TCFD and Companies Act disclosures, principal risks, Streamlined Energy and Carbon Reporting disclosures

Burberry Group plc – Annual report – 28 March 2026

Industry: retail

SUSTAINABILITY INFORMATION (page 45 extract)

6. Basis for preparation (extract)

Frameworks and legislation

This section contains our climate-related financial disclosure consistent with the Task Force on Climate-related Financial Disclosures (TCFD) (pages 46 to 75) to comply with the Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 and UK Listing Rule 6.6.6R(8). Our energy and carbon data is reported on page 58 to comply with the UK’s Streamlined Energy and Carbon Reporting requirements. We also publish a Modern Slavery and Transparency in the Supply Chain Statement on Burberryplc.com on an annual basis. This is in accordance with the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act of 2010, Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act and Australia’s Modern Slavery Act 2018.

ENVIRONMENTAL DISCLOSURES (page 46)

Our purpose, To Embrace the Elements with Open Arms, reflects our heritage of creating outerwear that protects people from the weather and our deep connection to the outdoors. Businesses and society at large continue to face challenges presented by the climate crisis, water insecurity and biodiversity loss. Burberry is committed to addressing these issues to create a resilient business and sustainable value chain.

This section explains how our Burberry Beyond strategy helps us to manage our most significant environmental impacts and dependencies, mitigate risks and realise opportunities.

CLIMATE CHANGE

Introduction

Burberry has a longstanding commitment to addressing the impacts of climate change. Guided by the recommendations of the TCFD, we identify, assess and manage climate-related risks and opportunities, recognising climate change as a principal risk for the Company (see our Risk and Viability report on page 95).

Materiality underpins our approach to our decarbonisation agenda, and the results of the DMA we conducted in FY 2025/26 confirmed that climate change is a material topic for Burberry. This assessment strengthens our understanding of the risks and opportunities associated with climate change.

As our understanding of our GHG emissions has deepened, particularly across our value chain, we have refined our climate targets. We have extended our overall net zero target from FY 2039/40 to FY 2049/50, in line with the latest methodologies from the Science Based Targets initiative (SBTi). We remain committed to our short-term targets to deliver significant emissions reductions across Scope 1 and 2 by FY 2026/27 and Scope 3 by FY 2029/30. This decision, taken by the Board in FY 2025/26, is grounded in our business transformation and in building clear, credible delivery pathways that we know are required to decarbonise our business. As part of this, we have published our first Climate Transition Plan disclosure (available via Burberryplc.com) which outlines Burberry’s objectives, strategy and governance to realise our net zero ambition.

The Burberry TCFD Basis of Reporting outlines how we have prepared the Financial Statements and disclosures, considering relevant TCFD guidance publications and the principles for effective disclosure. We have engaged EY as independent practitioners to provide a limited assurance statement in accordance with ISAE 3000 on our FY 2025/26 TCFD disclosures and specific sustainability data denoted with a ^.

For the results of that assurance, see EY’s Independent Limited Assurance Report and Burberry’s TCFD and Sustainability Basis of Reporting FY 2025/26 on Burberryplc.com.

TCFD statement

Below is a TCFD index outlining where we have reported on all key disclosure requirements.

SUSTAINABILITY INFORMATION (page 43 extracts)

Risk management and internal controls

The overarching approach to identifying sustainability-related risks is the same as for all principal risks, which is detailed on pages 95 to 97. For each risk, including climate change and supply chain impacts, we have a Risk Management Framework detailing the controls in place and those responsible for managing the overall risk and the relevant mitigating controls. We monitor risks throughout the year to identify changes in principal risk profiles. Management of sustainability-related risks is distributed throughout the organisation, depending on where the risk resides. For example, climate-related risks in relation to raw materials in the supply chain are managed by our Raw Material Procurement team responsible for buying materials.

When sustainability-related risks are assessed, existing mitigating activities and controls are highlighted and, where relevant and appropriate, additional activities and controls are implemented if risks fall outside of risk tolerance. Progress against these mitigating activities is assessed by the appropriate Committee responsible for monitoring the associated risk (as described in the Management oversight section on page 43).

Sustainability-related risks and opportunities are continually monitored as part of our Group Risk Management Framework. This allows us to evaluate the relative significance of our risks based on their likelihood and impact, and to prioritise accordingly.

We also scan for new and emerging risks and keep abreast of evolving regulatory requirements.

5. Governance and management

Board oversight

Sustainability is a core part of Burberry’s strategy, with the Board responsible for both its oversight and its integration across the business.

Our Governance Framework of Committees and advisory forums provides updates and key information to the Board to ensure it can make informed decisions. This is outlined in the Corporate Governance Statement on pages 121 to 122. The Matters Reserved for Board Decision and the Committees’ terms of reference, which are available in the Corporate Governance section of Burberryplc.com, provide more detail on the role of the Board and each of its committees.

The Board considers sustainability-related issues, including spend associated with our Burberry Beyond strategy, capital expenditure relating to improving energy efficiency in our own operations and colleague bonuses aligned to our sustainability targets. The Board also oversees and monitors the risks and opportunities related to climate change, nature and water. Further information on Burberry’s risk management approach is included in the Risk and Viability Report on pages 95 to 97.

As part of its review of preparedness for upcoming sustainability-related regulatory requirements, the Audit Committee reviewed and approved the results of the DMA for external publication. In addition, sustainability reporting is considered as part of the Board’s assessment of whether the Annual Report is fair, balanced and understandable.

The Board also receives an annual update on the Company’s community investment agenda and approves the budget for charitable giving.

Management oversight

Burberry’s CEO is accountable for implementing Burberry Beyond at the executive level and delegates managerial oversight of environmental and social responsibility matters to our Corporate Responsibility team. Led by the Vice President of Corporate Responsibility, the team guides the execution of our Burberry Beyond strategy by collaborating with teams across the business, including Sustainable Finance, Information Technology (IT), Legal, Product Development, Supply Chain and Human Resources. The management team tracks performance against our Burberry Beyond commitments and mitigation measures and provides regular updates to the Board and Committees on progress and performance.

The Company’s Sustainability Committee, which is chaired by the CEO, is responsible for reviewing and overseeing targets relating to the Product and Planet pillars of our Sustainability strategy, Burberry Beyond. The Committee is responsible for the identification, assessment and management of environmental risks and opportunities, including nature- and water-related risks such as land use change and water dependencies across our value chain. The Committee plays an important decision-making role in supporting Burberry’s environmental agenda, with membership including senior leaders from across the organisation who are responsible for the execution of the strategy within their respective business areas. This includes operational planning and supply chain due diligence processes to manage exposure to land conversion risks, water availability and quality constraints, as well as associated regulatory and reputational risks. In FY 2025/26, the Sustainability Committee met three times and provided the Board with two updates. These included progress against the Company’s sustainability-related goals and targets as well as Burberry’s decarbonisation plans and disclosures.

The Ethics Committee oversees the Company’s governance and strategy relating to our social agenda, including the governance of human rights risks across our value chain. Where risks are identified, they are reported by management to the Ethics Committee, which reports directly to the Audit Committee.

The Ethics Committee also has oversight of our community investment work as it reviews the Company’s charitable giving twice a year.

The Risk Committee, which is chaired by the Chief Financial Officer (CFO), is responsible for managing and monitoring sustainability-related IROs. It has oversight of the Company’s climate-related financial risk disclosures and preparations for upcoming reporting regulations.

Knowledge and skills

As part of its ongoing review of Board composition, the Board considers whether it has the appropriate skills and competencies to oversee the delivery of Burberry Beyond. Where required, additional training is provided. To support the Board in its review and ongoing monitoring of Burberry’s Climate Transition Plan, the Board undertook carbon literacy training in February 2026. Details regarding Board members’ sustainability skills and experience are included in the biographies section on pages 109 to 112.

Building sustainability knowledge and educating colleagues across the business are both fundamental to the delivery of our Burberry Beyond strategy. Through frequent engagements and communications, alongside tailored and targeted training, we strive to develop the sustainability learning of our colleagues on a continuous basis.

We aim to reach as many colleagues as possible through internal communications, including a weekly sustainability fast-fact series and a periodic sustainability newsletter covering everything from spotlights on colleagues who support the delivery of Burberry Beyond to sustainability regulation updates. In FY 2025/26, we introduced a weekly call entitled ‘Leaders Look Ahead and Round Up’ with the purpose of sharing key business updates, including relevant sustainability communications, for leaders to cascade across their teams.

We have enhanced our colleague training to focus on reaching new audiences during the year. For our supply chain and product development colleagues, we continued to deliver training covering how our Burberry Beyond strategy supports the delivery of product sustainability and responsible sourcing. We also expanded this training to include dedicated sessions for Design teams with a focus on sustainable product development from materials to manufacturing and circularity. On top of the guidance our Marketing colleagues receive on our Sustainability Principles for creative marketing, in FY 2025/26, we introduced tailored training for relevant marketing teams on the responsible and compliant use of environmental claims. The aim of this training is to reinforce the importance of ensuring all sustainability-related product claims are credible and in line with our internal Green Claims Policy and Green Claims Standard Operating Procedure.

Raising awareness and conducting training on the risks associated with modern slavery is essential for all relevant internal stakeholders and functions that may identify or influence modern slavery risks across the business. In FY 2024/25, we launched our online mandatory Modern Slavery training programme. We expanded the rollout of this training in FY 2025/26, requiring completion from over 1,695 colleagues globally across Supply Chain, Product Development, Corporate Responsibility, Human Resources and Retail functions, achieving a 94% completion rate. This training helps colleagues who have close contact with our key rights holders (including employees, supply chain workers, communities and our customers) to be more familiar with the risk areas, likely indications of human rights abuses (including instances of modern slavery) and actions to take if an incident of modern slavery is identified.

In addition to training and internal communications, we engaged colleagues through in-person and live-streamed events, including six panel events, two sustainable product showcases and two Burberry Inspire showcases.

In FY 2025/26, we hosted two Sustainable Product and ReBurberry showcases in our Leeds and London offices, inviting colleagues to explore the materials, innovations, initiatives and services behind our Burberry Beyond strategy. These exhibition-style events provided colleagues with an opportunity to meet subject-matter experts working on sustainability and experience our ReBurberry services in person, including refreshing their own cashmere and leather items. We also held Burberry Inspire showcases in London and Milan to bring young people together to celebrate creativity and highlight successful collaborations with local communities (see page 89 to 90 for more details on Burberry Inspire events).

We prioritise connecting with our colleagues across the globe to ensure our teams have the relevant sustainability-related knowledge and skills to support decision-making. In FY 2025/26, we launched a series of live-streamed panel events covering all four pillars of our Burberry Beyond strategy: Product, Planet, People and Community Investment. The panel events covered topics including the ‘Future of Sustainable Luxury’, ‘Ask Me About: Sustainability at Burberry’ and a human rights-focused session. Collectively these events reached an in-person audience of 500 colleagues and over 1,000 via digital streams.

Remuneration

The remuneration of Burberry’s Executive Directors is partly linked to our progress in building a more sustainable future, including progress towards Burberry’s longer-term climate goals, via the annual bonus plan and our long-term incentive plan. For FY 2025/26, 25% of the annual bonus for Executive Directors was linked to performance against strategic objectives related to our Burberry Forward strategy, including key sustainability measures. The Burberry Share Plan (BSP) award granted to the Executive Directors in 2025 also included a sustainability underpin. More information about our remuneration for FY 2025/26 can be found on pages 141 to 177.

Since FY 2023/24, we have linked a proportion of our discretionary annual corporate bonus plan for the wider workforce to the achievement of sustainability metrics. This approach encourages all colleagues to consider their contribution to our Burberry Beyond strategy.

Approach

Strategy

Climate change has been identified as a principal risk to Burberry and has the potential to impact our business in the short, medium and long term. Our strategy to address climate‑related risks is integrated into our business strategy and decision-making in areas such as capital allocation, investment appraisal, supply chain planning and raw material sourcing.

Background to scenario analysis

Scenario analysis is a process for identifying and assessing the potential implications of a range of plausible future states under conditions of uncertainty. Scenarios are hypothetical constructs and not designed to deliver precise outcomes or forecasts. Instead, scenarios provide a way for the business to consider how the future may look if certain trends continue, or certain conditions are met, and to assess Burberry’s strategic resilience. Climate-related risk scenario analysis is led by Sustainable Finance, with input from Supply Chain, Corporate Responsibility, Commercial and Finance teams across the business.

Our approach to scenario analysis

Our scenario analysis incorporates the Group’s financial forecasts, operational footprint, supply chain information and environmental data to create a digital twin representation of the business. The product portfolio is modelled based on our strategy, with the Group’s value chain being modelled using historical data. This information is combined with industry reference scenarios on climate emission pathways, including assessments by the Intergovernmental Panel on Climate Change (IPCC), International Energy Agency (IEA) and Network for Greening the Financial Systems (NGFS), to consider the potential impact of physical and transition risks on the business.

Each physical and transition risk was modelled independently due to the complexity and uncertainty associated with measuring the interconnectivity of risks and how they influence each other. Planned future mitigating actions, including those to deliver our ambition to be net zero by 2050, have not been taken into consideration in the scenario analysis.

In addition, we considered how a market shock arising from the transition to a low-carbon economy may impact the Group’s cost of debt and how low-carbon innovations could potentially devalue the Group’s technology. We have concluded that these risks are not significant at this time due to the Group’s cash position, focus on renewable energy consumption and absence of carbon-intensive machinery. We will continue to monitor and report on these risks.

Scenarios evaluated

The impact of physical and transition risks has been considered over a range of possible scenarios and temperature outcomes. This is in line with the recommendations of the TCFD to select a set of scenarios that cover a reasonable variety of future outcomes, both favourable and unfavourable.

In FY 2025/26, we updated the scenarios used in our assessment of transition risks, drawing on scenarios developed by the NGFS, a coalition of central banks and supervisors. These scenarios focus more on how a potential transition to a low-carbon economy may take place and whether this is in an orderly or disorderly manner, moving away from the previously modelled linear scenarios. The scenarios used to evaluate physical risks remain consistent with prior years and are based on the IPCC’s Shared Socioeconomic Pathways. For disclosure purposes, we have aligned the physical risk and transition risk scenarios, based on equivalent temperature outcomes.

The scenarios assessed include a low-emissions Net Zero 2050 pathway designed to limit global warming to below 1.5°C, in line with the TCFD recommendation that organisations assess resilience under a 2°C or lower scenario. The >4°C scenario used in previous years has been retired as it relies on outdated assumptions which do not reflect current energy transitions, particularly the rapid decline in renewable energy costs, which makes a significant global resurgence in coal use increasingly unlikely. The scenarios used in the modelling of climate-related risks are outlined on page 50, along with a summary of the potential global implications for both transition and physical risks under each pathway.

Time horizons considered

We have defined our time horizons as:

short term (five years);
medium term (five to 20 years); and
long term (more than 20 years).

The time horizon used for our detailed scenario analysis is a short-term outlook of five years, during which we can influence decisions through strategy, capital allocation, costs and revenues. Typically, three years is used for our financial and operational planning, as this is sufficient to cover the majority of approved capital expenditure projects and most current business development projects will be completed in this period.

Our viability assessment is broadly aligned to this timeframe, covering a three-year period. For the purposes of scenario analysis, we have extended the timeframe to five years using a growth assumption, which more closely aligns with our expected asset lifetimes and strategic plans.

Furthermore, we have used our detailed five-year analysis to consider how climate-related risks may evolve over 10 years to further guide the development of our climate strategy.

Results of our scenario analysis

The output of our scenario analysis considers the financial impact of climate-related risks on Burberry. This entails estimating the loss of value to the Group’s discounted cash flows over the next five years, assuming no mitigating actions are taken.

Overall, the results of our scenario analysis indicate that the physical and transition risks associated with climate change could impact the business in the short, medium and long term. The size of the impact will depend on the nature and speed of the global transition towards a low-carbon economy and the level of uncertainty increases beyond a five-year horizon. In the short to medium term, the Net Zero 2050 scenario would have most impact on Burberry before considering any mitigating actions, with market risk being a key driver of the impact.

Transition risks are expected to be the most impactful in the short to medium term, continuing the trends our five-year scenario analysis identified, as they relate to events such as policies and market behaviour that are either current or anticipated to come into effect in the near future. Physical risks are expected to become most impactful in the long-term, with the size of the impact dependent on the success of global initiatives to limit the repercussions of climate change. These long-term physical risks may disrupt our supply chain and create operational challenges. Our commitment to procure certified or responsibly sourced raw materials and our continued focus on innovation are key to limiting this impact. We will remain agile and continue to monitor this risk, informed by the latest scientific understanding of climate change. We will also continue to assess how the outputs of our scenario analysis can be utilised to inform future strategic planning, including our Climate Transition Plan, where relevant.

Detailed risk analysis

This section details the approach and results of our scenario analysis for each modelled risk. The financial impact reflects the estimated loss in the Group’s discounted cash flows over the next five years, assuming no mitigating actions are taken. This impact has been categorised as ‘High’, ‘Medium’ or ‘Low’, reflecting materiality to the Group’s Financial Statements.

Our strategic response to the identified climate-related risks can be found within the Actions sections on pages 55 to 75 as indicated by the risk type icons.

Opportunities

In addition to climate-related risks quantified through scenario analysis, Burberry continues to identify and act upon climate-related opportunities aimed at supporting the Company’s overarching Climate Transition Plan and net zero target. The Sustainability Committee plays a pivotal role in identifying, prioritising and realising climate-related opportunities. The Committee receives pertinent opportunities from internal teams working on our environmental agenda, which are then evaluated for feasibility and potential impact, as well as their alignment with key priorities.

Examples of such climate-related opportunities are summarised below.

Summary of response to scenario analysis

At Burberry, we believe our long-term success depends on proactively addressing the potential impact of climate-related risks while positioning the business to adapt to emerging opportunities. As such, we have adopted strategies and actions to mitigate these risks and ensure our strategy adapts to the potential opportunities. Where such actions have quantifiable investments associated with them, these are embedded within our Board-approved financial plans, which are translated into annual budgets.

We have also considered the impact of climate change in the preparation of our Financial Statements, which can be found on page 197. As scientific understanding of climate change, availability of data and modelling methodologies continue to evolve, we will further develop and update our scenario analysis to support our assessment of the resilience of our business strategy to climate-related risks and ensure relevant mitigating strategies are in place.

Details on targets and metrics aligned to the identified climate-related risks can be found within the Targets sections and Metrics sections on pages 55 to 75, as indicated by the risk type icons.

Policies

Our Global Environmental Policy establishes Burberry’s commitment to improving our environmental performance and to preventing or minimising any potential negative impacts on the environment along Burberry’s value chain.

The Global Environmental Policy defines Burberry’s target to reach net zero by 2050, requiring the reduction of GHG emissions across our value chain (Scope 1, 2 and 3 emissions) in line with our science-based emissions reduction targets. The policy includes our commitment to procure or generate 100% of our electricity from renewable sources, where feasible, and to improve the efficiency of energy consumption at Burberry’s own sites.

The policy applies to all Burberry operations and compliance is mandatory for all Business Associates. Business Associates include any individual, entity, business or company associated with Burberry, including supply chain partners who carry out any processing or provide any goods directly or indirectly supplied to Burberry. Burberry engages key stakeholders, including industry partners, government bodies and NGOs, in setting and implementing the policy effectively. Regular training and communication are key aspects of our environmental programmes.

The policy is available on Burberryplc.com and shared with employees, contractors and Business Associates during their onboarding as part of their contractual compliance obligations.

Burberry’s Sustainability Committee, chaired by the CEO, oversees the implementation of the Group Environmental Policy.

Targets

We have refined our climate targets to reflect a greater understanding of GHG emissions across our value chain, investments in our GHG data management capabilities and updates to the SBTi and GHG Protocol standards and frameworks. Our revised targets also take into account the observed and projected speed and scale of decarbonisation across our industry and economies where we operate, both significant dependencies for the realisation of our goals. Based on these insights, we have extended our overall net zero target from FY 2039/40 to FY 2049/50 and segregated our Scope 3 targets between FLAG (Forests, Land and Agriculture) and non-FLAG emissions1.

We believe our revised targets reflect a pragmatic response to external factors, while allowing us to maintain a level of ambition in line with our assessment of climate change as a principal risk facing our business.

Our targets remain aligned to a 1.5°C pathway and will be submitted to the SBTi for validation against the current Corporate Net-Zero Standard (V1.3).

Our methodology for measuring progress towards our emissions targets is aligned with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard. Please see Revisions to our GHG accounting on page 57 for further details on how we have evolved our GHG accounting methodology in FY 2025/26 to ensure that our reported data is as accurate, transparent and actionable as possible. Further details on our GHG accounting methodology can be found in our Sustainability Basis of Reporting FY 2025/26 on Burberryplc.com.

We actively monitor changes to external guidance and standards for corporate emissions targets, receiving insights from bodies such as the SBTi and ISO. We will continue to evolve our targets as required.

FY 2025/26 performance

In FY 2025/26, we continued to make meaningful progress towards reaching net zero, with sustained reductions across Scope 1, 2 and 3 GHG emissions. Our approach to achieving net zero is to first work towards the level of emissions reductions required by our Scope 1, 2 and 3 reduction targets (see page 56), before neutralising our residual emissions with limited use of high-integrity and certified carbon removal credits from FY 2049/50 onwards. This approach is in line with the SBTi’s Corporate Net-Zero Standard.

1. FLAG emissions refer to GHG emissions and removals from land-based activities, including land use change and land management. Non‑FLAG emissions encompass all other GHG emissions not directly related to these land-based activities, such as those from energy or industrial processes.