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All our businesses operate within a clear governance framework defined by the Group. Our devolved business model gives our businesses autonomy to assess and manage their own ESG impacts, risks and opportunities within this framework.
We adapt our governance process as required to cover all relevant ESG issues, including climate-related matters.
The ABF Board (the Board) has oversight and overall responsibility for ESG across the Group, including climate-related matters. The Board holds our businesses accountable for their assessment and management of ESG impacts, risks and opportunities, which includes an annual review of material ESG matters. The Chief Executive and Finance Director have responsibility for assessing and managing material ESG matters across the Group, including climate-related matters, and reporting this to the Board.
In carrying out its duties the Board is also supported by:
The Finance Transformation team, which is part of the Group Finance team, oversees and collates all non-financial data used for Group reporting, collaborating closely with the CR Hub to ensure timely and accurate reporting. It coordinates with other finance teams within the businesses across the Group to ensure robust and consistent data collection aligned with assurance requirements. Additionally, dedicated teams covering specific areas such as DEI, health, safety, environment and procurement ensure the businesses have a comprehensive level of support across ESG matters.
The Board receives regular updates each year on material ESG matters, including climate-related matters from a variety of sources including senior management and internal reporting. In 2025 these included updates on the following:
Since 2022, we have included strategic ESG KPIs in our short-term incentive plan (STIP) for executive directors. We report to the Remuneration Committee on progress against these KPIs three times each year. The measures applied in 2025, and how we assessed progress against them, are disclosed in the Directors’ Remuneration Report on our Annual Report.
Our ESG Policy and Reporting Group is a central, cross-functional group that meets regularly and is responsible for overseeing the ESG reporting strategy, allocating central resource, prioritising activities, and reviewing Group ESG reporting or policy as needed. It sits at the ABF Group level and includes representatives from Finance, ESG Legal, Risk, CR Hub and People and Performance, supported by subject matter experts (SMEs) as required.
In 2025, we have further strengthened our governance of ESG matters through introducing quarterly ESG Update Meetings with the Chief Executive and Finance Director. These meetings are run by the Group Corporate Responsibility Director and include senior leadership members from the Finance, Legal, People and Performance and Business Performance teams. The meetings cover monitoring progress against material Group ESG topics, receiving regular updates on priorities, and horizon scanning, as well as providing a route for escalation where required on any material topics.
Under ABF’s devolved structure, each of our businesses is required to understand its material ESG impacts, risks and opportunities, and is given the responsibility as well as the independence to put in place the necessary measures and policies that it believes will effectively manage such matters.
In addition to individual business leaders, divisional chief executives are accountable for their businesses taking the appropriate action in relation to ESG risks, opportunities and impacts, including assessing, managing and mitigating the impact of climate change on their businesses.
Across most of our divisions, ESG measures are part of the personal objectives of the divisional chief executives, with appropriate KPIs in place to reflect the nature of their business. In addition, for the last two financial years, all Primark directors have had ESG measures for a significant part of their short-term incentive performance targets.
Divisional management presents quarterly to the Chief Executive and Finance Director on business performance including relevant material ESG issues and, where appropriate, on significant climate-related matters. They also have other regular touch points with the Chief Executive where these matters are also discussed as needed. Additionally, the businesses periodically present material ESG matters to the Board.
The identification, assessment and management of ESG risks and opportunities resides within the business where the risk or opportunity sits. This is the same process for all other business risks. Annually, risks are collated and reviewed at individual business and divisional level and then reviewed also at Group level. Where risks or opportunities are not deemed material for the Group, the businesses incorporate these into their risk registers and their wider ESG strategies as appropriate.
The Board is accountable for overall risk management, which includes agreeing the principal risks facing the Group, both existing and emerging, and ensuring these are effectively managed by the businesses. Further details on risk management can be found in our Annual Report.
We recognise that climate change presents a material risk throughout our businesses’ operations and supply chains, resulting in challenges as well as opportunities for our businesses. While each business is responsible for identifying and managing its climate risks, we also undertake certain risk assessments at Group level, which include climate risk. Individual businesses may also include climate-related matters in their regular updates to the Board. Divisional chief executives are responsible for managing and mitigating the impacts of climate change on their divisions.
Our Task Force on Climate-related Financial Disclosures (TCFD) reporting is overseen by a cross-functional steering committee, which briefs the Board and the Audit Committee. As part of the 2025 disclosure, we have included a summary of the transition plans for the Primark, ABF Sugar and Twinings Ovaltine businesses, our most significant contributors to Scope 1 and 2 GHG emissions and adjusted operating profit. For more information on our TCFD reporting, see our Annual Report.
We maintain and keep under review a series of Group-level policies and position statements. Ranging from Health, Safety and Wellbeing, Environment, Animal Health and Welfare, and Board Diversity (which also applies to the Group approach to DEI) to our Supplier Code of Conduct, our policies and position statements articulate the Group’s requirements and set expectations for the actions of our businesses, employees, suppliers and partners.
It is the responsibility of the chief executive of each business to ensure that their business is compliant with relevant legislation and Group policies.
Our Group policies, position statements and Supplier Code of Conduct can be accessed online.
Our approach to governance is to respect not simply the letter, but also the spirit, of our Anti-Bribery and Corruption Policy and always act with integrity. All of our businesses are responsible for their compliance with our policies and procedures. To ensure effective implementation each business has its own designated Anti-Bribery and Corruption Officer, and we have monitoring systems in place at various levels within the Group, including global risk assessments. In addition, all relevant employees are required to complete an e-learning course on the subject when they join the Group and at regular intervals thereafter, and those who work in higher-risk roles are required to attend regular face-to-face training.
Our approach to the recently introduced failure to prevent fraud offence in the UK has involved conducting ongoing risk assessments across the Group and building on our existing Anti-Bribery and Corruption Policy and processes, including the Anti-Bribery and Corruption training and due diligence processes.
A copy of the policy is available online.
We are committed to always acting with integrity. We proudly promote and protect a culture of trust, fairness and accountability.
Our Speak Up Policy empowers our people to raise a grievance or tell us whenever they encounter anything inappropriate, improper, dishonest, illegal or dangerous, including fraud, and ensures that their concerns will be handled confidentially and professionally. Speak Up includes both a telephone line and a web reporting platform, managed by an independent provider.
We encourage all individuals working for the Group in any of our businesses, in any country and in any capacity, to use Speak Up, including employees at all levels, directors, officers, part-time and fixed-term workers, casual and agency workers, seconded workers and volunteers.
Speak Up also enables issues to be raised by third parties that are, will be, or have been associated with our Group.
In the year to 30 June 2025, 434 notifications were received, of which:
A copy of the ABF Speak Up Policy is available online.