Methodologies

Health, safety and wellbeing

Employee: A person working directly for, and paid directly by, the business. Full-time employees include all people with a contract of employment to work the hours of a standard working week. Part-time employees include all people with a contract of employment to work for fewer hours than the standard working week.

Contractor: An independent person who works for the business and is under our control but who is employed by another company or is self-employed. A contractor or seasonal worker does not work regularly or permanently for the business. They work only as and when required. Typically, a contractor or seasonal worker will have a period of work specified in their contract, and an end date will usually be specified. As the nature of contract work varies across our businesses – for example from contract cleaning, security and catering staff to seasonal agricultural staff – our businesses are responsible for applying the Group’s definition of a contractor to their workforce. With each year of monitoring contractor safety, we see improvements in how this definition is applied with greater consistency from year to year and across the businesses.

Fatal injury: We report the death of an employee, contractor or seasonal worker as a result of work activities with the business. This includes activities in our operations, under our direct control and for people who are our responsibility, be they an employee, contractor or seasonal worker. It also includes employees and contractors travelling for work purposes (for example, engineers visiting factory sites or travelling to attend a training course). Deaths that occur during an individual’s commute to or from work are not included unless the national legislation stipulates this as a work-related fatality. Deaths from natural causes, such as heart attacks and deaths from non-work activities, are not included.

Safety data: For Group safety data, we include Associated British Foods plc central employees based in our head offices as part of our total headcount.

Lost Time Injury (LTI): An injury that arises out of, or in connection with, work activities, which occurred on-site and results in the injured employee or contractor being absent from work for at least one day or one shift within 12 months of the accident. When we report the percentage of sites without an LTI during the year, we include the number of factories providing employee numbers and production figures and, in the case of Primark, the number of stores and distribution centres.

Lost Time Injury (LTI) rate: The LTI rate is the percentage of employees (full-time equivalent) or contractors having an LTI during the year.

Methodologies

Employee: a person working directly for, and paid directly by, the business, including directly employed contractors. Full-time employees include all people with a contract of employment to work the hours of a standard working week. Part-time employees include all people with a contract of employment to work for fewer hours than the standard working week.

Women: within local legislation these are those that are defined, or define themselves, as female or women.

Men: within local legislation these are those that are defined, or define themselves, as male or men, or those that are defined, or define themselves as non-binary/other gender or the individuals prefer not to say. This also includes where there is a legislative requirement not to hold such classification of employees.

Other: within local legislation there are those that are defined, or define themselves as non-binary/other gender or the individuals prefer not to say. Also includes where there is a legislative requirement not to hold such classification of employees.

Average number of employees: the average number of employees as defined above for each pay period in the year divided by the number of pay periods in the financial year.

Average number of men and women in the workforce: the average number of men and women employed for the financial year is calculated on the same basis as the average number of employees as a whole, as set out above.

Average number of men and women in management roles: the average number of men and women in management roles employed for the financial year is calculated on the same basis as the average number of employees as a whole, as set out above. A management role is defined as a role that has one or more direct reports and where the individual has management responsibilities.

Senior management role: a role which has one or more direct reports and in which the individual has management responsibilities, as well as within a minimum reporting line of the Group or divisional chief executives.

Gender pay gap

Consistent with previous years, we have chosen to report voluntarily on the gender pay gap that relates to our employee population in Great Britain (GB) as of 5 April 2026. However, more than half of our workforce is employed outside GB and therefore not included in this gender pay analysis. Consistent with last year we have presented data for the Group businesses in GB as a whole and for the Group businesses in GB without Primark.

Methodologies

Reporting our GHG emissions

We follow the GHG Protocol Corporate Accounting and Reporting Standard using a financial control approach. We report our GHG emissions in kilotonnes of carbon dioxide equivalent (ktCO2e).

We have developed detailed reporting guidance including estimation and calculation methodologies and assumptions based on the GHG Protocol. This reporting guidance is issued to the businesses each year. Emissions have been calculated using carbon conversion factors published by the UK Government in June 2025, other internationally recognised sources and bespoke factors based on laboratory calculations at selected locations.

Under the GHG Protocol, GHG emissions are categorized into three scopes, as outlined below. For transparency and to provide a holistic view of our carbon footprint, we also report our biogenic carbon dioxide emissions, which originate from biological sources as plant-based materials and are part of the natural carbon-cycle. Within our operations, biogenic carbon emissions are primarily from the combustion or fermentation of biomass / biofuels on our sites.

Scope 1 emissions are direct emissions from our own operations and include those from:

• the use of non-renewable fuels such as natural gas and coal in boilers and dryers, as well as fugitive emissions;
• our manufacturing processes such as the fermentation process to make bioethanol, bread baking, the management of on-site wastewater and from electrical equipment;
• directly controlled agricultural activities including growing sugar beet and sugarcane, other crop production and CO2 emitted from horticulture; and
• owned transport.

Scope 2 emissions are from purchased electricity, heat or steam used on our sites. Scope 2 emissions are reported on both a location and market-based approach in line with the GHG Protocol Scope 2 Guidance. Scope 2 location-based emissions reflect the average emissions intensity of grids from which our energy consumption occurs. Scope 2 market-based emissions are calculated using the emissions from the electricity that our businesses have purchased. Purchased renewable electricity, which is supported by appropriate evidence from the energy provider (i.e. renewable energy certificates, Guarantees of Origin or similar), and that meets the ‘quality criteria’ outlined in the GHG Protocol Scope 2 Guidance, is converted to CO2e by applying supplier-specific emission factors. Where supplier-provided emission factors are not available, we have applied the specific residual mix factor. Where the residual mix factor is not available, we revert to the location-based grid average emission factor.

We have reported Scope 2 GHG emissions on a market-based basis since 2021. Unless otherwise stated, Scope 2 GHG emissions are therefore market-based. For reporting against targets with baselines set before 2021, those baselines are location-based, which are generally more conservative as they reflect average grid emission factors. Comparisons therefore reflect location-based baseline data versus market-based current data.

Primark’s Scope 3 GHG emissions

Primark completed a Scope 3 inventory for 2025/26, which was assured by EY. Only the following categories are included in Primark’s Scope 3 emissions data as per the screening process. Unless otherwise stated, the UK Government’s GHG Conversion Factors for Company Reporting (DEFRA) 2026 factors were applied.

Category 1 – Purchased goods and services. Emissions factors derived from supplier primary data (captured from the Higg FEM and Trustrace) were used alongside DEFRA 2012, DEFRA 2014, DEFRA 2026, Sphera MLC DB 2023.2, NAICS-6 SupplyChainGHGEF and were supplemented by custom emission factors based on averages for the type of activity (derived from The Higg Materials Sustainability Index versions 3.10 and 3.12).

Category 2 – Capital goods (NAICS-6 SupplyChainGHGEF).

Category 3 – Fuel and energy-related activities (DEFRA 2020, DEFRA 2026, Sphera MLC DB 2023.2 and Sphera Solutions GmbH 2019).

Category 4 – Upstream transportation and distribution. Emissions from Primark’s upstream transportation and distribution activities include the well-to-tank lifecycle emissions (DEFRA 2023, DEFRA 2026 and Clean Cargo 2025).

Category 5 – Waste generated in operations (DEFRA 2026 and Sphera MLC DB 2023.2).

Category 6 – Business travel (DEFRA 2026).

Category 7 – Employee commuting (DEFRA 2026).

Category 9 – Downstream transportation and distribution Emissions from Primark’s upstream transportation and distribution activities include the well-to-tank lifecycle emissions (DEFRA 2026 and Clean Cargo 2025).

Category 11 – Use of sold products (ECOSI 2018).

Category 12 – End-of-life treatment of sold products (DEFRA 2020, DEFRA 2026 and WRAP 2012).

Category 13 – Downstream leased assets (DEFRA 2026 and UK Government Non-domestic need data framework 2022).

Category 14 – Franchises (DEFRA 2026 and IEA 2026).

Methodologies

Energy used: Energy data is reported in line with our greenhouse gas (GHG) reporting scope. The total energy used includes energy from electricity, natural gas, gas oil, coal, diesel, coke, anthracite, petrol, kerosene, heavy fuel oil, liquefied petroleum gas (LPG), imported steam and renewable sources. The total is displayed as gigawatt hours (GWh) with a split between energy consumed from non-renewable and renewable sources. Energy consumption is calculated using country-specific conversion factors from physical quantities to kWh to provide an accurate representation of our energy consumption.

Energy used from renewable sources: This includes energy that is generated on-site from renewable fuels which includes bagasse and its residue, biogas and wood; energy generated from non-fuel renewable sources on-site including solar and purchased electricity and steam supported by evidence of renewable source. The total is displayed as gigawatt hours (GWh). From 2022, we include purchased electricity and steam from a renewable source in the total figure. The emissions from our on-site generated energy from renewable sources are captured in our Scope 1 GHG emissions.

Energy exported: The total energy exported includes electricity and biogas generated on our sites and is usually sold to the national distribution network or grid, sold to tenants or sold directly to another organisation.

Exported electricity is generated in the main from bagasse, the renewable plant-based fibrous residue that remains after the extraction of juice from the crushed stalks of sugarcane. Biogas is generated from on-site wastewater treatment or anaerobic digestion of waste.