Most large companies recognize the risks climate change poses to their facilities, operations, and supply and distribution chains. And many of these companies are letting their stakeholders know how climate risks and opportunities will affect their bottom line.
Currently, much of this information is made public through voluntary reporting to non-profit organizations, in corporate sustainability reports, and, for publicly-traded companies, filings with the Securities and Exchange Commission. In our research on company strategies to manage climate risks and opportunities, we have found that the quality of reporting and level of detail varies extensively from company to company, and sector to sector.
Reflecting the growing importance of climate change as a material set of risks for companies to manage, finance ministers from 20 major economies asked the Financial Stability Board (FSB) to review the financial implications of climate change. The G-20 Finance Ministers established the FSB after the 2008 financial crisis to monitor and make recommendations on the global financial system. The FSB convened an industry-led task force to develop voluntary recommendations to better, and more consistently, integrate into financial filings the risks and opportunities posed by physical climate impacts and the transition to a lower carbon economy.
In a speech, “The Tragedy of the Horizon,” describing the impetus for creating the FSB task force, Bank of England Governor Mark Carney said: “We don’t need an army of actuaries to tell us that the catastrophic impacts of climate change will be felt beyond the traditional horizons of most actors – imposing a cost on future generations that the current generation has no direct incentive to fix.”
In December 2016, the task force, chaired by Michael Bloomberg, released recommendations focused on four areas of climate-related financial disclosure: governance, strategy, risk management, and metrics and targets.
C2ES commends the task force on its efforts to shine a light on the risks we are already facing from climate change, and to enhance the transparency we need to better understand and address them over the long term.
In our comments submitted on the recommendations, we suggested that the task force:
- Provide additional guidance on the timeframes companies would use for conducting scenario analysis of their business models and portfolios. For example, if a company is reviewing an investment with a short time horizon, a scenario running out to 2050 or longer might not be helpful.
- Provide additional guidance for companies on how to select the appropriate scenario tools to assess climate risks.
- Provide additional guidance on how mainstream financial filings can interact with corporate sustainability reports in a consistent way given that financial data and sustainability data have different levels of precision and timelines.
- Consider how implementation of the recommendations could involve a “maturity model” that would allow companies to self-assess their progress, benchmark against peers, and influence executive decision-making. An example of this type of model is the Electric Power Research Institute’s Electric Power Sustainability Maturity Model.
- Provide additional implementation guidance for sectors that the recommendations currently do not reference specifically, such as for information technology, telecommunications, health care, consumer products, and professional services. Translating climate risks and opportunities into material financial impacts on income statements and balance sheets requires sector-specific guidance. As a starting point, the recommendations provide sector-specific guidance for sectors with high greenhouse gas emissions and energy and water use. Climate-related financial disclosures will be more helpful if they are adopted economy-wide so additional sector-specific guidance may be useful.
- Engage with stakeholders to identify ways to promote consistency across voluntary reporting regimes to reduce the burden on data preparers.
Many companies will be interested in demonstrating to investors and stakeholders that they are reviewing their corporate sustainability reports and environmental, social, and governance disclosures in line with the task force’s recommendations. An iterative process for enhancing climate-related financial disclosure will likely be needed to make this possible.
We believe the task force recommendations will help ensure that companies take a long view and avoid the “tragedy of the horizon.”