June 25, 2018 – 427 REPORT. Regulatory pressure and financial damage are necessitating an increase in physical climate risk disclosure in Australia. In exercising their own due diligence and assessing the exposure to physical climate risks in their portfolios, investors arm themselves with valuable information on corporate risk exposure which they can leverage to engage with companies around resilience. This report explores the connection between climate hazards and financial risks and shares examples of corporate adaptation and investor engagement to build resilience.
The global tide of interest in the Task Force on Climate-related Financial Disclosures (TCFD) has hit the shores of Australian financial markets, steered by regulators concerned about the systemic risk climate change poses to the economy. In 2017 Australian Prudential Regulation Authority’s Geoff Summerhayes was the first Australian regulator to formally endorse the TCFD. “Some climate risks are distinctly ‘financial’ in nature. Many of these risks are foreseeable, material and actionable now,” he said. This sentiment was echoed by John Price of the Australian Securities and Investments Commission in 2018 and reflects growing regulatory concern over climate risk disclosure internationally, as shown by Article 173 of France’s Law on Energy Transition and Green Growth and the 2018 European Commission Action Plan.
This Four Twenty Seven Report, Responding to Economic Climate Risk in Australia, explores the drivers of financial risk in Australia and discusses approaches to addressing this risk. The nation’s dominant industries are particularly threatened by the prevalent climate hazards. For investors, understanding a company’s risk to climate change is an essential first step to mitigating portfolio risk, but must be followed by corporate engagement to build resilience. Institutional investors are increasingly leveraging shareholder resolutions and direct engagement to prompt companies to disclose their climate risks and adapt.
This seminal report aims to inform and support early adoption efforts of climate risk reporting, based on findings from industry-led working groups from the financial sector and corporations. The report calls on companies to perform forward-looking risk assessments and disclose material exposure to climate hazards. It also invites firms to investigate benefits from investing in resilience and opportunities to provide new products and services in response to market shifts.
The Task Force on Climate-related Financial Disclosures (TCFD) seeks to “develop recommendations for voluntary climate-related financial disclosures that are consistent, comparable, reliable, clear, and efficient, and provide decision-useful information to lenders, insurers and investors.” It has crystallised a growing concern among investors and business leaders about the physical impacts that climate change could have on the economy and on financial markets.
The TCFD’s initial report noted a lack of understanding about the impact of climate change on corporate value chains and infrastructure, the channels through which these impacts are transmitted to financial markets, and a lack of transparency in reporting these risks. The final report recommended that financial disclosures should include metrics on the physical risks and opportunities of climate change but did not provide detailed guidance on appropriate metrics.
Without formal or regulatory guidance on metrics and indicators, firms are uncertain about what to include in their disclosures. Investors are therefore likely to receive a heterogeneous mix of financial reports including diverse indicators, metrics, assumptions and timeframes, which will fail to provide comparable data across a portfolio or provide the necessary transparency.
Recognising the challenges in the path towards standardising disclosure of physical risks and opportunities related to climate change, the European Bank for Reconstruction and Development (EBRD) and the Global Centre of Excellence on Climate Adaptation (GCECA) launched an initiative, “Advancing TCFD guidance on physical climate risk and opportunities.” The initiative aims to work with innovative thinkers in the financial and corporate sectors to identify the greatest needs for guidance, research and development. It also seeks to lay the foundations for a common conceptual framework and a standard set of metrics for reporting physical climate risks and opportunities.
The preliminary guidance in this report aims to build on the TCFD recommendations and provide common foundations for the disclosure of climate-related physical risks and opportunities. The report also identifies areas where further research or market action is needed so that detailed, consistent, industry-specific guidelines can be developed on the methodology for quantifying and reporting these risks and opportunities. The project focused on disclosure metrics that are specific to corporations. Improving the quality of firms’ climate disclosures is not just important for them, but also critical to managing climate risks and opportunities in financial markets.
This EBRD-GCECA initiative involved three industry working groups of a dozen participants, with a mix of financial institutions (asset owners, asset managers, banks, insurance), corporations, credit rating agencies, and a financial data provider. Each working group met several times over the first half of 2018 to discuss and consider research questions related to the topic on hand. The working groups debated how best to help the market make progress on disclosure.
The recommendations we developed aim to serve a dual purpose, seeking to improve corporations’ understanding of their own exposure and risk profile as well as opportunities arising from climate change, and provide clear signals for financial institutions to understand risks and opportunities implicit in individual holdings as well as portfolio-wide exposures.
The working groups built on the TCFD guidance, existing reporting frameworks, and an extensive review of literature to develop a set of recommendations on physical risks and opportunities. As a general rule, this report has prioritised recommendations that are consistent with current industry practices and that leverage metrics and frameworks already used for financial disclosures. It also includes a mix of recommendations that focus on providing better information, as well as recommendations that require more sophisticated analysis. In line with the TCFD recommendations, the recommendations of this EBRD-GCECA initiative are geared to facilitating comparability across companies within a sector, industry or portfolio, and to promoting disclosure of reliable and verifiable information.
A corporation’s vulnerability to climate impacts goes well beyond the physical exposure of its facilities. It includes supply chains, distribution networks, customers and markets. Furthermore, a company’s resilience to climate impacts depends on its risk management and business plans, as well as its governance.
Figure ES-1. How climate change affects corporate value chains
The impacts of climate change on corporate value chains depend on where the company operates and what impacts may affect relevant locations, but they also depend on the company’s activities. Corporations whose production processes consume high volumes of water, for example, may be particularly sensitive to changes in drought and the availability of water. Similarly, corporations with high energy consumption or significant use of outdoor labour will experience greater challenges as average temperatures rise, affecting both energy costs and labour productivity.
Recommendation 1: Assess exposure to all first-order climate impacts
Corporations should consider all first-order impacts when undertaking a climate risk assessment – heat stress, extreme rainfall, drought, cyclones, sea-level rise and wildfires – and additional climate hazards relevant to their industries, such as ocean acidification for fisheries. Exposure to climate hazards should be assessed at the local scale, using the most recent climate data and literature.
Recommendation 2: Assess climate risks over the duration of an asset’s lifetime or over the lifetime of a financial instrument
This report recommends that corporations provide more detailed information on the location of their critical operations, suppliers and market, at least at the country-level, as part of segment reporting to enable investors and creditors to conduct analysis on exposure to risk in their portfolio.
Firms should consider climate impacts over the following timeframes,
Recommendation 5: Disclose the impacts of weather variability on value chains
Corporations with moderate or high sensitivity to variability in temperature and precipitation should identify and disclose whether and how changes in temperature and precipitation have materially affected their performance.
Recommendation 6: Perform forward-looking assessment climate-related risks
Corporations should disclose 1) their assessment of the types of climate-related risks to which they may be exposed in the future due to the geographic exposure of their facilities and 2) the estimated financial impacts from the risks they have identified as being material.
Recommendation 7: Describe risk management processes for the physical impacts of climate change
Corporations should describe their processes for identifying, assessing and managing the physical risks of climate change, as noted by the TCFD. For these physical impacts, aspects of particular interest to financial institutions and banks include risk management processes, insurance coverage, planned facility moves or retrofits, corporate adaptation strategy, and engagement with local authorities to build climate resilience locally.
The TCFD also encourages corporations to disclose opportunities related to the impacts of a changing climate. This recommendation is critical to ensuring that businesses and financial institutions continue to thrive in a changing environment. It is also vital for promoting the healthy development of resilience products and services that cater to new market needs for resilience.
The TCFD defines “climate-related opportunity” as “the potential positive impacts related to climate change on an organisation,” and notes that opportunities “will vary depending on the region, market and industry in which an organisation operates.” This report identifies three broad types of opportunities related to physical climate change impacts:
Recommendation 8: Identify opportunities based on managing risks and market shifts
Corporations and financial institutions should strive to identify opportunities in managing existing climate-related risks and responding to emerging risks. Corporations should also assess the potential changes in their value chains, explore potential market shifts as customer needs change and target their products and services to cater to growing demand for adaptation solutions.
Recommendation 9: Assess climate opportunities over timeframes relevant to business planning
Corporations should define the appropriate timescales in which to report opportunities in consultation with their investors. Opportunities in response to managing existing risks that affect recent and current accounts and the next year’s accounts should be reported as part of core financials. Opportunities arising from market shifts are unlikely to be reported quantitatively and are more appropriate for disclosure in general reporting on future business expectations.
Recommendation 10: Disclose business opportunities at the segment level; for critical facilities, disclose resilience benefits at the facility level
Opportunities may be disclosed at different levels to best serve firms and investors. Opportunities due to shifting market demand or new products should be reported at the segment level, in line with risk disclosures. Benefits from managing existing or emerging risks may be disclosed at the segment level (for process or supply-chain improvements, for example). For critical facilities, it may be advantageous for firms to disclose significant resilience upgrades or strategic improvements at the facility level, to showcase good stewardship and provide confidence that critical facilities are protected.
Recommendation 11: Disclose benefits from resilience investments using the same metrics as for risk disclosure
Corporations should acknowledge the importance of accurately accounting for the opportunity effects on their core financials arising from actions to manage current risks and respond to emerging risks. These metrics may include avoided negative impacts on revenues, operating expenses, capital expenses, supply chain costs, value-at-risk, or projected annual average losses.
Recommendation 12: Include business opportunities in qualitative disclosures
The disclosure of opportunities involving market shifts and new products and services can be achieved by qualitative disclosures of the lifecycle of new commercial opportunities. The disclosures may include information on the development stage of endeavours, sector, the size of potential markets, and the length of time until commercial viability.
With regard to climate intelligence for business strategy and financial planning, the TCFD recommendations strongly advocate the development and use of scenarios when analysing climate risks and opportunities. In this context, scenario analysis is intended as a tool to address challenges and acquire key information. Scenarios provide a narrative, either qualitative or quantitative, which “describes a path of development leading to a particular outcome.”
Recommendation 13: Consider current and desired GHG concentration pathways and related warming projections as a basis for scenario analysis of physical climate risks and opportunities
Corporations should not be concerned with developing new climate scenarios themselves. Instead, as a basis for their scenario analysis of physical risk, they should consider at least two main types of existing climate scenarios, based on the Intergovernmental Panel on Climate Change (IPCC):
Recommendation 14: Integrate scenario analysis of physical climate risks and opportunities into existing planning processes to ensure strategic, flexible and resilient businesses and investments
The main reason to undertake scenario analysis is to obtain a comprehensive assessment from firms of their risks and opportunities. Firms should achieve this by exploring different possibilities of what might happen in the future, despite uncertainty and by integrating climate change considerations into their existing business strategies and financial planning.
Recommendation 15: Avoid standardised scenario analysis in order to have a more comprehensive range of outcomes
Firms should look at more than one scenario and multiple climate models in order to have a more comprehensive range of potential outcomes. Although a degree of comparability is desirable, it is also recommended that corporations develop their own scenarios, which should be highly contextual, and based on the views and values of individual corporations.
Recommendation 16: Consider data from a wide variety of sources and scales when developing scenario analysis of physical climate risks
In order to construct plausible physical climate risk and opportunity scenarios, firms should consider inputs from a wide variety of sources and levels of detail. These include scientific data (not only on climate change), macroeconomic data, socio-economic data, data on political economics and policy, corporate data, ‘vision’ and market analysis data, ‘big data’, and so on.
Recommendation 17: Take account of scientific uncertainty inherent in climate data and in scenario analysis of physical risks and opportunities
Corporations and financial institutions are very well accustomed to making decisions within a large spectrum of uncertainty. In the same way, they should consider and manage the uncertainty that surrounds climate data and climate science for scenario analysis. Scientific uncertainty should be taken into account and made explicit when assessing climate-related financial risks and opportunities.
Recommendation 18: Disclose qualitative information that is relevant to the company and its investors
The ultimate objective in disclosing the use of scenarios is to build investor confidence that a company is meaningfully engaged on the topic of climate change, that it is looking at a broad range of outcomes and is responsive and proactive, rather than defensive and reactive. In this context, firms should disclose information on their climate risks and opportunities in the way that is most appropriate to them, as well as to their investors, and to the type of information disclosed or its format (quantitative or qualitative).
Efforts to formalise and standardise the assessment and disclosure of climate-related risks and opportunities are still in their infancy. As science and business continue to progress in their understanding of climate impacts, the recommendations made in this report will evolve over time, informed by emerging practices and the continuous efforts of corporations, financial institutions, credit rating agencies, industry groups, think-tanks, regulators and governments.
Climate disclosures will remain a topic of active research and discussion, and this report aims to support the emergence of market practices that bring transparency to markets and help build resilience in firms and financial institutions.
The EBRD hosted the initiative and funded its technical secretariat. The GCECA provided a secondment to the technical secretariat. The technical secretariat was provided by Four Twenty Seven, the leading provider of intelligence on climate risk to financial markets, and by Acclimatise, an advisory company specialised in adaptation to climate change.
The expert working groups in the initiative included participants from Agence Française de Développement, Allianz, APG Asset Management, AON, the Bank of England, Barclays, Blackrock, Bloomberg, BNP Paribas, Citi, Danone, the Dutch National Bank, DWS Deutsche AM, European Investment Bank, Lightsmith Group, Lloyds, Maersk, Meridiam Infrastructure, Moody’s, S&P Global Ratings, Shell, Siemens, Standard Chartered, USS and Zurich Alternative Asset Management.
The European Bank for Reconstruction and Development (EBRD) and the Global Centre of Excellence on Climate Adaptation (GCECA) have announced details of their conference, “Advancing TCFD guidance on physical climate risk & opportunities.” A culmination of their initiative focused on building climate resilience in the financial sector, the conference will share findings on physical risk and resilience metrics from three expert working groups. Read the press release below, originally published on EBRD’s website:
Findings of industry working groups will be published ahead of the event “Advancing TCFD guidance on physical climate risk and opportunities”
The EBRD and GCECA are hosting an event “Advancing TCFD guidance on physical climate risk and opportunities”, which will be held on 31 May 2018 at the EBRD’s headquarters in London.
Findings about physical climate risk and opportunity disclosure by industry-led working groups, which have been meeting at the EBRD’s headquarters since 2017, will be released at the conference.
This event will build on the recommendations of the TCFD, headed by Mark Carney and Michael Bloomberg. These recommendations highlight a growing concern over the effects of climate change on the economy and financial markets, and the need for investors to be able to assess climate-related risks.
At the conference, senior representatives from the financial, business and regulatory communities will discuss the development of metrics for disclosing physical climate risk and opportunities, and the integration of these disclosures into decision-making.
The confirmed high-level speakers at the conference will include:
The panelists will represent a rich variety of market leaders such as Aon, Citi, Maersk, Moody’s and Standard Chartered, as well as the Bank of England, the French Treasury and the European Commission.
Findings from the expert working groups will also be published. The working groups include representatives from Allianz, APG, Aon, Bank of England, Barclays, BlackRock, Bloomberg, BNP Paribas, Citi, DNB, DWS, Lightsmith Group, Lloyds, Meridiam Infrastructure, Moody’s, OECD, S&P Global, Shell, Siemens, Standard Chartered, USS and Zurich Asset Management. An expert team led by Acclimatise and Four Twenty Seven is providing the Secretariat function to the working groups.
TCFD recommendations, released for the G20 summit in June 2017, call for the inclusion of metrics on physical climate risk and opportunities into financial disclosures by corporations and financial institutions. This is echoed in the recommendations of the European Union’s High Level Expert Group on sustainable finance, released in January 2018, and the Action Plan from the European Commission released in March 2018.
Last month the EBRD become a TCFD supporter, the first multilateral development bank to do so. The EBRD’s 2017 Sustainability Report, to be released later this month, will provide an initial outline of how TCFD recommendations relate to the Bank’s operations. The conference on 31 May will be an important milestone in the Bank’s support for the TCFD process.
Since 2006 the EBRD has invested over €22 billion in projects under its Green Economy Transition approach. Energy efficiency and environmental sustainability have been a priority for the Bank since its creation in 1991.
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.”