via HM Govt) and then BIS the Guidance issued ASAP! If a company rents their property but pays for gas use through boiler is that scope 1 or 2? Are Scope 1 travel emissions included? That is vehicles owned by a company e.g. company cars How will the GHG programme interact with the proposed EU directive on CSR reporting? Can the reporting term "Landlord Supplies" be clarified? Will this not be double accounted by the Landlord if they are reporting? Can you confirm Oslo Bors companies are required to report? Would I be sent with reply regarding companies registered with Oso Bors stock exchange and if they are considered quoted companies under mandatory GHG regulation? If a company uses an overseas GJHG calculation methodology for its overseas operation, and a UK or international methodology for its UK operations, which methodology should be referenced in the Directors' Report? How does a company decide what the intensity ratio is for its operation? Is it certain that Parliament will approve these regulations within the next few weeks? What happens if they don't? You say that all 6 GHGs need to be reported. The current Defra conversion factors mainly reference only CO2, CH4 and N2O. Do you provide information in your guidance notes as to which set of conversion factors will facilitate the reporting of is yours. The American company would need be UK registered and listed on the stock markets - at the group level. Please also see Defra guidance and consult your company secretary Carla explained in her slide 11 how the timelines fitted - You are correct that some companies should now be collecting data if they are to meet the regulations. If a company can not report a full year of data in its first report, it will need to explain this (be transparent) The forthcoming Defra guidance will further address this issue They know but we will pass this on - thanks We would say scope 1 BUT The regulations refer to responsible for. It will be for the company to decide if they deem themselves as responsible for these emissions. Yes Separate but complimentary Possibly it could be. You have to resolve by deciding if it is you or landlord that is responsible for the emissions They would have to refer to the quoted company definition in Defra presentation. However, Oslo Bors companies would only be required to report if they are UK incorporated. Defra are not planning to send any s out to affected companies. We suggest that you need to provide sufficient information for the readers of the directors report to understand what you have done. If you have used two different methodologies then you will need to provide that information. It is however likely that even different methodologies would have certain consistencies and therefore you could just explain where you have differentiated from one or the other. Defra guidance will further explain IR but effectively it will be for company to decide itself Yes as certain as we can be Defra already provide guidance - There are on- line EFs. These will be further referenced in forthcoming defra guidance

4 all six GHGs? Does the GHG reporting period have to match the financial reporting period? If financially we use the calendar year can the GHG data included in the report be Oct 1 to Sept 30? Thank you for your response Can you explain what an intensity ratio is? Do regulations cover all 6 Greenhouse Gases? Do the regulations require the global GHG footprint for each obliged company or only the UK footprint Will there be published templates itemising the minimum standard including conversion and intensity? Will the UK conversion factors be the same as that stipulated by the CRC? Thank you. Will central and local government be required to report in same was as companies? It seems very unfair if the onus is only upon quoted companies. I'd like to know more about the new GHG conversion factor tool, and whether the conversion factors will still be visible / available so we can ensure our tools remain in line? Will there be any penalties for companies who fail to report their MCR data? Are carbon offsets allowed? Will the GHG conversion factors also still be available in pdf format for those that use them for reference, but don't use the DEFRA tool? I understand BIs has written to all Participants whose financial year end at the end of September 2013 last week. The integration of GHG with narrative reporting seems to make sense, but the timescales for implementation are not far away. So when will the detail all be published completely in the public domain so that all affected companies are completely aware of their obligations? With regard to the requirement for an auditor to This is expected -- You may report emissions for a different 12 month period but if you decide to do so you must state this within the Directors Report Intensity ratio relates overall emissions to a per unit measure (e.g. turnover, employees, output, etc) - Defra guidance addresses Yes Global but see guidance due soon There will be published guidance due soon from defra Yes as CRC is to use Defra conversion factors There was a national indicator requiring this until recently. This was dropped but there is still an expectation and many LAs do continue to report (and referred to use defra guidance) The tool will ask a number of filtering questions about which factors the user will require and then the set of factors will be produced in an excel format. There is the option to view the full set of factors in an excel format. This is covered in the guidance. Financial Reporting Council will enforce the regulation, they have the power to enquire into cases where it appears info has not been disclosed and can ask for revised report and/or set of accounts. There are no immediate financial penalties for not complying, but a very real reputational risk of providing no or inaccurate data. Some have suggested that in the extreme - it could mean a qualified audit report for non compliance, the AR&A being sent to the FRRP or the directors facing prosecution. NO (although can be in voluntary reports and under Defra voluntary guidance) The new tool is web based and will provide the factors in an excel output file which can be saved or printed. When you save the file you can choose to do this as a PDF which will then provide the factors in a PDF format. Understood that publication is due as soon as Regulations have been laid

5 consider whether the information is consistent with the financial statements. Can we get more clarification - is this an internal or external auditor (Internal Audit team, environmental consultants, csr Verification Company...) How do attendees get onto Defra's list for info on updates to their GHG conversion factor tool Thank you for the presentation. What are the requirements for manufacturing companies where revealing overall CO2 emissions would enable confidential production information to be calculated by competitors? I am not clear about whether being in a Climate Change agreement exempts a company from this disclosure Will the 2013 emissions factors still be available in a spreadsheet even if the calculation part is a web tool? The DEFRA excel spreadsheet is very useful for recording workings, not only calculating the end result. It would be very useful to keep this as an option With regards to landlord supplies. We currently scale up our results (from about actual data coverage of 85%), this takes account of the small serviced offices where we don t get bills. Will scaling up be allowed for mandatory reporting? Could you confirm whether the reporting period will be required retrospectively? In Carla's presentation she stated reporting period dating back to My understanding was that the the reporting periods were 'as from' when the legislation comes into force (i.e. from October 2013 onwards) Does Defra maintain any links or information regarding conversion factors for other countries? This refers to the external statutory auditor of the financial statements. Please We do not believe there are any exemptions. Instinctively it feels almost impossible to reverse calculate critical specific information - as production figures, running time, type and number of machines are all variables. Furthermore, you would be aggregating your data for all sites. Difficult to see this as an issue unless looking at a single very large facility. OTHER VIEW - it is very unlikely that a comply or explain exemption would be needed on the grounds of something being seriously prejudicial to the commercial interests of the company in all but very extreme circumstances. The web tool will ask a number of filtering questions about which factors the user will require and then a set of factors will be produced in an excel format, as a spreadsheet but split into different tabs for each factor category. There is the option to view the full set of factors in this excel format. Unfortunately the calculation facility in the existing spreadsheets has not been carried over to the new web tool, although factors will be provided to the user in a new excel/spreadsheet format. Defra have consulted with a number and variety of business over the last 6 months and indicate this was not something that was used much and so it was decided to remove the calculation functionality. However, the figures for each factor are still supplied and it is a simple multiplication of this number by your activity data that will give you your total emissions figure. Yes but you should explain and be transparent on your methods This is addressed in slide 11 from carla Defra/DECC conversion factors include international electricity factors for certain countries.

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