Managing Risks For A Changing Climate Sustainalytics Ebook
Managing Risks For A Changing Climate Sustainalytics Ebook
Managing Risks For A Changing Climate Sustainalytics Ebook
a Changing Climate
A Guide for
Institutional Investors
2
Acknowledgements
Morningstar Sustainalytics would like to thank the following
members of our Climate Solutions team for their input and feedback
on this ebook:
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Contents
Introduction: The Financial and Market Burdens of Climate Change 04
*Unless otherwise stated, we use the term climate risk(s) in a broad sense throughout, as the risks (i.e., environmental, business,
societal, existential, etc.) presented by global climate change. Physical climate risk and transition climate risk are later presented with
their own distinct meanings.
Managing Risks for a Changing Climate: A Guide for Institutional Investors Today’s Major Investment Risks Due to Climate Change 6
Extreme Wind
With only partial policy actions by governments and regulators, investors’ evaluations
of issuers’ exposure to climate risks are based, for the most part, on
Purchased Leased Assets Company Use of Sold Products
voluntarily reported information. Without a mandatory and standardized reporting Electricity, Vehicles
Steam, Heating
framework, it’s difficult to gather the necessary data, and harder still to and Cooling
Employee Commute Leased Assets
compare that information between companies and across industries.
Company
Facilities
When conducting climate risk assessments, crucial data is often unavailable and
Fuel and Energy End-of-Life Treatment
the lack of uniformity in reported data makes it difficult to evenly assess a of Sold Sroducts
portfolio of companies. An analysis of companies’ emissions data reporting found
Transportation
that in fiscal year 2021 close to 60% of scope 1 and 2 emissions data and over and Distribution Processing of
75% of scope 3 emissions data were unreported.16 Mandatory climate risk disclosures, Sold Products
which are likely coming to the U.S. and are mandated in the EU Action Plan
Business Transportation
for Financing Sustainable Growth’s CSRD, will not only provide investors with reliable Travel and Distribution
data, but will make it much easier to analyze those disclosures using the
same formats, definitions, and calculations.17
Purchased Goods Waste Capital Investments
and Services Goods
Franchises
Action One: Communicate Organizational Commitments Action Two: Source The Most Accurate Data Available
To effectively manage climate risk, commitment needs to come from an Access to the right data can support making good decisions and complying with
organization’s leadership. The board of directors is responsible for implementing regulatory bodies. Institutional investors and financial institutions that are
climate risk management into the fabric of the organization. As such, climate signatories to the TCFD are required to disclose their climate-related risks in
risk assessments must be integrated into all financial risk considerations like credit alignment with the framework, so it’s important that they have access to
risk, liquidity risk and operational risk. Accountability mechanisms, such as the right information. This means retrieving accurate data from portfolio companies.
linking executive pay to climate performance or regular climate committee meetings,
While the pace of implementation of climate disclosure frameworks differs around
are good governance practices that will keep businesses alert to evolving
the world, companies may already be disclosing their climate-related data
climate risks.
to a recognized global framework. In these scenarios, investors and financial
Part of a robust climate risk strategy includes the commitment to reach net-zero institutions can be relatively confident in the data they are receiving.
emissions in lending and investment portfolios by 2050, complete with Companies that are not reporting to such a framework may be providing less
intermediate targets and strategies to hit those targets. Net-zero resources, reliable or incomplete data. Investors and financial institutions should be
implementation guidance, improved target setting, regulatory updates, and pushing their portfolio companies to disclose their data to a globally recognized
peer accountability are all available to banks who join the Net-Zero Banking Alliance, climate framework like the TCFD, or the International Sustainability
a coalition of over 100 banks in more than 40 countries that represent 41% Standards Board’s (ISSB) Climate-related Disclosures Standard.23 Doing so will
(US$73 trillion) of global banking assets. Similar guidance can be found for asset provide investors and financial institutions with access to more reliable data
owners at the Net Zero Asset Owner Alliance, and for companies at the and enable their compliance with policy regulations.
Greenhouse Gas Protocol and the Science-Based Targets initiative (SBTi).
Managing Risks for a Changing Climate: A Guide for Institutional Investors Essential Actions for Responding to Portfolio Climate Risks 12
International Sustainability Standards Board (ISSB) Sustainability Sustainable Finance Disclosure Regulation (SFDR)
Disclosure Standards As a regulation included in the European Commission’s Action Plan for Financing
The ISSB standards are set to be released in 2023.29 They will include guidance on Sustainable Growth, the EU’s strategy for sustainable finance, the SFDR aims
broader environmental, social and governance (ESG) reporting along with to improve transparency in the market for sustainable investment products. Under
climate-related risk reporting. It’s expected that 40 or more countries could adopt the SFDR, certain financial market participants are required to disclose how
an ISSB-aligned reporting mandate after its release.30 In the U.K., it’s they consider sustainability risks in their investment process, what metrics they
anticipated that the ISSB will replace the TCFD-aligned requirements.31 However, the use to assess ESG factors, and how they assess investment decisions that
frameworks are expected to remain aligned with each other, ensuring might result in negative effects on sustainability factors, called principal adverse
interoperability for companies and stakeholders using both frameworks. impacts (PAIs). SFDR requirements may apply to both EU firms and non-EU
firms operating within the region. Firms may also be required to make disclosures
One key difference between the TCFD framework and ISSB standards is that the
at both the entity/company level and at the product/fund level.
ISSB standards will introduce industry-specific approaches. Additionally,
reporting on scope 3 GHG emissions will be mandatory in ISSB disclosures, Financial market participants are required to publish on their websites information
whereas they are currently optional under the TCFD.32 about their policies to integrate sustainability risks in their investment decision-
making process. Firms must also report on how they have integrated sustainability
Securities and Exchange Commission (SEC) Climate Disclosure Rules risk in their remuneration policies. Additionally, firms are expected to report on
Also being released in 2023 are the SEC climate disclosure rules. This set of rules how they consider and act to alleviate the adverse sustainability impacts of their
will likely require mandatory climate-related disclosures from all publicly investments or provide an explanation of why they do not.35
listed companies in the United States. The disclosure rules are expected to include
carbon emissions, climate risks, and climate-related goals or targets.33 Corporate Sustainability Reporting Directive (CSRD)
The CSRD is the EU’s version of climate disclosure rules, although it includes
The disclosure rules were designed in close accordance with the TCFD but will see
sustainability factors more broadly. The CSRD came into law in January 2023
a degree of variation. Scenario analysis is not required under the SEC proposal,
and is an update to the Non-Financial Reporting Directive (NFRD), bringing a more
whereas it is required with TCFD; the conditions to demonstrate materiality are
thorough reporting system that requires roughly 50,000 companies to report
lower in the SEC rules; and scope 3 emissions are expected to be required
as compared to the 12,000 companies under the NFDR.36 The more detailed
where they are material to a business.34
information companies are required to provide under CSRD will support
investors’ compliance with the SFDR.
The CSRD’s climate disclosure section will include scope 3 emissions and
scenario analysis.37
Managing Risks for a Changing Climate: A Guide for Institutional Investors Essential Actions for Responding to Portfolio Climate Risks 15
of the NZAM commit to reach net-zero emissions by 2050 across all assets
Hong Kong 2022 Singapore 2022
under management, setting interim targets that include a 50% reduction in
carbon emissions by 2030. Egypt 2022
New
2022
Zealand
United
Switzerland 2022 2022
Kingdom
Canada 2024
*Reporting for Malaysian financial institutions will become required for reporting periods starting in 2024.
Mexico, India, South Africa, and South Korea have also recommended their respective governments codify
reporting for companies or financial institutions into official regulations.
Source: Morningstar Sustainalytics. For informational purposes only.
Addressing Challenges in
Assessing and Reporting
on Climate Risks
Regulations vary depending on jurisdiction, but in general, climate risk reporting looks
similar worldwide thanks to widespread adoption of the TCFD framework
and the incoming ISSB framework. That said, it doesn’t mean that climate risk
reporting is straightforward and easy. There are many challenges that
institutional investors and financial institutions face when assessing and reporting
on their climate risks.
Managing Risks for a Changing Climate: A Guide for Institutional Investors Addressing Challenges in Assessing and Reporting on Climate Risks 17
Challenge One: Assessing the Validity of Portfolio Challenge Two: Collecting Data Across Company
Companies’ Net-Zero Commitments Reports and Documents
While strategies to achieve net-zero may differ by company and by industry, there Despite the regulations that mandate climate disclosures, there are still many
are universal components of a net-zero commitment that should be accounted challenges in collecting and analyzing company data. The scale at which
for. First, the pledge to reach net-zero by 2050 or sooner must be made by the head financial institutions need to collect and compile data can be enormous depending
of the organization.41 Following that, there must be science-based targets to on the size of their lending and investment portfolios. Further complicating
reduce GHG in the short, medium, and long term, signaling an achievable path to matters, not all companies report their data to the same degree or use the same
net-zero. Other things to look for are a detailed decarbonization strategy, format and terminologies in doing so. Data gaps can aggravate reporting
capital allocation alignment disclosure, climate risk and opportunities disclosure, challenges for financial institutions.
and a TCFD-aligned disclosure.42
Investors and financial institutions need to dig deep to analyze the validity of
companies’ commitments and run forward-looking scenario projections to gauge
the effectiveness of those commitments in the short, medium, and long term.
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About Morningstar Sustainalytics
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