MATERIALITY: AT A GLANCE
This section outlines the ESG issues most critical to First Gen’s value creation. Guided by our regenerative ambition, we are moving beyond a traditional ‘do less harm’ view toward more active restoration and regeneration.
32 Material ESG Topics.
Our final set consists of eight Environmental, 13 Social, and 11 Governance topics.
Double Materiality Lens.
We assess both Impact Materiality (how we affect the world) and Financial Materiality (how sustainability risks affect our value).
Methodological Rigor.
The assessment was conducted by the UA&P-CSR in 2023, gathering input from 232 respondents across nine stakeholder discussions.
Regenerative Progression.
We manage our footprint through an ambition to move from sustainability to restoration to regeneration.
Which Matters Most: Our Materiality Approach
Our materiality lens starts from a straightforward premise. We want to build more renewable energy while continuing to preserve the natural systems that enable our operations. Every new geothermal, hydro, wind, or solar project helps decarbonize the grid but we also recognize that while it expands the physical footprint of development, it can also disrupt nature.
This central tension determines which ESG issues are material to our business. It has driven a shift in our operational philosophy from simply managing impacts to a three‑step progression: sustain, restore, and ultimately regenerate the ecosystems and communities where we operate. Instead of relying on traditional sustainability models that focus only on minimizing harm, we now focus on building relationships with communities, co-creators, and other stakeholders to support long‑term environmental and social resilience.
We therefore use a double materiality lens:
- We assess information on how the environment and the economy impact our business for the benefit of multiple stakeholders, including investors, employees, customers, suppliers, and local communities. This includes evaluating how climate- and nature-related risks affect our ability to deliver reliable, low-carbon power and protect our long-term enterprise value (Financial Materiality).
- We evaluate how our own projects, operations, and supply chain affect ecosystems and communities, ensuring we remain accountable for our footprint as we scale our renewable energy portfolio (Impact Materiality).
What Makes Issues Material for First Gen
2025 has continued to reaffirm what the Company has observed under the evolving conditions of our operating environment. From business operations to stakeholder management, we are constantly evaluating the topics that shape our value creation. The discussion below brings further focus on the exposures most evident in our sector and the basis on which we respond through strategy and direction.
From the broader business environment, three forces stand out as material to us. Climate and nature risks matter because stronger typhoons, shifting rainfall, and rising temperatures can test the limits of our wind turbines, affect geothermal reservoir recharge, and change water availability for hydropower. If our assets cannot withstand these swings, we cannot deliver reliable baseload renewable energy—which weakens our value proposition versus more carbon-intensive fuels.
Communities and employees are under the same climate pressure affecting our assets. Host communities live with typhoons, droughts, and unpredictable temperature swings near our sites. Our social license depends on adapting with them, not apart from them. Ignoring shared climate vulnerabilities while pursuing energy development would erode the community support or social license our business requires. This is why community partnership and employee engagement are treated as material issues, not just compliance topics.
Policy implementation also affects materiality. Even when capital and technology are ready, gaps in rules and execution change how efficiently we can deploy renewable projects and energy solutions. These constraints directly influence our growth trajectory and investor confidence.
Our Impacts on Nature and Society
Like any infrastructure project, renewable energy development involves environmental, social, and cultural considerations. Our power plants occupy land, interact with biodiversity, and alter natural systems—geothermal projects often sit in forest reserves, hydro facilities affect river flows and aquatic ecosystems, wind farms intersect migratory routes, and solar projects can convert agricultural or natural land. These impacts are often localized, manageable, and more likely to be reversible than those of conventional energy sources. We treat biodiversity and ecosystem health as priority issues because the stability of these natural systems is essential to the long-term viability of our operating areas.
Because we are working with natural resources, we adopt cautious utilization practices that address the effects of our operations. We adopt the mitigation hierarchy principle which prescribes the following action in order of importance: a) avoidance of adverse impact; b) reduction of adverse impact; c) restoration of nature’s altered attributes; and d) offset of residual adverse effects of the operation. We take Environmental Impact Assessments seriously—going beyond the conditions of our permits to implement proactive measures that protect the ecosystems and communities near our sites.
We are mostly renewable, but not emission free. Some geothermal reservoirs release small amounts of carbon dioxide, and we purchase grid electricity that is not yet fully decarbonized. Our supply chain—from equipment manufacturing to logistics—also generates indirect emissions from our value chain. Building and operating power plants creates construction waste, decommissioned components, and operational waste that must be managed and diverted from disposal. Treating greenhouse gas emissions and circularity as material topics ensures that our Net Zero by 2050 ambition is grounded in an operational plan and measurable indicators.
How We Determine Material Topics
To structure the assessment, First Gen commissioned the University of Asia and the Pacific–Center for Social Responsibility (UA&P‑CSR), an independent academic institution, to conduct a Double Materiality Assessment in 2023. The assessment, which is updated every three years, defines the material ESG topics used in this 2025 Integrated Report. Double materiality means looking at both financial materiality (how sustainability issues affect our enterprise value) and impact materiality (how our activities affect the environment, the economy, and the communities we serve).
The Logic of Double Materiality
UA&P-CSR used a double materiality approach of the GRI Standards to determine the factors and concerns that affect both our operations and the stakeholders we work with. This allows our strategy to address both internal and external impacts by bringing together two perspectives:
- Impact Materiality (Inside-Out): Information on economic value creation at the level of the reporting company for the benefit of investors (shareholders).
- Financial Materiality (Outside-In): Information on the reporting company’s impact on the economy, environment and people for the benefit of multiple stakeholders, such as investors, employees, customers, suppliers, and local communities.
Stakeholder Prioritization: Identifying Our Partners
The stakeholders in our materiality evaluation are individuals or groups who are, or may be, affected by First Gen’s activities. This perspective helps the Company decide how best to implement its strategy and achieve its objectives.
With the support of various departments, we identified and grouped stakeholders based on three criteria: interest, benefit, and contribution to the Company’s long‑term value creation. Each group was assessed on how it affects the Company’s ability to generate value over time and, in turn, how the Company affects that group’s ability to generate value.
Stakeholder Consultation and Engagement
UA&P‑CSR designed a survey to determine the priorities for our material topics. To build a comprehensive view, we held nine discussions with internal and external stakeholders across our head office and all plant sites, and 232 respondents rated each topic based on its significance to both the company and society.
Validation and Finalization
After the consultations, the Sustainability Technical Working Group convened senior management to review the results. This validation step confirmed the final list of 32 material topics that underpins this 2025 Integrated Report.
The Material Topic Landscape
Following the assessment and management validation, First Gen finalized 32 material ESG topics that capture the issues most critical to our value creation and impact. These reflect rising expectations on how our financial decisions support national development and a just transition.
Environmental Topics
Our environmental priorities focus on increasing power supplied by clean energy and leveraging technological advancements for decarbonization.
- Energy and Materials (Energy, Materials) — Expanding our renewables portfolio while enhancing resource efficiency
- Water and Effluents (Water and Effluents) — Managing withdrawal and discharge in our operating sites to protect watershed ecosystems
- Emissions and Climate Action (Emissions, Climate Action) — Grounding our Net Zero by 2050 ambition in measurable GHG Emissions Scope 1, 2, and 3 indicators and climate action initiatives
- Biodiversity and Compliance (Biodiversity, Environmental Compliance) — Maintaining zero non-compliance with environmental regulations and sustaining biodiversity programs that are paramount for long-term sustainability
- Waste — managing generated waste from our operations and activities to minimize environmental impacts
Social Topics
Our social priorities center on moments that matter for our people and on building long-term partnerships with communities and suppliers.
- Our Workforce (Employment, Labor-Management Relations, OSH, Training and Education, Diversity and Equal Opportunity) — Prioritizing occupational safety, health, and employee engagement as material drivers of productivity
- Community and Human Rights (Local Communities, Human Rights, Stakeholder Engagement) — Implementing health, education, and livelihood programs to ensure social license to operate
- The Value Chain (Supplier Social Assessment, Customer Health and Safety, Customer Privacy, Customer Relationships) — Influencing suppliers to ensure fair treatment of workers and maintaining industry-leading standards for customer safety and privacy
Governance Topics
Our governance framework ensures that generated economic value is reinvested into the economy through operating costs, wages, and government payments.
- Financial and Market (Tax, Sustainable Finance, Market Presence, Indirect Economic Impacts) — Topics that support our mission and national development commitments
- Ethics and Risk (Anti-Corruption, Data Privacy, Business Ethics and Governance, Risk Management) — Enforcing anti-corruption policies and data privacy to ensure business activities are conducted in an ethical manner
- Resilience (Corporate Governance, Economic Performance, Innovation) — Continuous improvement of corporate processes to remain at par with global best practices and mitigate risks to power generation efficiency
First Gen Materiality Matrix 2025
