As an example of the supplier engagement programme development, we initiated a collaboration with wind turbine manufacturer Siemens Gamesa to use recycled glass fibres for certain new wind turbine blades at our Greater Changhua 2b and 4 offshore wind farms in Taiwan. The intended outcome of our supplier engagement and procurement strategy is to have a firm set of circularity-related supplier requirements in place within the next four to five years. For selected components, recycled materials have already been introduced as a sourcing evaluation criterion, ensuring our gradual transition away from the use of virgin resources.

To govern the identified risk and negative value chain impact from using virgin materials, we have adopted a ‘Resource management policy’, covering all of our activities and locations. The policy’s objective is to ensure that we minimise the use and depletion of virgin resources by developing circular value chains together with our suppliers, where feasible, and guide our efforts on sustainable sourcing. It further addresses our adherence to the waste hierarchy, prioritising waste avoidance by reducing and reusing before recycling.

To address our negative impact of materials wasted, we have a ‘Waste management policy’, covering all our activities and locations. The policy outlines our waste management processes and provides detailed definitions of key aspects of waste management assurance. Our QHSE department is responsible for its ongoing implementation. As the policy is the steering document for our internal way of working with waste and thus contains detailed guidance on waste handling and data reporting for our global waste operations, the policy is only accessible internally.

In 2024, we have progressed on this action by ordering more than 300 refurbished yaw brake calipers on our East and West Coast hubs in the UK. Calipers are used to hold the nacelle in place when the brakes are applied and are a part of the hydraulic system. For each caliper we reuse, we also lower the cost of our wind farm maintenance. In addition, we have set up refurbishment loops for several other minor components with a long leadtime to reduce the risk of lost production.

We have identified key materials fundamental to the construction of our global portfolio of renewable energy projects across offshore and onshore wind, solar, and battery energy storage systems (BESS). To enhance our understanding and management of resource inflows, we are actively working with suppliers to explore lower-emissions alternatives and aim to establish closer collaboration for obtaining data on the composition of their products, including the percentage of reused or recycled materials. Steel is a primary focus at this stage, given its significant role in renewable energy infrastructure and its high potential for recyclability. The use of scrap steel is a norm in steel production, with its content varying across geographies and reflecting established industry practices. Approximately 80% of the steel we source used in the production of steel plates for foundations comes from Europe, where supplier data indicates that, on average, 35% of the material used in these plates derive from scrap. While we account for geographic variability in our presentation, reflected in a range of 20 - 35%, our current estimates place us at the upper end. Lower-emissions steel offers a dual benefit: It minimises greenhouse gas emissions and, depending on the production method, can reduce reliance on virgin iron ore. Steel produced via electric arc furnaces (EAFs), which use scrap steel as feedstock, significantly lowers the need for virgin iron ore compared to traditional blast furnace-basic oxygen furnace (BF-BOF) methods that rely heavily on it. Even though recycled content is widely used in steel production, low-emissions steel still has a limited market availability. Closing this gap is key to cutting emissions, reducing reliance on virgin materials, and advancing a more circular steel industry. Thus, our focus is on sourcing lower-emissions steel, as it represents the most impactful opportunity to drive meaningful progress in reducing the environmental footprint of steel production. In addition to steel, critical raw materials, such as copper, aluminium, and rare earth elements (REEs), are essential for renewable energy technologies but present negative impacts and risks related to the depletion of virgin materials and the scarcity of supply. Improving the recyclability of materials such as plastics and glass fibres, including composites used in wind turbine blades, is a priority to reduce reliance on finite resources and ensure sustainable materials.

We engage with our key suppliers on decarbonisation matters as part of our supplier engagement and procurement strategy. In 2024, we have extended these engagements to also include resource use and circularity matters. These two topics naturally overlap as we are looking for opportunities to, for example, source more scrap steel as a means of increasing our usage of lower-emissions steel. As our negative impact occurs outside our own operations, we are dependent on continuous collaboration to make meaningful progress that will mitigate both the material negative impact as well as the risk related to our reliance on virgin scarce resources, when constructing our renewable energy assets. As an example of the supplier engagement programme development, we initiated a collaboration with wind turbine manufacturer Siemens Gamesa to use recycled glass fibres for certain new wind turbine blades at our Greater Changhua 2b and 4 offshore wind farms in Taiwan. The intended outcome of our supplier engagement and procurement strategy is to have a firm set of circularity-related supplier requirements in place within the next four to five years. For selected components, recycled materials have already been introduced as a sourcing evaluation criterion, ensuring our gradual transition away from the use of virgin resources.

In alignment with our resource management policy objective, we continuously work to reduce, reuse, and recycle resources for our assets. As we have a large portfolio of offshore wind farms in operation, our ability to increase the reuse and refurbishment of spare parts during the lifetime of the assets can both lower our use of virgin materials, extend the lifetime of the assets, and reduce our operational costs. In 2024, we have progressed on this action by ordering more than 300 refurbished yaw brake calipers on our East and West Coast hubs in the UK. Calipers are used to hold the nacelle in place when the brakes are applied and are a part of the hydraulic system. For each caliper we reuse, we also lower the cost of our wind farm maintenance. In addition, we have set up refurbishment loops for several other minor components with a long leadtime to reduce the risk of lost production. By 2030, we intend to establish fully commercial, technically approved refurbishment loops for more than 100 of our key minor components, reducing our overall need for virgin materials during the operational phase of our renewable assets. This is further a mitigation measure towards our identified risk related to the global increase in demand for various scarce critical materials.

In 2024, we completed the decommissioning of our onshore wind farm Owenreagh 1 in Northern Ireland, which had been in operation since 1997 and consisted of 10 wind turbines with a total capacity of 5 MW. We did so in collaboration with Plaswire, with whom we entered into a partnership in 2023. Plaswire enables the recycling of wind blades, as they specialise in the shredding, granulating, and re-moulding required to turn the blade material into, for example, durable polymer. Durable polymer is typically used in the construction industry, and as a result, some of the retired blades may end up being used to produce road marking poles for some of our new onshore wind farms in Ireland, replacing the use of virgin plastics in our own projects. Similarly, we work with the US solar recycling company SOLARCYCLE on the treatment of defective and retired solar panels. With the installation of various solar assets in the US in 2024, we have, where necessary, sent damaged panels to SOLARCYCLE for recycling, demonstrating our ambition to recycle retired solar panels. Our collaborations with Plaswire and SOLARCYCLE are examples of how we engage with partners on our material resource-related impacts. Over the past few years, we have successfully carried out several small-scale recycling pilots in the US and the UK and will continue to leverage retired blades and panels from our assets to help accelerate the maturation of promising, innovative, recycling technologies and solutions in our markets going forward.

The materials wasted during construction, operation, and decommissioning constitutes a negative impact. In general, we see two complementary pathways to address waste generation that we must work on simultaneously. Firstly, we must consider if our waste generation can be avoided in the first place, by addressing the challenges at their root cause. This is done as we work to design our assets with minimal reliance on the use of a specific material, for example by switching non-recyclable content with more recyclable content to allow for proper waste treatment. At the same time, we need to ensure that waste is diverted from disposal by enhancing sorting and collection processes as well as supporting the maturation of reuse and recycling markets for our components and materials.

To address our negative impact of materials wasted, we have a 'Waste management policy', covering all our activities and locations. The policy outlines our waste management processes and provides detailed definitions of key aspects of waste management assurance. Our QHSE department is responsible for its ongoing implementation. As the policy is the steering document for our internal way of working with waste and thus contains detailed guidance on waste handling and data reporting for our global waste operations, the policy is only accessible internally.