Risk Management
RISK MANAGEMENT
Climate-related risks and opportunities are identified and assessed through Cromwell’s broader ESG materiality
process. Further information on the Group’s ESG materiality assessment, key findings and material topics is
provided in the ESG Materiality section.
Risk identification and prioritisation
Cromwell’s approach to scenario analysis is influenced by the topics identified during the ESG materiality review, as
these topics affect how the business adapts to climate change, either directly or indirectly. To capture the material
impacts (risks/opportunities rated as high or very high) to the business, the scenario analysis process considers
both the physical impacts from climate change (namely acute and chronic risks) and transitional impacts from
shifting to a low-carbon economy (including shifts in reputation, market, technology, legal and policy).
For physical risks, Cromwell distinguishes between acute events (such as cyclones, floods, and heatwaves) and
chronic changes (including drought and rising sea levels). Assets within Cromwell’s platform were reviewed to
identify areas most affected by these conditions, using regional and asset-specific data sourced from government
climate models and databases.
The transition risk assessment starts with a qualitative review of the portfolio’s exposure to climate-related risks
and opportunities. This subjective analysis evaluates how a shift to a low-carbon economy could affect asset costs
and revenues, categorising identified risks and opportunities as reputation, market, technology, legal and policy-
related climate factors.
Each identified risk is rated for consequence and likelihood, using a scale from ‘insignificant’ to ‘very high’ and
timeframes spanning short, medium and long term. These ratings inform Cromwell’s risk matrix, which determines
inherent and residual risk levels. Risks are recorded in the ERM system and reviewed at least every six months to
ensure controls remain effective.
This process enables Cromwell to prioritise risks and opportunities with the greatest strategic impact, supporting
proactive risk management and informed decision-making.
Risk integration and monitoring
Climate-related risks are managed through Cromwell’s Enterprise Risk Management Framework and Board-
approved Risk Appetite Statement. Further information on the Group’s approach to risk governance, risk owne