Risk Management 23-24

Climate‑related risks are identified, assessed and monitored in accordance with the AMP's Risk Management Framework (RMF) which includes the Risk Management Strategy (RMS) and Risk Appetite Statement (RAS) that guide consistent risk oversight across the organisation.

Risk identification and assessment processes

Climate change as a top risk

Climate change is identified as one of QBE's top risks: The physical and transition risks associated with climate change, resulting in potential impacts on QBE's operating environment, underwriting or investment activities, or impacts associated with failing to meet regulatory requirements or our own commitments.

Top risk process

QBE's top risk process is designed to ensure that the most significant threats to the Group's strategic objectives are identified, assessed, and managed proactively. Assessing QBE's top risks occurs at least annually and more regularly when there are material changes in the risk profile. This profile is informed by a combination of divisional risk assessments and external perspectives, including insights from global industry reports and regulatory developments. Risks are prioritised using QBE's standardised criteria for assessment of likelihood and impact, with trends monitored to capture changes in the risk landscape.

Climate risk assessment methods

These risks are continually assessed through catastrophe modelling and underwriting analysis, which inform the Group's underwriting and reinsurance strategy, as well as the calibration of the catastrophe allowance within the business plan.

Risk governance framework

QBE's Risk Management Strategy (RMS) enables the achievement of QBE's strategic agenda and business objectives by articulating the fundamental principles for managing risk, which apply to all levels of the organisation. We undertake ongoing monitoring of the effectiveness of the RMS and an annual audit review to assess compliance and effectiveness. QBE's Enterprise Risk Management (ERM) Framework is part of the RMS. It describes our approach to managing risk effectively and supports our strategy and fundamental principles.

Processes for Identifying and Assessing Climate-Related Risks and Opportunities

Risk Management Framework: At Santos, we refer to enterprise risks as those risks which could materially impact the Company's ability to achieve its Purpose, Vision and Strategy. Climate-related risks are integrated into this framework.

Materiality Assessment Process: We have matured our materiality process, building on a four-step process based on GRI methodology:

1. Understanding Santos Context: Analysis of activities across the value chain and current business relationships, including climate-related impacts

2. Identifying Actual and Potential Impacts: Review with internal stakeholders, subject matter experts and business functions to update assessment of material topics including climate change

3. Assessing Significance of Impacts: Application of Santos Risk Management Framework to assess severity, likelihood, scale, scope and potential consequence of climate impacts

4. Prioritising Most Significant Impacts: Grouping assessed impacts according to GRI and SASB standards under sustainability pillars

External Stakeholder Engagement: In 2025, Santos conducted interviews with 10 diverse stakeholder groups and held 110 ESG-focused investor meetings to understand climate-related risks and opportunities from external perspectives.

Enterprise Risk Integration: The Company enterprise risk register is a key input when assessing external risks related to longer-term impact on value creation, including climate-related risks.

Continuous Monitoring: Regular review and update of climate risk assessments through the Santos Management System and Safety and Sustainability Committee oversight.

Assessing climate-related risks and opportunities

Our assessment relies on both quantitative and qualitative factors to identify and assess material climate-related risks and opportunities and their potential impacts on our business model and value chain.

Our assessment draws on climate scenario analysis, our Enterprise Risk Management framework and governance processes, as well as inputs from internal and external subject matter experts. Through this work we continue to identify, assess, prioritise and monitor climate-related risks and opportunities.

Through our assessment, we identified the following as material climate related risk and opportunities for our business: • Transition risk (policy / legal) – Exposure to climate related government regulations that impose an additional cost of carbon. • Transition risk (market / technology) – The demand destruction of traditional fuels driven by the technological advancements (electrification of the transport fleet and improved fuel efficiency) and consumer preferences. • Transition opportunities (market / technology) – Increased demand for low emission or alternative fuels such as biodiesel, renewable diesel and sustainable aviation fuel (SAF), as well as EV charging infrastructure, are opportunities to retain and diversify revenue sources.

We maintain ongoing oversight of a broad range of climate-related risks and opportunities. While many of these are not currently assessed as material, we anticipate that additional climate-related risks (including physical climate risks) and climate-related opportunities may emerge over time as internal priorities and external operating conditions evolve.

We assess the materiality of climate‑related risks and opportunities considering both their likelihood and potential financial impact. This involves a mix of qualitative and quantitative analysis, supported by judgement and assumptions that we update each reporting period to reflect the best available information.

To identify and assess the climate-related risks and opportunities that could reasonably be expected to affect the Group's prospects, and to determine material information for disclosure, judgement was applied in evaluating impacts and dependencies across the Group's business model and value chain that could reasonably be expected to affect the Group's strategy, business model, or financial position and performance.

The Sustainability team is responsible for the continual update of the Company's climate-related risk and opportunity register, with input from subject matter experts throughout the business. Additional oversight of the register is facilitated by the CEO, Chief Financial Officer (CFO), and the Chief Strategy Officer.