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Centre for Environmental Rights


Exploration and operation of mines. South32 is the fourth highest emitter of greenhouse gasses in South Africa. It is the best performer of the emitters assessed in this report. It is not listed on the JSE.


South32 provides the best practice example of risk identification and strategies to manage risks. It sets out detailed disclosures, including timeframes and impacts, with timeframes in mainstream annual reporting. It also discloses how climate risks and opportunities are incorporated into strategy through efforts such as mitigation, adaptation, resource efficiency, pollution reduction and transition plans. These strategies are informed by three scenarios developed by South32, including a 2°C or lower scenario.

South32 is the only company assessed that discloses its internal carbon price in mainstream reports. It also discloses its liability under the carbon tax in its CDP submissions. This additional reporting supports efforts to meet both the short- and long-term emissions reductions targets set by the company. The board is explicitly mentioned as responsible for managing climate-related opportunities and risks, and their remuneration policy includes short-term incentives for sustainability, including greenhouse gas reductions and keeping abatement projects on track.

Emissions Score Card

14.43 MtCO2e
Total Scope 1 and 2 Emissions (South Africa, 2018)
Contribution to South Africa’s total emissions (estimated)
Ranking out of 10 emitters assessed (1 = highest)
22.63 MtCO2e
Total Scope 1 and 2 Emissions (Worldwide)



Is the company a supporter of the TCFD?

Dec 17

Who has oversight of climate-related risks and opportunities?

Disclosure explicitly mentions that the board is responsible for overseeing climate risk. Board responsibility for “sustainability”, “environmental issues”, or “ESG” is not sufficient.

South32’s Sustainability Committee “represents and assists the Board in managing climate-related opportunities and risks” – CC 2018, p 13

The Board is briefed on strategic risks, which include climate-related risks, at each Board meeting. – AR 2018, p 20

Does the remuneration policy include performance metrics used to measure and manage climate-related risks?

Remuneration policy includes climate-related performance metrics.

Short-term incentives for sustainability, which has a 25% weighting, include “GHG reduction and abatement projects on track” – AR 2018, p 76


Does the company identify climate change as a material business risk?

Climate risks are explicitly mentioned as a material or principal risk in the annual or integrated report.

Climate change impacts’ is one of 15 identified strategic risks that have the “potential to significantly impact the performance and sustainability of our business”. – AR 2018, p 20-21

Has the company outlined the risks and opportunities from climate change?
Mainstream reports

Detailed disclosure, including timeframes and impacts, with timeframes in mainstream annual reporting.

South32 has identified climate-related risks and opportunities and, from 2018, has indicated the time horizon to which these relate. The risks, mitigation options and opportunities are presented in a table in the South32 document ‘Our approach to climate change’.

Does the company describe how its strategy might change to address climate change risks and opportunities?

Disclosure of how climate risks and opportunities are incorporated into strategy through efforts such as mitigation, adaptation, resource efficiency, pollution reduction and transition plans.

“We developed our Climate Change Strategy in 2015 and have been progressively implementing programs to take advantage of opportunities and mitigate or adapt to climate-related risks.” – CC 2018, p 5

Does the company describe the climate change scenarios used to inform strategy and financial planning?

Disclosure of scenario analysis describes the range of scenarios used (including a 2°C or lower scenario), critical inputs and assumptions, timeframes, and potential implications.

“In collaboration with subject matter experts and stakeholders we developed three scenarios:
(1) Global Cooperation
(2) Patchy Progress (South32 base case)
(3) Runaway Climate Change”

Risk Management

Does the company have a process to manage climate-related risks?

Climate-related risks form part of company-wide risk management programme or specific climate-related risk management process.

Climate change-related risks are identified and assessed as part of the Company’s risk management framework. “We disclose and manage material climate-related risks in the same way we manage financial risks to our operations and long-term strategy.” – CC 2018, p 13

Metrics and Targets

Has the company set GHG emission reduction targets?

The company has set an absolute emission reduction target.

Short-term carbon emission reduction target is “to stay below our FY15 Scope 1 carbon emission baseline in FY21” – CC 2018, p 10

Is there a long-term GHG emission reduction target?

There is an absolute or intensity reduction target over five years in duration.

“Our goal is net zero CO2e emissions by 2050.” – AR 2018, p 9

Does the company disclose its GHG emissions?
Scope 1, 2 and 3

Companies report on their Scope 1, 2 and 3 emissions for the current year and at least the previous year.

“Approximately 60 per cent of our Scope 3 emissions come from the use of our energy and metallurgical coal downstream.” – CC 2018, p 10

Full breakdown of Scope 3 emissions performance, including the calculation methodology, is available.

Does the company provide their internal carbon price?

Internal carbon price is disclosed.

“we form a near-term view reflecting existing or imminent carbon markets in our countries of operation (e.g. the Safeguard Mechanism in Australia, the carbon tax in Colombia and the potential introduction of the South Africa carbon tax). Longer-term, our carbon price is set to a global average of $15/tonne(6) from 2025 onwards.” – CC 2018, p 19

Additional Information

Does the company disclose the extent of liability under the carbon tax?
CDP only

Liability is only disclosed in CDP submissions.

South32 acknowledges the potential impact of a carbon tax in South Africa, but does not provide an estimate of the financial liability.

Does the company disclose its participation in the DEA's voluntary carbon budget programme?

Participation is disclosed in mainstream reports.

According to Environment at South32, in FY2017 South32 “participated in the South Africa Carbon Budget Pilot Study as part of progress towards the introduction of a carbon tax” – Env, p8

Disclosures Considered

  • Annual Report 2018
  • Our Approach to Climate Change 2018
  • Sustainability Data Tables FY2018
  • Our Material Sustainability Issues FY18
  • Carbon Disclosure Project (CDP) 2018 Climate Change submission

This report is accurate as at 1 August 2019.

Company Profile


Australia, South Africa, Asia, Europe, Middle East, North America, South America (divested in South African coal business, 2019)

Key Shareholders

  • Schroder Investment Management Ltd (6.45%)
  • BlackRock Fund Advisers (3.10%)
  • Vanguard Investments Australia (2.89%)
  • Norges Bank Investment Management (2.30%)