Strategy
TCFD recommended disclosure
Consistency
NCC Group disclosure
Focus area of FY26
Strategy
• See the tables below and on page 24 describing risks and opportunities, which were selected based on the location of our existing business and known climate change risks affecting the broader region we operate in • Climate-related taxes, or fines for non-compliance, could impact the business if we fail to take action • Our ability to raise capital to invest in growth may be restricted if we fail to make progress on climate- related action, if this is a requirement of any future sustainable lending requirements • We have conducted an initial quantitative analysis against two scenarios of 1.5°C and 4°C
• Monitor actions arising from the risk register
A. Describe the climate‑related risks and opportunities the organisation has identified over the short, medium and long term B. Describe the impact of climate‑related risks and opportunities on the organisation’s business strategy and financial planning C. Describe the resilience of the organisation’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario
Consistent
• Assess financial implications of climate scenarios in our financial planning
Partially consistent
• Develop initial scenario analysis and integrate into NCC Group’s strategy development through implementation of the Carbon Reduction Plan
Partially consistent
Our focus is not limited to risk mitigation but extends to exploring opportunities where we can make a positive impact. This includes improving the energy efficiency of our operations, collaborating with our landlords and requesting renewable energy sources, and identifying ways our technology solutions can contribute to our clients’ sustainability efforts. As we continue our climate change journey, we are committed to regularly reporting our progress against these objectives, showing transparency in our endeavours, and constantly seeking ways to better our efforts.
Climate-related risks Our comprehensive risk management framework (summarised in the Risk Management section of the Annual Report on pages 29 to 37) is instrumental in identifying and assessing climate-related risks. We categorise these risks into: • Short term (less than one year) – based on short-term regulatory or policy changes impacting climate-related risks and opportunities as well as existing forecasting processes considered by management which are reviewed and evaluated on an annual basis • Medium term (one to five years) – based on regulatory changes that may affect climate-related risks and opportunities • Long term (more than five years) – based on the likely timeline of international agreements and commitments, technological trends and changes to policy or carbon pricing and their impact on our operations, client services and supply chain
For instance, short-term risks might include immediate regulatory changes or extreme weather events, while long-term risks could be major shifts in our industry driven by the transition to a low carbon economy. Each identified risk is paired with corresponding mitigation measures, such as implementing energy-efficient technologies or diversifying our supply chain, aimed to reduce our vulnerability. It’s critical that we remain flexible in our approach but focused on taking responsibility for the emissions we generate and seek to reduce what we can control. While these risks apply to the Group as a whole, we do recognise that certain locations face unique challenges. For example, our operations in coastal areas are more susceptible to rising sea levels and increased frequency of extreme weather events. For a more detailed understanding of the climate-related risks and opportunities we face, please refer to the table below. It provides a snapshot of the specific challenges we’re addressing and the strategic responses we have undertaken.
Short/medium/ long term
Regions impacted
Risk
Risk impact
Mitigating activities
Physical risks
• Business interruption cover • Business continuity plans • Remote working in place • Dutch flood defences in place
Extreme weather (acute)
Short to medium term
All but particularly Europe (Rijswijk and Amsterdam) Europe – Rijswijk and Amsterdam offices
Causing business disruption and loss of service delivery if colleagues or clients are impacted adversely, which would in turn potentially impact revenue Increased likelihood of flooding in Delft and Amsterdam offices causing increased insurance premiums to mitigate against business interruption and material loss
Sea level rises (chronic)
Long term
NCC Group plc — Annual report and accounts for the year ended 30 September 2025 23
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