Streamlined Energy & Carbon Reporting for the financial year ending 31st December 2021

The Group has appointed Carbon Footprint Ltd, a leading carbon and energy management company, to assess independently its Greenhouse Gas (GHG) emissions in accordance with the UK Government’s ‘Environmental Reporting Guidelines: Including Streamlined Energy and Carbon Reporting Guidance’.

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The Group’s definition of its carbon footprint for SECR

For the purposes of the SECR report, the Group has defined its carbon footprint as a measure of the impact its activities have on the environment in terms of the amount of greenhouse gases produced, measured in units of carbon dioxide equivalents (CO2e). The Group’s carbon footprint is therefore made up of two parts, direct and indirect emissions.

Direct emissions
Direct emissions are produced by sources which are owned or controlled by the reporting organisation and include electricity use, burning oil or gas for heating, and fuel consumption as a result of business travel or distribution. Direct emissions correspond to elements within scopes 1, 2 and 3 of the World Resources Institute GHG Protocol, as indicated below.

  • Electricity, heat or steam generated on-site
  • Natural gas, gas oil, LPG or coal use attributable to Company-owned facilities
  • Company-owned vehicle travel
  • Production of any of the six GHGs (CO2, CH4, N2O, HFCs, PFCs and SF6)
  • Consumption of purchased electricity, heat steam and cooling
  • Employee business travel (using transport not owned by the Company)
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Indirect emissions

Indirect emissions result from a company’s upstream and downstream activities. These are typically from outsourced/contract manufacturing, and products and the services offered by the organisation. Indirect emissions correspond to scope 3 of the World Resources Institute GHG Protocol excluding employee business travel as indicated below.

  • Employee commuting
  • Transportation of an organisation’s products, materials or waste by another organisation
  • Outsourced activities, contract manufacturing and franchises GHG emissions from waste generated by the organisation but managed by another organisation
  • GHG emissions from the use and end-of-life phases of the organisation’s products and services
  • GHG emissions arising from the production and distribution of energy products, other than electricity, steam and heat, consumed by the organisation
  • GHG emissions from the production of purchased raw or primary materials
  • GHG emissions arising from the transmission and distribution of purchased electricity
Based on the above classifications the Group’s GHG emissions have been assessed by Carbon Footprint Ltd following ISO14064-1:2018, using the 2020 emission conversion factors published by Department for Environment, Food and Rural Affairs (DEFRA) and the Department for Business, Energy & Industrial Strategy (BEIS).
Although not required to meet the SECR legislation, the Group is reporting CO2 emissions for scope one and two as well as reporting additional scope three emissions (the scope two assessment follows the location-based approach for emissions from electricity usage). The Group’s reporting extends to all operations of the business including its wholly owned business interests in the USA, UK, Middle East and Asia.
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Treatment of scope three, indirect emissions

Having received advice from Carbon Footprint Ltd, the Group’s ISO14064-1:2018 audit partner, it has further delineated scope
three, indirect emissions, into two broad categories these being:

  • Scope three items indirectly associated with the delivery or growth of the Group’s business (travel, home working, etc.). The Group believes these items are directly related to its business activities and therefore should be included within our carbon footprint assessment even if that is beyond the current SECR requirement; and
  • Scope three items associated directly with demand instigated by a customer, this being mainly aircraft fuel consumption. The Group recognises and records these CO2 emissions and will, given the limitations of the current engine, fuel and associated technologies, work with its customers to limit and mitigate these emissions through its best endeavours

2021 verified Greenhouse Gas emissions

The Group is keenly aware that 2021 was another year where business operations and our customers’ use of their aircraft was greatly reduced. This was again due to the prevalence of the Delta and Omicron variants of COVID-19 which restricted international travel. Consequently, the GHG emissions table below reflects a year of continued lower than expected flight activity in scope 3, which is only marginally higher than that seen in 2020.

Table 1 provided summarises the GHG emissions for reporting year: 1 January 2021 to 31 December 2021.

Gama Aviation SECR carbon reporting

1 The data for the US includes that for Jet East, which was purchased by the Group in January 2021 and then subsequently merged into Gama Aviation’s existing US maintenance business. Data has therefore been collected on a best endeavours basis for 2021 based on fluctuations in staffing, facilities and other factors due to the integration of the two operations.

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Offsetting carbon emissions

The Board has approved the offsetting in 2022 of the Group’s 2021 emissions pertaining to the following categories audited by Carbon Footprint under ISO 14064-1:2018:

  • The Group’s scope one emissions;
  • The Group’s scope two emissions; and
  • The Group’s scope three emissions but limited to those for which the business is directly responsible. This omits indirect customer aircraft fuel consumption as previously defined

To this end the Group is committed to offsetting at least 2,723 tonnes of CO2e during 2022. The table below shows the breakdown of the scope 1, 2 & 3 emissions excluding customer aircraft fuel consumption and the effect of the offsetting.

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Selection of offsetting programmes

In accordance with the Group’s wider corporate social responsibility programme and its values, the Group believes that any offsetting programme should be compatible with the spirit of its corporate social responsibility aims. It is for this reason that the selection of the offsetting programme:

  • Shall not include tree-planting in the UK as its sole means of carbon reduction;
  • Shall not be limited to activities in the UK to reflect the geographic diversity of the Group;
  • Should empower gender and racial diversity and encourage economic growth within a community;
  • Should comply with the Group’s ethical standards; and
  • Should be delivered through a Gold Standard VER/Verified Carbon Standard or equivalent scheme

Project Element Six: Carbon reduction and a low carbon future

After the first year of Project Element Six, the Board acknowledges the efforts by the business leadership to adapt to a low GHG emission environment in line with our published Carbon Reduction Plan. The SECR report demonstrates:

  • A year on year reduction of the Group’s scope 1, 2 and partial scope 3 CO2 emissions during a period when headcount has grown
  • A lowering of the Group’s UK scope 1 and 2 energy consumption by more than 2.5m kWh
  • Given the limitations of the current technology used directly and indirectly by the Group, it is likely that the Group will continue to use carbon offsetting to mitigate its carbon footprint in the near future.
    However, the proportion of GHG emission derived by the business is dwarfed by that of fuel burn directly relating to customer-initiated activity. Therefore, further efforts are needed to work with customers to use reductive or offset mechanisms to mitigate the impact of their fuel consumption.

    Over the course of this year the Executive and business leadership will continue, via Project Element Six, to:

    • Improve audit accuracy and data such that the Group has, in the future, a near real time view of carbon emissions which is reported through the current quarterly business review cycle;
    • Fix, optimise or add policies/processes and changes in procurement practice that seek to lower the Group’s scope one, two and three emissions through change;
    • Further promote the ability to mitigate GHG emissions for all charter flights booked with us;
    • Include as standard, the option to mitigate all GHG emissions within all new aircraft management contracts;
    • Include as standard, the option to mitigate all GHG emissions within all UK Government contracts;
    • Review, aid and partner with low carbon technologies (fuels, engines, systems) that may substitute current technologies to achieve a low carbon future;