Carbon neutral by 2030: Member update

02 May 2022 10 min read

We have entered a decisive decade for humanity, with the warnings about the impact of inaction on climate being evidenced around the world. Economic systems will face major disruption and therefore we need to make a paradigm shift in our economic models to protect our members’ retirement savings. NGS Super took the bold decision to go where no other super fund has gone, and in 2021, we announced our ambitious target to transition the portfolio to carbon neutral by 2030.

As a Fund, we recognise that this is the moment in history in which we need to take drastic action to contribute to change. By using the collective capital of committed NGS members, we will support companies building sustainable, lower carbon businesses, while aiming to improve on current average long-term investment returns for NGS members. We are delighted to announce that our work over the last 12 months has confirmed that a carbon-neutral investment portfolio by 2030 is achievable, and we have set an interim target of a 35% reduction in carbon by 2025.

This update covers the following:

What have we done since March 2021?
What does this work tell us?
What does decarbonisation look like for NGS Super?
Reporting and feedback
Members’ best financial interests remain paramount

What have we done since March 2021?

What have we done since March 2021?

We have been working on 3 significant items:

  1. obtaining a baseline measurement of the carbon intensity of our very diverse investment portfolio
  2. completing scenario analysis over the listed and unlisted assets of our portfolio
  3. completing a glide path analysis to model carbon reduction scenarios over time, taking into consideration risk, return and tracking error.

We’ll look at each of these steps — and why they’re important — in detail below.

Baseline measurement of carbon intensity

Understanding our starting point — that is, how much carbon1 is in our portfolio right now? — allows us to quantify the actions we need to take from now until 2030 to reduce our carbon intensity figure to net zero.

Our baseline measurement of carbon intensity focused on scope 1 and scope 2 emissions of the Diversified (MySuper) investment option, in which more than 70% of the membership is invested. As the Diversified (MySuper) investment option is decarbonised, all the other NGS Super investment options will also decarbonise.

The Fund’s investment portfolio is diverse. The asset allocation for the Diversified MySuper investment option shows holdings across an array of asset classes such as equities, alternatives, fixed income, property, infrastructure and cash. Due to the diverse nature of the portfolio, the Fund engaged specialist third-party service providers to help in the carbon intensity measurement of the Diversified (MySuper) investment option.2

As at 30 June 2021, the Fund’s baseline measurement of the Diversified (MySuper) option was approximately 48 tonnes of carbon dioxide equivalents per million dollars invested (tCO2e/$ million invested).

Scenario analysis

It is important to conduct scenario analysis while transitioning to a carbon-neutral investment portfolio because it can help to:

  • identify key risk within the investment portfolio, allowing us to implement an action plan through either divestment or engagement, and
  • understand where opportunities lie to invest in the solutions for climate change – we want to invest in climate solutions.

We completed our scenario analysis on 6 main scenarios, looking at the results as at 2030, 2040 and 2050. For listed assets, we considered all 6 scenarios. For unlisted assets, we considered 3 scenarios (Current policies, Delayed transition and Net zero by 2050). You can find details of the 6 scenarios in the appendix at the end of this article.

It will be important for the Fund to revisit the scenario analysis as the scenario assumptions will change over time, depending on government policy implementation and enhanced technologies. This will ensure we stay abreast of the relative risks and opportunities as they change. We will outline our key findings and takeaways from the scenario analysis in our second Task Force on Climate-Related Financial Disclosure (TCFD) report later in 2022. Read our current TCFD report

Glide path analysis

If we wanted to decarbonise the portfolio tomorrow, we could, but it would come at a significant cost (investment performance) to the retirement savings of our members. Abruptly divesting currently held high scope 1, 2 and 3 assets would bring immense volatility and tracking error to investment returns, which is not in members’ best financial interests. Also, merely divesting high scope 1, 2 and 3 companies would not reduce the Fund’s carbon emissions to zero. To become carbon neutral tomorrow, as well as abruptly divesting, we would need to purchase carbon offsets — this would not be in members’ best financial interests, as the cost of those offsets would be deducted from investment returns. For example, using carbon credit units as a proxy for carbon offset costs, as at 24 March 2022 a carbon credit unit was approximately $31.4 Applying this estimated cost to the Diversified (MySuper) investment option’s current carbon intensity, this would amount to 0.15% in additional costs, which would be deducted from investment returns.

Below is a Fees and Costs5 example illustrating how the costs of purchasing carbon offsets would increase the investment costs to members:
Fees and Costs example for a member 100% invested in Diversified (MySuper) for a 1-year period with a $50,000 account balance
  Current Fees and Costs If we used carbon offsets
Administration fees and costs $65 p.a. plus 0.10% p.a. of the account balance,
capped at $500 = ($65 + $50) = $115
$65 p.a. plus 0.10% p.a. of the account balance,
capped at $500 = ($65 + $50) = $115
PLUS Investments fees and costs 0.70% = $350 0.70% = $350
PLUS Transaction costs 0.09% = $45 0.09% = $45
PLUS Estimated carbon offset costs N/A 0.15% = $75
Totals $510 $585

As you can see, simply using carbon offsets to become carbon neutral increases costs to the membership - thus the importance of the glide path analysis. We needed to model various decarbonisation scenarios across multiple time frames to understand the rate at which we could divest the desired high emitting scope 1, 2 and 3 companies, while ensuring that we did not attract undesirable tracking error6 or inferior performance outcomes.

What does this work tell us?

First and foremost, in the work done so far, there is nothing to indicate that we can’t meet our target of a carbon-neutral investment portfolio by 2030.

In fact, based on the analysis completed to date, we are proud to set an interim target of 35% less emissions (tCO2e/$ million invested) in the Diversified (MySuper) investment option by 2025.7

What does decarbonisation look like for NGS Super?

What does decarbonisation look like for NGS Super?

Our plan for decarbonisation from now until 2025, and then on until 2030 will include:

  • engagement
  • divestment
  • investing in carbon-positive investments.

We have committed to making no new investments in stranded assets and will be communicating this to our investment managers over the course of 2022.


If we have a company or investment that has high scope 1, 2 or 3 emissions, and we can see that they have a sound and realistic business plan to transition to the low-carbon economy within a timeframe deemed acceptable to the Fund (taking into consideration industry trends and the overall global target of net zero by 2050), we will take an engagement approach.

We will regularly meet with the relevant company and/or investment manager to ensure they are progressing with their transformation business plans while still delivering value to the Fund.

NGS Super’s target of carbon neutral by 2030 is an ambitious one, and we are aware that not all of those companies we invest in today may be net zero by this time. But we are willing to accept companies with some level of scope 1 and 2 emissions at 2030 and beyond provided they are genuinely transitioning to the low-carbon economy, pose no transition risk, and we are obtaining acceptable risk-adjusted returns from these investments.

At 2030 we envisage that we will have investments that:

  1. have low or justifiable scope 1 and 2 emissions
  2. are carbon-neutral or
  3. are carbon-positive, offsetting those investments within the portfolio at point (1).


Our divestment assessment and program starts now. Any asset we deem as a stranded asset will be flagged for assessment and divestment. An exclusion list and divestment plan is being formulated.

The timing of our divestment from these companies will vary, but we have committed to have no stranded assets in the portfolio by 2025 — this ensures we can divest in the best financial interests of members.

The Fund does hold investments in unlisted unit trusts which are pooled vehicles and, at times, we don’t have veto rights on the acquisition of new assets within these funds. Redemption can also take time. We are communicating closely with our unlisted investment managers, advising of our wish not to acquire any of these assets in the future.

Investing in carbon-positive and low emission investments

We have been and will continue to seek out what we deem to be carbon-positive and low-carbon investments within our portfolio. Carbon-positive investments are investments in things like carbon capture and storage (also known as carbon sequestration) and timber or forestation projects.

Low-emission investments are investments that promote solutions for the transition to the low-carbon economy. Examples include (but are not limited to):

  • renewable energy generation and distribution
  • low-carbon energy generation and storage
  • green bonds (financing initiatives to combat climate change).

Reporting and feedback

reporting and feedback

Each year, we commit to report on our progress against our new interim target and the end goal of net zero emissions in the investment portfolio by 2030. Each year we will:

  1. re-measure the carbon intensity of the portfolio and track progress
  2. re-evaluate the scenario analysis findings and
  3. reassess the Fund’s glide path analysis and pathway to a carbon neutral investment portfolio by 2030 and adjust as necessary.

Members’ best financial interests remain paramount

The work outlined above has confirmed that we can make significant progress towards our net zero by 2030 target while acting in the best financial interests of members. Acting in the best financial interests of our members is the paramount duty for the Trustee and will always be the first consideration as we embark on our decarbonisation journey and at each annual progress review. If at any point it becomes clear that we may be jeopardising our members’ best financial interests, we will adjust our goals and timeframes accordingly.

Appendix: Scenarios

1 CO2e – Carbon Dioxide equivalents.
2 Several areas were deemed out of scope for the measurement of scope 1 and scope 2 emissions mainly due to: risks of double counting; inability to attribute carbon emissions to certain asset types such as government bonds, commodities (gold), cash, term deposits and derivatives; immaterial holdings; assets that are in wind-down (return of capital phase).
3 Estimate.
4 Australian Carbon Credit Unit (ACCU) as at 24 March 2022.
5 Based on the NGS Super Fees, Costs and Tax Fact Sheet dated 20 April 2022 and supplemented with estimated carbon offset costs from the Australian Carbon Credit Unit (ACCU) as at 24 March 2022.
6Also known as deviation away from the benchmark.
7 The base line emissions calculation is as at 30 June 2021.
8 35% less emissions as at 30 June 2025 (when compared to the 30 June 2021 emissions measurement).

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