Task Force on Climate-related Financial Disclosures

Download our full TCFD disclosure


The Group has complied with the requirements of LR 9.8.6 R by including climate-related financial disclosures consistent with the TCFD recommendations and recommended disclosures.


Board’s oversight of climate-related risks and opportunities

Until May 2022, the Board’s oversight of the environment was through its Safety & Environment Committee. Since May 2022, it has been through its dedicated Sustainability Committee, with a remit to cover the governance of environmental and sustainability matters. The Sustainability Committee met twice during 2022, with the Safety & Environment Committee also meeting once during the year prior to it being repurposed. In future, the Sustainability Committee will meet three times a year. The terms of reference can be found on our Committees page.

Key activities

With the Safety & Environment Committee having previously approved the Group’s environmental strategy, which is centred on the transition of the Group’s fleet to ZEVs, this year the key activities of the newly formed Sustainability Committee focused on monitoring the progress of implementing the strategy, including: • Assessing the Group’s performance against its sustainability targets and reviewing the plans for achieving its sustainability ambitions, the Group’s Sustainability road map and the Group’s ZEV transition road map; 

  • Reviewing and approval of the Group’s first Group-wide Sustainability Report published in July 2022; 
  • Monitoring of the Group’s plans to align with the Paris Agreement target of limiting global warming to 1.5 degrees above pre-industrial levels; and 
  • Reviewing and approval of the sustainability disclosures reported in this Annual Report.


The Committee reports to the Board of Directors, with the Committee Chair providing updates to the Board after each Committee meeting on the matters discussed. The Board is specifically updated on information received by the Committee in respect of the physical and transitional risks associated with climate change and any strategic recommendations made by the Committee. The Committee also produces a formal written report each year to the Company’s Shareholders, which is approved by the Board. This year’s report is set out on pages 136 to 139 of this Annual Report, which includes a list of Committee members and other attendees.

Review of climate-related issues

The Evolve strategy, launched in 2021 was reviewed by the Board prior to launch. One of the key outcomes of the strategy is for the Group to be an environmental leader, by delivering the transition to zero emission vehicles.

To monitor progress against this strategy and the financial impact, the Board reviews on an annual basis both the long-term strategic plan, of which the latest runs until 2027, and the annual budget, the most recent of which was for FY23. Both of these exercises consider the financial and operational impacts of both the transition to a low carbon economy and the potential impact of physical risks from climate change, which are discussed in detail in the Strategy section of this disclosure.

Please refer to the risk management section for how the Board exercises oversight vis-à-vis the incorporation of climate-related issues into the risk management processes.

Training and Development

To assist them in discharging their oversight responsibilities on the Group’s environmental strategy and having the ability to give direction and raise challenges, the Committee received a Benchmarking and Landscape review presentation from international sustainability consultants BRODIE during the year. Committee members also have access to climate related resources, including Chapter Zero.

Management’s role in assessing and managing climate-related risks and opportunities

The Company’s Executive Directors are responsible for the delivery of the Group’s environmental strategy and are the sponsors of its overall 2040 net zero ambitions. The Group Sustainability Director, who joined the Group in December 2021, has supported this delivery and continued to develop the Group’s environmental and wider sustainability strategy during the year. As the Group’s environmental strategy is centred on the transition of the Group’s fleet to ZEVs, the Group has steering Groups to oversee and lead the ZEV transition. This includes a new Global Sustainability Steering Group (GSSG), which was incorporated during the year and has the Group CFO and the Group Human Resources and Communications Director as the Executive sponsors. The following diagram explains the role both Board committees and different senior leaders play in having oversight of assessing and managing climate-related risks and opportunities:

The following table explains the role both Board committees and different senior leaders play in having oversight of assessing and managing climate-related risks and opportunities:

Board of Directors

Responsible for reviewing the Group’s strategy and its management of risk and ensuring that there is a robust system of internal control in place, including for climate risks.
Sustainability Committee

Newly formed in the year with a remit to cover the governance of environmental and sustainability matters. 

Remuneration Committee

Reviewed and approved the inclusion of ESG targets within the Executive Directors, and senior management’s remuneration to ensure alignment with strategy and performance

Nominations Committee

Considered and recommended the proposed size and composition of the newly formed Sustainability Committee, taking into account the Non-Executive Directors’ experience, expertise and other Board and Committee responsibilities

Audit Committee

Reviewed the annual report including TCFD disclosures 

Company Executive Management (Group CEO & CFO)

  • Delivery of the Group’s overall strategy, including its ZEV fleet transition strategy and management of other climate-related risks and opportunities 
  • Ensure effectiveness of the Group’s risk management system, including for climate-related risks 
  • Management of the functional managers and divisional executive managers, and being members of the Company ZEV Steering Group 


Group Sustainability Director
  • Supports Company executive management in developing and delivering a sustainability strategy, consistent with the Evolve strategy

Group Head of Compliance & Risk 
  • Supports Company executive management in ensuring there is an effective risk management system

Functional Managers

Managers and their climate-related responsibilities: 

  • Group General Counsel: assists with the identification of climaterelated risks e.g. by advising on regulatory changes driving transitional risks 
  • Group Insurance Manager: assists with managing climate-related risks e.g. by securing insurance coverage for physical risks 
  • Group Safety Director: assists with managing climate-related risks e.g. by devising new safety policies and procedures to mitigate physical risks
  • Group Procurement Director: identifies, negotiates and builds partnerships with vehicle manufacturers for the supply of ZEVs on the best obtainable terms 
  • Group Head of Internal Audit: provides independent assessment of the effectiveness of climate-related risk management activities and of other functions’ climate-related activities 
  • Group Financial Controller: assists with the quantification of climate-related risks and scenario modelling 
Company ZEV Steering Group

Membership: Group CEO, Group CFO, Divisional CEOs, Divisional ZEV Leads, Group Procurement Director, Group Commercial Director

Climate-related activities: 

  • Lead and oversee progress of delivery of ZEV transition plans 
  • Receive reports from Divisional ZEV Steering Groups on all matters reviewed by them

Global Sustainability Steering Group (GSSG)

The GSSG was newly established in the year. Attendees also include the Group Head of Sustainability, Group Financial Controller, Group Procurement Director, and representatives from each division who are primarily responsible for environmental and sustainability matters. The Steering Group is tasked with:

  1. Ensuring consistent reporting of ESG and sustainability targets 
  2. Setting the global strategic framework for our sustainability strategy 
  3. Establishing how to communicate our ESG strategy, vision and purpose externally
  4. Sharing best practice and collective learning 
  5. Communicating our successes to our stakeholders – particularly shareholders 


Divisional Executive Management (Divisional CEOs & CFOs) 
  • Build climate-related risks and opportunities into divisional business plans, allocate resources for their delivery, and manage and track their delivery 
  • Build the financial implications of climate-related risks and opportunities into divisional budgets and track these through forecasts

Divisional Commercial & Operations/Service Delivery Managers
  • Manage the operational impact of climate-related risks e.g. develop and implement contingency plans to mitigate physical risks 
  • Deliver commercial arrangements to capitalise on climate-related opportunities e.g. arrange road services to cover disruption caused by physical risks to rail infrastructure and apply for ZEV grant funding 
  • Assist in identifying new climate-related risks and opportunities
Divisional ZEV Steering Groups (x3)

Membership: Divisional CEOs, Divisional ZEV Leads, Divisional Procurement Directors, Divisional Commercial Directors

Climate-related activities: 

  • Develop and track progress against divisional ZEV transition plans 
  • Track financial impact of ZEV initiatives 
  • Review customer (passenger and contract counterparty) demand for ZEVs 
  • Review ZEV supply chain relationships 
  • Review ZEV funding options 
  • Track ZEV technological advancements