The Group is committed to progressively enhancing its
sustainability practices in line with evolving global expectations. As part of
this journey, we are strengthening our understanding of how environmental,
social, and governance (ESG) considerations intersect with our business
operations and influence stakeholder interests. In preparation for anticipated
reporting standards, including IFRS S1 and S2, we are taking deliberate steps
to enhance the comprehensiveness and transparency of our sustainability disclosures
Our first materiality assessment was conducted for the
FY2022 Sustainability Report. Building on that foundation, we completed a
refreshed traditional materiality assessment in October 2024. This update has
allowed us to sharpen our understanding of the sustainability topics most
relevant to our business and stakeholders
Materiality Analysis Process

Materiality Analysis Results

The Group is currently in transition from traditional
materiality to double materiality. This shift reflects our commitment to not
only assess how our business activities impact the environment and social
dimensions, but also how sustainability issues impact our business. We continue
to develop and refine our approach to identifying and addressing the risks and
opportunities that double materiality presents.
We considered the latest guidance from standard setters
to identifying, assessing, and disclosing sustainability-related impacts,
risks, and opportunities, including but not limited to:
•
GRI 3: Material Topics (2021);
•
The ISSB’s IFRS S1 General Requirements for Disclosure of
Sustainability-related Financial Information; and
•
ISO 31000 Risk Management – Applying ERM to ESG-related Risks
While the Group continues to enhance its approach to
materiality assessment by integrating best practices, the material topics
identified since FY2022 have remained largely consistent, with some updates and
considerations across the short, medium, and long term. The Group has
established a three-year cycle for conducting its double materiality assessment
process.

Sustainability Risks and Opportunities
Management
The Group has embedded sustainability into its risk
management framework, recognising ESG risks as immediate challenges rather than
future threats. ESG considerations are integrated into strategic planning and
proactively managed to enhance long-term resilience.
The process for identifying material sustainability
risks and opportunities is as below: -
a)
Identification
The Group identifies sustainability-related risks
and opportunities across its value chain, focusing on ESG factors that may
reasonably impact cash flow, access to finance, or cost of capital over the
short, medium, or long term. Financial impacts are estimated using professional
or informed judgment, particularly where forward-looking data cannot be
directly quantified.
This process integrates existing risk management
and stakeholder engagement outcomes, and relevant industry standards, including
the Iron & Steel Producers – SASB Sustainability Accounting Standard.
Identified risks are categorised under key material topics such as greenhouse
gas emissions, air emissions, energy and water management, waste, workforce
safety and health, supply chain, circular economy, ethics and integrity, and
data privacy and security
b)
Analysis and Evaluation
Each identified risk and opportunity is assessed
based on its likelihood and potential financial impact. This evaluation
underpins the prioritisation and supports the development of mitigation
strategies and monitoring mechanisms, guided by defined metrics and targets.
c)
Treatment and Mitigation
Mitigation measures are established and
implemented for material sustainability risks. The Group tracks performance
against relevant metrics and targets to ensure effective management and
continuous improvement.
Sustainability-related Risks and
Opportunities
The table below presents the
sustainability-related risks and opportunities identified through materiality
assessment. The subsequent chapters on Governance, Environment, Economic and
Social aspects will provide detailed disclosure for each material topic.
















Climate-related Risks and Opportunities
Management
The Group conducts climate-related risk and opportunity
assessments in accordance with the recommendations of the Task Force on
Climate-related Financial Disclosures (TCFD) and IFRS S2, applying its existing
risk management framework to identify and evaluate potential climate-related
issues.
The process for identifying material climate change
risks and opportunities is as below:
a) Identification
Using the TCFD and IFRS frameworks, along with insights
from international steel industry reports, the Group identified 11 transition
risks, 2 physical risks, and 3 opportunities that may materially affect cash
flow, access to finance, or cost of capital over the short, medium, or long
term.
Risks are categorized as follows:
• Transition
Risks: Policy and legal, technology, market, and reputational risks.
• Physical
Risks: Acute (e.g., extreme weather events) and chronic (e.g., long-term
climate shifts).
Opportunities include:
• Access
to sustainable financing,
• Enhancing
environmental performance,
• Developing
climate-aligned products and services.
This assessment is integrated into the Group’s existing
risk management processes and aligned with the SASB Industry Standard for Iron
& Steel Producers. The identified risks and opportunities are mapped to key
material topics, including greenhouse gas (GHG) emissions, energy management,
water security, and supply chain management
b) Analysis and Evaluation
Each identified risk and opportunity is assessed using
a metric that evaluates both likelihood and consequence. This process
determines the level of risk or opportunity and guides the prioritization of
risks, mitigations, and monitoring efforts.
c) Treatment
and Mitigation
Treatment and mitigation strategies are developed to
reduce the likelihood or impact of each risk.
• Treatment:
Avoid, reduce, transfer, or accept the risk.
• Mitigation:
Implement adaptation measures (e.g. flood defences, energy efficiency upgrades)
d) Prioritisation
of Risks
After mitigation strategies are outlined, the Group
focuses resources on significant and major material risks, particularly those
with the potential to impact its operations or strategic objectives, and
ensures that scenario analysis is applied where it adds the most value.
e) Scenario
Analysis
The Group strengthen its climate-related risk
management approach by conducting scenario analysis on significant and major
risks. These analyses help evaluate the Group’s exposure under different
climate scenarios, providing insights that guide the identification of risks
that warrant immediate attention. This enables the Group to anticipate
potential implications, assess impacts, and develop strategies to enhance
long-term resilience.
Scenario analysis is guided by the Intergovernmental
Panel on Climate Change (IPCC) and the International Energy Agency (IEA). The
Group considers both internal operational characteristics and external factors
such as market and political dynamics

The Group monitors performance against established
metrics and targets to ensure effective risk management and continuous
improvement. The identified sustainability and climate-related risks
and opportunities are incorporated into SSB’s Integrated Management System Risk
and Opportunity Register.
Climate-related Risks and Opportunities
The tables below outline the identified climate-related
risks and opportunities. We assess our resilience to climate impacts and
develop corresponding strategies and management approaches to address them.
a) Transition
Risks







b) Physical
Risks

c) Opportunities



d) Insights
of Scenario Analysis
Following are the insights from scenario analysis
conducted on significant and major climate-related risks. The outcomes indicate
that the previously developed management approaches and mitigations measures
are consistent with, and aligned to, the strategic direction of the analysis.

There are a range of
uncertainties and judgements that need to be made when modelling different
scenarios and their climate-related impacts. The significant areas of
uncertainty considered in the Group’s assessment includes the timing, scope,
and pricing structure of the forthcoming carbon pricing mechanisms in Malaysia
and other jurisdictions which will be implementing measures such as the EU
Carbon Border Adjustment Mechanism (CBAM). The lack of clarity on regulatory
design and enforcement timelines poses challenges in forecasting future costs
and assessing long-term competitiveness impacts.