Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
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Introduction & contents Embarking on the TCFD journey Contents Luminous has developed this briefing What is TCFD reporting? 2 guide for UK-listed companies starting When does TCFD reporting become mandatory? 3 out on their TCFD reporting journey. What level of detail is initially required to comply? 4 TCFD reporting refers to the set of What new information, if any, is likely to be required? 6 recommendations published by the What information are other companies providing? 8 Task Force on Climate-related Financial Disclosures in 2017. In November last year, What does good look like? 9 the Financial Conduct Authority (FCA) Summary recommendations 12 Harriet Rumball announced that reporting against the Senior Investor What are the next steps? 14 Engagement Consultant recommendations will become mandatory Appendix15 in the UK from 2022, with disclosures to Luminous be included in the Annual Report. Acknowledgements: Luminous is most grateful to Sarah Abbot and Helen Wickham of Berkeley Group plc, Jon Harrington of While some of the TCFD recommendations Britvic plc, Richard Eadie of Severn Trent plc, Hannah Armitage of the Financial Reporting Council’s (FRC) Financial Reporting Lab overlap with existing non-financial and Simon Weaver of KPMG for their valuable and generous input reporting requirements, others do not on the research for this paper. and are likely to require new disclosures. This guide is designed to help companies navigate the recommendations, identify where existing activity and data is relevant, and pinpoint where new information is required. We deliberately refer to this as a journey because the TCFD recommendations will apply on a ‘comply or explain’ basis (at least initially) and they are sufficiently flexible to allow companies add to and enhance their disclosures over time. We hope this guide will provide a helpful and timely starting point for companies embarking on this journey. 1
What is TCFD reporting? TCFD stands for the Task Force The framework consists of 11 on Climate-related Financial recommendations on climate-related Disclosures. It was established financial disclosures structured in 2015 by the Financial Stability around four thematic areas: Board under the leadership of • Governance Mark Carney, then Governor of the • Strategy Bank of England. In the context • Risk Management of corporate reporting, the term • Metrics and Targets refers to a framework published by the Task Force in 2017 for The recommendations are designed to use by companies to provide be adoptable by all organisations for information about their climate- inclusion in companies’ annual financial related financial risks to investors filings, i.e. the Annual Report for and other stakeholders. UK-listed companies. 2
When does TCFD reporting become mandatory? UK premium listed companies Is TCFD reporting relevant to all An important part of the recovery from with reporting periods beginning listed companies? Covid will be to stimulate and support on or after 1 January 2021 are now investment… To support this, we need The groundswell of support from required by the FCA to adopt TCFD to see a strong focus on public metrics governments and capital markets reporting in their Annual Report. that set out the climate impacts of both regulators for measures to address The requirement will be rolled out investment and corporate activities.” climate change is now evident globally. more widely from the following Without needing to expand on this Thus, even where climate-related year onwards. trend, the recent launch by the Bank reporting may not feel immediately Immediately following the FCA’s of England of climate stress tests for relevant to all companies, it appears announcement on mandatory TCFD commercial lenders from June 2021 is likely that the provision of capital may reporting in November 2020, the relevant here. increasingly be linked to compliance Financial Reporting Council (FRC) with frameworks such as TCFD. In his speech at the Green Horizon also announced its support for Summit on 9 November 2020, companies to report against the TCFD Andrew Bailey, Bank of England recommendations. For reference, Governor, commented: at the same time it announced its encouragement for companies also “What we cannot measure we cannot to report against the Sustainability manage, so it is important that financial Accounting Standards Board (SASB) firms and their clients use the TCFD metrics, these being metrics designed framework and the latest tools available to help companies report financially to measure, model and disclose the material sustainability information climate risks and opportunities they to investors on a sector-specific basis. are exposed to today and in different “We encourage companies to report on future climate scenarios… these areas within their next reporting As we have set out in our supervisory cycle,” the FRC commented. However, expectations, firms must assess how reporting against SASB metrics is not climate risks could impact their mandatory for the time being. business and review whether additional capital needs to be held against this… 3
What level of detail is initially required to comply? The FCA has confirmed that reporting against TCFD recommendations will “The flexibility the TCFD framework offers is valuable in allowing each company “ The flexibility the TCFD framework initially be introduced on a ‘comply or explain’ basis. This will be important to set out its own metrics and targets and showcase how it approaches risk offers is valuable in allowing each in allowing companies to start on the journey towards TCFD reporting, with management. A company can also showcase both risks and opportunities company to set out its own metrics further detail provided over time. To date, TCFD reporting has been relating to climate change in an appropriate context. TCFD allows and targets and showcase how it presented in the form of an index table or a narrative, or a combination companies to set new targets as the business develops or add new approaches risk management.” targets as external situations develop. of both. While it typically features COVID-19 is a good example of when cross-referencing to various sections Sarah Abbot businesses may want to bring in of the Annual Report, the inherent Financial Reporting Manager additional targets or amend their flexibility provided by the TCFD Berkeley Group plc existing targets to take account of framework means that additional external factors.” commentary, beyond an index of disclosures, can – and probably should – be provided. The benefit of this flexibility was clearly explained by Sarah Abbot, Financial Reporting Manager of FTSE 100 Berkeley Group, which reported against TCFD for the first time in its 2020 Annual Report: 4
What level of detail is initially required to comply? continued Alongside Berkeley Group, Luminous spoke to two of its other clients which Where Severn Trent has committed to publishing science-based targets, “ We include in our Annual Report have been early adopters of TCFD reporting, each at sightly different Britvic has already done so and described the process as beneficial and Accounts which Directors stages in their reporting journey but sharing a clear commitment to to the business: “The climate crisis is the defining issue possess sustainability – and, climate-related reporting and the TCFD framework: of our time and the greatest challenge to sustainable development, affecting in particular, climate change – Severn Trent commented: every country, business and person on the planet. experience and expertise.” “Climate change is a key consideration in our business planning and we have “At Britvic, our commitment to a long history of reducing carbon achieving our science-based carbon Richard Eadie emissions, having held the Carbon reduction targets has concentrated our Head of Corporate Strategy, Sustainability and Group Transformation Trust accreditation for over a decade. focus and helped us embed climate- Severn Trent plc We include in our Annual Report and related decision-making across our Accounts which Directors possess business. Specifically, our approved sustainability – and, in particular, science-based targets mean reducing climate change – experience and our Scope 1 and 2 emissions by 50% expertise and last year announced our and our Scope 3 emissions by 35% by triple carbon pledge of net zero carbon emissions, 100% electric vehicles, 2025. We have also pledged to be a carbon-neutral business by 2050. “ Our commitment to achieving and 100% of energy from renewable sources, by 2030. “Clearly, we are already committed to working towards incorporating the our science-based carbon “Importantly, we also took the decision to report against the TCFD TCFD recommendations in full and we also plan to integrate it in our internal reduction targets has concentrated recommendations for the first time. We published our TCFD disclosures in decision making processes.” our focus and helped us embed our Sustainability Report along with a commitment to develop science-based climate-related decision-making targets and are looking forward to building on our TCFD reporting going right across our business.” forward.” Sarah Webster Director of Sustainable Business Britvic plc 5
What new information, if any, is likely to be required? Given existing non-financial reporting requirements, some Hannah Armitage, Project Manager at The Financial Reporting Council’s “ There is a clear need for of the TCFD recommendations are already being met by listed Financial Reporting Lab, acknowledged this but highlighted that, as more standardisation in global companies, for instance around greenhouse gas (GHG) emissions companies report on TCFD, the volume of data available will increase frameworks but reporting against under Metrics and Targets. Others are likely to be underway, for which should, in turn, open up this area of data provision: frameworks like TCFD and SASB is instance around Governance, while others still are likely to “There is a clear need for standardisation in global frameworks an important interim step.” be achievable (at least in part) but reporting against frameworks like within existing structures and TCFD and SASB is an important interim processes, for instance around Hannah Armitage step. Climate scenarios are complex Project Manager Risk Management. but as more companies consider these, The FRC’s Financial Reporting Lab That said, it is likely that new and as disclosures are increasingly information will be required by standardised, more data will emerge most companies around scenario which should help make benchmarking planning in response to the TCFD and scenario planning more accessible.” Strategy recommendations and, given The FRC’s statement on Non-Financial its complex and technical nature, Reporting Frameworks can be found at some investment in specialist data www.frc.org.uk/news/november-2020/ modelling is likely to be required. frc-nfr-statement. In addition, its support for IFRS Foundation consultation paper on international sustainability reporting standards can be found at www.gov. uk/government/publications/joint- statement-of-support-for-ifrs-foundation- consultation-on-sustainability-reporting/ initial-response-to-ifrs-foundation- trustees-consultation 6
What new information, if any, is likely to be required? continued Figure 1. Identifying likely new information requirements versus likely relevant existing corporate disclosures Based on the TCFD graphic opposite we Governance Strategy Risk Management Metrics and Targets have sought to identify where companies Disclose the organisation’s Disclose the actual and potential impacts of Disclose how the organisation identifies, Disclose the metrics and targets used reporting for the first time are likely to governance around climate– climate–related risks and opportunities on assesses and manages climate-related risks. to assess and manage relevant climate- require new information in order to related risks and opportunities. the organisation’s businesses strategy, and related risks and opportunities where such comply, as opposed to referencing financial planning where such information information is material. is material. relevant existing disclosures: Recommended disclosures a) D escribe the Board’s oversight of a) D escribe the climate-related risks a) Describe the organisation’s processes a) Disclose the metrics used by the climate-related risks and opportunities. and opportunities the organisation for identifying and assessing climate- organisation to assess climate-related b) Describe management’s role in assessing has identified over the short, medium related risks. risks and opportunities in line with and managing climate-related risks and and long term. b) Describe the organisation’s processes strategy and risk management processes. opportunities. b) D escribe the impact of climate- for managing climate-related risks. b) D isclose Scope 1, Scope 2 and, if related risks and opportunities on c) Describe how processes for identifying, appropriate, Scope 3 GHG emissions, the organisation’s businesses, strategy assessing, and managing climate-related and the related risks. and financial planning. risks are integrated into the organisation’s c) Describe the targets used by the c) D escribe the resilience of the organisation’s overall risk management. organisation to manage climate-related strategy, taking into consideration different risks and opportunities and performance climate-related scenarios, including a 2°C against targets. or lower scenario. Luminous commentary on new and/or existing information required a) and b) a) F or many companies, shorter-term a), b) and c) a) If climate is already included as a principal Mechanisms and processes at both Board key risks and opportunities related to It is likely that the mechanisms and risk or is included in a company’s emerging and executive management levels are climate change will probably have been processes for risk identification, risk register (or equivalent), it is likely that likely already to be in place for ESG/CSR/ identified, if material, but additional data management and mitigation will serve, appropriate metrics have already been sustainability issues. With timely planning, to assess longer-term implications may at least initially, to address climate-related identified/are in use. these could be extended, as required, be required. A holding statement on risk where it is material. b) Most companies will already make to include climate-related issues. the company’s intentions/plans may Scope 1 and 2 disclosures (and Scope 3 therefore be required. The TCFD recommendations make a distinction in their supporting commentary where appropriate) as part of their b) A s above, if material, it is probable that between physical risks (such as flooding) GHG emissions disclosures and, since companies can explain how they have and transitional risks (such as regulatory April 2019, to meet the Streamlined responded in terms of strategy and changes in response to climate change) and Energy and Carbon Reporting (SECR) financial planning to shorter-term risks these should therefore be considered here. compliance requirements. and opportunities. A description of how c) M any companies will already have some they intend to evolve these in the longer targets in place and may wish to commit term may also be possible based on to identifying more in due course. existing information. Science–based targets, probably c) H owever, an explanation of how requiring specialist third–party input, companies would respond to specific have tended to be considered for year temperature/climate changes is likely two of TCFD reporting or thereafter, to require new information, probably as a next step in enhancing reporting. achieved with the help of a specialist third party. As above, a holding statement on the company’s intentions/plans may therefore be required. 7
What information are other companies providing? Set out in the Appendix are some (but by no means all) of the key Naturally, companies in sectors such as financial services, oil and gas, and Establishing science-based targets is disclosures made by a selection of companies to illustrate – at a glance fashion are likely to have been earlier adopters of TCFD disclosures and to be likely to require specialist input. – the type of content that could be providing a greater level of detail based on considered for inclusion in year one. scenario analysis, financial metrics and, in some instances, science-based targets. The intention here is to give a flavour of the kind of information companies are For reference, emissions reduction providing, the level of their ambition in targets are defined as ‘science-based’ terms of disclosures and how they are if they are developed in line with the explaining their position where more scale of reductions required to meet the information will be provided over time. goals of the Paris Agreement or COP 21 (as it was adopted at the 21st Conference of the Parties (COP 21) which took place in Paris in 2015) of limiting global warming to well-below 2°C above pre- industrial levels, and pursuing efforts to limit warming to 1.5°C. Establishing science-based targets is likely to require specialist input. 8
What does good look like? Figure 3. HSBC Annual Report 2019 More advanced TCFD reporting Strategic report Annual Report | How and Accounts 2021we do business How we do business AVEVA Group plc Annual Report and Accounts 2021 from early adopters provides a good Strategic Report – Governance Report – Financial Statements b reference point for best practice. Task Force on Climate-related Financial Disclosures (‘TCFD’) continued TaskChief Force on Climate-related Financial Disclosures (‘TCFD’) Strategic report Executive’s Review An example here is Landsec, which Developing our approach to transition risk from over 750 customers within the six higher are designed to help us identify key areas of We all have a role to play in limiting climate climate risk forum and an ESG Steering disclosure. We also partnered with climate includes specific financial disclosures change and supporting the transition to a Committee also provides executive oversight change experts at MIT to produce exploratory We have started to develop and publish new risk transition sectors, which represented 34% vulnerability to climate change, the associated Insight into the of climate commitments. We have formally Have you found reporting on transition scenarios. These scenarios were nonsecestrum transition metrics to help us gain queaea inis earumque deeper of our exposure. We are using this information impact on property portfolios and economic low-carbon economy. We are a signatory section 172toduties a useful understandingmi, cupit aut estrupis ofvoluptas as shown below (Figure 2.) to the disclosure recommendations by the Financial Stability Board’s task force. 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This information is also being used help us to understand any gaps in policies and procedures and will also improve our An introduction Governance macroeconomic the material available to will reflect the strategic thinking We have an established governance framework to help ensure that risks associated finance and climate change ‘master class’;que Group Risk Committee carried out a thematic the volor aut qui nonsed utempor samet eturRiskautmanagement omnimenem rerum et the Board We are considering transition to consider our allowed risk from you s.172 three criteria to supplement the management of transition risk in our credit risk management processes. understanding of our physical risk exposure and how this might change over time. perspectives: understanding exposure to and culture that are firmly embedded with climate change are considered at the review of sustainability and climate changeeum riskquisciis We aredestiae in themolupti processoribus of incorporating to our section 172 effectively? transition risk; understanding how our clients To improve our understanding of the progress In next year’s TCFD disclosure, we also expect most senior levels of our business. management; and the Group Audit Committee climate-related et qui nobis iur? 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Obis dolorit escit labores antis Metus, cus del il ma gas construction dit, suntbusAutomotive Chemicals cum utilities mining Total Transition risk sector gas construction Chemicals Automotive utilities aut re, ventemp oreperu ntionsequi mining Total statement presents to provide ditatis es estiam verovid et quidum % of total wholesale loans ≤ 3.8% ≤ 3.9% ≤ 3.9% si nonseque net raectium ad quae ≤ 3.2% ≤ 3.2% ≤ 2.7% ≤ 20.6% Proportion of earunti sector fornonse pori imo quuntio quas which 33% 37%maio offic tecum il earibusvid 27% eium 39% 30% 44% 34% laborio dolecep raestrum et labo. Ita questionnairesacepel were tistiore completedsint4 is dolupitium aut investors and wider stakeholders and advances to customers harita quis dem. Ipsunt. Figure 2. Landsec Annual Report 2020 and banks in 2019 1,2,3 quo ea volorum que verest et dolorpo esequid ea qui aci nos dolecullest, Proportion of questionnaire responses 84% 51% 85% 64% 94% 62% 72% Arumet volenih itaque quossunt with % of total anloans wholesale and advances to customers insight into≤ 3.9% the processes ≤ 3.8% ≤ 3.9% Which ≤ 3.4% tough decision ≤ 3.0% are you most proud of making in the ≤ 2.8% ≤ 20.8% that reported Did eitheryou stakeholders policy or a management review having a board the impact on plan4 of key decisions modis autem as eostiistia duntum and banksthein 2018 Board has in place to capture 1,2,3 last year and why? more closely this year than Sector weight as proportion of high 18% quiaeperfere ommodicient. Ximus 19% sunt que volestibus veratec tatur, 19% 15% 15% 13% 100% Metus, cus del il ma dit, suntbus transition risk ever? sector 4 1 Amountssection 172 shown in the table matters, include its objectives green and other sustainable quantifying our exposure to higher transition risk sectors and the transition risk metrics will evolve over cum ditatis finance loans, which support the transition quid to the es timecomnia as moredus estiam verovid low-carbon datamos economy. alicatium becomes etThe methodology for available and is incorporated in Metus, cus del il ma dit, suntbus cum Pilot as % of total sector ditatis 4 es estiam verovid et quidum 38%il doluptatus eiciist, eum quiant eium volores tibeat. 41% Sum re ventur30% rest quis 52% 42% 46% 41% in our risk reviewing management systems and that processes. information and its 2 Counterparties are allocated to the higher transition risk sectors via a two-step approach. Firstly, where labo. Neque endae preic torporro the main business Proportion of earibusam co considerations pilot that report carbon helped 49% sum volumqui dolendam secti verem 53% 38% que odis et odi quid et eatempelendi 48% 38% 30% 44% vendisofnis a group et autoflatur, connected counterparties is in aidentification of the outcomes ofofthe ipsantionse intensity metricshape a particular through CDP 4 decision? dolorrum higher transition risk sector, all lending to the group is included irrespective the sector of each individual obligor within the group. Secondly, where the si unti corum dolut quam quid que re que pelignat. odiscias vellesequi imporuptio. Ore main business of a group of connected counterparties is not in a higher transition risk sector, only lending to individual obligors in the higher transition risk sectors Weighted averagelabo. carbon emissions 688 408 517 301 7,235 787 key is included. decisions it makes. 3 Total wholesale loans and advances to customers and banks amount to $680bn (2018: $668bn). si doluptas con reici con explicto rem deni te porepudamus aliatur ma Itatur aut as sit autatis molorem per million dollars of revenue (total recatiis vitem inume eaquiatat vid client emissions/revenue weighted Antia corepudae volorum aspis expliquam de dit laut que se inus sequia nam nobitiur asi tempores by exposure) maio 4,5 offic tecum eium harita quis qui nihiciatest, quat. Im derem. Sit Read more, see our XXXX section on pages XX-XX rem. Ut verferunt que volluptatis mil dem. Ipsunt. volorios amenis con nobitate lat. il ipsamus ni ducimol uptate molupta 4 All percentages are weighted by exposure. 5 Customer responses to CDP have been used to formulate the carbon intensity metrics in table 2. If a client does not complete the CDP questionnaire, information is not included in the metrics. The CDP questionnaire is voluntarily completed by clients between April and July of a given year and may not all be from a single point in time. Figures obtained from CDP have not been separately validated. The carbon intensity ratio is calculated by CDP using both reported figures and estimated data. Carbon emissions are measured in tonnes of carbon dioxide equivalent (tCO2e) and revenue is measured in millions of US dollars. 22 HSBC Holdings plc Annual Report and Accounts 2019 HSBC Holdings plc Annual Report and Accounts 2019 23 9
What does good look like? continued Figure 4. Berkeley Group Annual Report 2020 A more pragmatic approach forstrategic Our group those planning team is responsible for using data from Metrics and targets Annual Report and Accounts 2021 making disclosures for the first time the BP Energy Outlook and implementing the insights in our strategic frameworks, including our net zero ambition and mid-term RIC targets. Recommendation: Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities where could be informed by companies such We recognize that climate-related risks are an important consideration in developing our strategy. Climate-related risks are incorporated into such information is material. Task Force on Climate-related Financial Disclosures We present the principal group-wide metrics and targets used to assess as Berkeley Group, whichBP’s provides a see How we manage risk on page 69. governance process, and manage climate-related risks and opportunities on page 17. This Chief Executive’s Review concise one-page summary and Risk management signals Recommendation: Disclose how the organization identifies, includes the targets we set out in 2018 in our RIC framework. Insight into the In addition, in 2019 BP announced that sustainable GHG emissions Berkeley welcomes the recommendations of the Financial Stability Board’s (FSB) HaveTask Force youon Climate-related found reporting Financial on further disclosures to follow over time, assesses and manages climate-related risks. reductions would be included as a factor in the reward of around Disclosures (TCFD). Berkeley reports on climate-related governance, strategy, risk management, and metrics and targets in section 172 duties a useful a stand-alone report as found on our website (www.berkeleygroup.co.uk/about-us/sustainability/reports-and-case-studies) process in its own right this Our processes for identifying and managing climate-related risks are 37,000 eligible employees across the group and around the world, right (Figure 4.) and within our annual response to CDP’s Climate Change Programme. Both climate change mitigation and adaptation are Boardroom. integrated into BP’s risk management policy and the associated risk including executive directors. This target was 10% of the group’s annual year? key areas of focus for Berkeley, featuring prominently within the Our Vision business strategy. Faceptatur? Metus, cus del il ma dit, management procedures. BP’s risk management system is designed cash bonus scorecard and we exceeded the target set of 1.0Mte suntthrough que idem Berkeley continues to take actions to further implement the TCFD recommendations theexerit fugit of evolution rerferiatur our The index of disclosures provided to address all types of risks and as part of this system our operating (1.4Mte). In 2020 we plan to increase the percentage of remuneration assincilBerkeley idus sum sim faccumet aut An introduction processes and reporting mechanisms. The table below summarises the key areas where has already made businesses are responsible for identifying and managing their risks. which is linked to emissions reductions for our leadership and eligible progress and where we have reported on these. que volor aut qui nonsed utempor by BP (Figure 5., below) is another Risks which may be identified include potential effects on operations employees. Our aim is to mobilize our workforce to become advocates Governance samet etur aut omnimenem rerum et eumrisks The Board has ultimate responsibility for climate-related quisciis and destiae molupti oribus opportunities. to our section 172 at asset level, performance at business level and developments at for our net zero ambition. example of clear communication regional level from extreme weather or the transition to a lower For information on our 2020 remuneration policy, see page 110. Disclose the organisation’s governance A nominated Executive Director, Karl Whiteman, has direct and wider sustainability topics. et qui responsibility for climate nobis iur? Quibusam conechange prem utemquaepe velest odit, se pra carbon economy. which supports more detailed around climate-related lanis rero es dolut erro odicitthere volupta statement To ensure climate-related actions are incorporated into Berkeley’s daily activities, risks and opportunities. is a Group Sustainability Team focused on identifyingilluptatem ra coreped strategic risks ut fugitatis and opportunities, As part of our annual planning process we review the group’s principal narrative disclosures againstrisks the four Climate change and the transition to a lower and uncertainties. carbon economy has been identified as a principal risk, see page 69. place within Berkeley’s operating companies to support mod que deliqui performance monitoring and reporting. Dedicated sustainability invenienimin practitioners local management rehendic conse are also and project tem inciderferum in dest que teams in meeting their responsibilities to implement Berkeley’s eni untur. Our Vision strategy, identify main areas of the recommendations. This covers various aspects of how risks associated with the energy climate change risks and opportunities facing their business and to drive continual improvement in performance. Assitatem faccus in pediam ut pa transition could manifest. Similarly, physical climate-related risks such For reference, this sits within a larger as extreme weather are covered in our principal risks related to safety Read more on pages 76 to 77 and 90. essinti antemquam rem ut et ut dolupta dolores nonserum fugia and operations. narrative set of TCFD disclosures: Strategy Disclose the actual alique Climate change mitigation and adaptation are key areas ium volor of focus reperios featuring for Berkeley, iuntur ad prominently within the Our Vision business strategy. que dolum dolla neceria tusdaerissin and potential impacts consenducia is ente parum is A detailed climate change adaptation risk identification exercise was undertaken in 2014 to of climate-related risks niscitatis nos rehenda non nihit Figure 5. BP Annual Report 2019 and opportunities inform strategic commitments as part of Our Vision, facilitated by specialist consultants and autatatiis aut que que et eicit rate involving key representatives from across the business. The key risks identified for the homes on the organisation’s occullorro water maximil shortage.luptaquaepe During this year, which has and places we develop include flooding, overheating and These have TCFD index table businesses, strategy, remained the key risks and areas of focus in terms of con rest ut et, the product weariae buildpedicabo. since theUnt, risk and financial planning volorep tatur, odi sunt lacearunt. been significantly shaped by the assessment was first undertaken. TCFD recommended disclosure Where reported where such information is material. In addition to recognising the importance of adaptingWas reporting our homes on more and places to be resilient Governance Disclose the organization’s a. Describe the board’s oversight of climate-related risks and opportunities. Page 42. disruption caused by COVID-19, to future climate change risks, Berkeley is focused ondifficult taking action resulting from our direct activities and those resultingfrom decisions COVID-19 from the to reducearising use of the a homes the emissions challenge and governance around climate- b. Describe the management’s role in assessing and Page 42. consideration homes of the impact of developments we create as evidenced by our carbon for commitments. the positive Board? and net zero carbon Board decisions onwillstakeholders related issues and opportunities. managing climate related risks and opportunities. Metus, cus del il ma dit, suntbus Berkeley cum ditatis be undertaking more detailed climate-related es estiam scenario analysisverovid to evolveet our and the long-term success of the Strategy a. Describe the climate-related risks and opportunities Achieving the Paris goals, page 13 – for a discussion of the understanding of climate-related risks and opportunities. quidus, cus et ut aut fugia dolum Disclose the actual and potential the organization has identified over the short, different pathways and time horizons considered Read more on pages 16 to 17 and 30 to 45. que pa consenimolor rem vellabo impacts of climate-related risks and opportunities on the medium, and long term. RIC framework, page 41 – for an outline of opportunities. Risk factors, pages 70-71 – description of principal risks. company Risk Management has come under very Climate change is considered a principal risk to Berkeley. reptaquo ditas ea volesedis aut eost aut a nobitaerro The eturis dollandae Group Sustainability Team organization’s business, strategy and financial planning where b. Describe the impact of climate-related risks and Risk factors, pages 70-71 – description of principal risks. close scrutiny. Disclose how the organisation identifies, identifies strategic climate change risks and regular review of issues and trends. Active collaboration rae voluptae opportunities sequodis dunt laniae. facing Berkeley aut ab int, with external Luptam, through tempore, experts, the and ut as opportunities on the organization’s businesses, The Board risks.strongly welcomed enimolu ptatiunt et essi nonemolor such information is material. assesses and manages representation at conferences and events help to ensure up-to-date knowledge. Identified strategy, and financial planning. risks and opportunities are shared with the Board andsimet included within climate-related et dolor autthe strategic etus, et untisrisk the opportunity the section 172 c. Describe the resilience of the organization’s strategy, Achieving the Paris goals, page 13. register reviewed by the Audit Committee. suntiberum delita sedipsant adi taking into consideration different climate-related Our strategy, page 16. Read more on pages 66 to 79. ventemp oreperu ntionsequi aut re, scenarios, including a 2°C or lower scenario. statement Metrics and Targets presents Berkeley to reports provide on greenhouse gas (GHG) emissions si nonseque net raectium ad quae laborio for dolecep which we areraestrum responsibleet labo. Ita on an Risk management Disclose how the organization a. Describe the organization’s processes for identifying and assessing climate-related risks. Risk management, page 44. Upstream, page 50. investors and wider Disclose the metrics annual basis. stakeholders quo eachange, To minimise Berkeley’s contribution to climate volorumwe que verest have carbon intensity reduction target under Our Vision that is reviewed every two years to et dolorpo an operational with an insightensure intocontinual theimprovement. processes and targets used identifies, assesses and Downstream, page 56. to assess and manage Whichtotough Berkeley has also committed procuringdecision are you 100% renewable manages climate-related risks. Other businesses and corporate, page 63. most proud electricity for its UK operations and offsetting our remaining emissions ofsince making in the 2017/18. the Board risks and has in place to capture relevant climate related Berkeley has broader targets for the homes and places lastwe year and develop, why? the provision including b. Describe the organization’s processes for managing Risk management, page 44. of energy efficient lighting and appliances, as well as Metus, enabling cus del il to homes maoperate dit, suntbus at net zero section 172 matters, its objectives opportunities where climate-related risks. such information carbon by 2030. cum ditatis es estiam verovid et c. Describe how processes for identifying, assessing, Risk management, page 44. We are currently working with an external consultant quid comnialonger-term dus mos alicatium in reviewing that information and its is material. to develop science-based and managing climate-related risks are integrated How we manage risk, pages 68-69. targets for our activities labo. Neque endae preic torporro identification of the outcomes ofandthe into the organization’s overall risk management. Risk factors, pages 70-71. ipsantionse vendis nis et aut latur, Read more on pages 46 to 47 138 to 139. odiscias vellesequi imporuptio. Ore key decisions it makes. Metrics and targets a. Disclose the metrics used by the organization to Relevant group-wide metrics and targets, page 17. si doluptas con reici con explicto Disclose the metrics and targets assess climate-related risks and opportunities in line rem deni te porepudamus aliatur ma Berkeley will continue to work with external experts to develop science-based targets, climate-related scenario analysis used to assess and manage with its strategy and risk management process. sequia nam and related disclosures in line with the recommendations of the TCFD. We have complied withnobitiur asi tempores the Streamlined Energy relevant climate-related risks b. Disclose Scope 1, Scope 2, and, if appropriate, GHG emissions data, page 40. rem.Report and Carbon Reporting (SECR) framework in our emissions reporting in the Directors’ Ut verferunt que138 on pages volluptatis to 139. mil and opportunities where such Scope 3 GHG emissions, and the related risks. il ipsamus ni ducimol uptate molupta information is material. 64 Berkeley Group 2020 Annual Report c. Describe the targets used by the organization to RIC framework, page 41. manage climate-related risks and opportunities and (Also note: Net zero ambition and aims, page 6). performance against targets. 10 44 BP Annual Report and Form 20-F 2019
climate-related issues is Simon Carter, for analysing: Sustainability Committee, which Chief Financial Officer. Simon chairs consists of senior managers from – Climate-related risks to the Risk our Risk and Sustainability Committees, across the business including Committee, which consists of the ensuring continuity and accountability. strategy, asset management, Executive Committee and leaders As part of assuming these responsibilities, and leasing. The delivery of the from business units, including Simon took part in The Prince of Wales’s sustainability programme, including procurement and property What does good look like? Business & Sustainability Programme our net zero targets, is overseen by management. Each business unit at the Cambridge Institute for this Committee, which reports to the maintains a comprehensive risk Sustainability Leadership. Board’s Corporate Social register, which is reviewed quarterly Responsibility Committee. The Board is updated on climate-related by the Risk Committee. Climate risks issues at least annually and has are identified through a process continued ultimate oversight of risk management. involving trend analysis and Significant and emerging risks are stakeholder engagement. Identified escalated to the Audit Committee and risks are incorporated into our risk climate risk is tracked as part of our framework and managed by the Catastrophic Business Event risk appropriate business areas. category (see page 84). – The TCFD Steering Committee Our Board CSR Committee meets reports to the Risk and Sustainability three times a year and oversees the Committees, both of which meet delivery of the sustainability strategy, quarterly. Ultimate oversight is at including the delivery of the Pathway Board level, with our new Corporate to net zero and the management Social Responsibility Committee of climate-related risks. playing a role from May 2019. Any resulting disclosure requires approval Figure 7. British Land Annual Report 2020 by the Audit Committee. When approaching cross-referencing • O rganisational charts Board of Directors and an index of disclosures, two A simple but effective organisational Board practical points are worth considering: chart is provided by Barclays (Figure 6) Audit Committee Corporate Social Responsibility (CSR) Committee and an alternative is from British Land First, many larger listed companies will (Figure 7). Risk Committee Sustainability Committee already provide a response to the CDP’s annual questionnaire on climate change, • O pportunities as well as risks TASK FORCE ON CLIMATE-RELATED FINANCIAL DISCLOSURES (TCFD) Executive and Management Climate-Related Financial TCFD Steering Committee forests and water security to provide an There is a tendency for companies to Members include representatives from across the business: Asset management, Development, Finance, Investment, Procurement, Property management, Risk management, Strategy and Sustainability assessment of their environmental impact. focus primarily or exclusively on risk This is likely to contain information that in their TCFD reporting. Care should Disclosures is relevant to TCFD reporting. However, therefore be taken to ensure that both Figure 8. British Land Annual Report 2020 British Land Annual Report and Accounts 2020 43 rather than simply referencing their risks and opportunities are considered. CDP responses, companies should use The Board recognises the systemic threat posed by climate change and the need for urgent mitigating action. We have a track record • A clear roadmap to full disclosure of improving environmental performance, we were one of the first real estate companies to introduce stretching carbon reduction them as a starting point for their own targets that go beyond the demands of the Science Based Targets initiative for Scope 1 and 2 emissions, and we are a founding The example (Figure 8.) from British signatory of the Better Buildings Partnership’s Climate Change Commitment. Since 2009, we have reduced our operational carbon intensity by 73%, and we are announcing an ambitious set of climate targets as part of our new pathway to net zero (see page 40). TCFD disclosures. Land is a helpful reference point for Our roadmap to full disclosure in 2021/22 Second, it is always helpful if the data those ready to commit to a fuller level 2019/20 Establish governance Scoped potential risks Potential risks identified Roadmap agreed referred to in the TCFD disclosure is of disclosures. GOVERNANCE Board-level oversight Two climate workshops, including: located in the same publication, typically 1. Established the CSR Committee – low carbon transition Our governance framework 2. Net zero strategy reviewed at risk scenario the Annual Report, or in full in one the Board away days Operational Accountability – physical risk scenario location on the corporate website to 1. TCFD Steering Committee established avoid a time-consuming search for Progress information and the risk of valuable Figure 6. Barclays Annual Report 2020 – Our newly-formed TCFD Steering Committee undertook two climate risk scenarios workshops, where facilitators from Forum for the Future took the group through the latest climate science and ran breakout sessions on climate risk identification and organisational responses. data being overlooked. – As part of the new sustainability strategy, we worked with experts to develop our pathway to net zero, including aggressive climate and energy targets. Our updated Sustainability Brief will enable asset-level delivery of this approach. Barclays PLC Board – The Board’s strategy away days in 2019/20 included the review and discussion of our new sustainability strategy including the Specific aspects of others’ reporting may pathway to net zero. also be helpful to consider. These might include the following: Group Executive Committee 2020/21 Establish exposure Physical: Transitional: – Audit asset resilience – Policy development – Potential compound impact – Supplier resilience – Identify opportunities – Identify opportunities Environmental and Social Impact Group Risk Committee Chair: Group CEO Committee 2021/22 Organisational response Portfolio level: Adapting corporate strategy Quantified exposure Mitigation targets Sustainability TCFD Forum to each risk event Adapting financial planning Forums Incorporate into enterprise Risk management metrics risk management For more information, see our 2020 Sustainability Accounts at www.britishland.com/data Board deep dives in 2019 plausible climate stress. This analysis will support the Group’s response to the The Board’s agenda in 2019 has been 42 British Land Annual Report and Accounts 2020 forthcoming Bank of England industry-wide significantly influenced by a comprehensive stress test. This progress was welcomed ‘listening tour’, undertaken by our new 11 Chairman following his arrival at Barclays in whilst acknowledging the need for risk management practices generally to evolve March, before he became Chairman in May. further across the whole industry in respect of Nigel Higgins held around 50 meetings with climate change risk. shareholders and other stakeholders as part of
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