Sustainability continued
Task Force on Climate-related Financial Disclosures (TCFD)
Our assessments indicate a low risk of exposure to physical and transitional climate changes, thanks to our business model. However, we acknowledge the high importance of mitigating greenhouse gas emissions, which emerged as a priority from stakeholder feedback as part of our “ongoing assessment” of double materiality in accordance with European Sustainability Reporting Standards. In FY25 we appointed a new partner – Positive Planet – to support the design and publication of our global Carbon Reduction Plan and to calculate and verify our GHG emissions. We recognise the considerable opportunities presented by the growing climate-focused market. Our collaborations with clients in industries such as electric vehicles, renewable energy, Operational Technology and other climate-friendly technologies underscore our readiness to seize these opportunities for sustainable growth.
In alignment with the UK Listing Rules, which mandates climate-related disclosure for all UK listed companies, we have produced a comprehensive TCFD Report. Our report covers the four pillars recommended by TCFD: governance, strategy, risk management and metrics/targets, and the 11 disclosures recommended by TCFD except as noted below. To ensure consistency across our report, we adhered to section C of the TCFD Annex, titled “Guidance for All Sectors”. As a result the following are documented as partially consistent, with further detail available within this report: • Strategy B and C – these disclosures have not been fully met due to prioritising drafting our Carbon Reduction Plan, which will use FY25 as our baseline year to enable reduction targets aligned to science-based targets.
Governance
TCFD recommended disclosure
Consistency
NCC Group disclosure
Focus area of FY26
Governance
• The Board’s Head of the Audit Committee is the lead Non-Executive Director responsible for sustainability. Monthly updates are provided via the CFO report to the Board as well as directly from quarterly meetings with the VP, Investor Relations and Sustainability and the lead NED, including an update on progress against the Group’s goals and targets where appropriate • The Board takes overall accountability for the management of climate-related risks and opportunities and considers them as part of its overall risk review processes • The VP, Investor Relations and Sustainability reports to the Chief Financial Officer, providing advice and updates to the Executive Committee on climate- related issues as and when relevant • An Executive Risk Management (ERM) Committee meets quarterly and addresses any climate risks as part of that process where appropriate
• Introduce reporting aligned to the Carbon Reduction Plan targets to reflect, discuss and ensure actions are being taken
A. Describe the Board’s oversight of climate- related risk and opportunities
Consistent
• Roll out Climate Literacy Training to all ExCom members and senior leaders during FY26 • Continue to embed climate action into key business decisions • Assign accountabilities and track progress resulting from the Carbon Reduction Plan
B. Describe the
Consistent
management’s role in assessing and managing climate-related risks and opportunities
The results from our ongoing double-materiality assessment continue to inform our sustainability framework. With the changes in requirements for CSRD and the fact our business operations are not in scope for the foreseeable future, we do not intend to report voluntarily against the standards. We will continue to review and assess to ensure we can bid competitively for work within Europe. The Board is committed to communicating its dedication to addressing climate change. By way of example Lynn Fordham along with Guy Ellis, CFO, attended NCC Group’s inaugural Carbon Literacy Training and received their certification in August 2025. They continue to champion training and action in their respective roles.
Lynn Fordham, the lead Non-Executive Director for Sustainability, was appointed by the NCC Group Board Chair. In addition to her position as the Head of the Audit Committee, Lynn’s role is to oversee the Company’s sustainability strategy, ensure its integration with the overall business strategy and provide regular sustainability updates to the Board. While there is no specific Board committee for environmental issues, an Executive Risk Management (ERM) Committee chaired by the SVP, Global Governance, Procurement and Estates addresses these issues. The ERM meets bi-monthly and is attended by our CEO and CFO. It discusses, among other risks, sustainability and environmental challenges where relevant, which are then reported to the Board.
NCC Group plc — Annual report and accounts for the year ended 30 September 2025 22
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