Quarterlytics / Energy / Oil & Gas Integrated / Santos Ltd / FY2024 Annual Report

Santos Ltd
Annual Report 2024

STO · ASX Energy
Claim this profile
Ticker STO
Exchange ASX
Sector Energy
Industry Oil & Gas Integrated
Employees 1001-5000
← All annual reports
FY2024 Annual Report · Santos Ltd
Loading PDF…
ENERGY 
FOR  
GENERATIONS

Annual Report  

2024

Incorporating Appendix 4E 

This report has been prepared in 
accordance with the Corporations Act 
2001 (Cth), the Australian Accounting 
Standards, and other authoritative 
pronouncements of the Australian 
Accounting Standards Board, the Global 
Reporting Initiative (GRI) Standards, the 
Task Force on Climate-related Financial 
Disclosures (TCFD) recommendations. 
The report has also been prepared 
with reference to reporting frameworks 
including the Australian Stock Exchange 
(ASX) Corporate Governance Council’s 
Principles and Recommendations 
(4th edition). All references to dollars, 
cents or $ in this document are to 
US currency, unless otherwise stated. 
An electronic version of this report is 
available on Santos’ website santos.com.

Important notices
Forward-looking statements and 
scenario analysis limitations

This Annual Report contains forward-
looking statements that reflect Santos’ 
expectations at the date of this report 
(including with respect to Santos’ 
strategies and plans relating to climate 
change). These statements are based 
on management’s current expectations 
and reflect judgements, assumptions, 
estimates and other information 
available as at the date of this 
document and/or the date of Santos’ 
planning processes. However, a range 
of variables could cause actual results 
or trends to differ materially from 
the statements we have made. These 
variables include but are not limited 
to: price or currency fluctuations, 
actual demand, geotechnical factors, 

drilling and production results, gas 
commercialisation, development 
progress, operating results, 
engineering estimates, reserves and 
resource estimates, loss of market, 
industry competition, environmental 
and climate-related risks, carbon 
emissions reduction and associated 
technology risks, physical risks, 
legislative, fiscal and regulatory 
developments, economic and 
financial market conditions in various 
countries, approvals, conduct of joint 
venture participants and contractual 
counterparties, cost estimates, 
reputational risk, social licence and 
stakeholder risk and activism.

Santos makes no representation, 
assurance or guarantee as to the 
accuracy, completeness, correctness, 
likelihood of achievement or 
reasonableness of any forward-
looking statement contained in this 
report or any assumptions on which 
these statements are based. Except 
as required by applicable laws or 
regulations, Santos does not undertake 
to publicly update or review any 
forward-looking statements. Past 
performance cannot be relied on as a 
guide to future performance.

This report also discusses scenario 
analysis. There are inherent limitations 
with scenario analysis. Scenarios do 
not constitute definitive outcomes and 
it is difficult to predict which, if any, of 
the scenarios discussed in this report 
might eventuate. Scenarios are based 
on assumptions, which may or may 
not be, or prove to be, correct, and 
may or may not eventuate. Scenarios 

may be impacted by additional factors 
to the assumptions disclosed.

Information prepared by third parties

Certain information contained in 
this report is based on information 
prepared by third parties. Santos 
does not make any representation or 
warranty that this third-party material 
is accurate, complete or up to date.

Unreasonable prejudice

As referred to and articulated in the 
section Unreasonable prejudice on 
page 166 of this report, Santos has 
omitted some information in relation 
to the Group’s business strategies, 
prospects and likely developments 
in the Group’s operations and the 
expected results of those operations in 
future financial years on the basis that 
such information, if disclosed, is likely 
to result in unreasonable prejudice 
(for example, information that is 
commercially sensitive, confidential or 
could give a third-party a commercial 
advantage).

Santos' carbon storage growth target

This is a target not a forecast and 
is a growth target for gross storage 
from Santos operated carbon storage 
projects. The target is ambitious and 
subject to substantial engineering, 
finance, commercial and policy work 
to establish enabling frameworks with 
customers, governments, regulators 
and other stakeholders. The potential 
projects that would enable achieving 
the target remain at an early phase of 
planning and commercial and economic 
viability is still to be confirmed.

Appendix 4E

Results for Announcement to the Market1  

Revenue/Profit
Revenue from ordinary activities 
Net profit from ordinary activities after tax attributable to members2
Net profit for the period attributable to members2
Underlying profit for the period2,3 

Dividends

Current financial year
2024 Interim dividends ordinary securities2
2024 Final dividends ordinary securities2

Total

Previous corresponding financial year
2023 Interim dividends ordinary securities

2023 Final dividends ordinary securities

Total

Down 9% to

Down 14% to

Down 14% to

Down 16% to

US$million
5,381

1,224

1,224

1,201

Amount  
per security  
US cents

Franked amount 
per security at  
30% tax  
US cents

13.0

10.3

23.3

8.7

17.5

26.2

Nil franked

Nil franked

Nil franked

Nil franked

Nil franked

Nil franked

Up 49%

Down 41%

1  This report is based on audited accounts.

2  Comparisons are made to the financial year ended 31 December 2023.

3 

 Underlying profit is a non-IFRS measure that is presented to provide an understanding of the underlying performance of Santos’ operations. The measure excludes 
the impacts of asset acquisitions, disposals and impairments, as well as items that are subject to significant variability from one period to the next, including the 
effects of fair value adjustments. The non-IFRS financial information is unaudited, however the numbers have been extracted from the financial statements which 
have been subject to audit by the Company’s auditor. A reconciliation between net profit for the period and underlying profit is provided in the 2024 Annual Report.

Acknowledgement

Santos acknowledges the Traditional Custodians of the areas 
on which we work and pays respect to Elders past and present.

Our reporting suite

This report forms part of our annual reporting suite which brings together information on Santos' financial and sustainability 
performance for the year, and other disclosures.

ENERGY 
FOR  
GENERATIONS

Annual Report  

2024

Incorporating Appendix 4E 

2024 Full year results
19 February 2025

Annual Report

Sustainability Data Book

Our primary disclosure document 
containing our operational and financial 
review, sustainability and climate 
performance, remuneration report, 
financial statements and key governance 
disclosures.

SUSTAINABILITY
DATA BOOK

Provides key data for sustainability 
metrics, trends and additional 
sustainability disclosures.

2024 Full Year Results

Modern Slavery Statement

Provides performance highlights and 
supplementary information on Santos' 
strategic and financial performance for 
the convenience of analysis and 
institutional investors.

MODERN SLAVERY 
STATEMENT

Statement for 2023

Describes how we identify, assess and 
address modern slavery risks within our 
operations and supply chains. Santos' 
Modern Slavery Statement will be 
released later in the year.

Climate Transition Action Plan

Addresses our key strategic climate policy 
commitments and provides an update on 
our Climate Transition Action Plan (CTAP).

Annual  
Report

Full Year 
Results

Sustainability 
Data Book

Modern 
Slavery 
Statement

Climate 
Transition 
Action Plan

Where to find

Business strategy

Corporate governance

Financial performance

Climate

Board membership, skills and experience

Sustainability governance

Sustainability performance

 Comprehensive    Key messages

The 2024 reporting suite can be found  
online at: santos.com/investors 

Cover photo 
Moomba Carbon Capture and Storage 

1

Santos Annual Report 2024 
  
 
 
Corporate Governance Statement  121
122
2024 Governance highlights 
123
Board of Directors 
126
Santos Leadership Team 
128
Corporate governance at Santos 

Reserves Statement 

Directors’ Report 

Remuneration Report 

Financial Report 
Directors' Declaration 
Independent Auditor’s Report 
Auditor’s Independent Declaration 

Shareholder and additional 
information  
Securities exchange and shareholder information 
Glossary 
Corporate directory 

149

155

169

205
282
283
290

291
292
294
303

Contents

Overview 
About us 
Our operations and customers 
2024 year in review 
Our emissions performance 
Letter from the Chair and the  
Managing Director and CEO 
Our values 

Our business 
Energy market update – Underpinning our strategy 
Company strategy 
Capital allocation framework 
How we create and deliver value 
Our portfolio 
Our projects 

Sustainability Report  
Our approach to sustainability 
Governance 
Health and safety 
Environment 
People and culture  
Community relations 
Economic sustainability 
Sustainability advocacy 
Santos Foundation 

Climate Report 
Governance 
Strategy 
Our targets 
Building a commercial carbon storage business 
Our approach to the Paris Agreement 
Our emissions performance 
Scope 1 and 2 emissions reduction plan 
Scope 3 emissions reduction plan 
Our approach to methane emissions 
Capital allocation and governance 
Just transition 
Climate Transition Action Plan 
Delivering on our Climate Transition Action Plan 
Targets and metrics 
Climate risk management 
Portfolio resilience and scenario analysis 
Investor feedback and our response 
Appendices 
Independent Limited Assurance Report 

3
4
5
6
8

10
12

13
14
16
17
18
20
22

24
25
33
37
41
48
51
55
60
64

68
69
70
71
71
72
73
74
75
76
78
79
80
82
89
91
98
109
111
115

2

Santos Annual Report 2024O
v
e
r
v
i
e
w

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

3

OVERVIEW

About us

Our operations and customers

2024 year in review

Our emissions performance

Letter from the Chair and the Managing Director and CEO

Our values

4

5

6

8

10

12

Santos Annual Report 2024

 
 
 
 
 
 
 
 
 
About us

Our purpose is to provide reliable and affordable energy to help create 
a better world for everyone. 

Santos is a global energy company with 
operations across Australia, Papua New 
Guinea (PNG), Timor-Leste and the 
United States of America (USA). 

Santos is an important Australian 
domestic gas supplier and liquefied 
natural gas (LNG) supplier in Asia.  
We are committed to supplying critical 
fuels such as oil and gas, and abating 
emissions through carbon capture and 
storage (CCS), energy efficiency projects, 
use of renewables in our operations and 
high integrity emissions reduction units. 

At Santos, our goal is to backfill and 
sustainably grow our oil and gas 
portfolio to meet growing energy 
demand and provide reliable, affordable 
energy the world needs for modern life 
and human progress. 

LNG growth will be supported by 
demand growth in Asia, decarbonisation 
through CCS and the development of 
low carbon fuels as energy markets 
and customer demand evolves.

There is customer and third-party 
interest in carbon management services 
through CCS, which gives Santos 
confidence in the potential to build a 
commercial carbon management 
business both reducing emissions and 
providing an economic return.

For 70 years, Santos has been working 
in partnership with local communities, 
providing jobs and business 
opportunities, safely developing natural 
gas resources to power industries and 
households. 

The Santos portfolio is resilient across a 
range of decarbonisation scenarios. 
Santos has a Climate Transition Action 
Plan (CTAP) that will continue to evolve 
with time. 

Santos has a regional operating  
model. The Company’s operating 
structure comprises three regional 
business units focused on executing 
corporate strategy and a Midstream 
Energy Solutions business unit. 

Santos is committed to delivering 
superior value for shareholders.

87.1mmboe

Production volume

$5.4b

Sales revenue

3,958

Employees

$12.7b

of cumulative free cash flow  
from operations1 generated since 2016

3,641

2,128

1,891

1,504

1,138

1,006

740

618

206

1 

 Free cash flow from operations is defined as operating cash flows less investing cash flows net of acquisitions and disposals and major growth capital 
expenditure less lease liability payments. The Board will have the discretion to adjust free cash flow for individually material items.

2016

2017

2018

2019

2020

2021

2022

2023

2024

4

Santos Annual Report 2024Our operations 
and customers

PIKKA

NORTH  
AMERICA

Anchorage

87.1mmboe

Production volume

CHINA

TAIWAN

MALAYSIA

Singapore

SOUTH  
KOREA

JAPAN

Tokyo

LNG export  
Routes

PAPUA NEW GUINEA

TIMOR-LESTE

Dili

BAROSSA

PNG LNG
Port Moresby

PNG DEVELOPMENT PROJECTS

BAYU-UNDAN

Darwin

DARWIN  
LNG

BEETALOO / NT SHALES

AUSTRALIA

GLADSTONE LNG

FAIRVIEW
ROMA

ARCADIA
SCOTIA

MOOMBA

BALLERA

Brisbane

PORT 
BONYTHON

NARRABRI

Adelaide 
(corporate headquarters) 

Sydney

WA CCS

DORADO

BARROW ISLAND
VARANUS ISLAND

NINGALOO VISION
PYRENEES

DEVIL CREEK

MACEDON

Perth

Operating decarbonisation hub

Planned decarbonisation hub

Development projects

Operated facilities

Non-operated facilities

Unsanctioned projects – subject to 
regulatory approvals and/or FID

Santos office locations

5

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Annual Report 20242024 year in review

In 2024 Santos delivered strong free cashflow and returned $757 million 
of declared dividends to shareholders. We safely and permanently 
injected and stored CO2 at the globally significant Moomba CCS project 
and successfully progressed the Barossa and Pikka development projects. 
Santos is rapidly approaching an inflection point, poised to deliver strong 
long-term production and cashflow that will drive shareholder returns 
and position the Company to benefit through the energy transition.

Creating value for our shareholders

$1.9b

Free cash flow 
-11% on 2023

$1.2b

Underlying net profit after tax1 
-16% on 2023

$1.2b

Net profit after tax1 
-14% on 2023

$2.9b $7.85

Capital expenditure2 
+9% on 2023

Production cost per barrel3 
+3% on 2023

10.3cps

Dividend per share 
-41% on 20234

Development project execution

Pikka phase 1

Barossa gas project

Pikka phase 1 is 74 per cent complete as of end-2024 and 
on track to deliver first oil in mid-2026. The current focus 
is on accelerating pipelay activities to two programs from 
three following increased realised productivity over the 
2024 winter season, as this may create an opportunity to 
accelerate first oil timing. 15 wells have been drilled as of 
end-2024, with 11 stimulated and 10 flowed back. Well 
tests continue to de-risk the subsurface, with well results 
in line with expectations.

Barossa gas project is now over 88 per cent complete 
and remains on track for production in Q3 2025. The 
Santos-operated Barossa gas project, located in 
Commonwealth waters approximately 285 kilometres 
offshore north-northwest from Darwin in the Northern 
Territory (NT), is a gas and condensate project that will 
provide a new source of gas to the existing Darwin 
LNG plant.

1  Excludes profit attributable to non-controlling interest.

3  Excludes Bayu-Undan.

2 

 Capital expenditure including restoration expenditure but excluding 
capitalised interest.

4  Compared to final 2023 dividend.

6

Santos Annual Report 2024Both safety metrics are our best 
performance in more than 10 years.

Creating value through our ESG approach

340k

Tonnes (gross) of CO2e stored  
at year-end 2024

28.1%

Female employees  
up from 21.3% in 2020, 
>40% for non-field staff

0.14

Loss of containment incident (LOCI) 
rate is our process safety measure 
down 70% from 0.47 in 2023

26%

Reduction in  
Scope 1 and 2 emissions1

$290m

Climate Transition Action Plan  
total spend in 2024

0.081

Lost time injury rate (LTIR)  
down 40% from 0.14 in 2023 
IOGP top quartile in 2023²

Moomba CCS

Moomba CCS project completed 
commissioning and is now online 
and storing CO2 in Cooper Basin 
depleted reservoirs. Technology 
and reservoir performance is in line 
with expectations. Santos injected 
340,000 tonnes (gross) to 
year-end 2024 of carbon dioxide 
equivalent since start up in late 
September 2024, with the project 
already at full injection rates. Phase 
1 has capacity to permanently 
store up to 1.7 million tonnes of 
CO2e annually depending on CO2e 
availability, making Moomba CCS a 
significant part of Australia’s 
journey to Net Zero emissions.

1 

26 per cent absolute reduction is from the Santos and Oil Search combined 2019-20 equity Scope 1 and 2 emissions baseline of 5.9 MtCO2e.

2  Most recent IOGP data available at the time of Annual Report release.

7

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Annual Report 2024Our emissions  
performance

Since our baseline year of 2019-20, our total Scope 1 and 2 equity 
emissions have reduced by 26 per cent, which represents 84 per cent 
progress to our 2030 emissions reduction target.

Since 2016, Santos’ absolute emissions have fluctuated as our production and asset mix has changed. However, both total 
emissions and emissions intensity have reduced since our baseline year of 2019-20 as lower carbon intensive assets have 
been incorporated into the portfolio and in 2024 Moomba CCS came online. 

Scope 1 and 2 net equity emissions

2024 Scope 1 and 2 net equity emissions

5.9

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

6

5

4

3

2

1

0

70

60

50

40

30

20

10

0

y
t
i
s
n
e
t
n

I

s
n
o
i
s
s
i
m
E

e
o
b
m
m
/
e
2
O
C
t
k

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

0.5

0.4

0.3

0.2

0.1

0.0

Total
4.59

Total
4.38

2016 2017 2018 2019 2020 2021 2022 2023 2024

Jan Feb Mar Apr May Jun Jul Aug Sep Oct

Nov Dec

Emissions

Emissions intensity

Oil Search emissions included in baseline year (2019-20) 
for emissions reduction target

Emissions (including Moomba CCS)
Emissions (excluding Moomba CCS)

In 2024, equity emissions reduced to 4.38 Mt, following Moomba CCS start-up at the end of September. Emissions intensity 
in the fourth quarter with Moomba CCS operating at full rates reduced to 45 kt/mmboe, representing an 18 per cent 
reduction from 2019-20 baseline emissions intensity. For calendar year 2024 emissions intensity has reduced by 
approximately 10 per cent since 2019-20, representing 23 per cent progress to our 2030 emissions 
intensity reduction target. 

This rate of reduction in emissions intensity will accelerate as late life assets, including Bayu-Undan and Ningaloo Vision 
FPSO, come to the end of production. Late life assets become more emissions intensive with decreasing production.

New production at Barossa LNG and Pikka will be net-zero reservoir emissions to comply with the Australian Government's 
Safeguard Mechanism and net-zero Scope 1 and 2 equity emissions respectively, resulting in an increase in production 
without the requisite emissions increase as would have been the case historically.

Methane emissions (gross operated)

Scope 3 emissions

Santos methane emissions intensity is well below OGCI target

y
t
i
s
n
e
t
n

i

s
n
o
i
s
s
i
m
e
e
n
a
h
t
e
M

0.20

OGCI methane 

intensity target

0.15

0.10

t
n
e
c
r
e
p

0.05

0.00

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

35
30
25
20
15
10
5
0

0.60

0.50

0.40

0.30

0.20

0.10

0.00

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

2020

2021

2022

2023

2024

Emissions

Emissions intensity

Santos is continuing the focus on reducing methane 
emissions across the business, and in 2024, we continue  
to remain below the Oil and Gas Climate Initiative (OGCI) 
methane emissions target of 0.2 per cent. Since the start- 
up of the Moomba CCS project, our company methane 
emissions have reduced by approximately 21 per cent.1

1 

 Moomba CCS captures and stores both CO2 and methane from the CO2 
removal process.

8

2023

2024

Downstream (Categories 10 & 11)

Upstream (Category 1)

Other Categories

In 2024, Santos continued its focus on better understanding 
Scope 3 emissions sources and improving quantification of 
these. Our significant collaboration with suppliers has resulted 
in improved estimations of upstream (category 1) emissions. 
Our 2024 upstream Scope 3 emissions intensity, expressed as 
tonnes of CO2e per million dollars spent with suppliers, 
reduced by more than 50 per cent compared to 2023. In 2023 
we undertook a detailed analysis of the end use of our 
product and this was repeated in 2024, finding that 
approximately 23 per cent of our products are not combusted 
but instead utilised as petrochemical feedstock.

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
We have made history out at Moomba. It’s a first 
for Santos, it’s a first for South Australia and a first 
for Australia in terms of large-scale, onshore CCS.

Kevin Gallagher, Managing Director and CEO

The Honourable Peter Malinauskas MP, Premier of South Australia with Managing Director and CEO 
Kevin Gallagher at the Moomba CCS plant official opening on 31 January 2025.

9

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Annual Report 2024 
Letter from the Chair and the 
Managing Director and CEO

Keith Spence, Chair (left), and 
Kevin Gallagher, Managing Director 
and CEO (right).

oil in the first half of 2026. Fifteen 
of 26 wells have been drilled and 
completed and importantly, all vertical 
support members for the pipeline 
have been installed. 

When Barossa and Pikka come online, 
Santos’ production is expected to 
increase by more than 30 per cent by 
2027 compared to 2024, significantly 
lowering unit production cost which 
will support robust free cash flow 
generation throughout the commodity 
price cycle.

Low cost disciplined 
operating model

2024 delivered strong operational 
performance from the base business, 
providing reliable production and 
cash flows. Our focus on safety has 
produced the best personal and 
process safety performance in more 
than a decade.

In Papua New Guinea, Angore 
was brought online, producing 
~350 mmscf/day (gross) in the fourth 
quarter. PNG LNG continued to 
deliver reliable production, delivering 
108 cargoes, including 11 equity 
cargoes. There was record operated 
equipment reliability of 97 per cent 
in 2024.

In Queensland, GLNG delivered record 
production of 6.08 Mt LNG and 
100 cargoes. In Western Australia, the 
Halyard-2 infill well was successfully 
drilled, completed and tested. 

In Timor-Leste, the Bayu-Undan field 
continued to supply gas into the 
Northern Territory domestic market. 

Dear fellow shareholders,

In 2024, we were unrelenting in 
executing our strategy to backfill and 
sustainably grow production, while 
continuing to decarbonise our base 
business.

The last year has set the business up 
for an exciting 2025 as the Barossa 
LNG Project is set to deliver increased 
production and cash flows and the 
Moomba CCS Project builds on its 
successful start-up in 2024.

Always Safe is a core value at Santos 
and we made significant progress in 
2024, with a 40 per cent improvement 
in Lost Time Injury Rate from 2023 
and a 60 per cent reduction in our 
Moderate Harm Injury Rate.

This improved safety performance 
is a result of the commitment and 
dedication of our teams. Across the 
business in 2024, almost 27,000 
STRIVE safety conversations were 
held to keep safety at the forefront 
of everything we do.

Strong base business 
operational performance 

Santos delivered annual production 
of 87.1 mmboe, sales revenue of 
$5.4 billion and free cash flow from 
operations of $1.9 billion – allowing 
$757 million in dividends to be 
returned to shareholders.

With net debt of $4.9 billion, 
liquidity of $4.4 billion and gearing 
at 23.9 per cent, including leases, 
our balance sheet remains strong. In 
addition, we have put hedges in place 
to continue to protect the balance 
sheet from down side commodity and 
foreign exchange risk through 2025.

As Santos reaches an inflection point 
in 2025, with new production to 
come online, we will remain focused 
on driving our low cost disciplined 
operating model to deliver free cash 
flow to drive shareholder returns.

In 2024, we announced a new Capital 
Allocation Framework that will target 
returns to shareholders of at least 
60 per cent of all-in free cash flow 
from 2026 once the current major 
development projects are online. 
This framework underpins our 
commitment to shareholder returns 
when new production comes online 
following completion of the Barossa 
and Pikka projects.

Development projects

2024 was an historic year for Santos 
with the successful start-up of our 
1.7 million tonnes per annum Moomba 
CCS project in September. The project 
had an immediate impact on the 
company’s emissions, driving equity 
emissions in the fourth quarter 14 per 
cent lower than the prior quarter. 

The Moomba CCS project captured 
and stored 340,000 tonnes of CO2 
from first injection and the technology 
and reservoirs are performing as 
expected.

The Barossa LNG project was nearing 
90 per cent completion at year-end 
and is on track for first gas in the 
third quarter of 2025. We are well 
progressed with the drilling program 
and the Darwin Life Extension project 
was 72 per cent complete at year-
end 2024. 

The Pikka project in Alaska made 
significant progress through 2024 and 
was 74 per cent complete at year-end 
2024 and remains on track for first 

10

Santos Annual Report 2024We are proud to share Santos’ first 
integrated report. The report consolidates 
our financial, sustainability, and climate 
performance, demonstrating all aspects 
of business performance.

Decarbonisation

In 2024, Santos' Scope 1 and 2 equity 
emissions were 26 per cent lower  
than our baseline year of 2019-20. 

This reduction represents 84 per  
cent progress to our 2030 target 
to reduce Scope 1 and 2 emissions 
by 30 per cent. Over the same time 
period, our emissions intensity has 
reduced by approximately 10 per cent. 

The success of Moomba CCS and 
the positive outlook for CCS demand 
growth gives us confidence in setting 
a new carbon storage growth target1 
to build and operate a commercial 
third-party carbon storage business. 

The new target was supported by 
ongoing shareholder engagement and 
supports a long-term aspiration for 
Santos to store more carbon than we 
emit (Scope 1, 2 and equivalent 3). 

We believe our Climate Transition 
Action Plan strikes the right balance in 
lowering our emissions and continuing 
to deliver the fuels the world demands, 
while developing commercial carbon 
management services and low carbon 
fuels to meet customer demand. 
Santos applies the same stringent 
economic criteria to CTAP projects 
at FID as we do to traditional oil and 
gas projects and the pace of new low 
carbon fuels will be customer led.

This approach has been shaped by 
investor engagement. Santos’ Board 
and management have held 222 
meetings with investors since 2022, 
including 151 meetings in 2024, to 
listen to what investors are saying.

In 2025, our climate transition 
approach will again be put to a non-
binding advisory Say on Climate vote 

at our AGM. A summary of our climate 
performance can be found in our 
Climate Transition Action Plan update. 
We ask for your support for our 2025 
Say on Climate. 

Creating shared value 

We continue to be proud of our 
employees’ passion and unwavering 
commitment to be a part of, and 
contribute to, the creation of long 
term shared value for our stakeholders 
which include our communities, 
Traditional Custodians, employees 
and suppliers as well as our 
shareholders. 

Building a better world begins with 
our people, as demonstrated by the 
recognition of the Santos Foundation 
at the esteemed Platts Global Energy 
Awards. The Foundation’s local Bel isi 
PNG initiative, aimed at changing 
attitudes towards family and sexual 
violence, was honored with the 2024 
Corporate Impact Award – Targeted 
Program. This award acknowledged 
the program’s support for over 2,000 
women and children, as well as 
educational sessions provided to 
5,000 private sector employees.

In 2024, Santos won 15 external awards 
across Australia, Papua New Guinea 
and the United States, including for 
our Healthier Me initiative, community 
awards for our Indigenous Training and 
Employment program in the Northern 
Territory and for the Santos Aboriginal 
Power Cup in South Australia as well 
as our people being recognised as 
leaders in safety.

Outlook

2024 was another peak consumption 
year for hydrocarbon fuels globally, 

1  Refer to ‘Important notices’ for further information on this target.

making it increasingly clear that 
decarbonisation of their production 
and use is critical to the world’s Net 
Zero goals.

Wood Mackenzie's latest gas outlook 
shows that global gas demand 
will grow 13 per cent overall to 
2034, supported by 34 per cent 
growth in Asia. Santos is well 
placed to meet ongoing demand 
with low-cost production and a 
leading infrastructure and adjacent 
resource position.

In 2025 we remain focused on 
driving shareholder returns by 
delivering our low-cost operating 
model and executing on our major 
development projects.

On behalf of the Board and 
management team, we would like 
to take this opportunity to thank our 
employees and contractors who work 
tirelessly for our shareholders. To you 
our shareholders thank you for your 
ongoing trust and support. 

Keith Spence 
Chair

Kevin Gallagher
Managing Director  
and CEO

This letter is current as at  
31 December 2024

11

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Annual Report 2024 
 
 
 
 
Our values

The Santos values define our beliefs about people, work and 
behaviours. They reflect how we work, how we treat each other 
and how we interact with the people and communities around us. 
In essence our values are a distinct blueprint for behaviour at Santos.

Our values will help shape the culture we require to deliver on our 
strategy, serve our purpose and achieve our vision. They are:

Work as one team

•  Value diverse perspectives

Be accountable 

•  Do what we say we are going to do

•  Challenge respectfully then get behind 

•  Take responsibility for our actions

the decision

•  Unite and share learnings

•  Be disciplined about meeting 
requirements and standards 

•  Learn from success and failure

Always safe

•  Plan work to protect all from harm

•  Be skilled and competent

•  Understand the risks, controls 

and barriers

•  Follow the rules and respond 

to change

•  Speak up

•  Step back, think and be ready

Act with integrity

•  Act ethically and do the right thing

•  Value our customer relationships

•  Confront the facts

•  Treat people with respect

Pursue exceptional results

•  Deliver value for our stakeholders

•  Be decisive about what we can do 

better

•  Recognise and reward achievement

•  Strive for constant improvement

•  Enable innovation

Build a better future

•  Leave a positive legacy 

• 

Invest in our people

•  Have a positive impact 
in our communities

•  Protect the environment

•  Be health and safety champions

12

Santos Annual Report 2024O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

OUR  
BUSINESS

Energy market update – Underpinning our strategy

Company strategy

Capital allocation framework

How we create and deliver value

Our portfolio

Our projects

14

16

17

18

20

22

Santos Annual Report 2024

13

 
 
 
 
 
 
 
 
Energy market update  
Underpinning our strategy

In 2024, geopolitical tensions and regional conflicts continued to 
highlight the fragility of global energy systems, underscoring the 
critical need for reliable and affordable energy supplies.

The conflict in the Middle East and 
leadership changes in significant 
nations have occurred against 
a backdrop of continued high 
inflation and cost of living pressures. 
Increased demand for oil and natural 
gas has underscored the need for 
ongoing production and investment 
in hydrocarbons.

Macroeconomic

The global economy in 2024 was 
marked by geopolitical instability and 
macroeconomic uncertainty, which 
continue to pose risks to markets. 
This has led to a renewed focus on 
energy security amid ongoing price 
volatility and increasing challenges for 
the energy transition as technology 
development has fallen behind.

The latest UN forecast the global 
population will increase from 
about 8 billion people in 2023 
to approximately 8.5 billion by 2030.2 
During this period global energy 
demand is expected to continue 
rising at an average annual rate of 
0.7 per cent, driven primarily by 
emerging and developing economies.3 
By 2030, the largest increases in 
demand are projected to come from 
India, Southeast Asia, the Middle East 
and Africa.4

Oil

The Organization of the Petroleum 
Exporting Countries Plus (OPEC+) 
continues to exert control in balancing 
oil markets and maintained production 
cuts through to the end of March 2025.

High interest rates, permitting and 
regulatory barriers, and project 
cancellations have created headwinds 
for lower carbon technologies.

Non-OPEC+ oil production has seen 
significant growth, with an increase of 
approximately 1.5 million barrels per 
day, primarily driven by the Americas.4

Over the past year, several major 
economies have experienced 
leadership changes, bringing different 
approaches to managing high 
inflation, the energy transition and 
regional conflicts. The effects of these 
new policies remain uncertain and are 
yet to be fully realised.

China's economy grew by five per cent 
in 2024, meeting the government's 
target. However, the growth was 
uneven, driven primarily by exports 
and industry.1 The outlook for 2025 is 
uncertain due to global trade tensions.

This robust growth in non-OPEC+ 
supply has helped to balance the 
global oil market despite ongoing 
geopolitical tensions, particularly in 
the Middle East.

Dated Brent averaged ~US$81/bbl in 
2024, down from 2023.5 Oil prices 
are expected to be driven by OPEC+ 
production management through 
2025 and strength of demand growth 
in key markets such as China, in lieu of 
any major disruptions.

Liquefied natural gas

The LNG market remained finely 
balanced in 2024.

Northeast Asian LNG spot prices 
averaged just below US$12/MMBtu, 
down over 25 per cent from 2023.5 
The market is expected to remain 
tight until new supply comes online 
from 2026. Uncertainties around 
the continuation of piped gas from 
Russia into Europe, impacts of Russian 
sanctions and project delays remain 
and could impact the market balance.6

Gas is set to play a pivotal role in the 
Asia Pacific’s energy future, driven 
by the region’s dynamic economic 
and population growth and need to 
meet decarbonisation targets. The 
International Energy Agency's (IEA) 
Stated Policies Scenario (STEPS) 
shows gas demand increasing by over 
25 per cent by 2040.3 The region will 
be home to the largest and fastest- 
growing LNG demand centres in the 
world through the 2030s.6

Wood Mackenzie’s latest gas outlook 
shows that global gas demand will 
grow 13 per cent overall to 2034, 
supported by 34 per cent growth in 
Asia. Global LNG demand will grow 
55 per cent, with most of the growth 
coming from China this decade, and 
South and Southeast Asia in the 
2030s and beyond.6

1  Reuters, January 2025.

2  United Nations, Department of Economic and Social Affairs, Population Division, World Population Prospects 2024.

3 

4 

International Energy Agency, World Energy Outlook 2024, October 2024.

International Energy Agency, Oil Market Report, January 2025.

5  S&P Global Commodity Insights.

6  Wood Mackenzie, Global gas 10-year investment horizon outlook, November 2024. 

14

Santos Annual Report 2024"Gas is set to play a 
pivotal role in the Asia 
Pacific’s energy future, 
driven by the region’s 
economic and 
population growth 
and the need to meet 
decarbonisation 
targets."

Santos is well-positioned to take 
advantage of the expected growth 
in Asia. Santos’ LNG portfolio is 
largely contracted under long and 
medium-term oil-linked contracts 
into the 2030s with high-quality 
counterparties.

Marketing activities across 2024 
emphasised the long-term demand 
for LNG in the Asian region. In May 
2024 Santos signed a ten-year LNG 
supply contract with Hokkaido Gas 
commencing in 2027. In December 
2024 Santos signed a 12-year LNG 
supply contract with Shizuoka Gas 
commencing in 2032. Both contracts 
will supply approximately 0.4 million 
tonnes per annum of LNG each, from 
Santos’ portfolio of world-class LNG 
assets. A number of other mid-term 
contracts were entered into over 
the year.

Carbon capture and 
storage and low carbon 
fuels

Globally, there has been a strong push 
towards developing and deploying 
CCS technologies. Santos plans to 
expand its carbon management 
services to help businesses achieve 
their decarbonisation targets, 
including overcoming potential 
challenges such as technology 
development and maturity, and 
government policy uncertainty.

Additionally, Santos intends to 
collaborate closely with customers to 
seek to develop low carbon fuels, such 
as synthetic gas, leveraging existing 
infrastructure and responding to 
market needs as demand evolves.

Australian domestic 
markets

The future of supply for the Australian 
domestic gas market faces challenges 
on both the east and west coasts.

This comes as Australia's Future 
Gas Strategy, released in May 2024, 
highlights the essential role of gas in 
achieving Net Zero emissions by 2050, 
while ensuring energy security and 
affordability. 

In Western Australia, new projects will 
be required from 2030 onwards as 
reserves in existing fields decline and 
industrial consumption grows.7 

In the southern states on the east 
coast, further investment in supply 
and infrastructure will be necessary to 
meet demand, with potential seasonal 
shortfalls starting from 2026 and 
annual shortfalls forecast from 2028.8

Santos has projects in both markets 
that could provide additional supply 
to the domestic market, including 
Narrabri in New South Wales (NSW) 
and backfill opportunities close to 
existing domestic gas assets in WA.

7  AEMO, 2024 WA Gas Statement of Opportunities (WA GSOO), December 2024.

8  AEMO, 2024 Gas Statement of Opportunities (GSOO), March 2024.

15

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationCompany  
strategy

Santos’ purpose is to provide reliable and affordable energy to help 
create a better world for everyone.

Business strategy

Santos’ backfill and sustain, 
decarbonisation and low carbon fuels 
strategy builds on the successful 
execution of the previous Transform, 
Build and Grow strategy. From 2016, 
the Transform, Build and Grow strategy 
transformed Santos into a more 
reliable and lower-cost producer 
positioned for disciplined growth and 
sustainable shareholder returns.

Santos’ strategy is focused on 
backfilling our core assets and to 
sustainably grow our portfolio to 
deliver the critical fuels the world 
needs into the 2040s. Santos will seek 
to decarbonise these critical fuels, in 

line with our net-zero emissions 
targets, and also seeks to develop low 
carbon fuels as customer demand 
evolves. For further information, see 
the Climate Report from page 68.

LNG), focused on meeting growing 
LNG demand in Asia. These projects 
are complemented by our integrated 
oil and gas business which includes WA 
and Alaska.

Santos' strategy aims to deliver a 
lower carbon intensity base business 
by driving our disciplined low-cost 
operating model and maximising 
existing infrastructure. This approach 
will sustainability grow shareholder 
returns and fund the energy transition 
over the longer term in line with our 
updated capital allocation framework.

Santos' portfolio includes three 
world-class LNG projects (PNG LNG, 
Gladstone LNG, Barossa to Darwin 

Santos Midstream and Energy Solutions 
is our decarbonisation business, 
focused on enabling the transition to a 
lower carbon energy future, and is 
focused on developing three CCS hubs 
designed to provide decarbonisation 
and carbon management services to 
Santos and third parties. Santos 
Midstream and Energy Solutions will 
seek to develop low carbon fuels as 
market and customer demand evolves 
in the decades ahead.

Backfill and sustain 

Decarbonisation

Low carbon fuels

•  Deliver Barossa and Pikka 
development projects

•  Prioritise LNG backfill opportunities 

•  Develop three CCS hubs to provide 

•  Explore new fuel opportunities 

decarbonisation and carbon 
management services 

•  Market led developments, 

leveraging existing customers 

in PNG, NT and Queensland

•  Develop new revenue streams from 

•  Drive improved performance 

through technology, efficiencies 
and lower cost operations

•  Progress projects in the Bedout 

Basin and Pikka

2024 progress 

•  Barossa Gas project 88 per cent 

complete and on track for 
production in Q3 2025.

•  Pikka phase 1 project 74 per cent 
complete and forecast to deliver 
first oil mid 2026.

•  PNG delivered 108 cargoes with 

reliability at all-time record levels. 
Angore gas development online in 
Q4 2024.

•  Gladstone LNG delivered 6.08 Mtpa 
of LNG, Queensland CSG hitting 
record production rates and 226 
wells drilled, and 254 wells 
connected across Gladstone LNG.

•  Successfully drilled Halyard-2 infill 

well for 2025 tie back to the Varanus 
Island Hub, WA

carbon management services 

• 

Investigate other technologies to 
develop new carbon management 
solutions

2024 progress

•  Moomba CCS phase 1 online and 
running at full injection rates, 
reducing Santos' net equity Scope 1 
and 2 emissions by five per cent 
(0.21 million tonnes per annum)  
in 2024

• 

Initial study completed on  
CCS pipelines for Moomba CCS 
phase 2

•  Approved Front-end Engineering 
Design (FEED) for WA CCS and 
FEED almost complete for  
Bayu-Undan CCS

2024 progress

•  Study agreement signed with 

Japanese customers for concept 
select and pre-FEED studies on 
synthetic gas1 utilising imported 
CO2e as feedstock

Low carbon fuels

Decarbonisation

Backfill and sustain

1 

 Previously referred to as e-methane, terminology updated to adopt more widely recognised term. See the glossary for full definition.

2022

2030

2040

2050

16

Santos Annual Report 2024 
Capital allocation
framework

Santos has been on a transformational journey from 2016 to 2024, 
leading to shareholder value creation through the implementation  
of our disciplined low-cost operating model. 

Santos aims to maintain a predictable and sustainable business model to deliver 
strong shareholder returns through our refreshed capital allocation framework. 
The capital allocation framework is planned to take effect from 2026, once new 
production comes online from the Barossa Gas project and Pikka phase 1 project. 
The projects are expected to increase Santos' production by more than 
30 per cent by 2027 compared to 2024, significantly lowering unit production 
costs which will support strong free cash flow generation throughout the 
commodity price cycle. 

From 2026: Simplified 
framework prioritises 
shareholder returns, 
a strong balance sheet 
and stable production.

We have deployed capital to decarbonise our operations, highlighted by the 
completion of Moomba CCS phase 1, a world-class, low-cost CCS project. 
Through partnerships with customers, we are progressing studies and 
development plans to build a commercial carbon management and low carbon 
fuels business looking to meet market demands and generate returns for 
decades to come.

Strong balance sheet

Shareholder returns

Existing

Target gearing range maintained 
15 – 25%

Disciplined capital  
reinvestment

From 20261

Target shareholder returns 
≥40%
of FCF from operations2

Long-term indicative annual production profiles 
~100 – 140 mmboe

Prioritised shareholder returns 
At least 60% and up to 100%
of all-in free cash flow (FCF)3

Prioritised shareholder returns supported by:

Sustainable annual production target range  
2026-2030 
~100 – 120 mmboe

+

Sustaining and development capital expenditure
Cyclical

Annual sustaining and development  
capital expenditure
Constrained by capital ceiling4

1 

2 

 Updated capital allocation framework effective once new production comes online following the delivery of Barossa gas project, and Pikka phase 1, estimated HY26. 
Existing policy remains until that time.

 Free cash flow from operations is defined as operating cash flows less investing cash flows net of acquisitions and disposals and major growth capital expenditure 
less lease liabilities.

3  All-in free cash flow is defined as operating cash flows less investing cash flows (net of acquisitions and disposals), less lease liability payments.

4  Capital expenditure ceiling is subject to annual Board approval.

17

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationHow we create  
and deliver value

Our diversified portfolio and disciplined operating model delivers strong 
free cash flows for shareholder returns, dept repayments and 
reinvestment.

Upstream oil and 
gas portfolio

Process

Santos' upstream oil and gas portfolio 
is diversified yet focused. Our three 
regional business units deliver safe and 
reliable production from our assets and 
prioritise backfilling and sustainably 
growing production through our 
extensive infrastructure position. 

Santos' disciplined operating model 
makes the company resilient through 
the commodity price cycle. This 
enables us to deliver competitive 
returns to shareholders and reinvest in 
developments to create long-term 
value for shareholders.

Santos has three business sectors: 

•  LNG 

• 

Integrated oil and gas 

•  Midstream energy solutions.

Products and transportation

Santos has a high-quality LNG 
portfolio ideally located to meet 
growing energy demand in Asia. Our 
strong position in the Asian market is 
supported by our proximity to 
demand centres, long-term LNG 
contracts with strong pricing, 
reputation for reliable supply and 
high-heating value LNG.

Santos disciplined operating model

Asset lifecycle

Portfolio and portfolio rules

Diversified portfolio

Resource add

LNG Assets

Integrated  
Oil and Gas

Midstream  
and Energy 
Solutions

Development

Disciplined criteria

Production

Marketing

18

Portfolio target operating free cash flow 
breakeven at ≤US$35/bbl , excluding major 
development capex

Each asset target operating free cash flow 
breakeven at ≤US$35/bbl , excluding major 
development capex

Target gearing range of 15-25%

All investments meet corporate hurdle rates

Santos Annual Report 2024Santos Midstream and Energy Solutions

Carbon capture and storage

Our CCS projects have the potential to create a new 
revenue stream through the storage of third-party 
emissions as well as decarbonising Santos' base business.

There is strong customer interest in our CCS hubs 
and Santos has signed a series of memorandums 
of understanding (MOUs) with domestic and international 
third parties.

Future products

Santos is investigating low carbon fuel opportunities which 
could deliver long-term affordable and reliable energy for 
our customers. 

Disciplined capital allocation

Creating shared value

Santos is committed to delivering social value across 
our business, investing in the communities in which 
we operate and building a diverse workforce.

We are confident this will enable Santos to deliver on 
our strategy and continue to generate value for 
employees and shareholders.

$757m

Dividends declared to shareholders in 2024

$1b

Global tax paid in 20241

$25.1m 

Combined community investment and Santos 
Foundation spend in 20242

Return to 
shareholders

Debt repayment

Reinvest:  
backfill and grow

1 

2 

 Global tax paid includes royalty-and government related taxation, corporate 
income tax and employee tax paid.

 Community investment is Santos gross spend for operated assets. Santos 
Foundation spend is for both Australian and PNG (and include both Santos 
funded and also 100% JVPNG LNG) and are unaudited.

19

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur  
portfolio

Santos has a portfolio of world-class LNG plants, adjacent to prolific gas 
resources and diverse integrated oil and gas production assets.

Cooper Basin

Oil and gas

The Cooper Basin asset is strategically 
important, housing key infrastructure, 
including the Moomba Gas Plant, that 
is integral to the processing and 
transportation of natural gas around 
the east coast of Australia and to 
Gladstone LNG.

Santos Midstream and Energy 
Solutions

The Moomba CCS phase 1 project is 
now online and storing CO2 in Cooper 
Basin depleted reservoirs. Technology 
and reservoir performance is in line 
with expectations. Santos injected 
340,000 tonnes (gross) of carbon 
dioxide equivalent in 2024, with the 
project operating at full injection rates. 
Moomba CCS has outstanding growth 
potential depending on the availability 
of CO2 for storage.

Queensland and NSW

Domestic gas

LNG

Gladstone LNG (GLNG) is a joint 
venture between Santos and three 
global energy companies. Natural gas 
from fields in the Bowen and Surat 
Basins in Queensland and from the 
Cooper Basin is transported via a 
420-kilometre underground pipeline 
to the Gladstone LNG plant, a two-train 
liquefaction and storage facility on 
Curtis Island in Gladstone. 

Gladstone LNG sells approximately two 
cargoes per week and the GLNG plant 
produced over 6 Mt and sold 100 
cargoes of LNG in 2024. It has been 
supplying two long-term Asian 
customers since the first cargo was 
shipped in October 2015. Feed gas is 
sourced from Gladstone LNG's 
upstream fields and the Cooper Basin, 
Santos portfolio gas and third-party 
suppliers.

Santos is progressing the proposed 
Narrabri domestic gas project in NSW. 
Santos is continuing to progress land 
access agreements, cadastral surveys 
and environmental assessments to 
finalise the Hunter Gas Pipeline route 
alignment and has commenced 
preliminary works on supporting 
infrastructure.

Papua New Guinea

LNG

The PNG LNG project is an integrated 
development that includes gas 
production and processing facilities 
that are connected by over 700 
kilometres of onshore and offshore 
pipelines. The facilities include a gas 
conditioning plant in Hides and a 
two-train liquefaction and storage 
facility near Port Moresby. LNG 
production began in April 2014 and 

 Cooper Basin 

 Queensland and NSW 

13.4mmboe

Production

14.5mmboe

Production

$682m

Revenue

$1,369m

Revenue

$10.78/boe

Production cost

$7.26/boe

Production cost

$390m

EBITDAX 

$799m

EBITDAX

20

Santos Annual Report 2024since then, PNG LNG has been reliably 
supplying LNG to four long-term 
major customers in Asia. 

Northern Australia and 
Timor-Leste

Western Australia

Oil and gas

The PNG LNG plant produced over 
8 million tonnes of LNG in 2024 and 
shipped 108 cargoes. LNG production 
was down on the previous 
corresponding period (8.4 million 
tonnes of LNG), primarily due to Hides 
field natural decline, partially offset by 
continued high compression reliability 
from Santos-operated gas production 
from Kutubu and Gobe fields. 
Production at the two Angore wells 
started in the fourth quarter of 2024, 
returning the PNG LNG plant to full 
capacity. In 2024 Santos completed 
the sale of 2.6 per cent of PNG LNG 
to Kumul Petroleum Holdings 
Limited (Kumul). Santos' total cash 
consideration for the transaction 
was US$602 million. Santos reduced 
our equity position in PNG LNG 
to 39.9 per cent.

Near-term backfill opportunities for 
PNG LNG include the APF tie-in 
project, which is a development of 
associated gas from Agogo and Moran 
oil fields to supply ~0.8 trillion cubic 
feet of gas to PNG LNG delivering up 
to 250 million standard cubic feet per 
day gross and Hides Footwall which is 
targeting potential incremental 
volumes up to ~160 million standard 
cubic feet per day gross within Hides 
field. Santos has medium and longer 
term backfill and growth opportunities 
including Papua and P'nyang.

Darwin LNG

The Darwin LNG facility is currently a 
single train liquefaction and storage 
facility with the approvals in place for 
further expansion of a second train. 
The Bayu-Undan field, which has 
supplied gas to Darwin LNG via a 
26-inch subsea pipeline for many 
years, is located in Timor-Leste 
offshore waters, approximately 250 
kilometres southeast of Timor-Leste 
and 500 kilometres northwest of 
Darwin. In 2024 Bayu-Undan supplied 
gas directly into the NT domestic 
market following the end of economic 
LNG production, as the fields nears 
end of life. The Darwin LNG plant has 
the capacity to produce approximately 
3.7 million tonnes of LNG per annum 
and will process natural gas from the 
Barossa LNG Project once online.

Santos Midstream and Energy 
Solutions

The Bayu-Undan CCS project which 
entered FEED in 2022, could 
potentially safely and permanently 
store up to 10 million tonnes of carbon 
dioxide per annum. The FEED work 
includes engineering and design for 
additional carbon dioxide processing 
capacity at Darwin LNG, plus 
repurposing of the Bayu-Undan 
facilities for carbon sequestration 
operation after gas production ceases. 
Santos and our Barossa joint venture 
partners have invested significantly in 
the Darwin Pipeline Duplication to 
make Barossa CCS ready.

Santos is the operator of the Varanus 
Island and Devil Creek domestic gas 
processing facilities and a joint venture 
partner in the Macedon gas facility,  
all supplied by offshore fields. We 
operate the Ningaloo vision floating 
production storage and offtake 
(FPSO) facility and we are a joint 
venture partner in the Pyrenees FPSO.

Santos is one of the largest producers 
of domestics natural gas in WA and is 
also a significant producer of oil and 
condensate.

Santos’ share of WA domestic gas 
production of 93.3 petajoules was  
5 per cent lower than the previous 
year (98.7 petajoules), primarily due  
to natural field decline and 
maintenance activities. Santos’ share 
of crude oil production of 2.1 million 
barrels was lower than the previous 
year due to natural field decline.

Santos Midstream and Energy 
Solutions

Santos is seeking to develop a  
CCS hub in WA and is working with 
potential industrial CCS customers in 
northwest Western Australia.

 Papua New Guinea 

  Northern Australia 
and Timor-Leste

 Western Australia 

39.5mmboe

Production 

0.8mmboe

Production

18.9mmboe

Production

$2,576m

Revenue

$50m

Revenue

$850m

Revenue

$6.47/boe

Production cost

$86.27/boe

Production cost

$10.21/boe

Production cost 

$2,042m

EBITDAX 

$0m

EBITDAX 

$516m

EBITDAX

21

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur  
projects

Santos is focused on backfilling and sustainably growing production to 
optimise existing infrastructure and leverage our access to Asian markets. 
Santos will maintain disciplined growth through rigorous assessment and 
phased capital allocation.

LNG 

Barossa gas project 

The Santos-operated Barossa gas 
project, located in Commonwealth 
waters approximately 285 kilometres 
offshore northwest from Darwin in the 
NT, is an offshore gas and condensate 
project that aims to provide a new 
source of gas to the existing Darwin 
LNG facility in the NT. The project, 
which will be net-zero reservoir 
emissions from day one, is expected to 
deliver first gas in Q3 2025.

Papua LNG1

Subject to sanction, the Papua 
LNG project is proposed to see the 
development of the Elk-Antelope 
gas field located in PRL 15 licence 
in the Gulf Province, onshore PNG. 
The Papua LNG project is well 
positioned to contribute to growth 
in LNG supply worldwide. The Papua 
LNG joint venture is committed to 
developing a landmark project in 
terms of sustainability, biodiversity 
and low carbon emissions. In 2024, 
TotalEnergies, as operator, announced 
it is reviewing the structure of some 
contractor packages and broadening 
those to bid. 

APF Tie-in

The APF tie-in Project, involves 
developing associated gas from 
Santos operated Agogo and Moran 
oil fields delivering up to 125 mmscf/d 
gross into PNG LNG, with future 
optionality, targeting FID ready in 
2026. 

P’nyang

Narrabri1 

P’nyang is an unsanctioned, 
discovered conventional resource with 
potential to backfill into PNG LNG. 
The project is progressing through 
the concept select phase. Gas and 
Fiscal Stability Agreements have been 
executed with regard to the project. 

Beetaloo

The Beetaloo Sub-Basin, part of the 
greater McArthur Basin, is estimated 
to contain more than 200 TCF of gas 
in-place2. A drilling appraisal program 
is planned for 2026. This basin 
provides large and scalable supply 
for tight, well-priced Eastern and 
Northern LNG export and domestic 
gas markets. It is in a supportive 
jurisdiction with a published plan 
for development of the resource3. A 
memorandum of understanding was 
executed with Tamboran Resources to 
complete a joint study on gas export 
options for Beetaloo through DLNG 
expansion up to approved nominal 
10 Mtpa capacity.

Integrated oil and gas

Pikka phase 1 project

The Pikka phase 1 project in Alaska 
will include a single drill site, an 
oil processing facility and other 
infrastructure to support production 
of 80,000 (gross) barrels of oil per 
day at full production rates. The world-
class project is the most significant 
development on Alaska’s North Slope 
in more than 20 years. Pikka phase 1 
project aims to be net-zero (equity 
share) Scope 1 and 2 emissions from 
first oil.

Subject to sanction, Santos’ Narrabri 
gas project is proposed to deliver 
100 per cent of gas to the domestic 
market. Once completed, the project 
could supply up to half of NSW's 
natural gas needs, delivering energy 
security for the region and putting 
downward pressure on gas and 
electricity prices for households, 
manufacturers and businesses. 
The project would bring significant 
economic benefits to Narrabri and 
the surrounding region. It involves 
the production of natural gas through 
the progressive development of up to 
850 wells connected into processing 
facilities south of Narrabri.

Bedout Basin

The Bedout Basin is proposed to 
be an integrated gas and liquids 
project. To date five fields have 
been discovered. Net 2C contingent 
resource of 230 mmboe is booked 
as at 31 December 2024. Two gas 
exploration wells are proposed to be 
drilled in 2026.

Pikka future phases

Pikka future phases provide an 
opportunity to leverage existing 
infrastructure to grow production on 
the North Slope. Pikka phase 2 would 
utilise existing phase 1 infrastructure: 
roads, export pipeline, seawater 
supply, camps and processing 
facilities. 

1  Subject to Final Investment Decision (FID), Government and regulatory approvals.

2  Munson TJ, 2014. Petroleum geology and potential of the onshore Northern Territory, 2014. Northern Territory Geological Survey, Report 22.

3  Northern Territories Strategic Basin Plan (https://www.industry.gov.au/publications/beetaloo-strategic-basin-plan).

22

Santos Annual Report 2024Midstream and Energy 
Solutions

Santos Midstream and Energy 
Solutions’ principal activities 
are operating midstream assets, 
progressing technologies, such as 
CCS, that support decarbonisation of 
Santos and third party products, the 
generation of high integrity emissions 
reduction units and development of 
low carbon fuels, as customer demand 
evolves.

Bayu-Undan and Reindeer 
CCS projects1 

A decision to enter FEED for the 
proposed Bayu-Undan CCS project 
was announced in March 2022. In 
2024 Santos has continued to work 
with the Timor-Leste government 
regarding implementation of 
regulatory and fiscal frameworks, 
approvals, government to government 
agreements (with Australia) and 
commercial arrangements to make 
the project FID ready. In February 
2024 a decision to enter FEED for 
the proposed Reindeer CCS project 
was announced. During 2024 Santos 
has progressed FEED in parallel with 
customer negotiations on third-party 
supply of CO2.

Low Carbon Fuels

As customer demand evolves, low 
carbon fuels is an opportunity that 
Santos aims to pursue.

Santos continued to explore low 
carbon fuels opportunities in 2024, 
particularly the potential for synthetic 
gas. In 2024, Santos completed early 
engineering studies on a synthetic 
gas facility with Japanese gas utilities: 
Toho Gas, Tokyo Gas, and Osaka Gas. 
Santos is now executing a concept 
select joint study agreement with the 
aim of delivering a commercial-scale 
synthetic gas project in the Cooper 
Basin by 2030.

Carbon solutions

Santos is building a portfolio of 
nature-based projects that will deliver 
emissions reduction and tradeable 
emissions reduction units. We 
prioritise nature-based projects that 
are close to our operational footprint, 
benefit local Indigenous people and 
communities and have environmental 
benefits. Santos has core expertise 
in the design, execution, delivery 
and operation of nature-based 
sequestration methods and has 
developed a robust process to ensure 
the integrity of our nature-based 
carbon projects. 

For more information on Santos’ 
Carbon solutions projects refer to the 
Climate Report.

Midstream and Energy 
Solutions 2024 
financial snapshot

340k

Tonnes (gross) of CO2e stored 
at Moomba CCS since late 
September 2024

$379m

Total revenue

$163m

Capex

$198m

EBITDAX

52%

EBITDAX margin

1  Subject to Final Investment Decision (FID), Government and regulatory approvals.

23

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSUSTAINABILITY 
REPORT 

Our approach to sustainability

  Our sustainability pillars

  Our goals and targets

  Materiality assessment 

Investor feedback and our response

 Our sustainability performance in 
external benchmarks

  Sustainability governance

Governance 

 Policy, business ethics and 
compliance

  Human rights

Health and safety 

  Health, safety and security

  Asset integrity and process safety

25

25

26

28

30

31

32

33

33

35

37

37

39

Environment 

  Closure and rehabilitation

  Water

  Biodiversity

People and culture 

  Diversity and inclusion

Community relations 

 Community relations and land and 
resource access

Economic sustainability 

 Economic impacts: contribution 
to society and supply chain 
management

Sustainability advocacy

Santos Foundation

41

41

44

46

48

48

51

51

55

55

60

64

Our sustainability report has been prepared in accordance with the Global Reporting Initiative (GRI) Standards and comprises the reporting period from 1 January 
to 31 December 2024. Santos Limited (ABN 80 007 550 923) is the ultimate holding company of all subsidiaries in the Santos group. All references to “us”, “we”, 
and “our” refers to Santos Limited and/or its subsidiaries. The Santos Foundation is a not-for-profit organisation operating in Papua New Guinea and Australia and 
comprises two trusts managed by corporate trustees which are Santos subsidiaries.

24

Santos Annual Report 2024 
 
 
 
 
Our approach  
to sustainability

Our seven sustainability pillars support the implementation of our 
strategy. We focus on managing risks and opportunities to drive long-
term shareholder value while considering broader environmental and 
social impacts.

Our sustainability pillars

Health and safety 

At Santos, sustainability is about 
building a better future by creating 
long-term value for our stakeholders. 
We seek to balance the needs 
of today, supplying reliable and 
affordable energy, with the need to 
transition to a lower carbon future.

We have a framework based on seven 
sustainability pillars which underpin 
the delivery of our strategy and 
are essential to Santos’ efforts to 
consider the environment and social 
impacts of our activities. The pillars 
provide structure for our materiality 
process, risks and opportunities and 
setting sustainability objectives and 
targets to help guide our strategy, 
monitor performance and manage our 
material issues.

Key elements of our approach under 
each pillar are outlined here. We have 
set Company targets and linked them 
to global goals and objectives. 

Governance

We incorporate robust governance 
structures designed to ensure our 
sustainability efforts align with best 
practices and are accountable. This 
includes: 

Ethical conduct: A focus on ethical 
business practices enables operations 
to comply with international and 
local regulations, and underpins 
us maintaining high standards.

Sustainability oversight: Sustainability 
initiatives are integrated into the 
overall business strategy, with 
oversight by the Board and executive 
leadership. 

We commit to transparency 
in reporting by publishing our 
sustainability report detailing our 
progress across our sustainability 
pillars. As part of this commitment, 
our auditors EY have performed 
limited assurance over the statements 
and figures in this report. Refer 
to page 115 for their statement of 
assurance.

We integrate health and safety into 
every aspect of our operations, 
creating a strong safety culture where 
every team member is responsible 
for maintaining safe work practices. 
Our key programs Frontline Safety 
Leadership training, Life Saving Rules 
and STRIVE safety conversations help 
reinforce this commitment. 

The wellbeing of employees is a 
core priority for us. We promote 
physical and mental health through 
comprehensive wellness programs, 
flexible work arrangements and 
resources for mental health support.

Process safety and asset integrity

Santos integrates process safety and 
asset integrity into its sustainability 
framework to prevent major incidents 
and foster safe, reliable operations. 
We also emphasise the importance of 
process safety by formalising practices 
around reliability and maintenance, 
benchmarking against industry, and 
fostering a culture that prioritises 
safety.

Environment

We take steps to minimise 
environmental impacts on local 
ecosystems. This includes habitat 
restoration and careful monitoring to 
assist compliance with environmental 
regulations. We include measures to 
protect groundwater and minimise 
usage through recycling and advanced 
management techniques. 

Santos has established protocols 
and technologies to prevent spills 
and require swift responses to 
any incidents that could impact 
the environment. Additionally, the 
company takes proactive corrective 
actions to drive continuous 
improvement in environmental 
management practices.

Climate 

We have set decarbonisation goals, 
including net-zero equity Scope 1 and 
equity Scope 2 emissions targets, and 
a long-term aspiration to store more 

carbon than we emit (Scope 1, 2 and 3 
equivalent).1, 5

We advocate for the critical role 
natural gas will play in the energy 
transition in moving towards a  
lower carbon future.

Refer to our Climate Report  
(page 68) for our reporting on  
this sustainability pillar.

Community relations 

We are committed to building strong 
relationships with all communities 
including Indigenous communities 
and respecting their land rights and 
cultural heritage. 

We aim to support local economies 
by creating jobs, sourcing materials 
locally, and contributing to community 
development.

People and culture 

We strive for a diverse and inclusive 
workplace culture and aim to foster 
an environment where employees 
from different backgrounds 
and experiences are valued and 
respected. This is reflected in our 
policies and initiatives that support 
gender balance, Indigenous and 
national representation and equal 
opportunities. 

We invest in training and development 
programs to build employees’ skills 
and support their career growth. This 
includes technical training, leadership 
development and mentorship 
programs that help employees achieve 
their full potential.

Economic sustainability 

We contribute to job creation 
and local employment to support 
economic stability and growth. We 
work with local businesses to support 
local and Indigenous participation 
through our supply chain. 

We also invest in local communities 
to improve living standards, build 
respectful relationships and create 
stronger communities in the areas 
where we operate.

25

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur goals and targets

We have aligned our sustainability framework with the United Nations Sustainable Development Goals (UNSDGs), with a 
focus on the most relevant goals where our Company has an impact and where we can make a meaningful contribution to 
global progress towards attainment of these goals.

Our sustainability pillars UNSDGs
Governance

Health and safety

Environment

Climate1

People and culture

Our targets
• 

• 

In 2025, roll out a New Code of Conduct e-learning module 
supported by delivery of face to face sessions in PNG.
In 2025, roll out EthicsPoint, a new reporting tool for 
Whistleblower/Misconduct and community-related matters 
across the organisation.

•  Lost time injury rate (LTIR) at top quartile (Benchmark – 

International Oil and Gas Producers (IOGP)).

•  Major harm reduction year-on-year.
•  Tier 1 and 2 Loss of containment rate of less than  

0.5 per million hours worked. 

•  Santos is committed to achieving net-zero abstraction 

of water from the Great Artesian Basin by offsetting our 
groundwater use through the funding of water-saving 
initiatives. 

•  Year-on year increase in percentage of produced water 

• 

beneficially reused in onshore Australia. 
In 2025, develop a Santos framework to identify dependency 
and impact-related nature risks in line with international 
standards. 

•  By 2030, identify dependencies and impact-related nature 

risks at operated sites.

•  Safely and sustainably decommission in line with industry 

standards.

•  By 2030, 30% reduction in Scope 1 and 2 emissions.2 
•  By 2030, 40% reduction in Scope 1 and 2 emissions intensity.3 
•  By 2030, from the supply of low carbon fuels and carbon 

management services, reduce customers’ emissions (Santos' 
Scope 3) by at least 1.5 Mtpa of CO2e.

•  By 2030, achieve zero routine flaring where economically 

feasible for operated oil production.

•  By 2030, achieve near-zero methane emissions.4
•  By 2040, net-zero Scope 1 emissions.
•  By 2040, build and operate a commercial carbon dioxide 

storage business that would permanently store approximately 
14 Mt (gross) of third-party CO2e per annum.5

•  By 2050, net-zero Scope 2 emissions.6
• 

In 2025, maintain over 30% female representation at Board 
and Executive Leadership positions.
Improve local workforce representation across locations 
in which Santos operates (including Indigenous workforce 
participation).

• 

1  Refer to our Climate Report (page 68) for further information on this sustainability pillar and our targets.

2 

3 

 Absolute reduction (30 per cent) is from the Santos and Oil Search combined 2019-20 equity Scope 1 and 2 emissions baseline of 5.9 MtCO2e, representing a 
reduction to 4.1 MtCO2e or lower by 2030.

 Intensity reduction (40 per cent) is equity share of Santos Scope 1 and 2 emissions intensity from a 2019-20 baseline of 55 ktCO2e/mmboe, representing a 
reduction to 33 ktCO2e/mmboe or lower by 2030.

4  Methane emissions intensity of <0.20 per cent from operations, calculated as a percentage of marketed natural gas.

5  Refer to 'important notices' at the front of this report for further information about this target.

6  Santos has revised our Scope 2 net-zero emissions target from 2040 to 2050. For more information, see Santos’ Climate Report.

26

Santos Annual Report 2024Our sustainability pillars UNSDGs
Community relations

Our targets
• 

In 2025, have community plans over the lifecycle of activities 
in place in all areas where we operate. 

•  No impact to cultural heritage.
• 

In 2025, embed process for community feedback including 
complaints to be recorded, responded to, and resolved, in 
accordance with our revised community complaints process.
In 2025, integrate 2024 Community Survey results and 
Community Plans to inform community engagement 
activities.

• 

Economic sustainability

•  Expand the Santos Foundation activities to include projects 

in new regions in addition to Papua New Guinea.

• 

• 

In 2026, implement a framework to collect and report Scope 
3 emissions data from suppliers, ensuring alignment with 
organisational sustainability targets and improving data 
transparency and reporting.

In 2025, update and distribute Responsible Sourcing 
Principles, incorporating our sustainability pillars and 
associated actions, to our suppliers.

The following UNSDG topics relate to the  
Santos Foundation overarching mission and objectives:

Updates to our Scope 2 emissions reduction target

Scope 2 emissions are determined 
by the local energy grids from 
which we draw electricity supply. 
According to government 
projections, these energy grids 
are not expected to be fully 
decarbonised by 2040,1 with risks 
and challenges related to planning 
approvals, availability of a skilled 
workforce, supply chain constraints 
and expansion of transmission lines, 
among other factors.2 As a result, 

Santos has revised our Scope 2 net-
zero emissions target from 2040 to 
2050. This change aligns with the 
Net Zero targets of the majority of 
jurisdictions where we operate.

We remain committed to 
decarbonising our operations 
and our Scope 2 emissions, which 
make up six per cent of our 2024 
Scope 1 and 2 equity emissions, 
and will decarbonise at the pace 
of the energy grids where we 

operate. Santos intends to identify 
opportunities to secure renewable-
generated electricity for our 
operations, where economically 
feasible, and will continue to 
monitor whether this target can be 
achieved earlier. 

For more information on our 
emissions reduction targets  
and our progress towards these 
targets, refer to our Climate  
Report (page 68).

Refer to our Climate Report (page 68)  
for our reporting on this sustainability pillar.

1 

 DCCEEW 2024. ‘Australia’s emissions projections 2024’, page 43.

2  AEMO 2024. Integrated System Plan for the National Electricity Market.

27

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationMateriality assessment

Materiality assessment 
process

In 2024, we leveraged the work done 
in the previous reporting period 
and reviewed our impacts with both 
internal and external stakeholders 
according to the GRI standard 
methodology. This review helps to 
ensure that our material topics stay 
relevant, evolve and represent our 
most significant impacts and those of 
greatest concern to our stakeholders. 

Building on the four-step process 
outlined in last year’s report, we 
have more deeply engaged with 
stakeholders to better understand our 
material topics, including:

1. Understanding Santos context

We analysed our activities across 
the value chain and current business 
relationships. We also updated 
our peer benchmarking analysis 
on material topics, media reports, 
environmental, social and governance 
(ESG) ratings results and mapped out 
our key external stakeholders.

3. Assessing the significance of 
impacts

We applied the Santos risk framework 
to assess the significance of our 
identified impacts for prioritisation. 
Assessing the severity, likelihood, 
scale, scope and unavoidable 
character of impacts enabled us to 
determine the priorities for reporting.

2. Identifying actual and potential 
impacts

4. Prioritising most significant 
impacts for reporting

We reviewed our impacts with internal 
stakeholders, subject matter experts 
and business functions to update 
the assessment of our material 
topics. In addition, we conducted 
interviews with identified key external 
stakeholders to understand their most 
material topics.

We grouped our assessed impacts 
into topics according to the GRI 
11 Oil and Gas standard and our 
sustainability pillars and tested them 
with management to determine a 
threshold for reporting. The Santos 
Sustainability and Safety Committee 
has endorsed our material topics for 
disclosure.

Stakeholders' material topic alignment

Continuous engagement with our stakeholders enables valuable feedback on managing our material topics. This year, 
we engaged with ten diverse stakeholder groups who participated in interviews and an online survey to help understand, 
validate and prioritise our material topics. The table below summarises our stakeholders’ most material topics and 
alignment with our material topics.

Governance

Health  
and safety

Environment

Climate

People  
and culture

Community 
relations

Economic 
sustainability

Our investors and 
financial community

Local communities 

Indigenous 
communities 

Our landholders/
landowners

Our people

Our suppliers and 
contractors 

Our joint venture 
partners and peers 

Our governments 
and regulators 

Our customers and 
consumers 

Non-government 
organisations 

28

Santos Annual Report 2024Our 2024 material sustainability topics

Our 12 material topics for 2024 
reflect a comprehensive review of our 
impacts across our pillars as depicted 
in the materiality process enriched by 
external stakeholder engagement.

The materiality assessment further 
enhanced our understanding of 
the material topics across our 
activities and how they relate to 
our stakeholders. This year we have 
focused on the most material topics 
for reporting. 

The key changes this year are:

•  Biodiversity and water have been 

assessed as material.

•  Closure and rehabilitation, including 

decommissioning, and impacts 
related to environmental and social 
concerns were added into the 
environmental pillar.

•  Community relations was added 

to our community material topics 
to better align with international 
standards. 

•  Economic sustainability focuses on 
economic impacts encompassing 
economic contribution to society 
and supply chain management. 

Health and safety

Health, safety  
and security

Asset integrity and 
process safety

Governance

Policy, business ethics 
and compliance

Human rights

Environment

Closure and rehabilitation

Water

Biodiversity

Climate

Greenhouse gas emissions

Climate adaptation 
resilience and  
transition

Economic sustainability

Economic impacts: 
contribution to society 
and supply chain 
management

Community relations

Community relations 
and land and  
resource access

Information on other topics  
can be found on our website:  
santos.com/sustainability/

People and culture

Diversity and inclusion

29

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationInvestor feedback and our response

Engagement with our stakeholders is a priority for Santos. Following the release of the 2023 Sustainability and Climate 
Report, Santos sought feedback from investors and investor groups on our sustainability strategy and disclosures. The table 
below outlines the key themes raised by shareholders and the steps taken to address, or otherwise explain our rationale, in 
response to this feedback. Investor feedback on our climate strategy is covered on page 109.

Investor feedback
Safety

Describe how changes in approach 
and process have resulted in 
improved safety outcomes

Include further information on 
psycho-social safety programs

Cultural heritage management

Describe improvements to processes 
made in response to Barossa and 
Narrabri challenges

Traditional Owner relationships and 
stakeholder consultation

Provide more information on ongoing 
relationships with Traditional Owners 
on the Tiwi Islands

Describe approach to stakeholder 
consultation for onshore and offshore 
activities

Describe Santos' approach to Free, 
Prior, and Informed Consent 

Whistleblower mechanism

Provide more detail on how Santos 
promotes the whistleblower 
mechanism

Explain reasons for, and response to, 
increase in reported misconduct

Outline how sexual harassment 
complaints are managed and the 
supports provided

Complaints and grievances

Define approach to complaints 
and the grievance mechanisms in 
place across each operation and 
jurisdiction

Explain differences in outcomes 
across operations and jurisdictions 
and Santos plans to improve

Response
We continuously improve how we embed safety in our 
everyday processes, including enhancing frameworks, 
leveraging safety leadership programs, and developing 
communities of practice. This embeds the ownership 
of safety outcomes at every level of the company, 
from management to individual employees. 

In 2024, we have expanded our Healthier Me  
program for all employees, including access to onsite 
GP clinics. We continued to develop our psychosocial 
risk framework across the business.
In 2024, we consolidated our Indigenous 
engagement, agreement-making, and onshore and 
offshore cultural heritage management requirements 
under one Technical Standard. The updated Technical 
Standard outlines Santos’ approach and commitment 
to the rights of Indigenous people. 

Santos will continue to conduct extensive 
consultation with Aboriginal and Torres Strait Islander 
communities on all aspects of Barossa as the project 
progresses. Consultations have been pivotal in 
addressing concerns related to environmental impact, 
cultural heritage, and social and economic benefits, 
with feedback incorporated into the project planning 
and implementation processes. Further information 
has also been included on the Indigenous Advisory 
Panel and the Barossa Aboriginal Future Fund.

We comply with regulatory requirements regarding 
consultation and consent with respect to where we 
operate.
Santos is committed to providing a safe environment 
for reporting misconduct. During 2024, we 
progressed implementation of EthicsPoint. The tool 
will be rolled out for use in 2025 and promoted across 
our sites. Reports of misconduct and breaches of the 
Code of Conduct, including sexual harassment, are 
handled by our newly established Business Integrity 
function.

In October this year we updated our complaints 
definition and process to improve the recording and 
management of community feedback. Since 1 October 
2024, and according to the new definition and process, 
Santos recorded 40 complaints across our footprint.

Since 1 October, in Australia 27 complaints were 
recorded and 17 resolved. The complaints were 
related to damage to roads and property, vehicles 
not using correct access tracks and failure to provide 
notice. In Papua New Guinea, 13 complaints were 
received and eight resolved. Complaints were 
related to landowner compensation, local business 
development contracts. No complaints were recorded 
in Timor-Leste or Alaska.

Section disclosed  
in report
Asset integrity and 
process safety: 
Our actions and 
performance

Health, safety and 
security: Our actions 
and performance

Community relations 
and land and resource 
access: Our process 
and due diligence

Refer also to our 
website: 

narrabrigasproject.
com.au

santos.com/barossa

Policy, business ethics 
and compliance: 
Our approach; Our 
process and due 
diligence

Community relations:  
Our process and due 
diligence; Our actions  
and performance

30

Santos Annual Report 2024People and culture

Provide detail on the evolution of 
the Real Talk survey, whether results 
are improving, and how it has driven 
change in the organisation 

The Real Talk employee sentiment survey is an 
important tool for measuring our progress against our 
Real Thrives Here commitment. 

People and culture: 
Our actions and 
performance

Following the 2023 survey, actions taken included 
empowering leaders with survey results to drive 
action planning, a company focus on humanising the 
Santos values and the Real Thrives Here commitment, 
and fostering cross-cultural awareness. 

The 2024 survey saw improvement across all survey 
factors related to employee experience including a  
16 per cent relative improvement in the inclusion 
index and a significant increase in overall engagement 
result nearing top quartile performance. The results 
highlighted key strengths in health and wellbeing, 
safety, clear vision and strategy and inclusion as well 
as pride in working for Santos. Santos continues to 
evolve the Real Thrives Here commitment to create 
the culture and workplace to deliver on our Purpose 
and Vision 2040.

Our sustainability performance  
in external benchmarks

Santos actively engages with ESG rating agencies as part of our 
continued commitment to improved transparency in sustainability 
reporting. Our 2024 performance included top quartile results for 
MSCI and S&P Corporate Sustainability Assessment.

S&P Global ESG score

MSCI ESG ratings

Top quartile among our peers

Top quartile among our peers

Santos has improved its S&P Global ESG score from 55 
to 58 with very high data availability.1 

The S&P Global CSA score is a key component of the 
S&P Global ESG score. Santos scored 55 in the 2024 S&P 
Global Corporate Sustainability Assessment reflecting 
an improvement of four points as compared to the 2023 
assessment (CSA Score as of 25/08/2024).

Santos’ rating remains unchanged since August 2021. 

Santos is a leader among 131 companies in the oil and gas 
exploration and production industry.

As of 2024, Santos received an MSCI ESG Rating of AA.

The use by Santos of any MSCI esg research llc or its 
affiliates (“MSCI”) data, and the use of msci logos, 
trademarks, service marks or index names herein, 
do not constitute a sponsorship, endorsement, 
recommendation, or promotion of Santos by MSCI. 
MSCI services and data are the property of msci or 
its information providers, and are provided ‘as-is’ 
and without warranty. MSCI names and logos are 
trademarks or service marks of MSCI. 

1  Source: https://www.spglobal.com/esg/scores/results?cid=4157467

31

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSustainability  
governance

The Board views sustainability as a material strategic area for Santos.  
It oversees the safe and sustainable operations of the Company in 
accordance with our values, within a Risk Management Framework that 
respects all stakeholder interests.

Our approach

Effective corporate governance is 
critical to the long-term success 
and sustainability of Santos. The 
Board and all levels of management 
are committed to maintaining 
and enhancing a strong corporate 
governance framework.

Reporting standards 
and frameworks

Our reporting practices are informed 
by and reflect our commitment to 
current industry applicable standards, 
guidance and frameworks, including: 

•  Global Reporting Initiative –  

GRI Standards, GRI 11 Oil and Gas 
Sector 2021 and GRI 3 Material 
Topics 2021 (refer to the GRI Index 
at santos.com).

• 

International Financial Reporting 
Standards (IFRS) TCFD (refer to 
the TCFD Index at santos.com).

•  Sustainability Accounting 

Standards Board, Oil and Gas 
Sector.

• 

Ipieca, the global oil and gas 
association for advancing 
environmental and social 
performance across the  
energy transition.

•  UNSDGs 17 Goals and key 

objectives.

Consistent with industry best practice, 
this year we have combined our 
sustainability and climate update 
into one integrated report. Based 
on engagement and feedback from 
stakeholders and in line with disclosure 
requirements and expectations, we 
have integrated opportunities, risks, 
metrics and targets. 

Our engagement with peers and 
industry associations has also 
provided contemporary guidance and 
common references. This has included 
the Ipieca Sustainability reporting 
guidance for the oil and gas industry.

The way we manage 
sustainability across  
the business 

The Board has ultimate responsibility 
for the approval and oversight 
of strategy, and this includes our 
approach to sustainability. The 
Charters for the Board and each 
Committee formally outline the 
responsibilities of each body in 
respect of sustainability, including the 
monitoring and review of risks.

The Board’s oversight of sustainability 
is supported by board committees, 
including the Safety and Sustainability 
Committee which meets four times 
per year (and otherwise as determined 
by the Chair of the Committee). The 
Committees’ cross memberships 
support sound communication of 
sustainability-related matters across 
the various committees. 

The CEO reports to the Board and 
is responsible for delivering the 
strategy and goals approved by the 
Board. These include accountability 
for outcomes of sustainability-related 
targets approved by the Board. The 
CEO is supported by the Executive 
Leadership Team. The CEO and 
Executive Leadership are in turn 
supported by their teams.

To help to ensure effective cross-
functional communication on issues 
related to sustainability and climate, 
Santos’ governance processes include 
meetings across a range of business 
groups. This includes meetings of 
the Executive Leadership Team to 
require conformance with the Santos 

Constitution

Specifies the rules 
governing the activities 
of the Company and the 
relationship between 
the Company, its 
directors and 
shareholders.

Policies

Charters

Code of Conduct

Management System (SMS) and 
to track delivery against plans and 
targets as well as the effectiveness 
of controls and processes pertaining 
to sustainability-related activities. 

Santos Management 
System

The SMS applies to all of Santos’ 
people and establishes the 
requirements for how Santos does 
business across our assets and 
functional support teams. It is 
designed to protect our people, the 
communities where Santos operates, 
and the environmental values of our 
assets, operations, and activities. The 
SMS includes: 

•  Delegation of Authority (DOA)

•  Operating Standards explaining 

the minimum standards for ‘what’ 
the business must achieve

•  Technical Standards outlining the 
detailed technical requirements or 
specifications that must be achieved 
in a consistent manner in support of 
the relevant operating standard

•  procedures, processes and tools 
explaining the expectations and 
practices for how business activities 
should be undertaken. Various 
business teams are responsible for 
the day-to-day implementation 
of plans, processes, procedures, 
and tools that are embedded 
within the SMS and align with the 
seven sustainability pillars. Each 
sustainability pillar has an assigned 
business owner who supports 
communication and reporting 
of performance.

DOA

Operating
standards

Technical standards

Compliance documentation
• Global procedures and practices

• Region/division/function procedures and practices
• Functional processes

Set by our shareholders

Set by the Board

Managing Director and CEO

32

Santos Annual Report 2024Sustainability pillar 
Governance

Policy, business ethics  
and compliance

Governance is a core function for Santos. We promote a culture of 
ethical and responsible conduct in line with our values and legal 
obligations to support long-term success.

2024 calendar year substantiated 
types of misconduct by individuals

Total
9

Sexual harassment 

Harassment 

Policy / standard / code / procedure 

Misuse of company assets 

Delegation of Authority 

4

2

2

1

0

Regulatory / government / external complaint 0

Our opportunities 
and risks

Our opportunities include:

Improvements in setting 
expectations for ethical behaviour 
and transparency. 

Review of the Code of Conduct 
and supporting initiatives for 
improved governance outcomes 
and performance.

Our risks include:

Breaches of legislation or regulation 
in the areas of anti-corruption, 
sanctions compliance, and anti-
competitive behaviour.

Code of Conduct breaches not 
reported.

Our approach

Governance and business ethics 

Our corporate governance framework 
underpins effective decision-making 
and operational integrity. 

Our Code of Conduct sets clear 
expectations for ethical behaviour, 
guiding how we interact, make 
decisions and perform daily work. 
All employees and contractors are 
required to adhere to these standards, 
and we offer mandatory training 
across all global locations. We report 
on breaches related to our Code 
of Conduct.

Reportable misconduct 

Santos is committed to providing 
a safe environment for reporting 
misconduct. Our Reporting 
Misconduct (Whistleblower) 
Procedure allows stakeholders to 
report concerns such as misconduct, 
fraud or corruption through various 
channels, including anonymously 
and through an external confidential 
24-hour hotline. All reports are 
investigated, as appropriate, under our 
internal processes. Training is provided 
to those who work for and with us as 
well as to our Board Directors, in line 
with Australian whistleblower laws. In 
2024, a total of 27 whistleblower and 
misconduct reports were received 
and assessed for investigation, with 
the majority of the reports relating to 
harassment or policy/code violations. 

•  9 reports were substantiated, 

(including 2 reports reported in 
2023 but concluded in 2024), 
resulting in disciplinary action 
being taken 

•  4 of the 27 reports remained open 

at the end of 2024

•  Four employees were either 
terminated as a result of 
substantiated misconduct, resigned 
prior to being terminated, or were 
excluded from Santos’ sites

Our process and due 
diligence

Managing regulatory compliance 
risks and enhancing opportunities 

At Santos, regulatory compliance 
is critical to minimising risks and 
ensuring operational integrity. 
One of the key risks we face is 
non-compliance with regulatory 
obligations, which can result in 
legal, financial and reputational 
damage. The Board is responsible, 
with the assistance of the Audit 
and Risk Committee, for overseeing 
management's implementation and 
the effectiveness of the regulatory 
compliance program. Compliance 
performance is regularly monitored 
and reported to Executive 
management and the Board and 
Committees of the Board, enabling 
issues identified and addressed 
proactively. 

Risk mitigation 

Our broader compliance approach is 
supported by the Code of Conduct 
(including underlying procedures) 
and the SMS, which set out the 
mandatory requirements for managing 
our business. Regulatory compliance 
is a core element of focus and its 
implementation is guided by the 
Santos Compliance Framework, which 
aligns with international standards 
such as ISO 37301. This framework 
helps identify, manage, report and 
address any compliance gaps across 
our business, reducing risk exposure. 

To mitigate these risks, we also utilise 
a compliance management database 
that tracks tenure and environmental 
approvals. The Board, with the 
assistance of the Audit and Risk 
Committee, oversees the Compliance 
Framework’s effectiveness through 
annual reviews. These reviews aim to 
have a framework that remains robust 
and responsive to evolving regulatory 
obligations. 

33

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Policy, business ethics and compliance
(continued)

Leveraging technology for  
enhanced compliance 

In 2023, we launched the RSA Archer 
platform, known internally as the 
Santos Compliance Management 
System. This digital tool centralises 
all regulatory compliance obligations, 
assigns accountability to business 
areas and tracks compliance 
performance. It provides real-time 
transparency, and as of 2024, now 
incorporates alerts on regulatory 
reforms. 

Our actions and 
performance

In 2024, we continued to enhance and 
reinforce our strong focus compliance 
and ethical standards across the 
business. 

Key risks, particularly in the areas of 
anti-corruption, sanctions compliance, 
and anti-competitive behaviour were 
managed through appropriate controls 

and regular monitoring. The Santos 
Compliance Framework and the 
regulatory compliance program helped 
to maintain a proactive approach to 
identifying and addressing compliance 
risks.

We have taken the following steps in 
2024 to further improve governance 
and ethical business practices:

•  Established the Business Integrity 

Function with responsibility 
for Whistleblower/Reporting 
Misconduct investigations and the 
Code of Conduct and underlying 
policies, procedures and training. 

•  Progressed the implementation 
of EthicsPoint, a new external 
reporting tool for Whistleblower/
Misconduct and community-related 
matters, designed to further 
enhance the ease of reporting and 
improve analytics for misconduct-
related matters once rolled out 
in 2025.

•  Progressed a review of the Santos 
Code of Conduct for approval by 
the Board and roll out in 2025. 
The review is focused on further 
reinforcing and strengthening 
our clear and mandatory ethical 
standards and expectations.

•  Continued to develop the Code 

of Conduct delivery frameworks, 
including refreshed Code of 
Conduct e-learning modules  
and face-to-face sessions.

•  Delivered face-to-face training 
on anti-bribery, corruption, and 
sanctions compliance to the Board.

In addition to our internal governance 
improvements, Santos continued 
our broader engagement, with 
participation as a panellist for the 
UN Global Compact Network 2024 
Dialogue on Bribery and Corruption.

Pictured: Moomba Control Room

34

Santos Annual Report 2024Sustainability pillar 
Governance

Human rights 

Santos is committed to upholding internationally recognised human rights, 
guided by the UN International Bill of Rights and the UN Guiding Principles 
on Business and Human Rights. 

51

A-Grade

Barossa gas project  
community consultation sessions held 

in Monash University's Modern 
Slavery Disclosure Quality Ratings 

Our approach

Human Rights Framework 

Santos is committed to upholding 
internationally recognised human 
rights, guided by the UN International 
Bill of Rights and the UN Guiding 
Principles on Business and Human 
Rights. We also work to align with the 
Voluntary Principles for Security and 
Human Rights, integrating these into 
our policies and practices, including 
our Human Rights and Modern 
Slavery Policy. 

Our Human Rights Framework 
supports these commitments and 
guides our processes to address 
key risks. We recognise the role of 
governments in protecting human 
rights and work collaboratively to 
align our operations with these 
responsibilities.

Our opportunities 
and risks

Our opportunities include:

Alignment of our policies 
and practices with legislative 
requirements, stakeholder 
expectations and international 
standards.

Our risks include:

Modern slavery and forced labour 
in our supply chain.

Unauthorised impacts to cultural 
heritage or landholder properties.

Human rights impacts from security 
arrangements, involving public and 
private security providers.

Employment-related issues such as 
equal opportunity, discrimination, 
harassment, and bullying.

Our process and due 
diligence

Santos applies rigorous due 
diligence to manage human rights 
risks, including modern slavery, 
Indigenous engagement, security and 
employment practices. We collaborate 
with stakeholders to mitigate risks 
and create opportunities across our 
operations.

Modern slavery and forced labour in 
our supply chain

Santos releases an annual Modern 
Slavery Statement, with our 2023 
Statement released in June 2024. 
Our 2023 Statement, consistent with 
2022 and 2021 Statements, received 
an A-grade in Monash University's 
Modern Slavery Disclosure Quality 
Ratings. Key due diligence as outlined 
in our Statement includes supplier 
assessments, deep-dive investigations, 
and enhanced counterparty screening 
via Compliance Catalyst. Our internal 
Modern Slavery Working Group 
oversees these processes and 
identifies and manages additional risks 
and opportunities.

87%

of security personnel trained  
in Voluntary Principles on Security 
and Human Rights

Indigenous engagement

Santos is committed to Indigenous 
engagement through our Human 
Rights and Modern Slavery Policy. We 
operate under legal frameworks that 
enable Indigenous participation in 
project assessments, and we engage 
with communities and stakeholders 
to incorporate their feedback into 
project planning to mitigate impacts. 
For further information, refer to the 
Community relations and land and 
resource access section of this report 
(pages 51–54).

Security and human rights

Santos performs security risk 
assessments and collaborates with 
state and federal law enforcement, 
including the Department of Home 
Affairs in Australia. Our Major Hazard 
Facilities maintain strong links with 
law enforcement and we comply 
with regulations under the Maritime 
and Offshore Facilities Security Act 
(2003) and the Security of Critical 
Infrastructure Act (2018). In PNG and 
Alaska, we work closely with local 
authorities. Private security providers 
must adhere to the Santos Code 
of Conduct, Santos values, modern 
slavery and human rights obligations 
and the Voluntary Principles on 
Security and Human Rights. We 
monitor compliance through regular 
reporting, site assessments and 
performance monitoring, with 
grievance mechanisms available 
via the Reporting Misconduct 
(Whistleblower Procedure).

35

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationHuman rights
(continued)

Pictured: Van Gogh Field

Employment and equal opportunity

Santos fosters a safe, inclusive 
workplace committed to equal 
opportunity and preventing 
discrimination, harassment and 
bullying. In addition, our Internal 
Psychosocial Risk Framework and 
Committee oversees workplace 
conditions, assessing psychosocial 
risks that may affect employee 
wellbeing. Mandatory annual Code 
of Conduct training requires that all 
employees understand our policies 
on equal opportunity, respect and 
workplace behaviour. Our internal 
grievance mechanisms are available 
to address concerns promptly and 
thoroughly.

Through these processes, Santos 
mitigates human rights risks, monitors 
regulatory compliance, and fosters an 
environment where human rights are 
respected across all aspects of our 
operations.

For further information, refer to  
the diversity and inclusion section  
of this report.

The Responsible Sourcing Principles 
under development are structured 
under Santos' material topics and 
consider human rights, environmental 
management and business integrity.

In 2024, we consolidated our 
Indigenous engagement, agreement-
making, and onshore and offshore 
cultural heritage management 
requirements under one Technical 
Standard. The updated Technical 
Standard outlines Santos’ approach 
and commitment to the rights of 
Indigenous people. 

Santos will continue to conduct 
extensive consultation with Aboriginal 
and Torres Strait Islander communities 
on all aspects of Barossa as the 
project progresses. Consultations 
have been pivotal in addressing 
concerns related to environmental 
impact, cultural heritage, and social 
and economic benefits, with feedback 
incorporated into the project planning 
and implementation processes.

We comply with regulatory 
requirements regarding consultation 
and consent with respect to where we 
operate. 

Our actions and 
performance

In respect to our human rights 
processes and practices generally, in 
2024 we have:

•  Monitored completion of our annual 

mandatory refresher Code of 
Conduct training (which includes 
human rights and modern slavery 
training) for all Santos personnel.

•  Completed a comprehensive 

review of the whistleblower and 
investigations processes, tools 
and training ensuring we continue 
to meet or exceed regulatory 
requirements and progress against 
the grievance requirements, 
outlined in the UN Guiding 
Principles on Business and Human 
Rights Economic Sustainability 
Climate Appendices. 

•  Continued the meetings of the 

internal Modern Slavery Working 
Group to provide oversight of 
potential human rights and modern 
slavery issues and actions being 
taken across our operations.

Santos has been actively developing 
its Responsible Sourcing Principles 
to enhance sustainable and ethical 
practices within its supply chain. 
The company reviewed these 
principles for potential future 
implementation, aiming to align them 
with global standards and stakeholder 
expectations. 

36

Santos Annual Report 2024Sustainability pillar 
Health and safety

Health, safety and security

Santos is steadfast in pursuing safety excellence and is committed to 
conducting business activities in a manner that allows all employees and 
contractors go home healthy and safe.

27,259

STRIVE safety conversations

60%

Reduction in moderate harm  
injury rate  
from 0.07 in 2023 to 0.03 in 2024

4,700

Free onsite GP consultations  
provided to Santos employees

Our approach

Santos is committed to being one of 
the safest, most reliable operators 
across the globe through a proactive 
and systematic approach to health, 
safety and security. Our commitment 
to safety is led from the Board and 
Executive Leaders demonstrating this 
commitment through regular site visits 
to engage directly with our workforce 
and observe safety practices firsthand. 

Guided by our Always Safe value 
and Code of Conduct, the SMS 
encompasses comprehensive policies 
and operating standards for health, 
safety and security. These standards 
articulate our strategic direction and 
minimum mandatory requirements 
across the organisation, while allowing 
flexibility in how these standards are 
achieved operationally.

Our opportunities 
and risks

Our opportunities include: 

Improved investigation and learning 
management with AI. 

Proactively managing psychosocial 
risks to enhance employee 
wellbeing, productivity and overall 
organisational resilience aligning 
with best practices in the global oil 
and gas industry.

Our risks include: 

Uncontrolled hazards from high-risk 
work with potential for fatal injury 
to people.

Our process and  
due diligence

Santos has robust health, safety and 
security technical standards that 
outline our minimum mandatory 
requirements. Aligned to ISO 45001 
Occupational Health and Safety 
Management Standard plan-do-
check-act cycle, the health, safety and 
security technical standards form a 
key part of the SMS to manage risks 
and minimise harm to our people. 
These are reviewed and assured by 
our integrated assurance program to 

check for compliance, effectiveness 
and continuous improvement.

Health and wellbeing

Our enhanced health and wellbeing 
program delivers regular health 
campaigns across the pillars of 
Healthier Bodies, Healthier Minds, 
Healthier Places, Healthier Finances 
and Healthier Relationships. These 
campaigns offer employees 
opportunities to participate in 
education sessions, group activities, 
access online resources and attend 
individual appointments with experts.

Health and safety key elements

12

1

Management
of change

Legal and other
requirements

2

Planning

11

Crisis, 
incident and
security 
management

10

Incident
investigation

Monitoring,
measurement 
and reporting

9

|   Roles an

h i p  

d r

e

P

L

A

N

ead e r s

T

A C

L
| 
y
c

i
l
o
P

|

C

o

n

s

Leadership 
and worker 
participation

C

H

E

u

lt

ation and c o m m u

C

K

s

p

o

n

s

i

b

i

l

i

t
i
e
s

|

n 

nicatio

O

D

Risk
management

3

Training and
competency

4

Assurance,
audit and
inspection

8

Contractors 
and suppliers

5

Occupational
health

Operations
excellence

7

6

37

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
Our actions and 
performance
Employee and contractor safety

Santos operates in challenging and 
inherently high-risk environments. 
Approximately 79 per cent of our work 
is performed by contractors, and our 
contractors represent a commensurate 
proportion of our high potential events 
and injuries. This trend aligns with global 
patterns observed by international oil 
and gas producers. 

In 2024, we prioritised improving 
our contractor health and safety 
management framework with a focus 
on enhancing pre-qualification tools 
and assurance processes. We foster 
collaboration on risk management and 
shared learnings through contractor 
forums. 

We further embedded our frontline 
leadership safety program in 2024 and 
focused on our Always Safe value and 
associated leadership behaviours to 
effectively and consistently lead safety 
in operations. As a result, 183 frontline 
supervisors have received specific 

safety leadership training since program 
inception in late 2023.

central to our efforts as we move 
through 2025.

We continue to successfully deliver 
and embed STRIVE, our safety 
conversations program centered on care 
and curiosity. This initiative leveraged 
best practices from similar programs 
implemented across the business. 
In 2024, we trained 2638 workers in 
STRIVE, and had 27,259 conversations. 
Participation has increased throughout 
the year and conversations have led to 
recognition of positive safety practices, 
proactive identification of hazards, 
and implementation of improvement 
opportunities.

In 2024, we made significant reductions 
in key injury metrics, achieving top 
quartile performance in LTIR according 
to 2023 published results from the 
International Association of Oil and 
Gas Producers (IOGP). This outcome 
was largely attributed to the successful 
implementation of our STRIVE and 
Frontline Safety Leadership programs, 
along with governance and assurance 
efforts. Additionally, we focused 
on enhancing the management of 
contractors, a priority that will remain 

We will continue to implement and 
embed our psychosocial risk framework 
using a multidisciplinary approach in 
recognition of the diversity of skills and 
expertise required to effectively manage 
this risk. There will be a strong focus on 
building organisational capability  
and psychosocial risk awareness.

Health and wellbeing: Healthier 
Me program

In 2024, we have expanded our onsite 
General Practitioner (GP) clinics 
to Brisbane and Perth, providing 
both face-to-face and telehealth 
appointments. These services provide 
more accessible medical advice 
and supports for all employees in a 
more proactive approach to health 
management.  
In Alaska, PNG and Timor-Leste we 
also offer health support through our 
health insurance partners and local 
medical teams. In 2024, our on-site GP 
clinics in Adelaide, Brisbane, and Perth 
had 4,700 visits by Santos employees.

Lost time injuries 
Lost time injury rate (LTIR)

Moderate harm injuries 
Moderate harm injury rate

s
r
u
o
h
k
r
o
w
n
o

i
l
l
i

m

r
e
p
R
T
L

I

1.2

0.9

0.6

0.3

0.0

s
r
u
o
h
k
r
o
w
n
o

i
l
l
i

m

2020

2021

2022

2023

2024

r
e
p
e
t
a
R

0.6

0.5

0.4

0.3

0.2

0.1

0.0

2020

2021

2022

2023

2024

Employee rate

Contractor rate

Combined rate

IOGP (Global rate)

Employee rate

Contractor rate

Combined rate

40% Improvement in LTIR from 2023. 2024 LTIR below 
IOGP 2023 top quartile of 0.09. None were severe (life-
changing) harm injuries.

Further 60% reduction in moderate harm injury rate from 
0.07 in 2023 to 0.03.

High potential event rate with fatality potential
High potential events with fatality potential 

GP consultations

0.50

0.25

0.00

8

7

6

5

4

3

2

1

0

s
t
n
e
v
e
f
o
r
e
b
m
u
N

5,000

4,000

3,000

2,000

1,000

0

l

s
t
l
u
s
n
o
c
/
s
e
e
y
o
p
m
e
f
o
r
e
b
m
u
N

d
e
k
r
o
w
s
r
u
o
h
n
o

i
l
l
i

m

r
e
p
e
t
a
R

2020

2021

2022

2023

2024

Number of events

Rate

Further reduction in high potential event rate with fatality 
potential. Continued focus on enhancing frontline safety 
leaders effectiveness and contractor health, safety and 
environment (HSE) management practices to further 
improve performance. Some 2024 event classifications are 
still under review and subject to confirmation.

38

80%

60%

40%

20%

0%

l

s
e
e
y
o
p
m
e
f
o
e
g
a
t
n
e
c
r
e
P

2023

2024

Employees who have accessed the GP service
Number of GP consults
% of employees who have accessed the GP service

In 2024 over 70% of Australian-based employees accessed 
the free onsite GP service.

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sustainability pillar 
Health and safety

Asset integrity and  
process safety

Asset integrity, process safety, life saving rules, and incident and  
crisis management are core parts of our prevention approach.

53%

70%

96%

Reduction in loss of primary 
containment (LOPC) rate  
from 0.47 in 2023 to 0.22 in 2024

Reduction in loss of containment 
incident (LOCI) rate  
from 0.47 in 2023 to 0.14 in 2024

Safety Critical Compliance1 
an improvement from 95 per cent  
in 2023

Our approach 

Santos aspires to be the safest energy 
company where we have a presence 
by preventing harm to people and the 
environment. A failure to manage asset 
integrity and process safety can result 
in a major accident or environmental 
events. Using our improved safety risk 
assessment methodology, multiple 
independent barriers are identified 
and implemented to prevent a loss 
of containment and mitigate the 
escalation potential should it occur.

As seen in Figure 1, Santos applies 
a process safety philosophy in our 
early design phase to identify hazards 

and reduce risks as low as possible. 
Once projects are developed and in 
operation, Santos applies a four-stage 
approach focused on management 
and continual improvement, as shown 
in Figure 2.

Our opportunities 
and risks

Our opportunities include: 

Enhance safety-critical barrier 
ownership, frontline competency, 
and leadership accountability to 
drive continuous improvement in 
process safety performance. 

Improve the identification and 
response to early warning signs and 
weak signals by implementing an 
effective incident learning process 
to prevent recurring process safety 
events.

Proactive identification of hazards 
and robust implementation of 
control measures.

Our risks include:

Unplanned or uncontrolled release 
of hydrocarbons impacting 
environmental resources and 
assets.

Figure 1: Asset integrity and process safety  
in design process

Figure 2: Asset integrity and process safety in operations

Safety design 
philosophy

Learn and 
improve

Stage 1  
Safety  
assessment

Identify  
barriers

Start-up  
review

Hazard 
identification

Stage 4 
Analayse and 
improve

Stage 2 
Operationalise 
safety 
assessment

Safety  
deliverables

Manage  
risks

Stage 3 
Manage 
barrier health

Manage 
barriers

Safety in design and operations processes are designed to be compliant with all relevant standards, codes of practice, 
regulations, and Santos' SMS. Our iterative approach across all asset lifecycle stages reduces asset integrity and process 
safety risks to so far as is reasonably practicable (SFAIRP) or as low as reasonably practicable (ALARP).

1 

 Safety Critical Compliance is a key safety measure that tracks how many critical maintenance tasks are completed on time. It shows how effectively we are 
testing and maintaining the safety barriers that prevent major accidents. A 96% compliance rate highlights our strong commitment to keeping these barriers 
functional and effective.

39

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationAsset integrity and process safety
(continued)

Our process and due 
diligence 

We have an Operations Excellence 
Framework in place, enabling 
operations teams to comply with the 
requirements of our Asset integrity 
and process safety management 
standards and procedures. A three-
level assurance framework has been 
implemented to verify that critical 
process safety controls and operations 
excellence requirements are 
embedded to align with our SMS. 

First level

Frontline leadership assurance

Second level

Regional line  
management assurance

Third level

Independent corporate  
functional audit

Learnings from these assurance events 
drive improvement actions across 
Santos' regional business units and 
individual assets, and are reflected in 
our SMS. 

Effective risk management also entails 
multi-tiered governance processes 
through live dashboard reporting 
of critical KPIs at the asset, regional 
business unit and corporate levels. 
KPIs include key process safety and 
asset integrity lead and lag indicators.

We conduct bow-tie risk assessments 
as part of our corporate assurance 
program. The focus of these risk 
bow-ties is preventing loss of 
containment and mitigating potential 
escalations of loss of containment. 
We are continuously improving our 
bow-tie risk methodology in response 
to identified incidents and near-
misses. Preventative and mitigative 
processes require that asset integrity 
and process safety risks are reduced 
SFAIRP. 

In Santos, asset integrity is managed 
through integrity management 
plans which are based on risk-based 

40

inspection principles. They are 
executed through non-intrusive or 
intrusive inspection programs, well-
defined Integrity Operating Windows, 
and robust excursion management 
processes embedded within the 
governance framework.

We use a range of tools, such as an 
Integrated Risk Register and Permit 
to Work, and implement integrity 
management systems to ensure 
process requirements under SMS 
are met.

Our actions and 
performance

During 2024, we continued to 
focus on the integration of the 
SMS into operations of recently 
acquired PNG and Alaskan assets, 
while implementing continuous 
improvement practices within 
existing assets. Santos’ Permit to 
Work standards have been in place 
in PNG since early 2024, with digital 
transformation for frontline operations 
and maintenance personnel underway. 
In 2024, Alaska has applied the SMS 
Opportunity Development Process 
(ODP) as part of its ongoing project 
design and execution.

The review of the safety assessment 
and case for Darwin LNG – in line with 
the five-yearly review and relicensing

process – is in its final stages and 
will incorporate life extension of the 
facility ahead of Barossa production 
commencing.

Significant asset integrity and process 
safety input has been incorporated 
into the finalisation of the design 
and operation of Moomba CCS and 
Barossa facilities during 2024. Formal 
safety assessments for onshore 
upstream assets continue to provide 
comprehensive and systematic 
identification and management of 
process safety risks.

Communities of practice are the 
result of our Operational Excellence 
Framework integration and our focus 
on frontline operations engagement 
in identifying and understanding 
integrity and process safety risks. 
Field operations personnel contribute 
to bow-tie risk assessments and 
validation, enabling continuous 
improvements in facility design 
and operations as reflected in LOCI 
performance improvements.

We also engage with external forums 
to contribute to a wider industry 
community of process safety 
knowledge, lessons-sharing through 
incident review panels, and supporting 
publications on process safety to 
drive broader industry learning 
and improvement. During 2024, we 
participated in workshops with Safer 
Together and IChemE, of which we are 
founding members. 

LOCIs

s
r
u
o
h
k
r
o
w
n
o

i
l
l
i

m

r
e
p
e
t
a
r

0.8

0.6

0.4

0.2

0.0

16

12

8

4

0

2020

2021

2022

2023

2024

Tier 1 LOCIs

Tier 2 LOCIs

Tier 1 and 2 combined LOCI frequency rate 

s
t
n
e
d
c
n

i

i

f
o
r
e
b
m
u
N

The loss of containment incident (LOCI) rate fell by over 70% in 2024.

Santos Annual Report 2024 
 
 
 
 
 
Sustainability pillar 
Environment

Closure and rehabilitation

We have developed a structured approach to the closure and 
decommissioning of assets, reflecting best practices in environmental 
management, safety and community engagement.

Our approach

Our approach is to have a 
decommissioning plan that addresses 
our obligations, including regulatory 
and sustainability requirements.  
We have a set of standards embedded 
in our SMS that govern the 
decommissioning of the oil and gas 
assets where we operate. These 
standards enable us to fulfill our 
environmental and social obligations 
during decommissioning.

Repurposing of assets is also part 
of our broader commitment to 
sustainability and responsible resource 
management.

Phased approach to decommissioning 
closure and rehabilitation

We take a phased approach across an 
assets lifecycle:

•  Planning for decommissioning: 
While assets are still producing, 
the Company develops a 
decommissioning strategy 
or plan that addresses all 
obligations, including regulatory 
requirements, joint venture 
agreements, and timing constraints. 
Decommissioning plans also 
include a cost estimate, which 
drives our decommissioning 
provisions, and outlines the risks 
and opportunities. This document 
is reviewed and updated every year 
during the whole life of the asset.

•  Decommissioning assets:

 – Well decommissioning: This 
involves safely plugging and 
abandoning the wells following 
company standards and 
regulatory requirements.

 – Infrastructure removal: 

Platforms, pipelines, subsea 
infrastructures and other 
facilities are decommissioned as 
per the approved environmental 
plan (EP) and with reference to 
relevant safety considerations.

•  Repurposing assets: As part of 

our environmental and social risk 
assessment process and broader 
commitment to sustainability and 
responsible resource management, 
alternative uses for our assets, 
infrastructure and facilities are 
considered as an important part of 
our approach.

•  Site monitoring and rehabilitation: 

 – Offshore assets: Following 

infrastructure decommissioning, 
we actively monitor the seabed 
as required in approved EPs. 

 – Onshore assets: We work 
to rehabilitate the sites, 
including revegetation and soil 
stabilisation, and facilitate the 
return of the land to the state as 
agreed with the landowner or 
for future use.

Our opportunities 
and risks

Our opportunities include:

Technology solutions for 
repurposing of assets toward CCS 
technology and decarbonisation.

Building local community capability 
and planning for sustainable 
opportunities after closure.

Our risks include:

Environmental liabilities.

Regulatory and compliance. 

Social licence to operate.

Our process and due 
diligence

Santos executes decommissioning 
projects in line with regulatory 
requirements and industry best 
practice. In 2024, Decommissioning 
Project Process and Decommissioning 
Technical Standards were developed:

•  Decommissioning project process: 

sets out steps that projects 
must follow for compliance with 
regulatory requirements and the 
effective execution of the project.

•  Decommissioning Technical 

Standards: defines mandatory 
requirements of Regional Business 
Unit operations and project teams 
throughout the asset lifecycle.

Our approach, process and due 
diligence includes the below principles:

Repurposing of assets

Repurposing of assets involves finding 
alternative uses for oil and gas wells, 
infrastructure pipelines and facilities 
which have reached the end of their 
original operational life. 

Carbon capture and storage: We have 
successfully repurposed reservoirs 
to support the storage of carbon 
dioxide for our flagship CCS project. 
We actively assess reservoirs and 
wells for their suitability for long-term 
carbon dioxide storage as part of our 
decommissioning repurposing studies. 

Renewables integration: We explore 
opportunities to integrate renewable 
energy sources into our existing 
operations by repurposing existing 
infrastructure for solar and wind energy. 

Low carbon fuels: We are also 
exploring repurposing existing 
pipelines and processing facilities 
for new energy projects, including 
transporting low carbon fuels, such as 
synthetic gas.1

1 

 Synthetic gas, which is in early stages of development, is being analysed for technical and economic feasibility. Synthetic gas was previously referred to as 
e-methane. Terminology update to reflect more widely recognised term. See Glossary for full definition.

41

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationClosure and rehabilitation
(continued)

Decommissioning activities throughout the asset lifecycle

Relinquish
title

Secure 
acreage

Decommissioning 
strategy 
development as a 
condition of project 
investment 
decision

Decommissioning 
cost estimate 
incorporated into 
project lifecycle 
costs

Asset 
retirement phase1 
Decommissioning 
projects execution 
following due 
processes

Asset 
development phase 
Strategy and cost 
estimate defined as 
part of project 
investment decision

Final Investment 
Decision

Decommission
to regulatory 
requirements

Maintain 
suspended 
assets

Cessation of 
production 

Develop
decommissioning
plan

Asset production phase 
Progressive decommissioning: 
annual update of strategy, 
plan and cost estimates

Commence 
production

Decommissioning 
strategy updated 
annually and 
reflected in long-
term planning 
processes

5 years prior 
to production 
cessation: initiate 
decommissioning 
process including 
documentation 

10 years prior 
to production 
cessation: Explore 
opportunities for 
asset repurpose/ 
divestment/field 
life extension

Input to asset
restoration
obligations cost 
estimate half-year 
refresh, and full 
year update 
reporting

Cost estimate 
updated every 
three years

Progressive 
decommissioning 
incorporated into 
operation and 
maintenance plans 
and budgets 

Further information on repurposing of 
our assets is available in the Delivering 
on our CTAP section of the Climate 
Report. 

 Rehabilitation for agricultural or 
community use

Gas extraction activities generally 
do not significantly disturb land 
and co-existence of land uses is 
common. We are committed to 
minimising the environmental impacts 
of our operations and activities 
including impacts on agricultural and 
community uses. Where significant 
disturbance to land occurs, we aim to 
restore sites to as close as possible 
to its pre-disturbed condition or 
as otherwise agreed with relevant 
stakeholders. This approach seeks to 
ensure that the land can continue to 

provide value to local communities, 
even after resource extraction has 
ceased.

stewardship and achieved 99.5 
per cent of recycling rate for the 
recovered materials.

 Environmental and social 
responsibility 

We emphasise environmental 
stewardship throughout the 
closure process. The Company’s 
decommissioning plans include 
measures for:

•  Removing or repurposing 

infrastructure (such as platforms, 
pipelines, and wells) in a manner 
that minimises environmental 
impact.

•  Recycling rate. For example, the 

Campbell platform has been fully 
decommissioned in alignment with 
best practices and environmental 

•  Restoring ecosystems per the 

approved Environmental Plan or 
adapting them for beneficial reuse.

•  Managing any residual 

environmental risks through post 
decommissioning monitoring 
and mitigation per the approved 
Environmental Plan.

Santos engages local communities and 
stakeholders in closure planning to 
enable transparency and social licence 
to operate during decommissioning. 
This often involves consultation with 
a wide range of stakeholder groups to 
manage potential impacts.

1 

 We actively assess reservoirs and wells for their suitability for long-term carbon dioxide storage as part of our decommissioning repurposing studies.

42

Santos Annual Report 2024 
 
 
 
 
 
 
 
Refer to the Community section for 
more information about community 
plans throughout the lifecycle of 
activities.

Sustainability integration

We are committed to integrating 
sustainability principles throughout 
the lifecycle of the assets, including 
decommissioning. This involves 
reducing the carbon footprint 
of decommissioning activities 
by optimising processes and 
methodologies, using sustainable 
materials, and minimising energy use. 
The Company also seeks to reuse 
and recycle materials and equipment 
where possible.

 Post-decommissioning monitoring 
and maintenance

After decommissioning, Santos 
monitors decommissioned sites 
in accordance with regulatory 
requirements. This is to check 
environmental restoration is effective. 
This often includes ongoing water and 
soil testing, biodiversity monitoring 
and periodic site inspections.

Our actions and 
performance

We continue to engage with 
communities in the regions where 
we operate. In 2024, this included 
our engagement process for the 
decommissiong of the Campbell 
facility as part of our Asset Removal 
Operations Environment Plan.

We collaborate with industry 
bodies such as the Centre of 
Decommissioning Australia (CODA) 
and we are part of its Industry 
Advisory Committee to help shape the 
future of decommissioning for the oil 
and gas industry in Australia.

In 2024, we successfully completed a 
number of decommissioning projects:

•  Campbell platform topside and 

substructure removal and disposal

•  Harriet Joint Venture project 
completed 13 wells plug and 
abandonment (P&A)

•  Mutineer Exeter Plug and 

Abandonment project completed 
multiple wells P&A

• 

In addition to our full field 
decommissioning activities, 
we also undertook progressive 
decommissioning for our onshore 
assets. For example, in the Cooper 
Basin, we decommissioned five per 
cent of expired wells in compliance 
with local regulations. Additionally, 
we plugged and abandoned one 
well in Papua New Guinea (PNG).

For our non-operated assets, we 
supported the completion of the nine-
platform removal on the Thevenard 
project and completed over 140 
well plug and lower abandonment 
projects on the Barrow Island 
Decommissioning project. 

Pictured: Campbell Decommissioning Project

43

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSustainability pillar 
Environment

Water

Santos is dedicated to sustainably managing impacts to water 
resources from our activities. We do this through continuing  
to understand our water-related risks and applying the water 
management hierarchy across all our operations. 

2

695

New technical standards  
integrated into company wide risk 
management process

Megalitre reduction  
in water withdrawn from GAB aquifers

9,082

Megalitres of produced water 
beneficially reused

Our approach

Our risks include:

Our activities seek to avoid and 
reduce water abstraction by ensuring 
operations maximise efficiency and 
avoid unnecessary consumption. 

When oil and gas is produced to the 
surface it is accompanied by water, 
known as produced water. Our aim 
is to maximise the reuse of this 
produced water.

Beneficially using produced water 
minimises dependency on other water 
sources and avoids residual water 
volumes that need to be otherwise 
managed, reducing costs and impacts 
across the full operating lifecycle.

In Australia, we are reducing our 
impact on community water resources 
by funding initiatives to return water 
to the Great Artesian Basin (GAB). 

Our opportunities 
and risks

Our opportunities include:

Understanding our impact on water 
resources in water stress regions.

Development of a Santos 
framework to identify dependency 
and impact-related water risks. 

Investing in water-saving initiatives 
under the GAB Industry Partnership 
Program. 

Development of new technologies 
and opportunities for produced 
water treatment and beneficial 
reuse. 

Impacts to water resources, 
including the GAB, and water 
dependent ecosystems.

Water availability in operational 
areas.

Regulatory challenges.

Reputation and social licence  
to operate.

Water contamination.

Our process and  
due diligence

Santos conducts assessments for 
water dependency and impact-
related risks across new and existing 
operational sites in line with regulatory 
requirements, which include criteria 
and processes defined by relevant 
state and federal regulators. 

Water impact and risk assessments, 
consistent with these regulatory 
requirements, are integrated into 
Company-wide risk management 
processes. In 2024, two applicable 
technical standards were developed:

•  The Environment Approval 

Technical Standard, which includes 
requirements for undertaking 
environmental risk assessments to 
inform preparation of approvals. 

•  The Environment Management 
Technical Standard, including 
requirements for water sourcing 
and water management across the 
business. 

In 2025, Santos aims to develop a 
Company-wide framework to identify 
and evaluate dependency and impact-
related water risks to improve our 
understanding and management of 
our water risk profile.

We extract and manage water 
responsibly in accordance with 
licences issued by authorities which 
regulate access to water resources. 

Santos only releases water to the 
environment in accordance with 
licences issued by regulatory 
authorities.

Our actions and 
performance

Overview of controlled produced 
water releases

Santos complies with regulatory 
mandates, implementing monitoring 
protocols for discharges in line with 
approved environmental oversight 
plans. In 2024, all monitored 
discharges adhered to established 
compliance thresholds.

In offshore Australia and PNG, most 
of the produced water is re-injected 
into depleted hydrocarbon reservoirs, 
thereby reintroducing it into 
subsurface formations that replicate 
its original geological context. This 
approach minimises ecological impact 
and upholds sustainable resource 
management principles.

In onshore Australia, regulatory 
frameworks permit the controlled 
release of produced water at three 
designated sites within Queensland: 
Jackson and Naccowlah in the 

44

Santos Annual Report 2024Cooper Basin, as well as the Dawson 
River in the Bowen Basin. The total 
volume of released water in 2024 was 
1,607 million litres, a reduction from 
2023 and 2022 volumes. 

Santos complies with regulatory 
mandates, implementing monitoring 
protocols for discharges in line with 
approved environmental oversight 
plans. In 2024, all monitored discharges 
adhered to established compliance 
thresholds.

Comprehensive water management 
and environmental monitoring across 
Santos' global operations

The monitoring and verification 
plan for the Moomba CCS project 
was approved in 2024 by the South 
Australian Department for Energy 
and Mining. This plan outlines the 
necessary monitoring activities so  
that groundwater remains unaffected 
by the project. 

In PNG, ongoing monitoring of water 
extraction and discharge continued 
in 2024 so that extraction rates stay 
within approved limits, and that base 
flows crucial for maintaining aquatic 
ecology are not disrupted.

Additionally, Santos conducts 
comprehensive water resource 
monitoring programs around the 
Pikka Project area in Alaska. These 
include under-ice monitoring 

during winter and ‘spring breakup’ 
hydrology monitoring during the 
thawing season. Hydrologists assess 
flooding extents, the impact of ice 
jams on water surface elevations, 
peak discharge estimates, flood and 
stage frequencies, erosion, changes 
in the hydraulic regime, and water 
quality. This essential monitoring 
allows Santos to design infrastructure 
for no negative impact on the natural 
environment and provides insights 
for post-construction performance 
assessments.

Sustainable water management 
and protection of groundwater-
dependent ecosystems

In Australia, the Great Artesian 
Basin (GAB) is a vital water source 
for many communities in the areas 
where we operate. We are committed 
to offsetting our groundwater 
abstraction from the GAB through the 
funding of water-saving initiatives. 
Over the past three years, Santos has 
invested A$3m in projects under a 
GAB Industry Partnership Program, 
which has resulted in water savings for 
the GAB's aquifers. In 2024, our total 
gross water extraction from the  
GAB was 1,234 million litres, offset by 
return of 3,005 million litres.

In 2024, we continued to actively 
manage our operations to prevent 
impacts to springs and other 

groundwater-dependent ecosystems. 
Ongoing monitoring of impacts to 
springs in the Precipice Sandstone, 
conducted by the Queensland Office 
of Groundwater Impact Assessment, 
confirmed that Santos' extraction of 
produced water has not resulted in 
any recorded impacts.

In Alaska in 2023, Santos completed 
an upgrade of a bridge in the village 
of Nuiqsut replacing a damaged 
structure and restoring the impacted 
stream channel to its natural state. 
These efforts benefited over 13 
kilometres of stream and 580 acres 
of connected water bodies, including 
lakes and ponds. The improvements 
restored natural drainage patterns, 
reduced sedimentation, eliminated 
barriers to fish passage, and enhanced 
access to critical upstream habitats, 
including overwintering areas. The 
project also improved community 
access for subsistence and other 
activities. To establish a baseline, 
fisheries biologists conducted a fish 
survey in 2021. A follow-up survey 
in 2024 revealed an increase in fish 
populations and the presence of 
new species compared to 2021. A 
subsequent survey is scheduled for 
2027 to assess habitat health and the 
recovery of aquatic life.

GAB water footprint

Reusing produced formation water

3,500
3,500

3,000
3,000

2,500
2,500

2,000
2,000

1,500
1,500

1,000
1,000

500
500

0
0

)
3
m
0
0
0
1
(

r
e
t
a
w

f
o
e
m
u
o
V

l

2020

2021

2022

2023

2024

GAB water extracted

GAB water offset

24,000

20,000

16,000

12,000

8,000

4,000

0

)
3

m
0
0
0
1
(

r
e
t
a
w

f
o
e
m
u
o
V

l

2020

2021

2022

2023

2024

Produced formation water withdrawn
Beneficially used produced formation water withdrawn

Santos has funded projects that have delivered more than 
3,000 million litres in water savings per annum for aquifers 
within the GAB.

In 2024 Santos reused 9,082 million litres of produced 
formation water. Reuse activities included irrigation and stock 
watering, dust suppression, drilling and completions and civil 
works.

45

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
Sustainability pillar 
Environment

Biodiversity 

Santos works across a broad range of terrestrial and marine environments 
from tropical and arid to polar biomes, each with its own unique and 
dynamic biodiversity. We aim to minimise our impact wherever possible. 

Our approach

We implement structured 
development processes that follow an 
avoidance hierarchy (avoid, minimise 
and offset) to prevent and/or minimise 
our impacts on nature. We work 
collaboratively with our stakeholders 
to achieve positive biodiversity 
outcomes. Where we cannot avoid a 
biodiversity impact, we offset these 
impacts by protecting larger areas 
with similar biodiversity values.

We are committed to leaving a 
positive legacy by enhancing and 
sustaining biodiversity in our areas 
of operation and supply chain. 

Our opportunities 
and risks

Our opportunities include:

Understanding dependency and 
impact-related biodiversity risks. 

Development of a framework to 
identify dependency and impact-
related biodiversity risks in line with 
international standards.

Protecting and enhancing 
biodiversity in our areas of 
operation.

Our risks include:

Impacts to biodiversity.

Land disturbance.

Impacts to threatened ecological 
communities and listed species.

Our process and due 
diligence

Santos conducts biodiversity impact 
and risk assessments across new 
and existing operational sites in line 
with regulatory requirements, which 
include criteria and processes defined 
by authorities. 

In 2024, two Technical Standards were 
developed to integrate biodiversity 
impact and risk assessment and 
management methodologies into 
Company-wide processes:

•  The Environment Management 
Technical Standard including 
minimum requirements across 
the business such as biodiversity 
management, pest plant and animal 
management.

•  The Environment Approval 

Technical Standard including 
requirements to be undertaken in 
relation to environment approvals 
such as completing environmental 
risk assessments to inform 
preparation of approvals.

Biodiversity risk assessment process 
steps vary by jurisdiction and may 
include: 

•  Literature review of previous 

ecological impact assessments, 
flora and fauna surveys and 
research studies in both project 
and adjacent areas.

•  Conducting surveys for flora and 

fauna. 

•  Analysis of biodiversity datasets 

and mapping. 

•  High resolution aerial photography 
and Light Detection and Ranging 
(LiDAR) to investigate vegetation 
cover, landscape features and 
disturbance patterns.

•  Searching databases and maps 
for threatened species and 
populations.

•  Consultation and collaboration with 

local communities.

In 2025 we will develop a Company-
wide framework to identify and 
evaluate dependency and impact-
related biodiversity risks to improve 
our understanding and management 
of our biodiversity risk profile.

Our actions and 
performance

Our risk assessments to date have not 
identified any sites that have had a 
significant biodiversity impact or are in 
proximity to critical biodiversity sites. 
Santos has controls and monitoring in 
place and some of these initiatives and 
programs are outlined here.

Environmental monitoring and 
biodiversity conservation initiatives 
across global operations

Since 2010, we have been collaborating 
with the Lake Kutubu Wildlife 
Management Area Committee in 
PNG to monitor and implement 
environmental improvement initiatives. 
The program was disrupted in 2018 by 
a devastating earthquake and again 
between 2020 and 2022 due to the 
COVID-19 pandemic. After consulting 
with the Committee, we resumed 
monitoring in 2023, and the program 
continued in 2024.

The 2024 monitoring program included 
assessments of hydrodynamics and 
sediment quality, a fish survey, snorkel 
survey, hydroacoustic data collection, 
villager questionnaire and catch 
landing survey. Key findings from the 
program include:

•  fish biomass showed a general 
increase compared to previous 
studies

•  two native fish species were 

documented after an absence 
of more than 14 years

46

Santos Annual Report 2024•  nine of the 12 species endemic 
to the region were observed or 
recorded in the surveys

•  Active management and control of 
invasive flora species on Varanus 
Island.

•  the abundance of exotic fish 

decreased to levels similar to those 
in 2014.

Queensland

In 2024 we continued our partnership 
with the Goorathuntha Traditional 
Owners Ltd to secure approximately 
2,400 hectares of additional 
biodiversity offsets at Mount Tabor 
Station in Queensland. Once ratified, 
this will bring the total secured high 
ecological value vegetation, at Mount 
Tabor Station, to more than 7,700 
hectares.

Northern Territory

In Darwin, we completed our annual 
mangrove surveillance and monitoring. 
Additionally, we are a member of the 
Darwin Harbour Advisory Committee, 
which tracks the overall health of the 
harbour and reports findings to the 
government.

Western Australia

Santos' Varanus Island operation 
is located within a Class C nature 
reserve. Our biodiversity and 
monitoring programs are centred 
around the following principles:

•  Enabling the continued breeding 

success of fauna native to Varanus 
Island.

•  Operations-friendly wildlife 

programs including nest relocations 
and distressed fauna rescues.

This is achieved through our extensive 
environmental and compliance 
programs at Varanus and Airlie Islands, 
including:

•  annual shearwater and seabirds 

protection program

•  annual shearwaters fledgling 

success program

•  annual turtle monitoring including 
tagging and hatching success 
monitoring

• 

long-term coral and sea 
temperature monitoring program at 
Varanus Island

•  flora and mangrove surveillance 
program including active weed 
management and seed collection 
for rehabilitation programs.

Key to biodiversity management 
on Varanus and Airlie Islands is the 
implementation of the Western 
Australia Quarantine Management 
Plan. Quarantine inspections are 
completed in accordance with the 
plan and include a process for the 
management of weed species. All 
goods, materials and equipment 
destined for the islands are inspected 
for the presence of soil, vegetative 
matter and non-indigenous fauna 
prior to being shipped to the islands. 
In addition, all vessels destined for the 
islands are routinely inspected for the 
presence of vermin.

Alaska

In Alaska, Santos is collaborating with 
a contractor to test a temperature 
forecasting tool as part of the Pikka 
project. The temperature forecasting 
tool is designed to enhance winter 
season ice road construction 
operations on the North Slope. This 
promising tool helps with project 
planning, ensuring that activities do 
not adversely affect the sensitive 
tundra environment, while also 
allowing efficient mobilisation of 
construction crews. The tool provides 
real-time insights into how tundra 
temperatures respond to climatic 
factors such as air temperature and 
snow cover.

Large herds of caribou migrate across 
the North Slope of Alaska, including 
near the Pikka project area. Santos 
sponsors the deployment of radio 
collars to track caribou locations, 
in collaboration with the Alaska 
Department of Fish and Game. The 
Department's research program, 
which has been ongoing for over two 
decades, seeks to understand how 
caribou movements and behaviour are 
influenced by industrial activity. 

Since 2021, wildlife consultants have 
studied caribou distribution and 
movement in the Pikka Project area 
both before and after construction. 
This research helps Santos assess 
how caribou are affected by seasonal 
movement patterns and industrial 
activities, enabling us to identify and 
implement measures to minimise 
impacts on the caribou population.

Pictured: Pikka phase 1

47

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSustainability pillar 
People and culture

Diversity and inclusion 

Santos is committed to building a diverse workforce and fostering an 
inclusive workplace environment. We continue to implement actions to 
drive creativity and innovation within our diverse workforce.

16% 

Relative increase  
in our Inclusion Index

13.8%

Increase of females  
in field-based roles since 2023

Our approach

The Santos values and Leader, Expert 
and Professional (LEAP) behavioural 
framework define our beliefs about 
people, work and required behaviours. 
They reflect how we work, how we 
treat each other and how we interact 
with the people and communities 
around us.

The Diversity and Inclusion Policy 
outlines our commitment to an 
inclusive workplace culture. We 
recognise that an inclusive workplace 
creates the environment to harness 
diversity of thought and skills which 
can help individuals, colleagues and 
teams to achieve their goals.

The Diversity and Inclusion strategy 
consists of three key pillars:

•  Build diversity: Leverage different 
backgrounds, perspectives and the 
unique viewpoints that will enable 
us to think differently and be more 
innovative.

•  Foster inclusion: Create a ‘One 

Santos’ work environment where 
all people can be themselves, feel 
supported, respected and have a 
sense of belonging.

•  Enhance potential: Develop diverse 
leadership and decision-making to 
drive innovation, thinking quality 
and equity.

Our opportunities 
and risks

Our opportunities include:

Advance and retain female 
representation.

Foster an inclusive work environment 
where all our people can be 
themselves, feel supported, respected 
and have a sense of belonging.

Advance and retain Indigenous 
representation.

Our risks include:

Inability to attract and retain female 
talent in a competitive market 
particularly in the field.

Inability to attract and retain 
Indigenous talent in communities in 
which we operate.

Our process and due 
diligence

Santos embeds diversity and inclusion 
through a multi-faceted approach that 
starts with leadership commitment 
and a clear vision. There are four key 
areas:

•  recruitment processes to attract 

and reach a wide range of 
candidates with leaders actively 
engaging in diverse hiring practices

2.7%

Australian workforce Indigenous 
participation  
up from 2.1% in 2023

•  training programs focused on 
unconscious bias and cultural 
awareness to foster an inclusive 
workplace culture, encouraging 
employees to engage with one 
another’s perspectives

•  regular review of policies and 

practices for them to be effective, 
relevant and aligned to Santos’ 
diversity and inclusion objectives

•  continuous feedback through 
ongoing employee sentiment 
surveys, and targeted mentorship 
programs to identify and address 
barriers to inclusion.

Our actions and 
performance

The diversity and inclusion strategy 
outlines the key objectives to measure 
our performance. These are:

Objective: Increase gender diversity 
within the company.

Santos is committed to fostering 
gender equality and enhancing 
diversity and inclusion to unlock 
the potential of our people and our 
business. We recognise how a range 
of experiences and viewpoints can 
lead to an improved performance and 
decision-making.

48

Santos Annual Report 2024Our actions include:

•  a targeted recruitment strategy 
to attract diverse candidates has 
resulted in female representation 
in executive leadership roles (CEO 
direct reports) increasing from 38.5 
per cent (2023) to 41.7 per cent in 
2024. At the senior leadership level 
there has been a small increase 
from 28.6 per cent to 32.1 per cent. 
Female representation on the 
Board has increased from 40.0 
per cent to 44.4 per cent. The 
percentage of female new hires was 
37.7 per cent for 2024. We have 
seen female representation increase 
in both field and non-field locations 
with the non-field representation 
now over 40 per cent.

•  female development: A supportive 

ecosystem promotes growth, 
confidence, and career progression 
for women. During 2024 female-
specific programs have been 
designed and deployed. These 
include talent mentoring, targeted 
development plans and coaching. 

•  employee resource groups: 

Establishing a platform that will 
empower diverse employees and 
improve our understanding of their 
needs. In 2024, we designed and 
selected founding members to lead 
the implementation of two new 
Employee Resource Groups: 

 – Thriving Together: a Gender 

Equality group.

 – Walk Along: an Aboriginal and 
Torres Strait Islander group.

Objective: Increase the Inclusion Index 
score part of the Real Talk employee 
sentiment survey. 

Real Thrives Here is our commitment 
to creating the workplace and culture 
that will deliver on our Purpose and 
Vision 2040. 

We measure progress against the Real 
Thrives Here commitment through 
the Real Talk employee sentiment 
survey. Relevant to the Diversity and 
Inclusion strategy is overall employee 
experience and the Inclusion Index 
which measures company-wide 
inclusion as part of the survey.

16 per cent relative improvement in 
the inclusion index and a significant 
increase in overall engagement result 
nearing top quartile performance. This 
highlights that we are taking action 
on the things that matter most to our 
people. The key focus areas include:

•  health and wellbeing: The targeted 

health and wellbeing strategy 
has shown a 31 per cent relative 
increase in the belief that Santos 
cares for the health and wellbeing 
of its people. In 2024 the program 
focused on delivering proactive 
support and services across all five 
key pillars of Healthier Me. 

•  strong leadership: Empowering 

leaders with survey insights to drive 
action planning, informed decision-
making and a responsive listening 
culture. There has been a focus on 
building capability to take action on 
what matters most to employees 
through action-planning thought 
starters, results dashboards and 
training sessions. 

•  storytelling: Focus on humanising 
the Santos values and the Real 
Thrives Here commitment. 
Employees were invited to share 
experiences through internal 
stories and face-to-face Santos 
Stories panel sessions in multiple 
locations. In addition, 12 of our 
people from different locations 
and backgrounds were selected to 
help bring Real Thrives Here to life 
through unscripted, diverse and 
authentic stories.

•  cultural awareness: Fostering 
cross-cultural awareness and 
understanding across our different 
geographical locations has been 
another area of focus. In 2024, we 
celebrated and recognised several 
key diversity dates to promote 
deeper understanding of diverse 
perspectives. We hosted several 
internal events for International 
Women's Day, NAIDOC week, PNG 
Independence Day, and Indigenous 
Peoples' Day, specifically 
acknowledging Alaska Natives.

Objective: Increase Aboriginal and 
Torres Strait Islander representation in 
our Australian workforce.

The 2024 survey saw improvement 
across all survey factors related to 
employee experience including a 

As part of the Indigenous Participation 
Plan (IPP) we take targeted actions to 
increase and support Aboriginal and 

Torres Strait Islander representation in 
our Australian operations.

The early careers pathway 
programs continue to have strong 
Aboriginal and Torres Strait Islander 
representation, with 34.1 per cent 
across the apprenticeship, and 
traineeship programs, and 2 per cent 
in the graduate program. This, coupled 
with an increase in direct hires to 
more than 60 employees has led to 
a positive improvement in our total 
workforce representation (contractors 
and employees) increasing to 2.7 per 
cent up from 2.1 per cent in 2023. 

Improving local capabilities

•  The Making Tracks program 

supports local Aboriginal and 
Torres Strait Islander people 
holistically to acquire the 
skills needed to be ready for 
employment. The focus of the 
pilot program was to strengthen 
and increase local Aboriginal and 
Torres Strait Islander capability in 
participation at assessment centres 
by fostering a supportive and 
culturally inclusive environment. 
We continue to strengthen 
relationships with Traditional Owner 
Groups through pre-employment 
opportunities, foster diversity in our 
early career programs, and support 
broad capability development 
in the regional areas where we 
operate.

•  Santos-Kaefer training program.  
In Darwin, Santos has partnered 
with Kaefer to deliver an 
Indigenous training program which 
creates pathways and careers in 
skills such as scaffolding, health and 
safety, boilermaking, accounting 
and mechanical engineering. We 
have 26 NT-based First Nations 
people who have either: completed 
training and are working at the 
Darwin LNG facility (12 candidates), 
are undertaking their training  
(eight candidates) or have been 
identified for future recruitment  
(six candidates).

These projects highlight how we are 
expanding our pathways program in 
collaboration with service suppliers.

49

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDiversity and inclusion 
(continued)

New hires

Female representation in field and non-field roles

500

400

300

200

100

0

l

s
e
e
y
o
p
m
e
f
o
r
e
b
m
u
N

l

s
e
o
r
d
e
s
a
b
-
d
e
fi
n

l

i

2020

2021

2022

2023

2024

l

s
e
a
m
e
f

f
o
e
g
a
t
n
e
c
r
e
P

50%

40%

30%

20%

10%

0%

2021

2022

2023

2024

Female

Male

Field-based roles

Non-field-based roles

We continue to target attracting high calibre, diverse talent 
to deliver on our Purpose and Vision 2040.

Overall female representation across the general workforce 
of which 43.7% of roles are field based has continued to 
increase, to 28.1% in 2024. Representation increased in field 
locations to 11.9% and non-field locations to 40.7%.

Australian Indigenous workforce participation

Females leadership representation

l

a
t
o
t

f
o
e
g
a
t
n
e
c
r
e
P

e
c
r
o
f
k
r
o
w
d
e
s
a
b
n
a

i
l

a
r
t
s
u
A

3.0%

2.5%

2.0%

1.5%

1.0%

0.5%

0.0

50%

40%

30%

20%

l

e
v
e

l

i

p
h
s
r
e
d
a
e

l

h
c
a
e
n

l

i
s
e
a
m
e
f

2020

2021

2022

2023

2024

Aboriginal and Torres Strait Islander workforce

f
o
e
g
a
t
n
e
c
r
e
P

10%

0%

2020

2021

2022

2023

2024

Board

Executive Leadership

Leading business

Leading teams

We are committed to increasing Aboriginal and Torres 
Strait Islander representation in our Australian operation. 
This year there has been an increase from 2.1% to 2.7% of 
the Australian workforce.

In 2024, female Executive Leadership representation has 
increased to 41.7% and Senior Leadership increased to 32.1%.

50

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sustainability pillar 
Community relations

Community relations and  
land and resource access

Santos is committed to partnering with communities to build respectful 
and mutually beneficial relationships and deliver positive outcomes in 
the areas where we operate. 

262

Cultural heritage officers engaged

$518m

Spent with Indigenous suppliers1 
representing 8.1 per cent of total 
procurement spend

71

Agreements with Indigenous groups

Our approach

We partner with host communities 
across Australia, PNG, Alaska and 
Timor-Leste, guided by our Local 
and Indigenous Communities Policy 
and our Modern Slavery Policy. In all 
areas where we operate, we aim to 
forge mutually beneficial community 
relationships and deliver sustainability 
and positive social outcomes. 

Our opportunities 
and risks

Our opportunities include:

Improved engagement 
responsiveness with the 
communities in which we  
operate.

Investment in our local 
communities. 

Our risks include:

to their perspectives and understand 
their needs.

to them, enabling an informed 
decision to consent or otherwise.

Local community engagement

Santos has regular engagements 
with our stakeholders, including 
local communities, landholders 
and landowners and Indigenous 
communities. Community engagement 
is undertaken through community 
forums, shopfronts and events, 
community partnership activations, 
ongoing engagements with 
community stakeholders, regular 
sentiment survey, consultation 
meetings, forums and information 
sessions, community complaints 
and feedback in the regions where 
we operate. In Australia, our Yarning 
Circle and Indigenous Advisory Panel 
are community-tailored engagement 
instances. Through our strong and 
collaborative relationships with our 
stakeholders, Santos is committed to 
building mutually beneficial outcomes.

• 

• 

Involvement of Indigenous people 
in agreement-making, commencing 
early in the planning cycle well 
before commencement of on-
ground activities, continuing over 
the lifecycle of Santos’ activities.

Involvement of Indigenous 
people in their cultural 
heritage identification, control 
implementation and obtaining any 
required consent over the lifecycle 
of Santos activities.

•  Access by Indigenous people to 

their cultural heritage and cultural 
heritage information.

The Technical Standard also specifies 
that cultural heritage assessment 
processes to identify site specific 
cultural heritage risks must be in 
place prior to onshore activities 
commencing with controls to be 
identified to avoid cultural heritage 
over the lifecycle of Santos' activities.

Operational disruptions due to local 
community opposition.

Indigenous access and cultural 
heritage management

Cultural heritage impact.

Our process and due 
diligence

Santos' Community and Indigenous 
Participation Technical Standard sets 
out our requirements for community 
engagement, community investment, 
Santos' IPP and managing community 
feedback. Central to our approach is 
the need to identify our stakeholders, 
engage with them meaningfully, listen 

Santos' Indigenous (Land and 
Marine) Access and Cultural Heritage 
Management Technical Standard 
sets out our processes for Indigenous 
engagement, agreement-making, and 
onshore and offshore cultural heritage 
management. Respectful and culturally 
appropriate engagement with 
Indigenous people has always been 
integral to our processes, including:

•  Provision of sufficient information 

to Indigenous people during 
agreement-making on the potential 
risks, benefits, and alternatives 

1 

 Procurement spend with Indigenous, Native and PNG landowner suppliers. Indigenous spend at Santos is defined as an Indigenous enterprise providing goods or 
services to Santos. Historical data includes Australian Indigenous direct and indirect spend.

51

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationCommunity relations and land and resource access
(continued)

Community feedback and complaints

Our approach to community feedback is driven by our commitment to build respectful and enduring relationships with 
communities. Understanding stakeholder issues and concerns enables us to manage impacts and risks. Our process is 
embedded in the Community and Indigenous Participation Technical Standard allowing community members to have 
access to grievance mechanisms and provision for, or contribution of, remedy as appropriate. 

Consultation

Santos’ commitment to ongoing consultation with community stakeholders is embedded in our Environment Operating 
Standard and Environment Approvals Technical Standard which describe the six steps that we take to achieve meaningful 
stakeholder consultation.

Figure 1. External consultation framework

Connected communities 

Demonstrate that 
stakeholder concerns 
have been addressed 
to ALARP and are 
acceptable

Assess merit 

Review and assess merit  
of stakeholder feedback

Stakeholder  
consultation  
process

Achieve  
meaningful  
consultation

1

2

6

5

4

3

Identify stakeholders

1. Identify stakeholders 
(individuals and groups) 

2. Confirm reasons why each 
stakeholder is considered  
relevant and not relevant

3. Identify stakeholder risks/
opportunities

Establish  
engagement strategy 

1. Analyse stakeholders 
in collaboration with 
internal stakeholder teams 
and define engagement 
purpose

2. Map best available tools  
to inform and consult

3. Choose the appropriate 
methods and technologies

Consult 

Obtain stakeholder 
feedback on the 
regulated activity

Inform 

Provide stakeholders 
with information to assist 
them to understand 
the regulated activity, 
impacts and risks to 
the stakeholders' rights 
and activities

52

Santos Annual Report 2024Our actions and performance

Community feedback and complaints

In October this year we updated our complaints definition and process to improve the recording and management 
of community feedback. Since 1 October 2024, and according to the new definition and process, Santos recorded 40 
complaints across our footprint.

Of these, 27 complaints were recorded in Australia and 17 resolved. The complaints related to damage to roads and 
property, vehicles not using correct access tracks and failure to provide notice. In PNG, 13 complaints were received and 
eight resolved. Complaints related to landowner compensation, and local business development contracts. No complaints 
were recorded in Timor-Leste and Alaska.

Region

Papua New Guinea

Australia

Timor-Leste

Alaska

Community engagement and surveys

•  There is support for Santos’ 

Since 2019, Santos has undertaken 
community surveys to seek feedback. 
We aim to understand community 
perspectives to build enduring and 
respectful relationships, improve 
impacts of benefit programs and 
lift community living standards. 
In 2024, Santos expanded the 
research into a wider monitoring of 
community attitudes towards the oil 
and gas sector to better understand 
community priorities and needs. We 
also expanded our survey to include 
communities in Alaska and PNG.  
More than 1,700 community 
members were surveyed providing 
valuable insights to guide ongoing 
improvements in systems, processes, 
culture, and capabilities.

The results across regions showed:

• 

In both Australia and PNG, 
approximately 75 per cent agreed 
that gas is an essential part of 
everyday life for households, 
business and industry.

continued presence and operations 
in each asset area.

•  Santos performed well on worker 

behaviour and appearance but less 
strongly on providing community 
information and opportunities for 
engagement and feedback.

Community and Indigenous 
consultation

In 2024, we continued to consult with 
communities on the Barossa and 
Narrabri Gas projects to enable the 
risks and benefits of the projects to 
be communicated and understood 
by communities, their concerns to 
be heard and understood by Santos 
and ways that communities can 
benefit from project development  
to be shared (refer to our website:  
narrabrigasproject.com.au and  
santos.com/barossa/).

2024 (Oct – Dec) 

Complaints1

Resolved

13

27

0

0

8

17

0

0

For the Barossa project, in 2024 there 
were 51 consultation sessions across 
12 locations in northern Western 
Australia and the Northern Territory, 
conducted between January and 
December 2024. Attendance at these 
sessions was more than 4,300.

A condition of consent for the Narrabri 
Gas Project is the establishment 
and operation of a Community 
Consultation Committee (CCC) and 
four advisory groups:

•  Aboriginal Cultural Heritage 

Advisory Group

•  Biodiversity Advisory Group

•  Greenhouse Gas Emissions 

Advisory Group

•  Water Technical Advisory Group.

These groups provide a forum for 
open dialogue between Santos, 
independent experts, key stakeholder 
groups and the local community. 
Groups are chaired by an independent 
person appointed by the former 
NSW Department of Planning and 
Environment. 

1  Updated global community complaints definition and process effective from 1 October 2024.

 In PNG, 117 complaints recorded between January and September included complaints that were not due to Santos activities (e.g. issues with government royalty 
payments and or clan disputes). Moving forward and in line with the updated definition, complaints will only include matters directly related to Santos activities 
or operations. 

 In Australia, 166 ‘negative interactions’ recorded between January and September related to day-to-day interactions with landholders that were not classified 
as complaints under the definition in place at the time. Moving forward and in line with the updated definition, previously classified ‘negative interactions’ now 
constitute a complaint.

53

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
Community relations and land and resource access
(continued)

Indigenous participation

In 2024, the IPP achieved the following 
outcomes:

• 

• 

implemented a pilot pre-
employment program, Making 
Tracks, for Indigenous candidates 
to enhance role capability across 
Santos’ operations

introduced the ‘Mob Matters’ 
mentoring program to guide and 
support Indigenous staff in their 
roles

•  partnered with five Traditional 

• 

• 

Owners to establish the Cooper 
Basin Ranger Program and recruit 
Rangers

increase in Australian Indigenous 
workforce participation from  
2.1 per cent in 2023 to 2.7 per cent 
in 2024

increased Indigenous participation 
in pathway programs (apprentices, 
trainees) from 22.4 per cent in 2023 
to 34.1 per cent in 2024

•  $66m spent supporting Australian 
Indigenous suppliers, both directly 
and indirectly.

The Indigenous Advisory Panel (IAP) 
met three times in 2024, tracking 
the delivery of IPP commitments 
and providing valuable insights into 

contemporary issues and interests of 
Indigenous communities in Australia. 
Key outcomes from the IAP include:

•  development of cultural terminology 

to be used across Santos

•  embedded the IAP within the Local 
and Indigenous Communities Policy

•  review and revision of Santos 

policies for cultural appropriateness 
and incorporating this review into 
future policy updates

•  employment of a dedicated point 

of contact within Santos for 
Indigenous contractor support  
and assistance.

In November, IAP members participated 
in the third CEO Traditional Owners 
Yarning Circle, where Traditional  
Owner representatives from across 
Santos’ Australian footprint gathered  
to engage in open dialogue on how  
we can collaborate to shape a better 
future together.

Cultural heritage management

Across the business in 2024, 510 
cultural heritage assessments were 
completed, and 262 cultural heritage 
officers were engaged during cultural 
heritage management processes. 

Santos has made significant strides 
in cultural heritage management, 
securing 507 cultural heritage 
assessments supporting onshore 
development and operations across 
Queensland, South Australia, New 
South Wales and the Northern 
Territory. Key advancements include 
working together with Cooper 
Basin Traditional Owners in South 
Australia for protection of cultural 
heritage sites during safety-critical 
emergency works. Collaborative 
efforts have resulted in establishment 
of a working group with five 
Cooper Basin Traditional Owners 
groups, Boothamurra, Dieri, Kullili, 
Wongkumara and Yandruwandha 
Yawarrawarrka for the Cooper Basin 
Ranger Program, designed to allow 
Traditional Owners to connect with 
and care for their country. Progress 
in 2024 has paved the way for up to 
15 applicants to commence ranger 
training in Q1 2025. 

Notably, 2024 marked the rollout 
of strengthened cultural heritage 
training and awareness across 
the business through on-country 
and office sessions. Engagements 
with Traditional Owners included 
facilitation of 13 group visits to country 
including for Traditional Owner Elders 
and youths.

Indigenous Advisory Panel (Australia) - “Keep flying high”

Jonathan Knight's artwork, 'Barkindji 
Dreaming Still Flying', is the winner 
of the Santos Aboriginal and Torres 
Strait Islander Artwork Competition.

In an artist's statement, Knight 
revealed the inspiration for his 
artwork which includes a striking 
hawk eagle.

"This artwork represents Me, it is the 
story of my life," he said.

"Walking on country. Working in 
different communities. Living along 
the rivers that feed into all the 
different communities, that connect 
us all.

"The hawk eagle is my Barkindji totem.

"For me it represents my strength to 
keep flying high, keep on wanting to 
do better for myself and my people 
and our future."

See the full artwork pictured on 
the right.

The IAP plays a crucial role in 
building connections between 
Santos and the communities in which 
we operate, providing advice and 
insight about Aboriginal and Torres 
Strait Islander participation. Knight's 
winning artwork was unveiled at 
the Yarning Circle held late last year 
in Adelaide, which brings together 
Traditional Owners with members 
of the IAP to discuss community 
needs and initiatives. It's a chance 
for Traditional Owner representatives 
from across Australia to meet and 
'yarn' with Santos executive leaders 
and engagement teams, and a rich 
opportunity for Santos people to 
listen to the stories and experiences 
of Traditional Owner representatives.

54

Santos Annual Report 2024Sustainability pillar 
Economic sustainability

Economic impacts: 
contribution to society and supply chain management

Santos aims to make meaningful, positive, long-term contributions to 
the economy and the areas and the communities where we operate. 

$1.34b

Spend with local suppliers1 
representing 21 per cent of total  
procurement spend

Our approach
Our approach focusses on:

•  procurement practices and local 

content

•  paying our taxes and providing a 

return to the community

•  community investment Strategy 

and Framework

$711m

in global tax paid2

$299m

in employee tax paid3

•  creating jobs beyond Santos

Community investment

•  community partnerships and 

Santos Foundation: investing in 
capacity-building and needs-based 
priorities to have a positive impact 
on communities’ well-being and 
long-term development.

Santos' Community Investment 
Framework (see below) sets out 
our three focus areas of Resilient 
Communities, Economic Pathways, 
and Environment. This enables us 
to make meaningful, sustainable 
investments with our community 
partners.

Community investment framework 
Vision 2040

We aim to improve living standards, build respectful relationships, and create stronger communities in the areas 
where we operate.

Resilient communities

Economic pathways

Environment

Focus areas

Focus areas

Focus areas

Supporting access to social 
infrastructure, systems and 
services to help build healthy 
communities

Outcomes

• 

• 

• 

Improved health and 
wellbeing

Increased social inclusion/
diversity

Increased community 
connection and participation

•  Protecting cultural practices

Advancing skills, systems and 
infrastructure for communities 
to create economic opportunity

Outcomes

• 

Increase in skills and 
qualifications that lead to 
sustainable employment 
pathways

• 

Improved local infrastructure

Supporting environmental 
initiatives and programs 
that support and protect 
biodiversity

Outcomes

•  Protect and re-establish 

biodiversity 

•  Support environmental 
research and education 
programs, as well as land and 
water conservation

UNSDGs

UNSDGs

UNSDGs

This framework seeks to define community broadly, including all the many individuals, groups and organisations located in the areas where we operate.

1 

 Procurement Spend is Santos gross spend for operated assets. Local content is defined as goods and services procured within the region/country where Santos 
operations are based.

2  Global tax paid includes royalty-and government related taxation and corporate income tax.

3  Employee tax includes PAYG withholding tax, state payroll tax and fringe benefits tax.

55

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationEconomic impact
(continued)

Payments to governments – taxes 

Our approach to tax is guided by 
principles of transparency, compliance, 
and responsible tax practices. Santos 
pays taxes in four key jurisdictions: 
Australia, PNG, the USA and Timor-
Leste. Key elements include:

1.   Compliance: Santos is committed 
to complying with all applicable 
tax laws and regulations in the 
jurisdictions where we operate. This 
includes timely and accurate tax 
filings.

2.   Transparency: The Company 

is commited to be transparent 
about our tax practices, disclosing 
relevant information in its annual 
reports, sustainability disclosures 
and as part of Santos’ participation 
in the Board of Taxation’s Voluntary 
Tax Transparency Code. This 
includes providing insights into 
how Santos pays taxes and our 
contributions to local economies.

3.   Responsible tax practices: We focus 
on being a responsible taxpayer, 
which includes honouring our 
responsibility to our stakeholders to 
be a reputable corporate citizen in 
relation to our tax affairs.

4.   Engagement with stakeholders: 

We have an open and transparent 
relationship with all tax authorities, 
which includes participating in 
ongoing dialogue regarding current 
issues relevant to Santos and the oil 
and gas industry.

5.   Tax Policy: Board-approved Tax 
policy that is designed to meet 
expectations of the community  
and the tax authorities in the 
respective jurisdictions in which  
we operate to in relation to 
managing tax risk. 

These principles reflect Santos' 
commitment to ethical business 
practices and our recognition of 
the role taxes play in supporting 
community development and 
infrastructure. For further information 
see the taxation section in our 
financial report and our annual tax 
contribution disclosure reports.

56

Our opportunities 
and risks

Our opportunities include:

Opportunities for local and 
Indigenous suppliers to increase 
their capability to supply goods 
and services. 

Opportunities for improvement 
through our anti-corruption 
compliance program, including 
counterparty screening and due 
diligence.

Our risks include:

Barriers to participation with 
Indigenous, local suppliers and 
contractors. 

Potential ethical misconduct and 
human rights issues associated with 
modern slavery by our suppliers. 

Uneven distribution of benefits in 
the community.

Representation in workforce 
does not mirror local community 
composition.

Our process and  
due diligence

Santos prioritises the integrity of our 
supply chain by holding our suppliers 
and contractors to their contractual 
obligations.

Prior to collaboration, a risk-based 
approach is applied whereby suppliers 
are subject to a counterparty due 
diligence process that evaluates risk 
management practices, compliance 
with international sanctions and 
overall integrity.

Throughout the procurement phase, 
Santos requests suppliers comply 
with international standards related 
to the relevant scope of works 
including safety, environmental, ethical 
behaviour and modern slavery and 
human rights, as outlined in Santos’ 
policies. 

To uphold compliance and manage 
risks effectively, we conduct regular 
performance reviews of our suppliers 
and take corrective actions when 
necessary. This comprehensive 
approach helps safeguard the supply 

chain against potential disruptions and 
alignment with our commitment to 
responsible business practices.

Procurement practices and local 
content 

We have adopted a sustainable 
approach to procurement that aligns 
with our broader commitment to 
environmental, social, and governance 
(ESG) principles. We screen our 
suppliers based on ESG and economic 
sustainability aspects as part of 
our process. This also includes 
considerations relating to local 
sourcing, country and sector risks. 

Procurement processes

Key aspects of our approach include: 

1.   Supplier engagement: We actively 
engage with suppliers to require 
they meet sustainability criteria. 
This includes assessing their 
environmental practices, labour 
standards and commitment to 
ethical operations. 

2.   Local sourcing: The Company 

emphasises local procurement to 
support regional economies and 
reduce transportation emissions, 
thereby promoting community 
engagement and economic 
development. 

3.   Sustainable practices: Santos 
encourages suppliers to adopt 
sustainable practices, such 
as reducing greenhouse gas 
emissions, minimising waste, and 
promoting resource efficiency.

4.   Risk management: Supply 

chain risk assessments include 
sustainability risks, ensuring that 
potential environmental and 
social impacts are identified and 
managed. 

5.   Transparency and reporting: 

Santos is committed to 
transparency in our procurement 
processes, publishing an annual 
sustainability report and Modern 
Slavery Statement.

6.  Innovation and technology:  

 We seek to partner with suppliers 
who offer innovative solutions 
that enhance sustainability, such 
as technologies for lower carbon 
energy production or waste 
reduction. 

Santos Annual Report 2024 
By integrating these principles into 
our procurement processes, we aim to 
minimise our environmental footprint, 
while fostering responsible business 
practices throughout our supply chain. 

Approach to managing supply  
chain risks

Performance review

•  Evaluating performance in 

modern slavery, human rights, 
environmental metrics, and safety 
throughout the contract term.

• 

Implementing corrective actions if 
required standards are not met or 
commitments are breached.

•  Analysing financial and business 
aspects (for example financial 
statements, tax compliance, 
insurance).

•  Explicit acceptance of Santos’  
Code of Conduct for Suppliers.

•  Performing compliance risk 

assessments (for example anti-
corruption and sanction checks).

•  Checking criteria for compliance 

with current legislation are 
validated.

Our actions and 
performance

Community contributions

Due diligence and qualification

•  Registering suppliers and 

contractors.

•  Conducting reputational and 
counterparty due diligence  
analysis of suppliers.

Our community investment and 
partnerships are focused on 
capacity-building, as well as creating 
social value by supporting local 
organisations to deliver programs 
that address key priorities or needs. In 
2024, Santos invested $10.8m (gross 
operated) across our communities.

In 2024, the community team focused 
on increasing the level of governance 
across community investments and 
improving data accuracy and quality. 

Updates made include: 

•  Development of a Community and 
Indigenous Participation Technical 
Standard. 

• 

Improved due diligence and 
evaluation of community 
investment to align with Santos’ 
Community Investment Framework.

• 

Improved data quality through 
increased assurance.

Papua New Guinea 

Timor-Leste 

Alaska

Santos Community health program 
supported the rehabilitation of 
three government health facilities 
including staff housing for eight 
health workers who provide basic 
health services to more than 3,000 
community members in Kutubu and 
in Kikori. 

Partnership with St John of God 
Outreach Services (SJOG) continued 
to build capacity of nurses and health 
professionals with 666 participants 
across its programs including, new 
nurse and midwife training, educator 
development, basic life support 
refresher training, and leadership and 
management during 2024.

Arctic Education Foundation Culture 
Camp provides a local culture-
based program, including traditional 
Inupiat activities. In 2024, it was 
attended by 27 youth participants 
and 13 traditional knowledge experts, 
elders and guides.

57

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationEconomic impact
(continued)

Australia

Australia (National) 

Northern Territory 

Hunter region

In 2024, Santos continued to support 
the Clontarf Foundation and the 
Stars Foundation across Australia. 
Both foundations are focused on 
supporting Indigenous student 
engagement at school, year 12 
completion and transition to further 
study or employment. In 2024, Santos’ 
contribution supported the Clontarf 
Foundation and the Stars Foundation 
to achieve Year 12 completion rates 
of 94 per cent and 90 per cent, 
respectively.

With Santos’ support, Australian Earth 
Science Education engaged 2,070 
primary and secondary students in 
hands-on earth science-based STEM 
incursions across the NT, including 
18 rural and remote schools. The 
program also provided professional 
development opportunities for 
educators including 151 female 
educators and nine Aboriginal and 
Torres Strait Islander educators.

In 2024, Santos was a major supporter 
of Hunter Academy of Sport’s 
Muswellbrook Indigenous Talent 
Identification Day, followed by a six-
week strengthening and conditioning 
program supporting young Indigenous 
athletes from the Hunter region to 
develop their talents. The partnership 
also provided ten Regional Athlete 
Assistance Scholarships and 17 Athlete 
Excellence Scholarships for aspiring 
athletes.

Western Australia

Cooper Basin

Gladstone

Embarked on a three-year Land and 
Sea Management program around 
Gnoorea Point, including Recfishwest 
fishing clinics to build awareness 
of sustainable fishing. This also 
involved engagement with 18 Clontarf 
Foundation and 26 Stars Foundation 
students, helping improve wellness 
and education outcomes.

As a result of Santos' support of the 
Outback Gondwana Foundation 
and Eromanga Dinosaur Dig, the 
Eromanga Natural History Museum 
began excavation on a newly 
discovered dinosaur site, as well as 
well as increasing fossil collection  
by about 15 per cent.

The Resilience Project School 
Wellbeing Program supports positive 
mental health in the classroom and 
beyond. In 2024, with Santos’ support, 
30 programs were completed with 
390 students from Gladstone Central 
State School participating.

Port Bonython 

Roma 

In 2024, Santos supported Sammy D 
educators to travel 425 kilometres 
across Whyalla to deliver Violence 
Prevention and PartyWise (drug 
and alcohol) education sessions to 
1,163 secondary students from eight 
schools.

Santos supported the Australian 
Driver’s Institute to deliver Youth 
Driving Program to 26 young people. 
The objective of the program is to 
increase awareness of safe driving 
practices and to address risks for road 
users in Roma.

South Australia

Narrabri

The Santos Aboriginal Power Cup 
in its 17th year continued to leverage 
the power of sport to encourage 
educational participation and promote 
career pathways for Aboriginal and 
Torres Strait Islander secondary 
students. In 2024, the program 
engaged 565 secondary school 
students from 58 schools.

2024 marked ten years of Santos’ 
support for the Westpac Rescue 
Helicopter, service providing 
aeromedical emergency transport 
across Northern NSW, including 
537 lifesaving missions flown from 
the New England North-West base, 
including 30 missions in the Narrabri 
Shire.

58

Santos Annual Report 2024Spend with local suppliers

Spend with Indigenous suppliers

n
o

i
l
l
i

m
$
S
U

1,600

1,400

1,200

1,000

800

600

400

200

0

2020

2021

2022

2023

2024

25%

20%

15%

10%

5%

0

l

a
c
o

l

h
t
i

w
d
n
e
p
s

t
n
e
m
e
r
u
c
o
r
p

l

a
b
o
G

l

)
e
g
a
t
n
e
c
r
e
P
(

s
r
e

i
l

p
p
u
s

n
o

i
l
l
i

m
$
S
U

600

500

400

300

200

100

0

2020

2021

2022

2023

2024

10%

8%

6%

4%

2%

0

h
t
i

w
d
n
e
p
s

t
n
e
m
e
r
u
c
o
r
p

l

a
b
o
G

l

)
e
g
a
t
n
e
c
r
e
P
(

s
r
e

i
l

p
p
u
s

s
u
o
n
e
g
d
n

i

I

Spend with local suppliers 
Percentage of global procurement spend with local suppliers 

Percentage of global procurement spend with Indigenous suppliers 

Spend with Indigenous suppliers 

Santos spent $1,336m globally in 2024 across local 
suppliers which represents 21 per cent of total global spend. 

Santos spent $518m globally in 2024 with Indigenous 
suppliers across Australia, Alaska, and PNG landowner 
companies, which in total represents 8.1 per cent of total 
global spend. 

Global tax contributions (excluding employee tax)
Global tax contributions

Global employee tax paid
Global employee tax paid

n
o

i
l
l
i

m
$
S
U

1,200

1,000

800

600

400

200

0

2020

2021

2022

2023

2024

Government royalties, levies and excise 

Royalty-related contributions

Corporate income tax 

n
o

i
l
l
i

m
$
S
U

300

250

200

150

100

50

0

2020

2021

2022

2023

2024

Since 2020 Santos has paid over $3.2b in global tax 
contributions (excluding employee tax).

Since 2020 Santos has paid over $1b in employee taxes.

59

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Sustainability  
advocacy

All Santos advocacy activities, including both direct and indirect 
engagement and responses to government consultations, are guided 
by our policy positions, including those relating to human rights,  
anti-bribery and corruption, climate, environment, health and safety, 
local and Indigenous communities and diversity and inclusion.

Our approach 

Political engagement

We are a member of a large 
number of organisations, ranging 
from community bodies, chambers 
and business councils relevant to 
the communities and regions we 
operate in, as well as industry-related 
representative bodies known as 
‘industry associations’.

Santos is a member of these 
organisations so that we can:

•  gain an understanding of 
communities, regions and 
economies where we operate

•  understand how we can contribute 

positively and effectively with 
stakeholders

•  enhance technical knowledge, 
share learnings and develop 
standards within industry

•  engage in policy development.

Our memberships allow us a forum 
to listen, debate, seek alignment 
and promote the key interests 
of communities and industry 
organisations. 

In addition to our policy positions, 
this advocacy is also guided by our 
support for the Paris Agreement 
where it acknowledges the need to 
balance emissions reduction with “the 
imperatives of a just transition of the 
workforce and the creation of decent 
work and quality jobs in accordance 
with nationally defined development 
priorities.1”

1 

 United Nations Framework Convention on 
Climate Change. Paris Agreement: unfccc.int/
process-and-meetings/ the-parisagreement/.

Santos engages with all levels of 
government in relation to our projects, 
operations, maintaining energy supply 
and reducing our carbon footprint. In 
Australia, this includes engagement 
in business forums and events where 
Santos pays for membership and/or 
attendance.

Santos believes it is important for us 
to engage in the discussion about the 
world's energy future and the role 
we can play through our natural gas 
portfolio and our emerging low carbon 
fuels business.

We manage fundraising requests 
from Australian political parties under 
rules set out in an operating standard 
and we:

•  do not make cash donations to 
political parties or candidates

•  declare payments made for 

attending political events and 
memberships of political party 
business forums in accordance with 
applicable legislation.

In Alaska, we do not engage in 
fundraising for political parties 
through the corporate treasury. Being 
involved in political party business 
programs in a bipartisan manner is an 
appropriate and important way for 
the business community and Santos 
to contribute transparently to the 
political process, and to help ensure 
the stability of democratic systems. 
This helps foster stable policy, 
regulation and taxation for business, 
which in turn generates investment, 
jobs and greater prosperity for 
the communities we operate in. 
These programs have transparent 
membership fees and services.

For more information on Santos’ 
membership associations visit: 
santos.com

60

Santos is a member of the following 
Australian national political party 
business forums:

•  Federal Labor Business Forum 

(Federal ALP)

•  Australian Business Network 

(Federal Liberal Party)

•  National Policy Forum (Federal 

National Party).

From time-to-time, specific events 
such as Budget or Budget-reply 
events or policy launch events are 
also held. Individual members of 
parliament or candidates also host 
business events featuring guest 
speakers who are generally ministers 
or shadow ministers. Participation in 
these events often requires payment 
of an attendance fee not covered 
by the fees paid for membership of 
the business forums. Attendance 
and representation of Santos at a 
political event is regulated by the 
SMS and CEO approval is required in 
accordance with the Delegation of 
Authority.

Given there is no public funding of 
Commonwealth election campaigns, 
there is an expectation by the major 
political parties that the corporate 
sector will engage through the 
above transparent mechanism. The 
involvement of a wide range of 
companies in this process helps to 
ensure that funding of the democratic 
process is received from multiple 
sources and wide-ranging policy 
positions and interest, so that no 
single interest unduly influences the 
political process.

Santos is not a member of state-based 
political party business forums and 
considers individual event requests on 
a case-by-case basis where there is a 
clear business reason. Federal, State 
and Territory Electoral Commissions in 
Australia publish reported payments 
through transparency registers and 
electronic disclosure systems.

Santos Annual Report 2024Climate advocacy 

Santos recognises the scientific 
consensus of climate change assessed 
by the IPCC. We support the objective 
of the Paris Agreement to limit 
global temperature rise to less than 2 
degrees Celsius and pursue efforts to 
limit the temperature increase to 1.5 
degrees Celsius.

Through direct engagement 
with policy makers and indirect 
engagement through our industry 
association memberships, Santos 
advocates for environmentally, 
socially and economically effective 
and responsible energy and carbon 
policies that are aligned with our 
Climate Policy.

Santos actively works with, and 
provides input to, governments and 
stakeholders in the design of climate 
regulation. We do this in pursuit of 
decarbonisation goals, striving for 
a policy and regulatory framework 
that supports lowest-cost abatement 
and innovation and investment in 
low emissions technologies, while 
continuing to provide access to reliable 
and affordable energy in Australia 
and Asia.

In 2024, this included direct 
engagement with, and/or submissions 
made, to government agencies on the 
following topics:

•  development of the Australian 
Sustainable Finance Taxonomy

•  Alaska’s proposed emissions 

reduction Projects on State Land 
Regulations 

•  Future Made in Australia 

(Guarantee of Origin) Bill 2024.

These submissions were assessed 
against our Climate Policy for 
consistency with the Company’s 
public positions. 

Santos similarly assesses the climate 
policy positions of the industry 
associations of which we are a 
member. Where an association is 
neutral or unaligned to Santos’ climate 
policies, the Company will make its 
views known to the association by 
working proactively to influence 
alignment. This includes promoting 
the goals of the Paris Agreement, 
recognition of the scientific consensus 
of climate change and support for net-
zero emissions by 2050 or earlier.

In 2024, out of the 11 associations 
assessed, we found that eight 
were aligned with Santos’ climate 
policy positions and three were 
neutral. Organisations assessed as 
aligned include the PNG Chamber 
of Resources and Energy which was 
previously determined as neutral prior 
to Santos’ engagement across 2024 
in assisting develop its approach to 
climate change. 

Building on this, we will continue 
working with the Alaska Oil and 
Gas Association, and Resource 
Development Council of Alaska to 
align their climate policies to our 
own. The remaining neutral body, 
the Australian Resources and Energy 
Employer Association, is appropriate 
to be classified accordingly given the 
focus of its activities and advocacy is 
not climate or environmental matters.

Further information on Santos’ 2024 
review of industry associations can be 
found on our website at: santos.com

61

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSustainability advocacy
(continued)

Human rights

Our commitment to sustainability and corporate responsibility includes integrating human rights considerations across 
our operations. We recognise potential human rights risks associated with our environmental footprint, interactions with 
Indigenous communities, labour practices and broader social issues throughout our activities.

Human rights commitment 
and policy

Our company has implemented 
a Human Rights and Modern 
Slavery Policy. Santos is 
committed to support and 
respecting the protection of 
international recognised human 
rights as set out in the United 
Nations International Bill of 
Human Rights and works to align 
to the UN Guiding Principles 
on Business and Human Rights 
and the Voluntary Principles for 
Security and Human Rights in 
our practices and procedures. 

Respect for Indigenous rights

Supply chain management

We are committed to fostering 
a supply chain that respects 
human rights. Key due diligence 
measures encompass supplier 
assessments, deep-dives 
and advanced counterparty 
screening through Compliance 
Catalyst. These efforts are 
overseen by our internal 
Modern Slavery Working Group, 
which monitors processes, 
identifies additional risks and 
opportunities. 

We operate in regions that 
overlap with traditional lands 
of Indigenous communities, 
particularly in Australia, Alaska 
and Papua New Guinea. The 
Company has a specific focus 
on respecting the rights of these 
communities by:

•  consulting with Indigenous 

peoples on land use

•  acknowledging their 

connection to the land

• 

identifying suitable 
commercial opportunities 
to partner with Indigenous 
businesses and employment 
and upskilling of local 
Indigenous people.  

We collaborate with local 
Indigenous groups so that 
our projects benefit these 
communities economically 
and socially, while also 
respecting cultural heritage and 
environmental stewardship.

Pictured: Pikka phase 1

62

Santos Annual Report 2024We integrate human rights advocacy into our business 
practices by focusing on Indigenous rights and community 
engagement, fair labour practices, responsible supply 
chain management and external security arrangements. 
Our approach reflects a broad commitment to ethical 
corporate behaviour and sustainable development.

Transparency and 
accountability

We engage in transparent 
reporting on human rights 
impacts through our 
Sustainability Reports and 
Modern Slavery Statements. 
The Company tracks our 
progress and performance on 
human rights issues and shares 
this information publicly. This 
includes efforts to address risks 
of modern slavery within our 
operations and supply chains.

Grievance mechanisms

Santos maintains internal 
processes and an external 
grievance mechanism for 
individuals who work for or with 
us, including the community at 
large, to facilitate reporting of 
potential breaches of our Code 
of Conduct, including in relation 
to human rights concerns. 
Reporting can be made 
anonymously.

Workplace rights and safety

Santos prioritises the rights of its 
workers by: 

•  fostering diversity and 

inclusion

•  upholding fair labour 

practices, including no 
tolerance for discrimination, 
harassment and exploitation 

•  focusing on potential human 
rights impacts from security 
arrangements – both public 
and privately provided.

Our operations are aligned 
with Occupational Health and 
Safety (OHS) standards and 
labour laws across the regions 
in which we operate, reinforcing 
our commitment to a safe and 
equitable workplace as part of 
our human rights advocacy. 

Pictured: Narrabri Creek, Narrabri NSW

63

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Foundation

Mission

The Santos Foundation’s mission is to invest in partnerships and local 
initiatives that help communities thrive. We do this by focusing on activities 
that support our twin objectives to advance economic pathways and build 
resilient communities in the regions where Santos operates. 

We work with communities, local partners and donors to address societal 
trends and local needs in the four key program areas of Health, Youth 
Opportunities, Community development and Family and sexual violence. 

Our approach respects the political, cultural, social and legislative systems 
and frameworks of the countries we operate in. We work to engage local 
leaders, align to national development priorities and foster opportunities for 
local businesses.

Guiding principles

Community engagement

At the Santos Foundation, we 
are guided by four fundamental 
principles. These principles 
underpin our approach and 
serve as the cornerstone of our 
work, shaping our strategies and 
actions as we strive to make a 
positive and lasting impact.

We work closely with local communities to build 
programs that respond to their needs. Where applicable, 
these programs are aligned to each country’s national 
development frameworks and priorities.

Partnership-driven

We recognise the power of partnerships in driving sustainable change. 
We actively seek collaborations with both local and global not-for-
profit organisations, corporates, governments and aid development 
agencies to address both broader societal trends and local needs.

Local and global impact

We want to leave a lasting positive legacy in the 
communities we serve. We also aim to contribute 
to national and global development challenges 
and make a difference on a broader scale.

Realistic ambition

We work with communities to strengthen and build on 
existing systems. Our approach takes into account the 
unique challenges each community faces, ensuring that 
goals are achievable and sustainable over the long term.

64

Santos Annual Report 2024Program areas

The Santos Foundation seeks to support meaningful impact in communities 
where Santos operates in four key program areas.

Health

•  health system and governance strengthening

•  health service delivery support

•  facility improvements (infrastructure)

•  technical capacity building

•  pandemic and natural disaster response.

Youth opportunities

•  education 

•  pathways to employment

• 

leadership

•  sustainable agri-business

•  community engagement.

Community development

•  early childhood literacy libraries

•  community small grants

•  rural electrification projects

•  water, sanitation and hygiene initiatives

•  empowerment and leadership roles for women.

Family and sexual violence (FSV)

•  family Support Centre strengthening 

•  case management and safe house services 

through Bel isi Papua New Guinea

•  domestic violence awareness and education services.

65

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos Foundation 
(continued)

2024 Program activity

Building on the passion, knowledge and experience of our team in PNG, the Santos Foundation announced its first program 
activity in Australia and commenced a stakeholder engagement program in Timor-Leste in 2024. In 2025 we will continue 
to build out our activity where Santos operates in Australia and Timor-Leste and seek to expand our operations into Alaska.

The Santos Foundation is proud to work closely with our partners and would like to thank the PNG national, provincial and 
local-level governments, the Australian Department of Foreign Affairs and Trade (DFAT), the US Agency for International 
Development (USAID), Gavi, PNG LNG joint venture partners, third-party donors including SLB and all private sector and 
non-government organisations that support the communities in the regions where we operate. 

Papua New Guinea

In PNG, the Santos Foundation supports program activities in the Gulf Province,  
Southern Highlands Province, Hela Province and Port Moresby.

Health

Youth opportunities

Community development

Santos Foundation support to 
the provincial health authorities 
contributed to:

Santos Foundation support in the 
Nipa-Kutubu district, Southern 
Highlands Province, contributed to: 

Santos Foundation support 
contributed to the following 
community development highlights: 

•  2,680 cervical cancer screenings 
at the Mendi Provincial Hospital, 
Southern Highlands in partnership 
with the UNSW Kirby Institute 

•  13,019 children receiving the 

pentavalent third-dose vaccine 
to protect against five life-
threatening diseases: Diptheria, 
Pertussis, Tetanus, Hepatitis B 
and Haemophilus influenzae type 
b (Hib) in the Gulf and Southern 
Highlands Provinces

•  six patrols to hard-to-reach 

remote communities resulting in 
1,087 children being immunised 
under the Accelerated 
Immunisation and Health Systems 
Strengthening (AIHSS) program 
in partnership with the Australian 
and New Zealand Governments 
and Gavi.

•  265 students being enrolled at 

the Pimaga Vocational Education 
and Training (VET) Centre 
in electrical, carpentry and 
mechanical courses, including 
31 females, an increase of 29 per 
cent and 24 per cent respectively 
on 2023

•  Flexible Open Distance Education 
course launched supporting 55 
students (16 female and 39 male) 
to complete either their Grade 10 
or Grade 11 certificates

• 

installation of a solar mini 
grid, battery and three-phase 
generator in partnership with SLB 
and USAID-PNG Electrification 
Partnership (PEP) to support 
a new multi-trade workshop, 
classrooms, dormitories, mess-hall 
and six new teacher houses at the 
Pimaga VET

•  support for 39 members of 

the Kutubu Local Level Youth 
Development Council (29 male 
and 10 female) to undertake 
Governance and Leadership 
training.

•  56 small grants worth more than 
PGK305,000 being awarded 
to Santos employees and 
contractors to support their local 
communities across a variety 
of initiatives including water, 
sanitation, hygiene, education, 
health and nutrition and women’s 
empowerment projects 

•  a baseline study being completed 
to assess water, sanitation and 
health (WaSH) conditions across 
the Nipa-Kutubu District in the 
Southern Highlands province

•  a amnesty campaign targeting 
electricity theft from the power 
grid resulting in more than 
30,600 new user registrations 
with PNG Power Limited and an 
additional PGK361,500 in revenue 
to be reinvested into improving 
electricity generation supply and 
reliability

•  178 students enrolled in early 

childhood education programs, 
with 47 girls and 63 boys being 
assessed as school-ready.

Official launch of the solar mini grid, battery and  
three-phase generator at the Pimaga VET Centre.

66

Santos Annual Report 20242025 cohort of Aboriginal  
Health Practitioner students 
supported by the Santos 
Foundation and Danila Dilba, 
Darwin's Aboriginal Community 
Controlled Health Organisation

Family and sexual violence

Santos Foundation support 
contributed to:

•  432 new clients being provided 
case management and/or safe 
house services through Bel isi 
PNG in Port Moresby. Bel isi PNG 
is a public-private partnership 
that creates safe space access 
support to individuals and 
families experiencing violence

•  the Bel isi PNG program was 

recognised for its life-changing 
impact through changing 
attitudes towards family and 
sexual violence and supporting 
survivors at the highly-respected 
Platts Global Energy Awards 
in New York by taking home 
the Corporate Impact Award – 
Targeted Program

•  the delivery of 19 education 
sessions to 479 employees 
(301 female and 178 male) across 
ten companies that subscribe 
to and support Bel isi PNG. 
One education session was also 
delivered to 29 employees  
(24 female and five male) from  
a non-subscribing company

•  the Tari Family Support Centre 

in the Hela Province conducting 
seven training sessions on 
psychosocial support and 
mindset behaviour with 229 
course participants comprising 
184 males and 45 females from 
ten locations.

Australia

Timor-Leste

In Timor-Leste, we commenced 
initial stakeholder engagement 
in the second-half of 2024 
to better understand the 
needs and challenges of local 
communities as well as the role 
of government, development 
and other non-government 
organisations active in the 
country. Engagement remains 
ongoing as we seek to develop a 
program strategy that will have 
a positive and lasting impact. 

Following support from the 
Santos Board in 2023 to expand 
the Santos Foundation across all 
regions where Santos operates, 
we announced our first activities 
outside of PNG with the launch of 
the Youth Opportunities program 
in Darwin to support education 
and employment pathways for 
young Northern Territorians.

Our initial activity in the Top End 
will support: 

•  the accreditation of eight 
Aboriginal Health Care 
Practitioners between 2025-
2026 in partnership with 
the Aboriginal Community 
Controlled Health Service, 
Danila Dilba

•  25 high school students to 
commence apprenticeships 
while also remaining in 
school to complete their 
Northern Territory Certificate 
of Education and Training 
(NTCET) in partnership with 
the employment and training 
solutions provider, the GTNT 
Group.

In the second-half of the year, 
we appointed our first Australian 
Program Coordinator to support 
current activity, identify and 
deliver new programs and build 
strong community connections. 

67

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationCLIMATE  
REPORT

Governance

Strategy

Our targets

Building a commercial carbon storage business

Our approach to the Paris Agreement

Our emissions performance

Scope 1 and 2 emissions reduction plan

Scope 3 emissions reduction plan

Our approach to methane emissions

Capital allocation and governance

Just transition

Climate Transition Action Plan

Delivering on our Climate Transition Action Plan

Targets and metrics

Climate risk management

Portfolio resilience and scenario analysis

Investor feedback and our response

Appendices

68

Santos Annual Report 2024

69

70

71

71

72

73

74

75

76

78

79

80

82

89

91

98

109

111

Our approach to climate

Governance

The Board has ultimate responsibility for overseeing the 
Company’s strategic direction and management. Full details of 
Santos’ corporate governance statement are disclosed on page 121. 
This section provides additional information related to the 
governance and oversight of climate, and how the governance 
framework supports our Climate Policy.

Management 

The CEO and Executive Leadership 
Team are responsible for delivering 
the strategy and goals approved by 
the Board. They are supported by 
their teams who monitor and assess 
trends and changes in Australian and 
international energy markets, and 
assess and model a range of energy 
mix scenarios based on varying market 
demand and policy and technology 
drivers. This analysis informs portfolio 
and asset reviews of our business 
and strategy. These teams are 
responsible for the implementation of 
appropriate controls and processes 
for climate-related risks to be 
overseen and effectively managed. 
To enable effective cross-functional 
communication on issues related to 
climate change and sustainability, 
Santos’ governance processes include 
meetings across a range of business 
groups and Executive Leadership 
Team meetings to enable conformance 
with the SMS and track delivery 
against plans and targets.

The Board’s oversight of climate 
is supported by the following 
committees that meet quarterly:

•  The Safety and Sustainability 

Committee supports the Board 
in overseeing Santos’ Climate 
Policy, including monitoring and 
reviewing climate-related targets 
set by the Board, and monitoring 
and reviewing performance and 
material risks and opportunities, 
including climate.

•  The Audit and Risk Committee 
is responsible for assessing 
the effectiveness of the Risk 
Management Framework and 
that management is operating 
with due regard to Santos’ Risk 
Appetite Statement. This includes 
responsibility for assessing 
the effectiveness of the Risk 
Management Framework in 
identifying, monitoring and 
managing material climate-
related risks. Santos' Risk 
Appetite Statement supports 
the consideration of climate and 
requires that carbon emissions 
are considered in decision-making 
processes. The Risk Appetite 
Statement is reviewed at least 
annually for ongoing alignment 
with strategic objectives. This 
enables risks and associated 
controls and risk management 
actions to be considered in our 
decision-making and enables 
a portfolio-wide focus on the 
delivery of the Company emissions 
reduction targets. 

•  The People, Remuneration 
and Culture Committee is 
responsible for the oversight 
of the remuneration policy and 
formulation of remuneration 
recommendations to the Board 
for the Senior Executives and the 
Company more broadly. Since 
2019 the Short-Term Incentive has 
included performance metrics that 
reward Key Management Personnel 
(KMP) for achieving sustainability 
and climate outcomes. In 2024 the 
Company Scorecard weighting for 
climate-related targets increased 
to 17.5 per cent (from 15 per cent in 
2023) and included metrics relating 
to emissions intensity reduction, 
decarbonisation projects and the 
delivery of Moomba CCS. This 
further strengthens the link between 
climate considerations and the 
outcomes of performance pay.

•  The Nomination Committee 

assists the Board with succession 
planning. It proposes candidates 
for consideration by the Board to 
fill casual vacancies or additions to 
the Board, and devises criteria for 
Board membership, which includes 
experience with climate and energy 
transition.

Committee cross-memberships 
support consideration of climate 
issues with all four committees 
having specific climate-related 
responsibilities.

69

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur approach to climate

Strategy

Our approach to climate is integral to our company strategy and 
delivering long-term value to shareholders. This strategy is focused on 
backfilling and sustaining existing infrastructure, decarbonising Santos 
and third-party operations and investing in the technologies needed to 
develop the low carbon fuels of the future as markets evolve. 

as a supplier of lower carbon energy 
and ultimately, carbon reduction 
solutions. This will enable us to build 
a valuable business using our unique 
capabilities and assets.

operations and, in relation to nature-
based project, provide additional 
benefits, including to local Indigenous 
people and the communities in which 
we operate.

Our strategy and business model 
has the capacity to adjust to the 
uncertainties arising from climate- 
related risks and benefit from climate- 
related opportunities. Key to our 
resilience is our unique combination 
of low-cost, long-life natural gas and 
liquids assets, CCS capability, potential 
low carbon fuels and nature-based 
solutions project optionality. Further 
details relating to the resilience of 
our portfolio can be found in the Risk 
management section.

We are seeking to meet our emissions 
reduction targets in line with our 
emissions hierarchy of avoid, reduce 
and offset. We prioritise avoidance 
and reduction of greenhouse gas 
emissions as a key lever towards 
decarbonising our business.

However, we recognise that 
emissions reduction units are likely 
to be required to offset hard-to-
abate emissions from both our own 
operations and the wider economy. 
Where emissions reduction units are 
required to comply with regulatory 
requirements, or to meet voluntary 
targets, we intend to prioritise 
generating our own units. These may 
be nature-based solutions or potential 
technology-based solutions, such as 
direct air capture (DAC).

Utilising emissions reduction units 
purchased on-market is the least 
preferred option as per the emissions 
hierarchy. Purchased units are either 
Australian Carbon Credit Units 
(ACCUs) or are registered under 
another internationally recognised 
standard. We prioritise development 
of emissions reduction projects 
which are co-located with existing 

Santos continues to invest in our core 
assets to deliver the critical fuels the 
world needs to meet global energy 
demand into the 2040s.1 Our products 
are essential to support energy 
security and economic development.

At the same time, we are working 
hard to reduce Scope 1 and 2 
emissions associated with these 
critical fuels, in line with our target 
of net-zero equity Scope 1 emissions 
by 2040 and net-zero equity Scope 
2 emissions by 2050. Due to slower 
than expected progress towards grid 
decarbonisation, we have extended 
the timeframe applicable to our Scope 
2 target, for further details on this 
change refer to page 27. Through 
selective investment in emerging 
technology, we are addressing the 
final horizon of our strategy, which is 
preparing the company to supply low 
carbon fuels as market and customer 
demand evolves. Our Climate 
Transition Action Plan (CTAP) sets out 
our response to the climate-related 
risks and opportunities in our business.

Our intent is to strike the optimal 
balance between disciplined and 
phased spending on development 
projects to meet global energy 
demand, while also investing in 
innovative energy solutions that 
supports the energy transition and 
meet the demands of customers. 
Looking to the future, we see our role 

For further information refer to 
Company Strategy on page 16

1 

IEA World Energy Outlook 2024

70

Santos Annual Report 2024Our approach to climate

Our targets

2025

2030

2040

COMPLETED

ON TRACK – 84% ACHIEVED

Reduced emissions across the 
Cooper Basin and Queensland  
by more than 

5 per cent

30 per cent

Reduction in Scope 1 and 2 
emissions (equity share)1

Net-zero

Scope 1 emissions (equity share) 

COMPLETED

ON TRACK – 23% ACHIEVED

Increased LNG exports to at least 

4.5 Mtpa

40 per cent

Reduction in Scope 1 and 2 
emissions intensity (equity share)2

2050

COMPLETED

Assessed the feasibility and invested 
in technology and innovation which 
have the potential to deliver 
a step-change in 
emissions by 2025

Santos has achieved its three short-term 
(2025) climate-related targets.

Aiming for near-zero 
methane emissions3 

Zero routine flaring4 

REVISED

Net-zero

Scope 2 emissions (equity share)5 

Building a commercial  
carbon storage business 

2040

approx.14 Mt

of third-party CO2e per 
annum. Equivalent to 
around 50% of Santos' 2023 
equity Scope 3 emissions 
from the combustion 
and use of our products 
(categories 10 & 11 ).6, 7

2030

1.5 Mt

of third-party CO2e per annum from 
the supply of low carbon fuels and 
carbon management services. 

The new targets were supported by investor engagement.

Santos aims to build and operate a commercial carbon storage business, safely 
and permanently storing approximately 14 Mt (gross) of third-party CO2e per 
annum by 2040. Santos is progressing its three CCS and decarbonisation hubs 
where this third-party CO2e could potentially be stored. Further information on 
these hubs can be found in our 'Climate Transition Action Plan' on page 80.

While Santos can only influence these emissions, we acknowledge we can have a 
role and are working with our customers and others to reduce them.

Consistent with our strategy to decarbonise our business and seek to develop 
low carbon fuels as markets evolve.

We aspire longer-term to store more carbon than we emit  
(Scope 1, 2, and 3 equivalent emissions).

1 

2 

 30 per cent absolute reduction is from the Santos and Oil Search combined 2019-20 equity Scope 1 and 2 emissions baseline of 5.9 MtCO2e, representing a 
reduction to 4.1 MtCO2e or lower by 2030.
 40 per cent intensity reduction is equity share of Santos Scope 1 and 2 emissions intensity from a 2019-20 baseline of 55 ktCO2e/mmboe, representing a 
reduction to 33 ktCO2e/mmboe or lower by 2030.

3  Methane emissions intensity of <0.20 per cent from operations, calculated as a percentage of marketed natural gas.
4  Zero routine flaring from Santos' operated oil assets where economically viable.
5  For full update on the change to the Scope 2 emissions reduction target, refer to page 27 of the Sustainability Report.
6 

 This is a target not a forecast and is a growth target for gross storage from Santos operated carbon storage projects. The target is ambitious and subject to 
substantial engineering, finance, commercial and policy work to establish enabling frameworks with customers, governments, regulators and other stakeholders. 
The potential projects that would enable achieving the target remain at an early phase of planning and commercial and economic viability is still to be confirmed.

7  Actual volumes depend on availability of CO2e for storage. Refer to 'important notices' at the front of this report for further information about this target.

71

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur approach to climate

Our approach to the  
Paris Agreement

The limiting of global warming to 1.5 degrees Celsius is modelled to result in less likelihood of extreme weather events, lower 
risk of irreversible damage to our ecosystems and shielding those who are most vulnerable to the impacts of climate change.1

Santos is setting its targets and undertaking actions to contribute to UN Paris Agreement Goals as set out below.

The UN Paris Agreement Goals How is Santos contributing?

Limit global warming

•  Ambitious short-, medium- and long-term emissions reduction targets to support the 
goals of the UN Paris Agreement as set out below. (See our Our targets page 71).

Achieve net-zero emissions

•  Decarbonisation of our business via our CTAP. (Refer to Climate Transition Action Plan 

on page 80).

Strengthen climate resilience

•  Physical climate-related risk assessment. (Refer to Climate Risk Management on page 91).

•  Community benefit through initiatives such as vegetation management, weather 

monitoring and water production from wells.

Provide climate finance

•  Committed to supporting a just transition for our assets, people and communities through 

an approach which is aligned to Ipieca principles.

Enhance national 
commitments

•  Meeting national commitments requires a collective approach and the collective efforts 

of the business community.

Foster global collaboration

•  Continuing compliance with regulatory frameworks, such as Australia’s Safeguard 
Mechanism, should enable greenhouse gas emissions to be in line with Australia’s 
Nationally Determined Contribution (NDC).

•  Continue to operate within legislative requirements that provide a framework for a 

country to meet its NDC in all jurisdictions where we operate, therefore contributing to 
the global trajectory to limit global warming in support of the Paris Agreement targets.

•  Commitment to support our global partners in their decarbonisation goals through the 
development of a three-CCS hub strategy within Australia and Timor-Leste. (Refer to 
Delivering on our Climate Transition Action Plan on pages 82 to 88).

•  Offering carbon management services and potential low carbon fuels, as demand 

evolves, to our customers and emitters in hard-to-abate industries. (Refer to Delivering 
on our Climate Transition Action Plan on pages 82 to 88).

Santos Scope 1 and 2 emissions reduction targets compared to third-party 1.5 degrees Celsius emissions trajectory scenarios

100
90
80
70
60
50
40
30
20
10
0

e
g
a
t
n
e
c
r
e
p
a
s
a
s
n
o
i
s
s
i
m
E

r
a
e
y
e
n

i
l

e
s
a
b
f
o

IEA Net Zero Emissions 
(NZE)

S&P accelerated CCS 
scenarios (ACCS)

S&P multi-tech mitigation 
(MTM)

NGFS Net Zero 2050

Shell Sky

Santos Scope 1 and 2 
emissions (actuals)

Santos Scope 1 and 2 
emissions reduction 
targets

Santos’ Scope 1 and 
2 emissions targets 
compared with 
third-party scenarios 
limiting global 
warming to 1.5°C.

2025

2030

2035

2040

2045

2050

Santos has undertaken analysis of how our Scope 1 and 2 emissions targets generally compare against emissions trajectory 
scenarios that third-parties have modeled which limit global warming to 1.5 degrees Celsius, a goal of the Paris Agreement. 
Comparing our historic and targeted emissions2 with such scenarios provides us with further general understanding of 
progress toward our climate goals. The analysis used a range of 1.5 degrees Celsius emissions scenarios developed by leading 
energy and climate institutions, including the IEA, S&P, Network for Greening the Financial System (NGFS) and Shell3, and 
sought to focus on emissions trajectories relevant to Santos' operations. Our historic and targeted emissions were analysed 
using 2023 as the baseline year and were compared against these modeled scenarios4.

1 

2 

3 

4 

IPCC Special Report: Global Warming of 1.5 degrees Celsius.

 Emissions reductions targets as per Targets and Metrics section of the report (page 89). The 2040 emissions reduction forecast represents the target of net-zero equity Scope 1 emissions plus a 
forecast of equity Scope 2 emissions through to the target of net-zero in 2050 based on portfolio forecast data accounting for electricity usage and forecast changes in grid intensity.

 Analysis also considered scenarios published by BP and IPCC but were not included due to discrepancies in baseline year, superseded datasets no longer reflective of current conditions, and/or 
availability of data not aligning with Santos’ operational context.

 The third-party emissions trajectories analysed are inclusive of all global emissions, including those which would be considered Santos Scope 3. Santos does not have control over our Scope 3 
emissions as they are the Scope 1 and 2 emissions of other entities, and as such we have not included our Scope 3 emissions in this analysis. In 2024, Scope 3 emissions comprised approximately 
88 per cent of our total Scope 1, 2 and 3 emissions. There remains uncertainty around 1.5 degrees Celsius pathway scenarios as the science of climate change continues to evolve. Santos has 
utilised the most up-to-date third-party pathways available as at the date of the report to conduct our analysis, however we acknowledge that 1.5 degrees Celsius pathway scenarios are subject 
to many assumptions and uncertainties and emissions trajectories analysed were generally aligned as closely as possible to Santos' operational context, including data interpolations as required 
where emissions trajectories did not align to the baseline year of 2023. However, limitations on external provider data availability and granularity may result in only partial comparability with 
Santos' emissions reduction targets.

72

Santos Annual Report 2024 
 
 
 
 
 
Our approach to climate

Our emissions  
performance

Since our baseline year of 2019-20, our total Scope 1 and 2 equity 
emissions have reduced by 26 per cent, which represents 84 per cent 
progress to our 2030 emissions reduction target.

Since 2016, Santos’ absolute emissions have fluctuated as our production and asset mix has changed. However, both total 
emissions and emissions intensity have reduced since our baseline year of 2019-20 as lower carbon intensive assets have 
been incorporated into the portfolio and in 2024 Moomba CCS came online. 

Scope 1 and 2 net equity emissions

2024 Scope 1 and 2 net equity emissions

5.9

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

6

5

4

3

2

1

0

70

60

50

40

30

20

10

0

y
t
i
s
n
e
t
n

I

s
n
o
i
s
s
i
m
E

e
o
b
m
m
/
e
2
O
C
t
k

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

0.5

0.4

0.3

0.2

0.1

0.0

Total
4.59

Total
4.38

2016 2017 2018 2019 2020 2021 2022 2023 2024

Jan Feb Mar Apr May Jun Jul Aug Sep Oct

Nov Dec

Emissions

Emissions intensity

Oil Search emissions included in baseline year (2019-20) 
for emissions reduction target

Emissions (including Moomba CCS)
Emissions (excluding Moomba CCS)

In 2024, equity emissions reduced to 4.38 Mt, following Moomba CCS start-up at the end of September. Emissions 
intensity in the fourth quarter with Moomba CCS operating at full rates reduced to 45 kt/mmboe, representing an 
18 per cent reduction from 2019-20 baseline emissions intensity. For calendar year 2024 emissions intensity has 
reduced by approximately 10 per cent since 2019-20, representing 23 per cent progress to our 2030 emissions 
intensity reduction target. 

This rate of reduction in emissions intensity will accelerate as late life assets, including Bayu-Undan and Ningaloo Vision 
FPSO, come to the end of production. Late life assets become more emissions intensive with decreasing production.

New production at Barossa LNG and Pikka will be net-zero reservoir emissions to comply with the Australian Government's 
Safeguard Mechanism and net-zero Scope 1 and 2 equity emissions respectively, resulting in an increase in production 
without the requisite emissions increase as would have been the case historically.

Methane emissions (gross operated)

Scope 3 emissions

Santos methane emissions intensity is well below OGCI target

y
t
i
s
n
e
t
n

i

s
n
o
i
s
s
i
m
e
e
n
a
h
t
e
M

0.20

OGCI methane 

intensity target

0.15

0.10

t
n
e
c
r
e
p

0.05

0.00

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

35
30
25
20
15
10
5
0

0.60

0.50

0.40

0.30

0.20

0.10

0.00

e
2
O
C
t
M
s
n
o
i
s
s
i
m
E

2020

2021

2022

2023

2024

Emissions

Emissions intensity

Santos is continuing the focus on reducing methane 
emissions across the business, and in 2024, we continue  
to remain below the Oil and Gas Climate Initiative (OGCI) 
methane emissions target of 0.2 per cent. Since the start- 
up of the Moomba CCS project, our company methane 
emissions have reduced by approximately 21 per cent.1

1 

 Moomba CCS captures and stores both CO2 and methane from the CO2 
removal process.

2023

2024

Downstream (Categories 10 & 11)

Upstream (Category 1)

Other Categories

In 2024, Santos continued its focus on better understanding 
Scope 3 emissions sources and improving quantification 
of these. Our significant collaboration with suppliers has 
resulted in improved estimations of upstream (category 1) 
emissions. Our 2024 upstream Scope 3 emissions intensity, 
expressed as tonnes of CO2e per million dollars spent with 
suppliers, reduced by more than 50 per cent compared to 
2023. In 2023 we undertook a detailed analysis of the end use 
of our product and this was repeated in 2024, finding that 
approximately 23 per cent of our products are not combusted 
but instead utilised as petrochemical feedstock.

73

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
Our approach to climate

Scope 1 and 2 emissions 
reduction plan

Santos employs a range of levers to decarbonise our operations  
in line with our emissions reduction strategy hierarchy of avoid,  
reduce and offset.

Our approach is to decarbonise 
our operations at the source of 
production, capture and store 
emissions which are not avoided or 
reduced, and then only offset as a 
last resort any residual emissions 
which are not otherwise avoided, 
reduced or captured. Our mitigation 
activities are structured to target each 
stage of production and our most 
material emissions sources. This multi-
layered process aims to drive Santos’ 
decarbonisation pathway to net-
zero Scope 1 emissions by 2040 and 
net-zero Scope 2 emissions by 2050, 
supported by our 30 per cent Scope 1 
and 2 reduction by 2030.

The technologies used to avoid or 
reduce our Scope 1 and 2 emissions on 
our current assets are also leveraged 
for future projects. 

In addition to replacing, upgrading or 
retrofitting existing equipment and 
infrastructure to reduce emissions 
from existing operations, Santos 
seeks to avoid emissions from the 
outset of new projects. This is the 
result of proactive engineering and 
technological solutions which aim 
to minimise the emissions intensity 
of future assets or production 
infrastructure.

Our potential to 
achieve net-zero Scope 
1 emissions by 2040 
and net-zero Scope 2 
emissions by 2050 

The expansion of CCS capability 
could provide Santos an opportunity 
to reach our long-term Scope 1 and 
2 emissions targets. Combined with 
the potential development of DAC, 
which could have the ability to remove 
CO2 directly from the atmosphere 
at existing CCS locations, and the 
development of new assets designed 
to avoid emissions from the outset, 
CCS capability underpins our current 
decarbonisation pathway.

However, the energy transition will 
not be linear. There is a range of 
uncertainty associated with the 
potential pathway Santos is currently 
following to achieve our net-zero 
equity Scope 1 and 2 emissions targets. 
To mitigate these risks and for Santos 
to be best placed to achieve our 
decarbonisation targets and maintain 
resilience through the energy transition, 
Santos seeks to retain the flexibility to 
invest in multiple pathways. We remain 
on track to achieve our 2030 climate 

Scope 1 and 2 equity emissions pathway to 20303

targets and pursue our Scope 1 and 2 
net-zero emissions targets.

Scope 2 emissions are determined 
by the local energy grids from which 
we draw electricity supply. According 
to government projections, these 
energy grids are not expected to be 
fully decarbonised by 2040,1 with risks 
and challenges related to planning 
approvals, availability of a skilled 
workforce, supply chain constraints and 
expansion of transmission lines, among 
other factors.2 As a result, Santos has 
revised our Scope 2 net-zero emissions 
target from 2040 to 2050. This change 
is generally consistent with the Net Zero 
targets of the majority of jurisdictions 
where we operate.

We remain committed to decarbonising 
our operations and our Scope 2 
emissions, which make up six per 
cent of our 2024 Scope 1 and 2 equity 
emissions, and will decarbonise at the 
pace of the energy grids where we 
operate. Santos intends to identify 
opportunities to secure renewable-
generated electricity for our operations, 
where economically feasible, and will 
continue to monitor whether this target 
can be achieved earlier.

8

7

6

5

4

3

2

1

0

)
O
T
S
e
2
O
C
t
M
(

s
n
o
i
s
s
i
m
E

5.9

2030 target: 4.1MtCO2e

2019-20 
Emissions

Growth 
to 2030

CCS projects

Operational 
efficiencies

1  DCCEEW 2024. ‘Australia’s emissions projections 2024’, page 43.

2030 net 
emissions

Carbon solutions 
(including generated 
and acquired 
emissions reduction 
units)

Santos currently expects our 
portfolio of emissions reduction 
initiatives will comprise 
approximately 70 to 80 per cent 
structural abatement and 20 to 
30 per cent emissions reduction 
units, a majority of which are 
aimed to be Santos generated, to 
meet our compliance obligations 
and voluntary targets. Refer to 
our Strategy on page 70 for 
further information on how we 
utilise emissions reduction units 
when needed.

2  AEMO 2024. Integrated System Plan for the National Electricity Market.

3 

 Emissions reduction projects will be subject to our internal project gating process and project approvals. As we pursue our backfill and sustain strategy to 2030, 
our unabated emissions will increase with Barossa, Pikka phase 1 and potential future projects such as Papua LNG, Bedout Basin, and future phases of Alaska and 
Narrabri coming online. CCS from Moomba (operational) and Bayu-Undan (in planning) are targeted to more than offset these emissions. Operational efficiencies 
including electrification, and carbon solutions in Australia, PNG and Alaska are intended to contribute to delivering our emissions pathway to 2030. Any shortfall 
to our 2030 target is intended to be addressed through both Santos-generated and Santos-acquired emissions reduction units.

74

Santos Annual Report 2024 
 
Our approach to climate

Scope 3 emissions  
reduction plan

We are committed to collaborating with our customers and suppliers  
to address our Scope 3 emissions. We are building a commercial carbon 
storage business which aims to give us a pathway to reduce equivalent 
Scope 3 emissions in our value chain.

Santos’ Scope 3 emissions are 
indirect emissions in our value chain. 
The Australian National Greenhouse 
and Energy Reporting (NGER) 
emissions measurement and reporting 
framework does not encompass 
Scope 3 emissions. However, Santos 
calculates and discloses our material 
Scope 3 emissions in observance 
of the World Resources Institute 
Greenhouse Gas Protocol Technical 
Guidance for Scope 3 Emissions.

There are a range of categories by 
which Scope 3 emissions can be 
classified under the Greenhouse Gas 
Protocol. These categories cover 
activities upstream and downstream 
of Santos’ emissions reporting 
boundaries. The majority of Santos’ 
Scope 3 emissions are downstream 
of our value chain, being from the 
processing and use of our products.

In 2023, Santos completed a materiality 
assessment of all 15 categories to 
improve its reporting of Scope 3 

Our key Scope 3 emissions sources2

Downstream

emissions. In 2024, we engaged directly 
with our suppliers and customers to 
better understand their emissions 
reduction plans and where we can have 
the most influence to reduce emissions 
along the value chain.

This target underscores our long-term 
aspiration to store more carbon than 
we emit (Scope 1, 2 and equivalent 
Scope 3 emissions) and also progress 
in parallel with our development of 
lower carbon energy.

This assessment has provided a more 
comprehensive view of our value chain 
emissions and associated supplier and  
customer decarbonisation plans. 

As a result, Santos has set a new 
carbon storage growth target in 
which we aim to build and operate a 
commercial carbon storage business, 
safely and permanently storing 
approximately 14 million tonnes 
(gross) of third-party CO2e per 
annum by 2040.1 

The carbon storage growth target 
is equivalent to storing 50 per cent 
of Santos’ 2023 equity downstream 
(categories 10 and 11) Scope 3 
emissions, or more than three 
times Santos’ 2023 equity Scope 1 
emissions.1

Santos does not control Scope 
3 emissions. We see our role as 
providing customers and suppliers 
with low carbon fuels and commercial 
decarbonisation services, while 
creating value for the business. This 
will give our customers and suppliers 
direct methods to reduce their 
emissions, in turn reducing our Scope 
3 emissions.

Despite only supplying customers 
from countries who are signatories 
to the Paris Agreement or have a 
Net Zero commitment, a degree of 
uncertainty remains given Santos 
alone cannot deliver on our customers’ 
climate targets.

Upstream

Category 11  
Use of sold 
products

Category 10 
Processing of 
sold products

Category 1 
Purchased 
goods and 
services

Category 2 
Capital goods

Approximately 71%  
of Scope 3 emissions

Approximately 14%  
of Scope 3 emissions

Approximately 12%  
of Scope 3 emissions  
combined

1  Refer to 'important notices' at the front of this report for further information about this target.
2  Downstream Scope 3 emissions are expressed on a net equity basis and upstream Scope 3 emissions are expressed on a gross operated basis.

75

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur approach to climate

Our approach  
to methane emissions

Methane emissions from oil and gas operations are a result of venting, 
fugitive emissions, flaring and incomplete combustion of fuel in the 
form of natural gas. Methane emissions equated to approximately 
10 per cent of our total gross operated Scope 1 emissions in 2024.

Methane management is fundamental 
to Santos’ business. It is the main 
component of natural gas and is  
also a greenhouse gas that accounts 
for approximately 30 per cent of 
global warming since pre-industrial 
times (IEA Global Methane Tracker, 
2023). As such it is in the best interest 
of Santos to detect, contain and 
mitigate methane emissions where 
possible.

2024 Santos  
methane emissions1

Fugitives

~42%

~5%

Flare

~1%

~26%

Fuel

Vent

~26%

CO2 vent

Our approach

Santos continues to prioritise the reduction of upstream venting and fugitive 
methane emissions while monitoring our progress toward reaching our methane 
targets. The Delivering on our CTAP - Operational efficiencies section (page 82) 
provides additional detail on how we manage routine and non-routine flaring and 
reduce fuel consumption along with associated greenhouse gas emissions.

In 2024, we consolidated our methane emissions reduction approach, 
incorporating existing activities, while delivering potential opportunities for 
future methane emissions reductions. Our approach focuses on three key areas: 

1.   Detect, measure and validate: Activities that detect and 

accurately measure methane emissions using a combination 
of evidence-based theoretical techniques and real-time 
technologies. The utilisation of various methods and 
technologies permits validation of results and comparison 
against reported emissions. Our most material emissions are 
assessed and prioritised accordingly.

2.   Monitor and mitigate: Asset-led programs that incorporate 
surveillance of emissions using different techniques and 
technologies. These programs permit prioritisation of our 
most material emissions, associated reparation feasibility 
assessment and value impact to the business. 

3.   Engagement and leadership: Interaction with stakeholders 
across the methane value chain to collaborate on solutions. 
This includes engagement and collaboration with our peers 
on approaches for methane measurement  
and reduction.

1

2

3

In 2024, Santos participated in the OGCI Satellite Monitoring Campaign.

Critically, the campaign identified a reduction of methane emissions 
following the first injection of Moomba CCS. 

Santos received satellite imagery and methane emissions data about key 
assets in eastern Australia. We used this information to validate our current 
knowledge of methane emissions within the areas we operate, build 
satellite-technology knowledge and experience across the business, and 
assess how this technology could further enhance our existing emissions 
reduction efforts.

1 

 Venting occurs as part of oil and gas operations, and results in the release of CO2 and methane. This is distinct from CO2 venting which is a result of gas 
processing to remove CO2 from the gas stream, this waste stream includes small amounts of methane due to technical limitations in the process.

76

Santos Annual Report 2024Delivering on methane emissions reduction

In 2024, we delivered on the three pillars of our methane emissions approach:

Detect, measure and validate

Engagement and leadership

•  Completed a methane emissions 

•  Conducted a gap analysis of 

our current methane reduction 
approach against international 
standards.

•  Participated in Australian Energy 

Producers methane working group.

•  Engaged with our gas value chain 

through the Climate Leaders 
Coalition to accelerate methane 
emissions measurement, tracking 
and reduction.

materiality assessment across our 
operated assets.

•  Completed a gap assessment 
against the United Nations 
Environment Programme Oil  
& Gas Methane Partnership 2.0 
(OGMP 2.0).

•  Leak detection in accordance with 
regulatory requirements carried 
out on 528 wells in south-eastern 
Queensland.

Monitor and mitigate

•  Continued our assessment and 

prioritisation of vent reduction and 
flare efficiency projects across our 
operations.

The start up of Moomba CCS 
phase 1 has played a role in 
significantly reducing the volume 
of vented methane in the Cooper 
Basin. The CO2 venting process 
at Moomba was responsible for 
approximately 39 per cent of 
Santos' total methane emissions 
from operated assets in 2024.1 
These methane emissions 
are now captured and stored 
alongside CO2 in the same 
reservoirs.

COMPLETED

Completion of CSIRO baseline assessment project 

In 2024, Santos completed the final of a series of baseline methane surveys across our Australian onshore operations. 

It confirmed that our monthly methane concentration was lower than the global monthly mean methane 
concentration. The overarching program, conducted by the Commonwealth Scientific and Industrial Research 
Organisation (CSIRO), measured atmospheric methane concentrations around existing assets and determined the 
baseline methane concentrations at new Santos’ developments prior to commencement of activities.

Methane emissions intensity3  
– near zero

As an OGCI member company, Santos continues 
to meet OGCI's target of “below 0.20 per cent” 
methane emissions intensity by 2025. In 2024, 
across our operated sites, our methane intensity1 
was 0.16, compared to 0.192 per cent in 2023. 

Our 2024 methane emissions were 17 per cent 
lower compared to 2023 which incorporates:

•  A 24 per cent reduction in emissions from flaring 

and venting activity.

•  A 5 per cent reduction in fugitive emissions.

0.16%

2024 methane emissions intensity 
As compared to OGCI 2025 target of 0.20%

1  Calculated in accordance with the 2023-2024 National Greenhouse and Energy Report.

2 

 During 2024 the reporting period for emissions data was aligned with the the calendar year, resulting in some updates to our 2023 reported figures. For further 
details see the Appendix on page 111.

3  Methane emissions intensity calculated as gross operated methane emissions divided by volume of marketed natural gas.

77

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur approach to climate

Capital allocation  
and governance

Santos’ capital allocation prioritises shareholder returns, a strong balance 
sheet and disciplined capital reinvestment. Our decarbonisation and 
climate strategy is embedded in our corporate strategy. Our CTAP 
activities and associated projected capital expenditure are captured 
as part of our long-term planning framework.

Investment criteria 

Our economic analysis processes 
consider the greenhouse gas 
emissions from all projects and the 
impact that a carbon price would have 
on our business. Where applicable, 
a carbon price is included in Santos’ 
economic modelling of projects, 
along with sensitivity testing to assess 
the impact of carbon pricing on 
all emissions. 

Santos applies the same stringent 
economic criteria to CTAP projects at 
FID, including IRR and payback period, 
as we do to traditional gas and liquids 
projects. 

Our current carbon planning price 
assumption projects a carbon price of 
~US$60 per tonne of carbon dioxide 
equivalent (real 2024) in 2030.

Climate Transition Action Plan spend 
outlook 

In 2024 we reviewed our outlook for 
CTAP spending with the intention of 
providing a more robust disclosure 
of our future intentions. In preceding 
periods our planned CTAP spending 
was presented with reference to the 
coming decade, this year we have 
revised this to align with 2030 and 
near-term targets. This has resulted 
in our disclosure of planned CTAP 
spend being lower as compared to 
previous reports. In addition to the 
change in timeframes, external factors 
including government frameworks not 
progressing as quickly as expected 
have meant capital associated with 
anticipated projects have had their 
timeframes pushed out. Santos 
remains confident in our projects 
and will continue to advocate for the 
required frameworks to enable them.

Capital is expected to be allocated 
to fund delivery of climate transition 
activities. Due to the nature of 
the projects included in our CTAP, 
spending will vary as different 
opportunities are progressed through 
our internal planning processes. These 
activities will necessarily be developed 
with consideration of capital available 
for allocation, technology maturity, 
commerciality and customer demand.

Over the next five years, potentially 
up to $500m to $1b could be 
invested in operational efficiency 
projects, other CCS and low carbon 
fuels hubs (depending on working 
interest, customer demand and 
value accretion) and nature-based 
projects with the potential to generate 
emissions reduction units. Investments 
must meet Santos' economic hurdles. 

For further details on Santos' capital  
allocation framework see page 17. 

Investment in Climate Transition Action Plan projects

$290m

2024

$265m

2023

$190m

2022

In 2024, Santos undertook a comprehensive review of our investment in the energy transition, resulting in reclassification 
of historical expenditure as CTAP spend. This is reflected in above figures for 2022, 2023, and 2024 investment in CTAP 
projects.

78

Santos Annual Report 2024Our approach to climate

Just transition

Santos has a just transition approach 
referencing Ipieca principles and we 
have processes in place to ensure a 
just transition for our employees, a 
sustainable future for the communities 
in which we operate, and the 
rehabilitation of the environment in 
which we work.

For Santos, the move to a lower 
carbon world is a continuation of 

the just transition that has been part 
of how we work. Over the coming 
decades, customer demand and the 
availability of technology has the 
potential to provide a structural shift 
in the way that the world generates 
and consumes energy. 

The Paris Agreement acknowledges 
the need to balance the reduction in 
emissions with “the imperatives of a 

just transition of the workforce and the 
creation of decent work and quality 
jobs in accordance with nationally 
defined development priorities.” 

We have several processes in place to 
consider the impacts on our assets, 
people and contribution to local 
community. 

Balanced energy approach: 

Job preservation and creation:

We recognise the need to reduce emissions while 
ensuring energy security and economic stability. We 
believe that natural gas plays a vital role in the energy 
transition to provide reliability and constant supply 
as a supplement to renewable energy. We invest in 
CCS projects to decarbonise our own and third-party 
emissions. The Australian Energy Market Operator 
(AEMO) has highlighted the role of gas in supporting 
renewables, with its ability to fill supply gaps and 
demand spikes crucial for reliability and security in a 
renewable energy power system.2

We are committed to maintaining and creating 
employment opportunities during the energy 
transition, focusing on both existing workers 
and future workforce development. We offer our 
employees access to continued opportunity and 
growth through employee development programs, 
and we prioritise local hiring and investment in 
communities where we operate, contributing to 
regional economic resilience. 

Community engagement and support:

Social and environmental responsibility:

We engage with local communities for them to be 
involved in and benefit from the transition process. 
Our community and Indigenous consultation and 
investment frameworks provide the basis for respectful 
and beneficial engagements with local communities. 
We fund community development projects in areas 
where we operate, focusing on education, health and 
economic development to help mitigate the social 
impacts of the energy transition by supporting local 
economies and improving quality of life.

Transition to a lower carbon economy should not 
come at the expense of human rights, environmental 
protection or social equity. We uphold human rights 
commitments, ensuring that workers and vulnerable 
communities are not left behind in the transition. 
This includes strong policies on modern slavery and 
Indigenous rights.

Ipieca principles of a just transition1

•  Respect the rights of communities and workforces, including in global supply chains. 

•  Address impacts on those who currently depend on the oil and gas industry for jobs and energy, or benefit from its 

social investments. 

•  Address impacts of new types of business that reduce carbon and develop renewables. 

•  Promote long-term opportunities for decent work and sustainable livelihoods. 

•  Make lower carbon energy affordable and reliable for developing nations as well as developed countries.

•  Avoid penalising poor, vulnerable and historically disadvantaged people, and promote social equity in the 

distribution of low carbon energy benefits. 

•  Fulfil the 2015 Paris Agreement statements on just transition, and leave no-one behind in a world aspiring to a Net 

Zero future. 

•  Support UN Sustainable Development Goals that are relevant to a just transition. 

1 

Ipecia statement on just transition: ipieca.org/work/people/just-transition/ipieca-statement.

2  AEMO 2024 Integrated System Plan. aemo.com.au/energy-systems/major-publications/integrated-system-plan-isp/2024-integrated-system-plan-isp.

79

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationOur approach to climate

Climate Transition 
Action Plan

Santos’ CTAP represents our response to managing climate-related risks 
and leveraging climate-related opportunities. It outlines our current plan 
for decarbonising and transforming our business, and is founded on our 
emissions hierarchy of avoid, reduce and offset.

Our CTAP outlines our current 
potential decarbonisation initiatives 
that provide a potential pathway 
for Santos to achieve both our own 
emissions reduction targets and 
provide valuable services to help 
our customers reduce emissions 
and achieve their own targets. It 
also provides a possible pathway to 
progressively develop and deliver 
lower carbon energy and low 
carbon fuels as demand develops. 
This includes emissions reduction 
initiatives across the value chain, such 
as working with our customers and 
suppliers to cultivate demand for low 
carbon fuels and carbon solutions. 

The IEA recognises a number of 
key levers that will drive emissions 
reductions to meet global Net 
Zero targets. These levers, which 
include reducing methane emissions, 
eliminating non-emergency flaring, 
electrifying upstream facilities 
with low-emission electricity, and 
providing CCS services, form a 
fundamental part of our CTAP.1

Our asset and project composition is 
optimised for the current operating 
environment and retains flexibility to 
respond to changes in the external 
environment. Key to our portfolio's 
resilience is our unique combination 
of low-cost, long-life natural gas 
and liquids assets, CCS capability 
and assets, and low carbon fuels 
and nature-based solutions projects 
currently under consideration.

The CTAP is underpinned by Santos’ 
three-horizon strategy: backfill and 
sustain, decarbonisation, and low 
carbon fuels. Santos’ reduction targets 
are guided by our emissions hierarchy 
of avoid, reduce and offset. For hard-
to-abate emissions, Santos continues 
to build and invest in a portfolio 
of projects including multiple CCS 
facilities and nature-based projects 
with the potential to deliver emissions 
reduction units. We continue to look 
to the future at new technologies that 
may enable large-scale emissions 
abatement (such as DAC), as well 
as the supply of low carbon fuels, as 
market demand develops.

It is expected that investment in our 
transition activities will initially focus 
on commercial decarbonisation and 
carbon management services, laying 
the foundation to support increased 
investment in low carbon fuels 
projects as technologies and customer 
demand develop.

We have established internal 
capabilities to address our climate-
related risks; and core expertise in 
the design, execution, delivery and 
operation of technological and nature-
based carbon sequestration methods. 
Santos’ CTAP has been created 
with the intent of leveraging these 
capabilities.

Updating our CTAP 

Santos’ CTAP will continue to evolve 
to incorporate changes in the global 
energy transition environment. Our 
disciplined economic and commercial 
criteria are being applied to inform 
investment decisions and create value 
for shareholders, as we continue 
our transformative decarbonisation 
journey. We have heard investor 
feedback on the CTAP through regular 
engagement over the past two years 
and have responded to that feedback 
through changes to our approach and 
further disclosures. In 2025, we again 
ask for investor support of our CTAP.

Our CTAP is reviewed by the Safety 
and Sustainability Committee half-
yearly in line with Santos’ corporate 
planning process. Annual reduction 
targets are included in the Company 
Scorecard and are stated in the Santos 
Annual Report.

Updates to our CTAP seek to reflect 
the progress of our initiatives and 
further evolutions of our strategy 
including in response to developments 
in technology, global energy markets, 
government policies and customer 
demand. 'Delivering on our Climate 
Transition Action Plan' (refer to page 
82) provides more specific details 
of our progress within each CTAP 
category.

1 

IEA 2023. Credible pathways to 1.5 °C - Four pillars for action in the 2020s.

80

Santos Annual Report 2024Decarbonising our operations

Developing commercial carbon management services

Operational 
efficiencies

Carbon  
solutions

Value chain 
collaboration

Low carbon 
 fuels hubs

Broad range of 
initiatives designed 
to avoid and reduce 
Scope 1 and 2 
emissions from our 
operations.

Opportunities to 
address emissions that 
cannot be avoided or 
reduced by Santos, 
our customers and 
third parties.

Working with 
customers and 
suppliers to mutually 
decarbonise and 
cultivate demand for 
low carbon fuels and 
carbon management 
services.

Leverage 
decarbonisation 
hubs as a platform 
for low carbon 
fuels as customer 
demand evolves.

Carbon capture and storage

Existing technology to reduce emissions and pave the 
way for new revenue streams from future low carbon 
fuels and carbon solutions.

2020

2030

2040

CCS projects
Moomba CCS (phase 1 online) – phase 2 concept development in progress | 1.7 Mtpa >> up to ~20 Mtpa

Bayu-Undan CCS – Targeting FID readiness in 2025 | ~10 Mtpa

WA CCS (phase 1 – Reindeer CCS) | ~5 Mtpa

Other CCS opportunities

Potential technology development
DAC (commercial scale)

Synthetic Gas

Targeting FID readiness

First injection target

Online

Technology trials and concept development

1 

 Our CTAP includes current projections that are necessarily based on assumptions, contingencies and commercial judgement. The estimates included do 
not take into account customer demand or any future sell-downs and acquisitions, partnering arrangements and infrastructure funding. Our CTAP is over a 
forward-looking period of approximately 20 years. It is important to recognise that markets are dynamic, emerging and still evolving, based on factors including 
developments in technology, science, markets, policy and experience over time.

Note: Future dates are target dates based on current understanding, not forecasts.

81

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDelivering on our  
Climate Transition Action Plan

Operational efficiencies

At Santos, we strive to avoid and 
reduce the emissions from our 
operations through design or 
operational optimisation. 

Our emissions hierarchy of avoid, 
reduce and offset guides our 
approach to operational efficiencies. 
As such emissions reductions through 
operational efficiencies are a priority. 
Efficiently operating plant and 
equipment has dual benefit; lowering 
carbon intensity and driving down 
production and operating costs. 

Wherever possible, emissions are 
avoided in the planning phase of 
projects (design-out). Assessments 
are also regularly undertaken to 
determine viable replacements, 

2024 Performance highlight

upgrades or modifications to existing 
plant and equipment to reduce 
emissions (operate-out). These 
opportunities, as well as any projects 
initiated to address the opportunity, 
are reported on an annual basis in 
regional business unit decarbonisation 
plans. 

Design-out

Emissions reduction from operational 
efficiencies are not limited to our 
existing operations. During project 
design of developments, Santos 
investigates engineering and 
technological solutions to avoid 
emissions from the outset.

Fuel, flare and vent (FFV) emissions 
reductions are all opportunities for 
improvement in the design phase 
of a project. However, each must 

be assessed using the principles of 
ALARP which weighs the benefits 
of the technological or engineering 
solution, against safety-critical risks. 

New developments, such as Pikka 
(phase one) and Barossa continue 
to investigate opportunities for 
emissions reductions through planned 
operational efficiencies. Examples of 
emissions reduction opportunities that 
have been identified for inclusion in 
Santos’ developments include: 

•  combined cycle power generation 

– Barossa 

•  efficient CO2 removal and disposal 
via Thermal Oxidiser – Barossa.

Design: Barossa floating production storage and offloading:

Numerous design features have been incorporated to deliver an efficient FPSO with reduced emissions: 

•  Combined Cycle Power Generation 

 – provides all required power for the facility including power for compressors 

 – waste heat recovery units adopted for all gas turbine generators delivering heat for process 

 – steam generator and steam turbine utilises waste heat from turbine exhausts to generate 29MW of power, 

reducing fuel usage by approximately 20%. 

•  CO2 removal system design minimises hydrocarbon losses in the waste stream

•  disposal of CO2 via thermal oxidiser enabling highly efficient conversion of stream reducing emitted CO2e 

• 

in accordance with World Bank Zero Routine Flaring by 2030 initiative, the FPSO is provided with a vapour recovery 
system and designed to operate with closed flare during normal operations.

The project will be net-zero reservoir emissions from first gas.

82

Santos Annual Report 20242024 operational efficiency highlights

Operational efficiency projects across the business in 2024 included:

• 

Implementation of a hot oil optimisation process at Varanus Island, which decreased compressor fuel gas 
consumption equivalent to an estimated emissions reduction of 4.9 kt CO2e per annum in 2024.

•  Fuel, flare, vent reduced by ~23 kt CO2e per annum at Moomba plant through the introduction of benchmarking 
and site-based projects, including operating with a refrigeration circuit offline during the cooler months and 
ceasing amine circulation in the ethane treatment plant.

•  Cooper Basin equipment rationalisation, which resulted in emissions reductions of 2.6 kt CO2e per annum through 

the strategic decommissioning of some non-value add assets.

• 

Implementation of the Inline Flowback project in the Cooper Basin which has resulted in an emissions reduction of 
approximately 9.4 kt CO2e per annum.

Operate-out

Opportunities include reducing fuel 
consumption, minimising flaring and 
venting activities, and addressing 
incomplete combustion where feasible, 
as well as integrating renewable 
energies and new technologies.

FFV emissions reduction opportunities 
are evaluated regularly by each asset 
using factors such as materiality, 
integrity risk and value to the business. 
While regularly identified and 
prioritised, FFV emissions reductions 
are subject to barriers including 
investment hurdles and the suitability 
and availability of technology in 
transitioning opportunities into action. 

In addition to the generated emissions, 
FFV represents a significant operating 
cost for assets. For this reason, fuel 
efficiency opportunities are regularly 
identified and assessed. Fuel emissions 
reduction projects implemented and/
or trialled in 2024 include:

•  central processing facility Stabiliser 

Reboiler Upgrade at our PNG 
operations, which is expected to 
reduce greenhouse gas emissions 
by 1.5 kt CO2e per annum per 
annum

•  reducing Moomba plant inlet 
pressure has decreased fuel 
consumption of upstream 
compression facilities resulting in a 
fuel gas reduction of approximately 
5 per cent or equivalent to 15 kt 
CO2e per annum.

Flaring at some assets during the 
production process is necessary 
for asset integrity and staff safety. 
While it cannot always be avoided, 
routine flaring can be minimised. Flare 
efficiency opportunity projects, either 
finalised or implemented in 2024, 
include:

•  overhead compressor replacement 
at our PNG central processing 
facility to reduce flaring

•  alternative technologies used at 
Roma East Trunkline to reduce 
flaring and fugitive emissions 
during the process of pigging 
the wet gas pipeline.

In 2024, Santos committed to the 
World Bank Zero Routine Flaring by 
2030 initiative. We aim to eliminate 
routine flaring at our oil operations 
where economically feasible through 
the implementation of a functional 
improvement plan which embeds 
and systemises zero routine flaring 
principles across our portfolio.

2024 performance highlight

Operate-out: Gladstone LNG

For further information on venting 
efficiencies and the associated 
emissions reduction activities 
undertaken by Santos, refer to  
Our approach to methane emissions 
(page 76). 

Renewable energies

Santos is dedicated to integrating 
renewable energies into existing 
operations and new developments 
where economically feasible as the 
technology and reliability of these 
energy sources continues to advance.

Through projects such as converting 
our camps at Cook and Limestone 
Creek to solar power, Santos has 
already adopted renewables into 
much of our operations. However, in 
2025 and beyond we are expanding 
our renewables integration and have 
completed, or are currently scoping, 
innovative projects such as:

•  remote well site solar battery 
installation at Roma with a  
potential total emissions reduction 
of 2.1 kt CO2e emissions once all 
batteries are operational.

•  The conversion of gas turbine engines at Fairview and Roma Hubs to electric motor drives has delivered Scope 1 

emissions reduction of ~175 kt CO2e per annum.

•  Successful process optimisation at our Gladstone LNG plant, including the installation of the boil-off gas advanced 

controller has reduced emissions by 3.3 kt CO2e per annum 

•  The removal of local gas power generation at well sites in Fairview has delivered an emissions reduction of  

~34 kt CO2e per annum.

83

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDelivering on our Climate Transition Action Plan
(continued)

Carbon capture  
and storage

CCS is one of the few at-scale 
solutions for large emitters in hard- 
to-abate sectors.

Global context of carbon capture  
and storage

CCS will require a significant scale-up 
of current capacity by 2050 to meet 
global Net Zero aspirations,1 providing 
a market opportunity to leverage our 
CCS first-mover advantage and build 
on global policy support. The ability 
to leverage existing infrastructure is 
a critical component in developing 
viable low-cost CCS services. The 
start-up of Moomba CCS is the 
cornerstone to Santos’ CCS capability 
to scale-up infrastructure and firm-up 
customer demand, both domestically 
and internationally. As such CCS 
forms a core component of Santos’ 
decarbonisation strategy as well as 
the decarbonisation strategies of our 
customers in hard-to-abate industries.

In late 2024 the Northern Lights CCS 
facility opened in Norway. This joint 
venture between Equinor, Shell and 
TotalEnergies is the world's first cross-
border CO2 transport and storage 
facility. With the ability to transport, 
inject and store up to 1.5 million 
tonnes of CO2 per year, Northern 
Lights represents a major advance in 
developing the global CCS market.

Within the Asia-Pacific region there is 
strong competition emerging from 
Indonesia and Malaysia for CCS 
services to customers. Both countries 
are developing frameworks and 
regulations in support of commerical 
CCS opportunities.

Santos’ progress during 2024

In the Cooper Basin, there is an  
annual carbon dioxide storage 
capacity of up to 20 million tonnes per 
annum, with domestic and 
international customer interest for 
Mooba CCS phase 2 strong, three 
MOUs signed with domestic and 
international emitters, aggregators 
and infrastructure partners. In 2024, 
Santos has undertaken early 
engineering studies on carbon dioxide 
import options to expand the existing 
1.7 million tonnes per annum capacity 
of phase 1 of the Moomba CCS project.

1 

IEA, Tracking Clean Energy Progress 2023 report

84

North of Australia, Santos has continued 
to progress towards carbon dioxide 
injection at Bayu-Undan CCS, which has 
the potential to store up to ten million 
tonnes per annum. While in WA, a 
phased approached around CCS 
could see capacity reach up to five 
million tonnes per annum (phase one 
approx. 1 million tonnes per annum) 
through the Reindeer field and nearby 
Greenhouse Gas storage permit G-9.

Santos continues to work with 
customers, government and regulators 
to develop carbon management 
services that leverage our existing 
capability and infrastructure footprint 
across our three CCS projects. To this 
end, we are focused on developing 
a low carbon fuels hub to support 
our decarbonisation goals alongside 
our existing Moomba CCS asset. We 
are also working with international 
customers to develop third-party 
carbon management services.

The learnings taken from the 
development of Moomba CCS will 
be applied to the Bayu-Undan CCS 
and WA CCS projects. Both projects 
continue to work towards FID 
readiness with engineering design and 
commercial engagements progressing 
in 2024. Looking forward, the focus 
will be on developing the domestic 
and international frameworks that 
underpin successful execution of 
Bayu-Undan CCS and WA CCS.

Carbon capture and storage 
regulation and policy

Regulations for CCS are essential 
to ensure environmental safety, 
effectiveness of CO2 storage, public 
confidence, economic stability, 
and legal clarity. The appropriate 
regulations help safeguard against 
risks and ensure the long-term 
success and integrity of CCS projects. 
At present, CCS legislation and 
regulations are not standardised 
across Australia as each state and 
territory regulate their own storage 
resources. Developing the regulatory 
framework to enable Moomba CCS 
to generate ACCUs was a critical 
component of the project taking 
FID. Without establishing a clear 
framework, CCS projects will not 
have the certainty to progress. Santos 
continues to engage with state, 
federal and international governments 
and regulatory bodies to support the 
development of CCS frameworks.

As part of this engagement a 
monitoring and verification plan, 
regulated by the South Australian 
Government, has been developed 
based on international standards 
and best practice. This program is 
designed to ensure containment 
of CO2e injected is appropriately 
managed.

Pictured: The Moomba CCS facility

Santos Annual Report 2024Moomba CCS

Project location
Annual gross CO2 storage potential ~20 MtCO2e
FID

2021 (phase 1)

South Australia

First injection achieved

September 2024

Project key details

Darwin and Bayu-Undan CCS

The Moomba CCS project is a world-class, commercial-scale project which captures 
CO2 reservoir emissions at the Moomba gas plant and transports and stores the CO2 
in depleted reservoirs in the Cooper Basin. 

As of December 31, the Moomba CCS project has stored 340,000 tonnes of CO2e.

Santos is exploring additional sources of CO2 from third parties and if made 
available, there is the capacity to permanently store CO2 in the Cooper Basin at a 
rate of up to 20 Mtpa for 50 years. In 2024, Santos commenced early engineering 
work to evaluate the technical options for CO2 imports to Moomba CCS (Moomba 
CCS phase 2). Moomba CCS phase 2 is looking at potentially storing up to 2-10 Mtpa.

Project location
Annual gross CO2 storage potential 9.8 MtCO2e through Darwin
FID ready target

2025 (Bayu-Undan CCS)

Northern Australia/Timor-Leste

First injection timing target

2028

Project key details

FEED throughout 2024 for the Bayu-Undan CCS project.

The project could utilise the existing Bayu-Undan to Darwin pipeline and the 
offshore Bayu-Undan platform. Potential CO2 sources include natural gas 
developments and industrial sources in Northern Australia with customers and 
investors in Korea and Japan also interested in the project for emissions reduction 
from their activities. Santos’ Barossa gas project has the potential to utilise Bayu-
Undan CCS as the foundation customer. This capture and storage of Barossa’s 
associated CO2 supports its position as a low-emissions intensity LNG project 
designed to be net-zero reservoir emissions from first gas.

Discussions are continuing with domestic and international CO2 customers to 
underpin the 10 Mtpa maximum capacity. 

The nearby greenhouse gas storage permit G-11-AP adds to the potential storage 
quantity in Northern Australia, providing an option for future hub expansion. 

Engagement continues with the Timor-Leste and Australian governments to 
progress an arrangement on transportation of CO2 across international boundaries, 
in accordance with Australian Government obligations under the London Protocol.

Western Australia CCS

Project location
Annual gross CO2 storage potential Up to 5 MtCO2e
FID ready target

WA

2026 (phase 1 – Reindeer CCS)

Pictured: The Moomba CCS facility

First injection timing target

2029

Project key details

The Reindeer CCS project offers a potential low-cost carbon storage solution with a 
phased development, through repurposing of existing infrastructure. Reindeer CCS 
phase 1 is expected to have a storage capacity of 1 Mtpa.

The nearby greenhouse gas storage permit, G-9-AP, enhances Santos’ storage 
capacity offering the potential for future hub expansion.

This hub offers capacity for third-party industrial CO2 sources and natural gas 
developments in the Pilbara region of Western Australia, as well as capacity for 
international CO2 imports. Santos submitted the Declaration of Storage Formation 
application to National Offshore Petroleum Titles Administrator (NOPTA) in 
November 2024.

Engagement continues with regional and international emitters to progress end-
to-end technical and commercial solutions to capture, transport and store CO2 
emissions in Santos CCS reservoirs.

85

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDelivering on our Climate Transition Action Plan
(continued)

Low carbon fuels

Low carbon fuels are a customer-
led opportunity to supply products 
that reduce both Santos’ and our 
customer’s emissions. 

The world is likely to need low carbon 
fuels to meet the commitments made 
globally on emissions reduction. Our 
investment in these technologies 
intends to enable our customers 
to contribute to the global energy 
transition, while also reducing their 
own emissions.

Santos' low carbon fuels hub at 
Moomba has several advantages 
including: 

•  access to existing infrastructure

•  renewable energy resource potential

•  well understood geology

•  future carbon storage reservoirs. 

These advantages are key in 
potentially delivering cost-competitive 
and low carbon fuels. The Moomba 
low carbon fuels hub is strategically 
co-located with Santos’ CCS projects 
and is supported by our investment 
in CCS. This approach will help 
accelerate the development of 
affordable, low carbon fuels as market 
and customer demand evolves.

The core components of low carbon 
fuels production for Santos include: 
CO2 capture, power, hydrogen 
production technology and 
customers. The skills and expertise 
gained through the Moomba CCS 
project on capture and supply of 
CO2 as a feedstock, will be crucial 
for the development of low carbon 

Synthetic gas process

Renewables

to Green hydrogen

fuels all the way through to DAC 
technology trials and beyond. Santos 
is investing and building capability 
in electrification first to decarbonise 
Santos’ existing operations and then 
for low carbon power generation to 
produce low carbon fuels. 

now executing a concept select (pre-
FEED) joint study agreement with the 
aim of developing a commercial-scale 
synthetic gas project in the Cooper 
Basin in the 2030s. In addition, Santos 
is exploring the potential to use 
synthetic gas in our own operations.

Santos is focused on synthetic gas 
given its potential to deliver hydrogen-
based fuel through established 
infrastructure. This would avoid 
significant infrastructure costs to 
substantially upgrade gas distribution 
networks to carry hydrogen. To support 
our production of low carbon fuels we 
are investigating low carbon sources 
of power, including the harnessing 
of geothermal energy, as an input to 
produce hydrogen and associated 
low carbon fuels. In December 2024, 
Santos’ acquired a 100 per cent interest 
in three geothermal exploration 
licenses (GEL’s 655, 656 and 658) in 
the Cooper Basin. The licenses cover 
an area of approximately 8,750 square 
kilometres around the Moomba gas 
plant and will be considered for future 
potential decarbonisation activities.

Santos has completed early 
engineering studies on a synthetic 
gas facility in the Cooper Basin 
with Japanese Gas Utilities Toho 
Gas, Tokyo Gas and Osaka Gas. The 
project is driven by the Gas Utilities’ 
requirements to supply a proportion 
(initially 1 per cent of city gas)1 of 
their customers with synthetic gas 
from 2030. The study considered the 
feasibility of producing low carbon 
synthetic gas from hydrogen and 
captured carbon dioxide for export to 
Japan. Following this project, Santos is 

Support in the Asia Pacific region

The Japanese Government has 
introduced a number of initiatives with 
the aim of stimulating growth in low 
carbon fuels, incuding:

•  Through its Ministry of Economy, 
Trade and Industry (METI), it 
promoted synthetic gas under its 
national policy, including as part  
of its Sixth Strategic Energy Plan. 
METI has a goal of replacing  
1 per cent of Japan’s city gas  
with synthetic gas by 2030 and  
90 per cent by 2050.

•  The Green Transformation Policy to 
achieve its 2050 carbon neutrality 
goal. This is a set of policies, 
including a ten-year roadmap 
outlining the allocation of 150 
trillion yen (US$1 trillion) of public-
private investment for various 
sectors and technologies.

•  Various support schemes that 

recognise synthetic gas and provide 
financial support for establishing 
new supply chains and infrastructure 
that can help the country transition 
from fossil fuels to a lower carbon 
energy-based society. 

The initiatives are likely to generate 
demand for low carbon fuels in Japan, 
a market in which Santos has built 
strong relationships and partnerships 
with customers.

Through capturing or importing CO2 and then exporting it to our 
trading partners in the form of synthetic gas, there is a potential 
opportunity to create a circular decarbonisation model.

DAC

Local emissions

Methanation

Existing pipes  
& infrstructure

Liquefaction  
& shipping

Destination

Captured CO2  
locked in methane

Japanese customer emits same 
carbon as captured in Australia

1  METI, Strategic Energy Plan, October 2021.

86

Santos Annual Report 2024Carbon solutions 
Nature-based solutions

Santos is focused on an emissions 
reduction hierarchy of avoid and 
reduce, while recognising that emissions 
reduction units will be needed to address 
residual emissions. When required, 
Santos is working to generate a nature-
based solutions portfolio to generate 
high integrity units that support Santos 
to achieve compliance requirements or 
voluntary targets, as well as aiming to 
provide environmental and community 
benefits in the regions where we operate. 

With an aim of ensuring access to high 
integrity emissions reduction units, 
Santos is building a portfolio of nature-
based projects. In 2024, a number 
of these projects came to fruition, 
highlighting the value in this approach:

•  Vegetation regeneration continuing 

at Waddy-Brae-Fairview Springwater 
Regeneration Project.

•  Project declaration and baseline soil 
samples completed at Summer Hills 
Soil Carbon Project, Queensland 
and Broandah Soil Carbon Project, 
Queensland.

•  First issuance of emissions reduction 

units from the Markham Valley 
Afforestation Reforestation Project, 
Papua New Guinea, on track for 
delivery in 2025.

•  Collaboration on two projects with 
local Alaska Native landowners 
secured 500,000 high integrity 
emissions reduction units in Q4 2024.

Santos is focused on nature-based 
projects as a means to supply to supply 
high integrity emissions reduction units 
where needed to meet our compliance 
and corporate commitments as a final 
resort. This includes our corporate 
commitment to be net-zero for the 
Santos equity share of Pikka phase 1 
Scope 1 and 2 emissions from first oil. 

High Integrity when used with reference 
to Santos nature-based projects 
and associated emissions reduction 
units, refers to Santos recognising the 
integrity challenges currently faced by 
international carbon markets as their 
depth and maturity grows and Santos 

using the following three pillars for its 
approach to integrity in our nature-based 
carbon projects:

•  Owing to our global presence, our 
integrity standards for emissions 
reduction projects seek to align 
with the Core Carbon Principles 
assessment framework of the Integrity 
Council for Voluntary Carbon Markets. 
We monitor developments in these 
standards and adjust our internal 
frameworks where necessary, seeking 
to align with the requirements of our 
partners, customers and other key 
stakeholders.

•  Recognising that the balance of 

risk in carbon projects is weighted 
towards post-transaction events, we 
have developed bespoke tools to 
assess the probability of these on an 
ongoing basis, in addition to standard 
due-diligence procedures leading up 
to transactions. These tools consider 
the ESG risks that may materialise 
including due to changes in the 
policy environment, natural disasters/
events and changing requirements in 
community expectations.

•  Own generation describes Santos’ 
philosophy of prioritising projects 
in which we can invest and manage 
directly, as opposed to seeking to 
be only an offtaker or on-market 
purchaser. This philosophy assists us 
to stay closer to and actively manage 
the risks from projects generating 
emissions reductions.

Santos's emissions reduction hierarchy 
prioritises meeting our compliance 
requirements and voluntary targets via 
self-generated emissions reduction units. 
Where additional emissions reduction 
units are required to be purchased on-
market, Santos has processes in place 
requiring that only verified units – under 
a range of internationally-recognised 
registries – will be purchased and utilised 
for emissions reduction purposes. During 
2024, Santos only purchased ACCUs, 
which are accredited by the Australian 
Clean Energy Regulator.

Direct air capture

atmosphere. By capturing CO2 from the 
atmosphere and then storing it through 
CCS, DAC provides a potential pathway 
to offset unavoidable CO2 emissions 
or remove legacy emissions from the 
atmosphere. 

The IEA1 forecasts DAC is needed 
to capture 85 million tonnes of CO2 
(MtCO2) in 2030, and 980 MtCO2 in 
2050. Currently, DAC technology is in its 
nascent stages, with a limited number 
of facilities operating globally. Reaching 
IEA’s forecasts involves overcoming 
challenges in technological maturity, 
energy requirements, commerciality and 
scalability.

Development of DAC technology has 
the potential to be a key contributor to 
Santos’ net-zero 2040 target and would 
be consistent with the technology-based 
approach we have taken to date. DAC 
provides an alternative to CO2 transport 
options, with the potential to unlock the 
full CCS capability of Santos’ existing 
hub assets, particularly those far from 
emissions sources. DAC could also 
provide CO2 feedstock for low carbon 
fuels such as synthetic gas. 

Santos is focusing on DAC technologies 
with credible potential to achieving a 
lifecycle cost of capture of less than 
US$100/tCO2.2

Since 2021, Santos has partnered 
with the CSIRO to conduct a field 
demonstration of DAC utilising 
CarbonAssist™ technology. The first unit 
was initially trialled in Perth and then 
moved to a location close to Santos' 
Moomba CCS site. Commissioning of 
the first 0.25 tonne per day unit was 
completed in Q3 2023. Testing continued 
in 2024 with learnings and modifications 
incorporated throughout. In addition, 
Santos has progressed early feasibility 
studies and engineering work with 
multiple DAC vendors for additional field 
trials in the Cooper Basin. Outside of 
Australia, Santos has received a grant 
from the United States Department of 
Energy (US DOE) to progress research 
on the use of DAC in Alaska.

Point source capture

DAC is a technology designed to 
capture carbon dioxide directly from the 

Point source capture involves the 
separation and concentration of CO2 

Global policy support
Globally, policy support is gaining 
momentum for DAC technology 
development. Santos, as part of a 
Consortium in Alaska, was awarded 
federal funding to conduct a feasibility 
study of DAC technologies in the Arctic 
as part of the US DOE's Regional DAC 
Hubs program. 

United States: 

Canada:

•  2022: Inflation Reduction Act (IRA), 
increases 45Q tax credit to US$180/t 
CO2 captured for storage via DAC, 
with a capture threshold as low as 1 
kt CO2/year.

•  2023: US$3.5 billion funding for 
Regional DAC Hubs Program.

•  2022: Budget proposed investment 

tax credit for CCUS projects between 
2022 and 2030, valued at 60% for 
DAC projects when CO2 is stored at 
an eligible permanent sequestration 
site, i.e. Paris Agreement, IPCC 
Special Report: Global Warming 
of 1.5 degrees celsius.

1 

2 

 IEA Net Zero Emissions by 2050 Scenario: iea.org/reports/direct-air-capture-2022.

 US$100/tCO2 is the target set by the US DOE. Many vendors have adopted this as their goal with some aiming to achieve this by 2035. The target also roughly 
aligns with Japan METI’s synthetic gas 2030 target of US$20/mmbtu, if it is assumed that US$100/tCO2 DAC credits offsets LNG’s Scope 1, 2 and 3 emissions. 

87

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDelivering on our Climate Transition Action Plan
(continued)

from exhaust gases generated by the 
combustion of fuel. The technology 
is based on proven techniques used 
in hydrocarbon processing industries 
for decades and can be retrofitted to 
existing plant and equipment, providing 
opportunities for CO2 capture. 

Santos is working with one of Australia’s 
leading industrial gases companies on 
a project to capture CO2 emissions 
from its Wilga Park power station 
for beneficial use. The purified CO2 
is intended to be used to service the 
growing demand on the east coast of 
Australia for food and beverage, water 
treatment, manufacturing and medical 
sectors.

Value chain collaboration
Santos' Scope 3 emissions are the 
indirect emissions generated though 
our value chain. To better understand 
and quantify our Scope 3 emissions, we 
have worked to develop insights on the 
emissions generated by our customers 
and suppliers and their efforts to reduce 
these emissions. To progressively reduce 
our Scope 3 emissions, it is critical that 
we investigate joint emissions-reduction 
opportunities and collaborate on those 
economically viable for both parties. 

With this in mind, in 2024 we undertook 
further detailed analysis of our most 
material upstream and downstream 
emissions. Through this assessment we 
identified that our customers continue to 
comprise most of our Scope 3 emissions 
(approximately 85 per cent) with 
suppliers and other sources comprising 
15 per cent. 

2024 performance highlight
In 2024, Santos contacted over 180 suppliers to request information on their 
Scope 1 and 2 emissions data (Santos Scope 3).

Results of this engagement indicate that suppliers are:

•  at varying levels of maturity in their approach to quantifying and reporting 

emissions

•  open to collaboration on cost-effective emissions reduction initiatives

•  seeking to differentiate themselves from competitors by investigating and 

adopting new emissions reduction processes and practices.

Through this process, we have deepened our understanding of our suppliers' 
Scope 1 and 2 emissions and the opportunities available to reduce emissions 
across our value chain. In 2025 we will seek to formalise and enhance our 
processes for engaging our suppliers on their emissions and emissions 
reduction targets.

Our gas and LNG customers of today 
will be the low carbon fuels customers 
of tomorrow as they are increasingly 
seeking lower carbon products and 
carbon management services. To meet 
this future demand, Santos aims to 
provide decarbonation solutions to our 
customers.

While all discussions with customers 
remain commercial-in-confidence until 
agreements are executed, examples of 
some opportunities explored with our 
customers in 2024 include:

•  CCS studies with multiple steel and 

fertiliser manufacturers

• 

low carbon fuel joint study with 
international energy consumers

•  negotiations for third-party CCS 
solutions for LNG customers.

To better understand how our supplier 
emissions and their individual emissions 
reduction pathways support our 
emissions reduction efforts, in 2024,  
we directly approached approximately 
180 suppliers and requested Scope 1 and 
Scope 2 emissions data. 

Santos is currently exploring 
enhancements to our procurement 
framework to strengthen sustainability 
and emissions reporting within our 
supplier tendering and selection 
processes. This aims to improve the 
mechanisms by which suppliers can 
report their emissions and convey the 
valuable work they are individually 
undertaking to reduce emissions and 
address sustainability more broadly.

The incorporation of sustainability and 
emissions data into Santos’ broader 
procurement processes and systems 
is a complex space. We also have the 
capacity to embed greenhouse gas 
emissions data collection and reporting 
into our future procurement framework. 
These initiatives are part of a plan to be 
rolled out supporting our ability to report 
progress on our Scope 3 emissions 
reduction plan.

Our customers

Our suppliers 

Santos continues to work with our LNG, 
liquids and domestic gas customers to 
reduce the emissions generated from 
downstream use of these products. 

Building on our work in 2023, in 2024 
we expanded our customer engagement 
across all product sectors to directly 
test our current understanding of the 
way in which they use and process our 
products. This approach provided an 
understanding of how our products 
contribute to reaching customer 
emissions targets, and how customer 
emissions reduction pathways support 
Santos’ Scope 3 downstream medium- 
and long-term targets. This process 
also helped to uncover new options for 
collaboration with our customers.

Santos’ procurement specialists maintain 
effective working relationships with our 
suppliers across all aspects of Santos’ 
business. Our specialists regularly 
discuss opportunities with suppliers that, 
through the provision of certain goods 
and services and emissions reduction 
initiatives, have the potential to reduce 
emissions within our supply chain. 

Santos’ supplier emissions reduction 
initiatives implemented during 2024 
include:

•  Collaborating with a LNG vessel 

owner in a trial of additional cooling 
technology on vessels. Initial testing 
in 2024 delivered a 16 per cent 
emissions reduction for the LNG 
vessel (3.8 kt CO2e). On an annualised 
basis it is anticipated this will deliver 
emissions reductions of 39 per cent 
on all voyages, approximately 24 kt 
CO2e.

88

Santos Annual Report 2024Targets and metrics

Santos recognises the scientific consensus of climate change assessed by the IPCC. We support the objective of the Paris 
Agreement to limit global temperature rise to less than 2 degrees Celsius and pursue efforts to limit the temperature rise to 
1.5 degrees Celsius. 

The Board, supported by the Safety and Sustainability Committee, oversees the setting and monitoring of targets, including 
emissions reduction ambitions, targets and metrics related to climate-related risks and opportunities through the annual 
strategy-setting process. Reviewing and monitoring of targets is addressed at least annually through performance updates 
to the Safety and Sustainability Committee.

EY provided limited assurance over Santos’ CTAP, in accordance with the Principles of the TCFD Recommendations, 
including the methodology for setting targets.

Change in targets

Scope 2 emissions are determined by the local energy grids from which we draw electricity supply. According to 
government projections, these energy grids are not expected to be fully decarbonised by 2040. As a result, Santos has 
revised our Scope 2 net-zero emissions target from 2040 to 2050. This change is generally consistent with the Net Zero 
targets of the majority of jurisdictions where we operate. Santos intends to identify opportunities to secure renewable-
generated electricity for our operations, where economically feasible, and will continue to monitor whether this target can 
be achieved earlier. For further information, refer to our Scope 1 and 2 emissions reduction plan on page 74.

Detail
Target set in 2018. Applies to gross operated 
emissions from all Cooper Basin and 
Queensland assets from the delivery of a 
suite of operational efficiency projects.

Metric1, 2
At least 295,000 tonnes of 
emissions reduction delivered 
through Energy Solutions 
projects by year-end 2024.

Progress during  
2024 and status  
as at 31 Dec 2024
Completed in 2022.

See our 2023 Climate Report 
for further detail on achieving 
this target.

Target1

Target to reduce 
emissions across 
the Cooper Basin 
and Queensland  
by more than  
5%.

5
2
0
2

Target to grow  
LNG exports to  
at least 4.5 Mtpa. 

Economically reduce emissions by more than 
5% across operations in the Cooper Basin and 
Queensland from the 2016-17 fixed baseline 
of 5,875 kt of gross operated CO2e by 2025.

Target set in 2018. Applies to the equity share 
of LNG exports from our entire portfolio. 
Grow LNG exports to at least 4.5 Mtpa  
by 2025.

Over 4.5 Mtpa of LNG 
exports by year-end 2024.

Completed in 2021 and 
maintained through to present.

Target to assess/
invest in CCS.

Target set in 2018. Assess the feasibility and 
invest in technology and innovation that can 
deliver a step-change in emissions by 2025.

FIDs on Moomba CCS project 
by year-end 2024.

Target to reduce 
Scope 1 and 2 
emissions by  
30%.

Target set in February 2022. Applies to 
Santos’ entire post-Oil Search merger 
portfolio on an absolute and equity share 
basis.

0
3
0
2

Target to reduce 
Scope 1 and 2 
emissions intensity  
by 40 per cent.

30% Scope 1 and 2 emissions reduction by 
2030 from the combined Santos and Oil 
Search 2019-20 financial year baseline of 5.9 
MtCO2e, adjusted for inclusion of the Bayu-
Undan and Darwin LNG assets for the full 
2019-20 financial year at 68.4% equity.

Target set in February 2022. Applies to Santos’ 
entire post-Oil Search merger portfolio on an 
absolute and equity share basis. Intensity is 
calculated by dividing Scope 1 and 2 equity 
share emissions by equity share of production 
over the same period. 40 per cent emissions 
intensity reduction by 2030 from Santos’ 2019-
20 financial year baseline of 55 ktCO2e/mmboe 
adjusted for inclusion of the Bayu-Undan and 
Darwin LNG assets for the full 2019-20 financial 
year at 68.4 per cent equity.

Net equity Scope 1 and 2 
emissions of 4.1 MtCO2e 
or less by year-end 2029 
(for the reporting period 
commencing 1 January 
2030), including by direct 
abatement and offsetting. 

Net equity Scope 1 and 2 
emissions of 33 ktCO2e/
mmboe or less by year-end 
2029 (for the reporting 
period commencing 1 January 
2030), including by direct 
abatement and offsetting. 

See our 2022 Climate Report  
for further detail on achieving 
this target.

Completed in 2021.

See our 2022 Climate Report  
for further detail on achieving 
this target.

Our CTAP provides a potential 
pathway we are following to 
achieve our 2030 targets. Refer 
to the Delivering on our CTAP 
section of this report for further 
details.

As of 31 December 2024 we 
have reduced our net equity 
Scope 1 and 2 emissions by  
1.5 Mt as compared to our 
2019-20 baseline, representing 
over 80 per cent achievement 
of our targeted reduction. Our 
net equity emissions intensity 
is approx. 50 ktCO2e/mmboe, 
representing 23 per cent 
achievement of our 2030 target 
from our 2019-20 baseline. 

89

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationTargets and metrics
(continued)

Target1

Target to reduce 
customers’ 
emissions 
(Santos Scope 
3) by at least 
1.5 MtCO2e pa 
from the supply 
of low carbon 
fuels and carbon 
management 
services.
Achieve near-
zero methane 
emissions.

Detail
Target set in 2022 and updated in 2023. 
Santos will actively work with new 
and existing customers to reduce their 
emissions by at least 1.5 Mt of CO2e per 
annum by 2030 through the supply of low 
carbon fuels and carbon management 
services.

Target set in 2023. Santos aims to achieve 
near-zero methane emissions intensity 
from our operations by 2030.

Metric1, 2
Demonstrable sustained 
displacement of customer 
emissions of 1.5 Mt of 
CO2e per annum or 
greater by year-end 2029 
(for the reporting period 
commencing 1 January 
2030), from the supply 
of low carbon fuels and 
carbon management 
services. 
Methane emissions 
intensity, measured as 
gross operated methane 
emissions divided by gross 
volume of marketed natural 
gas, of less than 0.20% 
for the reporting period 
commencing 1 January 
2030.3 

Achieve zero  
routine flaring.

Target set in 2023. Where economically 
viable, Santos will avoid routine flaring 
in new oil field developments and end 
routine flaring at existing oil facilities by 
2030.

Routine flaring at Santos’ 
operated oil assets will 
be eliminated where 
economically viable by  
1 January 2030.4

Target net-zero 
Scope 1 emissions.

Target set in 2021. Net-zero Scope 1 
emissions by 2040.

Net equity Scope 1 
emissions of net-zero 
by year-end 2039 (for 
the reporting period 
commencing 1 January 
2040), including by direct 
abatement and offsetting. 

0
4
0
2

0
5
0
2

Store ~14 million 
tonnes (gross) of 
third-party CO2e  
per annum.5

Target set in 2024. 

Target to build and operate a commercial 
carbon storage business, safely and 
permanently storing at least 13.65 million 
tonnes of third-party CO2e per annum.

Establish a carbon storage 
business which sequesters 
13.65 million tonnes of 
third-party CO2e per 
annum (gross) by  
31 December 2030.

Target of net-zero 
Scope 2 emissions.

Target revised in 2024. Net-zero Scope 2 
emissions by 2050.

Net equity Scope 2 
emissions of net-zero 
by year-end 2049 (for 
the reporting period 
commencing 1 January 
2050), including by direct 
abatement and offsetting. 

Progress during  
2024 and status  
as at 31 Dec 2024
Santos is working with 
our customers to identify 
opportunities to provide 
carbon management services. 
Refer to the Value chain 
collaboration section of this 
report for further details.

Our methane emissions 
intensity in 2024 was 0.16%. 
During 2024 the start-up 
of Moomba CCS mitigated 
approximately 21 per cent 
of our methane emissions 
during Q4 2024. Santos 
continues to focus on our 
methane emissions. Refer to 
Our approach to methane 
emissions for further details.
During 2024, Santos created 
a plan for zero routine 
flaring implementation. 
An implementation plan to 
address routine flaring is now 
being rolled out. 
Our CTAP provides a 
potential pathway we are 
currently following to allow 
us to achieve our 2040 
net-zero target. The CTAP 
is periodically reviewed 
and refined to adapt to 
developments in technology, 
science, markets, customer 
needs and demands, policy 
and experience. Refer to 
the Delivering on our CTAP 
section of this report for 
further details.

Santos continues to achieve 
portfolio emissions reduction 
as outlined in our progress 
to 2030 emissions reduction 
targets. 
During 2024 Santos 
continued to explore 
additional sources of 
CO2 from domestic and 
international third parties 
to underpin development 
of our third-part CCS 
storage projects. Refer to 
the Delivering on our CTAP 
section of this report for 
further detail.
Santos' Scope 2 emissions 
will decarbonise at the pace 
of the energy grids where 
we operate, which includes 
Australia, the USA, and PNG. 

1 

2 

 Quantitative targets are absolute metrics, except for ‘Target to reduce Scope 1 and 2 emissions intensity by 40 per cent’ and 'Achieve near-zero methane 
emissions', which are intensity targets.

 The metrics by which Santos measures achievement of our targets have been reviewed and updated during 2024 to improve transparency. Our targets and our 
potential pathways to achieve them remain unchanged.

3  Methane emissions intensity metric calculation and target aligns with the OGCI's 'Aiming for Zero' initiative, of which Santos is a signatory.

4  Aligns with the World Bank's Zero Routine Flaring initiative, of which Santos is an endorser.

5  Refer to 'important notices' at the front of this report for further information about this target.

90

Santos Annual Report 2024Climate risk management

The Board has ultimate responsibility for reviewing the Company’s Risk 
Management Framework to ensure that it is sound and that management 
is operating with due regard to the risk appetite set by the Board. 

Risk identification 

Santos takes an enterprise approach 
to risk management and operates 
under one Risk Management 
Framework for all risks, including 
climate-related risks. Our Risk 
Management Framework requires 
the identification and management 
of risks to be embedded in business 
activities and provides requirements 
and guidance on the tools and 
processes to manage risks. This 
enables risks that threaten the delivery 
of our Vision, Purpose and objectives 
to be effectively managed, including 
those related to climate.

To assess climate-related risks (as for 
all risks assessed through the Risk 
Management Framework), we use 
internal stakeholder engagement 
and current and emerging threat 
reviews. We use qualitative and semi-
quantitative criteria through a Risk 
Matrix, which considers the likelihood 
(by reference to timeframes) and 
severity of potential impacts by 
estimating the worst-case scenario 
in terms of damages and financial 
loss. This assessment results in the 
definition of a risk level that informs 
the prioritisation of climate-related 
risks (and all other risks), which are 
reviewed annually with risk owners 
for alignment with Santos' enterprise-
wide risks. 

To further support the consideration 
of climate, Santos maintains a Risk 
Appetite Statement, that enables 
emissions to be considered in 
decision-making processes and is 
reviewed at least annually for ongoing 
alignment with strategic objectives. 

This assists Santos in prioritising and 
understanding the significance of 
climate-related risks in relation to 
other risks.

The ongoing monitoring of climate-
related risks is embedded into 
business activities through the 
SMS, which sets the mandatory 
requirements for how we manage 
and operate the business. This 
includes a Risk Management 
Standard that sets out the detailed 
requirements and tools to identify 
and manage risks. Risk owners 
must assess climate-related risks, 
considering potential impacts across 
assets and communities and verify 
the effectiveness of controls in 
managing these risks.

Executive management and the Audit 
and Risk Committee regularly review 
the enterprise-wide risks, new or 
emerging risks, and the risk controls 
and mitigations that management has 
put in place in relation to those risks.

There have been no major changes to 
our risk management process from the 
prior year.

Climate risks

Climate risks and opportunities 
are separated into those relevant 
to the physical operations of the 
business, and those which impact the 
business model. There are significant 
differences in the drivers and 
outcomes associated with these which 
include:

•  temperature

•  macro-economic factors

•  consumer behaviours.

Climate-related physical risks 

Risks resulting from climate 
change that can be event-driven 
(acute physical risk) or from 
longer-term shifts in climatic 
patterns (chronic physical risk).

Climate-related transitional 
risks

Risks that arise from efforts 
to transition to a lower carbon 
economy. Transition risks include 
policy, legal, technological, 
market and reputational risks.

It is established that with higher 
global temperatures driven by climate 
change, the likelihood of extreme 
weather increases. Physical risk is 
highest in these scenarios. This is in 
contrast to transitional risks, where 
a focus on constraining temperature 
rise leads to high levels of business-
related risks. Santos therefore utilises 
different scenarios to analyse these 
risk categories.

Santos has performed an analysis of 
our exposure, impacts and potential 
mitigating responses to both 
transitional and physical climate risks. 
This has included consideration of a 
range of climate scenarios to assess 
the impact on our business model. 

Further details of Santos’ Risk 
Management are disclosed on page 
143. This section provides additional 
information on our process to identify, 
assess, prioritise and monitor climate-
related risks.

91

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationClimate risk management
(continued)

Climate-related risks and opportunities: Transitional risks and opportunities

Some of our climate-related transitional risks may become opportunities, through mitigations and adaptation. These are 
summarised in the table below. Our strategy and CTAP are based on managing climate-related risks and leveraging climate-
related opportunities. Assessment of time horizons is based on internal planning horizons used to support decision-making.

Santos has established internal capabilities to tackle the challenges, and identify and leverage the opportunities arising 
from climate change. Santos has a CTAP that will continue to evolve based on factors including developments in 
technology, science, markets, customer needs and demands, policy and experience over time. Refer to the CTAP section for 
further detail. 

Transitional risks

Risk type

Policy 

Climate-related risk
Adverse climate-
related policy and/or 
regulatory decisions 
that restrict or prevent 
development of key 
strategic projects 
(existing/new)  
or prevent or limit 
production.

Related material 
business risk (MBR): 
Project development.

Potential impacts
Impacts on operating  
costs/revenue:

•  deferred revenue from 

delayed project startups

• 

• 

increased taxation

increased operating 
costs through the cost of 
compliance

•  policy uncertainty 

undermines Santos’ value/
share price/investors.

Impacts on capital 
expenditure:

• 

increased expenditure on 
purchase and installation of 
low emitting equipment at 
our facilities.

Legal

Climate-related 
litigation.

Impacts on operating  
costs/revenue:

Related MBR: 
Litigation and 
disputes.

•  change to delays and / 
or denial of regulatory 
approvals which could 
have project schedule 
implications

•  payments of legal fees, 

fines, penalties, settlements 
or compensation.

Key time horizon

S

M

L

Potential mitigations  
and controls
•  government engagement 

plans

•  energy regulator 
engagement

•  community engagement 

plans

•  policy stakeholder 

engagement

•  media engagement

•  stakeholder engagement

• 

industry advocacy.

•  experienced cross-

functional legal team that 
monitors and manages 
potential and actual claims, 
actions and disputes

•  Santos policies including 
the Code of Conduct

•  avoiding litigation through 
proactive engagement 
with regulators and other 
stakeholders.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

MBR referers to material business risk. For further details on these risks, refer to the Directors Report.

92

Santos Annual Report 2024Key time horizon

S

M

L

Potential mitigations  
and controls
•  CTAP

•  funding and disciplined 

capital allocation to CTAP 
projects

•  ODP for successful delivery 

of projects

•  technology trials, building 
a portfolio of potentially 
viable technologies

•  disciplined low-cost 
operating model

•  portfolio optimisation 

including scenario analysis 
and long-term planning.

•  disciplined low-cost 
operating model

•  Santos' three-horizon 

strategy

•  balanced revenue streams

•  portfolio diversification

•  pursuit of future income 

streams from products and 
services that are attractive 
to consumers

•  potential to develop a 

portfolio of low carbon 
fuels opportunities to meet 
future customer needs and 
maintain investor support 
and access to capital.

•  disciplined low-cost 
operating model

•  Treasury Financial Risk 
Management Policy

•  adequate liquidity.

Risk type

Technology

Climate-related risk
Transition 
technologies 
to support 
decarbonisation may 
not be developed or 
economically scalable.

Related MBR: Project 
development.

Market

Market

Reduced demand 
for Santos’ oil, gas, 
LNG and other 
products due to either 
demand decreasing 
or transition to lower 
carbon products 
which Santos can’t 
compete with on 
price. 

Related MBR: 
Volatility and market.

Reduced access to 
capital markets due to 
increasing concerns 
about the negative 
effects of climate 
change.

Related MBR: Access 
to capital and liquidity.

Potential impacts
Impacts on operating  
costs/revenue:

•  higher costs to manage 

emissions reductions and 
meet targets

•  market loss/limited return 

on investment

• 

impacts on capital 
expenditure

•  higher capital expenditure 
required to meet emissions 
reductions and targets.

Impacts on operating  
costs/revenue:

•  free cash flow decline

• 

lower revenue from lower 
commodity prices reduces 
useful life 

• 

increased cost of capital.

Impacts on capital 
expenditure:

•  unable to execute desired 

backfill and sustain 
program without drawing 
down additional debt and 
increasing gearing above 
stated limit.

Impact on capital expenditure:

• 

increased cost of capital 
and reduced access to 
risk transfer via insurance 
markets

•  reduced capacity and/

or willingness for banks 
to provide finance 
accommodation

•  diversification of income 

streams and from portfolio 
of core assets.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

93

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationClimate risk management
(continued)

Climate-related risk
Risk type
Reputational Santos’ approach to 
decarbonisation and 
emissions targets 
are not aligned 
with stakeholder 
expectations.

Related MBR:  
Climate change.

Reputational Santos fails to achieve 

net-zero Scope 1 by 
2040 and net-zero 
Scope 2 by 2050. 

Related MBR: Climate 
change.

Potential impacts
Impacts on operating  
costs/revenue:

• 

• 

increased cost of capital 
and insurance

increased operating 
costs through the cost 
of compliance operating 
above baselines

•  government engagement 

and advocacy.

Impacts on capital 
expenditure:

•  higher capital expenditure 
required to meet emissions 
reductions and targets

•  reduction in capital 

availability.

Reputational Environmental and/or 
shareholder activism. 

Impacts on operating  
costs/revenue:

Related MBR: 
Litigation and 
disputes.

•  projects are delayed 
or blocked leading to 
decreased cashflows and 
increased costs through 
lawfare and lobbying

•  higher business costs 

from increased regulatory 
burden and delays in 
securing and executing  
on project approvals

• 

• 

impacts on capital 
expenditure

increased cost of capital 
and reduced access to 
risk transfer via insurance 
markets

•  decreased ability to raise 

debt and equity

•  shareholders withdraw 
investment from Santos.

Key time horizon

S

M

L

Potential mitigations  
and controls
•  climate and sustainability 

reporting

• 

investor, fund and bank 
engagement strategy

• 

industry advocacy.

•  CTAP

•  asset emissions controls

•  Santos Midstream and 
Energy Solutions and 
multiple hub structure

•  technology trials, building 
a portfolio of potentially 
viable technologies

•  disciplined low-cost 
operating model.

•  activist engagement and 

management plans

•  stakeholder consultation 
and engagement plans

• 

• 

investor relations strategy

land access and 
consultation processes

•  disciplined low-cost 
operating model.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

94

Santos Annual Report 2024Risk type

Reputational

Climate-related risk
Inability to attract and 
retain key Executives 
and personnel due 
to Santos’ perceived 
role in the energy 
transition.

Related MBR: 
Workforce.

Potential impacts
Impacts on operating  
costs/revenue:

•  decreased productivity or 
increased cost of labour as 
employees choose other 
industries

•  projects not advancing 

and workforce reduction, 
reduction of decent work 
and quality jobs.

Transitional opportunities

Opportunity 
type
Technology Transition technologies 

Climate-related 
opportunity

to support third-
party decarbonisation 
and development of 
low carbon fuels are 
economically scalable. 

Related MBR: Project 
development.

Market

 Santos meets increased 
demand for lower 
carbon energy at a 
competitive price point.

Related MBR: Volatility 
and market.

Potential impacts
Impacts on operating  
costs/revenue:

• 

• 

 lower costs to manage 
emissions reductions and 
meet targets

increased revenue due 
to increased demand for 
Santos’ lower carbon energy.

Impacts on capital expenditure:

• 

lower capital expenditure 
required to meet emissions 
reductions and targets.

Impacts on operating  
costs/revenue:

• 

increased revenue due 
to increased demand for 
Santos’ lower carbon energy.

Key time horizon

S

M

L

Key time horizon

S

M

L

Potential mitigations  
and controls
•  Employee value proposition

•  workforce capability plans

•  development programs 

and pipeline of new talent 
supply

•  talent and succession 

processes

•  employee engagement 
surveys and response

•  performance management

•  capability acquisition and 

targeted recruitment

•  competitive remuneration 

and rewards

•  Company ESG strategy.

Potential responses to 
opportunity
•  CTAP

•  funding and disciplined 

capital allocation to CTAP 
projects

•  ODP for successful delivery 

of projects

•  technology trials, building a 

portfolio of potentially viable 
technologies

•  disciplined low-cost 
operating model.

•  disciplined low-cost 
operating model

•  CTAP

•  funding and disciplined 

capital allocation to climate 
transition

•  pursuit of future income 

streams from products and 
services that are attractive 
to consumers.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

95

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationClimate risk management
(continued)

Climate-related risks: Physical risks

We identified potential financial impacts to our business associated with climate-related physical risks through internal 
stakeholder engagement across our global portfolio, and associated desktop research. Through climate scenario analysis, 
we assessed how these impacts may evolve into the future. This dual approach of stakeholder engagement and scenario 
analysis has helped us determine the regions with the largest future exposure over short-, medium- and long-term time 
horizons. 

Based on the scenario analysis outcomes from now to 2050, we developed inherent and residual risk ratings for climate-
related risks to support risk management. We engaged stakeholders from each operating region and assessed the 
likelihood and financial consequence of physical and climate-related risks using the Santos Risk Matrix. The time horizons 
reflect when the hazards, based on their risk likelihood, could reasonably be expected to impact our assets in these regions. 

The table below summarises the physical risks that our assessment indicates could have an impact on our producing 
operated assets.

Time horizon

S

M

L

Potential mitigations  
and controls
•  equipment designed, 

operated and maintained 
for operating environment

•  experience with operating 

in extreme heat.

•  rainfall and flood 

preparedness plans 

•  Return to Plan procedure

•  supply chain and logistics 

contingency plans.

•  Emergency Response Plans 

•  bushfire management 

program

•  vegetation management.

•  maintain network of 

weather stations on sites to 
monitor conditions

•  established operating limits 

and triggers for safety 
procedures during adverse 
weather.

•  equipment designed for 
operating environment

•  weather monitoring and 
logistic coordination.

Risk 
type

Climate-
related  
risk (hazard)

Acute Extreme 

heat

Operated assets 
with largest future 
exposure (scenario 
analysis)
Cooper Basin

WA NA and TL

PNG

Extreme  
rain

Cooper Basin

QLD and NSW 

PNG

Bushfires

QLD and NSW

Cyclones

WA NA and TL

Potential impacts
Impacts on operating  
costs/revenue:
•  decreased production 
from lower equipment 
performance

• 

increased energy 
consumption for 
additional cooling 
requirements.

Impacts on operating  
costs/revenue:
•  delayed/decreased 

production from wells 
shut-in 

• 

increased transport and 
logistics costs. 

Impacts on operating  
costs/revenue:
•  delayed/decreased 

production from wells 
shut-in, power outages

•  physical asset damage.

Impacts on operating  
costs/revenue:
•  delayed/decreased 

production from some 
assets shut-in 

•  physical asset damage.

Storm surge WA

PNG

Cooper Basin  
(Pt. Bonython)

Impacts on operating  
costs/revenue:
•  reduced ability of tankers 
to enter ports leading to 
operational disruptions

•  physical asset damage.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

96

Santos Annual Report 2024Time horizon

S

M

L

Risk 
type

Climate-
related  
risk (hazard)

Chronic Temperature 
rise

Operated assets 
with largest future 
exposure (scenario 
analysis)
Cooper Basin

QLD and NSW

WA NA and  
Timor-Leste

Sea level rise WA

PNG

Cooper Basin  
(Pt. Bonython)

Drought/
extreme dry

WA

QLD and NSW

Potential impacts
Impacts on operating  
costs/revenue:
•  decreased production 
from lower equipment 
performance

• 

increased energy 
consumption for 
additional cooling 
requirements.

Impacts on operating  
costs/revenue:
•  reduced ability of tankers 
to enter ports leading to 
operational disruptions

•  physical asset damage.

•  water stress impacts 
on water-intensive 
operations.

Potential mitigations  
and controls
•  equipment designed, 

operated and maintained 
for operating environment

•  experience with operating 

in extreme heat.

•  equipment designed for 
operating environment

•  weather monitoring and 
logistic coordination.

•  wells produce water 
that can be collected 
and beneficially re-used 
(QLD and NSW)

•  access to multiple 
water sources.

Refer to page 107 for information on physical climate risk for new projects, including a case study for Pikka phase 1.

S = Short (0-1 yrs), M = Medium (1-5 yrs), L = Long (5-30 yrs)

97

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience 
and scenario analysis

Santos' portfolio has been tested and shows resilience in an 
energy transition that limits the global temperature increase 
to 1.5 degrees Celsius.

Santos has performed an 
analysis of our exposure, 
impacts and potential 
mitigating responses 
to both transitional 
and physical climate 
risks. This has included 
consideration of a range 
of climate scenarios to 
assess the impact on our 
business model. Given 
the diverging nature 
of available climate 
scenarios, there are 
differing levels of physical 
and transitional risks 
inherently associated 
with each.

Introduction to scenario analysis
Climate scenarios are possible 
outcomes across the temperature, 
technological and behavioural 
spectrum. It is important to note that 
they are not forecasts, but potential 
future climate states based on sets 
of assumptions around changes in 
global behaviour, including energy 
supply and demand. They represent 
options for what could happen 
given specific sets of circumstances. 
At this stage, it is not possible to 
conclusively determine to what extent 
these scenarios will eventuate. This 
lack of certainty is a key reason why 
analysis of resilience against a range 
of scenarios is necessary.

Forward-looking estimates of 
temperature changes are inherently 
uncertain. Likewise, macroeconomic 
forecasts for energy transition 
scenarios continue to be volatile as 
views of potential global pathways 
evolve. Variations in these scenarios 
can create shifts in cashflow outcomes 
year-on-year. Santos will continue to 
reference a variety of scenarios within 
our strategic planning framework.

The Board and management 
continually assess strategic options 
and evaluate the current and future 
mix of assets within our portfolio. 
While our asset and project 
composition is optimised for the 
current operating environment, should 
any of the tested scenarios eventuate, 
our portfolio retains flexibility to 
respond to such changes.

We test our strategy to determine 
our resilience to a range of potential 
climate future states. Santos evaluates 
the resilience of our portfolio with 
reference to both quantitative and 
qualitative factors.

The operating environment and 
government policies in relevant 
jurisdictions are continually shifting 
and materially different to all 
scenarios considered. The Board 
and management team regularly 
review Company strategy and 
make necessary adjustments to 
maximise value and control risks for 
shareholders and other stakeholders. 
Scenario analysis is a tool in the 
strategic assessment and alignment 
process. We set our strategy 
according to prevailing circumstances 
and our best forecast of the future. 

98

Santos Annual Report 2024Transitional risk scenario analysis
Purpose and background

The energy transition poses a unique set of risks and opportunities for energy businesses. Changes in energy preference, 
demand patterns and prices are expected to drive fluctuations in cashflow derived from our business. Transitional risk 
scenario analysis is intended to support our understanding of Santos’ resilience in the given scenarios. Macroeconomic 
forecasts for energy transition scenarios continue to be volatile as views of potential global pathways evolve, which can 
create shifts in cashflow assessment outcomes year-on-year. Santos will continue to reference a variety of scenarios, 
including macroeconomic forecasts, within our strategic planning process.

The Company intends to unlock value from both traditional revenue streams and through emerging opportunities, which we 
will seek to develop as the world seeks to meet its emissions reduction goals. Santos continues to make significant progress 
on projects across all areas of our CTAP. These projects are decarbonising our business and creating the opportunity for 
new businesses that will contribute to the resilience of Santos’ strategy and business model. Further information relating to 
progress on Santos’ CTAP projects can be found in the Delivering on our CTAP section.

Santos notes that both the IEA and S&P Global acknowledge that their scenarios represent potential pathways – not 
definitive pathways – to limiting global temperature increase to 1.5 degrees Celsius, and that the world is not currently on 
these pathways.

Methodology

Santos’ portfolio has been tested to assess resilience through the energy transition, under both current policy settings 
and in accelerated transition scenarios. We have used after-tax cashflow as a measure of resilience as it is indicative of 
our ability to fund future investments, including those required to meet our climate targets. Modelling of decarbonisation 
initiatives is based on our emissions hierarchy of avoid, reduce, offset. This means our CTAP prioritises investment in 
decarbonisation projects such as CCS that reduce carbon emissions, rather than relying on the purchase of emissions 
reduction units.

Santos’ ability to generate positive cashflow was benchmarked using our current corporate assumptions, which reflect our 
estimate of commodity price and economic assumption forecasts. This was used as a baseline, with cashflows also assessed 
using commodity prices (Brent oil, natural gas and carbon) derived from three additional scenarios. Each scenario was 
evaluated with reference to short (0–1 years) medium (1–5 years) and long-term (6–10 years), consistent with our internal 
budget and planning horizons used to support decision making.

99

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience and scenario analysis
(continued)

Temperature  
increase

Background

IEA 2024 Net Zero by 2050 
Scenario (IEA NZE 2024)
Temperature rise limited to  
1.5 degrees Celsius

Assumes significant reduction in 
energy demand, rapid upscaling 
of investment, widespread 
lifestyle changes and immediate 
emissions reduction beyond 
current trajectories.

Global actions required, including 
significant changes in consumer 
behaviour and energy demand.

S&P Global Commodity 
Insights Accelerated Carbon 
Capture and Storage Scenario 
(S&P ACCS 2024)
Temperature rise limited to  
1.5 degrees Celsius

IEA 2024 Stated Policies 
Scenario (IEA STEPS 2024)
Temperature to rise 2.4 degrees 
Celsius (well above) pre-industrial 
levels.

Global actions required, including 
changes in consumer behaviour 
and energy demand.

Global energy transition 
under current policies and 
announcements.

Assumes incentivising investment 
in CCS technology, through high 
carbon prices and regulatory 
changes.

Models the current transition 
trajectory.

Driver

Net Zero by 2050. 

Net Zero by 2050. 

Sets out a pathway for the global 
energy sector to achieve Net Zero 
CO2 emissions by 2050. It does 
not rely on emissions reductions 
from outside the energy sector to 
achieve its goals. Universal access 
to electricity and clean cooking 
are achieved by 2030.

Demand for hydrocarbons and 
energy is materially lower than 
today but with varied implications 
for different fuel types. Assumes 
the successful commercialisation 
of CCS technology.

Energy mix

The NZE Scenario involves a 
more complete transition with all 
fossil fuels declining from today 
to make up less than 65% of 
total energy supply by 2030 and 
around 15% by 2050. This is offset 
by a rapid increase in the volume 
in renewables and a significant 
decline in energy demand.

Fossil fuel demand begins to  
drop from 2025, accelerating 
from 2030 onwards. By 2050 
fossil fuels represent ~30% of  
total energy use.

Trajectory based on current 
policies and promises.

Reflects current policy settings 
based on a sector-by-sector and 
country-by-country assessment 
of the energy-related policies 
that are in place as of the end 
of August 2024, as well as those 
that are under development. The 
scenario also takes into account 
currently planned manufacturing 
capacities for clean energy 
technologies.

Coal demand begins to decline 
around 2025, while oil and natural 
gas demand both peak towards 
the end of the decade. After 
decades of the fossil fuel share 
of total energy supply hovering 
around 80%, it declines to 75% by 
2030 and below 60% by 2050.

Brent
US$/bbl nominal

Uncontracted LNG (DES)
US$/mmbtu nominal

Carbon
US$/tCO2e nominal

20

15

10

5

0

2030

2040

2050

600

500

400

300

200

100

0

2030

2040

2050

2030

2040

2050

IEA STEPS 2024

IEA NZE 2024

IEA STEPS 2024

IEA NZE 2024

IEA STEPS 2024

IEA NZE 2024

S&P ACCS 2024

S&P ACCS 2024

S&P ACCS 2024

200

150

100

50

0

100

Santos Annual Report 2024Assumptions

Santos’ decarbonisation strategy is based on a set of assumptions including technology feasibility assumptions, cost and 
economic viability expectations, regulation and policy uncertainty, among others. The likelihood of these assumptions and 
expectations to materialise is uncertain, and this represents risks to Santos’ ability to manage the energy transition. 

The macroeconomic assumptions used are derived from each climate scenario as detailed below.

A carbon price is applied to Australian assets operating under the Australian Safeguard Mechanism and to assets where 
Santos has made a voluntary net-zero commitment.

Macroeconomic assumptions

•  For scenario analysis, commodity price assumptions have been derived from IEA STEPS, IEA NZE and S&P ACCS scenarios.

•  The LNG price has been based on the Japanese natural gas price in the IEA scenarios and Asian term LNG in the S&P ACCS 

scenario.

•  The price of carbon for advanced economies is assumed under the IEA NZE scenario and averaged across all regions for 

the S&P ACCS and IEA STEPS scenarios.

Limitations

Santos’ scenario analysis necessarily relies on a number of assumptions, both internal (including asset working interests, 
commercial arrangements, timing of investment decisions, project maturity, and technology risk and market) and external 
(including assumed changes to macroeconomic assumptions and conditions under each scenario and government policy). A 
change in any of these assumptions could impact the results of, and conclusions drawn from, scenario analysis. Santos notes 
that both the IEA and S&P Global acknowledge that their scenarios represent potential pathways – not definitive pathways – 
to limiting global temperature increase to 1.5 degrees Celsius, and that globally we are not currently on this pathway.

101

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience and scenario analysis
(continued)

Resilience of Santos’ long-term strategy and business model to climate 
scenarios

Santos’ strategy and business model is well-positioned to adapt and manage our climate-related risks and leverage our 
climate-related opportunities. Our scenario analysis demonstrates:

•  Our portfolio remains cashflow positive in the medium to long-term across the range of climate scenarios. This includes 

the IEA NZE and S&P ACCS scenarios that are aligned with the Paris Agreement goal to limit global warming to 
1.5 degrees Celsius, demonstrating resilience of our strategy and business model. 

•  Cashflows are inclusive of decarbonisation initiatives (informed by our CTAP) to meet our 2030 and 2040 emissions 

reduction targets. This is supported by our ability to repurpose existing infrastructure and depleted reservoirs to develop 
CCS hubs adjacent to our operated assets.

IEA STEPS

The STEPS scenario reflects current energy-related policies1 and is designed to provide a sense of the direction of 
the global energy transition based on the current policy landscape. Our current strategy and business model remains 
unchanged under this scenario, with positive cashflows across all relevant timeframes. 

Cashflow remains positive across all relevant timeframes.

IEA NZE

The NZE scenario reflects one pathway to limiting global temperature rise to 1.5 degrees Celsius and is designed to 
demonstrate a significant reduction in demand for oil and gas, replaced with significant and rapid investment in renewable 
energy technology. 

This scenario forecasts lower oil and LNG commodity prices in the medium-to-long term. Santos' portfolio retains the 
flexibility to deprioritize investment in future upstream projects should such price decreases occur, resulting in overall lower 
long-term cash flow from our gas and liquids business. This impact would be partially offset by increased cashflows from 
decarbonisation and CCS projects where linked to carbon pricing.

Cashflow remains positive across all relevant timeframes.

S&P ACCS

The S&P ACCS scenario reflects one pathway to limiting global temperature rise to 1.5 degrees and is designed to 
emphasise the importance of CCS to achieve decarbonisation of the global energy system. 

This scenario forecasts higher near-term oil and LNG commodity prices, which delivers higher cashflows in the medium-
term, followed by a period of lower commodity prices. The long-term commodity price forecasts support moderate 
investment in upstream projects, and cashflows from decarbonisation and CCS projects improve where linked to carbon 
pricing. 

Cashflow remains positive across all relevant timeframes.

1 

 The IEA STEPS scenario represented current energy-related global policies as at the date of scenario release (October 2024). It has not been updated to reflect 
subsequent changes in global policy conditions. The scenario nevertheless still represents a reasonable scenario against which to measure the resilience of 
Santos’ portfolio.

102

Santos Annual Report 2024Risks and opportunities

Climate-related physical risks are not considered as part of this scenario analysis, with the focus being the impact of the 
transition on Santos' ability to generate revenues/profits/returns for shareholders. These scenarios reflect the range of 
identified climate-related transition risks. Not all transition risks identified in the risk management section are linked to, or 
directly correlated with, the macroeconomic shifts represented by the scenarios selected for analysis. The table below is 
intended to highlight the impact of different scenarios on climate-related transition-risk profiles.

There are a variety of risks and opportunities associated with climate change, and an array of steps available to 
mitigate and capitalise upon these. Detail on these physical and transition risks can be found in the risk management 
section pages 92–97. 

Impact of 
scenario on  
level of risk

Risks

IEA NZE

 Technology

S&P ACCS

 Technology

IEA STEPS

 Technology

 Policy and legal

 Policy and legal 

 Policy and legal 

 Market

 Reputation

 Market

 Reputation

 Market

 Reputation

•  The world moves rapidly away 
from oil and gas resulting in 
significant decrease Santos’ 
upstream revenue and asset 
values due to falling prices and 
reduced demand.

•  New projects no longer receive 

funding or policy support, 
making further growth of any 
oil and gas projects practically 
impossible.

•  Funding becomes extremely 

restricted, resulting in 
significantly higher cost of 
capital for any financing needs.

•  Oil and gas usage will decrease 
and prices will depress even 
with CCS, due to increases in 
renewables and electrification 
of the energy system, resulting 
in reduced revenue from these 
operations.

•  Despite continuing demand for 
natural gas and oil, global focus 
on decarbonisation continues, 
potentially limiting access to 
capital markets.

•  Despite robust demand for 

natural gas and oil, global focus 
on decarbonisation continues, 
potentially limiting access to 
capital markets.

•  The impacts of climate change 
lead to increased physical risks, 
with extreme weather events 
becoming more commonplace.

Impact of 
scenario on  
level of 
opportunity

 Technology

 Technology 

 Technology 

 Policy and legal 

 Policy and legal 

 Policy and legal 

 Market

 Reputation 

 Market 

 Reputation 

 Market 

 Reputation 

Opportunities •  The demand growth in CCS 

•  The demand growth in CCS 

and low carbon fuels required 
to meet Net Zero targets 
in these scenarios benefits 
Santos’ infrastructure position, 
carbon storage resources, 
organisational skill sets and 
existing customer relationships.

and low carbon fuels required 
to meet Net Zero targets 
in these scenarios benefits 
Santos’ infrastructure position, 
carbon storage resources, 
organisational skill sets and 
existing customer relationships.

•  Value of emissions reduction 
units increases significantly, 
with high trust and high 
integrity emissions reduction 
units such as those from CCS 
commanding a premium.

•  Value of emissions reduction 
units increases significantly, 
with high trust and high 
integrity emissions reduction 
units such as those from CCS 
commanding a premium.

•  This scenario models strong 
demand for oil and gas 
through to 2050, which allows 
continuation of value derivation 
from natural gas and liquids 
assets in the Santos portfolio.

These risks and their implications do not represent an exhaustive list of all potential outcomes. They are intended to be 
demonstrative of the impacts which may result in each scenario.

103

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience and scenario analysis
(continued)

Physical risk scenario analysis
Purpose and background

Santos has a long operational history managing extreme weather events. Santos is exposed to physical climate-related 
risks from both acute (event-driven) and chronic (longer-term shifts) climate changes. Acute climate-related risks, such 
as extreme heat, extreme rain, bushfires and cyclones; and chronic climate-related risks from temperatures rises, including 
extreme dry, sea level rise and storm surge events could potentially impact some of our facilities, operations and supply 
chain, and potentially negatively impact our earnings, cash flows and overall financial performance. 

We identified potential financial impacts to our business associated with climate-related physical risks through internal 
stakeholder engagement across our global portfolio, and through associated desktop research. Through climate scenario 
analysis, we assessed how these impacts may evolve into the future. This dual approach of stakeholder engagement and 
scenario analysis has helped us determine the regions with the largest future exposure over short-, medium- and long-term 
time horizons. The time horizons reflect when the hazards, based off their risk likelihood, could reasonably be expected to 
impact our assets in these regions.

Based on the scenario analysis outcomes from now to 2050, we engaged stakeholders from each regional business unit and 
assessed the risk level by applying the Risk Matrix to assess likelihood and financial consequence of physical and climate-
related risks.

Methodology

In 2023, Santos engaged Deloitte to update our physical climate scenario analysis to reassess and inform the identification 
of physical climate risks. While the scenario analysis in previous years focused on individual regions and/or earlier 
generations of climate models, the 2023 assessment uses the latest climate models published by the IPCC. The climate 
scenario analysis considers three plausible and distinct Shared Socio-economic Pathways (SSPs) to assess how Santos may 
be impacted by physical risks. We compared future trends in 2030, 2050 and 2070 to the recent past. Each of the time 
horizons represented 20-year averages across the horizon to highlight climate (rather than inter-annual variability) trends.

This dataset was applied consistently to assess climate exposure across our global portfolio of operated producing assets. 
Please refer to our case study on page 107 for information about how physical climate risks were considered in the design 
of our Pikka phase 1 project in Alaska.

This process uses different types of climate scenarios to those used in the transition climate scenario analysis, as in the 
physical case, we assess physical climate hazards, as opposed to socio-economic, technology and market trends. Both 
approaches support transition planning (mitigation and adaptation) and risk and opportunity management. 

SSP1-2.6

Key scenario assumptions

1.8 degrees Celsius average 
global warming at 2100, 
associated with early and 
aggressive global mitigation.

Stringent policies and 
technological innovation help 
reach Net Zero after 2050.

Climate-related policies: Aggressive regulations limit the extraction and use 
of fossil fuels in all major economies. Greenhouse gas emissions pricing is 
implemented immediately after 2020.

Macro-economic trends: There is rapid economic growth, with an increasing 
shift toward sustainable practices. Economic value creation is not dependent 
on material consumption or energy demand.

National/regional variables: Decline in population globally, management of 
the global commons slowly improves, educational and health investments 
accelerate the demographic transition, and the emphasis on economic growth 
shifts toward a broader emphasis on human wellbeing.

Energy usage and mix: Strong decline in energy use due to technological 
development, lifestyle changes and policies supporting energy efficiency 
improvements. Renewable energy makes up a large portion of the total energy 
supply.

Developments in technology: Accelerated transition to renewables and 
electrification. Social acceptability is high for (non-biomass) renewables, but 
low for all other technologies (particularly nuclear).

104

Santos Annual Report 2024SSP2-4.5

Key scenario assumptions

2.7 degrees Celsius average 
global warming at 2100, 
associated with current global 
climate targets and pledges.

Delayed and divergent policies 
result in slow emissions 
reduction.

Climate-related policies: Global and national institutions work towards, 
but make slow progress in achieving sustainable development goals. 
Climate policies targeting emissions from fossil-fuel use and industry are 
geographically fragmented until 2020, and then converge to a globally uniform 
carbon price by 2040.

Macro-economic trends: Development and income growth proceeds unevenly, 
with some countries making relatively good progress, while others fall short of 
expectations. Income inequality persists or improves only slowly. Consumption 
is material-intensive.

National/regional variables: Transition happens faster in certain regions 
compared to others. Environmental systems experience degradation. Global 
population growth is moderate and levels out in the second-half of the century.

Energy usage and mix: While the overall global resource intensity and energy 
use declines, there is not strong reluctance to use unconventional fossil 
resources. There are no remarkable shifts in the primary energy mix and there 
is continued modernisation in the final energy mix.

Developments in technology: Technological improvements are medium for 
all technologies and social acceptance does not shift markedly from historical 
patterns. There are no fundamental breakthroughs in technology innovation.

SSP5-8.5

Key scenario assumptions

4.4 degrees Celsius average 
global warming at 2100, 
associated with limited global 
climate action.

Climate-related policies: There are delays in establishing global climate action. 
Climate policies targeting emissions from fossil fuel use and industry are 
geographically fragmented until 2020, and then converge to a globally uniform 
carbon price by 2040.

Lack of government and market 
response causes an increase in 
emissions.

Macro-economic trends: Global markets are increasingly integrated. There is 
rapid growth of the global economy.

National/regional variables: Global population peaks and declines in the 
21st century. There is high migration between countries. Local environmental 
problems like air pollution are successfully managed.

Energy usage and mix: The push for economic and social development 
is coupled with the exploitation of abundant fossil fuel resources and the 
adoption of resource and energy-intensive lifestyles globally.

Developments in technology: This world places increasing faith in competitive 
markets, innovation and participatory societies to produce rapid technological 
progress. Geo-engineering is an attractive option to lower emissions.

In 2024, we have used the 2023 climate scenario analysis findings to help integrate physical hazards into our risk register 
and summarise scenario analysis findings alongside risk ratings in the next section. The scope of this analysis was Santos’ 
producing operated assets across Cooper Basin, Queensland and New South Wales (QLD & NSW), Western Australia (WA) 
Northern Australia and Timor-Leste (NA & TL), Papua New Guinea (PNG).

105

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience and scenario analysis
(continued)

Limitations and assumptions

Climate projections are based on assumptions about future greenhouse gas emissions associated with human activity and 
other policy choices, of which the timing and impact are uncertain. The multi-model mean of 18 climate models is used in 
this assessment to smooth out biases of individual models. Business data is held constant over time.

Results

In 2024, we commenced work assessing and quantifying the potential impact of the scenario analysis as outlined above on 
our operated assets. Santos engaged Deloitte to facilitate physical climate risk assessment workshops across the business. 
Workshops were conducted at a regional level for the Cooper Basin, QLD & NSW, WA, NA & TL, PNG with the purpose of:

•  sharing the latest physical climate scenario analysis with the business

•  determining inherent and residual financial risk ratings using the Santos Risk Matrix for physical climate hazards to 2050 

at a regional level based on the latest scenario analysis

•  commenced understanding where in Santos’ value chain climate hazards may have potential financial impacts

•  forming a preliminary view of which assets and business activities are most vulnerable to physical climate risks 

by understanding climate exposure, susceptibility, potential production impacts, potential damage to assets and 
adaptability controls. 

These workshops found:

•  Physical and climate-related hazards identified by the latest scenario analysis are being actively managed by the 
regions through existing controls and adaption measures across the short (0-1 year) to medium term (1-5 years). 
These operational controls prioritise safety, including weather monitoring, preparation, emergency response plans and 
personnel trained in emergency response. There are examples of weather assumptions being factored into production 
planning, the development of operating plans and budgets, including factors such as operational interruptions caused by 
weather events such as cyclones. Operational controls designed to prevent equipment failure include regular inspection 
and maintenance routines, and maintaining inventory of critical spares. We also maintain supply chain continuity plans to 
identify, prepare for and mitigate risks, including weather events, to enable uninterrupted flow of materials and services 
to operations. Plans are focused on critical materials and services that can materially impact Santos' operations.

• 

In the longer term (5-30 years), the results of this latest assessment indicate that the frequency and severity of the 
identified climate hazards may increase in intensity and/or frequency over time. Regional business units will continue 
to monitor the potential impact of physical risk as part of the Santos Risk Management process and determine whether 
there is any need for adaptation action in the future. 

•  More specifically, our assessment to 2050 for our producing operated assets showed that:

 – For the Cooper Basin:

 –  Extreme rain and extreme heat were considered the highest climate-related risks to 2050, however based on our 

assessment at this time with our existing controls and adaptation, we don’t believe that there is a material increase 
from our current risk level.

 – Further assessment is required to understand the potential risk level of grass fires.

 – For QLD and NSW:

 –  Extreme rain is considered the highest climate-related risk to 2050, however based on our assessment at this time 
with our existing controls and adaptation, we don’t believe that there is a material increase from our current risk 
level.

 –  Further assessment is required to understand the potential risk of extreme dry and bushfires to our carbon 

projects. 

 – For WA, NA and TL: 

 –  Cyclones were considered the highest climate-related risk to 2050, however based on our assessment at this time 
with our existing controls and adaptation, we don’t believe that there is a material increase from our current risk 
level.

 –  Further detailed assessment is required to understand the risk of potential sea level rise and storm surge at our 

Varanus Island asset.

 – For PNG: 

 –  Extreme rain and extreme heat were considered the highest climate-related risks to 2050, however, based on our 
assessment at this time, with our existing controls and adaption measures in place, there is not a material increase 
from our current risk level.

 –  Storm surge and sea level rise projections are considered and actively managed as part of ongoing maintenance 

and future design of offshore infrastructure.

106

Santos Annual Report 2024Physical climate resilience for new projects 

For projects to consider physical climate risks, we have requirements for climate resilience plans to be developed as part 
of project delivery process. 

Climate resilience is a combination of preparing for risks, adapting to events and climate trends, and continuing to operate 
long term. Our projects must be planned and executed in accordance with our ODP and follow our Technical Standards 
relating to Project Controls. The ODP encompasses the opportunity identification, exploration and appraisal through to 
development, project execution, operation, and asset decommissioning or re-purposing. It serves as a Company-wide 
approach for consistency and supports the successful planning and delivery of new assets.

Santos has commenced the process of embedding the latest climate scenario assessment into the ODP to provide project 
teams with a central source for identification of physical climate-related risks for assessment. The ODP requires category 
one and two projects – projects greater than $30m total gross cost and of medium or high risk - to have climate resilience 
plans. In addition, Santos is in the process of updating our Engineering Management of Change process to require 
that considerations of future physical climate hazards in all engineering changes are connected to the latest scenario 
analysis work. 

Case study – Pikka phase 1

Our focus in Alaska is advancement of our Pikka phase 1 project, which includes a single drill site, an oil processing 
facility and other infrastructure to support production of 80,000 (gross) barrels of oil per day. As part of our ODP, 
Pikka phase 1 design components have been evaluated using the high-emissions scenario from the physical climate 
scenario analysis, including: extreme precipitation and extreme cold considerations during design and construction, 
potential temperature rise contributing to permafrost thaw and a decrease in extreme cold temperatures impacting 
work conditions and duration. 

Climate modelling projections and insights undertaken during the design phase of Pikka phase 1 shared similar future 
outlooks with the latest climate modelling projections from Deloitte. 

Several potential physical climate change considerations contributed to certain Pikka project design decisions, 
including: 

•  heat transfer from gravel infrastructure to the underlying permafrost minimised by design of gravel roads, well 

spacing, well conductor insulation with thermosyphons to maintain frozen ground conditions.

•  flood events minimised by design and location of gravel facilities, drainage and infrastructure.

107

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPortfolio resilience and scenario analysis
(continued)

Looking forward

Integrating physical climate scenario analysis findings into our corporate planning process.

Santos has a long operational history of managing weather through our operational planning process, including the use of 
historical weather-related data. To build on this, our next step is to incorporate forward-looking scenarios into our long-term 
planning process. This builds on our Risk Management Framework by embedding the consideration and quantification of 
long-term physical climate-related risks and enhance the resilience of our operations through capital allocation, as required. 

We recognise the impact of physical climate change on our operations is likely to extend beyond the boundary of our 
operational assets. 

As part of ongoing engagement with suppliers and customers, Santos has sought to understand the climate-related risks 
facing its value chain stakeholders. Through this process a significant proportion of respondents identified climate-related 
physical impacts as a key risk. This trend was consistent across the spectrum of businesses, who represent an array of 
different industries. They perceived this risk as impacting both their own operations and their ability to deliver their services 
to Santos. 

108

Santos Annual Report 2024Investor feedback  
and our response

In 2024, Santos actively engaged in 151 meetings seeking feedback from investors and investor groups on our 
decarbonisation strategy, targets and CTAP. These discussions have been pivotal in aligning our strategies with investor 
expectations and identifying key areas for growth and improvement.

The table below highlights the main themes raised by shareholders and actions we have taken, or our rationale, in response 
to their feedback.

Investor feedback

2024 report approach

Section disclosed  
in the report

CTAP 

•  Progress against our 

decarbonisation strategy

•  Details on the growth/ 

outlook of our 
decarbonisation business

•  Capital investment

The CTAP has been updated to demonstrate progress 
against our decarbonisation strategy. Information is 
provided on Santos’ current decarbonisation pathway as 
well as carbon management services to customers and 
third parties. We continue to disclose capital invested and 
potential forward-looking project investment over coming 
years for CTAP initiatives. 

Scope 1 and 2 emissions 
reduction plan 
(page 74) 

CTAP (page 80)

Capital allocation and 
governance (page 78)

This disclosure has been enhanced in 2024 to include 
a broad range of emissions reduction spend, and the 
timeline for future spend has been aligned to our planning 
timeframe. Building on previous reporting materials, 
additional disclosures are provided. This includes more detail 
on operational efficiencies and on carbon supply chains.

Scope 3 emissions

•  Breakdown of how we 

monitor and track our Scope 
3 emissions

•  Set an upstream and 

downstream Scope 3 target

• 

Increase disclosures on 
customer partnerships

We aim to build and operate a commercial carbon storage 
business, safely and permanently storing approximately  
14 Mt (gross) of third-party CO2e per annum by 2040.1 While 
we are not in direct control of Scope 3 emissions, we have 
progressed our plan to better understand them across our 
full value chain. Santos continues to identify opportunities to 
partner with our customers and suppliers. This has included 
collecting emissions data from key customers and suppliers 
to improve Scope 3 reporting. 

Scope 3 emissions 
reduction plan 
(page 75)

Value chain 
collaboration (page 88)

Emissions reduction units

Further details on our offset 
strategy including integrity of 
those used

Nature-based projects

Increase visibility on the quality 
and integrity of projects and 
the due diligence undertaken 
to assess the credibility of 
emissions reduction units 
generated

Methane/fugitives

Progress toward signing up to 
the OGMP 2.0

Following the development of a carbon storage growth 
target, Santos is now progressing the background data work 
in 2025 with the potential to inform an upstream Scope 3 
target.

Santos undertakes an internal screening process of projects 
with potential to generate emissions reduction units to 
ensure they meet minimum requirements. We recognise the 
integrity challenges faced by international carbon markets 
as their depth and maturity grows. Santos seeks to align our 
standards to global frameworks, implements real-time and 
future-focused risk assessments and prioritises projects that 
we can invest in and manage directly.

Residual emissions are addressed through investments in 
high integrity emissions reduction projects and acquisition 
of emissions reduction units. Santos undertakes an internal 
screening process of projects with potential to generate 
emissions reduction units, aims at ensuring they meet 
minimum requirements. 

Carbon solutions  
(page 87)

Carbon solutions  
(page 87)

We have significantly expanded our approach to methane 
emissions in 2024. Santos is committed to action on 
methane emissions and has completed work on a gap 
analysis and commenced work on implementation plans to 
assess our ability to sign up to OGMP 2.0.

Our approach to 
methane emissions 
(page 76)

1  Refer to 'important notices' at the front of this report for further information about this target.

109

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationInvestor feedback and our response
(continued)

Investor feedback

2024 report approach

Transition to NZE

Paris Agreement

Scope 1 and 2 emissions

Provide updated modelling to 
demonstrate Santos’ potential 
pathway to achieve our Scope 
1 and 2 emissions targets. 
The progress and percentage 
towards achieving our 2030 
targets achieved are also 
reported. 

Physical risk

Include quantitative physical risk 
analysis

Synthetic gas1 

Improve information about the 
lifecycle and commercial viability

Section disclosed  
in the report

Our approach to the 
Paris Agreement  
(page 72)

Santos has undertaken analysis to determine how our Scope 
1 and 2 emissions targets compare against third-party 
scenarios to limit warming to 1.5 degrees Celsius, as required 
by the Paris Agreement.

Santos is setting its targets and undertaking a range of 
actions to contribute to UN Paris Agreement Goals. Our 
climate targets are generally consistent with the Net Zero 
targets of the majority of jurisdictions where we operate 
including Australia, the United States of America and Papua 
New Guinea. Additionally, Santos only supplies customers 
from countries that have a Net Zero commitment or are 
signatories to the Paris Agreement.

For further information, see page 72.

Updated modelling is provided to demonstrate Santos’ 
potential pathway to achieve our Scope 1 and 2 emissions 
targets. The progress and percentage towards achieving our 
2030 targets achieved are also reported. 

Scope 1 and 2 emissions 
reduction plan  
(page 74)

Our targets – (page 71)

We have significantly expanded both our physical risk 
analysis and disclosures in 2024. Santos’ CTAP is based 
on managing these climate-related risks and leveraging 
climate-related opportunities. Building on an assessment of 
our physical climate risks in 2023, in 2024 we assessed the 
impacts of these risks.

Climate related risks: 
Physical risks (page 96)

Physical risk scenario 
analysis (page 104)

Synthetic gas is produced by combining hydrogen and CO2 
through a process known as methanation. The advantage 
of synthetic gas is that it has the same properties and 
chemistry as natural gas, and can use existing gas pipelines, 
LNG facilities and gas distribution networks. It has the 
potential to provide cost-competitive opportunities, 
including for hard-to-abate sectors where alternative 
technologies are not yet proven or economically viable.

Low carbon fuels  
(page 86)

1 

 Synthetic gas, which is in early stages of development, is being analysed for technical and economic feasibility. Synthetic gas was previously referred to as 
e-methane. Terminology update to reflect more widely recognised term. See Glossary for full definition.

110

Santos Annual Report 2024Appendices

Emissions calculation and reporting

Scope 1 and 2 emissions

Santos’ principal emissions 
reporting framework is Australia’s 
comprehensive greenhouse gas 
reporting scheme established under 
the National Greenhouse and Energy 
Reporting Act 2007 (NGER Act). 

The NGER Act requires controlling 
corporations to provide an annual 
report to the Clean Energy Regulator 
that includes the Scope 1 and 2 
greenhouse gas emissions, and 
energy production and consumption, 
for all Australian facilities under the 
operational control of any member of 
the controlling corporation’s corporate 
group. Santos Limited is a controlling 
corporation under the NGER Act.

The NGER Act is supported by 
the National Greenhouse and 
Energy Reporting (Measurement) 
Determination 2008 (NGER 
Determination), which specifies the 
methods for calculating Scope 1 and 2 
greenhouse gas emissions and energy 
data. 

Santos applies the NGER 
methodologies to emissions 
calculations and disclosures for all 
operated assets in Australia, and 
also PNG and Timor-Leste, which 
do not have their own emissions 
compliance reporting frameworks. 
Where an operated asset is located 
in a jurisdiction that has its own 
compliance emissions reporting 

Scope 1 and 2

framework, such as the United States 
Environmental Protection Agency’s 
Greenhouse Gas Reporting Program 
that is applicable to Santos’ operations 
in Alaska, then this framework is 
applied.

Scope 1 and 2 emissions from non-
operated assets are calculated by the 
operator in accordance with relevant 
emissions reporting frameworks.

Santos has been transparently 
reporting under the NGER framework 
since its inception in 2008.

Santos primarily adopts the prescribed 
emissions factors under Method 
1 (default method) in the NGER 
Determination to calculate greenhouse 
gas emissions. 

The estimation procedures 
under Method 1 are derived from 
methodologies used by the 
Department of Climate Change, 
Energy, the Environment and Water 
(DCCEEW) for the preparation of 
Australia’s National Greenhouse 
Accounts and align with the 
international guidelines adopted 
by the United Nations Framework 
Convention on Climate Change 
(UNFCCC) for the estimation of 
greenhouse emissions. The emissions 
factors under Method 1 are national 
average factors determined by 
DCCEEW.

Fuel emissions – quantity of own-
use fuel is measured via meters 
and purchased fuel volumes are 
obtained from invoices. The quantities 
consumed/invoiced are multiplied by 
the prescribed emissions factors from 
the NGER Determination.

Flare, vent, carbon dioxide removal 
emissions – quantity of gas flared 
or vented is measured via meters 
or engineering calculations, then 
multiplied by the prescribed emissions 
factor or relevant composition 
as appropriate under the NGER 
Determination.

Fugitive emissions – prescribed 
emission source (wells, produced 
water, pipelines, gathering and 
boosting stations, storage, natural 
gas processing facilities, offshore 
platforms and LNG facilities) are 
multiplied by the prescribed emissions 
factor applicable to each activity 
under the NGER Determination.

There have been no changes to the 
emissions calculation methodologies 
from the prior year.

Santos’ operated Australian Scope 1 
and 2 greenhouse gas emissions are 
independently audited each year prior 
to submission of the annual NGER 
Report.

For more detail on the NGER 
framework see the Clean Energy 
Regulator website.

Under the NGER framework, emissions are reported by Australian entities that have operational control over an 
emitting asset or facility. The NGER reporting framework covers:

Scope 1 and 2 emissions, 
and energy produced and 
consumed.

Greenhouse gases including 
carbon dioxide (CO2), 
methane (CH4) and 
nitrous oxide (N2O).

Emissions sources including 
the combustion of fuels 
for energy, and fugitive 
emissions from the extraction, 
processing and transportation 
of natural gas and oil.

111

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationAppendices
(continued)

Fugitive emissions

Santos calculates fugitive emissions across its operated assets in accordance with the compliance reporting framework that 
applies to the asset.

The fugitive calculation methodologies are based on component activity-based emission factors, with separate emission 
factors for wells, produced water, pipelines, gathering and boosting stations, storage, natural gas and liquids processing 
facilities, offshore platforms and LNG facilities. In 2024 our gross operated fugitive emissions were approximately 0.19 
million tonnes of CO2e, which is approximately 4 per cent of gross Scope 1 greenhouse gas emissions.

Scope 3

Santos’ Scope 3 emissions are indirect emissions in our value chain. The Australian NGER emissions measurement and 
reporting framework does not encompass Scope 3 emissions. However, Santos calculates and discloses our material Scope 
3 emissions in observance of the World Resources Institute Greenhouse Gas Protocol Technical Guidance for Scope 3 
Emissions.

There are a range of categories by which Scope 3 emissions can be classified under the Greenhouse Gas Protocol. These 
categories cover activities upstream and downstream of Santos’ emissions reporting boundaries. The majority of Santos’ 
Scope 3 emissions are from downstream of our value chain, being the processing and use of the products that we generate.

Change in reporting period

To align with Santos’ financial statements which are reported on a calendar-year basis, the emissions disclosures are now 
also presented on a calendar-year basis for Santos’ 2024 Annual Report. Prior year comparatives which were previously 
disclosed on a financial-year basis have been restated to calendar-year periods.

Australia’s Safeguard Mechanism

The Safeguard Mechanism under the NGER Act places a cap (baseline) on cost-free emissions from Australian facilities 
emitting greater than 100 kt of CO2e annually. All Safeguard facilities are required to keep their net emissions at or below 
their baseline. The annual net emissions for each Safeguard facility are compared against the facility’s baseline. Where a 
facility’s net emissions1 are above its baseline, the excess emissions must be managed, which may include the surrender of 
ACCUs or Safeguard Mechanism credit units (SMCs) in an amount equivalent to the exceedance for the year.

The Safeguard baselines for existing facilities are calculated for each financial year based on the quantity of each product 
produced at the facility, the emissions-intensity value for each product and the baseline decline rate. The emissions-
intensity values will transition from facility-specific emissions intensities to industry average values and an annual baseline 
decline rate of 4.9 per cent will be applied each year to 2030.

Santos will maintain compliance with the Safeguard Mechanism through reduction of emissions of the included facilities 
in line with legislative requirements, and via the surrender of ACCUs or SMCs. As discussed in the Operational efficiency 
section of this report (refer to page 82), we continue to look for ways to reduce our emissions alongside improvements in 
project economics.

Santos has nine operated Safeguard facilities, and their 2023-24 Safeguard Positions as issued by the Clean Energy 
Regulator are listed below.

2023-24 Safeguard Positions 
(gross operated, tCO2e)
Safeguard facility

Arcadia

Ballera

Darwin LNG Plant

Fairview

Moomba Plant

Ningaloo Vision FPSO

Port Bonython

Roma Hub

Varanus Hub

Baseline emissions

Net emissions1

Net position

Position status2

 166,220

 120,065

 100,000

 289,078

 2,048,421

 277,840

 100,000

 150,920

 237,234

 108,224

 153,917

 241,538

 214,228

 2,199,395

 226,731

 82,939

 129,375

 281,036

(57,996)

 33,852

 141,538

(74,850)

 150,974

(51,109)

(17,061)

(21,545)

 43,802

 SMC Issuance

 Excess

 Excess

 SMC Issuance

 Excess

 SMC Issuance

 No excess

 SMC Issuance

 Excess

1 

 The net emissions number for a facility reflects the total covered emissions reported in the NGER report for the compliance period, adjusted to deduct any 
ACCUs or SMCs surrendered during the period, and adds back any ACCUs issued during the compliance period.

2  For facilities in an excess position, the equivalent number of ACCUs or SMCs will be surrendered by 31 March 2025.

112

Santos Annual Report 2024Greenhouse gas emissions data

Units

2024

2023

2022

2021

2020

Scope 1 greenhouse gas emissions6 
Emissions - gross operated and equity share

Gross operated emissions

 MtCO2e 

Equity share emissions 
Equity share intensity8 
Emissions - operated and non-operated (equity share)

 MtCO2e 

 ktCO2e/mmboe 

Total operated
Total non-operated4
Emissions - by location (equity share)

Australia 

Timor-Leste

United States

Papua New Guinea

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

Emissions - by greenhouse gas component (gross operated)

Emissions from CO2

Emissions from CH4

Emissions from N2O

Emissions - by source (gross operated)

Emissions from fuel

Emissions from flare

Emissions from vent

Emissions from CO2 removal

Emissions from fugitives

Methane emissions (OGCI, gross operated)

Methane emissions
Methane emissions intensity12

Scope 2 greenhouse gas emissions7
Emissions - gross operated and equity share

Gross operated emissions

Equity share emissions 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MMSm3 

 per cent

 MtCO2e 

 MtCO2e 

Emissions - operated and non-operated (equity share)

Total operated
Total non-operated4

 MtCO2e 

 MtCO2e 

4.44

4.12

47

2.62

1.50

2.77

0.11

0.05

1.19

3.99

0.45

0.00

2.36

0.34

0.12

1.43

0.19

5.50

4.60

50

3.11

1.49

3.31

0.14

0.02

1.14

4.95

0.54

0.01

2.87

0.47

0.09

1.87

0.20

23.76

0.16

28.51

0.19

0.80

0.26

0.21

0.05

0.60

0.21

0.16

0.05

5.87

4.86

47

3.29

1.57

3.51

0.16

0.00

1.19

5.30

0.57

0.01

3.06

0.63

0.10

1.87

0.21

NPR

NPR

0.57

0.21

0.15

0.06

6.40

4.69

51

3.72

0.97

4.09

0.25

 - 

0.35

5.91

0.49

0.01

3.29

0.43

0.09

2.46

0.13

NPR

NPR

0.61

0.22

0.17

0.05

5.31

4.41

50

3.39

1.02

3.89

0.22

 - 

0.30

4.96

0.35

0.00

2.66

0.26

0.08

2.26

0.05

NPR

NPR

0.61

0.23

0.17

0.06

113

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
Appendices
(continued)

Emissions - by location (equity share)

Australia 

 MtCO2e 

0.26

0.21

0.21

0.22

0.23

Scope 1 and 2 greenhouse gas emissions
Equity share emissions 

Equity share intensity

 MtCO2e 

 ktCO2e/mmboe 

4.38

50

4.81

52

5.07

49

4.91

53

4.64

52

Units

2024

2023

2022

2021

2020

Scope 3 greenhouse gas emissions (operated and non-operated)9, 10, 11
Category 1: Purchased goods and services

 MtCO2e 

Category 10: Processing of sold products

Category 11: Use of sold products 

Other upstream

Other downstream

Total

NPR - not previously reported

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

 MtCO2e 

3.1

4.2

21.3

0.9

0.4

29.9

5.5

4.3

21.8

1.0

0.4

33.0

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

NPR

1 

2 

3 

 Greenhouse gas emissions are calculated in accordance with the National Greenhouse and Energy Reporting Act (2007), unless the asset is located in a 
jurisdiction that has a compliance emissions reporting framework, such as the United States Environmental Protection Agency's Greenhouse Gas Reporting 
Program.

 Scope 1 and 2 emissions are rounded to two decimal places, Scope 3 emissions are rounded to one decimal place, and emissions intensities are rounded to the 
nearest whole number. The sum of individual rows in the table may not equal the aggregated totals due to rounding. 

 From 1 July 2023, the GLNG Midstream assets, comprising the Curtis Island GLNG Plant and select GLNG pipelines, are under the operational control of GLNG 
Operations Pty Ltd. Given this change the GLNG Midstream assets are represented as non-operated for all years.  

4  Non-operated emissions data is sourced from information provided by the respective operator.  

5  Scope 1 and 2 emissions for Australian-operated assets are independently audited each year. 

6  Scope 1 emissions occur from sources controlled by Santos, for example emissions from fuel, flare and vent.  

7 

8 

 Scope 2 emissions are indirect, mainly electricity consumption. Operated Scope 2 emissions are estimated using location-based methods. Assets in PNG and 
Timor-Leste have Scope 2 emissions of less than 0.01 MtCO2e and are not included in the data tables.

 The production volume used to calculate Santos’ equity emissions intensity is derived from Santos’ publicly available production information. The Bayu-Undan 
facility is covered by a production sharing contract (PSC) arrangement with Timor-Leste. Consistent with the historical treatment for sustainability reporting, 
the post-PSC production volume associated with the Bayu-Undan facility has been used in the emissions intensity calculation. In line with guidance from IPIECA 
Guidelines, the equity emissions attributed to the Bayu-Undan facility are calculated by multiplying the gross emissions by the joint venture working interest. 

9 

 Scope 3 emissions represent indirect emissions in our value chain. Santos calculates and discloses its material Scope 3 emissions in observance of the World 
Resources Institute Greenhouse Gas Protocol Technical Guidance for Scope 3 Emissions. 

10  Downstream Scope 3 emissions are expressed on a net equity basis and upstream Scope 3 emissions are expressed on a gross operated basis.  

11 

12 

 Scope 3 other categories include Category 2 - Capital goods, Category 3 - Fuel- and energy-related activities, Category 4 - Upstream transportation and 
distribution, Category 6 - Business travel, Category 7 - Employee commuting, Category 9 - Downstream transportation and distribution. 

 Methane emissions intensity is calculated in accordance with the OGCI Reporting Framework on a gross operated basis, as the volume of methane emissions 
divided by the volume of marketed natural gas.

114

Santos Annual Report 2024 
 
 
 
 
Independent Limited Assurance Report 
to the Management and Directors of Santos Limited (‘Santos’)

What we assured 

Ernst & Young (‘EY’, ‘we’) were engaged by Santos to undertake a limited assurance engagement as defined by Australian 
Auditing Standards, hereafter referred to as a ‘review’, over certain sustainability and climate change disclosures in Santos’ 
2024 Annual Report specifically within the Sustainability and Climate Sections, for the year ended 31 December 2024. We 
reviewed the following Subject Matter in accordance with the noted Criteria, as defined in the following table: 

What EY assured it against (Criteria)
Global Reporting Initiative (‘GRI’) Principles for defining 
report content.

GRI Standards 2021 GRI 3: Material Topics.

Management’s own publicly disclosed criteria 

The Global Reporting Initiative (GRI) Standards (2021) 
Reporting Principles being Accuracy, Balance, Clarity, 
Comparability, Completeness, Sustainability Context, 
Timeliness, Verifiability.

Santos’ internally developed reporting criteria.

National Greenhouse and Energy Reporting Act 2007.

National Greenhouse and Energy Reporting Regulation 
2008.

National Greenhouse and Energy Reporting Regulation 
(Measurement) Determination.

US Environmental Protection Agency Code of Federal 
Regulations, Title 40, Chapter I, Subchapter C, Part 98 – 
Mandatory Greenhouse Gas Reporting.

World Resources Institute/World Business Council for 
Sustainable Development (WRI/WBCSD) Greenhouse Gas 
Protocol.

What EY assured (Limited Assurance Subject Matter)
Santos’ identification and reporting of its material 
sustainability topics described within Santos’ 2024 Annual 
Report specifically within the Sustainability and Climate 
Sections.

Qualitative disclosures within Santos’ 2024 Annual Report 
specifically within the Sustainability and Climate Sections in 
relation to Santos’ key material topics.

Santos’ reported performance of its greenhouse gas 
emissions metrics as follows:

Scope 1 emissions (for the period 1 January 2024 – 
31 December 2024)

Total gross operated emissions: 4.44 million tonnes of 
carbon dioxide equivalent (Mt CO2-e)

Total equity share emissions: 4.12 Mt CO2-e

Total equity share intensity: 47 kilo tonnes of carbon 
dioxide equivalent per million barrels of oil equivalent 
(‘kt CO2-e/mmboe’)

Gross operated Methane greenhouse gas emissions: 
23.76 million standard cubic meters (‘MMSm3’)

Methane emissions intensity: 0.16%

Scope 2 emissions (for the period 1 January 2024 – 
31 December 2024)

Total gross operated emissions: 0.80 Mt CO2-e

Total equity share emissions: 0.26 Mt CO2-e

Scope 3 emissions (for the period 1 January 2024 - 
31 December 2024)

Total gross operated emissions for Santos’ upstream Scope 
3 Category 1: Purchased goods and services: 3.1 Mt CO2-e

Total equity share emissions for Santos’ Scope 3 Category 
10: Processing of Sold Products: 4.2 Mt CO2-e

Total equity share emissions for Santos’ Scope 3 Category 11: 
Use of Sold Products: 21.3 Mt CO2-e

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

115

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Limited Assurance Report 
to the Management and Directors of Santos Limited (‘Santos’) 
(continued)

Scope 1 emissions (for the period 1 January 2023 – 
31 December 2023)

Total gross operated emissions: 5.50 Mt CO2-e

Total equity share emissions: 4.60 Mt CO2-e

Total equity share intensity: 50 kt CO2-e/mmboe

Gross operated Methane greenhouse gas emissions: 
28.51 MMSm3

Methane emissions intensity: 0.19%

Scope 2 emissions (for the period 1 January 2023 – 
31 December 2023):

Total gross operated emissions: 0.60 Mt CO2-e

Total equity share emissions: 0.21 Mt CO2-e

Scope 3 emissions (for the period 1 January 2023 - 
31 December 2023):

Total gross operated emissions for Santos’ upstream Scope 
3 Category 1: Purchased goods and services: 5.5 Mt CO2-e

Total equity share emissions for Santos’ Scope 3 Category 
10: Processing of Sold Products: 4.3 Mt CO2-e 

Total equity share emissions for Santos’ Scope 3 Category 11: 
Use of Sold Products: 21.8 Mt CO2-e

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

116

Santos Annual Report 2024Santos’ reported performance of its sustainability metrics as 
follows, for the period 1 January 2024 to 31 December 2024:

Definitions as per the GRI Sustainability Reporting 
Standards, including:

Health and safety

GRI 403: Occupational Health and Safety 2018.

Total Recordable Injury Rate (‘TRIR’): 1.94

GRI 204: Anti-corruption 2016.

Lost Time Injury Rate (‘LTIR’): 0.08

Asset integrity and critical incident management 

Number of hydrocarbon spills to the environment greater 
than 1 barrel: 8 hydrocarbon spills

Volume of hydrocarbon spills to the environment greater 
than 1 barrel: 213m³

Tier 1 and 2 Loss of Containment Incident (LOCI) frequency 
rate: 0.14

Economic contribution to society 

Total procurement spend: USD $6,431,265,697

Local Communities procurement spend: USD$1,335,896,957

GRI 11: Oil and Gas Sector 2021 11.7 Additional Sector 
Disclosures in relation to Closure and Rehabilitation.

GRI 405: Diversity and Equal Opportunity 2016.

GRI 411: Rights of Indigenous Peoples 2016 and GRI 412: 
Human Rights Assessments.

GRI 203: Indirect Economic Impacts, GRI 204: Procurement 
Practices.

IPIECA’s Oil and gas industry guidance on voluntary 
sustainability reporting (where appropriate).

World Resources Institute/World Business Council for 
Sustainable Development (WRI/WBCSD) Greenhouse Gas 
Protocol.

Indigenous spend: USD$518,267,300

National Greenhouse and Energy Reporting Act 2007.

Community investment: USD$10,816,460

Diversity and inclusion 

Female representation: 28%

National Greenhouse and Energy Reporting Regulations 
2008.

National Greenhouse and Energy Reporting (Measurement) 
Determination.

Australian Indigenous employment: 61 employees

Santos’ own publicly disclosed criteria.

Employee count by region: 

a.  Australia: 2,922 employees

b.  Papua New Guinea: 809 employees

c.  Timor-Leste: 35 employees

d.  United states: 175 employees

e.  Other international locations: 17 employees

Governance policy, business ethics and regulatory 
compliance 

Substantiated number of and type of misconduct by 
individuals: 9 incidents of substantiated misconduct

Community, land and resource rights

Number of prosecutions as a consequence of unauthorised 
impacts to cultural heritage or landholder properties: nil 
prosecutions

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

117

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Limited Assurance Report 
to the Management and Directors of Santos Limited (‘Santos’) 
(continued)

Recommendations of the Task Force on Climate-related 
Financial Disclosures. 

The TCFD Recommendations ‘Principles for Effective 
Disclosures’.

Santos’ internally developed reporting criteria as disclosed in 
the 2024 Reporting Suite.

Santos’ disclosures in relation to the Task Force on Climate-
related Financial Disclosures (‘TCFD’) Recommendations, 
detailed as follows:

Governance 

a.  Board oversight

b.  Management’s role 

Strategy

a.  Climate-related risks and opportunities

b.  Impact on the organisation’s business, strategy and 

financial planning

c.  Resilience of the organisation’s strategy

Risk Management

a.  Risk identification & assessment process

b.  Risk management process

c.  Integration into overall risk management

Metrics and Targets

a.  Climate-related metrics in line with strategy and risk 

management process

b.  Scope 1, 2, 3 greenhouse gas emissions metrics and the 

related risks

c.  Climate-related targets and performance against targets

Including the assumptions and approach supporting Santos’ 
scenario modelling, including:

The reasonableness of the process undertaken by Santos to 
conduct its scenario analysis.

The relevance of the external climate scenarios referenced.

Transparency – all the assumptions and inputs into the 
scenario analysis are appropriately documented and 
verifiable.

Accuracy – the assumptions utilised in the scenario analysis 
include the most relevant and reliable available inputs.

Completeness – the assumptions and inputs that form the 
basis of Santos’ scenario analysis do not omit relevant, 
well-established and publicly available inputs that could 
reasonably be expected to affect decisions of the intended 
users made on the basis of that subject matter information.

Santos’ disclosures in relation to the Climate Transition 
Action Plan, specifically:

Recommendations of the Task Force on Climate-related 
Financial Disclosures

Santos’ disclosures with reference to The Task Force on 
Climate-related Financial Disclosures Recommendations 
‘Principles for Effective Disclosures’, as presented in Santos’ 
Climate Transition Action Plan within the 2024 Reporting 
Suite

The approach supporting Santos’ planned actions and 
climate-related goals and targets as outlined in the Plan

The TCFD Recommendations ‘Principles for Effective 
Disclosures’

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

118

Santos Annual Report 2024Our Conclusion:

•  Limited Assurance 

Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention 
that causes us to believe the Subject Matter has not been prepared, in all material respects, in accordance with the 
Criteria defined above. 

Key responsibilities 

EY’s responsibility and independence

Our responsibility is to express a conclusion on the Subject Matter based on our review.

We have complied with the independence and relevant ethical requirements, which are founded on fundamental principles 
of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. 

The firm applies Auditing Standard ASQM 1 Quality Management for Firms that Perform Audits or Reviews of Financial 
Reports and Other Financial Information, or Other Assurance or Related Services Engagements, which requires the firm to 
design, implement and operate a system of quality management including policies or procedures regarding compliance 
with ethical requirements, professional standards and applicable legal and regulatory requirements.

Santos’ responsibility 

Santos’ management is responsible for selecting the Criteria, and for presenting the Subject Matter in accordance with 
that Criteria, in all material respects. This responsibility includes establishing and maintaining internal controls, maintaining 
adequate records and making estimates that are relevant to the preparation of the subject matter, such that it is free from 
material misstatement, whether due to fraud or error.

Our approach to conducting the review

We conducted this review in accordance with the Australian Auditing and Assurance Standards Board’s Australian Standard 
on Assurance Engagements Other Than Audits or Reviews of Historical Financial Information (‘ASAE 3000’), the Standard 
for Assurance on Greenhouse Gas Statements (‘ASAE 3410’); as well as Compliance Engagements (‘ASAE 3100’) for 
disclosures pertaining to scenario analysis; as well as the terms of reference for this engagement as agreed with Santos on 
the dates of the relevant signed engagement letters. That standard requires that we plan and perform our engagement to 
express a conclusion on whether anything has come to our attention that causes us to believe that the Subject Matter is not 
prepared, in all material respects, in accordance with the Criteria, and to issue a report.

Summary of review procedures performed 

A review consists of making enquiries, primarily of persons responsible for preparing the Subject Matter and related 
information and applying analytical and other review procedures. 

The nature, timing, and extent of the procedures selected depend on our judgement, including an assessment of the risk of 
material misstatement, whether due to fraud or error. The procedures we performed included, but were not limited to:

• 

Interviewing Santos personnel to understand the reporting processes at the group and site level, including 
management’s processes to: identify Santos’ material issues; identify Santos’ material climate-related risks and 
opportunities; and understand Santos’ processes for collecting, collating and reporting the selected performance of its 
sustainability metrics and greenhouse gas emissions metrics

•  Checking the Santos’ 2024 Annual report specifically within the Sustainability and Climate sections to understand how 

Santos’ identified material issues, risks and opportunities are reflected within the qualitative disclosures

•  Evaluating whether the information disclosed in the Limited Assurance Subject Matter is consistent with our 

understanding of sustainability performance at Santos

•  Evaluating the suitability of the Criteria and that the Criteria have been applied appropriately to the Subject Matter 

•  Conducting site procedures at Santos on a sample basis, based on our professional judgement, to evidence site level 

data collection and reporting as well as to identify completeness of the sustainability performance data and statements 
included within the Subject Matter 

•  Undertaking analytical procedures of the quantitative disclosures in the Subject Matter

•  Reviewing data, information or explanation about the sustainability performance data and statements included within 

the Subject Matter

•  Reviewing other information within the Santos’ 2024 Annual Report specifically within the Sustainability and Climate 
sections for consistency and alignment to other quantitative and qualitative information within the Subject Matter

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

119

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Limited Assurance Report 
to the Management and Directors of Santos Limited (‘Santos’) 
(continued)

•  On a sample basis, based on our professional judgement, re-performing calculations to check accuracy of claims within 

the Subject Matter

•  On a sample basis, based on our professional judgement, agreeing qualitative and quantitative statements within 
the Subject Matter and underlying data to source information to assess completeness of claims, including process 
conversations, review of invoices, incident reports, and meter data.

•  Checking the assumptions and approach supporting Santos’ scenario analysis and portfolio assessment were consistent 

with the principles specified in the Criteria

• 

Identifying and testing the reasonableness of assumptions and approach supporting Santos’ climate scenarios 

•  Checking the Climate Transition Action Plan to understand how Santos’ identified material climate-related transition risks 

and opportunities and decarbonisation ambitions are reflected in qualitative disclosures

•  Checking if the approach supporting Santos’ planned actions and climate-related goals and targets in the Climate 

Transition Action Plan was consistent with the principles specified in the Criteria 

• 

Identifying and testing the reasonableness of assumptions and approach supporting Santos’ planned actions and climate 
related goals and targets

We believe that the evidence obtained is sufficient and appropriate to provide a basis for our review conclusion.

Inherent limitations

Procedures performed in a review engagement vary in nature and timing from, and are less in extent than for a reasonable 
assurance engagement. Consequently, the level of assurance obtained in a review engagement is substantially lower than 
the assurance that would have been obtained had a reasonable assurance engagement been performed. Our procedures 
were designed to obtain a limited level of assurance on which to base our conclusion and do not provide all the evidence 
that would be required to provide a reasonable level of assurance.

While we considered the effectiveness of management’s internal controls when determining the nature and extent of our 
procedures, our assurance engagement was not designed to provide assurance on internal controls. Our procedures did not 
include testing controls or performing procedures relating to assessing aggregation or calculation of data within IT systems.

The greenhouse gas quantification process is subject to scientific uncertainty, which arises because of incomplete 
scientific knowledge about the measurement of greenhouse gases. Additionally, greenhouse gas procedures are subject 
to estimation and measurement uncertainty resulting from the measurement and calculation processes used to quantify 
emissions within the bounds of existing scientific knowledge.

Other matters

We have not performed assurance procedures in respect of any information relating to prior reporting periods, including 
those presented in the Subject Matter. Our report does not extend to any disclosures or assertions made by Santos relating 
to future performance plans and/or strategies disclosed in Santos’ 2024 Annual Report specifically within the Sustainability 
and Climate sections.

Use of our Assurance Report

We disclaim any assumption of responsibility for any reliance on this assurance report to any persons other than 
management and the Directors of Santos, or for any purpose other than that for which it was prepared. Our review included 
web-based information that was available via web links as of the date of this statement. We provide no assurance over 
changes to the content of this web-based information after the date of this assurance statement.

Ernst & Young 

Fiona Hancock  
Partner 
Ernst & Young  
Adelaide, Australia 
18 February 2025

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

120

Santos Annual Report 2024 
O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

CORPORATE 
GOVERNANCE 
STATEMENT

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

Santos Annual Report 2024

121

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
2024 
Governance highlights

•  Completed planned Board succession activities including the retirement of three 
Directors, the appointment of two new Directors and the appointment of new 
Committee Chairs

•  Board site visits to PNG, Roma and Darwin LNG

•  Ongoing Director education program, including Code of Conduct training and 

education sessions relating to anti-corruption and sanctions compliance, carbon 
markets, external markets, geopolitical developments, low emissions pathways  
and the role of natural gas

•  Conducted a Board skills matrix assessment and external Board performance review

•  Reviewed and updated Board and Committee Charters  

in line with current practice

•  Reviewed and updated three core corporate governance policies, including an 

update to the Local and Indigenous Communities Policy to incorporate a 
commitment to the Indigenous Advisory Panel.

•  Ongoing review and refresh of the Risk Management Framework and  

Risk Appetite Statement

•  Conformance audits across the whole business against the new Santos Management 

System operating standards conducted by Internal Audit

122

Santos Annual Report 2024Board of Directors

Keith Spence

Kevin Gallagher

Yasmin Allen AM

BSc (First Class Honours in Geophysics), 
FAIM

Chair: Since 19 February 2018

Term of office: Director since 1 January 2018

BEng (Mechanical) Hons, FIEAust 

BCom, FAICD

Managing Director and CEO 

Term of office: Director since 22 October 2014

Term of office: Managing Director and CEO 
since replace with 16 February 2016 

P   A

Independent: Yes 

S   N

Independent: Yes 

S   SS
Independent: No 

Experience: Mr Spence has 40 years’ 
experience in managing and governing oil 
and gas operations in Australia, PNG, the 
Netherlands and Africa.

A geologist and geophysicist by training,  
Mr Spence commenced his career as an 
exploration geologist with Woodside 
Petroleum Limited in 1977. He subsequently 
joined Shell (Development) Australia, where 
he worked for 18 years. In 1994, he was 
seconded to Woodside to lead the 
Northwest Shelf Exploration team. In 1998, 
he left Shell to join Woodside. He retired 
from Woodside in 2008, after a 14-year 
tenure in top executive positions in the 
company. Mr Spence has expertise in 
exploration and appraisal, development, 
project construction, operations and 
marketing.

On retirement Mr Spence took up several 
board positions, working in oil and gas, 
energy including geothermal, wind, solar 
and power from waste, mining, and 
engineering and construction services and 
renewable energy. This included Clough 
Limited, where he served as Chair (2010 to 
2013); Geodynamics Limited, where he 
served as a non-executive Director (2008 to 
2016) (including as Chair from 2010 to 2016) 
Verve Energy and Synergy (after merger 
with Verve) where he served as a non-
executive Director (2009 to 2014), Oil 
Search Limited, where he served as a 
non-executive Director (2012 to 2017);  
and Murray and Roberts Holdings Limited, 
where he served as a non-executive 
Director (2015 to 2020).

Mr Spence is also a past Chair of Base 
Resources Limited (2015 to 2021) and 
National Offshore Petroleum Safety and 
Environmental Management Authority 
Board. He led the Commonwealth 
Government’s Carbon Storage Taskforce 
(2008 to 2010) and chaired the Carbon 
Capture and Storage Flagship Independent 
Assessment Panel (2008 to 2012).

Current directorships/other interests: 

Director: non-executive Director of IGO 
Limited (since 2014).

Other directorships of listed entities within 
the past three years: Chair of Base 
Resources Limited (2015 to 2021).

Experience: Mr Gallagher has more than 
three decades of international experience in 
the oil and gas industry.

Mr Gallagher led significant transformation 
and growth of the Company, delivering 
a competitive advantage in the energy 
evolution. Mr Gallagher commenced his 
career as a drilling engineer with Mobil 
North Sea, before joining Woodside in 
Australia in 1998. 

At Woodside, Mr Gallagher led the drilling 
organisation through a rapid growth 
phase, delivering several Australian and 
international development projects and 
exploration campaigns, before leading 
the Australian oil business. He was Chief 
Executive Officer at Clough Limited, an 
engineering and construction company, 
from 2011 until his appointment at Santos. 

Under his leadership, Santos has become 
one of Australia’s largest independent gas, 
LNG and liquids producers, with high quality 
assets and resources in Australia, PNG, 
Alaska and Timor-Leste.

Mr Gallagher led growth through successful 
mergers and acquisitions of Quadrant 
Energy, ConocoPhillips’ Australia-West 
business and Oil Search, building a diverse 
portfolio of strategic long-life assets. 
Mr Gallagher is currently focused on 
organic growth through delivery of the 
Barossa Gas and Pikka Liquids Projects.

Mr Gallagher implemented a disciplined 
low-cost operating model and strengthened 
the Company’s balance sheet, creating a 
strong cash-generative business that has 
delivered a series of record results. He 
has also positioned Santos to leverage 
the critical role of gas in delivering energy 
security through the energy transition to 
Net Zero emissions. 

Experience: Ms Allen has more than 20 
years of experience as a non-executive 
Director and Chair across major public, 
private and government boards, following 
her extensive background in finance and 
investment banking. Her executive career 
included senior roles at Deutsche Bank AG, 
ANZ and HSBC Group Plc. Ms Allen served 
as former Chair of Macquarie Global 
Infrastructure Funds and Director at EFIC 
(Export, Finance and Insurance 
Corporation), non-executive Director ASX 
Limited and ASX Clearing and Settlement 
boards (2015 to 2024) and non-executive 
Director of Cochlear Limited (2010 to 2024).

Ms Allen has deep expertise in corporate 
governance, strategic leadership and more 
recently in digital transformation, through 
her roles as Chair of AI and platform 
companies, Faethm.ai (2020) and Tiimely 
(2021).

Current directorships/other interests: 

Chair: Future Skills Organisation (since 
2020) and Tiimely (since 2021).

Director: non-executive Director of QBE 
Insurance (Australia) Ltd.

Member: First Acting President of the 
Australian Government Takeovers Panel 
(since 2017), Member of the Order of 
Australia for significant service to finance 
and business, and to the not-for-profit 
sector (since 2023).

Other directorships of listed entities within 
the past three years: non-executive Director 
ASX Limited and ASX Clearing and 
Settlement boards (2015 to 2024), 
non-executive Director of Cochlear Limited 
(2010 to 2024).

Key to membership

 Chair 

Current directorships/other interests: 

 Committee member

Director: Australian Energy Producers and 
Asia Natural Gas and Energy Association 

Other directorships of listed entities within 
the past three years: Nil. 

S  Santos Finance Limited 

A  Audit and Risk Committee 

N  Nomination Committee 

P   People, Remuneration  

and Culture Committee 

SS  Safety and Sustainability Committee

123

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Board of Directors
(continued)

Vanessa Guthrie AO

DSc, PhD, BSc (Hons), FAICD, FTSE

John Lydon

BA, MBA

Term of office: Director since 1 July 2017

Term of office: Director since 11 April 2024

SS   P

Independent: Yes 

SS   N
Independent: Yes 

Experience: After starting his career at 
Citibank in London, Mr Lydon spent 25 
years at McKinsey where he advised clients 
on strategic growth and operational 
opportunities and also held leadership roles 
including founding McKinsey 
Implementation globally, Managing Partner 
McKinsey Australia & New Zealand, and 
leading Social Responsibility across Asia 
Pacific. He is also an Industry Professor at 
UTS Business School and previously served 
as an Economic Commissioner for the 
Greater Cities Commission, NSW 
Government.

Current directorships/other interests: 

Chair: Co-Chair of Australian Climate 
Leaders Coalition (since 2020) and 
Generation Australia (since 2019).

Director: Net Zero Emissions and Clean 
Energy Board (2023 to 2024).

Other directorships of listed entities within 
the past three years: Nil.

Experience: Dr Guthrie has extensive 
experience in the resources sector in diverse 
roles such as operations, environment, 
community and Indigenous affairs, 
corporate development and sustainability. 
She has qualifications in geology, 
environment, law and business management 
including a PhD in Geology. 

Dr Guthrie was awarded an Honorary 
Doctor of Science from Curtin University in 
2017 for her contribution to sustainability, 
innovation and policy leadership in the 
resources industry. 

Dr Guthrie was also a Board member of 
Infrastructure Australia (2021 to 2024), 
Lead Independent Director and Deputy 
Chair of AdBri Limited (2018 to 2023) 
and non-executive Director of Tronox 
Holding PLC (2019 to 2024).

Current directorships/other interests: 

Director: Lynas Rare Earths Ltd (since 
2020), Cricket Australia (since 2021), Orica 
Limited (since 2023) and North American 
Construction Group Ltd (since 2024).

Member: Officer of the Order of Australia 
for her contribution to the mining and 
resources sector and as a role model for 
women in business (since 2021).

Other: Chancellor of Curtin University.

Other directorships of listed entities within 
the past three years: Lead Independent 
Director and Deputy Chair of AdBri Limited 
(2018 to 2023) and non-executive Director 
of Tronox Holding PLC (2019 to 2024).

Janine McArdle

BS (Chemical Engineering), MBA, NACD 
Governance Fellowship, WCD, Carnegie 
Mellon CERT-Cyber Security Oversight

Term of office: Director since  
23 October 2019

A   SS   N
Independent: Yes 

Experience: Ms McArdle has extensive 
global energy experience in engineering 
and design, physical and financial energy 
commodities trading, risk management and 
mergers and acquisitions (M&A). She is the 
founder and CEO of Apex Strategies, a 
global consultancy business providing 
advisory services to companies engaged in 
the oil and gas industry and more recently, 
in the development of tools and strategies 
to facilitate achievement of corporate 
energy transition goals. Prior to Apex 
Strategies, she worked for Apache 
Corporation in the US for 13 years, where 
she held various executive roles including 
President, Kitimat LNG Co., Senior Vice 
President of Global Gas Monetization, and 
Vice President, Worldwide Oil and Gas 
Marketing with 'profit and loss' (P&L). She 
also had operational responsibility for the 
evacuation and sale of the company’s oil 
and gas production worldwide and the 
development and execution of their LNG 
strategy. Prior to Apache, Ms McArdle 
worked as an executive with Aquila Energy 
for nine years with P&L responsibilities 
across trading, M&A and B2B e-commerce, 
first in the US and then in the United 
Kingdom, as Managing Director of Aquila 
Energy Ltd, Aquila’s European Energy 
Trading Subsidiary. During this time, she was 
a key architect in the design and 
implementation of the ICE Trading platform 
and served on the ICE Board of Directors 
(2000 to 2002).

Ms McArdle was recognised nationally as 
one of the top 50 most powerful women in 
the oil and gas industry in 2014 and was the 
2016 recipient of the Houston Business 
Journal’s Women in Energy Leadership 
Award for Women of Influence. She was 
also a non-executive Director of Halcon 
Resources Corporation (US) (2018 to 2019).

Current directorships/other interests: 

Director: Antero Midstream Corp (US) 
(since 2020) and Advantage Energy Ltd 
(CA) (since 2022).

Other directorships of listed entities within 
the past three years: Nil.

124

Santos Annual Report 2024 
 
Vickki McFadden

BCom, LLB

Michael Utsler

Musje Werror

BSc (Ptrl Eng), GAICD, MAICD

BSc (Chem), MBA, MProfAcc, MAICD

Term of office: Director since 11 April 2024

Term of office: Director since 3 May 2022

A   P

Independent: Yes 

P   A

Independent: Yes 

Experience: Ms McFadden is an experienced 
company Director and Chair and brings a 
broad range of skills and experience gained 
through her current and previous non-
executive Director roles and her executive 
career spanning investment banking, 
corporate finance and corporate law.

Ms McFadden has particular experience in 
financial accounting and audit, capital 
management and corporate finance, risk 
management, remuneration, corporate 
governance and leadership and is an 
experienced Chair of Audit and Risk 
Committees.

Ms McFadden was formerly a non-executive 
Director of Tabcorp Holdings Limited (2016 
to 2020), Newcrest Mining Limited (2016 to 
2023), Myer Family Investments Pty Ltd 
(2011 to 2020) and Leighton Holdings 
Limited (2013 to 2014), and the non-
executive Chair of eftpos Australia Pty Ltd 
(2016 to 2018) and of Skilled Group Limited 
(2010 to 2015). Ms McFadden was the 
former President of the Australian Takeovers 
Panel (2013 to 2019), and Member of the 
Executive Council and Advisory Board of 
the UNSW Business School (2006 to 2019).

Current directorships/other interests: 

Chair: GPT Group (since 2018).

Director: Allianz Australia Limited (since 
2020).

Member: Chief Executive Women and the 
Australian Institute of Company Directors.

Other directorships of listed entities within 
the past three years: non-executive Director 
of Newcrest Mining Limited (2016 to 2023).

Experience: Mr Utsler has worked in the 
energy industry for more than 40 years, 
across multiple international areas. During 
his career, he has built deep knowledge and 
experience in the upstream, midstream and 
downstream areas of the energy industry. 
In addition, he has developed experience 
in power generation, alternative energy 
solutions and some aspects of carbon 
management. He has had extensive 
involvement in fostering technological 
solutions for driving efficiencies 
in operations.

Mr Utsler has held senior leadership and 
executive positions with Amoco, BP 
(including President of the Gulf Coast 
Restoration Organisation – GCRO and SVP 
BP Alaska Exploration), Woodside Energy 
and New Fortress Energy. In September 
2020, Mr Utsler joined Otto Energy as its 
CEO and Managing Director. He was further 
appointed Otto Energy’s Executive Chair 
(2020 to 2023).

Mr Utsler is a former non-executive Director 
of Integrated Asset Solutions (2017 to 2021) 
and Oil Search Limited (2021) and has 
previously served on a variety of not-for-
profit boards including the West Australian 
Symphony Orchestra (WASO).

Current directorships/other interests: 

Director: SciDev Pty Ltd (since 2024). 

Other directorships of listed entities within 
the past three years: Chair of Otto Energy 
Limited (2020 to 2023) and non-executive 
Director of Oil Search Limited (2021). 

Term of office: Director since  
17 December 2021

P   A

Independent: Yes 

Experience: Mr Werror brings over 20 years 
of leadership experience in the mining and 
resources sector in PNG. 

Mr Werror commenced his long career at 
Ok Tedi Mining Ltd as a graduate in 1988, 
and previously held various roles and 
responsibilities including managing health, 
safety and environment, mine closure 
planning, tax credit scheme projects, 
government affairs and leading community 
relations in Western Province, PNG.

Mr Werror was a non-executive Director 
of Oil Search Limited (2021), Managing 
Director and CEO of Ok Tedi Mining Ltd 
(2020 to 2022), the Chair of Ok Tedi 
Development Foundation (2020 to 2022) 
and Chair of Western Province Health 
Authority (2019 to 2023).

Current directorships/other interests:

Director: Mayur Resources Limited 
(since 2024).

Other directorships of listed entities within 
the past three years: non-executive Director 
of Oil Search Limited (2021).

125

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationSantos  
Leadership Team

Below the level of the Board, key management decisions are made by the Managing Director and CEO and the Santos 
Leadership Team in accordance with the Delegation of Authority. The Managing Director and CEO's biography can be read 
on page 123 in the Board of Directors.

Michael Abbott
Group General Counsel and Executive 
Vice President Environmental 
Approvals and Governance

BA, LLB, MBA

Mr Abbott is responsible for the Company’s 
Legal, Company Secretary, Business 
Integrity, Government Relations, Risk, Audit 
and Compliance, Environment Approvals 
and Cultural Heritage. Mr Abbott also serves 
as a Director on the Board of the Santos 
Foundation. 

Mr Abbott has over 30 years’ experience as 
a lawyer, and 17 years in various corporate 
roles with responsibilities including legal, 
internal audit, risk, governance, external 
affairs, security and properties. He has held 
leadership roles at Woodside and Ampol 
and prior to that was a salaried partner at 
Baker & McKenzie in Hong Kong. 

Brett Darley

Executive Vice President Eastern 
Australia and Papua New Guinea

BEng (Civil), FIEAust Eng Exec

Mr Darley joined Santos in December 2018. 
He previously led the Offshore Operating 
Division as Executive Vice President 
Offshore Oil and Gas. 

He has 30 years of experience in the 
upstream oil and gas industry, both in 
Australia and overseas, with technical, 
operational, commercial and management 
experience across varied assets, onshore 
and offshore. 

Mr Darley previously held senior leadership 
roles including CEO of Quadrant Energy 
and Managing Director and Region Vice 
President for Apache Energy Limited, Vice 
President of Drilling and Completions at 
Woodside Energy and Drilling Manager at 
Santos. 

Bruce Dingeman 
Executive Vice President Alaska

BEng (Petroleum), MBA (Hons)

Mr Dingeman joined Santos in December 
2021 as part of the Company’s merger with 
Oil Search. He had been working in Oil 
Search’s Alaska Business Unit since 2018, 
where he served as President.

Mr Dingeman joined Santos with more than 
35 years of global oil and gas industry 
experience. He began his career in Alaska, 
and since that time has held a wide range 
of technical, financial and executive 
leadership roles across international and 
domestic locations at ConocoPhillips, 
Talisman, CASA Exploration, Naftogaz and 
Oil Search. 

Sherry Duhe
Chief Financial Officer

BComm Accounting and Internal Audit, 
MBA, GAICD

Ms Duhe joined Santos in October 2024,  
as Chief Financial Officer. 

With close to 30 years’ global experience, 
primarily in the oil and gas industry, Ms 
Duhe has held senior finance, commercial, 
and M&A roles in Australia, the US, Europe 
and the Middle East. 

Most recently, Ms Duhe was interim CEO  
at Newcrest Limited where she worked 
closely with management and the Board  
to successfully negotiate and complete  
the sale of the company to Newmont. 

Jodie Hatherly 
CEO Santos Foundation

BA, LLB, GAICD

Ms Hatherly was appointed CEO of the 
Santos Foundation and a Director of Santos 
Foundation (Australia) upon its 
establishment in July 2023, and appointed a 
Director of the Santos Foundation Limited 
(PNG) Board in April 2024.

Prior to this, from 2019 Ms Hatherly was 
General Counsel and Company Secretary of 
the Santos Group.

Ms Hatherly joined Santos from INPEX 
Australia, where she was General Counsel 
and General Manager Legal for the Ichthys 
LNG project and INPEX’s Australia business.

Ms Duhe previously served as Chief 
Financial Officer at Woodside Energy for 
four years until early 2022, prior to which 
she had a 13-year career with Shell, holding 
varied international finance roles.

Ms Hatherly commenced her career in the 
private sector, working in the UK and 
Australia and has served on the advisory 
board of the Curtin University Law School 
as well as Muscular Dystrophy WA.

Rebecca Jones
Executive Vice President Subsurface 
and Portfolio Management

BSc. Geology & Biology (Hons), MSc DIC 
(Petroleum Geoscience), FGS

Ms Jones joined Santos in 2021 and was 
appointed Executive Vice President 
Subsurface and Portfolio Management in 
March 2024. Her previous roles at Santos 
include Deputy Executive Vice President, 
Upstream Gas and Liquids and Vice 
President Subsurface. 

Ms Jones has over 30 years’ international 
upstream experience, having held technical 
leadership roles at a number of independent 
oil and gas companies globally, including 
Mobil, Woodside, Enterprise Oil, Maersk and 
Apache. She was involved in large-scale 
upstream transaction and strategy in her 
role as Global Director Upstream Deals with 
PwC in London. 

A member of the Society of Petroleum 
Engineers, Ms Jones is also a Fellow of the 
Geological Society of London.

126

Santos Annual Report 2024 
Kim Lee 
Executive Vice President People, 
Culture and Brand

Anthony Neilson
Executive Vice President Marketing 
and Trading

BSc Biological Sciences

BComm, MBA, FFin, FCA

Ms Lee joined Santos in January 2023, as 
the Executive Vice President, People and 
Culture. She is responsible for delivering the 
People strategy at Santos, as well as 
providing leadership support to 
partnerships and branding. 

Ms Lee has more than 20 years of 
experience in a number of senior executive 
roles across Australia and internationally. 
She has worked in many diverse industries 
including fast moving consumer goods 
(FMCG), building products, paper and 
packaging, hospitality, tourism and gaming, 
in both large private and ASX-listed 
companies. 

Most recently, Ms Lee held senior executive 
roles as Chief People and Performance 
Officer, Transformation and Chief of Staff at 
The Star Entertainment Group.

Mr Neilson joined Santos in 2016 and was 
appointed Executive Vice President 
Marketing and Trading in January 2025. 

Previously he held the roles of Chief 
Financial Officer and later Chief Commercial 
Officer, where he was responsible for the 
commercial function as well as business 
development and marketing and trading.

Mr Neilson brings over 25 years of 
experience in chartered accounting, banking 
and corporate financial roles including more 
than 20 years’ experience in the upstream 
and downstream oil and gas industry. 

Mr Neilson is a Fellow of the Financial 
Services Institute of Australasia, and a 
Fellow of Chartered Accountants Australia 
and New Zealand.

Vincent Santostefano
Executive Vice President Western 
Australia, Northern Australia and 
Timor-Leste

BEng (Civil), SPE

Mr Santostefano rejoined Santos in 
September 2023 as Executive Vice 
President Western Australia, Northern 
Australia and Timor-Leste, after being 
engaged in various management and 
technical consulting assignments as well as 
a Board non-executive Director. 

Previously he spent over four years at 
Santos as Chief Developments and 
Operations Officer, where he was 
responsible for supporting the business 
during the turnaround and for the profit and 
loss of all operating assets. 

Throughout his career, Mr Santostefano has 
held technical and leadership roles at Esso 
Australia, Beach Energy and Woodside 
Energy. He was at Woodside for 16 years 
and his last senior executive role prior to 
leaving was Chief Operations Officer.

Alan Stuart-Grant
Executive Vice President Santos 
Energy Solutions

Steven Trench
Executive Vice President Operations 
and Technical Services

BSc (Business Administration), GAICD

BEng (Civil) Hons, MBA, GAICD

Mr Stuart-Grant joined Santos in August 
2023 as Executive Vice President, Santos 
Energy Solutions. He is accountable for 
Santos Energy Solutions portfolio 
management and strategy, encompassing 
our midstream, carbon capture and storage, 
and low carbon fuels activities.

He has more than 20 years’ experience in 
the energy and industrial sectors globally. 
He previously held leadership positions at 
Ampol Limited and in the oil and gas 
department of Glencore plc, which followed 
extensive experience in investment banking 
and private equity in Australia, Europe 
and Asia.

Mr Stuart-Grant is a graduate of the Harvard 
Business School Advanced Management 
Program.

Mr Trench joined Santos in 2021 and was 
appointed Executive Vice President, 
Operations and Technical Services in 
December 2023. 

He is responsible for global operations 
management systems, capabilities, 
innovation and performance oversight 
across production operations, process 
safety, production planning, major project 
assurance, drilling and completions, 
procurement and supply chain; health, 
safety, environment and security. Mr Trench 
has 25 years, global experience in the oil 
and gas industry. Before joining Santos, he 
spent 22 years at Woodside Energy where 
he held technical and operational leadership 
roles, across drilling and completions, 
supply chain logistics, development 
coordination, production and asset 
management, including leadership of North 
West Shelf Karratha LNG. He also served in 
strategy and governance roles, including as 
Vice President of Strategic Planning.

Tracey Winters
Chief Strategy Officer

BSc (Australian Environmental Studies)

Ms Winters joined Santos in 2017 and is 
Chief Strategy Officer, responsible for 
corporate and ESG strategy, media and 
external communications.

Ms Winters has held diverse roles in the 
resources and energy sector, including 
government and regulatory affairs, media 
and communications, environment, land 
access, project commercialisation, 
construction and asset management.  
She has also held senior roles in federal 
resources and energy policy and politics, 
and built a successful government approvals 
and environmental management consultancy.

127

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Corporate governance  
at Santos

Following is a list of the Company’s publicly available core governance framework documents, which are available on the 
Santos website at santos.com/about-us/corporate-governance/ and santos.com/about-us/corporate-governance/
committees-of-the-board/. These are outlined in relation to relevant principles in the ASX Corporate Governance Council’s 
Principles and Recommendation (4th Edition) (ASX Principles). 

Table 1: Core governance framework documents

ASX Principle

Principle 1: Lay solid foundations for management and 
oversight

Principle 2: Structure the Board to be effective and  
add value

Principle 3: Instil a culture of acting lawfully, ethically  
and responsibly

Relevant document/information
Santos Board Charter

Nomination Committee Charter 

Diversity and Inclusion Policy

Santos Board Charter

Nomination Committee Charter

Code of Conduct 

Securities Dealing Policy

Diversity and Inclusion Policy 

Climate Policy

Tax Contribution Disclosure 

Environment, Health and Safety Policy 

Local and Indigenous Communities Policy

Human Rights and Modern Slavery Policy

Anti-Corruption and Sanctions Compliance Procedure

Reporting Misconduct (Whistleblower) Procedure

Principle 4: Safeguard the integrity of corporate reports

Audit and Risk Committee Charter

Principle 5: Make timely and balanced disclosure

Market Communication and Continuous Disclosure Policy

Principle 6: Respect the rights of security holders

Company Constitution

Principle 7: Recognise and manage risk

Audit and Risk Committee Charter

Market Communication and Continuous Disclosure Policy

Santos’ corporate governance and investor web pages

Principle 8: Remunerate fairly and responsibly

People, Remuneration and Culture Committee Charter

Safety and Sustainability Committee Charter 

Risk Management Policy

Environment, Health and Safety Policy

Climate Policy

128

Santos Annual Report 2024Overview of Santos’ corporate governance framework

The purpose of our corporate governance framework is to assist our people to make good decisions that promote the 
longer-term success of Santos. Our corporate governance framework and its link to the Company’s values and culture is 
shown in the following diagram.

The Board is committed to Santos being a good corporate citizen with a culture that values high standards of ethical and 
socially responsible conduct. The Board also oversees Santos’ compliance with our legal obligations in all operations in 
accordance with the Santos values, which can be found on page 12 of this Annual Report. The Board, including through its 
various Board Committees, is responsible for setting, assessing and reinforcing the Santos culture.

Board 
Accountable to shareholders for the performance of Santos. Responsible for 
overseeing the safe and sustainable operations of the Company in accordance 
with the Company's values

Board Committees  
All Board Committees have procedures and practices in place to promote 
effective communication between them in relation to matters of shared 
responsibility. They assist the Board to discharge its responsibilities in relation to:

People, 
Remuneration 
and Culture

Including the 
frameworks, 
strategies and 
policies relating to 
people, 
remuneration and 
culture

Audit and Risk

Including risk 
management, 
internal and 
external audit, 
reserves and 
resources, 
financial reporting 
and 
Whistleblower/ 
Reporting 
Misconduct

Safety and 
Sustainability

Including safety 
and security, 
environment and 
nature, climate, 
community 
including 
Indigenous, 
cultural heritage, 
human rights and 
land access

Nomination

Including 
delivering and 
reviewing 
nomination 
criteria for Board 
membership and 
reviewing the 
structure, size and 
composition of 
the Board and the 
effectiveness of 
the Board as a 
whole

Regularly monitors the Risk 
Management Framework including 
the Risk Management Policy and 
material changes in risk appetite

Responsible for regular monitoring 
and reviewing Santos' approach to 
sustainability and climate, including our 
Climate Policy and sustainability and 
climate change risks and opportunities

Santos Management System: Delegation of Authority, operating and technical 
standards, procedures, including Risk Appetite Statement, Risk Management 
Framework, Assurance Framework and the annual internal audit planning process

Approves Santos' values 
and monitors our 
performance in line with 
our values

Approves the Santos' Code 
of Conduct 

Receives recommendations 
from all Board Committees

Reviews climate material 
enterprise risks

Receives recommendations 
from the Safety and 
Sustainability Committee 
on climate and 
sustainability-related issues 
and Santos' performance 
in managing climate risks 
and opportunities.

Receives updates on 
climate developments from 
subject matter experts 
including information 
about risks, risk mitigation 
measures, opportunities 
and the financial impacts 
for Santos arising from 
climate-related issues

Management under the leadership of the  
Managing Director and CEO 

Responsible for delivering the strategic direction and goals approved  
by the Board

The CEO as a member of 
the Board, along with the 
other Directors and Chair, 
are responsible for setting, 
assessing and reinforcing 
the Santos culture

Supported by teams who continually monitor and assess trends and changes in 
Australian and international energy markets, assess and model a range of energy 
mix scenarios based on varying policy and technology drivers, and conduct 
portfolio and asset reviews of our business and strategy

129

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
Part 1:
Santos Management System

The Santos Management System (SMS) applies to all of Santos’ people and establishes the requirements as to how Santos 
does business across our assets and functional support teams. It is designed to protect our people, the communities where 
Santos operates, and the safe and effective operation of our assets and conduct of our activities. The SMS comprises:

•  Delegation of Authority

•  operating standards explaining the minimum standards for what the business must achieve

•  technical standards, procedures, processes and tools explaining the expectations and practices for how business 

activities should be undertaken.

Various business teams are responsible for the day-to-day implementation of plans, processes, procedures and tools that 
are embedded within the SMS and align with the seven sustainability pillars. Each sustainability pillar has an assigned 
business owner who supports communication and reporting of performance.

For effective cross-functional communication on issues related to climate change and sustainability, Santos’ governance 
processes include meetings across a range of business groups, and Executive Leadership Team meetings to require 
conformance with the SMS and track delivery against plans and targets.

Board responsibilities

The Board is accountable to the shareholders for the performance of the Company. The Board oversees the safe and 
sustainable operations of the Company in accordance with the Company’s values. The Board’s focus is to pursue increases 
in shareholder value within a Risk Management Framework that respects all stakeholder interests. The Board understands 
the importance of a strong and healthy working relationship with management, and seeks to ensure that management 
implements sound strategies consistent with the Board’s overriding objectives.

1.1 Responsibilities

The Board is responsible for the overall corporate governance of the Company, including approving the strategic direction 
and financial objectives, oversight of the performance and operations of the Company, establishing goals for management 
and monitoring the attainment of these goals. 

The Board views sustainability, including climate, as a material strategic issue for Santos. The Board approves sustainability 
and climate strategy, goals and targets, the CTAP and related policies (including Climate Policy) and oversees performance 
against these. Sustainability and climate matters are discussed at Board and committee meetings, and the Board reviews 
and approves relevant material sustainability and climate-related disclosures including the Annual Report (including the 
Sustainability and Climate Reports), Modern Slavery and Industry Associations Statements. The Charters for the Board and 
each relevant Commitee formally outline the responsibilities of each body in respect of climate, including the monitoring 
and review of climate-related risks.

Each Director is required to ensure they are able to devote sufficient time to discharge their duties, and prepare for Board 
and Committee meetings and associated activities.

The Company Secretary is accountable directly to the Board, through the Chair, on all matters to do with the proper 
functioning of the Board. All Directors have direct access to the Company Secretary and the Company Secretary has a 
direct reporting line to the Chair.

Table 2: Board responsibilities

The Board’s responsibilities include:

• 

leading by example

•  overseeing the strategic direction and management of the Company

•  approving the annual capital and operating budget

•  approving Delegations of Authority to management

•  approving significant acquisitions and disposals of assets

•  approving significant expenditure decisions outside the Board-approved corporate budget

•  approving and monitoring performance against strategic plans and corporate budgets

•  approving and monitoring the Company’s Purpose, values, ethical standards and Code of Conduct

•  setting the Company’s risk appetite and overseeing the integrity of material business risk management

•  selecting, evaluating and succession planning for Directors, the CEO and Company Secretary, and generally endorsing 

the same for the CEO’s direct reports

•  setting the remuneration of Directors and the CEO, and generally endorsing the remuneration for the CEO’s direct reports

•  monitoring whether the Company’s remuneration policies and practices are aligned to the Company’s values, strategic 

direction and risk appetite

•  appointing and removing the external auditor

130

Santos Annual Report 2024Delegation of Authority

The Board delegates management of the Company’s day-to-day affairs to the Company’s Executive Leadership 
Team under the leadership of the Managing Director and CEO. This is formally documented in the Company’s 
Delegation of Authority. Management is accountable to the Board for the discharge of this delegated authority and 
for compliance with any limits on that authority (including complying with the law and Company policies).

Responsibilities delegated by the Board to management:

The conduct and operation of the Company’s business in the ordinary course

Implementing corporate strategies

Operating under approved budgets and written Delegations of Authority

The CEO and other Senior Executives are employed under written employment contracts that set out their rights, duties 
and responsibilities. Senior Executives are subject to rigorous background checks before they are appointed.

Management’s discharge of its responsibilities is monitored through regular Board reporting and performance evaluations 
against pre-determined performance objectives.

Performance evaluations of Senior Executives are usually undertaken by the CEO, having regard to key performance 
indicators (KPIs) set at the start of the year. The Chair undertakes the CEO’s annual review. During 2024, performance 
evaluations were undertaken in accordance with this process.

The results of these reviews are used in determining succession plans, performance and development plans, and 
remuneration in consultation with the People, Remuneration and Culture Committee.

Details of Santos’ policies and practices regarding remuneration of Senior Executives and Directors, and the remuneration 
received by the CEO and Senior Executives are set out in the Remuneration Report, commencing on page 169. This includes 
short- and long-term incentives relating to Company and individual performance targets. Details of non-executive Director 
remuneration are separately set out in the Remuneration Report on page 198.

131

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Part 2:  
Composition of the Board

2.1 Board composition and Director independence

Under the Company’s Constitution, the Board must have a minimum of five Directors (not including the Managing Director) 
and a maximum of ten. Directors, other than the Managing Director, are required to seek election at the first Annual General 
Meeting (AGM) after their appointment, and thereafter may not remain in office without re-election for more than three 
years or past the third AGM following their last election or re-election.

At every AGM of the Company, one-third of Directors must retire from office (after excluding the Managing Director and 
any new Directors standing for election for the first time).

To ensure regular Board renewal, the Board Charter contains a guideline that the expected tenure of a non-executive 
Director will be between six and nine years. This guideline is applied flexibly, and it is expected that some non-executive 
Directors may remain in office for longer periods where appropriate, for instance, to maintain the desired mix of skills and 
experience on the Board.

The Board assesses the independence of each Director, having regard to the factors relevant to assessing independence set 
out in the ASX Principles. Each Director’s independence is assessed by the Board on an individual basis, focusing on an 
assessment of each Director’s capacity to bring independence of judgement to Board decisions. In this context, Directors 
are required to make prompt disclosure to the Board of any changes in interests in material shareholdings, contracts, 
personal ties, cross-directorships and other factors or relationships that may be relevant in considering their independence.

Directors must declare any conflict of interest that they may have at the commencement of all Board meetings. Where a 
material personal interest arises with respect to a matter that is to be considered by the Board, the Director is required to 
declare that interest and must not take part in any Board discussion, or vote, in relation to that matter, unless permitted in 
accordance with the Corporations Act.

Table 3: Directors of the Company as at 31 December 2024

Name*
Yasmin Allen

Kevin Gallagher (Managing Director and CEO)

Vanessa Guthrie

John Lydon

Janine McArdle

Vickki McFadden

Keith Spence (Chair)

Michael Utsler

Musje Werror

Date of initial 
appointment
October 2014

February 2016

July 2017

April 2024**

October 2019

April 2024**

January 2018

May 2022***

December 2021***

Independent 
Y/N
Y

N

Y

Y

Y

Y

Y

Y

Y

Period  
of office
Full year

Full year

Full year

8 months

Full year

8 months

Full year

Full year

Full year

* 

 Note: Ms Eileen Doyle and Mr Peter Hearl were Directors during the reporting period from 1 January 2024, up until their retirement, effective 11 April 2024.  
Mr Guy Cowan was a Director during the reporting period, up until his retirement, effective 1 October 2024.

**  Note: Mr John Lydon and Ms Vickki McFadden were appointed as Directors on 11 April 2024.

*** 

 Note: Mr Musje Werror was appointed to the Oil Search Limited Board on 23 February 2021. Mr Michael Utsler was appointed to the Oil Search Limited Board on 
30 April 2021. Tenure on the Oil Search Limited Board has been carried over to the Santos Limited Board appointments.

132

Santos Annual Report 2024Directors and Directors’ shareholdings

The names of Directors of the Company during the year ended 31 December 2024, and up to the date of this report, along 
with details of the relevant interest of each of those Directors in shares in the Company at the date of this report, are as set 
out below:

Surname
Allen

Cowan

Doyle

Gallagher

Guthrie

Hearl

Lydon

Other names
Yasmin Anita
Guy Michael1
Eileen Joy2
Kevin Thomas (Managing Director and CEO)3
Vanessa Ann
Peter Roland4
John Gerard

McArdle

Janine Marie

McFadden

Vickki Anne 

Spence

Utsler

Werror

Keith William (Chair)

Michael Jesse

Musje Moses

Shareholdings in Santos Limited
48,883

-

-

2,166,731

39,188

-

63,797

50,000

26,000

119,945

40,000

17,820

1 

2 

3 

4 

 Mr Cowan held a balance of 45,487 fully paid ordinary shares at the date of his resignation as a Director on 1 October 2024.

 Ms Doyle held a balance of 47,367 fully paid ordinary shares at the date of her resignation as a Director on 11 April 2024.

Includes shares received as a result of the 2021 LTI vesting.

 Mr Hearl held a balance of 48,808 fully paid ordinary shares at the date of his resignation as a Director on 11 April 2024.

The abovenamed Directors held office during the financial year. Ms Doyle and Mr Hearl resigned as Directors on 11 April 
2024 and Mr Cowan resigned as a Director on 1 October 2024. Mr John Lydon and Ms Vickki McFadden were appointed as 
Directors on 11 April 2024. The remaining Directors were in office for the full year.

There were no other persons who acted as Directors at any time during the financial year and up to the date of this report. 
All shareholdings are of fully paid ordinary shares. No Director holds a relevant interest in a related body corporate of 
Santos Limited. 

At the date of this report, Mr Gallagher holds 2,417,889 share acquisition rights (SARs) and 146,253 restricted shares. No 
other Director holds options or SARs.

Details of the qualifications, experience and special responsibilities of each Director are set out in the Directors’ biographies 
on pages 123–125 of this Annual Report. This information includes details of other listed company directorships held during 
the last three years.

133

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 2:  
Composition of the Board
(continued)

2.2 Board capabilities

In determining the composition of the Board, consideration is given to whether the composition and mix remain 
appropriate and cover the skills needed to position the Company in respect of existing and emerging business risks, 
opportunities, strategy and governance issues. As the needs of the Board are dynamic, these skills and experiences may 
change over time. As the Company’s strategy evolves, the Board’s competencies will be reassessed to ensure they continue 
to align with the Company’s strategy. Board members bring diverse skill sets that support oversight of each of the seven 
sustainability pillars. The Board has a process for members to be informed on sustainability issues, including climate, via 
input from the Senior Leadership Team as well as independent advice when considered appropriate.

Directors are appointed primarily based on their capacity to contribute to the Company’s development. The Board Charter 
also recognises that the Board should include at least some members with experience in the upstream oil and gas and/or 
resources industries.

The following diagram shows how the Company’s governance arrangements (described in further detail in sections 129–131) 
support Santos in building an effective Board, with the breadth and depth of background, skills, experience and diversity 
necessary to guide the Company’s strategic growth plans.

Defining required skills  
and experience

Identifying areas for  
further development

Improving Board effectiveness

To ensure the skills and 
experience available on the 
Board align with Santos’ 
strategy the Board considers:

•  current business plans and 

operations

•  strategic plans for the 

future

• 

industry background and 
experience

Areas for further development, 
skills and experience that 
would complement existing 
skills and experience are 
identified by:

•  Board performance review 

to assess current 
capabilities

•  Nomination Committee 

consideration of succession 
planning

Steps taken to improve the 
Board’s effectiveness include:

•  site visits to enhance Board 
assessment of culture and 
understanding of operations

•  annual Board performance 

review

•  review of Board meeting 

effectiveness at the end of 
each Board meeting

Key actions in 2024

Key actions in 2024

Key actions in 2024

Board Strategy Day in May 
2024 

Section of each Board agenda 
dedicated to strategic matters 
and increased time allocated 
to strategy discussions

Appointment of two new 
Directors and changes to 
Committee Chairs and 
membership

Board composition diagnostic 
and skills assessment

External Board performance 
review

Continuation of education 
program including Code of 
Conduct training and 
education sessions relating to 
anti-corruption and sanctions 
compliance, carbon markets, 
external markets, geopolitical 
developments, low emissions 
pathways and the role of 
natural gas.

Site visits to PNG, Roma and 
Darwin LNG

Implementation of 
improvement actions identified 
in 2023 Board performance 
review and Board meeting 
effectiveness discussions

134

Santos Annual Report 2024The matrix below demonstrates the skills, experience and diversity of the Directors in office at the end of 2024 across 
several dimensions that are relevant to Santos as a global energy company. The skills matrix provides an overview of the 
relevant skills possessed by the Directors.

The matrix divides skills into critical and general categories, designed to prioritise the skill sets that are most relevant and 
specific to the Company's strategic priorities and Vision, and provides a collective view of these. Critical skills are the skills 
identified as the most critical for the Board over the next three-to-five years. Critical skills typically cannot be delegated to 
management or external advisors, and often demand specific professional expertise and experience. General skills, while 
still important, are considered less specific to the Company than critical skills. General skills are identified as those skills for 
which deep expertise on the Board is not essential and skills in which Directors can be trained or can be filled through 
management capability or external expertise and advisers. 

The Board is satisfied that this skills matrix demonstrates that the Board has the appropriate composition and mix of skills 
needed to position the Board to guide the Company in respect of existing and emerging business risks, opportunities, 
strategy and governance issues.

Directors with Primary skills 
Consistent ability to identify complex oversights

Critical

Summary

Oil and gas industry

Energy markets

Energy transition

Strategy and planning

Experience includes: Major project development and construction, 
project governance and assurance, production operations, 
unconventional hydrocarbons and supply and demand dynamics – 
particularly Asia Pacific region.

Experience includes: Global oil, gas and LNG markets – particularly Asia 
Pacific region for LNG, domestic gas market and east coast and west 
coast Australia power markets.

Experience includes: Greenhouse gas emissions oversight, 
decarbonisation, lower carbon energy technologies, global lower carbon 
energy markets, emissions reduction units and carbon trading and 
emerging trends.

Experience includes: Strategic process and implementation, strategy 
measurement and accountability, business planning and budgeting, 
portfolio-based capital allocation and strategic thinking.

Government engagement

Experience includes: Government relations, understanding of the 
political, policy and regulatory process, communication of policy 
positions and key government relationships.

Oil and gas mergers, 
acquisitions and divestments

Experience includes: Oil and gas due diligence, transaction structuring, 
multi-country acquisition integration and major industry transactions.

Social licence

Innovation and disruption

Experience includes: Sustainability governance, the process and 
preparation of sustainability reporting (including climate), community 
engagement, socially responsible operations, human rights and modern 
slavery oversight and community and social responsibility oversight.

Experience includes: Substantial and relevant disruption/industry 
transformation, emerging technology and skill implications, leading new 
venture development, changes to value models and industry structure 
and enterprise-wide transformation.

5

5

5

9

6

5

6

5

135

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 2:  
Composition of the Board
(continued)

Directors with Primary skills 
Consistent ability to identify complex oversights

General

Accounting and finance

Remuneration

Experience includes: External and internal audit, the process and 
preparation of financial statements, scale-appropriate financial systems/
processes, relevant financing/funding and understanding of equity/debt 
structures.

Experience includes: Setting balanced remuneration frameworks, external 
remuneration engagement, short/long-term performance incentives and 
the process and preparation of remuneration reporting.

Organisation culture 
development

Experience includes: Measurement and reporting, cultural interventions, 
establishing a positive organisational culture, building a culturally safe 
workspace and diversity initiatives.

Talent and leadership 
development

Experience includes: Leadership development, talent development and 
succession planning.

Risk management

Experience includes: Risk management systems and assurance, crisis 
management, regulatory risk management and cybersecurity risk 
management.

Communications and 
corporate affairs

Experience includes: Reputation management, external communication, 
crisis management, social licence and building digital presence.

Investor engagement

Experience includes: Understanding of investor narrative and positioning, 
investor communications and proxy advisor engagement.

International business

Experience includes: International executive experience in Asia Pacific 
(ex-Australia), internationalisation of a high-performance culture, 
community and social responsibility and international business 
connections.

Health, safety and 
environment

Experience includes: Health and safety and environment management 
systems; and health and safety and environment reporting oversight.

Corporate experience

Experience includes: Significant profit and loss leadership, track record of 
long-term value creation, relevant Board experience, Board/committee 
leadership and understanding of Board processes and procedures.

4

7

8

8

8

5

7

7

7

7

136

Santos Annual Report 2024Gender diversity 

Cultural diversity

 Male 

 Female 

56%

44%

Generational diversity

Board tenure in years

 51–55 

 56–60 

 61–65 

 66–70 

12%

33%

33%

22%

 Australia 

 UK 

 USA 

44%

22%

22%

 PNG/West Papua 

12%

 0–1 

 2–4 

 5–6 

 7–8 

 9–10 

 10–11 

22%

22%

11%

22%

11%

12%

Names and details of the experience, qualifications, special responsibilities (including Committee memberships) and term of 
office of each Director of the Company can be found on pages 123–125.

2.3 Director selection and succession planning

The Board renewal process is overseen by the Nomination Committee. It involves regularly reviewing the composition of the 
Board to determine whether the composition and mix remain appropriate and cover the skills needed to position the Board 
to guide the Company in respect of existing and emerging business risks, opportunities, strategy and governance issues. 
This will inform Board succession planning and renewal.

In making recommendations relating to Board composition, the Nomination Committee takes into account both the current 
and future needs of the Company. The Nomination Committee specifically considers each of the Directors coming up for 
re-election and makes an assessment as to whether to recommend the Board nominate a Director for re-election by 
shareholders. This assessment considers matters including their contribution to the Board, the results of Board and 
Committee reviews and the ongoing needs of the Company. The Committee also takes into account the succession plans of 
the Directors more broadly.

The Nomination Committee is responsible for defining the desired attributes and skill sets for a new Director. The services 
of an independent consultant are then used, where appropriate, to assist in the identification and assessment of a range of 
potential candidates based on a brief from the Nomination Committee. The Nomination Committee reviews prospective 
candidates and arranges for appropriate background checks to be undertaken, then makes recommendations to the Board 
regarding possible appointments of Directors, including recommendations for appointments to committees.

When Director candidates are submitted to shareholders for election or re-election, the Company includes in the Notice of 
Meeting biographical and other details that the Board considers relevant to shareholders’ decision to elect or re-elect the 
candidate, and the Board’s recommendation and the basis for it.

137

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 2:  
Composition of the Board
(continued)

2.4 Director appointment, induction and continuing education

Prior to appointment, each non-executive Director is provided with a letter of appointment, which sets out the terms of 
their appointment and includes copies of the Company’s Constitution, Board Charter, Committee Charters and relevant 
policies and procedures.

The expectations of the Board in respect of a proposed appointee to the Board and the workings of the Board and its 
Committees are also conveyed in interviews with the Chair. Induction includes site visits, access to appropriate Executives in 
relation to details of the business of the Company, and functional overviews of the Company’s strategic objectives and 
operations.

Directors are encouraged to continue their education by attending both internal and external training and education 
programs relevant to their role. During 2024, the Board conducted site visits to Papua New Guinea, Roma and Darwin LNG, 
attended Code of Conduct training and educations sessions relating to anti-corruption and sanctions compliance, carbon 
markets, external markets and geopolitical developments and low emissions pathways and the role of natural gas. Further 
opportunities for Board education continue to be pursued, and are informed by the outcomes of the Board skills review. 
This program is reviewed periodically to ensure Directors receive ongoing education in areas that will assist them to 
discharge their roles effectively.

All Directors have the right to access Company information, and the Board Charter sets out the circumstances and 
procedures pursuant to which a Director may seek independent professional advice at the Company’s expense.

2.5 Reviews of Board, Board Committees and Director performance

As specified in the Board Charter, reviews of the Board, its Committees and its individual Directors are conducted annually. 
At least once every three years, the annual reviews of the Board, Committees and individual Directors are carried out by an 
independent consultant.

The scope of the external review is agreed in advance with the Board. In the other years, an internal review is undertaken. 
Internal reviews are facilitated by the Chair, in consultation with the Nomination Committee. These involve questionnaires 
and formal interviews with each Director culminating in a written report prepared by the Chair.

In 2024, an external review of the performance of the Board and its Committees and individual Directors was conducted. 
Feedback from the 2023 review was incorporated into the Board’s practices in 2024.

The Board has established a number of Committees to assist with the effective discharge of its duties. The role of each 
Committee is set out in Part 3 on pages 139-141.

All Committees are chaired by, and composed of a majority of independent non-executive Directors.

Each Committee operates under a specific charter approved by the Board. From time to time Board Committees conduct 
their own internal review of their performance, structure, objectives and purpose.

Board Committees have access to internal and external resources, including to advice from independent external 
consultants or specialists.

The Chair of each Committee provides an oral report at the next Board meeting, and Committees refer to the Board and 
other Committees any matters that come to their attention that are relevant to them. Each Committee is responsible for 
ensuring an appropriate framework exists for relevant information to be reported by management to the Committee. 
Minutes of each Committee meeting are distributed to all Board members.

The membership requirements of each Committee are outlined in that Committee’s Charter. The Board regularly reviews 
Committee membership. Each Committee’s membership currently satisfies, and satisfied during the year, the membership 
requirements in the Charters and the composition requirements in the ASX Principles and ASX Listing Rules.

Details of the number of times the Board and each Committee met during the year, including the Committee memberships 
of each Director and their attendance at Board and Committee meetings, appear in the Corporate Governance Statement 
on page 142. Board members are encouraged to, and usually, attend all Committee meetings, even if they are not members. 
In 2024, the Board Chair attended all Committee meetings.

Members of management attend relevant parts of Board and Committee meetings, at which they report to Directors within 
their respective areas of responsibility. Where appropriate, advisers to the Company attend meetings of the Board and of 
its Committees.

Board meetings regularly include a session at which the independent non-executive Directors meet without the CEO or 
other members of management present.

The Board may, from time to time and where circumstances require, form ad hoc committees to consider specific matters 
requested by the Board.

138

Santos Annual Report 2024Part 3:
Board Committees

3.1 Role and activities of Committees

Table 4: Audit and Risk Committee

Composition

Membership in 2024

Purpose and responsibilities

Guy Cowan (Chair and 
member until October 
2024)

Vickki McFadden (Chair) 
(member from April 2024, 
Chair from October 2024)

Yasmin Allen  
Janine McArdle  
Michael Utsler

Musje Werror  
(from April 2024)

Must be comprised of at 
least three members, who 
are independent non-
executive Directors.

Chaired by an 
independent non- 
executive Director who  
is not the Board Chair.

Between them, members 
must have sufficient 
accounting and financial 
expertise, and an 
understanding of the oil 
and gas industry, to be 
able to discharge the 
Committee’s 
responsibilities.

The Committee must 
include at least one 
member who is also a 
member of the Safety and 
Sustainability Committee.

The purpose of the Committee is to oversee financial 
management and reporting, risk management and internal 
controls across Santos. Specifically, the Committee is responsible 
for:

•  reporting: overseeing the balance, transparency and integrity 

of published financial information

•  risk: reviewing the enterprise Risk Management Framework at 
least annually to satisfy itself that it continues to be sound and 
that management is operating with due regard to the risk 
appetite set by the Board

•  material incidents: reviewing relevant material incidents 
involving a breakdown of Santos’ risk controls, including 
recommendations to improve control effectiveness

• 

• 

internal controls: reviewing the adequacy and effectiveness of 
Santos’ internal control systems and framework

internal audit: satisfying itself with the effectiveness of the 
internal audit function and to approve the appointment and 
removal of the Vice President Risk, Audit and Compliance (or 
equivalent role) and review the adequacy of resources and 
performance, objectivity, independence and effectiveness of 
the risk and audit function

•  reviewing reports: reviewing reports from management on 
any material breaches of Santos’ Code of Conduct and 
Anti-Corruption and Sanctions Compliance Procedure or 
material incidents involving fraud

•  external audit: reviewing the independence of the external 
auditor, recommending the appointment of the external 
auditor to the Board and assessing the performance of that 
external auditor

•  reserves and resources reporting: assessing the 

appropriateness of the systems, processes and methods used 
in relation to reserves and resources estimation

•  compliance: reviewing the effectiveness of the regulatory 

compliance program 

•  whistleblower/reporting misconduct: reviewing the 

independence and effectiveness of the system, including by 
receiving, at least on a quarterly basis, an overview of 
whistleblower/reporting misconduct complaints.

139

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Part 3:
Board Committees
(continued)

Table 5: Safety and Sustainability Committee

Composition

Membership in 2024

Purpose and responsibilities

Must include at least three 
non-executive Directors 
and the Managing 
Director.

Peter Hearl (Chair and 
member until April 2024)

Vanessa Guthrie (Chair 
from April 2024) 

Kevin Gallagher  
Janine McArdle  
John Lydon  
(from April 2024)

Eileen Doyle  
(until April 2024)

Chaired by an 
independent non- 
executive Director who is 
not the Board Chair.

The Committee must 
include one member who 
is also a member of the 
Audit and Risk Committee, 
and one member who is 
also a member of the 
People, Remuneration and 
Culture Committee.

The purpose of the Committee is to oversee the governance and 
review of Santos’ sustainability-related activities in the areas of 
safety and security, environment and nature, climate, community, 
including Indigenous, cultural heritage, human rights and land 
access (Sustainability Remit). Specifically, the Committee is 
responsible for:

•  periodically reviewing the scope of the Sustainability Remit and 
the appropriateness of the Company’s policies and practices 
relating to evolving regulations, business circumstances and 
stakeholder expectations that impact the Company’s exposure 
to, and management of, material sustainability issues

•  monitoring the effectiveness of the Company’s management 

system to achieve the requirements of the applicable Company 
policies and all applicable legislation

•  monitoring and reviewing performance and material risks and 

opportunities that are relevant to the Company at every meeting

•  receiving and considering reports on all major changes to the 

Company’s responsibilities

•  receiving and considering reports on any significant incident

•  monitoring and reviewing the Company’s annual public or 

statutory reporting within the Sustainability Remit

•  maintaining an appropriate level of knowledge of research, 

developments, risks and applicable legislation

•  monitoring plans and targets set by the Board and reviewing the 

Company's progress in achieving those plans and targets

•  monitoring and reviewing the appropriateness and progress of 
implementation of the Company’s governance and compliance 
arrangements

•  reporting and making recommendations to the Board on any 
such matters to which the Board has referred the Committee.

140

Santos Annual Report 2024 
Table 6: Nomination Committee

Composition

Membership in 2024

Purpose and responsibilities

Includes at least three 
independent non- 
executive Directors 
including the Chair  
of the Board.

Chaired by the Board 
Chair.

Keith Spence (Chair) 
Janine McArdle (from 
April 2024)

John Lydon  
(from April 2024)

Peter Hearl  
(until April 2024)

Guy Cowan  
(until April 2024)

Yasmin Allen  
(until April 2024)

The purpose of the Committee is to assist the Board with its 
succession planning, propose candidates for consideration by the 
Board to fill casual vacancies or additions to the Board, to devise 
and review criteria for Board membership to review the structure, 
size and composition of the Board and the effectiveness of the 
Board as a whole. Specifically, the Committee is responsible for:

•  assessing the necessary and desirable competencies of Board 

members and regularly reviewing and, where necessary, 
updating the Board skills matrix in light of that assessment

•  reviewing Board succession plans to maintain an appropriate 
balance of skills, knowledge, experience, independence and 
diversity that will position the Board to guide the Company

•  as requested by the Board, assisting the Board in relation to 
evaluating the Board’s performance and, as appropriate, 
developing and implementing a plan for identifying, assessing 
and enhancing Director competencies

•  recommending the appointment and replacement of Directors

•  reporting and making recommendations to the Board on any 

matters that the Board has referred to the Committee.

Table 7: People, Remuneration and Culture Committee

Composition

Membership in 2024

Purpose and responsibilities

Includes at least three 
members, who are non- 
executive Directors and 
the majority of whom  
are independent.

Michael Utsler (Chair 
from April 2024) 

Yasmin Allen  
(Chair until April 2024)

Chaired by an 
independent non- 
executive Director.

Vanessa Guthrie  
Musje Werror 
Vickki McFadden  
(from April 2024)

Peter Hearl  
(until April 2024)

The People, Remuneration and Culture Committee is responsible 
for reviewing the remuneration policies and practices of the 
Company. Specifically, the Committee is responsible for:

•  assisting the Board to oversee and review the operation of 

Santos’ frameworks, strategies and policies relating to people, 
remuneration and culture

•  the remuneration arrangements for the Managing Director 
and CEO, and Executive Leadership Team members, and 
incentive award outcomes (including whether the Board 
should consider exercising any discretion)

•  the Remuneration Report and recommending the report to 

the Board for its approval

•  development and succession plans in relation to the CEO and 

Executive Leadership Team

•  the remuneration policies and practices for the Company 

generally, and reviewing whether they are aligned with the 
Company’s values, strategic direction and risk appetite

•  the annual remuneration review applying generally across the 

Company

•  Company superannuation arrangements

•  Non-executive Director remuneration

•  the Company’s organisational design, values and development 
of the key capabilities and culture necessary for alignment 
with strategic objectives

•  the Company’s people and culture strategies, policies and 

initiatives, including employee engagement surveys and other 
indicators of organisational culture

•  setting measurable objectives for achieving gender diversity 
and an annual assessment of those objectives as well as 
progress in achieving them, which will be reported to the Board.

141

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 3:
Board Committees
(continued)

Board meetings

The number of Board meetings and meetings of Board Committees held during the financial year and the number of 
meetings attended by each Director are set out below:

Table of Board meetings

Director
Allen
Cowan2
Doyle3
Gallagher

Guthrie
Hearl4
Lydon5
McArdle
McFadden6
Spence

Utsler

Werror

Yasmin Anita

Guy Michael

Eileen Joy

Kevin Thomas

Vanessa Ann

Peter Roland

John Gerard

Janine Marie

Vickki Anne

Keith William

Michael Jesse

Musje Moses

Board 
meetings

Attended/
Held1
10 of 10

8 of 8

5 of 5

10 of 10

10 of 10

5 of 5

5 of 5

10 of 10

5 of 5

10 of 10

10 of 10

10 of 10

Audit & Risk 
Committee

Attended/
Held1
4 of 4

3 of 3

n/a

n/a

n/a

n/a

n/a

4 of 4

3 of 3

n/a

4 of 4

3 of 3

Safety & 
Sustainability 
Committee

People, 
Remuneration 
& Culture 
Committee

Attended/
Held1
n/a

Attended/
Held1
4 of 4

Nomination 
Committee

Attended/
Held1
1 of 1

n/a

2 of 2

4 of 4

4 of 4

2 of 2

2 of 2

4 of 4

n/a

n/a

n/a

n/a

n/a

n/a

n/a

4 of 4

1 of 1

n/a

n/a

3 of 3

n/a

3 of 3

4 of 4

1 of 1

n/a

n/a

n/a

1 of 1

2 of 2

2 of 2

n/a

3 of 3

n/a

n/a

1 

Reflects the number of meetings held during the time the Director held office, or was a member of the Committee, during the year.

2  Mr Cowan retired as a Director on 1 October 2024.

3  Ms Doyle retired as a Director on 11 April 2024.

4  Mr Hearl retired as a Director on 11 April 2024.

5  Mr Lydon was appointed to the Board and the Safety and Sustainability Committee and the Nomination Committee on 11 April 2024.

6  Ms McFadden was appointed to the Board and the Audit and Risk Committee and the People, Remuneration and Culture Committee on 11 April 2024.

142

Santos Annual Report 2024Part 4:
Risk management

4.1 Risk management roles and responsibilities

The Board is responsible, with the assistance of the Audit and Risk Committee, for reviewing the Company’s Risk 
Management Framework at least annually to satisfy itself that it continues to be sound and that management is operating 
with due regard to the risk appetite set by the Board. 

The Risk Management Framework comprises a number of key elements, defining the requirements to manage risk at the 
enterprise, regional, project and operational level. 

Enterprise risks are captured in a central register and supported with risk bow-tie diagrams for each risk showing the 
relationship between cause, consequence and controls. This provides visibility of controls to be operationalised by the 
Santos Management System (SMS). 

Santos also monitors emerging risks which have the potential to disrupt the business in the future. The enterprise risk 
register carries a risk related to external environmental conditions, prompting regular review of threats such as emerging 
disruptive technologies, geopolitical developments or changing societal views that may impact the Company. Additionally, 
known risks such as Cyber Security are continually monitored for new or emerging technologies and strategies which may 
require modifications to the Company’s internal control environment.

Risk appetite is described in the Company’s Risk Appetite Statement which defines tolerance levels for strategic, financial, 
operational, cyber, reputational and commercial risk exposures. 

The Board, with the assistance of the Audit and Risk Committee assesses the effectiveness of the Risk Management 
Framework, at least annually, in identifying, monitoring and managing materials risks. Following this review the Committee 
may make recommendations to the Board in relation to changes that should be made to the framework. 

An independent review of the framework is also performed periodically to assure effectiveness and continuous improvement.

In 2024, the Audit and Risk Committee reviewed the Risk Management Framework and confirmed its effectiveness and also 
acknowledged significant improvements that have been delivered during the year, such as the creation of new technical 
standards within the SMS for Risk Management and also for a range of risks exposures, such a environment, health and 
safety, community, Indigenous engagement, people and culture. 

As part of Santos’ internal review, the Board reviewed and approved the updated Risk Appetite Statement. The Risk 
Appetite Statement is designed to support and inform Board and management decision-making and is reviewed at least 
annually to ensure ongoing alignment with strategic objectives. The Audit and Risk Committee also annually assesses that 
management is operating with due regard to the Risk Appetite Statement.

During 2024, the Audit and Risk Committee also reviewed the enterprise-wide risks, and the risk controls and mitigations 
that management has put in place in relation to those risks. The Board has continued to undertake regular ‘deep dives’ into 
the Company’s enterprise risks and incorporated reviews of operational and project risks into the Board’s site visits to 
Papua New Guinea, Roma and Darwin LNG.

4.2 Internal audit

Internal audit sits within the broader Group Risk, Audit and Compliance function that provides independent and objective 
assurance of the Company’s system of risk management, internal control and governance. The function reports to the  
Audit and Risk Committee, maintains and makes recommendations in relation to the Risk Management Framework, and 
undertakes audits and other advisory services to assure risk management across the Company. Group Risk, Audit and 
Compliance is independent of the external auditor and the Vice President Risk, Audit and Compliance is appointed by,  
and reports to, the Audit and Risk Committee, with functional oversight by the Group General Counsel and Executive  
Vice President Environment and Governance. The Audit and Risk Committee meets with the internal and external auditors 
separately without management present at least annually.

Santos adopts a risk-based approach in developing annual internal audit plans that align audit activities to the key risks and 
control frameworks across the Company. The 2024 Internal Audit Plan was approved by the Audit and Risk Committee, and 
tested the effectiveness of controls related to a selection of risk-based topics and also the level of conformance by the regional 
business, divisions and functions against the SMS operating standards which were released in February 2024. The conformance 
review established a baseline to establish improvement plans and progress against these will be assessed in 2025. 

4.3 Compliance management

The Board is also responsible, with the assistance of the Audit and Risk Committee, for ensuring the implementation and 
effectiveness of the regulatory compliance management program. The Audit and Risk Committee assists the Board in 
performing its role in relation to risk management by reviewing, at least annually, the effectiveness of the Santos’ 
Compliance Framework. Santos has an approved Compliance Framework that provides a consistent methodology for 
material regulatory obligations across the business to be identified, managed, reported and remediated should gaps exist. 
This Framework is aligned with international compliance standard ISO 37301.

143

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 4:
Risk management
(continued)

Implementation of the Compliance Framework and review of its effectiveness through ongoing assurance of regulatory 
compliance performance against the framework is led by the Group Compliance function and regular reports are provided 
to the Audit and Risk Committee on the implementation and assurance of the Compliance Framework. Implementation is 
currently supported by compliance reviews across several areas of the business. Reviews and assurance are conducted in 
accordance with an approved annual plan that is presented to the Board at the beginning of each year.

4.4 CEO and CFO assurance

The Board receives written certifications from the CEO and the CFO in relation to the Company’s financial reporting 
processes for the full and half-year reporting periods. Before the Board approved the financial statements for the half year 
ended 30 June 2024 and full year ended 31 December 2024, the CEO and CFO declared that, in their opinion, the financial 
records of the Company had been properly maintained and that the financial statements and associated notes complied 
with the appropriate accounting standards, and gave a true and fair view of the financial position and performance of the 
Company. They also declared that this opinion had been formed on the basis of a sound system of risk management and 
internal control that was operating effectively in all material aspects, including in relation to financial reporting risks. In 
addition, for the full year ended 31 December 2024, the CEO and CFO declared that in their opinion the Consolidated Entity 
Disclosure Statement was true and correct.

4.5 Business and sustainability risks

The Operating and Financial Review on pages 157–166 of the 2024 Annual Report contains detailed information about its 
material business risks, including its exposure to economic, environmental, health and social risks and how that exposure 
is managed.

4.6 External audit

The Audit and Risk Committee makes recommendations to the Board about the selection, appointment and independence 
of the Company’s external auditor.

The Audit and Risk Committee reviews and approves the scope and adequacy of the annual external audit plan, the terms 
of the annual engagement letter and audit fees. Findings and recommendations made by the external auditor are reviewed 
including regular assessment of the effectiveness of assurance provided and the independence of the external auditor. 

External auditors are provided with unrestricted and confidential access to the Committee Chair or, if deemed appropriate 
by the external auditors, the Chair of the Board.

The Company has a procedure in relation to the provision of non-audit services by the Company’s external auditor.  
The procedure requires that services considered to be in conflict with the role of statutory auditor are not performed by 
the Company’s external auditor, and prescribes the approval process for non-audit services where the Company’s external 
auditor is used.

A copy of the Auditor’s Independence Declaration, as required under section 307C of the Corporations Act, is set out on 
page 290 of the 2024 Annual Report.

144

Santos Annual Report 2024 
Part 5:
Diversity, ethics and conduct

5.1 Diversity

A safe, diverse and inclusive workplace environment is critical to achieving our Purpose and Vision 2040. Aligned to our 
strategic imperatives and Santos values, we will create an inclusive work environment to harness our local workforce and 
the diversity of thought which enables the creativity and innovation to achieve our Purpose and Vision 2040.

The Diversity and Inclusion Policy outlines our commitment to embracing a diverse workforce and an inclusive work 
environment. 

Santos’ People and Remuneration Committee is responsible for setting measurable objectives for achieving diversity, and 
ensuring the effectiveness of the Diversity and Inclusion Policy and related key performance indicators. Additionally, the 
Santos Leadership Team monitor people demographics, including key diversity and inclusion indicators, through quarterly 
reporting.

In 2025 we will continue evolving our diversity and inclusion strategy through the following key objectives:

•  Increase female representation across the employee workforce

•  Increase female representation in leadership roles

•  Increase Aboriginal and Torres Strait Islander representation in our Australian 

workforce

•  Create a ‘Santos One Team’ inclusive work environment where all our people 
can be themselves, feel supported, respected and have a sense of belonging

•  Foster cross-cultural awareness and understanding across our different 

geographical locations

•  Maintain gender equity

145

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Part 5:
Diversity, ethics and conduct
(continued)

Table 8: Measurable objectives

In line with our objective to build an inclusive workplace and continue investing in a diverse, highly capable workforce and a 
high-performance culture, the following measurable objectives have been set to continue to monitor progress and trends 
across a three-year time horizon.

Objectives and metrics

Build diversity
Increase female percentage of new hires

Increase female representation:

•  Board (maintain above 30%)
•  Executive Leadership1
•  Senior Leadership roles (JG21+)2
•  General workforce3
 – Field workforce

 – Non-field workforce

Maintain gender pay equity

Local employment

Australia
Increase Aboriginal and Torres Strait Islander peoples in the Australian workforce

PNG
Increase PNG citizen representation in PNG workforce
Increase PNG citizen representation in PNG in Mid-Senior Leadership roles (JG18-20)6

Foster inclusion
Increase inclusion index in employee surveys7

1 

2 

Executive leadership is CEO direct reports. CEO/MD is included in Board.

Senior Leadership roles is JG21+ (Leading Business).

3  General workforce refers to the employee population (does not include contractors).

4  Based on the results of the annual pay equity audit.

5  Not previously reported.

6  Mid-Senior Leadership roles refer to employees JG18-20 (Leading Teams) leadership level in PNG.

7 

Baseline Inclusion index established as part of Real Talk employee survey.

31 December 
2021

31 December 
2024

44.9%

37.7%

40.0%

31.3%

18.7%

24.0%

8.8%

35.4%
Equal4

44.4%

41.7%

32.1%

28.1%

11.9%

40.7%
Equal4

1.6%

2.7%

87.8%
NPR5

NPR5

91.0%

70.5%

72%

146

Santos Annual Report 20245.2 Ethical standards and Code of Conduct

Santos’ Directors, employees and contractors are expected to demonstrate high standards of professional and business 
conduct, and to comply with legal requirements wherever the Company operates.

The Company’s Code of Conduct sets out Santos’ values, policies, guidelines and expected behaviours with respect to 
safety, business conduct, environmental and other requirements. It is a key element of the Santos Management System 
(SMS). The SMS is a framework of policies, standards and procedures that set out mandatory performance requirements. 
The Code of Conduct is regularly reviewed.

All breaches of the Code of Conduct must be reported directly to specified Santos management personnel or any other 
eligible recipient (as defined in section 1317AAC(1) of the Corporations Act). Material breaches are also reported to the 
Audit and Risk Committee.

All employees are required to undertake a periodic refresher on the Code of Conduct by completing an online training 
module annually. This training module is also a compulsory component of new employee inductions available across Santos’ 
operations and geographic locations, including Alaska, Timor-Leste and Papua New Guinea.

Reportable misconduct

The Company has a Reporting Misconduct (Whistleblower) Procedure that outlines the process for reporting and 
investigating reportable misconduct. A key part of Santos’ commitment to achieving high standards of ethical conduct and 
compliance with its legal obligations involves creating and maintaining a working environment in which Santos workers (or 
other Eligible Whistleblowers) are able to freely raise concerns regarding actual or suspected unethical, unlawful or 
undesirable conduct, and to protect Santos workers (or other Eligible Whistleblowers) from reprisal. Material incidents 
reported under the Reporting Misconduct (Whistleblower) Procedure are reported at each Audit and Risk Committee 
meeting.

Additionally, Santos’ Anti-Corruption and Sanctions Compliance Procedure sets out the expectations and requirements for 
the identification and reporting of corruption and bribery, and sanctions at Santos. Material breaches of the Anti-Corruption 
and Sanctions Compliance Procedure must be reported to the Audit and Risk Committee.

Our values are further embedded in our Code of Conduct and LEAP (Leader, Expert and Professional) behavioural 
framework, which provide guidance on our expected behaviours across the Company.

The Code of Conduct describes how we put our commitment to be a good corporate citizen into practice every day and 
sets out the mandatory standards for how we interact with others, how we make decisions, the actions we take and the way 
in which we carry out our work. Any person who performs work for, or on behalf of Santos, must comply with Santos’ Code 
of Conduct, which contains the following core requirements:

•  We work safely and look out for the safety of our colleagues.

•  Our workplace is free from harassment, discrimination and bullying.

•  We act ethically and lawfully in all business conduct.

•  We understand and manage the impact of our operations on the environment and engage with our stakeholders with 

respect.

•  We communicate accurately and honestly with investors, government and the community.

•  All trading in Santos securities occurs in compliance with the Securities Dealing Policy.

•  Everyone at Santos is expected to understand and comply with the standards in the Code of Conduct.

•  All breaches of the Code of Conduct must be reported.

Our values, Code of Conduct and policies form the foundation of Santos’ corporate governance framework.

5.3 Securities Dealing Policy

The Securities Dealing Policy prohibits Directors, Executives, employees, contractors, consultants, secondees and advisers 
of Santos (collectively, Santos Personnel) from acquiring, selling or otherwise trading in the Company’s securities when they 
are in possession of market-sensitive information or inside information that is not in the public domain.

It also limits ‘Designated Persons’ (as well as connected persons whom a Designated Person may be expected to have 
control or influence over) to dealing in Santos securities during ‘Trading Windows’ and prohibits them from dealing in the 
Company’s securities on a short-term basis. They are not permitted to hedge their securities (including options and share 
acquisition rights) unless those securities have fully vested and are no longer subject to restrictions. The Securities Dealing 
Policy incorporates a ‘front page test’, that all Santos Personnel must apply before dealing in Santos securities.

Breaches of the Securities Dealing Policy are regarded as serious misconduct and are subject to appropriate sanctions, 
which could include disciplinary action or termination of employment.

147

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationPart 5:
Diversity, ethics and conduct
(continued)

5.4 Market communication and continuous disclosure

The Company is committed to giving all shareholders timely and equal access to information concerning the Company.

The Company has developed policies and procedures to ensure Directors and management are aware of, and fulfil, their 
obligations in relation to the timely disclosure of material price-sensitive information. In accordance with the Market 
Communication and Continuous Disclosure Policy, information must not be selectively disclosed prior to being announced 
to the ASX.

When the Company makes an announcement to the market, that announcement is released to the ASX and the Papua New 
Guinea National Stock Exchange (PNGX). The Board receives copies of all material market announcements after they have 
been made. A copy of new and substantive investor or analyst presentations is released to the ASX Market Announcements 
Platform ahead of the presentation. The Company Secretary and Head of Investor Relations are responsible for 
communications with the exchanges. All ASX announcements are lodged with the PNGX and made available  
on the Company’s website at santos.com after their release by the ASX. Other materials available on the Santos website 
include annual and half-year reports, notices of meetings, media releases and materials presented at investor, media and 
analyst briefings. An email alert facility is also offered to shareholders. Webcasting of material presentations, including 
annual and half-yearly results presentations, is provided for the benefit of shareholders, regardless of their location.

Santos facilitates and encourages shareholder participation at the Annual General Meeting. The Annual General Meeting 
provides an opportunity for any shareholder or their representative or proxy to attend, hear updates about Santos and ask 
questions of the Board and exercise their vote. Shareholders who are unable to attend the Annual General Meeting are 
encouraged to submit a directed proxy before the meeting and may also submit written questions in advance of the 
meeting. Before the meeting, copies of the speeches delivered by the Chair and CEO at the Annual General Meeting are 
released to the ASX and PNGX exchanges and posted on our website. In 2024, the Santos Annual General Meeting was held 
as an in-person meeting. Santos’ practice is to conduct all voting at the Annual General Meeting on substantive resolutions 
on a poll, to ensure that outcomes of voting reflect the proportionate holdings of all shareholders who vote (whether in 
person, when possible, or by proxy or other representative).

Consistent with previous practice, Santos made a recording of the event available for later viewing. Additionally, the 
Company’s external auditor attends Annual General Meetings to be available to answer shareholder questions relevant to 
the conduct of the audit.

The Board is conscious of its obligations to shareholders and will seek their approval as required by the Company’s 
Constitution, the Corporations Act and the ASX Listing Rules, or where otherwise considered appropriate by the Directors.

The Company also has in place an investor relations program of scheduled and ad hoc briefings with shareholders, analysts 
and financial media. The program is aimed at facilitating effective two-way communications with investors and provides an 
opportunity for the Company’s investors to interact with Senior Management and to gain a greater understanding of the 
Company’s business, financial performance, prospects and corporate governance. Information about Santos and its 
governance is available on the Company’s website at santos.com/about-us/corporate-governance.

The Company’s dedicated investor relations team and share registry provide shareholders with the option to send and 
receive electronic communications. Any shareholder can request to send and receive electronic communications via links on 
the Santos website.

5.5 Verification of periodic corporate reports

The Company is committed to:

•  providing all investors with material information in a full and timely manner

•  disclosing material information to the market in a clear, concise, factual and balanced manner.

The Company has a comprehensive process for preparing, verifying and approving external corporate reports and the full 
and half-year financial statements. 

Santos publishes additional unaudited information in the annual and half-year reports and quarterly reports. Although this 
information is not externally audited, material statements in these documents are verified by the responsible business 
Executive prior to approval for release to the market. In 2024, a new Document Verification Procedure was approved, which 
outlines that the verification must be documented with reference to, where possible, written source materials and data. It is 
signed off by the responsible business Executive and progresses through a hierarchy of reviews and approvals before 
release to the market.

The Board reviews and approves the full and half-year reports and any other matters that are significant in terms of Santos’ 
policy or strategy. Quarterly reports are approved by the CEO following review by the Company’s Disclosure Officers.

This Corporate Governance Statement is current as at 31 December 2024 and has been approved by the Board of Santos 
Limited on 18 February 2025.

148

Santos Annual Report 2024O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

RESERVES 
STATEMENT

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

Santos Annual Report 2024

149
149

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
Reserves Statement
for the year ended 31 December 2024

Reserves and resources

At 31 December 2024, Santos’ proved plus probable (2P) reserves are 1,559 million barrels of oil equivalent (mmboe) and 
the 2C contingent resources are 3,338 mmboe. 

Before production of 87 mmboe, 2P reserves decreased by 15 mmboe. This is inclusive of a 30 mmboe reduction following 
completion of the sale of a 2.6 per cent interest in PNG LNG to Kumul. Additions in Cooper Basin (+2 mmboe), Queensland 
coal seam gas fields (+4 mmboe), PNG (+6 mmboe) and revisions to reflect ongoing production at Bayu-Undan, Reindeer 
and Van Gogh (+1 mmboe each) gave an organic reserves increase of 15 mmboe. 

The annual 2P reserves replacement ratio (RRR) was -17 per cent, 2P organic RRR was +17 per cent and the three-year RRR 
was 58 per cent. The 2P reserves held in international assets comprise 41 per cent of Santos’ total 2P reserves. 

The 2C contingent resources increased by 13 mmboe. Additions in offshore Northern Australia and Western Australia, 
Alaska and Queensland were partially offset by relinquishment of the Burnside acreage offshore Northern Australia. 

The 2P CO2 storage capacity remains unchanged at 9 million tonnes after injection of 0.2 million tonnes, following 
successful startup of the Moomba CCS project. The 2C contingent storage resources have increased 47 million tonnes  
to 178 million tonnes in the Cooper Basin.

Reserves and 2C contingent resources 

Santos share as at 31 December

Santos share
Proved reserves

Proved plus probable reserves

2C contingent resources

Unit
mmboe

mmboe

mmboe

Reserves and 2C contingent resources by product 

2024

 917 

 1,559 

 3,338 

2023
 998 

 1,661 

 3,325 

% change
(8%)

(6%)

0%

Santos share as at 31 December

Santos share
Proved reserves

Proved plus probable reserves

2C contingent resources

Key metrics  

Sales gas  
PJ

Crude oil 
mmbbl

Condensate 
mmbbl

LPG  
000 tonnes

 4,498 

 7,580 

 14,775 

 113 

 200 

 635 

 29 

 53 

 142 

 363 

 739 

 3,517 

Total  
mmboe

 917 

 1,559 

 3,338

Annual proved reserves replacement ratio

Annual proved plus probable reserves replacement ratio

Three-year proved plus probable reserves replacement ratio

Organic annual proved plus probable reserves replacement ratio

Organic three-year proved plus probable reserves replacement ratio

Developed proved plus probable reserves as a proportion of total reserves
Reserves life1

1 

2P reserves life as at 31 December 2024 using production of 87 mmboe. 

7%

-17%

58%

17%

67%

40%

18 years

150

Santos Annual Report 2024 
 
 
Proved reserves

Santos share as at 31 December 2024

Sales gas  
PJ

Crude oil 
mmbbl

Condensate 
mmbbl

LPG  
000 tonnes

Developed Undeveloped

All products 
mmboe

Asset
Cooper Basin
Queensland & NSW1
PNG

Northern Australia  
& Timor-Leste

Western Australia

USA (Alaska)

 236 

 938 

 1,828 

 1,268 

 228 

 - 

 9 

 - 

 9 

 - 

 6 

 90 

Total 1P
Proportion of total proved reserves that are unconventional

 4,498 

 113 

 3 

 - 

 13 

 12 

 2 

 - 

 29 

 363 

 - 

 - 

 - 

 - 

 - 

 363 

 41 

 117 

 209 

 - 

 36 

 - 

 403 

 13 

 45 

 126 

 229 

 11 

 90 

 514 

1 

 Queensland proved sales gas reserves include 787 PJ GLNG and 144 PJ other Santos non-GLNG Eastern Queensland assets.

Proved reserves reconciliation

Product
Sales gas

Crude oil

Condensate

LPG

Total 1P 

Unit
PJ

mmbbl

mmbbl

000 tonnes

mmboe

2023
 4,923 

Production
(442)

Revisions and 
extensions
135 

 118 

 32 

 372 

 998 

(6)

(4)

(100)

(87)

2 

2 

88 

27 

Net 
acquisitions 
and 
divestments
(118)

- 

(1)

3 

(21)

Total

 55 

 161 

 335 

 229 

 46 

 90 

 917 
18%

2024
 4,498 

 113 

 29 

 363 

 917

151

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationTotal

 116 

 310 

 471 

 375 

 123 

 165 

 1,559 
20%

2024
 7,580 

 200 

 53 

 739 

 1,559

Reserves Statement
for the year ended 31 December 2024

Proved plus probable reserves

Santos share as at 31 December 2024

Sales gas  
PJ

Crude oil 
mmbbl

Condensate 
mmbbl

LPG  
000 tonnes

Developed Undeveloped 

All products  
mmboe

Asset
Cooper Basin
Queensland & NSW1
PNG

Northern Australia  
& Timor-Leste

Western Australia

USA (Alaska)

 529 

 1,803 

 2,567 

 2,047 

 634 

 - 

 14 

 - 

 12 

 - 

 9 

 165 

 5 

 - 

 18 

 24 

 5 

 - 

 737 

 - 

 - 

 2 

 - 

 - 

Total 2P
Proportion of total proved plus probable reserves that are unconventional

 7,580 

 200 

 53 

 739 

 78 

 136 

 318 

 0 

 90 

 - 

 623 

 38 

 174 

 153 

 374 

 32 

 165 

 936 

1 

Queensland proved plus probable sales gas reserves include 1,385 PJ GLNG and 410 PJ other Santos non-GLNG Eastern Queensland assets.

Proved plus probable reserves reconciliation

Product
Sales gas

Crude oil

Condensate

LPG

Total 2P 

Unit
PJ

mmbbl

mmbbl

000 tonnes

mmboe

2023
 8,106 

 207 

 57 

 791 

 1,661 

Production
(442)

Revisions and 
extensions
84 

(6)

(4)

(100)

(87)

(1)

1 

43 

15 

Net 
acquisitions 
and 
divestments
(167)

- 

(1)

4 

(30)

152

Santos Annual Report 2024 
2C contingent resources

Santos share as at 31 December 2024

Asset
Cooper Basin

Queensland & NSW

PNG

Northern Australia & Timor-Leste

Western Australia

USA (Alaska)

Sales gas  
PJ

Crude oil 
mmbbl

Condensate 
mmbbl

LPG  
000 tonnes

All products 
mmboe

 1,149 

 3,043 

 4,557 

 4,643 

 1,382 

 - 

 28 

 - 

 10 

 - 

 149 

 447 

 635 

 17 

 - 

 57 

 48 

 20 

 - 

 142 

 1,660 

 - 

 - 

 - 

 1,857 

 - 

 3,517 

Total 2C
Proportion of total contingent resources that are unconventional

 14,775 

2C contingent resources reconciliation

Product

Total 2C 

Unit

mmboe

2023

 3,325 

Revisions and 
extensions

Discoveries

Net 
acquisitions 
and 
divestments

67 

10 

(64)

 255 

 523 

 847 

 843 

 422 

 447 

 3,338
24%

2024

 3,338

CO2 storage capacity and 2C contingent storage resources 

Santos share as at 31 December 2024

CO2 storage
Proved capacity

Proved plus probable capacity

2C contingent storage resources

Unit
MtCO2

MtCO2

MtCO2

2024

 6 

 9 

 178 

2023
 6 

 9 

 131 

% change
(3%)

(2%)

36%

Capacity and 2C contingent storage resources reconciliation

CO2 storage
Proved capacity

Proved plus  
probable capacity

2C contingent  
storage resources

Unit
MtCO2

MtCO2

MtCO2

Revisions 
and 

2023
 6 

Injection
(0)

extensions Discoveries
- 

- 

Net 
acquisitions 
and 
divestments
- 

 9 

 131 

(0)

-

- 

- 

- 

47 

- 

- 

2024
 6 

 9 

 178

153

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
Reserves Statement
for the year ended 31 December 2024

Notes 

1. 

This Reserves Statement:

6. 

a. 

b. 

c. 

 is based on, and fairly represents, 
information and supporting 
documentation prepared by, or under the 
supervision of, the qualified petroleum 
reserves and resources evaluators listed in 
note 14 of this Reserves Statement. 
Details of each qualified petroleum 
reserves and resources evaluator’s 
employment and professional 
organisation membership are set out in 
note 14 of this Reserves Statement; and

 as a whole has been approved by Steve 
Lawton, who is a qualified petroleum 
reserves and resources evaluator and 
whose employment and professional 
organisation membership details are set 
out in note 14 of this Reserves Statement; 
and

 is issued with the prior written consent of 
Steve Lawton as to the form and context 
in which the estimated petroleum 
reserves and contingent resources and 
the supporting information are presented.

 The estimates of petroleum reserves, 
contingent resources and CO2 storage 
quantities contained in this Reserves 
Statement are as at 31 December 2024.

 Santos prepares its petroleum reserves and 
contingent resources estimates in accordance 
with the 2018 Petroleum Resources 
Management System (PRMS) and CO2 storage 
capacity and contingent storage resource 
estimates in accordance with the 2017 CO2 
Storage Resources Management System 
(SRMS) sponsored by the Society of 
Petroleum Engineers (SPE). 

 This Reserves Statement is subject to risk 
factors associated with the oil and gas 
industry. It is believed that the expectations of 
petroleum reserves and contingent resources 
reflected in this statement are reasonable, but 
they may be affected by a range of variables 
which could cause actual results or trends to 
differ materially, including but not limited to: 
price fluctuations, actual demand, currency 
fluctuations, geotechnical factors, drilling and 
production results, gas commercialisation, 
development progress, operating results, 
engineering estimates, loss of market, industry 
competition, environmental risks, physical 
risks, legislative, fiscal and regulatory 
developments, economic and financial markets 
conditions in various countries, approvals and 
cost estimates.

 All estimates of petroleum reserves, 
contingent resources and CO2 storage 
reported by Santos are prepared by, or under 
the supervision of, a qualified petroleum 
reserves and resources evaluator or evaluators. 
Processes are documented in the Santos 
Reserves Policy which is overseen by a 
Reserves Committee. The frequency of reviews 
is dependent on the magnitude of the 
petroleum reserves and contingent resources 
and changes indicated by new data. If the 
changes are material, they are reviewed by the 
Santos internal technical leaders and externally 
audited.

2. 

3. 

4. 

5. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

 Santos engages independent experts Gaffney, 
Cline & Associates, Netherland, Sewell & 
Associates, Inc., RISC Advisory Pty Ltd and 
Ryder Scott Company to audit and/or evaluate 
reserves, contingent resources and CO2 
storage. Each auditor found, based on the 
outcomes of its respective audit and 
evaluation, and its understanding of the 
estimation processes employed by Santos, 
that Santos’ 31 December 2024 petroleum 
reserves, contingent resources and CO2 
storage quantities in aggregate compare 
reasonably to those estimates prepared by 
each auditor. Thus, in the aggregate, the total 
volumes summarised in the tables included in 
this Reserves Statement represent a 
reasonable estimate of Santos’ petroleum 
reserves, contingent resources and CO2 
storage position as at 31 December 2024. 

 Unless otherwise stated, all references to 
petroleum reserves, contingent resources and 
CO2 storage quantities in this Reserves 
Statement are Santos’ net share. PNG LNG is 
carried at 39.9 per cent following the 2.6 per 
cent sell down to Kumul.

 Reference points for Santos’ petroleum 
reserves and contingent resources and 
production are defined points within Santos’ 
operations where normal exploration and 
production business ceases, and quantities of 
produced product are measured under 
defined conditions prior to custody transfer. 
Fuel, flare and vent consumed to the reference 
points are excluded. 

 Petroleum reserves, contingent resources and 
CO2 storage are aggregated by arithmetic 
summation by category and as a result, proved 
reserves may be a very conservative estimate 
due to the portfolio effects of arithmetic 
summation.

 Petroleum reserves, contingent resources and 
CO2 storage are typically prepared by 
deterministic methods with support from 
probabilistic methods. 

 Any material concentrations of undeveloped 
petroleum reserves that have remained 
undeveloped for more than five years: (a) are 
intended to be developed when required to 
meet contractual obligations; and (b) have not 
been developed to date because they have 
not yet been required to meet contractual 
obligations. Development may comprise well 
construction, connection or facility activities. 

 Petroleum reserves replacement ratio is the 
ratio of the change in petroleum reserves 
(excluding production) divided by production. 
Organic reserves replacement ratio excludes 
net acquisitions and divestments.

 Information on petroleum reserves, contingent 
resources and CO2 storage quoted in this 
Reserves Statement is rounded to the nearest 
whole number. Some totals in the tables may 
not add due to rounding. Items that round to 
zero are represented by the number 0, while 
items that are actually zero are represented 
with a dash ‘-’.

14. 

 Qualified Petroleum Reserves and Resources 
Evaluators 

Name

Employer

S Lawton

Santos Ltd

M Dabiri

A White

Santos Ltd

Santos Ltd

J Cardwell

Santos Ltd

A Western

Santos Ltd 

Professional 
organisation

SPE

SPE

SPE

SPE

SPE

M Ireland

Santos Ltd

SPE, SPEE

J Hattner

NSAI

SPE, AAPG

SPE: Society of Petroleum Engineers

 SPEE: Society of Petroleum Evaluation 
Engineers

 AAPG: American Association of Petroleum 
Geologists

Abbreviations and conversion factors

Abbreviations

1P

2P

GJ

LNG

LPG

mmbbl

mmboe

MtCO2

NGLs

PJ

tcf

TJ

proved reserves

proved plus  
probable reserves

gigajoules

liquefied natural gas

liquefied petroleum gas

million barrels

million barrels of oil 
equivalent

million tonnes of 
carbon dioxide

natural gas liquids

petajoules

trillion cubic feet

terajoules

Conversion factors

Sales gas, 1 PJ

171,937 boe

Crude oil, 1 barrel

1 boe

Condensate, 1 barrel

0.935 boe

LPG, 1 tonne

8.458 boe

154

Santos Annual Report 2024 
 
 
 
 
 
 
 
O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

DIRECTORS’ 
REPORT

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s
’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

Santos Annual Report 2024

155

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
Directors’ Report

The Directors present their report together with the consolidated 
Financial Report of the consolidated entity, being Santos Limited 
(Santos or the Company) and its controlled entities, for the financial 
year ended 31 December 2024, and the Auditor’s Report thereon. 
Information in the Annual Report referred to in this report, including  
the Remuneration Report, or contained in a note to the financial 
statements referred to in this report, forms part of, and is to be read  
as part of, this report.

The Directors in office at any time during the year ended 31 December 2024 and up to the date of this report, and 
information on the Directors (including qualifications and experience and directorships of listed companies held by 
the Directors at any time in the last three years) are set out on pages 123–125 of this Annual Report. 

The number of Directors’ meetings held (including meetings of Committees of the Board) and the number of meetings 
attended by each of the Directors during the financial year are shown on page 142 of this Annual Report.

Details of the qualifications and experiences of the Company Secretary are set out in the Corporate directory on page 303 
of this Annual Report.

156

Santos Annual Report 2024Operating and Financial Review

Santos’ principal activities during 2024 were the exploration, development, production, transportation and marketing of 
hydrocarbons, and the development of decarbonisation technologies. Revenue is derived primarily from the sale of gas and 
liquid hydrocarbons. There have been no significant changes to the principal activities of Santos during 2024. Information 
about Santos' operations and business strategies is in page 16 and forms part of this Operating and Financial Review.

A review of the operations and the results of those operations of the consolidated entity during the year is as follows:

Summary of results table
Production volume

Sales volume

Product sales
EBITDAX1, 2
Exploration and evaluation expensed

Depreciation and depletion

Impairment loss

Change in future restoration assumptions
EBIT2
Net finance costs

Taxation expense

Net profit/(loss) for the period

Net profit/(loss) for the period attributable to equity holders of Santos
Underlying profit for the period attributable to equity holders of Santos2, 3
Underlying earnings per share (cents)4

2024  
mmboe

87.1

91.7

US$million

5,381

3,706

(69)

(1,679)

(123)

83

1,918

(169)

(485)

1,264

1,224

1,201

37.1

2023  
mmboe
91.7

96.4

US$million
5,889

4,083

(86)

(1,858)

(75)

(18)

2,046

(227)

(403)

1,416

1,416

1,423

43.6

Variance  
%
(5)

(5)

(9)

(9)

(20)

(10)

64

(561)

(6)

(26)

20

(11)

(14)

(16)

(15)

1 

2 

3 

4 

 EBITDAX (earnings before interest, tax, depreciation and depletion, exploration and evaluation expensed, net impairment loss and change in future restoration 
assumptions).

 EBIT (earnings before interest and tax), EBITDAX and underlying profit are non-IFRS measures that are presented to provide an understanding of the underlying 
performance of Santos’ operations.

 Underlying profit excludes the impacts of asset acquisitions, disposals and impairments, as well as items that are subject to significant variability from one 
period to the next, including the effects of commodity hedging. Refer to page 159 for the reconciliation from net profit to underlying profit for the period.

 Underlying earnings per share represents underlying profit for the period divided by the weighted average number of shares on issue during the year. The 
non-IFRS financial information is unaudited; however, the numbers have been extracted from the financial statements that have been subject to audit by the 
Company’s auditor.

Sales volume 
mmboe

107.1

104.2

112.3

96.4

91.7

Product sales revenue 
US$million

7,790

4,713

3,387

5,889

5,381

8000
7000
6000
5000
4000
3000
2000
1000
0

120

100

80

60

40

20

0

Production volume 
mmboe

89.0

92.1

91.7

87.1

103.2

2020

2021

2022

2023

2024

2020

2021

2022

2023

2024

2020

2021

2022

2023

2024

Sales volumes of 91.7 million barrels 
of oil equivalent (mmboe) was 
5 per cent lower than the previous 
year. This was primarily due to lower 
volumes in Western Australia and 
Northern Australia and Timor-Leste 
due to natural field decline and lower 
volumes from end of life fields. This 
was partially offset by higher volumes 
from upstream GLNG fields, Roma and 
Fairview during 2024.

Sales revenue of $5.4 billion was  
9 per cent lower compared to the 
previous year, primarily due to lower 
realised prices for LNG and crude oil 
and lower production volumes. The 
average realised oil price decreased  
3 per cent to US$84.76/bbl, and the 
average realised LNG price decreased 
3 per cent to US$12.31/mmBtu.  
This was partially offset by higher 
realised prices for condensate and 
LPG during 2024.

Production of 87.15 mmboe was  
5 per cent lower than prior year.  
This was primarily due to lower gas 
production in Western Australia, lower 
volumes from Bayu-Undan as the field 
approaches end of life, and lower 
production in PNG due to natural  
field decline. This was partially offset 
by Hides GTE re-starting in April 2024 
and the Angore fields coming online in 
Q4 2024.

5 

2024 pre-PSC production is 87.1 mmboe.

157

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
Directors’ Report
(continued)

Review of operations

A focus on operational excellence and project execution has delivered strong production and cash flow in 2024. There is 
also now line of sight to our major projects progressively coming online, starting with the Moomba CCS project, which came 
online in the second half of 2024. Other major projects will follow from 2025, ensuring Santos is in a strong position to 
deliver sustainable, competitive shareholder returns over the long term. 

At Santos there are three regional business units being Eastern Australia and Papua New Guinea, Western and Northern 
Australia and Timor-Leste, and Alaska. Each business unit executes both upstream development and Santos Energy 
Solutions activities. 

Regional Business Units

Eastern Australia and Papua New Guinea Business Unit 

Cooper Basin

Cooper Basin 
Production (mmboe) 
Sales volume (mmboe) 
Revenue (US$m) 
Production cost (US$/boe) 
EBITDAX (US$m) 
Capex – Upstream (US$m) 
Capex – SES (US$m) 

2024 
13.4
13.3
682
10.78
390
358
112

2023 
13.6
13.6
699
10.94
389
396
116

Cooper Basin EBITDAX was $390 million, in line with the corresponding period in 2023. 

Santos’ share of Cooper Basin sales gas and ethane production of 57.4 petajoules (PJ) was 0.9 per cent higher than the 
previous corresponding period (56.9 PJ). Weather events in the first half and planned maintenance through the year 
impacted Cooper Basin oil production during the period. The Granite Wash appraisal horizontal well, Moomba 389 was 
successfully drilled and is now online.

Queensland and NSW

Queensland and NSW 
Production (mmboe) 
Sales volume (mmboe) 
Revenue (US$m) 
Production cost (US$/boe) 
EBITDAX (US$m) 
Capex – Upstream (US$m) 

2024 
14.5
21.8
1,369
7.26
799
250

2023 
13.9
20.3
1,332
6.22
795
274

Queensland and NSW EBITDAX of $799 million was 0.5 per cent higher than the corresponding period in 2023. This was as 
a result of higher product sales, resulting from higher volumes from GLNG upstream fields, Roma and Fairview, and higher 
third-party product, partially offset by higher government royalties and higher production costs due to higher electricity 
costs and increased drilling activity. 

Papua New Guinea

PNG 
Production (mmboe) 
Sales volume (mmboe) 
Revenue (US$m) 
Production cost (US$/boe) 
EBITDAX (US$m) 
Capex – Upstream (US$m) 

2024 
39.5
36.8
2,576
6.47
2,042
350

2023 
40.5
38.8
2,884
6.32
2,342
477

PNG EBITDAX of $2,042 million decreased 13 per cent compared to the corresponding period in 2023, primarily due to 
lower realised prices and lower sales volumes. This was partially offset by Hides GTE re-starting in April 2024 and the 
Angore fields coming online in Q4 2024. In 2024, Santos completed the sale of 2.6 per cent of PNG LNG to Kumul 
Petroleum Holdings Limited (Kumul). Santos total cash consideration for the transaction was US$602 million.

158

Santos Annual Report 2024Western Australia, Northern Australia and Timor-Leste Business Unit 

Northern Australia and Timor-Leste

Northern Australia and Timor-Leste 
Production (mmboe) 
Sales volume (mmboe) 
Revenue (US$m) 
Production cost (US$/boe) 
EBITDAX (US$m) 
Capex – Upstream (US$m) 
Capex – SES (US$m)

2024 
0.8
0.8
50
86.27
0
549
2

2023 
2.6
2.6
141
39.79
66
515
2

Northern Australia and Timor-Leste EBITDAX was nil, due to lower production as it nears end of field life in the Bayu-Undan field. 
The Bayu-Undan field continues to produce beyond its LNG economic life. The asset will continue to provide required volumes, 
to support gas shortages in the Northern Territory, by providing domestic gas into this market.

The Santos-operated Barossa gas project, located in Commonwealth waters approximately 285 kilometres offshore 
northwest from Darwin in the Northern Territory, is an offshore gas and condensate project that proposes to provide a 
new source of gas to the existing Darwin LNG facility in the Northern Territory. The project will be net-zero reservoir 
emissions from day one, as required by the Safeguard Mechanism reforms. At 31 December 2024 the project was 
88.3 per cent complete, and on track for first gas in Q3 2025.

Western Australia

Western Australia 
Production (mmboe) 
Sales volume (mmboe) 
Revenue (US$m) 
Production cost (US$/boe) 
EBITDAX (US$m) 
Capex – Upstream (US$m) 
Capex – SES (US$m) 

2024 
18.9
21.1
850
10.21
516
398
41

2023 
21.1
21.4
853
9.87
596
200
55

Western Australia EBITDAX of $516 million was 13 per cent lower than the corresponding period in 2023, predominantly 
driven by lower sales volumes, increased third-party purchase costs and a decrease in product inventory. The Halyard-2 infill 
well was drilled, completed and tested in 2024, and is expected to come online in early 2025.

Alaska Business Unit

Santos’ assets in Alaska comprise of exploration and development licences, including the Pikka Unit (Santos 51 per cent equity 
interest), Horseshoe Unit (Santos 51 per cent equity interest) and Quokka Unit (Santos 46.6 per cent equity interest). 

The Pikka phase 1 project remains on schedule to deliver first oil in 2026 and at 31 December 2024 was 74.0 per cent 
complete. The first winter program was a success finishing in early 2024, with all facility piles installed, all vertical supports 
in place, and 40 miles of pipeline laid. The second winter season has now commenced and the drilling program is 
progressing, with results in line with pre-drill expectations. 

Net profit

The 2024 net profit attributable to equity holders of Santos Limited of $1,224 million is $192 million lower than the net profit 
of $1,416 million in 2023. This decrease is primarily due to lower realised pricing and lower volumes, partly offset by lower 
third-party purchase costs and changes in future restoration assumption charges.

Net profit includes items before tax of $95 million, adjusted for tax of $118 million, which is predominantly related to the 
PNG LNG sale to Kumul, resulting in a net decrease of $23 million (after tax), as referred to in the following table. 
Underlying profit was $1,201 million, $222 million lower than 2023.

Reconciliation of net profit/(loss) to underlying profit1

Net profit after tax attributable to equity holders of Santos Limited
Add/(deduct) the following:
Net gains on sales of non-current assets
Impairment losses
Fair value adjustments on commodity hedges
Acquisition and disposal related items

Underlying profit attributable to equity holders of Santos Limited1

2024 US$million

Gross

Tax

(13)
123
(18)
3
95

(103)
(19)
5
(1)
(118)

Net
1,224

(116)
104
(13)
2
(23)
1,201

2023 US$million

Gross

Tax

(5)
75
–
(41)
29

2
(23)
–
(1)
(22)

Net
1,416

(3)
52
–
(42)
7
1,423

1 

 Underlying profit is a non-IFRS measure that is presented to provide an understanding of the underlying performance of Santos’ operations. The measure 
excludes the impacts of asset acquisitions, disposals and impairments, as well as items that are subject to significant variability from one period to the next, 
including the effects of commodity hedging. The non-IFRS financial information is unaudited; however, the numbers have been extracted from the financial 
statements that have been subject to audit by the Company’s auditor.

159

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

Financial position

Summary of financial position

Exploration and evaluation assets

Oil and gas assets and other land, buildings, plant and equipment

Restoration provision
Other net assets1
Total funds employed
Net debt2
Net tax (liabilities)/assets3
Net assets/equity

2024 
US$million

2023 
US$million

Variance 
US$million

2,553

20,559

(4,146)

2,261

21,227

(4,891)

(799)

15,537

2,462

19,510

(4,338)

2,767

20,401

(4,264)

(862)

15,275

91

1,049

192

(506)

826

(627)

63

262

1 

2 

3 

 Other net assets are composed of trade and other receivables, prepayments, inventories, contract assets, other financial assets, share of investments in equity 
accounted associates and joint ventures, goodwill and assets classified as held-for-sale (excluding amounts included within net debt), offset by trade and other 
payables, contract liabilities, provisions, other financial liabilities and liabilities classified as held-for-sale (excluding amounts included within net debt).

 Net debt reflects the net borrowings position and includes interest-bearing loans, net of cash, commodity hedges, and interest rate and cross-currency swap 
contracts (inclusive of amounts classified as held-for-sale).

 Net tax (liabilities)/assets are composed of deferred tax assets and tax receivable, offset by deferred tax liabilities and current tax payable (excluding amounts 
included within net debt).

Impairment of assets

During the Company’s regular review of asset carrying values, Santos undertook an impairment review as part of the 
preparation of its 2024 full-year accounts.

At 31 December 2024, non-cash after-tax impairment losses of $104 million were recognised. The after-tax impairment 
losses relate to the impairment of late-life producing assets ($82 million) and exploration and evaluation assets 
($22 million).

Exploration and evaluation assets

Exploration and evaluation assets were $2,553 million, compared to $2,462 million at the end of 2023. The increase of 
$91 million was primarily due to 2024 capital expenditure across Cooper Basin, Queensland and New South Wales, and 
PNG, including Papua LNG FEED.

Oil and gas assets and other land, buildings, plant and equipment

Oil and gas assets and other land, buildings, plant and equipment of $20,559 million was $1,049 million higher than in 2023. 
This was mainly due to 2024 capital expenditure across Cooper Basin, GLNG, WA Offshore, PNG and Alaska, and 
movements in PNG LNG assets held for sale; offset by depreciation and depletion charges of $1,679 million.

Restoration provision

Restoration provision balances have decreased by $192 million to $4,146 million, mainly due to revised restoration cost 
estimates.

Net debt

Net debt of $4,891 million was $627 million higher than at the end of 2023, driven by major growth capex, capital returns 
through dividends, offset by more than $1.89 billion in free cash flow generated.

Net tax liabilities

Net tax liabilities of $799 million have decreased by $63 million in comparison to 2023. This is due to the increase in carried 
forward tax losses recognised in relation to the Pikka project, increases in carried forward PRRT credits, and a decrease in 
the deferred tax liability in relation to derivative financial instruments as a result of movements in the accounting value of 
swaps, derivatives and contractual assets.

Net assets/equity

Total equity increased by $262 million to $15,537 million at year end. This increase primarily reflects the net profit after tax 
attributable to owners of Santos of $1,224 million, which was offset by payments of dividends to shareholders of 
$991 million.

160

Santos Annual Report 2024Future commitments

Due to the nature of Santos’ operations, the Company has future obligations for capital expenditure, for which no amounts 
have been provided in the financial statements. Santos also has certain requirements to perform minimum exploration work 
and spend minimum amounts of money pursuant to the terms of the granting of petroleum exploration permits, in order to 
maintain rights of tenure.

The minimum exploration commitments are less than the normal level of exploration expenditures expected to be 
undertaken by the Company.

Oil price hedging

The objectives of Santos’ oil price hedging policy are to reduce the effect of commodity price volatility and support annual capital 
expenditure growth plans. There was a $18 million realised gain recognised for the year ended 31 December 2024 (2023: nil).

Material business risks

The achievement of Santos’ purpose and vision, business strategy and future financial performance is subject to various 
risks, including the following material business risks. Santos undertakes steps to identify, assess and manage these risks and 
operates under a Board-approved enterprise-wide Risk Management Framework.

Santos also monitors emerging risks which have the potential to disrupt the business in the future. Within the company’s 
enterprise risk register, a risk related to external environmental conditions, prompts regular review of threats such as 
emerging disruptive technologies, geopolitical developments or changing societal views that may impact the company. 
Additionally, known risks such as Cyber Security are continually monitored for new or emerging technologies and strategies 
which may require modifications to the Company’s internal control environment.

The risks described below are not an exhaustive list of the risks facing us or that may develop in the future. There may be 
additional risks, not presently known to us, or that we currently consider to be immaterial that could turn out to be 
material in the future.

Strategic risks

Volatility in oil and gas prices

Our business relies primarily on the production and sale of oil and gas products (including LNG) to a variety of buyers 
under a range of short and long-term contracts. All oil, a majority of the LNG, and a portion of the gas produced in our 
portfolio are sold under sales contracts where the sale price is linked to global benchmark prices for oil, such as Brent 
crude. Spot sales of our LNG are predominantly sold at prices linked to either global benchmark prices for oil or the Platts 
Japan-Korea-Marker (JKM), which is the LNG benchmark price assessment for spot physical cargoes. Sales of domestic gas 
typically occur under sales contracts of varying terms at fixed prices indexed to inflation.

Fluctuations in the global oil, LNG and domestic gas markets and any extended or substantial decline in demand or prices 
for oil and gas, may materially affect our financial position and results of operations and/or ability to fund our activities. 
Increases and decreases in oil and gas prices affect the amount of profit and cash flow available for servicing our funding 
requirements and capital expenditure. Such fluctuations may also impact our ability to borrow money or raise additional 
capital, and may also impact our credit rating. Lower oil and gas prices may reduce our reserves and/or the amount of oil 
and natural gas that we can produce economically.

Santos’ disciplined low-cost operating model and Hedging Policy assists to mitigate oil price risk exposure. Santos measures 
commodity price exposures and monitors market conditions and may enter into hedging transactions as appropriate. 
Additional measures include a clear focus on cash flow management, operational and cost efficiencies, and debt reduction.

Oil and gas reserves development

Reserve and resource quantities are inherently uncertain and may not materialise. Significant uncertainties are inherent in 
the reservoir geology, the seismic and well data available and other factors, such as project development and operating 
costs, together with relevant commodity prices. The process of estimating oil and gas reserves and resources is complex. 
Estimated reserve quantities are based on interpretations of geophysical, geological and reservoir models and assessments 
of the technical feasibility and commercial viability of producing the reserves. These assessments require assumptions to be 
made regarding future development and production costs, commodity prices, exchange rates and fiscal regimes.

A failure to successfully develop existing reserves may impact Santos’ ability to fully support LNG, gas or oil under customer 
contracts.

Santos has adopted a reserves management process that is consistent with the Society of Petroleum Engineers’ Petroleum 
Resource Management System and complies with ASX requirements for Australian publicly listed companies. The 
Company’s reserves and resources estimations are subject to independent audits and evaluations on a rolling basis.

Santos applies an integrated management system across all aspects of business performance, including reserves estimation 
and delivery. Progress against key reserves metrics is routinely reviewed by senior management and the Board, and 
reserves estimates are published annually.

161

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

CO2 Storage Resources

CO2 storable quantities are inherently uncertain and may not materialise. Significant uncertainties are inherent in various 
aspects, including subsurface factors such as reservoir geology and engineering considerations, the source of CO2 available 
to be stored, project development and operating costs, as well as relevant commodity prices, CO2 costs, and regulatory 
systems under which projects will operate. The process of estimating CO2 storable quantities is complex. Estimated 
storable quantities are based on interpretations of geophysical, geological, and reservoir models, as well as assessments of 
the technical feasibility and commercial viability of storing the CO2. These assessments require assumptions regarding 
future development and storage costs, commodity prices, exchange rates, and fiscal regimes. Failure to successfully 
develop CO2 storage resources may impact Santos’ ability to fully support future carbon storage projects. Santos has 
adopted a CO2 storage resources management process that is consistent with the Society of Petroleum Engineers’ CO2 
Storage Resources Management System (SRMS). The company’s CO2 storage estimations are subject to independent 
audits and evaluations on a rolling basis. Santos applies an integrated management system across all aspects of business 
performance, including CO2 storage and delivery. Progress against key metrics is routinely reviewed by senior management 
and the Board, and CO2 storage estimates are published annually.

Exploration and reserves replacement

Santos’ long-term prospects are also directly related to the success of efforts to replace existing oil and gas reserves as 
they are depleted through production, from either exploration or acquisition, in support of the Company’s strategy to 
backfill and sustain production through existing assets. Exploration activities are subject to geological and technological 
uncertainties and the failure to replace utilised reserves is a risk inherent in the industry.

Exploration risks are managed through an established exploration prospect evaluation methodology and risking process.

Demand and market

The demand for oil, gas, LNG and other products Santos markets may be adversely affected by a range of external factors, 
including the level of economic activity in the markets we serve, the level of worldwide economic activity, geopolitical 
developments and military conflicts in major oil and gas producing and trading regions, such as the Russian invasion of 
Ukraine, the Middle East crisis, and tensions in the Taiwan Strait. External factors also include the weather, the ability of the 
Organization of the Petroleum Exporting Countries (OPEC) and other producing regions (including North America and 
Russia) to influence global production levels and prices, the price and availability of new technology, including transition 
technologies, the availability and cost of alternative sources of energy and the transition away from fossil fuels and changes 
in environmental and other regulations.

The Company’s strategy development process considers independent oil, gas and LNG market forecasts, and other relevant 
macro-economic factors to enable the delivery of plans in support of the Company’s purpose and vision.

Project development

Santos’ strategy is robust and resilient to external volatility and aims to deliver shareholder value across three horizons, 
namely backfill and sustain, decarbonisation and low carbon fuels. Investment is undertaken in a variety of oil and gas 
projects to backfill and sustain our infrastructure assets to supply oil and gas to a variety of customers. In addition, there is 
increasing investment towards decarbonisation projects, such as the Moomba CCS Project.

With any major project we undertake, there is a risk the project may cost more or take longer to complete than we expect 
or it may fail to perform as planned, resulting in inadequate returns on our investment.

The risks we face for development projects include:

•  delay or failure to obtain and maintain the necessary government approvals 

•  adverse climate-related policies or changes in the regulatory requirements, including regulatory decisions during the 

development process

•  delay or failure to obtain and maintain land access, including agreements with Native Title holders or other Traditional 

Custodians as well as loss of community support

•  failures in design, engineering or construction

•  failures by contractors to perform their obligations

•  procurement issues, including equipment fabrication delays and logistical and sourcing challenges due to disruption in 

global supply chains, labour shortages, inflation and geopolitical instability

•  unexpected geological conditions, including as a result of failure to correctly interpret geological data

•  environmental, health or safety issues

• 

inadequate governance, risk management and decision-making.

Developing our development projects takes a number of years. During this period, market conditions, including those 
relating to costs, supply and demand fundamentals, financing conditions, geopolitical conditions (including sanctions) and 

162

Santos Annual Report 2024the status of counterparties (including contractors and off-take partners) may change from those that we have forecasted, 
and these changes may adversely impact our ability to deliver on our various project objectives.

In addition to financial losses, poor or failed delivery of development projects could result in damage to our reputation and 
relationships with project partners, threats to our social licence to operate, reduced workforce prospects and reduced 
ability to invest in our business.

Santos has a comprehensive project development process, supported by effective governance, risk management and 
reporting practices. Progress and performance of material projects is actively reviewed by senior management and the 
Board.

Joint venture arrangements

Much of Santos’ business is carried out through joint ventures. The use of joint ventures is common in the oil and gas 
exploration and production industry, and serves to mitigate the risk and associated costs of exploration, production and 
operational failure. However, failure of agreement or alignment with joint venture partners, or the failure of third-party joint 
venture operators, could have a material impact on Santos’ business. The failure of joint venture partners to meet their 
commitments, share costs and liabilities can result in increased cost to Santos.

Santos has defined critical expectations and requirements for participation and operation of joint ventures in order to 
optimise the Company’s commercial and operational interests. The Company works closely with its joint venture partners to 
reduce the risk of misalignment in joint venture activities.

Operational risks

Technical and engineering

Santos is exposed to technical and engineering risks in relation to our exploration, development, production, carbon storage 
and decommissioning activities, such as well control incidents (for example, blowouts, explosions or fires), failure of drilling 
and completions equipment, pipeline or facilities integrity failure incidents (for example, loss of containment, spills, 
explosions or fires), major processing or transportation incidents (including marine and aviation incidents), release of 
hydrocarbons or other substances, security incidents and other process safety risks, which may have an adverse effect on 
our profitability and results of operations.

Dedicated operating, technical standards and associated systems are applied across all operational activities to manage 
and monitor operations performance and material risk controls to enable the Company to meet regulatory and industry 
standards.

Access and licence to operate

Santos has interests in areas that may be subject to claims by communities and landowners who may have concerns over 
the social or environmental impacts of oil and gas operations, or the distribution of oil and gas royalties and access to 
mining and petroleum-related benefits. This has the potential to impact on land access or result in community unrest and 
activism, and may adversely impact the Company’s reputation.

A number of Santos’ interests are subject to one or more claims or applications for Native Title determination. In Australia, 
compliance with the requirements of the Native Title Act 1993 (Cth) can delay the grant of mineral and petroleum 
tenements and subsequent timing of exploration, development and production activities.

Santos and its operating joint venture partners work closely with relevant stakeholders, including governments, 
communities, landowners and Indigenous groups to address concerns wherever practicable, and we seek an outcome 
where local communities benefit from Santos’ presence in their communities. In addition, Santos and its operating joint 
venture partners develop and employ security and risk management plans, and are committed to conducting operations in 
a way that protects the security of personnel, facilities, operations and surrounding communities.

Santos has a long history of safe and reliable operations and working with communities and landholders across the country. 
Land access agreements are in place and a team of experienced community and land access representatives work with 
Indigenous stakeholders, landholders and communities to enable issues to be understood and addressed appropriately.

Human rights

Human rights risks include the use of force by public and private security forces, interference with Indigenous community 
land access or cultural heritage, sexual harassment and discrimination, and the labour practices of suppliers and 
contractors. These are particularly relevant where operations, or the operations of suppliers, customers and joint venture 
partners, occur in high-risk jurisdictions, including Papua New Guinea. The occurrence of any of these risks may result in the 
loss of social licence to operate, litigation or reputational damage. Training and awareness covering key human rights topics, 
such as responsible security and modern slavery, is conducted for employees in key functions, including Security and 
Procurement. Grievance mechanisms are in place and overseen at Board Committee level. Santos is committed to 
respecting human rights and continues to improve human rights-related controls in line with its Human Rights and Modern 
Slavery Policy.

163

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

Cyber security

Cyber security risks, including threats to information and operational systems from computer viruses, unauthorised access, 
cyber attack and other similar disruptions, have evolved rapidly and can impact all sectors of the economy, including the 
energy sector. The increasing technological advances in operations require monitoring and protection designed to ensure 
cyber security threats, including those enhanced by artificial intelligence, are appropriately managed and prevented. Cyber 
security risks may lead to disruption of critical business processes, a breach of privacy and theft of commercially sensitive 
information. A cyber event may lead to adverse impacts on Santos’ profitability and reputation.

Santos has established a cyber security risk management capability, with the American National Institute of Standards and 
Technology (NIST) Cyber Security Framework, which defines cyber security controls that fall under the categories of 
‘Identify, Protect, Detect, Respond and Recover’. Cyber security is incorporated into Santos’ risk management and 
assurance processes and practices across the Company’s business and operational information management systems.

Workforce

Santos’ future success is significantly influenced by the expertise and continued service of certain key Executives and 
technical personnel. An inability to attract and retain such personnel, caused by a range of factors, could adversely affect 
business continuity.

Employment arrangements underpinned by competitive benchmarked remuneration are designed to attract and retain 
executive talent and employees in business-critical roles. Talent management and succession planning frameworks are 
established for employee development, career planning and key people risks management.

Environmental, safety and sustainability risks

Health, safety and environment

The size, nature and complexity of Santos’ operations pose risks in relation to the health and safety of employees and 
contractors, and a range of environmental risks exist when carrying out exploration and production activities. Proactively 
and effectively managing health, safety and environmental risks and adhering to regulatory requirements, including safety 
cases and environmental licences or plans, is crucial. Failure to do so could lead to incidents and regulatory action, resulting 
in delays, disruption or loss of Santos' licence to operate. This could lead to delays, disruption or the shutdown of 
exploration and production activities.

Santos has a comprehensive approach to management of health, safety and environmental risks. The Company’s 
management system integrates technical and engineering requirements with personal health and safety requirements, in 
order to comprehensively manage health, safety and environmental risks within Company operations.

Climate change

Santos anticipates its activities will be subject to increasing regulation and costs associated with climate change and the 
management of carbon emissions. Risks are identified and managed in two broad categories: Physical, relating to acute and 
chronic effects of climate change on Santos’ operations and Transitional, arising from the move into a lower carbon 
economy.

Risks associated with climate change are incorporated into policy and strategy. The Company monitors climate change risk 
and proactively takes steps to mitigate any impacts on its objectives and activities. Santos’ net-zero emissions reduction 
targets remain a strong focus in the delivery of its strategic commitments. Along with specific projects focused on reducing 
emissions, an emissions reduction and minimisation focus forms part of the Company’s routine operations. For further 
information refer to our Climate Report on page 68.

Financial risks

The financial risk management strategy seeks to ensure Santos can fund its corporate objectives and meet its obligations to 
stakeholders. Financial risk management is carried out by a central treasury department that operates in line with a 
Board-approved policy and framework. The framework and principles for overall financial risk management address specific 
financial risks, such as commodity price risk, foreign exchange risk, interest rate risk and credit risk, approved derivative and 
non-derivative financial instruments, and liquidity management.

A hedging policy is in place in order to mitigate the effect of commodity price volatility. Santos measures commodity price 
exposure and monitors commodity market conditions and may enter into hedging transactions as appropriate.

An interest rate policy is in place with the objective of mitigating the effect of interest rate volatility. We are exposed to 
interest rate risk arising from our borrowings. Borrowings issued at variable rates expose us to cash flow interest rate risk. 
Borrowings issued at fixed rates expose us to fair value interest rate risk. Increases in interest rates, either through increases 
in base rates or borrowing margins, may reduce our cash flow and profitability.

164

Santos Annual Report 2024Foreign currency

Santos is exposed to foreign currency risk principally from commercial transactions and valuations of assets and liabilities 
that are denominated in a currency that is not our functional currency, United States Dollars. Our exposure to foreign 
currency risk arises principally through the sale of products denominated in currencies other than our functional currency 
and capital and operating expenditure incurred in other currencies, principally the Australian dollar and, to a lesser extent, 
the Papua New Guinea kina.

Santos also holds investment interests in domestic operations in which net assets are exposed to foreign currency 
translation risk.

A foreign currency hedging policy is in place with the objective of mitigating the effect of foreign currency exchange rate 
volatility which predominantly arises from operating and capital expenditure incurred in Australian dollars. Santos measures 
foreign currency exposure and monitors foreign currency market conditions and enters into hedging transactions as 
appropriate.

Credit

We are also exposed to credit risk through investments in cash and cash equivalents, derivative financial instruments 
and deposits with or undrawn committed liquidity from banks and financial institutions, as well as credit exposures to 
customers, including outstanding receivables and committed transactions. We may be exposed to potential financial loss 
if the counterparties to those investments and transactions fail to perform as contracted. We monitor our exposure to 
credit risk on an ongoing basis through the management of concentration risk and ageing analysis.

Access to capital and liquidity

Santos has debt obligations and relies on access to debt and equity financing to conduct its business, in particular, the 
development of large-scale projects. There is a risk that we may not be able to access equity or debt capital markets to 
support our business objectives, or successfully refinance debt facilities on commercially favourable terms, or at all. The 
ability to secure financing, or financing on acceptable terms, may be adversely affected by ESG factors, the Company's 
financial position volatility in the financial markets, or by a downgrade by credit rating agencies.

Santos had $4.4 billion in liquidity (cash and undrawn committed bank facilities) available as at 31 December 2024.

Contract and counterparty risks

As part of Santos' ongoing commercial activities, Santos is party to a number of material contracts, including finance 
agreements, infrastructure access agreements, agreements for the sale and purchase of hydrocarbon, transportation 
agreements, joint venture agreements, and engineering, procurement and construction (EPC) contracts. Santos also enters 
into sale and purchase contracts with third parties for the sale and purchase of natural gas, LNG and other products.

The economic effects of these contracts over their term may be impacted by fluctuations in commodity prices, price 
reviews, operational performance and other market conditions. Failure to perform material obligations under these 
contracts by Santos and/or the applicable counterparties, or to secure any extensions or amendments to these contracts, 
may result in a material impact on Santos’ operations and financial results.

Santos tracks key contractual obligations and monitors performance across its material contracts.

Political and legal risks

Political, legal and regulatory

Santos’ business is subject to various laws and regulations in each of the jurisdictions in which it operates that relate to the 
development, production, marketing, pricing, transportation and storage of its products. A change in the laws that apply to 
the Company’s business, or the way it is regulated, could have a materially adverse effect on Santos’ business, on the results 
of operations and the Company’s financial performance, including preventing or limiting production. For example, a change 
in government regime, taxation laws, environmental laws or land access laws could have a material effect on the Company.

The domestic gas business and GLNG project, including its ability to purchase gas, develop future growth projects and 
meet supply commitments, may also be adversely impacted by any governmental intervention, including limitations on LNG 
export volumes, domestic gas price caps and the redirection of gas from export to domestic markets. Any such intervention 
may also have broader implications for the future of the gas industry in Australia.

Continuous monitoring of legislative and regulatory changes and associated risks is undertaken, and regular engagement 
with regulators and governments supports the management of risks arising from these changes.

165

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

Litigation and disputes

Santos’ business means it is subject to litigation, disputes or regulatory actions arising from a wide range of matters. Santos 
may also be involved in investigations, inquiries or disputes, including debt recoveries, commercial and contractual disputes, 
Native Title claims, land tenure and access disputes, environmental claims or occupational health and safety claims. Any of 
these claims or actions could result in delays, increase costs or otherwise adversely impact Santos’ assets and operations, 
and adversely impact Santos’ financial performance and future financial prospects.

Santos has an experienced legal team that monitors and manages potential and actual claims, actions and disputes.

Unreasonable prejudice

As permitted by sections 299(3) and 299A(3) of the Corporations Act 2001 (Cth), Santos has omitted some information 
from the Operating and Financial Review and Directors’ Report in this Annual Report in relation to the Group’s business 
strategies, future prospects and likely developments in operations and the expected results of those operations in future 
financial years. This has been done on the basis that such information, if disclosed, would likely result in unreasonable 
prejudice (for example, because the information is premature, commercially sensitive, confidential or could give a third 
party a commercial advantage). The omitted information typically relates to internal budgets, forecasts and estimates, 
details of the business strategy and contractual pricing.

Significant changes in the state of affairs

There were no significant changes in the Group's state of affairs during the financial year.

Dividends

On 18 February 2025, the Directors resolved to pay a final dividend of US10.3 cents per fully paid ordinary share on 
26 March 2025 to shareholders registered in the books of the Company on 25 February 2025. This final dividend amounts 
to approximately US$335 million. The Board also resolved that the Dividend Reinvestment Plan (DRP) will not be in 
operation for the 2024 final dividend.

In addition, a 2024 interim dividend of US13.0 cents per fully paid ordinary share was paid to members on 
25 September 2024, and a 2023 final dividend of US17.5 cents per fully paid ordinary share was paid to members 
on 27 March 2024. The DRP was not in operation for the 2024 interim dividend, nor the 2023 final dividend.

Proceedings on behalf of Santos Limited 

No proceedings have been brought on behalf of Santos Limited, nor has any application been made, under section 237 
of the Corporations Act 2001 (Cth).

Environmental regulation

The consolidated entity’s Australian operations are subject to various environmental regulations under Commonwealth, 
state and territory legislation. Applicable legislation and requisite environmental licences are specified in the consolidated 
entity’s Environmental Compliance Database, which forms part of the consolidated entity’s overall management system. 
Environmental compliance performance is monitored regularly and in various forms, including audits conducted by 
regulatory authorities and the Company, through internal or external resources.

In 2024, Santos has received six penalty infringement notices with associated fines totaling A$79,222. The consolidated 
entity has undertaken corrective measures to prevent re-occurrences of the issues.

Post balance date events

On 18 February 2025, the Directors of Santos Limited resolved to pay a final dividend on ordinary shares in respect of the 
2024 financial year. The financial effect of these dividends has not been brought to account in the full-year Financial Report 
for the year ended 31 December 2024.

166

Santos Annual Report 2024Shares under option and unvested share acquisition rights (SARS)

Options

There are no unissued ordinary shares of Santos Limited under options at the date of this report.

Unvested SARs

Unissued ordinary shares of Santos Limited under unvested SARs at 31 December 2024 are as follows:

Date SARs granted
11 April 2021

15 July 2022

7 September 2022

20 September 2022

5 October 2022

21 October 2022

16 December 2022

24 March 2023

25 April 2023

28 April 2023

22 May 2023

14 June 2023

19 June 2023

30 June 2023

14 July 2023

31 July 2023

18 September 2023

1 December 2023

11 April 2024

23 April 2024

26 June 2024

5 July 2024

26 July 2024

9 August 2024

23 August 2024

11 September 2024

Number of shares  
under unvested SARs
847,458

2,869,654

693,750

572,468

1,298,671

154,250

138,751

220,479

176,345

124,211

506,722

1,000

560,406

966,290

313,616

625,606

2,349,714

276,104

409,033

756,670

2,965,282

56,968

1,340,638

301,199

908,283

166,064

19,599,632

Since 31 December 2024, no SARs have been granted over unissued ordinary shares of Santos Limited.

No amount is payable on the vesting of SARs. SARs do not confer an entitlement to participate in a bonus or rights issue, 
prior to the vesting of the SAR. Further details regarding the SARs (including when they will lapse) are contained in 
Note 7.2 of the Financial Report.

167

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

Shares allocated on the exercise of options and on the vesting of SARs

Options

No options were exercised during the year ended 31 December 2024, or up to the date of this report.

Vested SARs

The following ordinary shares of Santos Limited were allocated during the year ended 31 December 2024, on the vesting of 
SARs granted under the Santos Employee Equity Incentive Plan (SEEIP) (formerly known as the Santos Employee Share 
Purchase Plan (SESPP)) and ShareMatch Plan (ShareMatch). No amount is payable on the vesting of SARs and accordingly 
no amounts are unpaid on any of the shares.

Date SARs granted
19 March 2020

9 April 2020

31 August 2020

15 April 2021

12 May 2021

27 August 2021

17 December 2021

15 July 2022

5 September 2022

7 September 2022

20 September 2022

24 March 2023

19 April 2023

5 May 2023

31 July 2023

23 August 2024

Number of shares allocated
806,564

208,321

373,028

276,975

978,377

224,919

53,256

48,709

18,070

29,000

30,186

533,395

4,874

23,005

22,224

1,332

3,632,235

Since 31 December 2024, 931,977 ordinary shares of Santos Limited have been allocated on the vesting of SARs granted 
under the SEEIP and ShareMatch.

Directors’ and Senior Executives’ Remuneration

Details of the Company’s remuneration policies and the nature and amount of the remuneration of the Directors and senior 
management (including shares, options and SARs granted during the financial year) are set out in the Remuneration Report 
commencing on page 169 of this report and in Notes 7.2 and 7.3 of the Financial Report.

168

Santos Annual Report 2024O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

REMUNERATION 
REPORT 

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

Santos Annual Report 2024

169

 
 
 
 
 
 
 
 
Remuneration Report 

Message from Michael Utsler, People, Remuneration  
and Culture Committee Chair

Dear fellow shareholders,

On behalf of the Board, I am pleased to introduce Santos’ Remuneration Report for 2024 and to summarise key elements of 
Santos’ performance and the impact on remuneration outcomes.

Alignment of remuneration with corporate strategy

Santos’ remuneration framework is designed to support our strategic objectives, concentrated on three focused business 
horizons: backfill and sustain, decarbonisation, and low-carbon fuels. Our goal is to be robust and resilient to external 
volatility while being a global leader in the energy transition by providing reliable, affordable energy, aiding global 
decarbonisation efforts and delivering shareholder value. To this end, our remuneration policies are built on being 
competitive in providing Total Fixed Remuneration (TFR) with opportunities to earn Short-Term Incentives (STI)’s for in year 
achievements against specific targets and, where appropriate, Long-Term Incentives (LTI)’s. A key component of our STI 
includes sustainability metrics, with a 2024 weighting of 17.5 per cent for climate-related targets, emphasising emissions 
intensity reduction and the advancement of decarbonisation projects. We remain proactive in strengthening the linkage 
between our focus on sustainability and climate with our pay for performance structure.

2024 Business outcomes

In 2024, Santos concentrated on delivering across our strategic objectives and key development projects. The company 
achieved many significant milestones within the year:

•  Safety and sustainability: 28 per cent reduction in Total Recordable Injury Rate, a 40 per cent reduction in Lost Time 

Injury Rate surpassing IOGP top quartile benchmarks, and a 60 per cent reduction in moderate harm incidents. Loss of 
containment incidents decreased to the lowest rate in five years, a 70 per cent improvement from the prior year.

•  Operational performance: Annual production reached 87.1 mmboe, with strong sales revenue of US$5.4 billion and an 

underlying profit of US$1.2 billion. We secured four new long and mid-term LNG contracts and completed four mid-term 
price reviews.

•  Cost efficiency: Maintained low unit production costs at US$7.85/boe (excluding Bayu-Undan late-life production).

•  Project delivery:

 – Moomba Carbon Capture and Storage (CCS) phase 1: Commenced operations in the second half of 2024, injecting 

and storing nearly 340,000 tonnes (gross) of CO₂e, with reservoir and technology performance meeting expectations.

 – Barossa Gas project: 88.3 per cent complete, on track for first production in Q3 2025.

 – Pikka phase 1 project: 74.0 per cent complete, with second winter season pipeline activities initiated in December 

2024.

•  Decommissioning investment: Invested over US$319 million in decommissioning activities in 2024.

•  Financial position: Net debt stood at US$4.9 billion with gearing at 23.9 per cent as of 31 December 2024  

(20.8 per cent excluding leases).

Overall, the business performance reflected a strong year notwithstanding a capital intense period for the company with the 
portfolio generating robust annual free cash flows delivering significant returns to shareholders.

2024 Realised Remuneration strongly correlated with company performance

Realised remuneration for 2024 includes fixed pay received during the year, the cash component of the STI related to the 
performance year, and the value of vested deferred 2022 STI and 2021 LTI awards which vested in 2024, including share 
price movement over the deferral/vesting period. Results are shown in Table 6 on page 186.

Specific Managing Director and CEO realised remuneration for 2024 was lower than in 2023, primarily due to a reduced STI 
outcome compared to the prior year. 

2024 Fixed remuneration adjustments

In December 2023, the Board approved a 3 per cent increase in the Managing Director and CEO’s fixed remuneration to 
A$2,070,300, effective 1 January 2024, based on benchmarking data. Additionally, in February 2024, the Board approved 
increases for Mr. Brett Darley, Executive Vice President Eastern Australia and PNG (7%), and Ms. Anthea McKinnell, Chief 
Financial Officer (6.7%), effective 1 April 2024, reflecting expanded responsibilities and market positioning.

170

Santos Annual Report 20242024 Short-Term Incentive (STI) outcomes

The 2024 Company Scorecard outcome, determining the STI pool, was 90 per cent (53.9% of maximum). All financial 
gateways were achieved, and the STI pool remained within the 5 per cent free cash flow cap.

Short-Term Incentive enhancements

As part of our commitment to a unified “One Santos” approach, the 2024 STI Plan was enhanced to include regional-
specific gateways, ensuring that incentive outcomes reflect each region’s contribution to the company’s free cash flow. 
Those regions with these specific gateways include Eastern Australia and PNG region, Western Australia, Northern Australia 
and Timor-Leste region and Alaska. Regions not meeting their specific gateways may see a 50 per cent reduction in 
individual STI awards, reinforcing accountability and alignment with corporate performance.

To ensure a balanced approach across the organisation, a corporate centre moderator has been introduced. This moderator 
applies a 16.67 per cent weighting to each region which equates to 50 per cent in total for all the regions. This mechanism 
adjusts STI outcomes to reflect overall corporate performance, ensuring that individual and regional achievements are 
aligned with Santos’ strategic objectives and financial health.

Long-Term Incentive (LTI) outcomes

The 2021 Long-Term Incentive (LTI) was assessed over a four-year performance period ending 31 December 2024. During 
this period, the share price increased by 6.5 per cent, from A$6.27 to A$6.68.

The LTI was evaluated against four performance measures:

•  Relative Total Shareholder Return (TSR): Compared to the ASX100 (25% weighting) and the S&P Global 1200 Energy 

Index (25% weighting). The TSR thresholds, set at the 51st percentile, were not achieved, resulting in no vesting for these 
components.

•  Free Cash Flow Breakeven Point (FCFBP): With a 25 per cent weighting, the company’s average hedged FCFBP over 

the four-year period was US$15.31/boe, leading to full vesting of this component.

•  Return on Average Capital Employed (ROACE): Also with a 25 per cent weighting, the company achieved a ROACE of 

135.2 per cent over the period, resulting in 23.0 per cent vesting for this measure.

Overall, 48.0 per cent of the 2021 LTI vested, with the remainder lapsing.

Long-term equity compensation remains a significant component of remuneration for the Managing Director and CEO and 
other Executive Key Management Personnel (KMP). In 2024, (with over half of the Managing Director and CEO’s realised 
remuneration in the form of performance-based equity awards), our realised remuneration reflects this ongoing 
commitment to aligning executive rewards with the longer-term interests of the company and its stakeholders.

Specifically, for 2024, the Managing Director and CEO had an uplift of 3 per cent to the Fixed Annual Remuneration base 
(FAR), but an overall reduction in realised remuneration compared to 2023 due to lower earned outcomes against the STI 
performance metrics. Key progress against the Managing Director and CEO Growth Incentive program included Moomba 
CCS first injection and targeted injection rates achieved in September 2024.

Non-Executive Director fees

Following a review in 2023, the Board implemented a 4 per cent increase in Board and Committee fees, effective 1 January 
2024. This adjustment aligns with market benchmarks and remains within the shareholder-approved cap of A$3.5 million.

Stakeholder engagement and responsiveness

As in past years, the Board has continued its proactive efforts to engage and seek stakeholder feedback. We remain 
steadfast in our continuing commitment to this effort to ensure alignment with investor expectations. 

In closing, the Board believes the 2024 total remuneration outcomes are aligned with the Company’s performance delivery 
during the 2024 year and supports our drive to continue to create value for our shareholders. 

On behalf of the Board and the People, Remuneration, and Culture Committee,

Michael Utsler
Chair, People, Remuneration and Culture Committee

171

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

The Directors of Santos present this Remuneration Report for the consolidated entity for the year ended 31 December 
2024. The information provided in this report has been audited as required in section 308(3C) of the Corporations Act 2001 
(Cth) (Corporations Act) and forms part of the Directors’ Report.

The Remuneration Report outlines the Company’s key remuneration activities in 2024 and remuneration information for 
KMP of the consolidated entity for the purposes of the Corporations Act and Accounting Standards, as set out below.

Remuneration is disclosed in US$ (unless otherwise indicated) with all remuneration components having been 
converted from A$ to US$ using an average rate of $0.6599 for 2024 and $0.6644 for 2023. This means year-on-year 
changes in remuneration amounts when stated in US$ are partly attributable to exchange rate variations and not 
necessarily a change in the amount paid in A$.

Report structure

The Remuneration Report is set out in the following sections:

1.  KMP covered by the Remuneration Report and summary of five-year Company performance

2.  Remuneration governance

3.  Executive remuneration framework

4.  2024 Company performance outcomes and realised remuneration

5.  Incentive plan operation

6.  Key terms of employment contracts for Executive KMP

7.  Non-executive Director remuneration

8.  Statutory disclosures

172

Santos Annual Report 20241. KMP covered by the Remuneration Report and summary of five-year  
Company performance

KMP are the personnel who had authority and responsibility for planning, directing and controlling the activities of the 
Company’s major financial, commercial and operating divisions during 2024. The KMP during 2024 are set out in Table 1. 
Unless otherwise indicated in Table 1, all individuals were KMP for the full term in 2024.

Table 1: 2024 KMP

Executive KMP
Kevin Gallagher, Managing Director and Chief Executive Officer

Non-executive Directors
Keith Spence, Independent non-executive Chair

Brett Darley, Executive Vice President Eastern Australia and PNG

Yasmin Allen, Independent non-executive Director

Anthea McKinnell, Chief Financial Officer1

Guy Cowan, Independent non-executive Director3

Sherry Duhe, Chief Financial Officer2

Eileen Doyle, Independent non-executive Director4

Vincent Santostefano, Executive Vice President Western and 
Northern Australia and Timor-Leste

Vanessa Guthrie, Independent non-executive Director

Peter Hearl, Independent non-executive Director4

John Lydon, Independent non-executive Director5

Janine McArdle, Independent non-executive Director

Vickki McFadden, Independent non-executive Director5

Michael Utsler, Independent non-executive Director

Musje Werror, Independent non-executive Director

1  Ceased as KMP effective 13 September 2024.

2.  Commenced as KMP effective 14 October 2024.

3.  Ceased as a Director effective 1 October 2024.

4.  Ceased as a Director effective 11 April 2024.

5.  Commenced as a Director effective 11 April 2024.

Executive KMP Changes

In late 2023, Santos implemented a revised leadership structure. As a result of role changes, David Banks and Anthony 
Neilson ceased to be Executive KMP and were not KMP during 2024.

Table 2 sets out the Company’s performance over the past five financial years in respect of key financial and non-financial 
indicators and the STI and LTI award metrics during this period.

Table 2: Five-year company performance

Injury frequency:3

Total recordable case frequency

Lost time injury rate1

Moderate harm rate

Production (mmboe)

Reserve replacement rate – 2P organic (one-year average %)

Net (loss)/profit after tax (US$m)

Dividends per ordinary share (US cents)

Share buy-back executed (US$m)

Share price – closing price on last trading day of year (A$)2

Company Scorecard result expressed as % of maximum

LTI performance (% vesting) – shown against final year of 
performance period

1  Annual performance reporting.

2  The closing share price on the last trading day of 2019 was $8.18.

2024

2023

2022

2021

2020

1.94

0.08

0.03

87.1

17

1,264

23.3

0

6.68

53.9%

2.71

0.14

0.07

91.7

9

1,416

26.2

316

7.60

66%

2.12

0.24

0.19

103.2

166

2,112

22.7

384

7.14

64%

4.21

0.8

0.33

92.1

464

658

14.0

0

6.31

81%

3.54

0.24

0.08

89.0

11

(357)

7.1

0

6.27

67%

48.0%

47.1%

66.8%

89.5%

90.7%

3 

 Santos strives to continually improve the quality of our data and processes for capturing and reporting information. Due to the lag nature of incident reporting 
and subsequent verification, final rates may vary after the date of initial reporting. The 2022 and 2020 year TRIR results were adjusted due to subsequent 
verification and amendment of injuries. This had no impact on STI that was paid and LTI that was vested. 

173

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Remuneration Report 
(continued)

2. Remuneration governance

The following diagram illustrates Santos’ remuneration governance framework.

Shareholders

Board

The Board reviews, challenges and approves the recommendations of the People, Remuneration and Culture Committee 
around policy, performance, the remuneration arrangements for the Managing Director and Chief Executive Officer 
(Managing Director and CEO), all Executive KMP and non-executive Directors and the remuneration policies and processes 
for the wider Group.

People, Remuneration and Culture Committee

External advisers

Members

•  Michael Utsler (Chair)

•  Yasmin Allen

•  Vanessa Guthrie

•  Vickki McFadden (from 11 April 2024)

•  Musje Werror

Role

The People, Remuneration and Culture Committee 
oversees and formulates recommendations to the 
Board on the remuneration policies and practices of 
the Company generally (including the remuneration 
of non-executive Directors, the Managing Director 
and CEO and Executives) and reviewing the aligned 
policies and practices to the Company’s values, 
strategic direction and risk appetite.

Charter

The Committee operates under a Charter approved 
by the Board and regularly conducts a review of its 
performance, structure, objectives and purpose. The 
Committee Charter is available on the Company’s 
website at santos.com.

The Board and the Committee may seek advice from 
independent experts and advisers.

The Board has adopted a protocol for engaging and 
seeking advice from independent remuneration 
consultants from time to time. In 2024, no 
remuneration recommendations were provided by 
remuneration consultants as per section 9B of the 
Corporations Act.

Managing Director and Chief Executive Officer  
and executives

The Managing Director and CEO makes 
recommendations to the Committee regarding 
Executives’ remuneration. These recommendations 
take into account performance, culture and values.

The Managing Director’s remuneration is considered 
separately by the committee.

174

Santos Annual Report 20243. Executive remuneration framework

The fundamental purpose of Santos’ Remuneration Policy is to develop and maintain an effective remuneration framework 
that supports and reinforces the ongoing successful execution of Santos’ strategy and vision.

Attract, motivate and retain talented 
and qualified Executives

Focus Executives to deliver superior 
performance

Align Executive and shareholder 
interests

Remuneration Policy objectives

Enabled through the Company’s Executive remuneration framework

Total  Fixed  Remuneration  (TFR) 
(base salary plus superannuation)

•  Remuneration levels are 

market-aligned against similar 
roles in comparable companies 
within the ASX50, as well as the 
ASX100 energy and resources 
sectors.

•  Individual remuneration is set 
with regard to the Executive’s 
role and responsibilities, and 
also the individual’s experience 
and competencies.

•  The target market position for 

fixed remuneration for Executives 
is below market median, in line 
with the Company’s cost focus.

Short-term incentive (STI)

Long-term  incentive  (LTI)

•  LTIs are delivered as Share 
Acquisition Rights (SARs) 
following a four-year performance 
period.

•  Vesting of LTIs is contingent on 
achieving performance hurdles 
that are aligned with creation of 
long-term shareholder value.

•  These are:

 – relative Total Shareholder 
Return against the ASX100

 – relative Total Shareholder 

Return against the S&P Global 
1200 Energy Index

 – Return on Average Capital 
Employed versus weighted 
average cost of capital

 – Free Cash Flow Breakeven 

Point.

•  The share plan rules give the 

Company the discretion to lapse 
or forfeit unvested equity awards 
and claw back any vested shares 
or cash paid in certain 
circumstances.

•  A significant component of 

remuneration is at-risk. The value 
to the Executive is dependent on 
the Company and the individual 
meeting challenging targets.

•  STI levels are set to ensure total 
compensation appropriately 
rewards the delivery of Santos’ 
operating model and the 
increasingly demanding STI 
scorecard metrics.

•  STI outcomes are based on a 
balanced scorecard of annual 
performance measures aimed at 
delivering challenging outcomes 
for the Company across a range 
of financial, safety, environment, 
growth and culture KPIs.

•  Target setting is informed by prior 
year performance to ensure poor 
performance outcomes do not 
become baseline in the following 
year.

•  Target performance includes 
‘stretch’ to deliver superior 
outcomes beyond plan.

•  Half (50%) of Executives’ STI 
award is delivered as cash 
following the end of the 
performance year.

•  The other 50 per cent is delivered 
in equity (in the form of restricted 
shares), subject to a two-year 
restriction period. A service 
condition applies during the 
restriction period.

Minimum Shareholding Policy

The Company has a policy that mandates a significant shareholding requirement for the Managing Director and CEO and 
other Executives. The Company’s Minimum Shareholding Requirement requires the Managing Director and CEO and 
Executives to build, over a five-year period and then maintain, a minimum shareholding of Santos shares. For the Managing 
Director and CEO, this is approximately three times annual Total Fixed Remuneration (TFR) and for Executives it is 
approximately 1.5 times individual annual TFR. These levels of minimum shareholdings are significant compared to typical 
market practice. They ensure ongoing alignment with shareholders by requiring the Managing Director and CEO and 
members of the Company’s Executive Committee to hold shares beyond vesting until the minimum holding is achieved.

The Minimum Shareholding Policy allows the Managing Director and CEO and Executives to sell shares to manage tax 
liabilities that arise on the vesting of awards. Disposals to manage tax liabilities are encouraged to occur as closely as 
possible to the end of the deferred taxing point for the relevant award.

175

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

3.1 Remuneration mix

A significant portion of Executive remuneration is at-risk. The following charts show the remuneration mix for the Managing 
Director and CEO and Executives at the following performance levels:

Performance level
Minimum

Target

Maximum

Components of remuneration
TFR for the year only.

TFR for the year, STI at target level (awarded half in cash and half in deferred equity vesting 
two years after the end of the performance year, subject to continued service) and target LTI. 
LTI awards are allocated on a face value basis that is by dividing award values by the Santos 
share price to arrive at the number of SARs to be awarded. Vesting of LTI awards is subject to 
the achievement of the relevant performance and service conditions. The target LTI values in 
the following charts are shown at a 40 per cent discount to estimate a long-term probabilistic 
vesting outcome.

TFR for the year, STI at the maximum level (provided half in cash and half in deferred equity 
vesting two years after the end of the performance year, subject to continued service) and the 
maximum LTI (being the face value of the award). Vesting of awards is subject to the 
achievement of performance and service conditions.

The value of the STI deferred equity award and LTI does not include the impact of future share price movements or 
dividend payments.

The actual remuneration mix in any year varies with actual performance and incentive outcomes.

Managing Director and CEO remuneration quantum and mix

The remuneration quantum and mix for the Managing Director and CEO at minimum, target and maximum performance is 
shown in Chart 1.

Chart 1: Managing Director and CEO remuneration quantum and mix

Minimum

100%

2,070

Target

32%

16%

16%

36%

6,377

Maximum

22%

19%

19%

40%

9,254

0

2,000

4,000

6,000

8,000

10,000

TFR

STI cash

STI deferred equity

LTI

•  Minimum: TFR of A$2,070,300.

A$000

•  Target: TFR, target STI at 100 per cent of TFR (a cash award of 50% of TFR and a deferred equity award of 50% of TFR) 

and target LTI of 108 per cent of TFR.

•  Maximum: TFR, the maximum STI of 167 per cent of TFR (a cash award of 83.5% of TFR and a deferred equity award of 

83.5% of TFR) and the maximum LTI award of 180 per cent of TFR.

In addition, the Managing Director and CEO participates in a one-off Growth Projects Incentive. This is described in more 
detail in sections 4 and 5. The Growth Projects Incentive was provided as a one-off grant of performance rights subject to 
achieving key milestones and is not reflected in Chart 1.

176

Santos Annual Report 2024Executive remuneration quantum and mix

The remuneration quantum (as a multiple of TFR) and mix for Executives at minimum, target and maximum performance is 
shown in Chart 2.

Chart 2: Executive remuneration quantum and mix

Minimum

100%

1.00

Target

43%

15%

15%

27% 2.30

Maximum

32%

18%

18%

32% 3.17

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

TFR

STI cash

STI deferred equity

LTI

Multiple of TFR

Quantum is expressed as a multiple of TFR as Executives have different TFRs.

•  Minimum: TFR only.

•  Target: TFR, target STI at 70 per cent of TFR (a cash award of 35% of TFR and a deferred equity award of 35% of TFR) 

and target LTI of 60 per cent of TFR.

•  Maximum: TFR, the maximum STI of 117 per cent of TFR (a cash award of 58.5% of TFR and a deferred equity award of 

58.5% of TFR) and the maximum LTI award of 100 per cent of TFR.

177

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

4. 2024 Company performance outcomes and realised remuneration

2024 Business performance

The 2024 performance year has seen the organisation focus on the delivery of its development projects, with the first of 
three, Moomba Carbon Capture and Storage (CCS) phase 1 coming online in the second half of 2024, with the Barossa Gas 
project, and Pikka phase 1 projects to follow in 2025 and 2026 respectively. 

4.1 2024 Company Scorecard performance outcomes

Performance of the 2024 Company Scorecard as assessed by the Board resulted in an outcome of 90 per cent of target 
(53.9% of maximum).

Table 3 provides further details of Scorecard KPIs and the Company’s performance against them. Performance targets on 
achievements for each measure are cumulative. For example, achievement of a target level of performance requires the 
threshold metrics to also have been achieved, and achievement of a stretch outcome requires both the threshold and target 
metrics to have been achieved.

Table 3: 2024 Company Scorecard - KPI performance

Key performance indicators, measures and rationale Performance requirements 

Achievement

Sustainability (25%) 

Workplace and 
Process Safety 
(10%)

The targets for personal safety 
reflect the Company’s 
commitment to providing a 
workplace without injury or 
illness.

The targets for process safety 
represent the Company’s 
commitment to reducing the 
number of process safety-related 
incidents with potential for 
high-impact consequences.

Environment  
(5%)

The targets for environment 
represent the Company’s 
commitment to negating the 
occurrence of environmental 
incidents.

Threshold No life altering 
severe category incidents
Target LTIR < International 
Association of Oil and Gas 
Producers (IOGP) 3-year 
average top quartile rate 
Stretch Zero moderate harm 
incidents

Threshold No process safety 
incident with consequence ≥ 
moderate harm
Target LOCI frequency rate per 
million man hours better than 
IOGP Global average rate 
(combined Tier 1 and 2) < 0.5
Stretch Zero process safety 
LOCI Tier 1
Threshold No Spills to the 
environment with consequence 
≥ moderate
Target Spills to environment  
< 3-year average IOGP spills > 
1boe Benchmark
Stretch Zero hydrocarbon spills 
greater than 1boe

Threshold

Target

Max

There were no severe harm 
injuries during 2024. The 
Company achieved the 1-year 
IOGP top quartile rate, however 
did not achieve the 3-year 
average top quartile rate. 

The overall achievement of this 
metric was Threshold.
There were no process safety 
incidents with consequence > 
moderate harm during 2024. 
LOCI Tier 1 and 2 frequency rate 
of 0.14 achieved better than 
IOGP global average.

The overall achievement of this 
metric was Target.

There were no spills with a 
consequence > moderate during 
2024. The IOGP target was not 
met.

The overall achievement of this 
metric was Threshold.

178

Santos Annual Report 2024Key performance indicators, measures and rationale Performance requirements 
Landholder, 
Community & 
Cultural Heritage 
(2.5%)

Strong landholder, community 
and Indigenous relationships are 
key as we aspire to partner with, 
and be trusted by, Indigenous 
people and the communities in 
which we operate.

Threshold No prosecutions as  
a consequence of unauthorised 
impacts to cultural heritage or 
landholder properties
Target An additional 1.8% 
improvement on 2023 local 
communities and Indigenous 
participation procurement 
spend
Stretch Establish Indigenous 
agreements consistent with  
the principles of Free Prior  
and Informed Consent (FPIC) 
for all Santos jurisdictions and 
an additional 3.2% improvement 
on 2023 local communities  
and Indigenous participation 
procurement spend

Internal 
Governance and 
ESG Reporting  
(2.5%)

Strong assurance and 
governance processes  
underpin our corporate 
compliance program, and  
targets to achieve top quartile 
in ESG metrics represent our 
ongoing commitment to 
sustainability performance.

People and 
Culture 
(5%)

Included to reinforce the 
importance of cultural 
improvement and employee 
engagement as well as the 
development of capability to 
support future business growth.

Threshold Complete Board 
approved internal audit and 
compliance review plan
Target Implement 
improvements to achieve ISSB 
data requirements and 
complete audits and technical 
standards
Stretch First quartile ESG 
metrics for MSCI and S&P 
Global and environmental 
assurance plans embedded 

Threshold Implementation  
of Diversity and Inclusion 
strategy with improved 
inclusion sentiment scores, 
Health and Wellbeing strategy 
and Corporate and Functional 
training calendar
Target 20% improvement in 
employee engagement score  
as measured through the 
Employee Engagement Survey

Stretch Top quartile employee 
engagement score as measured 
through the Employee 
Engagement Survey

Achievement
All measures and initiatives for 
this measure were achieved 
during 2024:

•  no unauthorised impacts to 

cultural heritage or landholder 
properties

•  global local communities and 
Indigenous participation % of 
procurement spend was 8.9% 
above target and 7.5% above 
stretch

• 

Indigenous (Land and Marine) 
access and cultural heritage 
management technical 
standard implemented, 
including mandatory 
requirements consistent with 
FPIC principles with all new 
agreements to meet 
mandatory requirements.

The overall achievement of this 
metric was Stretch.
All measures and initiatives for 
this measure were achieved 
during 2024:

•  Board approved audit and 
compliance review plan 
completed

•  data gap improvement plan 
actions achieved with SMS 
Audits and Technical 
Standards completed

•  first quartile metrics for MSCI 

and S&P achieved

•  assurance plans embedded.

The overall achievement of this 
metric was Stretch.
Achievements in 2024 for this 
metric included:

•  H&W and D&I strategy 
initiatives implemented

• 

improvement of inclusion 
sentiment scores as measured 
through the Real Talk survey

•  37% improvement in 

employee engage score.

The overall achievement of this 
metric was Target. 

179

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

Key performance indicators, measures and rationale Performance requirements 
The overall outcome for Sustainability measures was between target and stretch, contributing 25.2 per cent to the total 
Scorecard outcome.

Achievement

Production (25%) 

Group Production 
(20%)

Operated 
Emissions 
Intensity 
Reduction  
(5%)

Production is the primary driver 
of revenue and therefore critical 
to the Company’s profitability, 
which is a key measure of the 
Company’s overall performance, 
underpinning annual earnings 
and cash flow.

The Company is held to account 
on emissions to air, land and 
water within targets and 
transparent reporting, in line with 
the recommendations of the Task 
Force on Climate-related 
Financial Disclosures.

Threshold 85 mmboe
Target 86.8 mmboe
Stretch 90.5 mmboe

Threshold

Target

Max

Group Production for 2024 was 
87.1 mmboe.

The overall achievement of this 
metric was between Target and 
Stretch.

Threshold 53 ktCO2e/mmboe
Target 50.7 ktCO2e/mmboe
Stretch 46 ktCO2e/mmboe

Operated Emissions Intensity for 
2024 was 55.2 ktCO2e/mmboe.

The overall achievement of this 
metric was below Threshold.

The overall outcome for the Production measure was between threshold and target, contributing 21.2 per cent to the total 
Scorecard outcome.

Threshold US$8.08/boe

Target US$7.89/boe

Stretch equal to or less than 
US$7.50/boe

Threshold 75% of budgeted 
planned volume of work done
Target 90% of budgeted 
planned volume of work done
Stretch 100% of budgeted 
planned volume of work done 
with spend below budget

Threshold US$84.66/bbl
Target US$78.17/bbl
Stretch US$65/bbl

Threshold 25%
Target 23.4%
Stretch 20%

Threshold

Target

Max

Unit production costs excluding 
Bayu-Undan for 2024 were 
US$7.85/boe.

The overall achievement of this 
metric was between Target and 
Stretch.

2024 decommissioning capex of 
90% of volume of work done 
achieved.

The overall achievement of this 
metric was Target.

All-in FCFBE over 2024 was 
US$82.44/bbl.

The overall achievement of this 
metric was between Threshold 
and Target.

2024 full year gearing was 23.9%.

The overall achievement of this 
metric was between Threshold 
and Target. 

Financial (25%) 

Unit Production 
Costs 
(10%)

Decommissioning 
Capex Efficiency 
(5%)

All-in FCFBE  
(5%)

Gearing 
(5%) 

Unit productions costs are 
included to ensure that the 
Company maintains its cost and 
efficiency focus for every unit of 
production.

Decommissioning capex 
represents capital expenditure 
incurred in the operation of the 
underlying business. This 
measure is included to ensure 
the focussed and cost-effective 
delivery of necessary 
decommissioning programs.

The all-in free cash flow break-
even is the average annual oil 
price at which cash flows from 
operating activities equal 
investing cash flows, including 
major growth capital on growth 
projects.

Santos is well positioned to fund 
growth out of operating cash 
flow and debt while maintaining 
gearing levels within a range 
which is consistent with an 
investment-grade credit rating. 
This measure rewards the 
delivery of strong free cash flow 
generation from the base 
business and through the 
optimisation of the broader asset 
portfolio through strategically 
aligned farm outs and disposals.

180

Santos Annual Report 2024Key performance indicators, measures and rationale Performance requirements 
The overall outcome for Financial measures was between threshold and target, contributing 24.0 per cent to the total 
Scorecard outcome.

Achievement

Backfill, sustain and decarbonisation (25%) 

Oil and gas backfill and sustain projects
Barossa 2024 
Scope volume  
of work done 
(7.5%)

These measures incentivise the 
delivery of planned 2024 project 
milestones for our two major 
projects.

Pikka 2024 Scope 
volume of work 
done 
(5%)

Threshold 75% complete
Target 80% complete and gas 
export pipeline partly laid, SURF 
campaign 1 completed,  
2 wells completed
Stretch 85% complete and gas 
export pipeline fully laid, SURF 
campaign 2 completed, total of 
4 wells completed
Threshold 60% complete plus 
threshold well stock inventory 
achieved
Target 65% complete plus 
target pipeline, well stock 
inventory and expenditure 
achieved
Stretch 70% complete plus 
stretch pipeline, well stock  
and inventory achieved

Decarbonisation, low carbon fuels and nature-based projects
Moomba CCS 
start-up  
(7.5%)

This measure incentivises the 
successful delivery of Moomba 
CCS start-up in 2024 with 
planned injection rates achieved.

Threshold December 2024
Target 31 July 2024
Stretch 15 May 2024

Decarbonisation, 
Clean Fuels, 
Nature-based 
Projects 
(5%)

This measure incentivises the 
delivery of a suite of 
decarbonisation, clean fuels and 
nature-based projects.

A scorecard of key low carbon 
fuels initiatives (which are 
critical to the Company’s 
significant ambitions to drive 
sustainable returns in a lower 
carbon future) has been set. 
Delivery of the initiatives 
contributes to the overall score 
on this metric.

Threshold

Target

Max

Project is 88.3% competed at  
31 December 2024 and gas 
export pipeline is completed. 
SURF campaign 1 is completed 
and three wells are available for 
production.

The overall achievement of this 
metric was Target.

Pikka project is 74.0% complete 
and threshold well stock 
inventory has been achieved.

The overall achievement of this 
metric was Threshold.

Moomba CCS project achieved 
first injection in September 2024 
with ramp up from early October. 
First injection achieved on 30 
September 2024 and planned 
injection rates achieved during 
October 2024.

The overall achievement of this 
metric was Threshold.
Key achievements in respect to 
this metric include:

•  Reindeer FEED entry achieved

• 

increased Moomba CCS 2C 
storage booking by 35%

•  Binding CO2 offtake 

agreement for Wilga Park  
and Narrabri complete

•  Darwin LNG tank warm up 

completed

•  2024 Darwin Life Extension 
major maintenance scope of 
work completed

•  acquired two additional 
acreages in Moomba.

The overall achievement of this 
metric was Threshold.
The overall outcome for Backfill, sustain and decarbonisation was between threshold and target, contributing  
19.6 per cent to the total Scorecard outcome.

Total The total Company Scorecard outcome for 2024 as a percentage of target was 90 per cent (53.9% of maximum).

181

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Remuneration Report 
(continued)

2024 Regional Gateway

In 2024, an additional regional-specific gateway was introduced to the total individual STI outcome to ensure bonus 
outcomes reflect the level of contribution each region makes to the total Company free cash flow. Those regions with a 
regional-specific gateway include Eastern Australia and PNG, Western and Northern Australia and Timor-Leste, and Alaska. 
The regional-specific gateway, if not achieved, will result in a reduction of 50 per cent of the total individual STI award 
outcome. 

For the corporate centre functions and divisions, including the Managing Director and CEO, a corporate centre moderator 
applies to the total individual STI outcomes to recognise the impact of Free Cash Flow across all the regional business units 
by moderating the outcome dependent on whether each of the three regions noted above met their regional-specific 
gateway. The corporate centre moderator applies a 16.67 per cent weighting to each region, equating to 50 per cent for all 
regions. Therefore, if one or more regions do not meet their regional-specific gateway, the corporate centre moderator 
applies to reduce the individual STI outcome by 16.67 per cent up to 50 per cent.

For the 2024 performance year, all regions met their specific gateway and the corporate centre was not impacted by any 
unmet regional gateways.

2024 Scorecard link to sustainability and climate

Sustainability and climate are key elements of our performance-based remuneration. In 2024, sustainability accounted for 
25 per cent of the Company Scorecard, including safety, environment, cultural heritage, community, internal governance 
and ESG reporting and people-related metrics. In addition, the 2024 Company Scorecard weighting for climate-related 
targets increased to 17.5 per cent (from 15% in 2023) and included metrics relating to emissions intensity reduction, 
decarbonisation projects and the delivery of Moomba CCS. These metrics continue to reinforce the link between 
sustainability and climate, and executive remuneration.

Capping STI outcomes to ensure alignment with shareholder experience

To ensure alignment with the shareholder experience and to make sure awards under the STI Plan are reasonable 
relative to free cash flow generated, a cap of 5 per cent of the Company’s free cash flow applies to the STI pool in any 
year. The STI pool for 2024 was accommodated well within the 5 per cent of free cash flow cap.

Table 4:  Executive role-specific KPIs

Note, some KPIs contain commercially sensitive information that cannot be detailed here.

Executive
B Darley

Role-specific KPIs
•  Production, volume and 

Key achievements in 2024
•  Region achieved zero LTIs in 2024 with an exposure of ~20 million 

cost

work hours.

•  Health, safety and 

•  Strong focus on reliability and integrity, delivering significant 

environment 

reduction in loss of containment risks.

•  Emissions reduction

•  Delivered successful start-up of the Moomba CCS project achieving 

full injection rate.

•  Delivered above regional production target.

•  Drove focus on unit cost to deliver better than target unit production 

costs for the region.

A McKinnell1

•  Corporate and 

•  Financed Moomba CCS project to drive decarbonisation.

operational cost control

•  Refinanced Syndicated debt facility with facility increased to US$850 

•  Balance sheet and 

million.

capital management

•  Financed Darwin LNG life extension works totalling US$800 million.

V Santostefano

•  Production, volume and 

•  Delivered Halyard 2 well under budget.

•  Executed 2024 FX and oil hedging programs.

cost

•  Health, safety and 

environment

•  Emissions reduction

•  Achieved budget production.

•  Drove momentum in Barossa Project which is now 88.3 per cent 

complete at year end and on track for first production in 2025 Q3.

•  Completed removal of Campbell platform with no safety or 

environment incidents.

• 

Implemented efficiency initiatives such as campaign maintenance and 
remote operations.

1  Ceased as a KMP effective 13 September 2024.

182

Santos Annual Report 20244.2 2024 STI outcomes

KMP
Managing Director 
and CEO

Executives

Company Scorecard
The Managing Director and CEO’s performance is 
primarily assessed using the Company Scorecard. 
In determining the Managing Director and CEO’s 
final STI payment for 2024, the Board also 
considered outcomes outside the Scorecard and 
the impact of the Managing Director and CEO’s 
personal performance and leadership on five 
dimensions: corporate activity, growing 
shareholder value, futureproofing the business, 
leadership and culture, and stakeholder 
engagement.

The Company performance result based on the 
Company Scorecard outcomes outlined above 
sets the size of the pool. Individual allocations of 
the pool are then modified to reflect individual 
performance and demonstration of the Santos 
values.

2024 STI performance
The STI outcome for the Managing Director and 
CEO for 2024 represents an outcome which is 90 
per cent of the target amount (53.9% of 
maximum STI opportunity), which is in line with 
the Company Scorecard outcome.

The 2024 STI outcomes for ongoing Executives 
ranged from 48 per cent to 65 per cent of their 
maximum opportunity, depending on their 
individual performance contribution. 

Further detail of each individual Executive’s 
outcome is provided in Table 5 on page 183.

All Executives had individual KPIs relating to 
environment, health, safety, culture and 
leadership. Role-specific KPIs by Executive are 
set out in Table 4 above.

Table 5 sets out the individual STI outcomes for Executives in 2024, as a percentage of their STI target and maximum STI 
opportunity.

Table 5: Executive 2024 STI outcomes

Target  
2024 STI 
(% of TFR)

Actual  
2024 STI 
(% of TFR)

2024 STI 
as a % of 
maximum

% of 
maximum 
STI 
forfeited

Total STI 
value 
A$

STI  
cash 
A$

STI 
deferred 
A$

100%

90%

54%

46%

1,863,270

931,635

931,635

70%

70%

-

70%

76%

57%

-

63%

65%

48%

-

54%

35%

52%

-

670,400

335,200

335,200

310,400

155,200

155,200

-

-

-

46%

533,000

266,500

266,500

Executive Director

K Gallagher

Executives

B Darley

A McKinnell1

S Duhe2

V Santostefano

1  Ceased as a KMP effective 13 September 2024.

2 

 Commenced as a KMP effective 14 October 2024. Based on eligibility rules for Short-Term Incentive participation and the requirement to commence employment 
prior to 1 October of the relevant performance year, Ms Duhe is not eligible to participate in the Short-Term Incentive for 2024.

183

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

4.3 2021 LTI performance outcomes

The 2021 LTI award was tested at the end of the four-year performance period from 1 January 2021 to 31 December 2024. 
As a result, 48.0 per cent of the 2021 LTI awards has vested.

The 2021 LTI grant was allocated at a base share price of A$6.27.

Performance measures
Relative TSR measured against 
constituent members of the 
ASX100 at the commencement of 
the performance period

Relative TSR measured against 
constituent members of the S&P 
Global 1200 Energy Index (GEI) at 
the commencement of the 
performance period

Free Cash Flow Breakeven Point 
(FCFBP)

Return on Average Capital 
Employed (ROACE) compared 
with weighted average cost of 
capital (WACC)

Total

Weighting

Threshold 
vesting

Full vesting

Result

Vesting 
Outcome  
(% of total LTI)

25% 51st percentile 76th percentile 44th percentile

Nil

25% 51st percentile 76th percentile

11th percentile

Nil

25%

=US$40/boe

<=US$25/boe

US$15.31

25.0%

25% >110% of WACC

100%

>=140% of 
WACC

135.2%

23.0%

48.0%

Chart 3:  TSR  performance  against  S&P  ASX100  Index  and S&P  Global  1200  Energy  Index

300

250

200

150

100

50

Dec 20

Jun 21

Dec 21

Jun 22

Dec 22

Jun 23

Dec 23

Jun 24

Dec 24

SGES Index

AS25 Index

STO AU Equity

184

Santos Annual Report 2024 
4.4 Managing Director and CEO Growth Projects Incentive (Growth Incentive) update

In April 2021, shareholders approved a one-off Growth Incentive to reward the Managing Director and CEO upon the 
successful delivery of Santos’ major growth projects and energy transition strategy to 31 December 2025. The Growth 
Incentive comprises a suite of demanding milestones and initiatives set by the Board in 2021 to be achieved over the five 
years to 31 December 2025. Achievement of milestones and initiatives allows success to be earned along the way. The 
Growth Incentive is subject to forfeiture if the Managing Director and CEO resigns from his employment prior to 31 
December 2025 unless otherwise agreed by the Board.

The share of the Growth Incentive achieved in 2024 (from the achievement of the Moomba CCS target) was 5%. The 
cumulative share of Growth Incentive achieved since commencement of the Incentive plan is 65%. The remaining 35% is 
subject to achievement of milestones in 2025.

Achievement in 2024 (5% share of Growth Incentive)

Following Board review, the following milestone initiatives were noted as having been achieved during 2024:

Emissions reduction, net-zero plan and energy transition

•  Moomba CCS first injection achieved on 30 September 2024 and planned injection rates achieved during October 2024.

Achievement in 2023 (12% share of Growth Incentive)

Following Board review, the following milestone initiatives were noted as having been achieved during 2023:

Major growth projects

•  regulatory approval for Dorado Offshore Project Proposal (OPP)

•  extended Reserves coverage for GLNG.

Achievements in 2022 (13% share of Growth Incentive)

Following Board review, the following milestone initiatives were noted as having been achieved during 2022:

Major growth projects

• 

 The Board approved the Final Investment Decision for the Pikka Project in August 2022.

Emissions reduction net-zero plan and energy transition

•  Santos achieved the 2025 target to reduce operational emissions by 5 per cent in the Cooper Basin and Queensland.

Achievements in 2021 (35% share of Growth Incentive)

Following Board review, the following milestone initiatives were noted as having been achieved during 2021.

Major growth projects

•  The Board approved the Final Investment Decision for the Barossa Gas project on 30 March 2021.

•  Santos completed the sell-down of 25 per cent interests in both Bayu-Undan and Darwin LNG to SK E&S on 30 April 

2021. This sell-down further aligned partner interests in the Barossa Project with those in Bayu-Undan and Darwin LNG.

•  On 29 June 2021, Santos announced the launch of front-end engineering and design (FEED) for the Dorado project in 
the Bedout Sub-basin, offshore Western Australia. Entering FEED for the Dorado project is a significant milestone and 
has the project on schedule for a Final Investment Decision around mid-2022. Dorado has high-quality reservoirs making 
it a very cost-competitive project globally. Dorado is also a very low CO2 reservoir with approximately 1.5 per cent CO2.

Emissions reduction net-zero plan and energy transition

•  On 1 November 2021, Santos and joint venture partner Beach Energy announced the Final Investment Decision to 

proceed with Santos’ A$210 million Moomba CCS project. Moomba CCS will be one of the biggest CCS projects in the 
world and will safely and permanently store 1.7 million tonnes of carbon dioxide per year in the same reservoirs that held 
oil and gas in place for tens of millions of years. The decision followed Santos’ successful registration of the Moomba 
CCS project with the Clean Energy Regulator. The Clean Energy Regulator’s CCS method provides a crediting period of 
25 years, over which period the project will qualify for Australian Carbon Credit Units for emissions reduction from 
Moomba CCS.

Achievement of these milestones are key enablers on the critical path to delivery of the overall performance goals in the 
Growth Projects Incentive.

All awards remain subject to forfeiture if the Managing Director and CEO resigns from his employment prior to  
31 December 2025, unless otherwise agreed by the Board.

185

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

4.5 Realised remuneration

Table 6 shows realised remuneration for the Managing Director and CEO and Executives in 2024 and 2023.

Realised remuneration differs from statutory remuneration, reported in Table 9, and other statutory tables that are prepared 
in accordance with the Corporations Act and Accounting Standards. This requires a value to be placed on share-based 
payments at the time of grant, and to be reported as remuneration, even though the Managing Director and CEO and 
Executives may ultimately not realise any actual value from the share-based payments.

The Realised remuneration table is shown in Australian dollars (the currency in which remuneration is paid), whereas, the 
statutory tables are shown in US dollars, which is the Company’s reporting currency. Showing remuneration in Australian 
dollars removes the impact of exchange rate movements.

Realised remuneration has been calculated as:

•  TFR paid in the year

•  cash STI awards earned in respect of performance for the year (albeit paid after the end of the year)

•  deferred STI awards from prior years that vested in the year

•  LTI SARs that were tested at 31 December in the year (and which vested in the subsequent year).

Vesting deferred STI awards and SARs are valued at the closing share price on 31 December of the respective year. 
Termination payments and leave movements are not included in Table 6.

Table  6:  Realised  remuneration  (non-IFRS)

TFR 
A$

2 
1  Cash STI 
A$

Deferred STI 
that vested 
3 
in the year 
A$

Other 
vested 
5 
grants 
A$

4 
LTI 
A$

Year

Executive Director
K Gallagher

Executives
B Darley

A McKinnell7

S Duhe8
V Santostefano

2024
2023

2,070,300
2,010,000

931,635
1,161,780

999,482
1,641,380

1,850,193
1,583,240

2024
2023
2024
2023
2024
2024

886,791
840,000
547,500
737,500
253,561
846,048

335,200
357,700
155,200
310,000
-
266,500

277,674
432,030
243,620
284,004
-
-

429,557
367,582
147,013
226,457
-
-

7,233
7,736

7,233
7,736
-
–
–
–

6 
Other 
A$

Total 
A$

11,159
10,190

5,870,002
6,414,326

10,596
34,837
3,799
5,228
-
11,739

1,947,051
2,039,885
1,097,132
1,563,189
253,561
1,124,287

1 

2 

 TFR comprises base salary and superannuation. The amounts shown here are actual received TFR. These amounts are pro-rated amounts for the period that 
Executives were in KMP roles.

 The ‘Cash STI’ column reflects the 50 per cent of the STI award for 2024 performance for continuing Executives that will be paid in cash. The remaining  
50 per cent will be awarded as equity restricted for two years. 

3  The deferred restricted equity from the 2022 STI award that vested on 31 December 2024, at a closing share price of A$6.68.

4 

5 

6 

 The 2021 LTI was tested at the end of its performance period on 31 December 2024 and 48.0 per cent of awards vested. The value shown in the table is based on 
the closing share price on 31 December 2024 of A$6.68. For the value of share-based payments calculated in accordance with the Accounting Standards, see 
Table 9 Statutory Executive KMP remuneration details on page 197.

‘Other vested grants’ includes vested ShareMatch 2021 SARs and Dividend Equivalent Shares.

’Other’ is made up of ad hoc payments treated as remuneration, such as assignment and mobilisation allowances and other non-monetary benefits.

7  Ceased as a KMP effective 13 September 2024.

8  Commenced as a KMP effective 14 October 2024.

186

Santos Annual Report 2024Notes on Mr Gallagher’s realised remuneration for 2024

Mr Gallagher’s realised remuneration for 2024 included the following at-risk performance related elements:

•  the cash component of Mr Gallagher’s STI award based on 2024 performance

•  the value of Mr Gallagher’s deferred STI award from 2022, which vested on 31 December 2024

•  the value of Mr Gallagher’s Long-Term Incentive award from 2021, which was tested at 31 December 2024.

As noted above, the Managing Director and CEO was awarded a cash STI for 2024 of A$931,635. The basis for the 2024 
cash STI is described in section 4.1.

Chart 4: Realised value of Mr Gallagher’s  
deferred 2022 STI 

Chart 5: Realised value of Mr Gallagher’s 
2021 LTI

m
$
A

1.2

0.9

0.6

0.3

0.0

1.07

0.07

1.00

Value at start 
of performance 
period

Share price 
movement

Value at vesting

m
$
A

5

4

3

2

1

0

3.62

0.24

(2.00)

1.85

Value at start 
of performance 
period

Share price 
movement

Forteited

Value at 
vesting

Mr Gallagher’s 2021 LTI allocation had a face value of A$3.62 million at the start of the performance period. The Santos 
share price appreciated 6.54 per cent between the start of the performance period and vesting. The value based on the 
closing share price on the last trading day of the year ending 2024 of A$6.68 was A$3.85 million. The vesting outcome of 
the 2021 LTI was 48.0 per cent and the value of the final vesting award at 31 December 2024 was A$1.85 million.

187

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

5. Incentive plan operation

5.1 Short-Term Incentive

The STI Framework aligns Executive interests with the delivery of the operating model and the Company’s challenging 
short-term operational and financial goals for the year. Goals are chosen to drive outcomes and behaviours that support 
safe operations and the achievement of the business outcomes that contribute to the delivery of long-term growth in 
shareholder value.

Element
Performance 
period

Performance 
measures

Description
1 year (i.e. 1 January to 31 December)

The Company’s annual performance is assessed using the Company Scorecard. The Scorecard contains a 
balance of challenging financial and operational KPIs that support the execution of the business strategy and 
drive business performance. In 2024, Scorecard KPIs covered a range of areas, including production, operating 
efficiency, safety, backfill and sustain, decarbonisation and culture.

The measures include lagging indicators to assess the Company’s past performance, as well as forward- 
looking indicators to ensure the Company is positioning itself effectively for future growth. The Board believes 
this Scorecard is balanced and focuses the Managing Director and CEO and Executives on achieving the key 
outcomes necessary to deliver stronger returns to shareholders.

STI pool

Vesting 
hurdle and 
cap

The STI pool for each performance year is set by reference to the Company Scorecard result. The Scorecard 
result is generally applied as a percentage of the target pool size (subject to the application of any Board 
discretion). 
The STI award is subject to a free cash flow gate that requires the Company to be free cash flow positive for 
an STI award to be made, regardless of performance against all other KPIs. This is aligned with the Company’s 
position to its shareholders under the Dividend Policy, which is to deliver strong cash flows through the oil 
price cycle. 

To provide further alignment with the shareholder experience and to ensure awards under the STI Plan are 
reasonable relative to free cash flow generated, a cap of 5 per cent of the Company’s free cash flow (excluding 
growth capex) is applied to the STI pool in any year. 
The Company Scorecard is composed of a range of KPIs with set threshold, target and stretch goals agreed 
with the Board at the start of the performance year. The relative importance of each KPI is determined and 
assigned a proportionate weighting of the total Scorecard result. 

Performance 
and vesting

Each KPI receives a percentage score relative to target performance, as follows: 

•  0 per cent for performance below threshold 

•  67–100 per cent for performance between threshold and target 

•  100–167 per cent for performance between target and stretch 

•  167 per cent for performance at or above stretch. 

The KPI weightings are then applied to these scores to derive a rating for each KPI. The overall Scorecard 
result is a weighted average of KPI scores. 

The Scorecard has a maximum result of 167 per cent of target. This maximum result can only be achieved for 
exceptional Company performance. The Board believes the above method of assessment is rigorous and 
provides a balanced assessment of the Company’s performance. 

The People, Remuneration and Culture Committee formally assesses the Company’s performance against the 
overall Scorecard at the end of each financial year, and this forms the basis of a recommendation to the Board. 

The Board assesses the Managing Director and CEO’s performance and determines his STI award. The 
Managing Director and CEO assesses Executive performance and determines STI award proposals that are 
then formally endorsed by the Board and the People, Remuneration and Culture Committee. 

188

Santos Annual Report 2024Element
Regional 
Gateway

Description
An additional regional-specific gateway applies to the total individual STI outcome to ensure bonus outcomes 
reflect the level of contribution each region makes to the total Company free cash flow. Those regions with a 
regional-specific gateway include Eastern Australia and PNG, Western and Northern Australia and Timor-Leste, 
and Alaska. The regional-specific gateway, if not achieved, will result in a reduction of 50 per cent of the total 
individual STI award outcome. 

For the corporate centre, which includes Santos Energy Solutions (SES), Finance, Commercial, People and 
Culture, Legal, Environment and Governance, Operations and Technical Services and Subsurface and Portfolio 
Management and the Managing Director and CEO’s office, including the Managing Director and CEO, a 
corporate centre moderator applies to the total individual STI outcomes to recognise the impact of free cash 
flow across all the regional business units by moderating the outcome dependent on whether each of the 
three regions noted above met their regional-specific gateway. The corporate centre moderator applies a 16.67 
per cent weighting to each region, equating to 50 per cent for all regions. Therefore, if one or more regions do 
not meet their regional-specific gateway, the corporate centre moderator applies to reduce the individual STI 
outcome by 16.67 per cent up to 50 per cent.

Half (50 per cent) of STIs provided to Executives are delivered in cash in March following the end of the 
performance year. The remaining half (50 per cent) is provided as deferred equity (in the form of restricted 
shares), restricted for two years and subject to a service condition during this time. Deferral provides increased 
alignment with shareholders and encourages longer-term thinking given the equity exposure. 

Deferred STI is forfeited if the Executive leaves the Company during the vesting period due to resignation or 
summary dismissal (including for fraud or misconduct). STI awards are also subject to clawback (see section 
5.4 for further information). 

Dividends are payable during the restriction period on restricted shares awarded under the STI. Restricted 
shares have the same voting rights as other Santos Limited shares.

Award

Forfeiture 
and  
clawback

Dividends 
and voting

5.2 Long-Term Incentive

The LTI aligns the interests of Executives with the creation of long-term shareholder value.

The relative TSR performance criteria provide for vesting when there are strong shareholder returns against relevant peer 
groups. The Free Cash Flow Breakeven Point (FCFBP) and Return on Average Capital Employed (ROACE) measures are 
achieved when the Company demonstrates underlying operational efficiency that generates free cash flow throughout the 
oil price cycle and disciplined use of capital to generate shareholder returns over a four-year period.

Element
LTI grant

Description
LTI grants are based on a set percentage of the Executive’s TFR allocated on a face value basis (based on 
the closing share price on 31 December of the prior year) and provided in the form of Share Acquisition 
Rights (SARs). Each SAR is a conditional entitlement to a fully paid ordinary share at zero price, subject to 
satisfaction of the relevant performance conditions. 

If SARs vest, shares are automatically allocated to the Executive. Nothing is payable by Executives on 
allocation of SARs or if SARs vest. Trading in shares received on vesting of SARs is subject to compliance 
with the Company’s Securities Dealing Policy and the Minimum Shareholding Requirement. 

The Board has discretion to settle the value of vesting SARs in cash. 

Performance 
period

SARs have a four-year performance period. This period represents an appropriate balance between 
providing a genuine and foreseeable incentive to Executives and fostering a long-term view of shareholder 
interests. 

189

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

Element
Performance 
measures

Description
The LTIP is measured against four equally weighted performance measures:

Weighting Performance measures
25%

Relative TSR measured against 
constituent members of the 
ASX100 at the commencement 
of the performance period

Relative TSR measured against 
constituent members of the S&P 
Global 1200 Energy Index (GEI) 
at the commencement of the 
performance period

Free Cash Flow Breakeven Point 
(FCFBP)

Description and rationale
The calculation of TSR takes into consideration share price 
growth and dividend yield and is therefore a robust and 
objective measure of shareholder returns.

TSR continues to effectively align the interests of individual 
Executives with that of the Company’s shareholders by 
motivating Executives to achieve superior shareholder 
outcomes relative to Santos’ competitors for investor 
capital and its energy sector peers.

FCFBP is the US$ oil price at which cash flows from 
operating activities equal cash flows from investing 
activities, as published in the Company’s financial 
statements. As the aim of this performance hurdle is to 
measure the performance of the underlying business, the 
Board has discretion to adjust FCFBP for individual material 
items, including asset acquisitions and disposals that may 
otherwise distort the measure.

Return on Average Capital 
Employed (ROACE) compared 
with weighted average cost of 
capital (WACC)

ROACE is measured as the underlying earnings before 
interest and tax (EBIT) divided by the average capital 
employed, being shareholders’ equity plus net debt, as 
published in the Company’s financial statements.

The use of ROACE as a performance measure aligns 
Executives with shareholder interest by focusing on the 
efficient and disciplined use of capital to generate 
shareholder returns.

25%

25%

25%

190

Santos Annual Report 2024Element
Vesting 
conditions

Description
The vesting scales set out in the following tables are in respect to the 2024 LTI grant and apply to both the 
Managing Director and CEO’s and Executives’ LTI performance grants. SARs that do not vest upon testing 
of the applicable performance condition lapse. 

Relative TSR against the ASX100 and S&P GEI

TSR percentile ranking
Below 51st percentile

51st percentile

76th percentile and above

Straight line pro-rata vesting in between

Free Cash Flow Breakeven Point (FCFBP)

FCFBP
Above US$35/bbl

Equal to US$35/bbl

Equal to or below US$25/bbl

Straight line pro-rata vesting in between

% of component vesting
0%

50%

100%

% of component vesting
0%

50%

100%

Core to Santos’ strategy has been the establishment of a disciplined low-cost operating model that delivers 
strong cash flows through the oil price cycle. Free cash flow breakeven is the average annual oil price at 
which cash flows from operating activities equal cash flows. FCFBP is a key metric for Santos and it is 
therefore critical for it to form part of the Long-Term Incentive performance assessment. 

When the FCFBP hurdle was introduced in 2016, Santos’ FCFBP was approximately US$50/bbl. Over time, 
targets have progressively been set at more challenging levels. 

In 2020, the stretch target was made harder to achieve by lowering it from US$35/bbl to US$30/bbl and in 
2021 it was lowered again to US$25/bbl. In 2022, the threshold was made harder to achieve by lowering it 
from US$40/bbl to US$35/bbl despite increasing cost pressures across the business.

Return On Average Capital Employed (ROACE)

ROACE percentile ranking
Santos ROACE <= 110% of WACC

Santos ROACE > 110% of WACC then:

Santos ROACE >= 140% of WACC

Straight line pro-rata vesting in between

% of component vesting
0%

50%

100%

Performance on all measures are externally audited. The Board has discretion to adjust the result on 
non-market measures based on the agreed methodology.

The Board may adjust the TSR comparator groups to take into account events including, but not limited to, 
takeovers, mergers or de-mergers that might occur during the performance period. The Board also has the 
discretion to adjust the FCFBP and ROACE for individual material that may otherwise distort the 
measurement.

Re-testing

There is no re-testing of the performance condition.

Forfeiture and 
clawback

The LTI is forfeited if the Executive leaves the Company during the vesting period due to resignation or 
summary dismissal (including for fraud or misconduct). STI awards are also subject to clawback (see 
section 5.4 for further information). 

Dividends  
and dividend 
equivalent 
payment  
(DEP) and 
voting

Dividends are not payable on SARs during the LTI performance period. 

The DEP is payable on shares that vest in accordance with performance outcomes.

The DEP is not payable until the end of the performance period and is only payable on SARs that vest in 
accordance with their terms.

The provision of a notional dividend entitlement on awards is entirely consistent with using the face value of 
Santos shares in the calculation of individual Long-Term Incentive awards. No dividends are provided in 
relation to SARs which do not vest, as is common practice among ASX companies. 

The DEP is not payable on SARs that lapse or are forfeited (see section 5.4 for further information). 

SARs do not carry any voting rights.

191

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Remuneration Report 
(continued)

5.3 Managing Director and CEO Growth Projects Incentive

In April 2021, the Board agreed to provide the Managing Director and CEO a one-off Growth Projects Incentive to reward Mr 
Gallagher for the successful delivery of Santos’ major growth projects and energy transition strategy to 31 December 2025. 
Mr Gallagher is well-recognised as one of Australia’s leading chief executives with a proven track record of delivering for 
shareholders.

Santos is moving into a growth phase with significant major growth projects including Barossa, Dorado, Moomba CCS, 
Narrabri and Pikka phase 1 underway. Santos is leading the energy transition to lower carbon fuels and has a clear plan 
targeting net-zero scope 1 equity emissions by 2040 and net-zero scope 2 equity emissions by 2050, and our vision is 
strongly supported by investors and other stakeholders. Mr Gallagher is uniquely placed to lead Santos through this 
transition.

This offer recognises the unique value that Mr Gallagher brings to Santos and the significant role he will play in leading and 
driving delivery of the major growth projects through to the end of 2025. The projects are a critical part of Santos’ strategy 
and vision, which Mr Gallagher has designed and led since joining Santos. Achievement of these goals will accelerate and 
strengthen the transition to a lower-carbon future enabling more effective realisation of sustainable growth and shareholder 
returns with longer-term profitability.

Element
Managing 
Director and  
CEO growth 
incentive grant

Description
The Growth Projects Incentive was provided wholly in the form of 847,458 SARs granted under the Santos 
Employee Equity Incentive Plan. This was calculated by dividing the maximum award quantum of A$6 
million by the volume weighed average price of Santos shares for the five trading days up to and including 
9 April 2021 of A$7.08.

Performance 
period

Performance 
measures

Five-year performance period (1 January 2021 to 31 December 2025)

The underlying performance conditions of the Growth Projects Incentive are commercially sensitive and 
therefore only a high-level overview of the deliverables and milestones has been provided below. A more 
detailed description of achievements is being provided each year in the Remuneration Report on a 
retrospective basis, as seen in section 4.4. 

Deliverables
Major growth 
projects

Allocation (% of 
total award)
60%

Targets
Initiatives related to the delivery of:

•  the Barossa Project

•  the Dorado and/or Pikka Project 

40%

Emissions 
reduction, 
net-zero plan and 
energy transition

•  developing backfill resources to maximise ongoing utilisation and 

future expansion of existing facilities.

Initiatives related to the delivery of:

•  CCS Operational targets

•  progress towards net-zero Scope 1 and 2 operations emissions 

•  new energy business development which supports energy transition

•  achieve significant progress on a commercial scale hydrogen or 

downstream clean fuels project.

The Board considers that the 40 per cent weighting to emissions, net-zero and energy transition 
significantly increases the exposure of the Managing Director and CEO’s remuneration to climate change 
measures. 

Progressive 
assessment

The Managing Director and CEO growth projects incentive comprises milestones and initiatives to be 
achieved over the five years to 31 December 2025. 

The Board is reviewing performance annually as part of the Managing Director and CEO’s performance 
assessment. Achievement of initiatives over the five-calendar year performance period (2021-2025) allows 
success to be ‘locked in’ along the way, noting that any award is subject to the final performance 
assessment. There is no re-testing of this award. 

Final 
performance 
assessment

The SARs are at-risk and vesting will be determined following an assessment of delivery against strict 
performance conditions related to growth projects and emissions reduction and energy transition 
deliverables, as detailed in the Performance measures section of this table. 

192

Santos Annual Report 2024Element
Vesting

Description
Following this assessment, if the SARs vest, shares are automatically allocated to Mr Gallagher. Nothing is 
payable by Mr Gallagher to the Company if SARs vest. 

While any vesting awards will not be subject to a further restriction period post vesting, Mr Gallagher is 
required to retain a minimum shareholding of approximately three times his annual Total Fixed 
Remuneration. Trading in shares is subject to compliance with the Company’s Securities Dealing Policy. Mr 
Gallagher also participates in deferred STI and LTI, which are provided in equity and that provide ongoing 
alignment with shareholders. 

Termination 
and forfeiture

The SARs remain subject to forfeiture if the Managing Director and CEO resigns from his employment prior 
to 31 December 2025 unless agreed by the Board.

Dividends  
and dividend 
equivalent 
payment  
(DEP) and 
voting

Dividends are not payable on SARs during the LTI performance period.

The DEP is payable on shares that vest in accordance with performance outcomes. The DEP is not payable 
on SARs that lapse or are forfeited (see section 5.4 for further information).

SARs do not carry any voting rights.

5.4 General terms applying to equity awards

Element
Award 
allocation

Description
Awards are allocated using a face value approach – that is using the full Santos share price. No discount is 
applied to reflect the probability of vesting or to reflect dividends forgone over the vesting period. As 
noted below a Dividend Equivalent Payment is payable on SARs which satisfy their vesting conditions. 

Treatment on 
termination  
and change  
of control

Generally, if an Executive resigns or is summarily dismissed, their unvested SARs will lapse and restricted 
shares are forfeited. In all other circumstances (including death, total and permanent disability, redundancy 
and termination by mutual agreement), unvested SARs and restricted shares remain on foot and will vest or 
lapse in accordance with their original terms, unless the Board determines otherwise. 

Where there is a change in control, the Board may determine whether, and the extent to which, SARs may 
vest and restricted shares released. 

Malus/ 
clawback

The share plan rules give the Company the discretion to lapse or forfeit unvested equity awards under the 
STI or LTI programs, and claw back any vested shares or cash paid in certain circumstances. 

These circumstances include dishonest or fraudulent conduct, breach of material obligations, miscalculation 
or error, a material misstatement or omission in the accounts of a Group company or events that require 
re-statement of the Group’s financial accounts in circumstances where an LTI or deferred STI award would 
not otherwise have been granted or would not have vested. This is in addition to any rights the Company 
has under the plan rules and general legal principles to seek to recover payments made in error. 

Under the Company’s Securities Dealing Policy, Directors, Executives and employees cannot enter into 
hedging or other financial arrangements that operate to limit the economic risk associated with holding 
Santos securities prior to the vesting of those securities or while they are subject to a holding lock or 
restriction on dealing. 

The Company’s Minimum Shareholding Requirement requires the Managing Director and CEO and 
Executives to build, over a five-year period and then maintain, a minimum shareholding of Santos shares. 
For the Managing Director and CEO this is approximately three times annual Total Fixed Remuneration 
(TFR) and for Executives it is approximately one and a half times the average TFR. These levels of minimum 
shareholdings are significant compared to typical market practice. They ensure ongoing alignment with 
shareholders by requiring the Managing Director and CEO and Executives to hold shares beyond vesting 
until the minimum holding is achieved. 

The Minimum Shareholding Policy does allow the Managing Director and CEO and Executives to sell shares 
to manage arising tax liabilities that occur on the vesting of awards. Disposals to manage tax liabilities are 
encouraged to occur as closely as possible to the end of the deferred taxing point for the relevant award. 

Share Acquisition Rights (SARs) are eligible for a cash payment, or the equivalent value in shares, equal to 
the dividend amount that would have been earned on the underlying shares that ultimately vest to the 
participant. The provision of a notional dividend entitlement on equity awards is entirely consistent with 
using the face value of Santos shares in the calculation of individual awards. The DEP is made to 
participants once the SARs vest into restricted or ordinary shares. No DEP is made in respect to 
SARs that lapse or are forfeited. 

Securities 
hedging

Minimum 
shareholding 
requirement

Dividend 
equivalent 
payment (DEP)

193

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Remuneration Report 
(continued)

6. Key terms of employment contracts for Executive KMP

The main terms of employment contracts for Executive KMP are set out in Table 7.

Table 7: Executive KMP contract terms

K Gallagher

Contract duration
Ongoing

Termination provision

Notice period–Company
12 months

Notice period–Individual
12 months

Employment may be ended immediately in certain circumstances, including misconduct, incapacity and 
mutual agreement, or in the event of a fundamental change in the Managing Director and CEO’s role or 
responsibility.

The Company may elect to pay the Managing Director and CEO in lieu of any unserved notice period. 
If termination is by mutual agreement the Managing Director and CEO will receive a payment of 
A$1.5 million.

In the case of death, incapacity or fundamental change in the Managing Director and CEOs role 
or responsibility, the Managing Director and CEO is entitled to a payment equivalent to 12 months’ 
base salary.

Other KMP

Ongoing

6 or 12 months

6 months

Termination provision

In a Company-initiated termination, the Company may make a payment in lieu of notice equivalent to 
the TFR that the Executive would have received over the notice period. All Executives’ service 
agreements may be terminated immediately for cause whereupon no payments in lieu of notice of other 
termination payments are payable under the agreement.

194

Santos Annual Report 2024 
7. Non-executive Director Remuneration

Remuneration  Policy

The key objectives of Santos’ non-executive Director Remuneration Policy and how these are implemented through the 
Company’s remuneration framework are as follows:

Remuneration Policy objectives

Securing and retaining talented, 
qualified Directors

Promoting independence 
and impartiality

Aligning Director and 
shareholder interest

Enabled through the non-executive Director remuneration framework

Fee levels are set with regard to:

•  time commitment and workload

•  the risk and responsibility 

attached to the role

•  experience and expertise

•  market benchmarking.

Fee levels do not vary according to 
the performance of the Company or 
individual Director performance 
from year to year. Non-executive 
Directors do not receive 
performance-based remuneration.

Non-executive Director 
performance is assessed at the time 
of their re-election.

Santos encourages its non-
executive Directors to build a 
long-term stake in the Company.

Non-executive Directors are 
required to acquire and maintain a 
shareholding in the Company 
equivalent in value to one year’s 
remuneration.

Under the Minimum Shareholding Requirement, non-executive Directors are required to hold fully paid ordinary shares in 
the Company equivalent in value to 100% of their annual fee (base fee and committee fees) and should meet this minimum 
shareholding requirement within four years of being appointed as a non-executive Director and maintain holding for the 
period that they remain a non-executive Director of the Company.

195

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

Maximum aggregate amount

Total fees paid to all non-executive Directors in a year, including Board committee fees, must not exceed A$3.5 million, 
being the amount approved by shareholders at the 2022 Annual General Meeting.

Remuneration

Fees paid to non-executive Directors are reviewed periodically and are fixed by the Board. Following a review in 2023, the 
Board implemented a 4 per cent increase in Board and Committee fees, effective 1 January 2024. This adjustment aligns 
with market benchmarks and remains within the shareholder-approved cap of A$3.5 million.

Table 8 summarises the fee structure for main Board and committees for 2024.

Table 8: Non-executive Directors’ annual fee structure1

Board

Audit and Risk Committee

Environment, Health, Safety and Sustainability Committee

Nomination Committee3

People, Remuneration and Culture Committee

1  Fees are shown inclusive of superannuation.

From 1 January 2024
2 
Chair  
A$
583,778

Member 
A$
208,000

52,000

52,000

N/A

52,000

26,000

26,000

N/A

26,000

2  The Chair of the Board does not receive any additional fees for serving on or chairing any Board committee.

3 

 The Chair of the Board is the Chair of the Nomination Committee, in accordance with its Charter, so does not receive any additional fees for this role (see 
footnote 2 above).

Non-executive Directors may also be paid additional fees for special duties or exertions and are entitled to be 
reimbursed for all business- related expenses. The total remuneration provided to each non-executive Director in 
2024 and 2023 is shown in section 8, Table 10.

Superannuation  and  retirement  benefits

Superannuation contributions are made on behalf of non-executive Directors in accordance with the requirements of the 
Company’s statutory superannuation obligations. Non-executive Directors are not entitled to retirement benefits (other 
than mandatory statutory entitlements).

196

Santos Annual Report 2024n

i

s
e
g
n
a
h
c
r
a
e
y
-
n
o
-
r
a
e
Y

.

.

.

3
2
0
2
r
o
f
4
4
6
6
0
$
d
n
a
4
2
0
2
r
o
f
9
9
5
6
0
$
f
o
e
t
a
r
e
g
a
r
e
v
a
n
a
g
n
i
s
u
$
S
U
o
t
$
A
m
o
r
f
d
e
t
r
e
v
n
o
c
n
e
e
b
e
v
a
h
s
t
n
e
n
o
p
m
o
c
n
o
i
t
a
r
e
n
u
m
e
r
y
r
o
t
u
t
a
t
S

e
h
t
e
r
a
s
P
M
K
t
n
e
r
r
u
c
e
h
T

.
t
c
A
s
n
o
i
t
a
r
o
p
r
o
C
e
h
t

r
e
d
n
u
d
e
r
i
u
q
e
r

s
a
3
2
0
2
d
n
a
4
2
0
2
n

i

s
P
M
K
e
v
i
t
u
c
e
x
E
r
o
f
n
o
i
t
a
r
e
n
u
m
e
r
e
h
t

f
o
s
l
i

a
t
e
d
d
e
s
i
r
a
m
m
u
s

s
t
n
e
s
e
r
p
9
e
b
a
T

l

.
t
c
A
s
n
o
i
t
a
r
o
p
r
o
C
e
h
t

r
e
d
n
u
d
e
r
i
u
q
e
r

s
a
P
M
K
f
o
n
o
i
t
i
n
fi
e
d
e
h
t

t
e
e
m
o
t
y
t
i
l
i

b
i
s
n
o
p
s
e
r
d
n
a
y
t
i
r
o
h
t
u
a
e
t
i
s
i
u
q
e
r
e
h
t
e
v
a
h
o
h
w
s
e
v
i
t
u
c
e
x
E

n
o
i
t
a
r
e
n
u
m
e
r
e
v
i
t
u
c
e
x
E
1
.
8

.

$
A
n

i

i

d
a
p
t
n
u
o
m
a
e
h
t
n

i

e
g
n
a
h
c
a
y

l
i
r
a
s
s
e
c
e
n
t
o
n
d
n
a
s
n
o
i
t
a
i
r
a
v
e
t
a
r
e
g
n
a
h
c
x
e
o
t
e
b
a
t
u
b
i
r
t
t
a
y
l
t
r
a
p
e
r
a
$
S
U
n

l

i

d
e
t
a
t
s
n
e
h
w
s
t
n
u
o
m
a
n
o
i
t
a
r
e
n
u
m
e
r

%

l
a
t
o
T

k
s
i
r
-
t
a

$
S
U

l
a
t
o
T

$
S
U

6
)
e
c
i
v
r
e
s

$
S
U

s
t
fi
e
n
e
b

$
S
U

s
t
n
e
m
y
a
p

g
n
o
l
(

s
t
fi
e
n
e
b

n
o
i
t
a
n
m
r
e
T

i

d
e
s
a
b
-
e
r
a
h
s

5
S
U
L
P

e
r
a
h
S

$
S
U

r
e
h
t
O

m
r
e
t
-
g
n
o

l

l
a
t
o
T

I
T
S
d
e
r
r
e
f
e
D

s
t
c
e
o
r
P

j

$
S
U

4
)
s
e
r
a
h
s

d
e
t
c
i
r
t
s
e
r
(

$
S
U

)
s
R
A
S
(

e
v
i
t
n
e
c
n
I

h
t
w
o
r
G

n
o
i
t
a
u
n
n
a
r
e
p
u
S

$
S
U

$
S
U

$
S
U

)
s
R
A
S
(

I
T
L

s
n
o
i
t
u
b
i
r
t
n
o
c

3
r
e
h
t
O

2
I
T
S

$
S
U

$
S
U

e
s
a
B

y
r
a
l
a
s

1

s
t
n
e
m
y
a
p
d
e
s
a
b
-
e
r
a
h
S

t
n
e
m
y
o
p
m
e

l

l

s
t
fi
e
n
e
b
e
e
y
o
p
m
e
m
r
e
t
-
t
r
o
h
S

-
t
s
o
P

s
l
i
a
t
e
d
n
o
i
t
a
r
e
n
u
m
e
r
P
M
K
e
v
i
t
u
c
e
x
E
y
r
o
t
u
t
a
t
S

:

l

9
e
b
a
T

r
o
t
c
e
r
i
D
e
v
i
t
u
c
e
x
E

.

s
t
n
e
m
y
a
p
d
e
s
a
b
-
e
r
a
h
S
2
B
S
A
A
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n

i

l

d
e
t
a
u
c
a
c

l

,
r
a
e
y

l

i

a
c
n
a
n
fi
e
h
t
g
n
i
r
u
d
d
e
s
n
e
p
x
e
s
t
n
e
m
y
a
p
d
e
s
a
b
-
e
r
a
h
s
e
d
u
c
n

l

i

d
n
a
s
d
r
a
d
n
a
t
S
g
n
i
t
n
u
o
c
c
A
n
a

i
l

a
r
t
s
u
A
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n

i

d
e
r
a
p
e
r
p
e
r
a
s
e
r
u
s
o
c
s
i
d
y
r
o
t
u
t
a
t
S

l

s
e
r
u
s
o
l
c
s
i
d
y
r
o
t
u
t
a
t
S

.

8

%
4
7

%
4
7

%
9
5

%
7
5

%
1
5

%
3
5

%
0

-

,

5
5
0
5
6
5
5

,

,

0
5
9
9
1
5
5

,

-

3
9
1
,
5
1
5
,
1

,

6
6
4
4
8
3
,
1

,

4
5
8
8
0
1
,
1

1
5
1
,
3
9
0
,
1

1
4
9
9
6
1

,

7
0
2
7
4

,

2
3
9
2
7

,

-

2
9
0
0
3

,

2
1
4
4
1

,

2
4
5
2
2

,

1
0
0
6
1

,

7
1
6
2

,

-

-

-

%
0
4

5
3
1
,
9
6
9

5
4
5
7
1

,

-

-

-

-

-

-

-

-

-

6
7
3
8
5
1

,

,

7
0
5
9
2
5
3

,

,

7
1
9
2
3
3
3

,

-

-

8
1
7
,
1
7
6

7
5
1
,
1
5
5

7
1
7
,
1
6
4

,

8
1
7
7
7
3

-

,

4
7
6
9
0
2

9
1
4

5
0
4
,
1

9
1
4

5
0
4
,
1

-

-

-

-

-

-

3
0
3
7
8
6

,

,

0
1
5
5
5
8

,

5
7
2
6
8
9
,
1

2
7
9
8
1

,

4
0
6
9
8
7

,

,

2
9
4
4
8
9

,

6
1
4
7
5
5
,
1

1
7
2
8
1

,

4
6
3
7

,

0
7
7
6

,

6
8
7
4
1
6

,

7
8
8
,
1
7
7

9
1
2
7,
4
3
,
1

3
7
1
,
7
1
3
,
1

5
5
1
,
9
1
2

5
5
2
5
2
2

,

8
9
0
5
5
1

,

3
9
9
,
1
7
1

-

-

-

9
3
7
2
8

,

-

-

-

-

-

-

-

-

-

-

4
4
1
,
2
5
4

7
9
4
4
2
3

,

,

9
1
6
6
0
3

,

5
2
7
5
0
2

-

4
5
1
,
0
2

1
7
2
8
1

,

1
9
9
2
1

,

4
0
5
7
1

,

9
4
9
4

,

-

-

-

-

2
9
9
6

,

8
9
1
,
1
2
2

5
4
1
,
3
2

6
5
6
7
3
2

,

7
0
5
2

,

3
7
4
3

,

,

6
1
4
2
0
1

4
6
9
5
0
2

,

-

9
3
0
5
6
5

,

,

5
2
8
9
3
5

5
0
3
8
4
3

,

,

1
9
4
2
7
4

5
7
3
2
6
1

,

-

-

-

-

-

5
3
9
6
2
1

,

2
7
9
8
1

,

6
4
7
7

,

3
6
8
5
7
1

,

,

5
3
3
9
3
5

4
2
0
2

3
2
0
2

4
2
0
2

3
2
0
2

4
2
0
2

3
2
0
2

4
2
0
2

3
2
0
2

4
2
0
2

3
2
0
2

s
e
v
i
t
u
c
e
x
E

y
e
l
r
a
D
B

7
l
l

i

e
n
n
K
c
M
A

o
n
a
f
e
t
s
o
t
n
a
S
V

8
e
h
u
D
S

r
e
h
g
a

l
l

a
G
K

r
e
v
o

l

d
e
s
n
e
p
x
e
y
e
v
i
s
s
e
r
g
o
r
p
d
n
a
e
t
a
d
t
n
a
r
g
e
h
t

i

t
a
s
a
d
e
n
m
r
e
t
e
d
n
o
i
t
a
s
n
e
p
m
o
c
d
e
k
n

i
l
-
y
t
i
u
q
e
e
h
t

l

f
o
e
u
a
v
e
h
t

f
o
n
o
i
t
r
o
p
o
r
p
a
s
e
d
u
c
n

l

i

n
o
i
t
a
r
e
n
u
m
e
r

,

s
d
r
a
d
n
a
t
S
g
n
i
t
n
u
o
c
c
A
e
h
t

f
o
s
t
n
e
m
e
r
i
u
q
e
r
e
h
t
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n
 I

1

l

f
o
e
u
a
v
e
h
T

.
t
s
e
v
s
t
n
e
m
u
r
t
s
n

i

y
t
i
u
q
e
e
h
t
d
u
o
h
s
e
s
i
l

l

l

a
e
r
y
e
t
a
m

i
t
l
u
y
a
m
s
e
v
i
t
u
c
e
x
E
e
h
t

t
a
h
t

)
y
n
a
f
i
(

t
fi
e
n
e
b

l

a
u
t
c
a
e
h
t

,
f
o
e
v
i
t
a
c
d
n

i

i

r
o

,

o
t
e
v
i
t
a
e
r

l

t
o
n
s
i

n
o
i
t
a
r
e
n
u
m
e
r

s
a
d
e
t
a
c
o

l
l

a
t
n
u
o
m
a
e
h
T

.

d
o
i
r
e
p
g
n
i
t
s
e
v
e
h
t

.

o
t
2
7
e
t
o
N
n

i

l

t
u
o
t
e
s
e
r
a
n
o
i
t
a
u
a
v
e
h
t
g
n
y
l
r
e
d
n
u
s
n
o
i
t
p
m
u
s
s
a
e
h
t

i

f
o
s
l
i

a
t
e
D

.

l

d
o
h
t
e
m
n
o
i
t
a
u
m
i
s
o
l
r
a
C
e
t
n
o
M
e
h
t
g
n
y
p
p
a
t
n
e
m
y
a
P

i

l

d
e
s
a
b
-
e
r
a
h
S
2
B
S
A
A
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n

i

i

d
e
n
m
r
e
t
e
d
s
a
w
n
o
i
t
a
s
n
e
p
m
o
c
d
e
k
n

i
l
-
y
t
i
u
q
e

.

s
t
n
e
m
e
t
a
t
s
l

i

a
c
n
a
n
fi
e
h
t

r
o
f
d
r
a
w
a
e
c
n
a
m
r
o
f
r
e
p

I

T
S
e
h
t

f
o
n
o
i
t
r
o
p
h
s
a
c
e
h
t

s
t
n
e
s
e
r
p
e
r

t
n
u
o
m
a
s
i
h
t

,

3
2
0
2
r
o
F

.

5
2
0
2
h
c
r
a
M
g
n
i
r
u
d
d
a
p
e
b

i

l
l
i

w
h
c
h
w

i

,

4
2
0
2
r
o
f
d
r
a
w
a
e
c
n
a
m
r
o
f
r
e
p

I

T
S
e
h
t

f
o
n
o
i
t
r
o
p
h
s
a
c
e
h
t

s
t
n
e
s
e
r
p
e
r

t
n
u
o
m
a
s
i
h
t

,

4
2
0
2
r
o
 F

.

s
t
fi
e
n
e
b
y
r
a
t
e
n
o
m
-
n
o
n
r
e
h
t
o
d
n
a
e
c
n
a
w
o

l
l

a
n
o
i
t
a
s
i
l
i

b
o
m
d
n
a
t
n
e
m
n
g
i
s
s
a
s
a
h
c
u
s

,

n
o
i
t
a
r
e
n
u
m
e
r

s
a
d
e
t
a
e
r
t

s
t
n
e
m
y
a
p
c
o
h
d
a
s
e
s
i
r
p
m
o
c

’
r
e
h
t
O

 ‘

.

4
2
0
2
h
c
r
a
M
n

i

i

d
a
p
s
a
w
h
c
h
w

i

,

3
2
0
2

l

g
n
i
t
s
e
v
r
a
e
y
-
e
e
r
h
t
a
r
e
v
o
d
e
s
n
e
p
x
e
y
e
v
i
s
s
e
r
g
o
r
p
d
n
a
t
n
e
m
y
a
P
d
e
s
a
b
-
e
r
a
h
S
2
B
S
A
A

f
o
s
t
n
e
m
e
r
i
u
q
e
r
e
h
t
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n

i

i

d
e
n
m
r
e
t
e
d

,
I

T
S
d
e
r
r
e
f
e
d
e
h
t

l

f
o
e
u
a
v
d
e
t
a
m

i
t
s
e
e
h
t

f
o
n
o
i
t
r
o
p
o
r
p
a
s
t
n
e
s
e
r
p
e
r

t
n
u
o
m
a
s
i
h
 T

s
e
v
i
t
u
c
e
x
E
e
h
t

t
a
h
t

)
y
n
a
f
i
(

t
fi
e
n
e
b

l

a
u
t
c
a
e
h
t

,
f
o
e
v
i
t
a
c
d
n

i

i

r
o

,

o
t
e
v
i
t
a
e
r

l

t
o
n
s
i

n
o
i
t
a
r
e
n
u
m
e
r

s
a
d
e
t
a
c
o

l
l

a
t
n
u
o
m
a
e
h
T

.

s
e
t
a
e
r

l

i

t
n
a
r
g
e
h
t
h
c
h
w
o
t
e
c
v
r
e
s

i

f
o
d
o
i
r
e
p
r
a
e
y
-
o
w

t
a
d
n
a
e
c
n
a
m
r
o
f
r
e
p
f
o
r
a
e
y
e
h
t
g
n
e
b
d
o
i
r
e
p

i

d
e
r
r
e
f
e
d
e
h
T

.

s
t
n
e
m
u
r
t
s
n

i

y
t
i
u
q
e
e
h
t

l

f
o
e
u
a
v
r
i
a
f
e
h
t

f
o
e
t
a
m

i
t
s
e
n
a
n
o
d
e
s
a
b
t
n
e
m
y
a
P
d
e
s
a
b
-
e
r
a
h
S
2
B
S
A
A
h
t
i

w
e
c
n
a
d
r
o
c
c
a
n

i

l

l

d
e
t
a
u
c
a
c
n
e
e
b
s
a
h
e
u
a
v
e
h
T

l

.
t
s
e
v
s
t
n
e
m
u
r
t
s
n

i

y
t
i
u
q
e
e
h
t
d
u
o
h
s
e
s
i
l

l

l

a
e
r
y
e
t
a
m

i
t
l
u
y
a
m

.

4
2
0
2

l
i
r
p
A
n

i

d
e
t
a
c
o

l
l

a
s
a
w
d
r
a
w
a
I

T
S
3
2
0
2
e
h
t

f
o
t
n
e
n
o
p
m
o
c
y
t
i
u
q
e
d
e
r
r
e
f
e
d
e
h
T

.

5
2
0
2
h
c
r
a
M
n

i

d
e
t
a
c
o

l
l

a
e
b
o
t
d
e
d
n
e
t
n

i

s
i

d
r
a
w
a
I

T
S
4
2
0
2
e
h
t

f
o
t
n
e
n
o
p
m
o
c
y
t
i
u
q
e

.

s
l
i

a
t
e
d
r
o
f

s
t
n
e
m
e
t
a
t
s

l

i

a
c
n
a
n
fi
e
h
t

n

i

2
7

.

e
t
o
N
o
t

r
e
f
e
R

.

l

s
n
a
p
e
r
a
h
s

e
e
y
o
p
m
e

l

l

a
r
e
n
e
g
s
o
t
n
a
S
e
h
t

r
o
f
d
e
s
u
m
r
e
t

e
v
i
t
c
e

l
l

o
c

e
h
t

s
i

S
U
L
P
e
r
a
h
 S

t
a
h
t
e
t
a
d
n
o
i
t
a
n
m
r
e
t

i

r
e
h

l
i
t
n
u
e
t
a
d
s
i
h
t

m
o
r
f
e
v
a
e

l

i

g
n
n
e
d
r
a
g
n
o
d
e
d
e
e
c
o
r
p

l
l

i

e
n
n
K
c
M
s
M

.

e
t
a
d
s
i
h
t
o
t
d
e
t
a
r
-
o
r
p
n
e
e
b
e
v
a
h
n
o
i
t
a
u
n
n
a
r
e
p
u
s
d
n
a
y
r
a
a
s
e
s
a
b
s
’
l
l

l

i

e
n
n
K
c
M
s
M

.

4
2
0
2
r
e
b
m
e
t
p
e
S
3
1
e
v
i
t
c
e
ff
e
P
M
K
a
s
a
d
e
s
a
e
 C

.

s
e
t
a
d
g
n
i
t
r
o
p
e
r
e
v
i
t
c
e
p
s
e
r
e
h
t
n
e
e
w
t
e
b
e
c
v
r
e
s

i

.

4
2
0
2
r
e
b
m
e
c
e
D

1
3

l
i
t
n
u
4
2
0
2
r
e
b
m
e
t
p
e
S
3
1

m
o
r
f
n
o
i
t
a
u
n
n
a
r
e
p
u
s

l

l

s
u
p
y
r
a
a
s
h
s
a
c
e
d
u
c
n

l

i

s
t
fi
e
n
e
b
n
o
i
t
a
n
m
r
e
t

i

s
’
l
l

i

e
n
n
K
c
M
s
M

.

5
2
0
2
h
c
r
a
M
n

i

r
u
c
c
o

l
l
i

w

.

4
2
0
2
r
e
b
o
t
c
O
4
1
e
v
i
t
c
e
ff
e
P
M
K
a
s
a
d
e
c
n
e
m
m
o
 C

’

s
e
v
i
t
u
c
e
x
E
e
h
t

f
o
t
c
e
p
s
e
r
n

i

e
d
a
m
e
b
o
t

s
w
o
fl
t
u
o
h
s
a
c
e
r
u
t
u
f
d
e
t
a
m

i
t
s
e
e
h
t

l

f
o
e
u
a
v
t
n
e
s
e
r
p
e
h
t

s
a
d
e
r
u
s
a
e
m
s
t
n
e
m
e
l
t
i
t
n
e
e
v
a
e

l

i

e
c
v
r
e
s
g
n
o

l

’

s
e
v
i
t
u
c
e
x
E
e
h
t
n

i

t
n
e
m
e
v
o
m
e
h
t

s
t
n
e
s
e
r
p
e
r

’

s
t
fi
e
n
e
b
m
r
e
t
-
g
n
o

l

r
e
h
t
O

 ‘

2

3

4

5

6

7

8

197

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Remuneration Report 
(continued)

8.2 Non-executive  Director  remuneration

Details of the fees and other benefits paid to non-executive Directors in 2024 are set out in Table 10. Differences in  
fees received between 2024 and 2023 include currency movements as fees are paid in Australian dollars but disclosed in  
US dollars.

No share-based payments were made to any non-executive Director.

Table 10: 2024 and 2023 non-executive Director remuneration

Short-term benefits

Directors’ 
fees (incl. 
committee 
fees) 
US$
158,518

Fees for 
special 
duties or 
exertions 
US$
–

Retirement 
benefits

Other long- 
term benefits 
US$
–

1 
Superannuation 
US$
17,683

Share-based 
payments 
US$
–

165,255

115,755

149,978

39,416

134,980

165,353

149,979

48,175

165,255

110,464

-

171,574

166,100

125,440

-

366,319

355,440

179,199

149,490

165,333

149,490

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

-

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

17,455

12,925

16,122

4,336

14,510

18,520

16,122

7,820

17,455

12,497

-

–

–

13,827

-

18,916

17,504

–

–

1,475

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

Total 
US$
176,201

182,710

128,680

166,100

43,752

149,490

183,873

166,101

55,995

182,710

122,961

-

171,574

166,100

139,267

-

385,235

372,944

179,199

149,490

166,808

149,490

Director
Y Allen

G Cowan2

E Doyle3

V Guthrie

P Hearl3

J Lydon4

J McArdle

V McFadden4

K Spence

M Utsler

M Werror

Year 

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

2024

2023

1 

Includes superannuation guarantee payments.

2  Ceased as a Director effective 1 October 2024.

3  Ceased as a Director effective 11 April 2024.

4  Commenced as a Director effective 11 April 2024.

198

Santos Annual Report 20248.3 Movement in SARs and restricted shares for Executive KMP

Tables 11 and 12 contain details of the number and value of SARs and shares granted, vested and lapsed for Executive KMP 
in 2024.

Table 11: Executive KMP SARs

LTI SARs

Granted1

Vested3

Lapsed

Dividend  
equivalent shares4

Maximum 
2 
value 
US$

Number

Number

Value  
US$

Number

Number

Value 
US$

490,3345

2,008,568

276,9756

1,220,942

300,058

47,787

210,651

118,421

485,090

105,263

431,191

64,305

22,008

283,465

97,014

69,666

23,845

11,090

3,792

48,886

16,716

-

-

112,736

461,804

-

-

-

-

-

-

-

-

-

-

826,754

3,386,653

363,288

1,601,421

393,569

62,669

276,253

Granted

Vested

Lapsed

Dividend  
equivalent shares9

Other SARs

Maximum 
value  
US$

Number

Number

Number

Number

Value  
US$

4,190

4,190

-

-

-

Value  
US$

583

583

-

-

-

125

125

-

-

-

-

-

-

-

-

-

1,796

8,380

250

1,166

-

-

-

-

-

-

-

-

-

-

-

-

898

898

-

-

-

Executive Director

K Gallagher

Executives

B Darley

A McKinnell7

S Duhe8

V Santostefano

Total

Table 11.1: Other SARs

Executive Director
K Gallagher

Executives
B Darley

A McKinnell

S Duhe

V Santostefano

Total

1  This relates to the 2024 LTI.

2 

3 

4 

5 

6 

 The maximum value represents the fair value of LTI grants received in 2024, determined in accordance with AASB 2 Share-based Payment. The weighted average 
fair value of each SAR as at the grant date of 4 September 2024 is A$7.07. Details of the assumptions underlying the valuations are set out in Note 7.2 to the 
financial statements. The minimum total value of the grant to the Executive KMP, if the applicable vesting conditions are not met, is nil in all cases. All values have 
been converted to US$.

 Vesting of LTI SARs that relates to the 2021 LTI award. The value is determined by the share price of A$6.68 on 31 December 2024, the last trading day of the 
vesting period.

 SAR awards as of 2021 attract additional shares in value of the dividends accrued and reinvested during the vesting period under the terms that apply to such 
equity awards. The additional shares are delivered in full following release of the vested SARs. Dividend equivalent shares are not issued for awards that do not 
satisfy their performance conditions.

 The SARs granted to the Managing Director and CEO relate to his 2024 LTI performance grant as approved at the 2024 Annual General Meeting, under Listing 
Rule 10.14. This grant relates to the LTI award for the four-year performance period ending on 31 December 2027.

 The number of SARs vested for the Managing Director and CEO relates to the Managing Director and CEO’s 2021 LTI performance grants as approved at the 2021 
Annual General Meeting. This was tested based on performance to 31 December 2024 with 48.0 per cent of the award vested as described in section 4.3. There 
are no retesting provisions under the LTI and the lapsed amount reflects the 52.0 per cent, which did not satisfy the vesting conditions.

7  Ceased as a KMP effective 13 September 2024.

8  Commenced as a KMP effective 14 October 2024.

9 

 Dividend Equivalent Shares allocated on 4 September 2024 (closing share price of $7.07 used), relating to ShareMatch 2021 SARs. Reportable in 2024 
Remuneration Report.

199

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Remuneration Report 
(continued)

Table 12: Executive KMP restricted shares

Executive Director
K Gallagher

Executives
B Darley
A McKinnell4
S Duhe5
V Santostefano

Total

Table 12.1: Other Shares

Executive Director
K Gallagher

Executives
B Darley

A McKinnell

S Duhe

V Santostefano

Total

Granted1

Vested3

Lapsed

Maximum 
value  
US$2

Number

Number

Value  
US$

Number

146,253

756,657

149,623

659,558

47,052

37,552

-

243,429

194,280

-

13,947

72,156

41,568

36,470

183,237

160,765

-

-

-

-

244,804

1,266,522

227,661

1,003,560

-

-

-

-

-

-

Granted

Vested

Lapsed

Maximum 
value 
US$

Number

Number

Value 
US$

Number

-

-

-

-

-

-

898

4,190

898

4,190

-

-

-

-

-

-

1,796

8,380

-

-

-

-

-

-

1  This relates to the 2023 STI award delivered as restricted shares.

2 

 For restricted shares, the maximum value represents the fair value of 2023 STI shares received in 2024 determined in accordance with AASB 2 Share-based 
Payment. The fair value of the deferred STI grant as at the grant date of 2 April 2024 was A$7.84. The minimum total value of the grant, if the applicable vesting 
conditions are not met, is nil. All values have been converted to US$.

3  This relates to the 2022 STI grant that was deferred for two years from 1 January 2023 to 31 December 2024 and vested in full on 31 December 2024.

4  Ceased as a KMP effective 13 September 2024.

5  Commenced as a KMP effective 14 October 2024.

200

Santos Annual Report 2024 
8.4 KMP  shareholdings

Table 13 sets out the movements during the reporting period in the number of fully paid ordinary shares of the Company 
held directly, indirectly or beneficially, by each KMP, including their related parties.

Full details of all outstanding equity awards can be found in Note 7.2 to the financial statements and in prior 
Remuneration Reports.

Table 13: 2024 Movements in ordinary shareholding for KMP

Received 
upon 
vesting of 

SARs1 Purchased

Sold

Deferred 
2022 STI 
that vested 
on 31 
December 
2024

Other 
changes

Closing 
balance

Opening 
balance

48,883

39,188

-

50,000

26,000

119,945

20,000

1,620

47,367

45,487

48,808

1,667,847

208,321

208,722

70,462

-

56,659

33,722

-

200,794

57,625

-

-

-

-

-

-

-

-

-

-

-

-

-

63,797

-

-

-

20,000

16,200

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

(47,367)

(45,487)

(48,808)

48,883

39,188

63,797

50,000

26,000

119,945

40,000

17,820

–

–

–

(213,205)

149,623

29,383

1,841,969

(115,381)

-

-

-

41,568

36,470

-

-

-

-

-

-

191,568

140,654

-

258,419

Non-executive Directors

Y Allen

V Guthrie

J Lydon2

J McArdle

V McFadden2

K Spence

M Utsler

M Werror

Former non-Executive Directors
E Doyle3

G Cowan4

P Hearl3

Executive Director

K Gallagher

Executives

B Darley

A McKinnell5

S Duhe6

V Santostefano

Total

2,595,123

356,327

99,997

(328,586)

227,661

(112,279)

2,838,243

1 

2 

3 

4 

 This reflects SARs that vested and converted to ordinary shares in 2024. This includes the 2020 LTI. The 2021 LTI was tested at the end of its performance period 
on 31 December 2024 and 48.0 per cent vested, and the vested SARs converted to ordinary shares after 31 December 2024.

 Commenced as a Director effective 11 April 2024.

 Ceased as a Director effective 11 April 2024. Ms Doyle and Mr Hearl held balances of fully paid ordinary Santos shares upon their retirement from the Board, 
reflecting a nil closing balance at year end.

 Ceased as a Director effective 1 October 2024. Mr Cowan held a balance of fully paid ordinary Santos shares upon his retirement from the Board, reflecting a nil 
closing balance at year end.

5  Ceased as a KMP effective 13 September 2024.

6  Commenced as a KMP effective 14 October 2024.

201

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationRemuneration Report 
(continued)

8.5 Executive KMP SARs and restricted shares

Tables 14 and 15 set out the movement during the reporting period in the number of SARs and restricted shares of the 
Company held directly, indirectly or beneficially, by each KMP, including their related parties. There are no options held 
by KMPs.

Table 14: Movements in Executive KMP SARs

Grant 
date

Balance at  
1 Jan 2024

SARs 
granted

SARs 
vested1

SARs  
lapsed

Balance at  
31 Dec 
2024

%  
vested in 
the year

%  
forfeited  
in the year

Financial 
year of 
vesting

Executive Director
K Gallagher

31/08/20

15/04/21

11/04/21

15/07/22

898

577,033
847,4582
573,375

22/05/23

506,722

-

-

-

-

-

26/06/24

-

490,334

(898)

-

(276,975)

(300,058)

-

-

100%

48.0%

0%

52.0%

-

-

-

-

-

-

-

-

847,458

573,375

506,722

490,334

-

-

-

-

-

-

-

-

Total

2,505,486

490,334 (277,873)

(300,058)

2,417,889

Executives
B Darley

A McKinnell3

31/08/20

12/05/21 

15/07/22 

22/05/23 

26/06/24 

Total
12/05/21 

15/07/22 

898

133,971

133,122

117,647

-

385,638
45,853

110,935

22/05/23 

105,042

-

-

-

-

118,421

118,421
-

-

-

26/06/24 

-

105,263

S Duhe4

Total
-

Total

V Santostefano 26/06/24 

Total

261,830
-

-
-

105,263
-

-
112,736

112,736

(898)

-

(64,305)

(69,666)

-

-

100%

48.0%

0%

52.0%

-

-

-

-

-

-

(65,203)
(22,008)

(69,666)
(23,845)

-

-

-

-

-

-

(22,008)
-

(23,845)
-

-

-

133,122

117,647

118,421

369,190
-

110,935

105,042

105,263

321,240
-

-
112,736

112,736

-

-

-

-

-

-

48.0%

52.0%

-

-

-

-

-

-

-

-

-

-

2024

2024

2025

2025

2026

2027

2024

2024

2025

2026

2027

2024

2025

2026

2027

-

-
2027

1  Rights vested represents SARs that had satisfied their vesting performance conditions in 2024. Vested LTI SARs do not convert to ordinary shares until 2025.

2 

 This relates to the special one-off Growth Projects Incentive SARs granted in 2021. The award will vest on 31 December 2025 contingent on the achievement of 
the relevant performance and employment conditions outlined in more detail in section 5.3.

3  Ceased as a KMP effective 13 September 2024.

4  Commenced as a KMP effective 14 October 2024. Ms Duhe does not hold any SARs.

202

Santos Annual Report 2024Table 15: Movements in Executive KMP restricted shares

Grant 
date

Balance at  
1 Jan 2024

Restricted 
shares 
granted

Restricted 
shares 
vested

Restricted 
shares 
forfeited

Balance at  
31 Dec 
2024

%  
vested in 
the year

%  
forfeited  
in the year

Financial 
year of 
vesting

Executive Director

K Gallagher 

31/08/20

898

24/03/23

149,623

-

-

(898)

(149,623)

02/04/24

-

146,253

-

Total

150,521

146,253

(150,521)

Executives

B Darley 

31/08/20

24/03/23

02/04/24

Total

A McKinnell1 

24/03/23

898

41,568

-

-

(898)

(41,568)

-

47,052

-

42,466

36,470

47,052

(42,466)

-

(36,470)

02/04/24

-

37,552

-

S Duhe2

Total

-

Total

V Santostefano 02/04/24

Total

36,470

37,552

(36,470)

-

-

-

-

-

13,947

13,947

-

-

-

1  Ceased as a KMP effective 13 September 2024.

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

146,253

146,253

-

-

47,052

47,052

100%

100%

-

100%

100%

-

-

100%

37,552

37,552

-

-

13,947

13,947

-

-

-

0%

0%

-

0%

0%

-

0%

-

-

-

2024

2024

2025

2024

2024

2025

2024

2025

2025

2  Commenced as a KMP effective 14 October 2024. Ms Duhe does not currently hold any restricted shares.

ShareMatch offer

In 2020, KMP were able to participate in the Santos ShareMatch employee share plan. The 2020 ShareMatch offer (2020 
offer) provided the opportunity for participants to acquire up to A$10,000 of Santos shares, funded through pre-tax and 
post-tax salary deductions (which concluded in June 2021). Shares allocated under the 2020 offer were subject to a three 
or four year restriction period. In addition, for every share acquired under the 2020 offer, participants received one 
‘matched’ share right, subject to a continuous service condition, at no additional cost to the participant. A dividend 
equivalent was also payable in relation to any share rights that vested. ShareMatch was not offered to KMP from 2021 
onwards. 

The general terms of ShareMatch and full details of all outstanding equity awards can be found in note 7.2 to the Financial 
Statements.

Loans to Key Management Personnel

 No loans have been made, guaranteed or secured, directly or indirectly, by the Company or any of its subsidiaries at any 
time throughout the year to any KMP, including their related parties.

203

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationDirectors’ Report
(continued)

Indemnification 

Rule 61 of the Company’s Constitution requires that the Company indemnifies, on a full indemnity basis and to the full 
extent permitted by law, officers of the Company for all losses or liabilities incurred by the person as an officer of the 
Company, a related body corporate or trustee of a Company-sponsored superannuation fund. 

Rule 61 also permits the Company to purchase and maintain a Directors’ and Officers’ insurance policy. 

In conformity with Rule 61, the Company is party to Deeds of Indemnity in favour of each of the Directors referred to in this 
report who held office during the year, and certain Senior Executives of the consolidated entity. The indemnities operate to 
the full extent permitted by law and are not subject to a monetary limit. Santos is not aware of any liability having arisen, 
and no claims have been made during or since the financial year ended 31 December 2024 under the Deeds of Indemnity. 

The Company purchases directors and officers liability insurance in respect of current and former Directors and other 
officers of the Company and its controlled entities, which insures against certain liabilities (subject to exclusions). Due to 
confidentiality obligations, we are unable to disclose any further details about the premium or insurance. 

Non-audit services 

Amounts paid or payable to the Company’s auditor, Ernst & Young, for non-audit services provided during the year were: 

Ernst & Young for other assurance services

Ernst & Young (Australia) for taxation compliance services

Ernst & Young (Australia) for other services

$1,969,000

 $301,000

 $99,000

The Directors are satisfied, based on the advice of the Audit and Risk Committee, that the provision of the non-audit 
services detailed above by Ernst & Young is compatible with the general standard of independence for auditors imposed by 
the Corporations Act 2001 (Cth). 

The reason for forming this opinion is that all non-audit services have been reviewed by the Audit and Risk Committee to 
ensure they do not impact the impartiality and objectivity of the auditor. 

A copy of the auditor’s independence declaration as required under section 307C of the Corporations Act 2001 (Cth) is set 
out on page 290. 

Rounding 

Australian Securities and Investments Commission Corporations (Rounding in Financial/Directors’ Reports) Instrument 
2016/191 applies to the Company. Accordingly, amounts have been rounded off in accordance with that Instrument, unless 
otherwise indicated. 

This report is made out on 18 February 2025 in accordance with a resolution of the Directors. 

Director

204

Santos Annual Report 2024 
O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

FINANCIAL 
REPORT 

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
i
a
l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a

l

I

n
f
o
r
m
a
t
i
o
n

Santos Annual Report 2024

205

 
 
 
 
 
 
 
 
Contents

Consolidated Income Statement

Consolidated Statement of Comprehensive Income

Consolidated Statement of Financial Position

Consolidated Statement of Cash Flows

Consolidated Statement of Changes in Equity

Notes to the Consolidated Financial Statements

207

208

209

210

211

212

Section 1

Basis of preparation

1.1  Statement of compliance

1.2  Key events in the current period

1.3   Significant accounting judgements, estimates  

and assumptions

1.4  Foreign currency

Section 2

Financial performance

2.1  Segment information

2.2 Revenue from contracts with customers

2.3 Expenses

2.4 Taxation

2.5 Earnings per share

2.6 Dividends

2.7 Other income

Section 3

Capital expenditure, operating assets  
and restoration obligations

3.1  Exploration and evaluation assets

3.2 Oil and gas assets

3.3 Intangible assets

3.4 Impairment of non-current assets

3.5 Restoration obligations and other provisions 

3.6 Leases

3.7 Commitments for expenditure

Section 4

Working capital management

4.1  Cash and cash equivalents

4.2 Trade and other receivables

4.3 Inventories

4.4 Trade and other payables

Section 5

Page

Funding and risk management

212

212

212

214

5.1  Interest-bearing loans and borrowings

5.2 Net finance costs

5.3 Issued capital

5.4 Reserves and accumulated profit

5.5 Financial risk management

Section 6

Page

Group structure

215

218

221

222

225

226

226

Page

227

228

231

232

235

237

240

Page

241

242

243

243

6.1 Consolidated entities

6.2 Disposals

6.3 Non-controlling interests

6.4 Assets held for sale

6.5 Joint arrangements

6.6 Parent entity disclosures

6.7 Deed of cross guarantee

Section 7

People

7.1  Employee benefits

7.2  Share-based payment plans

7.3  Key Management Personnel disclosures

Section 8

Other

8.1  Contingent liabilities

8.2 Events after the end of the reporting period

8.3 Remuneration of auditors 

8.4 Accounting policies 

Consolidated Entity Disclosure Statement

Directors’ Declaration

Independent Auditor’s Report

Auditor’s Independence Declaration

Page

244

247

247

248

249

Page

258

261

262

263

264

267

268

Page

270

271

276

Page

277

277

277

278

279

282

283

290

206

Santos Annual Report 2024 
Consolidated Income Statement
for the year ended 31 December 2024

Revenue from contracts with customers – Product sales

Cost of sales

Gross profit
Revenue from contracts with customers – Other

Other income

Impairment of non-current assets

Other expenses

Finance income

Finance costs

Share of net profit of associates and joint ventures

Profit before tax
Income tax expense

Royalty-related tax benefit

Total tax expense

Net profit for the period 
Attributable to:

  Owners of Santos Limited

  Non-controlling interests

Earnings per share attributable to the equity holders of Santos Limited (¢)
Basic profit per share 

Diluted profit per share

Dividends per share (¢)
Paid during the period

Declared in respect of the period

2024

2023

Note

US$million

US$million

2.2

2.3

2.2

2.7

3.4

2.3

5.2

5.2

6.5(b)

2.4(a)

2.4(b)

6.3

2.5

2.5

2.6

2.6

5,381 

(3,395) 

1,986 

5,889

(3,667)

2,222

137

187

(123)

(271)

122

(291)

2

1,749

(489)

4

(485)

1,264

1,224 

40 

1,264

37.8

37.6

30.5

23.3

145

123

(75)

(374)

106

(333)

5

1,819

(485)

82

(403)

1,416

1,416

–

1,416

43.4

43.2

23.8

26.2

The Consolidated Income Statement is to be read in conjunction with the Notes to the Consolidated Financial Statements.

207

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationConsolidated Statement of Comprehensive Income
for the year ended 31 December 2024

Net profit for the period

  Other comprehensive (loss)/income, net of tax

Items to be reclassified to the income statement in subsequent periods

Exchange (loss)/gain on translation of foreign operations

Tax effect

  Movement in cash flow hedge reserve 

Tax effect

 Net other comprehensive (loss)/income to be reclassified to the income 
statement in subsequent periods

  Other comprehensive (loss)/income, net of tax

Total comprehensive income
Attributable to:

  Owners of Santos Limited

  Non-controlling interests

2024

2023

US$million

US$million

1,264

1,416

(32)

7

(25)

(169)

51

(118)

(143)

(143)

1,121

1,081

40

1,121

13

–

13

132

(39)

93

106

106

1,522

1,522

–

1,522

The Consolidated Statement of Comprehensive Income is to be read in conjunction with the Notes to the Consolidated 
Financial Statements.

208

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated Statement of Financial Position
as at 31 December 2024

Current assets
Cash and cash equivalents

Trade and other receivables

Prepayments

Contract assets

Inventories

Other financial assets

Assets held for sale

Total current assets

Non-current assets
Contract assets

Investments in associates and joint ventures

Other financial assets

Prepayments

Exploration and evaluation assets

Oil and gas assets

Other land, buildings, plant and equipment

Deferred tax assets

Intangible assets

Total non-current assets

Total assets

Current liabilities
Trade and other payables

Contract liabilities

Lease liabilities

Interest-bearing loans and borrowings

Current tax liabilities

Provisions

Other financial liabilities

Liabilities directly associated with assets held for sale

Total current liabilities

Non-current liabilities
Contract liabilities

Lease liabilities

Interest-bearing loans and borrowings

Deferred tax liabilities

Provisions

Other financial liabilities

Total non-current liabilities

Total liabilities

Net assets

Equity
Issued capital

Reserves

Accumulated profit

Equity classified as held for sale

Equity attributable to owners of Santos Limited

Total equity

2024

2023

Note

 US$million

 US$million

4.1

4.2

2.2(b)

4.3

5.5(h)

6.4

2.2(b)

6.5(b)

5.5(h)

3.1

3.2

2.4(d)

3.3

4.4

2.2(b)

3.6

5.1

3.5

5.5(h)

6.4

2.2(b)

3.6

5.1

2.4(d)

3.5

5.5(h)

5.3

5.4

5.4

6.4

1,833 

729

77

87

428

32

–

3,186

92

393

59

509

2,553

20,134

425

1,017

1,265

26,447

29,633

969

79

200

687

12

423

43

–

1,875

829

94

86

442

404

617

4,347

179

406

127

436

2,462

19,101

409

1,038

1,251

25,409

29,756

1,080

59

189

646

7

438

257

272

2,413

2,948

139

621

5,180

1,804

3,918

21

11,683

14,096

15,537

14,345

105

1,087

–

15,537

15,537

150

596

4,728

1,893

4,128

38

11,533

14,481

15,275

14,339

489

398

49

15,275

15,275

The Consolidated Statement of Financial Position is to be read in conjunction with the Notes to the Consolidated  
Financial Statements.

209

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Consolidated Statement of Cash Flows
for the year ended 31 December 2024

Cash flows from operating activities
Receipts from customers

Interest received

Dividends received

Pipeline tariffs and other receipts

Payments to suppliers and employees

Restoration expenditure

Exploration and evaluation seismic and studies

Royalty and excise paid

Commodity hedging

Borrowing costs paid

Income taxes paid

Royalty-related taxes paid

Insurance proceeds

Overriding royalty

2024

2023

Note

US$million

US$million

5,773

122

2

241

5,992

106

1

216

(2,149)

(2,019)

(319)

(56)

(163)

14

(94)

(438)

(116)

39

(6)

(108)

(78)

(153)

(6)

(132)

(428)

(158)

17

8

Net cash provided by operating activities

4.1(b)

2,850

3,258

Cash flows from investing activities
Payments for:

Exploration and evaluation assets

  Oil and gas assets

  Other land, buildings, plant and equipment

  Acquisitions of a controlled entity, net of cash acquired

  Costs associated with acquisition of subsidiaries

Loan to associate

Repayment of loan by associate

Net proceeds associated with disposal of non-current assets

Borrowing costs paid

Net cash used in investing activities 

Cash flows from financing activities
Dividends paid

Drawdown of borrowings

Repayment of borrowings

Net proceeds associated with disposal of subsidiary

Repayment of principal portion of lease liabilities

Purchase of shares on-market (Treasury shares)

Purchase of shares on-market (Share buy-back)

Other financing

Net cash used in financing activities

Net decrease in cash and cash equivalents

Cash and cash equivalents at the beginning of the period
Effects of exchange rate changes on the balances of cash held in foreign currencies

Amounts transferred from assets held for sale 

Cash and cash equivalents at the end of the period

(157)

(2,214)

(30)

-

(27)

(29)

111

6

(345)

(2,685)

(991)

1,135

(667)

592

(254)

(15)

-

(6)

(206)

(41)

1,875

(37)

36

 1,833

(174)

(2,154)

(41)

(209)

(3)

(82)

–

10

(243)

(2,896)

(777)

1,293

(787)

-

(236)

(22)

(316)

(15)

(860)

(498)

2,352

(21)

 42

1,875

2.6

6.2

5.3

5.3

6.4

4.1

The Consolidated Statement of Cash Flows is to be read in conjunction with the Notes to the Consolidated Financial 
Statements.

210

Santos Annual Report 2024 
 
Consolidated Statement of Changes in Equity
For the year ended 31 December 2024

-
n
o
N

d
e
t
a
l
u
m
u
c
c
A

i

n
g
e
r
o
F

y
c
n
e
r
r
u
c

d
e
t
i

i

m
L
s
o
t
n
a
S
f
o
s
r
e
n
w
o
o
t
e
b
a
t
u
b
i
r
t
t
a
y
t
i
u
q
E

l

t
s
e
r
e
t
n

i

y
t
i
u
q
e

t
fi
o
r
p
/
)
s
e
s
s
o
l
(

e
v
r
e
s
e
r

e
v
r
e
s
e
r

e
v
r
e
s
e
r

g
n

i
l
l

o
r
t
n
o
c

l
a
t
o
T

d
e
t
a
l
u
m
u
c
c
A

s
t
fi
o
r
p

i

g
n
g
d
e
H

n
o
i
t
a
l
s
n
a
r
t

7
3
5
5
1

,

–

7
3
5
5
1

,

7
8
0
,
1

.

s
t
n
e
m
e
t
a
t
S

)
0
4
(

)
8
0
0
,
1
(

5
4
3
4
1

,

–

l
a
t
o
T

y
t
i
u
q
e

3
4
8
4
1

,

6
0
1

6
1
4
,
1

2
2
5
,
1

)
7
7
7
(

)
2
2
(

)
6
1
3
(

5
2

–

5
7
2
5
1

,

5
7
2
5
1

,

–

–

–

–

–

–

–

–

–

–

–

–

)
3
4
1
(

1
2
1
,
1

4
6
2
,
1

0
4

–

0
4

)
0
0
0
,
1
(

)
9
(

)
5
1
(

–

6
3

5
5
3

)
5
3
2
(

–

–

–

5
8
1

)
6
1
2
(

3
4
8
4
1

,

)
8
1
1
(

–

)
0
0
9
(

6
0
1

6
1
4
,
1

2
2
5
,
1

)
7
7
7
(

)
2
2
(

)
6
1
3
(

5
2

6
1
4
,
1

–

6
1
4
,
1

–

–

–

–

5
7
2
5
1

,

5
7
2
5
1

,

8
9
3

8
9
3

–

)
0
5
5
(

4
2
2
,
1

4
2
2
,
1

)
3
4
1
(

–

1
8
0
,
1

4
2
2
,
1

)
5
1
(

)
1
9
9
(

–

6
3

0
7
1

)
9
1
(

–

–

–

–

–

5
1

–

–

–

1
7
2
,
1

0
0
9

–

–

–

)
7
7
7
(

4
9
3
,
1

4
9
3
,
1

0
5
5

–

–

–

)
1
9
9
(

–

–

–

–

0
0
2

3
5
1
,
1

)
5
1
(

1

)
7
4
9
(

–

–

3
9

3
9

–

–

–

–

8
7

8
7

–

–

)
8
1
1
(

)
8
1
1
(

–

–

–

–

–

–

–

–

3
1

3
1

–

–

–

–

1

)
4
3
9
(

1
)
4
3
9
(

–

–

)
5
2
(

)
5
2
(

–

–

–

–

)
0
3
(

)
9
1
(

d
e
u
s
s
I

l
a
t
i
p
a
c

2
5
6
4
1

,

e
t
o
N

–

–

–

–

–

)
2
2
(

)
6
1
3
(

5
2

9
3
3
4
1

,

9
3
3
4
1

,

–

–

–

–

–

)
5
1
(

–

1
2

–

–

6
2

.

3
5

.

3
5

.

3
5

.

6
2

.

3
5

.

3
5

.

3
5

.

e
v
r
e
s
e
r

s
t
fi
o
r
p
d
e
t
a
u
m
u
c
c
a
o
t

l

s
t
fi
o
r
p
d
e
n
a
t
e
r

i

r
e
f
s
n
a
r
T

3
2
0
2
y
r
a
u
n
a
J
1

t
a
e
c
n
a
l
a
B

s
r
e
n
w
o
s
a
y
t
i
c
a
p
a
c
r
i
e
h
t
n

i

s
r
e
n
w
o
h
t
i

w
s
n
o
i
t
c
a
s
n
a
r
T

d
o
i
r
e
p
e
h
t

r
o
f
e
m
o
c
n

i

e
v
i
s
n
e
h
e
r
p
m
o
c
r
e
h
t
O

d
o
i
r
e
p
e
h
t

r
o
f
e
m
o
c
n

i

e
v
i
s
n
e
h
e
r
p
m
o
c

l

a
t
o
T

e
m
o
c
n

i

e
v
i
s
n
e
h
e
r
p
m
o
c
f
o
s
m
e
t
I

d
o
i
r
e
p
e
h
t

r
o
f

t
fi
o
r
p
t
e
N

e
v
r
e
s
e
r

s
t
fi
o
r
p
d
e
t
a
u
m
u
c
c
a
o
t

l

s
t
fi
o
r
p
d
e
n
a
t
e
r

i

r
e
f
s
n
a
r
T

s
r
e
n
w
o
s
a
y
t
i
c
a
p
a
c
r
i
e
h
t
n

i

s
r
e
n
w
o
h
t
i

w
s
n
o
i
t
c
a
s
n
a
r
T

d
o
i
r
e
p
e
h
t

r
o
f
e
m
o
c
n
i
/
)
s
s
o
l
(
e
v
i
s
n
e
h
e
r
p
m
o
c

l

a
t
o
T

d
o
i
r
e
p
e
h
t

r
o
f

s
s
o

l

e
v
i
s
n
e
h
e
r
p
m
o
c
r
e
h
t
O

e
m
o
c
n

i

e
v
i
s
n
e
h
e
r
p
m
o
c
f
o
s
m
e
t
I

d
o
i
r
e
p
e
h
t

r
o
f

t
fi
o
r
p
t
e
N

)
s
e
r
a
h
s
y
r
u
s
a
e
r
T
(
e
s
a
h
c
r
u
p
e
r
a
h
s

t
e
k
r
a
m
-
n
O

)
k
c
a
b
-
y
u
b
e
r
a
h
S
(
e
s
a
h
c
r
u
p
e
r
a
h
s

t
e
k
r
a
m
-
n
O

s
n
o
i
t
c
a
s
n
a
r
t

t
n
e
m
y
a
p
d
e
s
a
b
-
e
r
a
h
S

3
2
0
2
r
e
b
m
e
c
e
D
1
3
t
a
e
c
n
a
l
a
B

4
2
0
2
y
r
a
u
n
a
J
1

t
a
e
c
n
a
l
a
B

i

d
a
p
s
d
n
e
d
v
D

i

i

)
s
e
r
a
h
s
y
r
u
s
a
e
r
T
(
e
s
a
h
c
r
u
p
e
r
a
h
s

t
e
k
r
a
m
-
n
O

)
k
c
a
b
-
y
u
b
e
r
a
h
S
(
e
s
a
h
c
r
u
p
e
r
a
h
s

t
e
k
r
a
m
-
n
O

s
n
o
i
t
c
a
s
n
a
r
t

t
n
e
m
y
a
p
d
e
s
a
b
-
e
r
a
h
S

i

s
e
i
r
a
d
i
s
b
u
s
n

i

d
e
u
s
s
i

y
t
i
u
q
E

i

s
e
i
r
a
d
i
s
b
u
s

f
o

l

a
s
o
p
s
i
D

4
2
0
2
r
e
b
m
e
c
e
D
1
3
t
a
e
c
n
a
l
a
B

i

d
a
p
s
d
n
e
d
v
D

i

i

n
o

i
l
l
i

m
$
S
U

.

l

e
a
s

l

r
o
f
d
e
h
n
o

i
l
l
i

m
9
4
$
s
e
d
u
c
n

l

I

1

l

i

i

a
c
n
a
n
F
d
e
t
a
d

i
l

o
s
n
o
C
e
h
t
o
t

s
e
t
o
N
e
h
t
h
t
i

w
n
o
i
t
c
n
u
n
o
c
n

j

i

d
a
e
r
e
b
o
t

s
i

y
t
i
u
q
E
n

i

s
e
g
n
a
h
C

f
o
t
n
e
m
e
t
a
t
S
d
e
t
a
d

i
l

o
s
n
o
C
e
h
T

211

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
for the year ended 31 December 2024
Section 1:  Basis of preparation

This section provides information about the basis of preparation of the Financial Report and certain accounting policies 
that are not disclosed elsewhere in the Financial Report. Accounting policies specific to individual elements of the financial 
statements are located within the relevant section of the report.

1.1 Statement of compliance

The consolidated financial report (Financial Report) of Santos Limited (the Company) for the year ended 31 December 
2024 was authorised for issue in accordance with a resolution of the Directors on 18 February 2025.

The Financial Report of the Company for the year ended 31 December 2024 comprises the Company and our controlled 
entities (the Group). Santos Limited (the Parent) is a company limited by shares incorporated in Australia, whose shares are 
publicly traded on the Australian Securities Exchange (ASX) and on PNG's National Stock Exchange (PNGX), and is the 
ultimate parent entity of the Group. The Group is a for-profit entity for the purpose of preparing the Financial Report. The 
nature of the operations and principal activities of the Group are described in the Directors’ Report.

This Financial Report is:

•  a general purpose financial report that has been prepared in accordance with the requirements of the Corporations 

Act 2001 (Cth), Australian Accounting Standards and other authoritative pronouncements of the Australian 
Accounting Standards Board (AASB)

•  compliant with Australian Accounting Standards as issued by the AASB and International Financial Reporting 
Standards (IFRS) as issued by the International Accounting Standards Board, including new and amended 
accounting standards issued and effective for reporting periods beginning on or after 1 January 2024

•  presented in United States dollars (US$)

•  prepared on the historical cost basis except for derivative financial instruments, contingent consideration and other 

financial instruments measured at fair value

• 

rounded to the nearest million dollars, unless otherwise stated, in accordance with ASIC Corporations (Rounding in 
Financial/Directors' Reports) Instrument 2016/191. 

1.2 Key events in the current period

The financial position and performance of the Group was particularly impacted by the following events and transactions 
during the year:

•  production of 87.1 mmboe (2023: 91.7 mmboe) and sales of 91.7 mmboe (2023: 96.4 mmboe)

•  average realised oil price of $84.8 per barrel compared to $87.6 per barrel in 2023

•  net profit after tax of $1,264 million for 2024 (2023: net profit after tax $1,416 million)

• 

free cash flow generated of $1,891 million for 2024 (2023: $2,128 million)

•  net debt increased to $4,891 million at 31 December 2024, from $4,264 million at 31 December 2023.

1.3 Significant accounting judgements, estimates and assumptions

The carrying amount of certain assets and liabilities are often determined based on management’s judgement regarding 
estimates and assumptions of future events. The key judgements, estimates and assumptions that have significant risk of 
causing material adjustment to the carrying amount of certain assets and liabilities within the next annual reporting period 
are highlighted throughout the Financial Report. 

The full-year Financial Report has been prepared using the going concern basis of preparation and the Group continues to 
pay its debts as they fall due. 

Financial reporting impacts of climate change and sustainability matters 

In preparing the Financial Report, management has considered the impact of climate change and current climate-related 
legislation.

212

Santos Annual Report 20241.3 Significant accounting judgements, estimates and assumptions (continued)

Santos seeks to balance the needs of today, supplying the affordable, reliable energy the world needs, with the 
development of low carbon fuels as energy markets and customer demands evolve. Our climate strategy, outlined in the 
Climate Report, details our approach to climate, governance, strategy, metrics and targets, and risk. Since 2018, we have 
published an annual Climate Report aligned with the Financial Stability Board’s Task Force on Climate-Related Financial 
Disclosures (TCFD) recommendations. 

At Santos, our goal is to backfill and sustainably grow our natural gas portfolio to meet growing energy demand in Asia and 
to provide the reliable, affordable energy the world needs for modern life and human progress. Growth will be supported by 
decarbonisation of our operations and development of commercial carbon management services, and the development of 
low carbon fuels as energy markets and customer demands evolve.

Santos has a three-horizon strategy which underpins our decarbonisation pathway to net-zero Scope 1 emissions by 2040 
and net-zero Scope 2 emissions by 2050. It is focused on backfilling and sustaining existing infrastructure, decarbonising 
operations and investing in the technologies needed to develop low carbon fuels of the future.

Central to achieving our strategy is Santos Energy Solutions, the principal activities of which relate to operating midstream 
assets, progressing technologies that support the decarbonisation of ours and others' products, including development of 
commercial carbon management services, such as carbon capture and storage (CCS), the generation of high integrity 
emissions reduction units and development of low carbon fuels.

The estimated impacts of climate change may be assessed through a range of economic and climate-related policies and 
scenarios, as reported in the Climate Report, which includes the Santos Climate Transition Action Plans (CTAP). This 
includes market supply and demand profiles, carbon emissions reduction profiles, legislative impacts and technological 
impacts, all of which are affected by the global demand profile of the economy as a whole. A carbon price is included in 
Santos’ economic modelling of projects and the portfolio, where applicable.

Geo-political factors and the energy transition is expected to bring volatility in commodity prices. This may result in 
scenarios of lower prices through demand destruction and, conversely, structurally higher commodity prices through 
demand and supply dynamics. In accordance with IFRS, Santos’ financial statements are based on reasonable and 
supportable assumptions that represent the Group’s current best estimate of the range of economic conditions that may 
exist in the foreseeable future. The Group has considered the Australian Government’s emissions reduction target and the 
amendments to the Safeguard Mechanism.

The potential impacts of climate change and sustainability-related matters have been considered in the significant 
judgements and key estimates in a number of areas in the Financial Report, including:

•  asset carrying values (exploration and evaluation assets and oil and gas assets) through determination of valuations 

considered for impairment – see Note 3.4 and consideration of asset useful lives – see Note 3.2

• 

restoration obligations, including the timing of such activities – see Note 3.5

•  deferred taxes, primarily related to asset carrying values and restoration obligations – see Note 2.4.

The Group continues to monitor climate-related policy and its impact on the Financial Report.

213

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 1:  Basis of preparation

1.4 Foreign currency

Functional and presentation currency

The Group’s financial statements are presented in United States dollars (US$), as that presentation currency most reliably 
reflects the global business performance of the Group as a whole and is more comparable with our peers. 

The functional currency of the Parent and the majority of subsidiaries is US$. The assets, liabilities, income and expenses of 
non-US dollar denominated functional currency companies are translated into US$ using the following applicable exchange 
rates: 

Foreign currency amount
Income and expenses

Assets and liabilities 

Equity

Reserves

Applicable exchange rate
Average rate prevailing for the relevant period 

Period-end rate

Historical rate

Historical and period-end rates 

Statement of cash flows 

Average rate prevailing for the relevant period

Foreign exchange differences resulting from translation to presentation currency are initially recognised in the foreign 
currency translation reserve and subsequently transferred to the income statement on disposal of the operation.

The period-end exchange rate used was A$/US$0.6222 (2023: 1:0.6812).

Transactions and balances

Transactions in currencies other than an entity’s functional currency are initially recorded in the functional currency by 
applying the exchange rate ruling at the date of the transaction. Monetary assets and liabilities denominated in currencies 
other than an entity’s functional currency are translated at the foreign exchange rate ruling at the reporting date. Foreign 
exchange differences arising on translation are recognised in the income statement with the exception of monetary items 
that form part of the net investment in a foreign operation. 

Foreign exchange differences that arise on the translation of monetary items that form part of the net investment in a 
foreign operation are recognised in the translation reserve in the Financial Report until the net investment is disposed of, 
at which time, the cumulative amount is reclassified to the income statement.

Non-monetary assets and liabilities that are measured at historical cost in currencies other than an entity’s functional 
currency are translated using the exchange rate at the date of the initial transaction. Non-monetary assets and liabilities 
denominated in currencies other than an entity’s functional currency that are stated at fair value are translated to the 
functional currency at foreign exchange rates ruling at the dates the fair value was determined. 

Group companies

The results of subsidiaries with a functional currency other than US$ (the functional currency of the Parent) are translated 
to US$ as at the date of each transaction. The assets and liabilities are translated to US$ at foreign exchange rates ruling at 
the reporting date. Foreign exchange differences arising on translation are recognised directly in the translation reserve. 

Exchange differences arising from the translation of the net investment in foreign operations and of related hedges are 
recognised in the translation reserve. They are released into the income statement upon disposal of the foreign operation.

214

Santos Annual Report 2024 
Notes to the Consolidated Financial Statements
Section 2: Financial performance 

This section focuses on the operating results and financial performance of the Group. It includes disclosures of segmental 
financial information, taxes, dividends and earnings per share, including the relevant accounting policies adopted in each 
area.

2.1 Segment information

The Group has a regional operating model, with the three regional business units being Eastern Australia and Papua New 
Guinea (PNG), Western and Northern Australia and Timor-Leste, and Alaska. Each regional business unit executes both 
upstream development activities and Santos Energy Solutions activities. The Santos Energy Solutions financial information 
is included in the Santos Energy Solutions segment, rather than being included in the Regional Business Unit segments. 
The Alaska Business Unit is currently captured in the ‘Corporate, exploration, eliminations & other’ segment information in 
the Financial Report while the asset is in the development phase. This is the basis on which internal reports are provided to 
the Chief Executive Officer (Chief Operating Decision Maker) for assessing performance and determining the allocation of 
resources within the Group. 

Segment performance is measured based on earnings before interest, tax, depreciation and depletion, exploration and 
evaluation expensed, impairment loss, and change in future restoration assumptions (EBITDAX). Corporate and exploration 
expenditure and inter-segment eliminations are included in the segment disclosure for reconciliation purposes.

Revenue from external customers by geographical location
Australia

PNG

Total

Non-current assets by geographical location  
(excluding financial and deferred tax assets)
Australia

PNG

Other

Total

1 

Amounts have been restated to ensure consistency in classification with current period.

2024 
US$million

2023 
US$million

2,942

2,576

5,518

3,150

2,884

6,034

2024 
US$million

2023 
US$million1

12,266

10,503

2,602

25,371

11,768

10,811

1,665

24,244

215

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 2: Financial performance 

l
a
t
o
T

4
2
0
2

–

7
3
1

1
8
3
5

,

8
1
5
5

,

)
6
4
7
(

)
5
8
5
(

)
6
4
3
(

–

)
5
3
1
(

6
0
7
3

,

)
9
7
6
,
1
(

)
9
6
(

)
3
2
1
(

3
8

)
9
6
1
(

8
1
9
,
1

)
9
8
4
(

9
4
7
,
1

4

4
6
2
,
1

7
9
1

5
1
6
2

,

0
8

3
3
1

5
2
0
3

,

0
7
1

)
1
1
2
(

)
5
7
2
(

)
6
1
3
(

1
2

)
6
3
(

7
2
2

1
0
1

)
8
2
(

)
1
3
(

)
2
3
(

)
1
2
(

)
5
2
(

)
1
(

)
0
1
1
(

)
9
6
1
(

)
9
8
4
(

–

2

9
6
8

–

0
3
1

1
0
0
,
1

,

e
t
a
r
o
p
r
o
C

,

n
o
i
t
a
r
o
p
x
e

l

s
n
o
i
t
a
n
m

i

i
l

e

s
o
t
n
a
S

y
g
r
e
n
E

n
r
e
t
s
e
W

a
i
l
a
r
t
s
u
A

n
r
e
h
t
r
o
N

&
a
i
l
a
r
t
s
u
A

e
t
s
e
L
-
r
o
m
T

i

4
2
0
2

r
e
h
t
o
&

4
2
0
2

4
2
0
2

4
2
0
2

s
n
o
i
t
u
o
S

l

m
a
e
r
t
s
p
U

m
a
e
r
t
s
p
U

–

–

9
7
3

9
7
3

–

–

)
1
4
(

)
6
2
1
(

)
4
1
(

8
9
1

)
3
0
1
(

)
2
(

–

3

6
9

2

1

7
4
8

0
5
8

)
4
0
1
(

)
9
5
2
(

)
7
4
(

–

)
2
4
(

8
9
3

)
3
8
3
(

)
7
(

)
8
9
(

6
1

)
4
7
(

–

–

0
5

0
5

)
8
6
(

–

–

–

8
1

–

)
9
(

)
3
(

–

3
4

1
3

G
N
P

4
2
0
2

1
7
5
2

,

–

5

W
S
N

&
d
n
a
l

4
2
0
2

9
2

9
1

1
2
3
,
1

6
7
5
2

,

9
6
3
,
1

)
5
5
2
(

)
5
8
1
(

)
7
2
(

–

)
7
6
(

)
3
2
6
(

2
4
0
2

,

)
5
(

–

2
2

)
5
0
1
(

)
1
3
1
(

)
6
3
2
(

)
1
(

)
7
9
(

)
1
1
(

9
9
7

)
4
7
2
(

–

–

6
3
4
,
1

4
1
5

2
2
4

0
8
1

8

0
1
6

–

)
4
(

)
1
(

)
9
0
1
(

)
6
9
1
(

0
0
3

)
5
5
2
(

)
0
2
(

–

–

5
2

4
2
0
2

n
i
s
a
B

m
a
e
r
t
s
p
U

-
s
n
e
e
u
Q

r
e
p
o
o
C

–

)
1
2
(

3
6

)
8
3
(

–

–

2

1
8

–

0
8

3
6
1

–

3

4

3
3
2

0
4
2

–

–

–

2
8
6

2
8
6

–

–

3
0
1

7
3
2

0
4
3

–

–

9
2

5
1
2

4
4
2

–

–

7
5

8
9
2

5
5
3

s
r
e
m
o
t
s
u
c

l

a
n
r
e
t
x
e
o
t

s
e
a
s

l

t
c
u
d
o
r
P

e
u
n
e
v
e
R

s
e
s
a
h
c
r
u
p
t
c
u
d
o
r
p
y
t
r
a
p
-
d
r
i
h
T

e
u
n
e
v
e
r

t
n
e
m
g
e
s

l
a
t
o
T

s
t
s
o
c
g
n
i
t
a
r
e
p
o
r
e
h
t
O

s
t
s
o
c
n
o
i
t
c
u
d
o
r
P

s
t
s
o
C

1

s
e
a
s

l

t
n
e
m
g
e
s
-
r
e
t
n

I

r
e
h
t
O

1

s
e
s
a
h
c
r
u
p
t
n
e
m
g
e
s
-
r
e
t
n

I

l

d
e
s
n
e
p
x
e
n
o
i
t
a
u
a
v
e
d
n
a
n
o
i
t
a
r
o
p
x
E

l

l

n
o
i
t
e
p
e
d
d
n
a
n
o
i
t
a
c
e
r
p
e
D

i

X
A
D
T
I
B
E

r
e
h
t
O

n
o

i
l
l
i

m
$
S
U

s
s
o

l

t
n
e
m

r
i
a
p
m

i

t
e
N

s
n
o
i
t
p
m
u
s
s
a
n
o
i
t
a
r
o
t
s
e
r
e
r
u
t
u
f
n

i

e
g
n
a
h
C

s
n
o
i
t
i
s
i
u
q
c
a
d
n
a
s
n
o
i
t
i
d
d
a
t
e
s
s
A

e
s
n
e
p
x
e
x
a
t
d
e
t
a
e
r
-
y
t
l
a
y
o
R

l

t
fi
o
r
p
t
e
N

e
s
n
e
p
x
e
x
a
t
e
m
o
c
n

I

s
t
s
o
c
e
c
n
a
n
fi
t
e
N

x
a
t
e
r
o
f
e
b
t
fi
o
r
P

T
I
B
E

l

s
t
e
s
s
a
n
o
i
t
a
u
a
v
e
d
n
a
n
o
i
t
a
r
o
p
x
E

l

2
s
t
e
s
s
a
s
a
g
d
n
a

l
i

O

3
n
o
i
t
a
s
i
n
o
b
r
a
c
e
D

i

t
n
e
m
p
u
q
e
d
n
a
t
n
a
p

l

,

s
g
n
d

i

l
i

u
b

,

d
n
a

l

r
e
h
t
O

L
T

,

U
A
n
r
e
h
t
r
o
N

,

A
W

G
N
P

,

U
A
n
r
e
t
s
a
E

)
d
e
u
n
i
t
n
o
c
(
n
o
i
t
a
m
r
o
f
n

i

t
n
e
m
g
e
S
1
.
2

216

.

n
o
i
t
a
d

i
l

o
s
n
o
c
n
o
d
e
t
a
n
m

i

i
l

e
e
r
a
s
e
s
a
h
c
r
u
p
d
n
a
s
e
a
s

l

t
n
e
m
g
e
s
-
r
e
t
n

I

.

s
i
s
a
b
h
t
g
n
e

l

'

s
m
r
a
n
a
n
o
d
e
n
m
r
e
t
e
d
s
i

i

i

g
n
c
i
r
p
t
n
e
m
g
e
s
-
r
e
t
n

I

.

.
)
5
3
e
t
o
N
o
t

r
e
f
e
r
(

s
n
o
i
t
p
m
u
s
s
a
n
o
i
s
i
v
o
r
p
n
o
i
t
a
r
o
t
s
e
r
n

i

s
e
g
n
a
h
c
g
n
w
o

i

l
l

o
f

s
t
e
s
s
a
n
o
i
t
a
r
o
t
s
e
r
n
o
t
c
a
p
m

i

s
e
d
u
c
n

l

I

i

.
t
n
e
m
p
u
q
e
d
n
a
t
n
a
p

l

,

s
g
n
d

i

l
i

u
b

,

d
n
a

l

r
e
h
t
o
d
n
a
s
t
e
s
s
a
s
a
g
d
n
a

l
i

o
n

i

s
n
o
i
t
i
s
i
u
q
c
a
d
n
a
s
n
o
i
t
i
d
d
a
d
e
t
a
e
r
n
o
i
t
a
s
i
n
o
b
r
a
c
e
d
s
t
n
e
s
e
r
p
e
R

l

1

2

3

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
l
a
t
o
T

3
2
0
2

–

5
4
1

9
8
8
5

,

4
3
0
6

,

)
2
8
7
(

)
3
4
5
(

)
1
7
4
(

–

)
5
5
1
(

)
8
5
8
,
1
(

3
8
0
4

,

)
6
8
(

)
5
7
(

)
8
1
(

)
7
2
2
(

)
5
8
4
(

9
1
8
,
1

2
8

6
1
4
,
1

6
4
0
2

,

3
1
1

9
2

7
3
2

3
2
5
2

,

2
0
9
2

,

0
1
3

)
5
0
2
(

)
2
8
2
(

)
7
7
1
(

2
2

)
2
4
2
(

)
8
9
1
(

3
1
1

)
5
8
(

)
3
8
(

)
4
2
(

)
5
2
(

)
8
1
(

–

)
0
5
1
(

)
7
2
2
(

–

)
5
8
4
(

4

4
4
6

–

4
2

2
7
6

–

–

9
7
3

9
7
3

)
3
2
1
(

)
8
2
(

–

–

)
6
1
(

2
1
2

)
1
2
1
(

–

–

–

1
9

–

1

1
5

3
1
1

–

5
6
1

4
4
8

4

5

3
5
8

)
0
2
1
(

)
8
7
2
(

)
2
2
(

–

3
4

6
7
4

)
5
7
6
(

)
8
1
(

)
7
5
(

)
3
1
(

)
7
8
2
(

–

–

1
4
1

1
4
1

)
2
(

)
4
0
1
(

–

–

3
1

8
4

)
2
1
(

)
3
(

–

)
9
(

4
2

–

9
2

3
4

6
1

5
5
8
2

,

3
7
2
,
1

4
8
8
2

,

2
3
3
,
1

)
6
5
2
(

)
3
8
1
(

)
5
1
(

–

)
8
8
(

)
6
1
(

)
3
4
5
(

2
4
3
2

,

–

4

)
7
8
(

)
8
1
1
(

)
6
3
2
(

)
9
0
1
(

3
1

5
9
7

)
9
(

)
3
4
2
(

–

–

7
8
7
,
1

3
4
5

6
6
4

8
5
1

)
2
(

2
2
6

)
4
1
1
(

)
6
7
1
(

–

)
4
(

)
5
3
(

3
9
2

)
0
4
2
(

)
5
1
(

–

–

8
3

8
5

2
3

)
8
(

–

–

3

2
0
3

–

5

0
1
3

–

–

–

7
0
4

7
0
4

–

–

3
4
1

2
5
5

5
9
6

–

–

9
3

0
6
2

–

–

7
4

7
0
3

9
9
2

4
5
3

,

e
t
a
r
o
p
r
o
C

,

n
o
i
t
a
r
o
p
x
e

l

s
n
o
i
t
a
n
m

i

i
l

e

s
o
t
n
a
S

y
g
r
e
n
E

n
r
e
t
s
e
W

a
i
l
a
r
t
s
u
A

n
r
e
h
t
r
o
N

&
a
i
l
a
r
t
s
u
A

e
t
s
e
L
-
r
o
m
T

i

3
2
0
2

r
e
h
t
o
&

3
2
0
2

3
2
0
2

3
2
0
2

s
n
o
i
t
u
o
S

l

m
a
e
r
t
s
p
U

m
a
e
r
t
s
p
U

G
N
P

3
2
0
2

-
s
n
e
e
u
Q

r
e
p
o
o
C

W
S
N

3
2
0
2

&
d
n
a
l

3
2
0
2

n
i
s
a
B

m
a
e
r
t
s
p
U

s
r
e
m
o
t
s
u
c

l

a
n
r
e
t
x
e
o
t

s
e
a
s

l

t
c
u
d
o
r
P

e
u
n
e
v
e
R

s
e
s
a
h
c
r
u
p
t
c
u
d
o
r
p
y
t
r
a
p
-
d
r
i
h
T

e
u
n
e
v
e
r

t
n
e
m
g
e
s

l
a
t
o
T

s
t
s
o
c
g
n
i
t
a
r
e
p
o
r
e
h
t
O

s
t
s
o
c
n
o
i
t
c
u
d
o
r
P

s
t
s
o
C

1

s
e
a
s

l

t
n
e
m
g
e
s
-
r
e
t
n

I

r
e
h
t
O

1

s
e
s
a
h
c
r
u
p
t
n
e
m
g
e
s
-
r
e
t
n

I

l

d
e
s
n
e
p
x
e
n
o
i
t
a
u
a
v
e
d
n
a
n
o
i
t
a
r
o
p
x
E

l

l

n
o
i
t
e
p
e
d
d
n
a
n
o
i
t
a
c
e
r
p
e
D

i

X
A
D
T
I
B
E

r
e
h
t
O

4
n
o

i
l
l
i

m
$
S
U

s
s
o

l

t
n
e
m

r
i
a
p
m

i

t
e
N

s
n
o
i
t
p
m
u
s
s
a
n
o
i
t
a
r
o
t
s
e
r
e
r
u
t
u
f
n

i

e
g
n
a
h
C

s
n
o
i
t
i
s
i
u
q
c
a
d
n
a
s
n
o
i
t
i
d
d
a
t
e
s
s
A

e
s
n
e
p
x
e
x
a
t
d
e
t
a
e
r
-
y
t
l
a
y
o
R

l

t
fi
o
r
p
t
e
N

e
s
n
e
p
x
e
x
a
t
e
m
o
c
n

I

s
t
s
o
c
e
c
n
a
n
fi
t
e
N

x
a
t
e
r
o
f
e
b
t
fi
o
r
P

T
I
B
E

l

s
t
e
s
s
a
n
o
i
t
a
u
a
v
e
d
n
a
n
o
i
t
a
r
o
p
x
E

l

2
s
t
e
s
s
a
s
a
g
d
n
a

l
i

O

3
n
o
i
t
a
s
i
n
o
b
r
a
c
e
D

i

t
n
e
m
p
u
q
e
d
n
a
t
n
a
p

l

,

s
g
n
d

i

l
i

u
b

,

d
n
a

l

r
e
h
t
O

L
T

,

U
A
n
r
e
h
t
r
o
N

,

A
W

G
N
P

,

U
A
n
r
e
t
s
a
E

)
d
e
u
n
i
t
n
o
c
(
n
o
i
t
a
m
r
o
f
n

i

t
n
e
m
g
e
S
1
.
2

.

n
o
i
t
a
d

i
l

o
s
n
o
c
n
o
d
e
t
a
n
m

i

i
l

e
e
r
a
s
e
s
a
h
c
r
u
p
d
n
a
s
e
a
s

l

t
n
e
m
g
e
s
-
r
e
t
n

I

.

s
i
s
a
b
h
t
g
n
e

l

'

s
m
r
a
n
a
n
o
d
e
n
m
r
e
t
e
d
s
i

i

i

g
n
c
i
r
p
t
n
e
m
g
e
s
-
r
e
t
n

I

.

.
)
5
3
e
t
o
N
o
t

r
e
f
e
r
(

s
n
o
i
t
p
m
u
s
s
a
n
o
i
s
i
v
o
r
p
n
o
i
t
a
r
o
t
s
e
r
n

i

s
e
g
n
a
h
c
g
n
w
o

i

l
l

o
f

s
t
e
s
s
a
n
o
i
t
a
r
o
t
s
e
r
n
o
t
c
a
p
m

i

s
e
d
u
c
n

l

I

i

.
t
n
e
m
p
u
q
e
d
n
a
t
n
a
p

l

,

s
g
n
d

i

l
i

u
b

,

d
n
a

l

r
e
h
t
o
d
n
a
s
t
e
s
s
a
s
a
g
d
n
a

l
i

o
n

i

s
n
o
i
t
i
s
i
u
q
c
a
d
n
a
s
n
o
i
t
i
d
d
a
d
e
t
a
e
r
n
o
i
t
a
s
i
n
o
b
r
a
c
e
d
s
t
n
e
s
e
r
p
e
R

l

.

d
o
i
r
e
p
t
n
e
r
r
u
c
h
t
i

w
n
o
i
t
a
c
fi
i
s
s
a
c
n

l

i

y
c
n
e
t
s
i
s
n
o
c
e
r
u
s
n
e
o
t
d
e
t
a
t
s
e
r
n
e
e
b
e
v
a
h
s
t
n
u
o
m
A

1

2

3

4

217

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 2: Financial performance

2.2 Revenue from contracts with customers 

Revenue from contracts with customers is recognised in the income statement when the performance obligations are 
considered met, which is when control of the hydrocarbon products or services provided are transferred to the customer. 
Revenue is recognised at the transaction price, which is an amount that reflects the consideration the Group expects to be 
entitled to, net of goods and services tax or similar taxes.

Revenue from contracts with customers – Product sales

Revenue from contracts with customers – Product sales is recognised based on volumes sold under contracts with 
customers at the point in time where performance obligations are considered met. Generally, regarding the sale of 
hydrocarbon products, the performance obligation will be met when the product is delivered to the specified measurement 
point (gas) or point of loading/unloading (liquids). No adjustments are made to revenue for any differences between 
volumes sold to customers and unsold volumes that the Group is entitled to sell based on its working interest.

The Group’s sales of crude oil, liquefied natural gas, ethane, condensate, LPG, and in some contractual arrangements, 
natural gas, are generally based on market prices. In contractual arrangements with market-based pricing, at the time of the 
delivery, there is only minimal risk of a change in transaction price to be allocated to the product sold. Accordingly, at the 
point of sale, where there is no significant risk of revenue reversal relative to the cumulative revenue recognised, there is no 
constraining of variable consideration. 

The Group applies the allocation exception that allows an entity to allocate the market price to product sales as delivered, 
rather than recognising an average price over the term of the contract. For those contractual arrangements based on 
market pricing, the aggregate transaction price allocation to unsatisfied performance obligations is fully constrained at the 
end of the reporting period. Revenue for existing contracts will be recognised over varying contract tenures.

During the year, the Group earned revenue from three customers that were individually greater than 10 per cent of total 
revenue. These amounted to $585 million (2023: $568 million), $571 million (2023: $637 million) and $567 million (2023: 
$548 million), arising from sales from segments Queensland and NSW, PNG and Queensland and NSW respectively.

Contract assets

In a business combination, pre-existing revenue contracts are fair valued and may result in contract assets that represent 
the differential in contract pricing and market price, and will be realised as performance obligations are considered met in 
the underlying revenue contract. The contract asset will be unwound through other expenses. Where different tranches 
exist within a contractual arrangement, individual contracts acquired may contain both a contract liability in respect of 
deferred revenue and a contract asset arising from revenue contracts being fair valued on acquisition.

Contract liabilities

In a business combination, pre-existing revenue contracts are fair valued and may result in contract liabilities being 
recognised. The contract liabilities represent the differential in contract pricing and market price, and will be realised as 
performance obligations are considered met in the underlying revenue contract. To the extent the contract liability 
represents the fair value differential between contract pricing and market price, it will be unwound through ‘revenue – other’ 
upon satisfaction of the performance obligation.

Contract liabilities – Deferred revenue

A contract liability for deferred revenue is recorded for obligations under sales contracts to deliver natural gas in future 
periods for which payment has already been received. Where the period between when payment is received and 
performance obligations are considered met is more than 12 months, an assessment will be made for whether a significant 
financing component is required to be accounted for. Deferred revenue liabilities unwind as revenue from contracts with 
customers upon satisfaction of the performance obligation and if a significant financing component associated with 
deferred revenue exists, will be recognised as finance costs over the life of the contract.

218

Santos Annual Report 2024 
 
2.2 Revenue from contracts with customers (continued) 

(a) Revenue from contracts with customers

Product sales
  Gas, ethane and liquefied natural gas

  Crude oil

  Condensate and naphtha

Liquefied petroleum gas

Total product sales1
Revenue – other

Pipeline tolls and tariffs

  Unwind of acquired contract liabilities

Trading revenues

  Other

Total revenue – other

Total revenue from contracts with customers

1 

Total product sales include third-party product sales of $697 million (2023: $805 million).

2024

2023

US$million

US$million

4,406

548

370

57

5,381

93

1

23

20

137

5,518

4,798

650

390

51

5,889

99

5

15

26

145

6,034

(b) Assets and liabilities related to contracts with customers

The Group has recognised the following assets and liabilities related to contracts with customers:

Acquired contract assets

Current

  Acquired contract assets

  Non-current
  Acquired contract assets

Total acquired contract assets

Contract liabilities

Current

  Acquired contract liabilities

  Deferred revenue

  Non-current
  Acquired contract liabilities

  Deferred revenue

Total contract liabilities

2024

2023

US$million

US$million

87

87

92

92

179

1

78

79

–

139

139

218

86

86

179

179

265

1

58

59

2

148

150

209

219

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 2: Financial performance

2.2 Revenue from contracts with customers (continued)

(b) Assets and liabilities related to contracts with customers (continued)

The following table illustrates the movement in contract asset and contract liability balances for the current reporting 
period:

Acquired contract assets
  Opening balance

Transfer from assets held for sale

  Other expenses

Total acquired contract assets

Acquired contract liabilities
  Opening balance

Revenue – other

Contract liabilities – Deferred income
  Opening balance

  Additional receipts in advance

Revenue from contracts with customers – Product sales

Interest accretion for financing component

  Other

Total contract liabilities

2024

2023

Note

US$million

US$million

6.4

2.3

2.2(a)

5.2

265

–

(86)

179

3

(2)

1

206

–

(12)

15

8

217

218

327

18

(80)

265

8

(5)

3

287

4

(97)

17

(5)

206

209

220

Santos Annual Report 2024 
 
 
 
2.3 Expenses 

Cost of sales

Production costs

  Other operating costs:

LNG plant costs

Pipeline tariffs, processing tolls and other

  Carbon costs

Royalty and excise

  Overriding royalty costs

Shipping costs

Total other operating costs

Total cash cost of production

  Depreciation and depletion:

  Depreciation of plant, equipment and buildings

  Depletion of subsurface assets

Total depreciation and depletion

Third-party product purchases

  Decrease in product stock

Total cost of sales

Other expenses
Selling

  General and administration

  Costs associated with acquisition and disposals

  Change in future restoration assumptions for non-producing assets

Foreign exchange (gain)/loss

Exploration and evaluation expensed

  Unwind of acquired contract assets

  Other

Total other expenses

2024

2023

US$million

US$million

746

109

212

8

162

8

86

585

1,331

1,142

537

1,679

346

39

3,395

16

138

3

(83)

(8)

69

86

50

271

782

110

210

–

157

–

66

543

1,325

1,048

810

1,858

471

13

3,667

23

132

3

18

15

86

80

17 

374

221

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 2: Financial performance

2.4 Taxation 

Income tax

Income tax on the profit or loss for the year comprises current and deferred tax. Income tax is recognised in the income 
statement except in relation to items recognised directly in equity.

Current tax is the amount of income tax payable on the taxable profit or loss for the year, using tax rates enacted or 
substantively enacted at the reporting date, and any adjustment to tax payable in respect of previous years. 

Current income tax assets and liabilities for the current and prior periods are measured at the amount expected to be 
recovered from, or paid to, the taxation authorities. The tax rates and tax laws used to compute the amount are those that 
are enacted or substantively enacted at the reporting date in the countries where the Group operates and generates 
taxable income. Where applicable, tax balances include an estimate of any amounts expected to be paid to settle uncertain 
tax positions if it is probable that an amount will settle the obligation, and a reliable estimate can be made of the amount of 
the obligation. When the Group expects some or all of an amount of tax payable to be reimbursed, the expense relating to 
the income tax payable is presented in the income statement net of any reimbursement that is virtually certain. If the effect 
of the time value of money is material, current tax payable is discounted.

The Company and all of our eligible wholly-owned Australian resident entities are part of a tax-consolidated group under 
Australian taxation law. Santos Limited is the head entity in the tax-consolidated group. The head entity and the controlled 
entities in the tax-consolidated group continue to account for their own current and deferred tax amounts. Current tax 
liabilities and assets, and deferred tax assets arising from unused tax losses and tax credits of the members of the tax-
consolidated group, are recognised by the Company (as head entity in the tax-consolidated group).

The Company and the other entities in the tax-consolidated group have entered into a tax funding agreement and a tax 
sharing agreement.

Royalty-related tax

Petroleum Resource Rent Tax (PRRT), Resource Rent Royalty, and Timor-Leste and PNG’s Additional Profits Tax are 
accounted for as income tax or royalty tax.

International Tax Reform – Pillar Two model rules 

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on Base Erosion and 
Profit Shifting (BEPS) published the Pillar Two model rules to address the tax challenges arising from the digitalisation 
of the global economy in December 2021. Specifically, the BEPS Pillar Two model rules are designed to ensure large 
multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions in which they operate, 
imposing an additional tax on profits where the effective tax rate in that jurisdiction falls below the minimum rate of 
15 per cent. 

As a large multinational enterprise, the Group is subject to the BEPS Pillar Two model rules globally from 1 January 2024 
after the enactment of legislation to give effect to the model rules in Australia in December 2024. 

Based on current information available, the Group does not expect the application of the rules to have a material current 
tax impact on the Group’s financial position. 

The Group has applied the temporary mandatory relief under AASB 2023-2 from deferred tax accounting for the impacts of 
the additional tax at 31 December 2024.

222

Santos Annual Report 2024 
 
2.4 Taxation (continued)

Income tax and royalty-related tax recognised in the income statement for the Group are as follows:

2024

2023

US$million

US$million

(a) Income tax expense

Current tax expense/(benefit)

  Current year

  Adjustments for prior years

  Deferred tax expense

  Origination and reversal of temporary differences

  Adjustments for prior years

Total income tax expense

(b) Royalty-related tax benefit

Current tax expense

  Current year

  Deferred tax benefit

  Origination and reversal of temporary differences

Total royalty-related tax benefit, net of income tax expense

(c) Numerical reconciliation between pre-tax net profit and tax expense

Profit before tax

Prima facie income tax expense at 30% (2023: 30%)

Increase/(decrease) in income tax expense/(benefit) due to:

Profits subject to different tax rate

Movements in losses and deferred tax assets not recognised

Deferred tax assets not previously recognised

Other deductible expenses

Non-deductible expenses

Tax adjustments relating to prior years

De-recognition of deferred tax liability on sale of subsidiary

Other

Income tax expense

Royalty-related tax benefit, net of income tax expense

Total tax expense

475

15

490

3

(4)

(1)

489

120

120

(124)

(124)

(4)

1,749

526

(1)

42

–

–

12

11

(102)

1

489

(4)

485

480

(19)

461

13

11

24

485

113

113

(195)

(195)

(82)

1,819

546

(3)

3

(28)

(20)

10

(8)

–

(15)

485

(82)

403

223

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 2: Financial performance

2.4 Taxation (continued)

(d) Deferred tax assets and liabilities

 Deferred tax is determined using the statement of financial position approach, providing for temporary differences 
between the carrying amounts of assets and liabilities for financial reporting purposes and the appropriate tax bases. 

The following temporary differences are not provided for: 

• 

the initial recognition of assets or liabilities that affect neither accounting or taxable profit 

•  differences relating to investments in subsidiaries to the extent it is probable that they will not reverse in the 

foreseeable future. 

 The amount of deferred tax provided is based on the expected manner of realisation or settlement of the carrying 
amount of assets and liabilities, using tax rates enacted or substantively enacted at the reporting date.

Significant judgement – Uncertain tax positions

 The calculation of the Group’s tax charge involves a degree of estimation and judgement in respect of certain items for 
which the ultimate tax determination is uncertain. 

 The Group recognises deferred tax assets only to the extent that it is probable that future taxable profits will be 
available against which the asset can be utilised. Future taxable profits are estimated by internal budgets and forecasts. 
Deferred tax assets are reduced to the extent that it is no longer probable that the related tax benefit will be realised.

Recognised deferred tax assets 
and liabilities

2024 
US$million

2023 
US$million

2024 
US$million

2023 
US$million

2024 
US$million

2023 
US$million

Note

Assets

Liabilities

Net

Exploration and  

evaluation assets

  Oil and gas assets

  Other assets

  Derivative financial  

instruments

Interest-bearing loans  
and borrowings

Provisions

Royalty-related tax

  Other items

Tax value of carry-forward  

losses recognised

Tax assets/(liabilities)

Set-off of tax

  Net deferred tax assets/ 

(liabilities)
  Amounts classified as  
held for sale

  Adjusted deferred tax  

assets/(liabilities)

231

919

1

27

275

72

–

53

343

1,001

1

3

268

138

–

18

(333)

(2,444)

(64)

–

(3,008)

(17)

(102)

(1,525)

(63)

343

(2,007)

(16)

(83)

(2)

–

(48)

(65)

(135)

(1)

–

(141)

(61)

(56)

273

72

(48)

(12)

674

(787)

–

(132)

267

138

(141)

(43)

625

(966)

–

674

2,252

(1,235)

625

2,397

(1,359)

–

(3,039)

1,235

–

(3,363)

1,359

1,017

1,038

(1,804)

(2,004)

(787)

(966)

6.4

–

–

–

111

–

111

1,017

1,038

(1,804)

(1,893)

(787)

(855)

  Accounting judgement and estimate – Deferred taxes unrecognised 

 Deferred tax assets have not been recognised in respect of the items set out on the following page, because it is not 
probable that the temporary differences will reverse in the future and that there will be sufficient future taxable profits 
against which the benefits can be utilised. There are no tax losses which are expected to expire. The remaining 
deductible temporary differences and tax losses do not expire under current tax legislation.

224

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.4 Taxation (continued)

Unrecognised deferred tax assets
  Deferred tax assets have not been recognised in respect of the following items:

Temporary differences in relation to investments in subsidiaries

  Deductible temporary differences in respect of provisions

  Deductible temporary differences relating to royalty-related tax,  

net of income tax 

Tax losses

2024

2023

US$million

US$million

2,260

156

4,173

281

6,870

2,185

128

3,800

221

6,334

2.5 Earnings per share

Basic earnings per share amounts are calculated by dividing net profit or loss for the year attributable to ordinary equity 
holders of Santos Limited by the weighted average number of ordinary shares outstanding during the year.

Diluted earnings per share amounts are calculated by adjusting basic earnings per share by the weighted average number 
of ordinary shares that would be issued on the conversion of all the dilutive potential ordinary shares into ordinary shares.

Earnings used in the calculation of basic and diluted earnings per share reconcile to the net profit or loss after tax in the 
income statement as follows:

Earnings used in the calculation of basic and diluted earnings per share

2024

2023

US$million

US$million

1,224

1,416

The weighted average number of shares used for the purpose of calculating diluted earnings per share reconciles to the 
number used to calculate basic earnings per share as follows:

  Weighted average number of shares – basic earnings per share

  Dilutive potential ordinary shares

  Weighted average number of shares – diluted earnings per share

Earnings per share attributable to the equity holders of Santos Limited

Basic earnings per share

  Diluted earnings per share

2024

2023

Number of 
shares

Number of 
shares

3,239,980,317

3,261,616,703

13,450,907

14,317,724
3,253,431,224 3,275,934,427 

2024

¢

37.8

37.6

2023

¢

43.4

43.2

225

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 2: Financial performance

2.6 Dividends

Dividends are recognised as a liability at the time the Directors resolve to pay or declare the dividend.

Dividends recognised during the year

2024
2023 Final ordinary dividend – paid on 27 March 2024

2024 Interim ordinary dividend – paid on 25 September 2024

2023

2022 Final ordinary dividend – paid on 29 March 2023

2023 Interim ordinary dividend – paid on 28 September 2023

Dividends declared in respect of the year

2024
Final ordinary dividend

Interim ordinary dividend

2023

Final ordinary dividend

Interim ordinary dividend

Dividend franking account

Franked/ 
unfranked

Unfranked

Unfranked

Unfranked

Unfranked

Franked/ 
unfranked

Unfranked

Unfranked

Unfranked

Unfranked

Dividend  
per share

Total

US¢

US$million

17.5

13.0 

30.5 

15.1

8.7

23.8

569 

422

 991 

498

279

777

Dividend  
per share

Total

US¢

US$million

10.3

13.0

23.3 

17.5 

8.7

26.2

335

422 

 757 

569

283

852

2024

2023

US$million

US$million

30% franking credits available to the shareholders of Santos Limited for future distribution

18

20

2.7 Other income

Other income
Gain on sale of non-current assets

Other income associated with lease arrangements

Insurance recoveries

Overriding royalties

Other

Fair value gain on oil derivatives

Fair value loss on electricity derivatives

Carbon units

Total other income

2024

2023

Note

US$million

US$million

3.6

3.3

13

65

39

7

34

18

–

11

187

5

58

17

9

50

–

(16)

–

123

226

Santos Annual Report 2024 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

This section includes information about the assets used by the Group to generate profits and revenue, specifically 
information relating to exploration and evaluation assets, oil and gas assets, associated restoration obligations, and 
commitments for capital expenditure not yet recognised as a liability.

The life cycle of the Group’s assets is summarised as follows:

Exploration  
and evaluation 

Appraisal  
drilling

Development

Production

Decommissioning

Restoration

3.1 Exploration and evaluation assets

Exploration and evaluation expenditure

Exploration and evaluation activity involves the search for hydrocarbon resources, the determination of technical feasibility 
and the assessment of commercial viability of an identified resource. Expenditure in respect of each area of interest is 
accounted for using the successful efforts method of accounting.

The successful efforts method requires all exploration and evaluation expenditure to be expensed in the period it is 
incurred, except the costs of acquiring interests in new exploration and evaluation assets, the cost of successful wells, and 
appraisal costs relating to determining development feasibility, which are capitalised as intangible exploration and 
evaluation assets.

Exploration and evaluation expenditure is recognised in relation to an area of interest when the rights to tenure of the area 
of interest are current and either:

•  such expenditure is expected to be recovered through successful development and commercial exploitation of the 

area of interest or, alternatively, by its sale; or

• 

the exploration activities in the area of interest have not yet reached a stage that permits reasonable assessment of 
the existence of economically recoverable reserves, and active and significant operations in, or in relation to, the area 
of interest are continuing. 

Where an ownership interest in an exploration and evaluation asset is exchanged for another, the transaction is recognised 
by reference to the carrying value of the original interest. Any cash consideration paid, including transaction costs, is 
accounted for as an acquisition of exploration and evaluation assets. Any cash consideration received, net of transaction 
costs, is treated as a recoupment of costs previously capitalised with any excess accounted for as a gain on disposal of 
non-current assets.

No amortisation is charged during the exploration and evaluation phase. 

Acquisition of assets

All assets acquired are recorded at their cost of acquisition, being the amount of cash or cash equivalents paid, and the fair 
value of assets given, shares issued or liabilities incurred. The cost of an asset comprises the purchase price, including any 
incidental costs directly attributable to the acquisition, any costs directly attributable to bringing the asset to the location 
and condition necessary for it to be capable of operating, and the estimate of the costs of dismantling and removing the 
asset and restoring the site on which it is located.

Exploration licence and leasehold property acquisition costs are capitalised as intangible assets. Licence costs paid in 
connection with a right to explore in an existing exploration area are capitalised.

227

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.1 Exploration and evaluation assets (continued)

Significant judgement – Exploration and evaluation

The application of this policy requires management to make certain estimates and assumptions as to future events and 
circumstances, particularly in relation to the assessment of whether economic quantities of resources have been found. Any 
such estimates and assumptions may change as new information becomes available. If, after having capitalised exploration 
and evaluation expenditure, management concludes that the capitalised expenditure is unlikely to be recovered by future 
exploitation or sale, then the relevant capitalised amount will be impaired through the income statement.

Exploration and evaluation activities give rise to a number of uncertainties with regard to the estimates and assumptions 
made as to the existence and economic viability of hydrocarbon recovery within a prospect. The nature and extent of the 
energy transition in relation to future climate-related conditions, legislation and policies, can impact the assessment of 
those uncertainties with regard to considerations, such as project economics, development scenarios and potential time 
horizons.

Cost

Less: Accumulated impairment

Balance at 31 December

Reconciliation of movements
Balance at 1 January 

Acquisitions 

Additions

Unsuccessful wells expensed

Impairment losses

Disposals

Transfer to oil and gas assets in production

Transfer to oil and gas assets in development

Transfers from assets held for sale

Exchange differences

Balance at 31 December

Comprising:
  Acquisition costs

Successful exploration wells

3.2 Oil and gas assets

2024

2023

US$million

US$million

 4,081 

 (1,528)

2,553

2,462

–

197

(15)

(36)

–

(54)

–

–

(1)

2,553

1,661 

 892 

2,553

3,952

(1,490)

2,462

2,271

2

235

(5)

(18)

(5)

(46)

(3)

33

(2)

2,462

1,711

751

2,462

Oil and gas assets are usually single oil or gas fields being developed for future production or are in the production phase. 
Where several individual oil or gas fields are to be produced through common facilities, the individual oil or gas field and 
the associated production facilities are managed and reported as a single oil and gas asset.

Assets in development

When the technical and commercial feasibility of an undeveloped oil or gas field has been demonstrated and approval of 
commercial development occurs, the field enters its development phase from the exploration and evaluation phase. 
Expenditure on the construction, installation or completion of infrastructure facilities, such as platforms, pipelines, and the 
drilling of development wells, as well as exploration and evaluation costs, are capitalised as tangible assets within oil and 
gas assets. Other subsurface expenditures include the costs of dewatering coal seam gas fields to provide access to coal 
seams to enable production from coal seam gas reserves. Dewatering expenditures include the costs of extracting, 
transporting, treating and disposing of water during the development phase of the coal seam gas fields.

When commercial operation commences, the accumulated costs are transferred to oil and gas producing assets. 

228

Santos Annual Report 2024 
 
3.2 Oil and gas assets (continued)

Producing assets

The costs of oil and gas assets in production are separately accounted for as tangible assets and include past exploration 
and evaluation costs, pre-production development costs and the ongoing costs of continuing to develop reserves for 
production and CO2 storage capacity, and the expansion or replacement of plant and equipment, and any associated land 
and buildings.

Ongoing exploration and evaluation activities

Often the initial discovery and development of an oil or gas asset will lead to ongoing exploration for, and evaluation of, 
potential new oil or gas fields in the vicinity with the intention of producing any near-field discoveries using the 
infrastructure in place.

Exploration and evaluation expenditure associated with oil and gas assets is accounted for in accordance with the policy in 
Note 3.1. Exploration and evaluation amounts capitalised in respect of oil and gas assets are separately disclosed in the 
table below.

Depreciation and depletion

Depreciation charges are calculated to write off the value of buildings, plant and equipment over their estimated economic 
useful lives to the Group. Each component of an item of buildings, plant and equipment with a cost that is significant in 
relation to the total cost of the asset is depreciated separately. 

Depreciation of onshore buildings, plant and equipment and corporate assets is calculated using the straight-line method of 
depreciation from the date the asset is available for use, unless a units of production method represents a more reasonable 
allocation of the asset’s depreciable value over its economic useful life.

The estimated useful lives for each class of onshore assets for the current and comparative periods are generally as follows:

•  Buildings 

•  Pipelines 

20–50 years

10–30 years

•  Plant and facilities 

10–50 years

Depreciation of offshore plant and equipment is calculated using the units of production method from the date of 
commencement of production.

Depletion charges are calculated to amortise the depreciable value of carried-forward exploration, evaluation and 
subsurface development expenditure over its useful life. Useful life is generally determined based on the life of the 
estimated Proved plus Probable (2P) reserves for a hydrocarbon reserve and 2P CO2 storage capacity, together with future 
subsurface costs necessary to develop the respective hydrocarbon reserve and CO2 storage capacity, unless an alternative 
method is considered a better representation of useful life.

Significant judgement – Estimates of reserve quantities

The estimated quantities of 2P hydrocarbon reserves and 2P CO2 storage capacity reported by the Group are integral to 
the calculation of depletion and depreciation expense. The 2P hydrocarbon reserves and 2P CO2 storage capacity are 
incorporated into the assessment of impairment of assets, along with 2C contingent resources and 2C contingent storage 
resources as appropriate. Estimated reserve quantities are based upon interpretations of geological and geophysical 
models and assessments of the technical feasibility and commercial viability of producing the reserves. These assessments 
require assumptions to be made regarding future development and production costs, commodity prices, exchange rates 
and fiscal regimes. The estimates of reserves may change from period to period as the economic assumptions used to 
estimate the reserves can change from period to period, and as additional geological and engineering data is generated 
during the course of operations. Reserves and resources estimates are prepared in accordance with the Group’s policies 
and procedures for reserves estimation which conform to guidelines prepared by the Society of Petroleum Engineers.

Accounting judgement and estimate – Depletion charges 

Depletion and certain depreciation charges are calculated using the units of production (of hydrocarbon reserves) or units 
of injection (of CO2 storage capacity) method. This is based on barrels of oil equivalent/tonnes of CO2 equivalent which 
will amortise the cost of carried-forward exploration, evaluation and subsurface development expenditure (subsurface 
assets) generally over the life of the estimated 2P hydrocarbon reserves or 2P CO2 storage capacity, as appropriate, for an 
asset or group of assets. This includes amortisation of future subsurface costs necessary to develop the hydrocarbon 
reserves or CO2 storage capacity in the respective asset or group of assets. Units of production or units of injection method 
of depletion is used, unless an alternative method is considered a better representation of useful life. The estimated useful 
lives of our assets align with long-term planning and impairment modelling. The impact of climate change is considered in 
these processes. Future climate-related conditions, legislation and policies may have an impact on these estimates and 
continue to be monitored.

229

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.2 Oil and gas assets (continued)

2024

2023

Subsurface 
assets

Plant and 
equipment

Subsurface 
assets

Plant and 
equipment

Total

Total

US$million US$million US$million

US$million

US$million

US$million

Cost

 17,837 

 25,693 

 43,530 

16,300

24,421

40,721

Less:  Accumulated depreciation, 

depletion and impairment

Balance at 31 December

Reconciliation of movements

Assets in development
Balance at 1 January
Additions1
Transfer from exploration and  

evaluation assets

Transfer to producing assets

Transfer from assets held for sale 

Exchange differences

Balance at 31 December

Producing assets
Balance at 1 January
Additions1 
Transfer from exploration and  

evaluation assets

Transfer from land and buildings

Transfer from assets in development

Disposals

Depreciation and depletion 

Transfer from assets held for sale

Net impairment losses

Exchange differences

Balance at 31 December

Total oil and gas assets

Comprising:
Other capitalised expenditure

 (10,035)

 (13,361)

 (23,396)

 7,802 

 12,332 

 20,134 

(9,442)

6,858

(12,178)

12,243

(21,620)

19,101

2,901

 1,255 

–

(656)

 34 

–

1,222

 517 

4,123

 1,772 

2,006

1,006

–

–

(460)

(1,116)

 –

(1) 

 34 

(1) 

3

(114)

–

–

917

401

–

(96)

–

–

2,923

1,407

3

(210)

–

–

3,534 

 1,278 

 4,812 

2,901

1,222

4,123

3,957

256 

54

–

656 

(51)

(572)

–

(20)

(12)

4,268 

7,802 

7,802 

7,802 

11,021

 659 

–

47

 460 

(395)

(1,122)

462

(67)

(11)

 11,054 

 12,332 

14,978

 915 

54

47

 1,116 

(446)

(1,694)

462

(87)

(23)

 15,322 

 20,134 

 12,332 

 12,332 

 20,134 

 20,134 

3,983

682

10,904

547

14,887

1,229

46

–

114

(14)

(813)

–

(57)

16

3,957

6,858

6,858

6,858

–

–

96

–

(1,043)

525

–

(8)

11,021

12,243

12,243

12,243

46

–

210

(14)

(1,856)

525

(57)

8

14,978

19,101

19,101

19,101 

1 

Includes impact on capitalised restoration costs following changes in future restoration provision assumptions (refer to Note 3.5).

230

Santos Annual Report 2024 
 
 
3.3 Intangible assets

Goodwill

Goodwill arises as a result of a business combination and has an indefinite useful life which is not subject to amortisation. 
Goodwill is initially measured at cost and is subsequently measured at cost less any accumulated impairment losses. 

Where goodwill has been allocated to a cash-generating unit (CGU) and part of the operation within that unit is disposed 
of, the goodwill associated with the disposed operation is included in the carrying amount of the operation when 
determining the gain or loss on disposal.

Other intangibles

Intangible assets, other than goodwill, includes carbon units which are designated for own use. Carbon units are earned or 
purchased by the Group as described below:

Earned carbon units 

The Group earns carbon units through carbon reduction projects administered by respective Government Regulators, in 
areas to which our carbon reduction projects operate, which are accounted for as government grants. Once the obligations 
of the grant are satisfied, the Group recognises Other Income based on the fair value of carbon units earned but not yet 
formally issued, refer to Note 2.7.

When carbon units are issued to the Group by the relevant Government Regulators, the carbon unit is recognised as an 
intangible asset and subsequently measured at cost less accumulated impairment losses. During 2024, the Group 
recognised 41,696 carbon units (2023: nil carbon units). 

Purchased carbon units

For purchased carbon units, these are initially measured at cost and subsequently measured at cost less accumulated 
impairment losses. During 2024, the Group purchased 650,000 carbon units (2023: 50,000 carbon units).

The Group also enters into forward purchase contracts for carbon units, which are designated for own use. As at  
31 December 2024, the Group has forward purchase contracts for 2.3 million carbon units (2023: 2.4 million carbon units).

Cost

Less: Accumulated impairment

Balance at 31 December

Goodwill allocated as follows: 

CGU
WA Gas

PNG

Reconciliation of movements
Balance at 1 January

Transfer from assets held for sale

Disposal of subsidiary

Balance at 31 December

2024 
US$million

Other 
intangibles

15

–

15

Goodwill

1,495

(245)

1,250

2023 
US$million

Other 
intangibles

1

–

1

Total

1,510

(245)

1,265

Goodwill

1,495

(245)

1,250

Total

1,496

(245)

1,251

Segment
Western Australia

PNG

2024 
US$million

2023 
US$million

236

1,014

1,250

66

(66)

1,250

236

1,014

1,190

60

–

1,250

231

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.4 Impairment of non-current assets

Impairment of goodwill

For the purposes of impairment testing, goodwill acquired in a business combination is, from the acquisition date, allocated 
to each of the Group’s CGUs that are expected to benefit from the combination, irrespective of whether other assets or 
liabilities of the acquiree are assigned to those units. Goodwill that is created on acquisition as a consequence of deferred 
tax balances is tested for impairment net of those associated deferred tax balances. Goodwill is tested at least annually for 
impairment and more frequently if events or changes in circumstances indicate that it might be impaired.

Impairment of oil and gas assets

The carrying amounts of the Group’s oil and gas assets are reviewed at each reporting date to determine whether there is 
any indication of impairment or impairment reversal. Where an indicator of impairment or impairment reversal exists, a 
formal estimate of the recoverable amount is made.

a)  Indicators of impairment – Exploration and evaluation assets

 The carrying amounts of the Group’s exploration and evaluation assets are reviewed at each reporting date, to 
determine whether any of the following indicators of impairment exist:

• 

tenure over the licence area has expired during the period or will expire in the near future, and is not expected  
to be renewed

•  substantive expenditure on further exploration for, and evaluation of, mineral resources in the specific area is not 

budgeted or planned

•  exploration for, and evaluation of, resources in the specific area have not led to the discovery of commercially 

viable quantities of resources, and the Group has decided to discontinue activities in the specific area

•  sufficient data exists to indicate that, although a development is likely to proceed, the carrying amount of the 
exploration and evaluation asset is unlikely to be recovered in full from successful development or from sale.

b)  Cash-generating units – Oil and gas assets

 Oil and gas assets, land, buildings, plant and equipment are assessed for impairment on a CGU basis. A CGU is the 
smallest grouping of assets that generates largely independent cash inflows, and generally represents oil or gas fields 
that are being produced through a common facility. 

 Individual assets within a CGU may become impaired if their ongoing use changes or if the benefits to be obtained from 
ongoing use are likely to be less than the carrying value of the individual asset. 

Impairment losses or reversal of impairment losses

An impairment loss is recognised in the income statement whenever the carrying amount of an asset or its CGU (including 
any amount of allocated goodwill) exceeds its recoverable amount. Impairment losses recognised in respect of CGUs are 
allocated to reduce goodwill first (if goodwill is included within the carrying amount of the CGU) and then allocated to 
reduce the carrying amount of the assets in the CGU on a pro-rata basis. 

A reversal of impairment losses is recognised in the income statement when the recoverable amount of an asset or CGU 
exceeds its carrying amount. An impairment loss is reversed only to the extent that the asset carrying amount does not 
exceed the carrying amount that would have been determined if no impairment loss had been recognised.

Recoverable amount

The recoverable amount of an asset or CGU is the greater of its fair value less costs of disposal (FVLCD) (classified as level 
3 in the fair value hierarchy) and its value-in-use (VIU), using an asset's estimated future cash flows (as described on the 
following page) discounted to their present value using a pre-tax discount rate that reflects current market assessments of 
the time value of money and the risks specific to the asset. 

232

Santos Annual Report 2024 
 
 
3.4 Impairment of non-current assets (continued)

Significant judgement – Impairment of oil and gas assets

For oil and gas assets, the expected future cash flow estimation is based on a number of factors, variables and assumptions. 
For VIU calculations, the most important variables for future cash flows are estimates of hydrocarbon reserves and 
resources, future production profiles, commodity prices, operating costs, foreign exchange rates, and carbon price and 
abatement cost assumptions. Operating costs include third-party gas purchases and any future development costs 
necessary to produce the reserves and resources.

Under a FVLCD calculation, future cash flows are based on the variables noted above for VIU calculations plus other 
relevant factors, such as value attributable to additional resource and exploration opportunities beyond reserves based on 
production plans.

In most cases, the present value of future cash flows is most sensitive to estimates of hydrocarbon reserves and resources, 
future oil prices and discount rates.

Estimates of future commodity prices are based on the Group’s best estimate of future market prices with reference to 
external market analysts’ forecasts, current spot prices and forward curves. Future commodity prices are reviewed at least 
annually. Where volumes are contracted, future prices are based on the contracted price.

The nominal future Brent crude oil prices (US$/bbl) used in impairment calculations were:

31 December 2024

1 

Based on US$67.50/bbl (2024 real). 

2025

78.49

2026

74.76

2027
72.271

2028
73.861

2029+
75.481

Forecasts of the exchange rate for foreign currencies, where relevant, are estimated with reference to observable external 
market data and forward values, including analysis of broker and consensus estimates.

The future estimated long-term exchange rate applied in impairment calculations was A$/US$ 1:0.72.

The discount rates applied to the future forecast cash flows are based on the weighted average cost of capital, adjusted for 
risks where appropriate, including functional currency of the asset and risk profile of the countries in which the asset 
operates. The range of pre-tax discount rates that have been applied to non-current assets is typically between 11 per cent 
and 18 per cent. 

The Group has net-zero emission targets for both Scope 1 and Scope 2 equity emissions by 2040 and 2050, respectively. 
The Group’s CTAP includes current and proposed activities to give effect to the plan and deliver the Group’s emissions 
targets. Where relevant, the cost of the CTAP is taken into account in the carrying value of assets held. In addition, the 
Group includes a cost of carbon assumption in determining the carrying values of assets held as noted below. 

The nominal future carbon prices (US$/tonne CO2e) used in impairment calculations were:

31 December 2024

2025
30.091

2026 
35.821

2027
42.531

2028
50.491

2029
59.931

1 

 Long-term price (2025+) based on A$35.00/t (2024 real, US$25.20/t equivalent) increasing to the Commonwealth Government’s cost containment measure 
(CGCCM) price by 2030 (2024 real, US$60.81/t equivalent). From 2030 onwards, the price is aligned to the CGCCM.

Risks associated with climate change are factored into the recoverable amount calculation and will continue to be 
monitored. This includes the assessment of discount rates and the potential impact to future prices of commodities, such as 
oil and natural gas. This may, in turn, affect the recoverable amount of oil and gas assets and goodwill in the future, as may 
future demand and supply profiles. Management continues to review cost of capital, price assumptions and demand profile 
assumptions as the energy transition progresses.

In the event that future circumstances vary from these assumptions, the recoverable amount of the Group’s oil and gas 
assets could change materially and result in impairment losses or the reversal of previous impairment losses.

Due to the interrelated nature of the assumptions, movements in any one variable can have an indirect impact on others 
and individual variables rarely change in isolation. Additionally, management can be expected to respond to some 
movements to mitigate downsides and take advantage of upsides, as circumstances allow. Consequently, it is impracticable 
to estimate the indirect impact that a change in one assumption has on other variables and hence, on the likelihood, or 
extent, of impairments, or reversals of impairments, under different sets of assumptions in subsequent reporting periods. 

During the period, there were no changes to asset useful lives nor depletion or depreciation rates as a result of climate-
related risks. If changes are required in the future, these changes will be accounted for on a prospective basis in accordance 
with IFRS.

233

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.4 Impairment of non-current assets (continued)

Recoverable amount and resulting impairment write-downs recognised in the year ended 31 December 2024:

Impairment expense
Exploration and evaluation assets

  Oil and gas assets

Total impairment 

2024

Segment

  Oil and gas assets – producing

Barrow

Western Australia

Total impairment of oil and gas assets

Exploration and evaluation assets
South Nicholson 

Exploration

Yoorn

Exploration

Total impairment of exploration and  

evaluation assets

Total impairment

2023

Segment

  Oil and gas assets – producing

Barrow

Western Australia

Total impairment of oil and gas assets

Exploration and evaluation assets
Beanbush 

Exploration

Total impairment of exploration and  

evaluation assets

Total impairment

Recoverable amount calculated using the VIU method.

1 

2 

2024

2023

US$million

US$million

36

87

123

18

57

75

Subsurface 
assets 
US$million

Plant and 
equipment 
US$million

Goodwill 
US$million

Total 
US$million

Recoverable 
amount 
US$million

20

20

25

11

36

56

67

67

–

–

–

67

Nil1

Nil2
Nil2

–

–

–

–

–

–

87

87

25

11

36

123

Subsurface 
assets 
US$million

Plant and 
equipment 
US$million

Goodwill 
US$million

Total 
US$million

Recoverable 
amount 
US$million

–

–

18

18

18

57

57

–

–

57

Nil1

Nil2

–

–

–

–

–

57

57

18

18

75

 All exploration and evaluation asset amounts use the FVLCD method. Impairment of exploration and evaluation assets relates to certain individual licences/areas 
of interest that have been impaired to nil.

Oil and gas assets

The impairment of the Barrow CGU has arisen due to an increase in oil and gas asset carrying values, following 
remeasurement of restoration obligations. The recoverable amount of the asset is nil due to the late-life phase of the asset.

Exploration and evaluation assets

The impairment of exploration and evaluation assets has arisen as further work on these licences concluded they were not 
commercially viable.

234

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.5 Restoration obligations and other provisions 

Provisions recognised for the period are as follows:

Current 
Restoration obligations

Other provisions

Non-current
Restoration obligations

Other provisions

Restoration obligations

2024

2023

US$million

US$million

320

103

423

3,826

92

3,918

324

114

438

4,014

114

4,128

Provisions for future removal and environmental restoration costs are recognised where there is a present obligation as a 
result of exploration, development, production, transportation or storage activities having been undertaken, and it is 
probable that future outflow of economic benefits will be required to settle the obligation. The estimated future obligations 
include the costs of removing facilities, abandoning wells and restoring the affected areas, and is the best estimate of the 
present value of the future expenditure required to settle the restoration obligation at the reporting date, based on current 
legal requirements or observed industry analogs. 

Restoration provisions are updated regularly, with changes in the estimate reflected in the present value of the restoration 
provision at the reporting date, with a corresponding change in the cost of the associated asset. In the event the restoration 
provision is reduced, the cost of the related oil and gas asset is reduced by an amount not exceeding its carrying value. If 
the decrease in restoration provision exceeds the carrying amount of the asset, the excess is recognised immediately in the 
income statement. The amount of the provision for future restoration costs relating to exploration, development and 
production facilities is capitalised and depleted as a component of the cost of those activities.

The timing of restoration activities and the requirements to decommission assets may change, thereby impacting the 
present value of associated decommissioning provisions. In addition, cost estimates may change in the future, including as a 
result of the energy transition.

Risks associated with climate change are factored into forecast timing of restoration activities and will continue to be 
monitored. 

Significant judgement – Provision for restoration

The Group estimates the future removal and restoration costs of oil and gas production facilities, wells, pipelines and related 
assets at the time of installation of the assets, and reviews these assessments periodically. In most instances, the removal of 
these assets will occur many years in the future. The estimate of future removal costs therefore requires management to 
make judgements utilising current knowledge and information regarding the removal date, future environmental legislation 
and regulations, the extent of restoration activities required, the engineering methodology for estimating costs, and 
discount rates to determine the present value of future cash flows. 

The Group’s restoration estimates are based on compliance with regulations in the respective jurisdictions in which it 
operates. 

The Group's provision includes the following costs: 

•  For onshore assets, provision has been made for the permanent decommissioning of all wells and the full removal of 

production facilities and pipelines.

•  For offshore assets, provision has been made for:

 – permanent decommissioning of all wells

 –

 –

removal of infrastructure, including but not limited to, platforms and vessels

 removal of subsea infrastructure, except some major pipelines as set out below.

235

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Notes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.5 Restoration obligations and other provisions (continued) 

The Group’s estimated future removal and restoration costs may include certain major pipelines remaining in-situ, where the 
Group believes it will result in better environmental and safety outcomes than full removal, and that will be satisfactory to 
the relevant regulator and the regulator’s compliance obligations. In the event that all major pipelines currently assumed to 
be restored in-situ are required to be removed, the Group estimates the additional cost would result in an increase to the 
provision of approximately $450-$650 million. 

The Group’s restoration provisions reflect estimates based on current knowledge and information, with further assessment 
and analysis of restoration activities to be performed towards the end of an asset’s operational life and/or when 
decommissioning plans are required by the relevant regulator. The basis of future restoration decommissioning plans or 
directions issued by the regulator can differ from the restoration assumptions disclosed above. Actual costs and cash 
outflows can materially differ from the current estimates included in the provision recognised as at 31 December 2024 as a 
result of changes in regulations and their application, prices, analysis of site conditions, future studies, timing of restoration, 
and changes in removal technology. 

In addition, the Group is progressing its three hub CCS strategy. This strategy incorporates the utilisation of some elements 
of existing infrastructure, potentially extending the life of these assets. Extending the life of these assets will likely defer 
certain decommissioning activities and could reduce the decommissioning provision accordingly. 

The Group has recorded provisions for restoration obligations as follows:

Current provision

Non-current provision

Movements in the provision during the financial year are set out below:

Balance at 1 January 

Provisions made and changes to assumptions during the year

Provisions used during the year

Liabilities transferred from held for sale

Disposal of subsidiary

Unwind of discount 

Change in discount rate

Inflation change

Balance at 31 December

Other provisions

2024

2023

US$million

US$million

320

3,826

4,146

324

4,014

4,338

Total 
restoration

US$million

4,338

195

(319)

16

(16)

175

(190)

(53)

4,146

In addition to the provision for restoration shown above, other items for which a provision has been recorded are:

Current 
Employee benefits

Remediation provision

Liability for carbon costs

Other provisions

Non-current
Employee benefits

Remediation provision

Other provisions

236

2024

2023

Note

US$million

US$million

7.1

7.1

88

2

13

–

103

17

4

71

92

105

2

–

7

114

14

5

95

114

Santos Annual Report 2024 
3.6 Leases

The Group as a lessee

Recognition of lease liabilities and right-of-use assets

As a lessee, the Group will recognise a right-of-use asset, representing its right to use the underlying asset, and a lease 
liability, for all leases with a term of more than 12 months, exempting those leases where the underlying asset is deemed  
to be of a low-value.

The Group recognises a right-of-use asset and a lease liability at the lease commencement date, i.e. when the underlying 
asset is first available for use. The right-of-use asset is initially measured to be equal to the lease liability and adjusted for 
any lease incentives received, initial direct costs, and estimates of costs to dismantle or remove the underlying leased asset. 
Subsequently, the right-of-use asset is measured at cost less any accumulated depreciation and impairment losses, and 
adjusted for certain remeasurements of the lease liability.

The lease liability is initially measured at the present value of the lease payments that are not paid at the commencement 
date, discounted using the interest rate implicit in the lease or, if that rate cannot be readily determined, the Group’s 
incremental borrowing rate, adjusted for asset-specific factors.

The lease liability is subsequently increased by the interest cost on the lease liability and decreased by lease payments 
made. It is remeasured when there is a change in future lease payments arising from a change in an index or rate, a change 
in the estimate of the amount expected to be payable under a residual value guarantee or, as appropriate, changes in the 
assessment of whether purchase, renewal or termination options are reasonably certain to be exercised.

The Group has applied judgement to determine the lease term for some contracts in which Santos is a lessee that include 
purchase, renewal or termination options. The assessment of whether the Group is reasonably certain to exercise such 
options impacts the lease term, which affects the value of lease liabilities and right-of-use assets recognised.

Modifications to lease arrangements

In the event that there is a modification to a lease arrangement, a determination of whether the modification results in a 
separate lease arrangement being recognised needs to be made. Where the modification does result in a separate lease 
arrangement needing to be recognised, due to an increase in scope of a lease through additional underlying leased assets 
and a commensurate increase in lease payments, the measurement requirements as described above need to be applied.

Where the modification does not result in a separate lease arrangement, from the effective date of the modification, the 
Group will remeasure the lease liability using the redetermined lease term, lease payments and applicable discount rate.  
A corresponding adjustment will be made to the carrying amount of the associated right-of-use asset. Additionally, where 
there has been a partial or full termination of a lease, the Group will recognise any resulting gain or loss in the income 
statement.

Lease impact on joint operating arrangements

Where lease arrangements impact the Group’s joint operating arrangements (JOA), the facts and circumstances of each 
lease arrangement in a JOA are assessed to determine the Group’s rights and obligations associated with the lease 
arrangement. 

The Group applies judgement in its determination of which party directs the use of a leased asset. Outlined below are a 
number of scenarios that could exist for lease arrangements which impact the Group’s JOAs:

1) 

 Where it has been determined that the Group directs the use of the leased asset, and is the only party with legal 
obligation to pay the lessor, the Group will recognise the full lease liability and right-of-use asset on its statement of 
financial position. Depreciation is then recognised on the entire right-of-use asset, however, other income would be 
recognised for any amount of the lease payments that are recoverable from other parties, representing other income 
associated with lease arrangements.

2)   If it has been determined that the leased asset is either jointly controlled by all parties in a joint operation, or is utilised 
by a single joint operation, and the Group is the only party with a legal obligation to pay the lessor, the Group will 
recognise the full lease liability, its net share of the right-of-use asset, and a receivable for the amounts recoverable from 
other parties.

3)   In instances where it has been determined that all parties to the joint arrangement have the right to control the leased 
asset jointly and all parties have a legal obligation to make lease payments to the lessor, the Group will recognise only 
its net share of the lease liability and right-of-use asset on its Consolidated Statement of Financial Position.

237

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.6 Leases (continued)

The Group’s leasing activities

The Group leases a number of different types of assets, including properties and plant and production equipment, such as 
production rigs. The lease arrangements have varying renewal and termination options. Lease terms for major categories of 
leased assets are shown below: 

•  Production rigs 

•  Marine vessels, including LNG tankers 

•  Helicopters 

•  Building office space 

1–5 years

1–30 years

1–10 years

10–20 years

•  Other plant and production equipment 

2–20 years

The Group presents the following in relation to AASB 16 Leases, within its Consolidated Statement of Financial Position:

• 

‘Other land, buildings, plant and equipment’ or ‘Oil and gas assets’ – right-of-use assets are presented in either 
depending on the type of leased asset;

• 

‘Lease liabilities’ – lease liabilities.

Set out below are the carrying amounts of right-of-use assets recognised and their movements during the period: 

US$million
Balance at 1 January

Additions

Remeasurements of lease    

arrangements

Depreciation

Transfer of assets from held for sale

Derecognition of lease  

arrangements

Balance at 31 December

2024

Other land, 
buildings, 
plant and 
equipment

Oil and gas 
assets

554

186

(20)

(202)

22

(18)

522

150

97

(3)

(17)

–

–

227

2023

Other land, 
buildings, 
plant and 
equipment

Oil and gas 
assets

600

107

–

(197)

44

–

554

170

–

–

(20)

–

–

150

Total

704

283

(23)

(219)

22

(18)

749

Total

770

107

–

(217)

44

–

704

During the period, $94 million of depreciation on right-of-use assets has been capitalised and forms a component of 
additions to oil and gas assets. This capitalisation results in a difference between the amount of depreciation expense 
recorded during the period and the movement in accumulated depreciation. 

Set out below are the carrying amounts of lease liabilities and the movements during the period: 

Lease liabilities
Balance at 1 January

Additions

Remeasurements of lease arrangements

Accretion of interest

Payments

Foreign exchange gain on lease liabilities

Transfer of liabilities from held for sale

Derecognition of lease arrangements

Balance at 31 December

238

2024

2023

US$million

US$million

785

344

(34)

45

(299)

(20)

24

(24)

821

846

151

(5)

42

(278)

–

29

–

785

Santos Annual Report 2024 
 
 
3.6 Leases (continued)

Current lease liabilities

Non-current lease liabilities

2024

2023

US$million

US$million

200

621

821

189

596

785

Short-term and low-value lease asset exemptions

The Group had total cash outflows for leases of $793 million in 2024 (2023: $563 million), including outflows for short-term 
leases, leases of low-value assets, and variable lease payments. 

For the 12-month period ended 31 December, the following payments have been made for lease arrangements that have 
been classified as short-term or for low-value assets:

Short-term leases

Leases for low-value assets

Total payments made 

Variable lease payments

2024 
US$million

2023 
US$million

202

63

265

48

38

86

The Group holds lease contracts which contain variable payments based on the usage profile of the leased asset. The type 
and quantum of activities undertaken utilising these assets (primarily rigs) is entirely at the Group’s discretion in response 
to operational requirements.

The lease liability and corresponding right-of-use asset for these lease contracts is calculated based on the fixed rental 
payment components of the contracts. The table below indicates the relative magnitude of variable payments to fixed 
payments made during the year ended 31 December, for those lease contracts which contain a variable payment 
component.

Fixed payments (included in calculation of lease liability)

Variable payments 

Total payments made for leases with a variable payment component

2024 
US$million

2023 
US$million

299

229

528

278

199

477

Other income associated with lease arrangements

Where it has been determined that the Group directs the use of the leased asset and is the only party with legal obligation 
to pay the lessor, the Group recognises other income for any amount of the lease payments that are recoverable from other 
parties, representing ‘Other income associated with lease arrangements’ in the income statement. For the year ending  
31 December 2024, the amount recognised was $65 million (2023: $58 million). 

239

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
Notes to the Consolidated Financial Statements
Section 3: Capital expenditure, operating assets  
and restoration obligations

3.7 Commitments for expenditure

The Group has certain obligations to perform minimum exploration work and expend minimum amounts of money pursuant 
to the terms of the granting of petroleum exploration permits in order to maintain rights of tenure.

These commitments may be varied as a result of renegotiations of the terms of the exploration permits, licences or 
contracts, or alternatively upon their relinquishment. The minimum exploration commitments are less than the normal level 
of exploration expenditures expected to be undertaken by the Group.

The Group has the following commitments for expenditure for which no liabilities have been recorded in the financial 
statements as the goods or services have not been received, including commitments for non-cancellable lease 
arrangements where the lease term has not commenced:

Capital

Minimum exploration

Leases

2023

2024
US$million US$million
161

1,012

2023

2024
US$million US$million
161

128

512

–

1,524

197

–

358

644

11

783

408

1,246

1,815

2023

US$million

200

439

1,336

1,975

Commitments
Not later than one year

Later than one year but not later  

than five years

Later than five years

2024

US$million

470

14

39

523

240

Santos Annual Report 2024 
 
Notes to the Consolidated Financial Statements
Section 4: Working capital management

This section provides information about the Group’s working capital balances and management, including cash flow 
information. Cash flow management is a significant consideration in running our business in an efficient and resourceful 
manner. We also consider inventories which contribute to the business platform for generating profits and revenues.

4.1 Cash and cash equivalents

Cash and cash equivalents comprise cash balances and short-term deposits that are readily convertible to cash, are subject 
to an insignificant risk of changes in value, and generally have an original maturity of three months or less. The carrying 
amounts of cash and cash equivalents represent fair value. Bank balances and short-term deposits earn interest at floating 
rates based upon market rates.

Cash at bank and in hand

(a) Restricted cash balances

2024

2023

US$million

US$million

1,833

1,833

1,875

1,875

 As at 31 December 2024, total Group restricted cash was $546 million (2023: $596 million, including $36 million 
disclosed as held for sale (refer to Note 6.4)). The restricted cash relates to cash flows from the PNG LNG project,  
which are required to be held in restricted bank accounts.

(b) Reconciliation of cash flows from operating activities

  Net profit after income tax
  Add/(deduct) non-cash items:

  Depreciation and depletion

Exploration and evaluation expensed – unsuccessful wells/seismic

  Costs associated with acquisitions/disposals

Impairment loss

  Net loss on fair value derivatives 

Share-based payment expense

  Changes in restoration provision

  Unwind of the effect of discounting on provisions

  Gain on sale of non-current assets

Share of net profit of associates

2024

2023

US$million

US$million

1,264

 1,679 

 13 

–

123

–

36

 (83)

 190 

 (13) 

 (2)

1,416

1,858

8

(41)

75

16

25

18

175

(5)

(5)

  Net cash provided by operating activities before changes in assets or liabilities
  Add/(deduct) change in operating assets or liabilities, net of acquisitions or disposals  

3,207 

3,540

of businesses:

  Decrease/(increase) in trade and other receivables

  Decrease in inventories

  Decrease in other assets

(Decrease)/increase in net deferred tax liabilities

Increase/(decrease) in net current tax liabilities

  Decrease in trade and other payables

  Decrease in provisions

  Net cash provided by operating activities

100 

14 

17 

(68)

5

(72)

(353)

2,850

(61)

1

17

9

(65)

(38)

(145)

3,258

241

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 4: Working capital management

4.1 Cash and cash equivalents (continued) 

(c) Reconciliation of liabilities arising from financing activities to financing cash flows 

US$million
Balance at 1 January 2023
Financing cash flows1
Operating cash flows

Non-cash changes:

Reclassification to current liability

  Additions to lease liabilities

  Other

Transfer of liabilities from held for sale

Balance at 31 December 2023
Balance at 1 January 2024
Financing cash flows1
Operating cash flows

Non-cash changes:

Reclassification to current liability

Transfer from assets held for sale

  Disposal of subsidiaries

  Additions to lease liabilities

  Other 

Balance at 31 December 2024

Short-term 
borrowings
694

Long-term 
borrowings
3,979

(787)

–

689

–

1

49

646

646

(667) 

–

708

42

(43)

–

1

687

1,292

–

(689)

–

3

143

4,728

4,728

1,135 

–

(708)

68

(46)

– 

3

5,180

Lease 
liabilities
846

(236)

(42)

–

151

37

29

785

785

(254)

(45)

–

24

(24)

344

(9)

821

Total 
5,519

269

(42)

–

151

41

221

6,159

6,159

214

(45)

–

134

(113)

344

(5)

6,688

1 

 Financing cash flows consist of the net amount of proceeds from borrowings, repayments of borrowings and repayment of lease liabilities in the statement of 
cash flows. 

4.2 Trade and other receivables

Trade receivables are initially recognised at the transaction price, as described in Note 2.2, and other receivables are initially 
recognised at fair value, which in practice is the equivalent of the transaction price, and subsequently measured at cost, less 
any impairment losses.

Long-term receivables are initially recognised at fair value and are subsequently stated at amortised cost, less any 
impairment losses.

Trade receivables are non-interest bearing and settlement terms are generally within 30 days.

Trade receivables

Other receivables

2024

2023

US$million

US$million

363

366

729

473

356

829

Due to the nature of the Group’s receivables, their carrying amount is considered to approximate their fair value. 

The Group applies the simplified approach to providing for expected credit losses for all trade receivables as set out in  
Note 5.5(e). 

242

Santos Annual Report 2024 
 
 
 
4.3 Inventories

Inventories are stated at the lower of cost and net realisable value. Net realisable value is the estimated selling price in the 
ordinary course of business, less the estimated costs of completion and selling expenses. Cost is determined as follows:

•  Drilling and maintenance stocks, which include plant spares, consumables and maintenance and drilling tools used 

for ongoing operations, are valued at weighted average cost.

•  Petroleum products, which comprise extracted crude oil, liquefied natural gas, liquefied petroleum gas, condensate 

and naphtha stored in tanks and pipeline systems and processed sales gas and ethane stored in subsurface 
reservoirs, are valued using the absorption cost method.

Petroleum products 

Drilling and maintenance stocks 

Inventories included above that are stated at net realisable value

2024

2023

US$million

US$million

140

288

428

25

165

277

442

19

4.4 Trade and other payables

Trade and other payables are recognised when the related goods or services are received at the amount of cash or cash 
equivalents that will be required to discharge the obligation, gross of any settlement discount offered. Trade payables are 
non-interest bearing and are settled on normal terms and conditions.

Trade payables 

Non-trade payables

2024

2023

US$million

US$million

459

510

969

567

513

1,080

The carrying amounts of trade and other payables are considered to approximate their fair values, due to their short-term 
nature. 

243

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 5: Funding and risk management

Our business has exposure to capital, credit, liquidity and market risks. This section provides information relating to our 
management of, as well as our policies for, measuring and managing these risks. 

Capital risk management objectives

The Group’s objectives when managing capital are to safeguard its ability to continue as a going concern, allowing returns 
to shareholders and benefits for other stakeholders to be maintained, and to retain an efficient capital structure. In order to 
optimise the capital structure, the Group may adjust its dividend distribution policy, return capital to shareholders, issue 
new shares, draw or repay debt, or undertake other corporate initiatives consistent with its strategic objectives. 

In applying these objectives, the Group aims to:

•  minimise the weighted average cost of capital while retaining appropriate financial flexibility

•  ensure ongoing access to a range of debt and equity markets

•  maintain an investment-grade credit rating. 

A range of financial metrics are used to monitor the capital structure, including ratios measuring gearing, funds from 
operations to debt (FFO to Net Debt), interest coverage (EBITDA/net interest expense) and Net Debt to earnings before 
interest, tax, depreciation and amortisation (Net Debt to EBITDA). The Group monitors these capital structure metrics on 
both an actual and forecast basis. 

At 31 December 2024, Santos Limited’s corporate credit rating was BBB- (stable outlook) from Standard & Poor’s, BBB 
(stable outlook) from Fitch, and Baa3 (stable outlook) from Moody’s.

5.1 Interest-bearing loans and borrowings

Interest-bearing loans and borrowings are recognised initially at fair value, net of transaction costs incurred. Subsequent to 
initial recognition, interest-bearing loans and borrowings are stated at amortised cost with any difference between cost and 
redemption value being recognised in the income statement over the period of the borrowings on an effective interest 
basis. The carrying values of the Group’s interest-bearing loans and borrowings are shown below. 

Fixed-rate notes that are hedged by interest rate swaps are recognised at fair value.

All borrowings are unsecured, with the exception of the secured bank loans and lease liabilities. 

All interest-bearing loans and borrowings, with the exception of secured bank loans and lease liabilities, are borrowed 
through Santos Finance Ltd, which is a wholly-owned subsidiary of Santos Limited. All interest-bearing loans and 
borrowings by Santos Finance Ltd are guaranteed by Santos Limited. Refer to Note 3.6 for disclosures related to leases.

2024

2023

Ref 

US$million

US$million

(a)

(a)

(b)

(c)

687

687

363

1,585

3,232

5,180

646

646

1,050

450

3,228

4,728

Current
Bank loans – secured 

Non-current
Bank loans – secured

Bank loans – unsecured

Long-term notes

244

Santos Annual Report 20245.1 Interest-bearing loans and borrowings (continued)

The Group’s weighted average interest rate on interest-bearing liabilities was 6.57 per cent for the year ended 31 December 
2024 (2023: 6.66 per cent).

(a) Bank loans – secured

Facility 

Currency

Limit

Drawn principal

Accounting balance

PNG LNG
US dollars

$1,050 million (2023: $1,806 million)

$1,050 million (2023: $1,806 million) 

$1,050 million (2023: $1,696 million) including prepaid amounts

Accounting balances do not include liabilities reclassified to held for sale; (2023: $110 million) (refer to Note 6.4).

Effective interest rate

8.99% (2023: 9.15%)

Maturity

Other

2026

Loan facilities for the PNG LNG project, in which Santos entities hold an equity 
interest of 39.9 per cent (2023: 42.5 per cent), were entered into by the joint 
venture participants, through the entity Papua New Guinea Liquified Natural Gas 
Global Company LDC (the Borrower) and are provided by commercial banks and 
export credit agencies, bear fixed and floating rates of interest, and have final 
maturity dates of June 2026. During 2024, the Group completed the sale of a  
2.6 per cent interest in PNG LNG project to Kumul (refer to Note 6.2). 

Assets pledged as security and restricted cash

The PNG LNG facilities include security over assets and entitlements of the 
participants in respect of the project. The total carrying value of the Group’s assets 
pledged as security is $8,083 million at 31 December 2024 (2023: $8,992 million).

As referred to in Note 4.1(a), under the terms of the project financing, cash relating 
to the Group’s interest in undistributed project cash flows is required to be held in 
restricted bank accounts. 

The liquids and LNG sales proceeds from the PNG LNG project are received into a 
sales escrow account from which agreed expenditure obligations and debt 
servicing are first made and, subject to meeting certain debt service cover ratio 
tests, surpluses are distributed to the project participants. 

Each borrower granted to the security trustee for the PNG LNG facilities has: 

 – a first-ranking security interest in all of its assets, with a few limited exceptions

 –  a fixed and floating charge over existing and future funds in the offshore 

accounts; a deed of charge (and assignment) over the sales contracts, LNG 
charter party agreements, rights under insurance policies, LNG supply and sales 
commitment agreements, on-loan agreements and the sales, shipping and 
finance administration agreements, collectively known as Borrower Material 
Agreements 

– a mortgage of contractual rights over Borrower Material Agreements. 

The Santos participants have granted the security trustee for the Project Finance 
Debt Facility a security interest in all their rights, titles, interests in and to all of their 
assets, excluding any non-PNG LNG project assets. The Company, as the 
shareholder in the Santos Participants, has provided the security trustee for the 
PNG LNG facilities a share mortgage over its shares in the Santos Participants.

The PNG LNG facilities are subject to various covenants and a negative pledge 
restricting further secured borrowings, subject to a number of permitted lien 
exceptions. Neither the covenants nor negative pledge have been breached at any 
time during the reporting period.

245

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.1 Interest-bearing loans and borrowings (continued)

(b) Bank loans – unsecured

Facility 

Currency

Limit

Drawn principal

Accounting balance

Effective interest rate

Maturity

Other

(c) Long-term notes

Facility 

Currency

Limit

Drawn principal

Accounting balance

Effective interest rate

Maturity

Other

Facility 

Currency

Limit

Drawn principal

Accounting balance

Effective interest rate

Maturity

Other

Syndicated and bilateral bank loans
US dollars

$4,165 million (2023: $3,065 million)

$1,585 million (2023: $450 million)

$1,585 million (2023: $450 million) 

6.21% (2023: 6.99%)

Various – 2025 to 2030 (2028 to 2030 for drawn principal)

The syndicated and bilateral bank loans bear a floating interest rate.

Regulation S bonds
US dollars

$1,400 million (2023: $1,400 million)

$1,400 million (2023: $1,400 million)

$1,394 million (2023: $1,389 million) including prepaid amounts

4.74% (2023: 4.74%)

2027 and 2029

Both bonds bear fixed interest rates.

Rule 144A/Regulation S bonds
US dollars

$1,850 million (2023: $1,850 million)

$1,850 million (2023: $1,850 million)

$1,838 million (2023: $1,839 million)

5.20% (2023: 5.20%)

2031 and 2033

The bonds are unsecured and bear a fixed interest rate.

246

Santos Annual Report 20245.2 Net finance costs

Borrowing costs

Borrowing costs relating to major qualifying oil and gas assets under development are capitalised as a component of the 
cost of development. Where funds are borrowed specifically for qualifying projects, the actual borrowing costs incurred are 
capitalised. Where the projects are funded through general borrowings, the borrowing costs are capitalised based on the 
weighted average cost of borrowing. Borrowing costs incurred after commencement of commercial operations are 
expensed to the income statement.

All other borrowing costs are recognised in the income statement using the effective interest method.

Interest income

Interest income is recognised in the income statement as it accrues using the effective interest method. 

Finance income

Interest income

Total finance income

Finance costs

Interest expense

Interest on lease liabilities

  Deduct borrowing costs capitalised

  Unwind of the effect of discounting on contract liabilities – deferred revenue

  Unwind of the effect of discounting on provisions

Total finance costs

Net finance costs

5.3 Issued capital

Ordinary share capital

2024

2023

US$million

US$million

122

122

400

45

(344)

101

15

175

291

169

106

106

359

42

(243)

158

17

158

333

227

Ordinary share capital is classified as equity. The issued shares do not have a par value and there is no limit on the 
authorised share capital of the Company. 

Fully paid ordinary shares carry one vote per share, which entitles the holder to participate in dividends and the proceeds 
on winding up of the Company in proportion to the number of, and amounts paid on, the shares held. The market price of 
the Company’s ordinary shares on 31 December 2024 was A$6.68 (2023: A$7.60).

Transaction costs

Transaction costs of an equity transaction are accounted for as a deduction from equity, net of any related income tax 
benefit. During 2024, no transaction costs in respect of capital raisings were deducted from equity (2023: $Nil).

Movement in ordinary shares
Balance at 1 January

On-market share purchase (Treasury shares)

On-market share purchase (Share buy-back)

Utilisation of Treasury shares on vesting of employee  

share schemes

Treasury shares cancelled pursuant to on-market  

buy-backs

Balance at 31 December

2024  
Number of 
shares

2023 
Number of 
shares

2024 
US$million

2023 
US$million

3,247,772,961

3,313,298,877

14,339

–

–

–

–

3,247,772,961

–

–

–

(65,525,916)
3,247,772,961

(15)

–

21

–

14,345

14,652

(22)

(316)

25

–
14,339

Included within the Group’s ordinary shares at 31 December 2024 are 10,000 (2023: 10,000) ordinary shares paid to one 
cent with a value of Nil (2023: Nil).

247

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.3 Issued capital (continued)

Treasury shares 

Treasury shares are purchased as part of the capital management framework and for use on vesting of employee share 
schemes. Shares are accounted for at weighted average cost. No shares were cancelled during 2024 (2023: 65,525,916 
shares were purchased on-market and cancelled as part of the capital management framework. The total amount of shares 
acquired for this purpose was $316 million).

In addition, $15 million (2023: $22 million) of Treasury shares were purchased on-market for employee share arrangements. 

Movement in Treasury shares
Balance at 1 January
Shares purchased on-market 
Treasury shares cancelled pursuant to on-market buy-backs
Treasury shares utilised:

Santos Employee Share1000 Plan
Santos Employee ShareMatch Plan

  Utilised on vesting of SARs

Executive STI (deferred shares)
Executive LTI (ordinary shares)
Santos Employee Share1000 Plan (relinquished shares)

  Dividend equalisation shares

Balance at 31 December

5.4 Reserves and accumulated profit

Note

7.2
7.2

7.2
7.2

2024  
Number of 
shares

8,582,553

3,000,000

–

2023  
Number of 
shares

9,217,171
70,025,909
(65,525,916)

(168,810)

(761,387)

(1,545,181)

(540,195)

(1,014,885)

35,415

–

7,587,510

(147,975)
(569,966)
(1,768,849)
(502,979)
(2,108,265)
3,362
(39,939)
8,582,553

The balance of the Group’s reserves and accumulated profit, and movements during the period, are disclosed in the 
Statement of Changes in Equity.

Foreign currency translation reserve

The foreign currency translation reserve is used to record foreign exchange differences arising from the translation of the 
financial statements of foreign entities from their functional currency to the Group’s presentation currency.

Santos Limited and the majority of its wholly-owned subsidiaries within the Group have a functional currency of US$, the 
same currency as the presentation currency of the Group. For non-US$ functional currency entities (foreign operations), 
foreign exchange differences resulting from translation to presentation currency are recognised in the foreign currency 
translation reserve, and subsequently transferred to the income statement on disposal of the operation. The difference in 
foreign exchange rates, at 31 December 2023 to 31 December 2024, resulted in the Group recognising a foreign currency 
loss in the translation reserve of $25 million for non-US$ functional currency companies. 

Hedging reserve

The hedging reserve comprises the cash flow hedge reserve and the own credit risk revaluation reserve. The cash flow 
hedge reserve comprises the effective portion of the cumulative net change in the fair value of cash flow hedging 
instruments related to hedged transactions that have not yet occurred.

The own credit risk revaluation reserve comprises the cumulative changes in the fair value of the financial liabilities 
designated at fair value through profit or loss attributable to changes in the Group’s own credit risk. Refer to Note 5.5(g) for 
a reconciliation and movement of cash flow hedge reserve and own credit risk revaluation reserve.

Accumulated profits reserve 

The accumulated profits reserve acts to quarantine profits generated in current and prior periods. The reserve was 
established during 2015.

Accumulated profit 

Accumulated profit represents the cumulative net profit that has been generated across the Group.

248

Santos Annual Report 2024 
 
 
 
 
5.5 Financial risk management

Exposure to foreign currency risk, interest rate risk, commodity price risk, credit risk and liquidity risk arises in the normal 
course of the Group’s business. The Group’s overall financial risk management strategy is to ensure that the Group is able to 
fund its corporate objectives and meet its obligations to stakeholders. Derivative financial instruments may be used to 
hedge exposure to fluctuations in foreign exchange rates, interest rates and commodity prices.

The Group uses various methods to measure the types of financial risk to which it is exposed. These methods include 
sensitivity analysis in the case of foreign exchange, interest rate and commodity price risk, and ageing and credit rating 
concentration analysis for credit risk.

Financial risk management is carried out by a central treasury department (Treasury) which operates under Board-
approved policies. The policies govern the framework and principles for overall risk management and cover specific 
financial risks, such as foreign exchange risk, interest rate risk, commodity price risk and credit risk, approved derivative and 
non-derivative financial instruments, and liquidity management.

(a) Financial instruments

 The Group classifies its financial instruments in the following categories: financial assets at amortised cost, financial 
assets at fair value through profit or loss (FVTPL), financial assets at fair value through other comprehensive income 
(FVOCI), financial liabilities at amortised cost, financial liabilities at FVTPL, and derivative instruments. The classification 
depends on the purpose for which the financial instruments were acquired, which is determined at initial recognition 
based upon the business model of the Group.

Financial assets at amortised cost

 The Group classifies its financial assets at amortised cost if the asset is held with the objective of collecting contractual 
cash flows and the contractual terms give rise on specified dates to cash flows that are solely payments of principal and 
interest. These include trade receivables and bank term deposits. They are financial assets at amortised cost and are 
included in current assets, except for those with maturities greater than 12 months after the reporting date.

Financial assets at fair value through profit or loss 

 The Group classifies its financial assets at fair value through profit or loss if they are acquired principally for the purpose 
of selling in the short term, i.e. are held for trading. The Group has not elected to designate any financial assets at fair 
value through profit or loss. 

Financial assets at fair value through other comprehensive income

 Financial assets at fair value through other comprehensive income comprise debt securities where the contractual cash 
flows are solely principal and interest, and the objective of the Group’s business model is achieved both by collecting 
contractual cash flows and selling financial assets. Upon disposal, any balance within the other comprehensive income 
(OCI) reserve for these debt investments is reclassified to accumulated profits. 

Financial liabilities 

 On initial recognition, the Group measures a financial liability at its fair value minus, in the case of a financial liability not 
at fair value through profit or loss, transaction costs that are directly attributable to the issue of the financial liability.

 After initial recognition, trade payables and interest-bearing loans and borrowings are stated at amortised cost. 
Fixed-rate notes that are hedged by an interest rate swap are recognised at fair value. For financial liabilities classified as 
fair value through profit or loss, the element of gains or losses attributable to changes in the Group’s own credit risk are 
recognised in other comprehensive income.

Policies for the recognition and subsequent measure of derivative liabilities are as outlined below. 

  Derivative instruments 

 Derivative financial instruments are entered into by the Group for the purpose of managing its exposures to changes in 
foreign exchange rates, commodity prices and interest rates arising in the normal course of business and have been 
designated as part of cash flow and fair value hedge relationships. The principal derivatives that may be used are 
forward foreign exchange contracts and interest rate swaps. Electricity derivatives are also used to manage the Group’s 
exposure to changes in electricity prices. The use of derivative financial instruments is subject to a set of policies, 
procedures and limits approved by the Board of Directors. The Group does not trade in derivative financial instruments 
for speculative purposes. 

249

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.5 Financial risk management (continued)

(a) Financial instruments (continued)

The Group holds the following financial instruments:

Financial assets

Financial assets at amortised cost
  Cash and cash equivalents

Trade and other receivables

  Other

Financial assets at FVTPL
  Derivative financial instruments 

1 

Balances include held for sale assets. 

Financial liabilities

Financial liabilities at amortised cost

Trade and other payables

Borrowings at amortised cost

Lease liabilities

  Other

Financial liabilities at FVTPL
  Derivative financial instruments

1 

Balances include held for sale liabilities. 

2024

US$million

20231
US$million

1,833

729

87

5

2,654

1,911

842

398

133

3,284

2024

US$million

20231
US$million

969

5,867

821

23

41

7,721

1,091

5,484

809

295

–

7,679

The Group’s financial instruments resulted in the following income, expenses, gains and losses recognised in the income 
statement: 

Interest on cash investments

Interest on debt held at FVTPL

Interest on debt held at amortised cost

Interest on derivative financial instruments

Interest accretion on lease liabilities

Fair value gains on debt held at FVTPL

Fair value gains on derivative financial instruments

Net foreign exchange gains/(losses)

2024

2023

US$million

US$million

122

–

(57)

–

(45)

–

19

8

47

106

–

(116)

–

(42)

–

–

(15)

(67)

(b) Liquidity

The Group adopts a prudent liquidity risk management strategy and seeks to maintain sufficient liquid assets and available 
committed credit facilities to meet short-term to medium-term liquidity requirements. The Group’s objective is to maintain 
flexibility in funding to meet ongoing operational requirements, exploration and development expenditure, and other 
corporate initiatives.

The following tables analyse the contractual maturities of the Group’s financial assets and liabilities held to manage  
liquidity risk. The relevant maturity groupings are based on the remaining period to the contractual maturity date,  
as at 31 December. The amounts disclosed in the table are the contractual undiscounted cash flows comprising principal 
and interest repayments. Estimated variable interest expense is based upon appropriate yield curves as at 31 December. 

250

Santos Annual Report 2024 
 
 
 
 
5.5 Financial risk management (continued)

(b) Liquidity (continued)

Financial assets and liabilities held to  
manage liquidity risk

2024
Cash and cash equivalents

Derivative financial assets
Other derivatives

Non-derivative financial liabilities
Trade and other payables

Lease liabilities

Bank loans

Long-term notes 

Derivative financial liabilities
Other derivatives

Financial assets and liabilities held to  
manage liquidity risk1
2023
Cash and cash equivalents

Derivative financial assets
Other derivatives

Non-derivative financial liabilities
Trade and other payables

Lease liabilities

Bank loans

Long-term notes 

1 

Balances include held for sale assets and liabilities.

(c) Foreign currency risk

Less than 
1 year

1 to 2 
years

2 to 5 
years

More than 
5 years

US$million

US$million

US$million 

US$million

1,833

5

(969)

(203)

(825)

(159)

(41)

(359)

Less than 
1 year

US$million
1,911

133

(1,091)

(187)

(838)

(159)

(231)

–

–

–

–

–

–

(254)

(1,323)

(1,777)

(534)

(442)

(2,116)

–

–

(3,354)

(3,092)

–

–

–

(126)

(470)

(159)

–

(755)

1 to 2 
years

2 to 5 
years

US$million
–

US$million 
–

–

–

(131)

(818)

(159)

(1,108)

–

–

(251)

(857)

(1,236)

(2,344)

More than 
5 years

US$million
–

–

–

(488)

–

(2,817)

(3,305)

 Foreign exchange risk arises from commercial transactions and valuations of assets and liabilities that are denominated 
in a currency that is not the entity’s functional currency. 

 The Group is exposed to foreign currency risk principally through the sale of products, borrowings and capital and 
operating expenditure incurred in currencies (mostly Australian dollars) other than the functional currency. In order to 
hedge foreign currency risk, the Group may enter into forward foreign exchange, foreign currency swap and foreign 
currency option contracts. 

 The Group has certain investments in domestic and foreign operations whose net assets are exposed to foreign 
currency translation risk. 

  All external borrowings of the Group are denominated in US$.

 The Group has lease liabilities and other monetary items, including financial assets and liabilities, denominated in 
currencies other than the functional currency of an operation. These items are restated to US$ equivalents at each 
period end, and the associated gain or loss is taken to the income statement. The exception is foreign exchange gains  
or losses on foreign currency provisions for restoration at operating sites that are capitalised in oil and gas assets.

 At 31 December 2024, the Group had open forward foreign exchange contracts to buy A$1.8 billion and sell US$  
(2023: A$1.3 billion). These contracts had been designated in cash flow hedge relationships. 

Sensitivity to foreign currency movement

 Based on the Group’s net financial assets and liabilities at 31 December 2024, the estimated impact of a ±15 cent 
movement in the Australian dollar exchange rate (2023: ±15 cent) against the US dollar, with all other variables held 
constant is $22 million, including the impact of hedging (2023: $1 million) on post-tax profit and $224 million (2023: 
$188 million) on equity. The impact on equity is mainly attributable to changes in the fair value of foreign exchange 
forward contracts designated as cash flow hedges. The impact of the PNG kina has been assessed as immaterial. The 
sensitivity analysis is unrepresentative of the inherent foreign exchange risk, as the year end exposure does not reflect 
the exposure during the year.

251

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.5 Financial risk management (continued)

(d) Market risk

Cash flow and fair value interest rate risk

 The Group’s interest rate risk arises from its borrowings. Borrowings issued at variable rates expose the Group to cash 
flow interest rate risk. Borrowings issued at fixed rates expose the Group to fair value interest rate risk.

 The Group’s risk exposure is managed by maintaining an appropriate mix between fixed and floating rate borrowings 
and by the use of interest rate swap contracts. Hedging is evaluated regularly to align with the Group’s policy, interest 
rate outlook and risk appetite, ensuring the most cost-effective hedging strategies are applied.

Sensitivity to interest rate movement

 Based on the net debt position as at 31 December 2024, it is estimated that if the US secured overnight financing rate 
(SOFR) changed by ±0.50% (2023: ±0.50%) with all other variables held constant, the impact on post-tax profit is 
$1.81 million (2023: $0.07 million).

 This assumes that the change in interest rates is effective from the beginning of the financial year and the net debt 
position and fixed/floating mix is constant over the year. However, interest rates and the debt profile of the Group are 
unlikely to remain constant and therefore the above sensitivity analysis will be subject to change.

Price risk exposure 

 The Group is exposed to commodity price fluctuations through the sale of petroleum products and other oil price-linked 
contracts. The Group may enter into Brent crude oil price swap and option contracts to manage its commodity price 
risk. Hedging is evaluated regularly to align with the Group’s policy, pricing outlook and risk appetite, ensuring the most 
cost-effective hedging strategies are applied. At 31 December 2024, the Group had nil open Brent crude oil zero-cost 
collar option contracts (2023: 18 million barrels). These contracts had been designated in a cash flow hedge relationship. 

 The Group is exposed to electricity price fluctuations on the purchase of electricity for use in the business. The 
Group may enter into electricity swap contracts to manage this exposure. At 31 December 2024, the Group had 
458,136 megawatt-hours (MWh) of electricity swaps (2023: 642,265 MWh) maturing 2025 to 2026 that are 
designated in a cash flow hedge relationship.

(e) Credit risk

 Credit risk represents the potential financial loss if counterparties fail to complete their obligations under financial 
instrument or customer contracts. Santos employs credit policies which include monitoring exposure to credit risk on an 
ongoing basis through management of concentration risk and ageing analysis. 

 The majority of Santos’ gas contracts are spread across major energy retailers and industrial users. Contracts exist in 
every mainland state, across a wide range of customers.

 The Group considers the probability of default upon initial recognition of the asset and whether there has been a 
significant depreciation in credit quality on an ongoing basis throughout each reporting period. A significant decrease 
in credit quality is defined as a debtor being greater than 30 days past due in making a contractual payment. The Group 
applies the simplified approach to providing for expected credit losses prescribed by AASB 9 Financial Instruments, 
which permits the use of the lifetime expected loss provision for all trade receivables and contract assets.

 A default on a financial asset is when the counterparty fails to make contractual payments within 60 days of when they 
fall due. Financial assets are written off when there is no reasonable expectation of recovery. The Group categorises a 
loan or receivable for write-off when a debtor fails to make contractual repayments greater than 120 days past due. 
Where loans or receivables have been written off, the Group continues to engage in enforcement activity to attempt to 
recover the receivable due. Where recoveries are made, these are recognised in the income statement.

 At 31 December 2024, there were no significant concentrations of credit risk within the Group and financial instruments 
are spread amongst a number of financial institutions to minimise the risk of counterparty default. 

 The maximum exposure to financial institution credit risk is represented by the sum of all cash deposits plus accrued 
interest, bank account balances and fair value of derivative assets. The Group’s counterparty credit policy limits this 
exposure to commercial and investment banks, according to approved credit limits based on the counterparty’s credit 
rating. The minimum credit rating is A- from Standard & Poor’s subject to approved exceptions.

 Under the simplified approach, determination of the loss allowance provision and expected loss rate incorporates past 
experience and forward-looking information, including the outlook for market demand and forward-looking interest 
rates. As the expected loss rate at 31 December 2024 is Nil (2023: Nil), no loss allowance provision has been recorded at 
31 December 2024 (2023: Nil).

252

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.5 Financial risk management (continued)

(f)  Fair values

 Fair value is the price that would be received to sell an asset or the price that would be paid to transfer a liability in an 
orderly transaction between market participants at the measurement date. The fair value measurement is based on the 
presumption that the transaction to sell the asset or transfer the liability takes place either:

• 

• 

in the principal market for the asset or liability; or

in the absence of a principal market, in the most advantageous market for the asset or liability, that is accessible 
by the Group.

 The financial assets and liabilities of the Group are all initially recognised in the statement of financial position at their 
fair values. Receivables, payables, interest-bearing liabilities and other financial assets and liabilities, which are not 
subsequently measured at fair value, are carried at amortised cost. The following summarises the significant methods 
and assumptions used in estimating the fair values of financial instruments:

  Derivatives

 The fair value of interest rate swaps is calculated by discounting estimated future cash flows based on the terms of 
maturity of each contract, using market interest rates for a similar instrument at the reporting date.

 The fair value of forward foreign exchange contracts is determined by discounting future cash flows using market 
interest rates and translating the amounts into US dollars using the spot rate at the reporting date. The fair value of 
Brent crude options is determined using an option pricing model, which takes into consideration the price of the option, 
the strike price, the time until expiration, implied volatility and a risk-free rate. The fair value of electricity derivative 
contracts is determined by estimating the difference between the relevant market prices and the contract strike price, 
for the notional volumes of the derivative contracts. 

Financial liabilities

 Fair value is calculated based on the present value of future principal and interest cash flows, discounted at the market 
rate of interest at the reporting date. 

Valuation technique used for determining fair value

 The Group uses the following hierarchy for determining and disclosing the fair value of financial instruments by 
valuation technique:

Level 1: quoted (unadjusted) prices in active markets for identical assets and liabilities

 Level 2: other techniques for that all inputs which have a significant effect on the recorded fair value are observable, 
either directly or indirectly

 Level 3: techniques which use inputs that have a significant effect on the recorded fair value that are not based on 
observable market data.

  All of the Group’s financial instruments were valued using the Level 2 valuation technique. 

253

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.5 Financial risk management (continued)

(g) Derivatives and hedging activity

The Group’s accounting policy for fair value and cash flow hedges are as follows:

Types of hedges
What is it?

Fair value hedges
A derivative or financial instrument 
designated as hedging the change in fair 
value of a recognised asset or liability.

Cash flow hedges
A derivative or financial instrument 
designated to hedge the exposure to 
variability in cash flows attributable to a 
particular risk associated with an asset, 
liability or forecast transaction.

Recognition date

At the date the instrument is designated as a 
hedging instrument.

At the date the instrument is designated as a 
hedging instrument.

Measurement

Measured at fair value (refer to Note 5.5(f)).

Measured at fair value (refer to Note 5.5(f)).

Changes in fair value

The gains or losses on both the derivative or 
financial instrument and hedged asset or 
liability attributable to the hedged risk are 
recognised in the income statement 
immediately.

The gain or loss relating to the effective 
portion of interest rate swaps hedging 
fixed-rate borrowings is recognised in the 
income statement within finance costs, 
together with the loss or gain in the fair value 
of the hedged fixed-rate borrowings 
attributable to interest rate risk. 

The gain or loss relating to the ineffective 
portion is recognised in the income statement 
within other income or other expenses. 

If the hedge no longer meets the criteria for 
hedge accounting, the adjustment to the 
carrying amount of a hedged item, for which 
the effective interest method is used, is 
amortised to the income statement over the 
period to maturity using a recalculated 
effective interest rate.

Movements in fair value of liabilities 
designated at FVTPL due to changes in the 
Group's own credit risk are recorded in the 
Own credit risk revaluation reserve through 
OCI and do not get recycled to the income 
statement. 

Changes in the fair value of derivatives 
designated as cash flow hedges are 
recognised directly in other comprehensive 
income and accumulated in equity in the 
hedging reserve to the extent that the hedge 
is effective.

Ineffectiveness is recognised on a cash flow 
hedge where the cumulative change in the 
designated component value of the hedging 
instrument exceeds on an absolute basis the 
change in value of the hedged item 
attributable to the hedged risk. In hedges of 
foreign currency purchases this may arise if 
the timing of the transaction changes from 
what was originally estimated.

To the extent that the hedge is ineffective, 
changes in fair value are recognised 
immediately in the income statement within 
other income or other expenses. 

Amounts accumulated in equity are 
transferred to the income statement or the 
statement of financial position, for a non-
financial asset, at the same time as the 
hedged item is recognised. 

When a hedging instrument expires or is sold, 
terminated or exercised, or when a hedge no 
longer meets the criteria for hedge 
accounting, any cumulative gain or loss 
existing in equity at that time remains in 
equity and is recognised when the underlying 
forecast transaction occurs. 

When a forecast transaction is no longer 
expected to occur, the cumulative gain or loss 
that was reported in equity is immediately 
transferred to the income statement.

Hedge effectiveness is determined at the inception of the hedge relationship, and through periodic prospective 
effectiveness assessments to ensure that an economic relationship exists between the hedged item and hedging 
instrument. The Group enters into hedge relationships where the critical terms of the hedging instrument match exactly 
with the terms of the hedged item, and so a qualitative assessment of effectiveness is performed. If changes in 
circumstances affect the terms of the hedged item such that the critical terms no longer match exactly with the critical 
terms of the hedging instrument, the Group uses the hypothetical derivative method to assess effectiveness.

254

Santos Annual Report 2024 
 
5.5 Financial risk management (continued)

(g) Derivatives and hedging activity (continued)

  Hedge of monetary assets and liabilities

 When a derivative financial instrument is used to hedge the foreign exchange exposure of a recognised monetary asset 
or liability, hedge accounting is not applied and any gain or loss on the hedging instrument is recognised in the income 
statement.

  Hedge of net investment in a foreign operation

 The gain or loss on an instrument used to hedge a net investment in a foreign operation is recognised directly in equity. 
On disposal of the foreign operation, the cumulative value of any such gains or losses recognised directly in equity is 
transferred to the income statement. There was no such hedging activity during 2024.

The effects of applying hedge accounting on the Group’s financial position and performance are as follows: 

Cash flow hedge: Derivative financial instruments – Oil derivative contracts
Carrying amount 

Notional amount (mmbbl)

Maturity date
Hedge ratio1
Change in value of outstanding hedging instruments since 1 January 

Change in value of hedged item used to determine hedge effectiveness 

Hedged rate range floor/average cap tranche 1 – 13 mmbbl

Hedged rate range floor/average cap tranche 2 – 5 mmbbl 

Cash flow hedge: Derivative financial instruments – Foreign exchange contracts
Carrying amount 

Notional amount (A$ millions)

Maturity date
Hedge ratio1
Change in value of outstanding hedging instruments since 1 January 

Change in value of hedged item used to determine hedge effectiveness 

2024

2023

US$million

US$million

–

–

–

–

(108)

108

–

–

89

18

2024

1:1

89

(89)

75/90.94

80/90.15

2024

2023

US$million

US$million

(44)

1,814

2025-2026

1:1

(89)

89

44

1,260

2024

1:1

49

(49)

Weighted average hedged rate

$0.6481

$0.6480

1 

 The Group has established a hedge ratio of 1:1 for the hedging relationships with the underlying risk of the hedging instrument being identical to the hedged risk 
component of the hedged item. 

255

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
Notes to the Consolidated Financial Statements
Section 5: Funding and risk management

5.5 Financial risk management (continued)

(g) Derivatives and hedging activity (continued)

Cash flow hedge: Derivative financial instruments – Electricity derivatives
Carrying amount 

Notional amount (MWh)

Maturity date
Hedge ratio1
Change in value of outstanding hedging instruments 

Change in value of hedged item used to determine hedge effectiveness 

Weighted average hedged rate

Reserves – Cash flow hedge reserve
Balance at 1 January 

Add: Change in fair value of hedging instrument recognised in OCI for the year  

(effective portion) 

Less: Deferred tax 

Balance at 31 December 

Reserves – Own credit risk revaluation reserve
Balance at 1 January 

Add: Fair value changes on financial liabilities designated at fair value due to own  

credit risk 

Balance at 31 December 

2024

2023

US$million

US$million

7

–

458,136

642,265

2025 - 2026

2024 - 2026

1:1

8

(8)

1:1

9

(9)

$89.13

$90.67

2024

2023

US$million

US$million

(91)

169

(51)

27

2

(132)

39

(91)

2024

2023

US$million

US$million

13

–

13

13

–

13

1 

 The Group has established a hedge ratio of 1:1 for the hedging relationships with the underlying risk of the hedging instrument being identical to the hedged risk 
component of the hedged item. 

256

Santos Annual Report 2024 
 
 
5.5 Financial risk management (continued)

(h) Other financial assets and liabilities

 The table below contains all other financial assets and liabilities as shown in the statement of financial position, including 
derivative financial instruments used for hedging:

Current assets
Foreign exchange contracts

Electricity derivatives

Commodity derivatives (oil hedges)

Deposit

Sub-lease receivables

Other

Non-current assets
Sub-lease receivables

Loan to equity accounted entity

Other

Current liabilities
Sundry liability

Foreign exchange contracts

Other

Non-current liabilities
Other

2024

2023

US$million

US$million

–

5

–

–

27

–

32

21

–

38

59

–

41

2

43

21

21

44

–

89

252

17

2

404

32

61

34

127

252

–

5

257

38

38

257

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Notes to the Consolidated Financial Statements
Section 6: Group structure

This section provides information which will help users understand how the Group structure affects the financial position 
and performance of the Group as a whole. Specifically, it contains information about consolidated entities, acquisitions and 
disposals of subsidiaries, joint arrangements, as well as parties to the Deed of Cross Guarantee under which each company 
guarantees the debts of others. 

6.1 Consolidated entities

Subsidiaries are entities controlled by the Company. Control exists when the Company is exposed to, or has the rights to, 
variable returns from its involvement with an entity and has the ability to affect those returns through its power over the 
entity. The financial statements of subsidiaries are included in the consolidated financial statements from the date that 
control commences until the date that control ceases.

Acquisitions of subsidiaries are accounted for using the acquisition method of accounting. The cost of an acquisition is 
measured as the aggregate of the consideration transferred, measured at acquisition date fair value and the amount of any 
non-controlling interest in the acquiree. For each business combination, the Group measures the non-controlling interest in 
the acquiree at the lower of either fair value or the proportionate share of the acquiree’s identifiable net assets.

Entities have a 12-month measurement period from the acquisition date to finalise the fair values of assets and liabilities 
acquired. If new information obtained within the 12 months from acquisition date about facts and circumstances that 
existed at the acquisition date identifies adjustments to fair values, or any additional provisions that existed at the 
acquisition date, then the accounting for the acquisition, including the value of goodwill, is updated retrospectively.

When the Group acquires a business, it assesses the financial assets and liabilities assumed for appropriate classification 
and designation in accordance with the contractual terms, economic circumstances and pertinent conditions as at the 
acquisition date.

If the business combination is achieved in stages, the previously held equity interest is remeasured at its acquisition date 
fair value and any resulting gain or loss is recognised in the income statement.

Any contingent consideration to be transferred by the acquirer will be recognised at fair value at the acquisition date. 
Subsequent changes to the fair value of the contingent consideration which is deemed to be an asset or liability will be 
recognised in accordance with AASB 9 either in the income statement or as a charge to other comprehensive income. If the 
contingent consideration is classified as equity, it shall not be remeasured until it is finally settled within equity. In instances 
where the contingent consideration does not fall within the scope of AASB 9, it is measured in accordance with the 
appropriate AASB standard.

A change in ownership interest of a subsidiary that does not result in the loss of control is accounted for as an equity 
transaction.

Intra-group balances and any unrealised gains and losses or income and expenses arising from intra-group transactions are 
eliminated in preparing the consolidated financial statements.

All subsidiaries within the Group are wholly owned.

258

Santos Annual Report 20246.1 Consolidated entities (continued)

Country of incorporation

Name
Santos Limited1 (Parent Company) Controlled entities: 
Alliance Petroleum Australia Pty Ltd1
Basin Oil Pty Ltd1 
Bridgefield Pty Ltd 
Bridge Oil Developments Pty Ltd1
Bronco Energy Pty Ltd1
Doce Pty Ltd
Fairview Pipeline Pty Ltd1
Moonie Pipeline Company Pty Ltd

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

Papuan Oil Search Ltd

  Oil Search (Uramu) Pty Ltd

  Oil Search (USA) Inc

  Oil Search (Alaska) LLC 

Santos Pipelines (Alaska) LLC2

Oil Search Ltd

  Oil Search (Middle Eastern) Ltd

  Oil Search (Iraq) Ltd

  Oil Search (Libya) Ltd

  Oil Search (Tunisa) Ltd

  Oil Search (Newco) Ltd

  Oil Search (Gas Holdings) Ltd

  Oil Search (Tumbudu) Ltd

  Oil Search Highlands Power Ltd

  Oil Search (PNG) Ltd

  Oil Search (Drilling) Ltd

  Oil Search (Exploration) Inc

  Oil Search (LNG) Ltd

  Oil Search Finance Ltd

  Oil Search Power Holdings Ltd

PNG Biomass Ltd

  Markham Valley Renewables Ltd

Santos Foundation Ltd3
Pac LNG Investments Ltd

Pac LNG Assets Ltd

Pac LNG International Ltd

Pac LNG Overseas Ltd

Pac LNG Holdings Ltd

Reef Oil Pty Ltd1
Santos Australian Hydrocarbons Pty Ltd
Santos (BOL) Pty Ltd1
Santos Browse Pty Ltd
Santos CSG Pty Ltd1
Santos Darwin LNG Pty Ltd

Santos Direct Pty Ltd

Santos Finance Ltd
Santos Foundation Pty Ltd4
Santos GLNG Pty Ltd

Santos International Holdings Pty Ltd

Santos Americas and Europe LLC

Santos TPY LLC

Santos Queensland LLC

AUS

AUS

USA

USA

USA

PNG

BVI

BVI

BVI

BVI

BVI

PNG

PNG

PNG

PNG

PNG

CI

PNG

BVI

PNG

PNG

PNG

PNG

PNG

PNG

PNG

PNG

PNG

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

USA

USA

USA

Name

Country of incorporation

Santos TOG LLC

Santos TPY CSG LLC

Barracuda Ltd

Sanro Insurance Pte Ltd

Santos Bangladesh Ltd

Santos (UK) Ltd

Santos Northwest Natuna B.V. 

Santos NA (19-12) Pty Ltd

Santos NA (19-13) Pty Ltd

Santos NA Bayu Undan Pty Ltd

Santos NA Emet Pty Ltd

Santos NA Timor Sea Pty Ltd

Santos NA Timor Leste Pty Ltd

Santos Hides Ltd

Santos P’nyang Ltd

Santos Sangu Field Ltd

Santos Singapore Hold Co Pte Ltd

Santos SG Trading Pte Ltd

USA

USA

PNG

SGP

GBR

GBR

NDL

AUS

AUS

AUS

AUS

AUS

AUS

PNG

PNG

GBR

SGP

SGP

Santos Singapore Shipping Pte Ltd

SGP 

Santos Vietnam Pty Ltd

Santos TOGA Pty Ltd

Santos (JPDA 91-12) Pty Ltd
Santos Midstream Holdings Pty Ltd1
Santos Devil Creek Pty Ltd1
Santos Resources Pty Ltd1
Santos Infrastructure Holdings Pty Ltd

Santos Midstream Asset Holdings Pty Ltd

Santos Infrastructure WAQ Holdings Pty Ltd

Santos Infrastructure WAQVIDC Pty Ltd

Santos Infrastructure WAQ Assets Pty Ltd

Santos Infrastructure West Holdings Pty Ltd

Santos Infrastructure WASDCA Pty Ltd

Santos Infrastructure WASVIA Pty Ltd

Santos (NARNL Cooper) Pty Ltd1
Santos NSW Pty Ltd

Santos NSW (Betel) Pty Ltd

Santos NSW (Hillgrove) Pty Ltd

Santos NSW (Holdings) Pty Ltd

Santos NSW (LNGN) Pty Ltd

Santos NSW (Pipeline) Pty Ltd

Santos NSW (Narrabri Energy) Pty Ltd

Santos NSW (Eastern) Pty Ltd

  Hunter Gas Pipeline Pty Ltd

Santos NSW (Narrabri Gas) Pty Ltd

Santos NSW (Narrabri Power) Pty Ltd

Santos NSW (Operations) Pty Ltd

Santos (N.T.) Pty Ltd

Bonaparte Gas & Oil Pty Ltd

Santos Offshore Pty Ltd1

BAFF Pty Ltd2

Santos Petroleum Pty Ltd1

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

259

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 6: Group structure

6.1 Consolidated entities (continued)

Name
Santos QLD Upstream Developments Pty Ltd
Santos QNT Pty Ltd1
  Outback Energy Hunter Pty Ltd

Country of incorporation

Santos QNT (No. 1) Pty Ltd

Santos QNT (No. 2) Pty Ltd

Petromin Pty Ltd

Santos Wilga Park Pty Ltd

Santos (TGR) Pty Ltd

Santos Timor Sea Pipeline Pty Ltd

Santos Ventures Pty Ltd
Santos WA Holdings Pty Ltd1

Santos KOTN Holdings Pty Ltd1

Santos KOTN Pty Ltd1

Santos Agency Pty Ltd

Santos NA Barossa Pty Ltd

Santos NA Browse Basin Pty Ltd

Santos Singapore Management Pte Ltd
Santos NA Energy Holdings Pty Ltd1

Santos NA Energy Pty Ltd1

 Santos NA Asset Holdings    

Pty Ltd1
Santos NA Assets Pty Ltd1

 Santos NA Darwin Pipeline  

Pty Ltd

Santos WA AEC Pty Ltd1
Santos WA Energy Holdings Pty Ltd1

Notes
1 

Company is party to a Deed of Cross Guarantee. Refer to Note 6.7.

2  Company incorporated during the 2024 financial year.

Name

Country of incorporation

Santos WA Asset Holdings Pty Ltd1
Santos WA Lowendal Pty Ltd

Santos WA International Pty Ltd

  Harriet (Onyx) Pty Ltd1
Santos WA Energy Ltd1
  Ningaloo Vision Holdings Pte Ltd

  Northwest Jetty Services Pty Ltd

Santos WA DC Pty Ltd

Santos WA (Exmouth) Pty Ltd
Santos WA East Spar Pty Ltd1
Santos WA Julimar Holdings Pty Ltd
Santos WA Kersail Pty Ltd1
Santos WA LNG Pty Ltd

Santos WA Management Pty Ltd

 Santos WA Finance Holdings  

Pty Ltd

 Santos WA Finance General  

Partnership

Santos WA Northwest Pty Ltd1
Santos WA Onshore Holdings Pty Ltd
Santos WA PVG Holdings Pty Ltd1

Santos WA PVG Pty Ltd1
Santos WA Southwest Pty Ltd1
Santos WA Varanus Island Pty Ltd1

SESAP Pty Ltd
Vamgas Pty Ltd1

AUS

AUS

AUS

AUS

AUS

SGP

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

AUS

SGP

AUS

AUS

AUS

AUS

AUS

AUS

AUS

3 

4 

 Santos Foundation Ltd is a Trustee of the Santos Foundation Trust (previously Oil Search Foundation Trust), a not-for-profit organisation established for 
charitable purposes in PNG. This Trust is not controlled and is not consolidated within the Group. Santos Foundation Ltd was previously registered under the 
name Oil Search Foundation Ltd until 19 June 2023.

 Santos Foundation Pty Ltd is a Trustee of the Santos Foundation Trust, a not-for-profit organisation established for charitable purposes in Australia. This Trust is 
not controlled and is not consolidated within the Group.

5 

Lavana Ltd was a consolidated entity within the Group until 4 November 2024, when it was disposed of. Refer to Note 6.2 for details.

Country of incorporation
AUS  

Australia

BVI   

British Virgin Islands 

CI 

Cayman Islands

GBR  

United Kingdom

NDL  

Netherlands

PNG  

Papua New Guinea

SGP  

Singapore

USA  

United States of America

260

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.2 Disposals

During the period, the Group finalised the sale of a 2.6 per cent interest in the PNG LNG project for a total consideration of 
$592 million. The key steps in the sale process are detailed below.

In 2022, Santos received a binding conditional offer from Kumul Petroleum Holdings Limited (Kumul) to acquire a 5 per 
cent economic interest in PNG LNG assets, including a proportionate share of the project finance debt. The associated 
assets and liabilities of the disposal group were classified as held for sale as at 30 June 2022. In September 2023, the 
transaction was restructured to include a binding sales agreement for a 2.6 per cent share of the PNG LNG project and the 
issuance of a call option to Kumul for the remaining 2.4 per cent. This option has now expired. The sale of the 2.6 per cent 
share was classified as held for sale as at 31 December 2023.

On 31 January 2024, the Group announced the execution of an amendment to the binding sales agreement where Kumul 
has taken an effective economic interest in the wholly owned Santos subsidiary (Lavana Limited) that holds the 2.6 per cent 
interest in the PNG LNG project. The transaction involved an upfront payment from Kumul of $352 million to Santos for this 
effective economic interest (equivalent to a 59.4 per cent interest in Lavana Limited or a ~1.6 per cent interest in the PNG 
LNG project) and provided additional time for Kumul to pay the remaining purchase price of $241 million.

On 4 November 2024, the Group finalised the sale of the 2.6 per cent interest in the PNG LNG project, having received the 
final payment of $241 million for the remaining 1.0 per cent interest. 

The following summarises the assets, liabilities and amounts in equity that were disposed and the impact on the Group’s 
Consolidated Income Statement.

Assets, liabilities and amounts included in equity disposed
Cash and cash equivalents

Oil and gas assets

Goodwill

Other

Assets

Interest-bearing loans and borrowings 

Deferred tax liabilities

Other

Liabilities

Net assets 

Foreign currency translation reserve

Amounts included in equity

US$million

55

446

66

18

585

89

102

34

225

360

49

49

261

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 6: Group structure

6.2 Disposals (continued)

The disposal of the balances noted on the previous page has been recorded in the Group’s Consolidated Income Statement 
and Consolidated Statement of Changes in Equity as follows.

Consideration received

Net assets disposed

Less: current period profits attributable to NCI

Amounts included in equity disposed

Other

Total gain on disposal

US$million

592

(360)

40

49

(4)

317

As noted above, the disposal was completed in several stages. Due to this, the gain on disposal has been recognised in the 
Group’s financial statements as follows.

Consolidated Statement of Changes in Equity – Accumulated profits reserve1
Consolidated Income Statement: Tax expense2
Consolidated Income Statement: Other income – gain on sale of non-current assets2

Total gain on disposal

200

102

15

317

1 

2 

Relates to the 1.6 per cent transfer of economic interest in the PNG LNG project and initial recognition of non-controlling interests (NCI), refer to Note 6.3.

 Relates to the receipt of funds for the remaining 1.0 per cent in the PNG LNG project, marking the completion of the transaction whereby the accumulated NCI 
balance was de-recognised and the net assets of Lavana Limited was disposed by the Group.

6.3 Non-controlling interests

Non-controlling interests (NCI) represent the equity in subsidiaries that is not attributable, directly or indirectly, to Santos’ 
shareholders. The Group recognised and disposed of an NCI during the period, resulting in there being no NCI as at 31 
December 2024 or as at the end of the comparative period. Below are details of the events that resulted in this occurring.

As referred to in Note 6.2, on 31 January 2024, Kumul paid $352 million to Santos for an effective economic interest in the 
wholly-owned subsidiary Lavana Limited, which holds a 2.6 per cent interest in the PNG LNG project. This agreement was 
classified as an equity instrument and recognised as an NCI. This equated to an effective economic interest in the PNG LNG 
project of ~1.6 per cent. Subsequent to 31 January 2024, Kumul’s share of PNG LNG project distributions, issued by way of 
an NCI dividend ($9.1 million), was applied to increase Kumul’s effective economic interest by a further 0.02 per cent, 
representing a 60.0 per cent interest in Lavana Limited.

On 4 November 2024, there ceased to be an NCI on finalisation of the sale of the 2.6 per cent interest in the PNG LNG project.

Summarised financial information relating to the Group’s subsidiary with NCI that is material to the Group before any 
intra-group eliminations is shown below.

Current assets
Non-current assets
Current liabilities
Non-current liabilities
Net assets
Net assets attributable to NCI
Goodwill attributable to subsidiary
Accumulated balance of NCI

Revenue 
Net profit
Profit attributable to NCI
Dividends paid to NCI

Net operating cash flow
Net investing cash flow
Net financing cash flow

US$million 
as at  
disposal date
75
444
(57)
(168)
294
176
40
216

121
66
40
9

76
(23)
(34)

As referred to above and in Note 6.2, the accumulated NCI balances noted above are as at the disposal date of 4 November 
2024 and the profit and loss and cash flow information is for the period 1 February 2024 to 4 November 2024. There is no 
NCI as at 31 December 2024. 

262

Santos Annual Report 20246.4 Assets held for sale

Non-current assets are classified as held for sale and measured at the lower of their carrying amount and fair value less 
costs of disposal if their carrying amount will be recovered principally through a sale transaction. They are not depreciated 
or amortised. For an asset to be classified as held for sale, it must be available for immediate sale in its present condition 
and its sale must be highly probable.

As referred to in Note 6.2, there are balances related to the sale of a 2.6 per cent interest in the PNG LNG project that were 
classified as held for sale in the comparative period. These amounts are summarised in the table below.

Assets and liabilities classified as held for sale
Cash and cash equivalents

Trade and other receivables

Prepayments

Inventories

Oil and gas assets

Goodwill

Assets classified as held for sale 

Trade and other payables

Interest-bearing loans and borrowings 

Provisions

Lease liabilities

Deferred tax liabilities

Liabilities classified as held for sale

Net assets 

Amounts included in equity:
Foreign currency translation reserve

Reserves of the disposal group

2024

2023

US$million

US$million

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

–

36

13

1

5

496

66

617

11

110

16

24

111

272

345

49

49

263

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Notes to the Consolidated Financial Statements
Section 6: Group structure

6.5 Joint arrangements

The Group’s investments in joint arrangements are classified as either joint operations or joint ventures depending on the 
contractual rights and obligations each investor has, rather than the legal structure of the joint arrangement. Santos’ 
exploration and production activities are often conducted through joint arrangements governed by joint operating 
agreements, production sharing contracts or similar contractual relationships. 

The differences between joint operations and joint ventures are as follows: 

Types of arrangement
Characteristics

Rights and obligations

Accounting method

Joint operation
A joint operation involves the joint control, 
and often the joint ownership, of assets 
contributed to, or acquired for the purpose 
of, the joint operation. The assets are used 
to obtain benefits for the parties to the joint 
operation and are dedicated to that 
purpose. 

Each party has control over its share of 
future economic benefits through its share 
of the joint operation, and has rights to the 
assets, and obligations for the liabilities, 
relating to the arrangement.

The interests of the Group in joint operations 
are brought to account by recognising the 
Group’s share of jointly controlled assets, 
share of expenses and liabilities incurred, 
and the income from its share of the 
production of the joint operation.

Joint venture
The Group has interests in joint ventures, 
whereby the venturers have contractual 
arrangements that establish joint control 
over the economic activities of the entities.

Parties that have joint control of the 
arrangement have rights to the net assets of 
the arrangement.

The Group recognises its interest in joint 
ventures using the equity method of 
accounting.

Under the equity method, the investment in 
a joint venture is initially recognised in the 
Group’s statement of financial position at 
cost and adjusted thereafter to recognise 
the post-acquisition changes to the Group’s 
share of net assets of the joint venture. After 
application of the equity method, the Group 
determines whether it is necessary to 
recognise any impairment loss with respect 
to the Group’s net investment in the joint 
venture.

The Group’s share of the joint venture’s 
post-acquisition profits or losses is 
recognised in the income statement and its 
share of post-acquisition movements in 
reserves is recognised in the statement of 
changes in equity and, when applicable, in 
the statement of comprehensive income. 
Dividends receivable from the joint venture 
reduce the carrying amount of the 
investment in the consolidated financial 
statements of the Group.

264

Santos Annual Report 20246.5 Joint arrangements (continued)

(a) Joint operations

The following are the material joint operations in which the Group has an interest:

Joint operation

Area of cash-generating 
unit/area of interest

Principal activities

2024 
% Interest

2023 
% Interest

North Carnarvon

Oil and gas production

PNG LNG

Gas and liquids production

Oil production

Gas production

Oil and gas production

Gas production

Gas production

Gas production

LNG facilities

Gas production

Oil and gas exploration

Oil and gas exploration

Contingent oil and gas

Oil and gas exploration

Contingent oil and gas

Oil and gas exploration

Oil and gas assets – Producing assets
Pikka phase 1

Alaska

Caldita/Barossa

Bonaparte Basin

SA Fixed Factor Area

SWQ Unit

Combabula

Fairview

Gladstone LNG (GLNG) 
Downstream

Roma

Macedon/Pyrenees
PNG LNG1

Cooper Basin

Cooper Basin

GLNG

GLNG

GLNG

GLNG

Exploration and evaluation assets 
Alaska
Horseshoe

Pikka phase 2

WA-435-P

WA-437-P

WA-436-P 

WA-438-P

Petrel

WA-90-R, WA-91-R, 
WA-92-R

WA-281-P

WA-45-R

EP161

Muruk 1

PDL 1

PDL 9

PPL 476

PRL-3 

PRL-9

Alaska

Bedout

Bedout

Bedout

Bedout

PNG

PNG

PNG

PNG

PNG

PNG

WA-58-R (WA-274-P)

Bonaparte Basin

Gas development

WA-80-R

Browse

Contingent gas resource

Bonaparte Basin

Contingent gas resource

Browse

Browse

Carnarvon

Gas and liquids exploration

Gas and liquids exploration

Gas exploration

McArthur Basin

Contingent gas resource

Gas and liquids exploration

Gas and liquids exploration

Contingent gas resource

Gas and liquids exploration

Gas exploration

Gas and liquids exploration

Contingent gas resource

PRL-15 (PNG LNG Project) PNG

1 

During the year, the Group disposed of a 2.6 per cent interest in PNG LNG, refer to Note 6.2.

51.0

50.0

66.6

60.1

 7.3

22.8

30.0

30.0

28.6

39.9

51.0

51.0

80.0

80.0

70.0

70.0

40.3

30.0

47.8

40.0

70.5

75.0

75.0

57.5

40.7

24.4

25.0

38.5

40.0

22.8

51.0

50.0

66.6

60.1

 7.3

22.8

30.0

30.0

28.6

42.5

51.0

51.0

80.0

80.0

70.0

70.0

40.3

30.0

47.8

40.0

70.5

75.0

75.0

57.5

40.7

24.4

25.0

38.5

40.0

22.8

265

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Notes to the Consolidated Financial Statements
Section 6: Group structure

6.5 Joint arrangements (continued)

(b) Investments in equity accounted associates and joint ventures

 The Group’s only material joint venture or associate is Darwin LNG Pty Ltd, which operates the Darwin LNG liquefaction 
facility. The Group’s interest in Darwin LNG is 43.4 per cent. The investment is accounted for as an equity accounted 
investment in an associate, given the Group is deemed to have only significant influence over the separately 
incorporated company, based on the structure of voting and decision-making rights.

 Summarised financial information of the joint venture, based on the amounts presented in its financial statements, and a 
reconciliation to the carrying amount of the investment in the consolidated financial statements, are set out below:

Share of investment in Darwin LNG Pty Ltd

Group’s equity interest

2024

2023

US$million

US$million

43.4%

43.4%

Summarised net asset position
Current assets

Non-current assets

Current liabilities

Non-current liabilities

Closing net assets

Group’s share of net assets

Summarised income statement
Gross (loss)/profit 

Other income and expenses

Depreciation and amortisation

Profit before tax

Income tax (expense)/benefit

Net profit after tax for the period

Group’s share of net profit of associates

Reconciliation to carrying amount
Opening balance

Add: Group’s share of net profit

Shareholder loan

Carrying amount of investments in associate

49

1,311

(21)

(434)

905

393

(2)

7

9

14

(9)

5

2

406

2

408

(15)

393

221

993

(57)

(222)

935

406

2

(6)

8

4

22

26

11

373

11

384

22

406

266

Santos Annual Report 2024 
 
6.5 Joint arrangements (continued)

(b) Investments in equity accounted associates and joint ventures (continued)

 The following are the equity accounted associates and joint ventures in which the Group has an interest, including those 
which are immaterial:

Equity accounted associate or joint venture
Darwin LNG Pty Ltd

GLNG Operations Pty Ltd

NiuPower Ltd

NiuEnergy Ltd

Pacific Compass LLC

Pikka Transportation Company LIC

2024

2023

% Interest

% Interest

43.4

30.0

50.0

50.0

51.0

51.0

43.4

30.0

50.0

50.0

51.0

–

 At 31 December 2024, the Group reassessed the carrying amount of its investments in equity accounted associates and 
joint ventures for indicators of impairment. As a result, no impairment was recorded (2023: $nil).

 The opening carrying value of equity accounted associates and joint ventures (other than Darwin LNG Pty Ltd) was nil 
(2023: $6 million). Share of profits for the period was nil (2023: $6 million loss), resulting in a closing carrying value at 
31 December 2024 of nil (2023: nil). 

6.6 Parent entity disclosures

Selected financial information of the ultimate parent entity in the Group, Santos Limited, is as follows: 

Net profit for the period
Total comprehensive income

Current assets

Total assets

Current liabilities

Total liabilities

Issued capital

Accumulated profits reserve

Other reserves

Accumulated losses

Total equity

Commitments of the parent entity
The parent entity’s commitments are:

  Capital expenditure commitments

  Minimum exploration commitments

2024

2023

US$million

US$million

 642

642

 482 

 13,862

331 

 1,375 

14,375 

 958 

 (1,306)

(1,540)

12,487

1,022

1,022

419

13,713

311

883

14,375

1,396

(1,306)

(1,635)

12,830

7

13

2

11

Guarantees entered into by the parent entity in relation to the debts of its subsidiaries

All interest-bearing loans and borrowings, as disclosed in Note 5.1, with the exception of the lease liabilities and secured 
bank loans, are arranged through Santos Finance Ltd, which is a wholly-owned subsidiary of Santos Limited. All interest-
bearing loans and borrowings of Santos Finance Ltd are guaranteed by Santos Limited.

Contingent liabilities of the parent entity

Contingent liabilities arise in the ordinary course of business through claims against Santos Limited, including contractual, 
third-party and contractor claims. In most instances it is not possible to reasonably predict the outcome of these claims 
and, as at reporting date, Santos Limited believes that the aggregate of such claims will not materially impact the 
Company’s Financial Report.

267

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
Notes to the Consolidated Financial Statements
Section 6: Group structure

6.7 Deed of cross guarantee

Pursuant to ASIC Corporations (Wholly-owned Companies) Instrument 2016/785 (the Instrument), the Company and each 
of the wholly-owned subsidiaries identified in Note 6.1 (collectively, the Closed Group) are relieved from the Corporations 
Act 2001 requirements for preparation, audit and lodgement of their financial reports.

As a condition of the Instrument, the Closed Group has entered into a Deed of Cross Guarantee (the Deed). The effect of 
the Deed is that the Company has guaranteed to pay any deficiency in the event of winding up of any of the subsidiaries 
under certain provisions of the Corporations Act 2001. The subsidiaries have also given a similar guarantee in the event that 
the Company is wound up.

Set out below is a consolidated income statement, consolidated statement of comprehensive income and summary of 
movements in consolidated accumulated losses for the year ended 31 December of the Closed Group. No changes to the 
Deed group occurred during 2024. 

Consolidated income statement
Product sales

Cost of sales

Gross profit/(loss)
Other revenue

Other income

Other expenses

Impairment of non-current assets

Interest income

Finance costs

(Loss)/profit before tax
Income tax (expense)/benefit1
Royalty-related tax benefit

Total tax (expense)/benefit

Net (loss)/profit for the period

Total comprehensive (loss)/profit

Summary of movements in the Closed Group’s accumulated losses:
  Accumulated losses at 1 January

Transfer to accumulated profits reserve

  Net (loss)/profit for the period

Share-based payment transactions

Accumulated losses at 31 December

1 

Amounts have been restated to ensure consistency with current period. 

2024

2023

US$million

US$million

1,779

(1,635)

144

86

805

(240)

(120)

209

(873)

11

(32)

1

(31)

(20)

(20)

(4,648)

(550)

(20)

(13)

1,766

(1,779)

(13)

79

1,202

(301)

(63)

187

(962)

129

(93)

74

(19)

110

110

(3,858)

(900)

110

–

(5,231)

(4,648)

268

Santos Annual Report 2024 
 
6.7 Deed of cross guarantee (continued)

Set out below is a Consolidated Statement of Financial Position as at 31 December of the Closed Group:

Current assets
Cash and cash equivalents

Trade and other receivables

Other current assets

Total current assets

Non-current assets
Other financial assets

Exploration and evaluation assets

Oil and gas assets

Other non-current assets

Total non-current assets

Total assets

Current liabilities
Trade and other payables

Other current liabilities

Total current liabilities

Non-current liabilities
Interest-bearing loans and borrowings

Provisions
Other non-current liabilities1

Total non-current liabilities

Total liabilities

Net assets

Equity
Issued capital

Reserves
Accumulated losses1

Total equity

1 

Amounts have been restated to ensure consistency with current period. 

2024

2023

US$million

US$million

315

2,120

284

2,719

12,272

953

5,776

1,773

20,774

23,493

9,186

547

9,733

–

2,308

787

3,095

12,828

10,665

14,345

1,551

(5,231)

10,665

172

4,901

279

5,352

12,278

977

5,593

1,813

20,661

26,013

10,659

496

11,155

12

2,489

676

3,177

14,332

11,681

14,339

1,990

(4,648)

11,681

269

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationNotes to the Consolidated Financial Statements
Section 7: People

This section includes information relating to the various programs the Group uses to reward and recognise our people. It 
includes details of our employee benefits, share-based payment schemes and Key Management Personnel. 

7.1 Employee benefits

Wages, salaries and sick leave

Liabilities for wages and salaries, including non-monetary benefits that are expected to be settled within 12 months of the 
reporting date, are recognised in respect of employee service up to the reporting date. They are measured at the amounts 
expected to be paid when the liabilities are settled. Expenses for non-vesting sick leave are recognised when the leave is 
taken and are measured at the rates paid or payable.

Long-term service benefits

Liabilities for long service leave and annual leave that is not expected to be taken within 12 months of the respective service 
being provided, are recognised and measured at the present value of the estimated future cash outflows to be made in 
respect of employee service up to the reporting date. 

Defined contribution plans

The Group makes contributions to several defined contribution superannuation plans. Obligations for contributions are 
recognised as an expense in the income statement as incurred. The amount incurred during the year was $22 million (2023: 
$19 million).

The following amounts are recognised in the Group’s statement of financial position in relation to employee benefits:

Current provisions
Employee benefits

Non-current provisions
Employee benefits

Total employee benefits provisions

2024

2023

US$million

US$million

88

17

105

105

14

119

270

Santos Annual Report 20247.2 Share-based payment plans

The Group provides benefits to employees of the Group through share-based incentives. Employees are paid for their 
services or incentivised for their performance in part through shares or rights over shares. 

Santos' share-based payment plans are equity-settled. The equity-settled plans consist of the general employee share-
based payment plans, Executive Long-Term Incentive share-based payment plans and Executive Short-Term Incentive 
share-based payment plans.

The amounts recognised in the income statement of the Group during the financial year in relation to shares issued under 
the share plans are summarised as follows:

Employee expenses:

  General employee share plans:

Share1000 Plan 

ShareMatch Plan (matched Share Appreciation Rights (“SARs”)) 

Executive Long-Term Incentive share-based payment plans – equity-settled 

Executive Short-Term Incentive share-based payment plans – equity-settled 

  Other equity grants

2024

US$000

2023

US$000

(828)

(2,627)

(10,050)

(5,054)

(9,144)

(27,703)

(785)

(2,861)

(8,736)

(5,526)

(7,027)

(24,935)

The net cash impact from share-based payment plans on accumulated (losses)/profit, net of Treasury shares utilised in the 
current year, is $15 million (2023: nil). 

271

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 7: People

7.2 Share-based payment plans (continued)

(a) Equity-settled share-based payment plans

 The cost of equity-settled transactions is determined by the fair value at the grant date using an appropriate valuation 
model. The cost is recognised, together with a corresponding increase in other capital reserves in equity, over the period 
in which the performance and/or service conditions are met. Currently, the Company has four equity-settled share-
based payment plans in operation, the details of which are as follows:

i.  General employee share plans

 Santos operates two general employee share plans, the Share1000 Plan and the ShareMatch Plan. Eligible employees 
have the option to participate in either the Share1000 Plan or the ShareMatch Plan. Directors of the Company, Key 
Management Personnel, Senior Executives, casual employees, employees on fixed-term contracts, employees on 
international assignment and employees with an unsatisfactory performance rating in the previous year are excluded 
from participating in the Share1000 Plan and the ShareMatch Plan.

What is it?

The employee’s ownership 
and right to deal with them

How is the fair value 
recognised?

Share1000
The Share1000 Plan provides for grants 
of fully paid ordinary shares up to a value 
determined by the Board, which in 2024 
was A$1,000 per employee (2023: 
A$1,000).

Subject to restrictions until the earlier of 
the expiration of the three-year 
restriction period and the time when the 
employee ceases to be in employment.

The fair value of these shares is 
recognised as an employee expense with 
a corresponding increase in issued 
capital, and the fair value per share is 
determined by the Volume Weighted 
Average Price (VWAP) of ordinary 
Santos shares on the ASX during the 
week up to and including the date of 
issue of the shares.

ShareMatch
The ShareMatch Plan allows for the 
purchase of shares up to $5,000 on a 
pre-tax basis. Shares are provided via an 
employee loan, repaid over a maximum 
12-month period, and employees receive 
matched SARs according to their 
performance rating. 

Upon vesting, subject to restrictions until 
the earlier of the expiration of the 
three-year restriction period and the 
time when he or she ceases to be an 
employee.

The fair value of the shares is recognised 
as an increase in issued capital and a 
corresponding increase in loans 
receivable. The fair value per share is 
determined by the VWAP of ordinary 
Santos shares on the ASX during the 
week up to and including the date of 
issue of the shares.

The fair value of services required in 
return for matched SARs granted is 
measured by reference to the fair value 
of matched SARs granted. The estimate 
of the fair value of the services received 
is measured by discounting the share 
price on the grant date using the 
assumed dividend yield and recognised 
as an employee expense for the term of 
the matched SARs.

The following shares were issued pursuant to the employee share plans during the period:

Share1000 Plan

ShareMatch Plan

Issued  
shares

No.

168,810
147,975

Fair value  
per share

A$

7.22
7.96

Issued  
shares

No.

761,387
569,966

Fair value  
per share

A$

7.22
7.96

Issue date

30 August
31 July

Year

2024
2023

272

Santos Annual Report 2024 
 
 
 
 
 
 
 
7.2 Share-based payment plans (continued)

i.  General employee share plans (continued)

The number of SARs outstanding and movements throughout the financial year are:

Year

2024 Total
2023 Total

Beginning of 
the year

No.

1,952,640
2,408,894

Granted

No.

917,074
690,998

Lapsed

No.

(110,873)
(213,485)

Vested

No.

(651,660)
(933,767)

The inputs used in the valuation of the SARs are as follows:

Matched SARs grant
Share price on grant date (A$)

Exercise price (A$)

Right life (weighted average, years)

Expected dividends (% p.a.)

Fair value at grant date (A$)

End of  
the year

No.

2,107,181
1,952,640

30 August 
2024

7.22

Nil

3

–

7.22

The loan arrangements relating to the ShareMatch Plan are as follows:

 During the year the Company utilised $4 million of Treasury shares (2023: $3 million) under the ShareMatch Plan, 
with $3 million (2023: $3 million) received from employees under loan arrangements. The movements in loans 
receivable from employees are:

Employee loans at 1 January

Treasury shares utilised during the year

Cash received during the year

Foreign exchange movement

Employee loans at 31 December

2024

US$000

1,795

3,736

(2,961)

(302)

2,268

2023

US$000

2,107

3,023

(3,319)

(16)

1,795

ii.  Executive Long-Term Incentive share-based payment plans

 The Company’s Executive Long-Term Incentive Program (LTI Program) provides for eligible Executives selected by 
the Board to receive SARs upon the satisfaction of set market and non-market performance conditions. Each SAR is 
a conditional entitlement to a fully paid ordinary share, subject to the satisfaction of performance or service 
conditions, on terms and conditions determined by the Board. The Board has the discretion to cash-settle SARs 
granted under the amended Santos Employee Equity Incentive Plan. 

 The fair value of SARs is recognised as an employee expense with a corresponding increase in equity. The fair value 
is measured at grant date and recognised over the period during which the Executive becomes unconditionally 
entitled to the SARs. The fair value of the performance-based SARs granted is measured using a Monte Carlo 
simulation method, taking into account the terms and market conditions upon which the SARs were granted. The 
fair value of the deferred SARs granted is measured by discounting the share price on the grant date using the 
assumed dividend yield for the term of the SAR. The amount recognised as an expense is only adjusted when SARs 
do not vest due to non-market-related conditions.

 The 2024 LTI Program offers consisted only of SARs. Performance Awards were granted to eligible Executives in 
2024 who were granted one four-year grant (1 January 2024 – 31 December 2027).

273

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 7: People

7.2 Share-based payment plans (continued)

ii.  Executive Long-Term Incentive share-based payment plans (continued)

  Vesting of the grants is based on the following performance targets:

•  25 per cent of the SARs are subject to Santos’ Total Shareholder Return (TSR) relative to the performance of the 

ASX 100 companies (ASX 100 comparator group)

•  25 per cent are subject to Santos’ TSR relative to the performance of the Standard & Poor’s Global 1200 Energy 

Index companies (S&P GEI comparator group)

•  25 per cent are subject to Santos’ Free Cash Flow Breakeven Point (FCFBP) relative to internal targets

•  25 per cent are subject to Santos’ Return on Average Capital Employed (ROACE) relative to internal targets, 

measured at the end of the performance period.

The numbers of SARs outstanding at the end of, and movements throughout, the financial year are:

Year

2024 Total
2023 Total

Beginning of 
the year

No.

11,045,378
9,884,206

Granted 

No.
3,098,7771
4,143,255

Lapsed

No.

Vested

No.

End of  
the year

No.

(1,790,372)
(2,165,079)

(1,461,131)
(817,004)

10,892,652
11,045,378

1 

Balance includes 100,223 SARs granted during 2024 related to prior years’ tranches, no additional valuations were issued.

 The SARs granted during 2024 totalling 2,998,554 were issued under the following tranche, with its corresponding 
valuation:

Senior Executive LTI – granted 26 June 2024

Performance Awards
Performance index

Fair value at grant date (A$)

Share price on grant date (A$)

Exercise price (A$)

Expected volatility (weighted average, % p.a.)

Right life (weighted average, years)

Risk-free interest rate (% p.a.)

Total granted (No.)

2024

25%
ASX 100

25%
S&P GEI

$4.79

$7.66

nil

30%

4

4.1%

$4.72

$7.66

nil

30%

4

4.1%

25%
FCFBP

$7.66

$7.66

nil

30%

4

4.1%

25%
ROACE

$7.66

$7.66

nil

30%

4

4.1%

749,659

749,649

749,630

749,616

 The above tables include the valuation assumptions used for Performance Awards SARs granted during the current 
year. The expected vesting period of the SARs is based on historical data and current expectations and is not 
necessarily indicative of exercise patterns that may occur. The expected volatility reflects the assumption that the 
historical volatility over a period similar to the life of the SARs is indicative of future trends, which may not 
necessarily be the actual outcome.

  Vesting of Performance Awards

 All Performance Awards are subject to hurdles based on the Company’s TSR relative to both the ASX 100 and S&P 
GEI comparator group over the performance period, as well as the FCFBP and ROACE at the end of the vesting 
period. There is no re-testing of performance conditions. Each tranche of the Performance Awards subject to TSR 
granted during 2024 vests in accordance with the following vesting schedule:

TSR percentile ranking
< 51st percentile

= 51st percentile 

52nd to 75th percentile 
≥ 76th percentile

% of grant vesting
0%

50%

Further 2.0% for each percentile over 51st

100%

274

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
 
 
 
 
 
7.2 Share-based payment plans (continued)

iii.  Executive Deferred Short-Term Incentives (STIs)

 Short-term incentive outcomes for Senior Executives and Executives are delivered in a mix of cash and equity, which 
are subject to a two-year restriction period. For the Managing Director and CEO and his direct reports, the equity is 
provided in the form of deferred shares. For other Executives, the equity is provided in the form of Share Acquisition 
Rights.

  Deferred shares 

 The deferred shares are subject to a 24-month continuous service period following the year to which the STI is 
related. The number of deferred STI shares outstanding at the end of, and movements throughout, the financial year 
are:

Year

2024 Total
2023 Total

Beginning of 
the year

No.

464,296
697,789

Granted 

No.

540,195
502,979

Lapsed

No.

(29,957)
(159,126)

Vested

No.

(434,339)
(577,346)

End of  
the year

No.

540,195
464,296

 On 2 April 2024, the Company issued 540,195 deferred shares to eligible Executives. The share price and fair value 
on the grant date was A$7.84, with no discounting applied for a dividend yield assumption, given the deferred 
shares being eligible to receive dividends from the date of grant.

Share acquisition rights 

 The share acquisition rights are subject to a 24-month continuous service period following the year to which the STI 
is related. The number of deferred STI share acquisition rights outstanding at the end of, and movements 
throughout, the financial year are:

Year

2024 Total
2023 Total

Beginning of 
the year

No.

780,992
674,749

Granted 

No.
829,7671
836,463

Lapsed

No.

(110,383)
(202,079)

Vested

No.

(523,227) 
(528,141)

End of  
the year

No.

977,149
780,992

1 

Balance includes 9,481 acquisition rights granted during 2024 related to 2023 grants.

 On 23 April 2024, the Company issued 820,286 acquisition rights to eligible Executives. The share price and fair 
value on the grant date was A$7.71. No discounting was applied for a dividend yield assumption, as for SARs which 
vest, participants receive additional Santos shares equivalent in value to notional dividends accrued and reinvested 
during the period between allocation and vesting, or the cash equivalent value. No entitlement to additional shares 
or cash payment is provided in respect of SARs which do not vest. 

iv.  Other equity grants

 The SARs in the table below are subject to varying continuous service periods, depending on the specific grant. The 
number of other equity grants outstanding at the end of, and movements throughout, the financial year are: 

Year 

2024 Total 
2023 Total 

Beginning of 
the year 

Granted 

Lapsed 

No. 

No. 

4,236,976
3,859,861

2,236,439
1,597,584

No. 

(199,142)
(345,176)

Vested 

No. 

(78,622)
(875,293)

End of the 
year

No. 

6,195,651
4,236,976

275

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Financial Statements
Section 7: People

7.2 Share-based payment plans (continued)

iv.  Other equity grants (continued)

The other SARs granted during the year are as follows:

Continuous service period

Grant date

2024

SARs

Vesting

Grant date
11 Apr 2024

granted Commencing
1 Jan 2024
409,033

Expiring

date
31 Dec 2026 31 Dec 2026

26 Jul 2024

1,359,760

1 Jan 2024

31 Dec 2026 31 Dec 2026

9 Aug 2024

11 Sep 2024

301,582

166,064

1 Jan 2024

31 Dec 2026 31 Dec 2026

1 Jul 2024 30 Jun 2027 30 Jun 2027

Share

price
7.84

7.74

7.69

6.85

Fair

Dividend

value
7.84

7.74

7.69

6.85

yield
– 

– 

– 

– 

7.3 Key Management Personnel disclosures

(a) Key Management Personnel compensation

Short-term benefits

Retirement benefits

Other long-term benefits

Termination benefits

Share-based payments

2024

US$000

5,747

184

120

158

4,873

11,082

2023

US$000

7,103

202

171

183

4,773

12,432

276

Santos Annual Report 2024 
 
 
 
Notes to the Consolidated Financial Statements
Section 8: Other

This section provides information that is not directly related to the specific line items in the financial statements, including 
information about contingent liabilities, events after the end of the reporting period, remuneration of auditors and changes 
to accounting policies and disclosures.

8.1 Contingent liabilities

Contingent liabilities arise in the ordinary course of business through claims against the Group, including contractual, 
third-party and contractor claims. In most instances it is not possible to reasonably predict the outcome of these claims.  
As at reporting date, the Group believes that the aggregate of such claims will not materially impact the Group's Financial 
Report.

8.2 Events after the end of the reporting period

On 18 February 2025, the Directors of Santos Limited resolved to pay a final dividend of US$10.3 cents in respect of the 
2024 financial year. Consequently, the financial effect of these dividends has not been brought to account in the full-year 
financial statements for the year ended 31 December 2024. Refer to Note 2.6 for details.

8.3 Remuneration of auditors

The auditor of Santos Limited is Ernst & Young.

(a) Audit and review services 

 Amounts received or due and receivable for an audit or review of the financial report of the entity and any other entity 
in the Group by:

Audit of statutory report of Santos Limited Group

Audit of statutory report of controlled entities

2024

US$000

1,210

812

2,022

2023

US$000

1,209

795

2,004

(b) Other services 

  Amounts received or due and receivable for other services in relation to the entity and any other entity in the Group by:

Ernst & Young for other assurance services

Ernst & Young (Australia) for taxation compliance services

Ernst & Young (Australia) for other services

2024

US$000

1,969

301

99

2,369

2023

US$000

1,328

259

113

1,700

277

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Notes to the Consolidated Financial Statements
Section 8: Other

8.4 Accounting policies

(a) Changes in accounting policies and disclosures 

 The Group applied the following amendment to accounting standards applicable for the first time for the financial year 
beginning 1 January 2024:

•  Amendments to AASB 101 – Classification of Liabilities as Current or Non-current

 This amendment did not have a significant or immediate impact on the Group’s annual consolidated financial 
statements or half-year condensed financial statements.

(b) New standards and interpretations not yet adopted 

 A number of new standards, amendments to standards and interpretations are effective for annual reporting periods 
beginning on or after 1 January 2025 and have not been applied in preparing these consolidated financial statements. 
The Group’s assessment of the impact of these new standards, amendments to standards and interpretations is set out 
below.

i) AASB 2024-2 Amendments to AASB 7 and AASB 9 – Classification and Measurement of Financial Instruments
Description

The amendments clarify the following:

•  that a financial liability is derecognised on the ‘settlement date’, being when the 
related obligation is discharged, cancelled, expires or the liability otherwise 
qualifies for derecognition 

•  how to assess the contractual cash flow characteristics of financial assets that 

include environmental, social and governance linked features

•  the treatment of non-recourse assets and contractually linked instruments

•  requirements for additional disclosures for financial assets and liabilities with 

contractual terms that reference a contingent event.

Impact on Group  

Financial Report

Management has not yet assessed the impact of this amendment on the Group’s 
results or disclosures.

Application of standard

1 January 2026

 Several other amendments to standards and interpretations will apply on or after 1 January 2025, and have not yet been 
applied, however they are not expected to impact the Group’s annual consolidated financial statements. 

(c) Australian sustainability reporting standards

 The Australian Accounting Standards Board (AASB) issued the final Australian Sustainability Reporting Standards 
(ASRS) in September 2024, following a consultation period relating to the draft ASRSs (Exposure Draft ED SR1) that 
ended in March 2024.

 The climate-related financial disclosures legislation Treasury Laws Amendment (Financial Market Infrastructure and 
Other Measures) Act 2024 received Royal Assent in early September 2024. The Act mandates relevant entities to 
disclose their climate-related plans, financial risks and opportunities, in accordance with ASRS made by the AASB.

The first ASRS were also issued in September 2024 by the AASB and comprise: 

•  ASRS 1 General Requirements for Disclosure of Climate-related Financial Information

•  ASRS 2 Climate-related Financial Disclosures 

 The Group is in the process of finalising a gap assessment from current reporting to the requirements of the new 
standards noted above, to ensure appropriate disclosures are made for the period commencing 1 January 2025.

278

Santos Annual Report 2024 
 
 
 
 
 
 
 
 
Consolidated Entity Disclosure Statement
for the year ended 31 December 2024

Basis of preparation: This consolidated entity disclosure statement (CEDS) has been prepared in accordance with the 
Corporations Act 2001 and includes information for each entity that was part of the consolidated entity as at the end of the 
financial year in accordance with AASB 10 Consolidated Financial Statements.

Name
Santos Limited
Alliance Petroleum Australia Pty Ltd
Basin Oil Pty Ltd
Bridgefield Pty Ltd 
Bridge Oil Developments Pty Ltd
Bronco Energy Pty Ltd
Doce Pty Ltd
Fairview Pipeline Pty Ltd
Moonie Pipeline Company Pty Ltd
Papuan Oil Search Ltd
Oil Search (Uramu) Pty Ltd
Oil Search (USA) Inc
Oil Search (Alaska) LLC1
Santos Pipelines (Alaska) LLC1
Oil Search Ltd
Oil Search (Middle Eastern) Ltd2
Oil Search (Iraq) Ltd2
Oil Search (Libya) Ltd2
Oil Search (Tunisa) Ltd2
Oil Search (Newco) Ltd2
Oil Search (Gas Holdings) Ltd
Oil Search (Tumbudu) Ltd
Oil Search Highlands Power Ltd
Oil Search (PNG) Ltd
Oil Search (Drilling) Ltd
Oil Search (Exploration) Inc2
Oil Search (LNG) Ltd
Oil Search Finance Ltd2
Oil Search Power Holdings Ltd
PNG Biomass Ltd
Markham Valley Renewables Ltd
Santos Foundation Ltd
Pac LNG Investments Ltd
Pac LNG Assets Ltd
Pac LNG International Ltd
Pac LNG Overseas Ltd
Pac LNG Holdings Ltd
Reef Oil Pty Ltd
Santos Australian Hydrocarbons Pty Ltd
Santos (BOL) Pty Ltd
Santos Browse Pty Ltd
Santos CSG Pty Ltd
Santos Darwin LNG Pty Ltd
Santos Direct Pty Ltd 
Santos Finance Ltd
Santos Foundation Pty Ltd
Santos GLNG Pty Ltd
Santos International Holdings Pty Ltd
Santos Americas and Europe LLC
Santos TPY LLC
Santos Queensland LLC
Santos TOG LLC
Santos TPY CSG LLC
Barracuda Ltd
Sanro Insurance Pte Ltd 
Santos Bangladesh Ltd 

Country of 
incorporation

Entity type
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
USA Body Corporate
USA Body Corporate
USA Body Corporate
PNG Body Corporate
BVI Body Corporate
BVI Body Corporate
BVI Body Corporate
BVI Body Corporate
BVI Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
CI Body Corporate
PNG Body Corporate
BVI Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
PNG Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
USA Body Corporate
USA Body Corporate
USA Body Corporate
USA Body Corporate
USA Body Corporate
PNG Body Corporate
SGP Body Corporate
GBR Body Corporate

Country  
of tax 
residence
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
USA
N/A
N/A
PNG
N/A
N/A
N/A
N/A
N/A
PNG
PNG
PNG
PNG
PNG
N/A
PNG
N/A
PNG
PNG
PNG
PNG
PNG
PNG
PNG
PNG
PNG
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
PNG
SGP
GBR

% of share 
capital held
N/A
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100

279

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationConsolidated Entity Disclosure Statement
for the year ended 31 December 2024

Name
Santos (UK) Ltd 
Santos Northwest Natuna B.V. 
Santos NA (19-12) Pty Ltd 
Santos NA (19-13) Pty Ltd 
Santos NA Bayu Undan Pty Ltd 
Santos NA Emet Pty Ltd 
Santos NA Timor Sea Pty Ltd 
Santos NA Timor Leste Pty Ltd 
Santos Hides Ltd 
Santos P’nyang Ltd 
Santos Sangu Field Ltd 
Santos Singapore Hold Co Pte Ltd3
Santos SG Trading Pte Ltd
Santos Singapore Shipping Pte Ltd
Santos Vietnam Pty Ltd
Santos TOGA Pty Ltd
Santos (JPDA 91-12) Pty Ltd
Santos Midstream Holdings Pty Ltd
Santos Devil Creek Pty Ltd
Santos Resources Pty Ltd
Santos Infrastructure Holdings Pty Ltd 
Santos Midstream Asset Holdings Pty Ltd 
Santos Infrastructure WAQ Holdings Pty Ltd 
Santos Infrastructure WAQVIDC Pty Ltd 
Santos Infrastructure WAQ Assets Pty Ltd 
Santos Infrastructure West Holdings Pty Ltd 
Santos Infrastructure WASDCA Pty Ltd 
Santos Infrastructure WASVIA Pty Ltd 
Santos (NARNL Cooper) Pty Ltd
Santos NSW Pty Ltd 
Santos NSW (Betel) Pty Ltd 
Santos NSW (Hillgrove) Pty Ltd 
Santos NSW (Holdings) Pty Ltd 
Santos NSW (LNGN) Pty Ltd 
Santos NSW (Pipeline) Pty Ltd 
Santos NSW (Narrabri Energy) Pty Ltd 
Santos NSW (Eastern) Pty Ltd 
Hunter Gas Pipeline Pty Ltd 
Santos NSW (Narrabri Gas) Pty Ltd 
Santos NSW (Narrabri Power) Pty Ltd 
Santos NSW (Operations) Pty Ltd 
Santos (N.T.) Pty Ltd 
Bonaparte Gas & Oil Pty Ltd 
Santos Offshore Pty Ltd
BAFF Pty Ltd
Santos Petroleum Pty Ltd
Santos QLD Upstream Developments Pty Ltd 
Santos QNT Pty Ltd
Outback Energy Hunter Pty Ltd 
Santos QNT (No. 1) Pty Ltd 
Santos QNT (No. 2) Pty Ltd
Petromin Pty Ltd
Santos Wilga Park Pty Ltd
Santos (TGR) Pty Ltd
Santos Timor Sea Pipeline Pty Ltd
Santos Ventures Pty Ltd
Santos WA Holdings Pty Ltd
Santos KOTN Holdings Pty Ltd
Santos KOTN Pty Ltd

280

Country of 
incorporation

Entity type
GBR Body Corporate
NDL Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
PNG Body Corporate
PNG Body Corporate
GBR Body Corporate
SGP Body Corporate
SGP Body Corporate
SGP  Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate

Country  
of tax 
residence
GBR
NDL
AUS
AUS
AUS
AUS
AUS
AUS
PNG
PNG
GBR
N/A
SGP
SGP 
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS

% of share 
capital held
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100

Santos Annual Report 2024Name
Santos Agency Pty Ltd
Santos NA Barossa Pty Ltd
Santos NA Browse Basin Pty Ltd
Santos Singapore Management Pte Ltd
Santos NA Energy Holdings Pty Ltd
Santos NA Energy Pty Ltd
Santos NA Asset Holdings Pty Ltd
Santos NA Assets Pty Ltd
Santos NA Darwin Pipeline Pty Ltd
Santos WA AEC Pty Ltd
Santos WA Energy Holdings Pty Ltd
Santos WA Asset Holdings Pty Ltd
Santos WA Lowendal Pty Ltd
Santos WA International Pty Ltd
Harriet (Onyx) Pty Ltd
Santos WA Energy Ltd
Ningaloo Vision Holdings Pte Ltd 
Northwest Jetty Services Pty Ltd 
Santos WA DC Pty Ltd
Santos WA (Exmouth) Pty Ltd 
Santos WA East Spar Pty Ltd
Santos WA Julimar Holdings Pty Ltd 
Santos WA Kersail Pty Ltd
Santos WA LNG Pty Ltd 
Santos WA Management Pty Ltd 
Santos WA Finance Holdings Pty Ltd 
Santos WA Finance General Partnership 
Santos WA Northwest Pty Ltd
Santos WA Onshore Holdings Pty Ltd 
Santos WA PVG Holdings Pty Ltd
Santos WA PVG Pty Ltd
Santos WA Southwest Pty Ltd
Santos WA Varanus Island Pty Ltd
SESAP Pty Ltd
Vamgas Pty Ltd
Santos Infrastructure Holdings Trust
Santos Infrastructure West Holdings Trust
Santos Infrastructure WAQ Holdings Trust
Santos Infrastructure WAQ Asset Trust
Santos Infrastructure WASDCA Trust
Santos Infrastructure WASVIA Trust
Santos Infrastructure WAQDCA Trust
Santos Infrastructure WAQVIA Trust
Santos Infrastructure Operating Trust
Santos Infrastructure WAQDCB Trust
Santos Infrastructure WAQVIB Trust

Notes

Country of 
incorporation

Entity type
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
SGP Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
SGP Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
AUS Body Corporate
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS
Trust
AUS

Country  
of tax 
residence
AUS
AUS
AUS
SGP
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS
AUS

% of share 
capital held
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A

1 

2 

3 

 This entity is treated as a disregarded entity for US federal tax purposes and therefore cannot be characterised as a tax resident in the US in its own right. 
However, it is 100 per cent owned by Oil Search (USA) Inc, which reports the income and deductions of the LLC and pays tax on that income in its US federal 
returns.

 In the British Virgin Islands and the Cayman Islands, there are no taxation rules determining residency and, therefore, corporate taxation residency is not relevant in 
the context of this entity.

 In Singapore, tax residency is determined based on where an entity’s central management and control is located. As no central management and control was 
exercised for this entity, it is not a tax resident of any country.

Country of incorporation / residence

AUS  
BVI   
CI 
GBR  
NDL  
PNG  
SGP  
USA  

Australia 
British Virgin Islands  
Cayman Islands 
United Kingdom 
Netherlands 
Papua New Guinea 
Singapore 
United States of America

281

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Directors’ Declaration
for the year ended 31 December 2024

In accordance with a resolution of the Directors of Santos Limited (the Company), we state that:

1. 

In the opinion of the Directors:

(a)  the financial statements and notes of the consolidated entity are in accordance with the Corporations Act 2001 (Cth), 

including:

(i)   giving a true and fair view of the consolidated entity’s financial position as at 31 December 2024 and of its 

performance for the year ended on that date

(ii)  complying with Accounting Standards and the Corporations Regulations 2001 (Cth)

(b) the financial statements and notes comply with International Financial Reporting Standards as disclosed in Note 1.1 ;

(c)   the consolidated entity disclosure statement required by section 295(3A) of the Corporations Act 2001 (Cth) is true 

and correct; and

2. 

3. 

(d)  there are reasonable grounds to believe that the Company will be able to pay its debts as and when they become 

due and payable.

 This declaration has been made after receiving the declarations required to be made to the Directors in accordance with 
Section 295A of the Corporations Act 2001 (Cth) for the financial year ended 31 December 2024.

 As at the date of this declaration, there are reasonable grounds to believe that the members of the Closed Group 
identified in Note 6.7 will be able to meet any obligations or liabilities to which they are or may become subject to by 
virtue of the Deed of Cross Guarantee between the Company and those members of the Closed Group pursuant to 
ASIC Corporations (Wholly-owned Companies) Instrument 2016/785.

Dated this 18th day of February 2025 on behalf of the Board:

Director

282

Santos Annual Report 2024 
 
 
 
 
 
 
 
Independent Auditor’s Report
to the Members of Santos Limited

Ernst & Young 
121 King William Street 
Adelaide SA 5000 Australia 
GPO Box 1271 Adelaide SA 5001

Tel: +61 8 8417 1600 
Fax: +61 8 8417 1775 
ey.com/au

Report on the audit of the Financial Report

Opinion

We have audited the financial report of Santos Limited (the Company) and its subsidiaries (collectively the Group), which 
comprises the consolidated statement of financial position as at 31 December 2024, the consolidated income statement, the 
consolidated statement of comprehensive income, consolidated statement of changes in equity and consolidated statement 
of cash flows for the year then ended, notes to the consolidated financial statements, including material accounting policy 
information, the consolidated entity disclosure statement and the directors’ declaration.

In our opinion, the accompanying financial report of the Group is in accordance with the Corporations Act 2001, including:

a. 

 Giving a true and fair view of the consolidated financial position of the Group as at 31 December 2024 and of its 
consolidated financial performance for the year ended on that date; and

b.   Complying with Australian Accounting Standards and the Corporations Regulations 2001.

Basis for Opinion

We conducted our audit in accordance with Australian Auditing Standards. Our responsibilities under those standards are 
further described in the Auditor’s responsibilities for the audit of the financial report section of our report. We are 
independent of the Group in accordance with the auditor independence requirements of the Corporations Act 2001 and the 
ethical requirements of the Accounting Professional and Ethical Standards Board’s APES 110 Code of Ethics for Professional 
Accountants (including Independence Standards) (the Code) that are relevant to our audit of the financial report in 
Australia. We have also fulfilled our other ethical responsibilities in accordance with the Code. 

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Key Audit Matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the 
financial report of the current year. These matters were addressed in the context of our audit of the financial report as a 
whole, and in forming our opinion thereon, but we do not provide a separate opinion on these matters. For each matter 
below, our description of how our audit addressed the matter is provided in that context.

We have fulfilled the responsibilities described in the Auditor’s responsibilities for the audit of the financial report section of 
our report, including in relation to these matters. Accordingly, our audit included the performance of procedures designed 
to respond to our assessment of the risks of material misstatement of the financial report. The results of our audit 
procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on 
the accompanying financial report.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

283

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Auditor’s Report
to the members of Santos Limited

Carrying values of exploration and evaluation, oil and gas assets and goodwill

Why significant
Australian Accounting Standards 
require the Group to assess in respect 
of the reporting period, whether 
there is any indication that an asset 
may be impaired, or conversely 
whether reversal of a previously 
recognised impairment may be 
required. If any such indication exists, 
an entity shall estimate the 
recoverable amount of the asset or 
Cash Generating Unit (CGU).

At year end, the Group identified 
impairment indicators in respect of 
one CGU. Where required, impairment 
testing was undertaken, which 
resulted in an impairment charge of 
$87m being recognised, as disclosed 
in Note 3.4 of the financial report. 

The Group also identified impairment 
indicators in respect of certain 
exploration and evaluation assets. 
The impairment testing of those 
assets resulted in an impairment 
charge of $36m being recorded 
during the year, as set out in Note 3.4 
of the financial report.

The assessments for indicators of 
impairment and reversals of 
impairment are judgmental and 
include assessing a range of external 
and internal factors.

Where impairment indicators are 
identified, forecasting cash flows for 
the purpose of determining the 
recoverable amount of a CGU 
involves critical accounting estimates 
and judgements and is affected by 
expected future performance and 
market conditions. The key forecast 
assumptions, including commodity 
prices, discount rates, foreign 
exchange rates and recoverable 
hydrocarbon reserves used in the 
Group’s impairment assessment are set 
out in the financial report in Note 3.4.

We considered the impairment 
testing of the Group’s CGUs and its 
exploration and evaluation assets, 
and the related disclosures in the 
financial report, to be a key audit 
matter.

How our audit addressed the key audit matter
Assessing indicators of impairment

We evaluated whether there had been significant changes to the external or internal 
factors considered by the Group, in assessing whether indicators of impairment or 
reversal of impairment existed. Those indicators included specific matters related to 
the Group, CGUs and industry as well as broader market-based indicators.

Impairment testing of CGUs with goodwill and those for which triggers were identified

We focused on the composition of the forecast cash flows and the reasonableness of 
key inputs used to formulate recoverable amounts. Depending on the CGU, these 
procedures included:

•  Reconciling future production profiles to the latest hydrocarbon reserves and 

resources estimates (discussed further below), current sanctioned development 
budgets, long-term asset plans and historical operations.

• 

Independently developing a reasonable range of forecast oil and gas prices, based 
upon external data. We compared this range to the Group’s forecast oil and gas 
price assumptions to challenge whether the Group’s assumptions were reasonable. 
In developing our ranges, we obtained a variety of reputable third-party forecasts, 
peer information and market data, which contemplate forecast oil and gas demand 
in a decarbonising global economy.

• 

Independently evaluating discount rates used by the Group for impairment tests, 
which contemplate costs of capital considerations in light of a decarbonising global 
economy.

• 

Independently evaluating the reasonableness of inflation rates, foreign exchange 
rates and carbon costs used by the Group for impairment tests

•  Understanding the operational performance of the CGUs relative to plan, 

comparing future operating and development expenditure within the impairment 
assessments to current sanctioned budgets, historical expenditures and long-term 
asset plans and ensuring the Group’s judgements were within our expectations 
based upon other information obtained throughout the audit.

•  Examining the key drivers of changes to calculated recoverable amounts and 

ensuring the reasonableness of those drivers’ assumptions.

•  Testing the mathematical accuracy of the Group’s discounted cash flow models and 
their compliance with the requirements of the Australian Accounting Standards. 

Future production profiles 

A key input to impairment assessments is the Group’s production forecast, which is 
closely related to the Group’s hydrocarbon reserves and resource estimates and 
development plans. Our audit procedures focused on the work of the Group’s 
internal and external experts and included:

•  Assessing the processes and controls associated with estimating reserves and 

resources.

•  Reading reports provided by internal and external experts and assessing their 

scopes of work and findings.

•  Assessing the qualifications, competence and objectivity of the Group’s internal 

and external experts involved in the estimation process. 

•  Considering whether key economic assumptions used in the estimation of 

reserves and resources volumes were consistent with those used by the Group in 
the impairment testing of oil and gas assets and goodwill, where applicable. 

•  Understanding the reasons for reserve changes or the absence of reserves changes, 

for consistency with other information that we obtained throughout the audit.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

284

Santos Annual Report 2024Why significant

How our audit addressed the key audit matter
Impact of Climate-Related Risks

In undertaking our impairment procedures, we incorporated consideration of climate 
change-related risks by:

•  Performing independent sensitivity analysis of recoverable amounts across a 

range of key inputs which have been formulated to incorporate uncertainty risk 
associated with climate change, such as the inclusion of premiums in discount 
rates and alternative oil price forecasts which contemplate varied climate 
change-related assumptions and scenarios. 

•  Assessing the recoverable amount impact of the inclusion of carbon costs, 

including consideration of differing quantities of the Group’s carbon emissions 
subject to a carbon cost. 

•  Considering the audit results of procedures carried out over restoration and 
rehabilitation obligations and their impact on impairment risk (refer to the 
‘Accounting for Restoration Obligations’ Key Audit Matter below).

• 

Inquiring of management and reading the Group’s communications and publicly 
stated climate-related commitments regarding climate-related risks where 
relevant and their impact on financial reporting;

•  Reading the ‘other information’ presented by the Group, for consistency with key 

inputs used in the Group’s impairment testing. 

Exploration and Evaluation Assets

For exploration and evaluation assets, we assessed whether any impairment 
indicators, as set out in AASB 6 Exploration for and Evaluation of Mineral Resources, 
were present, and performed audit procedures in respect of the conclusions reached 
by management, including:

•  Considering whether the Group’s right to explore was current, which included 

obtaining and assessing supporting documentation such as licenses, permits and 
agreements. 

•  Considering the Group’s intention to carry out significant ongoing exploration and 

evaluation activities in the relevant areas of interest and enquiring of senior 
management as to their intentions and the strategy of the Group as it relates to 
particular areas of interest.

•  Assessing whether exploration and evaluation data, commercial, technical, 

climate-related or other information existed to indicate that the carrying value of 
capitalised exploration and evaluation assets was unlikely to be recovered 
through successful evaluation and development or sale.

With respect to impairment generally, we also assessed the adequacy of the financial 
report disclosures regarding the assumptions, key estimates and judgments applied 
by the Group in relation to the carrying values of exploration and evaluation, oil and 
gas assets and goodwill.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

285

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Auditor’s Report
to the members of Santos Limited

Accounting for Restoration Obligations

Why significant
At 31 December 2024, the Group has 
recognised provisions for restoration 
obligations relating to onshore and 
offshore assets of $4,146 million. As 
disclosed in Note 3.5, the calculation 
of restoration provisions is conducted 
by specialist engineers and requires 
judgemental assumptions to be made 
by the Group regarding removal date, 
compliance with environmental 
legislation and regulations, the extent 
of restoration activities required, the 
engineering methodology for 
estimating costs, future removal 
technologies in determining the 
removal costs and liability-specific 
discount rates to determine the 
present value of these cash flows. 

How our audit addressed the key audit matter
We assessed the restoration obligation provisions prepared by the Group, 
evaluating the assumptions and methodologies used and the estimates made. Our 
audit procedures included the following: 

•  Evaluating the Group’s process for identifying its legal and regulatory obligations 
for restoration and decommissioning and testing the completeness of operating 
locations.

•  Understanding and testing controls over the Group’s internal methodology for 
determining and approving gross cost estimates used to calculate the Group’s 
restoration provisions.

• 

In conjunction with our environmental specialists, assessing the reasonableness 
and completeness of restoration cost estimates based on the relevant current 
legal and regulatory requirements.

•  Assessing the competence, capability and objectivity of the Group’s internal and 
external experts engaged to carry out the gross restoration cost estimations as a 
basis for our reliance on the output of their work.

•  Comparing current year cost estimates to those of the prior year and 

considering explanations by management and both internal and external experts 
for observed changes.

•  Comparing the timing of the future cash outflows against the anticipated 

end-of-field lives, cross-checking that these dates were consistent with the 
Group’s reserve estimates and impairment calculations.

•  Evaluating the appropriateness of the discount rates, inflation rates and foreign 
exchange rates used to calculate the present value of each of the provisions.

•  Testing the mathematical accuracy of the restoration provision calculations.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

286

Santos Annual Report 2024How our audit addressed the key audit matter
Impact of Climate-Related Risks

In undertaking our restoration procedures, we incorporated consideration of 
climate change-related risks by:

•  Understanding the regulatory framework in which each project operates to 

ensure compliance with the regulatory requirements of the various jurisdictions 
as they relate to restoration obligations.

•  Evaluating the assumptions associated with the form and extent of 

abandonment activities, including conformity with regulation and industry 
practice and the nature of the items expected to be left in-situ, in abandonment 
activities.

•  Reading litigation registers, correspondence with solicitors and regulators to 

confirm the completeness of liabilities recognised.

•  Considering the estimated dates for the commencement of restoration and 

rehabilitation activities, possible impacts of physical risks of climate change and 
performing sensitivity analyses aligned with a range of scenarios associated with 
the Group’s net zero climate-related targets. 

We also considered the adequacy and completeness of the financial report 
disclosure of the assumptions, key estimates and judgements applied by the Group.

Why significant
The judgements and estimates in 
respect of restoration provisions are 
based upon conditions existing at 31 
December 2024, including key 
assumptions related to certain items 
remaining in-situ. Australian 
regulatory approval for these items 
remaining in-situ will only be sought 
towards the end of the respective 
asset’s field life and accordingly, at 31 
December 2024, there is uncertainty 
whether the Australian regulator will 
approve plans for these items to be 
decommissioned in-situ. 

The significant assumptions and 
estimates outlined above are 
inherently subjective. Changes to 
these assumptions can lead to 
changes in the restoration provisions. 
In this context, the disclosures in the 
financial report provide important 
information about the assumptions 
made in the calculation of the 
restoration provision and uncertainties 
at 31 December 2024, in arriving at 
the Group’s best estimate of the 
present value of future obligations. 

We consider the restoration provision 
calculation and the related disclosures 
in the financial report to be a key 
audit matter. We draw attention to the 
information in Note 3.5.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

287

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationIndependent Auditor’s Report
to the members of Santos Limited

Information Other than the Financial Report and Auditor’s Report thereon

The directors of the Company are responsible for the preparation of:

•  The financial report (other than the consolidated entity disclosure statement) that gives a true and fair view in 

accordance with Australian Accounting Standards and the Corporations Act 2001; and

•  The consolidated entity disclosure statement that is true and correct in accordance with the Corporations Act 2001; and

for such internal control as the directors determine is necessary to enable the preparation of:

•  The financial report (other than the consolidated entity disclosure statement) that gives a true and fair view and is free 

from material misstatement, whether due to fraud or error; and

•  The consolidated entity disclosure statement that is true and correct and is free of misstatement, whether due to fraud 

or error.

In preparing the financial report, the directors are responsible for assessing the Group’s ability to continue as a going 
concern, disclosing, as applicable, matters relating to going concern and using the going concern basis of accounting unless 
the directors either intend to liquidate the Group or to cease operations, or have no realistic alternative but to do so.

Responsibilities of the Directors for the Financial Report

The directors of the Company are responsible for the preparation of the financial report that gives a true and fair view in 
accordance with Australian Accounting Standards and the Corporations Act 2001 and for such internal control as the 
directors determine is necessary to enable the preparation of the financial report that gives a true and fair view and is free 
from material misstatement, whether due to fraud or error.

In preparing the financial report, the directors are responsible for assessing the Group’s ability to continue as a going 
concern, disclosing, as applicable, matters relating to going concern and using the going concern basis of accounting unless 
the directors either intend to liquidate the Group or to cease operations, or have no realistic alternative but to do so.

Auditor’s Responsibilities for the Audit of the Financial Report

Our objectives are to obtain reasonable assurance about whether the financial report as a whole is free from material 
misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable 
assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with the Australian 
Auditing Standards will always detect a material misstatement when it exists. Misstatements can arise from fraud or error 
and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the 
economic decisions of users taken on the basis of this financial report.

As part of an audit in accordance with the Australian Auditing Standards, we exercise professional judgment and maintain 
professional scepticism throughout the audit. We also:

• 

Identify and assess the risks of material misstatement of the financial report, whether due to fraud or error, design and 
perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to 
provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for 
one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override 
of internal control.

•  Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate 

in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group’s internal 
control. 

•  Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related 

disclosures made by the directors.

•  Conclude on the appropriateness of the directors’ use of the going concern basis of accounting and, based on the audit 
evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt 
on the Group’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required 
to draw attention in our auditor’s report to the related disclosures in the financial report or, if such disclosures are 
inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our 
auditor’s report. However, future events or conditions may cause the Group to cease to continue as a going concern. 

•  Evaluate the overall presentation, structure and content of the financial report, including the disclosures, and whether 
the financial report represents the underlying transactions and events in a manner that achieves fair presentation.

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

288

Santos Annual Report 2024•  Plan and perform the Group audit to obtain sufficient appropriate audit evidence regarding the financial information of 
the entities or business units within the Group as a basis for forming an opinion on the Group financial report. We are 
responsible for the direction, supervision and review of the audit work performed for the purposes of the Group audit. 
We remain solely responsible for our audit opinion. 

We communicate with the directors regarding, among other matters, the planned scope and timing of the audit and 
significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

We also provide the directors with a statement that we have complied with relevant ethical requirements regarding 
independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear 
on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.

From the matters communicated to the directors, we determine those matters that were of most significance in the audit of 
the financial report of the current year and are therefore the key audit matters. We describe these matters in our auditor’s 
report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we 
determine that a matter should not be communicated in our report because the adverse consequences of doing so would 
reasonably be expected to outweigh the public interest benefits of such communication.

Report on the Audit of the Remuneration Report

Opinion on the Remuneration Report

We have audited the Remuneration Report included on pages 169 to 203 of the directors’ report for the year ended 
31 December 2024.

In our opinion, the Remuneration Report of Santos Limited for the year ended 31 December 2024, complies with section 
300A of the Corporations Act 2001.

Responsibilities

The directors of the Company are responsible for the preparation and presentation of the Remuneration Report in 
accordance with section 300A of the Corporations Act 2001. Our responsibility is to express an opinion on the 
Remuneration Report, based on our audit conducted in accordance with Australian Auditing Standards.

Ernst & Young

D S Lewsen 
Partner 

Adelaide 
18 February 2025

D Hall
Partner 

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

289

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
Auditor’s independence declaration
to the Directors of Santos Limited

Ernst & Young 
11 Mounts Bay Road 
Perth WA 6000 Australia 
GPO Box M939 Perth WA 6843

Tel: +61 8 9429 2222 
Fax: +61 8 9429 2436 
ey.com/au

As lead auditor for the audit of the financial report of Santos Limited for the financial year ended 31 December 2024,  
I declare to the best of my knowledge and belief, there have been:

a.  No contraventions of the auditor independence requirements of the Corporations Act 2001 in relation to the audit; 

b.  No contraventions of any applicable code of professional conduct in relation to the audit; and

c.  No non-audit services provided that contravene any applicable code of professional conduct in relation to the audit.

This declaration is in respect of Santos Limited and the entities it controlled during the financial year.

Ernst & Young

D S Lewsen
Partner

18 February 2025

A member firm of Ernst & Young Global Limited 
Liability limited by a scheme approved under Professional Standards Legislation

290

Santos Annual Report 2024 
O
v
e
r
v
e
w

i

O
u
r
b
u
s
i
n
e
s
s

S
u
s
t
a
n
a
b

i

i
l
i
t
y
R
e
p
o
r
t

C

l
i

m
a
t
e
R
e
p
o
r
t

G
o
v
e
r
n
a
n
c
e

R
e
s
e
r
v
e
s
S
t
a
t
e
m
e
n
t

D
i
r
e
c
t
o
r
s

’

R
e
p
o
r
t

R
e
m
u
n
e
r
a
t
i
o
n
R
e
p
o
r
t

i

F
n
a
n
c
a

i

l

R
e
p
o
r
t

A
d
d
i
t
i
o
n
a
l

I
n
f
o
r
m
a
t
i
o
n

SHAREHOLDER 
AND  
ADDITIONAL  
INFORMATION 

Santos Annual Report 2024

291

OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional Information 
 
 
 
 
 
 
 
Securities exchange
and shareholder information

Listed on the Australian Securities Exchange at 31 January 2025 were 3,247,772,961 fully-paid ordinary Santos Limited 
shares. Unlisted were 5,000 partly-paid Plan 0 shares and 5,000 partly-paid Plan 2 shares.

There were 163,218 holders of all classes of issued ordinary shares, including: one holder of Plan 0 shares; one holder of Plan 
2 shares.

As at 31 January 2025 there were also: 1,817 holders of 19,322,395 Share Acquisition Rights pursuant to the SEEIP and 1,390 
holders of 2,100,983 Share Acquisition Rights pursuant to the ShareMatch Plan.

The listed issued ordinary shares plus the ordinary shares issued pursuant to the SEEIP, and the restricted shares issued 
pursuant to the SESPP and ShareMatch Plan represent all of the voting power in Santos. The holdings of the 20 largest 
holders of ordinary shares represent 77.09 per cent of the total voting power in Santos (77.74 per cent on 31 January 2024). 
The largest shareholders of fully-paid ordinary shares in Santos as shown in the Company’s Register of Members at 31 
January 2025 were:

Name
HSBC Custody Nominees (Australia) Limited

J P Morgan Nominees Australia Pty Limited

Citicorp Nominees Pty Limited

National Nominees Limited

BNP Paribas Nominees Pty Ltd 

Citicorp Nominees Pty Limited  

BNP Paribas Noms Pty Ltd

Argo Investments Limited

HSBC Custody Nominees (Australia) Limited 

BNP Paribas Nominees Pty Ltd 

BNP Paribas Nominees Pty Ltd 

BNP Paribas Noms Pty Ltd Deutsche Bank Tca

Merrill Lynch (Australia) Nominees Pty Limited

HSBC Custody Nominees (Australia) Limited

Netwealth Investments Limited 

HSBC Custody Nominees (Australia) Limited - A/C 2

Australian Foundation Investment Company Limited

HSBC Custody Nominees (Australia) Limited-Gsco Eca

CPU Share Plans Pty Ltd 

Netwealth Investments Limited 

Totals: Top 20 holders of ordinary fully paid shares (Total) 

Total remaining holders balance 

Balance at  
31 January 
2025
1,078,789,773

585,950,972

468,817,575

57,420,388

38,378,093

36,384,824

35,567,772

29,512,995

23,781,442

22,369,494

21,758,365

21,511,588

18,724,948

12,859,735

11,926,806

9,892,161

9,589,773

8,834,503

6,347,630

5,424,770

2,503,843,607

743,929,354

Percentage of 
share capital
33.22

18.04

14.44

1.77

1.18

1.12

1.10

0.91

0.73

0.69

0.67

0.66

0.58

0.40

0.37

0.30

0.30

0.27

0.20

0.17

77.09

22.91

292

Santos Annual Report 2024Securities exchange
and shareholder information

Analysis of shares – range of shares held

1–1,000

1,001–5,000

5,001–10,000

10,001–100,000

100,001 over

Rounding

Total

Fully-paid 
ordinary 
shares 
(holders)
70,704

Number of 
shares held
30,586,730

Percentage of 
shares held
0.94

62,367

155,628,283

17,106

12,634

123,411,537

276,104,576

407 2,662,041,835

4.79

3.80

8.50

81.97

163,218

3,247,772,961

100.00

Less than a marketable parcel of $500

4,584

Distribution of rights holdings and number of rights holders

The following table shows the distribution of rights holders in Santos Limited by size of rights holding and number of rights 
holders and rights as at 31 January 2025:

1–1,000

1,001–5,000

5,001–10,000

10,001–100,000

100,001 over

Total

Number of 
rights holders
988

Number  
of rights
653,445

Percentage of 
rights on issue
3.05

1,495

52

160

45

3,109,803

384,454

5,718,452

11,557,224

14.52

1.79

26.69

53.95

2,740

21,423,378

100.00

During the year, 3,000,000 shares were purchased on-market at an average price of $7.3398 per share for the purposes of 
the Company's employee share arrangements. As at 31 January 2025, the Company does not have any restricted securities 
or securities subject to voluntary escrow on issue.

On-market share acquisitions

There is no current on-market buy-back of shares.

Substantial shareholders as disclosed by notices received by the Company as at 31 January 2025:

Name
BlackRock Group

Vanguard Group (The Vanguard Group, Inc. and its controlled entities) 

State Street Corporation and subsidiaries

Number of  
shares held
129,700,122

165,560,037

199,610,157

Date of notice
30 March 2021

3 April 2023

6 September 2024

For Directors’ shareholdings see the Corporate Governance Statement as set out on page 133 of this Annual Report.

Voting rights

Every member present in person, or by an attorney, a proxy or a representative, shall on a show of hands, have one vote and 
upon a poll, one vote for every fully-paid ordinary share held. Pursuant to the Rules of the Santos Executive Share Plan, Plan 
2 and Plan 0 shares do not carry any voting rights except on a proposal to vary the rights attached to Plan shares.

293

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationGlossary

Definitions and acronyms

Term

absolute

access 
agreement

ACCU

administrative 
notices 
received from 
regulators

AEMO

ALARP

aspiration

available 
capacity

barrel (bbl)

basic earnings 
per share

beneficial use 
of produced 
formation 
water volume 
(water 
recycled/
re-used)

Meaning
When used in reference to emissions 
reduction targets, means reduction 
against the total emissions at the 
relevant point in time, rather than a 
relative or comparative amount or on an 
intensity basis 

An agreement with a landholder or other 
land or marine user outlining the 
activities proposed to be undertaken in 
the area as well as the terms and 
conditions of access and compensation 
arrangements

Australian Carbon Credit Unit. Each 
ACCU issued represents one tonne of 
carbon dioxide equivalent (tCO2e) 

An enforcement action issued by a 
regulatory authority for suspected / 
alleged or potential breaches of an Act, 
regulation or compliance condition, in 
which the regulatory authority has 
elected not to progress further as an 
offence. Generally issued for 
contraventions where a financial penalty 
is not considered appropriate. May be 
considered in future compliance matters

Australian Energy Market Operator

as low as reasonably practicable

When referenced in the context of 
Santos, an outcome that Santos 
recognises as a long-term ambition that 
is subject to material uncertainties or 
contingencies and where there is not yet 
a suitably developed plan or pathway to 
achieve that ambition or goal

Maximum throughput of installed 
equipment, adjusted for planned and 
unplanned outages. Total available 
capacity is the sum of each operated 
asset’s available capacity

A standard unit of measurement for all 
oil and condensate production volumes: 
one barrel equals 159 litres or 35 imperial 
gallons

Basic earnings per share is calculated by 
dividing net profit or loss for the year 
attributable to ordinary equity holders of 
Santos Limited by the weighted average 
number of ordinary shares outstanding 
during the year

Reuse of produced water for a purpose 
that has clear and tangible benefit(s). 
Includes activities such as irrigation and 
stock watering, dust suppression, drilling 
and completions, civil works and other 
operations. Does not include 'aquifer 
injection’ water

294

Term

biodiversity 
impact 
assessments

boe

carbon capture 
and storage 
(CCS)

Meaning
Fauna and / or flora surveys and 
assessments undertaken by suitably 
qualified independent external 
professional

Barrels of oil equivalent. Natural gas, 
NGL and condensate volumes are 
converted to oil-equivalent volumes via 
the relevant Santos conversion factor

A process in which greenhouse gases, 
including carbon dioxide, methane and 
nitrous oxide, from industrial and energy-
related sources, are separated 
(captured), conditioned, compressed, 
transported and injected into a 
geological formation, that provides safe 
and permanent storage deep 
underground

CCUS

carbon capture, utilisation and storage

carbon 
management 
services 

CEO

CO2

CO2e

community 
complaint

Carbon management services means 
services that focus on managing and 
reducing CO2 emissions of an 
organisation or individual project or 
facility through various strategies, which 
may include CO2 emissions reduction, 
abatement, avoidance, removal, and 
offsetting. Carbon management services 
may also include monitoring and 
reporting on CO2 emissions, carbon 
trading as well as developing and 
implementing carbon reduction plans

Chief Executive Officer

carbon dioxide

Carbon dioxide equivalent, being a 
measure of greenhouse gases (e.g 
carbon dioxide, methane, nitrous oxide) 
with equivalent potential impact on 
global warming as carbon dioxide

An expression of dissatisfaction with 
Santos made by a member of the 
community external to Santos, typically 
referring to a specific source of concern 
from business activities and a specific 
solution and / or remedy may be sought

Santos Annual Report 2024Term

community 
investment

Meaning
Community investment includes 
mandatory and voluntary community 
investment spend. 

Term

critical fuels

•  Mandatory community investment 
includes financial obligations that 
Santos is legally obligated to fulfil 
under a binding agreement, 
regulatory authority mandate, or 
other legal requirements, with the aim 
of providing social, economic, and or 
environmental benefits to a 
community through third party 
arrangements

•  Voluntary community investment 
includes community partnerships, 
community grants and donations 
which aim to provide direct 
community benefit, participation and 
or capacity building opportunities

Santos Limited and all its subsidiaries

A structured framework that sets out 
and defines technical and leadership 
competency requirements that 
individuals need to be able to 
demonstrate in order to competently 
perform the role

The collection of standards, procedures 
and tools, as defined by the Santos 
Management System, to ensure 
regulatory compliance obligations are 
identified, assessed and captured, along 
with the development of controls and 
the assignment of responsibilities to 
ensure these are implemented to achieve 
ongoing regulatory compliance

Hydrocarbons (mainly pentanes and 
heavier) that are gaseous in a reservoir 
and condense to form liquids at lower 
temperature and pressure including 
when produced to the surface

Those quantities of petroleum that are 
estimated, on a given date, to be 
potentially recoverable from known 
accumulations by application of 
development projects, but that are not 
currently considered to be commercially 
recoverable owing to one or more 
contingencies

Those storage quantities, as of a given 
date, to be potentially stored in geologic 
formations by application of 
development projects, but which are not 
currently considered to be commercial 
because of one or more contingencies

crude oil

CSG

CSIRO

CTAP

cultural 
heritage

cultural 
heritage 
agreement

cultural 
heritage 
assessment

DAC

DCCEEW

decarbonise

diluted 
earnings per 
share

Company

competency 
frameworks

compliance  
management 
system

condensate

contingent 
resources (2C)

contingent 
storage 
resources

Meaning
Hydrocarbon fuels, including oil and 
natural gas, that supply around 80 per 
cent of the world’s primary energy 
supply. Hydrocarbon fuels are critical to 
meet current and forecast energy 
demand and to the manufacturing of 
everyday products

Crude oil is the portion of petroleum that 
exists in the liquid phase in natural 
underground reservoirs and remains 
liquid at atmospheric conditions of 
pressure and temperature (excludes 
retrograde condensate). Crude oil may 
include small amounts of non-
hydrocarbons produced with the liquids 
but does not include liquids obtained 
from the processing of natural gas

coal seam gas

Commonwealth Scientific and Industrial 
Research Organisation

Climate Transition Action Plan

Both Aboriginal and non-Aboriginal 
cultural heritage. Cultural heritage can 
be either tangible (artefacts, scar tree, 
stock yards, cultural heritage) or 
non-tangible (Sacred Sites, Significant 
Aboriginal Areas, cultural heritage)

Agreements entered into by Santos to 
manage cultural heritage

Survey of an area prior to commencing 
activities to identify cultural heritage and 
the cultural heritage management 
practices required, including exclusion 
zones and site management actions, to 
ensure impacts to cultural heritage are 
avoided, where practical, or that impacts 
are minimised 

direct air capture

Department of Climate Change, Energy, 
the Environment and Water

The process of avoiding, reducing or 
offsetting anthropogenic greenhouse 
gas emissions through operational 
activities or efficiencies, technology 
deployment, use of generated or 
acquired emissions reduction units,  
and/or other means

Diluted earnings per share is calculated 
by adjusting basic earnings per share by 
the weighted average number of 
ordinary shares that would be issued on 
the conversion of all the dilutive 
potential ordinary shares into ordinary 
shares

DLNG

Darwin LNG

295

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationGlossary 
(continued)

Term

EBITDAX

Eligible 
Whistleblower

ESG

emissions

emissions 
intensity

emissions 
reduction units

enterprise risk 
register

environmental 
impact

exploration

FEED

FID

Foundation / 
Santos 
Foundation

Meaning
Earnings before interest, tax, 
depreciation and depletion, exploration 
and evaluation expensed, net impairment 
loss/reversal and change in future 
restoration assumptions

Has the meaning given by section 
13717AAA of the Corporations Act 2001 
(Cth) 

Term

GLNG

Meaning
Gladstone LNG

greenhouse gas 
(GHG)

The seven greenhouse gases listed in  
the Kyoto Protocol are: carbon dioxide 
(CO2); methane (CH4); nitrous oxide 
(N2O); hydrofluorocarbons (HFCs); 
nitrogen trifluoride (NF3); 
perfluorocarbons (PFCs); and sulphur 
hexafluoride (SF6)

environmental, social and governance

GRI

Global Reporting Initiative

Greenhouse gas emissions, unless 
otherwise specified

hazardous 
waste

The amount of greenhouse gas 
emissions per unit of specified output, 
such as production or facility throughput

An emissions reduction unit represents 
one tonne of carbon dioxide equivalent 
(tCO2e) emissions reduction or removal

A listing of enterprise risks that may 
materially impact Santos Limited. Each 
risk in the register is supported by an 
individual risk bowtie which displays 
causes, consequence, risk level, both 
preventative and mitigative controls to 
manage the risk

A change to the environment, whether 
adverse or beneficial, wholly or partially 
resulting from Santos’ activities. 

Prospecting for undiscovered petroleum 
and CO2 storage quantities, using 
various techniques, such as seismic 
surveys, geological studies, and 
exploratory drilling

front-end engineering design

final investment decision

A not-for-profit organisation whose 
mission is to invest in partnerships and 
local initiatives that help communities 
thrive

heads of 
agreement 
(HOA)

hierarchy of 
controls

Component of the waste stream which 
by its characteristics poses a threat or 
risk to public health, safety or the 
environment (includes substances which 
are toxic, infectious, mutagenic, 
carcinogenic, teratogenic, explosive, 
flammable, corrosive, oxidising and 
radioactive). Hazardous wastes are 
generally unsuitable for landfill disposal 
and should only be accepted within 
landfills after appropriate treatment and/
or in accordance with specific licence 
conditions. See also waste that 
possesses any of the characteristics 
contained in Annex III of the Basel 
Convention, or that is considered to be 
hazardous by Commonwealth legislation

An initial set of terms that establishes 
the framework for a transaction

The hierarchy of control is a step-by-step 
approach to eliminating or reducing risks 
and it ranks risk controls from the 
highest level of protection and reliability 
through to the lowest and least reliable 
protection. Eliminating the hazard and 
risk is the highest level of control in the 
hierarchy, followed by reducing the risk 
through substitution, isolation and 
engineering controls, then reducing the 
risk through administrative controls. 
Reducing the risk through the use of 
protective personal equipment (PPE) is 
the lowest level of control

floating production storage and offtake

FPSO
free cash flow Operating cash flows less investing cash 
flows (net of acquisitions and disposals 
and major growth capex) less lease 
liability payments

The average annual US$ oil price at 
which cash flows from operating 
activities (before hedging) equal cash 
flows from investing activities. Excludes 
one-off restructuring and redundancy 
costs, costs associated with asset 
divestitures and acquisitions, and major 
project capex. Includes lease liability 
payments. Forecast methodology uses 
corporate assumptions

Great Artesian Basin

natural gas

Net debt divided by the sum of net debt 
and net equity

free cash flow 
breakeven

GAB

Gas

gearing

296

Santos Annual Report 2024Term
high integrity When used with reference to Santos 

Meaning

nature-based projects and associated 
emissions reduction units, refers to 
Santos recognising the integrity 
challenges currently faced by 
international carbon markets as their 
depth and maturity grows and Santos 
focusing on the following three pillars for 
its approach to integrity in our nature-
based carbon projects:

•  Owing to our global presence, our 
integrity standards for emissions 
reduction projects seek to align with 
the Core Carbon Principles (CCP) 
assessment framework of the 
Integrity Council for Voluntary Carbon 
Markets (ICVCM). We monitor 
developments in these standards and 
adjust our internal frameworks where 
necessary, seeking to align with the 
requirements of our partners, 
customers and other key 
stakeholders.

•  Recognising that the balance of risk in 
carbon projects is weighted towards 
post-transaction events, we have 
developed bespoke tools to assess 
the probability of these on an 
ongoing basis, in addition to standard 
due-diligence procedures leading up 
to transactions. 

•  Own generation describes Santos’ 

philosophy of prioritising projects in 
which we can invest and manage 
directly, as opposed to seeking to be 
only an offtaker or on-market 
purchaser. This philosophy assists us 
to stay closer to and actively manage 
the risks from projects generating 
emissions reductions.

Where additional emissions reduction 
units are required to be purchased on 
market, Santos has processes in place 
generally requiring that only verified 
units under a range of internationally 
recognised registries will be purchased 
and utilised for emissions reduction 
purposes

Any incident or near miss that could 
have realistically resulted in severe harm 
or worse (safety) or moderate 
environmental harm or worse

Compounds containing only the 
elements hydrogen and carbon, which 
may exist as solids, liquids or gases

high potential 
event (HPE)

hydrocarbon

Term

hydrocarbon 
spill

IAP

IEA

IEA NZE

IEA STEPS

IFRS

information 
system

IOGP

IPCC

Ipieca

IPP

IRR

ISSB

joules

KPI

leaders

Meaning
Accidental release of a liquid 
hydrocarbon to land or water. 
Hydrocarbon may be in the form of 
crude, condensate, hydraulic or 
pneumatic fluid, diesel

Santos Indigenous advisory panel

International Energy Agency

The IEA 2024 Net Zero by 2050 
Scenario

The IEA 2024 World Energy Outlook 
Stated Policies Scenario

International Financial Reporting 
Standards

An integrated set of components for 
collecting, storing, and processing data 
and for providing information, 
knowledge, and digital products

The International Association of Oil and 
Gas Producers

Intergovernmental Panel on Climate 
Change

International Petroleum Industry 
Environmental Conservation Association

Indigenous Participation Plan 

internal rate of return

International Sustainability Standards 
Board

The metric measurement unit for energy

key performance indicator

Employees who are in roles which have 
direct line control and responsibility for 
employee safety, behaviour and 
performance

LEAP

Leader, Expert and Professional

liquid 
hydrocarbons 
(liquids)

LNG

A sales product in liquid form, for 
example condensate and LPG

Liquefied natural gas. Natural gas that 
has been liquefied by refrigeration for 
storage or transportation. Generally, LNG 
comprises mainly methane

LPG

liquefied petroleum gas

loss of primary 
containment 
(LOPC)

loss of 
containment 
incident (LOCI)

lost time injury 
rate (LTIR)

A loss of containment incident, meaning 
an unplanned or uncontrolled release of 
any material hydrocarbon from primary 
containment. Tier 1 and 2 classifications 
based on rate of release and production 
composition as per API 754

Sub-set loss of primary containment 
(LOPC), where the release breached 
secondary containment, or the risk is 
people or environment, and the incident 
could have been reasonably or 
practicably prevented by Santos through 
design, installation or maintenance

The number of lost time injuries 
(fatalities + lost time injuries) per million 
work hours

297

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationGlossary 
(continued)

Term

lower carbon / 
domestic gas / 
LNG / liquids

lower carbon 
energy

low carbon 
fuels

LPG

major accident 
event (MAE)

market 
capitalisation

moderate harm 
injury

Meaning
Domestic gas / LNG / hydrocarbon 
liquids classified as traditional fossil fuels 
that have had greenhouse gas emissions 
in their production, processing and / or 
use reduced, captured, sequestered and 
/ or offset, either wholly or partially 
compared to historical

Energy sources that have lower net 
greenhouse gas emissions in their 
production, processing and use 
(including through reduction and / or 
equivalent emissions reduction units) 
compared to traditional fossil fuels. This 
includes lower carbon domestic gas, 
LNG and hydrocarbon liquids, and may 
also include low carbon fuels as they are 
developed by Santos

Fuels that Santos may seek to develop 
with materially lower net greenhouse gas 
emissions in their production, processing 
and use (including through reduction 
and / or equivalent emissions reduction 
units) compared to traditional fossil 
fuels. This term may encompass a range 
of fuels such as hydrogen, ammonia or 
synthetic gas

Liquefied petroleum gas. A mixture of 
light hydrocarbons derived from oil 
bearing strata that is gaseous at normal 
temperatures but that has been liquefied 
by refrigeration or pressure for storage 
or transportation. Generally, LPG 
comprises mainly propane and butane

An event connected with a facility, 
including a natural event, having the 
potential to cause multiple fatalities of 
persons at or near the facility or as 
defined within the relevant legislation / 
regulation pertaining to a facility

A measurement of a company’s stock 
market value at a given date. Market 
capitalisation is calculated as the number 
of shares on issue multiplied by the 
closing share price on that given date

A work-related injury resulting in 
temporary disablement or medium-term 
impairment and taking three to six 
months to recover

moderate harm 
rate

The number of actual moderate harm 
injuries and above per million work hours

MOU

memorandum of understanding

Term

Native Title

natural gas

natural gas 
liquids (NGLs)

net debt

NPAT

Net Zero

net zero 
abstraction of 
water

net-zero Scope 
1 and 2 
emissions / 
net-zero 
emissions

OGCI

oil

Meaning
Recognition in law that Aboriginal and 
Torres Strait Islander people had a 
system of law and ownership of their 
lands before European settlement and 
that they have the interests and rights to 
land and water according to their 
traditional law and customs. Native Title 
is governed by the Commonwealth 
Native Title Act 1993 

Portion of petroleum that exists either in 
the gaseous phase or is in solution in 
crude oil in a reservoir, and which is 
gaseous at atmospheric conditions of 
pressure and temperature. Natural gas 
may include some amount of non-
hydrocarbons

A mixture of light hydrocarbons that 
exist in the gaseous phase in the 
reservoir and are recovered as liquids in 
gas processing plants. NGLs differ from 
condensate in two principal respects: (1) 
NGLs are extracted and recovered in gas 
plants rather than lease separators or 
other lease facilities, and (2) NGLs 
include very light hydrocarbons (ethane, 
propane, or butanes) as well as the 
pentanes-plus that are the main 
constituents of condensates

Reflects the net borrowings position and 
includes interest-bearing loans, net of 
cash, commodity hedges and interest 
rate and cross-currency swap contracts 
(inclusive of amounts classified as 
held-for-sale)

net profit after tax

In relation to greenhouse gas emissions, 
is achieved when anthropogenic 
emissions of greenhouse gases are 
balanced by anthropogenic removal of 
greenhouse gases through means such 
as operational activities or efficiencies, 
technology (e.g. CCS), offset through 
the use of emissions reduction units, or 
other means

Applies to the Australian Great Artesian 
Basin and means offsetting groundwater 
extracted by Santos during oil and gas 
production by supporting, enabling or 
funding equivalent reductions by third 
parties from uncontrolled groundwater 
releases (e.g. from free-flowing bores)

Santos’ equity share of Net Zero Scope 1 
and 2 greenhouse gas emissions

Oil and Gas Climate Initiative

A mixture of liquid hydrocarbons of 
different molecular weights

298

Santos Annual Report 2024Meaning
Organization of the Petroleum Exporting 
Countries

Term

probable 
reserves

Term

OPEC

opportunity 
development 
process (ODP)

penalty notices 
from regulators

Petroleum 
Resource Rent 
Tax (PRRT)

PHA

PNG

possible 
reserves

The ODP encompasses opportunity 
identification, exploration, and appraisal, 
through to development, project 
execution, operation and asset 
decommissioning or re-purposing. It 
serves as a company-wide approach to 
ensure consistency and to support the 
successful planning and delivery of new 
assets

An outcome of compliance action by a 
regulator in the form of a written notice. 
Generally issued for contraventions 
where prosecution or higher level 
enforcement action is not considered 
warranted. A financial penalty may be 
associated with the notice. Examples 
include notices of non-compliance and 
penalty infringement notices

A tax applied to profits generated from 
the recovery of marketable petroleum 
commodities from Australian offshore 
petroleum projects. Marketable 
petroleum commodities include crude 
oil, condensate, LPG, natural gas and 
ethane that are sold, used as feedstock 
for conversion to another product or 
direct consumption as energy

Provincial Health Authorities

Papua New Guinea

An incremental category of estimated 
recoverable quantities associated with a 
defined degree of uncertainty. Possible 
reserves are those additional reserves 
that analysis of geoscience and 
engineering data suggest are less likely 
to be recoverable than probable 
reserves. The total quantities ultimately 
recovered from the project have a low 
probability to exceed the sum of proved 
plus probable plus possible (3P), which 
is equivalent to the high estimate 
scenario. When probabilistic methods 
are used, there should be at least a ten 
per cent probability that the actual 
quantities recovered will equal or exceed 
the 3P estimate

Meaning
An incremental category of estimated 
recoverable quantities associated with a 
defined degree of uncertainty. Probable 
reserves are those additional reserves 
that are less likely to be recovered than 
proved reserves but more certain to be 
recovered than possible reserves. It is 
equally likely that actual remaining 
quantities recovered will be greater than 
or less than the sum of the estimated 
proved plus probable reserves (2P). In 
this context, when probabilistic methods 
are used, there should be at least a 50% 
probability that the actual quantities 
recovered will equal or exceed the 2P 
estimate

Water that is produced as a by-product 
during the extraction of oil and gas

produced water 
/ produced 
formation 
water (PFW)
production cost The costs associated with producing gas 

and liquid hydrocarbons, including 
extracting, processing, storing, repairs 
and maintenance and overhead costs 
allocated to the above activities

protected area Geographic area that is designated, 

regulated, or managed to achieve 
specific conservation objectives

proved reserves An incremental category of estimated 

recoverable quantities associated with a 
defined degree of uncertainty. Proved 
reserves are those quantities of 
petroleum that, by analysis of 
geoscience and engineering data, can be 
estimated with reasonable certainty to 
be commercially recoverable, from a 
given date forward, from known 
reservoirs and under defined economic 
conditions, operating methods, and 
government regulations. If deterministic 
methods are used, the term “reasonable 
certainty” is intended to express a high 
degree of confidence that the quantities 
will be recovered. If probabilistic 
methods are used, there should be at 
least a 90 per cent probability that the 
quantities actually recovered will equal 
or exceed the estimate

PSC

production sharing contract

renewables / 
renewable 
energy

A source of energy which naturally 
replenishes, such as solar energy, wind 
energy, geothermal, hydropower, ocean 
energy, and bioenergy

299

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationTerm

Scope 1 
emissions

Scope 2 
emissions

Scope 3 
emissions

senior 
leadership

severe harm 
injury

SMCs

SMS

S&P ACCS

STEM

storage 
capacity

Meaning
Direct greenhouse gas emissions that 
occur from sources that are owned or 
controlled by the reporting company

Indirect greenhouse gas emissions from 
the generation of purchased or acquired 
electricity, steam, heating or cooling 
consumed by the reporting company

All indirect greenhouse gas emissions 
(not included in Scope 2) that occur in 
the value chain of the reporting 
company, including both upstream and 
downstream emissions

A group of senior employees comprising 
General Managers, Heads of Functions, 
Vice Presidents and Group Executives

A work-related injury where the injured 
worker sustains permanent disablement 
or impairment, or where the worker does 
not fully recover within six months

Safeguard Mechanism credit units

Santos Management System

The S&P Global Insights (previously IHS 
Markit) 2024 Accelerated Carbon 
Capture and Storage Scenario

science, technology, engineering and 
maths

Those storable quantities anticipated to 
be commercially stored by application of 
development projects to known storable 
quantities from a given date forward 
under defined conditions

SuccessFactors Santos’ people management system 
used to manage key people-related 
processes including annual performance 
goals and reviews, talent and succession 
management, remuneration and payroll, 
leave management and organisation 
structure and employee records

surface water 
discharge

Water that meets regulatory 
requirements and is discharged into 
natural surface water bodies (e.g. rivers, 
lakes)

Glossary 
(continued)

Term

reserves

reserves 
replacement 
ratio

residual 
emissions

restored / 
rehabilitated 
area

Return on 
Average Capital 
Employed 
(ROACE)

Risk Appetite 
Statement

sales gas

Santos Life 
Saving Rules

Santos site

Meaning
Those quantities of petroleum 
anticipated to be commercially 
recoverable by application of 
development projects to known 
accumulations from a given date forward 
under defined conditions. Reserves must 
satisfy four criteria: they must be 
discovered, recoverable, commercial, and 
remaining (as of a given date) based on 
the development project(s) applied

The ratio of the change in petroleum 
reserves (excluding production) divided 
by production. Organic reserves 
replacement ratio excludes net 
acquisitions and divestments

Any greenhouse gas emissions which 
remain after an organisation has 
implemented all technically and 
economically feasible emissions 
reduction opportunities

Land that was used during or affected 
by operational activities, and where 
reinstatement/rehabilitation/remediation 
measures have either restored the 
environment to its original or an agreed 
state, or to a state where it has a healthy 
and functioning ecosystem

Is measured as the underlying earnings 
before interest and tax (EBIT) divided by 
the average capital employed, being 
shareholders’ equity plus net debt 
(adjusted for major project capex)

Santos Risk Appetite Statement is 
approved by the Board and defines 
tolerance to areas of material risk in 
relation to the company’s current 
strategic objectives. The Risk Appetite 
defines authorities for risk acceptance 
(across the Board and Management) as 
well as outcomes where there is no 
tolerance, for each of the risk exposures 
documented in the statement

Natural gas that has been processed by 
gas plant facilities and meets the 
required specifications under gas sales 
agreements

The Santos life saving rules are the 
critical controls for a range of fatal risks

Assets/projects where Santos has 
decision authority over the operation

Santos worker Any person who performs work, or 

provides services, in any capacity for, or 
on behalf of, Santos, including 
employees, officers and Directors; 
contractors, agents, consultants and 
subcontractors; and apprentices, 
trainees, secondees, students gaining 
work experience, and volunteers

300

Santos Annual Report 2024Term

underlying 
profit

United Nations 
Environment 
Programme Oil 
& Gas Methane 
Partnership 2.0 
(OGMP 2.0)

UNSDGs

USA

VET

Voluntary 
Principles on 
Security and 
Human Rights 
(VPSHR)

water stressed 
areas

Yarning Circle

Meaning
Underlying profit excludes the impacts 
of asset acquisitions, disposals and 
impairments, as well as items that are 
subject to significant variability from one 
period to the next, including the effects 
of commodity hedging

Is a reporting framework that helps the 
oil and gas sector systematically manage 
their methane emissions from upstream 
operations and provides a basis for 
member companies to report methane 
emissions (including methane emissions 
reductions)

United Nations Sustainable Development 
Goals

United States of America

vocational education and training

Created in 2000, the Voluntary 
Principles is a tri-partite initiative 
collaborated on by governments, 
non-government organisations and 
industry participants, that promotes the 
implementation of a set of principles 
that guide companies on providing 
security for their operations while 
respecting human rights

Areas identified within either the 'high' 
or 'extremely high' risk category within 
the WRI Aqueduct Water Risk Atlas. 
Water stress is measured by the ratio of 
water demand to available renewable 
water supplies. Water stress occurs when 
demand for water exceeds supply

Yarning for Aboriginal and Torres Strait 
Islander people was, and still is, a 
conversational process that involves the 
telling of stories as a way of passing on 
cultural knowledge. These circles provide 
a safe place for all to speak without 
judgement

Term

sustainable / 
sustainably / 
sustainability

synthetic gas

target 

TCFD

Total Fixed 
Remuneration 
(TFR)

total recordable 
injury rate 
(TRIR)

Total 
Shareholder 
Return (TSR)

Traditional 
Owner

Meaning
At Santos, sustainability is about striving 
to ensure safe operations, minimising 
environmental harm and greenhouse gas 
emissions, and creating long term value 
for our stakeholders including our 
customers, community, employees, 
partners and shareholders; balancing the 
needs of today without undermining the 
ability to meet the demands of 
tomorrow. While Santos aims to meet 
these objectives, there may be trade-offs 
between sustainability issues and other 
business considerations, and our 
business may impact (positively or 
negatively) on sustainability issues. 
References to sustainability (including 
sustainable and sustainably) do not 
mean that there will be no adverse 
impacts on the environment, the 
community and other social groups, or 
other sustainability issues

Fuels produced by combining hydrogen 
with carbon dioxide to produce 
methane. This process is called 
methanation and it could utilise carbon 
dioxide from direct air capture, emitters 
or other sources. Synthetic gas is still 
under consideration by Santos and is in 
the early planning stages, including the 
process and associated emissions. Based 
on current knowledge and depending on 
the net emissions in its production, 
processing, and use, synthetic gas has 
the potential to be a low carbon fuel 

When referenced in the context of 
Santos, an outcome sought that Santos 
has identified a potential pathway, or 
pathways, toward delivery, subject to 
conditions and assumptions

Task Force on Climate-related Financial 
Disclosures

Total Fixed Remuneration, 
comprising cash salary and company 
superannuation contributions (where 
provided or required to ensure 
compliance)

The number of recordable injuries 
(fatalities + lost time injuries + restricted 
work day cases + medical treatment 
cases) per million hours worked

Total capital growth plus dividends as a 
percentage of purchase price

An Aboriginal or Torres Strait Islander 
group or person recognised under law as 
having traditional and cultural 
associations with an area of land or sea

301

Santos Annual Report 2024OverviewSustainability ReportOur businessClimate ReportGovernanceReserves StatementDirectors’ ReportRemuneration ReportFinancial ReportAdditional InformationGlossary 
(continued)

Units of measure
bbl

barrel

boe

CO2e

kt

ktCO2e

mmbbl

mmboe

mmBtu

ML

MtCO2e

Mtpa

PJ

ppm

t

Mt

TJ

barrels of oil equivalent

carbon dioxide equivalent

thousand tonnes

kilotonnes carbon dioxide equivalent 
emissions

million barrels

million barrels of oil equivalent

million British thermal units

million litres

million tonnes of carbon dioxide 
equivalent

million tonnes per annum
Petajoules, 1 joule x 1015
parts per million

tonne

million tonnes
Terajoules, 1 joule x 1012

Conversion factors
Sales gas

1 PJ = 171,937 boe

Crude oil

1 barrel = 1 boe

Condensate

1 barrel = 0.935 boe

LPG

LNG

LNG

1 tonne = 8.458 boe

1 PJ = 18,040 tonnes

1 tonne = 52.54 mmBtu

For a comprehensive online conversion calculator tool, 
please visit: santos.com/conversion-calculator

302

Santos Annual Report 2024Corporate directory

Santos Limited ABN 80 007 550 923

Securities Exchange Listing

Santos Limited. Incorporated in Adelaide, South Australia, 
on 18 March 1954.

Quoted on the official list of the Australian Securities 
Exchange (ordinary shares code STO).

Quoted on the official list of the Papua New Guinea 
National Stock Exchange (ordinary shares code STO).

Company Secretary

Amelia Senneck
LLB (Hons), BCom (Hons) (International Business and 
Management) Company Secretary and Head of Business 
Integrity

Ms Senneck joined Santos in 2014 and was appointed to the 
role of Company Secretary and Head of Business Integrity 
in 2024. She has more than 19 years’ experience in 
commercial and corporate legal practice.

Registered and Head Office

Ground Floor Santos Centre  
60 Flinders Street 
Adelaide SA 5000 Australia

GPO Box 2455 
Adelaide SA 5001 Australia

Telephone: +61 8 8116 5000 
Facsimile: +61 8 8116 5050 

Website: santos.com

Share Register

Computershare Investor Services Pty Limited 
6 Hope Street, Ermington NSW 2115 Australia

GPO Box 2975 
Melbourne VIC 3001 Australia

Website: computershare.com/au  
Shareholder Access: investorcentre.com/au  
Telephone:  1300 096 259 (within Australia) 

+61 3 9415 4397 (International)

 
 
 
 
304

Santos Annual Report 2024