Sustainability continued
TCFD continued Risk management
TCFD recommended disclosure
Consistency
NCC Group disclosure
Focus area of FY26
Risk management
• Climate-related risks are managed through our Enterprise Risk Management framework
• Monitor actions arising from the risk register
A. Describe the organisation’s processes for identifying and assessing climate‑related risks B. Describe the organisation’s processes for managing climate-related risks
Consistent
• Climate-related risks are documented, mitigating actions are considered, a risk rating is assigned and associated actions are documented and followed up • Climate-related risks are managed through our Enterprise Risk Management framework
• Monitor actions arising from the risk register
Consistent
• Monitor actions arising from the risk register
C. Describe how processes for identifying, assessing and managing climate-related risks are integrated into the organisation’s overall risk management
Consistent
These climate-related risks are integrated into our Principal Risks section (pages 29 to 37). The Executive Risk Management Committee plays an active role in the ongoing review of these risks and their mitigations, controls and associated actions. This Committee meets on a regular basis and follows a stringent process for identifying, assessing, responding to and escalating serious concerns related to these risks. We firmly believe that this integrated and transparent approach will ensure effective risk management aligned with the principles of TCFD, while driving our strategic objectives for sustainability.
Climate-related risks are managed through our NCC Group Enterprise Risk Management (ERM) framework. This framework, which is detailed in the Risk Management section of the Annual Report on page 30, uses a sophisticated risk model to assess and score each risk based on likelihood and impact. Risks are re-evaluated consistently to ensure we’re responsive to evolving circumstances. Our risk management approach combines “top-down strategic” and “bottom-up operational” perspectives, fostering collaboration and promoting efficient risk identification. With respect to climate-related risks, we have outlined our strategies and targets for GHG emissions reduction and biodiversity preservation.
How we manage risks
Perform scenario analysis
Adapt ERM
Assess financial impacts
Solicit investor feedback
Secure leadership buy-in
Establish Committee oversight
Collaborate across the business
Integrate into reporting
Use existing tools
Implement internal control
Obtain assurance
NCC Group plc — Annual report and accounts for the year ended 30 September 2025 26
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