
§ Accounting policies
Taxonomy-eligible activities
We have identified our taxonomy-eligible
activities by screening the economic activi-
ties in the Climate Delegated Act (Commis-
sion Delegated Regulation (EU) 2021/2139),
the Complementary Climate Delegated
Act (Commission Delegated Regulation (EU)
2022/1214), the Environmental Delegated
Act (Commission Delegated Regulation
(EU) 2023/2486), and the amendments to
the Climate Delegated Act (Commission
Delegated Regulation (EU) 2023/2485).
Six activities in the delegated acts have been
identified as eligible for Ørsted:
· Manufacture of hydrogen (3.10).
· Electricity generation using solar
PV technology (4.1).
· Electricity generation from wind
power (4.3).
· Storage of electricity (4.10).
· Cogeneration of heat/cool and power
from bioenergy (4.20).
· High-efficiency cogeneration of heat and
power from fossil gaseous fuels (4.30).
Taxonomy-aligned activities
Regulation (EU) 2020/852, article 3, sets out
criteria which an economic activity must meet
to qualify as environmentally sustainable
(taxonomy-aligned):
· Comply with technical screening criteria
(TSC) for substantially contributing to one or
more of the six environmental objectives.
· Comply with TSC for doing no significant
harm (DNSH) to the other five environmental
objectives.
· Comply with minimum safeguards covering
social and governance standards.
Taxonomy alignment of our eligible activities
has subsequently been assessed against
annex I of the Climate Delegated Act. The
TSC for the environmental objectives have
been assessed per activity. Minimum safe-
guards have been assessed on Group level.
However, we have not assessed our gas-based
heat and power generation activities (4.30) for
taxonomy-alignment.
Substantial contribution
Climate change mitigation
We have assessed and documented whether
our taxonomy-eligible activities (3.10, 4.1, 4.3,
4.10, and 4.20) fulfil the substantial contribu-
tion criteria to climate change mitigation.
For activity 3.10, the future manufacturing
process of hydrogen was calculated to meet
the life cycle greenhouse gas (GHG) emis-
sion savings requirement in article 25(2) and
annex V to Directive (EU) 2018/2001. The
calculation of life cycle GHG emission savings
follows the methodology referred to in article
28(5) of Directive (EU) 2018/2001, and the
quanti fication methodology has been verified
by an independent third party. The quantified
life cycle GHG emission savings are subject
to final verification by an independent third
party upon an asset’s operation.
For activities 4.1, 4.3, and 4.10, our solar and
wind farms and our storage facilities auto-
matically fulfil the substantial contribution
criteria to climate change mitigation as we
generate electricity using solar PV technology
and wind power, and as we construct and
operate electricity storage facilities.
For activity 4.20, the sustainable biomass
used at our combined heat and power (CHP)
plants complies with the criteria in article 29,
paragraphs 2-7, of Directive (EU) 2018/2001
and with the GHG emission savings criteria.
Climate change adaptation
We have not assessed our taxonomy-eligible
activities against the substantial contribu-
tion criteria for climate change adaptation,
as the primary objective of our activities is to
contribute to climate change mitigation.
Do no significant harm (DNSH)
Climate change adaptation
We have assessed and documented how
asset resilience towards different chronic
and extreme climate hazards and their future
development, as projected by IPCC, is an
integrated part of our project development
and have confirmed that our assets are
resilient and able to withstand projected
climate changes during the assets’ lifetimes.
It is assessed that all relevant eligible
activities comply with the criteria set out
in appendix A to annex I of the Climate
Delegated Act.
Sustainable use and protection of water and
marine resources
We are legally required to conduct environ-
mental impact assessments (EIAs) as part
of all our projects to ensure that potential
impacts on water and marine resources are
avoided, mitigated, and addressed appro-
priately. During this process, we consider
environmental degradation risks related to
preserving water quality and avoiding water
stress. We have internal processes on legal
compliance concerning water to ensure all
assets live up to the requirements. In addi-
tion, we have a water policy, establishing our
approach to responsible water management.
For activity 4.3, we work to ensure that
construction of offshore wind does not
hamper the achievement of good environmen-
tal status as set out in Directive 2008/56/EC,
taking measures to prevent or mitigate impacts
in relation to the directive’s descriptor 11
(noise/energy).
It is assessed that all relevant eligible
activities comply with the criteria set out
in appendix B to annex I of the Climate
Delegated Act.
Transition to a circular economy
Renewable assets are built of highly durable
materials. To ensure reuse and recycling of
materials where feasible, we have a resource
management policy and internal waste
management processes in place. To ensure
we further transition to a circular economy,
we have implemented a strategic approach
focused on: (i) using fewer virgin resources,
(ii) using resources better and longer, and (iii)
recirculating resources upon end of life. For all
projects, we will develop decommissioning or
waste management plans to ensure maximal
reuse or recycling at end-of-life in accordance
with the waste hierarchy.
Pollution prevention and control
We are legally required to conduct EIAs
to ensure that potential pollution impacts
are avoided, mitigated, and addressed
appropriately, and that pollution requirements
are integrated into our environmental permit
conditions. We have internal processes in
place to fulfil these legal requirements.
For activities 3.10 and 4.20, it has been
assessed that emissions are within or lower
than the emission levels associated with the
best-available-techniques (BAT-AEL) ranges
set out in relevant best-available-techniques
(BAT) conclusions. No significant cross-media
effects have been identified.
It is assessed that all relevant eligible
activities comply with the criteria set out
in appendix C to annex I of the Climate
Delegated Act.
Protection and restoration of biodiversity
and ecosystems
We are legally required to conduct EIAs as
part of all our projects to ensure potential
impacts on biodiversity and ecosystems
are avoided, mitigated, and addressed
appropriately. Our biodiversity policy and
internal processes ensure all our assets
live up to the requirements. We have also
committed to ensuring that all new renewable
energy projects we commission from 2030
onwards deliver a net-positive biodiversity
impact, which we aim to achieve through our
biodiversity efforts.
For activity 4.3, we work to ensure that the
construction of offshore wind does not hamper
the achievement of good environmental
status as set out in Directive 2008/56/EC,
taking appropriate measures to prevent or
mitigate impacts in relation to the directive’s
descriptors 1 (biodiversity) and 6 (seabed
integrity).
It is assessed that all relevant eligible
activities comply with the criteria set out
in appendix D to annex I of the Climate
Delegated Act.
Minimum safeguards
Our human rights policy sets out our commit-
ment to respect human rights and lives up
to the UN Guiding Principles on Business and
Human Rights and OECD’s guidelines for mult-
inational enterprises, including the principles
of the Declaration of the International Labour
Organization on Fundamental Principles and
Rights at Work and the International Bill of
Human Rights, both in our own operations
and in our supply chain.
Together with our good governance practices
and policies, our systematic due diligence
approach ensures we have robust minimum
safeguards in place on human rights, corruption,
taxation, and fair competition.
Taxonomy KPIs
Our accounting policies for the taxonomy KPIs
are based on our interpretation of annex I to
the Disclosures Delegated Act ( Commission
Delegated Regulation (EU) 2021/4987) and
available guidelines from the European
Commission.
Linkage principle
The revenue, CAPEX, OPEX, and EBITDA
associated with our taxonomy-aligned
activities have been determined. In allocating
the financial numbers to the numerator, a
‘linkage principle’ has been applied, stipulating
that any revenue, CAPEX, OPEX, or EBITDA
that can be justifiably linked to an identified
taxonomy-aligned activity can be classified
as taxonomy-aligned and thereby included in
the numerator of the respective KPI.
Double counting
We have avoided double counting across
economic activities in the allocation of the
numerator for revenue, CAPEX, OPEX, and
EBITDA by using activity-specific factors to
allocate the financials across our taxonomy
activities. The factors are either 100 %, 0 %,
or a value in between where we have used
proxies to split the financial numbers into
taxonomy- aligned or non-eligible activities.
Here, the factors cannot sum to more than
100 %, which eliminates the possibility of double
counting the resulting financial numbers.
Proxies
Where the financial numbers are not appro-
priately split into the correct activity in the
financial account set-up, proxies have been
used to split the numbers. Two proxies have
been used:
1) The ratio of purchased power volumes
from renewable versus non-renewable
assets – applied to revenue and EBITDA
from balancing activities.
2) Bioenergy’s share of renewable energy
generation – applied to revenue, EBITDA,
CAPEX, and OPEX related to the CHP plants.
For more details on our taxonomy-aligned KPIs,
see our accounting policies on page 103.
107 Sustainability statements
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EnvironmentØRSTED ANNUAL REPORT 2024
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Taxonomy-aligned activities