Nuclear Energy: An ESG Investable Asset Class  
 
Generation IV International Forum, 2021

FOREWORD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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Foreword 
In 2020, the Economic Modelling Work Group (EMWG) of the Generation IV International Forum (GIF) convened a 
finance industry taskforce (the Taskforce) to consider the nuclear industry’s ability to report against Environmental, 
Social and Governance data collection and accounting metrics (ESG), and therefore whether nuclear energy should 
be considered as an investable asset class; thereby allowing nuclear companies and projects to access climate 
finance. This report has been produced by the finance community for the finance community. 
Nuclear Energy: An ESG Investible Asset Class has been developed from the discussions of the Taskforce, all of 
whom are listed in Appendix III of this report. The report could not have been produced without their valuable 
contributions, and the contribution and oversight of Fiona Reilly, Co-Chair of the EMWG and Chair of the Taskforce. 
GIF would also like to express its gratitude to the Nuclear Industry Association in the United Kingdom, the Canadian 
Nuclear Association, the Nuclear Energy Institute in the United States, Natural Resources Canada, and the Nuclear 
Innovation and Research Office and the National Nuclear Laboratory in the United Kingdom.  
Scope of the Report 
This report has various sections: 
• 
Climate Financing and Responsible Investment: Sets out the international policy framework and 
background around climate finance including the UN’s Principles of Responsible Investment, the rise of 
ESG reporting and its role in accessing climate finance and the role of taxonomies and how they fit, or 
rather do not fit, with ESG reporting; 
• 
Low Carbon ESG Reporting: Provides a very high-level overview of how low carbon energy companies 
and/or projects could report against ESG; 
• 
Nuclear Disclosures Against ESG: Demonstrates the nuclear industry’s ability to report against ESG and 
why it is an investable asset class, if projects and companies are established and managed well;  
• 
Appendix I Standard Metrics:  The Taskforce mapped the WEF ESG against relevant SASB and TCFD ESG 
to create a consolidated list of ESG, which are used in this report; and 
• 
Appendix II Consistent and Transparent Reporting: Provides significantly more details and cross-
references for the finance community and wider stakeholders to use when considering nuclear companies 
and projects reporting together with some analysis where other energy companies could follow the 
nuclear industry’s lead in their ability to report against ESG.  
It is hoped, and intended, that this report develops into a living document that is used by the finance industry as a 
reference and guide to use when considering nuclear companies and their assets.

TABLE OF CONTENTS 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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Table of contents 
Nuclear Energy: An ESG Investable Asset Class .................................................................................................... 1 
Foreword ............................................................................................................................................................ 3 
Scope of the Report ............................................................................................................................................ 3 
Table of contents ................................................................................................................................................ 5 
List of abbreviations and acronyms ..................................................................................................................... 7 
Executive summary ........................................................................................................................................... 11 
Governance ........................................................................................................................................................... 12 
Planet .................................................................................................................................................................... 13 
People ................................................................................................................................................................... 13 
Prosperity .............................................................................................................................................................. 14 
References ............................................................................................................................................................. 15 
Introduction and background ............................................................................................................................ 17 
Nuclear and renewables combine to address climate change .............................................................................. 17 
International policy framework ............................................................................................................................. 18 
References ............................................................................................................................................................. 19 
Climate financing and responsible investment .................................................................................................. 21 
Environmental, Social and Governance (ESG) ....................................................................................................... 21 
UN Principles of Responsible Investment ............................................................................................................. 22 
Standardising ESG ................................................................................................................................................. 22 
Green bond principles ........................................................................................................................................... 23 
Taxonomies ........................................................................................................................................................... 24 
References ............................................................................................................................................................. 29 
Low Carbon ESG Reporting ................................................................................................................................ 31 
Overview of energy companies / projects reporting ............................................................................................ 31 
Nuclear disclosures against ESG ........................................................................................................................ 35 
Governance: SDGs 12, 16 and 17 .......................................................................................................................... 35 
Planet: SDGs 6, 7, 12, 13, 14 and 15 ...................................................................................................................... 40 
People: SDGs 1, 3, 4, 5 and 10 .............................................................................................................................. 49 
Prosperity: SDGs 1, 8, 9 and 10 ............................................................................................................................. 53 
References ............................................................................................................................................................. 57 
Appendix I. Standard ESG  – World Economic Forum, Sustainability Accounting Standards Board (SASB) and Task 
Force on Climate-related Financial Disclosures (TCFD) ....................................................................................... 59 
General .................................................................................................................................................................. 59 
Governance: SDGs 12, 16 and 17 ......................................................................................................................... 61

TABLE OF CONTENTS 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Planet: SDGs 6, 7, 12, 13, 14 and 15 ..................................................................................................................... 62 
People: SDGs 1, 3, 4, 5 and 10 .............................................................................................................................. 65 
Prosperity: SDGs 1, 8, 9 and 10 ............................................................................................................................ 67 
Appendix II. Consistent and transparent reporting ............................................................................................ 69 
Governance: SDGs 12, 16 and 17 ......................................................................................................................... 69 
Planet: SDGs 6, 7, 12, 13, 14 and 15 ..................................................................................................................... 77 
People: SDGs 1, 3, 4, 5 and 10 ............................................................................................................................ 102 
Prosperity: SDGs 1, 8, 9 and 10 .......................................................................................................................... 112 
References ........................................................................................................................................................... 123 
Appendix III. The Taskforce ............................................................................................................................. 129 
Appendix IV. Glossary ..................................................................................................................................... 131

LIST OF ABBREVIATIONS AND ACRONYMS 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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List of abbreviations and acronyms 
oC 
Degrees Celsius 
AUM 
Assets under management  
BAT 
Best available techniques  
BEP 
Best environmental practice  
Bq 
Becquerel 
CAPEx 
Capital expenditure 
CCS 
carbon capture and sequestration  
CO2 
carbon dioxide  
c.  
Circa/approximately  
DAWN 
Driving the Advancement of Women in Nuclear (Canada) 
DGR 
Deep geological repository  
DNSH 
do no significant harm  
EC 
European Commission 
EPC 
Engineering, procurement and construction  
ESG 
Environmental, social and governance data collection and 
accounting metrics 
EU 
European Union 
FOAK 
First of a kind 
FSA 
Fuel supply agreement  
GBP 
Green Bond Principles 
Gen-III+/Gen-IV 
Generation III+ or Generation IV (reactors) 
GHG 
Greenhouse gas (emissions) 
G7 
The Group of Seven 
GVA 
Gross value added 
GW 
Gigawatt 
HLW 
High-level waste  
ICRP 
International Commission for Radiation Protection  
ICRU 
International Commission on Radiation Units and Measurements  
IAEA 
International Atomic Energy Agency 
IEA 
International Energy Agency 
ICMA 
International Capital Market Association

LIST OF ABBREVIATIONS AND ACRONYMS 
8 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
ILW 
Intermediate-level waste  
IPCC 
Intergovernmental Panel on Climate Change  
JRC 
Joint Research Centre (EU) 
kw 
Kilowatt 
kWh 
Kilowatt hour 
LCA 
Lifecycle assessment  
LLW 
Low-level waste  
LTO 
Long-term operation  
mSv 
Millisieverts 
MWe 
Megawatt electric  
NDC 
Nationally determined contributions (Paris Agreement) 
NEA 
Nuclear Energy Agency 
NEET 
(youth) not in education, employment or training  
NEI 
Nuclear Energy Institute (United States) 
NOx 
nitrogen oxide (NOx)  
NOAK 
NPT 
Next of a kind/ Nth of a kind 
Treaty on the Non-Proliferation of Nuclear Weapons 
OECD 
Organisation for Economic Co-operation and Development 
PRI 
Principles for Responsible Investment (United Nations) 
RO 
Reverse osmosis  
SASB 
Sustainability Accounting Standards Board 
SDGs 
Sustainable Development Goals (United Nations) 
SFAC 
Sustainable Finance Action Council (Canada) 
SOx 
Sulphur oxide  
SPV 
Special purpose vehicle  
TBq 
Terabecquerel 
tCO2e 
Metric tonnes of carbon dioxide equivalent  
TEG 
Technical expert group  
R&D 
Research and development 
TCFD 
Task Force for Climate-Related Financial Disclosures 
WEF 
World Economic Forum 
UN 
United Nations 
UNFCCC 
United Nations Framework Convention on Climate Change 
VAT 
Value added tax 
VLLW 
Very low-level waste  
WANO 
World Association of Nuclear Operators  
WEF 
World Economic Forum

LIST OF ABBREVIATIONS AND ACRONYMS 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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WNA 
World Nuclear Association

EXECUTIVE SUMMARY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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Executive summary 
In the last ten years, access to climate finance – focusing on creating a positive impact on global society through 
ethical, socially responsible and eco-friendly value - has become a major focus of the finance industry. Against the 
background of the United Nations (UN) Framework Convention on Climate Change, the Kyoto Agreement, and more 
recently the Paris Agreement, investors have sought to integrate ethics, governance, social value and environmental 
concerns into their investment strategies. This report has been drafted by the finance community for the finance 
community to use when considering whether nuclear assets are investable. 
The UN Principles for Responsible Investment (PRI) set out principles which are linked to Environmental, Social 
and Governance data collection and accounting metrics (ESG) for the investment community. More than 3,657 
investors have signed up to the PRI Principles. These investors are responsible for c. USD 104 trillion assets under 
management.  
ESG have been adopted by the investment community, against which companies or projects report in order to 
demonstrate their credentials. In other words, ESG are integrated into the investment decision-making process such 
that each investment is analysed for the potential level of ESG risk and impact that it may have. The assessment is 
not a binary screening but considered as a balanced scorecard i.e., on balance does the company report well. The 
risk is that companies reporting are potentially unethical, lack governance, are not socially responsible and/or are 
not eco-friendly. ESG are not only used for screening investment opportunities but also for assessing a company’s 
continuing performance.  
ESG reporting is undertaken by individual companies and projects rather than by an industry as a whole. This 
report is, therefore, intended to provide guidance to the finance community and wider stakeholders on how nuclear 
assets could report against ESG, rather than removing the requirement for each company to report against ESG. 
What are ESG? 
ESG are Environmental, Social and Governance data collection and accounting metrics. 
Companies report on ESG to any investors/ financiers who are invested in their company / project; and/or any investors/ 
financiers they want to invest in their company/ project. 
ESG are not a pass or fail test but a balanced scorecard against which financiers and investors assess their investments 
or assess whether they will invest, examining whether a company is well run, ethical socially responsible and eco-
friendly. 
The term ESG is often misused to refer to vague environmental, social and governance concepts rather than to data 
collection and accounting metrics.  
 
Nuclear energy, in combination with renewables, is the only way for countries to meet their nationally 
determined contributions (NDC) under the Paris Agreement and their Net-Zero commitments. As Barclays noted in 
their report “Nuclear for a decarbonized future”: “Nuclear’s high load factors and reliability could make achieving 
net-zero affordable.” (Barclays, 2021) Inconsistency in applying ESG reporting has nevertheless resulted in nuclear 
power having a higher hill to climb than other low-carbon energy sources.  
This report establishes not only how nuclear energy, as an asset class, has the potential to report well against 
a wide range of ESG; it highlights the importance of wide ranging, consistent and standardised ESG reporting to 
determine the credentials of all energy companies across their lifecycles and throughout their supply chains. The 
report discusses how ESG fit within international frameworks, including the UN Framework Convention on Climate 
Change (1992), the Kyoto Protocol (1997) and the Paris Agreement (2015), and how ESG are linked to the Green 
Bond Principles, while examining the relationship between ESG and the various taxonomies and other policy 
documents being developed around the world.

EXECUTIVE SUMMARY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
To obtain the greatest benefit from the adoption of ESG, consistency is essential, not only in terms of the ESG, 
but also in terms of how assets are intended to report and therefore how the investment community should assess 
ethics, governance, social value and environmental concerns. Requiring all companies to report against ESG in a 
consistent manner will allow for a level playing field across technologies. In other words, ESG need to be applied 
consistently across asset classes.  
One of the difficulties with ESG is that historically each institution has had its own set of ESG, and they are 
applied inconsistently. In 2020, the World Economic Forum (WEF) carried out a consultation and reported on the 
outcome of the consultation to propose a common set of ESG, with the aim of aligning mainstream reporting on 
performance against ESG. The Generation IV International Forum (GIF), and in particular the Taskforce, welcome 
the WEF 2020 consultation and report: “Towards Common Metrics and Consistent Reporting of Sustainable Value 
Creation”, (WEF, 2020). However, to address comments raised by the finance and energy industries, the WEF ESG 
have been mapped against the relevant standards of the Sustainability Accounting Standards Board (SASB) and the 
Task Force for Climate Related Financial Disclosure (TCFD) to create a consolidated list (see Appendix I), which is 
used through-out this report. 
The WEF defined four pillars of ESG: Governance, Planet, People and Prosperity. Under each pillar there are a 
set of ESG (see further details below). A great deal of the focus (including on the part of those looking at taxonomies) 
is on the ESG covered by the Planet metrics – namely climate change, including greenhouse gas (GHG) emissions, 
and waste management and mitigation. However, ESG address a much larger range of metrics to produce a balanced 
scorecard.  
The Taskforce assessed each ESG in the order that it was developed by the WEF. In doing so, it was recognised 
that for a truly complete reporting exercise, each asset should not only consider the full lifecycle of the asset but 
also the supply chains used during that lifecycle; there should be a move for all assets to reports on this full basis. 
Nuclear energy, as an asset class, has the ability to report well against many of the ESG identified in this report. It is, 
however, the responsibility of each company and each asset to develop and maintain the company and asset in a 
manner that will enable consistent reporting across the full scope of ESG. 
Governance  
• 
The governance metrics are: governing purpose; the quality of the governing body, including board 
composition and remuneration; stakeholder engagement including buy-in, impact and process; ethical 
behaviour and anti-corruption, ethics and reporting; and risk and opportunity oversight including integrating 
risks and opportunities such as climate change risk. 
• 
The governance metrics are largely asset specific including whether the governing purpose of the company is 
established and maintained, and whether the company is managed at the highest standards including having 
a strong and diverse board which is properly remunerated. As with the energy sector as a whole, the nuclear 
sector is improving its Board diversity credentials, but there is still more to be done.  
• 
Open and transparent stakeholder engagement also falls within these metrics, an area where the energy sector 
as a whole would generally report well. Stakeholder mapping for the nuclear sector has always been wide 
ranging and continues to be monitored throughout the lifetime of the asset. Transparency and openness vis-
á-vis a broad range of stakeholders is something that the nuclear industry has managed well, particularly in 
more recent years. Stakeholders with whom the nuclear industry liaises include governments and 
governmental departments, local and regional communities, schools and universities.  
• 
The ethical behaviour and risk oversight and management metrics are wide-ranging and place obligations on a 
company in relation to not only its own behaviour but also its supply chain and lifecycle. Again, this is something 
the nuclear industry can report well. The industry has long been aware of its need to behave ethically and to 
manage and mitigate risks to the highest standards. The nuclear industry takes unethical behaviours very 
seriously and assesses not only its own company’s behaviour but that of the supply chains across the whole 
lifecycle.  Although reporting on these metrics will be company-specific, nuclear companies often have gold 
standard training in place for all employees to ensure that best practice is understood for anti-bribery and 
corruption practices, what to look out for and how scenarios should be assessed; as well as money laundering 
processes and procedures and how inappropriate incidents should be reported within the company.  
• 
Nuclear regulation also has a role to play in maintaining the highest standards of behaviour. The Knowledgeable 
Customer and Safeguards regimes, together with nuclear health and safety standards and Export Controls are

EXECUTIVE SUMMARY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
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vital to regulatory compliance in nuclear corporate governance, helping to maintain both ethical behaviour and 
proper risk management.  
Planet  
• 
The Planet metrics are: climate change including GHG; nature loss, including land use and ecological sensitivity; 
fresh water availability, including consumption and management; pollution; waste, including management & 
mitigation; and resources. 
• 
The role of nuclear as a low-carbon technology is becoming widely accepted with many governments, 
philanthropists and even some environmental NGOs, recognising nuclear energy’s role in meeting Net-Zero 
commitments. Different reports show how nuclear can report that its GHG emissions are comparable with 
wind projects and lower than solar projects. 
• 
The area that is often cited as the concern for nuclear fission is around waste management and mitigation. 
However, it is becoming recognised that waste is a concern across the whole of the energy sector. There is 
more of a focus on the waste and emissions from technologies such as wind, solar and batteries. The more 
companies can address waste mitigation and management concerns the better. For a long time, nuclear has 
had processes and procedures in place to plan, manage and mitigate the waste arising from the plant including 
establishing funds to cover the costs of decommissioning the site, remediating the land and managing and 
mitigating waste. There is more that can be done, but nuclear leads the energy sector in decommissioning and 
the mitigation and management of waste. Solar companies are beginning to adopt similar waste management 
and mitigation measures, including pre-funding decommissioning and waste management. However, the wind 
sector only just beginning to consider how it should deal with decommissioning and management and 
mitigation of its waste. A consistency in approach across all technologies is vital. 
• 
The remaining metrics under the Planet pillar relate to the nature use, including land and water, the effects on 
the environment and ecology through land use, pollution and emissions and also the resources utilised in the 
production of energy, and how those resources are maintained and not depleted. 
• 
All energy projects will involve some loss to nature and the environment. The interrelationship between land 
use and energy is a complex balance. Energy is needed for the socio-economic development of regions and 
countries, but this needs to be balanced with the efficient and effective use of land, which is also needed for 
other activities including the production of crops and food. Therefore, the efficient use of land for the 
production of energy is an important factor to be considered.  Consideration should be given to the average 
energy produced per kilometre of land – average wind farms produce 0.77MWh; average solar farms produce 
1MWh and average small nuclear reactors produce 14.5MWh. 
• 
All energy plant utilise water. Some use it and others consume it. Nuclear uses a lot of water and yet has little 
effect on the water it uses. It can also be used for desalination thereby helping to provide fresh water, where 
needed.  
• 
Again, all energy projects create pollution to air, land and sometimes water.  For land and air, when considering 
particulates matter, nitrogen oxide (NOx) and sulfur oxide (SOx), nuclear and onshore wind are similar. For 
water pollution, nuclear projects often perform better than renewables. 
• 
Resources, created by nature, are scarce and need managing well. However nuclear resources are not at risk 
of being over-utilised (particularly when combined with the development in nuclear technologies) whereas 
other resources used in energy projects, including cobalt and lithium, are.  
• 
The mining of resources is a key concern across a number of technologies. Uranium mining is undertaken under 
strict regimes, but this is not necessarily the case for other mining activities. All mining activities should report 
against ESG to ensure that mining is undertaken in an ethical and eco-friendly way, while maintaining proper 
governance and creating social value.  
People  
• 
The People metrics are: dignity and equality, including diversity, inclusion, harassment, pay equality and pay 
gaps, wages levels and living wage, human rights, slavery and child labour; health and well-being including

EXECUTIVE SUMMARY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
health & safety (workforce and third parties), nuclear safety and emergency management, incidents on sites, 
well-being and impact; and skills for the future including training, recording the number of unskilled vacancies 
and the impact on the company. 
• 
Lack of diversity remains an issue for the energy sector as a whole. However, nuclear appears to be performing 
marginally better in relation to gender diversity but not in relation to wider diversity criteria, where it is similar 
to the rest of the energy industry. This is something the energy sector as whole needs to improve.  
• 
Energy companies and projects should have well managed policies and procedures on pay and remuneration. 
The energy sector wants to attract bright and diverse individuals who can develop the industry and deliver high 
quality and high performing projects and companies. Further work is needed across the sector. 
• 
Without proper checks and balances a company’s activities could facilitate human rights abuses and other 
social and environmental abuses. Without mechanisms for employees and stakeholders to report potential 
abuses, companies might miss the opportunities to identify, mitigate and manage activities. The nuclear 
sector’s focus on safety and compliance helps to mitigate some of these risks but investors will need to assess 
each company’s reporting on these matters. This also extends to ensuring there are no risks of incidents of 
child, forced or compulsory labour across their supply chains. An explanation of labour practices across the 
whole supply chain need to be disclosed by the executive and the board. The elimination of child labour and 
forced labour requires companies to be open and transparent and to assess their supply chain ethics.  Nuclear 
companies must investigate their supply chain in great detail to ensure regulatory compliance, which should 
protect against these practices. However, concerns are being raised in relation to the mining of rare earth, 
lithium and cobalt; there needs to be proper reporting against all mining activities across the energy sector to 
ensure ethical and eco-friendly practices, while maintaining proper governance and creating social value. Only 
through openness and transparency by businesses and financial institutions will these unethical practices be 
eradicated. 
• 
The nuclear industry has long been at the forefront of both general health and safety management (particularly 
physical but also mental health) and also nuclear specific health and safety. The global nuclear industry takes 
health and safety incredibly seriously. The nuclear sector has a wide range of health and safety regulations and 
systems in place to protect not only its workers (direct employees and through-out supply chains) but also third 
parties. 
• 
The energy sector is generally good at training and development, and at providing skills for the future. The 
nuclear sector has spent considerable time and effort in maintaining its skills and developing skills for the future 
(on existing and future technologies). The renewables sector is a newer industry and therefore has not has to 
consider maintaining skills for the future in the same way, and therefore any reporting will be more asset 
specific.  
• 
In many countries, nuclear has had to invest heavily in upskilling. This is partially due to the hiatus in the 
construction of new nuclear power plants, in some parts of the world. Also, many people working on existing 
plants and sites are reaching retirement age and so the nuclear industry has had to spend considerable efforts 
to bringing in the younger generation, this is particularly true in Western countries. Companies have 
implemented training and apprenticeships to bring in new people to the industry across various skills to protect 
the industry for the future. 
Prosperity  
• 
The Prosperity metrics are: wealth creation and employment; energy affordability; end-use efficiency and 
demand; grid resiliency; innovation in better products and services, including R&D spend and social value 
generated; and community and social vitality, including taxes paid and total social investment. 
• 
These ESG focus on the wider impact of the project, how it impacts greater value add (GVA) across the region 
and the country, including how much tax the company pays and its social and wider investment, its impact on 
the wider energy market in terms of prices but also efficiency and demand and how it impacts the grid resiliency.  
• 
Reporting against these ESG will largely be company or project specific. However, in terms of GVA and wider 
socio-economic impact, nuclear companies and projects have a wider and larger impact than other energy 
projects due to the scale of the projects, the number of direct and indirect long-term jobs created and the long-

EXECUTIVE SUMMARY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
15 
life of the projects. The macro-economic effect of nuclear projects extends through the construction, operation 
and decommissioning phases, resulting in GVA and wider socio-economic impacts for over 100 years.  
• 
In terms of energy affordability, end use and grid resilience, it is key to allow companies and projects to report 
on a level playing field. When considering the levelised costs of the projects and looking at the wider system 
costs associated with intermittent technologies, nuclear is competitive. Also nuclear helps with the resilience 
of the grid as a firm power source.  
• 
Innovation is key to prosperity.  R&D spend is seen as a basic indication of a company’s attempts to innovate 
and therefore be fit for the future. It can also indicate the company’s ability to adapt to new market conditions 
and to create further socio-economic benefits including delivery of SDGs. Nuclear R&D and innovation are 
continuous. The industry constantly looks to find better ways of delivering clean low carbon energy.  
• 
These metrics consider the wider benefits of a company’s activities through taxes paid and social investment. 
It takes into consideration the wider payments into the wider economy both from the company and as 
amplified through the life-cycle and the supply chain. These are company-specific, although all well run energy 
companies should be able to report well against these metrics. 
Nuclear, as an asset class, has the ability to report at least as well as or better than other energy sources against 
all these ESG. Key to reporting is ensuring that companies and projects are established to the highest standards, as 
the industry generally does, but there is also an obligation on the investor community to ask all energy companies 
to report on the wide range of ESG to make sure all projects are considered on a consistent open and transparent 
basis. Nuclear projects are vital to countries meeting their NDCs and Net-Zero commitments. The investment 
community has an obligation to ask companies to report in consistent ways to provide nuclear the opportunity of 
accessing climate finance and making nuclear an investable asset class.  
If countries have any chance of reducing carbon emissions, accelerating their actions and achieving Net Zero by 
2050, they need to have available to them all low-carbon technologies including nuclear – however accessing private 
finance for nuclear projects remains a barrier. It is intended that this report can be utilised by the investment 
community to demonstrate that nuclear should be an investable asset class, whether each company or project 
measures up will be a matter for ESG reporting. 
References 
Barclays (2021), Global Nuclear - Nuclear for a Decarbonized Future, a Barclays Capital Inc. special Report, 
https://app.box.com/s/ooduy5qkpevlb9rj4j7ftzze6ba456zl   
WEF (2020), Measuring Stakeholder Capitalism: Toward Common Metrics and Consistent Reporting of Sustainable 
Value Creation, Prepared in collaboration with Deloitte, EY, KPMG and PwC, World Economic Forum, Geneva, 
www.weforum.org/reports/measuring-stakeholder-capitalism-towards-common-metrics-and-consistent-
reporting-of-sustainable-value-creation.

INTRODUCTION AND BACKGROUND  
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
17 
Introduction and background  
Nuclear and renewables combine to address climate change 
In April 2021, the United States convened a meeting of 40 world leaders in a Virtual Summit on Climate.1 The aim of 
the meeting was to rally the world in tackling the climate crisis and meeting the demands of science. The United 
States and other countries announced ambitious new climate targets. 
More and more work is being undertaken by the scientific and policy communities to ascertain how these 
climate ambitions can be achieved. What is becoming clear, and highlighted in a 2019 report by the International 
Energy Agency, is that nuclear combined with renewables are the only way to meet our climate change obligations. 
As noted in the report: “Nuclear power and hydropower form the backbone of low-carbon electricity generation. 
Together, they provide three-quarters of global low-carbon generation. Over the past 50 years, the use of nuclear 
power has reduced CO2 emissions by over 60 gigatonnes – nearly two years’ worth of global energy-related 
emissions.” (IEA, 2019)   
Bill Gates and other climate change philanthropists have long supported nuclear energy’s role in the fight 
against climate change. “Nuclear energy will ‘absolutely’ be politically palatable…..That’s because the need for clean 
energy is dire, and the operation of nuclear power plants produces no greenhouse gas emissions,” Gates told 
Andrew Ross Sorkin on CNBC’s “Squawk Box” (2021). However, Gates’ support for nuclear is not new. In a 2018 
blogpost, Gates said, “Nuclear is ideal for dealing with climate change, because it is the only carbon-free, scalable 
energy source that’s available 24 hours a day” (Bill Gates, 2018, cited in Hayunga, 2021). Gates and other 
philanthropists are investing heavily in nuclear technologies in support of their belief in nuclear’s role in addressing 
climate change.  
Many countries are recognising that if there is any chance of them meeting their Net-Zero commitments then 
nuclear has to form part of their plans. Countries such as the USA, Canada, the UK, Argentina, Poland and France 
recognise that nuclear power combined with renewables is the only way to achieve Net Zero heat and power. 
Despite the growing recognition of nuclear energy’s role in Net-Zero, one of the biggest challenges facing global 
nuclear projects, whether Generation III+ or Generation IV, is access to financing and particularly climate finance.  
A number of issues have resulted in limited access to private sector investment for nuclear projects (and some 
companies). The issues include: the lack of long-term policy frameworks, the size of equity and debt needed, the 
large CAPEx, and the long-term development and construction periods as well as the challenges developing 
government backed off-take support for assets with such a long life.  Small Generation III+ and Generation IV 
reactors are addressing a number of these concerns by taking much more of a product-based factory build approach, 
thereby producing more certainly on costs and delivery, and delivering at a significantly lower cost and in shorter 
timescales. There is much written on these issues so they are not being revisited in this report. 
However, the issues have resulted in few investors having real experience with nuclear; this of itself breeds 
caution across the finance sector. Clear, transparent and standardised ESG reporting would allow nuclear to 
highlight its value in low carbon economic development.  
 
 
1. 
For more information on this summit, see: www.state.gov/leaders-summit-on-climate/.

INTRODUCTION AND BACKGROUND 
18 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
International policy framework 
The United Nations Framework Convention on Climate Change (1992) was a culmination of extensive work 
undertaken by the United Nations (UN) to address climate change. Article 2 sets out the objective of the convention 
and states: 
The ultimate objective of this Convention and any related legal instruments that the Conference of 
the Parties may adopt is to achieve, in accordance with the relevant provisions of the Convention, 
stabilizing of greenhouse gas concentrations in the atmosphere at a level that would prevent 
dangerous anthropogenic interference with the climate system. Such a level should be achieved 
within a time frame sufficient to allow ecosystems to adapt naturally to climate change, to ensure 
that food production is not threatened and to enable economic development to proceed in a 
sustainable manner (UNFCCC, 1992). 
On 11 December 1997 the Kyoto Agreement to the United Nations Framework Convention on Climate Change 
was entered into force (the Kyoto Protocol). The Kyoto Protocol has been signed by 192 countries and promotes 
sustainable development activities. The Kyoto Agreement was seen as a landmark environmental treaty as it 
represented the first-time nations agreed to legally mandate country-specific emission reduction targets. 
At the United Nations Climate Change Conference in Paris (COP 21), governments agreed to intensify their 
efforts against climate change. The Paris Agreement is a legally binding international treaty which was adopted on 
12 December 2015 and entered into force on 4 November 2016. To date, 197 countries have signed the Paris 
Agreement. 
Under the Paris Agreement, the parties agree to limit global warming to below 2 degrees Celsius (2°C), and 
preferably to 1.5°C (compared to pre-industrial levels). The parties aim to reach global peaking of greenhouse gas 
(GHG) emissions as soon as possible and to achieve a climate neutral world (Net Zero) by 2050. The Paris Agreement 
provides a framework for financial, technical and capacity building to support countries who need it. The financial 
aspects are the focus of this paper. 
Unlike the Kyoto Protocol, which established a top-down legally binding emissions reduction target for 
developed countries only, the Paris Agreement requires all countries to reduce greenhouse gas (GHG) emissions – 
but countries set their own emissions targets in line with their development status and their economic and social 
transformation possibilities. Targets are set through Nationally Determined Contributions (NDCs). While the Kyoto 
Protocol includes penalties for noncompliance, the Paris Agreement does not.  The Paris Agreement does however 
have robust systems of monitoring, reporting and assessing targets. 
By 2020 countries submitted their plans for climate action, their NDCs. The UK was the first G7 country to pass 
a Net Zero emissions law in 2019. Sweden, France, Denmark, Hungary, Japan, South Korea, China, New Zealand and 
the USA have also passed laws formally establishing Net-Zero targets and similar legislation is proposed in the EU, 
Spain, Canada, Chile and Fiji. To date, 192 countries have filed their NDCs with the UN, and nations accounting for 
half of the world’s economy have now committed to the emission reductions needed globally to aim to limit global 
warming to 1.5°C .2  
The Paris Agreement reaffirms that developed countries should take the lead in providing financial 
assistance to countries that are less endowed and more vulnerable, while for the first time also encouraging 
voluntary contributions by other parties. Finance is needed for mitigation because large-scale investments are 
required to significantly reduce emissions. Finance is equally important for adaptation, as significant financial 
resources are needed to adapt to the adverse effects and reduce the impacts of a changing climate. 
The 26th UN Climate Change Conference of the Parties (COP 26) is due to take place in Glasgow in the United 
Kingdom in November 2021. The aim of the conference is to accelerate action towards the goals of the Paris 
Agreement, as little has been achieved in the last five years. 
 
 
 
2. 
A register of these NDCs can be found at: www4.unfccc.int/sites/ndcstaging/Pages/LatestSubmissions.aspx.

INTRODUCTION AND BACKGROUND  
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
19 
References 
CNBC (25 February 2021), “Squawk Box”, CNBC, www.cnbc.com/2021/02/25/bill-gates-nuclear-power-will-
absolutely-be-politically-acceptable.html (accessed on 28 July 2021). 
IEA (2019), Nuclear Power in a Clean Energy System, IEA, Paris, www.iea.org/reports/nuclear-power-in-a-clean-
energy-system. 
Hayunga, R. (2021), “Bill Gates Talks About the Potential of Nuclear Innovation on ’60 Minutes’”, Nuclear Energy 
Institute, Blog, www.nei.org/news/2021/bill-gates-nuclear-innovation-60-minutes (accessed on 28 July 2021). 
UN (1992), “United Nations Framework Convention on Climate Change”, United Nations, New York, 
https://unfccc.int/files/essential_background/background_publications_htmlpdf/application/pdf/conveng.pdf. 
WEF (2020), Measuring Stakeholder Capitalism: Toward Common Metrics and Consistent Reporting of Sustainable 
Value Creation, Prepared in collaboration with Deloitte, EY, KPMG and PwC, World Economic Forum, Geneva, 
www.weforum.org/reports/measuring-stakeholder-capitalism-towards-common-metrics-and-consistent-
reporting-of-sustainable-value-creation.

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21 
Climate financing and responsible investment 
According to the United Nations, climate finance refers to: 
…local, national or transnational financing – drawn from public, private and alternative sources of 
financing – that seeks to support mitigation and adaptation actions that will address climate change. 
The Convention, the Kyoto Protocol and the Paris Agreement call for financial assistance from Parties 
with more financial resources to those that are less endowed and more vulnerable. This recognizes 
that the contribution of countries to climate change and their capacity to prevent it and cope with its 
consequences vary enormously. Climate finance is needed for mitigation, because large-scale 
investments are required to significantly reduce emissions. Climate finance is equally important for 
adaptation, as significant financial resources are needed to adapt to the adverse effects and reduce 
the impacts of a changing climate. (UN, 2021) 
Against the background of the UNFCCC, the Kyoto Protocol and latterly the Paris Agreement, particularly in the 
last 10 years, investors have sought to integrate social and responsible investment concerns into their strategies, 
thereby focusing on creating a positive impact on global society.  
The main focus of this report is ESG, which companies and projects report against for the investment 
community to determine whether investments meet their ethical, socially responsible and eco-friendly standards. 
In addition, the finance industry has developed the Green Bond Principles (GBP), which cross over significantly with 
ESG. 
In addition to ESG and GBP, governments are developing taxonomies which are policy frameworks documents. 
The distinction between ESG and taxonomies is discussed in further detail below. 
As ESG reporting becomes standardised, they should be at the forefront of determining whether companies 
and projects should be able to access climate finance i.e., can the company report a positive impact on global society 
through ethical, socially responsible and eco-friendly value creation.  The Taskforce understands that the US 
Government is considering leading the way in this regard by not having a sustainable investment taxonomy but by 
requiring greater reporting against ESG. 
Environmental, Social and Governance (ESG) 
ESG have been developed as a set of standards that socially conscious investors use to screen potential investments 
by asking companies and projects to report against them. They are an increasingly popular way for investors to 
evaluate companies in which they might want to invest. They can also help investors avoid companies that might 
pose a greater financial risk due to their environmental or other practices. 
In years past, socially responsible investments had a reputation for requiring a trade-off on the investor's part, 
limiting the universe of companies that were eligible for investment, and also limiting the investor's potential profit. 
So-called "Bad" companies sometimes performed very well, at least in terms of their stock price. 
More recently, however, some investors have come to believe that ESG have a practical purpose beyond any 
ethical concerns. By following ESG they may be able to avoid companies whose practices could signal a risk factor 
— as evidenced by BP's oil spill in 2010 and Volkswagen's emissions scandal in 2015, both of which rocked the 
companies' stock prices and resulted in billions of dollars in associated losses. Further, ethical companies are 
sacrificing profits in order to behave responsibly.  
As ESG-minded business practices gain more traction, investment firms are increasingly tracking their 
performance. Financial services companies such as JPMorgan Chase, Wells Fargo, and Goldman Sachs have 
published annual reports that extensively review their ESG approaches and the bottom-line results.  As noted in the 
Harvard Business Review’s ESG spotlight from September 2020: 
 “…following the spread of COVID-19, most ESG funds outperformed their benchmarks. And when colleagues 
and I looked at data for more than 3,000 firms between late February and late March 2020 – when global financial

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
markets were collapsing – we found that the ones the public perceived as behaving more responsibly had less-
negative stock returns than their competitors.” (Serafeim, 2020)  
UN Principles of Responsible Investment 
The UN’s Principles of Responsible Investment (PRI) set out principles linked to ESG for the investment community.  
In 2005, the United Nations Secretary General, Kofi Annan, invited a group of the world’s largest investors to develop 
the PRI. The PRI were launched in 2006. Since then, 3657 asset owners, investment managers and service providers 
have become signatories. The PRI are a voluntary and aspirational set of investment principles that offer a menu for 
possible actions for incorporating ESG issues into investment practice. They were developed by investors for 
investors.  
Signatories to the PRI agree to the following: 
"As institutional investors, we have a duty to act in the best long-term interests of our beneficiaries. 
In this fiduciary role, we believe that ESG issues can affect the performance of investment portfolios 
(to varying degrees across companies, sectors, regions, asset classes and through time). 
We also recognise that applying these Principles may better align investors with broader objectives of 
society. Therefore, where consistent with our fiduciary responsibilities, we commit to the following: 
• 
Principle 1: We will incorporate ESG issues into investment analysis and decision-making 
processes. 
• 
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies 
and practices. 
• 
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we 
invest. 
• 
Principle 4: We will promote acceptance and implementation of the Principles with the 
investment industry. 
• 
Principle 5: We will work together to enhance our effectiveness in implementing the 
Principles. 
• 
Principle 6: We will each report on our activities and progress towards implementing the 
Principles.” (UNPRI, 2021a) 
The PRI 2020 Annual Report records:  
Despite the pandemic, our signatory base has continued to grow over the past year. The collective 
AUM represented by PRI signatories increased by 20% from US$86.3 trillion to US$103.4 trillion as of 
31 March 2020, representing 3038 signatories. (UNPRI, 2021b)  
Their signatories have increased to 3657 since the publication of the report.  
ESG is integrated in the investment decision making process, such that all types of investments are analysed 
for the potential level of ESG risk and impact it has. It should be noted the ESG are not a pass or fail test but are 
used as an assessment tool to consider the overall profile of a project or company. 
In this paper we discuss nuclear’s role in providing a leading low-carbon energy source and how it performs 
against a wide range of ESG.  
Standardising ESG 
ESG broadly cover: 
• 
Environmental metrics such as a company’s energy use, waste, pollution, natural resource conservation, and 
treatment of animals; 
• 
Social metrics including how a company manages relationships with employees, suppliers, customers, and 
stakeholders. These metrics can consider a company’s relationships, its GVA and how socially responsible it is; 
and

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23 
• 
Governance metrics covers a company’s governing purpose, its Board, its executive, diversity and inclusion and 
ethical behaviours. 
No single company will successfully report against each ESG. Responsible and ethical companies are likely to 
produce a balanced scorecard. Equally, the balance of the metrics may change because of factors such as the country 
in which the company operates or is to operate, and wider development goals.  
Historically, each financial institution has applied ESG in their own way. While there is a more consistent 
approach being developed and there is a move towards harmonisation, there is currently a lack of standardisation 
across ESG. Different institutions have defined different sets of metrics and each financial institution has had its own 
set of metrics.  This includes the rating agencies Fitch, Standard & Poor’s and Moody’s, who have each have 
incorporated ESG into their credit rating methodologies.  
As stated by the European Investment Bank, there is a need for a common language in climate finance, which 
could be developed through the ESG framework. 
This lack of consistency and transparency has resulted in each financial institution and investor reviewing assets 
on different criteria. As a minimum, this has resulted in assets being reviewed in an inconsistent way and at worst 
it has allowed entities, including countries, to place much more stringent reporting metrics on some assets over 
others, allowing what has become known as “green-washing”.  
In January 2020, the World Economic Forum (WEF) issued a consultation, which was prepared in collaboration 
with Deloitte, EY, KPMG and PwC. The consultation proposes a common set of metrics and recommended 
disclosures that could be used to align mainstream reporting, and thereby reduce fragmentation and encourage 
faster progress towards a systemic solution, and ideally to produce an international accounting standard. Their 
objective was to amplify those standards rather than to create new standards all together.  
The WEF reported on its consultation in September 2020 with the report Measuring Stakeholder Capitalism: 
Toward Common Metrics and Consistent Reporting of Sustainable Value Creation (WEF, 2020). The WEF common 
metrics fall under four pillars: Governance, People, Planet and Prosperity. A set of ESG sit beneath each pillar. 
The Taskforce welcomes the WEF report and has adopted their metrics in this report. However, in discussions 
amongst the Taskforce it became clear that companies were also looking to the Sustainable Accounting Standard 
Board (SASB) and the Task Force for Climate Related Financial Disclosure (TCFD) standards. Views were expressed 
that SASB metrics are used more by corporates who have existing energy assets whereas TCFD is used more by the 
project finance community. The Taskforce mapped the WEF metrics with the SASB and TCFD metrics to take on 
board these views. This can be found in Appendix I.  
The remainder of this report therefore adopts the ESG mapped in Appendix I, for the reporting. Any deviation 
from the common metrics will be identified.  
Green bond principles  
The Green Bond Principles (GBP) were developed to enable capital-raising and investment for new and existing 
projects with environmental benefits. “The GBP are voluntary process guidelines that recommend transparency and 
disclosure and promote integrity in the development of the green bond market by clarifying the approach for 
issuance of a Green Bond” (ICMA, 2018). Many of the GBP align with ESG, and therefore in adopting the wide range 
of ESG investors will be able to determine whether assets are investable and eligible for both climate finance and 
Green Bonds. 
The GBP sets out the guidelines for transparency, disclosure and reporting in order to promote the integrity of 
the green bond market as well as drive the provision of the information required by the market in order to promote 
greater capital allocation to eligible projects. The GBP were established by a consortium of investment banks, with 
the ongoing monitoring and development now migrated across to being managed by the International Capital 
Market Association (ICMA).  
Green bonds are any type of bond instrument where the proceeds will be exclusively applied to 
finance or re-finance projects with clear environmental benefits and which are aligned with the four 
core components of GBP: 
• 
use of proceeds – the utilisation of the proceeds of the bond for “green projects” which 
have to be sufficiently described in the legal documentation. Clear environmental benefits

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
need to be assessed and ideally quantified. The GBPs recognise several broad categories 
which are eligible for Green Bonds including climate change mitigation; 
• 
process of project evaluation and selection – the issuer should outline the investment 
decision-making process to determine the eligibility of projects using the process for 
determining that a project is an eligible green project which includes how material 
environmental and social risks are to be managed; 
• 
management of proceeds – the funds and proceeds need to be managed and tracked in an 
appropriate and transparent manner and independently audited; and 
• 
reporting (pre-issuance and ongoing) – subject to confidentiality undertakings, reporting on 
an annual basis until the bond is fully allocated and then on a regular appropriate basis. 
(ICMA, 2018) 
The focus on the use of proceeds seeks to guide issuers towards an integrated business model which 
incorporates greater environmental and social value components to their projects. The principles also recommend 
green bond issuers to undergo a third-party verification/certification to establish that the proceeds are funding 
projects that would produce an environmental benefit, however there is no formal certification for a bond to be 
labelled as “Green”. 
While the GBP are voluntary and suggest broad “green” categories (developed by the private sector) and issuers 
are encouraged to consider these categories and the existing green bond standards, issuers can develop their own 
framework and ignore the principles. In considering acceptable categories and whether to issue a bond, the issuers 
can consider other initiatives, for example the Climate Bonds Initiative. It should be noted that while recognising 
nuclear energy’s low-carbon credentials, under the Climate Bond Initiative nuclear is in the “more work required” 
category i.e. not currently included but being contemplated and sitting with other technologies, including waste to 
energy, large hydro and carbon capture and sequestration (CCS). 
Nuclear is included in the European Investment Bank Climate Action List of eligible sectors and eligibility criteria. 
However, the European Investment Bank (which has issued over nineteen billion euros (EUR 19bn) of green bonds 
over the last ten years, including a 30-year Climate Awareness Bond issued in June 2017), has still not issued any 
bonds for nuclear projects. 
Alignment to the United Nations Sustainable Development Goals (SDGs) does not automatically mean that 
projects would align with the GBPs or ESGs. However, it is recognised by the United Nations and the International 
Atomic Energy Agency (IAEA) that nuclear plays an important role in the SDGs.1  Further alignment of the SDGs, ESG 
and the GBPs can only assist in developing market acceptance of nuclear for the green bond and other financial 
markets. 
Taxonomies 
General overview of taxonomies 
This section provides an overview of some of the taxonomy policies being developed around the world. Various 
taxonomies and policies are in different stages of development, and therefore, there are different levels of detail 
for different policy frameworks. 
A taxonomy is intended to be a classification system created to help investors and companies make informed 
investment decisions on environmentally friendly economic activities. Sustainable finance taxonomies are being 
developed by governments to be used as tools to grow the clean economy of the future and improve the 
environmental performance of industries.  
This is in contrast to ESG, which is the reporting methodology used by the investment community. Some 
countries, such as the US, are considering leading the way by not having a sustainable investment taxonomy but 
requiring greater reporting against ESG, The Taskforce supports this approach. 
 
1.  
Further details on nuclear energy’s role in the SDGs can be found at: www.iaea.org/about/overview/sustainable-
development-goals.

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25 
As a tool, taxonomies are policy documents which are intended to spur sustainable investment and improve 
market clarity and integrity. However, they are being used to assess activities to determine whether broad asset 
classes are “sustainable”2 or not, and therefore whether they should be able to access climate finance.  Each country 
has its own environmental and socio-economic objectives set out in NDCs and other documents, and as such, their 
respective taxonomies may differ.  While a clear global policy framework would be helpful to the markets, such 
policies should not contravene another country’s own jurisdiction to determine its own energy policy, nor should 
they be used to broadly assess technologies and assets. ESG should be used to assess assets and individual 
companies or projects to determine whether they are investable assets able to access climate finance. Unfortunately, 
taxonomies could be used to restrict access to climate finance. The roles of taxonomies and ESG need to be clarified.  
It should be noted, governments are always free to set policy to favour some technologies over another or to 
disqualify a technology from being used in their jurisdiction. However, this political determination should not drive 
the designation of an activity as “sustainable and thereby investable.  An efficient and effective policy should set 
standards for outcomes and remain technology agnostic. As such a fair taxonomy would adopt the ESG to determine 
access to finance, rather than attempting to predetermine “sustainability” and ethics by reference to asset classes.  
The current lack of consistency in the definitions of “green” and “sustainable” investments across jurisdictions 
results in barriers to scaling up ethical, socially responsible and eco-friendly investment, rather than in supporting 
investment. Convergence towards commonly accepted definitions is key to maximising the effectiveness, efficiency 
and integrity of the market for sustainable finance. 
Properly structured, taxonomies could greatly simplify the assessment of what is and is not socially responsible 
investment. Caution should be taken to not be too simplistic, as in their current forms taxonomies tend towards a 
pass or fail structure (i.e. an activity is environmentally “sustainable” or it is not). A broader qualitative assessment, 
as provided by ESG reporting, results in a wider and more structured approach, and continuous monitoring. Further 
as ESG reporting is done by an individual asset – the company or project - rather than attempting to undertake a 
broad assessment of an asset class, it is a much more focused exercise.  
An additional issue with taxonomies applying to economic activities is how to apply this to companies. For 
instance, the regulation may determine an economic activity “X” to be a “sustainable” activity. Therefore, the 
financial equity and debt of a company solely involved in this activity will be considered as a sustainable investment. 
However, this activity may be undertaken by a company that is also involved in other activities, which are not 
considered activities eligible for climate financing. Therefore, finding a model to account for such real-world 
situations will increase the complexity of implementing taxonomies. 
A recent report by the Organisation for Economic Co-operation and Development (OECD) entitled Developing 
Sustainable Finance Definitions and Taxonomies (2020) summarises and contrasts sustainable finance definitions 
and taxonomies in five jurisdictions: The European Union, People’s Republic of China, Japan, France and the 
Netherlands. It lays out preliminary considerations for good design of taxonomies, which can support policy makers 
to develop and grow sustainable finance markets to help achieve environmental and sustainable development goals. 
It also identifies differences among the taxonomies in scope as well as commonalities.  Other countries (such as 
Canada, Kazakhstan, South Africa and Indonesia) have also expressed interest in the development of sustainable 
finance taxonomies and are progressing towards this goal.   
The most well-known taxonomy is the European Union (EU) Taxonomy Regulation adopted in June 2020 as the 
cornerstone of the EU Sustainable Finance Action Plan. It will be discussed further below.  
EU taxonomy 
The EU Taxonomy is a list of economic activities with performance criteria for their contribution to six environmental 
objectives. This is as far as the taxonomies should go. However, the EU Taxonomy goes further in classifying assets 
classes as “sustainable” or not. Any asset omitted from the list is treated as not “sustainable”.  To be included in the 
proposed EU Taxonomy, an economic activity must contribute substantially to at least one environmental objective 
and do no significant harm to the other five, as well as meet minimum social safeguards. Technical screening criteria 
set requirements for determining substantial contribution and Doing No Significant Harm (DNSH). 
 
2. 
Sustainability is a term that is not favoured by many in the finance community as it is unclear what it is intended to cover. It 
should link to the SDGs, but the term is greatly miss-used. ESG are wide ranging and companies need to be assessed against 
a broad range of ESG.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
The six environmental objectives are: 
• 
climate change mitigation; 
• 
climate change adaptation; 
• 
sustainable use and protection of water and marine resources; 
• 
transition to a circular economy, waste prevention and recycling; 
• 
pollution prevention and control; 
• 
protection of healthy ecosystems. 
The EU used a Technical Expert Group (TEG) to assess a large number of activities and determine if they meet 
the criteria set out above.  For a long-time nuclear has been accepted as being one of the best technologies when 
assessed against all three scopes on GHG emissions (see more details below). However, there were concerns 
expressed by the TEG about nuclear not being able to meet the DNHP due to the waste it produces. Similar concerns 
about other technologies seem to be overlooked or at least discounted. However, following the initial TEG report, 
the EU appointed its Joint Research Centre (JRC) as the group of experts to assess nuclear under its sustainable 
finance taxonomy. In March 2021 the JRC issued its Technical Assessment on Nuclear Energy with respect to the ‘do 
no significant harm’ criteria of Regulation (EU) 2020/852 (‘Taxonomy Regulation’) (EU, 2021) (hereafter the EU 
report), finding that nuclear does no more harm than other energy sources that were seen as sustainable. This 
report is now being considered by the EU commission to further debate nuclear’s role in the EU taxonomy. In the 
meantime, a number of governments have expressed concerns about the role the EU is taking in trying to use the 
taxonomy to limit certain technologies such as nuclear.  
The EU taxonomy is mandatory in the sense that financial market participants will be obliged to comply with 
the regulation when they want to market a financial product as “environmentally sustainable as per EU legislation”. 
Financial products can still be issued with no reference to the EU taxonomy, if the issuer does not mention 
“environmentally sustainable” in its communications. The legislators’ state that their intention is not to impose 
prescriptions on financial markets, but rather to spur the development of a market for “environmentally sustainable” 
investments as defined in the regulation. However, in practice the EU Taxonomy is being used to prevent financial 
institutions registered in the EU from investing in assets not listed as “sustainable” in the taxonomy wherever they 
are in the world.  
United Kingdom 
The United Kingdom has announced that it is considering implementing a green taxonomy – a common framework 
for determining which activities can be defined as environmentally sustainable – to improve understanding of the 
impact on the environment of companies’ activities and investments and support the UK transition to a sustainable 
economy. 
Canada 
In May 2021, the government of Canada launched the Sustainable Finance Action Council (SFAC), recommended in 
the Final Report on the Expert Panel on Sustainable Finance: Mobilizing Finance for Sustainable Growth 
(Environment and Climate Change Canada, 2019), as a cross-departmental secretariat to advise and assist the 
federal government in implementing the panel’s recommendations (Government of Canada, 2021). One of the 
potential SFAC work streams may relate to providing advice on defining transition finance.  
Additionally, the Canadian Standards Association (CSA) is leading in the development of a Canadian transition 
finance taxonomy and has formed the Technical Committee for Transition and Sustainable Finance. The committee 
includes representatives from Canada’s financial sector (including the major banks, pension fund managers, wealth 
and asset managers, insurance companies, rating agencies), Canada’s natural resource sectors, and related industry 
stakeholders.

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27 
China 
As the largest economy in the world nowadays, China’s efforts to develop sustainable finance definitions, build 
sustainable finance markets and shift investments from environmentally unsustainable to sustainable activities is 
essential to meeting the global environmental objectives. 
In terms of financial regulation, China’s core framework is the Guiding Catalogue for the Green Industry 
(Ministry of Ecology and Environment et al., 2019) established in 2016 and updated in 2019.  
It consists of a list of eligible sectors and is based on both industrial policies and environmental considerations. 
The six categories of green industries listed in the catalogue are:  
• 
manufacture of energy efficient equipment; 
• 
clean production industry; 
• 
clean energy industry; 
• 
industry of ecology and environment; 
• 
green upgrade of infrastructure; 
• 
green services. 
China has specifically included nuclear power under the category of clean energy industry. 
Japan 
Rather than a “taxonomy”, Japan’s sustainable finance guidelines issued so far by the Japanese authorities are 
principle-based, containing metrics guidance but no thresholds.  
Japan is an important player in the development of sustainable finance. It is the world’s third largest economy 
and Tokyo is one of the main global financial centres home to some of the world’s most powerful financial 
institutions. 
Japan’s green bond guidelines provide an indicative, non-exhaustive sector list, including renewable 
energy, energy efficiency, pollution prevention and control, sustainable management of living natural 
resources and land use, projects for terrestrial and aquatic biodiversity conservation, projects for 
clean transportation, projects for sustainable water management, projects for climate change 
adaptation, projects concerning eco-efficient products, production technologies, and processes, and 
projects to newly build or renovate green buildings that not only are energy efficient but also address 
a wide range of issues for consideration such as water consumption or waste management.  
The guidelines recognize that some green projects may have incidental negative impacts on the 
environment, in addition to their intended environmental benefits. In such cases, the guidelines 
prescribe that those negative environmental impacts are evaluated by the issuers as limited compared 
to their environmental benefits, and that the issuers should include information regarding these 
negative impacts to investors so that the investors and market participants can appropriately evaluate 
these impacts.  
Issuers should inform investors of the environmental sustainability objectives they intend to achieve 
with the green bonds and the criteria for selecting the projects accordingly. Examples of 
environmental objectives are climate change mitigation, adaptation, and the conservation of 
biodiversity. For climate change mitigation, the criteria can be GHG emissions reductions (OECD, 2020). 
South Africa 
In May 2020, the South African Government’s National Treasury published the draft Technical Paper on “Financing 
a Sustainable Economy” with the aim of unlocking access to sustainable finance and stimulating the allocation of 
capital to support a development-focused and climate-resilient economy. 
Since then extensive consultation with local and international stakeholders have resulted in a Draft Version of 
such a taxonomy for South Africa. The draft describes a national Green Finance Taxonomy for South Africa. It is 
divided into three main sections including,

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
• 
a Matrix that provides high-level view of eligible activities under each sector;  
• 
a Catalogue that indicates basic attributes of the activities identified in the matrix, and maps the environmental 
objectives of each activity, and  
• 
technical Screening Criteria to give in-depth information on the attributes and requirements for each eligible 
activity, including principles, metrics, and thresholds for substantial contribution to climate change mitigation 
and climate change adaptation.  
This draft Green Taxonomy is clear on the applicability of wind, solar and hydropower but excludes mention of 
nuclear. The document is expected to be finalised and approved in 2022. 
.

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29 
References 
Environment and Climate Change Canada (2019), Final Report on the Expert Panel on Sustainable Finance: Mobilizing 
Finance 
for 
Sustainable 
Growth, 
Government 
of 
Canada, 
Gatineau, 
https://publications.gc.ca/collections/collection_2019/eccc/En4-350-2-2019-eng.pdf. 
EU (2020), Financing a sustainable European economy – Taxonomy: final report of the Technical Expert Group on 
Sustainable 
Finance, 
European 
Commission, 
https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/200
309-sustainable-finance-teg-final-report-taxonomy_en.pdf  
EU (2021), Technical assessment of nuclear energy with respect to the ‘do no significant harm’ criteria of Regulation 
(EU) 2020/852 (‘Taxonomy Regulation’), European Commission Joint Research Centre, Petten, 
https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/210
329-jrc-report-nuclear-energy-assessment_en.pdf. 
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https://www.canada.ca/en/department-finance/news/2021/05/canada-launches-sustainable-finance-action-
council.html  
IAEA (2021), Sustainable Development Goals, www.iaea.org/about/overview/sustainable-development-goals 
(accessed on 28 July 2021). 
ICMA (2018), Green Bond Principles – Voluntary Process Guidelines for Issuing Green Bonds, International Capital 
Market 
Association 
Publishing, 
Paris, 
www.icmagroup.org/assets/documents/Regulatory/Green-
Bonds/Green-Bonds-Principles-June-2018-270520.pdf  
Ministry of Ecology and Environment, Ministry of Housing and Urban-Rural Development, Ministry of Industry and 
Information Technology, Ministry of Natural Resources, National Development and Reform Commission, 
National Energy Administration, People’s Bank of China (2019), Guiding Catalogue for the Green Industry, 
www.chinawaterrisk.org/regulation/guiding-catalogue-for-the-green-industry-2019/.  
OECD (2020), Developing Sustainable Finance Definitions and Taxonomies, Green Finance and Investment, OECD 
Publishing, Paris, https://doi.org/10.1787/134a2dbe-en.  
Serafeim, G. (2020), “Social-Impact efforts that create real value”, Harvard Business Review, Harvard Business 
Publishing, https://hbr.org/2020/09/social-impact-efforts-that-create-real-value.  
UN (1992), “United Nations Framework Convention on Climate Change”, NDC Registry (interim), 
www4.unfccc.int/sites/ndcstaging/Pages/LatestSubmissions.aspx (accessed on 28 July).  
UN (2021), Introduction to Climate Finance, United Nations Climate Change, https://unfccc.int/topics/climate-
finance/the-big-picture/introduction-to-climate-finance (accessed on 28 July) 
UNPRI (2021a), Understanding and aligning with beneficiaries’ sustainability preferences, Principles for Responsible 
Investment, www.unpri.org/download?ac=13321   
UNPRI (2021b), Annual Report 2020, United Nations Principles for Responsible Investment, UNPRI Publishing, 
London, https://www.unpri.org/about-the-pri/annual-report-2020/6811.article  
WEF (2020), Measuring Stakeholder Capitalism: Toward Common Metrics and Consistent Reporting of Sustainable 
Value Creation, Prepared in collaboration with Deloitte, EY, KPMG and PwC, World Economic Forum, Geneva, 
www.weforum.org/reports/measuring-stakeholder-capitalism-towards-common-metrics-and-consistent-
reporting-of-sustainable-value-creation.

ESG REPORTING 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
31 
Low Carbon ESG Reporting 
This chapter provides a high level overview of how nuclear and other low-carbon energy asset classes could report 
against the ESG identified in Appendix I. The following chapter (Nuclear Disclosures against ESG) addresses how 
nuclear can positively report against the ESG. Appendix II provides greater details on how nuclear and other energy 
sources could broadly report against ESG.   
Overview of energy companies / projects reporting 
 
Table 1: General overview of how low carbon energy companies could report against the “Governance” pillar 
Metric 
Sub-metric/ 
comments 
Comments 
Governing purpose 
 
Asset specific 
Quality of governing 
body 
Board composition, 
remuneration, 
Asset specific 
Stakeholder 
engagement 
Buy-in, impact and 
process 
Energy companies and projects generally have strong and wide stakeholder 
engagement. 
Ethical behaviour 
Anti-corruption, 
ethics and reporting 
Energy companies and projects are generally considered to be ethical. 
However, the full lifecycle and supply chain should be considered. This is 
further complicated when considering the full system profile of assets, for 
example if renewables are using storage facilities to provide firm power. 
Risk and opportunity 
oversight 
Integrating risk and 
opportunity, 
including climate 
change risk 
Asset specific 
 
 
 
Pillar: GOVERNANCE

ESG REPORTING 
32 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
Table 2: General overview of how low carbon energy companies could report against the “Planet” pillar 
Metric 
Sub-metric/ 
comments 
Comments 
Climate change  
GHG emissions, 
scope 1, 2 and 3, 
including risk 
management and 
mitigation 
When considering the full life cycle and the supply chain, nuclear energy and 
on-shore wind have similar greenhouse gas (GHG) emission profiles. 
However, when considering the wider system profile and assets used to 
provide storage, this evaluation becomes much more complex for some 
renewable projects. Reporting should be extended to consider how assets 
work together to provide firm power. 
Nature loss  
Land use and 
ecological 
sensitivity, and land 
use 
Per kWh of power, nuclear energy reports better than solar, which in turn 
reports better than wind in terms of land use. 
Fresh water 
availability  
Consumption and 
management 
Nuclear energy does not consume water but it does use large quantities of 
water. This may change with more advanced designs, particularly with Gen-
IV technologies. Nuclear power can also be used for desalination to provide 
fresh water.  
 
Solar uses little water except in manufacturing, but if solar panels break they 
can contaminate the watercourse. 
 
Wind projects do not use water except in the manufacturing process, but off-
shore wind farms do have an impact on the marine environment.  
Each asset needs assessing on its own merits.  
Pollution 
Air and water, 
including NOx, SOx, 
particulate matter 
and lead 
Nuclear energy can report well against pollution ESG. Renewables need to 
be assessed as individual assets. 
Waste 
Management and 
mitigation 
All energy projects and companies produce waste and need to be 
decommissioned at the end of their lifetimes. 
During its many years of existence, nuclear power has developed world 
class waste management and mitigation processes and procedures. Solar 
companies are beginning to manage and mitigate their waste using similar 
standards, but the wind industry has yet to establish proper processes and 
procedures for the management and mitigation of waste.  
Resources 
 
Resource management is generally well-managed across energy projects. 
Some wind projects have been shown to be using balsa wood, and therefore 
such assets need assessing on an individual basis to ensure that the wood is 
ethically sourced.  
 
 
 
Pillar: PLANET

ESG REPORTING 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
33 
 
Table 3: General overview of how low carbon energy companies could report against the “People” pillar 
Metric 
Sub-metric/ 
comments 
Comments 
Dignity and equality 
Diversity, inclusion, 
harassment, pay 
equality and pay 
gaps, wage levels 
and living wages, 
human rights 
abuses, including 
trafficking, slavery 
and child labour 
Asset specific 
Health and well-
being 
Health and safety 
(workforce and third 
parties), including 
nuclear safety and 
emergency 
management, 
incidents on-site, 
well-being and 
impact  
Health and well-being across the energy sector is generally high. However, 
each asset will need to report to these high standards.  
Nuclear energy has developed gold standard health and safety procedures, 
not only for nuclear safety and emergency preparedness but also for 
organisations as a whole, and across lifecycles.  
Skills for the future 
Training, number of 
unskilled vacancies 
and impact. 
The energy sector is generally good at training and development, and at 
providing skills for the future. The nuclear sector has spent considerable time 
and effort in maintaining its skills and developing skills for the future (on 
existing and future technologies).  
 
The renewables sector is a newer industry and therefore has not yet had to 
consider maintaining skills for the future (although they have had to develop 
a workforce from scratch), and therefore it will be more asset specific.  
 
 
 
Pillar: PEOPLE

ESG REPORTING 
34 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
Table 4: General overview of how low carbon energy companies could report against the “Prosperity” pillar 
Metric 
Sub-metric/ 
comments 
Comments 
Wealth creation and 
employment 
Number of jobs, 
economic 
contribution, 
financial investment, 
Infrastructure 
investment, 
significant economic 
impact 
All energy projects create jobs and wealth, particularly during the 
construction period.  
 
Nuclear plants operate for 60 to 100 years and create significant and highly 
paid jobs at the plant itself, while also creating positive socio-economic 
impacts on the regions where they are built. These plants thereby create 
well-paid employment not only during the construction period but for the 60 
to 100 years of operation, as well as through decommissioning. 
 
The operation and maintenance of wind and solar projects can vary, and the 
plant life is much shorter. Wealth creation and employment therefore 
becomes more asset specific. 
Energy affordability 
Residential, 
commercial and 
industrial, number of 
disconnections and 
external factors 
When considering the cost of the plant and therefore the energy generation, 
nuclear energy can be perceived as having higher costs than those for other 
energy assets, particularly when considered over a shorter period than the 
life of the asset. However, when considering affordability against a levelized 
cost across the life of the asset, capacity factors and any associated system 
costs, energy affordability is in fact similar to renewable projects.  
End-use efficiency 
and demand 
Percentage of 
electric utility 
revenues, 
percentage of load 
served by smart grid 
technology and 
customer savings 
from efficiencies 
As a firm power source, nuclear power can often report better in terms of end 
use efficiency and demand. However, this will largely be asset specific for all 
three technologies. 
Grid resiliency 
Number of incidents 
and disruptions 
As a firm power source, nuclear power often reports well as it causes little 
disruption to the grid. 
Intermittent power sources that are weather dependent, such as wind and 
solar, can be more challenging.  
Innovation in better 
products and 
services 
R&D spending and 
social value 
generated 
The nuclear industry invests significantly in R&D in an effort to find better 
products for the future.  
The renewables industry is a newer industry and therefore R&D spending 
will be much more company specific. 
Community and 
social vitality 
Tax paid and total 
social investment 
Energy companies and projects tend to report well against community and 
social vitality metrics. 
 
 
Pillar: PROSPERITY

NUCLEAR DISCLOSURES AGAINST ESG 
 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
35 
Nuclear disclosures against ESG 
This chapter considers nuclear energy as an asset class, and how nuclear companies and projects could report 
against the ESG identified in Appendix I. This section is the main focus of the report on how nuclear energy is an 
ESG investable asset class. Appendix II provides greater detail on the reporting against each ESG, including what 
each metric is intended to cover. 
Governance: SDGs 12, 16 and 17 
Governing purpose 
Although this metric is very company-specific, many nuclear companies nonetheless clearly articulate their 
governing purpose as a utility, a generating company, a technology company, an operating company and/or a 
development company.  
When special purpose vehicles (SPVs) are established for a specific purpose, to develop and construct an asset 
such as a new nuclear plant, their governing purpose is very clearly established from the offset.  
A clear governing purpose, set out in the company’s documentation, is vitally important. Equally the company 
needs to be run to deliver its governing purpose. 
These roles have become a little confused in recent years with nuclear technology companies becoming 
shareholders in development companies. However, on the rare occasion this has happened, the governance 
procedures have been well established and maintained to ensure that an appropriate delineation of roles is 
maintained. The company’s role as shareholder and the company’s role as contractor selling their technology to the 
development company need to be separated to ensure that the correct governance is maintained.  
Nuclear regulation also has a role to play here. With the strict requirements around the “Controlling Mind” of 
a company and also the “Knowledgeable Customer” that are vital to regulatory compliance in nuclear corporate 
governance, and while these do not strictly apply before a nuclear company is operational (having radioactive 
material on site), many companies adopt processes and procedures to follow these principles before they are strictly 
required to do so. They have also very frequently developed plans to ensure compliance during the life of the asset. 
Nuclear projects and companies are often key to the socio-economic development of communities and 
countries. With the long-term nature of nuclear assets (a lifecycle of c. 100 years) they promote the long-term 
sustainable success of the company, generating value for shareholders and contributing to wider society as set out 
in this paper. There is an emerging focus on boards signing up to their own ESG statement to show how they will 
deliver their governing purpose in line with ESG across the lifecycle. The board should establish how the company 
proposes to fulfil its governing purpose through ESG means. More and more companies, including nuclear 
companies, should adopt this best practice. 
The Taskforce noted that there could be improvement in some company’s boards needing to ensure that the 
company’s purpose, values and strategy are aligned to the corporate culture and to workforce policies and practices. 
The nuclear industry has stringent policies and practices but sometimes the leadership does not flow up to the board. 
The number of stakeholders in any energy project, but particularly in nuclear projects, are extensive and 
complex and need to buy into the company purpose, and then they need to be kept informed of developments 
within the company. This is especially true in any new build project where the local community, local government 
and central governments will need to align for the project to move ahead.  
Stakeholder mapping for the nuclear sector has always been wide ranging. Being transparent and open with a 
broad and wide range of stakeholders is something the nuclear industry has, in more recent years, managed well. 
Stakeholders the nuclear industry liaises with include governments and governmental departments, local and 
regional communities, schools and universities.

NUCLEAR DISCLOSURES AGAINST ESG 
36 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
All material stakeholders need to buy into the company’s governing purpose. Nuclear companies need to 
identify and manage all material issues that could affect stakeholders – which they are used to doing. Due to the 
misconceptions around nuclear, the sector has to go further than many other sectors in managing stakeholders and 
dealing with perceived concerns.  
With the additional regulatory and stakeholder impact on nuclear companies, the quality of the company’s 
governing body (both the board and the executive) are key to the successful performance of a company. The 
processes and procedures required to manage nuclear regulatory compliance are far-reaching, resulting in gold 
standard processes and procedures being adopted (sometimes to the financial detriment of the company), which 
needs to be considered. If other companies were to adopt such strict and stringent processes and procedures it 
would likely result in an increase in project and company costs. 
Due to governance and regulatory oversight the composition of the board and its committees is a key concern. 
The challenge provided by the non-executive to the executive team is also good practice that many nuclear 
companies adopt from early in the company’s existence.  Some companies go further in having: 
• 
a well-constituted board; 
• 
independent, non-executive directors to provide oversight;  
• 
a supervisory/advisory board to provide wider supervision and advice to the company. While this may be best 
practice, it also adds further costs and therefore needs to be considered against the additional value provided 
to the company. 
Energy companies tend to remunerate reasonably well. Capital projects generally remunerate better to reflect 
the risks being undertaken in trying to get the project developed. The nuclear sector recognises the importance of 
its people and seeks to compensate them well. Capital project remuneration packages also tend to include success 
fees and bonuses linked to the milestones achieved. While corporates also link bonuses to milestones, they are 
often lower, reflecting the level of risk involved.  
Whether an individual company has met these milestones will be a matter of due diligence, however the gold 
standard adopted by many in the nuclear sector should set the standards that others should aspire to.   
Quality of governing body  
The capabilities, thinking, experience and perspectives of board members are key to the successful operation of a 
company. Much has been written in recent years about the importance of diversity of the individuals and diversity 
of thought. The WEF research examining public companies across multiple jurisdictions found that companies with 
higher diversity financially outperform their peers. 
A diverse and inclusive board and workforce brings out the best in its people and the company as a whole can 
then better understand the needs of its customers. It is also better equipped to manage risk and exhibits 
responsibility for the organisation. Diversity of thought also provides the most fertile environment for innovation 
and disruption, allowing the company the ability to quickly pivot to meet changing demands.   
Gender diversity is one form of diversity. In April 2020, PwC conducted a survey on powerful women1 looking 
at women in energy companies and found that 38% of UK energy companies have no women on the board and only 
21% of board positions in UK energy companies were held by women, with only 13% of executive board positions 
across the UK energy companies being held by women. The nuclear industry performs slightly better than the other 
parts of the energy industry, including renewables, in terms of gender diversity, but it is marginal. Some of the 
Canadian nuclear companies report extremely well on gender diversity on their boards and Canada has 
implemented the Equal by 30 programme2 and Driving the Advancement of Women in Nuclear (DAWN) to advance 
the participation of women in the clean energy transition and to close the gender gap.  
Human Resources Canada has also implemented a Diversity and Inclusion3 programme to foster diversity and 
inclusion within all organisations. The programme represents the right for diversity and inclusion of under-
represented groups in the electricity sector, including women and Canada’s indigenous population. The Diversity 
 
1. 
For more information on this survey, see https://powerfulwomen.org.uk/board-statistics-by-company/. 
2. 
For more information on this programme, see: www.equalby30.org/en/splashify-splash. 
3.  
For further information, see: https://electricityhr.ca/workplace-solutions/diversity-inclusion/.

NUCLEAR DISCLOSURES AGAINST ESG 
 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
37 
and Inclusion programme works with the Canadian Council for Aboriginal Business 4  to consider corporate 
performance in Aboriginal relations. Further, the Canadian BlackNorth Initiative5 seeks to end anti-black systemic 
racism – over 450 companies have signed up to the initiative. These programmes also work with Nuclear Against 
Racism,6 under which the nuclear industry has pledged to agree to stand in solidarity with black and indigenous 
communities, and people of colour across the world.    
In the UK, the revisions to the Nuclear Sector Deal will further address diversity and inclusion across the nuclear 
sector. The focus is likely to be on diversity of thinking and diversity of socio-economic backgrounds. There are also 
likely to be regional targets around cultural diversity to reflect the cultural diversity in different regions of the UK.  
The UK has also established a not-for-profit initiative, called Inclusion and Diversity in Nuclear (IDN),7 with the aim 
of creating an inclusive and diverse industry.  
Even with all these initiatives, and others, diversity remains a challenge. There are many considerations to 
developing diversity policies and procedures and some will be country and even regionally specific. The UK is 
considering the approach in its revisions to the Nuclear Sector Deal and not only looking at diversity of thinking 
together with cultural, racial, sexual orientation, gender, disability and socio-economic diversity, but also looking at 
different targets based on the socio-economic and cultural diversity in each region rather than trying to consider 
the country as a whole. The energy sector as a whole has a long way to go before it can be seen as truly diverse. 
Whether a company is inclusive and diverse is a matter for investors’ due diligence and for a company’s reporting.  
Organisations need to be purpose-led. The ability to achieve milestones provides a useful mechanism to assess 
whether the board and its management have the ability to oversee the company and to deliver the stated purpose. 
It provides as indication of the board and executives ability to guide and lead the company. 
It is important that projects run to time and to budget. In the West, infrastructure projects’ ability to run to 
time and to budget has historically been a problem for large projects, including nuclear projects. As nuclear moves 
to more of a product-based approach (minimal on-site construction time) with the majority of the kit being factory 
built, this should improve dramatically. Also, with smaller reactors the project schedule will be shorter and less 
complex and therefore it should be easier to maintain milestones. Some smaller reactors are showing construction 
periods of only two to three years. As technologies advance, reactors will become more product-based and 
therefore construction periods will be shorter. This is an area that the nuclear industry needs to keep under constant 
watch and develop methods to keep to time and to budget. However, delays and cost overruns are not just the 
domain of the nuclear industry. Major megaprojects, including renewables, face the same challenges. 
The company’s remuneration policy needs to reflect both the company and the project. Energy projects are 
vital to society and important for the socio-economic development and regeneration of regions and countries. The 
remuneration policy, performance criteria, appraisal and assessment processes and performance incentives should 
reflect the delivery of the stated purpose as well as the importance to society of these projects. 
Nuclear companies generally pay well and above the market rate, reflective of the importance of their Board 
and staff. However, due diligence will assess the specifics of a company against the wider country profile. The 2019 
Oxford Economics report, Nuclear power pays: Assessing the Trends in Electric Power Generation Employment and 
Wages (2019) indicates that in average jobs in nuclear energy are 20% better paid than in fossil fuel generation, and 
30% better than wind and solar generation, directly demonstrating the higher education in nuclear as well as a 
higher potential for premium activities and jobs. 
Stakeholder engagement, including buy-in, impact and process 
Stakeholder engagement and assessing the impact of the company on stakeholders is something the energy industry, 
and particularly the nuclear industry, is used to doing. When developing new projects, energy companies engage 
with a wide range of stakeholders in bringing the project to fruition. These stakeholders will include: the government, 
the planning authorities, regulators, local communities, schools, universities and off-takers. To develop these 
projects, various hurdles will need to be overcome to reach financial close, including raising finance, getting all the 
relevant planning, environmental, and licensing approvals and consulting with communicates and wider 
 
4.  
See: www.ccab.com/programs/progressive-aboriginal-relations-par/. 
5.  
See: https://blacknorth.ca/the-pledge/. 
6.  
See: www.nuclearagainstracism.com. 
7.  
See: www.niauk.org/media-centre/member-news/inclusion-diversity-nuclear/.

NUCLEAR DISCLOSURES AGAINST ESG 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
stakeholders. This is even more stringent on nuclear projects where there are additional regulatory requirements 
to meet before a project can move ahead. 
Established energy companies maintain their relationships with stakeholders but not to the same extent as 
capital projects SPVs. Nuclear companies tend to maintain relationships with wider stakeholders as a matter of 
course as they are part of the community for such a long period of time and they often work with a whole range of 
stakeholders to maintain their position in the community. Nuclear can be a controversial topic for some 
stakeholders and nuclear companies work hard to maintain their relationships. Nuclear companies often understand 
well their impact on different stakeholders and the importance to their business of maintaining those relationships.    
Again, whether a company can report well against this metric will depend on the individual company and how 
well they have identified the material issues and engaged with a wide enough group of stakeholders.  
Ethical behaviour 
Bribery and corruption undermine stakeholder trust and are linked to fraudulent behaviour, misconduct, lack of 
governance and due process, misallocation of capital, illegal behaviour and human exploitation. In short, bribery 
and corruption fundamentally undermine businesses and all ESG. 
The nuclear industry takes unethical behaviours very seriously and assesses not only its own company’s 
behaviour but that of the supply chains across the whole lifecycle.  Although this will be company-specific, nuclear 
companies often have gold standard training in place for all employees to ensure that best practice is understood 
for anti-bribery and corruption practices, what to look out for and how scenarios should be assessed; as well as 
money laundering processes and procedures and how inappropriate incidents should be reported within the 
company.   
Anti-corruption and bribery training is vital for the development and understanding of employees and to ensure 
that they understand the latest developments in anti-corruption and bribery prevention. However, training is not 
the be-all and end-all to protect the company and its reputation. Companies also need to invest in processes and 
procedures (including reporting) to ensure the highest levels of governance around anti-corruption and anti-bribery 
systems. 
In addition, companies should train people, and have processes and procedures in place, to assess their supply 
chains and potential supply chains in order to look out for unethical or illegal behaviour, whether that relates to 
people (human trafficking, fraudulent behaviour) or financial practices. Implementing gold star processes and 
procedures helps to prevent corruption and bribery in organisations. Companies need to be aware of not only the 
local laws that apply to the company but also other laws, legal systems and regulations that have an impact. 
Monitoring is a key element of such processes.  
Companies need to be able to assess and report unethical issues and need processes and procedures which 
facilitate reporting. Unethical behaviour needs to be prevented and remedied. Whistleblowing procedures need to 
be established to allow reporting of unethical behaviour without consequence on the reporter. Having such 
procedures in places helps to evidence proper governance and control by the board and the executive. 
Energy is vital to countries’ socio-economic development. Energy projects are developed throughout the world 
and investors need to be confident that concessions and contracts have been awarded in a professional, appropriate 
and ethical way. Corruption is a major concern for all energy projects, particularly in climate and green projects 
(where “green washing” can occur) or projects where resource such as forest are in issue. Corruption is a major 
issue for energy projects. With nuclear projects, due to the international oversight provided by organisations such 
as the International Atomic Energy Agency (IAEA), it is more difficult for unethical practices at a government level 
to exist, although it is possible and should be reviewed as part of any reporting and ESG assessment.  
Nuclear technology is subject to two main regimes in order to ensure its use for peaceful purposes in energy, 
medicine and science. These are international safeguards and export controls. There are international and domestic 
standards around safeguarding of nuclear matters in place to ensure that nuclear materials are not misappropriated 
or used for illegal purposes. International safeguards exist to ensure that nuclear material cannot be diverted for 
non-peaceful uses and consist of a system of nuclear material accountancy by the operator of an installation and 
reporting to the national safeguards body, and ultimately the IAEA. Verification of accountancy figures, remote 
monitoring and sealing of inventories are all carried out, and backed up by periodic inspections from the national 
safeguards responsible authority and/or the IAEA to provide independent verification.

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39 
Equally there are complex and detailed international and national export controls as well as international and 
national practices in place to ensure that a wide range of materials (nuclear or other) cannot be misappropriated 
for nefarious purposes. Although many countries have export controls in place for a wide range of materials, the list 
of items on the export controls list are significantly higher for the nuclear industry. Export controls cover a variety 
of areas from nuclear, aerospace, communications, materials and weapons. They are intended to aid countries in 
discharging their obligations. Through numerous treaties, export controls place restrictions on the export of 
components, documentation, knowledge and training. For certain nuclear technologies, prior to export, exporters 
will have to obtain an export licence from their country’s recognised authority and satisfy them that the technology, 
component or knowledge will not be diverted for purposes other than the peaceful exploitation of nuclear 
technology, and will not threaten the security of nations or contribute to the oppression of persons in the country 
of import. Importers are required to satisfy the exporting country’s export authority that the materials will not be 
diverted anywhere other than their intended use. 
Due to international oversight, countries that do not implement gold standards in relation to safeguarding and 
export controls are likely to be criticised by the market for failing to implement proper standards. This will equally 
apply to companies that do not have the current controls in place. 
Risk and opportunity oversight 
This metric relates to a company’s overall risks and opportunities. The onus sits with the board and the executive to 
have oversight of all the risks and opportunities. Risk registers should be maintained. The primary responsibility for 
maintaining registers and managing risks and opportunities lies with the executive, but the board must maintain 
oversight. The risks and opportunities must be appropriate for the organisation and not extend past the risk appetite 
of the company. The risks and opportunities should be wide enough to cover its stakeholders and the wider 
community. The risks should include ESG including environmental risks such as GHGs and climate change (see the 
Planet section below). The risk register must develop and adapt over time, including but not limited to an energy 
company transitioning from a development company, to a construction company, to an operational company and 
finally through to decommissioning. The risks and opportunities at each stage will be different.  
Nuclear companies often have gold standard process and procedures in place to manage risks, particularly 
those around nuclear risks and health and safety. Health and safety varies across jurisdictions, and whether a 
company meets this metric will be company- and country-dependent and will be weighted accordingly. The 
standards of health and safety, generally whether in nuclear or other energy projects, varies across the globe. 
Investors will assess the projects on their culture, processes and procedures, including the board’s oversight. 
Nuclear regulations provide for nuclear licenses to be in place for the construction, operation and 
decommissioning of the plant. The precise details depend on jurisdiction. However, under internationally agreed 
norms, the licensee has to be the Controlling Mind and Knowledgeable Customer for the site. 
The Controlling Mind is a legal concept has its origins in health and safety law relating to corporate 
manslaughter. In nuclear projects, it relates to the health and safety responsibilities in respect of risk management 
on a nuclear site. Under nuclear site licenses, the site licensee is responsible for health and safety and the overriding 
risk management of the site (the precise details of this will depend on the jurisdiction). The site licensee needs to 
be the “Controlling Mind” of all safety, security and safeguarding issues on the site. In relation to those areas, it 
cannot be constrained by the owner of the nuclear power plant or even the operator’s parent company, 
shareholders or investors. This can adversely affect the ability of investors to enforce their rights in a traditional 
project finance way. This in turn can affect the structure of the project. The Controlling Mind principle does not 
mean that the site licensee takes over others responsibility on the site or is the only entity responsible for health 
and safety and risk management on the site i.e. owners, operators and contractors still have to comply with their 
contractual and legal responsibilities. However, the site licensee has to have an understanding of all work being 
undertaken on the site. The precise details of this will depend on each jurisdiction. 
In addition to the Controlling Mind principle is the Knowledgeable Customer. A site licensee is expected to have 
the capability, within its own organisation, in terms of staffing and expertise, to understand the safety case for all 
the nuclear facilities on the site and the limits under which it must be operated. A nuclear licensee needs to 
understand the safety significance of any work undertaken by contractors and to oversee and take responsibility for 
each contractor’s activities, including ensuring that the contractor’s staff are suitably qualified and experienced to 
carry out their nuclear safety duties. This means that major contracts which affect the safety, security or 
safeguarding of the plant, including the EPC Contract and the Fuel Supply Agreement (FSA), must sit with the

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
licensed entity i.e., the licensed entity needs to have control of those contracts to be able to fulfil its Knowledgeable 
Customer obligations.  
Nuclear safety culture is defined as “the core values and behaviours resulting from a collective commitment by 
leaders and individuals to emphasise safety over competing goals, to ensure protection of people and the 
environment” (WANO, 2013). Nuclear companies should have detailed processes and procedures for managing 
health and safety and risk through-out the company and at every level of the organisation.   
However nuclear companies’ focus on nuclear risks and health and safety may be to the detriment of other 
risks such as delays and cost overruns in construction projects. These risks are large risks for the finance community 
and should not be underestimated as they have a direct impact on rates of returns. Delays and cost overruns are 
also true of other parts of the energy sector and therefore nuclear should not be discriminated against for this. In 
fact, it could be argued that other players in the energy sector should also improve their performance on sector-
specific risks, and health and safety.  
Therefore, a balanced and cross-board approach to risk, and risk mitigation and management, needs to be 
established and one risk should not be overly focused on to the detriment of other risks. All risks need to be managed 
and no company or project should be exempted from managing risks through perception or bias. Much can be learnt 
from the way nuclear manages and mitigates its risks. 
Planet: SDGs 6, 7, 12, 13, 14 and 15 
Climate change  
The role of nuclear as a low carbon technology is becoming widely accepted.  
As identified in the Canadian Nuclear Factbook 2020, “Today by displacing the use of coal and natural gas, 
nuclear power helps avoid about 2.2 billion tonnes of CO2 emissions annually. This is the same as taking about 480 
million passenger vehicles off the road – or nearly half of all the passenger vehicles in the world.” (CNA, 2020) 
In January 2016, the Public Service Commission of the state of New York ruled that the state's Clean Energy 
Standard (CES) portfolio must include nuclear power plants among its non-carbon-emitting generation resources.  
In the “Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and 
the European Atomic Energy Community for Cooperation on the Safe and Peaceful Uses of Nuclear Energy”, signed 
on 31 December 2020, it was noted: 
NOTING the United Kingdom’s commitment to developing and deploying nuclear energy as part of its 
diversified and low-carbon energy mix; 
DESIRING to make long-term cooperative arrangements in the field of peaceful and non-explosive 
uses of nuclear energy in a predictable and practical manner, which take into account the needs of 
their respective nuclear energy programmes and which facilitate trade, research and development 
and other cooperative activities between the United Kingdom and the Community;” (EU, 2020) 
On the global stage, the potential role of nuclear in reducing carbon impacts from power generation was a 
central theme of the COP21 summit in Paris. During the event, Loreta Stankeviciute – Energy Economist at the IAEA 
– stressed that “nuclear energy should be considered on equal footing with other low-carbon energy sources in 
weighing the energy options for mitigating climate change, in recognition of its broader potential for contributing 
to sustainable development”. 
Stankeviciute was speaking at a session hosted jointly by the IAEA and the Nuclear Energy Agency, which has 
also consistently highlighted the credentials of nuclear power as a way to drive carbon emissions out of the 
generation mix.  
As the NEA’s report, The Role of Nuclear Energy in a Low-carbon Energy Future (2012), states: 
The generation of electricity from nuclear power does not result in any direct emissions of CO2, the 
most important of the greenhouse gases thought to be responsible for global warming. As with all 
energy sources, there are some indirect emissions; these result mainly from fossil fuel use for 
operations in the nuclear fuel cycle. The exact level of these indirect emissions varies according to 
location and the technologies used, but studies described in this report show that even in the highest

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41 
cases they remain more than an order of magnitude below the direct emissions from fossil fuel 
generation, and are comparable to the indirect emissions from most renewable energy sources. (NEA, 
2012) 
This message was further amplified during a 2020 NEA webinar and in an NEA Policy Brief (NEA, 2020a) entitled 
“Building Low-Carbon Resilient Electricity Infrastructures with Nuclear Energy in the Post-COVID Era,8” and again in 
recent IEA reports: Net Zero by 2050: A Roadmap for the Global Energy Sector (2021), and Nuclear Power in a Clean 
Energy System (2019) and Nuclear Power in a Clean Energy System (2019). 
GHG emissions have been identified as one of the primary causes of climate change, and therefore key to the 
mitigation of climate change. GHG emissions is one of the main metrics for ESG across a number of reporting bodies. 
Over the past ten years, businesses associated with high emissions have fallen out of favour as the markets have 
moved towards low carbon economies.  
There remain difficulties in adequately measuring emissions. However, scope 1, 2 and 3 reporting has been 
developed. These are defined by the Task Force on Climate-Related Financial Disclosures (TCFD) as: 
• 
Scope 1 refers to all direct GHG emissions.  
• 
Scope 2 refers to indirect GHG emissions from consumption of purchased electricity, heat or steam. 
• 
Scope 3 refers to other indirect emissions not covered in scope 2, that occur in the value chain of the reporting 
company, including both upstream and downstream emissions.  
There are also challenges about the accuracy of the reporting against these metrics and also there is a bias 
towards certain technologies who often only report against scope 1 and sometimes scope 2. Some nuclear 
companies are beginning to report on scope 1,2 and 3. Requiring companies to report on all 3 scopes would create 
a level playing field across technologies. Looking at the lifecycle emissions provides a more accurate view of 
technologies and their overall impact on climate change.  
For a nuclear plant, many of the emissions are associated with the upstream supply chain – particularly the 
mining of uranium and the enrichment and fuel fabrication processes. In certain configurations with high grade ore 
or no enrichment or centrifuge-based enrichment the emissions from a nuclear lifecycle are the same as those from 
an on-shore wind farm (i.e., lower than an off-shore wind farm). 
Appendix II references three reports on GHG emissions, comparing different technologies. These reports are: 
• 
The Hatch report (2014) was commissioned by the Canadian Nuclear Association to consider lifecycle emissions 
from different technologies employing a lifecycle assessment (LCA) overview methodology (for further details 
see page 83). The LCA meta-analysis is a cradle-to-gate study spanning resource extraction to the production 
of electricity at the point (or gate) of delivery to the electricity grid. The study encompasses all upstream and 
downstream processes associated with the generation of 1 kWh of electricity, excluding transmission and 
distribution losses, and considers two dimensions of the lifecycle: 
– Supply chain – processes corresponding to the ongoing operation of the power generation facility, 
including the upstream systems associated with fuels and consumables and downstream systems 
associated with the management and disposal or waste; and 
– Lifespan – processes corresponding to the entire lifetime of the power plant from inception to eventual 
decommissioning, not otherwise captured in the day-to-day operation of the plant; 
• 
The Intergovernmental Panel on Climate Change (IPCC) synthesised evidence from a comprehensive review of 
published Life Cycle Assessments (LCAs) covering all regions of the world, to produce a comparison of carbon 
dioxide emissions from different electricity generation technologies; and 
• 
An article in Nature Energy (Pehl et al., 2017) measured the full lifecycle GHG emissions of a range of sources 
of electricity out to 2050. 
The table below shows the findings of these three reports. 
 
8. 
 To watch the NEA webinar, see: www.oecd-nea.org/jcms/pl_34301/webinar-building-low-carbon-resilient-electricity-
infrastructures-with-nuclear-energy-in-the-post-covid-19-era.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Table 5: Statistical Mean Total Lifecycle GHG Emissions for various sources of electricity 
Technology 
Hatch 
IPCC 
Nature Energy 
Nuclear power plant 
18.5 ± 1.7gCO2e/kWh 
16gCO2/ kWh 
4gCO2e/kWh 
On-shore wind turbine 
10.5 ± 0.9gCO2e/kWh 
 
4gCO2e/kWh 
Solar 
 
 
6gCO2e/kWh 
NGCC power plant* 
478 ± 10gCO2e/kWh 
 
78gCO2e/kWh 
Coal 
 
 
109gCO2e/kWh 
Hydro 
 
 
97gCO2e/kWh 
Bioenergy 
 
 
98gCO2e/kWh 
*Current NGCC plant and coal production is typically in the range 400- 900+. The figures in the table assume the projects 
have been fitted with carbon capture and sequestration (CCS). KWh = kilowatt hour; NGCC = natural gas combined cycle. 
Source: Adapted from Hatch (2014), IPCC (2007) and (Pehl et al., 2017) 
Reporting needs to be consistent and cover all three scopes for all technologies. Across the lifecycle, nuclear is 
on a par with on-shore wind and below solar and off-shore wind (although these reports do not specifically deal 
with off-shore wind, the cabling and converter stations [if any] increase the emissions to higher than on-shore wind 
projects). All low-carbon technologies are well below fossil fuel sources. 
Nature loss  
Reporting on the area of land owned, leased or managed by the company, together with adjacent land that is 
impacted by the company’s activities, and in particular protected areas or key biodiversity areas, is vital to being 
able to assess the impact of any energy source. 
Key biodiversity areas provide recognised ways of identifying sites contributing significantly to biodiversity. 
Protected areas or zones are recognised as areas of ecological importance. Any activities in such areas indicate 
heightened risk of environmental damage, adverse impacts on biodiversity or ecology and therefore risk to 
reputation.  
The interrelationship between land use and energy is a fascinating balance. Energy is needed for the socio-
economic development of regions and countries, but this needs to be balanced with the efficient and effective use 
of land, which is also needed for other activities, including the production of crops and food. Therefore, the efficient 
use of land for the production of energy is an important factor to be considered. As highlighted in Figure 1 below,  
• 
An average wind farm produces 0.77MWh per square kilometre of land;  
• 
An average solar farm produces 1MWh per square kilometre;  
• 
whereas a small modular reactor (SMR) produces up to 14.5 MWh per square kilometre of land.

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43 
Figure 1: Land use of nuclear, solar and wind 
 
    Source: GIF 
 
It should be noted that this reporting only takes into account the plant itself. For technologies which do not 
produce firm power the wider system profile should be considered to provide the comparable figures. 
Like many other infrastructure projects, the development of any energy plant could have an impact on sensitive 
species and habitats. The impact will depend primarily on the site where the plant is deployed, but when considering 
the land to be utilised, a nuclear plant of similar size is likely to have a smaller impact than a renewable plant of 
equal size. Consideration should also be given to any plant and other carbon sinks that are removed to allow the 
development, and any plants or trees planted by the asset developer to help to balance out the impact on the 
environment. A developer of any energy plant is required to provide sufficient information (including in relation to 
avoidance and mitigation measures) in order for an assessment to be made. This includes any off-shore impacts, 
whether it is an off-shore wind farm or the outlet pipe for cooling water from a nuclear plant. An environmental 
impact assessment would need to be undertaken to determine the specific impacts on a particular site.  
Fresh water availability  
Energy projects need to be considered in terms of their freshwater consumption. This is particularly relevant in 
water-stressed areas where there is a risk of a negative social impact. However, this metric should consider a 
company’s water stewardship as a whole. 
The reporting of the units, used together with how water is managed, should be reported in a way that 
executives, the board and investors can easily understand. The report should include an assessment of the 
environmental impact of the water use. 
In 2014, The Energy and Water in a Warming World Initiative produced a report entitled Freshwater Use by U.S. 
Power Plants: Electricity’s Thirst for a Precious Resource. They found that: 
…the water profile of power plants in 2008 shows that:  
Power plants are thirsty. Every day in 2008, on average, water-cooled thermoelectric power plants in 
the United States withdrew 60 billion to 170 billion gallons (180,000 to 530,000 acre-feet) of 
freshwater from rivers, lakes, streams, and aquifers, and consumed 2.8 billion to 5.9 billion gallons 
(8,600 to 18,100 acre-feet) of that water. Our nation’s large coal fleet alone was responsible for 
67 percent of those withdrawals, and 65 percent of that consumption.

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Where that water comes from is important. In the Southwest, where surface water is relatively scarce, 
power plants withdrew an average of 125 million to 190 million gallons (380 to 590 acre-feet) of 
ground-water daily, tapping many aquifers already suffering from overdraft. By contrast, power plants 
east of the Mississippi relied overwhelmingly on surface water.  
East is not west: water intensity varies regionally. Power plant owners can reduce their water 
intensity—the amount of water plants use per unit of electricity generated. Plants in the East generally 
withdrew more water for each unit of electricity produced than plants in the West, because most have 
not been fitted with recirculating, dry cooling, or hybrid cooling technologies. Freshwater withdrawal 
intensity was 41 to 55 times greater in Virginia, North Carolina, Michigan, and Missouri than in Utah, 
Nevada, and California. Freshwater consumption intensity was similar in those sets of states. 
Low-carbon electricity technologies are not necessarily low-water. On average in 2008, plants in the 
U.S. nuclear fleet withdrew nearly eight times more freshwater than natural gas plants per unit of 
electricity generated, and 11 percent more than coal plants. The water intensity of renewable energy 
technologies varies. Some concentrating solar power plants consume more water per unit of 
electricity than the average coal plant, while wind farms use essentially no water. (Averyt et al., 2011) 
The exact water use will be project-specific, especially as some assets consume water whereas others (e.g. an 
operating nuclear or hydropower plant) simply use it and replace it. However, water consumption should also be 
assessed together with desalination and the creation of potable water for those countries where this is needed.  
Nuclear plants can be used for desalination and the creation of potable water and can help to off-set the impact 
of water consumption, particularly in water-stressed areas. The technology has been proven for desalination, 
principally in Kazakhstan, India and Japan. According to the World Nuclear Association (WNA), the costs of 
desalination by nuclear plants is much the same as fossil-fuel plants that do the same – c. USD 70 to 90 cents per 
cubic metre. This cost may drop with some of the advanced high temperature reactors in development. Whether 
countries chose to take the benefit of this option in nuclear plant is yet to be seen and will depend on the economics 
and other developments in each country.  
Pollution  
Many governments have been legislating for decades to try to reduce pollution generally, including energy projects. 
Renewable energy plants and nuclear plants are recognised as plants that have much reduced pollution across the 
supply chain. 
The impact of air pollution needs to be assessed across the supply chain. This should include nitrogen oxide, 
sulphur oxides, particulates, lead and mercury as well as other air emissions. The reporting needs to provide a 
meaningful assessment of the impact of air pollution and the impact on air quality.  
Hatch’s lifecycle assessment showed wind and nuclear to have similar emissions: 
Table 6: Statistical Mean Total Lifecycle Emission for nuclear and on-shore wind 
Scenario 
PM* (g/kWh) 
NOx (g/kWh) 
SOx (g/kWh) 
On-shore wind turbine 
0.015 ± 0.003 
0.028 ± 0.003 
0.025 ± 0.003 
Nuclear power plant 
0.008 ± 0.003 
0.039 ± 0.006 
0.023 ± 0.003 
*PM = particulate matter. 
Source: Adapted from Hatch (2014). 
 
In the Annual Reviews “Life-Cycle Assessment of Electric Power Systems” (Masanet et al., 2013), the pollution 
from various plants was assessed. As can be seen in Table 7, nuclear and renewable projects have far fewer 
emissions than fossil fuels. Each different form of energy creates its own air pollution. For example, the 
manufacturing of cabling and the wind turbines for wind farms (particularly off-shore) produces air pollution (and 
water pollution). The table below outlines the emissions identified in the report.

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45 
Table 7: Range of electric power technology emissions  
Environmental 
exchange 
 
Sulphur dioxide 
(SO2) (mg/kWh) 
NOx (mg/kWh) 
PM (mg/kWh) 
Coal 
Hard coal 
530-7 680 
540-4 230 
17-9 780 
Lignite 
425-27 250 
790-2 130 
113-947 
Natural gas 
Combined cycle 
1-324 
100-1 400 
18-133 
Steam turbine 
∼0-5 830 
340-1 020 
ID 
Nuclear energy 
 
11-157 
9-240 
∼0-7 
Bioenergy 
 
40-940 
290-820 
29-79 
Solar 
PV 
73-540 
16-340 
6-610 
Concentrated 
35-48 
54-160 
7-26 
Geothermal 
 
∼0-160 
∼0-50 
1.3-50 
Hydropower 
Reservoir 
9-60 
3-13 
0.1-25 
River 
1-6 
4-6 
 
Ocean 
 
64-200 
49 
15-36 
Wind 
 
3-88 
10-75 
1-14 
Source: Adapted from Masanet et al. (2013). 
There is a unique connection between the use of water and the production of energy. Energy production across 
the supply chain creates water pollution. The impact of energy projects on water varies from technology to 
technology and from project to project. Companies need to report in an accessible way the impact of water pollution, 
including excess nutrients, heavy metals and other toxins.  
The EU report from the JRC (EU, 2021) considers water ecosystems and the damage caused by various energy 
technologies and reports that: 
Water ecosystems are also damaged by toxic chemical releases, including heavy metals, volatile 
organic compounds (VOCs) and particles. Various ecotoxicity indicators have been used in 
sustainability assessments to compare technologies in terms of the toxic damage potential of their 
lifecycle chemical emissions.  
Freshwater aquatic ecotoxicity potential (FAETP) refers to the impact on fresh water ecosystems, as a 
result of emissions of toxic substances to air, water and soil. Marine ecotoxicity refers to impacts of 
toxic substances on marine ecosystems. Both indicators are expressed as grams 1,4-dichlorobenzene 
equivalents/kWh (g 1,4-DCB-eq/kWh).  
Stamford & Azapagic […], as well as Treyer & Bauer […], compared both fresh water and marine 
ecotoxicity potentials of several electricity generating technologies. The results are provided in the 
figures below. 
With regard to freshwater ecotoxicity, nuclear energy is again the best performer according to Treyer 
& Bauer, whereas the results of Stamford & Azapagic rank natural gas as best, with the other 
technologies fairly evenly matched, although nuclear has the potential to be comparable with gas 
according to the sensitivity studies. The data of Poinssot et al. again compare very well with the data 
of Treyer & Bauer and the lower bound data of Stamford & Azapagic. Concerning nuclear, the bulk of 
the impact is due to metals such as vanadium, copper and beryllium coming from uranium mill tailings. 
Regarding marine ecotoxicity, nuclear is again ranked best (Treyer & Bauer – ReCiPe methodology) or 
second best (Stamford & Azapagic – CML methodology) along with natural gas. (EU, 2021) 
As such, nuclear power is one of the better energy technologies when considering pollution and water toxicity.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Figure 2: Freshwater ecotoxicity potentials of various electricity generation technologies 
 
Source: Adapted from EU (2021)  
Figure 3: Marine ecotoxicity potentials of various electricity generation technologies 
 
Source: Adapted from EU (2021)

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47 
Waste, including management and mitigation 
All energy companies and projects produce waste. Waste needs to be reported, mitigated and managed. The metrics 
for waste have not been standardised and need to apply across industries and consider the whole of the supply 
chain across the project lifecycle. The reporting of waste arising from companies and projects needs to be 
meaningful and inciteful, and investors should ensure that they understand how companies and projects are 
managing and mitigating their waste.  
Reporting on single use plastics is in its infancy, and standardisation is key to a fair and balanced reporting. 
However, this should be extended to include not only single use plastics but all plastics to ensure that those that 
can be recycled are recycled and managed.  
For a long time, waste has been seen as an issue for all energy projects; however, more focus falls on waste 
arising from the nuclear industry. In response to this, the nuclear industry has developed the gold standard for 
reporting, mitigating and managing its waste. Lessons have been learnt through the management of waste arising 
from nuclear companies which should be applied across the energy sector and more widely (this is further discussed 
later in the report).  
In line with best practices, nuclear power plants have to plan and pre-fund the decommissioning and waste 
management activities, for new plants. Generally, the funding is accumulated over the early life of the power plant 
and payments into the decommissioning and waste management fund can be the first payment out of the payment 
cascade i.e. before debt service. However, the payment is so small that it should not be a concern for lenders. 
The objective of the planning and funding regimes is to ensure that nuclear operators make prudent provision 
for the full costs of decommissioning installations; and the full share of the costs of safely and securely managing 
and disposing of their waste; and that in doing so the risk of recourse to public funds is remote. Other energy 
producers, such as some solar companies, are beginning to follow this approach as it is recognised that plants need 
decommissioning and waste management plans.  
Radioactive waste is managed in different ways. The IAEA defines low and intermediate level waste as waste 
with activity levels above clearance levels (i.e. unregulated levels) and thermal powers below 2kW/m3. 
The storage and disposal technology for dealing with low-level waste (LLW) is well-established. It is: 
• 
the majority of solid radioactive waste by volume (c. 90%);  
• 
the lowest activity category of radioactive waste;  
• 
generally made up of materials such as plastics, glass, metal, paper and soil that have become contaminated 
by contact with radioactive liquids or powders; and 
• 
produced by hospitals, research establishments and the nuclear industry. 
Very low-level waste (VLLW) is a subset of the LLW category of radioactive waste, covering miscellaneous waste 
arising with very low concentrations of radioactivity. LLW and VLLW are either dealt with in LLW repositories or sent 
to landfill. Much of LLW and VLLW does not need to be disposed of in specialist facilities. 
Intermediate level waste (ILW):  
• 
arises from the reprocessing of spent fuel (most), from general operations and maintenance at nuclear sites, 
and from decommissioning;  
• 
can include metal items such as reactor components (e.g. reactor pressure vessel components), and sludges, 
filters and resins from the treatment of radioactive liquid effluents.  
Legacy ILW is typically being managed through a process of encapsulation in cement and packaged in stainless 
steel drums or higher capacity steel or concrete boxes as soon as reasonably practicable and placed into interim 
storage. Geological disposal is the preferred option for management of ILW in the long term, preceded by safe and 
secure interim storage.  
High-level waste (HLW) is sometimes referred to but it encompasses spent fuel or waste materials which arise, 
should the spent fuel be reprocessed or recycled. Spent fuel is defined as “nuclear fuel that has been irradiated in 
and permanently removed from the reactor core”. Spent fuel is not categorised as waste, because it still contains 
uranium and plutonium which could potentially be separated through reprocessing and used to make new fuel (i.e. 
be an asset to the company). Fast reactors are being developed which can utilise these resources.

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Spent fuel and waste also contain medical isotopes, including: 
• 
Actinium-225 (Ac225), radium-223 (Ra223), Actinium-227 (Ac227) and lead-212 (Pb212), which are used for 
targeted alpha therapy. Currently, the production routes for these isotopes are typically via the “milking” of 
existing sources of nuclear materials that would otherwise be considered as waste. Given their position in 
decay chains, waste from nuclear fission can contain these isotopes (or their source isotopes);  
• 
Yttrium-90 (Y90), which is used for beta irradiation therapy. The production route is the purification of 
strontium-90 (Sr90) from spent nuclear fuel for loading into an Sr90/Y90 generator;  
• 
Xenon-133 (Xe133), which is an established diagnostic and is the only approved tracer for imaging the 
distribution and rate of exchange of air in the lungs. Xe-133 is a product of uranium-235 (U235) fission. 
There are many more isotopes of interest for therapy, diagnostics, or combination in the form of theragnostics, 
some of which could be obtained from existing material, and others that might use existing material that can be 
irradiated (i.e. using a reactor or accelerator) to produce the isotope of interest. 
Spent fuel is essentially fuel assemblies that have been “burnt” in the nuclear reactor, and the number of fuel 
assemblies depends on the size and life of the plant.  The higher burn-up of the modern fuel means that an individual 
spent fuel assembly will have a higher heat output and external radiation compared with a fuel assembly discharged 
from nuclear reactors currently in use. Long-lived radionuclides remain thermally hotter and therefore require 
longer periods of cooling in interim storage. Interim storage of spent fuel can be carried out in a manner which 
causes a very low level of risk of detriment to human health and/or nature and/or the environment.  
The current preferred method for the long-term management of spent fuel and HLW is placement in a deep 
geological repository (DGR), although none are currently operational. However, a number of countries are 
progressing deep geological repositories including Finland, Canada and the UK. The OECD NEA published a 
statement in 2008 which said that: “The overwhelming scientific consensus worldwide is that geological disposal is 
technically feasible” (OECD, 2008).  
The NEA further noted that “Releases from engineered barriers would occur over thousands of years after 
disposal and would be very small. Additionally, these releases are diluted and slowed by the geological formation 
surrounding the repository and are further reduced by radioactive decay. The resulting potential radiological 
exposure in the biosphere would not represent, at any time, a significant increment above the natural background”.  
In respect of external dose rate, the encapsulation, transport and emplacement of high burn-up spent fuel can 
be shown to be feasible using existing technology applied in the management of vitrified HLW. In particular, the 
relevant IAEA dose rate limits for transport can be met after interim storage by providing a combination of a 14 cm 
thick stainless steel gamma shield surrounded by a 5 cm thick neutron shield.  
Radioactive wastes are transported in accordance IAEA regulations and in accordance with domestic and 
regional agreements and directives. The packaging requirements for material containing radionuclides are 
dependent upon the radionuclide specific activity of the material, its form (solid, liquid or gas) and the total quantity 
of activity in the consignment.  
The 1992 Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR 
Convention) and the OSPAR Radioactive Substances Strategy both aim to reduce discharges into the marine 
environment of the North-East Atlantic Region to levels where the additional concentrations above historic levels, 
resulting from such discharges, are close to zero.  
It is important to note that while the ultimate objective of the OSPAR Convention is to reduce the 
concentrations in the marine environment, it does not prohibit the future development of the nuclear sector and 
the building of new reactors. OSPAR’s Radioactive Substances Strategy acknowledges the need to take account of 
what is achievable and focuses on the delivery of the Convention’s objectives through the application and use of 
BAT and BEP.  
Non-radioactive waste is produced from operating and maintaining power plants, and includes laboratory 
chemicals and lubricating and fuel oils, which need safe management and disposal.  
Hazardous waste is defined as waste with one or more properties that are hazardous to health or to the 
environment. Categories or generic types of hazardous wastes as well as the properties of hazardous waste are 
listed in directories such as the European Commission’s Hazardous Waste Directive.

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The volumes produced by new nuclear power stations is small in relation to the total volumes of such wastes 
produced generally. Amounts of non-radioactive hazardous waste arising from reactor construction and 
decommissioning are expected to be broadly equivalent to those arising from any major infrastructure, or power 
construction or demolition project and amenable to the normal waste minimisation techniques.  
The treatment and disposal of waste is regulated in order to ensure the protection of the environment and 
human health, and is dealt with in accordance with the regulations applicable to non-nuclear sites.  
Other low carbon energy projects create large amounts of waste which can be detrimental to people and the 
environment if not properly managed. This can extend to the lead in solar panels and the blades from wind farms. 
All waste needs managing properly and should be assessed against the highest international standards.  
Resources 
In the long term, nuclear power is dependent upon the uranium resources (or other special nuclear material) being 
available. Special nuclear materials are defined in the international conventions. 
According to Uranium 2020: Resources, Production and Demand (NEA/IAEA, 2020), “identified recoverable 
uranium resources, including reasonably assured resources and inferred resources at a cost of <USD 260/kgU 
(equivalent to USD 100/lb U-3O8) are sufficient for over 135 years, considering uranium requirements as of 2019. 
Exploitation of the entire conventional resource of about 15.3 MtU based on current demand would increase this 
to over 250 years. The conventional resources include reasonably assured, inferred, prognosticated and speculative 
resources but exclude secondary sources or unconventional resources, such as uranium from phosphate rocks.”  
With the development of advanced reactors and fast reactors uranium and other resources will be utilised more 
efficiently and therefore last for much longer than the 135 years highlighted in the NEA/IAEA report. 
With fast-spectrum reactors operated in a “closed” fuel cycle by reprocessing the used nuclear fuel and 
recycling uranium and plutonium, the reserves of natural uranium may be extended to several thousand years. 
Therefore, the main current resource of nuclear power is not seen as a concern. 
People: SDGs 1, 3, 4, 5 and 10 
Dignity and equality 
Organisations need to be built on a culture of respect, courtesy and professionalism. Without this foundation, 
employees and organisations will be unable to grow and develop.  
Equality across the workforce and providing dignity to employees is a key metric for any modern business. 
Equity, dignity and inclusion irrespective of age, sexual orientation, gender, disability, race, ethnicity, origin or 
religion is key to good management and governance.  Diversity of socio-economic background as well as diversity 
of thought is key to performance.  Diversity attracts the best people to an organisation, including at the executive 
level, and provides the best environment for company growth and cohesion. All energy companies and projects 
need to work on improvements in diversity, equality and inclusion. The nuclear sector has shown developments in 
gender equality but there is still more to do.  
As mentioned in the governance section, a number of countries are making strides towards gender and cultural 
diversity. Some of the Canadian nuclear companies report well on gender diversity on their boards, and Canada has 
implemented the Equal by 30 programme9 and the Driving the Advancement of Women in Nuclear (DAWN) to 
advance the participation of women in the clean energy transition, and to close the gender gap in this field.  
Human Resources Canada has also implemented a Diversity and Inclusion10 programme to foster diversity and 
inclusion within all organisations. The programme represents the right for diversity and inclusion of under-
represented groups in the electricity sector, including women and Canada’s indigenous population. The Diversity 
and Inclusion programme works with the Canadian Council for Aboriginal Business 11  to consider corporate 
 
9.  
For more information on this programme, see: www.equalby30.org/en/splashify-splash. 
10.  For more information on this programme, see: https://electricityhr.ca/workplace-solutions/diversity-inclusion/. 
11. See: www.ccab.com/programs/progressive-aboriginal-relations-par/.

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performance in Aboriginal relations. Further, the Canadian BlackNorth Initiative12 seeks to end systemic anti-black 
racism – over 450 companies have signed the initiative. These programmes also work with Nuclear Against Racism,13 
under which the nuclear industry has pledged to agree to stand in solidarity with black and indigenous communities, 
and people of colour across the world. 
In the UK, the revisions to the Nuclear Sector Deal will further address diversity and inclusion across the nuclear 
sector. The focus is likely to be on diversity of thinking and diversity of socio-economic backgrounds. There are also 
likely to be regional targets around cultural diversity to reflect the cultural diversity in different regions of the UK. 
The UK has also established a not-for-profit initiative called Inclusions and Diversity in Nuclear (IDN)14 with the aim 
of creating and inclusive and diverse industry.  
Energy companies and projects should have well managed policies and procedures on pay and remuneration 
through-out the organisation. The energy sector wants to attract bright and diverse individuals who can develop 
the industry and deliver high quality and high performing projects and companies.  
A corporate’s processes and procedures should also identify any pay gaps in the organisation to highlight 
unrepresented and disadvantaged groups. Pay gap analysis should identify inequality of pay, with is an obligation 
on the executive to monitor these areas to ensure that minorities are not disadvantaged. Wage levels and benefits 
should be assessed across the company to determine a fair distribution across the workforce; and against the living 
wage in their country to increase the socio-economic development of a region and a country. 
Organisations should disclose the percentage of the workforce who are covered by collective bargaining 
agreements and should assess its supply chain to ensure they allow for freedom of associations and collective 
bargaining. These metrics and processes are seen to respect the rights of workers and human rights. It is important 
that companies promote these rights across their own workforce and through their supply chains. 
Without proper checks and balances a company’s activities could facilitate human rights abuses and other social 
and environmental abuses. Without mechanisms for employees and stakeholders to report potential abuses, 
companies might miss the opportunities to identify, mitigate and manage activities. Reporting the number of 
operations that have been subject to human rights reviews – both within the company and across the lifecycle and 
supply chain –  is of key importance to organisations. Companies should also report any grievances raised and the 
type of grievances together with the number of operations and suppliers considered to be at risk of human rights 
abuses. 
Companies need to ensure that there are no risks of incidents of child, forced or compulsory labour through-
out their supply chains. An explanation of labour practices across the whole supply chain needs to be disclosed by 
the executive and the board. The elimination of child labour, forced labour and human trafficking requires 
companies to be open and transparent and to assess their supply chain ethics. Nuclear companies have to 
investigate their supply chain in great detail to meet regulatory requirements, which should protect against these 
practices. However, other energy sources also need to report correctly their supply chain activities, including the 
mining practices, for example around the mining of rare earth metals, lithium and cobalt. Only through openness 
and transparency by businesses and financial institutions will these unethical practices be eradicated. 
Health and well-being  
Maintaining strong standards of health and safety and worker’s rights can improve productivity and operational 
efficiency in businesses and enhance employee well-being, which in turn benefits the company as a whole. Proactive 
health and safety processes and procedures help to identify and mitigate potential risks. Health and safety not only 
relates to physical health and safety but also mental health and safety. Mental health and safety is becoming more 
of a focus in modern business. Mental health awareness together with access to medical and healthcare services 
helps to demonstrate a company’s commitment to these important issues. Clear communication linked to processes 
of how workers access medical and healthcare services are also important metrics.  
“Well-being is associated with numerous health, job, family, and economically-related benefits. [For example,] 
Higher levels of well-being are associated with decreased risk of disease, illness, and injury; better immune 
 
12. See: https://blacknorth.ca/the-pledge/. 
13. See: www.nuclearagainstracism.com. 
14. See: www.niauk.org/media-centre/member-news/inclusion-diversity-nuclear/.

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51 
functioning; speedier recovery; and increased longevity. Individuals with high levels of well-being are more 
productive at work and are more likely to contribute to their community.” (CDC, 2018) 
“Mental health problems and stress can affect anyone, regardless of their position in the business. Therefore, 
physical and mental well-being should be made a high priority in the workplace. Worryingly, for many, this isn’t the 
case. In the United Kingdom, 84% of managers acknowledge their responsibility in helping with employee mental 
health, but only 24% have any training in the area. Yet promoting well-being in the workplace can strengthen 
employee engagement, reduce the likelihood of poor mental health, and improve team happiness.” (Murphy, 2020)  
In the United Kingdom, an estimated 38.8 million working days were lost due to work-related ill health and 
non-fatal workplace injuries in 2019/2020.15. Deloitte reported in 2020 that poor mental health costs UK employers 
up to £45 billion a year; this is a rise of 16% since 2016 – an extra £6 billion a year.16   
“US businesses lose up to $300 billion yearly as a result of workplace stress and only 43% of US employees think 
their employers care about their work-life balance” (AIS, 2019). It is reported that “83% of US workers suffer from 
work-related stress and over a quarter of employees are at risk of burn-out in the next 12 months.”  
“Canadian companies lose an estimated $16.6 billion in productivity per year due to workers calling in sick, as 
a result of mental health issues. This is a trend that many expect to increase in severity as more workers are 
reporting higher levels of stress and other mental health concerns (…) One in four workers has left their job due to 
work-related stress”, according to a 2017 Monster Canada study. Similar statistics are available for other countries, 
the wellbeing of staff is becoming a bigger challenge and is reported to be getting worse. 
The nuclear industry has long been at the forefront of both general health and safety management and also 
nuclear specific health and safety. The global nuclear industry takes health and safety incredibly seriously. The 
nuclear sector has a wide range of health and safety regulations and systems in place to protect not only its workers 
(employees and supply chain) but also third parties. 
A company’s processes and procedures should ensure that records are maintained for the following elements 
as a minimum: 
• 
the number and rate of fatalities as a result of work-related injuries; 
• 
the number and rate of high-consequence work-related injuries; 
• 
the number and rate of recordable work-related injuries; 
• 
the main types of work-related injuries;  
• 
the number of hours worked. 
Safety in the workplace can refer to both physical and psychological safety. In both instances, it means having 
a workplace that does not put employee's health and safety at risk, and that the health and safety of members of 
the public are not affected by the activities of the employer.  
Radioactivity is managed through strict processes and procedures to ensure that not only the health and 
welfare of employees is maintained but also the health and safety of third parties –  both on-site and off the site – 
is maintained. This extends to the general public. This potential radiological health detriment across various 
industries, including power, medicine and airlines, is mitigated by strict regulatory regimes. The regimes cover both 
emissions associated with normal operation and limits the possibility of a release radioactive material as the result 
of an accident.  
The system of radiation protection that is used across Europe and worldwide is based on the recommendations 
of the International Commission for Radiation Protection (ICRP), and the International Commission on Radiation 
Units and Measurements (ICRU). The ICRP system of radiation protection is based on three fundamental principles: 
justification, optimisation and dose limitation. The principle of justification requires that any decision that alters the 
radiation exposure situation should do more good than harm. The principle of optimisation requires that the 
likelihood of incurring exposures, the number of people exposed and the magnitude of their individual exposure 
 
15. www.hse.gov.uk/statistics/dayslost.htm. 
16. www2.deloitte.com/uk/en/pages/press-releases/articles/poor-mental-health-costs-uk-employers-up-to-pound-45-billion-
a-year.html.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
should all be kept as low as reasonably achievable, taking into account economic and societal factors. The third 
principle of the ICRP’s system of protection is that of dose limitation. 
In the European Union, radiation protection legislation relating to ionising radiation derives from the Euratom 
Treaty. Its common objective is to establish uniform safety standards to protect the health of workers, patients and 
of the general public, and to ensure that they are applied. 
Nuclear safety is probably one of the most talked about topics, both within the nuclear sector and in the general 
public. It is an area that all nuclear companies take extremely seriously and is a principal core value of businesses 
within the sector across the world. 
Even though the occupational and public mortality and morbidity risks are lower than those of other power 
options, the perception of nuclear can far outweigh the reality. Misperceptions have resulted in the gold-plating of 
standards in the nuclear industry, in an attempt to manage these misperceptions. This can be to the detriment of 
projects moving ahead, and therefore, a balanced approach is required, as with other energy industries (Mckenna, 
2011). 
An IEA report on the environmental and health impacts of electricity generation put together existing studies 
to compare fatalities per unit of power produced for several leading energy sources (IEA, 2002). The agency 
examined the lifecycle of each fuel from extraction to post-use and included deaths from accidents and long-term 
exposure to emissions or radiation. Nuclear came out best, and coal proved to be the deadliest energy source. 
The IAEA notes that national governments are responsible for regulations that govern how safety at nuclear 
facilities is maintained, as well as to reduce radiation risks, including emergency response and recovery actions, to 
monitor releases of radioactive substances to the environment and to regulate the safe decommissioning of facilities 
and disposal of radioactive waste. However, the IAEA, through the Department of Nuclear Safety and Security, works 
to provide a strong, sustainable and visible global nuclear safety and security framework for the protection of people, 
society and the environment. This framework provides for the harmonized development and application of safety 
and security standards, guidelines and requirements; but it does not have the mandate to enforce the application 
of safety standards within a country. 
Skills for the future  
Skills improve a company’s future and a wide and diverse range of skills are key to the success of a company. Training 
and skills also help to improve careers prospects and to improve human capital. When companies fail to invest in 
training and skills it can result in a detrimental effect on a company’s performance. Training and development 
enhance a company’s ability to attract and retain talent, which in turn helps the company to grow. Training needs 
to cover a wide range of hard and soft skills which can help with an individual’s development.  
Reporting should include: types of training and topics, paid educational leave, training or education pursued 
externally and reskilling of employees. Providing information on the investment in training is also important.  
The rise in technology and development of companies’ processes and procedures has resulted in skills gaps. It 
is vital that companies identify those skills gaps and seek to fill them. This is crucial not only at an individual company 
basis but also across industries, regions and countries. If the socio-economic development of a region is to be 
undertaken, a long-term strategy for filling skills gaps should be considered as training to fill future skills gaps begins 
in schools. 
Companies should report on the number of unfilled skilled positions and report their strategies to hire and train 
candidates for these positions. 
Training and innovation can have a direct impact on a company’s performance and long-term value as well as 
employees on satisfaction. Companies should report on the investment made in training as a percentage of payroll 
and should analyse the effects of training and reskilling on the business.17  
Nuclear has had to invest heavily in upskilling. This is partially due to the hiatus in the construction of new 
nuclear power plants. Also, many people working on existing plants and sites are reaching retirement age and so 
the nuclear industry has had to spend considerable efforts in bring on the younger generation. Companies have 
 
17. The WEF recommends the Kirkpatrick Model, which evaluates four levels of training (Reaction – Learning – Behaviour – 
Results), each successive level representing a more precise measure of the effectiveness of a training program.

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53 
implemented training and apprenticeships to bring in new people to the industry across various skills to protect the 
industry for the future. 
Prosperity: SDGs 1, 8, 9 and 10 
Wealth creation and employment  
These metrics are intended to consider the wider socio-economic development activities of the company and the 
company’s impact on wider societal development. This is intended to be a more holistic approach that has recently 
been used by companies to consider their social impact.  
Assessments of the wider socio-economic impacts of a particular activity typically consider the following: 
• 
direct effects – the economic value created by the activity itself; 
• 
indirect effects – the economic value created by the supply chain that is needed to serve the activity itself;  
• 
induced effects – the impact on the wider economy by employees. 
Government bodies conduct extensive analysis for their country or region of the interlinkages between 
different activities within the overall economy. Multipliers are produced to capture the effects of a company’s 
activities on society. Multipliers can be either Type I or Type II. Type I multipliers capture the increment in economic 
value linked to indirect effects, but not induced effects. Type II multipliers capture the increment in economic value 
linked to indirect effects and induced effects. 
The reporting metrics expect companies to consider the jobs created during a defined period. For an 
established company that may be year on year; for a capital project that may be by phase of the project. Job creation 
is viewed as a key indicator of economic growth, and when taken together with remuneration and other processes 
and procedures indicates an ability of a company to attract talent. It is evidence of prosperity as it captures the 
ability of the company to support employment and growth in the region. 
Energy new build projects always create direct, new jobs. However, different levels of new jobs are created 
through different phases. An analysis by the WNA on Employment in the Nuclear and Wind Electricity Generating 
Sectors (2020) shows that for a given installed capacity, nuclear power generates more than 3 times more jobs than 
wind power.  
A 400 GW global nuclear fleet generates about 1.2 million direct and indirect jobs, or an average of 3000 
jobs/GW (NEA, 2020b). These jobs are long-term, requiring higher levels of education. Such high-skilled employment 
with premium wages can result in significant spill-over investment into the local and regional economy. 
The Canadian Nuclear Association’s report on the Benefits of Nuclear Energy for Canadians reported: 
“The many Canadian organizations that make up the nuclear industry create high quality jobs and 
bring income to our Canadian communities. This study has assessed the number of jobs created and 
the impact on Canada’s GDP with the following results: 
o 
The total number of jobs created across Canada is 76000 
o 
The total impact to the Canadian GDP is $17 Billion per year 
o 
The medical isotope industry with all its benefits to the health of Canadians creates 8500 
jobs 
…The impact on Canada’s economy in terms of GDP is $17 Billion per year.” (MZ Consulting, 2019) 
For example, the Hinkley Point C project in the United Kingdom will result in 25 000 employment opportunities, 
including over 1,000 apprenticeships during the construction phase and 900 permanent jobs onsite during the 60+-
year life of the plant. UK companies will deliver a proportion of the construction contracts, and the project is 
estimated to contribute to the local economy in the region of GBP 1.5 billion during construction, and about GBP 40 
million a year during operation. In contrast, 39% of all renewable energy jobs are in China (IRENA, 2019).

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Figure 4: Employment for 1GWe capacity of nuclear and wind  
(construction; O&M; decommissioning) 
 
Source: Adapted from NEA (2018, cited in NEA 2020b). 
With the development of small light water and Gen-IV reactors and more of a product-based approach, the 
wider socio-economic development will come from not only the energy project itself but also the wider 
manufacturing development. 
Capital expenditure (CapEx) is of particular relevance to capital projects. However, it is also relevant to 
established companies who are looking to grow and expand. When reporting on the wealth creation and 
employment metric, companies need to consider the CapEx minus depreciation as an indication of the company’s 
overall investment strategy. In addition, the metric reporting includes the payback to shareholders by considering 
share buybacks and dividends.  
Investment and payback are key indicators of a company’s growth strategy and its ability to expand its 
operations and to create additional employment. Also, wealth creation from investment activities can be evidenced 
through the CapEx versus shareholder distributions.  
The extent of any infrastructure investment and the services supported through it are an exceptional indication 
of growth. For a special purpose vehicle (SPV) established for a new infrastructure development, this is the main 
focus for the company. However, for an established company, new capital projects are evidence of growth. Any 
infrastructure development has an impact on the local communities and therefore on the socio-economic 
development of those communities. In kind and pro bono activities should not be discounted as they also have a 
wider benefit. This evidences a company’s capital and other contribution to the wider economy. 
Positive and negative impact on the wider economy need to be considered. The significance of the indirect 
economic impact should be considered in light of national and international benchmarks.  Socio-economic growth 
or decline needs to be considered to assess the wider and long-term impacts on society.

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55 
Energy affordability 
SDG 7 provides for access to affordable, reliable, sustainable and modern energy for all. Access to affordable, reliable 
and clean energy is crucial for achieving sustainable development goals, from eradicating poverty through to 
advancing health and education, facilitating industrial development and reducing greenhouse gas emissions. Since 
1992, energy’s role in meeting all of the SDGs has been identified; however, it is also important that energy be 
affordable and reliable to allow people access to other resources including schools, clean water and healthcare. 
One of the challenges as the world moves to decarbonised energy is the need to reconsider the basis for pricing 
energy - as with many aspects of modern life – to include the consequences of previously ignored externalities – in 
this case the previously un-priced consequences of CO2 pollution. Energy pricing and taxation varies significantly 
around the world with approaches varying on the extent of inclusion of sales tax or VAT, the extent to which time-
of-day pricing passes on some elements of production price variability (itself derived from a manufactured 
wholesale market mechanism) and even the extent to which costs are fully passed on to consumers or covered by 
wider taxation systems. The net effect of this has been to disguise the true costs of energy in some cases and some 
early attempts at behavioural economics have rendered energy pricing a socially inconsistent tool. The challenge 
for most countries as they replace their entire primary energy creation systems will be one of the sheer speed 
needed to achieve Net Zero, and as a consequence, there will not be time for a near-perfect cost optimisation.    
Low carbon energy, including wind, solar and nuclear, can provide the energy to ultimately achieve high living 
standards, good health, a clean environment and a sustainable economy.  According to the latest IEA/NEA study on 
the Projected Costs of Generating Electricity – 2020 Edition, nuclear is the dispatchable low-carbon technology with 
the lowest costs. Only large hydro reservoirs can provide a similar contribution at comparable costs but are 
constrained by geography. Electricity produced from nuclear long-term operations (LTO) is highly competitive and 
is not only the least cost option for low-carbon generation – when compared to building new power plants – but for 
all power generation across the board, if carbon costs of USD 30 per tonne of CO2 are taken into account for the 
emissions generated by coal- and gas-fired power plants (IEA/NEA, 2020). 
There is the modern comparison of access to energy in developed countries as being as much of a human right 
as the right of access to virtually limitless supplies of clean water.  Driving significant changes in demand through 
conventional pricing signals increasingly looks to be hard where it relies on human interaction. The drive to Net Zero 
is the biggest challenge rather than the need for more affordable technologies. 
Nuclear power plants are a clear example of resilient facilities. The resilience of nuclear energy is the result of 
the combination of high levels of safety, operational flexibility and continuous learning from previous major events. 
By design, and beyond design, nuclear power plants are conceived following the principles of defence-in-depth: 
prevention, protection and mitigation (IAEA, 2016). This results in the implementation of redundant, independent 
and diversified safeguards designed to withstand external hazards. From an organizational perspective, nuclear 
facilities also incorporate emergency and contingency plans to rapidly identify critical activities and maintain normal 
operations with limited personnel. 
Confronted with major disruptions in the past, the nuclear sector has been required to adapt profoundly, while 
always continuing to provide a stable supply of low-carbon electricity. Current nuclear systems and operations have 
been refined according to an evolving regulatory environment seeking the highest level of safety and reliability in 
the most diverse situations, including extreme weather events like those caused by climate change. The resulting 
nuclear governance models incorporate procedures and approaches that allow the continuous assessment of 
ongoing practices, the application of corrective measures and the integration of the latest knowledge available.  
At the system level, a resilient low-carbon infrastructure requires a balanced and diversified power mix. 
Different technologies have different complementary roles in low-carbon electricity systems. Flexible power 
provision by plants that are dispatchable upon demand makes nuclear power an indispensable complement to wind 
and solar production in countries without large amounts of hydropower capacity. Furthermore, it also supports 
electric grid stability by providing valuable inertia, reactive capacity and voltage control to the system. Additional 
operational resilience can be obtained with strategic fuel stockpiles. One of the main advantages of nuclear power 
is the easiness of securing energy-dense uranium fuel for several years of operation.  
Innovation in better products and services 
Innovation is key to prosperity. R&D spend is seen as a basic indication of a company’s attempts to innovate and 
therefore be fit for the future. It can also indicate the company’s ability to adapt to new market conditions and to 
create further socio-economic benefits, including delivery of SDGs. Nuclear R&D and innovation are continuous. The

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
industry constantly looks to find better ways of delivering clean nuclear power. However, much R&D spend is funded 
by governments which is not directly applicable to this metric as it is not reflective of a company investing in its own 
future. 
The R&D spend of an individual supply company or the supply chain will be subject to reporting on the relevant 
project. Accompanying the financial data should be a report on how the company is preparing for different scenarios 
and future proofing itself. This will allow investors to understand better how the company is protecting itself from 
innovation and disrupters in its industry. 
There is considerable R&D spend across the nuclear sector. While much of this comes from countries and 
governments, there is more and more private equity being ploughed into small light water and Gen-IV technologies. 
Two examples of private sector investment are: 
• 
Moltex Energy, which has raised significant financing from the private sector to help with the development of 
its molten salts technology;  
• 
Bill Gates, who is a cornerstone investor in Terrapower, which is developing various technologies.  
There are various other examples of the private sector and philanthropists investing in new nuclear 
technologies in the race to combat climate change. 
Community and social vitality  
These metrics consider the wider benefits of a company’s activities through its taxes paid and social investment. It 
takes into consideration the wider payments into the wider economy.  
Total tax includes corporation tax, income taxes, property taxes, VAT, and other sales and payroll taxes. 
Reporting total tax paid provides global information on the company’s contribution to governmental revenues 
through different forms of taxes, which in turn support governmental functions and public benefits.  
This is intended to be an oversight of ESG efforts. This metric is intended to be a more inclusive definition of 
community investment. It seeks to capture the multiple ways in which companies can demonstrate their 
investments in social activities beyond traditional charity giving.  
It provides an ability for companies to report on additional global tax collected by the company on behalf of 
other taxpayers – for example VAT and employee’s tax. This allows companies to report on their further global 
contributions to government revenues. This includes reporting on the total tax paid and reported, and additional 
tax remitted by country for all of the company’s significant locations. Companies may choose to supplement their 
reporting on tax paid.  
The amount of tax paid and remitted by a company will depend on the company and any allowances permitted 
for areas such as R&D. The tax reporting should not differ depending on technology.

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57 
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content/uploads/2019/11/MZ-Consulting-Benefits-of-Nuclear-Energy-for-Canadians.pdf. 
NEA (2020a), “Building low-carbon resilient electricity infrastructures with nuclear energy in the post-COVID-19 era”, 
NEA Policy Brief, OECD Publishing, Paris, www.oecd-nea.org/jcms/pl_34623/building-low-carbon-resilient-
electricity-infrastructures-with-nuclear-energy-in-the-post-covid-19-era. 
NEA (2020b), “Creating high-value jobs in the post-COVID-19 recovery with nuclear energy projects”, NEA Policy 
Brief, OECD Publishing, Paris, www.oecd-nea.org/news/2020/covid-19/post-covid-19-recovery/policy-brief-2-
jobs-in-nuclear.pdf. 
NEA/IAEA (2020), Uranium 2020: Resources, Production and Demand, OECD Publishing, Paris, www.oecd-
nea.org/jcms/pl_52718/uranium-2020-resources-production-and-demand. 
NEA (2012), The Role of Nuclear Energy in a Low-Carbon Energy Future, OECD Publishing, Paris, 
https://doi.org/10.1787/134a2dbe-en. 
OECD (2008), Moving Forward with Geological Disposal of Radioactive Waste – A collective statement by the NEA 
Radioactive 
Waste 
Management 
Committee 
(RWMC), 
OECD 
Publishing, 
Paris, 
www.oecd-
nea.org/upload/docs/application/pdf/2019-12/nea6433-statement.pdf   
OECD (2020), Green Finance and Investment – Developing Sustainable Finance Definitions and Taxonomies, OECD 
Publishing, Paris, https://doi.org/10.1787/134a2dbe-en. 
Oxford Economics (2019), Nuclear Power Pays: Assessing the Trends in Electric Power Generation Employment and 
Wages, Oxford Economics Publication, New York, www.oxfordeconomics.com/my-oxford/projects/494437.  
Pehl, M., A. Arvesen, F. Humpenöder, A. Popp, E. G. Hertwich, G. Luderer (2017), “Understanding future emissions 
from low-carbon power systems by integration of life-cycle assessment and integrated energy modelling,” 
Nature Energy 2, pp. 939-945, https://doi.org/10.1038/s41560-017-0032-9. 
USNRC (2020), Safety Culture, United States Nuclear Regulatory Commission, USNRC Publishing, 
www.nrc.gov/about-nrc/safety-culture.html  
WANO (2013), WANO Principles, Traits of a Healthy Nuclear Safety Culture, PL 2013-1, World Association of Nuclear 
Operators Publishing, www.wano.info/getmedia/49f169b0-a385-4cd2-a7d8-2f64b64cd8d2/WANO-PL-2013-
1-Pocketbook-English.pdf.aspx 
WEF (2020), Measuring Stakeholder Capitalism: Towards Common Metrics and Consistent Reporting of Sustainable 
Value Creation, World Economic Forum, Prepared in collaboration with Deloitte, EY, KPMG and PwC, 
www3.weforum.org/docs/WEF_IBC_Measuring_Stakeholder_Capitalism_Report_2020.pdf. 
WNA (2020), Employment in the Nuclear and Wind Electricity Generating Sectors, World Nuclear Association, 
www.world-nuclear.org/getmedia/690859bf-ebe6-43a2-bedd-57ddf47ee3ac/Employment-in-Nuclear-
Report-Final.pdf.aspx

STANDARD METRICS – WEF, SASB AND TCFD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
59 
Appendix I. Standard ESG – World Economic Forum, Sustainability Accounting 
Standards Board (SASB) and Task Force on Climate-related Financial Disclosures 
(TCFD) 
Figure 5: The 17 United Nations Sustainable Development Goals 
 
 Source: UN (2020) 
General 
There is an urgent demand for consistency and comparability in sustainability reporting. To obtain the greatest 
benefit of adopting these metrics, there needs to be consistency not only of the metrics but also as to how assets 
are intended to report, and therefore how the investment community assesses whether companies are ethical, 
socially responsible and eco-friendly. They need to be applied consistently across asset classes.  
World Economic Forum consultation on standardised metrics 
The Generation IV International Forum and the Taskforce welcomes the World Economic Forum’s (WEF) 2020 
consultation and report on a proposed conformed set of ESG. In this report the Taskforce has mapped the WEF 
metrics against the Sustainability Accounting Standards Board (SASB) and the Task Force for Climate Related 
Financial Disclosure (TCFD) standards to address concerns raised by the finance and energy industries. These 
mapped metrics have been use through-out this report. 
Sustainable Accounting Standards Board – Different criteria for different industries 
The Taskforce recommended using the Electric Utilities and Power Generators Sustainability Accounting Standards 
from the SASB suite of metrics. These are more relevant to existing generators and transmission companies rather 
than new build, project finance or capital projects.

STANDARD METRICS – WEF, SASB AND TCFD  
60 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
The SASB use of the term “sustainability” refers to corporate activities that maintain or enhance the ability of 
the company to create value over the long term.  Sustainability accounting reflects the governance and management 
of a company’s environmental and social impacts arising from the production of goods and services, as well as its 
governance and management of the environmental and social capitals necessary to create long term value. They 
identify a minimum set of criteria and do not include issues such as Board governance.   
The SASB criteria apply to production and transmission of electricity only. They may not be sufficient when the 
energy assets are being used for other production such as medical, heat, hydrogen or synthetic fuels. 
In addition to sustainability metrics, the SASB has activity metrics looking at: 
• 
Number of residential, commercial and industrial customers served; 
• 
Total electricity delivered to residential, commercial, industrial and other retail customers and wholesale 
customers; 
• 
Length of transmission and distribution lines; 
• 
Total electricity generated percentage by major energy source, percentage of regulated markets; and 
• 
Total wholesale electricity purchased. 
Task Force on Climate-related Financial Disclosure  
In June 2017, the TCFD released its final recommendations which provide a framework for companies and other 
organisations to develop more effective climate-related financial disclosures. The TCFD is supported by 110 
regulators and government entities from around the world. These include Belgium, Canada, Chile, France, Japan, 
New Zealand, Sweden and the UK. 
The TCFD is seeing governments embed the recommendations in policy and guidance and move towards 
requiring TCFD disclosures. These include: 
• 
“New Zealand’s Ministry for the Environment announced that the government plans to make climate-related 
financial disclosures mandatory for certain publicly listed companies and large financial institutions. 
• 
The European Commission incorporated the TCFD recommendations into its Guidelines on Reporting Climate 
Related Information to support companies in disclosing climate-related information under the European 
Union’s reporting requirements; and 
• 
The United Kingdom’s Financial Conduct Authority released a proposal for certain listed companies to state in 
their annual financial reports whether they made disclosures consistent with the TCFD recommendations.” 
(TCFD, 2020)  
The TCFD splits its recommendations and supporting recommended disclosures into: Governance, Strategy, 
Risk Management and Metrics and Targets. It focuses on climate-related disclosures and is not as wide as the World 
Economic Forum criteria. The TCFD criteria are more often used in the project finance world – so are more related 
to nuclear new build projects than SASB.

STANDARD METRICS – WEF, SASB AND TCFD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
61 
Governance: SDGs 12, 16 and 17 
 
 
 
World Economic Forum 
 
SASB 
TCFD 
Theme 
Sub-theme 
Topic 
Metric 
Recommendation 
Supporting 
disclosure 
Governing 
purpose 
Material 
stakeholder buy-in 
 
 
 
 
Quality of 
governing 
body 
Board composition 
 
 
 
 
 
Progress against 
strategic 
milestones 
 
 
 
 
 
Remuneration 
 
 
 
 
Stakeholder 
engagement 
Impact of material 
issues on 
stakeholders 
 
 
 
 
 
Process for 
engaging 
stakeholders 
 
 
 
 
Ethical 
behaviour 
Anti-corruption 
 
 
Governance: 
disclose the 
company’s 
governance 
around climate-
related risks and 
opportunities. 
Describe the 
board’s oversight 
of climate-
related risks and 
opportunities. 
 
Ethics and 
reporting 
 
 
 
 
Risk and 
opportunity 
oversight 
Integrating risk 
and opportunity 
 
 
Governance: 
disclose the 
company’s 
governance 
around climate-
related risks and 
opportunities. 
Describe 
management’s 
role in assessing 
and managing 
climate-related 
risks and 
opportunities. 
 
 
 
 
Strategy: disclose 
the actual and 
potential impacts 
of climate-related 
risks and 
opportunities on 
the company’s 
businesses, 
strategy and 
financial planning 
where such 
information is 
material. 
Describe the 
climate-related 
risks and 
opportunities the 
company has 
identified over 
the short, 
medium and 
long term.

STANDARD METRICS – WEF, SASB AND TCFD  
62 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Planet: SDGs 6, 7, 12, 13, 14 and 15 
World Economic Forum 
SASB 
TCFD 
Theme 
Sub-theme 
Topic 
Metric 
Recommendation 
Supporting 
disclosure 
Climate 
change 
Greenhouse 
gas (GHG) 
emissions 
GHG 
emissions 
and energy 
resource 
planning 
1) Gross global 
scope 1 
emissions, 
percentage 
covered under; 2) 
emissions-limiting 
regulations; and 
3) emissions-
reporting 
regulations  
Scope 1 refers to 
all direct GHG 
emissions.  
Scope 2 refers to 
indirect GHG 
emissions from the 
consumption of 
purchased 
electricity, heat or 
steam. 
Scope 3 refers to 
other indirect 
emissions not 
covered in scope 2, 
which occur in the 
value chain of the 
reporting company, 
including both 
upstream and 
downstream 
emissions.  
 
 
 
Impact of GHG 
emissions 
 
GHG emissions 
associated with 
power deliveries 
 
 
 
Task Force on 
Climate-
Related 
Financial 
Disclosure 
aligned 
reporting on 
material climate 
risks and 
opportunities 
 
Discussion of 
long-term and 
short-term 
strategy or plans 
to manage scope 
1 emissions, 
emission- 
reduction targets, 
and an analysis 
of performance 
against those 
targets  
Strategy: disclose 
the actual and 
potential impacts of 
climate-related 
risks and 
opportunities on the 
company’s 
businesses, 
strategy and 
financial planning 
where such 
information is 
material. 
Describe the 
resilience of the 
company’s 
strategy, taking 
into 
consideration 
different climate-
related 
scenarios, 
including a 2°C 
or lower 
scenarios. 
 
 
 
1) Number of 
customers served 
in markets 
subject to 
renewable 
portfolio 
standards (RPS); 
and 2) 
percentage 
fulfilment of RPS 
target by market  
 
 
 
Science-based 
targets to 
reduce GHG 
emissions 
 
 
Risk management: 
disclose how the 
company identifies, 
assesses, and 
manages climate-
related risks. 
Describe how 
processes for 
identifying, 
assessing and 
managing 
climate-related 
risks are

STANDARD METRICS – WEF, SASB AND TCFD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
63 
integrated into 
the company’s 
overall risk 
management. 
 
TCFD-aligned 
reporting 
 
 
Metrics and targets: 
disclose the metrics 
and targets used to 
assess and 
manage relevant 
climate-related 
risks and 
opportunities where 
such information is 
material 
Disclose the 
metrics used by 
the company to 
assess climate-
related risks and 
opportunities in 
line with its 
strategy and risk 
management 
process.  
Disclose Scope 
1, Scope 2 and, 
if appropriate, 
Scope 3 GHG 
emissions and 
the related risks.  
Describe the 
targets used by 
the company to 
manage climate-
related risks and 
opportunities and 
performance 
against targets. 
Nature loss 
Land use and 
ecological 
sensitivity 
 
 
 
 
 
Impact of land 
use 
 
 
 
 
Fresh water 
availability 
Fresh water 
consumption in 
water stressed 
areas 
Water 
management 
1) Total water 
withdrawn; 2) 
total water 
consumed, 
percentage of 
each in regions 
with high or 
extremely high 
baseline water 
stress.  
 
 
 
 
 
Number of 
incidents of non-
compliance 
associated with 
water quantity 
and/or quality 
permits, 
standards and 
regulations. 
 
 
 
 
 
Description of 
water 
management 
risks and 
discussion of 
strategies and 
practices to 
mitigate those 
risks.

STANDARD METRICS – WEF, SASB AND TCFD  
64 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
 
 
Impact on fresh 
water 
consumption 
 
 
 
 
Air pollution 
Fine particle 
matter 
Air quality 
Air emissions of 
the following 
pollutants: 1) 
NOx (excluding 
N2O); 2) SOx; 3) 
particulate matter 
(PM10); 4) lead 
(Pb); and 5) 
mercury (Hg); 
percentage of 
each in or near 
areas of dense 
population.  
 
 
 
Impact on air 
pollution 
 
 
 
 
Water 
pollution 
Nutrients 
 
 
 
 
 
Impact on 
water pollution 
 
 
 
 
Solid waste 
Single use 
plastics 
 
 
 
 
 
Impact on solid 
waste disposal 
 
 
 
 
Resource 
availability  
Resource 
circularity

STANDARD METRICS – WEF, SASB AND TCFD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
65 
People: SDGs 1, 3, 4, 5 and 10 
World Economic Forum 
SASB 
TCFD 
Theme 
Sub-theme 
Topic 
Metric 
Recommendation 
Supporting 
disclosure 
Dignity and 
equality 
Gender pay 
equality 
 
 
 
 
Diversity and 
inclusion 
 
 
 
 
 
Pay equality and 
pay gaps 
 
 
 
 
 
Wage level 
 
 
 
 
 
Human rights 
review, grievance 
impact and modern 
slavery 
 
 
 
 
 
Risk of incidents of 
child, forced or 
compulsory labour 
 
 
 
 
 
Discrimination and 
harassment 
incidents and 
monetary losses 
 
 
 
 
 
Freedom of 
association and 
collective 
bargaining 
 
 
 
 
 
Living wage 
 
 
 
 
Health and well-
being 
Health and safety 
Workforce 
health and 
safety 
1) Total 
recordable 
incident rate; 2) 
fatality rate; 
and 3) near 
miss frequency 
rate  
 
 
 
Monetised impacts 
of work-related 
incidents on 
employees, 
employers and 
society 
 
 
 
 
 
Well-being 
 
 
 
 
 
 
Nuclear 
safety and 
emergency 
management 
Total number of 
nuclear power 
units, broken 
down by the 
US Nuclear 
Regulatory 
Commission 
(NRC) Action 
Matrix column

STANDARD METRICS – WEF, SASB AND TCFD  
66 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
 
 
 
 
 
Description of 
efforts to 
manage 
nuclear safety 
and emergency 
preparedness 
 
 
Skills for the 
future 
Training 
 
 
 
 
 
Number of unfilled 
skilled positions 
 
 
 
 
 
Monetised impacts 
of training – 
increasing earning 
capacity as a result 
of training 
intervention

STANDARD METRICS – WEF, SASB AND TCFD 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
67 
Prosperity: SDGs 1, 8, 9 and 10 
World Economic Forum 
SASB 
TCFD 
Theme 
Sub-theme 
Topic 
Metric 
Recommendation 
Supporting 
disclosure 
Wealth 
creation and 
employment 
Number of 
jobs created 
 
 
Strategy: disclose the 
actual and potential 
impacts of climate-
related risks and 
opportunities on the 
company’s 
businesses, strategy 
and financial planning 
where such 
information is 
material. 
Describe the 
impact of 
climate-related 
risks and 
opportunities on 
the company’s 
businesses, 
strategy and 
financial 
planning. 
 
Economic 
contribution 
 
 
 
 
 
Financial 
investment 
contribution 
 
 
 
 
 
Infrastructure 
investment 
and services 
supported 
 
 
 
 
 
Significant 
indirect 
economic 
impacts 
 
 
 
 
 
 
Energy 
affordability 
Average retail 
electricity rate for 1) 
residential; 2) 
commercial; and 3) 
industrial customers. 
 
 
 
 
 
Typical monthly 
electric bill for 
residential customers 
for 1) 500 kWh; and 
2) 1 000 kWh of 
electricity delivered 
per month.  
 
 
 
 
 
Number of residential 
customer electric 
disconnections for 
non-payment, 
percentage 
reconnected within 
30 days. 
 
 
 
 
 
Discussion of the 
impact of external 
factors on customer 
affordability of 
electricity, including 
the economic 
conditions of the 
service territory.

STANDARD METRICS – WEF, SASB AND TCFD  
68 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
 
 
End-use 
efficiency 
and 
demand 
Percentage of 
electric utility 
revenues from rate 
structures that 1) are 
decoupled; and 2) 
contain a lost 
revenue adjustment 
mechanism.  
 
 
 
 
 
Percentage of 
electric load served 
by smart grid 
technology. 
 
 
 
 
 
Customer electricity 
savings from 
efficiency measures 
by market. 
 
 
 
 
Grid 
resiliency 
Number of incidents 
of non-compliance 
with physical and/or 
cybersecurity 
standards or 
regulations.  
 
 
 
 
 
1) System Average 
Interruption Duration 
Index; 2) System 
Average Interruption 
Frequency Index; 
and 3) Customer 
Average Interruption 
Duration Index, 
inclusive of major 
event days. 
 
 
Innovation in 
better 
products and 
services 
R&D 
spending 
ratio 
 
 
 
 
 
Social value 
generated 
and vitality 
index 
 
 
 
 
Community 
and social 
vitality 
Total tax 
paid 
 
 
 
 
 
Total social 
investment  
 
 
 
 
 
Additional 
tax remitted 
 
 
 
 
 
Total tax 
paid by 
country for 
significant 
locations.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
69 
Appendix II. Consistent and transparent reporting  
Governance: SDGs 12, 16 and 17 
Governing purpose 
The governing purpose should be clearly articulated in a 
company’s 
documentation 
establishing 
the 
company, 
whether that be Articles of Association, Members Agreements 
or other. It is often forgotten that a company has its own legal 
personality, and that governing purpose is linked to that 
specific legal entity. The leadership team needs to be 
conscious of the “hat it is wearing”, as well as the company 
and purpose, they are representing. The legal requirements 
for a company vary from jurisdiction to jurisdiction. However, 
the governing purpose of the company should be clearly established from the offset; and there is an emerging focus 
on boards signing up to their own ESG statement to show how they will deliver their governing purpose in line with 
ESG. Often companies start to expand their remit by drift rather than purposefully; they do this without being clear 
about the governing purpose of the company as the company evolves and without updating the company’s 
documentation. The board statement should evolve in line with the company’s governing purpose. According to the 
WEF, there is emerging evidence that purpose-led firms outperform their peers in terms of shareholder value and 
are better positioned to account for and deliver economic, environmental and social value. 
This is often clearer with energy companies who have a clear governing purpose as a utility, a generating 
company, a technology company, an operating company and/or a development company. This is definitely easier 
for special purpose vehicles (SPVs) which are established for a specific purpose such as developing and constructing 
an asset (e.g. in energy, a renewable plant or a nuclear plant). However, confusion has arisen in recent years when 
technology companies (companies whose purpose is to develop and sell a technology) have invested in capital 
project development companies (i.e. SPVs established to develop and construct, and possibly to operate and 
decommission an energy asset), resulting in confusion in the market. This has been seen in the nuclear market. 
Clearer delineation of roles and transparency is required to maintain clear governing purposes. 
The governing purpose should state how the company proposes to fulfil its governing purpose through 
economic, social and environmental means. The board of the company should promote the long-term sustainable 
success of the company, generating value for shareholders and contributing to wider society. This is particularly true 
of energy projects and companies who are often key to the socio-economic development of communities and 
countries. The board needs to ensure that the company’s purpose, values and strategy are aligned to the corporate 
culture and to workforce policies and practices. It should also establish a framework of prudent and effective 
controls and ensure effective engagement with shareholders and stakeholders (see more on stakeholder 
management below). 
Material stakeholder buy-in 
All material stakeholders need to buy into the company’s governing purpose. The company will need to identify and 
manage all material issues that could affect stakeholders. The company will need to manage its stakeholders’ 
expectations and understanding. This is further reason for a clearly defined governing purpose which meets ESG. 
The number of stakeholders in any energy project, but particularly in nuclear projects, are extensive and complex 
and stakeholder need to be kept informed of developments within the company. This is especially true in any new 
build project where the local community, local government and central governments will need to align for the 
project to move ahead.  
Whether a nuclear or energy company has met this metric will depend on the individual company and will form part 
of investors’ assessment of the company’s reporting.  
World Economic Forum 
Theme 
Sub-theme 
Governing 
purpose 
Material stakeholder buy-in 
Quality of 
governing body 
Board composition, 
progress against strategic 
milestones, remuneration

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
70 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Quality of governing body 
The quality of the company’s governing body (i.e. both the board and the executive) are key to the successful 
performance of a company.   
However other key elements are the processes and procedures established for the board and for any board 
committees such as the audit committee, the remuneration committee etc… Finally, the differentiation and balance 
between the executive and non-executive team is a further key element in the overall quality of the governing body. 
As nuclear companies and projects tend to be long-term propositions, they often have not only independent non-
executive directors to provide oversight and challenge but also advisory positions to provide support to the company.  
Board composition 
The capabilities, thinking, experience and perspectives of the board members are key to the successful operation of 
the company. Much has been written in recent years about the importance of diversity of the individuals and 
diversity of thought. According to the WEF research, examining public companies across multiple jurisdictions has 
found that companies with higher diversity financially outperform their peers. 
A diverse and inclusive board and workforce brings out the best in its’ people and provides a better 
understanding of the needs of its customers. It is also better equipped to manage risk, and exhibits responsibility 
for the organisation. Diversity of thinking also provides the most fertile environment for innovation and disruption, 
allowing the company the ability to quickly pivot to meet changing demands.   
Diversity remains a challenge for the energy industry as a whole. Gender diversity is only one area of diversity, 
but women are generally better represented than other groups identified by cultural, racial, sexual orientation or 
disability. However, the energy market is not a very diverse industry for women. The International Energy Agency 
(IEA) stated: 
Women’s participation in the energy sector is below that of the broader economy and varies widely 
across energy sub-sectors. Despite making up 48% of the global labour force, women only account for 
22% of the labour force in the oil and gas sector and 32% in renewables. These gender gaps in 
employment vary across the different energy sub-sectors. 
For example, based on labour force survey data for the European Union, we find that women’s share 
of employment in energy sub-sectors perform poorly when compared with both the overall labour 
force (46%) and to other industrial sub-sectors. The lowest performing sub-sector, which is also 
energy-related, is mining of coal and lignite. (IEA, 2020) 
In April 2020, PwC conducted a survey for Powerful Women1 looking at women in energy companies and found 
that 38% of UK energy companies have no women on the board and only 21% of board positions in UK energy 
companies were help by women; with only 13% of executive board positions across UK energy companies held by 
women.  
The nuclear industry is slightly better than the other parts of the energy industry, including renewables, in terms 
of gender diversity. Some of the Canadian nuclear companies report extremely well on gender diversity on their 
boards, with Canada having implemented the Equal by 30 programme2 and the Driving the Advancement of Women 
in Nuclear (DAWN) to advance the participation of women in the clean energy transition and to close the gender 
gap.  
Human Resources Canada has also implemented a Diversity and Inclusion3 programme to foster diversity and 
inclusion within all organisations. The programme represents the right for diversity and inclusion of under-
represented groups in the electricity sector, including women and Canada’s indigenous population. The Diversity 
and Inclusion programme works with the Canadian Council for Aboriginal Business 4  to consider corporate 
performance in Aboriginal relations. Further, the Canadian BlackNorth Initiative5 seeks to end systemic anti-black 
racism – over 450 companies have signed up to the initiative. These programmes also work with Nuclear Against 
 
1. 
See: https://powerfulwomen.org.uk/board-statistics-by-company/. 
2. 
See: www.equalby30.org/en/splashify-splash. 
3. 
To learn more about this programme, see: https://electricityhr.ca/workplace-solutions/diversity-inclusion/. 
4. 
See: https://www.ccab.com/programs/progressive-aboriginal-relations-par/. 
5. 
See: https://blacknorth.ca/the-pledge/.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
71 
Racism,6 under which the nuclear industry has pledged to agree to stand in solidarity with black and indigenous 
communities, and people of colour across the world. 
In the UK, the revisions to the Nuclear Sector Deal will further address diversity and inclusion across the nuclear 
sector. The focus is likely to be on diversity of thinking and diversity of socio-economic backgrounds. There are also 
likely to be regional targets around cultural diversity to reflect the cultural diversity in different regions of the UK. 
The UK has also established a not-for-profit initiative called Inclusions and Diversity in Nuclear (IDN)7 with the aim 
of creating an inclusive and diverse industry. 
The energy sector as a whole has a long way to go before it can be seen as truly diverse. Whether a particular 
board composition is sufficient is a matter for each company’s reporting.  
Progress against strategic milestones 
Organisations need to be purpose lead. The ability to achieve milestones provides a useful mechanism to assess 
whether the board and its management have the ability to oversee the company and to deliver the stated purpose. 
It provides an indication of the ability of the board and executives to guide and lead the company. 
Corporates should have a strategic plan for delivery of its purpose which should be measurable.  
Capital Project SPVs will have a project plan, which will set milestones: 1) during the development period to 
financial close; and 2) during construction, which would link to investor draw-downs. Progress against the plan 
should be easily managed and reported on. Once operational, they will behave as an existing corporate with 
milestones for operation and outages. These are all very measurable. In addition, the impact on the wider socio-
economic development of a region may be linked to a capital SPV milestones.  
It is important that projects run to time and to budget. In the West, projects are often late and over-budget 
and historically this has been a problem for large nuclear projects. As nuclear moves to more of a modular and 
product-based approaches (i.e. minimal on-site construction time) with the majority of the plant being factory built, 
this should improve dramatically.   
However, delays and cost overruns are not just the domain of the nuclear industry. Other energy projects are 
often over budget and delayed. According to one study on cost overruns and electricity infrastructure, “An analysis 
of 401 power plant and transmission projects in 57 countries suggests that costs are underestimated in three out of 
every four projects, with only 39 projects across the entire sample experiencing no cost overrun or underrun. 
Hydroelectric dams, nuclear power plants, wind farms and solar facilities each have their own unique set of 
construction risks.” (Sovacool et al., 2014) 
According to another study examining megaprojects, “Results show that construction costs were, on average, 
97.53% above the initial estimates. The distribution that best fits the hydroelectric power plants costs overruns is 
the gamma distribution. For the delays, the construction completion time had an average increase of 74.28%, or 3.5 
years.” (Callegari et al., 2018) 
Remuneration 
The company’s remuneration policy needs to reflect the company and the project. Energy projects are vital to 
society and to the socio-economic development and regeneration for regions and countries. The remuneration 
policy, performance criteria, appraisal and assessment processes and performance incentives should reflect the 
delivery of the stated purpose and reflect the importance to society of these projects. 
Having the right remuneration policy should reinforce the long-term value creation of energy projects. The 
remuneration of the board and executive can reinforce or impede long-term socio-economic development but the 
remuneration throughout the company is also important to support the value creation of the team. Without the 
correct remuneration policy, the company will not attract the current level of candidates and also will not raise the 
wage levels for any areas that they are trying to regenerate. Further, the structure should be transparent to allow 
the development of trust and openness for all stakeholders, both internal and external.   
 
6. 
See: www.nuclearagainstracism.com. 
7. 
See: www.niauk.org/media-centre/member-news/inclusion-diversity-nuclear/.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Energy companies tend to remunerate reasonably well. Capital projects generally remunerate better to reflect 
the risks being undertaken in trying to get the project developed. Capital project remuneration packages also tend 
to include success fees and bonuses linked to the milestones achieved. While corporates also link bonuses to 
milestones, they are often lower, reflecting the level of risk involved.  
The nuclear sector generates a significant amount of high-skilled, high-paid and mostly local jobs for an 
extended period of time – often more than 60 to 80 years – including construction, operations and decommissioning 
(NEA, 2020b). An Oxford Economics study for the Nuclear Energy Institute (NEI) in the United States, entitled Nuclear 
Power Pays: Assessing the Trends in Electric Power Generation Employment and Wages (2019), indicated that in 
average jobs in nuclear energy are 20% better paid than in fossil fuel generation, and 30% better than wind and 
solar generation, directly demonstrating the higher education in nuclear as well as the higher potential for induced 
activities and jobs. 
Whether a nuclear or energy company has met this metric will depend on the individual company and will form 
part of the company’s reporting.  
 
Stakeholder engagement 
The relationship between energy companies or projects and their 
stakeholders is important. Understanding the impact of the 
company on internal and external stakeholders is key to the 
success of the company. As companies move to more defined 
purposes 
with 
socio-economic 
development 
objectives, 
stakeholder engagement becomes more important. The criteria 
require the identification of a wide range of stakeholders and the 
impact the company’s activities have on those stakeholders. 
As stated by the International Atomic Energy Agency (IAEA) on its website regarding Stakeholder Engagement 
processes and guidance: 
“Involving a wide range of interested parties in the decision-making on nuclear power programmes 
can enhance public awareness, understanding and confidence. This is also important for those 
stakeholders that do not have a direct role in making those decisions. 
Member States often identify the effective communication with stakeholders, and their awareness 
and understanding, as one of the biggest challenges when initiating a nuclear power programme or 
undertaking related activities, such as uranium mining. Creating awareness and promoting 
understanding among the various interested parties, who do not only come from the nuclear industry 
or government institutions but also the media, local communities and non-governmental 
organizations, is essential to build mutual trust related to nuclear science and technology questions. 
Therefore, designing and implementing productive stakeholder involvement programmes starts with 
communication about energy policies and strengthening stakeholders’ understanding of nuclear 
power, including its benefits and risks.” (IAEA, Stakeholder Involvement, n.d.) 
Impact of material issues on stakeholders and process for engaging stakeholders 
Stakeholder engagement and management is something the energy industry, and particularly the nuclear industry, 
is used to doing. When developing new projects, energy companies engage with a large range of stakeholders in 
bringing the project to fruition. Stakeholders will include: the government, the planning authorities, regulators, local 
communities, schools, universities and off-takers. To develop these projects various hurdles will need to be 
overcome to reach financial close, including raising finance, getting all the relevant planning, environmental, 
planning and licensing approvals. This is even more stringent on nuclear projects where there are additional 
regulatory requirements to meet before a project can move ahead. 
With established energy companies, they maintain their relationships with stakeholders. Nuclear companies tend 
to maintain relationships with wider stakeholders as a matter of course as they are part of the community for such 
a long period of time and they often work with a whole range of stakeholders to maintain their position in the 
community. Nuclear can be a controversial topic for some stakeholders and nuclear companies work hard to 
World Economic Forum 
Theme 
Sub-theme 
Stakeholder 
Engagement 
Impact of Material 
Issues on 
Stakeholders 
 
Process for engaging 
stakeholders

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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73 
maintain their relationships. Nuclear companies often understand well their impact on different stakeholders and 
the importance to their business of maintaining those relationships.   
Nuclear projects are encouraged to engage with a wide range of stakeholders and to work with them in relation 
to the role of the project or company in the wider community.  This extends to not only the local stakeholders and 
local communities but to wider regional communities, indigenous people as well as to the schools, colleges and 
universities.  
Again, whether a company has met this metric will depend on the individual company and how well they have 
identified the material issues and engaged with a wide enough group of stakeholders.  
 
Ethical behaviour 
Bribery and corruption undermine 
stakeholder trust and are linked to 
fraudulent behaviour, misconduct, lack 
of governance and due process, 
misallocation 
of 
capital, 
illegal 
behaviour and human exploitation. In 
short, they fundamentally undermine 
businesses and all ESG. 
Ethical behaviour is brought into 
sharper focus in the energy sector and 
particularly in the nuclear sector. In the 
nuclear sector, employees are vetted to 
a higher standard because of them 
working with nuclear material on a 
nuclear site (see the Health and Safety 
section below). 
Anti-corruption 
Anti-corruption and bribery training is 
vital for the development and understanding of employees and to ensure that they understand the latest 
developments in anti-corruption and bribery prevention. However, training is not the “be all and end all” to protect 
the company and its reputation. Companies also need to invest in processes and procedures (including reporting) 
to ensure the highest levels of governance around anti-corruption and anti-bribery systems. Implementing gold star 
processes and procedures helps to prevent corruption and bribery in organisations. Companies need to be aware 
of not only the local laws that apply to the company but also other laws, legal systems and regulations that have an 
impact. Monitoring is also a key element of such processes.  
Energy is vital to countries socio-economic development. Energy projects are developed throughout the world, 
and investors need to be confident that concessions and contracts have been awarded in a professional, appropriate 
and ethical way. Corruption is a major concern for energy projects, particularly around renewable resources such 
as forests where deforestation is a concern, and in climate and green energy projects.  Projects can, if mismanaged, 
lead to environmental degradation and destruction. Mismanaging natural resources can dramatically affect the 
livelihoods of local people who are dependent on those resources. Corrupt practices can undermine ecosystems 
and global resources and often affect the most vulnerable people. Investors need to ensure that projects are 
undertaken and maintained ethically and with the support of the local community, so as not to adversely affect the 
local environment and population.8 
Projects can also be mismanaged through the lack of proper regulation and policy, and systems that do not 
allow any environmental impact to be assessed correctly. All energy projects need to assess the environmental 
impact of their project in great detail, including the impact on habitats. Nuclear projects are more diligent than 
 
8. 
 For more information on anti-corruption guidance in renewable resource sectors, see the U4 Anti-Corruption Resource 
Centre at: www.u4.no/topics/renewable-resources/basics. 
World Economic Forum 
TCFD 
Theme 
Sub-theme 
Recommenda
tion 
Supporting 
disclosure 
Ethical 
behaviour 
Anti-
corruption 
Governance: 
disclose the 
company’s 
governance 
around 
climate-related 
risks and 
opportunities 
Describe the 
board’s oversight 
of climate-related 
risks and 
opportunities 
 
Ethics and 
reporting 
 
 
Risk and 
opportunity 
oversight 
Integrating 
risk and 
opportunity 
Governance: 
disclose the 
company’s 
governance 
around 
climate-related 
risks and 
opportunities 
Describe 
management’s 
role in assessing 
and managing 
climate-related 
risks and 
opportunities

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
renewables projects due to the additional regulatory requirements. Nuclear projects also assess the impact of 
radiation on the environment (even though the levels of radiation are very low) as well as the environmental impact 
on the resources and any effect on people. These projects are monitored not only by local regulators and 
stakeholders but also by international organisations such as the IAEA. 
Companies need to ensure that not only are they and their projects complying with anti-corruption and anti-
bribery practices but that their supply chains and through-out their lifecycles are also compliant. With the 
introduction of anti-bribery and corruption legislation in many countries and the consequences of poor practice in 
this area, energy companies have improved their reporting and monitoring for corruption and unethical practices. 
Ethics and reporting 
Companies need to be able to assess and report ethical issues and need processes and procedures which facilitate 
reporting. Unethical behaviour needs to be prevented and remedied. Whistleblowing procedures need to be 
established to allow reporting of unethical behaviour without consequence on the reporter. Having such procedures 
in places helps to evidence proper governance and control by the board and the executive. 
Nuclear technology is used for peaceful purposes in energy, medicine and science. Two predominant regimes 
are deployed to ensure ethical behaviour and reporting in the energy industry and particularly the nuclear industry. 
These are the safeguards regime and the export controls regulations. 
The nuclear safeguards regime has been in place since the 1960s and is the gold standard for safeguarding. The 
regime is based on a number of international conventions and international agreements including: the IAEA 
Safeguards System, the Treaty on the Non-Proliferation of Nuclear Weapons (NPT) and the Convention on the 
Physical Protection of Nuclear Material and Nuclear Facilities. The renewables industry is beginning to establish their 
own safeguards regimes to protect the environment and resources from improper use. These are in the early stage 
of development. 
The IAEA Safeguards Glossary provides that the purpose of safeguards is: 
“… to verify that commitments made by States under safeguards agreements with the IAEA are fulfilled. 
It is therefore necessary to define the objectives of safeguards in technical terms relevant to each type 
of safeguards agreement so that safeguards can be applied in an effective manner.” (IAEA, 2001) 
International safeguards regimes exist to ensure that nuclear material cannot be diverted for non-peaceful uses. 
They consist of a system of nuclear material accountancy by the licensee operator of an installation and reporting 
to the national safeguards body, and ultimately to the IAEA. Verification of accountancy figures, remote monitoring 
and sealing of inventories are all carried out, backed up by periodic inspections from the national safeguards 
responsible authority and/or the IAEA to provide independent verification.  
The IAEA sets out examples of non-compliance as follows: 
“(a) Under an INFCIRC/153-type safeguards agreement, the diversion of nuclear material from 
declared nuclear activities, or the failure to declare nuclear material required to be placed under 
safeguards;  
(b) Under an INFCIRC/66-type safeguards agreement, the diversion of the nuclear material or the 
misuse of the non-nuclear material, services, equipment, facilities or information specified and placed 
under safeguards; 
(c) Under an additional protocol based on, the failure to declare nuclear material, nuclear activities or 
nuclear related activities required to be declared under Article 2; 
(d) Under all types of agreement, violation of the agreed recording and reporting system, obstruction 
of the activities of IAEA inspectors, interference with the operation of safeguards equipment, or 
prevention of the IAEA from carrying out its verification activities.” (IAEA, 2001) 
Export controls apply to a wide range of projects across a variety of areas from nuclear, aerospace, 
communications, materials and construction. For the energy industry, and particularly for the nuclear industry, 
export controls play a large part in ensuring information and products are not misappropriated for unethical 
purposes. Intended to aid countries in discharging their obligations under numerous international treaties (such as 
the NPT for nuclear technology), export controls place restrictions on the export of components, documentation, 
knowledge and training on such particular items and areas. For certain nuclear technology, prior to export, exporters

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
75 
will have to obtain an export licence from their county’s recognised authority and satisfy them that the technology, 
component or knowledge will not be diverted for purposes other than the peaceful exploitation of nuclear 
technology and will not threaten the security of nations or oppression of persons in the country of import. Importers 
are required to satisfy the exporting country’s export authority that the materials will not be diverted for anything 
other than their intended use. 
The nuclear industry and the wider energy industry need to maintain ethical behaviour with strong reporting 
principles. The nuclear industry leads the way in this regard and the renewables industry is seeking to establish its 
own policies and practices. 
Risk and opportunity oversight, and integrating risk and opportunity 
This metric relates to a company’s overall risks and opportunities. Risk registers should be maintained. The primary 
responsibility to maintaining the managing risks and opportunities lies with the executive, but the board must 
maintain oversight. The risks and opportunities must be appropriate for the organisation and not extend past the 
risk appetite of the company. The risks and opportunities should be wide enough to cover its stakeholders and the 
wider community. The risks should include ESG including environmental risks such as GHG emissions and climate 
change (see the Planet section below). The risk register must develop and adapt over time, including but not limited 
to any energy company transitioning from a development company, to a construction company, to an operational 
company and finally through to decommissioning. The risks and opportunities at each stage will be different.  
The standards of health and safety generally, whether in nuclear or other energy projects, vary across the globe. 
Investors will assess the projects on their culture, processes and procedures, including the board’s oversight. All 
energy projects should have gold standard levels of health and safety and risk management on their sites (see the 
Health and Safety section below). 
Nuclear regulations provide for nuclear licenses to be in place for the construction, operation and 
decommissioning of the plant. The precise details depend on jurisdiction. However, under internationally agreed 
norms, the licensee has to be the “Controlling Mind” and the “Knowledgeable Customer” for the site. 
The Controlling Mind is a legal concept that has its origins in health and safety law relating to corporate 
manslaughter. In nuclear projects, it relates to the health and safety responsibilities in respect of risk management 
on a nuclear site. Under nuclear site licenses, the site licensee is responsible for health and safety and the overriding 
risk management of the site (although the precise details of this will depend on the jurisdiction). The site licensee 
needs to be the “Controlling Mind” of all safety, security and safeguarding issues on the site. In relation to those 
legal requirements, the site licensee cannot be constrained by the owner of the nuclear power plant or even the 
operator’s parent company, shareholders or investors. This can adversely affect the ability of investors to enforce 
their rights in a traditional project finance way. This in turn can affect the structure of the project. The Controlling 
Mind principle does not mean that the site licensee takes over others responsibility on the site or is the only entity 
responsible for health and safety and risk management on the site i.e. owners, operators and contractors still have 
to comply with their contractual and legal responsibilities. However, the site licensee has to have an understanding 
of all work being undertaken on the site. The precise details of this will depend on each jurisdiction. 
In addition to the Controlling Mind principle is the Knowledgeable Customer. A site licensee is expected to have 
the capability, within its own organisation, in terms of staffing and expertise, to understand the safety case for all 
the nuclear facilities on the site and the limits under which it must be operated. A nuclear site licensee needs to 
understand the safety significance of any work undertaken by contractors and to oversee and take responsibility for 
contractor’s activities, including ensuring that the contractor’s staff are suitably qualified and experienced to carry 
out their nuclear safety duties. This means that major contracts which affect the safety, security or safeguarding of 
the plant, including the EPC Contract and the Fuel Supply Agreement (FSA), must sit with the site licensee i.e. the 
licensed entity needs to have control of those contracts to be able to fulfil its Knowledgeable Customer obligations.  
Nuclear safety culture is defined as “the core values and behaviours resulting from a collective commitment by 
leaders and individuals to emphasise safety over competing goals, to ensure protection of people and the 
environment” (USNRC, 2020). Nuclear companies should have detailed processes and procedures for managing 
health and safety and risk throughout the company and at every level of the organisation.  
With these additional levels of compliance, the nuclear industry leads the way in health and safety. This can be 
costly for projects and increase the overall costs associated with the project. This therefore needs to be balanced as 
both health and safety and costs are risks that the nuclear industry, and the energy industry more widely, must 
consider. The challenge for the nuclear sector is that the levels of health and safety management are set at such a

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
76 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
high standard, making the nuclear industry one of the safest industries in the world, that compliance is costly and 
sometimes overly constrained.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
77 
Planet: SDGs 6, 7, 12, 13, 14 and 15 
World Economic Forum 
SASB 
TCFD 
Theme 
Sub-theme 
Topic 
Metric 
Recommendation 
Supporting 
disclosure 
Climate 
change 
GHG 
emissions 
GHG 
emissions 
and energy 
resource 
planning 
1) gross global 
scope 1 
emissions, 
percentage 
covered under; 2) 
emissions-limiting 
regulations; and 
3) emissions-
reporting 
regulations  
Scope 1 refers to all 
direct GHG emissions.  
Scope 2 refers to 
indirect GHG emissions 
from the consumption 
of purchased electricity, 
heat, or steam. 
Scope 3 refers to other 
indirect emissions not 
covered in scope 2, 
which occur in the 
value chain of the 
reporting company, 
including both 
upstream and 
downstream emissions. 
 
 
Impact of 
GHG 
emissions 
 
GHG emissions 
associated with 
power deliveries 
 
 
 
Task Force 
on Climate-
Related 
Financial 
Disclosure 
aligned 
reporting on 
material 
climate risks 
and 
opportunities 
 
Discussion of 
long-term and 
short-term 
strategies or 
plans to manage 
scope 1 
emissions, 
emission-
reduction targets, 
and an analysis 
of performance 
against those 
targets.  
Strategy: disclose the 
actual and potential 
impacts of climate-
related risks and 
opportunities on the 
company’s businesses, 
strategy and financial 
planning where such 
information is material. 
Describe the 
resilience of the 
company’s 
strategy, taking 
into consideration 
different climate-
related scenarios, 
including a 2°C or 
lower scenarios. 
 
 
 
1) Number of 
customers served 
in markets 
subject to 
renewable 
portfolio 
standards (RPS); 
and 2) 
percentage 
fulfilment of RPS 
target by the 
market  
 
 
 
Science-
based target 
to reduce 
GHG 
emissions 
 
 
Risk management: 
disclose how the 
company identifies, 
assesses and manages 
climate-related risks. 
Describe how 
processes for 
identifying, 
assessing, and 
managing climate-
related risks are 
integrated into the 
company’s overall 
risk management.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
78 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Climate change 
Greenhouse gas (GHG) emissions are the main cause of climate change and therefore a key focus for those 
considering climate finance. Over the past ten years, businesses associated with high emissions have fallen out of 
favour as the markets have moved towards low-carbon economies.  
There remain difficulties in adequately measuring emissions. However, scope 1, 2 and 3 reporting have been 
developed. These are defined by the TCFD as: 
• 
Scope 1 refers to all direct GHG emissions.  
• 
Scope 2 refers to indirect GHG emissions from consumption of purchased electricity, heat, or steam. 
• 
Scope 3 refers to other indirect emissions not covered in Scope 2 that occur in the value chain of the reporting 
company, including both upstream and downstream emissions. Scope 3 emissions could include: the extraction 
and production of purchased materials and fuels, transport-related activities in vehicles not owned or 
controlled by the reporting entity, electricity-related activities (e.g. transmission and distribution losses), 
outsourced activities, and waste disposal. 
Emissions are reported in metric tonnes of carbon dioxide equivalent (tCO2e). 
The TCFD are established as the primary framework for the disclosure of risk and opportunities relating to 
climate change, and particularly GHG emissions. Established companies are used to producing annual filings. It is 
recognised that this framework is also in line with the Paris Agreement. The WEF has included the TCFD metrics and 
the Climate Disclosure Standards Board, and the SASB have produced a joint TCFD implementation guide and a 
related set of good practices. 
The Paris Agreement on climate change sets our long-term goals to limit the increase in global average 
temperature to 1.5oC. In addition, a number of countries have committed to be Net Zero by 2050. Alongside these 
developments, companies have published science-based targets consistent with the Paris Agreement and Net Zero 
objectives. These are seen as minimum reporting requirements for all companies. 
Greenhouse gas (GHG) emissions 
There is scientific consensus that human activities are causing global climate change. The burning of fossil fuels, 
changes in land use and various industrial processes are adding GHG, particularly CO2, to the atmosphere. CO2 
concentrations have increased by 40% since pre-industrial times, primarily from fossil fuel emissions and secondarily 
from net land use change emissions. The effects of these additional gases can already be seen (global average 
 
TCFD 
aligned 
reporting 
 
 
Metrics and targets: 
disclose the metrics 
and targets used to 
assess and manage 
relevant climate-related 
risks and opportunities 
where such information 
is material. 
Disclose the 
metrics used by 
the company to 
assess climate-
related risks and 
opportunities in line 
with its strategy 
and risk 
management 
process.  
Disclose scope 1, 
scope 2 and, if 
appropriate, scope 
3 GHG emissions 
and the related 
risks.  
Describe the 
targets used by the 
company to 
manage climate-
related risks and 
opportunities and 
performance 
against targets.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
79 
temperatures have risen by 0.75°C since about 1990) with consequences for both the environment and people’s 
lives.  
GHG emissions is one of the main metrics for ESG across a number of reporting bodies. GHG emissions have 
been identified as one of the primary causes of climate change and therefore key to the mitigation of climate change. 
There are challenges about the accuracy of the reporting against these metrics and also there is a bias towards 
certain technologies who often only report against scope 1 and sometimes scope 2. Some nuclear companies are 
beginning to report on scope 1,2 and 3. Requiring companies to report on all 3 scopes would create a level playing 
field across technologies. Looking at the lifecycle emissions provides a more accurate view of technologies and their 
overall impact on climate change.  
Nuclear power stations produce very few carbon dioxide emissions directly from electricity generation. As set 
out in the Technical Assessment on Nuclear Energy with respect to the ‘do no significant harm’ criteria of Regulation 
(EU) 2020/852 (‘Taxonomy Regulation’): “…the TEG concluded that nuclear energy has near to zero greenhouse gas 
emissions…. The comparison of impacts of various electricity generation technologies (e.g. oil, gas, renewables and 
nuclear energy) on human health and the environment, based on recent Life Cycle Analyses (LCA) […], shows that 
the impacts of nuclear energy are mostly comparable with hydropower and the renewables, with regard to non-
radiological effects.” EU, 2021) 
The role of nuclear as a low carbon technology is becoming widely accepted. In January 2016, New York Public 
Service Commission ruled that the state's Clean Energy Standard (CES) portfolio must include nuclear power plants 
among its non-carbon-emitting generation resources.  
As identified in the Canadian Nuclear Factbook 2020 (CNA, 2020). “Today by displacing the use of coal and 
natural gas, nuclear power helps avoid about 2.2 billion tonnes of CO2 emissions annually. This the same as taking 
about 480 million passenger vehicles of the road – or nearly half of all the passenger vehicles in the world.” 
In the Agreement Between the Government of the United Kingdom of Great Britain and Northern Ireland and 
the European Atomic Energy Community for Cooperation on the Safe and Peaceful Uses of Nuclear Energy, signed 
on 31 December 2020, it was noted: 
NOTING the United Kingdom’s commitment to developing and deploying nuclear energy as part of its 
diversified and low-carbon energy mix; 
DESIRING to make long-term cooperative arrangements in the field of peaceful and non-explosive 
uses of nuclear energy in a predictable and practical manner, which take into account the needs of 
their respective nuclear energy programmes and which facilitate trade, research and development 
and other cooperative activities between the United Kingdom and the Community; (EU, 2020) 
On the global stage, the potential role of nuclear in reducing carbon impacts from power generation was a 
central theme of the COP21 summit in Paris. During the event, Loreta Stankeviciute – (Energy Economist at the IAEA) 
– stressed that “nuclear energy should be considered on equal footing with other low-carbon energy sources in 
weighing the energy options for mitigating climate change, in recognition of its broader potential for contributing 
to sustainable development”. 
Stankeviciute was speaking at a session hosted jointly by the IAEA and the Nuclear Energy Agency (NEA), which 
has also consistently highlighted the credentials of nuclear power as a way to drive carbon emissions out of the 
generation mix.  
All forms of electricity generation have some carbon dioxide emissions associated with the energy used in the 
construction, operation and decommissioning of the plant. Nuclear has carbon dioxide emissions associated with 
energy use during mining; and also with extraction, enrichment, and the manufacture of its fuel. Like coal, energy is 
also used in management of the waste products from generation, resulting in carbon dioxide emissions.  
In 2011, the Intergovernmental Panel on Climate Change (IPCC) synthesised evidence from a comprehensive 
review of published Life Cycle Assessments (LCAs) covering all regions of the world, to produce a comparison of 
carbon dioxide emissions from different electricity generation technologies. This showed that emissions from 
nuclear power stations (median figure of 16gCO2/ kWh) are comparable to those from renewable resources, and 
significantly lower than those from electricity generated from fossil fuels.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
In the Energy Systems chapter of its 2018 Report,9 the IPCC stated: 
Renewable heat and power generation and nuclear energy can bring more significant reductions in 
GHG emissions. The information provided here has been updated from the data provided in  
SRREN, taking into account new findings and reviews, where available. The ranges of harmonized 
lifecycle greenhouse gas emissions 012), and 4 – 110 gCO2eq / kWh for nuclear power (Warner and 
Heath, 2012). The harmonization has narrowed the ranges down from 5 – 217 gCO2eq / kWh for PV, 
7 – 89 gCO2eq / kWh for CSP, and 1 – 220 gCO2eq / kWh for nuclear energy. A new literature review 
for wind power published since 2002 reports 7 – 56 gCO2eq / kWh, where the upper part of the range 
is associated with smaller turbines (< 100 kW) (Arvesen and Hertwich, 2012), compared to 2 – 81 
gCO2eq / kWh reported in SRREN. For all of these technologies, at least five studies are  
reviewed. The empirical basis for estimating the emissions associated with geothermal and ocean 
energy is much weaker. SRREN reported 6 – 79 gCO2eq / kWh for geothermal power and 2 – 23 
gCO2eq /kWh for ocean energy (IPCC, 2011a). For ocean power, Figure 7.6 shows only the results of 
newer assessments, which range between 10 – 30 gCO2eq / kWh for tidal barrages, marine current 
turbines, and wave power (Walker and Howell, 2011; Kelly et al., 2012). For RE, emissions are mainly 
associated with the manufacturing and installation of the power plants, but for nuclear power, 
uranium enrichment can be significant (Warner and Heath, 2012). Generally, the ranges are quite 
wide reflecting differences in local resource conditions, technology, and methodological choices of 
the assessment. The lower end of estimates often reflects incomplete systems while the higher end 
reflects poor local conditions or outdated technology. (IPCC, 2018) 
In the Energy Supply chapter of its 2018 Report,10 the IPCC stated: 
Total life-cycle GHG emissions per unit of electricity produced from nuclear power are below 40 gCO2-
eq/kWh (10 gC-eq/kWh), similar to those for renewable energy sources […]. Nuclear power is 
therefore an effective GHG mitigation option, especially through license extensions of existing plants 
enabling investments in retro-fitting and upgrading. Nuclear power currently avoids approximately 
2.2–2.6 GtCO2/yr if that power were instead produced from coal […] or 1.5 GtCO2/yr if using the world 
average CO2 emissions for electricity production in 2000 of 540 gCO2/kWh […]. (IPCC, 2018) 
The Canadian Nuclear Association commissioned a report by Hatch to consider the lifecycle emissions from 
different technologies. Hatch employed a LCA Overview methodology where they measured “the environmental 
impacts of a product by modelling the processes, materials consumed and emissions at each stage of the product 
lifecycle, extending beyond the conventional operational boundaries of any one company or process stage […]. The 
process of conducting an LCA is standardized under ISO 14040, consisting of a four-step process including goal and 
scope definition, inventory analysis, impact assessment, and interpretation” (Hatch, 2014). The Hatch report the 
lifecycle assessment for nuclear, wind and natural gas. 
The LCA meta-analysis is a cradle-to-gate study spanning from resource extraction up to the production of electricity 
at the point (or gate) of delivery to the electricity grid. The study encompasses all upstream and downstream 
processes associated with the generation of 1 kWh of electricity, excluding transmission and distribution losses. The 
environmental impacts and emissions in this study were obtained taking into account two dimensions of their 
lifecycle: 
• 
Supply Chain – processes corresponding to the ongoing operation of the power generation facility, 
including the upstream systems associated with fuels and consumables and downstream systems 
associated with the management and disposal or wastes. 
• 
Lifespan – processes corresponding to the entire lifetime of the power plant from inception to 
eventual decommissioning, not otherwise captured in the day-to-day operation of the plant. The 
supply chain encompasses the extraction, production and transportation of raw materials (fuels and 
consumables) to the power plant, operations and maintenance, and the management of all waste 
associated with the activities of the power plant. The lifespan includes all the process stages required 
build and disassemble the power plant at the start and end of the plant‘s lifetime, including the 
extraction, production, transportation and application of materials and fuels used during construction, 
 
9. 
www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg3-chapter4-1.pdf. 
10. www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg3-chapter4-1.pdf.

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81 
as well as the disassembly and disposal or re-use of plant materials during decommissioning. 
Combined, the supply chain and lifespan represent the complete range of processes directly and 
indirectly required to generate electricity from each generation scenario. 
Hatch’s lifecycle assessment for GHG shows that wind and nuclear have similar emissions, and that both are 
significantly below gas plants: 
Table 8: Statistical Mean Total Lifecycle GHG Emissions 
Scenario 
GHG (gCO2-e/kWh) 
On-shore wind turbine 
10.5 ± 0.9 
Nuclear power plant 
18.5 ± 1.7 
NGCC power plant 
478 ± 10 
Note: NGCC = natural gas combined cycle. 
Source: Adapted from Hatch (2014) 
Much of the emissions associated with windfarms are generated primarily during construction and 
decommissioning. Off-shore wind farms have higher emissions than on-shore windfarms due to the foundations, 
cabling and transport impact. This becomes more of a concern when one considers the short life of a wind turbine. 
The design life of many wind turbines is 20 years, but for many, particularly off-shore windfarms, they are taken out 
of service in 15 years or less. Further, due to the intermittent nature of wind and solar, wind and solar plant are 
being paired with batteries and other storage facilities to create a firmer power solution. The figures above do not 
take into consideration the GHG emissions associated with the battery production, which can be significant.  
For nuclear plants, many of the emissions are associated with the upstream supply chain – particularly the 
mining of uranium and the enrichment and fuel fabrication processes. In certain configurations with high grade ore 
or no enrichment or centrifuge-based enrichment, the emissions from a nuclear lifecycle are the same as those from 
an on-shore wind farm (i.e. smaller than an off-shore wind farm). 
The report further looks at a range of technologies within each group: 
Table 9: Statistical Mean Total Lifecycle Emissions 
Scenario 
GHG (g/kWh) 
Average Current Study 
GHG (g/kWh)  
Range of reference study* 
On-shore wind turbine 
10.5 ± 0.9 
3-45 
Wind (mix) 
3-41 
Nuclear LWR 
18.5 ± 1.7 
3.7-110 
Nuclear PWR 
3.7-110 
Nuclear BWR 
4.6-17 
Nuclear mix 
1.36-288.25 
Nuclear mix 
3-35 
NG (NGCC) 
478 ± 10 
360-720 
NG (mix) 
380-1000 
*The reference study refers to the literature Hatch used to compare the results of its study. 
Note: LWR = light water reactor; PWR = pressurized water reactor; BWR = boiling water reactor. 
Source: Adapted from Hatch (2014). 
In 2017 an article in Nature Energy (Pehl et al., 2017) measured the full lifecycle GHG emissions of a range of 
sources of electricity out to 2050. The carbon footprint of solar, wind and nuclear were shown to be significantly 
lower than other sources, even after taking into account emissions during manufacture, construction and fuel

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
supply. The study found each kilowatt hour of electricity generated over the lifetime of a plant has an emissions 
footprint of:  
• 
nuclear – 4gCO2e/kWh CO2 equivalent (gCO2e/kWh); 
• 
solar – 6gCO2e/kWh;  
• 
wind – 4gCO2e/kWh; 
• 
coal CCS11 – 109gCO2e/kWh; 
• 
gas CCS – 78gCO2e/kWh; 
• 
hydro12  – 97gCO2e/kWh;  
• 
bioenergy13 – 98gCO2e/kWh. 
Further details and analysis on the GHG emissions and the impact on climate change of nuclear power can be 
found in reports such as the report entitled The Role of Nuclear Energy in a Low-carbon Energy Future (NEA, 2012). 
The message was further emphasized during a 2020 NEA webinar and in the NEA Policy Brief entitled “Building Low-
Carbon Resilient Electricity Infrastructures with Nuclear Energy in the Post-COVID Era (NEA, 2020a).14 
What is clear from the various analysis cited above is nuclear power’s low-carbon credentials and its vital role 
in the fight against climate change. 
Nature loss 
All energy generating technologies impact the environment in their 
vicinity. Whilst any emissions from a facility or installation are 
generally regulated by national laws, regional laws and regulations, 
facilities can still have an impact on the environment, landscape 
and ecology. This section describes the relative habitat and ecology 
impacts brought about by differing generating technologies. 
The emphasis of this metric is on reporting the area of land owned, leased or managed by the company, together 
with adjacent land, which is impacted by the company’s activities, particularly in protected areas or key biodiversity 
areas. 
Key biodiversity areas provide recognised ways of identifying sites contributing significantly to biodiversity. 
Protected areas/zones are recognised as areas of ecological importance. Any activities in such areas indicate 
heightened risk of environmental damage, adverse impacts on biodiversity or ecology and therefore risk to 
reputation. 
Land use and ecological sensitivity, and the impact of land use 
The land use should consider the whole of the supply chain, including commodities used. Consideration should also 
be given to areas used to supply the project and the impact on ecology across that supply chain. Companies should 
consider a sustainable certification programme and the impact of each significant element of the supply chain, in 
terms of land and resources used and the overall balance, taking into consideration the adverse production impact. 
The ESG credentials of businesses in the supply chain should be addressed in any procurement programme.  
 
11. The figures for CCS are elevated for two reasons. First, upstream emissions during mining of coal or extraction of gas continue. 
Second, the study assumes that CCS only captures 90% of power plant CO2. Higher capture rates are more costly and would 
not eliminate upstream emissions, equivalent to 23-42gCO2e/kWh, still well above the numbers for nuclear, wind or solar. 
12. The footprint for hydro is highly variable, the paper notes, with lifecycle emissions largely due to the rotting organic matter 
flooding the dam. This means certain sites should be avoided, in particular shallow dams in warm regions, with large 
variations in water levels. 
13. For bioenergy, the footprint is also highly uncertain and variable, the paper says, depending on how the biomass is sourced 
and if it involves converting high-carbon stock land such as forests. 
14. To watch the NEA webinar, see: www.oecd-nea.org/jcms/pl_34301/webinar-building-low-carbon-resilient-electricity-
infrastructures-with-nuclear-energy-in-the-post-covid-19-era. 
World Economic Forum 
Theme 
Sub-theme 
Nature Loss 
Land 
Use 
and 
Ecological Sensitivity 
 
Impact of Land Use

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83 
The interrelationship between land use and energy is a balance. Energy is needed for the socio-economic 
development of regions and countries, but this needs to be balanced with the efficient and effective use of land, 
which is also needed for other activities such as the production of crops and food. The efficient use of land for the 
production of energy is an important factor to be considered. The impact of land use needs to be assessed 
meaningfully by the energy company, it also needs to be presented to the Board, executive and stakeholders in an 
accessible way.  
As highlighted in Figure 5 below: 
• 
An average wind farm produces 0.77MWh per square kilometre of land;  
• 
An average solar farm produces 1MWh per square kilometre;  
• 
whereas a small modular reactor (SMR) produces up to 14.5 MWh per square kilometre of land. 
Figure 5: Land use of nuclear, solar and wind 
 
    Source: GIF 
 
Capacity factors need to also be considered in any assessment of land use. Each technology has different capacity factors. 
As can be seen from Table 10 below capacity factors can have a significant impact on electricity output:

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Table 10: Capacity factor and land use for various electricity generating technologies 
Technology 
Capacity factor15 
(%) 
Electrical output 
(MWe per km2) 
Nuclear energy16 
90 
17 164 
Off-shore wind17 
43 
3 
Solar photovoltaic18 
9.2 
9 
Source: see footnotes   
Both of these analyses only consider the direct land use associated with the plant itself rather than considering 
the supply chain across the lifecycle of the plant.  
A report by the US Department of Energy, Quadrennial Technology Review 2015: Enabling Modernization of the 
Electric Power System (hereafter “the US report”, 2015) recognises that there is no definite source for land use 
mapped against energy intensity and as a result metrics often have different units that are not always comparable. 
However, it provides the Representative Land Use Intensity Estimates shown in Table 11 and Table 12 below. 
Table 11: Land use estimates for a variety of electricity generating technologies 
(power plants site only) 
Energy technology 
m2/MW 
System boundary 
(power plant site only*)   
Biomass; direct-fired 
9 000-45 000 
Power plant site only 
Coal 
270-8 000 
Power plant site only 
Coal: CCS 
12 000 
Power plant site only 
Nuclear energy 
6 700-13 800 
Low estimate is site only. High estimate includes transmission lines, 
water supply and rail lines, but does not include land used to mine, 
process or dispose of waste. 
Source: Adapted from US Department of Energy (2015) 
 
15. Nuclear capacity factor taken from American Nuclear Society Nuclear News 2021 five-year capacity factor average for US 
fleet. Off-shore wind capacity factor lifetime average from Ofgem and Elexon data. Solar PV capacity factor taken from long- 
term patterns of European PV output using 30 years validated hourly re-analysis and satellite data, S Pfenninger & I Staffell. 
16. Average of UK generating fleet: Sizewell B, Torness, Hunterston B, Hinkley Point B, Dungeness B, Hartlepool, Heysham I and 
Heysham II and new build at Hinkley Point C. All are AGRs with the exception of Sizewell B and Hinkley Point C (PWRs). 
Electrical output obtained from UK regulator website onr.org.uk and site footprint obtained from Google Maps area 
calculator. 
17. Average of UK off-shore wind farms at: Hornsea One, East Anglia One, London Array, Race Bank, Rampion, Walney Extension, 
West of Duddon Sands, Gwynt Y Môr, Sheringham Shoal and Humber Gateway. Electrical output from wind farm developer’s 
respective websites. 
18. Average of UK Solar PV farms at: Shotwick, Stonebarrow, Burnaston, RAF Lyneham, New Mains of Guynd, Owls Hatch, 
Westmill, QEII Reservoir, Prestop Park and Rhosygilwen Estate. Electrical output obtained from developer’s website. Area 
calculated from Google Maps area calculator.

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85 
Table 12: Land use estimates for a variety of electricity generating technologies 
(energy resource extraction area and power plant site) 
Energy technology 
m2/MW 
System boundary 
Energy resource extraction area plus power plant site 
Biomass gasification 
3 000 000 
Site and crop area. Area used, primarily driven by biomass productivity 
and power plant efficiency.  
Coal (site and 
upstream) 
40 000 
Site and strip mining included 
Geothermal: 
hydrothermal 
1 200-150 000 
Low estimate is for the site only. Upper estimate includes well-field and 
plant. 
Geothermal:  
hot dry rock 
4 600-17 000 
Includes well-field and plant  
Hydropower: reservoir 
20 000-10 000 000 
Site of generators and reservoir 
Solar: PV 
10 000-60 000 
Site of PV system, which includes the area for solar energy collection. 
PV systems on pre-existing structures have essentially no net increase 
in land use.  
Solar: thermal 
12 000-50 000 
Site of concentrating solar thermal system, which includes the area for 
solar energy collection. 
Wind 
2 600-1 000 000 
Low-end value is for the site only, which includes the physical footprint 
of the turbines and access roads. The high-end value includes the land 
area between turbines, which is typically available for farming or 
ranching.  
*Does not consider energy resource mining or collection, processing or transport area, or land used for waste disposal. 
Note: CCS = Carbon capture and storage; PV = photovoltaic.  
Source: Adapted from US Department of Energy (2015)  
Like many other infrastructure projects, the development of any energy plant will have an impact on sensitive 
species and habitats. The impact will depend primarily on the site where the plant is deployed. However, when 
considering land utilisation, a nuclear plant will have a smaller impact than a renewable plant of equal power.  
A developer of any energy plant is required to provide sufficient information (including in relation to avoidance 
and mitigation measures) of its impact on land, habitats and species in order for a proper assessment to be made. 
This includes any off-shore impacts, whether an off-shore wind farm or the outlet pipe for cooling water from a 
nuclear plant. An environmental impact assessment would need to be undertaken to determine the specific impact 
on a particular site.  
These assessments aim to identify sites in the first instance where there are no impact or a minimal impact on 
the environment and local ecology. Where impacts are inevitable, suitable mitigation to compensate are required 
to be agreed and demonstrated prior to consent for construction being granted. For example: all applications to 
build nuclear power stations within the EU are subject to the EU Directive on the assessment of the effects of certain 
plans and programmes on the environment (known as the Strategic Environmental Assessment Directive 
(2001/42/EC)).  The Directive specifically refers to effects on people, fauna and flora, soil, water, air, climate, the 
landscape, material assets and cultural heritage, and the interaction between them. All applications must include 
an Environmental Statement from the applicant describing the likely significant effects of the proposed project on 
the environment and the measures envisaged for avoiding or mitigating significant adverse effects. When 
considering cumulative effects, the environmental statement should provide information on how the effects of the 
applicant’s proposal would combine and interact with the effects of other development, including projects for which 
consent has been sought or granted, as well as those already in existence.  
Acquisition and maintenance of land can be a key issue for plants or installations and the smaller the land area 
required, generally the easier the process of siting and construction, which presents potentially less of a commercial 
risk as the project progresses. The siting of new nuclear power stations takes into account the implications of climate 
change, including the possibility of more severe weather patterns and rising sea levels. This is in addition to other 
postulated events that could impact the safety of the plant, both man-made and natural such as extreme weather 
events.

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Fresh water availability 
Where relevant, energy projects 
need to be considered in terms of 
their freshwater consumption. This 
is particularly relevant in water-
stressed areas where there is a risk 
of negative social impact. However, 
this metric should consider a 
company’s water stewardship as a 
whole. 
Fresh water consumption and 
water management 
The reporting of the units used 
together 
with 
how 
water 
is 
managed should be reported in a 
way that executives, the board and 
investors can easily understand. 
The report should include an 
assessment of the environmental 
impact of the water use. 
In 2014, the Energy and Water in a Warming World Initiative produced a report entitled Freshwater Use by U.S. 
Power Plants Electricity’s Thirst for a Precious Resource”, and found that: 
…findings on the water profile of power plants in 2008 show that:  
Power plants are thirsty. Every day in 2008, on average, water-cooled thermoelectric power plants in 
the United States withdrew 60 billion to 170 billion gallons (180,000 to 530,000 acre-feet) of 
freshwater from rivers, lakes, streams, and aquifers, and consumed 2.8 billion to 5.9 billion gallons 
(8,600 to 18,100 acre-feet) of that water. Our nation’s large coal fleet alone was responsible for 67 
percent of those withdrawals, and 65 percent of that consumption.  
Where that water comes from is important. In the Southwest, where surface water is relatively scarce, 
power plants withdrew an average of 125 million to 190 million gallons (380 to 590 acre-feet) of 
groundwater daily, tapping many aquifers already suffering from overdraft. By contrast, power plants 
east of the Mississippi relied overwhelmingly on surface water.  
East is not west: water intensity varies regionally. Power plant owners can reduce their water 
intensity—the amount of water plants use per unit of electricity generated. Plants in the East generally 
withdrew more water for each unit of electricity produced than plants in the West, because most have 
not been fitted with recirculating, dry cooling, or hybrid cooling technologies. Freshwater withdrawal 
intensity was 41 to 55 times greater in Virginia, North Carolina, Michigan, and Missouri than in Utah, 
Nevada, and California. Freshwater consumption intensity was similar in those sets of states. 
Low-carbon electricity technologies are not necessarily low-water. On average in 2008, plants in the 
U.S. nuclear fleet withdrew nearly eight times more freshwater than natural gas plants per unit of 
electricity generated, and 11 percent more than coal plants. The water intensity of renewable energy 
technologies varies. Some concentrating solar power plants consume more water per unit of 
electricity than the average coal plant, while wind farms use essentially no water. (Averyt et al., 2011) 
While solar and wind plants do consume water, they use significantly less water than nuclear plants.  However 
most of the water used in nuclear plant is used rather than consumed. A 2019 review of the water use of electricity 
technologies emphasised the challenges of determining the water consumed across various technologies and 
concluded that: “The results show that photovoltaics, wind power, and run-of-the-river hydropower consume 
relatively little water, whereas reservoir hydropower and woody and herbaceous biomass can have an extremely 
large water footprint. The water consumption of power production can differ greatly across countries due to 
different geographic conditions.” (Jin et al., 2019) 
World Economic Forum 
SASB 
Theme 
Sub-theme 
Topic 
Metric 
Fresh 
water 
availability 
Fresh water 
consumption 
in water 
stressed areas 
and the impact 
on fresh water 
consumption 
Water 
management 
1) Total water 
withdrawn; 2) total 
water consumed, as 
well as the percentage 
of each in regions with 
high or extremely high 
baseline water stress.  
 
 
 
Number of incidents of 
non-compliance 
associated with water 
quantity and/or quality 
permits, standards, and 
regulations. 
 
 
 
Description of water 
management risks and 
discussion of strategies 
and practices to 
mitigate those risks.

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87 
The exact water use or consumption will be project-specific. However, water consumption should also be 
assessed with desalination and the creation of potable water for those countries where this is needed. Desalination 
and potable water can help to offset the impact of water use, particularly in water-stressed areas. 
Fresh water is a major priority in sustainable development, it is estimated that one fifth of the world’s 
population does not have access to safe drinking water,19 and that this proportion will increase due to population 
growth relative to water resources. The worst affected areas are the arid and semi-arid regions of Asia and North 
Africa. “Wars over access to water, not simply energy and mineral resources, are conceivable” (WNA, 2020a). Where 
freshwater cannot be obtained from streams and aquifers, desalination of sea water or groundwater is required. 
A report in 2002 from the UNESCO said that the freshwater shortfall worldwide was then running at some 230 
billion m3/yr and would rise to 2,000 billion m3/yr by 2025. A report in January 2015 from the World Economic 
Forum highlighted the problem and said that “shortage of freshwater may be the main global threat in the next 
decade.” (Ali, 2018) 
Desalination is a very energy intensive process often contributing to increased levels of GHG, as the vast 
majority of desalination plants use fossil fuel sources. Current information on desalination shows that “only 1% of 
total desalinated water is generated from renewable sources” (IEA/IRENA, 2012).  The use of fossil fuels is also 
vulnerable to volatile global market prices as well as logistical supply problems in remote and island communities. 
Until now, the majority of desalination plants have been located in regions where there is a high availability of low-
cost energy. While renewable production is increasing, the demand for desalinated water in energy-importing 
countries such as India, China and small islands is also increasing.  
According to the IEA/IRENA (2012), “there are two broad categories of desalination technologies. Thermal 
desalination uses heat to vaporise fresh water, while membrane desalination (reverse osmosis) uses high pressure 
from electrically-powered pumps to separate fresh water from seawater using a membrane”. Reverse Osmosis (RO) 
needs about 6 kWh of electricity per cubic metre of water, while thermal distillation processes require heat at 70°C-
130°C or 25 kWh/m3 to 200 kWh/m3. (Hore-Lacy, 2007)  
However, the purity of the water produced from RO is not as high as with thermal distillation techniques and 
the cost-effectiveness of RO depends highly on any required chemical pre-treatment of the feed-water.  
Nuclear plants can be used for desalination and the creation of potable water. The technology has been proven 
for desalination, principally in Kazakhstan, India and Japan. According to the World Nuclear Association (WNA), the 
costs of desalination by nuclear plant is much the same as fossil-fuel plant that do the same – c. 70 to 90 US cents 
per cubic metre. This cost may drop with some of the advanced high temperature reactors in development. Whether 
countries will widely choose to take the benefit of this option in a nuclear plant is yet to be seen and will depend on 
the economics and other developments in each country.  
Small and medium-sized nuclear reactors are suitable for desalination, often with cogeneration of electricity 
using low-pressure steam from the turbine and hot sea water feed from the final cooling system. The main 
opportunities for nuclear plants have been identified as the 80-100 000 m3/d and 200-500 000 m3/d ranges (IAEA, 
2009). US Navy nuclear powered aircraft carriers reportedly desalinate 1 500 m3/d each for use onboard. 
The cost of desalination from fossil fuels is USD 0.64/m3 – USD 2.00/m3, with nuclear energy being slightly lower 
at USD 0.50/m3 – USD 1.48/m3 (IAEA, 2007). The cost of desalination from renewables is, as shown in Table 13 below, 
greater at USD 1.3/m3 – >USD 10/m3 (World Bank, 2019). It should however be noted that while the cost of 
renewable desalination is more expensive, it can compete in remote regions where the cost of energy transmission 
and distribution is higher than the cost of distributed generation. 
 
19. For more information, see the United Nations Department of Economic and Social Affairs International Decade for Action 
“Water for Life” web page at: www.un.org/waterforlifedecade/scarcity.shtml.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Table 13- Comparative costs for common renewable desalination* 
 
Technical 
capacity 
Energy Demand 
(kWh/ m3) 
Water cost  
(USD/ m3) 
Development 
stage  
Solar stills 
< 0.1 m3/d 
Solar passive 
1.3 – 6.5  
Application 
Solar – Multiple Effect 
Humidification 
1 – 100  m3/d 
thermal: 100 
electrical: 1.5 
2.6 – 6.5  
R&D Application 
Solar – Membrane 
Distillation 
 0.15 – 10  
m3/d 
thermal: 150 - 200 
10.5 – 19.5  
R&D 
Solar/CSP – Multiple Effect 
Distillation 
> 5000 m3/d 
thermal: 60 – 70 
electrical: 1.5 – 2  
2.3 – 2.9  
(possible cost) 
R&D 
Photovoltaic – Reverse 
Osmosis 
< 100 m3/d 
electrical: BW:  
0.5 – 1.5  
SW: 4 – 5  
BW: 6.5 – 9.1  
SW: 11.7 – 15.6 
R&D Application 
Photovoltaic – 
Electrodialysis Reversed 
< 100 m3/d 
electrical: only  
BW : 3 – 4  
BW: 10.4 – 11.7  
R&D  
Wind – Reversed Osmosis 
50 – 2000  
m3/d 
electrical: BW:  
0.5 – 1.5  
SW : 4 – 5  
units under 100 m3/d,  
BW: 3.9 – 6.5  
SW: 6.5 – 9.1  
About 1,000 m3/d,  
2 – 5.2  
R&D Application 
Wind – Mechanical Vapor 
Compression 
< 100 m3/d 
electrical: only  
SW : 11 – 14  
5.2 – 7.8  
Basic Research  
Wind – Electrodialysis  
- 
 
- 
 
BW: 2.0 – 3.5  
- 
 
Geothermal – Multi Effect 
Distillation  
- 
 
- 
 
SW: 3.8 – 5.7  
- 
 
* The cost of fossil fuel desalination is ~USD 1.00 USD/m3. 
Note: BW = Brackish Water; SW = Sea Water. 
Source: Adapted from IEA/IRENA (2012) 
In December 2015, the "Global Clean Water Desalination Alliance – H2O minus CO2 initiative was launched at 
the COP 21 climate talks in Paris “to seek solutions that will substantially reduce the projected increase in CO2 
emissions from the desalination process, as global demand for drinking water continues to grow” (WaterWorld, 
2015). The call was part of the alliance's aim to tackle the water-energy nexus and climate change. 
A French study for Tunisia compared four nuclear power options with combined cycle gas turbine and found 
that nuclear desalination costs were about half those of the gas plant for thermal technology and about one-third 
less for RO (Nisan et al., 2007).  Also, the cost of water produced through nuclear desalination is less volatile than 
fossil fuel production as most of the cost is capital investment rather than dependent on fuel costs.  
Using lifetime levelised unit costs to compare combinations of energy source and type of desalination plant, 
the Royal Society (2020) calculated that nuclear energy with RO technology is the cheapest option as can be seen in 
Figure 6 below.

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89 
Figure 6: Cost of desalinated water by fuel and process 
 
Source: Adapted from The Royal Society (2020).  
In the IEA outlook to 2040 produced in 2019, “the production of desalinated seawater in the Middle East is 
projected to increase almost fourteen-fold to 2040, and there is a concerted shift towards membrane-based 
desalination in both IEA New Policies Scenario (NPS) and Sustainable Development scenarios (SDS)” (Walton, 2019), 
as can be seen in Figure 7 below. The IEA shows that the rapid phase-out of subsidies for fossil fuels in the SDS 
results in a higher share of water production from membrane-based and solar power desalination in 2040 than in 
the NPS. The policy choices taken in the SDS also lead to the deployment of more renewable and nuclear production, 
which account for over half of power generation by 2040. This shift not only reduces carbon dioxide emissions and 
local air pollutants, but also allows for more effective management of the region’s energy and water needs. 
Figure 7: Water production from seawater desalination in the Middle East by input fuel and scenario 2016-2040 
 
Source: Adapted from Walton IEA Commentary (2019). 
With over a fifth of the world estimated to not have access to fresh water and a shortfall predicted of over 2 
000 billion m3/yr within the next five years, there is a growing need for methods that will cost effectively produce 
potable water, while also considering the production method and carbon emissions. As shown, nuclear energy 
offers a solution which is cost comparable to current fossil fuel production methods whilst not contributing to 
climate change.

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Pollution 
Air pollution and quality 
The impact of air pollution needs 
to be assessed across the supply 
chain. This should include nitrogen 
oxide, sulphur oxides, particulates, 
lead and mercury, as well as other 
air emissions. The reporting needs 
to 
provide 
a 
meaningful 
assessment of the impact of air 
pollution, or impact on air quality. 
Fine particle matter and the 
impact on air pollution 
Air pollution from coal-fired power plants is linked with asthma, cancer, heart and lung ailments, neurological 
problems, acid rain, as well as climate change and other public health impacts. Many governments have been 
legislating for many decades to try to reduce pollution generally, including that from energy projects. Renewable 
energy plants and nuclear plants are recognised as plants that have much reduced the pollution across the supply 
chain. 
In the “Life-Cycle Assessment of Electric Power Systems”, the pollution from various power plants was assessed 
(Masanet et al., 2013). Their data can be found in the table below.  
Table 14: Ranges of electric power technology emissions and resource-use factors (per unit generation) 
  
Environmental 
exchange 
Coal 
Natural gas 
  
  
Hard coal 
Lignite 
Combined 
cycle 
Steam 
turbine 
Nuclear 
Bioenergy 
SO2 (mg/kWh) 
530-7 680 
425-27 250 
1-324 
∼0-5 830 11-157 
40-940 
NOx (mg/kWh) 
540-4 230 
790-2 130 
100-1 400 
340-1 020 9-240 
290-820 
PM (mg/kWh) 
17-9 780 
113-947 
18-133 
ID 
∼0-7 
29-79 
Environmental 
exchange 
Solar 
  
Hydropower 
  
  
 
PV 
Concentrated 
solar power 
Geothermal 
Reservoir River 
Ocean 
Wind 
SO2 (mg/kWh) 
73-540 
35-48 
∼0-160 
9-60 
1-6 
64-200 
3-88 
NOx (mg/kWh) 
16-340 
54-160 
∼0-50 
3-13 
4-6 
49 
10-75 
PM (mg/kWh) 
6-610 
7-26 
1.3-50 
0.1-25 
15-36 
1-14 
Source: Adapted from Masanet et al. (2013). 
 
As can be seen in the above table, nuclear and renewable projects have far fewer emissions than fossil fuels. 
Each different form of energy creates its own air pollution. For example, the manufacturing of cabling and the wind 
turbines for wind farms (particularly off-shore) produces air pollution (and water pollution). 
According to the Hatch report (also see Table 15 below):  
World Economic Forum 
SASB 
Theme 
Sub-theme 
Topic 
Metric 
Air 
pollution 
Fine particle 
matter and 
impact on air 
pollution 
Air 
quality 
Air emissions of the 
following pollutants: 1) NOx 
(excluding N2O); 2) SOx; 3) 
particulate matter (PM10); 
4) lead (Pb); and 5) mercury 
(Hg); percentage of each in 
or near areas of dense 
population.  
Water 
pollution 
Nutrients and 
impact on water 
pollution

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The results of this process showed that GHG and NOx emissions from natural gas combined cycle 
(NGCC) generation greatly exceeded the wind and nuclear lifecycles […]. The variation in PM and SOx 
emissions by comparison are less pronounced […]. The lowest range of emissions corresponds to 
nuclear generation followed by wind and natural gas. 
SOx emissions from the wind and nuclear lifecycle exceed the emissions from NGCC and wind-NGCC 
generation. The construction and upstream fuel supply chain are the dominant sources of SOx 
emissions from wind and nuclear, respectively, and may be related to emissions from coal-derived 
electricity consumption or manufacture of intermediate products such as steel.  
The total emissions from the nuclear and wind power lifecycles were similar. Onshore wind power, on 
average, is a slightly more GHG efficient option than nuclear power over its lifecycle. The distribution 
of wind LCA data resides in the lower band of the range of nuclear power technologies considered. Of 
the nuclear power lifecycle, technologies that do not use diffusion-based enrichment produce similar 
emissions to onshore wind power. Average emissions of PM, SOx and NOx are comparable over the 
lifecycle of wind and nuclear power. No discernible difference in the statistical mean total lifecycle 
emissions of wind and nuclear power were observed. (Hatch, 2014) 
            Table 15: Statistical Mean Total Lifecycle Emissions for nuclear and on-shore wind 
Scenario 
PM (g/kWh) 
NOx (g/kWh) 
SOx (g/kWh) 
On-shore wind turbine 
0.015 ± 0.003 
0.028 ± 0.003 
0.025 ± 0.003 
Nuclear power plant 
0.008 ± 0.003 
0.039 ± 0.006 
0.023 ± 0.003 
Source: Adapted from Hatch (2014). 
Water pollution 
Companies need to report the impact of water pollution, including excess nutrients, heavy metals and other toxins 
as detailed below. 
Nutrients and impact on water pollution 
Again, this need to be reported in a way that is accessible for the executives, the board and the investors. This should 
include as much information on the water impact across the supply chain, and not simply from the plant itself. 
There is a unique connection between the use of water and the production of energy. Energy production across 
the supply chain creates water pollution. The impact of energy projects on water varies from technology to 
technology and from project to project.     
A nuclear plant often discharge water used in the plant. This can result in minor increases in the temperature 
of the sea or other water source where the water is discharged. This has little long-term effects. 
By contrast off-shore wind farms have an impact on water pollution, as well as on marine mammals and birds. 
An article in Aquatic Biosystems entitled “Assessing environmental impacts of offshore wind farms: lessons learned 
and recommendations for the future” (Baily et al., 2014) looked at the potential effects of off-shore wind farm 
construction and operation, demonstrating that these effects differ from project to project and according to how 
the wind farm interacts with the species. Many studies have considered the effects on marine mammals and birds. 
The areas of concerns include: transportation of equipment to the site, pile driving, cable burial, as well as cable 
production and blade manufacturing impacts on water pollution and temperature. Environmental impacts include 
sound pollution, air pollution and water pollution. In addition, the alternating current (AC) or direct current (DC) 
cables also emit electromagnetic fields which may have an impact on species.  
The EU report from the JRC (EU, 2021), Technical Assessment on Nuclear Energy with respect to the ‘do no 
significant harm’ criteria of Regulation (EU) 2020/852 (‘Taxonomy Regulation’), considers water ecosystems and the 
damage caused by various energy technologies and reports: 
Water ecosystems are also damaged by toxic chemical releases, including heavy metals, volatile 
organic compounds (VOCs) and particles. Various ecotoxicity indicators have been used in

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sustainability assessments to compare technologies in terms of the toxic damage potential of their 
lifecycle chemical emissions.  
Freshwater aquatic ecotoxicity potential (FAETP) refers to the impact on fresh water ecosystems, as a 
result of emissions of toxic substances to air, water and soil. Marine ecotoxicity refers to impacts of 
toxic substances on marine ecosystems. Both indicators are expressed as grams 1,4-dichlorobenzene 
equivalents/kWh (g 1,4-DCB-eq/kWh).  
Stamford & Azapagic […], as well as Treyer & Bauer […], compared both fresh water and marine 
ecotoxicity potentials of several electricity generating technologies. The results are provided in the 
figures below. 
With regard to freshwater ecotoxicity, nuclear energy is again the best performer according to Treyer 
& Bauer, whereas the results of Stamford & Azapagic rank natural gas as best, with the other 
technologies fairly evenly matched, although nuclear has the potential to be comparable with gas 
according to the sensitivity studies. The data of Poinssot et al again compare very well with the data 
of Treyer & Bauer and the lower bound data of Stamford & Azapagic. Concerning nuclear, the bulk of 
the impact is due to metals such as vanadium, copper and beryllium coming from uranium mill tailings. 
Regarding marine ecotoxicity, nuclear is again ranked best (Treyer & Bauer – ReCiPe methodology) or 
second best (Stamford & Azapagic – CML methodology) along with natural gas. (EU, 2021) 
Figure 8: Freshwater ecotoxicity potentials of various electricity generation technologies 
 
Source: Adapted from EU (2021)  
 
Figure 9: Marine ecotoxicity potentials of various electricity generation technologies

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Source: Adapted from EU (2021)  
As such, nuclear energy is one of the better energy technologies when reporting on the impacts of water 
pollution and water toxicity.  
Waste 
Waste needs to be reported, mitigated and managed. The 
metrics for waste have not been standardised and need to apply 
across industries and consider the whole of the supply chain 
across the project lifecycle. The reporting of waste arising from 
companies and projects needs to be meaningful and inciteful, 
and the lack of reporting of waste from some companies should 
not be overlooked.  
For a long time, waste has been seen as an issue for all energy projects. Waste needs to be reported but it is also 
key that it is mitigated and managed. This applies to plastic and all other waste arising from the plant. The metrics 
for reporting waste management have not been standardised and needs to apply across industries. As set out in 
depth below, the nuclear has accounted for and managed its waste for many years and will continue to do so. 
Lessons have been learnt through the management of waste arising from nuclear companies which can be applied 
across the energy sector and more widely.   
Single use plastics 
Reporting on single use plastics is in its infancy and standardisation is key to a fair and balanced reporting. However, 
this should be extended to include not only single use plastics but all plastics to ensure that those that can be 
recycled are recycled and managed.  
Solid waste 
The reporting of waste arising from companies and projects needs to be meaningful and inciteful, and the lack of 
reporting of waste from some companies should not be overlooked. The waste arising from the whole of the supply 
chain and across the lifecycle needs to be considered and not simply the waste arising from the energy plant itself. 
The impact, mitigation and management of all waste needs to be reported. 
Radioactive waste 
Despite waste being an issue for the whole energy industry, more focus falls on waste arising from the nuclear 
industry. However, in response to this, the nuclear industry has developed the gold standard for reporting, 
mitigating and managing its waste. Lessons have been learnt through the management of waste arising from nuclear 
companies which should be applied across the energy sector and more widely.  
World Economic Forum 
Theme 
Sub-theme 
Solid waste 
Single use plastics 
 
Impact on solid waste 
disposal

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Before assessing how energy projects deal with radioactive waste, radiation needs putting in context.  
The Hatch report for the Canadian Nuclear Association sets out the radioactivity of some selected common 
materials (see Table 16 below). 
Table 16: Radioactivity of selected materials 
Source 
Radiation 
1 adult human (65 Bq/kg) 
4 500 Bq 
1 kg of coffee  
1 000 Bq 
1 kg of brazil nuts  
400 Bq 
1 banana  
15 Bq 
The air in a 100 sq metre Australian home (radon)  
3 000 Bq 
The air in many 100 sq metre European homes 
(radon) 
Up to 30 000 Bq)  
1 household smoke detector (with americium)  
30 000 Bq 
Radioisotope for medical diagnosis  
70 million Bq 
Radioisotope source for medical therapy  
100 000 000 million Bq (100 TBq) 
1 kg 50-year-old vitrified high-level nuclear waste  
10 000 000 million Bq (10 TBq) 
1 luminous Exit sign (1970s)  
1 000 000 million Bq (1 TBq) 
1 kg uranium ore (Canadian, 15%)  
25 million Bq 
1 kg uranium ore (Australian, 0.3%)  
500 000 Bq 
1 kg low level radioactive waste  
1 million Bq 
1 kg of coal ash  
2 000 Bq 
1 kg of granite  
1 000 Bq 
1 kg of superphosphate fertilizer  
5 000 Bq 
Bq = becquerel; TBq = Terabecquerel. 
Source: Hatch (2014). 
 
As the EU report states:  
The analyses did not reveal any science-based evidence that nuclear energy does more harm to 
human health or to the environment that other electricity production technologies …. Management 
of radioactive waste and its safe and secure disposal is a necessary step in the lifecycle of all 
applications of nuclear science and technology (nuclear energy, research, industry, education, medical, 
and other). Radioactive waste is therefore generated in practically every country, the largest 
contribution coming from the nuclear energy lifecycle in countries operating nuclear power plants. 
Presently, there is broad scientific and technical consensus that disposal of high-level, long-lived 
radioactive waste in deep geologic formations is, at the state of today’s knowledge, considered as an 
appropriate and safe means of isolating it from the biosphere for very long time scales. (EU, 2021) 
It further indicates that:  
Measures to ensure that radioactive waste does not harm the public and the environment include a 
combination of technical solutions and an appropriate administrative, legal and regulatory framework. 
Although there remain contrasting views, it is generally acknowledged, that the necessary 
technologies for geological disposal are now available and can be deployed when public and political 
conditions are favourable. No long-term operational experience is presently available as technologies 
and solutions are still in demonstration and testing phase moving towards the first stage of 
operational implementation. Finland, Sweden and France are in an advanced stage of implementation 
of their national deep geological disposal facilities, which are expected to start operation within the 
present decade. The radiological impact of nuclear energy lifecycle activities, including radioactive

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waste management and disposal, is regulated by law in the Member States, setting the maximum 
allowed releases and radioactivity exposure to the professionally exposed groups, to the public and 
to the environment. Respecting these limits, establishing the boundaries below which no significant 
harm is caused to human life and to the environment, is a precondition for any nuclear lifecycle activity 
to be authorized and is subsequently monitored by independent authorities. (EU, 2021) 
There are different categories of nuclear waste and the volumes of particularly high-level waste are significantly 
less than many appreciate. These are: 
• 
Low-level (LLW) and very low-level waste (VLLW) – 90% of the volume of waste, but containing less than 
0.0003% of total radioactivity: 
– LLW represents: 
– 
the majority of solid radioactive waste in the UK by volume;  
– 
the lowest activity category of radioactive waste;  
– 
generally made up of materials such as plastics, glass, metal, paper and soil that have become 
contaminated by contact with radioactive liquids or powders;  
– 
produced by hospitals, research establishments and the nuclear industry. 
– VLLW is a subset of the LLW category of radioactive waste, covering miscellaneous waste arising with 
very low concentrations of radioactivity.  
– The storage and disposal technology for dealing with LLW is well-established. Landfill sites often take 
LLW and VLLW as the waste does not need to be disposed of in specialist facilities. However, where 
there are large volumes of LLW it is super-compacted to reduce its volume and sent for disposal at the 
LLW repositories, where it is packaged and encapsulated in cement and large steel containers, and 
placed in an engineered vault a few metres below the surface.  
• 
Intermediate-level waste (ILW): 
– Arises from the reprocessing of spent fuel (most), from general operations and maintenance at nuclear 
sites and from decommissioning; and 
– it can include metal items such as reactor components (e.g. reactor pressure vessel components), and 
sludges, filters and resins from the treatment of radioactive liquid effluents.  
– Legacy ILW is typically being managed through a process of encapsulation in cement and packaged in 
stainless steel drums or higher capacity steel or concrete boxes as soon as reasonably practicable and 
placed into interim storage. Geological disposal is the preferred option for management of ILW in the 
long term; preceded by safe and secure interim storage.  
• 
High-level waste is sometimes referred to but it encompasses spent fuel and waste materials which arise 
should the spent fuel be reprocessed or recycled. This document has assumed that spent fuel will not be 
reprocessed and therefore high-level waste is not separately considered. 
In addition to radioactive waste, there is spent fuel: 
– Spent fuel are the fuel assemblies that have been “burnt” in the nuclear reactor; and the number of 
fuel assemblies depends on the size and life of the plant. 
– Spent fuel is not categorised as waste, because it still contains uranium and plutonium which could 
potentially be separated through reprocessing and used to make new fuel (i.e. be an asset to the 
company.) The latest generation of nuclear power plants are designed to extract more energy from the 
fuel by leaving it in the reactor longer for increased irradiation, otherwise known as “burn-up”. This 
results in fewer spent fuel assemblies. However, the exact number will depend on the size and life of 
the plant.  
– The higher burn-up of the modern fuel means that an individual spent fuel assembly will have a higher 
heat output and external radiation compared with a fuel assembly currently discharged from nuclear 
reactors currently in use. The long-lived radionuclides remain thermally hotter and therefore require 
longer periods of cooling in interim storage. Interim storage of spent fuel can be carried out in a manner

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which causes a very low level of health detriment, and considers below the arrangements for ensuring 
the safe and secure disposal of spent fuel from new nuclear power stations.  
Spent fuel and waste also contain medical isotopes, including: 
• 
Ac225, Ra223, Ac227 and Pb212 which are used for targeted alpha therapy. Currently production routes for 
these are typically by “milking” existing sources of nuclear material that would otherwise be considered as 
waste. Given their position in decay chains, wastes from nuclear fission can contain these isotopes (or their 
source isotopes);  
• 
Y90, which is used for beta irradiation therapy. The production route is purification of Sr-90 from spent nuclear 
fuel for loading into a Sr90/Y90 generator;  
• 
Xe-133, which is an established diagnostic and is the only approved tracer for imaging the distribution and rate 
of exchange of air in the lungs in the USA. Xe-133 is a product of U-235 fission. 
There are many more isotopes of interest for therapy, diagnostics, or combination in the form of theragnostics, 
some of which could be obtained from existing material, and others that might use existing material that can be 
irradiated (reactor or accelerator) to produce the isotope of interest. 
Transportation 
Radioactive wastes are transported in accordance with International Atomic Energy Agency (IAEA) regulations, 
and in accordance with domestic and regional agreements and directives. The packaging requirements for material 
containing radionuclides are dependent upon the radionuclide specific activity of the material, its form (solid, liquid 
or gas) and the total quantity of activity in the consignment.  
Spent fuel is transported in a shielded transport flask designed to reduce external dose rates to the low levels 
required by the transport regulations and to provide containment of the radioactive material, both during normal 
transport conditions and conditions representing transport accidents involving fire and impact. ILW packaging meets 
transport regulatory requirements in order to give confidence that these wastes can ultimately be transported. LLW 
transport methods are well-established by both road and rail. LLW is routinely transported in packages that are 
designed, certified and transported by industry as permitted in the transport legislation.  
According to a recent report by the NEA (2020), there is a strong international scientific consensus that deep 
geological repositories (DGRs) are a safe and effective approach to the permanent disposal of high-level wastes and 
spent nuclear fuel. Countries are successfully selecting sites for DGRs using open and transparent activities that 
involve stakeholders as equal participants in the decision process. Several countries are implementing these 
demonstrations and have shared their experiences. The first DGR will likely be in Finland, with operations beginning 
around 2023. 
The NEA published a statement in 2008 saying that “The overwhelming scientific consensus worldwide is that 
geological disposal is technically feasible”. (OECD, 2008) 
The NEA further noted that “Releases from engineered barriers would occur over thousands of years after 
disposal and would be very small. Additionally, these releases are diluted and slowed by the geological formation 
surrounding the repository and are further reduced by radioactive decay. The resulting potential radiological 
exposure in the biosphere would not represent, at any time, a significant increment above the natural background.” 
(OECD, 2008) 
In respect of external dose rate, the encapsulation, transport and emplacement of high burn-up spent fuel can 
be shown to be feasible using existing technology applied in the management of vitrified HLW. In particular, the 
relevant IAEA dose rate limits for transport can be met after interim storage by providing a combination of a 14 cm 
thick stainless steel gamma shield surrounded by a 5 cm thick neutron shield.  
The 1992 Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR 
Convention) and the OSPAR Radioactive Substances Strategy both aim to reduce discharges into the marine 
environment of the North-East Atlantic region to levels where the additional concentrations above historic levels, 
resulting from such discharges, are close to zero.  
It is important to note that while the objectives of the OSPAR Convention ultimately aim to reduce the 
concentrations in the marine environment, they do not prohibit the future development of the nuclear sector and 
the building of new reactors. OSPAR’s Radioactive Substances Strategy acknowledges the need to take account of

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what is achievable and focuses on the delivery of the Convention’s objectives through the application and use of 
best available techniques (BAT) and best environmental practice (BEP).  
Funded Decommissioning and waste management 
In line with best practice, nuclear power plants have to plan and pre-fund decommissioning and waste 
management activities. Generally, the funding is accumulated over the early life of the power plant, and payments 
into the decommissioning and waste management fund can be the first payment out of the payment cascade (i.e. 
before debt service). However, the payment is so small that it should not be a concern for lenders. 
The objective of the planning and funding regimes is to ensure that nuclear operators make prudent provision 
for the full costs of decommissioning installations and the full share of the costs of safely and securely managing 
and disposing of their waste, thereby reducing the risk of recourse to public funds is remote. 
Non-radioactive waste 
Non-radioactive waste is produced from operating and maintaining power plants and includes laboratory chemicals 
and lubricating and fuel oils, which need safe management and disposal.  
Hazardous waste is defined as waste with one or more properties that are hazardous to health or to the 
environment. Categories or generic types of hazardous waste, as well as the properties of hazardous waste, are 
listed in directories such as the European Commission’s Hazardous Waste Directive.  
The volumes produced by new nuclear power stations is small in relation to the total volumes of such waste 
produced generally. Amounts of non-radioactive hazardous waste arising from reactor construction and 
decommissioning are expected to be broadly equivalent to those arising from any major infrastructure or power 
construction or demolition project and amenable to the normal waste minimisation techniques. 
The treatment and disposal of waste is regulated in order to ensure the protection of the environment and 
human health, and is dealt with in accordance with the regulations applicable to non-nuclear sites.  
Other low-carbon technology waste 
Waste management from wind farms consists largely of waste associated with turbine and cable management. As 
wind farms go further off-shore, and as cables transition from AC cabling to high voltage direct current (HVDC) 
cabling (to reduce losses over longer distances) there will also be the waste associated with the converter stations. 
The precise level of the waste will depend on the individual farm and will take into account factors including the size 
of the turbine blades and the turbine type.  
There is little published data on the volumes of waste arising from wind and solar farms as the waste is generally 
not managed and is simply sent to landfills. Also, as the wind and solar industries rarely prefund decommissioning 
and waste management, the costs associated with decommissioning and waste management are not readily 
available.  Combining wind and solar farms with storage such as battery storage to produce a firn power solution 
increases the waste produced, and that needs to be managed and mitigated. There is increasing commentary and a 
significant number of studies emphasising the beneficial environmental impact if the wind sector started recycling 
materials across its lifecycle. 
However, we are beginning to see greater reporting of waste arising from different energy sources. In 2018, 
Michael Shellenberger wrote an article for Forbes entitled: “If Solar Panels are So Clean, Why Do They Produce So 
Much Toxic Waste.” The article highlighted the challenges which are being identified across the globe by 
environmental scientists around waste arising from solar panels and waste management (Shellenberger, 2018). 
Solar panels often contain a series of toxic chemicals including plastics, heavy metals including lead, cadmium and 
antimony.  
There is a growing concern that cadmium can be washed out of solar modules by rainwater, increasing the 
concerns for the environmental community. The concerns include leaching during use if the panels are broken, and 
also during decommissioning. Panels containing cadmium are beginning to be classified as hazardous waste and 
should be dealt with as such. However, despite this, panels containing cadmium are still being sent to landfills in 
some countries. These chemicals mean that the glass cannot be reused as float glass. Equally, the glass cannot simply 
be disposed of in landfill sites as the toxic chemicals are likely to leach into the soil and the water table.

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Some solar panels have been disposed of by selling them to other countries who are willing to manage the 
lower performance of second-hand panels. This allows the original plant not to have to deal with the panels as they 
create a secondary market, and thereby the panels become someone else’s problem and less developed countries 
become, as Michael Shellenberger describes them, “primary e-waste destinations”. The United Nations 
Environment Program is aware of these and similar issues. In 2015, they estimated that 60-90 % of electronic waste 
was illegally traded and dumped on poorer nations. ESG, particularly if they include the full lifecycle, should be 
highlighting on this illegal activity and helping to prevent and stop it.  
In 2015 California’s Department of Toxic Substance Control called an industry meeting to discuss the growing 
problem of solar waste. They determined that deciding whether waste was hazardous or not is more difficult at the 
end of life and that it would be better to create a database where the panels, and therefore the waste, is tracked.  
Following California’s analysis, creating a system of decommissioning and waste management at the start of 
life, as nuclear new build projects now do, could help to solve some of the problems arising with solar waste. History 
has shown the energy industry the problems of not prefunding and planning for decommissioning and waste 
management, with the historic liabilities and allocation of liabilities to operators that we witnessed in the oil and 
gas industry. 
In 2012 First Solar established a waste management fund and offered clients access to their waste management 
solutions. Some parties have raised concerns that regulating waste management and waste management funds 
would make projects uneconomic. However, it would simply put solar projects on the same basis as nuclear projects, 
thereby allowing parties, including investors, to access projects on an equal footing.  
The International Renewable Energy Agency (IRENA) estimated in 2016 that there was about 250 000 metric 
tonnes of solar panel waste in the world and projected that this amount could reach 78 million metric tonnes by 
2050. In its report entitled End of Life Management, Solar Photovoltaic Panels, the waste from photovoltaic panels 
is estimated as: 
At the end of 2016, cumulative global PV waste streams are expected to have reached 43,500-250,000 
metric tonnes. This is 0.1%-0.6% of the cumulative mass of all installed panels (4 million metric tonnes). 
Meanwhile, PV waste streams are bound to only increase further. Given an average panel lifetime of 
30 years, large amounts of annual waste are anticipated by the early 2030s. These are equivalent to 
4% of installed PV panels in that year, with waste amounts by the 2050s (5.5-6 million tonnes) almost 
matching the mass contained in new installations (6.7 million tonnes). (IEA/IRENA, 2016) 
The report continues to look at how solar panel waste should be mitigated and managed, and many of the 
suggestions are on a par with how nuclear waste is managed Further details on solar waste can be found in the links 
provided in the footnote below.20 
Waste is not just a concern of solar and nuclear. Wind and battery farms also have their fair share of waste that 
needs to be managed and mitigated. In August 2019, the Wall Street Journal wrote on the challenges facing the 
renewables industry: “If You Want ‘Renewable Energy,’ Get Ready to Dig - Building one wind turbine requires 900 
tons of steel, 2,500 tons of concrete and 45 tons of plastic” (Mills, 2019). The waste arising from the wind industry 
was also highlighted by Bloomberg in February 2020 in an article entitled “Wind Turbine Blades Can’t be Recycled, 
So They’re Piling Up in Landfills” (Martin, 2020). 
What is clear is that the nuclear industry leads the way in waste management and decommissioning and waste 
funding. Other low-carbon technologies need to follow suit and make sure they manage and mitigate their waste. 
ESG reporting should help facilitate a consistent assessment. 
Resource availability 
The resources required for any energy project are significant. The 
circularity metric for the company and its supply chain needs to be 
considered. According to the WEF, The Ellen MacArthur 
Foundation has developed the circularity transition indicators 
 
20. See also: www.nytimes/com/2021/01/08/business/economy/china-solar-companies-forced-labor-xinjiang.html; and 
www.scmp.com/news/china/society/article/2104162/chinas-ageing-solar-panels-are-going-be-big-environmental-problem. 
World Economic Forum 
Theme 
Sub-theme 
Resource 
availability  
Resource circularity

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metrics to cover resource management (Ellen MacArthur Foundation, n.d.). Again, these need to be standardised 
across all energy projects.  
In the long term, nuclear power is dependent upon the uranium resources or other special nuclear material 
being available. 
According to Uranium 2020: Resources, Production and Demand (NEA/IAEA, 2020), “identified recoverable 
uranium resources, including reasonably assured resources and inferred resources at a cost <USD 260/kgU 
(equivalent to USD 100/lb U3O8) are sufficient for over 135 years, considering uranium requirements as of 2019. 
Exploitation of the entire conventional resource of about 15.3 MtU based on current demand would increase this 
to over 250 years. The conventional resources include reasonably assured, inferred, prognosticated and speculative 
resources but exclude secondary sources or potential unconventional resources, such as uranium from phosphate 
rocks or the vast amounts at low concentration in sea-water”.   
With fast-spectrum reactors operated in a “closed” fuel cycle by reprocessing the used nuclear fuel and 
recycling uranium and plutonium, the reserves of natural uranium may be extended to several thousand years. 
Therefore, the main resource of nuclear power is not seen as a concern.  
The 2018 IPCC states:  
In the long term, the potential of nuclear power is dependent upon the uranium resources available. 
Reserve estimates of the uranium resource vary with assumptions for its use […]. Used in typical light-
water reactors (LWR) the identified resources of 4.7 Mt uranium, at prices up to 130 US$/kg, 
correspond to about 2400 EJ of primary energy and should be sufficient for about 100 years’ supply 
[…] at the 2004 level of consumption. The total conventional proven (identified) and probable (yet 
undiscovered) uranium resources are about 14.8 Mt (7400 EJ). There are also unconventional uranium 
resources such as those contained in phosphate minerals, which are recoverable for between 60 and 
100 US$/kg […]. If used in present reactor designs with a ‘once-through’ fuel cycle, only a small 
percentage of the energy content is utilized from the fissile isotope U-235 (0.7% in natural uranium). 
Uranium reserves would last only a few hundred years at current rate of consumption […]. With fast-
spectrum reactors operated in a ‘closed’ fuel cycle by reprocessing the spent fuel and extracting the 
unused uranium and plutonium produced, the reserves of natural uranium may be extended to 
several thousand years at current consumption levels. In the recycle option, fast-spectrum reactors 
utilize depleted uranium and only plutonium is recycled so that the uranium-resource efficiency is 
increased by a factor of 30 […]. Thereby the estimated enhanced resource availability of total 
conventional uranium resources corresponds to about 220,000 EJ primary energy […]. Even if the 
nuclear industry expands significantly, sufficient fuel is available for centuries. If advanced breeder 
reactors could be designed in the future to efficiently utilize recycled or depleted uranium and all 
actinides, then the resource utilization efficiency would be further improved by an additional factor 
of eight […]. Nuclear fuels could also be based on thorium with proven and probable resources being 
about 4.5 Mt […]. Thorium-based fast-spectrum reactors appear capable of at least doubling the 
effective resource base, but the technology remains to be developed to ascertain its commercial 
feasibility […]. There are not yet sufficient commercial incentives for thorium-based reactors except 
perhaps in India. The thorium fuel cycle is claimed to be more proliferation-resistant than other fuel 
cycles since it produces fissionable U-233 instead of fissionable plutonium, and, as a by-product, U-
232 that has a daughter nuclide emitting high-energy photons.” (IPCC, 2018) 
The WNA indicates in their website that: “The world's present measured resources of uranium (6.1 Mt) in the 
cost category less than three times present spot prices and used only in conventional reactors, are enough to last 
for about 90 years.” 
The use of natural resources is not only a concern for nuclear and uranium. It is clear that companies and 
projects need to report on all resources used. The US Report also highlights material requirements of various 
technologies (but again not all), as seen in Table 17 below.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Table 17: Range of material requirements (fuel excluded) for various electricity generation technologies 
Materials 
(tonne/TWh) 
Generator only 
 
Upstream energy collection plus generator 
Coal 
NGCC 
Nuclear 
PWR 
Biomass 
 
Hydro 
Wind 
Solar PV 
(silicon) 
Geothermal 
HT binary 
Aluminium 
3 
1 
0 
6 
 
0 
35 
680 
100 
Cement 
0 
0 
0 
0 
 
0 
0 
3 700 
750 
Concrete 
870 
400 
760 
760 
 
14 000 
8 000 
350 
1 100 
Copper 
1 
0 
3 
0 
 
1 
23 
850 
2 
Glass 
0 
1 
0 
0 
 
0 
92 
2 700 
0 
Iron 
1 
1 
5 
4 
 
0 
120 
0 
9 
Lead 
0 
0 
2 
0 
 
0 
0 
0 
0 
Plastic 
0 
0 
0 
0 
 
0 
190 
210 
0 
Silicon 
0 
0 
0 
0 
 
0 
0 
57 
0 
Steel 
310 
170 
160 
310 
 
67 
1 800 
7 900 
3 300 
Note: NGCC = natural gas combined cycle; PWR pressurized water reactor; PV = photovoltaic; HT = high temperature. 
Source: US Department of Energy (2015) 
The US Report clearly does not cover all resources. Rare earth metals, cobalt, lithium and wood are materials 
which are not considered The Economist magazine ran an article in January 2021 raising concerns about balsa wood 
production for wind projects: “A Worrying Windfall. The Wind-Power Boom Set off a Scramble for Balsa Wood for 
Turbines’ Blades – with Unintended Consequences” (2019). The list is endless but what is key is that full reporting is 
required. 
The US report also identifies critical materials in the medium term (2105-2025), as shown in Figure 10. 
Figure 10: Critical materials in the medium term (2015-2025) 
 
Source: Adapted from the US Department of Energy (2012)

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Some of these materials are controversial, and it is important in reporting to ensure that these materials are 
ethically sourced in an environmentally friendly way and fully reported.

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People: SDGs 1, 3, 4, 5 and 10 
Dignity and equality 
Diversity and inclusion 
Equality across the workforce and providing dignity to 
employees is a key metric for any modern business. Equity, 
dignity and inclusion irrespective of age, sex, gender, disability, 
race, ethnicity, origin, religion is key to good management and 
governance.  Diversity of gender and culture as well as 
diversity of thought is key to performance. The WEF 
recognises that: “Gender and ethnic/cultural diversity 
particularly within executive teams are closely correlated to 
both financial and non-financial performance and enhance 
stability of companies across the globe.”  
Diversity of thought, gender and culture attracts the best 
people to an organisation, including at the executive level, 
and provides the best environment for company growth and 
cohesion. The benefits of diversity, equality and dignity have 
been well documented. A 2019 book entitled Rebel Ideas: The 
Power of Diverse Thinking by Matthew Syed bring together 
many of the benefits of diversity of culture and thought to 
organisations.21 
All energy companies and projects need to work on 
improvements in diversity, equality and inclusion. The nuclear sector has shown developments in gender equality 
but there is still more to do. The renewable sector has again shown progress but has more work to do. Also, the 
Nuclear Skills Strategy Group in the UK has joined forces with Women in Nuclear to ensure that the entire sector 
embraces diversity, and to build the business case for both diversity of people and thought. Further details can be 
found on their Commitment Page22 and also in the Nuclear Sector Gender Roadmap: A journey to a diverse and 
inclusive sector.23. 
The on-going safe operation of nuclear stations continue to support highly paid skilled jobs, as the station 
provides employment to local labour, which is required to meet local salary and wage compensation, and thereby 
support the local communities.   
Pay equality, pay gaps and wage level 
Corporate policies, processes and governance should support equal basic pay and remuneration for all categories 
of employees. They help to promote equality across cultural, gender and backgrounds. They are shown to attract 
talent and to drive long-term competitiveness across companies and projects. Well-developed processes and 
procedures should maximise professional opportunities regardless of background, gender or culture. However, 
having well developed processes and procedures should not be the only metric required. How the processes and 
procedures are implemented and managed is also key to diversity and inclusion. This can include systems to mitigate 
unconscious bias. 
Wage levels and benefits should be assessed across the company to determine a fair distribution across the 
workforce. Fair compensation and benefits contribute to the economic well-being of individuals, as they help with 
the socio-economic development of regions and countries. Too wide a gap between the pay of those at the top of 
an organisation and those at the bottom can highlight inequality across the workforce. Disclosure and transparency 
of wage and benefits has not been encouraged by various cultures but has been shown to be key to equality and 
development.  
 
21. See: www.matthewsyed.co.uk/resource/rebel-ideas-the-power-of-diverse-thinking/. 
22. See: www.nssguk.com/gender-commitment/diversity/. 
23. See: www.nssguk.com/media/2017/nssg-win-sector-gender-roadmap_web.pdf. 
World Economic Forum 
Theme 
Sub-theme 
Dignity and 
equality 
Diversity and inclusion 
 
Pay equality and pay Gaps 
 
Wage level 
 
Human rights review, 
grievance impact and modern 
slavery 
 
Risk of incidents of child, 
forced or compulsory labour 
 
Discrimination and 
harassment incidents and 
monetary losses 
 
Freedom of association and 
collective bargaining 
 
Living wage

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103 
A corporate’s processes and procedures should also identify any pay gaps in the organisation to highlight 
unrepresented and disadvantaged groups. Pay gap analysis should identify inequality of pay, with an obligation on 
the executive to monitor these areas to ensure that minorities are not disadvantaged. The UK Government Equalities 
Office and the UK Chartered Institute of Personnel and Development have well established methodologies for 
undertaking a pay gap analysis. 
Energy companies and projects should have well managed policies and procedures on pay and remuneration. 
The energy sector wants to attract people who can develop the industry and deliver high quality and high performing 
projects and companies.24.  While due diligence on the company will identify any pay inequality and pay gaps, the 
energy industry, and particularly the nuclear industry, is well placed in relation to this metric. Energy companies 
want to attract the brightest and the best, and to do this they need to be awarding competitive salaries. As the 
Nuclear Energy Institute (NEI) states:  
The nuclear energy industry creates lasting, high-paying jobs for people from a wide range of fields 
and educational backgrounds. Recruiting from universities, community colleges, the military and the 
trades, nuclear power plants provide high-quality jobs to the whole community […]. Nuclear worker 
salaries are 20 percent higher on average than those of other electricity generation sources. The 
typical nuclear power plant creates $40 million in labor income each year. For every 100 nuclear 
power plant jobs, 66 more jobs are created in the local community. Nearly one in four nuclear workers 
are veterans. (NEI, 2021) 
Human rights reviews, grievance impact and modern slavery and risks of incidents of child, forced or 
compulsory labour 
Without proper checks and balances, a company’s activities could facilitate human rights abuses and other social 
and environmental abuses. Without mechanisms for employees and stakeholders to report potential abuses 
companies might miss the opportunities to identify, mitigate and manage activities. Reporting the number of 
operations that have been subject to human rights reviews both within the company and across the lifecycle and 
supply chain is of key importance to organisations. Companies should also report any grievances raised and the type 
of grievances together with the number of operations and suppliers considered to be at risk of human rights abuses.  
Companies need to ensure that there are no risks of incidents of child, forced or compulsory labour across their 
supply chains. An explanation of labour practices across the whole supply chain need to be disclosed by the 
executive and the board, and reported on. The elimination of child labour, forced labour and human trafficking 
requires companies to be open and transparent and to assess their supply chain ethics. Only through openness and 
transparency by businesses and financial institutions will these unethical practices be eradicated. 
The nuclear industry undertakes a considerable number of checks into the safety and security of its employees 
and contractors. Employees and many contractors need to be security cleared to allow them to work on the plant. 
Considerable checks are undertaken into both individuals and their companies. However, there is more that can be 
done on the wider supply chain and lifecycle of a nuclear plant.  
In July 2019, the Financial Times published an article called “Congo, child labour and your electric car”, raising 
concerns about child labour and the mining of cobalt for electric cars (Sanderson, 2019). This followed an article by 
Amnesty International called: “Exposed: Child labour behind smart phone and electric car batteries” (Amnesty 
International, 2016). In December 2019, a US court case was brought against Apple and Google (among others) over 
deaths related to Congolese child cobalt mining (Kelly, 2019). It is thus essential that mining practices are verified as 
part of the supply chain for a number of energy projects. Mining practices thus need to be diligenced as part of the 
supply chain for a number of energy projects. 
In January 2021, the New York Times raised concerns about some solar companies in China using forced labour 
(Swanson, 2021). Investors, when considering ESG and investing in projects, need to undertake full lifecycle 
assessments to ensure that forced labour is not being used in the supply chain and that companies are fully reporting 
on all activities.  
 
24. Further details on this subject can be found in Global Reporting Standards (GRI)405 at 
www.globalreporting.org/standards/media/1020/gri-405-diversity-and-equal-opportunity-2016.pdf.

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Discrimination and harassment incidents, and monetary losses 
Organisations need to be built on a culture of respect, courtesy and professionalism. Without this foundation, 
employees and organisations will be unable to grow and develop. Incidents of discrimination and harassment need 
to be reported and dealt with fairly and transparently, but without causing more distress to those subjected to the 
discrimination or harassment. Companies need to record and disclose any incidents and to try to eradicate the 
behaviours.  In addition, companies need to report the monetary losses, including those due to legal proceedings 
or claims relating to such behaviours. Ideally, this should be broken down to identify the basis for the proceedings 
or claims and to highlight any failings within the organisations which have allowed such behaviours to grow. 
Much will depend on the culture and reporting within an individual company. However, the energy industry as 
a whole and the nuclear industry in certain countries, are doing significant work to try to eradicate discrimination 
and harassment in all forms. 
Freedom of association and collective bargaining 
Organisations should disclose the percentage of the workforce that is covered by collective bargaining agreements 
and should assess its supply chain to ensure they allow for freedom of associations and collective bargaining. These 
metrics and processes are seen to respect the rights of workers and human rights. It is important that companies 
promote these rights across their own workforce and through their supply chains. 
The Unions in the UK energy industry have strong connections with both the workforce and with industry 
generally. Prospect alone represents over 14 000 individuals across the energy supply chain. Thousands of Unison 
members in the UK also work in the energy sector. In Canada, collective bargaining is established by law and highly 
regulated. There are two main unions who represent approximately 23 000 people across the electricity sector. The 
two unions are the Power Workers Union and the Society of United Professionals.   
Living wage 
Companies should assess their wages not only internally but against the living wage in their country, and also 
as required to increase the socio-economic development of a region and a country. Levelling up to address 
disparities across regions is important to the creation of balanced societies and to deal with discrimination across 
areas. The living wage is a benchmark for responsible employers. However, because of energy’s wider role in socio-
economic development, all energy projects should be treating the living wage as the lowest denominator for any 
assessment.  
Companies should regularly benchmark their wages to ensure that they are reflective of the market. The energy 
industry as a whole often pays a premium to attract the brightest and the best to the industry, and this is particularly 
true of the nuclear industry.  
According to a report prepared by Oxford Economics (2019) and called Nuclear Power Pays: Assessing the 
Trends in Electric Power Generation Employment and Wages, the nuclear power generation industry employed 
nearly 48 400 workers in the US paying an average salary of USD 136 600. This exceeded average regional wages 
across the country and placed nuclear power as the highest paying industry in the electric power generation sector.

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105 
Health, safety and well-being 
There is a growing recognition that 
the well-being of employees is vital 
to successful businesses. Well-
being extends to having a healthy 
work-life balance. Well-being is key 
to performance, productivity and 
success and contributes to a high 
performing 
organisation 
with 
employees 
who 
are 
socially 
integrated. 
Maintaining strong standards 
of health and safety and wellbeing 
can 
improve 
productivity 
and 
operational 
efficiency 
across 
companies. Effective management 
of health and safety requires 
companies to understand the risks 
their work presents to employees, 
contractors and other third parties 
as well as to members of the public. 
In many countries this is enshrined 
in law. Countries have regulatory 
bodies; for example, in the US the 
Occupational Safety and Health 
Administration (OSHA) and the 
Health and Safety Executive in the 
UK provide guidance on effective 
ways of managing risks to health 
and safety for employers, employee representative groups and employees. On occasions when health and safety is 
not effectively managed, these bodies also have powers to enforce companies to improve health and safety, 
including, where necessary, through prosecution.  
The wellbeing of employees and contractors is becoming more of a focal point as the importance of mental 
health and work-life-balance becomes more important. 
Health and safety 
Employers should strive to create and maintain a safe workplace for their employees. Workplace safety should be a 
high priority for the board and the executive (and ultimately the shareholders) in all types of workplaces and 
industries.  Safety is the responsibility of everyone in a company, with the board and the executive setting the 
policies and leading by example, but responsibility for safety lies with everyone working in the company. Companies 
are obligated to provide a safe working environment for their employees. Regardless of the type of work they 
perform, whether it's pouring concrete to repair heavily trafficked roads or pouring over accounts in the finance 
department, employees should never be in a position where their physical safety is in jeopardy. 
At its heart, workplace safety is the concept that employers must control recognised hazards in the workplace. 
This doesn't mean that a place of employment is completely free of all hazards, but rather that the risk associated 
with the hazards is reduced to an acceptable (or, reasonably practicable) level. Safety hazards can come from many 
sources, but the common ones are slips and trips, working from height, working in confined spaces, electricity, fire, 
and explosions, working with machinery and pressure systems.  
Effective safety management requires open and transparent communication. Employees should feel 
empowered to raise any concerns they have and work with the company to develop and maintain practical and 
effective processes, procedures and controls to manage the risk.  
World Economic Forum 
SASB 
Theme 
Sub-theme 
Topic 
Metric 
Health and 
well-being 
Health and 
safety 
Workforce 
health and 
safety 
1) Total recordable 
incident rate 
(TRIR); 2) fatality 
rate; and 3) near 
miss frequency rate 
(NMFR)  
 
Monetised 
impacts of 
work-related 
incidents on 
employees, 
employers 
and society 
 
 
 
Well-being 
 
 
 
 
Nuclear safety 
and 
emergency 
management 
Total number of 
nuclear power units, 
broken down by US 
Nuclear Regulatory 
Commission (NRC) 
Action Matrix 
Column  
 
 
 
Description of 
efforts to manage 
nuclear safety and 
emergency 
preparedness

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
In Europe and the UK there is a downward trend of workplace fatal injuries. The UK consistently has one of the 
lowest rates of fatalities. In the year 2019 to 2020, 111 workers were nonetheless killed at work.25. 
Death rates were considered by Our World in Data for various energy technologies. Nuclear is shown to be 
comparable with renewables, as shown in the Figure 11 below.   
Figure 11: Death rates from energy production per TWh* 
 
*Death rates are measured based on deaths from accidents and air-pollution perTWh 
Source: Our World in Data 
The health of employees is vital to the productivity and success of a company. Health includes both physical 
and mental health.  In the year 2019 to 2020, 1.6 million working people in Great Britain suffered from a work-
related illness and 38.8 million working days were lost due to work-related illness and workplace injury. These 
figures illustrate the impact on companies of health-related issues in the workplace.  
The hazards and risks associated with occupational health are often harder to identify and therefore effectively 
control. However, occupational health issues such as cancer consistently account for many fatalities given their long 
latency. Health hazards can come from many sources, but the common ones are exposure to hazardous substances, 
manual handling and repetitive strain, noise, vibration, and exposure to chemicals, pollutants and radiation. Stress 
is also a key contributor to workplace absenteeism. Stress affects people differently and many external factors can 
contribute to stress in the workplace.  
Energy companies generally operate to the highest health and safety standards. As Energy UK states on its 
website: “Maintaining Health and Safety standards across all activities is critical to the industry. From our generators 
through to our suppliers, our members are committed to the highest standards of health and safety. Whether 
through monitoring trends, developing best practice or guidance on regulation or legislation implementation, we 
work with members to ensure the energy industry's workforce is safe and healthy at work” (Energy UK, 2019). 
Nuclear regulation is a mix of international and national laws. The International Atomic Energy Agency (IAEA) 
works to provide a strong, sustainable, and visible global nuclear safety and security framework for the protection 
of people, society, and the environment. This framework provides for the harmonized development and application 
of safety and security standards, guidelines, and requirements; but it does not have the mandate to enforce the 
application of safety standards within a country. 
 
25. See 
more 
health 
and 
safety 
statistics 
at 
the 
UK 
Parliament, 
House 
of 
Commons 
Library 
website: 
https://commonslibrary.parliament.uk/research-briefings/sn04936/.

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107 
The EU cooperates with non-EU countries and international organisations on nuclear safety and in 2013, the 
European Commission signed a Memorandum of Understanding with the IAEA to further strengthen the 
cooperation through expert peer reviews, emergency preparedness and response, and other measures.  
In 2014, Euratom amended the Community framework for the nuclear safety of nuclear installations directive, 
which requires EU countries to give the highest priority to nuclear safety at all stages of the lifecycle of a nuclear 
power plant through independent national regulatory authorities, peer reviews and re-evaluation for all nuclear 
power plants to be conducted at least once every ten years. 
A key attribute of the nuclear sector is behavioural safety which is developed within individuals through training 
and observing others over many years such that good practice becomes the norm within staff and a subconscious 
level of high safety is implemented, rather than something that needs to be actively reinforced and seen as a “chore”. 
The World Association of Nuclear Operators (WANO) have also developed their principles of a healthy nuclear safety 
culture. 
The system of radiation protection that is used across Europe and worldwide is based on the recommendations 
of the International Commission for Radiation Protection (ICRP) and the International Commission on Radiation 
Units and Measurements (ICRU). The ICRP system of radiation protection is based on three fundamental principles: 
justification, optimisation, and dose limitation.  
The UK government issued the “Nuclear Emergency Planning and Response guidance”, which describes the UK 
response framework and associated capabilities that may be required in the event of a radiation emergency. The 
document discusses the importance of knowledge of radiation and its effects, and the importance of effective 
communication in a radiation emergency. In 2017, the UK government ran a consultation on revised requirements 
for radiological protection, which included a range of stakeholders from local authorities and industry to members 
of the public, professional bodies, and emergency services. In October 2018, the UK government responded to this 
by making a commitment to take steps to build on already robust radiological emergency preparedness and 
committed to implementing several enhancements.  
As in other counties, regulation in the United States is robust. For example, the U.S. Nuclear Regulatory 
Commission (NRC) requires all nuclear plants to be able to withstand the most severe natural phenomena 
historically reported in a 200-mile area around each plant. All nuclear energy facilities in the United States are 
required to develop and test detailed emergency response plans to protect the public. The NRC reviews and 
approves these plans and also coordinates approval of these plans with the Federal Emergency Management Agency 
(FEMA). State and local agencies develop detailed plans for the population within the 10-mile emergency planning 
zone. Zones out to 50 miles are geared toward protecting public health along with monitoring and protecting the 
food supply. Nuclear facilities are also responsible for sampling water, milk, soil and crops within 50 miles of a plant 
(Exelon, 2020). 
Whether international or national, best practice around health and safety is key to the energy industry as a 
whole. In the nuclear industry, there is one health and safety concern which attracts more than its fair share of focus 
– radiological health and safety. Nuclear companies go to extreme lengths to protect both employees and wider 
stakeholders, including the general public from exposure to ionising radiation. 
Often communication in this area focusses on the management of incidents and the emergency response to 
accidents. However, any company involved in nuclear activities – whether that be power companies, medical 
companies (e.g. hospitals and radiological medical facilities) and even airlines – operate and maintain open and 
transparent processes and procedures to manage and mitigate exposure to radiation.    
The release of radioactivity into the environment could occur through the planned release of gaseous and liquid 
discharges, through to an unplanned release of radioactive waste or as the result of an accident or terrorist incident. 
Public Health England, which regularly reviews the radiation exposure of the UK population, has calculated that the 
overall average annual dose to a member of the public from all sources of radioactivity is 2.7 millisieverts (a measure 
of dose and abbreviated as mSv) per year. Of this dose, about 84% is from natural sources, including cosmic radiation 
entering the earth’s atmosphere from space, and radiation from the radioactive materials that occur naturally in 
soils and rocks, about 16% from medical procedures such as X-ray equipment and about 0.2% from all other sources, 
including domestic smoke detectors and nuclear power plants.  
Through its focus on health and safety, and particularly protecting all parties from exposure to ionising radiation, 
the nuclear power sector has become a leader in health and safety regimes.  A 2002 review by the International 
Energy Agency (IEA) on the environmental and health impacts of electricity generation compared fatalities per unit 
of power produced for several leading energy sources. Nuclear companies’ processes and procedures such as open

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
reporting, peer observation, independent verification, learning from experience and action tracking/resolution are 
key to sustaining a vigorous health and safety culture. The IEA examined the lifecycle of each fuel from extraction 
to post-use and included deaths from accidents as well as long-term exposure to emissions or radiation. Nuclear 
was reported to have the lowest impact of health, with coal having the highest impact on health. The low rates of 
conventional health and safety incidents in the nuclear sector are often attributed to the translation of nuclear, 
radiological safety principles being applied to general health and safety practice on site.  In other words, the culture, 
systems and processes in place to facilitate effective nuclear, radiological safety are the same as those applied to 
general health, safety and environment. 
The potential effects from radiation on the general public are constantly monitored. The Committee on Medical 
Aspects of Radiation in the Environment (COMARE) has, since 1986, investigated the incidence of childhood cancer 
and other cancers around nuclear sites. Its view is that “there is no evidence from this very large study that living 
within 25 km of a nuclear generating site in Britain is associated with an increased risk of childhood cancer”. (UK 
Government, 2011)  
The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR)26  has been publishing 
reports on exposure to radiation from the whole nuclear fuel cycle since the 1970s. UNSCEAR’s finding is that the 
dose rate to members of the public from uranium mining is low and would be imperceptible from variations of the 
normal background dose rate from natural sources.  
UNSCEAR’s finding is that: 
The average annual effective doses to workers in the nuclear fuel cycle are, in most cases, larger than 
the doses to those in other occupations; for the fuel cycle overall, the average annual effective dose 
is about 1.75 mSv. For the mining of uranium, the average annual effective dose to monitored workers 
in countries reporting data was about 4.5 mSv [for the most recent period considered (1990-1994)], 
and for uranium milling operations, it was about 3.3 mSv. There are, however, very wide variations 
about these average values, with doses of about 50 mSv being reported in some countries.  
UNSCEAR’s finding summarises detailed evidence presented in the report. From this evidence it is clear that 
these high doses are exceptional. In only one country and period (uranium mining in Gabon in the period 1985-1989) 
is the average annual effective dose to workers recorded as being over 20 mSv, at 21.0 mSv. In all other countries 
the average annual effective dose to workers is consistently below 20 mSv – and in most cases well below – and in 
most countries, including Gabon, the trend over the periods covered (from 1975-1979 to 1990- 1994) is downwards.  
Across the world, therefore, UNSCEAR reported the exposure of employees to radiation for uranium mining 
and milling as, with some exceptions, well below the recommended ICRP annual limit applied in the UK of 20 mSv.  
In August 2010, UNSCEAR published the first volume of its 2008 report entitled Sources of Ionizing Radiation, 
which includes, as Annex B, further consideration of “Exposures of the public and workers from various sources of 
radiation”. (UNSCEAR, 2008) 
The Organisation for Economic Co-operation and Development (OECD) conducted a study in 2000. Although its 
purpose was to compare options for the management of spent fuel, this involved looking at the radiation exposure 
caused by uranium mining. The study found that the dose levels to employees, although higher than for other stages 
in the nuclear fuel cycle, remained at levels similar to the averages reported by UNSCEAR, and therefore well below 
the recommended ICRP annual limit of 20 mSv. The study also found that doses to members of the public were “low 
compared to the pertinent regulatory limits, and also insignificantly low compared with exposures from natural 
background radiation”. (OECD, 2000) 
UNSCEAR looked at the average annual effective doses to workers in the nuclear fuel cycle and concluded that 
the average annual effective dose is about 1.75 mSv. For the mining of uranium, the average annual effective dose 
to monitored workers in countries reporting data was about 4.5 mSv, and for uranium milling operations, it was 
about 3.3 mSv. There are, however, very wide variations about these average values, with doses of about 50 mSv 
being reported in some countries. UNSCEAR reported the exposure of employees to radiation for uranium mining 
and milling as, with some exceptions, well below the recommended annual limit of 20 mSv. 
In August 2010, UNSCEAR published its findings demonstrating that average annual effective doses have 
declined further since their previous report.  
 
26. For more information on UNSCEAR announcements and reports, see at www.unscear.org/.

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109 
Average annual doses in uranium mining were down from: 
• 
4.5 mSv in 1990-1994; to  
• 
3.9 mSv in 1995-1999; and  
• 
1.9 mSv in 2000-2002. 
For uranium milling, average annual doses were down from 
• 
3.3 mSv in 1990-1994; to  
• 
1.6 mSv in 1995-1999; and  
• 
1.1 mSv in 2000-2002. 
The findings of these studies are therefore that the radiation exposure caused by uranium mining is high 
compared with other stages of the fuel cycle but in the vast majority of cases it is low in terms of impact on employee 
and members of the public and well below regulatory dose limits. 
The Medical Exposure Directive (MED) deals with the health protection of individuals against the dangers of 
ionising radiation in relation to medical exposure. This is the main legal instrument dealing with the protection of 
patients undergoing diagnostic and therapeutic procedures which utilise ionising radiation. The MED aims at 
eliminating the practice of unnecessary medical exposures, and to this end, the principle of justification is central to 
the Directive. The scope of the Directive includes not only patients, but also other individuals exposed either directly 
or indirectly. This includes those exposed in occupational health surveillance, health screening, research, and 
medico-legal procedures. Passenger security scanning using ionising radiation is not addressed explicitly in the 
current text.  
Well-being 
Well-being is associated with numerous health, job, family, and economically related benefits. Again, as an 
example, poor mental health costs UK employers up to £45 billion a year, this is a rise of 16% since 2016 - an extra 
£6 billion a year27. Higher levels of well-being are associated with decreased risk of disease, illness, and injury; better 
immune functioning; speedier recovery; and increased longevity. Individuals with high levels of well-being are more 
productive at work and are more likely to contribute to their community.28  
“Mental health problems and stress can affect anyone, regardless of their position in the business. Therefore, 
physical and mental well-being should be made a high priority in the workplace. Worryingly though, for many, this 
is not the case. In the UK 84% of managers acknowledge their responsibility in helping with employee mental health, 
but only 24% have any training in the area. Yet promoting wellbeing in the workplace can strengthen employee 
engagement, reduce the likelihood of poor mental health, and improve team happiness.” (Murphy, 2020)  
According to the American Institute of Stress (2019), “US companies lose up to $300 billion yearly as a result of 
workplace stress and only 43% of US employees think their employers care about their work-life balance”. It is also 
reported that “83% of US workers suffer from work-related stress and over a quarter of employees are at risk of 
burning out in the next 12 months”. Canadian companies lose an estimated $16.6 billion in productivity per year 
due to workers calling in sick, as a result of mental health issues a trend that many expect to increase in severity, as 
more workers are reporting higher levels of stress and other mental health concerns. One in four workers has left 
their job due to work-related stress, according to a 2017 Monster Canada study.29 Similar statistics are available for 
other countries, where the well-being of staff is a key challenge and is reported to be getting worse. 
While initiatives in this area are generally not legal requirements, companies can gain increased productivity 
and impact positively on employee’s health through activities, and promoting well-being in the workplace can 
strengthen employee engagement with a positive impact on health and safety management.  
 
27. See “Poor mental health costs UK employers up to £45 billion a year”, Deloitte at www2.deloitte.com/uk/en/pages/press-
releases/articles/poor-mental-health-costs-uk-employers-up-to-pound-45-billion-a-year.html  
28. www.cdc.gov/hrqol/wellbeing.htm. 
29. www.mercer.ca/en/our-thinking/how-much-are-you-losing-to-absenteeism.html.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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These initiatives often form part of a company’s social and corporate responsibility efforts. Mental health 
awareness, together with medical and healthcare services, helps to demonstrate a company’s commitment to these 
important issues.  
Clear communication linked to processes of how workers access medical and health-care services are also 
important metrics. 
In the OECD study How’s Life? 2020 Measuring Well-being, 11 dimensions of well-being are examined, including 
income and wealth, work and job quality, housing, health, knowledge and skills, environment quality, subjective 
well-being, safety, work-life balance, social connections and civil engagement. While this study reported increases 
in well-being since 2010, many people are stating they feel more disconnected and 7% of people in OECD countries 
report very low life satisfaction and two thirds of people in OECD countries continue to be exposed to dangerous 
levels of air pollution. (OECD, 2020)   
Studies benchmarking and measuring well-being across sectors are not commonplace, as the Corporate 
Wellness Magazine discusses in its article “Benchmarking Wellness Programs: How Does Your Program Measure 
Up?”. According to this article:  
The search for benchmarks is a fluid process. The scientific literature is helpful in establishing 
benchmarks from visionary employers who have used sophisticated design, development, marketing, 
communication, implementation, and evaluation strategies to apply leading programs. The 
information to be obtained from the published literature is not typical though, because there is little 
incentive to publish poor results. To help others evaluate their wellness programs, we encourage you 
to make your findings public. As employers increasingly disseminate and discuss their findings, the 
knowledge required to improve program outcomes will grow for everyone, and the health and 
productivity of the U.S. workforce will improve along the way. (Musich et al., n.d.)  
When looking specifically at the nuclear industry, while wellbeing is taken extremely seriously, finding impartial 
evidence to back this up is not easy. It is often integrated into wider health and safety policies.  
Nuclear safety and emergency management 
The WEF did not identify this as a metric, presumably because it is seen to be very specific to nuclear companies 
and projects. However, the global nuclear industry is amongst the industries with the highest levels of health and 
safety and emergency management as demonstrated above. Other energy companies could learn from the nuclear 
industry in this regard. Standardisation of these highest levels across the energy, and other sectors, should be 
encouraged and developed.  
 
Skills for the future 
Skills improve a company’s future, and a wide and diverse range of 
skills are key to the success of a company. Training and skills also 
help to improve careers prospects and to improve human capital. 
When companies fail to invest in training and skills it can result in a 
detrimental effect on a company’s performance. Training and 
development also enhance a company’s ability to attract and retain 
talent, which in turn helps the company to grow. Training needs to 
cover a wide range of hard and soft skills, which can help with an 
individual’s development.  
Reporting should include: types of training and topics, paid 
educational leave, training or education pursued externally and 
reskilling of employees. Providing information on the investment in 
training is also important. 
The nuclear industry experienced a hiatus in building new power plants and bringing new people into the 
industry. Over a decade ago, skills for the future were recognised as a concern for the industry and considerable 
World Economic Forum 
Theme 
Sub-theme 
Skills for the 
Future 
Training 
 
Number of unfilled 
skilled positions 
 
Monetized impacts of 
training – increasing 
earning capacity as a 
result of training 
intervention

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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111 
work has been undertaken to attract new people to the industry and to support future projects and companies. In 
the UK, the Nuclear Skills Strategy Group30 (NSSG) was established: 
• 
to bring together major employers, government, regulators and trades unions to address the sector’s skills 
challenge; 
• 
to ensure we can meet the demand for 100,000 skilled jobs needed in the UK – both skills for nuclear and 
nuclear skills; 
• 
to build a more diverse workforce – including 40% female representation by 2030 (up from 22%); 
• 
to grow our Subject Matter Experts, to replace those retiring and to ensure we lead innovation in new 
technology; 
• 
to improve the mobility of skilled people, both within our sector and from other sectors; and 
• 
to attract young people into the nuclear sector, increasing visibility in schools of careers in nuclear. 
The NSSG has undertaken a review of the industry to assess the nuclear workforce. Its findings can be found in 
the report entitled Nuclear Workforce Assessment (2021). Similar activities have been undertaken in other countries. 
Some counties, such as China, have continued to build and to develop skols for the future through their nuclear new 
build programme. 
Number of unfilled skilled positions  
The rise in technology and development of companies’ processes and procedures has resulted in skills gaps. It is 
vital that companies identify those skills gaps and seek to fill them. This is crucial not only at an individual company 
basis but also across industries, region and countries. If the socio-economic development of a region is to be 
undertaken, a long-term strategy for filling skills gaps should be considered as training to fil future skills gaps begins 
in schools. 
Companies should report on the number of unfilled skills positions, and on their strategies to hire and train 
candidates for these positions. 
Training and monetized impacts of training 
Training and innovation can have a direct impact on a company’s performance and long-term value, as well as on 
employees’ satisfaction. Companies should report on the investments made in training as a percentage of payroll 
and should analyse the effects of training and reskilling on the business.31. 
 
 
 
30. www.nssguk.com/. 
31. The WEF recommends the Kirkpatrick Model, which evaluates four levels of training (Reaction – Learning – Behaviour – 
Results), each successive level representing a more precise measure of the effectiveness of a training program.

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Prosperity: SDGs 1, 8, 9 and 10 
Wealth creation and employment 
These metrics are intended to consider the wider socio-
economic development activities of the company and the 
company’s impact on wider societal development. This is 
intended to be a more holistic approach than what has recently 
been used by companies to consider their social impact.  
Assessment of the wider socio-economic impacts of a 
particular activity typically considers the following: 
• direct effects – the economic value created by the activity 
itself; 
• indirect effects – the economic value created by supply chain 
that is needed to serve the activity itself;  
• induced effects – the impact on the wider economy by 
employees. 
Government bodies conduct extensive analysis for their country or region of the interlinkages between 
different activities within the overall economy. Multipliers are produced to capture the effects of a company’s 
activities on society. Multipliers can be either Type I or Type II.  Type I multipliers capture the increment in economic 
value linked to indirect effects, but not induced effects. Type II multipliers capture the increment in economic value 
linked to indirect effects and induced effects. 
Countries measure GVA in different ways. Standardised reporting would be helpful and could include: 
• 
Employment Multipliers (direct and indirect jobs) 
• 
Employment Effects – the effect of employment on the wider region/ country. 
• 
Income (or Compensation of Employees) Multipliers and Effects – the effect of employment on wider 
income and compensation for employees. 
• 
GVA multipliers – a ration of direct and indirect jobs and multipliers to calculate the change to the 
economy as a whole. 
• 
GVA effects – changes to the wider economy from the final use.  
Companies need to report on the specific GVA effects from their company and/or project.  
Number of jobs created 
This metric wants companies to consider the jobs created during a defined period. For an established company that 
may be year in year, and for a capital project that may be by phase of the project. Job creation is viewed as a key 
indicator of economic growth, and when taken together with remuneration and other processes and procedures it 
provides an indication of the ability of a company to attract talent. It is evidence of prosperity as it captures the 
ability of the company to support employment and growth in the region. 
Energy new build projects always create direct new jobs. However, different levels of new jobs are created 
through different phases. An analysis by the WNA (2020) shows that for a given installed capacity, nuclear power 
would generate more than three times more jobs that wind power. 
In 2019, a Deloitte study (Foratom, 2019) found that for every euro spent in the nuclear industry, EUR 5 in the 
EU economy and EUR 3.6 of disposable income to the European households are generated, and every direct job 
created in the nuclear industry creates an additional 3.2 jobs in the EU economy as a whole. In the United States 
each dollar spent by an average nuclear power plant during one year of operation is estimated to trigger an 
additional USD 1.04 of output in the regional economy, USD 1.18 in the state and USD 1.87 at the national economy 
level (NEI, 2014). 
World Economic Forum 
Theme 
Sub-theme 
Wealth creation 
and employment 
Number of jobs created 
 
Economic contribution 
 
Financial investment 
contribution 
 
Infrastructure 
investment and 
services supported 
 
Significant indirect 
economic impacts

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113 
With a global nuclear fleet of about 400 GW today, nuclear energy generates about 1.2 million direct and 
indirect jobs, or an average of 3 000 jobs/GW (NEA, 2020b). These jobs are long-term, highly educated, high-skilled 
employment with premium wages that result in significant spill-over investment into the local and regional economy. 
For example, the Hinkley Point C project in the United Kingdom will result in 25 000 employment opportunities, 
including over 1 000 apprenticeships during the construction phase, and 900 permanent jobs onsite during the 60-
year life of the plant. UK companies will deliver about 64% of the construction contracts, and the project will 
contribute to the local economy GBP 1.5 billion during construction, and about GBP 40 million a year during 
operation. In contrast, 39% of all renewable energy jobs are in China (IRENA, 2019). 
The Canadian Nuclear Association 2019 report on the “Benefits of Nuclear Energy for Canadians” states: 
The many Canadian organizations that make up the nuclear industry create high quality jobs and bring 
income to our Canadian communities. This study has assessed the number of jobs created and the 
impact on Canada’s GDP with the following results: 
• 
The total number of jobs created across Canada is 76,000 
• 
The total impact to the Canadian GDP is $17 Billion per year 
• 
The medical isotope industry with all its benefits to the health of Canadians creates 8,500 
jobs 
• 
…The impact on Canada’s economy in terms of GDP is $17 Billion per year. (MZ Consulting, 
2019) 
Economic contribution 
This metric requires the consideration of direct economic value generated and distributed on an accruals basis, 
covering the basic components: revenue, operating costs, wages and benefits, payments to investors/debt and 
equity service, payments to government and community investment. It also takes into consideration any financial 
assistance received from government. 
This is intended to provide a basic indication of how a company has created wealth for stakeholders. It provides 
an overview of the direct monetary value the company has created. This includes taxes paid to governments and 
therefore into the wider economy.   
Financial investment contribution  
Capital expenditure (CapEx) is of particular relevance to capital projects. However, it is also relevant to established 
companies that are looking to grow and expand. This metric considers the CapEx minus depreciation as an indication 
of the company’s overall investment strategy. In addition, the metric asks to consider the payback to shareholders 
by considering share buybacks and dividends.   
Investment and payback are key indicators of a company’s growth strategy and its ability to expand its 
operations and to create additional employment. Also, wealth creation from investment activities can be evidenced 
through the CapEx versus shareholder distributions.   
Infrastructure investment  
The extent of any infrastructure investment and the services supported through it are an exceptional indication of 
growth. For a special purpose vehicle (SPV) established for a new infrastructure development, this is the main focus 
for the company. However, for an established company new capital projects are evidence of growth. Any 
infrastructure development has an impact on the local communities and therefore the socio-economic development 
of those communities. In kind and pro bono activities should not be discounted as they also have a wider benefit. 
This evidences a company’s capital and other contribution to the wider economy.

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Services supported significant indirect economic impacts 
Positive and negative impact on the wider economy need to be considered. The significance of the indirect economic 
impact should be considered in light of national and international benchmarks.  Socio-economic growth or decline 
needs to be considered to consider the wider and long-term impacts on society.  
 
Energy affordability 
SDG 7 provides for access to affordable, reliable, 
sustainable and modern energy for all. Access to 
affordable, reliable and clean energy is crucial for 
achieving 
sustainable 
development 
goals, 
from 
eradicating poverty through to advancing health and 
education, facilitating industrial development and 
reducing greenhouse gas emissions. Since 1992 energy’s 
role in meeting all of the SDGs has been identified, 
however that energy needs to be affordable and reliable 
to allow people access to other resources including 
schools, clean water and healthcare.  
Low-carbon energy – wind, solar and nuclear – can 
provide the energy to ultimately achieve high living 
standards, good health, a clean environment and a 
sustainable economy. Nuclear, wind and solar are also 
vital to countries abilities to meet their NDCs and Net-
Zero commitments. Nuclear and renewables need to 
work together to provide system solutions.  
Energy pricing – energy rates, typical bills, 
disconnections  
One of the challenges as the world moves to 
decarbonised energy is the need to reconsider the basis 
for pricing energy – as with many aspects of modern life 
– to include the consequences of previously ignored 
externalities – in this case the previously unpriced 
consequences of CO2 pollution. Energy pricing and 
taxation varies significantly around the world with 
approaches varying on the extent of inclusion of sales 
tax or VAT, the extent to which time-of-day pricing 
passes on some elements of production price variability 
(itself derived from a manufactured wholesale market 
mechanism) and even the extent to which costs are fully 
passed on or covered by wider taxation systems. The net 
effect of this has been to disguise the true costs of 
energy in some cases and some early attempts at 
behavioural economics have rendered energy pricing a 
socially inconsistent tool. 
Part of this has been a consequence of the different 
approaches to charging for energy usage to businesses 
and individuals with intricate market models, not always at the service of citizens.  A simple example of this is where 
energy regulators’ supervision of monopolistic elements of the energy system is predicated on reducing the cost to 
consumers over a short period of time when compared to asset lives. Others examples include systems such as that 
in Texas where the instantaneous energy price from an auction process is passed on directly to consumers, resulting 
in households being charged rates of up to USD 9/kWh in the cold snap of February 2021 – compared to the more 
normal USD 0.12/kWh – and consumers facing bills of USD 6 000 to heat normal-sized homes for a few days (Meyer 
et al., 2021).   
SASB 
Topic 
Metric 
Energy 
affordability 
Average retail electricity rate for: 
1) residential;  
2) commercial; and  
3) industrial customers 
 
Typical monthly electric bill for 
residential customers for: 1) 500 
kWh; and  
2) 1 000 kWh of electricity 
delivered per month.  
 
Number of residential customer 
electric disconnections for non-
payment, and the percentage 
reconnected within 30 days.  
 
Discussion of impact of external 
factors on customer affordability 
of electricity, including the 
economic conditions of the 
service territory.  
End-use 
efficiency and 
demand 
Percentage of electric utility 
revenues from rate structures that 
1) are decoupled; and 2) contain a 
lost revenue adjustment 
mechanism. 
 
Percentage of electric load served 
by smart grid technology. 
 
Customer electricity savings from 
efficiency measures by market. 
Grid resiliency 
Number of incidents of non-
compliance with physical and/or 
cybersecurity standards or 
regulations. 
 
1) System Average Interruption 
Duration Index (SAIDI); 2) System 
Average Interruption Frequency 
Index (SAIFI); and 3) Customer 
Average Interruption Duration 
Index (CAIDI), inclusive of major 
event days.

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115 
As energy systems are entirely redesigned, and in many countries the entire primary energy provision is 
replaced, socially equitable pricing debates will return and the role of a “market” will increasingly become 
questioned. Historically, markets have set the price for energy and changes to the pricing were slow, with a focus 
by markets on bringing down the costs of energy.  Over that period, the changes were generally slow enough and 
small enough to avoid wholesale problems with stranded assets, which the drive to Net Zero is already creating. 
The challenge for most countries as they replace their entire primary energy creation systems will be one of 
the sheer speed needed to achieve Net Zero, and as a consequence there will not be time for a near-perfect cost 
optimisation. Equally, the risk of stranded assets will increase. So the question will have to be asked about the role 
of markets and indeed where many of the low-carbon electricity generation technologies are near zero marginal 
cost, there will be a question to be answered about what exactly is the role of a market in these circumstances. 
What is the objective of the market? How do markets deal with the complexities of consumer action “behind the 
meter” which can add to system-level complexity? To what extent can and will consumers react in a meaningful way 
to behavioural pricing signals in a world where, for the developed economies, energy is now seen as much as an 
individual right as clean water? 
This could lead to more regulated energy markets, but where the regulatory control period is much longer. It 
could also lead to different approaches to so-called “Energy Poverty” which is a political construct that could perhaps 
be more fairly dealt with as an issue of welfare failure. The rapid pace and scale of change that achieving Net Zero 
will entail gives a perfect opportunity to revisit the entire basis for energy pricing. It is not impossible that the variety 
of responses to this may create fundamental differences in national economic competitiveness for the second half 
of the 20th Century, as well as further shifts in employment opportunities. An extreme example of the way energy 
pricing drives behaviour in the internet world is the movement in the physical location of Bitcoin mining where, 
given the huge energy costs of the technology as the number of bitcoins increases, has dominated the economics 
of the cryptocurrency for some years. The bulk of bitcoin mining now happens in China (65% at the time of writing) 
as a result of the relatively low energy costs with 35% of the total bitcoin mining happening in Xinjiang province. 
The rise in bitcoin mining malware affecting corporate systems is the other response to high energy needs – to steal 
the electricity from others.  
According to the latest NEA/IEA study on the Projected Costs of Generating Electricity – 2020 Edition, nuclear 
is the dispatchable low carbon technology with the lowest costs. Only large hydro reservoirs can provide a similar 
contribution at comparable costs but are constrained by geography. Electricity produced from nuclear long-term 
operations (LTO) is highly competitive and is not only the least cost option for low-carbon generation – when 
compared to building new power plants – but for all power generation across the board if carbon costs of USD 30 
per tonne of CO2 are taken into account for the emissions generated by coal and gas-fired power plants (IEA/NEA, 
2020).  
Energy generation costs from nuclear differ significantly between existing reactors and those being constructed 
(or planned). Figure 13 shows that existing nuclear reactors globally (Nuclear Long Term Operation or LTO) produce 
electricity cheaper than all other forms of electricity generation (IEA/NEA, 2020). This provides a benchmark which 
new nuclear should target.

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Figure 13: Electricity costs by technology   
 
Source: Adapted from IEA/NEA (2020) 
 
End-use efficiency and demand 
First, there is the modern comparison of access to energy in developed countries as being as much of a human right 
as the right of access to virtually limitless supplies of clean water.  Driving significant changes in demand through 
conventional pricing signals increasingly looks to be hard where it relies on human interaction. It currently seems 
more likely that more sophisticated “behind the meter” use of internet of things (IoT) technology and smartness 
built into some appliances may provide some route forward. However, there are still likely to be limits to this sort 
of market behaviour in developed countries for the really large energy use – heat and air conditioning.  Both are 
examples of energy use where the limits to markets for many families, other than those in more deprived 
circumstances, will be constrained and there is a material risk that behavioural economics approaches could result 
in unintended discriminatory consequences for the wrong parts of society. While a tough drive on energy efficiency 
in the design and manufacture of energy-consuming appliances will become ever more necessary, and while the 
rapidly increasing recognition of the need to hit Net Zero amongst the younger segment of society grows, there is a 
school of thought that “demand side response is a polite phrase for supply side failure”.  
There are bigger issues in end-use efficiency which will have to be taken into account in energy systems redesign. 
In many countries, a very significant amount of energy is delivered to end users – whether domestically or 
industrially – down large gas pipes. If that transportation mechanism cannot be re-purposed – e.g. by converting to 
deliver about three times the volume of hydrogen – there will have to be radical changes in the transportation of 
primary energy. In the extreme case for countries such as the UK, Japan and many in Europe where natural gas is 
currently a large vector, failure to repurpose the gas system will probably require a complete rebuild of the 
electricity distribution system. There is currently no social licence for this nor are citizens and industry remotely 
prepared for the large physical changes which would result. 
The one point which has to be borne in mind throughout the drive to Net Zero is that the biggest challenges 
will not be the need for new technology. They will be the practicalities of the necessary physical change – whether 
building new sources of low-carbon primary energy or its transportation to end users. This pace and scale of change 
which society will need to welcome – or at least tolerate – is not something for which current generations are 
prepared.

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117 
Grid resilience 
There are two major contexts in which to consider the resilience of electricity grids – overall capacity factors and 
frequency stability. 
Frequency stability is a critical issue for electrical grids – not because of the impact on timekeeping as is often 
assumed, but because of the safety consequences of even quite small but sudden shifts in frequency on end users. 
Sudden shifts in frequency can, and does, damage or destroy electrical equipment from distribution assets to electric 
motors, whether in industrial settings or in homes – such as washing machines, dishwashers and fridges. Frequency 
itself is not constant across a grid but is dependent on the relationship between supply and demand – as the demand 
approaches the limits of what’s possible to supply, frequency drops and when generating equipment or connections 
fail, the drops in frequency can be profound and damaging. To provide protection against this, grid operators have 
a variety of tools at their disposal including standby conventional generation assets, batteries and invertors for quick 
response and ultimately demand side response and load shedding (i.e. disconnection of users).  The more that 
generation suffers from intermittency, the more the grid needs additional protection against that intermittency. 
While grids have evolved to deal with a host of potential problems historically, the addition of inherently 
intermittent supply has inevitably complicated frequency stability. At lower levels of intermittent supply penetration, 
grids can and do adapt well but there comes a point where the economics of “Band-Aid” solutions becomes 
unacceptable and, at a national level, uncompetitive. As decarbonisation gathers pace, for most countries it will 
mean the replacement of much – and in some cases such as the UK and Japan – all of the primary energy production. 
At that point, anything less than a full and proper system (re)design32 will be both economically and practically sub-
optimal. The reliance on Darwinian evolutionary market-led solutions to smaller pace and scale of changes to a 
country’s electrical system is extremely unlikely to provide a good answer for most countries and states cannot 
avoid ensuring that redesign is done in the national interest.  
Capacity factors are a related issue. While sudden relatively small shifts in frequency can damage a range of 
equipment, to protect against that the ultimate measure is major curtailment of grid power which not only has a 
major impact on the lives of the customers but bringing a grid back from a major shutdown is both a complex and 
slow procedure – as the problems in Texas in February 2021 showed all too well. Amongst other challenges, part of 
what has emerged from that event was the consequences of the local energy regulator – ERCOT – in maintaining 
total independence from US Federal Standards including those of resilience. To quote the Washington Post, the 
failure of the system was “…  a financial structure for power generation that offers no incentives to power plant 
operators to prepare for winter. In the name of deregulation and free markets, critics say, Texas has created an 
electric grid that puts an emphasis on cheap prices over reliable service.” (Englund, 2021). The short-term impact of 
the collapse of the electricity system saw the wholesale price of electricity in Houston go from USD 22 a megawatt-
hour to about USD 9 000. Meanwhile, 4 million Texas households were without power and 57 deaths have been 
attributed to that failure, the majority from hypothermia. An academic commentator Edward Hirs, an energy fellow 
at the University of Houston, said the disinvestment in electricity production in Texas reminded him of the last years 
of the Soviet Union or of the oil sector today in Venezuela.  Modern societies now rely on uninterrupted supplies of 
energy whether to protect from extremes of weather as populations move to less habitable areas, or as populations 
move to mega-cities where the dependence on energy for survival increases markedly from older community 
structures in smaller towns and village.  Modern societies also rely on uninterrupted supplies of energy for an 
increasingly data-driven world. The adaptation of communities to the changed nature of work and day-to-day 
existence in response to the COVID-19 pandemic has further exaggerated dependence on the energy system. 
This again returns to the issue of the need for a proper system design for the electricity grid to ensure resilience 
for citizens and that there is proper accountability for the creation of that system design but then for its operation 
and maintenance. 
There is also, of course, those communities for whom grid connections are unfeasible and just as they have 
gone from no telecommunications straight to mobile telephony and wireless internet access, electrification for the 
first time, or the decarbonisation of existing electricity supplies will be a different challenge. Cases such as remote 
communities in Canada where local generation is currently provided by diesel generation (in some cases with fuel 
supplies actually flown in) are but one example. The drive to provide low-carbon energy to the developing world is 
also a critical challenge and, in a world where, with low cost of capital, nuclear power can be competitive with the 
 
32. See the National Engineering Policy Centre and Royal Academy of Engineering brochure: “Net Zero: A systems perspective 
on the climate challenge” at https://bit.ly/3rsMoyc.

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cost of renewable power, leadership on a global scale is essential to avoid the developing world relying on fossil 
power as their route to increasing economic prosperity. 
Nuclear power plants are a clear example of resilient facilities. The resilience of nuclear energy is the result of 
the combination of high levels of safety, operational flexibility and continuous learning from previous major events. 
By design, and beyond design, nuclear power plants are conceived following the principles of defence-in-depth: 
prevention, protection and mitigation (IAEA, 2016).33 This results in the implementation of redundant, independent 
and diversified safeguards designed to withstand external hazards. From an organizational perspective, nuclear 
facilities also incorporate emergency and contingency plans to rapidly identify critical activities and maintain normal 
operations with limited personnel. 
Confronted with major disruptions in the past, the nuclear sector has been required to adapt profoundly, while 
always continuing to provide a stable supply of low carbon electricity. Current nuclear systems and operations have 
been refined according to an evolving regulatory environment seeking the highest level of safety and reliability is 
the most diverse situations, including extreme weather events like those caused by climate change. The resulting 
nuclear governance models incorporate procedures and approaches that allow the continuous assessment of 
ongoing practices, the application of corrective measures and the integration of the latest knowledge available.  
At the system level, a resilient low-carbon infrastructure requires a balanced and diversified power mix. 
Different technologies have different complementary roles in low-carbon electricity systems. Flexible power 
provision by plants that are dispatchable upon demand makes nuclear power an indispensable complement to wind 
and solar production in countries without large amounts of hydropower capacity. Furthermore, it also supports 
electric grid stability by providing valuable inertia, reactive capacity and voltage control to the system. Additional 
operational resilience can be obtained with strategic fuel stockpiles. One of the main advantages of nuclear power 
is the easiness of securing energy-dense uranium fuel for several years of operation.  
Innovation in better products and services 
Innovation is a key enabler for prosperity. Investing in research and 
development is seen as a key indicator of a company or nation’s attempts 
to innovate. This innovation in better products and services supports: 
• 
the ability to adapt to new market conditions; 
• 
the capacity to create a long-term sustainable business model.  
• 
the possibility to create further socio-economic benefits, including the 
delivery of SDGs.   
Investing and supporting R&D can result in positive externalities known 
as spillovers, which occur when innovations and ideas flow beyond the 
organisation conducting R&D. These societal benefits can in turn lead to new innovation and wealth creation 
through increased GVA and supported jobs. Societal returns on R&D are generally estimated to be two to three 
times larger than private returns (Frontier Economics, 2014), while clean technology R&D has historically provided 
an additional 40% in social returns when compared to other conventional technologies (Rydge et al., 2018). 
Furthermore, clean innovation can play a significant role in assisting with economic regeneration. This can be seen 
in Figure 12 below (Martin et al., 2020).  
 
33. For more information on the safety of nuclear power plants and design, see the 2016 IAEA report in the IAEA Safety Standards 
series, Safety of Nuclear Power Plants: Design – Specific Safety Requirements, IAEA Safety Standards Series, No. SSR-2/1 
(Rev. 1) at www-pub.iaea.org/MTCD/Publications/PDF/Pub1715web-46541668.pdf. 
World Economic Forum 
Theme 
Sub-theme 
Innovation in 
better products 
and services 
R&D 
spending 
ratio 
 
Social value 
generated 
and vitality 
index

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
119 
Figure 12: Distribution of patenting across Great Britain 
 
Source: Martin et al. (2020) 
 
According to the IEA report, Nuclear Power in a Clean Energy System (2019), “a range of technologies, including 
nuclear power, will be needed for clean energy transitions around the world […] The biggest barrier to new nuclear 
construction is mobilising investment [...] A collapse in investment in existing and new nuclear plants in advanced 
economies would have implications for emissions, costs and energy security. Taking nuclear out of the equation 
results in higher electricity prices for consumers.” 
Nuclear R&D has decreased materially in relative terms since the 1970s as investment has become more diverse. 
The IEA estimates that 20% of the public R&D energy budget was invested in nuclear technologies in 2015, down 
from nearly 73% of the public R&D energy budget in 1975. Over the same period, investment in energy efficiency 
and renewables increased markedly, with each attracting similar shares of total energy R&D to nuclear in 2015 (WNA, 
2018).

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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Figure 14: IEA Energy R&D Expenditures  
 
Source: Adapted from WNA (2018). 
Figure 15 below shows the reducing R&D investment in nuclear, by nation. (NIRAB, 2020) 
Figure 15: Civil nuclear R&D spent by country from 1978 to 2018 
     
 
Source: Adapted from NIRAB (2020) 
The reduction in nuclear R&D is a contributory factor in why new nuclear build programme costs significantly 
exceed energy costs from existing nuclear sites (as shown in Figure 13). However, with new (i.e. advanced) nuclear 
technologies emerging, innovation across the sector is now accelerating.   
The IAEA states: 
Global interest in small and medium sized or modular reactors has been increasing due to their ability 
to meet the need for flexible power generation for a wider range of users and applications and replace 
ageing fossil fuel-fired power plants. They also display an enhanced safety performance through 
inherent and passive safety features, offer better upfront capital cost affordability and are suitable 
for cogeneration and non-electric applications. In addition, they offer options for remote regions with

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
121 
less developed infrastructures and the possibility for synergetic hybrid energy systems that combine 
nuclear and alternate energy sources, including renewables. 
Many Member States are focusing on the development of small modular reactors, which are defined 
as advanced reactors that produce electricity of up to 300 MW(e) per module. These reactors have 
advanced engineered features, are deployable either as a single or multi-module plant, and are 
designed to be built in factories and shipped to utilities for installation as demand arises. 
There are about 50 small modular reactor (SMR) designs and concepts globally. Most of them are in 
various developmental stages and some are claimed as being near-term deployable. There are 
currently four SMRs in advanced stages of construction in Argentina, China and Russia, and several 
existing and newcomer nuclear energy countries are conducting SMR research and development 
(IAEA, n.d.). 
A recent American Nuclear Society Task Force stated:  
Dozens of nuclear technology companies are designing advanced reactors that will reshape how we 
think about nuclear power. Backed by a recent and unprecedented surge of private investment in 
nuclear technologies, they recognize the market needs of a zero-carbon energy future. Some of these 
new reactor designs will eventually be licensed and constructed. What is not yet clear is whether they 
will be deployed at a scale and a pace that will rapidly impel the United States to a clean energy future. 
Commercialization is not the finish line, but it will usher in a new kind of energy system—one that can 
be served by clean, reliable nuclear energy in a range of reactor sizes and types that share the grid 
with other low carbon or carbon-free technologies. Federal investments in nuclear research and 
development are critical to lower costs and reduce the time to deployment, while building momentum 
to catalyse more private investment, more research, and more innovation. United momentum is key 
to deriving maximum benefit from nuclear technologies and securing America’s clean energy future. 
(ANS, 2021) 
Without innovation in new products and services nuclear sites above will progressively support less 
employment through the nuclear decommissioning phase. 
New build plants have a typical operational life of 60 years (excluding any potential lifetime extensions). When 
construction and decommissioning are included, a nuclear programme can support three to five generations. This 
multi-generational support drives large economic and social value with both direct and indirect local employment 
and integrated communities.  
Companies need to report on their innovation and social value creation to show that they are investing in the 
future of the company, the industry and the wider community. 
 
Community and social vitality  
These metrics consider the wider benefits of a company’s activities 
through taxes paid and social investment. It takes into 
consideration the wider payments into the wider economy. These 
are all company specific 
Total tax paid 
Total tax includes corporation tax, income taxes, property taxes, 
VAT, and other sales and payroll taxes. Reporting total tax paid 
provides global information on the company’s contribution to 
governmental revenues through different forms of taxes, which in 
turn supports governmental functions and public benefits. 
Total social investment 
This is intended to be an oversight of sustainability and ESG efforts. This metric is intended to be a more 
inclusive definition of community investment. It seeks to capture the multiple ways in which companies can 
demonstrate their investments in social activities beyond traditional charity giving.  
World Economic Forum 
Theme 
Sub-theme 
Community and 
social vitality 
Total tax paid 
 
Total social 
investment  
 
Additional tax remitted 
 
Total tax paid by 
country for significant 
locations

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Additional tax remitted 
This metric provides an ability for companies to report on additional global tax collected by the company on 
behalf of other taxpayers – for example VAT and employee’s tax. This allows companies the opportunity to report 
on their further global contributions to government revenues. 
Total tax paid by country for significant locations 
This metric allows companies to report on the total tax paid and reported, additional tax remitted by country 
for all of the company’s significant locations. Companies may choose to supplement their reporting on tax paid.  
Energy companies 
The amount of tax paid and remitted by a company will depend on the particular company and also any 
allowances permitted for areas such as R&D. The tax reporting should not differ depending on technology.

CONSISTENT AND TRANSPARENT REPORTING – NUCLEAR AND WIDER ENERGY 
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123 
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TASKFORCE OF THE ECONOMIC MODELLING WORKING GROUP  
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
129 
Appendix III. The Taskforce 
 
Chair 
Fiona Reilly, Co-chair of the GIF Economic Modelling 
Working Group (EMWG)  
FiRe Energy Ltd 
Secretariat 
Michel Berthélemy 
Nuclear Energy Agency 
 
Gina Abdelsalam 
Nuclear Energy Agency 
 
Robert Alford 
Nuclear Innovation and Research Office  
Taskforce members 
Anne Crepin 
Société de FInancement Local (SFIL) 
 
Milt Caplan 
MZ Consulting Inc. 
 
Alec Cheng 
Ontario Power Generation 
 
Chris Gadomski 
Bloomberg 
 
Arthur Hyde 
Segra Capital 
 
Emily Johnston  
Bruce Power 
 
David Kaposi  
Ontario Power Generation 
 
Craig Lester  
Department of Business, Energy and Industrial Strategy  
 
Darryl Murphy  
Aviva Investors 
 
Matthew Toolan  
Bank of Ireland 
 
Laughlan Waterston  
Sumitomo Mitsui Banking Corporation 
 
Tim Purvis  
Bruce Power

GLOSSARY 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
131 
Appendix IV. Glossary 
Term 
Definition 
Bond 
A negotiable certificate evidencing indebtedness. 
Capital markets 
The markets for medium- and long-term instruments, predominantly bonds, notes and other 
equities and commodities. 
Capital project 
A long-term project to build or develop a capital asset. 
Controlling Mind 
The nuclear licensee’s obligation to be responsible for all safety, security and safeguarding issues 
at a nuclear site.  
Credit committee 
An investor’s internal committee, whose job it is to scrutinise investments and to confer authority 
on individuals within the investor to act. 
Debt 
Capital loaned to a company on a repayable basis, and on which interest is due and payable. 
Debt equity ratio 
The ratio of debt to equity in a commercial enterprise. A measure of the financial stability of a 
company and its ability to increase its level of total borrowing. 
Development 
company 
A company, often a special purpose vehicle (see below), established to develop a capital project 
for commercial use, i.e. to sell power. It will be the owner of the asset, the procurer of the 
technology, and it is likely to be the holder of any licences and approvals, as well as the counter-
party to any off-take agreements. 
Equity 
Cash or assets given to a company in exchange for an equity interest or as part of an ongoing 
obligation, or capital commitment, to fund the entity. There is no obligation to repay the equity, 
but it usually attracts a higher rate of return. An investor would extract its equity by selling its 
shares. 
ESG 
Environmental, social and governance data collection and accounting metrics. 
EU report 
The JRC Science for Policy report, Technical Assessment of Nuclear Energy with respect to the “do 
no significant harm” criteria of Regulation (EU) 2020/852 
Export controls 
Legislation and regulation implemented by governments to control the export of materials, 
including: 
dual-use items, software and technology, goods for torture and radioactive sources 
export controls: military goods, software and technology. 
Green Bond 
Principles/ GBP 
The principles developed to enable capital raising for, and investment in, new and existing projects 
with environmental benefits. They were established by a consortium of banks and are monitored 
and developed by the International Capital Market Association. 
Generation III+ 
Generation III+ designs offer significant improvements in safety and economics over Generation 
III advanced reactor designs.  
Generation IV 
Generation IV reactors are a set of advanced nuclear reactor designs that are currently being 
developed. The Generation IV International Forum is co-ordinating research and development on 
six selected designs, which are expected to be ready for deployment by 2030. A number of private 
companies are developing Gen-IV designs. 
Gross value added/ 
GVA 
Gross value added to the economy and society by companies and projects including indirect jobs 
(employment and multipliers) and the wider benefits to the regional economy through direct and 
indirect jobs. Different governments have different definitions of GVA. 
Hybrid capital 
Capital loaned to a company, which may attract some equity benefits such as the ability to defer 
or cancel interest payments and the ability to convert to shares.

GLOSSARY 
132 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
Knowledgeable 
Customer 
A nuclear licensee is expected to have the capability, in terms of staffing and expertise within its 
own organization, to understand the safety case for all the nuclear facilities on-site and the limits 
under which it must be operated. A nuclear licensee needs to understand the safety significance 
of any work undertaken by contractors and to oversee and take responsibility for the contractor’s 
activities, including ensuring that the contractor’s staff are suitably qualified and experienced to 
carry out their nuclear safety duties. This means that major contracts that affect the safety, 
security or safeguarding of the plant, including the engineering, procurement and construction 
contract and the fuel supply agreement, must sit with the licensed entity, i.e. the licensed entity 
needs to have control of those contracts to be able to fulfil its knowledgeable customer capability. 
This is known as the intelligent customer in some jurisdictions. 
Nationally 
Determined 
Contributions/ 
NDCs  
Each countries’ commitments and targets to reduce greenhouse gas (GHG) emissions that are 
established in the nationally determined contributions (NDCs).  
OSPAR Convention 
1992 
The Convention for the Protection of the Marine Environment in the North-East Atlantic 
OSPAR Radioactive 
Substances Strategy 
The OSPAR Commission’s strategic objectives with regards to radioactive substances, to prevent 
pollution of the OSPAR marine area. 
Safeguards 
The IAEA Safeguards are a system of inspections and verifications of the peaceful use of nuclear 
materials as part of the Nuclear Non-Proliferation Treaty, supervised by the IAEA. States access 
these measures through the conclusion of Safeguards Agreements. 
Special purpose 
vehicle/ SPV 
A company established for a specific project or venture. 
The Taskforce 
The taskforce convened by the Economic Modelling Working Group of the Generation IV 
International Forum to assist with this report. The members of the taskforce are set out in 
Appendix III. 
Technology 
company 
A company with responsibility for developing a technology. This company is likely to take the 
design from a theoretical or paper design through to feasibility studies and possibly to prototype 
development. 
US report  
The US Department of Energy’s 2015 Quadrennial Technology Review: An Assessment of Energy 
Technologies and Research Opportunities.

THE GENERATION IV INTERNATIONAL FORUM 
Established in 2001, the Generation IV International Forum (GIF) was created as a co-operative 
international endeavour seeking to develop the research necessary to test the feasibility and performance 
of fourth generation nuclear systems, and to make them available for industrial deployment by 2030. The 
GIF brings together 13 countries (Argentina, Australia, Brazil, Canada, China, France, Japan, Korea, Russia, 
South Africa, Switzerland, the United Kingdom and the United States), as well as Euratom – representing 
the 28 European Union members – to co-ordinate research and development of these systems. The GIF 
has selected six reactor technologies for further research and development: the gas-cooled fast reactor 
(GFR), the lead-cooled fast reactor (LFR), the molten salt reactor (MSR), the sodium-cooled fast reactor 
(SFR), the supercritical-water-cooled reactor (SCWR) and the very-high-temperature reactor (VHTR).

GLOSSARY 
134 
NUCLEAR ENERGY: AN ESG INVESTABLE ASSET CLASS, GIF 2021 
 
 
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