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Sep 2 2013


Mandatory Carbon Reporting: 7 Key Steps

With less than a month to go until the Mandatory Greenhouse Gas Reporting regulations come into force, this blog covers the 7 key steps all listed companies should take in order to get to grips with the new regulations.

Step 1: Check Your Company Status

Is your company UK incorporated?

Is your company ‘quoted’ i.e. listed on the Main Market of the London Stock Exchange or listed in the European Economic Area or admitted to dealing on either the New York Stock Exchange or NASDAQ?

If the answer to both these questions is yes, then you will need to start preparing to meet the UK Mandatory Greenhouse Gas Reporting Regulations. If the answer is no, its unlikely you will be covered by the regulations this year. However, a decision will be made by 2016 whether or not to extend the regulations

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to all large companies so it may be worth developing an understanding of the regulations now.

Step 2: Check when your company’s reporting year ends

If your company’s current financial reporting year ends on or after 30th September 2013, you should already have started measuring cialis tricare your greenhouse gas emissions in preparation including this information in your next Director’s Report. You will need to start collating and compiling your GHG data for the current financial reporting year if you have not already done so.

If your current financial reporting year ends before 30th September 2013, you won’t need to report your greenhouse emissions in your upcoming Director’s Report. Nonetheless you may find this year’s report a useful opportunity to start identifying gaps in your GHG data and ensuring your current reporting practices are aligned with the regulations.

Step 3: Get to grips with the Reporting Boundary

The key requirement is that companies ‘must state the annual quantity of emissions cialis price in tonnes of carbon dioxide equivalent from activities for which that company is responsible…’. To work out which emissions they are responsible for, companies should start by looking at which operations how much cost a viagra and activities are covered in the financial statement contained within the Director’s Report. Ideally the greenhouse gas reporting should be in line with this financial reporting boundary (both in terms of the time period and in terms of the operations and activities covered).

In terms of which emissions sources to include, the draft regulations require companies to ‘report their annual emissions from the combustion of fuel and the operation of any facility’ and to ‘state the annual quantity of emissions in tonnes of carbon dioxide equivalent resulting from the purchase of electricity, heat, steam or cooling’. The regulations essentially cover a company’s Scope 1 and Scope 2 emissions with Scope 3 reporting being optional under the regulations.

Step 4: Choose A Calculation Methodology

Whilst the GHG Reporting regulations are not prescriptive about which methodology companies should use to calculate their emissions, it is a requirement that the choice of methodology is clearly stated. Companies would be wise to ensure that their methodology is both widely recognised and robust. The GHG Protocol, ISO 14064-1 and the UK

Government’s Environmental

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Reporting Guidance (2013) are all well-used and accepted in the UK and further afield. CDP provides a list of commonly cited methodologies and standards in Q7.2 of their Reporting Guidance [available here]

Step 5: Identify Appropriate Emissions Factors

A key requirement of the legislation is that companies must include all six greenhouse gases covered in

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the Climate Change Act (2008) and that emissions must be reported in CO2e. If your company currently reports through the Carbon Reduction Commitment or EU ETS, you should note that the emissions factors used for these regulations only cover CO2, meaning that to comply with the Mandatory Reporting regulations you will need to seek out other emissions factors that cover all six greenhouse gases.

It should also be noted that emissions factors are often country-specific – for example, because of the different electricity grid mix of each country. Companies with international

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operations will therefore need to identify emissions factors that are appropriate for each country in which they operate.

Step 6: Select Intensity Ratios

Intensity ratios compare a company’s GHG emissions information against an appropriate financial indicator or other metric that is relevant to that company, such as GBP revenue or number of product units sold. This provides an alternative way of evaluating a company’s emissions performance over time and comparing similar companies to one another. Companies cheapcialisdosage-norx are required to include at least one intensity ratio which relates to their annual emissions for the entire company.

Step 7: Review and Reflect

As the regulations fall under the Companies Act, compliance will be be monitored by the Conduct Committee of the Financial Reporting Council. The Committee will raise concerns with companies where there is evidence of non-compliance and if necessary can apply to the court for a declaration that the annual report does not comply with the requirements. It is therefore essential that the Board of Directors and senior management are made fully aware of the regulations and the risks of non-compliance and a useful step may be to involve them in any review carried out of the GHG information.

An additional level of assurance can be provided for senior management by seeking independent verification of the GHG emissions statement. Whilst it is not a requirement of the regulations, seeking independent third party verification does help to satisfy both internal and external stakeholders of the quality and reliability of the data being reported. It is therefore recommended by DEFRA (and others) as good practice in the case of Mandatory Carbon Reporting.

If a company is unable to compile or report on all GHG information which is material to them, then there is a provision within the regulations to ‘Comply or Explain’, by which companies

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must state what has been omitted from the report and explain the reason for these omissions. This situation is only expected in very exceptional circumstances such as significant restructuring of the company in the lead up to the publication of the report.

About Carbon Masters

Carbon Masters is a carbon management consultancy which helps organisations in the public and private sector to measure, manage, reduce and report their carbon emissions.



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