Asset managers need companies to provide climate risk disclosure that is clear, precise, and tailored to specific sustainability guidelines. While there are numerous third-party frameworks that asset managers are using, the Task Force on Climate-Related Financial Disclosures (TCFD) is the most widely endorsed climate change reporting framework. Company disclosure in line with the TCFD framework is becoming a requirement by shareholders. Sustainability managers can begin preparing today by understanding the disclosure requirements and building their climate data management systems.
In 2016, the G20 Finance Ministers and Central Bank Governors became concerned that climate change was a risk that could potentially lead to financial instability. They were also concerned there was inadequate and inconsistent disclosure standards. Given these concerns, the Financial Stability Board’s (FSB) chair Mark Carney was tasked with reviewing how the financial sector can better account for climate-related issues. The Task Force, chaired by Michael Bloomberg, was asked to develop voluntary, consistent climate-related financial disclosures that would be useful to investors, lenders, and insurance underwriters in understanding material climate-related risks. Following a public comment period in 2017, the TCFD released its final recommendations report and supplemental materials including:
The Task Force structures its recommendations around four key areas (see Table 1).
Table 1 - Recommendations for Climate-Risk Disclosure
Governance - The organization’s governance around climate-related risks and opportunities | Strategy - The actual and potential impacts of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning where such information is material | Risk Management - The processes used by the organization to identify, assess, and manage climate-related risks | Metrics and Targets - The metrics and targets used to assess and manage relevant climate-related risks and opportunities where such information is material |
Describe the board’s oversight of climate-related risks and opportunities. | Describe the climate-related risks and opportunities the organization has identified over the short, medium, and long term. | Describe the organization’s processes for identifying and assessing climate-related risks. | Disclose the metrics used by the organization to assess climate-related risks and opportunities in line with its strategy and risk management process. |
Describe management’s role in assessing and managing climate-related risks and opportunities. | Describe the impact of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning. | Describe the organization’s processes for managing climate-related risks. | Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks. |
Describe the resilience of the organization’s strategy, taking into consideration different scenarios, including a 2°C scenario. | Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organization’s overall risk management. | Describe the targets used by the organization to manage climate-related risks and opportunities and performance against targets. |
Companies are unlikely to face divestment or dissenting shareholders immediately, but TCFD disclosure for all intents and purposes is no-longer optional. There will be time for companies to fall in line with reporting expectations, and this is more likely to be driven by regulators than investors.
Companies should start now before full compliance with sustainability disclosure standards is required. This is an iterative process. Starting now with an imperfect disclosure is better than waiting until the internal practices and procedures are in place.
Sustainability managers should consider taking the following steps:
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