On behalf of 551 investors with assets of US$71 trillion

Report written for Carbon Disclosure Project by:

Carbon Disclosure Projectinfo@cdproject.net+44 (0) 20 7970 5660www.cdproject.net

CDP FTSE 350 Report 2011Can UK Plc help meet the Carbon Budgets?

2

ABRAPP - Associação Brasileira das Entidades Fechadas de Previdência ComplementarAEGON N.V.AKBANK T.A.S. Allianz Global Investors Kapitalanlagegesellschaft mbHATP GroupAviva InvestorsBank of America Merrill LynchBlackRockBP Investment Management LimitedCalifornia Public Employees’ Retirement SystemCalifornia State Teachers’ Retirement SystemCalvert Asset Management Company, Inc.

Catholic SuperCCLA Investment Management LtdEthos FoundationGeneration Investment ManagementHSBC Holdings plcINGKB Kookmin BankKLPLegg Mason, Inc.London Pensions Fund AuthorityMitsubishi UFJ Financial Group (MUFG)Morgan Stanley National Australia BankNEI InvestmentsNeuberger BermanNewton Investment Management LimitedNordea Investment Management

PFA PensionRaiffeisen SchweizRoyal Bank of Scotland GroupRobecoRockefeller & Co., Inc.SAM GroupSchroders Scottish Widows Investment PartnershipSEBSompo Japan Insurance Inc.Standard CharteredSun Life Financial Inc.TD Asset Management Inc. and TDAM USA Inc.The Wellcome TrustZurich Cantonal Bank

CDP works with investors globally to advance the investment opportunities and reduce the risks posed by climate change by asking almost 6,000 of the world’s largest companies to report on their climate strategies, GHG emissions and energy use in the standardised Investor CDP format. To learn more about CDP’s member offering and becoming a member, please contact us or visit the CDP Investor Member section at www.cdproject.net/investormembers

2011 Carbon Disclosure Project Investor Members

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CDP Signatories

Carbon Disclosure Project 2011 551 financial institutions with assets of US$71 trillion were signatories to the CDP 2011 information request dated February 1st, 2011 Aberdeen Asset ManagersAberdeen Immobilien KAG mbHABRAPP - Associação Brasileira das Entidades Fechadas de Previdência ComplementarActive Earth Investment ManagementAcuity Investment ManagementAddenda Capital Inc.Advanced Investment PartnersAdvantage Asset Managers (Pty) LtdAEGON Magyarország Befektetési Alapkezelo Zrt.AEGON N.V.AEGON-INDUSTRIAL Fund Management Co., LtdAFP IntegraAIG Asset ManagementAk Asset Management AKBANK T.A.S.Alberta Investment Management Corporation (AIMCo)Alberta Teachers Retirement FundAlcyone FinanceAllianz Elementar Versicherungs-AGAllianz GroupAltira GroupAmalgamated BankAMP Capital InvestorsAmpegaGerling Investment GmbHAmundi AMANBIMA – Associação Brasileira das Entidades dos Mercados Financeiro e de CapitaisAntera Gestão de Recursos S.A.APG GroupAprionisAquila CapitalARIA (Australian Reward Investment Alliance)Arisaig Partners Asia Pte LtdARK Investment Advisors Inc.Arma Portföy Yönetimi A.S.ASB Community TrustASM Administradora de Recursos S.A.ASN BankAssicurazioni Generali SpaATP GroupAustralia and New Zealand Banking Group LimitedAustralian Central Credit Union incorporating Savings & Loans Credit UnionAustralian Ethical Investment LimitedAustralianSuperAvivaAviva InvestorsAXA GroupBaillie Gifford & Co.Bakers Investment Group (Australia) Pty LtdBanco Bradesco S/ABanco de Credito del Peru BCPBanco de Galicia y Buenos Aires S.A.Banco do Brasil S/ABanco Nacional de Desenvolvimento Econômico e Social - BNDESBanco SantanderBanesprev – Fundo Banespa de Seguridade SocialBanesto (Banco Español de Crédito S.A.)Bank of America Merrill LynchBank of MontrealBank Sarasin & Cie AGBank VontobelBankhaus Schelhammer & Schattera Kapitalanlagegesellschaft m.b.H.BANKINTER S.A.BankInvestBanque DegroofBarclays

Baumann and Partners S.A.BAWAG P.S.K. INVEST GmbHBayern LBBayernInvest Kapitalanlagegesellschaft mbHBBC Pension Trust LtdBBVABedfordshire Pension FundBentall KennedyBeutel Goodman and Co. LtdBioFinance Administração de Recursos de Terceiros LtdaBlackRockBlumenthal FoundationBNP Paribas Investment PartnersBNY MellonBNY Mellon Service Kapitalanlage GesellschaftBoston Common Asset Management, LLCBP Investment Management LimitedBrasilprev Seguros e Previdência S/A.British Columbia Investment Management Corporation (bcIMC)BT Investment ManagementBusan BankCAAT Pension PlanCadiz Holdings LimitedCaisse de dépôt et placement du QuébecCaisse des DépôtsCaixa Beneficente dos Empregados da Companhia Siderurgica Nacional - CBSCaixa de Previdência dos Funcionários do Banco do Nordeste do Brasil (CAPEF)Caixa Econômica FederalCaixa Geral de DepositosCaja de Ahorros de Valencia, Castellón y Valencia, BANCAJACaja NavarraCalifornia Public Employees’ Retirement SystemCalifornia State Teachers’ Retirement SystemCalifornia State TreasurerCalvert Asset Management Company, IncCanada Pension Plan Investment BoardCanadian Friends Service Committee (Quakers)Canadian Imperial Bank of Commerce (CIBC)CAPESESPCapital Innovations, LLCCARE Super Pty LtdCarlson Investment ManagementCarmignac GestionCatherine Donnelly FoundationCatholic SuperCbus Superannuation FundCCLA Investment Management LtdCeleste Funds Management LimitedCentral Finance Board of the Methodist ChurchCeresChristian SuperChristopher Reynolds FoundationChurch Commissioners for EnglandChurch of England Pensions BoardCI Mutual Funds’ Signature Global AdvisorsClean Yield Group, Inc.Cleantech Invest AGClearBridge AdvisorsClimate Change Capital Group LtdCM-CIC Asset ManagementColonial First State Global Asset ManagementComerica IncorporatedComite syndical national de retraite BâtirenteCommerzbank AGCommInsureCommonwealth Bank of AustraliaCompton Foundation, Inc.Concordia VersicherungsgruppeConnecticut Retirement Plans and Trust FundsCo-operative Financial Services (CFS)Corston-Smith Asset Management Sdn. Bhd.CRD AnalyticsCrédit AgricoleCredit SuisseGruppo Credito ValtellineseDaegu BankDaiwa Securities Group Inc.

de Pury Pictet Turrettini & Cie S.A.DekaBank Deutsche GirozentraleDeutsche Asset Management Investmentgesellschaft mbHDeutsche Bank AGDeutsche Postbank Vermögensmanagement S.A.Development Bank of Japan Inc.Development Bank of the Philippines (DBP)Dexia Asset ManagementDexus Property GroupDnB NOR ASADomini Social Investments LLCDongbu InsuranceDWS Investment GmbHEarth Capital Partners LLPEast Sussex Pension FundEcclesiastical Investment ManagementEcofi Investissements - Groupe Credit CooperatifEdward W. Hazen FoundationEEA Group LtdElan Capital PartnersElement Investment ManagersELETRA - Fundação Celg de Seguros e PrevidênciaEnvironment Agency Active Pension fundEpworth Investment ManagementEquilibrium Capital GroupErste Asset ManagementErste Group BankEssex Investment Management Company, LLCESSSuperEthos FoundationEureko B.V.Eurizon Capital SGREvangelical Lutheran Church in Canada Pension Plan for Clergy and Lay WorkersEvli Bank PlcF&C Management Ltd FAELCE – Fundacao Coelce de Seguridade SocialFAPERS- Fundação Assistencial e Previdenciária da Extensão Rural do Rio Grande do SulFASERN - Fundação COSERN de Previdência ComplementarFédéris Gestion d’ActifsFIDURA Capital Consult GmbHFIM Asset Management LtdFIPECq - Fundação de Previdência Complementar dos Empregados e Servidores da FINEP, do IPEA, do CNPqFIRA. - Banco de MexicoFirst Affirmative Financial Network, LLCFirst Swedish National Pension Fund (AP1)Firstrand LimitedFive Oceans Asset Management Pty LimitedFlorida State Board of Administration (SBA)FolketrygdfondetFolksamFondaction CSNFondation de LuxembourgFondiaria-SAIFonds de Réserve pour les Retraites – FRRFourth Swedish National Pension Fund (AP4)FRANKFURT-TRUST Investment-Gesellschaft mbHFukoku Capital Management IncFUNCEF - Fundação dos Economiários FederaisFundação AMPLA de Seguridade Social - BrasiletrosFundação Atlântico de Seguridade SocialFundação Attilio Francisco Xavier FontanaFundação Banrisul de Seguridade SocialFundação de Assistência e Previdência Social do BNDES - FAPESFUNDAÇÃO ELETROBRÁS DE SEGURIDADE SOCIAL - ELETROSFundação Forluminas de Seguridade Social - FORLUZFUNDAÇÃO ITAUBANCOFundação Itaúsa IndustrialFundação Promon de Previdência SocialFundação Vale do Rio Doce de Seguridade Social - VALIAFundação Rede Ferroviaria de Seguridade Social – ReferFundação Sistel de Seguridade Social (Sistel)FUNDIÁGUA - FUNDAÇÃO DE PREVIDENCIA COMPLEMENTAR DA CAESBFuturegrowth Asset ManagementGartmore Investment Management LtdGEAP Fundação de Seguridade SocialGenerali Deutschland Holding AG

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2011 Carbon Disclosure ProjectInvestor Signatories

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Carbon Disclosure Project 2011 – FTSE 350 Report

Generation Investment ManagementGenus Capital ManagementGjensidige Forsikring ASAGLS Gemeinschaftsbank eGGoldman Sachs Group Inc.GOOD GROWTH INSTITUT für globale Vermögensentwicklung mbHGovernance for OwnersGovernment Employees Pension Fund (“GEPF”), Republic of South AfricaGreen Cay Asset ManagementGreen Century Capital ManagementGroupe Crédit CoopératifGroupe Investissement Responsable Inc.GROUPE OFI AMGrupo Banco PopularGrupo Santander BrasilGruppo Credito ValtellineseGruppo MontepaschiGuardian Ethical Management IncGuardians of New Zealand SuperannuationGuosen Securities Co., LTD.Hang Seng BankHarbourmaster CapitalHarrington Investments, IncHauck & Aufhäuser Asset Management GmbHHazel Capital LLPHDFC Bank LtdHealth Super FundHealthcare of Ontario Pension Plan (HOOPP)Henderson Global InvestorsHermes Fund ManagersHESTA SuperHSBC Global Asset Management (Deutschland) GmbHHSBC Holdings plcHSBC INKA Internationale Kapitalanlagegesellschaft mbHHyundai Marine & Fire Insurance. Co., Ltd.Hyundai Securities Co., Ltd.Ibgeana Society of Assistance and Security SIAS / Sociedade Ibgeana de Assistência e Seguridade (SIAS)IDBI Bank LtdIlmarinen Mutual Pension Insurance CompanyImpax Group plcIndusInd Bank LimitedIndustrial Bank (A)Industrial Bank of KoreaIndustry Funds ManagementInfrastructure Development Finance CompanyINGInsight Investment Management (Global) LtdInstituto de Seguridade Social dos Correios e Telégrafos- PostalisInstituto Infraero de Seguridade Social - INFRAPREVInstituto Sebrae De Seguridade Social - SEBRAEPREVInsurance Australia GroupInvestec Asset ManagementIrish Life Investment ManagersItau Asset ManagementItaú Unibanco Holding S AJanus Capital Group Inc.Jarislowsky Fraser LimitedJPMorgan Chase & Co.Jubitz Family FoundationJupiter Asset ManagementKaiser Ritter Partner (Schweiz) AGKB asset ManagementKB Kookmin BankKBC Asset Management NVKDB Asset Management Co., Ltd.KEPLER-FONDS Kapitalanlagegesellschaft m. b. H.KfW BankengruppeKlimaINVESTKLPKorea Investment Management Co., Ltd.The Korea Teachers Pension (KTP)Korea Technology Finance Corporation (KOTEC)KPA PensionLa Banque Postale Asset ManagementLa Financiere ResponsableLampe Asset Management GmbHLandsorganisationen i Sverige

LBBW - Landesbank Baden-WürttembergLBBW Asset Management Investmentgesellschaft mbHLD Lønmodtagernes DyrtidsfondLegal & General Investment ManagementLegg Mason, Inc.LGT Capital Management Ltd.LIG Insurance Co., LtdLight Green Advisors, LLCLiving Planet Fund Management Company S.A.Local Authority Pension Fund ForumLocal Government SuperLocal SuperLombard Odier Darier Hentsch & CieLondon Pensions Fund AuthorityLothian Pension FundLupus alpha Asset Management GmbHMacif GestionMacquarie Group LimitedMAMA Sustainable Incubation AGManMaple-Brown Abbott LimitedMarc J. Lane Investment Management, Inc.Maryland State TreasurerMatrix Asset ManagementMcLean BuddenMEAG MUNICH ERGO Asset Management GmbHMeeschaert Gestion PrivéeMeiji Yasuda Life Insurance CompanyMendesprev Sociedade PrevidenciáriaMerck Family FundMeritas Mutual FundsMetallRente GmbHMetrus – Instituto de Seguridade SocialMetzler Investment GmbhMFS Investment ManagementMidas International Asset ManagementMiller/Howard InvestmentsMirae Asset Global Investments Co. Ltd.Mirae Asset Securities Co., Ltd.Missionary Oblates of Mary ImmaculateMistra, Foundation for Strategic Environmental ResearchMitsubishi UFJ Financial Group (MUFG)Mizuho Financial Group, Inc.Mn ServicesMonega Kapitalanlagegesellschaft mbHMorgan StanleyMotor Trades Association of Australia Superannuation Fund Pty LtdMutual Insurance Company Pension-FenniaNatcan Investment ManagementNathan Cummings Foundation, TheNational Australia BankNational Bank of CanadaNational Grid Electricity Group of the Electricity Supply Pension SchemeNational Grid UK Pension SchemeNational Pensions Reserve Fund of IrelandNational Union of Public and General Employees (NUPGE)NATIXISNedbank LimitedNeedmor FundNEI InvestmentsNelson Capital Management, LLCNest SammelstiftungNeuberger BermanNew Amsterdam Partners LLCNew Mexico State TreasurerNew York City Employees Retirement SystemNew York City Teachers Retirement SystemNew York State Common Retirement Fund (NYSCRF)New Zealand Earthquake CommissionNewton Investment Management LimitedNGS SuperNH-CA Asset ManagementNikko Asset Management Co., Ltd.Nikko Cordial SecuritiesNissay Asset Management CorporationNORD/LB Kapitalanlagegesellschaft AGNordea Investment ManagementNorfolk Pension Fund

Norges Bank Investment Management (NBIM)North Carolina Retirement SystemNorthern Ireland Local Government Officers’ Superannuation Committee (NILGOSC)Northern TrustNykreditOddo & CieOECO Capital Lebensversicherung AGOld Mutual plcOMERS Administration CorporationOntario Teachers’ Pension PlanOP Fund Management Company LtdOppenheim Fonds Trust GmbHOpplysningsvesenets fond (The Norwegian Church Endowment)OPSEU Pension TrustOregon State TreasurerOrion Asset Management LLCParnassus InvestmentsPax World FundsPensioenfonds VervoerPension DenmarkPension Fund for Danish Lawyers and EconomistsPension Protection FundPensionsmyndighetenPETROS - The Fundação Petrobras de Seguridade SocialPFA PensionPGGMPhillips, Hager & North Investment Management Ltd.PhiTrust Active InvestorsPhoenix Asset Management Inc.Pictet Asset Management SAPKAPluris Sustainable Investments SAPNC Financial Services Group, Inc.Pohjola Asset Management LtdPortfolio 21 InvestmentsPorto Seguro S.A.PREVHAB PREVIDÊNCIA COMPLEMENTARPREVI Caixa de Previdência dos Funcionários do Banco do BrasilPREVIG Sociedade de Previdência ComplementarProvinzial Rheinland HoldingPrudential Investment ManagementPsagot Investment House LtdPSP InvestmentsPSS - Seguridade SocialQ Capital Partners Co. LtdQBE Insurance GroupRabobankRaiffeisen SchweizRailpen InvestmentsRathbones / Rathbone Greenbank InvestmentsReal Grandeza Fundação de Previdência e Assistência SocialRei SuperReliance Capital LtdResolutionResona Bank, LimitedReynders McVeigh Capital ManagementRLAMRobecoRockefeller Financial Rose Foundation for Communities and the EnvironmentRoyal Bank of CanadaRoyal Bank of Scotland GroupRREEF Investment GmbHSAM GroupSAMPENSION KP LIVSFORSIKRING A/SSAMSUNG FIRE & MARINE INSURANCESamsung SecuritiesSanlamSanta Fé Portfolios LtdaSAS Trustee CorporationSauren Finanzdienstleistungen GmbH & Co. KGSchrodersScotiabankScottish Widows Investment PartnershipSEBSEB Asset Management AGSecond Swedish National Pension Fund (AP2)SEIU Master Trust

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CDP SignatoriesCDP Signatories

Seligson & Co Fund Management PlcSentinel InvestmentsSERPROS - Fundo MultipatrocinadoSeventh Swedish National Pension Fund (AP7)Shinhan BankShinhan BNP Paribas Investment Trust Management Co., LtdShinkin Asset Management Co., LtdSiemens Kapitalanlagegesellschaft mbHSignet Capital Management LtdSMBC Friend Securities Co., LTDSmith Pierce, LLCSNS Asset ManagementSocial(k)Sociedade de Previdencia Complementar da Dataprev - PrevdataSolaris Investment Management LimitedSompo Japan Insurance Inc.Sopher Investment ManagementSPF Beheer bvSprucegrove Investment Management LtdStandard CharteredStandard Chartered Korea LimitedStandard Life InvestmentsState Bank of IndiaState Street CorporationStatewideSuperStoreBrand ASAStrathclyde Pension FundStratus GroupSumitomo Mitsui Banking CorporationSumitomo Mitsui Card Company, LimitedSumitomo Mitsui Finance & Leasing Co., LtdSumitomo Mitsui Financial GroupThe Sumitomo Trust & Banking Co., Ltd.Sun Life Financial Inc.Superfund Asset Management GmbHSUSI Partners AGSustainable CapitalSvenska Kyrkan, Church of SwedenSwedbank ABSwiss ReSwisscanto Holding AGSyntrus Achmea Asset ManagementT. Rowe PriceT. SINAI KALKINMA BANKASI A.S.T.GARANTI BANKASI A.S.Tata Capital Limited TD Asset Management Inc. and TDAM USA Inc.Teachers Insurance and Annuity Association – College Retirement Equities Fund (TIAA-CREF)Telluride AssociationTempis Asset Management Co. LtdTerra Forvaltning ASTerraVerde Capital Management LLCThe Brainerd FoundationThe Bullitt FoundationThe Central Church Fund of FinlandThe Collins FoundationThe Co-operative Asset ManagementThe Co-operators Group LtdThe Daly FoundationThe GPT GroupThe Hartford Financial Services Group, Inc.The Japan Research Institute, LimitedThe Joseph Rowntree Charitable TrustThe Local Government Pensions InstitutionThe Pension Plan For Employees of the Public Service Alliance of CanadaThe Pinch GroupThe Presbyterian Church in CanadaThe Russell Family FoundationThe Shiga Bank, Ltd.The Standard Bank GroupThe United Church of Canada - General CouncilThe University of Edinburgh Endowment FundThe Wellcome TrustThird Swedish National Pension Fund (AP3)Threadneedle Asset ManagementTokio Marine & Nichido Fire Insurance Co., Ltd.Toronto Atmospheric Fund

Trillium Asset Management CorporationTriodos Investment ManagementTrygUBSUniCredit GroupUnion Asset Management Holding AGUnipensionUNISON staff pension schemeUniSuperUnitarian Universalist AssociationUnited Methodist Church General Board of Pension and Health BenefitsUnited Nations FoundationUniversities Superannuation Scheme (USS)Vancity Group of CompaniesVCH Vermögensverwaltung AGVeris Wealth PartnersVeritas Investment Trust GmbHVermont State TreasurerVexiom Capital, L.P.VicSuper Pty LtdVictorian Funds Management CorporationVietNam Holding Ltd.Vision SuperVOLKSBANK INVESTMENTSWaikato Community Trust IncWalden Asset Management, a division of Boston Trust & Investment Management CompanyWARBURG - HENDERSON Kapitalanlagegesellschaft für Immobilien mbHWARBURG INVEST KAPITALANLAGEGESELLSCHAFT MBHWells Fargo & CompanyWest Yorkshire Pension FundWestLB Mellon Asset Management (WMAM)Westpac Banking CorporationWhite Owl Capital AGWinslow Management, A Brown Advisory Investment GroupWoori BankWoori Investment & Securities Co., Ltd.YES BANK LimitedYork University Pension FundYouville Provident Fund Inc.Zegora Investment ManagementZevin Asset ManagementZurich Cantonal Bank

Figure 1: 2011 Signatory Investor Breakdown

Asset ManagersAsset OwnersBanksInsuranceOther

1% 37%

5%23%

34%

Figure 2: CDP Investor Signatories & Assets over time

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Carbon Disclosure Project 2011 – FTSE 350 Report

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I am delighted to introduce the Investor CDP FTSE 350 Report 2011.

CDP plays a vital role in communicating information about greenhouse gas emissions and related activities reported by the UK’s largest companies, enabling investors and the public to take informed action against climate change.

This year’s report, asking if UK business can help meet the Carbon Budgets, shows that many UK companies are working towards emissions reduction, and that there has been an increase from 2010 in the number setting targets. Those companies setting absolute targets are demonstrating a strong level of ambition in the scale of emissions they have pledged to reduce. Given that industry is responsible for 34%

of UK emissions, and commercial activity for a further 9%, this is a very encouraging finding.

However, with only 15% of companies setting emissions reduction targets beyond 2020, there is still some way to go. UK business needs to demonstrate more long-term strategic thinking, particularly in carbon-intensive sectors such as Materials where only 56% of companies have targets in place although the sector as a whole accounts for 26% of emissions from the FTSE 350.

The Committee on Climate Change believes that UK government can help to focus the minds of corporations through new measures including the Green Deal, the Energy Company Obligation, Energy Market Reform and a new round of Climate Change

Agreements. Additional developments at national and European level continue to raise the possibility that climate disclosure could become a requirement for companies following CDP’s pioneering work to raise the profile of voluntary disclosure.In this rapidly changing business environment I wholeheartedly commend the work done by CDP to help companies to accelerate their progress in reducing emissions, and look forward to even greater achievements in the future.

Sincerely,

Adair Turner

Foreword to the CDP FTSE 350 Report 2011

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CEO Foreword Corporations, investors and governments today are faced with a choice: to compete aggressively for finite resources, or to advance towards a low carbon economy that enables sustainable, profitable growth, whilst reducing reliance on increasingly scarce materials.

Last year, global energy-related carbon dioxide emissions reached a record high. The International Energy Agency’s estimates made for bleak reading but compounded the necessity to take bold and decisive action if we are to have any chance of limiting temperature increase to the 2°C level agreed by world leaders to protect against catastrophic climate change.

What’s more, rising energy demands are competing for a limited supply of fossil fuels. The competition for increasingly scarce natural resources is putting pressure on commodity prices and having a growing impact both socially and economically. It is clear that today, more than ever, we must build momentum to decouple economic growth from emissions.

Managing carbon emissions and protecting the business from climate change impacts is fundamental to achieving sustainable and strong shareholder returns. Earlier this year, the investment consultancy Mercer released a report concluding that the best way for institutional investors to manage portfolio risk associated with climate change may be to shift 40% of their portfolios into climate-sensitive assets with an emphasis on those that can adapt to a low carbon environment.

An important part of an investor’s strategy should be to engage with the companies in which they invest to encourage performance improvement. Carbon Action is a new initiative launched by CDP this year. It is driven by a leading group of investors to encourage their portfolio companies to reduce emissions by investing in emissions reduction activities with a satisfactory payback period. Carbon Action reflects a growing recognition that there is a huge range of carbon reduction activities that companies can undertake that have a very clear business case. It is therefore in the interests of all investors, and not just the more active owners of investments, to ensure these actions are taken.

As the management of carbon continues to move into companies’ core business strategies and mainstream investment thinking, demand for primary corporate climate change information grows around the world. As well as working on behalf of 551 institutional investors to gather relevant information from large corporations around the world, CDP is also working with global businesses and governments to strengthen the resilience and sustainability of their supply chains through the CDP Supply Chain program. CDP Cities has launched to help the world’s major cities reduce climate change risk and bolster economic growth, whilst CDP Water Disclosure is now in its second year of working with major global companies to improve water management. A key part of CDP’s strategy is to ensure the effective use of data collected. To assist with this companies are able to obtain tools that help them to measure, report and manage carbon more effectively, through CDP Reporter Services.

It is through partnerships that CDP can achieve the largest impact. We are delighted to be working again this year with PwC, our Global Advisor, as well as with Accenture, Microsoft, SAP and Bloomberg. These and our other partners around the world are integral to the acceleration of CDP’s mission.

Whilst we wait patiently for much needed global regulation, business must continue to forge ahead, innovate and seek out opportunities by doing more with less. The decisions that perpetuate a legitimate, low carbon and high growth economy will bring considerable value to those that have the foresight to make them. The information contained in this report and the companies’ responses assist in illuminating that path.

Paul SimpsonCEOCarbon Disclosure Project

CEO Foreword

Carbon Disclosure Project 2011 – FTSE 350 Report

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Contents 2011 Carbon Disclosure Project Members 02

2011 Carbon Disclosure Project Signatories 03

Commentary for the Carbon Disclosure Project: Lord Adair Turner, Committee on Climate Change 06

Foreword: Paul Simpson, CEO, Carbon Disclosure Project 07

Executive Summary 09

Can UK Plc help meet the Carbon Budgets? 12

Commentary for the Carbon Disclosure Project: Alan McGill, Partner PwC, What doesn’t get measured doesn’t get done 19

2011 Leaders 20

The 2011 Carbon Disclosure Leadership Index (CDLI) 21

The 2011 Carbon Performance Leadership Index (CPLI) 26

Appendix I: Table of Emissions 30

Appendix II: Largest non-respondents by market cap in 2011 43

Key to Appendix 43

Appendix III: Global Key Trends Summary 44

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The UK Government was the first to agree a Climate Change Act, which places legally binding limits on economy-wide greenhouse gas (GHG) emissions. These are known as the Carbon Budgets, and UK business will have a significant role to play in achieving the Government’s emissions targets. In 2011, the Carbon Disclosure Project (CDP) sent its annual questionnaire to the FTSE 350 companies on behalf of 551 investors with US$71 trillion of assets, asking them to measure and report what climate change means for their business. This year, two thirds of the FTSE 350 corporations responded to the CDP questionnaire1 (236).

The responses have been analysed to assess the maturity of corporate climate change strategy and understand the steps taken by UK companies (UK Plc) to limit their greenhouse gas emissions. Many of these companies are multinationals and have operations, and emissions, in numerous countries. The UK Carbon Budgets and underlying policies are just some of the pieces in a complex patchwork of national and regional legislation that FTSE 350 companies are responding to.

Key findings2

• 66% (138) of FTSE 350 respondents disclosed emissions reduction targets, an overall increase from 58% (126) in 2010. Of these, 22% were absolute targets (46 companies), 34% were intensity-based targets (71 companies), and the remainder have both absolute and intensity targets (10%, 21 companies). This indicates an increased recognition by some of the UK’s largest companies of the need to accelerate actions to reduce emissions and achieve resulting benefits. The 46 companies, which have adopted absolute targets, have pledged to reduce emissions by 3.8% per year, showing greater ambition than the 1.7-2.6% annual reductions set out in the Carbon Budgets. However, the majority of the FTSE 350 has still not set an absolute target.

• Only 15% of responding companies have reported emissions reduction targets that stretch beyond 2020. The emissions targets set could be more ambitious, particularly in the carbon intensive sectors. The average duration of the target is eleven years to 2018, with a 2007 baseline.

• 91% (190) of respondents have established emissions reduction activities whether or not they have targets in place, up from 69% (150) in 2010. The most commonly cited action is energy efficiency, the second most common being behavioural change. As companies engage with, and respond to, climate change policy development, they are likely to focus on identifying opportunities to reduce emissions from their operations and supply chain.

• 38% (79) of respondents have reduced emissions from some or all of their business by implementing specific emissions reduction measures in the last year. This compares to 22% (48) of respondents which had reduced their emissions in 2010. The leaders are clearly moving ahead in this regard, with 100% of the Carbon Performance Leadership Index (CPLI) companies and 74% (26) of the Carbon Disclosure Leadership Index (CDLI) making emissions reductions. Despite this upward trend, many more UK companies need to implement emissions reductions measures if the UK is to stay within its Carbon Budget.

• As the government implements policies to achieve emissions reductions, the carbon intensive sectors may have to take on more ambitious targets. Materials, Energy and Industrial companies represent 30% (106) of the FTSE 350. Of these 106 companies, 66% (70) responded to CDP and reported Scope 1 and 2 emissions of 495 million tonnes, thereby accounting for 71% of the total emissions disclosed this year. Despite representing such a high proportion of emissions, only 55% (39 of the 70) respondents from the carbon intensive sectors stated that they set emissions targets. This indicates that the government may have to intervene to generate further action in these sectors.

Executive Summary

1. Of the 236 responses, 27 respondents referenced their parent companies’ answers which were analysed in the Global 500 report or elsewhere. Therefore, the ‘FTSE 350 respondents’ refers to the 209 unique responses.

2. Please see the Importance Notice on the back cover of this report regarding its content and use.

Carbon Disclosure Project 2011 – FTSE 350 Report

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• Scope 1, 2 and 3 emissions, disclosed by FTSE 350 companies, have decreased slightly to 2.81 billion tonnes of CO2-e from 2.99 billion tonnes in 2010.

• 33% (114 companies) of the FTSE 350 failed to respond this year. Given that the UK government will decide in 2012 whether to require corporate reporting on climate change, this raises questions about whether these companies are prepared for such future regulation.

• 75% of emissions reduction activities by FTSE 350 respondents had paybacks of three years or less. Some willingness to invest in activities with medium to longer-term returns is an indication that some companies regard energy management and emissions reductions as an important strategic priority. However, companies need clearer, long-term signals from governments, such as regulations, standards and incentives, to invest in longer term emissions reduction projects.

• The high incidence of board and senior management responsibility for climate change and greenhouse gas emissions has been maintained within the FTSE 350: 96% (201) of respondents in 2011 and 96% (207) in 2010. This lays the foundation for strong corporate action.

• 65% (135) of respondents provided financial incentives to staff to better manage climate change issues, versus 51% (111) in 2010. This is a significant change and suggests that climate change commitments will be an increasingly important component of financial incentives and personal objectives.

• Tesco achieved the highest ever disclosure score (97) of a FTSE 350 company and topped the Carbon Disclosure Leadership Index (CDLI). Thirty five other companies achieved the CDLI this year.

• This is the second year that CDP has published a Carbon Performance Leadership Index (CPLI). This year, there are seven performance leaders, and all of these companies are also in the CDLI.

Sector Company Carbon disclosure

score

Carbon performance

bandConsumer Staples Tesco 97 AConsumer Staples British American Tobacco 91 AEnergy BG Group 85 AFinancials Great Portland Estates 87 AHealth Care GlaxoSmithKline 93 AIndustrials Serco Group 88 ATelecommunications Cable and Wireless

Worldwide84 A

Figure 3: Top companies recognised on both the CDLI and the CPLI

Companies need clearer, long-term signals from governments, such as regulations, standards and incentives, to invest in longer term emissions reduction projects.

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Executive Summary

2011 2010 2009 2008

Figure 4: Year on year disclosure levels for the FTSE 3503

500

Responded

236 (67%)243 (69%)

236 (67%)234 (67%)

Disclose GHG emissions

199 (57%)206 (59%)

194 (55%)163 (47%)

Publicly available

170 (49%)174 (50%)

158 (45%)128 (37%)

Board or senior management oversight

201 (57%)207 (59%)

172 (49%)No data available for 2008

No data available for 2008

Rewarding climate change progress

135 (39 %)

85 (24%)111 (32%)

Verify emissions

52 (15%)96 (27%)

111 (32%)

500

500

106 (30%)

300 3500 50 100 150 200 250

Number of companies

3. The data for response rate is based on data at time of printing. Data for other areas are based on data for those companies received by July 31, 2011. Whilst every effort has been made to ensure that comparisons between years are direct, a number of questions have changed year on year in the questionnaire which has meant that the closest possible match has been made where an exact match is not possible. Percentages in this graph are based on the total 350 companies asked, rather than the 209 (AQ) respondents.

As many of the FTSE 350 operate globally, a stronger and more coherent global framework is required to create the right incentives and ancillary benefits for companies to set the most demanding targets.

It appears that many FTSE 350 companies are responding to existing climate change policies and adapting their strategies to stay ahead of new government regulation in this area. Consequently, they are placing themselves in a favourable position to rise to the challenge of climate change and take advantage of the opportunities that this may bring.

Setting the UK Carbon Budgets sent a clear signal that companies need to manage and reduce their carbon

emissions over the long-term. This applies to all companies, not simply those covered by the EU Emissions Trading Scheme or CRC Energy Efficiency Scheme. While many companies show that they are prepared to respond, some still have a long way to go. As many of the FTSE 350 operate globally, a stronger and more coherent global framework is required to create the right incentives and ancillary benefits for companies to set the most demanding targets.

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Can UK Plc help meet the Carbon Budgets?

The UK Carbon Budgets

The UK Government is the first in the world to place legally binding limits, or carbon budgets, on economy-wide greenhouse gas (GHG) emissions. These cover total UK emissions from 2008 to 2027 and are split into four successive five-year phases. The Carbon Budgets were established to underpin policies that drive emissions reductions; progress in different sectors is measured against the budgets.

The UK Government is implementing a range of policy measures to achieve the Carbon Budgets. Although a number of policies are still to be finalised, it is clear that business will have a crucial role to play in meeting the Carbon Budgets. It is also clear that the regulatory burden is expected to increase. Whether it is a carbon price floor or a revised standard for new building, it is important that new regulations are clear and long-term. These policies will not only require companies to reduce their emissions, but will also incentivise the development of new low carbon products and

services, ranging from renewable energy to electric vehicles.

This report shows how FTSE 350 companies are preparing for these new policies and the increasingly complex regulatory landscape that they need to navigate. Their experience can be used as a blueprint by other companies if, and when, other governments implement their own emissions reduction plans.

Assess, measure, manage

Many FTSE 350 companies state that a critical step in addressing climate change is to establish ambitious corporate emissions targets. For example, both GlaxoSmithKline and Tesco aim to cut their emissions by 100% by 2050. Setting, and working towards, corporate targets is not simply a response to existing regulations or carbon prices, it shows that companies are being proactive in preparing for future national and international legislation. In 2011, 66% (138) of respondents stated that they have emissions reduction targets which is the highest percentage ever

Many FTSE 350 companies state that a critical step in addressing climate change is to establish ambitious corporate emissions targets. For example, both GlaxoSmithKline and Tesco aim to cut their emissions by 100% by 2050.

Figure 5: UK Carbon Budgets: Decreases in Greenhouse Gas emissions required under the UK Climate Change Act 2008 with (2.6%), and without (1.7%), international agreement

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4. It is important to note that these percentage changes are not directly comparable. However, the FTSE 350 figure provides a good proxy for the performance of the UK Plc.

5. Verification of emissions has decreased in the year on year analysis in this report because CDP raised the bar to reflect the importance of verification.

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Can UK Plc help meet the Carbon Budgets?

reported by the FTSE 350 and up from 2010 (58%, 126 respondents). In their responses to CDP, companies cite a number of reasons why they are moving forward in this area, but the overall picture is one of greater sophistication in how they engage with the issue of climate change:

• Companies are better at identifying the risks and, in particular, the opportunities that their businesses face. 73% (153) of the FTSE 350 respondents have disclosed that they have a risk assessment process in place. Early engagement in risk assessment will improve a company’s policy-preparedness and increase the prospect that they turn risks into opportunities.

• 79% (165) of the FTSE 350 respondents consider that climate change regulation will affect their business, the highest level to date, compared to 68% (147) in 2010. The vast majority of those respondents who cited climate regulation as a risk expect to face this risk in the near-term. Indeed, 87% (634) of risks were identified as ‘current’ or ‘likely in the next 1-5 years’, with just 6% (44) identified as likely to occur after five years. Of the 732 risks identified, only 54 (7%) had an unknown timescale of impact for companies. The risks identified will be drivers to reduce emissions.

“The UK government is considering imposing mandatory carbon emission reporting requirements on large organisations in the UK. However, recent reports indicate that any such requirements will be fairly light touch. Grainger has already embarked on a multi-year programme to expand its carbon reporting to cover all aspects of the business; including estimating tenant building related Scope 3 emissions.” Grainger

• In addition to monetary savings through efficiency improvements, 158 of the respondents (76%) have identified opportunities arising from climate change regulation (75% (163) in 2010). Identifying and capitalising on these opportunities will be the key to UK companies moving forward to meet the UK Carbon Budgets.

“Product efficiency regulations and standards could drive increased demand for lower carbon fuels and renewables through the greater up take of products to which they relate (e.g. gas boilers, generators and pump efficiency). BG promotes the efficient use of its products where we sell to consumers recognising this is a key differentiator that underpins demand for our core products.” BG Group

However, some companies note that the lack of a strong international framework is a barrier to action to reduce emissions, and others state that national legislation may even contradict their corporate approach to addressing climate change.

“BT advocates for a strong and effective international climate framework to be put in place to enable the business community to accelerate positive action to reduce their carbon emissions in a predictable framework.”BT Group

“The UK CRC directly impacts HSBC; The CRC does not take account of the fact that HSBC buys its electricity under green tariff arrangements; which means that we will be required to purchase credits for full energy usage. The CRC does not take account of a company’s carbon neutrality; which is a disadvantage for HSBC.”HSBC

Companies are increasingly investing in the measurement and assurance of emissions. Indeed, the key to reducing emissions is good measurement and management of those emissions. Scope 1, 2 and 3 emissions, disclosed by FTSE 350 companies, have decreased by 6% to 2.81 billion tonnes of CO2-e from 2.99 billion tonnes in 2010. The FTSE 350 includes power producers as well as electricity users, (so there is inevitably some double-counting of Scope 1 and 2 emissions) and multinationals (so the geographical boundary extends beyond UK territory). However, the 6% reduction is in contrast with the UK’s total emissions, which increased by 2.8% in the same period4.

• In 2011, a high number of FTSE 350 companies disclosed their emissions: 93% (194) disclosed both Scope 1 and Scope 2 emissions, slightly down from 95% (206) in 2010. The decrease is more likely to be due to a change in the responding population (as companies move into and out of the FTSE 350 as market capitalisation changes) than companies making the decision to stop reporting emissions.

• 5% of the FTSE 350 respondents still do not disclose emissions. If the UK Government moves towards mandatory reporting, these companies will be required to develop the systems to monitor, report and verify their emissions. Verification of emissions reductions helps create certainty surrounding progress towards emissions reduction targets. 94% (33) of the CDLI disclosed that they had their 2010 Scope 1 and Scope 2 emissions verified or assured by independent third parties (verification was either complete or underway at the time the CDP response was made). However, as set out in Figure 4, the number of companies verifying their emissions fell in 2011 from 96 (44%) in 2010 to 52 (25%)5.

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Carbon Disclosure Project 2011 – FTSE 350 Report

Good emissions management practice is most likely when it is overseen by the highest levels within the business. The high incidence of senior management responsibility for climate change in the FTSE 350 (96% in 2011 and 2010) is very positive and provides the foundation for strong corporate action. There is widespread recognition at board level that taking no action on climate change could affect top line revenues (if consumers’ behaviour changes), and bottom line profits (if costs, penalties or taxes increase).

“Growing consumer awareness of climate change means there are reputational benefits to taking a lead in the transition to a low carbon economy. Our customers consistently tell us they want and expect us to do so, and that this is a factor for them in choosing where to shop. There are also benefits to our ability to attract and retain staff, who are also increasingly interested in climate change. As a recognised leader on climate change, Tesco is well placed to take advantage of increasing environmental awareness from consumers.”Tesco

• 65% (135) of companies have financial incentives linked to climate change. This signifies that, although the same percentage of companies have senior level responsibility for climate change, increasingly strong signals are being sent to employees to take action to address greenhouse gas emissions. In 2010, only 51% (111) of companies had management incentives (2009: 40% (85)).

• Monetary incentives are by far the most commonly used incentive (74%), followed by recognition incentives (22%) and other types of incentive (4%).

“Ideas on energy savings are often made through employee feedback. There is an annual Green week held to stimulate staff participation and encourage others to become involved. The incentives are in the form of a prize or site or individual recognition on the Groups intranet.”Capita Group

Business actions to tackle emissions growth

TargetsWhile focusing on energy management or operational efficiency is important, setting emissions targets is one of the key ways that the FTSE 350 companies reduce their emissions. These targets therefore will play an important part in helping the UK meet the Carbon Budgets. 66% (138) of respondents note that they have one or more targets in place to tackle emissions growth (2010: 58% (126)). The most popular target type is the intensity target which is defined as ‘goals to reduce the ratio of emissions to a business metric over time’ (34% (71) of companies). Absolute targets are less popular, being set by 22% (46) of companies. These are defined as ‘goals to reduce absolute emissions over time’ and allow companies to account for growth. It should also be noted that 34% of companies did not set any targets.

The Consumer Staples sector has the highest proportion of companies which take on emissions reduction targets (94% of its respondents). However, this sector only accounts for 3% of the total Scope 1 and Scope 2 emissions meaning that, while commendable, its effect on overall UK emissions will be limited.

At the same time, only 56% of Materials companies have targets in place, although this sector accounts for 26% of the FTSE 350 emissions. More

Figure 6: Companies with Targets

Absolute and intensity targetsAbsolute targetsIntensity targetsNo targets

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Can UK Plc help meet the Carbon Budgets?

companies within the Materials sector will need to set targets if they are to help the UK meet its carbon budgets.

The variation in the proportion of companies with targets in different sectors may be due to the high level of customer awareness in the Consumer Staples sector. In the highly competitive Materials market, companies may not face this pressure from their business customers which has resulted in target setting being overlooked by many respondents. The Utilities sector, by contrast, accounts for 24% of Scope 1 and 2 emissions and an impressive 89% of its respondents have targets demonstrating their strategic engagement with climate change.

The responses show that there is variability in the duration of the targets. The absolute emissions targets span, on average, 11 years from their defined base year with an average reduction target of 3.8% per year and the intensity emissions targets span, on average, 5.7 years from their defined base year (78% of targets noted are under ten years) with an average of 4.4% per year. 152 intensity targets have deadlines set to 2020 or sooner. Figure 8: Emissions reduction targets of the FTSE 350, shows the different approaches to target setting. Only 15% (32) of companies have emissions reduction targets for 2020 or beyond, indicating the lack of longer term planning on this issue. It suggests that until the government sets out the longer term policies needed to meet the Carbon Budgets, companies are only able to plan actions in the short-term.

“International agreements are likely to force national governments to make a transition to a lower carbon economy; for example the introduction of the

Feed in Tariff to subsidise small-scale renewable energy generation in the UK. These policies; borne out of action towards meeting international agreements have the potential to help the Pennon Group of companies in achieving their own targets.”Pennon Group

Emissions reduction activities

38% (79) of the respondents decreased their absolute Scope 1 and 2 emissions as a result of emissions reduction activities ongoing within the reporting year. In 2010, only 48 (22%) companies reported that their decrease in emissions related to emissions reduction activities. Further reductions can be expected in the future as 190 companies (91% of respondents) have disclosed that they have a number of emissions reduction activities in place (2010: 69% (150) of companies). An interesting pattern identified between 2010 and 2011 is that, across all sectors, similar activity types are being identified as the most popular ones.

190 (91%) companies reported on a range of different activities to reduce their emissions. In total, 411 initiatives were disclosed which means that, on average, each company has approximately two initiatives. Of the initiatives which had payback period information, 75% (199) noted expected paybacks of less than three years; the remainder had paybacks of over three years.

The most popular initiatives related to energy efficiency measures (190). 120 companies invested in longer term energy efficiency measures such as building processes, building services and building fabric. These investments tend to have payback periods of more than one year. This willingness to invest

in activities with a medium to long-term payback is evidence that some companies regard energy management and emissions reductions as an important long-term strategic priority.

The second most popular activity that companies invest in, is behavioural change (59 different initiatives discussed by respondents). The reason for this popularity is likely to be the short payback period identified for those initiatives and the fact that lower investment is typically required. Indeed, of those with a known payback period, 54% (20) are less than one year. Primarily, companies are training and educating their staff in appropriate behaviours such as switching off computers or cycling to work. Through their products and interactions with clients, some companies are also trying to change the behaviours of their customers.

“Our GREENiQ employee engagement program supports the creation of GREENiQ Teams at our office and production locations. These teams implement energy-saving measures including lighting retrofits, raising employee awareness of their own carbon impacts, installing automatic sensors for lighting, and participation in Earth Hour and World Environment Day.”Diageo

“RBS has implemented in late 2010 a ‘switch-off, keep-off’ campaign in critical buildings across the total portfolio where non critical lighting and/or signage has been turned dark at night.”Royal Bank of Scotland

Carbon Disclosure Project 2011 – FTSE 350 Report

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“Driver training has been provided at some of the Wolseley UK distribution centres for all drivers with a focus on reducing fuel consumption, reducing vehicle maintenance and reducing driver stress and fatigue with the aim of improving environmental performance and reducing carbon emissions.”Wolseley

“B&Q UK ran a three-month employee engagement campaign in autumn 2010 to encourage employees to reduce energy use both at work and at home. Over 6,000 employees signed up for the campaign and received a free energy-saving pack, including an electricity monitor, a standby saver and a shower water-saving device.”Kingfisher

Avoidance of emissions through products and services

50% (104) of the FTSE 350 respondents provided examples of the products and services that they have developed in order to help third parties reduce their emissions. This is an increase from 2010 when only 42% (91) of companies disclosed this information. This suggests that companies do see the opportunity in selling low carbon goods and services to

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Can UK Plc help meet the Carbon Budgets?

third parties who are increasingly aware of environmental issues and are actively in the market for these types of goods.

“The introduction of auto-standby on our set top boxes saves approximately 90,000 tonnes of CO2 emissions per annum from the reduction in energy use in our customer homes which saves approximately £20m of customer electricity bills per annum.”British Sky Broadcasting

Conclusion

The UK Carbon Budgets are relatively new and many companies are still determining how to respond to them – both strategically and operationally. The overall ambition of the emissions reduction targets set out in the Carbon Budgets for the UK economy will depend on the success of international negotiations and whether other countries adopt comparable measures. Although the Carbon Budgets provide a series of targets, companies are asking for clear long-term policies to direct their emissions reduction strategies. A direct comparison between the targets disclosed by the FTSE 350 in their CDP responses and the UK’s Carbon Budgets cannot be made. However, an increasing number of companies have

set demanding emissions targets of their own and are implementing initiatives that will play an important role in the UK achieving significant emissions reductions. This indicates that many UK businesses are already on the path to a low carbon economy and preparing to compete in a global economy that will demand growth without carbon emissions. These companies are leading the way and setting best practices for other companies to follow.

The successful mitigation of climate change requires the collaboration of governments, businesses and individuals. The UK government has demonstrated global leadership by setting ambitious national targets for reducing carbon emissions. Therefore, some of the FTSE 350 companies can themselves be considered global corporate leaders on climate change. The more ambitious the targets set by the FTSE 350 companies, the better placed the UK will be to achieve its national goals. In responding to CDP, companies share details of how they are responding to regulatory requirements and how they derive financial value from tackling their emissions or those in their supply chain. Companies which are just starting the journey of developing targets can learn from the experiences of others further down the path.

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Although the Carbon Budgets provide a series of targets, companies are asking for clear long-term policies to direct their emissions reduction strategies.

Carbon Disclosure Project 2011 – FTSE 350 Report

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Number of Initiatives

Figure 9: Payback period breakdown of reported active emissions reduction initiatives by activity type

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The more ambitious the targets set by the FTSE 350 companies, the better placed the UK will be to achieve its national goals. In turn, these companies can become global leaders in this sphere.

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A recent Defra report highlighted that “a wide range of factors can drive companies to set emission reduction strategies, targets and deliver these reductions. Companies who participated in this study did not view reporting as one of the top drivers but an activity that enables emissions reduction/target setting”6.

The study therefore found that the activity of emissions measurement, driven by a desire or need to externally report such data, was a key enabler of greenhouse gas (GHG) emission reductions.

Whilst there is currently no mandatory requirement in the UK for companies to externally report their GHG emissions, an increasing number do so on a voluntary basis. In the absence of standard guidelines or frameworks on how to measure and report such data, there is limited consistency and comparability between companies’ voluntary reports.

This not only presents a challenge for investors and other key stakeholders who often wish to make decisions based on a company’s relative performance, but makes it difficult to compare UK companies’ emissions and targets to those set out under the UK carbon budgets, as the baseline and target years and measurement boundaries are often different.

Partly in recognition of these issues, the UK Climate Change Act requires the Government to look at introducing regulations requiring businesses to report their emissions, and Defra has recently closed a consultation on a range of options for both the introduction of mandatory reporting, or more specific guidelines for voluntary reporting. A decision is due in the autumn of 2011.

Looking broader than carbon emissions reporting, the UK Government has also recently closed a consultation on the future of narrative reporting. The consultation was part of implementing the Coalition Agreement

commitment to “reinstate an Operating and Financial Review to ensure that directors’ social and environmental duties have to be covered in company reporting and investigate further ways of improving corporate accountability and transparency”.

The outcome of these consultations will have implications for each other; mandatory GHG reporting would require additional commentary in the narrative section whilst increased disclosure in the form of narrative reporting would likely require evidence and data to support it. We understand that they are therefore being considered concurrently by the UK Government.

So, whilst the details of future requirements for corporate reporting on sustainability and climate change are still to emerge, it is clear that whether voluntarily or otherwise, companies will increasingly need to do so. The emissions measurement activities this will drive should be a key enabler of GHG emission, and often cost, reductions.

PwC Commentary: What doesn’t get measured doesn’t get done Alan McGill, Partner, PwC

Can UK Plc help meet the Carbon Budgets?

6. Defra, 2010. Review of the Contribution of Reporting to GHG Emissions Reductions and Associated Costs and Benefits – Final Report.

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Introduction to the Carbon Disclosure Leadership Index (CDLI) and the Carbon Performance Leadership Index (CPLI)

Each year, company responses are reviewed, analysed and scored for the quality of disclosure and performance on actions taken to mitigate climate change. This results in a disclosure score, and where sufficient disclosure exists, a performance band.

Disclosure scores • Disclosure scores are an assessment

of the quality and completeness of a company’s response; they are not a measure of a company’s performance in relation to climate change management.

• Scores are plotted over a 100-point normalised scale.

• Companies are assessed based on their level of disclosure of carbon emissions measurement techniques and subsequent public disclosure.

• Companies with the highest disclosure scores are listed in the CDLI.

Performance bands • Where a company’s disclosure score

is 50 or more, its overall performance in addressing the climate change issue is assessed and ranked.

• This year there are six performance bands (there were four bands in 2010).

• Companies with the highest performance bands that meet additional ‘CPLI’ criteria are listed in the CPLI.

Analysis of the CDLI and CPLI provides insights into the characteristics and common trends among the leading companies on carbon disclosure, and highlights good practices in reporting, governance, risk management, emissions reduction and other areas. Interrelations between the CDLI and CPLI companies are analysed to determine if those companies with better data use it within the business to drive value adding activities.

2011 Leaders

Analysis of the CDLI and CPLI provides insights into the characteristics and common trends among the leading companies on carbon disclosure, and highlights good practices in reporting, governance, risk management, emissions reduction and other areas.

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The 2011 Carbon Disclosure Leadership Index (CDLI)

Generally, companies scoring within a particular range suggest levels of commitment to, and experience of, carbon disclosure. The indicative description of each level is provided below for guidance only; investors should read individual company responses to understand the context for each business.

How is the disclosure score determined?

In determining the disclosure score for each company, we assess the following:

• Thelevelofunderstandinganddisclosure of company-specific exposure to climate-related risks and opportunities

• Thelevelofstrategicfocusandcommitment to understanding the business issues related to climate change, emanating from the top of the organisation

• Theextenttowhichacompanyhasmeasured its carbon emissions

• Theextentoftheinternaldatamanagement practices for understanding GHG emissions, including energy use

• Thefrequencyandrelevanceof disclosure to key corporate stakeholders

• Whetherthecompanyusesthirdparty for external verification of emissions data to promote greater confidence and usage of the data

Eligibility for the CDLI

In order to be included in the CDLI companies must:

• RespondusingtheOnlineReporting System (ORS) prior to the deadline

• Provideapublicresponse

• Scorewithinthetop10%ofthereporting population: a total of 35 companies are included in the 2011 FTSE 350 CDLI

More information on the CDLI can be found in the information request, supporting methodology and guidance documents at www.cdproject.net

What does a CDP carbon disclosure score represent?

The journey to leadership

High (>70) Senior management understand the business issues related to climate change and are building climate related risks and opportunities into core business

Midrange (50-70) Increased understanding and measurement of company-specific risks and opportunities related to climate change

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Limited or restricted ability to measure and disclose climate related risks, opportunities and overall carbon emissions

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Compliance Managing for value Strategic advantage

Figure 10: Carbon disclosure elements

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Carbon Disclosure Project 2011 – FTSE 350 Report

Sector Company Disclosure score

Consumer Discretionary British Sky Broadcasting 90Carnival 88TUI Travel 85Kingfisher 85Reed Elsevier 82

Consumer Staples Tesco 97British American Tobacco 91Diageo Plc 89Reckitt Benckiser 81

Energy Royal Dutch Shell 90BG Group 85

Financials HSBC Holdings plc 95Royal Bank of Scotland Group 91British Land Company 90

Barclays 89Great Portland Estates 87Standard Life 87

Old Mutual 85Lloyds Banking Group 85Segro 83Savills 81

Health Care GlaxoSmithKline 93Industrials Serco Group 88

Atkins 83Carillion 82Wolseley plc 82Kier Group 81

Information Technology Logica 92Materials Rio Tinto 86

Mondi PLC 84Anglo American 81

Telecommunications BT Group 84Cable and Wireless Worldwide 84Vodafone Group 81

Utilities Centrica 96Scottish & Southern Energy 87

Figure 11: The FTSE 350 CDLI 2011

Key:Companies highlighted in green are those that have been in the FTSE 350 CDLI for three consecutive years (2009-2011)Companies highlighted in orange have moved into the FTSE 350 CDLI index this year

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2011 Carbon Disclosure Leadership Index (CDLI)

The carbon disclosure leaders reported a much stronger understanding of the impact of climate change on their business, and as a result may derive a strategic advantage.

Tesco has the highest disclosure score in 2011 (97). The highest scores in previous years were 93 in 2010 and 92 in 2009. The average CDLI score in 2011 is 87 (85 in 2010), which is significantly higher than the average FTSE 350 score of 63. This also indicates that the quality and depth of responses continues to improve, despite the bar being raised each year by increasing the stringency of the scoring mechanism.

All ten industry sectors are represented in the CDLI again, confirming that high quality disclosure is possible regardless of sector. Financials have further increased their presence in the CDLI in 2011 with ten companies (2010: eight companies). The sector with the highest proportion of its respondents in the CDLI is Telecommunications with three out of five respondents (60%).

CDLI companies show consistent leadership across all areas of disclosure

As the overall quality of disclosure improved in 2011, the carbon disclosure leaders reported a much stronger understanding of the impact of climate

change on their business (as shown in Figure 12), and as a result may derive a strategic advantage.

Figure 12 compares the responses of the CDLI with the average FTSE 350 across six key areas of disclosure: emissions management, reporting, governance and strategy, opportunities, risks, and stakeholder engagement.

Generally, all companies score well on emissions management, emissions reporting and governance (average scores in these areas all exceeded 75 in 2011). Measurement and governance may be regarded as the early stages of a company’s approach to addressing the challenges presented by climate change. However, CDLI companies distinguish themselves from the overall population with significantly stronger responses in the areas of risks, opportunities and stakeholder engagement. CDLI companies are demonstrating their ability to identify new commercial opportunities based on their deep understanding of climate change issues and how these will impact their businesses by scoring on average 76 (overall, FTSE 350 companies scored 45).

Figure 12: Average disclosure score breakdown for the FTSE 350 – overall versus the CDLI

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Carbon Disclosure Project 2011 – FTSE 350 Report

The practice of reporting emissions and having them verified or assured will provide companies with the reliable data required to underpin efforts to achieve the UK Carbon Budgets.

Emissions managementA notable area of difference between the CDLI companies and the rest of the FTSE 350 is the practice of setting emissions reduction targets and the emphasis that CDLI companies are placing on this. Almost all (97%, 34) of the CDLI have emissions reduction targets in place compared to the overall population where 66% (138) have disclosed targets.

“In anticipation of Government action on climate change (e.g. the UK Climate Change Act), GSK has established ambitious climate change targets for GSK’s operations globally. GSK’s vision is to become a carbon neutral business across its value chain by 2050.”GlaxoSmithKline

Emissions reportingScores for emissions reporting were high across the FTSE 350 in 2011 (96), showing the value that they place on measuring and monitoring their emissions.

In 2011, the CDP information request placed particular emphasis on verification and assurance of emissions by companies. 92% of the CDLI have their Scope 1 and Scope 2 emissions verified (complete or underway) in the reporting year. The practice of reporting emissions and having them verified or assured will provide these companies with the reliable data required to underpin efforts to achieve the UK Carbon Budgets. The fact that these companies undertook the verification or assurance of their emissions is also a strong contributing factor to their inclusion in the CDLI.

“To manage the reputational impacts of legislation such as the CRC and the comparison of ICT with the aviation sector we have a programme supported by the Exec to decouple carbon from business growth, reduce the carbon intensity of our operations; improve energy efficiency and maximise on-site renewables by taking a longer term view of carbon management and costs.”Cable and Wireless Worldwide

Figure 13: Percentage of CDLI and overall FTSE companies disclosing opportunities and risks

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2011 Carbon Disclosure Leadership Index (CDLI)

Governance and StrategyGovernance continues to be a strong area for disclosure for both CDLI and non-CDLI companies in 2011, and forms a significant part of their corporate strategy as was the case in 2010. 100% of CDLI respondents stated that the board or senior management has responsibility for climate change in the company versus 96% (201) of the overall FTSE 350 respondents.

OpportunitiesCompanies in the CDLI have significantly higher disclosure scores on the opportunities that climate change presents than the rest of the FTSE 350. Despite this, identifying opportunities remains the lowest scoring area for all companies, and has remained at broadly the same level since last year. Those companies that identify opportunities may be better placed to capitalise on them as we shift towards a low carbon economy. Typically the opportunities cited by companies include the development of low carbon goods and services or increasing market share.

“There are a number of opportunities associated with driving down carbon emissions arising from our use of energy and our business travel footprint. Reducing our carbon emissions helps minimise our impact on the environment as well as keep our costs under control.”Lloyds Banking Group

“UK Government has ambitions and targets aimed at increasing the amount of renewable energy used. This provides an opportunity to develop a business more based on biomass fuels.”Drax Group

“Whilst physical climate parameters pose risks to our operations; they also present opportunities.”Lonmin

RisksCompanies in the CDLI are advanced by comparison with the non-CDLI companies in terms of their identification and reaction to risk. Companies identify a wide range of risks, including: technological advances not being fast enough; higher costs of energy or carbon emissions; regulatory requirements curtailing business development; and uncertainty regarding the extent and ambition of potential future requirements.

“To reduce and manage the potential financial implications of the regulatory risks we have a corporate target signed off by the Exec to reduce UK carbon emissions by 6% each year in 2011/12 and 2012/13 and then by 4% each year until 2019/20.”Cable and Wireless Worldwide

“Uncertainty surrounding new regulations is perhaps the greatest risk as politicians struggle to implement climate regulations.”Schroders

“Uncertainty on renewable energy subsidies affects our capital investment decisions.”Tesco

Stakeholder engagementLeading companies understand the importance of engaging with stakeholders. This area is a particular strength of CDLI companies compared to the overall FTSE 350 population: the average CDLI score is 83, relative to the overall average score of 47. The CDLI companies are demonstrating key strengths in identifying new commercial opportunities related to understanding climate change issues. They are highlighting how these will impact their businesses, who within their stakeholder groups are most likely to be affected, and how the company needs to respond to them.

“ Consumers and other stakeholders will increasingly judge companies on their policies and actions on climate change.” Marks & Spencer

26

This year, for the second time, all companies with a sufficiently high disclosure score received a performance band; the qualifying threshold to receive a performance band was a disclosure score of 50. Disclosure scores of less than 50 do not necessarily indicate poor performance; rather, they indicate insufficient information to evaluate performance. However, it can be assumed that companies which do not disclose are inactive on climate change.

Performance is grouped into six bands: A, A-, B, C, D and E (see Figure 14).

The Carbon Performance Leadership Index (CPLI) includes the companies in the highest performance band (A) and provides a valuable perspective on the range and quality of activities being performed by the FTSE 350 in response to climate change.

Eligibility for the CPLI (Band A) • Attainadisclosurescoreof50

or above

• Attainaperformancescore greater than 70

• Scoremaximumperformancepoints on question 13.1a (absolute emissions performance); at least a 2.65%7 reduction in carbon emissions must have been achieved as a result of emissions reduction activities over the last year

• DisclosegrossglobalScope1 and Scope 2 figures

• Scoremaximumperformance

points for verification of Scope 1 and Scope 2

Notes:

• BandA-(Aminus)companiesarenot in the CPLI. They are strong performers, with a performance score high enough to warrant inclusion in the CPLI but they do not meet all other CPLI requirements

• CDPreservestherighttoexclude a company from the CPLI if there is anything in its response that calls into question its suitability for inclusion

Performance scoring is an instructive exercise for all stakeholders. The score provides an indication of the extent to which companies are addressing the potential opportunities and risks presented by climate change. CDP recognises that this is a process that will evolve over time. It is important for investors to keep in mind that the carbon performance band is not:

• Ameasureofhowlowcarbonacompany is

• Anassessmentoftheextenttowhich a company’s actions have reduced carbon intensity relative to other companies in its sector

• Anassessmentofhowmateriala company’s actions are relative to the business; the score simply recognises evidence of action

It is possible to review individual company disclosures in addition to performance rankings in order to gain the most comprehensive understanding of company performance. A listing of companies and their bands is included in Appendix I. Companies that did not qualify for a performance band appear in Appendix I with a dash (-) in the performance band column.

More information can be found in the information request, supporting methodology and guidance documents, as well as within individual company responses at www.cdproject.net

7. The Intergovernmental Panel on Climate Change (IPCC) has set a target of 80% reduction in emissions by 2050, based on 1990 levels. This equates to a 2.65% annual reduction.

The 2011 Carbon Performance Leadership Index (CPLI)

Band A/A- (>70) Fully integrated climate change strategy driving significant maturity in climate change initiatives

Band B (>50) Integration of climate change recognised as priority for strategy, not all initiatives fully established

Band C (>30) Some activity on climate change with varied levels of integration of those initiatives into strategy

Band D (>15) Limited evidence of mitigation or adaptation initiatives and no/limited strategy on climate change

Band E (≤15) Little evidence of initiatives on carbon management potentially due to companies just beginning to take action on climate change

Per

form

ance

ban

d (A

is h

ighe

st)

No performance score allocated below a disclosure of 50%

Figure 14: Carbon performance elements

27

The 2011 Carbon Performance Leadership Index (CPLI)

In 2011, 236 FTSE 350 companies responded to CDP, seven of these attained FTSE 350 performance leader status as identified below. These companies represent six of the ten sectors.

Tesco, highlighted in orange, is the only company in the FTSE 350 CPLI for the second year running

Sector Company Also in the CDLI?

2011 Carbon Performance

Band

2010 Carbon Performance

BandConsumer Staples(2 companies, 11% of sector submission)

British American Tobacco

✓ A C

Tesco ✓ A AEnergy(1 company, 8% of sector submission)

BG Group ✓ A B

Financials(1 company, 2% of sector submission)

Great Portland Estates

✓ A B

Health Care(1 company, 14% of sector submission)

GlaxoSmithKline ✓ A B

Industrials(1 company, 3% of sector submission)

Serco Group ✓ A B

Telecommunications(1 company, 20% of sector submission)

Cable and Wireless Worldwide

✓ A B

Figure 15: The FTSE 350 CPLI 2011

In 2011, 236 FTSE 350 companies responded to CDP, seven of these attained FTSE 350 performance leader status as identified below. These companies represent six of the ten sectors.

In 2011, CDP raised the bar by enhancing the scoring methodology for both disclosure and performance questions to make the results more relevant to investors and other stakeholders. Overall, 166 (79%) FTSE 350 respondents received a performance score compared to 158 companies in 2010 (73%). However, as a consequence of more stringent CPLI entrance criteria on emissions reductions and verification, the number of companies included in the CPLI dropped from 13 to seven.

This is primarily the result of a change in focus of the performance scoring rather than a change in corporate performance. In 2010, the focus was

to measure the extent to which a company had a framework in place to address carbon management. This year, performance focused more on measuring the ambition and success of a company’s short and long-term actions to mitigate climate change.

Characteristics of Carbon Performance Leadership

Figure 16 provides a detailed view of the key indicators used to identify performance leaders. CPLI leaders tend to exhibit a comprehensive approach to climate change in the four areas of Governance, Strategy, Stakeholder Communication and Achievements.

Governance LeadersThe theme of this report, “Can UK Plc help meet the Carbon Budgets”, is most closely related to, and underpinned by, the governance and strategy of individual companies. Whilst all seven

of the CPLI have board or senior management responsibility for climate change within their business, the overall FTSE 350 responses also recognise that it is the management and board leadership which create the direction for the company and the focus of its employees.

All the leading performers consider monetary incentives an important way to promote action on climate change, compared to 57% of all FTSE 350 respondents.

“To reduce and manage the potential financial implications of the regulatory risks, we have a corporate target signed off by the Exec to reduce UK carbon emissions by 6% each year in 2011/12 and 2012/13 and then by 4 % each year until 2019/20.”Cable & Wireless Worldwide

28

Carbon Disclosure Project 2011 – FTSE 350 Report

CPLI companies all demonstrate the integration of their climate-related priorities into their overall business strategy. This is an area in which they significantly outperform the FTSE 350 respondents, where just 45% do the same.

Figure 16: Key indicators of performance leaders compared to all respondents

0% 20% 30%10% 40% 50% 60% 70% 90%80% 100%

Integration of climate change risks or opportunities into overall business strategy

Implementation of emissions reduction initiatives

Board or other senior management oversight

Monetary incentives

Verification of emissions

Disclosure of climate change information in mainstream filings or other external communications

Progress toward meeting targets

Significant emissions reduction in the past year

� FTSE 350 CPLI � FTSE350 respondents

Str

ateg

yG

over

nanc

eS

take

hold

er c

omm

unic

atio

nsA

chie

vem

ents

100%

45%

100%

91%

100%

96%

100%

57%

100%

25%

100%

29%

86%

53%

100%

38%

Strategic LeadersCPLI companies all demonstrate the integration of their climate-related priorities into their overall business strategy. This is an area in which they significantly outperform the FTSE 350 respondents, where just 45% do the same. All CPLI companies also disclosed targets aligned with emissions reduction initiatives. However, the gap reduced this year with 91% of FTSE

350 respondents disclosing at least one emissions reduction initiative, as opposed to just 58% in 2010.

At the same time, the total disclosed emissions for the FTSE 350 have decreased by 6.6% since 2010 and should provide a strong grounding for companies to reduce emissions further in the future in alignment with the UK Carbon Budgets.

29

“The UK Coalition Government is firmly committed to the move towards a Low Carbon Economy and is seeking to set a demanding policy framework which will create the long-term incentives required to enable investment in low carbon energy sources. Significant investment will be required in order to meet the UK Governments 2020 targets for CO2 emissions reductions and this will present significant opportunities. We have an opportunity to become a leading financer of renewable energy.”Lloyds Banking Group

Stakeholder Communication LeadersTo be eligible for inclusion in the CPLI, companies are required to score

maximum points for verification of Scope 1 and Scope 2. In contrast, only 25% of FTSE 350 respondents (versus 100% of CPLI companies) met all of CDP’s verification criteria in 2011. This dropped from 44% in 2010. In 2011, a number of criteria have been introduced that determine what is accepted as verification within CDP’s scoring methodology and so the decrease in numbers reflects this. The new criteria require that a verification statement is related to the relevant scope of emissions, clearly stating the type of verification that has been given and the standard used covers the current report year, and is undertaken by an independent third party.

Figure 17: Integration of climate change in corporate governance

128Board level responsibility

98%

Note: Not to scale

98Monetary incentives

75%

78 Integrated strategy

60%

77 Integrated strategy and board level responsibility

59%

97Board level responsibilityand monetary incentive

74%

67All 351%

67 Monetary incentives

and integrated strategy

51%

CDP encourages companies to obtain verification of their emissions and climate change responses to increase the quality of information published by companies and give greater confidence to investors, other stakeholders and to the management team.

“Our commitment to BREEAM Excellent for new build and Very Good for refurbishment projects along with the achievement of Level 3 Code for Sustainable Homes at residential developments allows us to market our properties to a wide cross section of potential tenants.”Great Portland Estates

“We believe that the potential financial opportunity of being ‘first-movers’ on product labelling could represent incremental growth in product sales.”Diageo

Leading AchievementsOnce the foundations are laid through strong governance, integrating climate change into the business strategy and stakeholder communications, the remaining, and possibly most important, area of leadership must be in demonstrating progress towards the corporate emissions reduction goals.

The CPLI companies have distinguished themselves from the rest of the FTSE 350 by making significant progress towards achieving their targets. 97% of companies have emissions reduction targets and 90% are making progress towards achieving these with ongoing emissions reduction activities. This is a significant change from 2010 where only 58% of companies had established emissions reduction targets and only 40% showed progress towards the target set. Fundamentally, this change in business approach to climate change will be critical if the UK is to achieve the goal set out in the Carbon Budgets.

The 2011 Carbon Performance Leadership Index (CPLI)

30

Appendix I: Table of emissions, scores and sector information by company

Table of emissions, scores and sector information by company.

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3i Group Financials AQ AQ 71 D 3282 745 2537 4220 TI Wa Tr X3i Infrastructure Financials AQ(SA) SA - - - - - - XA.G. Barr Consumer Staples NR AQ - - - - - -Aberdeen Asset Management

Financials AQ AQ 58 - NP - - - -

Aberforth Smaller Companies Trust

Financials DP AQ - - - - - -

Admiral Group Financials AQ AQ 46 - 6376 0 6376 577 Tr XAegis Group Consumer

DiscretionaryAQ NR 79 C 23566 877 22689 20072 Tr X Abs

and Int

Afren Energy NR NI - - - - - -African Barrick Gold

Materials NR NI - - - - - -

Aggreko Industrials DP AQ - - - - - -Alliance Trust Financials IN IN - - - - - -AMEC Energy AQ AQ 79 C 33920 13062 20858 21106 Tr ✓ Int

Amlin Financials AQ AQ 61 D 3322 285 3037 1629 Fu Wa Tr Oth

X

Anglo American Materials AQ AQ 81 C 19999891 9809076 10190815 177645320 Tr USP X Abs

Anglo Pacific Group Energy DP NR - - - - - -Antofagasta Materials AQ AQ 59 E 1294371 529560 764811 47373 Fu Tr Oth XAquarius Platinum Materials AQ AQ 65 C 576087 56720 519367 194397 TI XARM Holdings Information

TechnologyAQ AQ 49 - 10975 429 10546 4963 Tr X Int

Ashmore Group Financials NR NR - - - - - -Ashtead Group Industrials AQ AQ 30 - NP - - - -Associated British Foods

Consumer Staples AQ AQ 53 E 2956233 1905599 1050634 0 X Int

AstraZeneca Health Care AQ AQ 68 C 679391 385210 294181 365716 PGS TI Wa Tr USP

X Abs

Atkins Industrials AQ AQ 83 B 43948 22290 21658 12226 Tr ✓ Abs

Autonomy Information Technology

NR NR - - - - - -

Aveva Group Information Technology

DP IN - - - - - -

Avis Europe Industrials NR NR - - - - - -Aviva Financials AQ AQ 80 B 132412 63784 68628 15840 Tr EC ✓ Abs

Babcock International Group

Industrials AQ AQ 31 - 187034 38597 148438 0 X Abs

BAE Systems Industrials AQ AQ 56 - NP - - - -Balfour Beatty Industrials AQ AQ 78 C 472247 344092 128155 299675 PGS TI

Wa Tr EC SE

✓ Int

31

Appendix I: Table of emissions, scores and sector information by companyC

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Bankers Investment Trust

Financials AQ(SA) SA - - - - - - X

Barclays Financials AQ AQ 89 B 993000 57000 936000 110000 Tr ✓ Int

Barratt Developments

Consumer Discretionary

IN DP - - - - - -

BBA Aviation Industrials AQ AQ 48 - 138088 85559 52529 0 XBeazley Group Financials AQ AQ 48 - 45 45.49 0 2300 Tr EC

OthX

Bellway Consumer Discretionary

AQ AQ 41 - 5345566 897163 4448403 0 X

Berendsen Industrials AQ AQ 14 - NP - - - -Berkeley Group Holdings

Consumer Discretionary

AQ AQ 78 C 10000 3997 6003 3882 SE Oth X Abs

BG Group Energy AQ AQ 85 A 7974747 7951198 23549 88692000 USP ✓ Abs

BH Global (GBP) Financials DP DP - - - - - -BH Macro -Eur Financials NR(SA) DP - - - - - -BHP Billiton Materials AQ AQ 73 B 45731137 19591969 26139168 325311000 Fu USP ✓ Int

Big Yellow Group Financials NR AQ - - - - - -Blackrock World Financials AQ(SA) SA - - - - - - XBluebay Asset Management

Financials NR NR - - - - - -

Bluecrest Allblue Financials NR DP - - - - - -Bodycote International

Industrials NR NR - - - - - -

Booker Group Consumer Staples NR NI - - - - - -Bovis Homes Group

Consumer Discretionary

AQ AQ 41 - 1583 1029 554 840 Tr X Int

BP Energy AQ AQ 80 B 74920000 64920000 10000000 573000000 USP ✓Brit Insurance Holdings

Financials DP IN - - - - - -

British Airways Industrials AQ AQ 70 C 15370282 15255349 114933 516850 TI ¢ Abs and Int

British American Tobacco

Consumer Staples AQ AQ 91 A 743599 371610 371989 58518 Wa Tr Oth

✓ Int

British Assets Trust Financials AQ(SA) SA - - - - - - XBritish Empire Securities G-O

Financials NR NR - - - - - -

British Land Company

Financials AQ AQ 90 A- 34317 1696 32621 96115 Fu Tr Oth ✓ Int

British Sky Broadcasting

Consumer Discretionary

AQ AQ 90 B 152580 27462 125118 0 Oth ✓ Int

Britvic Consumer Staples AQ AQ 69 - NP - - - -BSS Group Industrials AQ(SA) DP - - - - - - XBT Group Telecommunications AQ AQ 84 B 1674583 204497 1470086 48434 Wa Tr

OthX Abs

and Int

BTG Health Care AQ AQ 40 - 2808 103 2705 0 X

Carbon Disclosure Project 2011 – FTSE 350 Report

32

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Bunzl Industrials AQ AQ 78 B 131533 100621 30912 32306 Wa Tr TSP

✓ Int

Burberry Group Consumer Discretionary

AQ AQ 62 E 32021 2903 29118 4474 Tr X Int

Cable & Wireless Communications

Telecommunications AQ NI - - 0 0 0 0 X

Cable & Wireless Worldwide

Telecommunications AQ AQ 84 A 211167 6205 204962 27451 Fu TI Wa Tr EC Oth

✓ Abs

Cairn Energy Energy AQ AQ 73 C 151659 151181 478 602 Tr ✓Caledonia Investments

Financials DP DP - - - - - -

Capita Group Industrials AQ AQ 79 C 58202 5263 52939 22914 Tr ✓ Int

Capital & Counties Properties

Financials NR NI - - - - - -

Capital Shopping Centres Group

Financials AQ AQ 63 C 44551 6047 38504 0 ✓ Abs

Carillion Industrials AQ AQ 82 B 231279 203165 28114 11452 Tr Oth ✓ Int

Carnival Consumer Discretionary

AQ AQ 88 B 10748637 10700267 48370 46246 PGS Wa Tr

✓ Int

Carpetright Consumer Discretionary

NR AQ - - - - - -

Catlin Group Financials AQ AQ 72 D 6174 842 5332 5884 PGS Wa Tr Oth

X

Centamin Egypt Materials NR NI - - - - - -Centrica Utilities AQ AQ 96 A- 10714959 10559082 155877 8992 Tr Oth ✓ Abs

and Int

Charter International

Industrials DP NR - - - - - -

Chemring Group Industrials AQ AQ 34 - 55447 0 55447 0 X IntCity of London Investment Trust

Financials AQ(SA) SA - - - - - - X

Close Brothers Group

Financials NR DP - - - - - -

Cobham Industrials AQ AQ 70 C 155918 92525 63393 309908 Fu Tr X IntCOLT Telecom Group

Telecommunications AQ AQ 59 - NP - - - -

Compass Consumer Discretionary

AQ AQ 42 - 96121 85868 10253 0 X Int

Computacenter Information Technology

AQ AQ 59 - NP - - - -

Cookson Group Industrials DP NR - - - - - -CPPGroup Consumer

DiscretionaryNR NI - - - - - -

Cranswick Consumer Staples AQ AQ 58 - NP - - - -Croda International Materials AQ AQ 58 E 217597 159032 58565 0 X

CSR Information Technology

DP NR - - - - - -

Daejan Holdings Financials DP DP - - - - - -

33

Appendix I: Table of emissions, scores and sector information by companyC

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Daily Mail & General Trust

Consumer Discretionary

AQ AQ 39 - 78100 15400 62700 24400 Tr TSP X Abs

Dairy Crest Group Consumer Staples AQ AQ 76 C 240235 159477 80758 2809119 PGS TI Tr

✓ Int

De La Rue Industrials AQ AQ 46 - NP - - - -Debenhams Consumer

DiscretionaryAQ AQ 68 D 196827 18664 178163 17020 PGS TI

Wa Tr X

Derwent London Financials AQ AQ 76 C 6533 3759 2774 21659 Fu Tr Ld Oth

X Int

Devro Consumer Staples DP NR - - - - - -Dexion Absolute Financials DP DP - - - - - -Diageo Consumer Staples AQ AQ 89 A- 724509 619161 105348 200000 TI X AbsDignity Consumer

DiscretionaryAQ AQ 64 E 23736 16798 6938 0 X

Dimension Data Holdings

Information Technology

AQ(L) AQ - - - - - -

Dixons Retail Consumer Discretionary

NR(SA) NI - - - - - -

Domino Printing Sciences

Information Technology

AQ NR 58 E 4977 1906 3070 0 Oth X

Dominos Pizza Consumer Discretionary

AQ AQ 66 E 94012 53806 40206 31628 Wa Tr EC Oth

X

Drax Group Utilities AQ AQ 50 D 22391000 22391000 0 242037 TI X IntDS Smith Materials AQ AQ 54 - NP - - - -Dunelm Group Consumer

DiscretionaryNR NR - - - - - -

Easyjet Industrials NR NR - - - - - -Edinburgh Dragon Trust

Financials AQ(SA) SA - - - - - - X

Edinburgh Investment Trust

Financials AQ(SA) SA - - - - - - X

Electra Private Equity

Financials AQ AQ - - 0 0 0 0 X

Electrocomponents Information Technology

AQ AQ 76 B 22956 4323 18633 2411 Tr X

Elementis Materials IN IN - - - - - -

EnQuest Energy DP NI - - - - - -Enterprise Inns Consumer

DiscretionaryAQ AQ 57 D 600 600 0 0 X Abs

Essar Energy Utilities AQ(SA) NI - - - - - - XEurasian Natural Resources

Materials DP DP - - - -

Euromoney Institutional Investors

Consumer Discretionary

AQ AQ 38 - 2970 210 2760 3580 Tr X Abs

Experian Group Industrials AQ AQ 74 B 63861 8590 55271 15731 Tr ✓ Int

F&C Asset Management

Financials AQ AQ 60 C 400 0 400 661 Tr X Abs

Carbon Disclosure Project 2011 – FTSE 350 Report

34

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F&C Commercial Property Trust

Financials AQ(SA) SA - - - - - - X

Fenner Industrials NR NR - - - - - -Ferrexpo Materials NR NR - - - - - -Fidelity China Special Situations

Financials NR NI - - - - - -

Fidelity European Values

Financials NR DP - - - - - -

Fidessa Group Information Technology

NR NR - - - - - -

Filtrona Materials AQ AQ 57 D 63800 6564 57236 0 X Int

FirstGroup Industrials AQ AQ 60 C 3007391 2630341 377050 3390 Tr ✓ Abs

Foreign & Colonial Investment Trust

Financials AQ(SA) SA - - - - - - X

Forth Ports Industrials NR AQ - - - - - -Fresnillo Materials AQ AQ 63 - NP - - - -G4S Industrials AQ AQ 42 - 538946 415031 123914 0 Oth X IntGartmore Group Financials NR NI - - - - - -Genesis Emerging Markets Fund

Financials NR NI - - - - - -

Genus Health Care NR DP - - - - - -GKN Consumer

DiscretionaryAQ AQ 59 - NP - - - -

GlaxoSmithKline Health Care AQ AQ 93 A 2007715 1001746 1005969 4923155 TI Tr USP Oth

✓ Abs and Int

Go-Ahead Group Industrials DP AQ - - - - - -Grainger Financials AQ AQ 69 D 739355 228099 511256 59771 Tr X IntGreat Portland Estates

Financials AQ AQ 87 A 5872 1758 4114 13 Tr ✓ Int

Greene King Consumer Discretionary

AQ AQ 63 C 148441 52049 96392 0 X Abs

Greggs Consumer Staples AQ AQ 71 - NP - - - -

Halfords Group Consumer Discretionary

IN IN - - - - - -

Halma Information Technology

NR NR - - - - - -

Hammerson Financials AQ AQ 63 C 65312 4726 60586 0 Oth X Int

Hansteen Holdings Financials NR NI - - - - - -Hargreaves Lansdown

Financials NR NR - - - - - -

Hays Industrials AQ AQ 48 - NP - - - -Henderson Group Financials AQ AQ 67 D 2375 126 2248 0 Oth X Int

Herald Investment Trust

Financials NR NR - - - - - -

Heritage Oil Energy AQ(L) NR - - - - - -

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Appendix I: Table of emissions, scores and sector information by companyC

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Hikma Pharmaceuticals

Health Care AQ AQ 39 - 15076 3180 11896 0 X Abs and Int

Hiscox Financials NR AQ - - - - - -Hochschild Mining Materials DP NR - - - - - -Home Retail Group Consumer

DiscretionaryAQ AQ 72 C 324025 135915 188110 1361 Tr ✓ Int

Homeserve Consumer Discretionary

NR AQ - - - - - -

Howden Joinery Group

Consumer Discretionary

NR NI - - - - - -

HSBC Holdings Financials AQ AQ 95 A- 831642 84025 747617 91814 Tr ✓ Int

HSBC Infrastructure Financials AQ(SA) SA - - - - - - XHunting Energy AQ AQ 11 - NP - - - -Icap Financials NR DP - - - - - -IG Group Holdings Financials DP NR - - - - - -Imagination Technologies

Information Technology

NR DP - - - - - -

IMI Industrials AQ AQ 57 E 97000 27000 70000 0 X IntImpax Environmental Markets

Financials AQ AQ 56 E 56 0 56 118 Tr X

Imperial Tobacco Group

Consumer Staples AQ AQ 71 D 266544 112299 154245 0 X Abs

Inchcape Consumer Discretionary

AQ AQ 15 - 0 0 0 0 X

Informa Consumer Discretionary

AQ AQ 63 - NP - - - -

Inmarsat Telecommunications NR AQ - - - - - -

Intercontinental Hotels Group

Consumer Discretionary

AQ AQ 76 B 4600000 2300000 2300000 4400000 Wa X Int

Intermediate Capital Group

Financials AQ AQ 36 - 842 24 818 1577 Tr X

International Personal Finance

Financials AQ AQ 68 D 24686 19525 5161 1301 Tr X Int

International Power Utilities AQ AQ 51 - NP - - - -International Public Partnerships

Financials NR NR - - - - - -

Intertek Group Industrials NR NR - - - - - -Invensys Industrials AQ AQ 68 C 100074 21255 78819 24530 Tr ✓ Abs

Investec Financials AQ(SA) SA - - - - - - XITE Group Industrials NR DP - - - - - -ITV Consumer

DiscretionaryDP AQ - - - - - -

J Sainsbury Consumer Staples AQ AQ 43 - 843055 204688 638367 0 X IntJardine Lloyd Thompson Group

Financials DP NR - - - - - -

JD Sports Fashion Consumer Discretionary

IN IN - - - - - -

Carbon Disclosure Project 2011 – FTSE 350 Report

36

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JKX Oil and Gas Energy AQ AQ 37 - 138204 128569 9635 9695 Fu TI Tr XJohnson Matthey Materials AQ AQ 65 D 414903 154932 259971 42260 Tr TSP X Abs

JPMorgan Asian Investment Trust

Financials AQ(SA) SA - - - - - - X

JPMorgan Emerging Mkts Inv Trust

Financials AQ(SA) SA - - - - - - X

JPMorgan Indian Investment Trust

Financials AQ(SA) SA - - - - - - X

JPMorgan Russian Sec

Financials AQ(SA) SA - - - - - - X

Jupiter Fund Management

Financials AQ NI 30 - 499 6 493 731 Wa Tr X

Kazakhmys Materials NR NR - - - - - -

Keller Industrials AQ DP 52 D 1854 1422 432 0 XKenmare Resources

Materials NR NR - - - - - -

Kesa Electricals Consumer Discretionary

NR NR - - - - - -

Kier Group Industrials AQ AQ 81 B 75009 65890 9119 7884 Tr X IntKingfisher Consumer

DiscretionaryAQ AQ 85 B 471906 141655 330251 42300 Wa Tr

Oth✓ Int

Ladbrokes Consumer Discretionary

AQ AQ 47 - NP - - - -

Laird Information Technology

AQ AQ 59 E 42184 2677 39507 0 X Int

Lamprell Energy AQ DP 18 - 0 0 0 0 XLancashire Holdings

Financials NR NR - - - - - -

Land Securities Financials AQ AQ 60 D 122099 21173 100926 0 X Int

Law Debenture Financials AQ AQ 15 - 0 0 0 0 XLegal & General Group

Financials AQ AQ 67 - NP - - - -

Lloyds Banking Group

Financials AQ AQ 85 B 406497 73182 333315 36038 Tr X Abs

Logica Information Technology

AQ AQ 92 A- 90920 33944 56976 2776 SE Oth X Abs

London Stock Exchange

Financials AQ AQ 23 - 0 0 0 2104 Tr X

Lonmin Materials AQ AQ 65 C 1530286 102130 1428156 4080 Fu X IntMan Group Financials AQ AQ 65 D 11345 1226 10119 2765 Tr ½Marks & Spencer Group

Consumer Discretionary

AQ AQ 75 B 641000 223000 418000 15000 Tr ✓ Abs and Int

Marstons Consumer Discretionary

AQ AQ 53 - NP - - - -

McBride Consumer Staples AQ AQ 45 - 65881 12811 53070 0 X Int

37

Appendix I: Table of emissions, scores and sector information by companyC

om

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Meggitt Industrials AQ AQ 39 - NP - - - -

Melrose Industrials NR DP - - - - - -

Melrose Resources Energy NR NR - - - - - -

Mercantile Investment Trust

Financials NR NR - - - - - -

Merchants Trust Financials AQ(SA) SA - - - - - - X

Michael Page International

Industrials DP AQ - - - - - -

Micro Focus International

Information Technology

AQ AQ 38 - NP - - - -

Millennium & Copthorne Hotels

Consumer Discretionary

AQ DP 62 D 321319 73754 247565 8264 Wa X

Misys Information Technology

AQ AQ 9 - NP - - - -

Mitchells & Butlers Consumer Discretionary

AQ AQ 28 - NP - - - -

MITIE Group Industrials AQ AQ 73 B 47976 44248 3728 12340 Fu Tr Lu Oth

X

Mondi Group Materials AQ AQ 84 B 5863953 4450294 1413659 1052333 PGS TI Tr EC TSP

✓ Int

Moneysupermarket.com Group

Information Technology

NR AQ - - - - - -

Monks Investment Trust

Financials NR DP - - - - - -

Morgan Crucible Industrials AQ AQ 70 C 427860 160967 266893 0 X IntMorrison Supermarkets

Consumer Staples AQ AQ 70 B 1341482 537728 803754 93355 Wa Tr EC X Abs

Mothercare Consumer Discretionary

AQ AQ 58 D 33689 8019 25670 45 Wa X Abs

Murray Income Trust

Financials AQ(SA) SA - - - - - - X

Murray International Trust

Financials AQ(SA) SA - - - - - - X

N Brown Group Consumer Discretionary

AQ AQ 77 C 13176 3346 9830 11761 Wa Tr EC TSP SE

Oth

X Abs and Int

National Express Group

Industrials AQ AQ 66 - NP - - - -

National Grid Utilities AQ AQ 63 D 9658188 9328836 329352 32370591 PGS USP Oth

X Abs and Int

Next Consumer Discretionary

AQ AQ 87 - NP - - - -

Northumbrian Water Group

Utilities AQ AQ 73 B 241952 29279 212673 6097 PGS Tr ½ Abs

Ocado Group Consumer Discretionary

NR NI - - - - - -

Old Mutual Financials AQ AQ 85 B 682976 10364 672612 34264 Tr EC TSP SE

✓ Int

Carbon Disclosure Project 2011 – FTSE 350 Report

38

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Pace Consumer Discretionary

AQ AQ 74 D 3836 309 3527 4577 Tr USP ✓ Int

Paragon Group of Companies

Financials NR NR - - - - - -

Partygaming Consumer Discretionary

NR DP - - - - - -

Pearson Consumer Discretionary

AQ AQ 64 D 157928 35739 122189 36816 Wa Tr X Abs

Pennon Group Utilities AQ AQ 76 B 788277 622446 165831 10986 Wa Tr Oth

✓ Abs

Perpetual Income & Growth Investment Trust

Financials AQ(SA) SA - - - - - - X

Persimmon Consumer Discretionary

AQ AQ 59 C 14015 9347 4667 0 X

Petrofac Energy AQ AQ 53 E 214121 191548 22573 0 X

Petropavlovsk Materials AQ NR 47 - 182868 182868 0 0 X

Phoenix Group Holdings

Financials NR NI - - - - - -

Polar Capital Partners

Financials NR DP - - - - - -

Premier Farnell Information Technology

AQ AQ 80 B 22326 3663 18663 4217 Tr ✓ Abs

Premier Foods Consumer Staples AQ AQ 49 - NP - - - -Premier Oil Energy AQ AQ 66 D 351911 350421 1490 181 Tr XProvident Financial Financials AQ AQ 70 B 7104 2098 5006 2841 Tr ✓

Prudential Financials AQ AQ 58 E 108099 14839 93260 5029 Tr X

Punch Taverns Consumer Discretionary

DP AQ - - - - - -

PZ Cussons Consumer Staples AQ AQ 39 - NP - - - -Qinetiq Group Industrials AQ AQ 69 - NP - - - -

Randgold Resources

Materials AQ AQ 80 C 212836 212315 521 18377 TI Tr SE ✓ Int

Rank Group Consumer Discretionary

NR NR - - - - - -

Rathbone Brothers Financials AQ AQ 63 - NP - - - -

Reckitt Benckiser Consumer Staples AQ AQ 81 B 290587 104813 185774 25928065 PGS TI Wa Tr

TSP USP DSP Ld

Oth

X Int

Redrow Consumer Discretionary

AQ AQ 68 C 7079 4334 2745 479 Tr X Abs

Reed Elsevier Consumer Discretionary

AQ AQ 82 A- 161447 13131 148316 420755 Tr SE Oth

✓ Int

Regus Group Industrials NR NR - - - - - -

Renishaw Information Technology

AQ AQ 42 - NP - - - -

Rentokil Initial Industrials AQ AQ 64 D 269374 227857 41517 0 X

39

Appendix I: Table of emissions, scores and sector information by companyC

om

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Resolution Financials AQ AQ 70 D 9581 2282 7299 1162 Tr X IntRestaurant Group Consumer

DiscretionaryNR DP - - - - - -

Rexam Materials AQ AQ 46 - NP - - - -

Rightmove Consumer Discretionary

NR NR - - - - - -

Rio Tinto Materials AQ AQ 86 B 44600000 27600000 17000000 492000000 PGS Fu TI USP

✓ Int

RIT Capital Partners Financials NR DP - - - - - -

Rolls-Royce Industrials AQ AQ 75 B 592123 232009 360114 175056020 TI Tr USP X Abs and Int

Rotork Information Technology

AQ AQ 65 D 4459 1061 3398 907 Tr X Abs

Royal Bank of Scotland Group

Financials AQ AQ 91 B 708325 84290 624034 143404 Fu Tr ✓ Abs

Royal Dutch Shell Energy AQ AQ 90 A- 85000000 75000000 10000000 690000 Fr Oth ✓ Abs

RPS Group Industrials AQ AQ 64 D 14196 8120 6076 2775 Tr X IntRSA Insurance Group

Financials AQ AQ 61 D 48984 16544 32440 17151 PGS Fu Wa Tr EC

Oth

✓

SABMiller Consumer Staples AQ AQ 63 C 2353868 1144900 1208967 261307 TI X IntSage Group Information

TechnologyAQ NR 63 D 28269 1722 26547 0 X

Salamander Energy Energy NR DP - - - - - -Savills Financials AQ AQ 81 C 903 81 822 1399 Tr EC X

Schroder Asiap-O Financials AQ(SA) SA - - - - - - ✓

Schroders Financials AQ AQ 61 D 8623 1087 7536 4910 Tr X Abs

Schroders N/V Financials AQ AQ 61 D 8623 1087 7536 4910 Tr X Abs

Scottish & Southern Energy

Utilities AQ AQ 87 B 26119153 24517024 1602129 0 Oth ½ Abs and Int

Scottish Investment Trust

Financials NR NR - - - - - -

Scottish Mortgage Investment Trust

Financials NR DP - - - - - -

SDL Information Technology

IN DP - - - - - -

Segro Financials AQ AQ 83 C 19042 1638 17404 258 Tr X IntSenior Industrials AQ AQ 43 - 51796 9171 42625 1813 Tr X IntSerco Group Industrials AQ AQ 88 A 111375 41822 69553 18932 Tr ✓ Int

Severn Trent Utilities AQ AQ 69 C 578294 165972 412322 1445 Tr Oth X AbsShaftesbury Financials AQ AQ 67 B 1297 0 1297 5 Tr X Abs

and Int

Shanks Group Industrials AQ IN 52 - NP - - - -

Shire Health Care AQ AQ 72 D 62186 25713 36473 27270 Tr Lu X

Carbon Disclosure Project 2011 – FTSE 350 Report

40

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SIG Industrials AQ AQ 56 C 117013 89676 27337 323 Tr X AbsSmith & Nephew Health Care AQ DP 61 C 76571 10911 65660 0 X AbsSmiths Group Industrials AQ AQ 30 - 118683046 99414248 19268798 0 X AbsSoco International Energy NR DP - - - - - -

Spectris Information Technology

AQ IN 71 - NP - - - -

Spirax-Sarco Engineering

Industrials AQ AQ 65 - NP - - - -

Spirent Communications

Information Technology

NR NR - - - - - -

Sportingbet Consumer Discretionary

NR NI - - - - - -

Sports Direct International

Consumer Discretionary

NR DP - - - - - -

SSL International Health Care AQ(SA) AQ - - - - - - X

St Modwen Props Financials NR IN - - - - - -St.James Place Financials AQ AQ 62 D 3240 703 2537 4897 PGS Wa

Tr EC X Int

Stagecoach Group Industrials AQ AQ 71 B 1221431 877313 344118 0 X Abs and Int

Standard Chartered Financials AQ AQ 77 B 257673 6318 251355 56685 Tr X IntStandard Life Financials AQ AQ 87 B 22081 3592 18489 3896 Tr ✓ Abs

and Int

Sthree Industrials DP DP - - - - - -Stobart Group Industrials NR NR - - - - - -

SuperGroup Consumer Discretionary

DP NI - - - - - -

SVG Capital Financials DP DP - - - - - -

Synergy Health Health Care AQ AQ 57 - NP - - - -

TalkTalk Telecom Group

Telecommunications AQ NI 61 - NP - - - -

Talvivaara Mining Company

Materials AQ AQ 56 E 221513 160160 61353 0 X

Tate & Lyle Consumer Staples AQ AQ 62 B 3554448 2291908 1262540 0 X IntTaylor Wimpey Consumer

DiscretionaryAQ NR 61 D 34097 10194 23903 425741 PGS X

Telecity Group Information Technology

AQ NR 15 - NP - - - -

Temple Bar Investment Trust

Financials AQ(SA) SA - - - - - - X

Templeton Emerging Markets IT

Financials AQ(SA) NR - - - - - - X

Tesco Consumer Staples AQ AQ 97 A 5373062 1889765 3483297 62233 Tr ✓ Abs and Int

41

Appendix I: Table of emissions, scores and sector information by companyC

om

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Thomas Cook Group

Consumer Discretionary

AQ AQ 78 C 4391205 4336470 54735 10304 Wa Oth X Abs and Int

TR Property Investment Trust

Financials AQ(SA) NR - - - - - - X

Travis Perkins Industrials AQ AQ 63 D 154637 89440 65197 5940 Tr In X IntTUI Travel Consumer

DiscretionaryAQ AQ 85 A- 6100123 5981254 118869 3912 Tr EC

Oth✓ Abs

Tullett Prebon Group

Financials DP NR - - - - - -

Tullow Oil Energy AQ AQ 50 D 294531 294531 0 0 ✓

UK Commercial Property Trust

Financials DP DP - - - - - -

Ultra Electronic Holdings

Industrials DP DP - - - - - -

Unilever Consumer Staples AQ AQ 79 B 2599158 1125515 1473643 0 X IntUnite Group Financials NR NI - - - - - -

United Business Media

Consumer Discretionary

AQ AQ 59 D 8294 495 7799 16 Fu Wa X

United Utilities Utilities AQ AQ 79 B 537095 153269 383826 2820 Tr Oth ✓ Abs

Vedanta Resources Materials AQ NR 62 C 32475715 31675465 800250 0 XVictrex Materials NR NR - - - - - -

Vodafone Group Telecommunications AQ AQ 81 B 2325463 414121 1911342 2295731 Tr In ✓ Abs

Weir Group Industrials AQ NR 40 - 133400 47126 86274 0 XWellstream Holdings

Energy AQ(SA) AQ - - - - - - X

Wetherspoon Consumer Discretionary

AQ AQ 71 C 201544 56638 144906 53860 Wa Tr X Int

WH Smith Consumer Discretionary

AQ AQ 62 C 58239 7592 50647 796 Tr X Abs

Whitbread Consumer Discretionary

AQ AQ 75 C 206053 53431 152622 0 Oth X Int

William Hill Consumer Discretionary

DP DP - - - - - -

Witan Investment Trust

Financials DP DP - - - - - -

Wolseley Industrials AQ AQ 82 B 807217 447148 360069 6173 Wa Tr ✓ Abs

Wood Group Energy AQ DP 68 D 7733 1763 5969 2515 Tr ✓WPP Consumer

DiscretionaryAQ AQ 65 D 166124 9375 156749 85848 Tr Oth X Int

Xchanging Information Technology

AQ AQ 56 - NP - - - -

Xstrata Materials AQ AQ 75 - NP - - - -Yell Consumer

DiscretionaryAQ AQ 69 C 32561 2404 30158 89404 TI Tr

DSP Oth✓ Abs

Yule Catto & Co Materials NR NR - - - - - -

42

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Aga Rangemaster Group

Consumer Discretionary

AQ AQ 71 C 28849 13531 15318 0 X Int

Costain Group Industrials AQ AQ 66 C NP 5438 Tr X Abs Int

Dialight Information Technology

AQ 25 0 X

Fiberweb Consumer Staples AQ AQ 44 NP 0 XFortune Oil Energy AQ AQ 42 24952 7527 17425 240 Tr XGalliford Try Industrials AQ AQ 56 C NP 0 XHolidaybreak Consumer

DiscretionaryAQ AQ 61 D 11709 5850 5859 0 X

Hyder Consulting Industrials AQ AQ 54 D 4432 456 3976 1637 Tr X Abs Interserve Industrials AQ AQ 74 C 33056 27312 5744 7892 Fu Tr EC X IntJohnston Press Consumer

DiscretionaryAQ AQ 48 NP 0 X

KCOM Telecommunications AQ NR 52 D 24566 3244 21321 1072 Wa Tr X AbsLSL Property Services

Financials AQ DP 31 7223 7223 0 0 X

Marshalls Materials AQ AQ 65 C 66037 43165 22872 54 Tr X Abs Int

Mecom Group Consumer Discretionary

AQ AQ 28 NP 0 X

Morgan Sindall Industrials AQ AQ 61 C 63427 35395 28032 10243 TI Wa Tr Oth

✓

Mouchel Group Industrials AQ AQ 51 C NP 9361 Tr X IntRobert Wiseman Dairies

Consumer Staples AQ 46 NP 7472 TI Tr X Abs Int

Speedy Hire Industrials AQ AQ 40 29797 24436 5361 0 X AbsTed Baker Consumer

DiscretionaryAQ AQ 64 D 3707 146 3560 37860 PGS Wa

Tr Oth X

Trinity Mirror Consumer Discretionary

AQ 61 C 56344 5419 50925 13627 TI Tr TSP Oth

X Abs

UK Mail Industrials AQ AQ 42 54000 36000 18000 0 X AbsUTV Media Consumer

DiscretionaryAQ AQ 64 D 3697 969 2728 120 Tr X Abs

Vectura Group Health Care AQ NR 30 NP 0 X AbsWincanton Industrials AQ AQ 56 C NP 93500 TI X AbsWorkspace Group

Financials AQ AQ 65 C 17687 4399 13288 0 X Abs

WSP Group Industrials AQ AQ 71 C 12043 1362 10681 13572 Eq Tr X AbsXP Power Information

TechnologyAQ 35 824 824 0 X Abs

The following tables contains the emissions, scores and sector information by company for FTSE All-Share companies that responded to CDP, but were not part of the FTSE 350.

43

Appendix II: Largest non-respondents by market cap in 2011

Sector Company8

Consumer Discretionary ITVFinancials Icap

Hargreaves LansdownIndustrials Aggreko

Intertek Group

Information Technology AutonomyMaterials Eurasian Natural Resources

KazakhmysFerrexpo

Telecommunications Inmarsat 8. Companies highlighted in yellow have not responded for two or more consecutive years.

AQ Answered questionnaire

AQ(L) Answered questionnaire late

AQ(SA) Response covered by another company

DP Declined to participate

IN Provided information relevant to some questions asked but not in format requested

NP Answered questionnaire but response not made publicly available

NR No response – Company has not provided

information or the information has not been made publicly available

* Company provided a figure for scope 2 contract arrangements

X No verification or assurance, or verification undertaken did not meet CDP’s verification requirements. For more details, please see www.cdproject.net/verification

✓ Verification complete for reporting

year

¢ Verification ongoing for reporting year - first year started

½ Verification ongoing for reporting year - prior year(s) completed

Scope 3 Source Key:

DSP End of life treatment of sold products

EC Employee commuting

Eq Capital goods

Fr Franchises

Fu Fuel energy – related activities not included in Scope 2

In Investment

Ld Leased assets (downstream) Lu Leased assets (upstream)

Oth Other

PGS Purchased goods and services

PSP Processing sold products

SE Supplier emissions

TI Transportation and distribution (goods and services)

Tr Business travel

TSP Transportation and distribution of sold products inc. warehousing and retail

USP Use of sold products

Wa Waste generated in operationsFootnotes for Appendix I

1. Total of Scope 1 and Scope 2 reported emissions.2. The verification/assurance key provided for each

company is based on the CDP’s criteria. If a company had more than one level of completion of verification/assurance across the different scopes, the highest level was used for purposes of the key. Moving from highest to lowest levels of verification/assurance:

- complete; - prior year(s) complete; - first year started; and - no verification/assurance.3. Those companies marked AQ(L) in 2011 submitted responses after the analysis cut off date of July 1, 2011. These companies’

responses are not included in the analysis of this report. PwC presents the overall scores in this report but confirms that we were not involved with the detailed scoring for these companies.

Key to Appendix I

44

Sample: geography/number of companies

Key Trends Indicators Asi

a ex

-JIC

K 1

70*4

Aus

tral

ia 2

00

Ben

elux

150

**

Bra

zil 8

0

Can

ada

200

Cen

tral

& E

aste

rn E

uro

pe

100

Chi

na 1

00

Em

erg

ing

Mar

kets

800

Eur

op

e 30

0

FTS

E A

ll-W

orl

d 8

00

Fran

ce 2

50

Ger

man

y an

d A

ustr

ia 2

50 *

Glo

bal

500

Glo

bal

Ele

ctri

c U

tilit

ies

250

Glo

bal

Tra

nsp

ort

100

Iber

ia 1

25

% of sample answering CDP 20113 25 49 34 67 53 20 8 34 89 75 33 50 81 38 41 36

Number of companies answering CDP 20113 43 99 51 53 106 20 8 271 268 590 82 126 404 96 41 45

Gov

erna

nce % of responders with Board or other

executive level responsibility for climate change

68 74 80 79 57 40 75 72 85 71 81 64 73 78 66 82

% of responders with incentives for the management of climate change issues

46 53 61 45 42 30 75 55 70 71 64 38 72 61 71 58

Str

ateg

y

% of responders with climate change integrated into their business strategy

83 83 89 81 72 60 88 79 91 88 87 69 90 93 90 98

% of responders engaging policymakers on climate issues to encourage mitigation or adaptation

68 74 78 70 63 20 38 68 83 80 76 54 84 92 83 73

Targ

ets

& In

itiat

ives

% of responders with emissions reduction targets

71 45 70 30 32 60 38 56 81 75 68 48 76 61 73 67

% of responders with absolute emissions reduction targets

44 27 41 26 16 30 13 33 42 43 35 28 44 43 37 33

% of responders with active emissions reduction initiatives in the reporting year

90 88 91 83 86 50 88 82 96 95 96 73 97 87 95 96

% of responders indicating that their products and services directly help third parties to avoid GHG emissions

66 60 65 60 52 30 50 54 68 69 64 62 70 81 56 80

Ris

ks &

O

pp

ortu

nitie

s % of responders seeing regulatory risks 76 81 76 77 66 60 63 79 79 74 79 56 79 94 85 87

% of responders seeing regulatory opportunities

76 74 83 83 68 50 63 76 87 78 87 68 81 93 78 89

Em

issi

ons

Dat

a

% of responders whose absolute emissions (Scope 1 & 2) have decreased compared to last year due to emissions reduction activities

27 29 48 11 27 40 13 31 48 46 37 19 48 24 34 56

% of responders independently verifying any portion of Scope 1 emissions data7

49 45 70 45 32 40 13 44 74 61 65 40 67 67 68 85

% of responders independently verifying any portion of Scope 2 emissions data7

54 45 65 43 20 30 0 42 69 57 54 34 61 35 59 85

This table outlines some of the key findings from CDP 2011 by geography or industry data-set.2

Appendix III: Global Key Trends Summary1

45

1. The key trends table provides a snapshot of response trends based on headline data. That is, responses given to main questions without assessment of detailed explanations in follow up questions. The numbers in this table are based on the online responses submitted to CDP as of 11 July 2011. They may therefore differ from numbers in the rest of the report which are based on the number of companies which responded by the applicable local deadline (e.g. 30 June 2011). Please refer to the CDP website and the local reports for an updated version of this table.

2. In some cases, the number of companies in a sample may differ slightly from the named sample size due to takeovers, mergers, acquisitions and duplicate share listings.

3. Includes offline responses to the CDP 2011 questionnaire and indirect answers submitted by parent companies. All other key trend indicators are based on direct and online company responses only.

4. Asia excluding Japan, India, China and Korea (ex-JICK). 5. Due to major disruptions caused by the tsunami the deadline

for the Japan 500 sample was extended until 31 August 2011. Therefore, the values in this table do not represent the final numbers but interim figures as of 11 July 2011.

6. Includes responses across all samples as well as responses submitted by companies not included in specific geographic or industry samples in 2011.

7. This takes into account companies reporting that data verification is either complete of underway.

* Denotes change in number of companies in sample compared to previous year.

**Denotes new sample for 2011.

Sample: geography/number of companies

Ind

ia 2

00

Irel

and

40

Ital

y 10

0*

Jap

an 5

005

Ko

rea

200

Lati

n A

mer

ica

50

New

Zea

land

50

No

rdic

260

*

Rus

sia

50

So

uth

Afr

ica

100

Sw

itze

rlan

d 1

00

Turk

ey 1

00

UK

FT

SE

350

US

S&

P 5

00

Ove

rall6

Key Trends Indicators25 44 29 12 45 54 42 52 8 81 59 16 68 68 N/A % of sample answering CDP 20113

49 17 29 61 89 27 21 136 4 81 59 16 238 339 2038 Number of companies answering CDP 20113

74 76 59 93 63 73 55 67 67 89 69 64 92 49 66 % of responders with Board or other executive level responsibility for

climate change

Gov

erna

nce

55 53 56 68 57 32 45 46 33 55 37 71 63 63 53 % of responders with incentives for the management of climate change issues

84 71 89 91 76 73 65 87 33 78 75 79 79 78 78 % of responders with climate change integrated into their business strategy

Str

ateg

y

71 53 70 84 64 68 45 73 33 78 61 50 72 70 66 % of responders engaging policymakers on climate issues to encourage mitigation

or adaptation

47 47 78 96 60 32 50 67 33 51 58 36 65 64 57 % of responders with emissions reduction targets

Targ

ets

& In

itiat

ives

5 29 56 66 34 23 35 33 33 26 24 36 31 40 36 % of responders with absolute emissions reduction targets

92 94 100 98 61 86 65 90 33 95 88 79 93 90 85 % of responders with active emissions reduction initiatives in the reporting year

53 35 67 75 54 59 40 73 67 54 61 57 55 60 58 % of responders indicating that their products and services directly help third parties to

avoid GHG emissions79 71 81 91 72 73 65 78 33 96 58 71 79 63 71 % of responders seeing regulatory risks

Ris

ks &

O

pp

ortu

nitie

s

82 65 85 82 64 73 45 81 67 92 68 79 77 63 71 % of responders seeing regulatory opportunities

18 35 44 48 42 9 25 41 33 39 31 36 40 38 33 % of responders whose absolute emissions (Scope 1 & 2) have decreased compared to last

year due to emissions reduction activities

Em

issi

ons

Dat

a

33 59 85 46 56 59 40 51 33 49 39 36 39 34 46 % of responders independently verifying any portion of Scope 1 emissions data7

34 53 70 46 60 50 40 43 0 50 37 29 36 28 41 % of responders independently verifying any portion of Scope 2 emissions data7

Appendix III: Global Key Trends

46

Notes

Paul RobinsDirector of Fundraising

Alan McGillPartner

Richard GledhillPartner

Jon WilliamsPartner

Frances Way Program Director

Marcus NortonHead Investor CDP andCDP Water Disclosure

Malcolm PrestonPartner

Jonathan GrantAssistant Director

Daniel TurnerHead of Disclosure

James HowardDisclosure Managerjames.howard@cdproject.net

Carbon Disclosure Project40 Bowling Green LaneLondon, EC1R 0NEUnited KingdomTel: + 44 (0) 20 7970 5660Fax: + 44 (0) 20 7691 7316www.cdproject.netinfo@cdproject.net

PricewaterhouseCoopers LLP7, More LondonLondon, SE1 2RTUnited KingdomTel: +44 (0) 20 7583 5000Fax: + 44 (0) 20 7822 4652

Important NoticeThe contents of this report may be used by anyone providing acknowledgement is given to Carbon Disclosure Project (CDP). This does not represent a license to repackage or resell any of the data reported to CDP and presented in this report. If you intend to do this, you need to obtain express permission from CDP before doing so.

PwC and CDP prepared the data and analysis in this report based on responses to the CDP 2011 information request. PwC and CDP do not guarantee the accuracy or completeness of this information. PwC and CDP make no representation or warranty, express or implied, and accept no liability concerning the fairness, accuracy, or completeness of the information and opinions contained herein or for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it. You should not act upon the information contained in this publication without obtaining specific professional advice. All information and views expressed herein by CDP and/or PwC are based on their judgment at the time of this report and are subject to change without notice due to economic, political, industry and firm-specific factors. Guest commentaries where included in this report reflect the views of their respective authors; their inclusion is not an endorsement of them.

PwC and CDP and their affiliated member firms or companies, or their respective shareholders, members, partners, principals, directors, officers and/or employees, may have a position in the securities discussed herein. The securities mentioned in this document may not be eligible for sale in some states or countries, nor suitable for all types of investors; their value and the income they produce may fluctuate and/or be adversely affected by exchange rates.

‘PricewaterhouseCoopers’ and ‘PwC’ refer to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) or, as the context requires, other member firms of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity.

‘Carbon Disclosure Project’ and ‘CDP’ refers to Carbon Disclosure Project, a United Kingdom company limited by guarantee, registered as a United Kingdom charity number 1122330.

© 2011 Carbon Disclosure Project. All rights reserved.

CDP Contacts

Report Writers Contacts

Chairman: Alan Brown Schroders

Jeremy SmithBerkeley Energy

James CameronClimate Change Capital

Takejiro Sueyoshi

Chris PageRockefeller Philanthropy Advisors

Tessa TennantThe Ice Organisation

Dr. Christoph SchroederTVM Capital

Martin WiseRelationship Capital Partners

CDP Board of Trustees

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In addition, CDP has been made possible through the generous funding of:

Carbon Disclosure Project 2011 This report and all of the public responses from corporations are available to download from www.cdproject.net

Our sincere thanks are extended to the following:

Accounting for Sustainability, Allen & Overy, Association of British Insurers, Brooklyn Bridge, Ceres, Clinton Global Initiative, Confederation of British Industry, Development Bank of Japan, Environmental Research Group of the UK Faculty and Institute of Actuaries, EPA Energy Star, EPA Climate Leaders, Forest Footprint Disclosure Project, Freshfields, GHG Protocol, Global Reporting Initiative, Institutional Investors Group on Climate Change, Investor Group on Climate Change, LMI, Principles for Responsible Investing, Skadden Arps, The Climate Group, UK Foreign & Commonwealth Office, United Nations Environment Programme Finance Initiative, United Nations Global Compact, World Business Council for Sustainable Development, World Bank Group, World Economic Forum, World Resources Institute, WWF.