Materiality

In line with our devolved business model, assessing and prioritising material environmental and social impacts, risks and opportunities starts with our businesses. This process builds on their business-level assessments of overall risk and opportunities, including ESG matters.

At Group-level, we aggregate the material ESG topics and risks identified by our businesses and incorporate a Group perspective. This includes considering topics discussed through stakeholder engagement, including with investors.

We are clear on our Group priorities, these are:

human and labour rights in Primark’s supply chain;
decarbonisation at British Sugar;
water treatment at AB Mauri;
employee accommodation and living standards at our sugar businesses in Africa; and
understanding our wider Scope 3 GHG emissions across our businesses.

We will continue to focus on these Group priorities next year with the additional priority area of human and labour rights in the  Twinings and Ovaltine supply chains. The investment and programme of work relating to water treatment and effluent at AB Mauri is almost complete and therefore will be removed as a Group priority in due course. We expect our individual businesses to set their own additional priorities as they see fit.

There will always be a need for the Group to be responsive to new and emerging priorities that may occur at any time. We will seek to ensure that we are able respond when there is something we need to do. The topics presented in the table below have been identified as material for the Group. Most are material for some or all businesses, however the degree to which each topic is material for each business varies.

As part of our ongoing review of our material thematic topics at  Group level, we will update the consolidation of topics as necessary. Our current grouping of material topics is detailed below:

our people;
people in our supply chains and surrounding communities;
carbon and climate;
water;
waste and packaging;
food safety and nutrition; and
agriculture and farming practices.

Our material topics

Our business segments

Our value chain

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Health, safety and wellbeing			Our businesses’ priority is to safeguard the wellbeing, health and safety of our employees, contractors and visitors to our sites.
Diversity, equity and inclusion			Fostering inclusive cultures and providing tailored support makes the most of all employees’ unique backgrounds and characteristics.
Engagement and development			We support our people to develop skills and capabilities through training, and we create opportunities for professional and personal development.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Human and labour rights in our supply chains			The risk of human rights and labour issues occurring across our businesses’ supply chains.
Supporting communities			Contributing to the development of the communities in which we work protects our licence to operate, supports job creation and builds public trust.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
GHG emissions			Our businesses and supply chains operate in many areas subject to climate risks and opportunities as we transition to a lower carbon world. Our success depends on mitigating these risks and making the most of the opportunities. We need to cut greenhouse gas (GHG) emissions and build resilience to secure a net zero future.
Energy and renewables			Efficient energy use and switching to renewables in our operations and supply chain are vital to reducing emissions and costs and increasing energy security.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Water use			Our suppliers and our operations use water, and the communities and environment around them need it too. We recognise water as a very valuable, shared resource that is becoming increasingly scarce in some parts of the world.
Water treatment			Water treatment is essential for our businesses to minimise environmental impact, ensure legal compliance, and manage water risks at our production sites. It also enables some of our sites to reuse water and recover valuable co-products.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Waste and circularity			A shift towards a circular economy, focusing on waste reduction and sustainable material use, presents significant opportunities and urgent challenges for our businesses.
Plastic and packaging			Packaging has an important role to play in ensuring the safety and quality of food products. Less plastic and using plastic which contains more recycled materials and is recyclable, contributes to reducing waste and moving towards circularity.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Nutrition and health			Governments and consumers are increasingly focused on healthier lifestyles. We want to support consumers’ preferences and governments to achieve their wider health and wellbeing goals.
Food safety			As a leading food manufacturer and retailer, it is vital that we manage the safety and quality of our products throughout our operations and value chain.

Group-level material topics	Impacts on the business segments	Impacts in the value chain	Why it is material
Responsible agriculture			Our businesses depend upon agricultural systems for most of the raw materials we use in our products.
Biodiversity and land use			Our products are made from agricultural commodities, which are dependent on biodiversity and healthy natural ecosystems.
Animal health and welfare			A number of our businesses have direct involvement with animals. Several also purchase ingredients derived from animals and some sell products into the livestock industry.

Double materiality and CSRD

With divisions operating across the EU, one of our areas of focus this year has been preparing for the upcoming disclosure requirements under the EU Corporate Sustainability Reporting Directive (CSRD). In 2025/26 some of our European entities will be required to report under CSRD.

At Group level, we are working to support those businesses in scope to ensure they are prepared for the requirements of CSRD. Over the past year we have held briefings and training sessions to outline the requirements, with a specific focus on the double materiality assessment, which will inform the disclosure requirements for each reporting entity.

At Group level, as part of this focus, we have worked closely with internal and external stakeholders to create guidance to assist the businesses as they undertake their double materiality assessments.

This is aligned with the guidance of EFRAG¹ and aims to ensure that the businesses are equipped to conduct their assessments in compliance with the required standard and that the analysis is conducted consistently, in preparation for our groupwide reporting, which will be required in 2028/29.

Our impact on the Sustainable Development Goals

We understand the potential to contribute towards certain Sustainable Development Goals (SDGs) through the ESG programmes of some of our businesses. Click here for more information.

1. European Financial Reporting Advisory Group

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