ESG and climate disclosure
Disclosure where it matters. Not where it doesn't.
Wavestar's ESG program is built against the Task Force on Climate-Related Financial Disclosures (TCFD) framework, with forward migration to the IFRS Sustainability Disclosure Standards (IFRS S1 and S2) issued by the ISSB. Our social disclosures are benchmarked against SASB industry standards for the financial-infrastructure sector. Governance disclosures follow the long-standing NYSE-listed corporate- governance baseline.
- Climate framework
- TCFD · ISSB / IFRS S1+S2
- Social framework
- SASB FMI · EEO-1 reporting
- Governance framework
- Audit Committee · NYSE baseline
- First TCFD report
- FY2027 · published 2028
Climate · TCFD
Four pillars. Reported annually.
The TCFD framework structures climate disclosures across four pillars — governance, strategy, risk management, and metrics and targets. Wavestar's first full TCFD report is issued for FY2027. A pre-report scoping exercise completes in 2026 to set the baseline.
- 01
Governance
The Board holds oversight of climate-related risks and opportunities. A designated Risk Committee reports to the Board on climate matters at least annually. Management accountability sits with the CFO and COO. - 02
Strategy
Climate scenarios assessed against a 1.5°C and a 3°C pathway through 2050. Transition risks (regulatory, market, reputational) and physical risks (acute, chronic) are documented. Opportunity mapping identifies the clearing-house contribution to an orbital decarbonisation tape. - 03
Risk management
Climate risk is integrated into the enterprise risk register. The Risk Committee assesses material climate exposures alongside regulatory, counterparty, and operational risks at each quarterly review. - 04
Metrics and targets
Scope 1, 2, and 3 greenhouse-gas emissions are measured under the GHG Protocol from the FY2027 baseline. Absolute reduction targets, science-based where appropriate, are set after the baseline is locked. Net-zero-by-2040 is the working ambition, subject to ratification once the baseline is available.
Climate roadmap
Sequencing the climate program.
- 2026In progress
Baseline scoping
Enterprise boundary set, data-collection framework designed, preliminary Scope 1 and 2 inventory for the Wyoming and New York operating footprint. Cloud-provider Scope 3 emissions received from the primary hyperscaler. - 2027Planned
FY2027 baseline year
First full-year greenhouse-gas inventory across Scopes 1, 2, and 3. Materiality assessment against the SASB Financial Infrastructure standard. Internal carbon price introduced for cloud consumption reviews. - 2028Planned
First TCFD report published
Full TCFD-aligned climate disclosure for FY2027 published alongside the FY2027 annual report. Baseline emissions locked, transition scenario-analysis published, and first reduction targets announced. - 2029Planned
ISSB / IFRS S1+S2 migration
Transition to ISSB Sustainability Disclosure Standards S1 (general) and S2 (climate). Alignment with SEC climate-disclosure rules and EU CSRD requirements where applicable to Wavestar's counterparties. - 2030Planned
Third-party assurance
Independent limited assurance on the climate disclosure issued by a qualified third party. Progression to reasonable assurance tracking the timeline set by the applicable regulators.
Social
Workforce, culture, and counterparty responsibility.
- 01
Workforce DEI reporting
Workforce diversity data published annually from FY2027, using EEO-1 categories where meaningful given headcount. Includes gender and ethnicity composition across the workforce and the leadership team, with explicit small-numbers caveats where applicable. - 02
Pay equity
Formal pay-equity analysis conducted annually. Any statistically material gaps remediated on the following compensation cycle. Methodology disclosed; results disclosed with appropriate privacy protections. - 03
Human-rights due diligence
Modern-slavery statement published annually under UK MSA 2015 § 54. Supplier human-rights diligence integrated into onboarding. Dodd-Frank § 1502 conflict-minerals diligence applied to cryptographic-hardware suppliers. - 04
Counterparty responsibility
Membership eligibility is conditioned on counterparty adherence to the Wavestar Code of Conduct, which incorporates sanctions compliance, human-rights commitments, and responsible operating practice. - 05
Community and industry
Active participation in space-industry associations and financial-market-infrastructure standards bodies. Open-source contributions to protocol SDKs and registry schemas under Apache 2.0. - 06
Health and safety
Employees are supported through comprehensive health coverage, mental-health parity, and flexible-work arrangements. Serious incidents are reported under applicable OSHA requirements.
Governance
Board, committees, and voting policy.
Governance baseline
- Board composition
- Founder seat, lead-investor seat, two independent directors, one regulatory-experienced director
Majority-independent target at Series A close. Director tenure capped at ten years.
- Committees
- Audit, Risk, Compensation, Nominating & Governance
Audit and Risk chaired by independent directors. Each committee has a published charter.
- Director training
- Initial director onboarding plus annual continuing-education programme
Covers clearing-house governance, regulatory developments, cybersecurity, and ESG.
- Lead independent director
- Appointed from among the independent directors at Series A close
Standing agenda item at every non-executive session.
- Voting rights
- One vote per unit · no dual-class structure
Charter prohibits differential voting rights on matters of corporate control.
- Related-party transactions
- Audit Committee pre-approval required for any related-party transaction above a materiality threshold
Policy published at /compliance/conflicts; aggregate disclosed in annual governance report.
Principles
What the program will not do.
ESG enquiry
Speak with the sustainability lead.
Institutional investors, insurers, and counterparties with specific ESG diligence questions can engage directly with the sustainability lead through investor relations.