Carbon Disclosure Project 2009 FTSE 350 Report

On behalf of 475 investors with assets of US $55 trillion

Report written for Carbon Disclosure Project Carbon Disclosure Project by: [email protected] +44 (0) 20 7970 5660 www.cdproject.net Carbon Disclosure Project

Carbon Disclosure Project 2009 CDP Members 2009 Generation Investment Management UK This report and all of the public responses from corporations are Grupo Santander Brasil Brazil available to download free of MEMBER 2009 charge from www.cdproject.net. ING Netherlands ABRAPP - Associação KLP Insurance Norway Brasileira das Entidades Legg Mason, Inc. US Fechadas de Previdência Complementar Brazil Libra Fund, L.P. US Aegon N.V. Netherlands London Pensions Fund Authority UK AIG Investments US Mistra, Foundation for APG Investments Strategic Environmental Netherlands Research Sweden ASN Bank Netherlands Mitsubishi UFJ Financial ATP Group Denmark Group (MUFG) Japan Aviva Investors UK Morgan Stanley Investment AXA Group France Management US Bank of America Corporation National Australia Bank US Limited Australia BBVA Spain Neuberger Berman US BlackRock US Newton Investment Management Limited UK BP Investment Management Limited UK Northwest and Ethical Investments LP Canada Caisse de dépôt et placement du Québec Pictet Asset Management SA Canada Switzerland California Public Employees’ Rabobank Netherlands Retirement System US Robeco Netherlands California State Teachers Russell Investments UK Retirement System US Schroders UK Calvert Group US Second Swedish National Catholic Super Australia Pension Fund (AP2) Sweden CCLA Investment Sompo Japan Insurance Inc. Management Ltd UK Japan CIBC Canada Standard Chartered PLC UK Daiwa Asset Sun Life Financial Inc. Management Co. Ltd Japan Canada Essex Investment Swiss Reinsurance Company Management, LLC US Switzerland Ethos Foundation Switzerland The RBS Group UK Folksam Sweden The Wellcome Trust UK Fortis Investments Belgium Zurich Cantonal Bank Switzerland

2 CDP Signatories 2009

CDP Signatories 2009 BlackRock US DB Advisors Deutsche Asset Management Germany Blue Marble Capital Management Limited Canada DEFO – Deutsche Fonds für Immobilienvermögen BMO Financial Group Canada 475 institutional investors with assets GmbH Germany BNP Paribas Investment Partners France of over US$55 trillion were signatories DEGI Deutsche Gesellschaft für Immobilienfonds to the CDP 2009 information request Boston Common Asset Management, LLC US mbH Germany dated 1st February 2009, including: BP Investment Management Limited UK Deka FundMaster Investmentgesellschaft mbH Germany Brasilprev Seguros e Previdência S/A. Brazil Deka Investment GmbH Aachener Grundvermögen British Columbia Investment Management Germany Kapitalanlagegesellschaft mbH Germany Corporation (bcIMC) Canada DekaBank Deutsche Girozentrale Germany Aberdeen Asset Managers UK BT Financial Group Australia Deutsche Bank Germany Acuity Funds Canada BT Investment Management Australia Deutsche Postbank Privat Investment Kapitalanlagegesellschaft mbH Germany Addenda Capital Inc. Canada Busan Bank South Korea Development Bank of Japan Japan Advanced Investment Partners US CAAT Pension Plan Canada Development Bank of the Philippines (DBP) Advantage Asset Managers (Pty) Ltd South Africa Caisse de dépôt et placement du Québec Canada Philippines Aegon N.V. Netherlands Caisse des Dépôts France Dexia Asset Management France Aeneas Capital Advisors US Caixa de Previdência dos Funcionários do Banco DnB NOR ASA Norway AGF Management Limited Canada do Nordeste do Brasil (CAPEF) Brazil Domini Social Investments LLC US AIG Investments US Caixa Econômica Federal Brazil DPG Deutsche Performancemessungs- Caixa Geral de Depósitos Portugal Alberta Investment Management Corporation Gesellschaft für Wertpapierportfolio mbh Germany (AIMCo) Canada California Public Employees’ Retirement System East Sussex Pension Fund UK Alberta Teachers Retirement Fund Canada US Economus Instituto de Seguridade Social Brazil Alcyone Finance France California State Teachers Retirement System US ELETRA – Fundação Celg de Seguros e California State Treasurer US Allianz Group Germany Previdência Brazil Calvert Group US Altshuler Shacham LTD Israel Environment Agency Active Pension fund UK Canada Pension Plan Investment Board Canada AMP Capital Investors Australia Epworth Investment Management UK Canadian Friends Service Committee (Quakers) AmpegaGerling Investment GmbH Germany Erste Group Bank AG Austria Canada APG Investments Netherlands Essex Investment Management, LLC US CAPESESP Brazil ARIA (Australian Reward Investment Alliance) Ethos Foundation Switzerland Australia Capital Innovations, LLC US Eureko B.V. Netherlands Arkitekternes Pensionskasse Denmark CARE Super Pty Ltd Australia Eurizon Capital SGR Italy Artus Direct Invest AG Germany Carlson Investment Management Sweden Evangelical Lutheran Church in Canada Pension Carmignac Gestion France ASB Community Trust New Zealand Plan for Clergy and Lay Workers Canada Catherine Donnelly Foundation Canada ASN Bank Netherlands Evli Bank Plc Finland Catholic Super Australia ATP Group Denmark F&C Management Ltd UK Cbus Superannuation Fund Australia Australia and New Zealand Banking Group Limited Faelba Brazil Australia CCLA Investment Management Ltd UK FAELCE – Fundação Coelce de Seguridade Social Australian Ethical Investment Limited Australia Central Finance Board Brazil of the Methodist Church UK AustralianSuper Australia Fédéris Gestion d’Actifs France Ceres, Inc. US Aviva Investors UK First Affirmative Financial Network US Cheyne Capital Management (UK) LLP UK Aviva plc UK First Swedish National Pension Fund (AP1) Sweden CI Mutual Funds’ Signature Advisors Canada AXA Group France FirstRand Ltd. South Africa CIBC Canada Baillie Gifford & Co. UK Fishman & Co. Israel Clean Yield Group, Inc. US Bakers Investment Group Australia Five Oceans Asset Management Pty Limited Banco Sweden ClearBridge Advisors, Socially Aware Investment Australia US Banco Bradesco S.A Brazil Florida State Board of Administration (SBA) US Close Brothers Group plc UK Banco de Galicia y Buenos Aires S.A. Argentina Folksam Sweden Colonial First State Global Asset Management Fondaction CSN Canada Banco do Brazil Brazil Australia Fonds de Réserve pour les Retraites – FRR Banco Santander, S.A. Spain Comite syndical national de retraite Bâtirente France Banesprev – Fundo Banespa de Seguridade Social Canada Fortis Bank Nederland Netherlands Brazil Commerzbank AG Germany Fortis Investments Belgium Bank of America Corporation US CommInsure Australia Forward Management, LLC US Bank Sarasin & Co, Ltd Switzerland Companhia de Seguros Aliança do Brasil Brazil Fourth Swedish National Pension Fund, (AP4) Sweden Bank Vontobel Switzerland Compton Foundation, Inc. US Frankfurter Service BANKINTER S.A. Spain Connecticut Retirement Plans and Trust Funds US Kapitalanlagegesellschaft mbH Germany Barclays Group UK Co-operative Financial Services (CFS) UK FRANKFURT-TRUST Investment BayernInvest Kapitalanlagegesellschaft mbH Corston-Smith Asset Management Sdn. Bhd. Gesellschaft mbH Germany Germany Malaysia Franklin Templeton Investment BBC Pension Trust Ltd UK Crédit Agricole Asset Management France Services Gmbh Germany BBVA Spain Credit Suisse Switzerland Frater Asset Management South Africa Bedfordshire Pension Fund UK Daegu Bank South Korea Friends Provident UK Beutel Goodman and Co. Ltd Canada Daiwa Securities Group Inc. Japan Front Street Capital Canada

3 Carbon Disclosure Project

Fukoku Capital Management Inc Japan Infrastructure Development Finance MEAG Munich Ergo Asset Company Ltd. (IDFC) India Management GmbH Germany Fundação AMPLA de Seguridade Social – Brasiletros Brazil ING Netherlands MEAG Munich Ergo Kapitalanlagegesellschaft mbH Germany Fundação Atlântico de Seguridade Social Brazil Inhance Investment Management Inc Canada Meeschaert Gestion Privée France Fundação Banrisul de Seguridade Social Brazil Insight Investment Management (Global) Ltd UK Meiji Yasuda Life Insurance Company Japan Fundação CEEE de Seguridade Social – Instituto de Seguridade Social dos Correios e ELETROCEEE Brazil Telégrafos- Postalis Brazil Merck Family Fund US Fundação Codesc de Seguridade Social – FUSESC Instituto Infraero de Seguridade Social – Mergence Africa Investments (Pty) Limited Brazil INFRAPREV Brazil South Africa Fundação de Assistência e Previdência Social do Insurance Australia Group Australia Meritas Mutual Funds Canada BNDES – FAPES Brazil Internationale Kapitalanlagegesellschaft mbH Metzler Investment Gmbh Germany Fundação Forluminas de Seguridade Social – Germany Midas International Asset Management FORLUZ Brazil Investec Asset Management UK South Korea Fundação Promon de Previdência Social Brazil Itaú Unibanco Banco Múltiplo S.A. Brazil Miller/Howard Investments US Fundação São Francisco de Seguridade Social J.P. Morgan Asset Management US Mirae Investment Asset Management Brazil South Korea Janus Capital Group Inc. US Fundação Vale do Rio Doce de Seguridade Mistra, Foundation for Strategic Social – VALIA Brazil Jarislowsky Fraser Limited Canada Environmental Research Sweden FUNDIÁGUA – Fundação de Previdência da Jubitz Family Foundation US Mitsubishi UFJ Financial Group (MUFG) Japan Companhia de Saneamento e Ambiental do Jupiter Asset Management UK Distrito Federal Brazil Mitsui Sumitomo Insurance Co.,Ltd. Japan K&H Investment Fund Management/K&H Gartmore Investment Management Ltd UK Mizuho Financial Group, Inc. Japan Befektetési Alapkezelö Zrt Hungary Generation Investment Management UK Mn Services Netherlands KB Kookmin Bank South Korea Genus Capital Management Canada Monega Kapitalanlagegesellschaft mbH Germany KBC Asset Management NV Belgium Gjensidige Forsikring Norway Morgan Stanley Investment Management US KCPS and Company Israel GLG Partners LP UK Motor Trades Association of Australia KDB Asset Management Co., Ltd. South Korea Superannuation Fund Pty Ltd Australia Goldman Sachs & Co. US Kennedy Associates Real Estate Counsel, LP US MP Pension – Pensionskassen for Magistre Governance for Owners UK KfW Bankengruppe Germany og Psykologer Denmark Government Employees Pension Fund (“GEPF”), Kibo Technology Fund South Korea Munich Re Group Germany Republic of South Africa South Africa KLP Insurance Norway Mutual Insurance Company Pension-Fennia Green Cay Asset Management Bahamas Korea Investment Trust Management Co., Ltd. Finland Green Century Funds US South Korea Natcan Investment Management Canada Groupe Investissement Responsable Inc. Canada KPA Pension Sweden Nathan Cummings Foundation, The US GROUPE OFI AM France Kyobo Investment Trust Management Co., Ltd. National Australia Bank Limited Australia GrowthWorks Capital Ltd. Canada South Korea National Bank of Canada Canada Grupo Banco Popular Spain La Banque Postale Asset Management France National Bank of Kuwait Kuwait Grupo Santander Brasil Brazil La Financiere Responsable France National Grid Electricity Group of the Electricity Gruppo Monte Paschi Italy LBBW – Landesbank Baden-Württemberg Supply Pension Scheme UK Germany Guardian Ethical Management Inc Canada National Grid UK Pension Scheme UK LBBW Asset Management GmbH Germany Guardians of New Zealand Superannuation National Pensions Reserve Fund of Ireland Ireland New Zealand LD Lønmodtagernes Dyrtidsfond Denmark Natixis France Hang Seng Bank Hong Kong Legal & General Group plc UK Needmor Fund US HANSAINVEST Hanseatische Investment GmbH Legg Mason, Inc. US Nest Sammelstiftung Switzerland Germany Lend Lease Investment Management Australia Neuberger Berman US Harrington Investments US Libra Fund, L.P. US New Alternatives Fund Inc. US Hastings Funds Management Limited Australia Light Green Advisors, LLC US New Jersey Division of Investment US Hazel Capital LLP UK Living Planet Fund Management Company S.A. New Mexico State Treasurer US Health Super Fund Australia Switzerland New York City Employees Retirement System US Helaba Invest Kapitalanlagegesellschaft mbH Local Authority Pension Fund Forum UK New York City Teachers Retirement System US Germany Local Government Superannuation Scheme Henderson Global Investors UK Australia New York State Common Retirement Fund (NYSCRF) US Hermes Fund Managers UK Local Super SA-NT Australia Newton Investment Management Limited UK HESTA Super Australia Lombard Odier Darier Hentsch & Cie Switzerland NFU Mutual Insurance Society UK Hospitals of Ontario Pension Plan (HOOPP) London Pensions Fund Authority UK Canada NH-CA Asset Management South Korea Lothian Pension Fund UK HSBC Holdings plc UK Nikko Asset Management Co., Ltd. Japan Macif Gestion France Hyundai Marine & Fire Insurance Co, Ltd Nissay Asset Management Corporation Japan Macquarie Group Limited Australia South Korea Nordea Investment Management Sweden Magnolia Charitable Trust US IDBI Bank Limited India Norfolk Pension Fund UK Maine State Treasurer US Ilmarinen Mutual Pension Insurance Company Norges Bank Investment Management (NBIM) Finland Man Group plc UK Norway Impax Group plc Maple-Brown Abbott Limited Australia UK Norinchukin Zenkyouren Asset Industrial Bank China Marc J. Lane Investment Management, Inc. US Management Co., Ltd Japan Industry Funds Management Australia Maryland State Treasurer US North Carolina State Treasurer US McLean Budden Canada Northern Ireland Local Government Officers’ Superannuation Committee (NILGOSC) UK 4 CDP Signatories 2009

Northern Trust US SEB Asset Management AG Germany The Local Government Pensions Insitution (LGPI)(keva) Finland Northwest and Ethical Investments LP Canada Second Swedish National Pension Fund (AP2) Sweden The Presbyterian Church in Canada Canada Oddo & Cie France Seligson & Co Fund Management Plc Finland The RBS Group UK Old Mutual plc UK Sentinel Funds US The Russell Family Foundation US OMERS Administration Corporation Canada SERPROS Fundo Multipatrocinado Brazil The Shiga Bank, Ltd. Japan Ontario Teachers Pension Plan Canada Service Employees International Union The Standard Bank of South Africa Limited Opplysningsvesenets fond Benefit Funds US South Africa (The Norwegian Church Endowment) Norway Seventh Swedish National Pension Fund (AP7) The Sustainability Group at the Loring, Oregon State Treasurer US Sweden Wolcott & Coolidge Office US Orion Asset Management LLC US Shinhan Bank South Korea The Travelers Companies, Inc. US Pax World Funds US Shinhan BNP Paribas Investment Trust The United Church of Canada – General Council PBU – Pension Fund of Early Childhood Teachers Management Co., Ltd South Korea Canada Denmark Shinkin Asset Management Co., Ltd Japan The University of Edinburgh Endowment Fund UK Pension Fund for Danish Lawyers and Economists Shinsei Bank Limited Japan The Wellcome Trust UK Denmark Siemens Kapitalanlagegesellschaft mbH Germany Third Swedish National Pension Fund (AP3) Pension Protection Fund UK Sweden Signet Capital Management Ltd Switzerland Pensionskassen for Jordbrugsakademikere Threadneedle Asset Management UK og Dyrlæger Denmark Skandia Nordic Division Sweden Tokio Marine & Nichido Fire Insurance Co., Ltd. PETROS – The Fundação Petrobras de SMBC Friend Securities Co., LTD Japan Japan Seguridade Social Brazil Smith Pierce, LLC US Toronto Atmospheric Fund Canada PFA Pension Denmark SNS Asset Management Netherlands Trillium Asset Management Corporation US PGGM Netherlands Social(k) US Triodos Bank Netherlands Phillips, Hager & North Investment Société Générale France Management Ltd. Canada TrygVesta Denmark Sompo Japan Insurance Inc. Japan PhiTrust Active Investors France UBS AG Switzerland Souls Funds Management Limited Australia Pictet Asset Management SA Switzerland Unibanco Asset Management Brazil SPF Beheer bv Netherlands Pioneer Alapkezelö Zrt. Hungary UniCredit Group Italy Sprucegrove Investment Management Ltd Canada Pioneer Investments Union Asset Management Holding AG Germany Kapitalanlagegesellschaft mbH Germany Standard Chartered PLC UK Union Investment Institutional GmbH Germany PKA Denmark Standard Life Investments UK Union Investment Privatfonds GmbH Germany Portfolio 21 Investments US State Street Corporation US Union Investment Service Bank AG Germany Portfolio Partners Australia Statewide Superannuation Trust Australia Union PanAgora Asset Management GmbH Porto Seguro S.A. Brazil Storebrand ASA Norway Germany PPM Premiepensionsmyndigheten Sweden Strathclyde Pension Fund UK UniSuper Australia PRECE Previdência Complementar Brazil Stratus Group Brazil Unitarian Universalist Association US PREVI Caixa de Previdência dos Funcionários Sumitomo Mitsui Banking Corporation Japan United Methodist Church General Board of do Banco do Brasil Brazil Pension and Health Benefits US Sumitomo Mitsui Card Company, Limited Japan Principle Capital Partners Limited United Nations Foundation UK Sumitomo Mitsui Finance & Leasing Co., Ltd US PSP Investments Canada Japan Universal Investment Gesellschaft mbH Germany QBE Insurance Group Limited Australia Sumitomo Mitsui Financial Group Japan Universities Superannuation Scheme (USS) UK Q Capital Partners South Korea Sumitomo Trust & Banking Japan Vancity Group of Companies Canada Railpen Investments UK Sun Life Financial Inc. Canada VERITAS SG INVESTMENT TRUST GmbH Germany Rathbones/Rathbone Greenbank Investments UK Superfund Asset Management GmbH Germany Vermont State Treasurer US Real Grandeza Fundação de Previdência e Svenska Kyrkan, Church of Sweden Sweden VicSuper Pty Ltd Australia Assistência Social Brazil Swedbank Sweden Victorian Funds Management Corporation Rei Super Australia Australia Swiss Reinsurance Company Switzerland Rhode Island General Treasurer US Visão Prev Sociedade de Previdencia Swisscanto Holding AG Switzerland Complementar Brazil RLAM UK Syntrus Achmea Asset Management Netherlands Waikato Community Trust Inc New Zealand Robeco Netherlands TD Asset Management Inc. and TDAM USA Inc. Walden Asset Management, a division of Boston Rose Foundation for Communities Canada Trust and Investment Management Company US and the Environment US Teachers Insurance and Annuity Association – Warburg-Henderson Kapitalanlagegesellschaft Royal Bank of Canada Canada College Retirement Equities Fund (TIAA-CREF) US für Immobilien mbH Germany RREEF Investment GmbH Germany Tempis Capital Management South Korea West Yorkshire Pension Fund UK Russell Investments UK Terra Forvaltning AS Norway WestLB Mellon Asset Management (WMAM) SAM Group Switzerland TfL Pension Fund UK Germany Sanlam Investment Management South Africa The Bullitt Foundation US Westpac Investment Management Australia Santa Fé Portfolios Ltda Brazil The Central Church Fund of Finland Finland Winslow Management Company US Sauren Finanzdienstleistungen Germany The Collins Foundation US WOORI BANK South Korea Savings & Loans Credit Union (S.A.) Limited. The Co-operators Group Ltd Canada YES BANK Limited India Australia The Daly Foundation Canada York University Pension Fund Canada Schroders UK The Dreyfus Corporation US Youville Provident Fund Inc. Canada Scotiabank Canada The Japan Research Institute, Limited Japan Zurich Cantonal Bank Switzerland Scottish Widows Investment Partnership UK The Joseph Rowntree Charitable Trust UK SEB Sweden 5 Carbon Disclosure Project 2009

Foreword to the 2009 Carbon Disclosure Project FTSE 350 report By Hilary Benn, Secretary of State for Department of Environment, Food & Rural Affairs (Defra)

I am delighted to contribute this foreword to the 2009 Carbon Disclosure Project’s FTSE 350 Report. The Carbon Disclosure Project has led the way in persuading companies in the UK, and around the world, to report on their greenhouse gas emissions and their corporate strategies for addressing climate change. I strongly support this initiative and Defra has contributed to funding it again this year. The Government is determined to help UK companies make the transition to a low carbon, resource efficient economy. The UK Climate Projections published in June will help companies to plan for a changing climate. The Low Carbon Transition Plan and the Low Carbon Industrial Strategy published in July set out our proposals for reducing emissions to prevent further damaging climate change and highlighted the business opportunities this will bring. Given the success of the CDP in getting leading companies in the UK to respond to their questionnaire, I am encouraged to believe that most – possibly all – leading UK companies will adopt the guidance that Defra, in co-operation with the Department for Energy and Climate Change, has recently published on how organisations should measure and report their greenhouse gas emissions. The publication of this guidance is one of the requirements of last year’s Climate Change Act. This guidance is based on the Greenhouse Gas Protocol, and its primary aim is to help all UK organisations to measure their emissions so that they can then start managing them more effectively. In this way corporate reporting has a contribution to make in helping us meet the challenging carbon budgets set out in the Low Carbon Transition Plan. Another requirement of the Climate Change Act is that Defra conducts a review of the effectiveness of company reporting in helping the UK meet its climate change objectives. - This review will be published by 1 December 2010 and will help Government to consider whether the reporting of greenhouse gases should become a mandatory part of corporate reporting under the Companies Act. A decision on this must be taken before April 2012 to meet the requirements of the Climate Change Act. I hope all organisations will follow the Government guidance; it is designed to help you reduce your emissions, and so save costs. The UK has set challenging targets to tackle climate change, and business has a critical role to play in helping the country achieve these and develop a truly low carbon economy.

6 Executive Summary

Introduction related to climate change and strategies for managing those risks The response rate for It is often said that a business can and opportunities. The corporations’ only manage what it measures. responses and reports assessing the the FTSE 100 increased Since 2000, the Carbon Disclosure results of these will be published in by four to 95%. Project (CDP) has, on behalf of more than 20 countries around the institutional investors, challenged the world and are freely available at world’s largest companies to measure www.cdproject.net. and report their carbon emissions; The standard of integrating the long-term value and CDP continues to be the global leader disclosure from FTSE cost of climate change into their in data that records the business assessment of the financial health and response to climate change; whether 350 companies has future prospects of their business. it be risks and opportunities, absolute increased dramatically emissions levels, performance over over the past four years. In 2009, the Carbon Disclosure Project time or governance. This report, (CDP) received the highest response prepared by CDP’s global adviser, rate to date, the highest level of PricewaterhouseCoopers LLP (PwC), disclosed emissions and greater detail analyses responses from the FTSE than ever before on the activities being 350. As of June 2009, the market undertaken by the largest corporations capitalisation of these companies was around climate change mitigation £0.8 trillion. and adaptation. This highlights the increasing action taken to respond to CDP 2009 highlights an increasingly pressing issue. Response rate holds firm despite Since the first CDP report in 2003, challenging economic environment the quantity and quality of data disclosed has advanced significantly: • The standard of disclosure a credit to those investors and from FTSE 350 companies has companies participating in the initiative. increased dramatically over the In parallel, CDP data is increasingly past four years since this group being applied as a catalyst for of companies was first included changing business behaviour and as a CDP sample in 2005. is becoming more integrated into • 236 companies responded mainstream financial analysis. Again, to CDP 2009, two more than this is a notable achievement. CDP 2008, maintaining an overall This year, CDP (backed by 475 response rate of 67%. The increase institutional investors representing in response rate for the FTSE 100 more than US$55 trillion of funds under was more marked, up by 4% management) sent questionnaires to to 95. These results suggest that, more than 3,700 of the world’s largest notwithstanding short term corporations requesting information concerns and pressure on senior on greenhouse gas emissions, the management time, climate change potential risks and opportunities remains high on the agenda and the value of the CDP exercise endures.

7 • The Utilities sector again has the The Carbon Disclosure There is a marked highest response rate, this year Leadership Index (CDLI) reaching 100% (10 companies), improvement in the followed by Consumer Staples The CDLI demonstrates range and disclosure of emissions (86%, 22 companies). The IT sector depth of carbon disclosure. data, with 55% (194) of saw the largest decrease of 37% down to just a 43% response. • Nine of the ten industry sectors are companies disclosing represented in the 38 companies Scopes 1 and 2 in CDP • Responses reveal that a global that constitute the CDLI in CDP 2009 compared to 47% agreement in Copenhagen 2009, Telecommunications is the would provide increased certainty only sector not represented this (163) in CDP 2008. for the FTSE 350 looking to set year. Furthermore, the top ten medium and long-term emissions scoring companies come from five reduction targets. different sectors. This shows that Fig. 1: Total response rates and there are clear and, in most cases, di sclosed emissions over • Companies across all sectors consistent disclosure leaders time (All Scopes;1 CDP 2007 identify sector-specific risks and across most areas of business; to CDP 2009) opportunities in relation to climate change. Of responding companies • The Financials and Consumer in CDP 2009, 91% (193 companies) Discretionary sectors have the cite at least one opportunity arising greatest representation at 24% 250 5 from climate change, although these (nine companies) and 18% (seven vary widely in terms of the size and companies) respectively in the 200 4 timing of perceived benefits. CDLI, these sectors also constitute ) 3.4 s the first and third largest sectors in

s • There is a marked improvement in e the FTSE 350; and s 3.1 150 3 the disclosure of emissions data, pon s with 55% (194) of companies • Industrials, the second largest (billion tonne s disclosing Scopes21 and 2 in sector accounting for 19% of the ion

100 1.7 2 ss CDP 2009 compared to 47% (163) FTSE 350 is under-represented with emi Number of re only 11% (four companies). Five of 2 3 in CDP 2008. This reflects the

CO increasing ability of companies to the ten Utilities companies in the 50 1 measure and report on carbon. FTSE 350 are in the CDLI, the highest proportion of all sectors. • FTSE 350 responding companies 0 0 accounted for 390 million tCO2-e Because the same questionnaire in CDP2007 CDP2008 CDP2009 on the basis of direct, or Scope 1, CDP 2009 was used for all companies, emissions. Total reported emissions the CDLI makes no distinction between under Scope 2 and Scope 3 are companies in carbon-intensive sectors Total emissions 130 million and 2,870 million versus those in non-carbon-intensive tCO2-e respectively. CDP 2009 sectors. Companies were asked to witnessed improved disclosure of answer all questions that applied to each emissions Scope. their business.

1 Scope 1, Scope 2 (calculated from grid averages) and Scope 3 (excluding non-transfers).

2 Scope 1, 2 and 3 emissions are terms used under the GHG Protocol. For a full description see: GHG Protocol: A Corporate Accounting and Reporting Standard, available at: www.ghgprotocol.org/files/ghg-protocol-revised.pdf 8 Executive Summary

Table 1: The highest scoring companies in FTSE 350 CDLI 2009 Climate change is Sector Company becoming an Financials HSBC Holdings Consumer Discretionary Carnival increasingly important Materials Rio Tinto issue for the majority Utilities Centrica of large businesses Financials Hammerson and companies are Materials BHP Billiton keen to share Utilities Northumbrian Water Group information on their Financials Aviva Financials Lloyds Banking Group carbon performance Consumer Staples Reckitt Benckiser and climatae risks and opportunities with investors and other stakeholders.

Fig. 2: Proportion of FTSE 350 at each disclosure level3 Five of the ten Utilities companies in the FTSE CDP 2009 Total population 350 (100%) 350 are in the CDLI, the highest proportion of all sectors.

Responses 236 (67%)

Report on GHG emissions in Disclose GHG emissions 194 (55%) annual corporate reporting 188 (54%)

Publicly available 158 (45%) Disclose emissions reduction targets 123 (35%) Verify emissions 111 (32%) Disclose forecasts 104 (30%)

3 The circles for response and ‘publicly available’ are based on data at time of printing. Data for the other circles are based on data for those companies scored. 9 Carbon Disclosure Project

Disclosure trends across Insights from the Conclusion the FTSE 350 performance scores pilot The depth and standard of the • The quantity of key data The CDP 2009 scoring methodology responses from the FTSE 350 to disclosed shows continued included, for the first time, separate the latest CDP questionnaire are a improvement in CDP 2009. scores for performance. This measure of shareholder and corporate All areas of disclosure increased, performance score is a pilot initiative to engagement on the issue of climate with disclosure of emission assess actions taken by companies to change. They demonstrate the many forecasts showing the greatest manage their response to, and reduce positive steps that have been taken by year-on-year improvement; their contribution to, climate change. UK listed companies over the past The performance score system is year. The strong growth in quality and • Sector-specific risks and integrated throughout the CDP 2009 quantity of disclosure also reflects the opportunities in relation to climate questionnaire. The exercise reflects advanced stage of climate change change were identified by most the desire of investors to move to a regulation and shareholder awareness companies. As might be expected, system that gives greater weight to in Europe. Regulatory regimes such two carbon-intensive sectors performance (cf. simple disclosure) over as the European Union Emissions (Utilities and Energy) perceive time. Initial findings for this year include: Trading Scheme (EU ETS) and the UK’s the greatest exposure to regulatory Carbon Reduction Commitment (CRC) risk. The sectors who consider • Generally, performance scores make climate change an increasingly themselves most exposed to reflect disclosure scores important issue for the majority of physical risk are Telecommunications although causality is difficult large businesses and companies are and Materials; to establish. Overall the data keen to share information on their suggested a company that carbon performance and climate risks • The Energy and Industrials achieved a high score for disclosure and opportunities with investors and sectors scored lowest for is also likely to have a high score other stakeholders. disclosure on risks and for performance. Of the top 10 opportunities. This is surprising performance scoring companies, Over the coming months, policymakers considering that carbon, either nine also feature in the CDLI; and negotiators from around the world directly or indirectly, is likely to be will be working hard, trying to agree financially material to the nature of • The Utilities sector leads the a new global deal on climate change. these businesses; FTSE 350, achieving the highest The outcome from these efforts will average performance score be significant for FTSE 350 listed • Emissions were disclosed by overall, with Energy the lowest; companies and it is therefore essential most companies across all and that the distinct voices of business sectors in relation to Scopes 1 and investors are heard clearly in and 2. Where all sectors performed • Utilities and Energy sectors are these negotiations. CDP 2009 has less well was disclosure around strong performers in engaging demonstrated that the FTSE 350 is energy use and disclosure of Scope with policymakers in regular stepping up to this challenge, however 3 emissions. Sectors tend to report dialogue at a global and national there is a long way to go in order to best on the areas of Scope 3 level. This reflects a willingness in meet the UK government’s carbon emissions where they have most these carbon-intensive sectors to reduction targets. responsibility and control; and devote resource to an area where there is considerable value at risk. • Governance of climate change at board-level has remained at a similar Incorporating performance assessment level to CDP 2008. Utilities had the into CDP 2009 has been a positive highest proportion of companies step; it has provided distinction with designated board-level between observing and rewarding responsibility for climate change. good reporting versus positive action This sector also had the highest to mitigate climate change. It is likely disclosure scores, demonstrating a that a performance score component potential link between high level will be integrated into the CDLI league engagement and the provision of table in the near future. good quality information.

10 Contents

CDP Signatories 2009 2 Contents Foreword to the 2009 6 CarbonDisclosure Project FTSE 350 report Hilary Benn, Secretary of State for Department of Environment, Food & Rural Affairs (Defra) Executive Summary 7 1 Overview of CDP 12 2 The FTSE 350 Carbon 16 Disclosure Leadership Index 2009 3 An overview of 19 the FTSE 350 CCS: Delivering the 24 potential of Carbon Capture and Storage Richard Gledhill, PwC Partner, Sustainability & Climate Change 4 CDP performance 25 scores – pilot exercise 2009 Moving to a low-carbon 29 economy: Improving standards in UK emissions reporting Dr Neil Bentley, Confederation of British Industry 5 Industry overview 30 7 Appendix 1 35 Summary table of company response status, scores and emissions 8 Appendix 2 46 Glossary of terms

11 1 Overview of CDP

The turmoil in the financial markets This year has seen considerable CDP now works with more than 55 and the global economy over the last growth in responses from emerging organisations including Dell, Unilever, year has highlighted the importance economies such as China, South Africa Wal-Mart Stores and departments of of effective disclosure and high-quality and Korea, and CDP expanded in the British Government to measure risk management. The financial crisis Russia in 2009 where major companies and assess climate change risk and of 2008 suggests we need to better such as Gazprom and Novatek opportunity through the supply chain. understand systemic risks that can reported. CDP’s reach continues to More than 800 companies report their cause significant de-stabilising impacts grow with the launch of the first CDP climate change strategies through the in the global economy. Climate change Europe report, covering the largest 300 CDP system to their customers and as has the potential to cause disruption in European listed companies, as well as a result we have seen a significant the form of unforeseen, high-impact expansion into countries within Central increase in the use of CDP data in events (such as extreme weather) as and Eastern Europe. We have also procurement operations. Now well as a longer term re assignment opened new offices in Germany and procurement professionals can of value across countries, industries Brazil, both key economies in the fight understand how their supply chains and corporations. against climate change. may be impacted and as a result begin to future-proof their procurement The Intergovernmental Panel on While the quantity and quality of data systems against climate change. Climate Change (IPCC) predicts that available has increased significantly, ‘future climate impacts show that the so has the use of the data, which is The process of measuring emissions is consequences could vary from acting as a catalyst for changing central to emissions management and disruptive to catastrophic’.4 So it is vital business behavior. CDP data is reduction. As regulatory frameworks that policymakers, companies and increasingly being integrated into develop to mandate emission investors have a full understanding of mainstream financial analysis, is reductions, CDP’s role will expand. We the associated risks and opportunities. available through Bloomberg will continue to work with corporations, According to HSBC research,5 Professional Services, and used to policymakers and information users to governments around the world have provide sector based analysis to CDP produce practical and robust results allocated US$430 billion in fiscal signatory members. A recent report that complement the development of stimulus to key climate change themes. produced by Mercer supports this view. mandatory reporting rules. Those providing the low carbon solutions are very well positioned to Some CDP signatories, such as In order to continue to provide the benefit, while those who ignore the CalSTRS are going a step further, global hub for carbon reporting, CDP risks gamble on being left behind. using shareholder resolutions to is currently undergoing a significant encourage companies to report systems upgrade, designed to By convening the collective power of through CDP and implement climate improve data comparability, facilitate the investment community, represented change management strategies. We benchmarking services and ultimately in 2009 by more than 475 investors, are also working with the Principles deliver data that is appropriate for with US$55 trillion in assets under of Responsible Investment (PRI) to investment analysis and regulatory management, CDP motivates more drive awareness and improve climate submissions. In countries like the US than 1800 companies globally to report change reporting. CDP has recently and UK, where mandatory carbon their climate change strategies and entered a new partnership with reporting is on the horizon, CDP’s greenhouse gas emissions. This global financial information services company systems will help companies prepare for system provides the market, investors, Markit to build a suite of indices based such requirements and will eventually policymakers and procurement on the Carbon Disclosure Leadership integrate with existing national registries directors with a clear understanding of Index, which will be licensed to to enable corporations to disclose more how companies are positioned as we exchange-traded fund (ETF) and detailed and standardised data. Climate move towards a low carbon economy structured product providers. change is a global problem, which and ensures corporations provide full requires a global solution and by transparency on climate change. bridging the gaps between national governments and international businesses across the globe, CDP will help to connect the national and international climate change ecosystem. 4 http://unfccc.int/essential_background/feeling_the_heat/ items/2905.php 5 HSBC Global Research: A Climate for Recovery The colour of stimulus goes green.

12 Overview of CDP

Table 2: Key trends snapshot6 This table outlines some of the key findings from CDP 2009 by geography and industry data-set.7 8

Sample: geography/ number of companies % of responders seeing physical % of responders opportunities % of responders with Board level with Board % of responders for climate change responsibility % of sample answering CDP 2009 % of sample answering CDP6 (2008) seeing % of responders risks regulatory seeing regulatory % of responders opportunities seeing physical risk % of responders % of responders disclosing % of responders Scope 1 emissions disclosing % of responders Scope 2 emissions externally% of responders verifying emissions disclosures engaged/considering % of responders participation in emissions trading with an emissions % of responders plan reduction reduction/energy engaging with policy % of responders makers on climate change Asia-ex JICK 1009 31 [35] 76 55 76 66 55 66 69 31 17 59 62 Australia 200 52 48 80 79 81 82 56 81 83 46 50 67 73 Brazil 80 76 [83] 49 61 73 73 53 61 55 22 25 61 49 Canada 200 49 55 70 57 68 56 46 81 76 27 34 49 61 Central & Eastern Europe 100 8 - 75 50 50 75 25 75 25 75 50 100 50 China 100 1055667786744222222116744 Europe 300 82 - 85 80 90 75 63 91 85 77 58 89 79 France 120 58 63 77 69 84 66 61 79 77 63 47 81 66 Germany 200 51 55 65 58 70 44 47 63 57 45 33 63 55 Global 500 81 77 80 78 84 78 63 85 80 63 54 80 74 Global Electric Utility 250 49 52 71 79 84 75 62 81 50 61 57 60 77 Global Transport 100 67 58 84 81 84 79 50 79 68 50 43 72 74 India 200 18 19 52 14 66 62 48 48 48 17 17 55 38 Ireland 40 33 - 71 71 71 64 43 71 50 50 43 57 43 Italy 60 35 [46] 52 67 86 67 48 81 62 71 33 67 57 Japan 500 37 [72] 85 87 83 80 64 77 72 33 90 49 49 Korea 100 50 [32] 61 67 76 69 57 55 55 33 35 63 55 Latin America 50 50 [52] 58 79 79 58 47 79 68 37 26 47 58 Netherlands 50 62 52 97 74 90 65 61 90 90 58 42 81 71 New Zealand 50 52 50 65 69 77 69 65 58 54 35 27 58 54 Nordic 200 65 [58] 77 76 81 63 54 83 77 46 33 78 59 Portugal 20 38 - 75 88 75 88 63 100 88 88 25 63 75 Russia 50 13 - 33 0 33 33 33 33 33 0 33 33 33 South Africa 100 68 58 86 73 86 89 68 83 86 38 33 68 65 Spain 85 41 [71] 80 66 77 63 54 91 83 86 34 80 74 Switzerland 100 56 57 74 44 72 48 48 72 67 35 19 65 43 UK FTSE 100 95 90 83 89 91 83 66 98 95 73 77 88 79 UK FTSE 250 57 58 79 78 76 72 53 81 80 36 43 61 49 US S&P 500 66 64 68 70 77 70 52 77 74 41 31 65 61

6 The numbers in this table are based on the total respondents at 10th July 2009. They may therefore vary from numbers in the rest of the report which are based on the number of companies who responded on time (e.g. 30th June for FTSE 350). 7 In some cases, the number of responses analysed is slightly less than the number answering CDP 2009 due to takeovers, mergers and acquisitions. 8 Percentages in square brackets reflect a different sized sample in 2008, e.g.: in 2008 we wrote to 75 companies in Brazil, not 80; and in Japan we wrote to 150 companies in 2008, not 500. A dash (-) shows that sample was not in CDP6 (2008). 9 Asia excluding Japan, India, China and Korea.

13 Carbon Disclosure Project

Highlights in carbon system beginning in 2012. The bill Progress on reporting regulation and outlook will pass through various Senate standards for Copenhagen Committees where amendments will be debated, before being put to a vote; While CDP has set the tone on matters 2009 has witnessed significant most likely in October. of disclosure over the years and, for the progress in the global approach first time this year, is now widening its In Australia, further work has to climate change. The Obama approach to encompass performance, progressed on the detail of the Carbon administration has introduced a new there are other valuable and Pollution Reduction Scheme (CPRS) era in climate change policy in the US complementary initiatives underway despite political challenges over and, as a result, a global deal in to address the clear requirement for possible competitive impacts in the Copenhagen this December appears the creation of a global carbon face of the economic downturn. The more tangible. China, so integral to the measurement and reporting system. Scheme, which would cover around success of Copenhagen, is set to meet 75% of total Australian emissions, is While the financial accounting system ambitious renewable energy and due to face a key vote later this year. has taken several hundred years to energy efficiency targets and hosts develop, carbon accounting is in its some of the world’s largest renewable Given the multinational nature of many infancy. In order to achieve a coherent energy companies. Brazil entered the companies, the evolution of these global system CDP is leading the work new year with a new National Plan on policies is likely to have significant of the Climate Disclosure Standards Climate Change and national implications on strategic direction and Board (CDSB), working with Deloitte, governments in industrialised countries operations and many of the world’s Ernst & Young, KPMG and including Japan and Australia are largest companies want to seize early PricewaterhouseCoopers to introducing new legislation to reduce mover advantage. develop robust accounting standards emissions. Of course, the role of government is to enable carbon reporting through Whilst the July G8 meeting agreed to crucial in providing the regulatory annual financial reports. CDP and prevent global temperatures rising frameworks. But investors and CDSB will also work with the World beyond 2º Celsius (3º-4º Fahrenheit) businesses will also play an essential Economic Forum to advise the G20 against pre-industrial levels, and role by driving capital flows towards the group of nations on climate change agreed on aims to cut greenhouse gas technologies which will allow economies accounting in 2010. emissions by between 50 and 80% by to flourish and innovation to thrive as we The CDP process demonstrates that mid-century they disappointed many transition to a low carbon economy. corporations can lead the way in taking by ducking the issue of medium term action that can be Measured, Reported targets. Although the multilateral Already these same investors and & Verified (MRV). It also shows how architecture still needs work, there is businesses are being directly affected international companies can reduce much to report on at a regional level. by climate change. Many companies report to CDP the material impacts of their emissions across the entirety of In Europe, the Energy and Climate climate change on their operations, their operations on a global basis, even Change package was approved in through increased flooding, water when subject to a range of different December 2008 which sets out the shortage, spread of disease and regulatory requirements. As more and policy framework and accompanying changing local weather patterns. more countries introduce climate measures to reduce emissions through Within the public sector, cities reporting change regulation, the CDP system the continuation (and expansion) of the through CDP also explain how they supports companies by bridging the EU Emissions Trading Scheme (EU are planning to adapt to changes in gap between international business ETS); targets for non-ETS sectors and weather patterns such as extreme heat and national reporting requirements new targets for the promotion of and extreme precipitation. and helps reduce the reporting burden renewable energy. on companies. Investors, policymakers, procurement In the US, the Obama administration directors and other stakeholders need The CDP Global Forum is part of the moved early to set out its ambitions to build up the necessary comparable inaugural Climate Week NYC, when around climate change mitigation: datasets in order to monitor and business leaders, heads of state and “We will harness the sun and the analyse changes; both in terms of the the world’s major investors congregate winds and the soil to fuel our cars response to mitigation measures (such in New York to prepare for negotiations and run our factories.”10 as carbon regulation) and adaptation at COP15. An agreement there will be policies and programmes. Integral to a vital step towards success, but it is The Waxman-Markey bill was finally put the success of the deal in Copenhagen just as important to look beyond before the House of Representatives in will be the availability of this accurate Copenhagen and to build the global June and passed by a narrow margin. reported data: if businesses don’t systems required to combat dangerous The proposed legislation would commit measure current emissions now, it will climate change. CDP remains focused the US to reduce greenhouse gas be impossible for them to manage and on and dedicated to this work and emissions by 17% below 2005 levels reduce them in the future. This is where thanks all of the organisations that by 2020 through a cap-and-trade CDP’s role is crucial. work with us to help realise this goal.

10 Obama inauguration speech, January 21st, 2009.

14 Overview of CDP

Layout of the printed report FTSE 350 printed report: & online PDF documents • The CDLI Investors and businesses will also For 2009 the layout of this CDP report • Overview of the FTSE 350 has been revised to deliver more play an essential role directly and concisely, the most • A geographical overview by driving capital relevant information to the right flows towards the audience. The printed report has • Analysis of the performance scores been reduced in length to provide an pilot exercise technologies which will accessible summary of the results of • An industry overview allow economies to the 2009 questionnaire, as well as to flourish and innovation reduce paper consumption. • Table of companies, scores and disclosed emissions – arranged to thrive as we To give greater consistency and alphabetically transition to a low transparency to the industry sector carbon economy. groupings for 2009 the reports follow Additional sections in online the Global Industry Classification PDF version (www.cdproject.net): Standard (GICS) and its 10 top-level industry sectors. For each of the 10 Industry reports covering the Global sectors a focussed industry report 500, S&P 500 and FTSE 350 has been produced and these are populations. available online in PDF format at • Consumer Discretionary – including www.cdproject.net. These industry automotive and retail reports covering the Global 500 data also include commentary and analysis • Consumer Staples – including food of the S&P 500 and FTSE 350 and beverage populations. This is to provide the • Energy – including oil and gas reader with a greater level of detail and (upstream) insight. The location of each area of analysis is listed below: • Financials – including banks, insurers and real estate • Health Care – including pharmaceuticals and health care providers • Industrials – including aerospace and defence, manufacturing and construction • Information Technology • Materials – including mining, metals, forestry and chemicals • Telecommunications • Utilities – including electricity, water and gas (downstream) CDP 2009 questionnaire CDP 2009 International Partner Information

15 The FTSE 350 Carbon Disclosure Leadership 2 Index 2009

All companies in the FTSE 350 that The relevance and meaning of the Eligibility for inclusion in the CDLI responded on time to CDP in 2009 CDLI can be summarised as follows: in 2009 depended on the following have been scored on the quality of conditions being satisfied: their disclosure using a standardised, • It is based entirely on the disclosure transparent methodology; see information provided in the • The company must score in the www.cdproject.net. The Carbon company’s CDP response; highest 10% of companies overall (across all industries); Disclosure Leadership Index (CDLI) • It suggests good internal data includes the companies with the management and understanding of • The response must be publicly highest scores and provides a valuable the issues climate change presents available; and perspective on the range and standard to the company’s business; of responses to CDP’s questionnaire. • The response must have been In contrast to CDP 2008, this year’s • It does not consider other submitted using CDP’s Online CDLI makes no distinction between efforts undertaken by companies Response System. companies in carbon-intensive or non- to provide carbon or wider carbon-intensive sectors. sustainability disclosure, such as The single table, combining those corporate responsibility reporting, industries previously split and defined This year’s CDLI includes the top scoring environmental statements in annual as carbon-intensive and non-carbon- 12 10% of the FTSE 350: 38 companies reports, or through meetings and intensive, follows CDP’s transition to in total (the top 35 companies are engagement with stakeholders a ‘parity of sectors’ approach for 2009. included, with four companies tied at and policymakers; and The rationale behind the transition is 35th place). In order to aid comparison that, as the wide-ranging implications between companies, the CDLI table • It is not a complete metric of a of climate change become clearer also includes information on the three company’s performance in relation for companies and all sectors develop emission Scopes and carbon intensity to climate change management, a response, there is a less clear (relative to $m revenue) to provide a as it does not currently make any distinction between disclosure fuller picture of the emissions profile judgement over absolute levels expectations of companies in different of each of the CDLI companies. of emissions, emission reduction sectors. Hence, during CDP 2009, achievements, or carbon intensity. questions were scored on the same basis for all companies and all sectors. An introduction to this year’s CDLI Furthermore, this year’s scoring methodology took into account Combined CDLI table for 2009 that some questions apply to all – what this means and why it companies, whereas the applicability has changed of other questions depends on the responding company’s individual The CDLI continues to be based on business circumstances. The CDLI disclosure and companies are ranked scoring methodology should not by their disclosure score alone. penalise companies who are unable Although a section on performance to respond to a question if it is not 11 scores was included in this year’s relevant to their business. CDLI methodology, it was not taken into account in compiling the CDLI for this year. However, performance scores are likely to become integrated into CDLI scoring in the near future.

11 The performance score is a CDP pilot initiative to assess actions taken by companies to manage their response to, and reduce their contribution to, climate change. This performance score is separate and distinct from the disclosure score and has no current impact on the CDLI. See the Performance chapter for a complete discussion of this pilot. 12 CDP 2008 distinguished between disclosure expectations of companies in different sectors, in particular between those classified as carbon-intensive and non-carbon-intensive.

16 The FTSE 350 Carbon Disclosure Leadership Index 2009

The transition to parity of sectors • Five of the ten Utilities companies in CDP 2009 means that some in the FTSE 350 are in the CDLI, We anticipate that we companies in non-carbon-intensive the highest proportion of all sectors. sectors may have received a lower This could be explained by the fact will be able to continue overall score (in absolute terms) than that the industry is relatively mature using our knowledge they did in CDP 2008, notwithstanding in terms of carbon regulation. and skills in emissions that the standard of their response may trading to better have improved or remained the same. The analysis of responses and This is because the total available CDLI scores in 2009 suggests that the package the fuel score against which the companies main reasons for significant changes supply requirements in non-carbon-intensive sectors have to the CDLI constituents compared to last year can be attributed to: of our customers to been assessed in CDP 2009 is greater create additional value, than the total available score that was • The CDLI having a smaller total particularly as mandatory available for ‘comprehensive’ questions number of companies in 2009 in CDP 2008. (38 compared to 4115 in 2008); emissions trading commences in Australia, However, it is important to note that • The CDP 2009 methodology although absolute scores may differ, rewarding companies more for and possibly in the US the transition should have little affect providing specific information that and other countries. on companies’ relative performance answers the question and informs within their respective sectors. Those investors, rather than for a high BHP Billiton CDLI companies classified as non- level of general detail; carbon-intensive in 2008, which also feature in this year’s CDLI, have seen • A few responses indicate that an average score decrease of some companies have reduced 16%. For the responding FTSE 350 resourcing and funding of carbon Carbon mitigation population overall, the sectors classed reporting teams as a result of the will produce new as non-carbon-intensive in 200813 and economic downturn; opportunities in the those equivalent sectors in 200914 have seen an average fall in scores of 17%. • Non-carbon-intensive company renewable energy and scores having reduced as a result low-carbon sectors Summary observations on the of the expectation that they should ranging from traditional constituents of the CDLI answer all questions rather than just the ‘minimum standard’ questions project insurance to • Nine of the ten industry sectors as in 2008; climate change specific are represented in the CDLI, with only Telecommunications being • The CDP 2009 questionnaire products such as absent this year, and five sectors asking for greater detail in a number carbon credit delivery feature in the top ten highest of areas; and guarantees. HSBC’s scoring companies. This shows that work to develop a there are clear and, in most cases, • The CDP 2009 methodology consistent disclosure leaders being more tailored and flexible detailed understanding across most areas of business; to the circumstances of different of the physical risks of businesses and companies • The Financials and Consumer receiving recognition on this basis. climate change will help Discretionary sectors have the most put the bank in a strong companies (24% (nine) and 18% Regulatory, physical and commercial position of knowledge. (seven) respectively) in the CDLI. drivers are key factors in response These sectors also constitute the levels, CDLI scores and high first and third largest sectors in the ‘performance’ scores in CDP. How HSBC FTSE 350 population. Industrials, these factors are reflected in responses the second largest sector of the and how they influence scores will be FTSE 350, constituting 19% (66 investigated in the following chapters. companies), makes up only 11% The report starts with an overview of (four companies) of the CDLI; and the FTSE 350 as a whole, followed by a further investigation into perspectives at industry level.

13 Non-carbon-intensive sectors in CDP 2008: Financial Services; Hospitality, Leisure and Business Services; Retail & Consumer; and Technology, Media and Telecommunications. 15 The criteria for the CDLI in 2009 of the top 10% 14 Equivalent non-carbon-intensive sectors in CDP 2009: (35 companies) has changed from last year’s criteria of Consumer Staples, Consumer Discretionary, Financials, the top 30 for both the carbon-intensive and non-carbon- Information Technology and Telecommunications. intensive groups.

17 Carbon Disclosure Project

Table 3: The CDLI 2009

Sector Company Score Emissions Intensity* Scope 1 Scope 2** Scope 3*** Consumer Discretionary Carnival 87 703 10,247,517 50,748 19,150 Reed Elsevier 76 16 18,559 107,653 131,703 N Brown Group 75 16 2,810 6,823 420 Wetherspoon 75 186 44,049 124,486 48,518 Berkeley Group Holdings 72 5 684 4,544 2,742 TUI Travel 71 475 6,564,026 53,472 70,597 Thomas Cook Group 69 456 3,985,071 34,289 – Consumer Staples Reckitt Benckiser 80 44 125,795 165,264 18,215,832 Unilever 76 69 1,167,662 1,618,220 110,600,000 Cadbury 72 155 385,901 450,151 2,700,000 Northern Foods 72 254 118,285 118,285 84,904 Tesco 69 105 1,877,340 3,080,130 58,744 Energy Royal Dutch Shell 75 185 75,000,000 10,000,000 691,401,000 Financials HSBC Holdings 92 7 102,933 771,506 107,445 Hammerson 84 151 6,093 55,468 91,830 Aviva 80 13 61,886 204,521 26,409 Lloyds Banking Group 80 22 97,709 357,942 25,129 Legal and General Group 78 ▲ 0 16,306 3,855 Royal Bank of Scotland Group 77 13 118,270 571,952 59,550 Barclays 74 15 27,709 579,302 71,735 Old Mutual 73 ▲ 5,822 519,431 39,202 Shaftesbury 69 18 0 1,188 1 Health Care GlaxoSmithKline 79 85 945,678 1,133,549 4,911,482 AstraZeneca 71 22 421,200 277,140 595,700 Shire 70 14 15,276 26,094 13,820 Industrials Interserve 76 20 29,649 5,972 971 Rolls-Royce 76 73 292,679 372,399 100,034,000 VT Group 75 214 24,057 70,684 83 Morgan Crucible 73 546 166,647 289,061 – Information Technology Logica 77 27 45,814 51,854 46,158 Dimension Data Holdings 74 15 12,409 55,186 23,620 Materials Rio Tinto 87 927 30,300,000 20,000,000 657,555,000 BHP Billiton 82 1,131 23,093,870 28,798,955 318,872,809 Utilities Centrica 84 520 10,871,403 232,294 23,317,006 Northumbrian Water Group 81 419 59,552 221,290 43,640 Scottish & Southern Energy 78 1,270 19,286,697 86,081 47,109 United Utilities 71 231 122,141 423,650 6,098 National Grid 69 1,066 11,939,000 243,000 5,263,000

* Disclosed Scopes 1 and 2 grid average emissions totals divided by annual US$ million revenues. Revenues based on data retrieved from Bloomberg on June 18, 2009. ** Only Scope 2 grid average data is included here. See Appendix 1 for data on Scope 2 contractual arrangements. *** The Scope 3 figure is the sum of data given in answer to questions 13.1-13.4. Information in response to 13.5 was not included in this figure. In a number of cases (marked with †), the company provided data for non-transfer emissions under 13.5. CDP advises you to look at their full response for details of these emissions. ▲ Intensity was not calculated where reported revenue was a negative value.

18 An overview of 3 the FTSE 350

The FTSE 350 response rate holds such not all were equally as affected by manage non-financial reporting firm despite challenging conditions. the crisis and subsequent economic during an economic downturn. This is particularly encouraging in a downturn. This explains why this sector This is especially likely to be the year when senior management time still makes up a large percentage of the case for the REITs16 and other is likely to have been highly focussed constituents of the FTSE 350. investment trusts which are a on the short-term business needs due significant proportion of the FTSE to challenging economic conditions. Response rate remains stable 250 population. Notwithstanding this, however, the • Two more companies responded • The Utilities sector again has past year has seen much activity at the to CDP 2009 than CDP 2008, policy level with preparatory meetings, the highest response rate, this maintaining an overall 67% response year reaching 100% (10), followed under both the UN process and other rate for the FTSE 350, although it is fora, to move forward debate on key by Consumer Staples at 86% worth noting that the response rate (19). The response rates for issues in advance of the Copenhagen for the FTSE 100 increased by 4% meeting in December 2009. Telecommunications, Consumer to 95. Given that many companies Discretionary, Utilities and Materials Who’s in the FTSE 350 have had to make tough decisions all increased, with the other six about where to save on costs sectors decreasing. in 2009? in the face of the current economic The club of the largest 350 public landscape, this slight increase in the • Seven of the top ten non-responders companies listed in the UK naturally response rate is notable and shows are not new to the FTSE 350 this changes every year as a result of M&A that climate change and the value of year, indicating that there are a few activity, changing profitability and the CDP exercise remains high on large companies that continue to structural economic conditions. This the corporate agenda; however choose not to participate in the CDP initiative. The largest non-responders year the composition of the FTSE 350 • The fall in the response rate from has remained broadly similar compared are mostly composed of Energy and the FTSE 250, a decrease of two Materials companies. to CDP 2008. As the Financials sector companies, and the continued is made up of a wide variety of financial non-response of many in that group The table below lists the ten largest institutions, less than a quarter are may reflect the greater difficulty for non-responders for 2009 by market within the Commercial Banking or smaller corporations to spend on capitalisation. Capital Markets sub sector, and as central corporate functions that

Table 4: Largest non-responders in 2009

Sector Company Consumer Staples British American Tobacco Materials Eurasian Natural Resources Information Technology Autonomy Corporation Materials Randgold Resources Materials Fresnillo Materials Kazakhmys Energy Petrofac Energy Venture Production Energy Wood Group Consumer Discretionary Carphone Warehouse

16 REITs = Real Estate Investment Trusts

19 The overall landscape of responses to Notable areas where the standard The total emissions reported to CDP CDP 2009 is summarised in the table of disclosure has increased include: 2009 have increased, following the below. As well as the absolute and continuous trend seen since CDP percentage values of companies • An improvement in the disclosure 2003. Total Scope 1 emissions have responding from the FTSE 350 of emissions data, with 55% (194) of seen a 7% increase, Scope 2 a 7% population, it shows how these have companies disclosing Scope 1 or 2 increase and Scope 3 a 12% increase changed from CDP 2008. The shading in CDP 2009 compared to 47% compared to CDP 2008. However, indicates the nature of any change (163) in CDP 2008. This reflects the increases in the total disclosed figures (increase or decrease). increasing ability of companies to most likely reflect progress on data measure and report on carbon; and capture systems and analysis rather Varying levels of disclosure • A significant increase in the number than simply because companies are As well as the increase in the of companies disclosing emissions emitting more. These improved response rates in CDP 2009, the forecasts. This may be due, in part, disclosures help provide CDP standard of information disclosed has to the question allowing companies signatories with a more comprehensive also increased markedly. This clearly to qualitatively explain their view of the carbon intensity of their increases the capability of investors to forecasting plans this year, thus portfolios. evaluate climate risks and opportunities removing some of the commercial The significant rise in Scope 3 within their investment and lending sensitivity in this area. disclosure could well be attributable to portfolios. This year-on-year continued advances in the tracking and improvement is illustrated in figure 4. Reported emissions of the FTSE 350 management of emissions in the supply chain as discussed in 2009’s Fig. 3: Total reported emissions FTSE 350 companies disclosed Scope CDP Supply Chain Report. (Scopes 1, 2 and 3) CO2 1 emissions of 390 million tonnes of Notwithstanding this improvement, billion tonnes CO2-equivalent (tCO2-e). This equates Scope 3 remains one of the lowest to 61% of total UK emissions17 which scoring areas of the questionnaire, not

3.5 shows the level of influence FTSE 350 just for the FTSE population but also companies have over the potential to the Global 500 and S&P 500. 2.87 mitigate climate change. FTSE 350 companies disclosed Scope 2 The Energy sector accounted for 1.3 billion tCO2-e or 45% of the total of 3 emissions of 130 million tonnes CO2 2.57 equivalent. Though there is duplication reported Scope 3 emissions, closely between the Scope 1 and 2 figures followed by Materials with 1.2 billion

s disclosed as one company’s Scope 1 tCO2-e, (42%). Over 99% of the Scope ion

ss is another’s Scope 2. 3 emissions disclosed by the Energy 2.5 sector are from the use and disposal of its products. Total emi

2 Table 5: Breakdown of response by industry

Sector Number Rate 1.13 1.5 Consumer Discretionary 61 72% Consumer Staples 22 86% Energy 21 57% Financials 109 63% 1 Health Care 11 55% Industrials 66 71% Information Technology 21 43% 0.1 0.5 Materials 23 65% 0.12 0.13 Telecommunications 6 83% 0.47 0.37 0.39 Utilities 10 100% FTSE 350 350 67% 0 CDP2007 CDP2008 CDP2009 Green Increase from 2008 Red Decrease from 2008 ■ Scope 1 ■ Scope 2 ■ Scope 3

17 640 million tonnes at 2007, UK Greenhouse Gas Inventory. Note: the Scope 1 emissions disclosed occur both in and outside the UK.

20 An overview of the FTSE 350

Fig. 4: Proportion of FTSE 350 at each disclosure level – year-on-year18 FTSE 350 companies disclosed Scope 1 CDP 2009 Total population 350 (100%) emissions of 390 million tonnes of CO2- equivalent (tCO2-e). This equates to 61% of Responses 236 (67%) total UK emissions. Report on GHG emissions in Disclose GHG emissions 194 (55%) annual corporate reporting 188 (54%)

Publicly available 158 (45%) Disclose emissions Staff whose role reduction targets 123 (35%) includes direct Verify emissions 111 (32%) Disclose forecasts 104 (30%) management of activities linked to Climate Change (e.g. operation of buildings) and their line managers all have relevant KPIs built into their pay bonus structure.

Land Securities

CDP 2008 Total population 350 (100%)

Responses 234 (67%)

Report on GHG emissions in annual corporate reporting 183 (52%) Disclose GHG emissions 163 (47%) Publicly available 144 (41%)

Disclose emissions Verify emissions 106 (30%) reduction targets 93 (27%)

Disclose forecasts 26 (7%)

18 The circles for response and ‘publicly available’ are based on data at time of printing. Data for the other circles are based on data for those companies scored. 21 Carbon Disclosure Project

Fig. 5: Proportion of FTSE 350 and Global 500 at each disclosure level19 Logica has developed SIRA, a software CDP 2009 FTSE 350 application for reporting Total population 350 (100%) energy consumption, travel, water usage and calculating relevant aspects into carbon Responses 236 (67%) emissions, including Report on GHG emissions in calculation of UK CRC Disclose GHG emissions 194 (55%) annual corporate reporting 188 (54%) emissions to help Publicly available 158 (45%) Disclose emissions organisations calculate reduction targets 123 (35%) Verify emissions 111 (32%) the amount of carbon Disclose forecasts 104 (30%) allowances they will have to procure.

Logica

CDP 2009 Global 500 Total population 500 (100%)

Responses 409 (82%) Report on GHG emissions in annual corporate reporting 349 (70%) Publicly available 345 (69%)

Disclose GHG emissions 339 (68%) Disclose emissions reduction targets 257 (51%) Verify emissions 247 (49%) Disclose forecasts 224 (45%)

19 The circles for response and ‘publicly available’ are based on data at time of printing. Data for the other circles are based on data for those companies scored. 22 An overview of the FTSE 350

Comparison of FTSE 350 and the “Centrica has been active in the market Global 500 for project credits for some time as Bahrain World Trade we see value in having a diversity of • On each disclosure level the contract types and sources to cover Centre – Designed by proportion of companies making a number of risks...Centrica is involved Atkins it is the first disclosure is higher in the Global in both the CDM and JI project commercial building in 500 population. markets. All the credits that we obtain the world to incorporate • The largest difference between the for use within the EU ETS and for large-scale turbines to two indices is in the proportion of offsetting purposes are from verified companies that make information sources under these two initiatives.” generate power. The publicly available, 45% of the FTSE Centrica turbines will provide up 350 do which is considerably less • Goods and services which avoid to 15% of power for than the 69% achieved by the emissions for third parties (Question the building. Global 500 companies. In the 14) – This question received 64 disclosure of GHG emissions the responses, many describing performance of the two indices was innovative action taken by a diverse Atkins closest; the FTSE 350 lagged range of companies, for example: behind the Global 500 by 13%. “We do reward our customers for good Responses to the new questions environmental behaviour such as of 2009 reduction in premiums for having The carbon reporting agenda energy efficient homes (Aviva France), continues to advance at a remarkable reduction in premiums for hybrid cars pace. Recognition is due, in part, to (Aviva Canada and Delta Lloyd), those leading CDP responders who Offsetting of emissions created by help to drive the standard forward by driving as part of the norm for motor raising the bar on disclosure each year. insurance policy (Delta Lloyd), free The CDP questionnaire is evaluated energy survey carried out by Bureau annually following feedback from the Veritas as part of our property owners CDP signatories and responding insurance (UK), Insurance premiums companies. Key new question areas related to the number of miles driven added during CDP 2009 included: (Aviva Canada, France and Turkey).” Aviva • Involvement in project-based carbon credits (Question 22) – 34 “We have also been very active in companies in the FTSE 350 stated tackling fuel poverty in the UK and that they purchased credits and 13 have committed to help one million have been involved in their homes with energy efficiency measures origination; and through our Affordable Warmth Programme....To date, more than 30,000 households have benefited from energy efficiency measures. This has generated £50 million ($77 million) in lifetime energy savings, and achieved an annual carbon saving of more than 8,100 tonnes per year. ” National Grid

23 Carbon Disclosure Project

CCS: Delivering the potential of Carbon Capture and Storage By Richard Gledhill, PwC Partner, Sustainability & Climate Change

Background CCS is important as it can address The race for demonstration projects high volume emissions from thermal Energy demand is rising relentlessly. power plants, refineries and energy The critical challenge for CCS, It is closely linked to rising living intensive industries such as steel as with any innovative energy standards, but it is also the most foundries and cement kilns. CCS is technology, is cost. The incremental significant contributor to climate a proven technology at small scale; cost of installing CCS at a modern, change, representing over two thirds there are many pilot projects that commercial scale, power station is of total greenhouse gas emissions. have been operating for a few years. approximately $1-2bn. The ‘first of At the G8 summit in July 2009, the a kind’ costs and risks cannot be leaders of the major economies It is now required to demonstrate borne by private companies alone – declared that the the global average the technology at a larger, significant financial support temperature change ought not to commercial scale before CCS can from governments is required. exceed two degrees Celsius. Rapid be effectively rolled out. New Evaluating value for money is and fundamental change in our partnerships – between governments essential when providing energy infrastructure is required to and between companies – government funding, whether achieve this – in effect the total are needed to achieve this. through public private partnerships decarbonisation of power generation or grants. Several countries have by 2050. “BP and Rio Tinto announced launched demonstration projects the formation of a new jointly of CCS technologies and these are The development and large scale owned company, Hydrogen Energy aiming for commercial scale CCS deployment of clean power International Limited, which will projects by 2015. generation is, therefore, an essential develop decarbonised energy part of the response to climate projects around the world.” In 2007, the UK Government change. This will include making BP launched a competition to build a significant energy efficiency gains, commercial scale CCS coal power Main CCS technologies developing large-scale renewable and plant capturing CO2 from 300MW nuclear energy, and rolling out Carbon CCS encompasses three stages: of the power station’s capacity. It is Capture and Storage (CCS). In its (i) the capture of CO2, (ii) its transport currently considering the introduction World Energy Outlook 2008, the IEA and (iii) its long term storage. Capture of a financial incentive mechanism, estimates that 160GW of CCS power technologies are split into three funded by electricity suppliers, to generation capacity will be required categories commonly referred to as support up to four CCS commercial- by 2030 to achieve the 550ppm ‘pre-combustion’ (generating CO2 scale demonstration projects. There stabilisation goal, with more than and hydrogen from the hydrocarbon is the also the potential for CCS to double that for the more ambitious fuel), ‘post-combustion’ (using sorbent be required for all new coal or gas 450ppm scenario. Critics of CCS chemicals to separate the CO2 fired power generation: argue that it perpetuates the use of from flue gases at power plants), unsustainable fossil fuels, and that “Certain new technologies may be and ‘oxyfuel’ (burning the fuel in made mandatory for our existing the investment should focus on pure oxygen which increases the renewables. Proponents state that generation facilities, or new ones concentration of CO2 in flue gas which which we may build, i.e. Carbon fossil fuels – notably coal – are the is subsequently easier to capture). dominant source of energy Capture and Storage technology.” (particularly in India and China), and The CO2 gas is then compressed for Scottish & Southern Energy will remain so for several decades. transport by pipeline and/or by ships. Although the costs may be high, Hence, only CCS is able to address Piping CO2 over long distance is not CCS could well become a multi these sources on a large scale. a novel technology – there are several billion dollar industry within the next thousand kilometres of CO2 pipeline decade – an opportunity recognised “Despite its costs, CCS is one of the in the US – but the regulatory regime critical technologies needed to buy by a number of companies. and public acceptance needs to be The rapid emergence of this low time in the race to prevent emissions addressed in other regions. With from rising too far, too fast.” carbon industry will be essential regard to the final storage, there to address emissions growth. Royal Dutch Shell are two principal types of storage solutions: saline aquifers, i.e. a “Regulatory incentives porous rock formation that contains supporting renewable electricity undrinkable water; and depleted generation, carbon capture and oil or gas reservoirs. Once injected, storage, renewable heat and energy the CO2 is trapped, dissolved or efficiency present business mineralised inside the formation. development opportunities.” National Grid

24 CDP performance scores – pilot 4 exercise 2009

Introduction to the Instead, performance scores for all performance scoring system respondents will be aggregated and Our overarching discussed on an industry basis. The CDP 2009 scoring methodology reduction target is included, for the first time, separate Performance-related questions are 20% reduction of GHG scores for performance. This integrated throughout the emissions per unit questionnaire. Each section of the performance score is a pilot initiative (defined as a consumer to assess the impact of climate change questionnaire provides respondents actions/activities and is distinct from with an opportunity to demonstrate dose) across the the CDP questionnaire’s Section 3 good performance – action to mitigate lifecycle of our products (which queries respondents on how climate change – in a variety of ways. by 2020. This requires they track their performance to stated Strong performers take considered goals and objectives). Whereas all parts of our business and effective action to manage to work towards historically scores have reflected the risks and be agile around new standard of disclosure, performance opportunities. reducing our carbon scores assess actions taken by impact, not just our companies to respond to, and reduce Performance points were awarded their contribution to, climate change. where respondents demonstrated that manufacturing sites. This helps provide investors insight into they had taken action to manage their the extent to which companies are perceived risks (physical, regulatory Reckitt Benckiser preparing to transition to, and compete or other) or maximise their perceived in, a low carbon economy. opportunities. Examples include designing business continuity plans, Certain questions in the CDP implementing regulation and policy questionnaire were identified as being monitoring teams, and introducing new eligible for performance points. For products or services to capitalise on example, where a company reports changes in consumer demand as a that it has a GHG emissions and/or consequence of climate change. energy reduction plan in place,20 performance points were awarded to Climate change presents a variety acknowledge this as an indication of of risks – regulatory, physical and good performance in the management commercial – which vary in their of emissions reductions – rather than probability and potential impact on a one point awarded for disclosure company. A company’s preparation for whether the answer was that they possible climate change risks will help have a plan or do not. to minimise the impact on operations if and when they occur. For example, It is important to note that, because a manufacturing site hit by a flood, performance scores are being piloted where no contingency is in place, for the first time this year, they have not could cause a halt in productivity and impacted upon the CDLI scoring. loss of revenue. With this type of Furthermore, individual respondent information CDP signatories are able performance scores will not be made to analyse the CDP responses and public in the CDP 2009 reports. benchmark companies within industry sectors on their level of climate change management. This can support better decision making on their asset or lending portfolios, and inform their engagement strategies.

20 This refers to question 23.1 25 Carbon Disclosure Project

Emission reduction targets vary The Materials and Utilities sectors By December 2020, greatly between sectors are strong in this regard. These sectors are among the most carbon-intensive BT Group will reduce Performance points were awarded and have considerable value at risk. its CO2-e emissions per where companies had reported Consequently, they are prepared to unit of contribution to emissions reductions targets. These devote considerable resources to points were awarded irrespective of the advocacy efforts around the design GDP by 80% against appropriateness or ambition of the target. 1996/7 levels. of policy and often maintain good Only 52% (123) of responding internal capacity to undertake their companies gained the performance own policy analysis. BT Group points available for having emission The Consumer Staples sector also reduction targets. However, there are scored highly in this area with 79% large differences between sectors as of companies participating in public the Utilities, Health Care, policy discussion. In 2008, assets directly Telecommunications, Consumer under the control Staples and Materials all scored above Carbon abatement activities 79% whilst the Energy, Financials, are delivering results of BG Group emitted Industrials and Information Technology 8.8 million tonnes of sectors scored less than 50%. Of the responding companies, 32% (75) confirmed that they had achieved CO2-e, a decrease of Stronger performers engage in positive results in emissions reduction 0.5 million tonnes (6%) regular dialogue with policymakers and energy saving measures from compared to 2007... to try and get the best deal from carbon abatement programmes. climate change regulation This decrease results Utilities and Energy were the from a reduced demand Performance scores were awarded strongest performing sectors in this for electricity from our where companies were clearly able to area with 67% and 50% of companies demonstrate their engagement with respectively stating that they have power stations in the policymakers to influence the design achieved reductions or savings. Energy UK and North America of policy measures around climate price fluctuations play a significant role and the effects of our change mitigation and adaptation. in these reductions, with higher prices GHG management Examples would include the provision increasing the business case for of research and data, consultation efficiency improvement measures programmes. responses and advice directly to and falling prices reducing production Governments or via industry bodies. levels. Regulatory regimes such BG Group as the EU ETS will also contribute to emissions reductions as they create a further commercial value in efficiency.

26 CDP performance scores - pilot exercise 2009

The reason for the introduction The methodology for performance of performance scores – use for scores does not currently ‘flex’ to We have achieved investors & policymakers account for a company’s area of business and situation in the same a 13.4% reduction Introduction of performance scores way as the methodology for disclosure. in our emissions in 2009 is an important step towards In addition, performance scores are between 2007 and recognising respondents’ progress only able to be awarded when the 2008 through energy in addressing climate change through underlying disclosure is provided by action, as well as scoring the the respondent. efficiency measures respondents on their disclosure and purchasing standard. The performance score aims There is no additional research, to be a useful benchmarking tool for or analysis undertaken independent renewable energy. CDP signatories to evaluate how of the company responses. There is, prepared their portfolio companies therefore, an inherent link between WPP are to remain profitable in a low performance scores and disclosure carbon economy. scores. However, this link is consistent across companies and so the focus of Following the increase in the number interest is how sectors perform relative of CDP signatories, many of whom to one another. Also, it is sensible to engage with companies to improve suggest that the more companies climate change reporting, the standard monitor and manage their impact, the of disclosure over the past seven years more they are likely to understand has increased dramatically. This is a where they can take action and the credit to those companies who have best way in which to do it – and hence participated in the CDP initiative. The ‘perform’ to a higher standard. increase also reflects greater activity by companies in mitigating climate Evolution of performance scoring change and it is the level of this effort that CDP now endeavours to measure Incorporating performance into CDP and give recognition for. Performance 2009 has been a positive step; it has scores serve to present a fuller picture provided distinction between observing to investors and policymakers of and rewarding good reporting versus corporate commitment to mitigating positive action to mitigate climate the effects of climate change. change. The exercise has highlighted that a performance score may be a Current limitations valuable additional component of report analysis and the CDLI league All companies who responded to table in the future. It would provide CDP 2009, irrespective of their guidance and incentives to industry, geography and level of respondents to take positive action emissions, were scored against the and also highlight to the CDP performance questions using one signatories where this is being done – common scoring methodology. It is i.e. risks are being managed and important, however, to make a number opportunities maximised. of caveats in this regard. The degree to which performance scoring is integrated into the CDLI score and the timeline for this is yet to be determined and stakeholders will be consulted on developments in this area.

27 Carbon Disclosure Project

Who achieved high performance Table 6: Companies achieving the highest performance scores in CDP 2009? scores in CDP 2009 – in alphabetical order Companies achieving high Sector Company performance scores in this year’s pilot exercise share a number of common Industrials Atkins traits. Generally, they: Utilities Centrica Industrials Interserve • Effectively manage carbon data and Utilities National Grid are transparent on the information – Consumer Staples Reckitt Benckiser by publicly disclosing their climate Energy Royal Dutch Shell change activities and performance Utilities Scottish & Southern Energy in an annual report; Consumer Staples Tesco • Effectively monitor and manage Consumer Staples Unilever the evolving climate change Utilities United Utilities agenda – by engaging positively with policymakers on climate change developments;

• Implement innovative ideas to Fig. 6: Analysis of performance scores versus disclosure scores – capitalise on climate change by industry sector opportunities and apply well designed solutions to manage climate change risks; 80 • Are forward-thinking and proactive in addressing climate change – 75 by having established emissions reductions plans, targets and 70

publishing forecasts; and 65 • Drive their business towards 60 core

climate change mitigation – by s

offering incentives, often financial, 55 to employees for individual management of climate 50 Performance change issues. 45 Observations on the leaders group (Table 6): 40

• Nine of the ten companies leading 35 on performance are also in the CDLI, showing there is a link 30 between disclosure and 45 50 55 60 65 70 75 performance; Disclosure score • Utilities and Consumer Staples ■ Consumer Discretionary ■ Consumer Staples ■ Energy ■ Financials ■ Health Care account for seven of the ten ■ Industrials ■ Information Technology ■ Materials ■ Telecommunications ■ Utilities companies whilst constituting only 9% of the FTSE 350. Consumer Sizes of bubbles are based on number of respondents. Staples has a high number of top The size of each ‘bubble’ is proportional to the number of relevant companies. scoring companies relative to its overall average performance score, Note: Performance scores have been normalised to 100 for comparison to disclosure scores. suggesting a number of high performing companies within this sector; and • As illustrated in Fig. 6 across the Utilities sector is a clear leader over all other industries.

28 CBI guest commentary

Moving to a low-carbon economy: Improving standards in UK emissions reporting by Dr Neil Bentley, Confederation of British Industry

Climate change represents perhaps the a business solution to implementing biggest social and economic challenge mandatory reporting in the UK. We of our time. brought together a broad group of businesses and experts on carbon The ‘business as usual’ approach reporting, including from the CDP, will not suffice. Businesses are thinking and in May this year we published more and more about the impact they our proposals on how to set up a are having on the environment. As our common approach to help shape economy moves from a high-carbon to government thinking. a low-carbon model we know we will have to closely manage the emissions The CBI believes the measurement produced from day-to-day operations and transparent reporting of corporate and investment decisions. Corporate emissions data is an important factor emissions reporting is becoming a in driving change and creating business vital tool in the UK’s transition to a advantage so it’s vital we get it right. low-carbon economy and the Carbon We need to agree on a process which Disclosure Project has helped drive this is robust, yet practical. Clearly a big shift agenda for the last nine years. Through is needed if large numbers of businesses their work emissions data is increasingly are to effectively capture emissions data used by the investment community to and publicly report them. We should not help them make a more informed underestimate the scale of the challenge decision on the risks and opportunities of getting businesses across the UK of a changing climate. to report their emissions, however the Carbon Disclosure Project has made Measuring greenhouse gas emissions is good progress in its engagement with the first step any business should take to the FTSE 350 over the last four years managing their environmental impact and the responses from those leading and can help identify where there are companies show that the business inefficiencies in the business processes, community is up to meeting it. in the building stock or the transport of goods. Emissions data can help to drive After all, the prize is great – there behaviour change amongst employees is a £3 trillion global market for low- and highlight where investment is carbon products and services. The CBI needed to cut energy use. The data will believes that those businesses which also become increasingly important seize the opportunity to adapt to a when government and businesses look low-carbon future will reap the rewards. to incorporate emission requirements Measuring, reporting and managing into their supply chain through emissions could lead to new business procurement criteria and when models, driving innovation and consumers seek environmentally changing consumer perceptions. Carbon responsible products and services. reporting is a vital means to an important end – accelerating the transition to a Companies are feeling the pressure low-carbon economy. to quantify their greenhouse gas emissions from multiple sources. That’s why in 2007, the CBI’s climate change taskforce committed to publishing proposals on a common method for companies to report these emissions. Our members could see the pressure building and wanted to play a constructive role in shaping the agenda. Under the Climate Change Act carbon Dr Neil Bentley, CBI Director reporting is likely to become mandatory of Business Environment for many companies in 2012. In our discussions with government, MPs and Download the CBI’s emissions peers, before the bill came on to the reporting proposals at statute book, the CBI pledged to deliver www.cbi.org.uk/climatechange

29 5 Industry overview

As noted in the introduction, CDP Table 7: Key themes from the CDP 2009 company responses has responded to feedback from its by industry sector signatories and other stakeholders for more industry-specific analysis Sector by choosing to present CDP 2009 Consumer Staples/ Devising an effective response to changing consumer habits findings in individual industry reports Consumer Discretionary Mixed views on the benefits of greater carbon labelling available online: www.cdproject.net. Concern around the cash costs and reputational aspects of the These cover the 10 industry groups forthcoming Carbon Reduction Commitment as defined in the Global Industry Information Technology How to capture the value from lower emissions through the Classification Standard (GICS). An use of advanced products and services overview of these findings is presented New business opportunities around climate change adaptation here with comment on the progress Telecommunications Devising new products to help consumers reduce emissions that has been made on overall levels New business opportunities around consulting services to help of disclosure and any significant clients reduce their own emissions variance observed on a sectoral basis. Implication of stricter energy efficiency targets for new products Levels of disclosure Health Care Impact of depleted biodiversity stocks on new drug development across industries How to effectively engage with employees on climate change Financials Strategies for maximising carbon value in lending and investment Table 8 provides a breakdown of the How to quantify physical risks to assets proportion of respondents that have Risks of litigation around carbon-intensive investments achieved each level of disclosure in Energy/Utilities Direct compliance costs to meet obligations under CDP 2009. The data is presented cap-and-trade programs by industry sector and illustrates Diversification into new markets with R&D and investment year-on-year trends (compared to programs to bring new energy technologies to market CDP 2008). Although overall disclosure New business units/products helping consumers reduce energy has increased, as noted previously, Materials The mining sector is particularly energy intensive and the performance at the sector level varies impact of increased energy and raw materials costs may affect significantly. their future growth potential Risk to business model of the extension of carbon regulation Investors, who are likely to have an at a global/regional level and the increasing customer focus on objective of diversifying risk across the level of ‘embedded carbon’ in final products sectors and/or countries, will value Industrials Opportunities to provide greener infrastructure and housing data that allows industry peer group projects designed with a focus on high energy efficiency and comparison and year-on-year resilience to extreme weather events (construction sector) performance to be assessed. How will changing regulation and consumer demands shape industry composition (transportation sector)

30 Industry overview

Table 8: Change in level of disclosure by sector CDP 2009 vs. CDP 2008

Sector Year Total Responded Publicly Report onDisclose Verify Disclose Disclose population available GHG GHG emissions emissions forecasts emissions emissions reduction in annual targets corporate reporting Consumer CDP 2009 61 44 72% 86% 93% 44% 58% 49% Discretionary CDP 2008 69 40 58% 80% 76% 44% 44% 13% Consumer CDP 2009 22 19 74% 89% 100% 74% 79% 68% Staples CDP 2008 19 20 59% 82% 77% 65% 65% 18% Energy CDP 2009 21 12 67% 83% 83% 58% 50% 25% CDP 2008 20 14 62% 62% 54% 54% 15% 15% Financials CDP 2009 109 69 77% 85% 85% 58% 50% 46% CDP 2008 101 77 57% 69% 61% 43% 33% 12% Health care CDP 2009 11 6 83% 100% 100% 33% 83% 67% CDP 2008 8 4 40% 100% 100% 60% 80% 20% Industrials CDP 2009 66 47 68% 89% 89% 36% 45% 45% CDP 2008 74 45 44% 91% 74% 35% 26% 7% Information CDP 2009 21 9 78% 89% 100% 33% 44% 56% Technology CDP 2008 19 7 39% 46% 62% 15% 23% 15% Materials CDP 2009 23 15 79% 93% 100% 64% 79% 50% CDP 2008 24 13 71% 93% 86% 50% 57% 0% Telecomms CDP 2009 6 5 100% 100% 100% 60% 80% 60% CDP 2008 5 5 67% 100% 100% 100% 100% 33% Utilities CDP 2009 10 10 89% 100% 89% 100% 89% 56% CDP 2008 11 9 60% 100% 60% 80% 80% 0% FTSE 350 CDP 2009 350 236 67% 80% 82% 47% 52% 44% CDP 2008 350 234 62% 78% 70% 45% 40% 11%

Notes for table: Colour Proportion of respondents The table above shows the proportion of companies achieving reaching disclosure level different levels of disclosure in CDP 2009 versus CDP 2008. Red 0% - 50% Percentage figures are calculated from ‘Responded’ column Orange 51% - 70% rather than ‘Total Population’ column, therefore % number is different to Figure 4 onion chart. Green 71% - 100%

Industry comparisons • As might be expected, two carbon- “The Carbon Reduction intensive sectors (Utilities and Commitment (CRC) will incentivise Average sector scores reflect the Energy) perceive the greatest change, even if it is reputational typical standard of responses provided exposure to regulatory risk, impact of league table position within a sector. The disclosure whereas the Financials sector rather than actual cost of carbon.” scores are grouped into three buckets: foresees minimal exposure. The United Utilities Risk and Opportunities; Reporting sectors who consider themselves of Emissions and Performance; most exposed to physical risk are • The UK Government recognised the and Governance. Telecommunications and Materials; need for increased focus on carbon management and the role reporting Risk and opportunities • The introduction of the Carbon needs to play with the commitments • Companies across all sectors Reduction Commitment (CRC) made in the Climate Change Act identify sector-specific risks and in April 2010 was identified by (2008). To meet these requirements opportunities in relation to climate many as both a risk (55%) and an Defra and DECC will jointly publish, change. Energy, Health Care and opportunity (24%). Aside from the this October, voluntary guidance on Utilities generally see more risk than financial costs, the administrative how to measure and report GHG opportunity. Conversely, Consumer obligations and reputational risk emissions. The Defra guidance is Staples, Industrials and Information aspects of this policy instrument primarily aimed at large and medium Technology see more opportunity were highlighted; sized companies but can be used than risk, with the most common by all UK organisations that wish to risk being from regulation;

31 Carbon Disclosure Project

measure and reporting their total GHG Reporting of emissions At Tesco we believe emissions. The Climate Change Act and performance requires the Government to introduce that we and our mandatory report of GHG emissions • Companies across all sectors customers can be under the Companies Act 2006, or lay performed consistently well in part of the solution to a report to Parliament explaining why relation to disclosure of Scope 1 and 2 emissions; tackling climate change. this has not happened, by April 2012. A key element of our There will be a further consultation on • In contrast, the area where all this guidance before a decision is made sectors performed poorly was strategy is to turn green to introduce mandatory reporting disclosure around energy use. consumption into mass requirements. Utilities and Materials scored consumption. With • Following the revision of the EU ETS highest as may be expected from 4,308 stores in 14 Directive, existing FTSE participants companies in energy intensive now have greater clarity over the industries where the monitoring of countries worldwide energy use would be of importance; along with our online third phase of the Scheme (2013- 2020) and the airline industry is • Disclosure of Scope 3 emissions businesses, helping making preparations for its inclusion remains the weakest area for all customers to make from 2012. sectors, and trends are difficult to greener choices is one “British Airways supports the concept discern. Sectors tend to report of the biggest impacts of carbon trading as the most most on the areas for which they we can make. environmentally effective instrument see they have most responsibility to control emissions from aviation. and control, for example the However, we have consistently Consumer Staples sector has Tesco proposed that the EU ETS should the highest proportion of disclosure initially only apply to intra-EU flights, for ‘external distribution logistics’ prior to reaching a global multilateral and ‘company supply chain’ agreement on aviation emissions. (at 58% and 42% of respondents In the last 4 years The EU decision to apply the system respectively) whereas Energy to all flights in and out of the EU will and Utilities had among the highest there have been three disclosure rates for ‘use and instances of offices distort competition in many of our markets leading to carbon leakage.” disposal of company products affected by floods, two British Airways and services’ (33% and 30% of where an office was respondents respectively); and • The Energy and Industrial sectors actually flooded and scored lowest for disclosure on • Sectors appear to be focussing one where the roads risks and opportunities. This is on managing and reducing the surprising considering that carbon, emissions which are most relevant in and out of the office and material to their operations, were closed due to either directly or indirectly, is likely to be financially material to the although given the challenge of flooding. The issues for nature of these businesses; and quantifying supply chain impacts, the business were not it is likely that many companies • The Financials sector performed do not yet have a comprehensive from direct flooding well on disclosing risks and grasp of their Scope 3 risks but were related to loss opportunities. Despite not having and opportunities. of water supply and a large direct exposure to carbon, treatment of sewage, the indirect exposure to the climate change agenda through trading, difficulty for staff investment and lending operations to commute to/from is clearly significant. work and flooding of employee’s homes.

Capita Group

32 Industry overview

Governance • Utilities and Telecommunications are the sectors most engaged with We encourage our • Most sectors performed similarly policymakers on climate change well in disclosure around public issues and scored best on suppliers to pursue reporting. This consistency of high disclosure of targets and plans. certification to ISO scores may follow the increase Surprisingly the Energy sector 140001 or similar. in the level of carbon reporting; scored ninth overall for targets We have also joined • The three sectors scoring and plans, however a much higher this year’s CDP Supply highest for accountability and proportion of companies in this incentivisation for climate change sector declined to provide this Chain Initiative, through (Utilities, Materials and Health disclosure due to it being which we will collect Care) are also the highest three considered commercially GHG data from 10 key sensitive; and overall for disclosure. This suggests suppliers as a first step that board responsibility for • Utilities and Information Technology in gaining a better climate change and incentivisation are the sectors where most often plays a role in driving the overall a board member has overall understanding of our level of disclosure performance responsibility for climate change. supply chain emissions. of companies; Rolls-Royce

Fig. 9: Score breakdown – overall FTSE versus CDLI average Board responsibility

100 for climate change and incentivisation 90 plays a role in driving

80 the overall level of disclosure performance 70 of companies. core range

S 60

50

40

30 s s s s sks Ri trading & plan s s e reporting ion ity reporting s s Opportunitie ss Data accuracy 1 & 2 reporting Target Public reporting s cope 3 reporting Emi S inten s Energy u cope reporting parameter ion s S ss ion Accountability & incentive ss Emi Emi

■ Average score ■ Average score CDLI

33 Commentary for the Carbon Disclosure Project

Table 9: Contrasting outlooks within sectors

Sector Outlook 1 Outlook 2 Industrials “We consider our company to be exposed to “We don’t know the answer to this question. physical risks. The risk process and financial Travis Perkins has not substantially changed assessment is described in the response to 1. its views in this area. We continue to face Regulatory risks. We consider our company is as yet unquantified risks: both the interruption exposed to physical risks. As Bunzl warehouses to trading and the damage to property assets and distributes goods, the biggest physical risks are caused by severe weather events associated those relating to or caused by: drought, flood, and with climate change. Both of these events are increased storm and hurricane activity. All of the occurring presently although we would expect above could cause damage to Bunzl’s warehouses that the frequency of events would increase in and potential disruption to distribution channels the future.” both from Bunzl to its customers and also from Travis Perkins Bunzl’s suppliers to Bunzl.” Bunzl Consumer “Regulatory requirements present opportunities “Regulatory requirements do not present Discretionary for my company. In the last 10 years changes to opportunities for my company. We see no building regulations have increased the thermal significant opportunities for our business from performance of new homes to the extent that a current or anticipated requirements of climate new home today is some 40% more efficient than change...we have seen little evidence to suggest a home built a decade ago. As the drive towards that our customers are basing their purchasing carbon reduction gains pace we believe that the decisions on environmental performance fuel efficiency of new homes will appeal more (rather than cost or location). Consequently, the to buyers than the less fuel efficient homes in the commercial driver for going beyond compliance second-hand market.” is often outweighed by the need to meet the Bellway requirements of legislation. However, it is clear that as awareness of climate change continues to grow the demands of our customers to ensure we incorporate the appropriate features into our homes will also increase.” Persimmon Health Care “Applications for the internal funding of energy “Currently there is no formal methodology and climate change capital projects must include to incorporate the above criteria.” assessment of the cost of future emissions. SSL International As a result of including these estimated costs in the calculations of cost and return on investment, Response to questions 24.1: How do you decisions to invest in energy reduction and climate factor the cost of future emissions into capital change projects have been made earlier than expenditures and what impact have those would otherwise be the case.” estimated costs had on your investment decisions? GlaxoSmithKline Materials “The Board Safety and Sustainable Development “It is principally managed at the divisional and Committee meets quarterly and reviews performance business level within a framework of the Group’s against each Business Unit’s CO2 and energy targets. overall policy. The Board reviews progress on all The senior executive responsible for climate change environmental matters, including climate change is the Group Head of Safety and Sustainable related issues, twice a year.” Development. The Group Head of Environment Smith (DS) sets policy and strategy, while Heads of Safety and Sustainable Development are responsible on an operational level.” Anglo American Financials “We publish information about Aviva’s response to “Yes, within Business Review section of climate change in our Annual Report and Accounts, Annual Report.” our CR Report. We use the Accounting for Admiral Group Sustainability framework to present our key data to link it to our financial reporting. We also include it in Response to Question 27.1 Do you publish benchmarking and investor surveys, the CDP survey information about the risks and opportunities of course. We also include it in our response to the presented to your company by climate change, ClimateWise Principles and in our Communication details of your emissions and plans to reduce of Progress for the UN Global Compact.” emissions? Aviva 34 6 Appendix 1

Key AQ Answered questionnaire AQ(L) Answered questionnaire late DP Declined to participate IN Provided some information (but did not answer the CDP questions) NP Non public response NR No response – Company not in CDP sample that year x Company provided information on Scope 3 emissions for that category Table 10: Summary table in alphabetical order* 22 21 20 23

Sector Scope 1 CDLI Score Company 2009 2008 Non-public Intensity Emissions Total Scope 2 Grid Average Scope 2 Contract Arrangements Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Financials 3i Group AQ AQ 51 4 5,535 1,233 4,302 2,790 x x Financials 3i Infrastructure AQ AQ (see 3i Group) Financials 3i Quoted AQ - Private Equity (see 3i Group) Consumer 888 HoldingsAQ AQ 24 NP Discretionary Financials Aberdeen Asset AQ AQ 46 NP Management Financials Aberforth Smaller DP DP Companies Trust Financials Absolute Return Trust DP - Financials Admiral Group AQ AQ 42 7 3,045 0 3,045 452 x Consumer Aegis Group AQ AQ 64 14 18,170 0 18,170 13,530 x x Discretionary Industrials Aggreko AQ NR 22 Financials Alliance Trust IN IN

* Some of the figures in this table have been updated since the initial response analysis and may therefore differ from data in the main report contents. 35 22 21 20 23

Sector Scope 1 CDLI Score Total Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Company 2009 2008 Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Non-public Financials Alternative NR - Investment Strategies Energy AMEC AQ AQ 53 14 36,256 6,625 29,631 * 15,330 x Financials Amlin AQ AQ 53 2 2,323 312 2,011 1,726 x x Materials Anglo American AQ AQ 58 752 19,797,000 9,620,000 10,177,000 Materials Antofagasta AQ NR 60 NP Materials Aquarius Platinum AQ AQ 52 611 544,024 57,676 486,348 Information ARM HoldingsAQ DP 54 NP Technology Industrials Arriva AQ AQ 51 486 1,479,660 1,374,927 104,733 7,267 x Financials Ashmore Group AQ DP 14 NP Industrials Ashtead Group AQ AQ 35 NP Consumer Staples Associated AQ AQ 53 437 3,595,292 2,609,346 985,946 British Foods Health Care AstraZeneca AQ AQ 71 22 698,340 421,200 277,140 595,700 x x x x Industrials Atkins AQ AQ 60 11 15,071 2,081 12,990 23,351 x Information Autonomy NR NR Technology Corporation Information Aveva Group IN DP Technology Financials Aviva AQ AQ 80 13 266,407 61,886 204,521 * 26,409 x Information Axon Group DP - Technology Financials Babcock & Brown DP - Public Partnerships Industrials Babcock AQ AQ 28 NP International Group Industrials BAE Systems AQ AQ 56 NP Industrials Balfour Beatty AQ AQ 48 37 307,187 249,425 57,762 12,374 x Financials Bankers AQ AQ Investment Trust (see Henderson Group) Financials Barclays AQ AQ 74 15 607,011 27,709 579,302 * 71,735 x Consumer Staples Barr (A.G.) NR - Industrials BBA Aviation AQ AQ 53 107 123,427 69,452 53,975 Financials Beazley Group NR NR Consumer Bellway AQ AQ 60 7 8,467 5,076 3,391 * Discretionary Consumer Berkeley AQ AQ 72 5 5,228 684 4,544 2,742 x Discretionary Group Holdings Energy BG Group AQ AQ 66 704 8,843,443 8,821,241 22,202 * 86,859,899 x x Financials BH Global (GBP) DP - Financials BH Macro (GBP) DP - Materials BHP Billiton AQ AQ 82 1,131 51,892,825 23,093,870 28,798,955 318,872,809 x x Financials Big Yellow Group IN AQ Financials BlackRock World IN - Mining Trust Industrials Bodycote NR IN International Consumer Bovis Homes Group AQ AQ 40 6 1,711 976 735 847 x Discretionary

36 Appendix 1 22 21 20 23

Sector Scope 1 CDLI Score Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Company 2009 2008 Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Energy BP AQ AQ 66 199 70,630,000 61,400,000 9,230,000 515,000,000 x Financials Brewin Dolphin DP - Holdings Financials Brit Insurance DP IN Holdings Industrials British Airways AQ AQ 58 1,935 16,946,408 16,840,627 105,781 639,113 x x Consumer Staples British American IN AQ Tobacco Financials British Assets Trust AQ - Financials British Empire Sec IN IN & General Tst Utilities British Energy Group AQ AQ NP (see EDF) Financials British Land AQ AQ 54 43 29,570 1,554 28,016 Consumer British Sky AQ AQ 42 9 45,068 23,793 21,275 31,547 x x x Discretionary Broadcasting Consumer Staples Britvic AQ AQ 58 NP Financials Brixton AQ AQ 60 7 1,354 188 1,166 * 58 x x Industrials BSS Group AQ AQ 19 NP Telecommunication BT Group AQ AQ 65 84 1,739,229 330,008 1,409,221 517,364 95,051,977 x x x Services Health Care BTG IN - Industrials Bunzl AQ AQ 58 ◆◆ ◆ 31,062 276,684 x x Consumer Burberry Group AQ AQ 57 24 23,542 2,191 21,351 1,843 x Discretionary Telecommunication Cable and Wireless AQ AQ 65 57 178,798 5,832 172,966 166,389 x x x x Services Consumer Staples Cadbury AQ AQ 72 155 836,052 385,901 450,151 2,700,000 x x x Energy Cairn Energy AQ AQ 63 100 29,861 29,339 522 216,502 x Financials Caledonia IN DP Investments Financials Candover NR NR Investments Industrials Capita Group AQ AQ 58 18 44,822 9,199 35,623 19,717 x Industrials Carillion AQ NR 56 21 92,869 81,754 11,115 * 7,019 x x Consumer Carnival AQ AQ 87 703 10,298,265 10,247,517 50,748 144 19,150 x x x Discretionary Consumer Carpetright NR NR Discretionary Consumer Carphone Warehouse NR AQ Discretionary Financials Catlin Group AQ IN 46 NP Financials Cattles AQ AQ 20 NP Utilities Centrica AQ AQ 84 520 11,103,697 10,871,403 232,294 23,317,006 x x x x Industrials Charter NR DP Financials Chaucer Holdings AQ - 12 0 2 2 Industrials Chemring Group AQ IN 31 NP Industrials Chloride Group IN IN Financials City of London AQ AQ Investment Trust (see Henderson Group) Financials Close Brothers Group AQ AQ 56 NP

37 Carbon Disclosure Project 22 21 20 23

Sector Scope 1 CDLI Score Total Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Company 2009 2008 Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Non-public Financials CLS Holdings NR - Industrials Cobham AQ NR 55 131 191,476 136,224 55,252 292,293 x Telecommunication COLT Telecom Group AQ NR 52 62 103,549 4,304 99,245 1,547 x Services Consumer Compass AQ AQ 46 8 91,870 82,700 9,170 Discretionary Industrials Connaught NR NR Industrials Cookson Group NR IN Consumer Staples Cranswick AQ - 56 NP Materials Croda International AQ AQ 52 312 298,301 198,507 99,794 Information CSR AQ AQ 46 6 4,243 255 3,988 3,714 x Technology Financials Daejan Holdings DP DP Consumer Daily Mail AQ AQ 49 39 90,076 18,940 71,136 28,159 x x Discretionary & General Trust Consumer Staples Dairy Crest Group AQ AQ 67 170 266,075 178,665 87,410 * 3,176,302 x x x Energy Dana Petroleum AQ AQ 44 35 18,027 17,369 658 60 x Industrials Davis Service Group AQ IN 14 Industrials De La Rue NR AQ Consumer Debenhams AQ DP 54 98 180,632 18,063 162,569 * 1,519 x x Discretionary Health Care Dechra NR - Pharmaceuticals Financials Derwent London AQ AQ 54 9 1,062 42 1,020 10,546 x Financials Dexion Absolute DP DP Consumer Staples Diageo AQ AQ 66 90 729,000 625,000 104,000 * 384,300 x x x Consumer Dignity AQ NR 67 140 24,650 13,727 10,923 Discretionary Information Dimension AQ AQ 74 15 67,595 12,409 55,186 23,620 x Technology Data Holdings Information Domino Printing DP - Technology Sciences Consumer Dominos PizzaDP - Discretionary Utilities Drax Group AQ AQ 54 12,769 22,381,803 22,381,803 249,000 x Consumer DSG International NR NR Discretionary Financials Dunedin Income AQ - Growth Investment Tst (see Aberdeen Asset Management) Consumer Dunelm Group NR - Discretionary Consumer Eaga NR AQ Discretionary Industrials Easyjet AQ AQ 58 1,824 4,309,000 4,307,000 2,000 Financials Edinburgh Dragon Tst AQ - (see Aberdeen Asset Management) Financials Edinburgh NR DP Investment Trust Financials Edinburgh UK DP - Tracker Trust Financials Electra Private Equity AQ AQ 0

38 Appendix 1 22 21 20 23

Sector Scope 1 CDLI Score Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Company 2009 2008 Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Financials Electric & General DP - Investment Trust Information Electrocomponents AQ AQ 60 23 20,994 2,698 18,296 * 1,902 x Technology Materials Elementis IN - Energy Emerald Energy DP - Consumer Enterprise InnsAQ AQ 22 NP Discretionary Materials Eurasian Natural DP - Resources Corporation Consumer Euromoney AQ AQ 53 14 4,680 1,865 2,815 5,635 x Discretionary Institutional Investors Industrials Experian Group AQ AQ 55 18 63,445 9,255 54,190 * 12,556 x Financials F&C Asset AQ AQ 53 2 681 681 * 938 x Management Financials F&C Commercial AQ AQ Property Trust (see F&C Asset Management) Materials Ferrexpo IN IN Financials Fidelity European DP DP Values Financials Fidelity Special Values DP - Materials Filtrona AQ AQ 59 134 70,332 9,744 60,588 Financials Finsbury Worldwide NR - Pharmaceutical Industrials FirstGroup AQ AQ 58 682 3,209,695 2,926,775 282,920 * 1,217 x Energy Fisher (James) & Sons DP - Financials Foreign & AQ - Colonial Eurotrust (see F&C Asset Management) Financials Foreign & Colonial AQ AQ Invest Trust (see F&C Asset Management) Industrials Forth Ports DP DP Materials Fresnillo NR - Financials Friends Provident AQ AQ 57 ▲ 12,028 3,276 8,752 Industrials G4S AQ AQ 42 73 432,000 342,000 90,000 18,000 x Consumer Game Group NR NR Discretionary Health Care Genus DP - Consumer GKN AQ AQ 53 NP Discretionary Health Care GlaxoSmithKline AQ AQ 79 85 2,079,227 945,678 1,133,549 4,911,482 x x x Industrials Go-Ahead Group AQ AQ 72 NP Financials Great Portland Estates AQ AQ 61 22 1,910 1,910 3,531 12 x Consumer Greene KingAQ AQ 44 170 163,523 54,247 109,276 Discretionary Consumer Staples Greggs AQ AQ 48 150 94,514 29,222 65,292 9,708 x Consumer Halfords Group NR AQ Discretionary

39 Carbon Disclosure Project 22 21 20 23

Sector Scope 1 CDLI Score Total Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Company 2009 2008 Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Non-public Information Halma NR AQ Technology Financials Hammerson AQ AQ 84 151 61,561 6,093 55,468 30,669 91,830 x x x x Financials Hargreaves Lansdown DP DP Industrials Hays AQ AQ 26 NP Financials HBOS (see Lloyds AQ AQ Banking Group) Financials Helical Bar DP - Financials Henderson Group AQ AQ 62 2 517 197 320 * 1,766 x x x Energy Heritage Oil NR - Health Care Hikma NR NR Pharmaceuticals Financials Hiscox AQ AQ 34 NP Consumer HMV Group NR DP Discretionary Materials Hochschild Mining NR NR Consumer Home Retail Group AQ AQ 49 48 285,000 138,400 146,600 73,000 Discretionary Industrials Homeserve AQ AQ 49 NP Financials HSBC Holdings AQ AQ 92 7 874,439 102,933 771,506 669,713 107,445 x x Energy Hunting AQ AQ 26 NP Financials Icap AQ NR 19 2 3,046 907 2,139 Financials IG Group Holdings AQ AQ 47 10 1,818 2 1,816 585 x Industrials IMI AQ AQ 45 54 102,550 26,800 75,750 Financials Impax Environmental AQ - 41 NP Markets Energy Imperial Energy NR DP Corporation Consumer Staples Imperial Tobacco AQ AQ 62 11 114,925 46,740 68,185 * Group Consumer Inchcape AQ(L) AQ(L) NP Discretionary Consumer Informa AQ AQ 47 NP Discretionary Telecommunications Inmarsat AQ DP 51 3 3,220 3,220 * 1,300 x Consumer InterContinental AQNR 43 2,540 4,600,000 0 4,600,000 4,400,000 x Discretionary Hotel Group Financials Intermediate NR AQ Capital Group Financials International AQ AQ 45 NP Personal Finance Utilities International Power AQ AQ 67 NP Industrials Interserve AQ AQ 76 20 35,621 29,649 5,972 971 x Industrials Intertek Group AQ AQ 23 NP Industrials Invensys AQ AQ 64 54 112,866 28,608 84,258 20,363 x Financials Investec AQ AQ 38 12,154 x x Industrials ITE Group NR NR Consumer ITV AQ AQ 23 NP Discretionary Consumer Staples J Sainsbury AQ AQ 49 49 873,464 205,765 667,699 Financials Jardine Lloyd NR IN Thompson Group

40 Appendix 1 22 21 20 23

Sector Scope 1 CDLI Score Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Company 2009 2008 Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Energy JKX Oil and Gas AQ AQ 52 NP Materials Johnson Matthey AQ AQ 56 49 371,000 160,000 211,000 23,815 x x Financials JPMorgan AQ - American IT (see JP Morgan Chase) Financials JPMorgan Emerging AQ AQ Mkts Inv Trust (see JP Morgan Chase) Financials JPMorgan Euro AQ - Fledgling Investment Tst (see JP Morgan Chase) Financials JPMorgan IT AQ AQ Fleming Mercantile (see JP Morgan Chase) Financials JPMorgan Indian AQ AQ Inv Trust (see JP Morgan Chase) Financials JPMorgan Japanese AQ - Investment Trust (see JP Morgan Chase) Materials Kazakhmys NR NR Industrials Keller NR IN Consumer Kesa ElectricalsAQ AQ 9 NP Discretionary Industrials Kier Group AQ IN 59 11 26,723 19,978 6,745 733 x Consumer Kingfisher AQ AQ 67 61 549,382 148,621 400,761 63,000 x x x Discretionary Consumer Ladbrokes AQ AQ 35 NP Discretionary Financials Land Securities AQ AQ 62 90 73,514 11,629 61,885 Financials Law Debenture AQ AQ 28 NP Corporation Financials Legal and AQ AQ 78 ▲ 16,306 0 16,306 3,855 x General Group Financials Liberty International AQ AQ 49 72 43,989 6,366 37,623 1,070 x Financials Lloyds Banking Group AQ AQ 80 22 455,651 97,709 357,942 * 25,129 x Information Logica AQ AQ 77 27 97,668 45,814 51,854 51,854 46,158 x x Technology Financials London Stock AQ AQ 22 5 2,687 631 2,056 Exchange Materials Lonmin AQ AQ 47 744 1,659,103 75,850 1,583,253 Financials Man Group AQ AQ 65 2 7,262 1,375 5,887 1,144 3,296 x Consumer Marks & AQ AQ 65 65 589,126 126,283 462,843 215,502 5,121,023 x x x x Discretionary Spencer Group Consumer Marstons AQ AQ 47 NP Discretionary Consumer Staples McBride NR - Industrials Meggitt AQ AQ 46 NP Industrials Melrose NR - Energy Melrose Resources AQ - 32 NP Financials Merchants Trust AQ AQ (see Allianz) Industrials Michael Page IN AQ International

41 Carbon Disclosure Project 22 21 20 23

Sector Scope 1 CDLI Score Total Emissions Total Company 2009 2008 Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Information Micro Focus NR NR Technology International Consumer Millennium & DP IN Discretionary Copthorne Hotels Information Misys NR DP Technology Consumer Mitchells & Butlers AQ AQ 21 NP Discretionary Industrials MITIE Group AQ AQ 47 23 32,280 32,280 Materials Mondi AQ AQ(L) 67 946 6,003,000 4,435,000 1,568,000 2,922 x Information Moneysupermarket AQAQ 34 NP Technology .com Group Financials Monks Investment IN IN Trust Industrials Morgan Crucible AQ AQ 73 546 455,708 166,647 289,061 * Industrials Morgan Sindall AQ NR 46 4 11,450 6,535 4,915 x Consumer Staples Morrison AQ AQ 43 95 1,233,351 632,857 600,494 39,675 x Supermarkets Consumer Mothercare AQ - 57 41 28,000 2,500 25,500 9,219 x x Discretionary Industrials Mouchel Group IN AQ Financials Murray Income Trust AQ AQ Financials Murray International AQ AQ Trust (see Aberdeen Asset Management) Consumer N Brown Group AQ AQ 75 16 9,633 2,810 6,823 * 420 x x Discretionary Industrials National Express AQ AQ 63 287 792,944 413,980 378,964 * 1,824 x x Group Utilities National Grid AQ AQ 69 1,066 12,182,000 11,939,000 243,000 5,263,000 x x Consumer Next AQ AQ 67 NP Discretionary Consumer Staples Northern Foods AQ AQ 72 254 236,570 118,285 118,285 84,904 x x x Utilities Northumbrian AQ AQ 81 419 280,842 59,552 221,290 43,640 x x x x Water Group Financials Novae Group DP - Financials Old Mutual AQ AQ 73 ▲ 525,253 5,822 519,431 * 39,202 x x x Consumer Partygaming NR NR Discretionary Industrials Paypoint DP DP Consumer Pearson AQ AQ 57 40 193,608 43,811 149,797 27,886 x x Discretionary Utilities Pennon Group AQ AQ 65 269 235,332 117,544 117,788 * 13,344 x x Financials Perpetual Income & NR AQ Growth Inv Tst Consumer Persimmon AQ AQ 40 7 11,900 10,000 1,900 Discretionary Energy Petrofac NR DP Information Premier Farnell AQ AQ 61 32 23,926 4,909 19,017 1,194 x Technology Consumer Staples Premier Foods AQ AQ 52 NP Energy Premier Oil AQ AQ 45 327 214,304 214,304 5,500,000 x Financials Provident Financial AQ AQ 68 10 7,854 2,840 5,014 3,325 2,721 x

42 Appendix 1 22 21 20 23

Sector Scope 1 CDLI Score Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Company 2009 2008 Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Financials Prudential AQ AQ 57 ▲ 74,139 19,337 54,802 19,271 x x Consumer Punch Taverns AQ AQ 56 85 133,429 36,617 96,812 Discretionary Industrials Pv Crystalox Solar IN IN Consumer Staples PZ Cussons AQ NR 45 NP Industrials Qinetiq Group AQ AQ 53 53 71,832 18,108 53,724 7,158 x Materials Randgold Resources NR NR Consumer Rank Group NR - Discretionary Financials Rathbone Brothers AQ AQ 53 NP Consumer Staples Reckitt Benckiser AQ AQ 80 44 291,059 125,795 165,264 18,215,832 x x x x x Consumer Redrow NR AQ Discretionary Consumer Reed ElsevierAQ AQ 76 16 126,212 18,559 107,653 93,512 131,703 x x x Discretionary Industrials Regus Group DP DP Information Renishaw NR AQ Technology Industrials Rentokil Initial AQ AQ 68 113 273,091 246,862 26,229 870 x Consumer Restaurant Group NR NR Discretionary Materials Rexam AQ(L) DP NP Consumer Rightmove NR NR Discretionary Materials Rio Tinto AQ AQ 87 927 50,300,000 30,300,000 20,000,000 * 657,555,000 x x x x x Financials RIT Capital Partners DP DP Consumer Staples Robert Wiseman AQ - 62 NP Dairies Industrials Rolls-Royce AQ AQ 76 73 665,078 292,679 372,399 100,034,000 x x x Information Rotork NR AQ(L) Technology Financials Royal & Sun Alliance AQ AQ 53 0 50,080 20,033 30,047 12,997 x x Insurance Group Financials Royal Bank of AQ AQ 77 13 690,222 118,270 571,952 * 59,550 x Scotland Group Energy Royal Dutch Shell AQ AQ 75 185 85,000,000 75,000,000 10,000,000 691,401,000 x x x Industrials RPS Group AQ AQ 58 16 7,527 4,912 2,615 1,216 x Consumer Staples SABMiller AQ AQ 54 109 2,343,184 1,513,037 830,147 404,533 x Information Sage Group AQ AQ 46 12 15,091 3,575 11,516 Technology Energy Salamander Energy DP - Financials Savills AQ DP 15 Financials Schroders AQ AQ 63 9 9,289 733 8,556 5,738 x Utilities Scottish & AQ AQ 78 1,270 19,372,778 19,286,697 86,081 65,567 47,109 x x Southern Energy Financials Scottish AQ NR 30 NP Investment Trust Financials Scottish Mortgage IN IN Investment Trust Financials Segro AQ AQ 65 4 1,275 142 1,133 * 17 x Consumer Serco Group AQ DP 50 81 253,693 65,029 188,664 10,114 x Discretionary

43 Carbon Disclosure Project 22 21 20 23

Sector Scope 1 CDLI Score Total Emissions Total Company 2009 2008 Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Utilities Severn Trent AQ AQ 58 430 667,866 244,830 423,036 * 126 x x Financials Shaftesbury AQ AQ 69 18 1,188 0 1,188 1 x Industrials Shanks Group AQ AQ 41 NP Health Care Shire AQ NR 70 14 41,370 15,276 26,094 6,910 x Industrials SIG AQ AQ 58 NP Health Care Smith & Nephew AQ AQ 63 19 73,224 8,428 64,796 Materials Smith (DS) AQ AQ 53 506 996,000 315,000 681,000 x Industrials Smiths Group AQ AQ 32 52 121,268 121,268 Energy Soco International AQ NR 34 NP Health Care Southern Cross IN AQ Healthcare Information Spectris IN IN Technology Industrials Spice DP - Industrials Spirax-Sarco AQ AQ 54 NP Engineering Information Spirent NR AQ Technology Communications Consumer Sports Direct DP NR Discretionary International Health Care SSL International AQ AQ 40 59 31,360 7,986 23,374 Financials St.James Place AQ AQ 64 ▲ 3,617 1,606 2,011 5,123 x x x Industrials Stagecoach Group AQ AQ 59 691 1,217,943 898,300 319,643 25,666 x x Financials Standard Chartered AQ AQ 66 12 269,902 14,913 254,989 50,262 x Financials Standard Life AQ AQ 57 ▲ 20,222 3,684 16,538 4,057 x Industrials Stobart Group DP - Financials SVG Capital NR IN Health Care Synergy Health AQ - 50 NP Materials Talvivaara AQ NR 52 NP Mining Company Consumer Staples Tate & Lyle AQ NR 8 1,138 3,261,824 3,261,824 Information Telecity Group NR - Technology Telecommunications Telecom Plus NR - Financials Temple Bar AQ AQ Investment Trust (see Investec) Financials Templeton IN DP Emerging Markets IT Consumer Staples Tesco AQ AQ 69 105 4,957,470 1,877,340 3,080,130 58,744 x Financials Thames River Multi DP - Hedge PCC (GBP) Consumer Thomas Cook Group AQ DP 69 456 4,019,360 3,985,071 34,289 Discretionary Consumer Thomson ReutersAQ AQ 36 NP Discretionary Industrials Tomkins AQ AQ 44 32 176,839 176,839 32,511 x Financials TR Property IN IN Investment Trust Industrials Travis Perkins AQ AQ 48 50 158,201 96,604 61,597 9,040 x Consumer TUI Travel AQ AQ 71 475 6,617,498 6,564,026 53,472 * 70,597 x x x Discretionary

44 Appendix 1 22 21 20 23

Sector Scope 1 CDLI Score Intensity Scope 2 Grid Average Scope 2 Contract Arrangements Company 2009 2008 Emissions Total Scope 3 Business Travel Logistics and Distribution & Services Use & Disposal of Products Supply Chain Other Non-public Financials Tullett Prebon NR NR Energy Tullow Oil AQ AQ 43 249 172,260 172,260 Financials UK Commercial DP DP Property Trust Industrials Ultra Electronics DP DP Holdings Consumer Staples Unilever AQ AQ 76 69 2,785,882 1,167,662 1,618,220 110,600,000 x x x x Consumer United Business AQNR 52 5 4,369 506 3,863 1,073 x Discretionary Media Utilities United Utilities AQ AQ 71 231 545,791 122,141 423,650 313,025 6,098 x x Materials Vedanta Resources AQ AQ 48 NP Energy Venture Production NR AQ Materials Victrex DP IN Telecommunications Vodafone Group AQ AQ 67 46 1,625,922 271,817 1,354,105 1,150,938 55,358 x Industrials VT Group AQ AQ 75 214 94,741 24,057 70,684 83 x Industrials Weir Group NR NR Energy Wellstream Holdings NR IN Consumer Wetherspoon AQ AQ 75 186 168,535 44,049 124,486 48,518 x x x Discretionary Consumer WH Smith AQ AQ 65 NP Discretionary Consumer Whitbread AQ AQ 66 170 206,800 57,363 149,437 24,981 x x x x Discretionary Consumer William Hill NR NR Discretionary Industrials Wincanton AQ AQ 14 NP Financials Witan DP DP Investment Trust Industrials Wolseley AQ AQ 33 NP Energy Wood Group IN DP Consumer WPP AQ AQ 56 15 112,901 4,344 108,557 94,376 117,087 x x Discretionary Information Xchanging AQ AQ 59 18 9,853 1,097 8,756 887 x Technology Materials Xstrata AQ AQ 68 891 24,913,251 15,605,091 9,308,160 * 215,157,719 x x x Consumer Yell AQ AQ 47 14 31,323 985 30,338 241,101 x x x Discretionary

20 Disclosed Scopes 1 and 2 grid average emissions totals divided by annual US$ million revenues. Revenues based on data retrieved from Bloomberg on June 18, 2009. 21 Company reported total emissions (Scopes 1 and 2 grid average). 22 Where there is a * in this column, the company did provide detail in relation to its contractual Scope 2 emissions. Please refer to the company’s response. ◆ Reported Scope 1 data was removed at time of going to 23 The Scope 3 figure is the sum of data given in answer to press due to miscalculation in the submission, therefore questions 13.1-13.4. Information in response to 13.5 was intensity and total emission data were also removed. Please not included in this figure. In a number of cases (marked see full company response at www.cdproject.net for with †), the company provided data for non-transfer updated Scope 1 emission data. emissions under 13.5. CDP advises you to look at their ▲ Intensity was not calculated where reported revenue full response for details of these emissions. was a negative value. 45 7 Appendix 2

Glossary of terms CDLI Carbon Disclosure Leadership Index CDM Clean Development Mechanism – Kyoto Protocol carbon reduction facility CDP Carbon Disclosure Project CSR Corporate Social Responsibility Defra Department for Environment, Food and Rural Affairs DECC Department for Energy and Climate Change EU ETS European Union Emissions Trading Scheme GHG Greenhouse Gases IPCC Intergovernmental Panel on Climate Change M&A Mergers and Acquisitions R&D Research & Development SRI Socially Responsible Investing tCO2-e metric tonnes of carbon dioxide equivalent

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PwC and CDP prepared the data and analysis in this report based on responses to the CDP 2009 information request. PwC and CDP do not guarantee the accuracy or completeness of this information. PwC and CDP make no representation or warranty, express or implied, and accept no liability concerning the fairness, accuracy, or completeness of the information and opinions contained herein. All opinions expressed herein by CDP and/or PwC are based on their judgment at the time of this report and are subject to change without notice due to economic, political, industry and firm-specific factors. Guest commentaries where included in this report reflect the views of their respective authors.

PwC and CDP and their affiliated member firms or companies, or their respective shareholders, members, partners, principals, directors, officers and/or employees, may have a position in the securities discussed herein. The securities mentioned in this document may not be eligible for sale in some states or countries, nor suitable for all types of investors; their value and the income they produce may fluctuate and/or be adversely affected by exchange rates.

‘PricewaterhouseCoopers’ and ‘PwC’ refer to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) or, as the context requires, other member firms of PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.

‘Carbon Disclosure Project’ and ‘CDP’ refers to Carbon Disclosure Project, a United Kingdom company limited by guarantee, registered as a United Kingdom charity number 1122330.

© 2009 Carbon Disclosure Project.