In current disclosures, ACT recognizes the materiality of climate change and the related risks to which it is exposed, including regulatory, legal, technology, market, and reputation risks, all of which threaten shareholder value if left unaddressed. ACT has described likely financial and strategic impacts of these risks to its business, including decreased revenues due to reduced demand for its products and services, and innovations in the market that outpace its ability to adapt.(1) Given the scope of these transition risks, the company must set clear emission reduction targets and implement an effective abatement strategy to manage them.

ACT has a goal to reduce net Scope 1 and 2 emissions from energy consumption by 50% by 2025 compared to a 2020 baseline, including the use of carbon credits, and a “carbon neutrality” goal for net Scope 1 and 2 emissions from energy consumption by 2030, including the use of carbon credits.(2) The portion of Scope 1 and 2 emissions covered by these targets and the extent to which carbon credits are relied on to achieve them remain undisclosed leaving investors to guess at possible emissions coverage and reduction scenarios. The lack of transparency about the use of carbon credits may also expose ACT to legal risks and may invite the perception of greenwashing.(3)

In addition, although ACT quantified its material Scope 3 emissions (categories 1 and 11) for the first time in 2024,(4) it does not articulate a coherent approach to reduce these emissions.

Internationally recognized standards including the International Financial Reporting Standards and GHG Protocol provide guidance for emissions reporting and targets. ACT’s current goals fall short of these recognized methodologies, creating a lack of clarity for investors.

In sharp contrast to ACT, the company’s self-identified peers Costco(5) and Empire(6) disclose unambiguous Scope 1 and 2 emissions reduction mid-term targets with plans that identify the factors driving reductions. Regarding Scope 3 emissions, Costco(7) plans to expand its EV charging offerings and has a fuel transition plan detailing to investors its strategy to decarbonize.
Setting fulsome and comprehensible GHG emission targets is critical to ensure ACT’s resilience, competitiveness, and long-term viability in a changing regulatory and market landscape. Investors should be able to understand, in absolute terms, how much a company plans to reduce its emissions and how these reductions map against each scope. ACT can assure investors that it understands and is managing its emissions profile and associated climate risks by disclosing Paris-aligned GHG reduction targets covering material emissions.

1 Alimentation Couche-Tard CDP Response, C2.2-2.3
2https://filecache.investorroom.com/mr5ircnw_alimentationcouchetard/403/ACT_Sustainability_Report_2024.pdf
3https://competition-bureau.canada.ca/en/how-we-foster-competition/education-and-outreach/guide-june-2024-amendments-competition-act#sec04 and https://filecache.investorroom.com/mr5ircnw_alimentationcouchetard/403/ACT_Sustainability_Report_2024.pdf
4https://filecache.investorroom.com/mr5ircnw_alimentationcouchetard/403/ACT_Sustainability_Report_2024.pdf
5 https://mobilecontent.costco.com/staging/resource/img/25w03130/5a_ClimateActionPlan_FY24.pdf
6 https://sobeyssbreport.com/wp-content/uploads/2024/07/Fiscal-2024-Sustainable-Business-Report__EN_.pdf
7 https://mobilecontent.costco.com/staging/resource/img/25w03130/5a_ClimateActionPlan_FY24.pdf