BNM Climate Change and Principle-based Taxonomy - What this means for FIs Hong Chin Pheng
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BNM Climate Change and Principle-based Taxonomy What this means for FIs Hong Chin Pheng Deputy Director Financial Conglomorate Supervision Department Bank Negara Malaysia
CCPT as a Key Building Block in Supporting an Orderly Transition Key Considerations 1 Provide a framework that facilitates robust and consistent assessments of economic activities and their associated impacts on climate and the broader environment 2 Consider the state of economic development and different stages of transitioning across economic agents 3 Support transition of economic activities that currently do not contribute to climate change objectives Progressive classification system to acknowledge concrete transition 5 Guiding Principles (GP) efforts and commitments 1 Climate Change Economic Activity Overall Classification Business 4 Mitigation Remedial (GP1) Measures to GP1 GP2 GP3 GP4 Transition Supporting 2 Climate Change (GP4) Activities with positive impacts on climate C1 GP1 or GP2 or both ✓ Adaptation change, and causing no significant harm to the environment 5 (GP2) Prohibited Transitioning Activities C2 GP1 or GP2 or both ✘ ✓ Activities causing significant harm to the 3 No Significant (GP5) environment but remedial measures C3 ✘ ✘ ✓ Harm to the Environment taken to reduce harm (GP3) Watchlist C4 GP1 or GP2 or both ✘ ✘ Activities causing significant harm to the environment and no remedial measures C5 ✘ ✘ ✘ taken to reduce harm 2
Supervisory Expectations FIs to play nurturing role • Accelerate customers’ (including value chain) transitioning towards more sustainable practices • Active channelling of resources towards low carbon and sustainable activities Conduct further due diligence on customers’ business operations • FIs to better understand how customers’ business model and operations contribute to climate risk mitigation/adaptation objectives and impact on the broader environment • Leverage on external sources to proxy customers’ GHG emission data, or external validation/certification, if necessary Integration of climate considerations (whole-of-bank approach) • Embed climate considerations in business strategy, operations and decision makings • Incorporate climate-related risks in risk appetite, overall risk management framework and lending/investment policies • Conduct stress testing/scenario analysis and incorporate results in internal capital target setting as part of ICAAP. • Explore relevant metrics/ targets and develop new products that aid management of climate-related risks. Continuous staff capacity building • Strengthen technical and assessment capabilities in climate-related risks to undertake effective risk assessment and customer due diligence Increased commitment on climate-related disclosures • Intensify readiness for greater climate-related risks disclosures, aligning with TCFD recommendations • Advocate improved sustainability disclosures by customers’ 3
Action Plans to Ensure Effective Implementation of CCPT Establishment of a CCPT Implementation Group FIs to report on Explore CCPT for exposures based on insurance/ takaful CCPT classification underwriting Continued supervisory engagements and review/stocktake for alignment of Socialisation with FIs supervisory and other relevant expectations and stakeholders post- progress of CCPT issuance of CCPT implementation Key Priorities Participation in the Development of ASEAN Regional Taxonomy 4
Illustration of CCPT classification process Q1: Does the purpose of the facility/transaction/funding contribute to: At the • Climate change mitigation (substantially avoid, reduce or enable), and/or [GP1] transaction • Climate change adaptation (increase own resilience or enable others to adapt) [GP2] level: Yes No At the Q2: Does the economic activity or the overall business Q2: Does the economic activity or the overall transaction potentially cause significant harm to the broader business potentially cause significant harm to the and issuer environment? [GP3] broader environment? [GP3] levels: DNSH May cause significant harm May cause significant harm At the Q3: Remedial measures taken to Q3: Remedial measures taken to promote transition transaction promote transition and reduce and reduce harmful practices? [GP4] and issuer harmful practices? [GP4] levels: Yes No Yes No C1 C2 C3 C4 C5 Supporting Transitioning Watchlist Source: Adaptation from “Overview and Recommendations for Sustainable Finance Taxonomies” paper by ICMA Case 1: Green Building (May 2021). Case 2: Fossil Fuel Case 3: Oil Palm 5
Case 1 : Refinancing a Green Building Background Transaction Level Overall Business Level GP1 GP2 GP3 GP4* Scenario 1 • An SPV – Refinance existing credit facility to part finance • Borrower had assessed and improved the building’s design to construction of a green • Purpose of building for own use. reduce adverse impact on climate change financing meets • Sustainability due diligence was conducted as part of the FIs • Issued a provisional Green climate change Building Index (GBI) Design mitigation objective approval process Assessment certification and (subject to a • Compliance with the FIs internal real estate and construction C1 applying for the final GBI minimum GBI silver sector guides’ requirements, sustainable financing policy and award. rating, based on the controversy check FI’s risk appetite). • Complies with applicable • Satisfactory report from Environmental Management Plan requirements such as • GBI mainly focuses and Occupational Safety & Health Management Plan. Environmental Management on evaluating the Plan and Occupational environmental GP4 Scenario 2 Safety & Health performance of GP2 Management Plan. buildings, not the • Borrower facing allegations of improper waste management. building’s adaptive • Adopts strict policy to ensure • FI assessed that the customer has put in place remediation capacity to climate- compliance with ESG measures and demonstrated serious commitment to improve related hazards. standards which includes its waste management practices with actionable, time-bound ensuring no deforestation, forced labour or and transparent remediation plans. C2 development-induced Legend : • This includes the development and implementation of a displacement of local Meets GP company policy to require recycling and proper disposal of communities. Does not meet GP construction waste. Not Applicable * Back to Main Slide 6
Case 2 : Financing in Fossil-Fuel Related Activities Background Transaction Level Overall Business Level Scenario 1 (Bond Issuance) • Customer involved in both upstream and downstream GP1 GP2 GP3 GP4 • Good track record in terms of demonstrating commitments in • Purpose – to facilitate addressing climate change and diversification on • Customer engages in other upstream and downstream oil the associated environmental renewal energy. and gas activities that do have potential negative effects on impacts the environment. • Meets GP1 as directly • Demonstrated a clear supports climate • However, customer has clear plans and practices in place C2 sustainability strategy e.g. to change mitigation but to support transition efforts towards a low carbon and achieve net zero carbon not adaptation. climate resilient economy. emissions by 2050 • Commitment to reduce GHG emissions, focusing on Scenario 2 (Revolving Credit) liquefied natural gas while transitioning towards renewable GP1 GP2 GP3 GP4 energy solutions. • Purpose – facilitate • Customer’s activities do have potential negative effects on • Complies to EQA 1974 and expansion of the environment. ISO 14001:2003 Environmental upstream business Management Systems • Nonetheless, customer has clear plans and is adopting • Do not contribute to sustainable practices to support the transition efforts certification for 80% of its exploration with target to climate change towards a low carbon and climate resilient economy such C3 achieve 100% by a committed mitigation or as commitment to reduce GHG emissions and focus on timeline adaptation objective supplying low carbon fuels. Legend : Meets GP Back to Main Slide Does not meet GP 7
Case 3 : Financing for Expansion of Oil Palm Plantation Background Transaction level Overall Business Level • Mid-sized customer requests GP4 Scenario 1 for project financing to fund GP1 GP2 GP3 new cultivation on existing MSPO certified and has Taken actions on remedial actions to reduce harm to the environment agriculture land and taken measures to reduce and subjected to periodic due diligence on progress of actions. implement measures to GHG emissions: support the adoption of i) No use of open burning for cultivation and waste disposal sustainable practices. i) Systematically collect, accumulate and transfer ii) Management of water table in existing peat areas to reduce peat subsidence rate i.e. release of GHG emission from peat soil C2 • Has obtained MSPO oil palm biomass for certification covering 7 MGP* iii) Use palm oil mill effluent as a substitute for inorganic fertiliser for oil palm plantation and 6 processing by biofuel producer MGP for its oil palm mills as GP3 GP4 Scenario 2 follows: ii) Use of hybrid vehicles for maintenance work and On top of the remedial actions above, customer is also implementing ✓ Management commitment international best practices to substantially limit harm to & responsibility transportation of palm fruits environment: ✓ Transparency i) No new deforestation and no new cultivation on peatland ✓ Comply with legal req. Has also taken measures to ii) Maintain a ground cover of natural vegetation in existing peatland ✓ Social responsibility, increase climate resilience: to keep surface moist, minimize irreversible drying and reduce GHG emission C1 health, safety and i) Install water harvesting employment conditions system (e.g. redirecting iii) Construct water management and drainage systems to maintain water from drainage and acceptable level of water table for existing peatland ✓ Environment, natural storage of rainwater as iv) No new cultivation on steep terrains (slope of 25 degree or more) resources, biodiversity and ecosystem services contingency for dry spells v) Conduct periodic soil testing to determine its organic matter and periods) pH structure, and maintain soil fertility ✓ Best practices *MGP – Malaysian Sustainable Legend : Meets GP ✓ Development of new Palm Oil General Princtiple Back to Main Slide 8 Does not meet GP planting
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