TCFDCommitment
FY22CONTENTSABOUT THIS STATEMENT										3FRAMEWORK

4PROGRESS

5COMMITMENT

5LOOKING TO THE FUTURE

5GOVERNANCE

6STRATEGY7RISK MANAGEMENT

9METRICS AND TARGETS

10AIRTRUNK’S TCFD COMMITMENTFY2222ABOUT THISSTATEMENTThe TCFD Commitment is jointly madeby the following entities within theAirTrunk Group:

Air Trunk Pty Ltd, as trustee for AirTrunk
Sydney Land TrustABN 89 561 908 089

AirTrunk Holding T1 Pty Ltd, as trustee
for AirTrunk Australia Holdings TrustABN 89 469 259 695

Andante Holding Company Pty Limited,as trustee for Andante Holding TrustABN 57 334 256 317

Together, these entities are referred to as
AirTrunk (we, us, or our).
This statement is made in relation to thefinancial year commencing 1 July 2021
and ending 30 June 2022.

AIRTRUNK’S TCFD COMMITMENT
FY222

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TCFD
FRAMEWORKThe Task Force on Climate-elated Financial
The Task Force on Climate-Related Financial
Disclosures(TCFD) is anda framework
designedtoenabletransparency
standardization
acrossenabletransparency
andstandardisation
acrosscompanies in their public disclosure of climatecompanies
theirpublic disclosure of climaterelatedrisksinandopportunities.
related risks and opportunities.
TCFD recommendations are structured
TCFD recommendations
arethatstructured
aroundaroundfour thematic areas
represent
fourthematic
areas
that
representcore
core elements of how organisations operate.
elements
organisations
operate:The
areas ofarehow
governance,strategy,risk
management, and metrics and targets.

AIRTRUNK’S TCFD COMMITMENT
FY22

GOVERNANCE

STRATEGYRISKMANAGEMENTMETRICS& TARGETS

4

PROGRESSIn FY22, AirTrunk made significant progressin aligning with the TCFD recommendations
including:• establishing a governance and risk
management approach to climate change;• conducting knowledge sessions on theTCFD with senior management and otherkey stakeholders;• performing a detailed assessment ofclimate risks and opportunities; and• performing scenario analysis for priority
climate risks.
These actions highlighted the climate-relatedrisks that AirTrunk could be exposed to under
two climate scenarios:
1) A speedy net zero scenario aligned to awell-below 2-degree world (IPCC Scenario
Reference: SSP1-2.6); and2) A hot house world aligned to the worst
case for climate outcomes (IPCC Scenario
Reference: SSP5-8.5).
The scope of risks identified ranged fromtransition risks, including evolving investor andcustomer expectations, through to significant
physical climate risks on operations, suchas drought, flooding and higher averagetemperatures.
From this assessment, AirTrunk designed
strategic response measures for the identified
priority risks to:• reduce climate risk exposure toacceptable levels; and• realise strategic opportunities related
to the climate transition.

AIRTRUNK’S TCFD COMMITMENTFY22COMMITMENT
AirTrunk is publicly committing itself
as a TCFD supporter.

LOOKING TO
THE FUTURE
AirTrunk will continue to leverage theinsights from the assessment to further
embed the recommendations of the TCFD by:• conducting quarterly reviews of climaterelated risks and opportunities as partof the ERM process;• performing quantitative scenario
analysis of priority risks and theassociated financial impact;• assessing and refining climate
strategies and response measures; and• enhancing its disclosure on Scope 3
emissions including its plan to manage
these emissions.
By adopting the TCFD recommendations,
AirTrunk is enacting its important role inaddressing the risks of climate change
and acting now to mitigate transitionand physical risks.
For further information on the TCFD
disclosures, refer to AirTrunk’scompany website: www.airtrunk.com

5GOVERNANCEDISCLOSURE
RECOMMENDATION

Describe the board’s
oversight of climaterelated risks andopportunities.

ACTIONThe AirTrunk Board has ultimate responsibility for the oversight of climaterelated risks and opportunities with delegated oversight responsibilities
assigned to the EHS Construction and Risk Committee (ECRC).
The ECRC receives quarterly updates from the Head of Risk andSustainability and the Senior Risk Management Committee (SRMC)
which is comprised of AirTrunk’s Senior Management team.
These quarterly updates are focused on providing the latest emerging
risks, climate risk profile and heatmap, as well as a summary of thecontrol environment for climate risks.

Describemanagement’s rolein assessing andmanaging climaterelated risks andopportunities.

AirTrunk has appointed numerous Executives as climate risk owners.
Specific priority risks have been allocated to AirTrunk’s Chief OperatingOfficer, Chief Technology Officer, Chief Development Officer, Chief Marketing
Officer and Chief Legal Officer who hold the ultimate responsibility forexecuting responses, management of their allocated risks and reporting
progress to the SRMC.
All climate-related risks are discussed at the SRMC on a quarterly basis
and reported at Board level through to the ECRC. The following items wereapproved by the SRMC in FY22:

AIRTRUNK’S TCFD COMMITMENT
FY22•

Identification and assessment of climate risks and opportunities;•Qualitative scenario analysis across two identified scenarios; and•

Mitigation and opportunity strategies.

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STRATEGYDISCLOSURE
RECOMMENDATION

Describe the climaterelated risks andopportunities theorganisation has
identified over theshort, medium andlong term.

ACTION

AirTrunk’s priority climate-related risk and opportunity areas have been
identified as follows:
Physical Risks:•Higher average temperatures (Chronic Risk) which increase energy
demand across AirTrunk’s operations and may require new technologies.

•Increased intensity of droughts (Acute Risk) that could result inwater disruption.

Transitional Risks:•

Capital availability: Increasing climate expectations from financiers
to maintain preferential capital rates and access to new capital.

•Customer expectations: Changing customer requirements driven bycustomer’s own sustainability frameworks, investor requirements andreputational pressures.

•Stakeholder scrutiny: Civil Society (communities and climate activists)
and media scrutiny of the tech sector on a range of issues including
but not limited to energy and water use; exacerbated by energy rationing
and droughts.

•Climate litigation and regulatory shifts: Potential for new moratoria
for data centres, energy use restrictions or carbon pricing schemes.

Opportunities:

AIRTRUNK’S TCFD COMMITMENT
FY22•

Low carbon products: Differentiating AirTrunk by providing innovative
low carbon solutions.

•Renewable energy: Increasing availability of renewable energy
procurement mechanisms and supply options for AirTrunk customers.

•

Resource efficiency: Enhanced availability of technologies driving
water and energy efficiencies across AirTrunk operations.

•Green finance: Tapping into preferential green finance tosupport the achievement of AirTrunk’s decarbonisation andenergy efficiency ambitions.

7STRATEGYDISCLOSURE
RECOMMENDATION

Describe the impact ofclimate-related risks
and opportunities
on the organisation’sbusiness, strategy andfinancial planning.

ACTIONThe risks and opportunities highlighted above have the potential toimpact the AirTrunk business if left unmanaged over the long term,with the financial impact expected to increase over time.
AirTrunk’s proactive response measures to these risks will limit theextent of exposure.
In FY23, AirTrunk will conduct further quantitative analysis to evaluate
the financial impact of material climate-related risks and opportunities
if unmitigated. This analysis will help AirTrunk to further finetune ourclimate risk controls and response measures.

Describe the resilienceof the organisation’s
strategy, taking into
consideration different
climate-related
scenarios, including
a 2-degree Celsius orlower scenario.

In FY22, AirTrunk undertook scenario analysis and conducted a qualitative
assessment to understand how its climate-related risks and opportunities
may manifest under different climate scenarios.
As it was the company’s first year of scenario analysis, it was determinedthat AirTrunk would be evaluated under two recognised climate scenarios:
1) A speedy net zero scenario aligned to a well-below 2-degree world(IPCC Scenario Reference: SSP1-2.6), and2) A hot house world aligned to the worst case for climate outcomes(IPCC Scenario Reference: SSP5-8.5).
AirTrunk also considered three different time horizons for the analysis,
including the short-term (2030), medium-term (2050) and long-term (2070).
As anticipated, under the speedy net zero scenario, transition risks are
expected to be intensified. While AirTrunk sees this as a risk, it also sees
this as an opportunity for its business and financial positioning. This
scenario also highlights the importance of AirTrunk’s decarbonisation
efforts and reinforces its strategic plan to combat climate change.
Under the hot house world scenario, priority transition risks are expected
to decrease in materiality, particularly after 2030. AirTrunk is consciousof the effect of exacerbated droughts and increasing temperatures in its
regions of operation and is exploring measures to limit their effect in themedium to long-term.
During FY23, AirTrunk will be initiating a process of conducting scenario
analysis with quantitative outcomes for a selection of priority risks andopportunities.

AIRTRUNK’S TCFD COMMITMENTFY228

RISK MANAGEMENTDISCLOSURE
RECOMMENDATION

Describe theorganisation’s
processes for
identifying andassessing climaterelated risks.

ACTIONIn FY22, the AirTrunk Management team identified 30 potential climate risks
and prioritised nine. To identify and assess these risks, AirTrunk aligned withits existing enterprise risk management framework to ensure climate risks
could be easily integrated into the existing risk management processes.
To identify climate risks and opportunities, AirTrunk takes an iterative
approach, continually reviewing a variety of sources of information, including
external audits, inputs from various functions, regulatory reviews, customer
and supplier feedback, consultation with climate risk experts, and site level
analysis. These insights are taken into workshop settings with the SRMC toensure all identified climate-related risks are considered and prioritised.
Identified risks are subsequently assessed using an established evaluationmatrix across likelihood and impact, relying on quantitative criteria todiscern the appropriate rating. As climate-related risks tend to manifest
over longer time horizons, AirTrunk has paid additional attention to allocating
an expected time horizon for each risk to reach materiality. Assessed risks
are captured within its enterprise level risk register and presented to theSRMC and subsequently the ECRC for their input, review and approval.

Describe theorganisation’sprocesses for
managing climaterelated risks.

For each priority risk, a member of the SRMC is allocated as the risk owner,with responsibility to manage and monitor the risk.
For the nine priority risks, the assigned risk owners have developed
43 mitigating strategies.
These strategies will be implemented and closely monitored to ensure climaterelated risks and opportunities are effectively and adequately managed.

Describe how
processes for
identifying, assessing,and managing climaterelated risks areintegrated into theorganization’s overallrisk management.

AIRTRUNK’S TCFD COMMITMENT
FY22

By aligning AirTrunk’s risk management approach for climate-relatedrisks to its existing enterprise risk management framework, these risks
can seamlessly be integrated into the company’s overall existing risk
management process.
In addition, AirTrunk has assessed the full spectrum of existing enterpriselevel risks to understand if they may have a climate-related dimension thatoverlaps with identified climate risks, and whether these risks could bemerged; or if identified, climate risks can be added to the risk register as
discrete climate-related risks.

9METRICS AND TARGETSDISCLOSURE
RECOMMENDATION

Disclose the metrics
used by the organization
to assess climaterelated risks andopportunities in linewith its strategy andrisk management
process.

ACTIONFor each prioritised risks and opportunities, a set of key risk indicators (KRIs)
is established to ensure AirTrunk appropriately monitors its exposure and isable trigger more intensified action in response.
Examples of KRIs include:• Tracking of climate events in its areas of operation and the associatedimpact on business operations.
• Monitoring temperature increases and the associated effect onenergy consumption.
• Tracking of developments in climate legislation in its territoriesof operation.
• Keeping abreast of shareholder and customer climate targets
and ambitions.

Disclose Scope 1, Scope2, and if appropriate,
Scope 3 greenhousegas (GHG) emissions,and the related risks.

GHG emissions are disclosed under the Carbon Management section in
AirTrunk’s Sustainability Report.

Describe the targets
used by the organisation
to manage climaterelated risks andopportunities andperformance againsttargets.

AirTrunk’s key climate-related targets include:••••

AIRTRUNK’S TCFD COMMITMENTFY22Renewable Energy target: To provide renewable energy sourcing options
to all AirTrunk customers through direct contracting.
Emissions Targets: In FY22, AirTrunk announced its Net Zero by2030 targets aligned with the Paris Agreement. Refer to the Carbon
Management section in AirTrunk’s Sustainability Report for more
information.
PUE: The single most important metric for managing energy is Power
Usage Effectiveness (PUE) which is widely adopted in the data centre
industry. Specifically, AirTrunk optimises, measures, and continuously
improves on annual average operating PUE as a key metric. Refer tothe Energy Management section in AirTrunk’s Sustainability Reportfor more information
Action plan for TCFD implementation: This includes the achievementof the following actions in FY23:– Quarterly reviews of climate-related risks and opportunities as partof the ERM process;– Quantitative scenario analysis of priority risks and the associatedfinancial impact;– Assess and refine climate strategies and response measures;– Enhance disclosure on Scope 3 emissions and further manage
these emissions.

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