6.02 Waste to landfill: the objectives table now states an annual group-wide objective, while the climate pages keep a 2030 objective for 'strategic' manufacturing facilities with no scope or performance reported against it
UK Company A · a UK-listed medical technology group · Regulator-style question
In brief
The Planet objectives table states the waste objective as "Maintain zero waste to landfill [wording masked]" and reports 95% of total manufacturing waste diverted and 6 zero-waste locations. The TCFD metrics section, which names waste to landfill as one of the two key climate-related metrics, states the key objective as zero waste to landfill at strategic manufacturing facilities by 2030, but the report does not say which facilities are 'strategic', how many there are, or how far they are from the 2030 objective. The Annual Report 2024 table had set zero waste at all manufacturing facilities by 2030; the report does not say whether the 2025 ESG strategy refresh replaced that objective.
The evidence, as filed
Further pages withheld to protect the company’s identity (five): Annual Report 2025, page 67; Annual Report 2024, page 67; Annual Report 2025, page 73; Annual Report 2024, page 73; Annual Report 2025, page 70. Their wording or layout could lead back to the company even with names and figures masked; the evidence list below records what each page shows.
Names, figures, dates, logos and any wording that could be searched back to the company are boxed out in grey; the point is highlighted in yellow.
What the report shows, and what the rule requires
| What the annual report shows | What the rule requires |
|---|---|
| What the annual report shows Two waste objectives in the same report: an annual group-wide objective, already met at 95% diversion, in the objectives table; and a 2030 objective for 'strategic' manufacturing facilities in the TCFD metrics section, with no facilities-in-scope figure and no performance stated against it. The Annual Report 2024 table objective (all manufacturing facilities by 2030) is no longer shown and its replacement is not explained. | What the rule requires One stated waste-to-landfill objective, used consistently in the objectives table and the TCFD metrics and targets section, with performance against it (facilities meeting the definition out of facilities in scope) and, if the 2025 ESG strategy refresh replaced the 2024 'all manufacturing facilities by 2030' objective, a sentence saying so. |
The rule
Companies Act 2006 s.414CB(2A)(g)
Version relied on: Companies Act 2006, revised text on legislation.gov.uk as in force for the financial year reviewed
a description of the targets used by the company to manage climate-related risks and to realise climate-related opportunities and of performance against those targets
Why it applies here: a group figure of 95% can be reached while individual facilities remain below 90%, so the aggregate does not show progress against a facility-level 2030 objective.
Why it matters
A reader cannot tell which waste target the Board is managing to, whether the 2030 objective covers all or only some manufacturing facilities, or how far the group is from it; the 95% aggregate reads as meeting an objective that, on the 2024 table wording, required every facility to reach 90%.
Exposure
A clarity point on a stated climate-related target; dealt with by clearer wording in the next report.
Our workings
page 67 gives the objective as maintaining zero waste to landfill for total manufacturing waste annually, defines zero waste as a diversion rate of 90% or greater, and reports 95% diverted and 6 zero-waste locations. Page [n] says the [wording masked] and that the key objective is zero waste to landfill at strategic manufacturing facilities by 2030; page 75 refers to the 2030 [wording masked]. Page [n] says the five-year ESG strategy was refreshed in 2025. In the Annual Report 2024 the objectives table set zero waste at [place] and [place] by 2025 and at all manufacturing facilities by 2030, and reported both 2025 milestones already achieved in 2024; its TCFD page used the same 'strategic manufacturing facilities by 2030' wording as this year, so the 'all' versus 'strategic' difference is not new. What is new is that the 2025 table drops the 2030 facility objective and substitutes an annual group aggregate that is already met.
The report gives the number of locations that met the definition (6) but not the number of strategic facilities in scope. Whether the objective changed is for management to confirm.
Management’s best defence, and our reply
Management would say the five-year ESG strategy was refreshed and approved by the Board in 2025, that the objectives table shows the refreshed annual objective, that the 2030 objective for strategic facilities has been stated on the TCFD page since the Annual Report 2024 and sits alongside the annual objective, and that the manufacturing network was consolidated during the transformation, so 'strategic' facilities is the natural scope. It would add that the TCFD page cross-refers to the Sustainability Report for detailed objectives and progress, and that the 95% figure is independently assured. That is a reasonable reading, so the point is put as a question; but s.414CB(2A)(g) asks the Annual Report itself to describe the targets and performance against them, and as printed it gives two objectives, no facilities-in-scope figure for the 2030 objective, and no statement that the 2024 table objective was replaced.
The fix
- State one objective, for example: "Zero waste to landfill (90%+ diversion) at our N strategic manufacturing facilities by 2030; 2025: X of N met the definition; total manufacturing waste diverted 95%", and say if the 2025 ESG strategy refresh replaced the 2024 'all manufacturing facilities' objective.
Question for the company
Which waste-to-landfill objective now applies: the annual group-wide objective in the Planet table, or zero waste at 'strategic' manufacturing facilities by 2030? Which and how many facilities are 'strategic', how many of them met the 90% definition in 2025, and did the 2025 ESG strategy refresh replace the Annual Report 2024 objective of zero waste at all manufacturing facilities by 2030?
Evidence relied on
| # | What it shows | Type | Where |
|---|---|---|---|
| 1 | the objectives table states an annual objective for total manufacturing waste | Document | Annual Report 2025, page 67 |
| 2 | progress reported as a group aggregate | Document | Annual Report 2025, page 67 |
| 3 | number of locations meeting the definition, with no number in scope | Document | Annual Report 2025, page 67 |
| 4 | definition of zero waste to landfill | Document | Annual Report 2025, page 67 |
| 5 | waste to landfill is named as a key climate-related metric | Document | Annual Report 2025, page 73 |
| 6 | the TCFD metrics section states a different, 2030 facility-level objective | Document | Annual Report 2025, page 73 |
| 7 | the Scope 3 page also refers to a 2030 objective | Document | Annual Report 2025, page 75 |
| 8 | the ESG strategy was refreshed during the year | Document | Annual Report 2025, page 70 |
| 9 | the Annual Report 2024 objective was facility-level, covering all manufacturing facilities by 2030 | Document | Annual Report 2024, page 67 |
| 10 | the Annual Report 2024 TCFD page already stated the 2030 objective for strategic facilities | Document | Annual Report 2024, page 73 |
| 11 | the Annual Report 2024 reported the [place] (and [place]) 2025 milestones already achieved in 2024 | Document | Annual Report 2024, page 67 |
Absence check
- Document
- Annual Report 2025
- Where it would appear
- Maintain zero waste to
- What is missing
- a statement whether the Annual Report 2024 objective of zero waste to landfill at all manufacturing facilities by 2030 was replaced or narrowed to strategic facilities, the number of strategic manufacturing facilities in scope, and performance against the 2030 objective
- Pages looked at
- p.17 (KPIs), 67-79 (ESG, TCFD, GHG and SECR pages), [n] (governance ESG highlights)
- Result
- 'strategic manufacturing' hits only p.73, the 2030 objective quoted in this entry; 'all our manufacturing' has no hit; 'zero waste' and 'landfill' hit p.17 (KPI 95%), [n] (objectives table), [n] (TCFD objective), [n] (Scope 3 reference to the 2030 objective) and [n] (governance highlight 95%), none giving the facilities in scope or explaining a change of objective; '[place]' hits p.7, [n] (transformation, risk, biography and property pages), none about waste.
Prepared by Pramanex from the company’s published annual reports, without the company’s involvement, to show how an annual report review reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other assurance engagement, and not legal advice. A regulator-style question is a question, not a conclusion.
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