ESG TRENDS: THE RISE OF CLIMATE LITIGATION AND THE CHALLENGES FOR BUSINESS
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ESG TRENDS: THE
RISE OF CLIMATE
LITIGATION AND
THE CHALLENGES
FOR BUSINESS
JULY 2021
ESG TRENDS: THE RISE OF CLIMATE
LITIGATION AND THE CHALLENGES
FOR BUSINESS
Activist shareholders and NGOs targeting governments and
businesses in relation to climate change are increasingly turning
to litigation.
In a recent landmark judgment, the risk proactively and appropriately might
District Court of The Hague ordered Royal substantially harm shareholder value,”
Dutch Shell (RDS) to reduce its CO2 he adds.
emissions by 45% by 2030, as compared
with 2019 levels. The ruling sets a Shareholder activism in this area has
precedent for other companies that could taken many forms – from proposing or
face similar lawsuits. The case was supporting emission reduction targets at
brought by the Dutch branch of Friends a company's AGM to pursuing litigation,
of the Earth (Milieudefensie), a number of often based on variants of established
other NGOs, and over 17,000 individual legal theories. For instance, around the
claimants (see our briefing). This is the world shareholders have brought cases
first time that any court has ordered a arguing that companies are failing to
company to reduce its CO2 emissions, analyse and disclose properly the risks
and the judgment may have significant climate change poses to their business;
consequences for other companies with or that directors are in breach of their
a link to the Netherlands who have fiduciary duties by not taking sufficient
significant CO2 emissions. account of climate change risks in their
decision-making. This is in addition to
Clifford Chance Counsel, Juliette Luycks, litigation brought by public bodies and/or
who is based in Amsterdam says: "The NGOs seeking to establish corporate
success of Milieudefensie will increase the liability for harm caused by emissions.
likelihood of similar proceedings being
brought against other large emitters of The role of NGOs and
CO2, especially if they are headquartered
National Contact Points
in the Netherlands. We may also see
attempts to bring similar cases against These actions are often led or supported
non-Dutch headquartered companies, by NGOs, for whom litigation is
arguing that the Dutch Courts have increasingly becoming an important
jurisdiction based on other connections of weapon in their arsenal. NGOs are
the company or case to the jurisdiction." supporting claims by alleged victims of
climate change against businesses, and
bringing complaints before the
A growing risk for Organisation of Economic Co-operation
businesses and Development (OECD) National
The rise in climate change litigation and Contact Points (NCPs) for breach of the
shareholder activism is a growing risk for OECD Guidelines for multinational
businesses across all sectors; it is no enterprises. NCPs provide a mediation
longer confined to the carbon majors. and conciliation platform for resolving
"This is due, in part, to sophisticated practical issues that may arise with the
litigation-focused NGOs using litigation as implementation of the Guidelines. “This
a campaigning tool, and a growing process does not lead to binding
recognition of the power of reputational judgments, but can generate a good deal
risk to influence corporate behaviour,” of bad publicity. It's also attractive
says Roger Leese, a London-based because it's cheap,” says Leese.
Partner in Clifford Chance’s Litigation &
Dispute Resolution Group, and co-head Following the devastating bushfires in
of the firm’s business and human rights Australia (discussed below), in January
group. “Tackling climate change is now 2020 victims (supported by Friends of the
very much on the boardroom agenda, as Earth Australia) filed an NCP complaint
is a recognition that failing to address this against Australia New Zealand Bank
2 CLIFFORD CHANCE
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
(ANZ) at the Australian NCP. The and once circumstances allow, the court
complaint alleges that ANZ, Australia's will travel to Huaraz to gather evidence;
largest financier of fossil fuel industries, the first time that a German civil court will
has failed to adhere meaningfully to the conduct an on-site visit on another
Paris Agreement reduction targets across continent to assess climate damage
its lending portfolio, or to disclose the full allegedly caused by a major
extent of its emissions, in breach of the European corporation.
OECD Guidelines. This follows a similar
complaint brought by Greenpeace and “Climate change disputes are being used
other NGOs against ING in 2017-2019 as a policy-making tool. NGOs are
concerning its involvement in fossil fuels. supporting and financing cases with the
The ING complaint resulted in an explicit aim of influencing corporate
undertaking by ING to bring its loan behaviour and strategies. So, the goal is
portfolio in line with the Paris Agreement, not to obtain a favourable decision and to
including an agreement to exit from be paid: it is rather about driving the
thermal coal by 2025. Discussions public debate forward and raising public
continue with ANZ. awareness for this cause. Mr Lluiya’s
case, for example, is largely driven by
Growing numbers NGOs – the actual compensation claimed
is only a few thousand Euros. The
of claims against litigation costs, however, are assumed to
companies globally be in the millions,” says Keller.
There are currently hundreds of cases
worldwide, and some are expected to Challenges to
shape the development of the law and
governments
the debate on climate change more
broadly. A recent report produced by Governments are also increasingly finding
Columbia Law School and the United themselves in the cross-hairs where
Nations Environment Programme found climate change issues are concerned.
that as of June 2021 there were over Cases have been brought across the
2,000 climate change related cases in globe from the US to Australia, with
41 countries. Belgium and Poland most recently joining
the ranks along with countries such as
Amongst these is the case of Saúl France, Germany, Ireland, Italy and
Luciano Lluiya, a Peruvian farmer who Norway. These claims, if successful, are
brought a claim against the German paving the way for more sweeping and
energy company RWE AG in Germany. stringent obligations on businesses, both
Mr Lluiya owns some land in a valley in through the consequential passing of
the Peruvian Andes, located just below a national laws and regulations, and the
melting glacier. He argues that RWE resultant development of judicial
should contribute to the cost of protective precedent and case theory.
measures necessary to safeguard his
property against flooding, commensurate Germany
with RWE’s proportionate share of global Recently a group of German citizens,
greenhouse gas emissions. “The activists from the global movement
interesting question at stake is one of "Fridays for Future" and islanders in fear
causation,” says Moritz Keller, a Frankfurt- of the direct effects of climate change
based partner in Clifford Chance's through rising sea levels, as well as
Litigation & Dispute Resolution Group. “Is Bangladeshi and Nepalese citizens,
it possible to prove that RWE’s emissions challenged the German Federal Climate
in Germany have caused the glacier in Change Act (Bundes-Klimaschutzgesetz -
Peru – that is some 10,000 kilometres Climate Change Act). Backed by NGOs
away – to melt?” including Greenpeace and Germanwatch,
the plaintiffs invoked the "Right to a
In November 2017, the Higher Regional Future", arguing that Germany's climate
Court of Hamm determined that Mr Lluiya change targets to reduce CO2 emissions
has a prima facie case against RWE, by 55% by 2030, are too low.
ordering that the claim progress to the
evidentiary stage. As part of this process,
CLIFFORD CHANCE 3
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
In another landmark ruling (published on approvals relating to coal mining projects
29 April 2021), the Federal Constitutional which could make a reasonably
Court held that provisions of the Climate foreseeable contribution to climate
Change Act governing national climate change under the Environment Protection
change targets and annual emission and Biodiversity Conservation Act 1999
budgets until 2030 are incompatible with (Cth). In this case, the Vickery Coal
fundamental constitutional rights, since Project (owned by Whitehaven Coal) was
they lack sufficient specifications for expected to extract 33 MT of coal, with
further emission reductions from 2031 consequent emissions of 100 Mt of CO2.
onwards. The Court found that reduction Detailed expert evidence relating to the
targets provided for in the Climate cause and impacts of climate change
Change Act are imbalanced, as they shift was considered by the Court, with
major reduction burdens to the future, Bromberg J noting that "[i]t is not
which could result in a considerable disputed that these [climate change
limitation on the freedom of coming induced] events will have impacts on the
generations. In response, the German Australian economy, Australia’s natural
cabinet has approved a reform of the and managed terrestrial and marine
Climate Change Act, setting a new target ecosystems, and on the health and
of a 65% cut to CO2 emissions and wellbeing of individuals, communities and
describing it as a “fair offer to the society". His Honour was satisfied that
younger generation.” injury-inducing events such as heatwaves,
bushfires and other flow-on effects
Thomas Voland, a Clifford Chance Partner "expose each of the Children to a real risk
based in Düsseldorf says: "The ruling of harm from extreme weather events
might necessitate that business sectors brought about by climate change."
adapt their processes to these stricter
requirements and accelerate the transition This ground-breaking decision follows a
process. In addition to the financial number of recent climate change-related
consequences, the ruling will have far- cases in Australia, including the class
reaching legal implications. It confirms action filed by Melbourne law student
that climate protection and mitigation of Kathleen O'Donnell in O’Donnell v
the long-term effects of climate change Commonwealth in July 2020. In a
are of high constitutional importance. This Statement of Claim filed on 23 December
finding is expected to further increase the 2020, the applicant alleges that the
risk of climate change-related lawsuits Commonwealth Government failed in its
against companies." duty to disclose climate change impacts
on the value of government bonds. The
Australia case promises to further clarify how
climate risk should be managed and
The Australian Government and Federal
disclosed by government entities looking
Minister for the Environment are facing
to raise funds in public markets.
increased pressure to take further action
on climate change following the
Amanda Murphy, a Counsel in Clifford
devastating bushfire emergency during
Chance's Perth office, who specialises in
the summer of 2019-2020, in which 33
international law, including climate change
people were killed, 3,094 homes
law, says: "The decision in the Sharma
destroyed, a total of 17 million hectares of
Case has established a novel duty of care
land was burned and over a billion
in Australian law, while also affirming the
animals were lost. Most recently, on 27
causes and probable generational harm
May 2021, the Federal Court of Australia
which will be caused by climate change.
issued a landmark judgment in Sharma
With the scars of the devastating bushfire
(by her litigation representative) v Minister
season still raw in the Australian psyche,
for the Environment [2021] FCA 560. This
this decision will no doubt open the door
Judgment recognises, for the first time,
for similar claims based on breach of this
that the Minister for the Environment
novel duty of care against both
owes a duty of care to protect Australian
Government and private entities."
children from the harmful impacts of
climate change when considering
4 CLIFFORD CHANCE
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
France On 1 April 2021, another administrative
court partially admitted a request from six
Both governments and corporates have
environmental NGOs seeking to revoke
been targeted in several landmark cases
Total Refining France's operating permit
this year before the administrative and
to continue to operate a refinery in South-
civil courts in France.
Eastern France. Total intended to
On 1 July this year, the Conseil d'Etat (the transform the refinery in question from
highest French administrative court) crude oil to biofuels. Whilst the NGOs did
ordered the French government to take not succeed in invalidating the permit, the
additional measures by 31 March 2022 to court did order Total to review its impact
reduce greenhouse gas emissions by study on the use of palm oil imported
40% by 2030. This case was originally from Asia. This decision demonstrates the
commenced by the city of Grande-Synthe French court's sensitivity to environmental
in northern France, and environmental issues and its increasing tendency to
groups including Greenpeace, Oxfam, require corporates to undertake more
Notre Affaire A Tous and the Nicolas impact or risk studies.
Hulot Foundation. This direct action
In this respect, NGOs tend to rely
resulted in an historical decision last
increasingly on the Loi de vigilance,
November, by which the administrative
enacted in 2017, to file claims against
courts gave the French government three
corporates regarding an insufficient
months to prove that current greenhouse
awareness and lack of effective measures
gas emissions targets for 2030 could be
to mitigate social and environmental risks.
met without additional measures. Having
An unsolved debate on jurisdiction is
disclosed this additional information, the
currently ongoing as NGOs tend to seize
court rejected the Government's claims
civil courts while corporates claim
that no further measures were required,
commercial courts should have
resulting in the injunction ordered on
jurisdiction. In this respect, on 11
1 July.
February 2021, the Nanterre Civil Court
Meanwhile, in February 2021, a Paris ruled that it did have jurisdiction to hear
administrative court found the French the complaint filed by NGOs and local
state guilty of failing to address climate authorities in climate litigation cases. This
change, and for not adhering to its decision came as a surprise, as it
promises to tackle CO2 emissions. contradicts the decision of the Court of
Dubbed the "case of the century", this Appeal of 10 December 2020, which
case was brought by environmental confirmed the lack of jurisdiction of civil
groups, including Greenpeace and courts in favour of commercial courts to
Oxfam, following a petition signed by 2.3 rule on the compliance of vigilance plans.
million people. Whilst the case only The judge ruled that even if a dispute
resulted in an award of one euro to each "relates to commercial companies" once
NGO (for non-material harm and prejudice the vigilance plan and the internal
moral), resolving the question of management of the company are directly
pecuniary compensation in such linked, it does not prevent civil courts
instances, the court did recognise the from having jurisdiction in cases brought
concept of "ecological damage" and by non-business claimants. The oil
established a duty on the State to its company involved in the Nanterre case
citizens to comply with the Paris announced that it will appeal the decision,
Agreement. The court has not yet ruled so a new decision from the Court of
on the measures needed to stop the Appeal of Versailles is expected.
future aggravation of damage and ensure
that the State complies with its The Netherlands
international engagements, but did order Perhaps the case that started it all took
the State to undertake further place in the Netherlands. Urgenda, a
investigative measures over a two-month foundation that wants to achieve, in its
period. Another hearing should be own words, “a sustainable Netherlands,”
scheduled in the near future to rule on took the Dutch state to court in 2013
such measures. over its alleged failure to take effective
CLIFFORD CHANCE 5
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
action on climate change. The case made amend their complaint and, in May 2021,
headlines globally in 2015 when the court the district court judge ordered a
found in favour of Urgenda, ruling that the settlement conference between the
government must cut greenhouse gas parties. Thus the case continues.
emissions by at least 25% by the end of
2020 (in comparison with 1990 levels). Over twenty state and local governments
The case came to an end with a final have pursued claims against energy
judgment of the Supreme Court in late companies in state courts under public
2019 – again finding in favour of Urgenda. nuisance laws for their contributions to
Urgenda is now seeking a court order climate change, but face roadblocks over
that the Dutch State pay penalties for questions of jurisdiction, in particular
each day that it fails to take steps whether the defendants can successfully
towards the reduction in greenhouse remove those cases to federal court and
gas emissions. arguments that the claims are pre-
empted by federal law. The Supreme
Arguably, a line can be drawn between Court recently sided with the energy
this 2019 decision and the recent companies in one such case, sending the
judgment against RDS by the District case back to the lower court to consider
Court of The Hague in May 2021. In the the jurisdictional question further, but the
Urgenda decision the court applied ruling was one of technical procedure and
articles 2 and 8 of the European did not address the substance of any
Convention on Human Rights (ECHR) claims. As this history shows, these
directly, in the RDS-case these cases often take years to resolve and
fundamental rights were part of a wider involve multiple levels of appeal in both
mix of relevant rules and norms which the the federal and state courts.
court applied in determining the standard
of care owed by a company towards the Outside of the courts, the US regulatory
inhabitants of The Netherlands in respect landscape is only becoming more
of greenhouse gas emissions. complex. At the federal level, President
Biden has indicated that the federal
“The outcome in Urgenda was surprising government will increase its regulatory
to many at the time – courts rarely dare activity following a "whole of government"
to oblige States to take action. In many approach, most recently with his 20 May
ways, this was the beginning of the 2021 executive order directing the
global wave of climate change cases," executive branch to develop a strategy
says Luycks. regarding the risks that climate change
poses to the US financial system.
The US Additionally, the Chairman of the
Securities and Exchange Commission has
In the US, although plaintiffs have
repeatedly stated that public companies
imposed pressure on companies through
could soon be expected to disclose
litigation, claims for climate-related harms
climate-related risks in their business.
have to-date met with limited success in
Where companies have already made
the US federal courts. In one case,
such disclosures, the accuracy of the
Juliana v. United States, twenty-one
disclosures has also exposed them to
young people sued the US government,
regulatory enforcement action and
alleging that its failure to act on climate
shareholder litigation, as has been the
change violated their rights under the US
case with lawsuits brought against Exxon
Constitution and asking the courts to
by the New York State Attorney General's
require the government to develop a
Office, which Exxon defended
climate action plan. In January 2020, the
successfully, and by shareholders in
US Court of Appeals for the Ninth Circuit
federal district court in Texas, which
dismissed the case for lack of standing.
Exxon continues to defend.
The court reasoned that no court order
could redress the plaintiffs' injuries
At the state level, the direction is mixed,
because it is beyond the courts' power to
following the political leanings of the
supervise the political branches in
individual states. For example,
developing a climate plan. The Ninth
Washington State enacted its Climate
Circuit refused to rehear the case en
Commitment Act, on 17 May 2021, which
banc. However, plaintiffs filed a motion to
6 CLIFFORD CHANCE
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
will create the country's most aggressive agreements (namely, the 1992 United
cap-and-trade system and will require Nations Framework Convention on
decreasing emissions over the coming Climate Change and the 2015 Paris
years. In contrast, Texas's Senate Bill Agreement), European conventions and
13 would require state entities to divest regulations (such as Article 2 and 8 of the
from companies that boycott high- ECHR, Article 191 of the Treaty on the
emissions companies. Functioning of the European Union and
Regulation No. 2018/1999) and Italian
Clifford Chance Partner Steve provisions (Articles 2 and 32 of the Italian
Nickelsburg, who is based in Washington, Constitution – solidarity principle and right
D.C., says: "across the board, companies to health). The claimants argue that the
doing business in the United States face Italian Government is in violation of the
a changing landscape for legal risk general duty of neminem laedere (or do
related to climate change. Especially as harm to no one, Article 2043 of the Italian
federal agencies begin to implement the Civil Code) and of the duty to take care of
Biden Administration's executive orders, goods (Article 2050 of the Italian Civil
companies should consider their Code) to which the Government is the
strategies to address anticipated sole custodian (i.e. the environment).
regulatory expectations around climate
change risks. In addition, businesses with It is expected that the case will
cross-border operations in particular will progress to an initial procedural hearing in
face increasingly complex requirements, approximately three months, but it is
depending on the level of coordination unlikely that the matter will come to trial
between the United States and, for before the end of 2021. The first instance
example, the European Union. decision may be expected in
Companies should prepare themselves approximately two years' time, depending
with a comprehensive strategy on how long the evidentiary phase
for adapting." will take.
Italy A ruling in favour of the claimants would
likely lead to the Italian Government
The Italian courts are about to hear Italy's
introducing new legislation setting
first climate-related case.
concrete steps to meet its 2015 Paris
Agreement obligations. Furthermore, as
On 5 June 2021, more than 200
has happened in other jurisdictions such
claimants, including 162 adults, 17
as the Netherlands, a successful outcome
minors (represented in court by their
on the part of the claimants may also
parents) and 24 NGOs, filed a lawsuit
encourage environmental activists to
against the Italian State, called "The Last
widen their attention from the
Judgement", along the same lines as the
Government to include corporations
Dutch Urgenda case and French Affaire
whose business involves heavy emissions
du Siècle. The aim of the lawsuit, brought
of greenhouse gasses.
before the Court of Rome, is to sue the
Italian State for "climate inaction" – an
insufficient commitment to promote Mounting commercial
adequate greenhouse gas emission pressure
reduction policies; seeking a ruling In addition to litigious and regulatory
ordering the Italian State to achieve a pressure, companies are also facing
reduction of 92% in greenhouse gas mounting commercial pressure to
emissions by 2030, in order to meet the address their exposure to climate change
long-term temperature goal of the Paris risks. On the same day as the RDS
Agreement (aiming at limiting global decision (26 May 2021), significant
warming to 1.5°C). climate change-related votes took place
at the AGMs of ExxonMobil and Chevron.
The claimants allege that the action taken At ExxonMobil, a small group of investors
by the Italian Government so far in this representing only 0.002% of shares won
area is undoubtedly insufficient and seats on the twelve-member board, after
results in the violation of numerous arguing that the company's focus on
fundamental rights recognised by the fossil fuels created an "existential risk" –
Italian State, deriving from international the first time in the company's history that
CLIFFORD CHANCE 7
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
it has faced a contested shareholder vote What's next?
of this nature. Meanwhile, over at
Climate change litigation is here to stay.
Chevron, shareholders voted for a
Growing climate awareness, increased
resolution calling on the company to
pressure on Governments to adopt
reduce substantially its Scope
progressive legislative and regulatory
3 emissions.
action to try to limit global warming to
"well below" two degrees (if not 1.5
Such resolutions have become a
degrees), and to take actual concrete
common feature in the energy sector.
steps now to implement these targets in
Banks are also being targeted by
the short to medium term, combined with
activists, with resolutions being put
a judicial willingness to grapple with these
forward designed to phase out financing
thorny issues as case theories start to
for carbon-intensive industries. Pushing
crystallise and a line of (global) precedent
for these resolutions has become a key
is formed, make this an efficient tool for
tactic of activists such as ShareAction
activists to apply pressure on businesses.
and has proven successful. As the Say
on Climate campaign continues to gather
"We see increasing shareholder activism
momentum, similar actions are imminently
and more and more litigation activity
expected at hundreds of other
relating to ESG. And ESG requirements
companies, assuming they fail voluntarily
are triggering a fundamental change of
to agree to develop comprehensive
business case across many sectors – not
climate plans, and to put them to a
just energy" says Leese. “We are advising
shareholder vote themselves.
our clients to monitor this changing
landscape and to work on "future
proofing" their business to take account
of what's coming down the track. ESG
is a boardroom topic and rightly so."
8 CLIFFORD CHANCE
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
CONTACTS
Roger Leese Carla Lewis Juliette Luycks
Partner Senior Associate Counsel
London London Amsterdam
T: +44 207006 8710 T: +44 207006 4323 T: +31 20 711 9118
E: roger.leese@ E: carla.lewis@ E: juliette.luycks@
cliffordchance.com cliffordchance.com cliffordchance.com
Thomas Voland Amanda Murphy Steve Nickelsburg
Partner Counsel Partner
Düsseldorf Perth Washington
T: +49 211 4355 5642 T: +61 8 9262 5567 T: +1 202 912 5108
E: thomas.voland@ E: amanda.murphy@ E: steve.nickelsburg@
cliffordchance.com cliffordchance.com cliffordchance.com
Daan Lunsingh Scheurleer Moritz Keller Alice Dunoyer de Segonzac
Partner Partner Avocat
Amsterdam Frankfurt Paris
T: +31 20 711 9047 T: +49 69 7199 1460 T: +33 1 4405 5262
E: daan.lunsinghscheurleer@ E: mortiz.keller@ E: alice.dunoyerdesegonzac@
cliffordchance.com cliffordchance.com cliffordchance.com
Charles-Henri Boeringer Carolina Piovano
Partner Senior Associate
Paris Milan
T: +33 1 4405 2464 T: +39 02 8063 4277
E: charles-henri.boeringer@ E: carolina.piovano@
cliffordchance.com cliffordchance.com
CLIFFORD CHANCE 9
ESG TRENDS: THE RISE OF CLIMATE LITIGATION
AND THE CHALLENGES FOR BUSINESS
This publication does not necessarily deal with every important
topic or cover every aspect of the topics with which it deals.
It is not designed to provide legal or other advice.
www.cliffordchance.com
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© Clifford Chance 2021
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