March 21, 2018 – 427 ANALYSIS. The first year of reporting under Art. 173 in France saw limited uptake of disclosures of physical risk and opportunities. Our review of disclosures from 50 asset owners in France shows only a quarter of respondents included substantial analysis and metrics on their exposure to physical impacts of climate change. We find insurance companies AXA and Generali provided the most detailed analysis for property portfolio, while FRR and ERAFP were the only pension funds to provide an initial assessment of physical risk exposure in their equity and fixed income portfolios.
Art. 173: the world’s first legal requirement to disclose climate risk
Article 173 of the French Law on Energy Transition and Green Growth passed August 2015 requires major institutional investors and asset management companies to explain how they take Environmental, Social and Governance (ESG) criteria into account in their risk management and investment policies. These institutions are also asked to report on the impacts of both physical risks and ‘transition’ risks caused by climate change on their activities and assets.
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. Its implementing decree invites these organizations to establish scenarios and models to take into account climate risks impacts on the value of their portfolios.
Article 173 covers publicly traded companies, banks and credit providers, asset managers and institutional investors (insurers, pension or mutual funds and sovereign wealth funds). In addition, 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, including both physical impacts of climate change and transition risks (impact of the transition to a low-carbon economy).
The inclusion of physical impacts of climate change in financial risk analysis is in line with the industry-led Task Force on Climate-related Financial Disclosures (TCFD) recommendations report, released in July 2017.
What did financial institutions report?
We conducted a desktop analysis of the 2017 reports (applying to 2016 portfolios) to understand how financial institutions responded to the requirements laid out by Art. 173 in the first compliance year. We reviewed 50 asset owners in France, including public pension funds, sovereign wealth fund and insurance companies, with an aggregate €5.5 trillion euro ($6.8tn) under management. Our analysis included all the public entities covered by the Article 173, as well as private insurers with asset under management above €2bn. Insurance companies play a particularly important role as asset owners in France, where individual savings are massively invested in life insurance savings products. French pension funds, on the other hand, are relatively small due to France’s pay-as-you-go retirement system.
We were able to find Art. 173 reports for 36 out of 50 organizations. It is possible that, in spite of our best efforts, we failed to locate reports. However, Art. 173 has a ‘comply or explain’ provision which also makes it acceptable not to publish a report if one can justify climate change is not a material risk.
Among the Art. 173 reports, we found 29 from insurance companies and seven from public entities. Among them, 20 organizations (40%) discussed only their carbon footprint and/or their exposure to energy transition risk, without including physical risk disclosures.
A small group of organizations (8%) mentioned physical risk as a topic they were exploring but not yet able to report on. Most of them emphasized the lack of tools and models as a major impediment to reporting physical risk.
All in all, we found 12 financial institutions (24%) of the institutions under review made an explicit attempt to disclose their exposure to physical climate risk.
We broke down this latter group in three categories. Eight companies (16%) provided an analysis of the physical risks threatening either their operations or property portfolios (for insurance), ranging in scope from a few buildings to €15bn worth of assets in the case of AXA. Most of the reports contain limited details on methodology and findings.
Two companies (4%) performed what we call a “top-down” analysis, working with investment advisor Mercer to perform a multi-asset class, sector-level analysis of climate risk using Mercer’s proprietary climate risk model, which blends transition and physical risk. Finally, two high profile investors, pension fund ERAFP and sovereign wealth fund FRR, included an initial assessment of climate risk in their equity and fixed income portfolios, at the asset level.
Table 1 presents a detailed breakdown of how those organizations take physical climate risks into account:
Case Studies: How do Investors Report on Physical Risk?
The best student in this 2016 reporting vintage is AXA France. AXA received the “International Award on Investor Climate-Related Disclosures” from the French Ministry for the Environment, for analyzing 15 billion euro of assets (real estate and infrastructures). The analysis takes into account most frequent European natural disasters and the geographical location of each individual asset as well as the destruction rate of their building materials. They found out that, over 30 years, the accumulated loss would aggregate to 24 million euro. The insurance company also reported that if a centennial storm was to occur, the portfolio would be impacted by a 15.2 million euro loss. While AXA provides some of the most detailed analysis, it also noted that “this new kind of analysis needs to be improved in order to take into account more natural disasters and other portfolios”.
The following graphs demonstrate the physical risk exposure to windstorms for the analyzed infrastructures. On the left, the graph displays the annual average destruction rate, which is linked to the average loss generated by windstorms every year (0.8M€ on average). The map on the right shows the destruction rates due to a 100-year event, with an estimated loss of 15.2M€.
Source (Award on Investor Climate-related Disclosures, AXA Group, October 2016: https://cdn.axa.com/www-axa-com%2Fcb46e9f7-8b1d-4418-a8a7-a68fba088db8_axa_investor_climate_report.pdf)
Generali France also provided a complete and detailed evaluation of the potential impact of physical risks on their property assets. They analyzed 112 assets, mainly in the Paris Area, accounting for 60% of their owned assets. Generali took into account two kinds of physical risks, flood and drought, to rate their assets from “high” to “very low” risk. Regarding drought, 3 assets enter the medium-risk category. As only 12 assets have been analyzed (Paris and the overseas departments being excluded), this risk is important as it accounts for 25% of their analysis. On the other hand, 10 out of 112 buildings owned by Generali France are exposed to a high risk of flood. They are mainly located in the Paris Area and would be heavily affected by a Seine flood.
To sum up, both AXA and Generali reports are valuable examples of emerging best practices as they show the willingness of those organizations to take physical risks into account in their reporting practice. However, their analyses would benefit from being extended to a broader portfolio and to other natural events.
In November 2017 the French pension fund, “Fonds de Réserve pour les Retraites” (FRR), released a report addressing Article 173 requirements. Four Twenty Seven performed the analysis, and applied its proprietary methodology to measure the types and levels of climate risk embedded in FRR holdings. Portfolio exposure was evaluated according to their respective industry and sector. The analysis produced a sector risk score based on three indicators:
This hotspot analysis gave FRR tools to get an initial understanding of its portfolios’ exposure. It highlighted strongly exposed sectors such as Materials and Consumer Staples, due to their dependency on natural resources, and Pharmaceuticals and Electronics hardware, due to their complex and global supply chains. Conversely, the results brought out the low exposure of service-based industries such as Media and Telecommunication.
Reporting on physical climate risk is a challenging task for financial institutions – many organizations lack the tools, models and data to perform a comprehensive assessment of their portfolios, whether they’re composed of real assets or equities. As TCFD reporting becomes standard for financial institutions and corporations, pressure will increase to report on physical risk. We expect fast changes in disclosures in this regard, starting as early as the 2018 reporting season.
This analysis was written with support from Thomas Poloniato.
Four Twenty Seven’s ever-growing database now includes close to one million corporate sites and covers over 1800 publicly-traded companies. We offer equity risk scoring and real asset screening services to help investors and corporations leverage this data.
The European Bank for Reconstruction and Development (EBRD) and the Global Centre of Excellence on Climate Adaptation (GCECA) have announced an initiative focused on building climate resilience in the financial sector. Throughout the project Four Twenty Seven and our partners, Acclimatise, are supporting the knowledge development on physical climate risk and resilience metrics for the financial sector. The project will culminate in an event in May in London: “Advancing TCFD guidance on physical climate risk & opportunities.”
The European Bank for Reconstruction and Development (EBRD) and the Global Centre of Excellence on Climate Adaptation (GCECA) are hosting an event: “Advancing TCFD guidance on physical climate risk and opportunities”, which will be held on 31 May at the EBRD’s headquarters in London. This event will build on the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), which crystallised a growing concern of investors and business leaders over the physical impacts of climate change on the economy and financial markets.
The TCFD’s final recommendations, released for the G20 summit in June 2017, recommended the inclusion of metrics on physical climate risk and opportunities into financial disclosures and called for further research and concrete guidance over what the appropriate metrics should be. Corporations and financial institutions need to agree on common metrics to ensure transparency and data comparability. Since then, the recommendations of the European Union’s High Level Expert Group on sustainable finance, released in January 2018, have also highlighted the need for a common taxonomy on climate change adaptation and metrics for physical climate risk and opportunity disclosures.
This event will be a forum for senior representatives from the financial and business community to discuss and identify the way forward for the development of metrics for disclosing physical climate risk and opportunities, as well as pointers for integrating physical climate risk considerations in scenario-based decision making by businesses and financial institutions.
The conference is sponsored by the EBRD and GCECA, and will feature the findings from expert working groups that include representatives from Allianz, APG, AON, Bank of England, Barclays, BlackRock, Bloomberg, BNP Paribas, Citi, DNB, Deutsche Asset Management, Lightsmith Group, Lloyds, Meridiam Infrastructure, Moody’s, OECD, S&P Global, Shell, Siemens, Standard Chartered, USS and Zurich AM, Acclimatise and 427 are providing the Secretariat function.
A detailed agenda will be circulated in due course. Please note that this is an invitation only event. Additional details are available on EBRD’s event page.
From Recommendations to Action
March 15, 2018 – 427 ANALYSIS. The EU laid out a clear plan to move towards mandatory climate risk disclosure as part of a new set of regulations to finance sustainable growth and support the transition to a low-carbon economy. The European Commission’s Action Plan lays out a two year timeline for implementation, with a goal to create a taxonomy for climate adaptation finance by the end of 2019. These regulations from the EU will drive change into financial markets globally and set standards on reporting, disclosures and infrastructure resilience that will likely set the bar for the rest of the world.
The European Commission recently released its Action Plan: Financing Sustainable Growth to establish a regulatory framework that supports the goals of the Paris agreement. The Action Plan calls for transformation of the whole financial system and to enable the financing a sustainable, resource-efficient economy.
The Action Plan builds on the recommendation from a high profile expert group, the High-Level Expert Group on Sustainable Finance (HLEG), which was created by the European Commission in December 2016. The group included experts from banking, insurance, asset management and stock exchanges. Its final recommendations to the Commission, released in January acknowledged the responsibility of the financial system to drive change towards “enduring and inclusive economic prosperity”. HLEG recommendations aimed to both promote sustainable investments, so that capital reaches sustainable projects and also to ensure that the financial system itself addresses risk and builds resilience.
Incorporating many of the recommendations of the HLEG, the Commission’s Action Plan lays out ten specific actions, setting deadlines within the next two years, with a number of thematic sub-actions that willbe pursued simultaneously. Action 1 lays the groundwork for many of the following actions as it will establish a Technical Expert Group on Sustainable Finance, with the responsibility of drafting a standardized EU sustainability taxonomy , including climate mitigation by Q1 2019 and adaptation by Q3. This effort will be supported by legislation this year that mandates the creation of the taxonomy.
The 10 actions are summarized in this infographic from the European Commission:
Of most immediate importance to investors is Action 7, which calls for the proposal by Q2 2018 of legislation mandating investors to explicitly consider sustainability factors in their investment decisions and disclose their methodology of doing so. This effort is particularly focused on improving the consistency and transparency of climate risk considerations by investors.
Likewise, Action 9 is focused on improving the methodologies and practice of corporate risk disclosure. The Commission will publish a report on current reporting legislation by Q2 this year, which will inform a revision of corporate reporting guidelines to help them align with the TCFD recommendations, by Q2 2019. Later this year the Commission will develop a European Corporate Reporting Lab, under the European Financial Reporting Advisory Group, to help develop best practices for corporate reporting. The goals of Action 10 will support these actions by supporting a shift in corporate governance. It aims to improve transparency and combat long-termism, by engaging with stakeholders around corporate governance starting by Q2 next year.
Revamping Credit Ratings
The Commission also commits to revamping the ways in which credit ratings incorporate sustainability metrics into their scoring. Through Action 6, the European Securities Markets Authority (ESMA) will examine the credit ratings’ current practices around this topic by Q2 2019 and the Commission will pursue comprehensive research on reporting standards, exploring the potential of mandating agencies to integrate specific sustainability metrics into their standards.
To improve consumers ability to identify sustainable investments, Action 2 calls for the technical expert group to publish a report exploring green bond standards by Q2 2019 and the Commission will consider expanding the EU Ecolabel to include financial products, initially focusing on retail investments. Likewise, Action 4 says that by Q2 2018, the MiFID II and IDD rules will be updated to ensure that sustainability preferences are considered when banks, investment firms and insurers offer accounts to clients and by the end of the year the ESMA will include these provisions in their guidelines. Through Action 5 the Commission will adopt acts that improve the transparency of sustainability benchmarks by Q2 2018.
Comprehensive Sustainability Support
The Commission identifies a lack of technical expertise as a challenge to pursuing sustainable infrastructure projects and aims to confront this by to increasing the technical support available to investors. It will run a pilot project offering tools for sustainable infrastructure projects, from 2019-2023 through Action 3.
Action 8 states that the Commission will consider including sustainability frameworks in prudential requirements, looping in the European Insurance and Occupational Pensions Authority (EIOPA).
“A Blueprint” for Change
While the HLEG emphasized that its report is only the beginning of an enduring effort to create a resilient financial system that supports a sustainable society, the Commission’s resulting Action Plan clearly defines the next steps. And as HLEG also emphasized its report’s relevance for financial sectors worldwide, the Commission’s Action Plan states that a “coordinated, global effort is crucial.” As “the HLEG hopes to stimulate a wide public debate that helps shift Europe’s financial system from post-crisis stabilization to supporting long-term growth,” that same widespread conversation is essential to driving global change. These regulations from the EU, as is often the case, will drive change into financial markets globally by setting new standards global financial institutions must meet.
For more resources on building a sustainable financial sector, read about Four Twenty Seven’s work providing the technical secretariat for an EBRD and GCECA initiative to build a resilient financial sector and download the GARI Investor Guide to Physical Climate Risk and Resilience.
Reaching the goals of the Paris agreement, and financing a sustainable, resource-efficient economy, requires a transformation of the whole financial system. Understanding that private-sector investments must be joined by a transformation of the regulatory landscape, the European Commission created the High-Level Expert Group on Sustainable Finance (HLEG) in December 2016. As the need for reform spans across all facets of the sector, HLEG members include experts from banking, insurance, asset management, stock exchanges and others. The group acknowledges that a sustainable society depends upon enduring and inclusive economic prosperity and that the financial system has a responsibility to drive change towards this sustainability. Thus, the HLEG aims to both promote sustainable investments, so that capital reaches sustainable projects and also to ensure that the financial system itself addresses risk and builds resilience.
After releasing an interim report and soliciting public feedback in July, the HLEG released its final recommendations for actions to facilitate this financial system reform. The report describes a set of priority recommendations and a set of “cross-cutting recommendations.” The former include developing an EU sustainability taxonomy, pushing investors to focus on ESG factors and consider broader time horizons, creating European sustainability standards for green bonds and other financing options, identifying investment needs by focusing first on climate mitigation, providing sustainable finance options for retail investors, and integrating sustainability into both the governance and financial oversight of financial institutions. The “cross-cutting” recommendations include embracing long-term vision, empowering citizens to shape a sustainable financial sector, monitoring sustainable investment and delivery, integrating a “Think Sustainability First” outlook throughout EU policy, and promoting global sustainable finance.
HLEG acknowledges that there are other social and environmental issues that must be addressed alongside climate change. Emphasizing that this report is only the beginning of an enduring effort to create a resilient financial system that supports a sustainable society, HLEG also states the report’s relevance for financial sectors worldwide. As “the HLEG hopes to stimulate a wide public debate that helps shift Europe’s financial system from post-crisis stabilization to supporting long-term growth,” that same widespread conversation is essential to driving global change.
For more resources on building a sustainable financial sector, read about Four Twenty Seven’s work providing the technical secretariat for an EBRD and GCECA initiative to build a resilient financial sector and download the GARI Investor Guide to Physical Climate Risk and Resilience.
Four Twenty Seven provides the technical secretariat for the European Bank for Reconstruction and Development (EBRD) and Global Centre of Excellence on Climate Adaptation (GCECA) initiative focused on building climate resilience in the financial sector. Over the coming months, Four Twenty Seven and our partners, Acclimatise, will be releasing briefing papers on physical climate risk and resilience metrics for the financial sector. The project will culminate in an event in May 2018 in London: “Towards a Resilient Financial Sector: Disclosing Physical Climate Risk & Opportunities”.
Read EBRD’s full press release below:
“The EBRD is partnering with the Global Centre of Excellence on Climate Adaptation (GCECA) in a joint initiative to help strengthen the resilience of the financial sector to the impacts of climate change.
Investors and businesses are becoming increasingly aware of the need to understand and manage the risks associated with climate change. In order to explore options for addressing these issues, the EBRD and GCECA will organise a conference entitled “Towards a Resilient Financial Sector: Disclosing Physical Climate Risk & Opportunities”, to be held at the EBRD’s London Headquarters on 31 May 2018.
The conference will bring together the financial, technical and policy perspectives to shape market action on climate resilience. The focus will be on improving financial sector awareness of climate risks and their impacts on investments, as well as facilitating the emergence of climate risk and resilience metrics, and identifying ways on which investors and businesses can integrate climate change intelligence into their business strategies and investment planning.
Announcing the cooperation Craig Davies, EBRD Head of Climate Resilience Investments, said: “We are very pleased to partner with the GCECA, the first international institution with a specific focus on climate change adaptation. Building climate resilient economies requires broad market action by businesses and investors, alongside effective government policies. We see great opportunities for working with the GCECA and a wider range of other stakeholders to enable businesses and investors to realise the value that can be created through building climate resilience.”
“We are grateful that the Paris Agreement has put Climate Adaptation on a par with mitigation but there is a long way to go. Understanding Climate Adaptation is crucial if we want to put paper into practice.”
Christiaan Wallet, Operations Director of GCECA
The announcement was made today in Bonn at the COP23 climate conference which this year is focussing on the implementation of the 2015 Paris Agreement on climate change. The EBRD is organising four panels on key climate issues and Bank representatives are also taking part in many more events.
The EBRD is a major investor in climate finance in many of the 38 emerging economies where it works, a driving force in energy efficiency projects, a pioneer in the development of renewable energy sources and an increasingly important player in adaptation to climate change, having signed almost 180 climate resilience investment since 2011. Under its Green Economy Transition (GET) approach, the EBRD aims to dedicate 40 per cent of its annual investment to green finance by 2020 and is well on the way to achieving this objective.
The Global Centre of Excellence on Climate Adaptation helps countries, institutions and businesses to adapt to a warming climate, which is increasing the frequency of natural disasters and causing economic disruptions. It is bringing together international partners, including leading knowledge institutes, businesses, NGOs, local and national governments, international organisations and financial institutions. A technical secretariat has been created and funded by the EBRD.”
At COP23 Four Twenty Seven and Deutsche Asset Management jointly released a white paper featuring a new approach to climate risk management in equity portfolios. Measuring Physical Climate Risk in Equity Portfolios showcases Four Twenty Seven’s Equity Risk Scoring methodology, which identifies hotspots in investment portfolios by assessing the geographic exposure of publicly-traded companies to climate change. Our methodology tackles physical risk head on by identifying the locations of corporate production and retail sites around the world and their vulnerability to climate change hazards, such as sea level rise, droughts, floods and tropical storms, which pose an immediate threat to investment portfolios.
Deutsche Asset Management is leveraging Four Twenty Seven’s Equity Risk Scores to satisfy institutional investors’ growing desire for more climate resilient portfolios and design new investment strategies. “This report is a major step forward to addressing a serious and growing risk that investors face. To keep advancing our efforts, we believe the investment industry needs to champion the disclosure of once-in-a-lifetime climate risks by companies so we can assess these risks even more accurately going forward,” said Nicolas Moreau, Head of Deutsche Asset Management.
Four Twenty Seven’s equity scoring methodology includes Operations Risk, Supply Chain Risk and Market Risk:
Since different industries will respond to climate hazards differently, the analysis includes both geographic location and business sensitivity. For Operations Risk, Four Twenty Seven screens each corporate site for its exposure and sensitivity to a set of climate hazards that include extreme precipitation, sea level rise, hurricanes, heat stress, water stress and wildfires. To calculate Supply Chain Risk and Market Risk, Four Twenty Seven uses companies’ financial data, such as revenues and production. The image below shows an example of extreme precipitation risk for 68,000 corporate sites belonging to France’s benchmark index CAC40 (France’s 40 largest public companies).
This comprehensive, data-driven scoring effort culminates in a composite physical risk score that allows for comparison and benchmarking of equities and indices. This integrated measure provides a point of entry to understand and address climate risk, engage with corporations and identify risk mitigation strategies.
The white paper includes a relative ranking of CAC40 companies, as shown below.
Asia is particularly vulnerable to climate change. Five out of six people in Asia live in climate hotspots. The Asian Development Bank warned that, without mitigation action, Asia will experience temperature rise of six degrees centigrade by the end of the century. Of extreme concern is the region’s vulnerability to sea level rise. For example, China leads the world in terms of coastal risk, with 145 million people and economic assets located on land threatened by rising seas.
To better understand the implications of these projections for financial markets, Four Twenty Seven mapped the physical climate risks for 500 large and mid-cap constituents of an Asia ex-Japan listed equity index. We found that many companies are highly vulnerable to sea level rise in the region. China’s Pearl River Delta is already experiencing a higher than average rate of sea level rise and has many assets that would be exposed to flood risk in a two-meter flood scenario (see below). Many of these are energy assets which are long-lived and high value capital assets that cannot easily be relocated, requiring protection from rising seas if they are not decommissioned.
An explicit example of the economic impacts of extreme weather events and the resulting damage to assets can be seen in the Thailand floods of 2011. This event led to vast repercussions across industries, including car manufacturers, Thailand’s rice industry and even tourism. While these events were most damaging in Thailand, negative impacts were felt internationally. For example, the production of hard drive manufacturers like Toshiba and Western Digital was stalled due to the floods, which affected companies like Lenovo that depend on Asian manufacturing.
Four Twenty Seven’s ever-growing database now includes close to one million corporate sites and covers over 1800 publicly-traded companies. We offer subscription products and advisory services to access this unique dataset. Options include data feeds, an interactive analytics platform and company scorecards, as well as custom portfolio analysis and benchmarking.