Glaukos 2024 Climate Disclosure

SB 261 · TCFD-Aligned Report

Glaukos Climate Disclosure: Executive Summary

TCFD & SB 261 Aligned · Resilient Strategy · Proactive Since 2020

TCFD Pillars at a Glance
💡 Understanding This Framework

The TCFD framework organizes climate disclosure into four pillars: how we govern climate issues, our strategy for addressing them, how we manage risks, and how we measure progress. This summary shows Glaukos's position across all four.

🏛️
Governance
Board: CNG Committee Quarterly Oversight (Charter 2020)
Management: Sustainability Council + Topic Ownership
Integration: ISO 14001 + 60% Shareholder Engagement
🔥
Strategy & Risks
Physical: Wildfire (CA Focus) ↑48% Fire Season (high-emissions scenario)
└─ 2017 Event: 3-Day Downtime, No Material Loss
Transition: CA/EU Regs + Customer Expectations (EyeSustain Coalition)
Opportunities: Efficiency + Competitive Positioning
🛡️
Risk Management & Resilience
Geo-Diversify: CA/MA + Huntsville, AL (~2030)
Redundancy: Two-Site Distribution + Third-Party Mfg
Assessment: All Risks Minimal/Low (scored ≤9 on 25-point scale)
Strategy Resilient Across All Scenarios
Scenario Resilience Pathway & Strategic Milestones
📈 Strategic Milestones by Horizon
📍
Current
Now
Scope 1+2 Ready
SB 261 Compliance
🎯
Near-Term
0-3 Yrs
Scope 3 Readiness
SB 253/261
Efficiency Gains
📊
Medium
3-10 Yrs
Potential SBTi
Huntsville, AL Live
🌱
Long-Term
10+ Yrs
Exploring Supply Chain Decarb and Renewable Transition
Near-Term Focus
Scope 3 Buildout Complete (1-2 Yrs) → Enables Compliance & Transparency
Medium-Term Momentum
SBTi Evaluation & Commitment (Post-Scope 3 Maturity)
All Horizons
Strategy Resilient Across SSP Scenarios (Geo-Redundancy + Proven Mitigations)
Intensity Trend (mtCO₂e / $100k Revenue)
↓7% YoY
0.68
2022
0.86
2023
0.80
2024

Why intensity metrics? Intensity measures emissions relative to revenue — allowing meaningful comparison across years regardless of company growth.

Scope 1+2 (2024): 3,058 mtCO₂e
Scope 2 Share: 82.9%

Strategic Advantages

Operational Efficiency: Distribution Optimization (4K tCO₂ Saved)
Market Positioning: 5 Yrs Reporting + ISO 14001 + EyeSustain Ties
Customer Relationships: Electronic IFU (2027) + Biodegradable Packaging (2026)

🎯 Resilient Outlook

Proven Continuity: Physical Risks Managed (2017 Test)
Market Access: Transition Risks Met Proactively
Accelerated Pathway: Scope 3 Ready (1-2 Yrs) → Positions for SBTi
Commitment: Ongoing Transparency & Adaptation
$383.5M
2024 Revenue (+22% YoY)
3,058
Total Scope 1+2 (mtCO₂e)
↓7%
Intensity Improvement
~4,000
mtCO₂ Avoided
3 Sites
By 2030 (CA/MA/AL)
Key Terms
TCFD: Task Force on Climate-related Financial Disclosures — framework for reporting climate risks and opportunities
SB 261: California Climate-Related Financial Risk Act — requires climate risk disclosure for large companies
SB 253: California Climate Corporate Data Accountability Act — requires Scope 1-3 emissions reporting
CSRD: EU Corporate Sustainability Reporting Directive — European sustainability disclosure requirements
SSP: Shared Socioeconomic Pathways — IPCC climate scenarios (e.g., SSP5-8.5 = high emissions)
ISO 14001: International standard for environmental management systems
SBTi: Science Based Targets initiative — validates corporate emissions reduction targets
mtCO₂e: Metric tons of carbon dioxide equivalent — standard emissions measurement unit

Glaukos Climate Governance: Oversight from Board to Action

Proactive since 2020 · Aligned with TCFD & SB 261

Governance Structure

📋 How Climate Oversight Works

Climate oversight flows from Board level through management to operational integration, ensuring accountability at every level. This structure was formalized in 2020 when the CNG Committee charter was updated to include sustainability oversight.

⚖️
Board Level CNG Committee
Quarterly updates to CNG Committee
Lead: Mark Foley (MedTech Leadership Expertise)
CEO: Thomas Burns (Strategic Integration)
⚙️
Management Level Sustainability Council
Cross-Functional Team (Formed 2020)
Topic Ownership: Each sustainability topic has an assigned executive owner
Annual Goal-Setting Cycle → CNG Review
🛡️
ERM Integration Risk Framework
ISO 14001 Certified: All Manufacturing Sites
Materiality: Tier 1 Priorities Guide Focus

Evolution Timeline

📅 Why This Timeline Matters

Glaukos began formal climate reporting in 2019 — years before California's SB 253/261 laws were enacted (2023). This timeline demonstrates proactive commitment rather than reactive compliance, building governance infrastructure incrementally as the company grew.

2019
1st Report
2020
CNG Charter
Council Formed
2021
Tier 1 Materiality
2023
Scope 1+2
Disclosure
2024
Distribution
Optimization
2025
Climate Risk
Assessment
2020
Cross-functional Sustainability Council established
2023
Pre-positioned for California climate disclosure laws
2025
EyeSustain industry partnership + 7th annual report
Future
Scope 3 measurement infrastructure by 2028
60%
Shareholder Engagement Annual outreach on ESG, compensation & governance

Strengths & Resilience

📊
7 Annual Reports GRI/SASB-Informed · EyeSustain Partner
🔮
Pre-Regulatory Setup Ready for Scope 3 measurement by 2028
🔄
Continuous Improvement Peer Benchmarking + NACD Training
7 Reports (2019–2025)
2 ISO 14001 Certified Sites
Tier 1 Materiality Focus
Key Terms
CNG Committee: Compensation, Nominating & Governance Committee — Board committee overseeing sustainability
ERM: Enterprise Risk Management — integrated approach to managing organizational risks
ISO 14001: International standard for environmental management systems
GRI: Global Reporting Initiative — sustainability reporting standards framework
SASB: Sustainability Accounting Standards Board — industry-specific disclosure standards
SB 253/261: California climate disclosure laws requiring emissions and risk reporting
Tier 1 Materiality: Highest priority sustainability issues identified through stakeholder assessment

Glaukos Climate Strategy: Risks, Opportunities & Resilience

Physical & Transition Risks · Scenario-Resilient Approach

Transition Risks & Mitigations

⚡ Understanding Climate Risk Types

Transition risks arise from the shift to a low-carbon economy — including new regulations, changing customer expectations, and market shifts. Physical risks (shown on right) stem from climate change impacts like extreme weather events. Companies must address both.

📋
Regulatory Risks Policy
CA SB 253/261: Scope 1-3 reporting by 2026
EU CSRD/CSDDD: Supply Chain Due Diligence
Proactive Foundation: ISO 14001 + 5 Yrs Reporting
🏥
Customer Procurement Risks Market
Hospitals: Carbon disclosure + sustainability certifications (e.g., Practice Greenhealth)
ASCs: Emerging Requirements
EU Markets: <30% Revenue, Due Diligence Requirements
Transition Mitigations Actions
EyeSustain Coalition Engagement
Scope 3 Measurement Readiness
Beyond Compliance: Sustainable Packaging (2026) + Electronic IFU (2027)

Physical Risks: Wildfire Projections

📊 Reading These Projections

These projections show how fire season length may increase under different global emissions pathways. SSP1-2.6 assumes aggressive climate action, SSP2-4.5 reflects middle-of-the-road policies, and SSP5-8.5 represents continued high emissions. Glaukos tests strategy resilience across all scenarios.

San Clemente Fire Season Length
CMIP6 Projections · % Change from Baseline
Mid-Century (2040–69)
SSP1-2.6
+24%
SSP2-4.5
+26%
SSP5-8.5
+37%
End-Century (2070–99)
SSP1-2.6
+24%
SSP2-4.5
+26%
SSP5-8.5
+48%
San Clemente: Primary manufacturing – elevated fire weather exposure
Burlington: +144% relative increase, but minimal absolute risk
2017 Event: 3-day downtime, no material losses – continuity proven
🛡️
Mitigated by Diversification: 2-site distribution model + Memphis hub + Burlington operations reduce single-point exposure

💡 Key Opportunities

Operational Efficiency: Memphis Model (consolidated U.S. distribution hub) – 19.7M air miles saved / 4K tCO₂ eliminated
Competitive Edge: Sustainability credentials in hospital & ASC RFPs
Relationship Building: Biodegradable packaging by 2026 + EyeSustain partnership

🔄 Scenario Resilience

Physical (All SSPs): Geo-diversification + 2-site model = proven continuity (2017 test)
Transition: Current capabilities meet regulatory baseline; EPD investments if buyer pressure accelerates
Key Finding
Strategy holds across futures – Huntsville expansion by 2030 adds further resilience
19.7M Air Miles Saved
🌿
~4,000 tCO₂ Eliminated
📦
2026 Biodegradable Packaging Target
📱
2027 Electronic IFU Transition
🏭
2030 Huntsville Expansion
Key Terms
SB 253/261: California climate disclosure laws requiring emissions and risk reporting
CSRD: EU Corporate Sustainability Reporting Directive — European disclosure requirements
CSDDD: EU Corporate Sustainability Due Diligence Directive — supply chain sustainability requirements
SSP Scenarios: Shared Socioeconomic Pathways — IPCC climate scenarios ranging from low (SSP1-2.6) to high (SSP5-8.5) emissions
CMIP6: Coupled Model Intercomparison Project Phase 6 — latest generation of global climate models
IFU: Instructions for Use — product documentation accompanying medical devices
Practice Greenhealth: Hospital sustainability membership organization setting environmental standards
EyeSustain: Ophthalmology industry coalition focused on sustainability initiatives

Glaukos Climate Risk Management: From Identification to Resilience

Systematic SB 261/TCFD-Aligned · Integrated into ERM

Risk Lifecycle Process
🔄 Our Three-Stage Approach

This systematic process identifies climate risks through multiple data sources, quantifies their potential impact using standardized severity scoring, and manages them through diversification and strategic investments. A score of 9 or below (out of 25) indicates risks manageable within normal business operations.

🔍
Risk Identification
Stage 1
Physical: CMIP6 Projections (Facilities + 75km Regional)
Transition: Regs (SB253/261, CSRD) + Customer (EyeSustain)
Supplier: Tier 1-2 Supplier Assessment + ISO 14001 Surveys
⚖️
Risk Assessment
Stage 2
Quantitative: Impact (1–5) × Likelihood (1–5) = Severity (1–25)
Scenarios: SSP1-2.6 (+1.8°C) | SSP2-4.5 (+2.7°C) | SSP5-8.5 (+4.4°C)
Facility: San Clemente (Wildfire) | Burlington (Diversification)
All Assessed Risks: Minimal or Low Severity
🛡️
Risk Management
Stage 3
Geo-Diversify: CA/MA + Huntsville ($82M by 2030)
Supply Chain: >70% Domestic + Backup Sterilization (2024)
Customer: Scope 3 Readiness (2028) + Electronic IFU (2027)
📊
Process Overview
Systematic three-stage approach ensures climate risks are identified through multiple data sources, quantitatively assessed using standardized severity scoring, and actively managed through diversification and strategic investments aligned with business growth.
Assessment Methodology
🔬 Data-Driven Analysis

Our assessment draws on peer-reviewed climate models (CMIP6), IPCC-aligned scenarios, and real operational data — not just qualitative judgment. This multi-source approach ensures risks are identified comprehensively and quantified consistently.

🌡️
CMIP6 Climate Projections
Facilities + 75km regional analysis
Physical
🔮
Scenario Analysis
SSP1-2.6, SSP2-4.5, SSP5-8.5 pathways
TCFD
⚙️
Operational Intelligence
Energy data, facility metrics, ISO 14001
Internal
📋
Regulatory Scanning
SB 253/261, CSRD, EU Tenders
Transition
🏥
Customer Intelligence
EyeSustain, Hospital RFPs
Market
Risk Assessment
Impact (1–5) × Likelihood (1–5) = Severity
Critical threshold: >10% revenue impact
Finding
All Risks: Minimal to Low
No risks exceed severity threshold of 9

🔗 ERM Integration

Board: CNG Quarterly Oversight + Topic Ownership (Ops/Finance)
QMS: ISO 14001/13485 for Env/Continuity
Capital: Huntsville Ties Growth to Resilience
Suppliers: Annual Audits + Geo Risk Scoring

🚀 Forward Momentum

Annual Goals: Scope 3 by SB253 Threshold (~$1B Rev)
Monitoring: 60% Shareholder Engagement
2024 Wins: Memphis Model (4K tCO₂ Saved) + EyeSustain Partner
Benchmarking: Peer Analysis + Materiality Refresh
5 Yrs
ISO 14001 Certified
94%
Supplier Response
>70%
Domestic Sourcing
~4K
tCO₂ Avoided (2024)
Low
Max Risk Severity
Key Terms
CMIP6: Coupled Model Intercomparison Project Phase 6 — latest generation of global climate models used for projections
SSP Scenarios: Shared Socioeconomic Pathways — IPCC scenarios modeling different emissions futures
ISO 14001: International standard for environmental management systems
ISO 13485: Quality management standard specific to medical device manufacturing
ERM: Enterprise Risk Management — integrated framework for managing organizational risks
SB 253/261: California climate disclosure laws requiring emissions and risk reporting
CSRD: EU Corporate Sustainability Reporting Directive — European disclosure requirements
EyeSustain: Ophthalmology industry coalition focused on sustainability initiatives

Glaukos Climate Metrics & Targets: Measured Progress & Credible Pathway

Foundational Metrics · Efficiency Wins · Growth-Aligned Targets · TCFD/SB 253-Aligned

Current Metrics Performance
📖 Understanding Emissions Scopes

Scope 1 covers direct emissions from our facilities and vehicles. Scope 2 covers indirect emissions from purchased electricity — which represents most of our footprint due to energy-intensive cleanroom operations required for medical device manufacturing.

📊 Emissions Overview 2022–2024
🔥
Scope 1
~520-575mt
(17%)
Natural Gas, Vehicles, Fugitives
Scope 2
Dominant (82.9%)
92.4% from CA Facilities → Cleanroom HVAC Intensity
📈 GHG Intensity Trend mtCO₂e / $100k
0.68
2022
Baseline
0.86
2023
Capacity Ramp
0.80
2024
-7% YoY
-7%
YoY
2024 Improvement
Revenue +22% while Emissions +12% → Decoupling Growth from Carbon
🚛 Standout Efficiency Win 2024
Two-Site Distribution Model
~4,000
mtCO₂ Avoided
+
19.7M
Air Miles Saved
Avoided emissions exceed entire Scope 1+2 footprint
Target Evolution & Future Pathway
🎯 Our Approach to Target-Setting

Rather than setting arbitrary targets, we're building measurement capability first — ensuring any future commitments are credible and achievable. This is especially important given operational constraints: medical device manufacturing requires controlled cleanroom environments with high air turnover, limiting opportunities for energy reduction without regulatory revalidation.

Baseline Established
2022–2024
Scope 1+2 tracking & reporting in place
Intensity metrics established
Distribution optimization deployed
Near-Term Initiatives
2025–2027
📋 Scope 3 Development
Purchased Goods, Transport, Use Phase
📦 Packaging Innovation
Biodegradable by 2026, eIFU by 2027
🏭 Continued Efficiency (ISO 14001 Drives Gains)
Medium-Term Goals
2028+
🎯 Potential SBTi Commitment
Post-Scope 3 Maturity
Future State
Long-Term
Evaluate Renewable Transition
🔗 Supply Chain Decarbonization
Key Rationale
Growth Phase
Revenue +35% (2022–2024) → Intensity Focus Over Absolute Targets
Operational Realities
Cleanroom Constraints + FDA Validation Requirements
Credibility First
Mature Baselines Before Formal Commitments
Supplier Readiness
94% Response Rate → Strong Scope 3 Foundation

Progress Highlights

ISO 14001 Certified Facilities (All Manufacturing Sites)
Distribution Optimization: Ongoing ~2,500–3,000 tCO₂ Avoided Annually
Zero Recalls / Zero OSHA Recordables (2024) → Operational Discipline
High Supplier Engagement (94% Response, >70% Domestic Spend)

🎯 Target Philosophy

Measurement-First: Accurate Baselines → Credible Targets
Growth-Aligned: Intensity Improvements While Scaling
Regulatory Ready: Scope 3 Capabilities for SB 253 Compliance
Future Enhancements: Scope 3 Inventory, Renewable Metrics
Baseline Established
2022–2024
Efficiency Wins
Ongoing
Scope 3 Build
2025–2027
Target Readiness
2028+
Key Terms
GHG Protocol: Greenhouse Gas Protocol — international standard for measuring and reporting emissions
Scope 1: Direct emissions from owned/controlled sources (e.g., company vehicles, on-site fuel)
Scope 2: Indirect emissions from purchased electricity, steam, heating, and cooling
Scope 3: All other indirect emissions in the value chain (suppliers, transportation, product use)
mtCO₂e: Metric tons of carbon dioxide equivalent — standard emissions measurement unit
ISO 14001: International standard for environmental management systems
SB 253: California Climate Corporate Data Accountability Act — requires Scope 1-3 reporting above revenue thresholds
SBTi: Science Based Targets initiative — validates corporate emissions reduction targets against climate science