Year ended 31 March
2026
Every year, the Trustee produces a formal statement which highlights how climate change might affect the Scheme and what is being done to manage those effects. This statement is known as the Taskforce on Climate-Related Financial Disclosures (TCFD) Statement. It’s structured around four pillars: Governance, Strategy, Risk Management, and Metrics and Targets.
The money that will one day pay your pension is invested, and this statement covers the climate-related risks and opportunities that go along with that. For example, how is the Scheme doing against its targets for carbon emissions? What might happen to the Scheme’s investments if global temperatures continue to rise? And what training is the Trustee Board undertaking in order to understand these issues?
This is a summary of the TCFD Statement. You can read the full TCFD Statement to find out more.
Governance
The Trustee Board has overall responsibility for the management of climate-related risks and opportunities. To help the Trustee Board with this, certain areas are delegated to particular groups.
Trustee Board
Overall responsibility, including setting objectives and formalising Climate Change Risk Management Policy
Investment and Funding Committee
Reviews and recommendations
Vodafone
In-House
Pension Team
Implementation of changes
External advisers
Advice and analysis
The Trustee reviewed its Climate Change Risk Management Policy (CCRMP) in May 2026. You can read the CCRMP at Appendix C of the full TCFD Statement. Additionally, the Trustee completed the following areas of training over the reporting year:
January 2026
Training on how tail-risk analysis, which looks at the impact of extreme but unlikely events, is incorporated into the Scheme's investment and risk management framework
May 2026
Training on the approach to TCFD reporting, including recent DWP guidance, ahead of the preparation of this report
Strategy
The Trustee considers engagement with investment managers to be the key tool in addressing climate risks and capitalising on opportunities.
This entails the following actions:
Meeting
The Trustee meets with investment managers throughout the year. As part of Investment and Funding Committee meetings, the Trustee held additional discussions with Schroders Greencoat (September 2025), Insight (November 2025) and ICG (March 2026).
Selection
The Trustee incorporates climate-related risks and opportunities into the manager selection process. During the year under review, this applied to the selections in March 2026 of PIMCO and Insight to manage the Scheme's Absolute Return Bonds Diversified allocation, and Ellington to manage its Enhanced Structured Credit allocation.
Delegation
The Trustee delegates engagement with the underlying companies in which the Scheme is invested to the Scheme’s investment managers.
Research and monitoring
The Scheme’s investment consultant provides the Trustee with manager research and monitoring.
The Trustee has looked at three different scenarios around the Paris Agreement’s goal of keeping global temperatures less than two degrees warmer than pre-industrial levels.
As last year, the Trustee has used a new set of scenarios developed by the Network for Greening the Financial System (NGFS). These are widely accepted as the leading reference climate scenarios.
When looking at these scenarios, the Trustee must consider physical risks (the financial consequences of doing business in a warming world) and transition risks (the financial consequences of adapting to meet climate policies).
Here’s what this analysis suggested would happen to the Scheme’s funding level in each scenario:
Orderly transition
Countries implement changes to reach the Paris Agreement’s goal at a steady, predictable rate, giving a reasonable chance of limiting global warming to 2°C.
Moderate physical risk, moderate transition risk
Vodafone section
-0.8%
CWW section
-0.4%
Disorderly transition
Countries implement changes to reach the Paris Agreement’s goal inconsistently, with unexpected policy announcements impacting companies' profitability.
Moderate physical risk, high transition risk
Vodafone section
-1.5%
CWW section
-0.8%
Hot-house world
Not reaching the Paris Agreement's goal, with global temperatures rising by more than 3°C.
Very high physical risk, low transition risk
Vodafone section
-2.0%
CWW section
-1.2%
The figures for the Vodafone section and CWW section are different because each section's assets are held separately and invested slightly differently.
The main reason why reaching the Paris Agreement’s goal could have a negative effect on the Scheme’s funding position is that combating climate change is likely to improve living conditions and lead to increased longevity. This is good news in general, but more expensive for pension schemes like ours, which would potentially have to pay benefits for longer.
Risk Management
Climate risks are integrated with the Trustee’s wider risk management framework.
The Trustee has the following safeguards in place:
Policies
The Trustee has a Statement of Investment Principles, an Implementation Statement and a Responsible Investment policy.
Regulations
The Trustee complies with relevant regulations, including the publication of this statement.
Monitoring
The Trustee meets with the Scheme’s investment managers and monitors their activity with respect to climate risks.
Investment manager selection
The Trustee assesses the climate credentials of the Scheme’s investment managers when appointing them.
Metrics and Targets
The Trustee monitors four metrics and has two main goals for the Scheme:
Here’s how the metrics changed compared with last year’s statement:
Total greenhouse gas emissions
Greenhouse gases are gases in the Earth’s atmosphere that are capable of absorbing infrared radiation and thereby trap and hold heat in the atmosphere. The main greenhouse gases are carbon dioxide (CO2), methane, and nitrous oxide.
Vodafone section
Decreased ↓
CWW section
Increased ↑
Carbon footprint
Carbon footprint measures the Scheme's carbon emissions in relation to its assets - so it's possible for carbon footprint to go up even when total greenhouse emissions have gone down.
Vodafone section
Increased ↑
CWW section
Increased ↑
Data Quality Score
This metric monitors the reliability of companies' emissions data, ranging from grade 1 (accurate and independently verified) to grade 5 (based on estimates and industry averages).
Vodafone section
Improved ↑
CWW section
Improved ↑
Science-based Target initiative alignment
The Science-based Target initiative (SBTi) is a widely-used benchmark to ensure our targets are aligned with the latest climate science.
Vodafone section
Increased ↑
CWW section
Increased ↑
Here are our targets for carbon emissions, which are unchanged since our previous TCFD Statement:
At the moment we're on track to achieve our targets but we will keep this under review.
The Trustee continues to support an orderly decarbonisation to net zero and believes it's in the best long-term interests of members. These targets were aligned to the ambitious goals of the Paris Agreement, and based on an assumption that globally the low-carbon transition would occur at a reasonable pace. While the world is currently behind the trajectory needed to achieve the Paris Agreement's goals, the Trustee is comfortable that its targets are appropriate in light of the Scheme's commitments and prevailing pensions industry practice.
The Trustee's main duty is to make sure the Scheme has enough money to pay members' benefits, and therefore it must invest accordingly. The Trustee will continue to monitor progress towards the Paris Agreement, and will adapt its position, potentially reviewing its own targets for carbon emissions, as required.