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.

Processes to identify and assess material impacts, risks, and opportunities include screening of assets as part of our DMA to understand impacts, risks, and opportunities across the value chain. We have not undertaken direct consultations with affected communities as part of the screening. We apply life cycle assessments (LCAs) for enhanced insights into impacts related to the use and depletion of virgin materials. We have calculated the recyclability rate of materials in offshore wind farms to understand recycling potential.

Policies related to resource use and circular economy include a 'Resource management policy' to minimize the use and depletion of virgin resources by developing circular value chains with suppliers. A 'Waste management policy' addresses negative impacts of materials wasted, outlining waste management processes and providing definitions for waste management assurance.

Key actions related to resource inflows involve a quantitative breakdown of key materials used in renewable energy assets, engaging with key suppliers on decarbonisation matters, and sourcing more scrap steel to increase lower-emissions steel usage.

Key actions related to resource outflows focus on addressing waste generation during construction, operation, and decommissioning by designing assets with minimal reliance on specific materials and ensuring waste is diverted from disposal by enhancing sorting and collection processes. Transition pieces for offshore wind farms are made from recyclable materials to increase recyclability rates.