Audio Blog: The Changing Landscape of Climate Risk Disclosures

Market expectations on corporate climate risk disclosures are fast changing as corporations, investors, and regulators are attempting to increase efficiency and strengthen economic resilience through more transparency. This panel discussion, held at the 2017 Climate Leadership Conference on March 1, 2017, provides an overview of recent developments by US and EU regulators and Bloomberg’s Task Force on Climate-related Financial Disclosures. Panelists shared how they are responding to the new regulatory context, challenges and opportunities arising from understanding climate impacts on business and markets, and expectations for further developments.

Panelists:

  • Emilie Mazzacurati, Founder & CEO, Four Twenty Seven (moderator)
  • Laline Carvalho, Director of the Financial Services Ratings Group at S&P Global
  • Tim Dunn, Founder and Chief Investment Officer, Terra Alpha Investments LLC
  • Mardi McBrien, Managing Director, Climate Disclosure Standards Board
  • Richard Saines, Partner; Head of North American Climate Change & Environmental Markets Practice, Baker McKenzie

You can listen to a recording of the panel here. Note that due to a technical issue with the recorder, the introductions from Laline Carvalho and Tim Dunn were unfortunately not captured.

For more information about the Taskforce on Climate-related Financial Disclosures, read our blog posts:

You can also watch our webinar discussing TCFD next steps, and issues to consider for implementation.

New EU Directive Requires Pension Funds to Assess Climate-related Risks

EU FlagOn December 8th, 2016 the EU adopted a new regulation regarding Pension Funds, the IORP II Directive — the successor of the Institutions for Occupational Retirement Provision Directive adopted in 2003. The directive’s main objectives are to enhance pension funds’ governance, risk management and supervision, and to facilitate cross-border activities.

A key feature of the directive is the consideration of environmental, social and governance (ESG) factors as part of pension providers’ investment. In particular, pension providers are now required to carry out their own risk assessment, including climate change-related risks, as well as risks caused by the use of resources and regulatory changes.

Moreover, the Directive explicitly allows pension funds to take into account ESG factors in investment decision-making, within the ‘prudent person’ rule. This comes as an important clarification as fiduciary duty is often cited by investors as a reason they cannot pay more attention to ESG issues in investment processes.

The implementation of the Directive

IORP II applies to all the 14,358 registered EU pension funds, among which 160 have cross-border activities.

Member States (EU countries) have until January 13, 2019 to transpose IORP II into their national law, which was published early January in the Official Journal of the European Union. According to current projections, the implementation deadline should therefore fall before Brexit, an important fact considering that the UK accounts for 50 percent of the EU occupational pension fund sector, followed by the Netherlands (33 percent).

A new risk assessment covering climate-related physical risks

The risk assessment is to be carried out every three years or after any significant change in the risk profile of the pension funds “in a manner that is proportionate to their size and internal organization, as well as to the size, nature, scale and complexity of their activities”.

The assessment must cover “new or emerging” risks, “including risks related to climate change, use of resources and the environment, social risks and risks related to the depreciation of assets due to regulatory change”.

The Directive’s preamble invites EU member states to use the Principles for Responsible Investment (PRI) as a reference for ESG and climate change-related reporting requirements and states that “the relevance and materiality of environmental, social and governance factors to a scheme’s investments and how they are taken into account should be part of the information provided by the scheme under this directive”.

While physical impacts of climate change are not mentioned in these terms, the inclusion of risks related to climate change, use of resources and social risks clearly point to the inclusion of physical impacts, in addition to regulatory and energy transition risks. National transpositions might provide more explicit guidance.

Beyond compliance considerations, pension funds are particularly exposed to climate risks given their long-term investment profile. The longer an asset manager’s time horizon, the more climate-related risks increase. As pension funds also tend to be particularly risk-averse, taking into account climate-related risks is crucial for effective risk mitigation. In 2015, the Economist Intelligence Unit valued the average expected loss as a result of climate change across scenarios as $4.2tn in financial assets.

Considering that EU pension funds now manage more than €2.5 trillion ($2.65 trillion) in combined assets, the assessment of physical climate risks will require considerable effort to access raw climate data at asset level, select appropriate indicators, and interpret the output.

Climate-related regulatory efforts gaining momentum

The adoption of this new climate risks mandatory disclosure at EU-level follows the adoption of an pioneering climate risk reporting law for asset managers and asset owners in France, discussed in a previous post, and occurs almost concomitantly with the release of the Task Force on Climate-related Financial Disclosures (TCFD) Phase II Report discussed  in a policy brief and a webinar.

European central banks and financial regulators are increasingly aware of the threat to financial stability of sudden market adjustments caused by climate-related risks. The concern is that the scale of impacts would pose a systemic risk to the financial system as a whole. A growing number of public institutions are paying attention to this issue including De Nederlandsche Bank; the Bank of England; Finansinspektionen; the SEC and the ESRB.


Four Twenty Seven helps investorsFortune 500 companies and government institutions understand how to quantify and monetize climate change impacts on operations as well as social factors that affect their value chain. Our clients rely on Four Twenty Seven’s tools and models to factor into financial and operational planning processes. Learn more about how we are helping our clients assess and adapt to climate risks.

 


You can find the full text here and the impact assessment made by the European Commission here

A handbook by Lane, Clark & Peacock on the IORP II

 

TCFD Key Recommendations for Climate Risk Disclosure

The Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) is an industry-led task-force established at the December 2015 G20 summit for improving voluntary financial disclosure of climate-related risks. Eight months after the release of its Phase I report (discussed  in a policy brief), the TCFD published a comprehensive set of recommendations on December 14 in its Phase II report. The recommendations provide detailed guidance for companies on how and what to integrate in their financial climate risk disclosure. These recommendations are categorized into four different components: Governance, Strategy, Risk management, and Metrics.

Core Elements of Recommended Climate Risk Disclosures

Governance

The first set of recommendations relates to the organization’s governance for addressing climate-related risks and opportunities.

At the board-level, TCFD report recommends disclosing how and how often is the board informed about climate-related issues, whether it integrates them when reviewing, guiding, monitoring the organization’s activities, and how it oversees progress against goals and targets for addressing those issues.

At the management-level, the TCFD suggests disclosing whether the organization has assigned climate-related responsibilities to management-level positions, what those responsibilities entail and how they are reported to the board. Just as for board-level, the report also invites organizations to describe processes by which management is informed about climate-related issues and how it monitors them.

Strategy

The second set of recommendations covers how climate-related issues may affect an organization’s businesses, strategy, and financial planning over the short, medium, and long term.

TCFD recommends organizations state what they consider to be the relevant short-, medium-, and long-term horizons, according to the nature of their assets / infrastructure, then identify the specific climate-related issues that could have a material financial impact on the organization for each time horizon and by distinguishing between physical and transition risks. According to the report, the risks and opportunities should be assessed by sector and geography when appropriate, and the methodology used should also be described along with the assessment.

Based on the above recommended disclosure, TCFD suggests disclosing as a first step how identified climate-related issues have already impacted the organization’s:

  • businesses, strategy and financial planning
  • products and services
  • supply chain and/or value chain
  • adaptation and mitigation activities
  • investment in R&D
  • operations, by types and location

As a second step, the report recommends assessing how the organization’s strategy is likely to perform under various climate-related scenarios and how what actions are subsequently taken to mitigate risks and take advantage of opportunities.

Risk management, metrics and targets

The last sets of recommendations relate to how the organization identifies, assesses, and manages climate-related risks, including the metrics and targets used.

The TCFD suggests disclosing the processes implemented within the organization for assessing the potential size and scope of identified climate-related risks, for managing those risks (be it through mitigation, transfer, acceptance or control) and for prioritizing them. More specifically, the organization should explain how materiality determinations are made.

According to the TCFD, organizations should consider providing the key metrics used to measure and manage those risks, especially metrics associated with water, energy, land use, and waste management where relevant, as well as the organization’s internal carbon prices. All metrics should be provided for historical periods to allow for trend analysis, along with a description of the methodologies used to calculate them.

Moreover, the TCFD recommends setting climate-related internal targets, such as those related to GHG emissions, water usage, energy usage, etc., but also efficiency goals, financial loss tolerances, or net revenue goals for products and services designed for a low-carbon economy. Targets description should detail whether the target is absolute or intensity based, time frames, key performance indicators and methodology used to assess progress against targets.

Examples of climate-related risks and their potential financial impacts

The report provides examples of physical and transition risks, along with their potential impacts on the organization’s finance.

Examples of climate-related risks and their potential financial impacts

The main challenge ahead: Identifying risk at asset-level

The process of scanning assets for physical climate risk exposure will require considerable effort and challenges, from accessing raw climate data at asset-level, to selecting appropriate indicators and time frame, and interpreting the output while accounting for climate data’s unique complexity and sources of uncertainties.

To support corporations and investors looking to identify hotspots and quantify value at risk in their portfolio of assets, facilities or across their supply chain, Four Twenty Seven has developed a suite of enterprise applications that provide rapid, cost-effective screening across portfolios of 10,000+ assets.

Learn more about CREST, our Climate Resilience Support Tool for corporate climate risk management, and our climate data analytics services for financial institutions.

Art. 173: France’s Groundbreaking Climate Risk Reporting Law

National Assembly, Paris, FranceIn the fall 2015, in the run up to COP21, France became the first country to pass a law introducing mandatory extensive climate change-related reporting for asset owners and asset managers, the Energy Transition Law and its now famous Article 173.

The reporting obligations set out under Article 173 and its implementing decree have potentially far-reaching implications, requiring institutional investors to report on the integration of both physical risks and ‘transition’ risks caused by climate change on their activities and assets.

Whom Does Article 173 Apply To?

Article 173 addresses publicly traded companies, banks and credit providers, asset managers and institutional investors, the latter being listed as insurers, pension or mutual funds and sovereign wealth funds, with differentiated reporting obligations depending on their size and nature.

The law applies to French companies, meaning that French subsidiaries of large financial groups are potentially subject to requirements that do not apply to their parent companies.

What Must the Climate Change-Related Reporting Include?

A comply or explain approach

The law provides investors with broad flexibility in choosing the best way to fulfil the objectives, based on a comply or explain approach. It does not impose any specific method, giving leeway to find the reporting methodology suiting best the investment portfolio, for example reflecting specific asset classes or subsidiaries. However, investors must provide information and justification on the methodology used. They are encouraged to draw from current best practices. An assessment of the implementation will be carried out after two years, at the end of 2018, and the best-in-class approaches will be promoted.

Differentiated requirements

Banks and credit providers will be subject to regular stress tests including a climate change component.

Publicly traded companies’ annual reports must disclose the financial risks related to the effects of climate change, the measures adopted by the company to reduce them and the environmental impact of the company’s activities and of the use of goods and services it produces.

Asset managers managing funds below 500 M€ and institutional investors with balance sheets below 500 M€ must report on the implementation of their ESG policies.

Asset managers managing funds above 500 M€ and institutional investors with balance sheets above 500 M€ are subject to extended climate change-related reporting obligations (besides their ESG policies). Those obligations are two-fold:

  1. Assessment of the portfolio’s exposure to climate change-related risks, including both physical risks (physical impact of climate change) and transition risks (impact of the transition to a low-carbon economy).
  2. Assessment of the investor’s contribution to meeting the international and national low-carbon goals, including the low-carbon targets set by the the investor itself and the actions taken to achieve these targets.

While Asset management companies have to report separately on each of the above 500 M€ funds they manage, institutional investors must provide a consolidated reporting on their assets.

Note that institutional investors may have a commercial relationship with asset management companies via dedicated funds and/or management mandates. Therefore, asset management companies may be directly or indirectly affected by Article 173, via their institutional investor clients. The terms and conditions of access to ESG information required by institutional clients to meet their own Article 173 reporting obligations are to be defined in the contractual relations between them and the asset management companies involved.

Though investors are free to choose which exact data to report, the implementing decree suggests including the following information:

  • The consequences of climate change and extreme weather events on the assets
  • Changes in the availability and price of natural resources
  • Policy risks related to the implementation of national and international climate targets
  • Measures of past, current or future emissions of GHG (both direct and indirect)

As mentioned above, all assessments must come with an explanation and justification of the methodology used.

As of now, 60 institutional investors are subject to the latter reporting requirements.

The Assessment of Climate Change-Related Physical Risks

What really makes Article 173 groundbreaking is the reporting obligation on climate change-related physical risks. The inclusion of physical impacts of climate change in a financial risk analysis is in line with the industry-led Task Force on Climate-related Financial Disclosures (TCFD) recommendations report, released on December 2016 and discussed in a policy brief and a webinar.

While traditional climate-related reporting focuses mainly (if not exclusively) on the impact of the organization’s activities on climate change, the French Energy Transition Law is truly pioneering as it also emphasizes the impact of climate change on the organization’s activities and assets. This new focus meets the demand of investors for enhancing financial risks assessment through taking better account of climate-related risks.

A Ripple Effect

The French government is hoping for a ripple effect, both internationally and on a national level, across the investment value chain. The service providers of eligible investors are already considering how to enhance their ESG and climate reporting practices in order to meet their clients’ demands and comply with the law.

Moreover, climate-related regulatory efforts are gaining momentum. Article 173 is expected to be the first of a series of national equivalent regulatory frameworks among the G20 countries. The TCFD was established shortly after the Law passed, at the December 2015 G20 summit, and explicitly offers its guidance for compliance with Art. 173.

In March 2016, the Dutch central bank DNB announced it was taking steps to monitor and mitigate climate risk. Last November, the European Union has issued a directive requiring all EU-based pension funds to assess for climate change risk.


Four Twenty Seven helps investorsFortune 500 companies and government institutions understand how to quantify and monetize climate change impacts on operations as well as social factors that affect their value chain. Our clients rely on Four Twenty Seven’s tools and models to factor into financial and operational planning processes. Learn more about how we are helping our clients assess and adapt to climate risks.


Documents
A handbook on Article 173 published by the French SIF

By Delphine Ly, Climate Analyst at Four Twenty Seven

TCFD: Climate Risk Disclosures Gaining Momentum

The Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) released a comprehensive set of recommendations on December 14. The recommendations provide detailed guidance for companies on how and what to integrate in their financial disclosures related to climate change. The TCFD’s definition of climate risk encompasses both transition and physical risk (see chart below) and recommends companies address climate risk across governance, strategy and risk management, with a set of metrics and targets to show ambition and progress.

How climate risk disclosures and opportunities affect financial impact
Source: Recommendations of the Task Force on Climate-related Financial Disclosures

The recommendations also encourage companies to consider opportunities to be found in climate-related efforts such as cost savings through improved resource efficiency or supply chain resilience. The Task Force recommends the use of scenario analysis to disclose an organization’s planning under future scenarios, most notably one with in a 2°C scenario.

Growing Regulatory Momentum in Europe

With these recommendations, companies will be guided to producing long term outlooks on their value and risk management strategies for financial markets. The recommendations for disclosures of climate-related information are voluntary, but offer transparency that is increasingly being demanded by investors and resonate with recent regulatory efforts in France and the UK to require such disclosures. Indeed, responsible investing received a big boost in Europe, as the European Parliament voted to confirm a law that will require pension fund managers in the EU to account for climate-related risks in their investment strategies. The law introduces new requirements for risk management and reporting.

The law echoes Art. 173 in France‘s Law on the Energy and Ecology Transition (Loi TEE), which requires asset owners and asset managers to disclose financial climate risks ranging from carbon and energy risks to physical impacts of climate change.

A Market Imperative

Climate risk disclosures are more important than ever. In the context of the Trump Presidency and the latest round of cabinet appointments, it may be tempting to dismiss the risk associated with the “Energy Transition” – the rapid transition to a low-carbon economy. It may be tempting to ignore the need to disclose risks from the physical impacts of climate change in a context that promises fewer regulations and a dismissal of climate policy.

Yet, there’s no escaping the science and the reality of climate change, and the Trump administration’s stance on climate change gives even more urgency to both transition and physical risks of climate change.

Climate change and its impacts are not going away, and will likely worsen at an increasing rate if we continue to ignore them. Looking out a few years, these same physical impacts from climate change will eventually force us to transition rapidly away from fossil fuels to stop further degradation of the climate, leading to a ripple effect across the economy as entire value chains relying on fossil fuels, including major energy and transportation systems, will need to adapt – potentially at a high cost. The only question is how fast, and how expensive.

Markets have a chance to avoid being blindsided by a predictable risk. The TCFD offers a market solution, by the market, for the market. Mark Carney and Mike Bloomberg point out in an Op-Ed in The Guardian that “early disclosure rules allowed 20th-century financial markets to grow our economies by pricing risks more accurately.”

Disclosures are a small step that can help set in motions much larger changes through market forces, by pricing risk accurately, rewarding companies that take appropriate steps to prepare and adapt, and unlocking finance for resilience. Climate risk disclosures are an opportunity and a necessity for markets to both accelerate the energy transition and prepare for growing climate impacts.

Tools for Identifying Risk

Climate Risk Portfolio Screening: the Right Tool for the JobThough the TCFD recommendations do offer guidance to disclosing climate risk, the process of scanning assets for exposure raises a number of challenges — from accessing raw climate data to selecting appropriate indicators and time frame, and interpreting the output while accounting for climate data’s unique complexity and sources of uncertainties.

To support corporations and investors looking to identify hotspots and quantify value at risk in their portfolio of assets, facilities or across their supply chain, Four Twenty Seven has developed a suite of enterprise applications that provide rapid, cost-effective screening across portfolios of 10,000+ assets.

Learn more about CREST, our Climate Resilience Support Tool for corporate climate risk management, and our climate data analytics services for financial institutions.

 


 

Four Twenty Seven in partnership Crowell & Moring LLP hosted a webinar on January 12th to present key recommendations from TCFD and discuss feasibility, next steps, and issues to consider for implementation. View the webinar recording.

Audio Blog: Private Sector Perspectives on Climate Resilience

The Inter-American Development Bank in partnership with Four Twenty Seven and the Global Adaptation and Resilience Investment (GARI) Working Group held a panel discussion, “Private Sector Perspectives on Climate Resilience”, on Monday, November 14th in Marrakesh, Morrocco as a side event to the proceedings at COP22. You can listen to a recording of the full discussion here.

 

Bringing together thought leaders from the private sector and international financial institutions, the panel examined challenges and opportunities facing private actors in the arena of climate resilience. The panelists provided insights into the latest developments in technology, finance and the entrepreneur community on how the private sector can turn climate risks into opportunities and contribute to greater social and economic resilience.

From left to right: James McMahon, Emilie Mazzacurati, Amal-Lee Amin, Jay Koh, Mari Yoshitaka discuss climate resilience

Panelists

  • Amal-Lee Amin, Chief Climate Change and Sustainability Division, IDB
  • Emilie Mazzacurati, Founder and CEO, Four Twenty Seven
  • Jay Koh, Founder & Chair, Global Adaptation & Resilience Investment Working Group (GARI)
  • James McMahon, CEO, The Collider
  • Mari Yoshitaka, Chief Consultant of Clean Energy Finance Division, Mitsubishi UFJ Morgan Stanley Securities

From Policy to Markets: the New Climate Agenda

The election of Donald Trump as President of the United States comes at a time where the world needs more engagement in climate policy, and threatens to derail the world’s efforts to keep global warning below 1.5oC. Financial markets’ interest in low-carbon and resilience finance can help counter-balance the expected scaling back of U.S. engagement.

Trump’s Climate Agenda

Myron Ebell, a well-known climate denier, is on Trump’s shortlist for nominees to the EPA.
Myron Ebell, a well-known climate denier, is on Trump’s shortlist for nominees to the EPA. Source: New York Times

While Donald Trump as a candidate did not expound much on his views on climate policy beyond calling climate change “a hoax” and promising to revive the coal industry in the U.S., the Republican agenda on climate change is well established. Trump’s short list of potential nominees for EPA and Dept. of Energy seems to confirm his alignment with the most conservative aisle of the Republican party on all things climate and environment. We expect the impact of the Trump administration on climate policy to be three-fold:

First, we anticipate a hard stop or slow down of U.S. efforts to reduce greenhouse gas (GHG) emissions, starting with the Clean Power Plan, mired in court since 2015, but also including other environmental regulations on air, water and land conservation. The incoming administration will likely face legal challenges since the Supreme Court mandated the EPA to regulate GHG emissions under the Clean Air Act, but these typically unfold over years and the EPA can also count on industry-led lawsuits to help bring down some existing or in progress regulations.

Second, we expect a sharp budget cut for the EPA, but also for development aid related to climate change (the U.S. is an important contributor to development finance institutions like the World Bank and the Inter-American Development Bank) and grants and subsidies to support local government. The Obama White House has been instrumental in providing concrete support and resources on adaptation and resilience, in particular with the Climate Data Initiative and the Climate Resilience Toolkit – the future of these programs is now called into question. Trump may also consider cutting funds for critical agencies like NOAA and NASA, which could impact long term climate data collection and analysis, similar to what was experienced in 2013 with the ‘sequester’.

Third, the U.S. will likely shift from being a driving force for a strong global climate agreement to becoming a negative influence, that may provide an excuse for other countries to slow down their own efforts. While the future of the Paris agreement is not called into question even if the U.S. withdraws, the effectiveness of multilateral efforts will be undermined by the absence of the second largest emitter in the world at the table. It is unclear at this point if the EU and China can and will jointly take over that leadership role, but together they could provide a stabilizing influence and governments in both regions take climate change very seriously.

Market Forces At Play

However, many analysts have noted that even without policy support going forward, the transition to the low-carbon economy is already well underway. Trump is unlikely to succeed at reviving the coal industry with low natural gas prices, and renewables and low-carbon technologies have largely reached the point where they compete effectively with fossil fuel sources. Financial markets are providing steady support for new renewable and energy efficiency projects, with over $65.5B worth of green bonds issued in 2016 YTD.

The world needs to step up adaptation finance by over 400 percent.
The world needs to step up adaptation finance by over 400 percent. Source: WRI

The private sector’s support is also going to be needed for adaptation and resilience. Disengaging from climate policy at a time where each year breaks new heat records, and 2016 is already locked into being the hottest year ever on record does not bode well for the future. Mercer estimates climate change will cause $1.5 trillion of potential impact of climate on returns for portfolios, asset classes and industry sectors, and impacts on communities and human welfare will be even more devastating.

UNEP estimates the financing needed for adaptation will be at least $100B a year, while current adaptation funding from multilateral organizations hovers around $25B a year. While there is a strong consensus over the need to bring more private capital into adaptation and resilience investments, meaningful flows are yet to materialize.

Mobilizing Private Capital for Adaptation

In this context, the discussion paper released today by the Global Adaptation and Resilience Investment (GARI) working group brings welcome insights into how investors see opportunities and barriers to adaptation investments. GARI was launched at Paris COP21, in conjunction with the UN Secretary General’s A2R Climate Resilience Initiative, to bring together private investors and other stakeholders to focus on the practical intersection of investment and climate adaptation and resilience. At COP22, GARI released Bridging the Adaptation Gap, a discussion paper that summarizes the discussions of over 150 private investors and other stakeholders in 2016.

The paper confirmed a high level of awareness among participants, with 70 percent of private investors surveyed declaring they see both risk and investment opportunity from the impact of climate change. Seventy-eight percent of respondents thought evaluating the physical risk from climate change was “very important,” and over 60 percent confirming that they were already, in fact, considering climate risk in their investment portfolio. The lack of a common approach to measuring climate risk, however, was identified as a critical barrier, with respondents calling for a transparent, practical approach to assess physical climate risk.

Where are the investment opportunities in adaptation? GARI maps the opportunities in key sectors. Source: Bridging the Adaptation Gap discussion paper.
Where are the investment opportunities in adaptation? GARI maps the opportunities in key sectors. Source: Bridging the Adaptation Gap discussion paper.

GARI also brought attention to investors’ interest in opportunities for investments in adaptation and resilience. Seventy percent of participants indicated they would consider making investments that supported adaptation to climate change or climate change resilience now. The paper catalogs various investment types, including existing infrastructure, corporate, and fixed asset investments that support adaptation and resilience to climate change. Over 60 percent of respondent investors are considering investments today in resilient infrastructure and in companies whose products address the impact of climate change on water, agriculture, healthcare, energy, and financial services.

Conclusion

The engagement shown by GARI participants, which includes some of the largest financial institutions in the world, opens the door to bringing private investors into a number of adaptation opportunities in need of funding, such as developing and deploying new and existing technologies to help deal with the effect of drought in agriculture, better flood prevention, resilient retrofits to infrastructure and cool, efficient housing.

Not all adaptation projects are suited to private sector investments however, and banks will not replace governments in investing in social capital, development projects and lifting the most vulnerable out of poverty. But leveraging and guiding financial flows towards projects that enhance economic and social resilience create a win-win opportunity and a powerful way to continue to make progress towards a low-carbon and resilient world in spite of political headwinds.

by Emilie Mazzacurati

Supply Chain Risk, on SustainabilityDefined

Supply Chain Risk on SustainabilityDefinedSustainabilityDefined is the podcast that seeks to define sustainability, one concept (and bad joke) at a time. Hosted by Jay Siegel and Scott Breen. Each episode focuses on a single topic that helps push sustainability forward. They explain each topic with the help of an experienced pro.

CEO Emilie Mazzacurati joins the show for Episode 14 to discuss supply chain risk, leading with the dire news that the world may run out of coffee and chocolate by 2050! How is that possible, you ask? Emilie helps Jay, Scott, and their listeners understand why supply chains are so critical to delivering the goods we love, and how understanding the effects of climate change could help us avert a world without coffee and chocolate. Click the audio player above to listen in!

Audio Blog: Engaging the Private Sector on Climate Resilience

Four Twenty Seven CEO Emilie Mazzacurati discusses how the private sector is responding to climate change risks and highlights opportunities for local governments to engage with local businesses on climate resilience in this audio recording from a panel on The Economic Impacts of Climate Change at the 2016 California Adaptation Forum.

Follow along with Emilie’s talk in the slides below.

Four Twenty Seven Comments to the SEC

Comment Letter from Four Twenty Seven to Securities and Exchange Commission on Concept Release S7-06-16. (Download full letter here)

 

July 21, 2016

Dear Mr. Fields,

I write on behalf of Four Twenty Seven, Inc., a climate risk analytics and market intelligence firm. We submit this letter of comment for your consideration on SEC Concept Release S7-06-16: Business and Financial Disclosure Required by Regulation S-K.

We warmly welcome the SEC’s renewed engagement and consideration of climate change risk and sustainability issues in corporate risk disclosure. Providing guidance around climate risk disclosures is a critical step not only to help ensure financial markets will not be blindsided by predictable risks, but also to ensure that investors send the appropriate price signals to the decision-makers for the underlying assets – from corporate boards to public officials and real estate owners – thus providing an incentive to better prepare for and adapt to the physical impacts of climate change.

Our comments stem from years of working closely with Fortune 500 corporations to help them understand climate change impacts, quantify risk and monetize costs. The analysis we provide are used by these corporations to inform whether any climate-related risk they face may reach the materiality threshold, and to fulfill disclosure and reporting needs including 10-K filings, CDP reports and SASB metrics. We anticipate this type of analysis will need to become widespread for corporations to comply with the forthcoming guidance from the TCFD, and wanted to share our lessons learned from our past and current work.

Our comments, detailed below following the questionnaire structure, center around two key takeaways:

  1. The Guidance released in 2010 on climate change disclosure was a useful contribution to framing the breadth of issues to be considered around climate change impacts on corporate value and equity risk, but has not been used and applied by the industry as it should have. We recommend the SEC enforces systematically its requirement to disclose material risks, include those related to climate change.
  2. Corporations should be required to provide greater details on how they are incorporating climate data into decision-making processes and perform vulnerability assessments at the asset-level for both corporations and investors, even if the disclosure itself is consolidated. They should demonstrate that they are utilizing fully the wealth of climate data and projections that are available, and leverage sophisticated techniques and models to incorporate uncertainty into their decision processes. Climate risk analysis should rely on common standards, assumptions and scenarios to enable comparison across assets and across markets.

We hope our comments are of use and are available should you have any follow-up questions.

 

Download Four Twenty Seven’s Comment Letter (FourTwentySeven_SEC_ConceptRelease_CommentLetter) for our detailed comments on the SEC Concept Release.

Related comment letters from other stakeholders for the SEC Concept Release are also available for download for information: