2 Providing information to direct
finance
Risk appetite
14. The Low Carbon Finance Group differentiated banks
from three other types of institutional investors—pension
funds and insurance companies, sovereign wealth funds, and listed
collective investment schemes.[19]
But for all types of investor, whether providing equity or debt,
investment hinges on the balance of risk and reward. Northumbrian
Water believed that high levels of risk meant that that balance
was often unfavourable for green investments:
Financiers broadly fall into
two categories: Banks that make loans and Institutional investors
that tend to buy listed, rated bonds. Banks and Institutional
investors are similar in the sense that they primarily make decisions
to invest their capital based on risk vs. return and there are
a number of common themes that mean the perception of risk (principally
political risk) in green finance is often higher than in alternatives.[20]
15. Michael Liebreich of Bloomberg New Energy Finance
saw, however, that the balance of risk and reward was changing,
and leading to a wider shift in the energy sector:
The energy system is changing.
There is a phased change from the old school centralised fossil
and nuclear related power system to something that is renewables,
lots more efficiency, smart grid, gas, some nuclear, and so on.
That change is happening partly because of lots of small legislative
interventions, partly because of the underlying economics in the
energy sector. I think that is a long-term trend.[21]
The dependence on regulatory frameworks and technological
innovation was emphasised by James Vaccaro of Triodos Bank:
Renewable energy ... is quite
attractive to banks when there is a stable enough regulatory environment
and the technology is proven. There is now a good European-based
infrastructure for operation and manufacture.[22]
RenewableUK highlighted that investment decisions
are based on "long term, low-risk returns on investment within
a diversified portfolio".[23]
Ian Simm of Impax Asset Management saw three factors at work:
We have seen a progressive
increase—in fact, we would argue almost an exponential increase-in
private sector capital coming into renewable energy projects in
the UK over the last five years, first of all as institutional
investors have sought out more exposure to infrastructure. Secondly,
they have fewer opportunities to make money elsewhere in their
portfolios because cash returns are low and bond yields are very
low. Thirdly, they are increasingly comfortable with the regulatory
framework that the Renewables Obligation has provided-with some
modifications and evolution, but consistently—since the
early part of the last decade.[24]
16. The risk profile of particular renewables projects
varies. Ian Simm told us that:
If you then look to other
types of green investments or green project, many of them fall
down on technology risk. Onshore wind is typically seen as low-risk,
proven technology where the pension fund has a very low likelihood
of losing money because the equipment does not work. If you could
switch over to some of the more emerging marine technologies like
wave or tidal, although there has been strong progress in those
areas, they are still not effective with the consistency and reliability
that the pension funds will need to see.[25]
Risks also vary depending on the project stage—project
development, pre-construction, construction and operations. Different
investors are willing to take on green investments at different
stages of the project. A significant amount of the cost of green
infrastructure projects is up-front which, as Josh Ryan-Collins
of the New Economics Foundation explained, is also the most uncertain
stage, with no guarantee that the project will reach full operation:
The cost of renewable energy
infrastructure is very, very high at the outset, which makes the
lifetime cost appear prohibitive, but of course the real lifetime
costs are much lower for renewable energy because it is free.
It comes from the sun. It is that initial up-front cost that is
creating the problem, and that is where the barrier is. You have
to have investment. I do not think it is enough to rely on pension
providers to do that.[26]
17. Donald MacDonald from the BT Pension Scheme concluded
that the risk profile of these early stages can be too high for
pension funds and institutional investors who tend to favour low-risk,
long-term investments with secure returns:
The large pension schemes
will tend to look for the very large and boring investments rather
than small investments. Small investments are probably better
for pooled vehicles where a whole number of different projects
can be wrapped up by a single manager with perhaps a number of
clients.[27]
On the other hand, private equity and infrastructure
funds, with a higher risk appetite, typically finance the initial
costs of project development and construction, and subsequently
sell these investments on to other investors seeking stable longer-term
returns. We heard from pension funds that "having a larger
pipeline of projects that we could invest in, that were up and
running to the point where they met our risk profile better, would
certainly be good".[28]
18. Whatever the risk appetite of particular types
of investor, the level of risk is influenced by the information
available to them. Michael Mainelli of Z/Yen told us that there
is a need for "long finance", but identified two obstacles
to its supply: "One is policy mistrust and the second is
information gaps."[29]
In a similar vein, the Committee on Climate Change identified
in May 2013 how Government energy policy-making could be adjusted
to improve the conditions for investment.[30]
In the absence of the measures it proposed (paragraph 23), the
Committee concluded that "there is a risk that current sources
of finance will be insufficient to deliver the increased levels
of investment required in a low-carbon portfolio".[31]
It noted financing constraints for both the energy companies and
investors:
Even if the investment climate
can be improved, there remain questions about whether finance
would be forthcoming for required investments. In particular,
large amounts of finance are required, while balance sheet strength
of energy companies may be limited, and appetite of banks and
institutional investors for project finance is unclear. ... In
the absence of finance backed by balance sheets, investment might
proceed using project finance—where debt is secured against
future project cash flows. However, appetite from banks and institutional
investors to provide project finance during the early stages of
projects where risks are high is unclear, and likely to be even
harder to secure until new market arrangements are proven. ...
The risk is that finance becomes a binding constraint on the level
of investment in low-carbon technologies.[32]
Regulatory certainty
19. Because many green investments have a long planning
phase, it is important that investors are clear not just about
when regulatory decisions are going to be made but about the likely
future direction of Government policy. Stephanie Maier of Aviva
Investors told us that "where you have stable, predictable,
simple policy, we can make investment decisions in that context."[33]
Mike Turnbull of Bank of America Merrill Lynch highlighted that
the Government has had a good record of giving investors confidence
by setting out a clear framework, but that recent policy reviews
had caused concerns:
Pension funds and insurance
companies want to invest in transparent, sustainable cash flows
and regulatory instability or lack of consistency—and we
have been renowned as one of the most consistent and one of the
longest-standing regulatory environments for energy, particularly
electricity and water—and there is more anxiety around that
now than there has been for some time.[34]
Ian Simm of Impax Asset Management told us that "policy
uncertainty and political uncertainty around future projects has
a dampening effect on project development activity today. ...
When there is policy and political change in this type of infrastructure
area, there is almost invariably a hiatus created."[35]
Investors needed certainty and stability not just for prospective
projects but also for those already in operation:
... it is absolutely essential
... that there are no retrospective changes to support in any
form, and that includes taxation for existing infrastructure assets.
If that is not possible, then there will be a very direct consequence—the
risk appetite for future investments among the private sector
will drop.[36]
20. These risks can be particularly significant for
community investment projects (which we discuss further in Part
3). We heard from Mike Smyth of Energy4All and Wey Valley Solar
Schools, who told us:
One of our schools went through
10 regulatory changes before we built the panels. That gives you
an idea of the extraordinary uncertainty and why people drop out
in droves, normally having lost time and money. At the moment
it has settled down for solar for communities. The problems are
difficult on wind because of longer timescales, and the renewable
heat incentive, which frankly has not worked as well as it should
have done, has complete uncertainty built into it. Broadly, the
rates can be changed at any time without any criteria applying.
On a project that might take a year or 18 months to deliver, you
do not know what the end point is and that is one reason why there
has been a low uptake.[37]
21. James Vacarro from Triodos Bank told us this
may be one reason why community energy had not become more widespread
in the UK. Against a background of "quite destabilising"
changes in Feed-in Tariffs and Contracts for Difference:
... you do not get enough
people entering the process with the confidence that there is
going to be something at the end of it and, if reviews are taking
place every year but it takes two or three years to develop a
project, that specific factor means that not enough people are
forming the habits.[38]
22. DECC highlighted initiatives which they considered
would stimulate green finance: Electricity Market Reform, including
Contracts for Difference and Capacity Market payments, and an
escalating carbon price floor.[39]
They stated that these "provide the longer term institutional
and financial structure to attract investment into energy infrastructure."[40]
We identified flaws in aspects of these programmes in our December
2013 report on Energy Subsidies, noting for example that gas will
be the only energy technology eligible for capacity payments when
they begin in 2018-19, and that on current proposals by the European
Commission renewables feed-in tariffs would not be driven by the
need to meet a UK renewables target after 2020.[41]
23. The City of London Corporation highlighted the
possibility of using index-linked carbon bonds to underwrite the
risk associated with investment in an uncertain policy environment.
This would align the incentives for government and investors together
for a stable policy environment, so that "if governments
fail to meet their green targets, they pay a higher interest rate
on the bond".[42]
The Committee on Climate Change listed in May 2013 a number of
measures that it considered the Government should take to provide
greater certainty for investors and "a strong signal about
the future direction of travel for the power system in order to
support supply-chain investment, which has long payback periods,
and development of new projects, which have long lead times".[43]
Those measures included:
· introducing a carbon-intensity
target for electricity generation (previously recommended by the
Committee) before the 2016 timeframe currently planned by the
Government;[44]
and
· extending the Levy
Control Framework, which covers feed-in tariffs for renewables
and nuclear, beyond 2020 to 2030 (the Committee assessed the current
£8 billion a year Levy provision to be "broadly sufficient"
but uncertainty beyond 2020 was limiting investment).[45]
24. The Committee on Climate Change acknowledged
that "investment conditions in the UK power sector will be
improved in the long run by the introduction of long-term contracts
(Contracts for Difference) ... and by the setting of the Levy
Control Framework."[46]
Subsequently, in December 2013, the Government announced the strike
prices for different types of renewable energy, but the Minister
suggested in a speech that he was intending to end subsidies for
onshore wind.[47]
He told us:
You may be placing a little
more weight on ministerial remarks and statements and speeches
than those speeches can bear. What matters is the strike price
itself. The strike price is there, it is final, they have been
published for each year and everybody can draw their conclusions
from it. [48]
However, in January 2014, the Government announced
more detailed plans for Contracts for Difference and Feed-in Tariffs
which differentiated more 'established' technologies, including
onshore wind below 5MW, which "should be subject to immediate
competition through a competitive process of CfD allocation".[49]
James Vaccaro told us that such media speculation could have an
impact on investor confidence:
At the moment there are some
of these perception-reality things, and the reporting of the green
levies, which is nothing to do with renewable energy and renewable
energy targets, undermines confidence in the regime in people's
minds.[50]
The Prime Minister's announcement in October 2013
of a review of energy bills, which we examined in our report on
Energy Subsidies,[51]
was however new and unexpected. The resulting delay in the implementation
of part of the Energy Company Obligation scheme has had an impact
on the energy efficiency market and the collapse of a number of
schemes to insulate hard to treat homes.
25. As we have highlighted in previous inquiries,
a significant barrier to investment in low-carbon energy has been
uncertainty for potential investors about the future direction
of Government policy. The Government's Electricity Market Reform,
including the contracts for difference and capacity market regimes,
though flawed, provide an opportunity for greater policy stability
in future. The Government should make the changes recommended
by the Committee on Climate Change to bring greater longer-term
certainty for investment—an early energy-intensity target
for electricity generation and an extension of the Levy Control
Framework and indicative funding levels to 2030. The Government
should reiterate its commitment to the already planned escalation
of the carbon price floor and use the implementation of the Electricity
Market Reform to make a clear commitment to avoiding further unplanned
regulatory and subsidy changes for low-carbon energy.
Providing investors with information
to assess risk
26. We first examined the risks of a 'carbon bubble'
in fossil fuel energy company stocks in our May 2012 Green
Economy report.[52]
Awareness of such a bubble would be an important factor for investors
to consider their exposure to the risks associated with unburnable
assets. However, many investors lack the information to adequately
factor carbon risk into their investment decision-making.
CARBON 'BUBBLE'
27. Dr Nicola Ranger from the Grantham Research Institute
told that the "total amount of reserves of oil, gas and coal,
currently held by both states and listed companies, far exceeds
what we call the 'carbon budget' that would allow us to keep global
temperatures to below 2 or 3 degrees".[53]
Since our 2012 report, the Grantham Research Institute and Carbon
Tracker have published further analysis of the carbon bubble.
Their report, Wasted Capital and Stranded Assets, concluded
that "60-80% of coal, oil and gas reserves of listed firms
are unburnable".[54]
28. Dr Ranger believed that "investing in these
[fossil fuel] companies that are potentially at risk from stranded
assets in the future could be a high-risk strategy for them, so
investing in other areas might be better in terms of the returns".[55]
The London stock market has become 7% more exposed to coal since
2011.[56]
Mark Campanale of Carbon Tracker told us that " two-thirds
of the revenues of the FTSE 350 is based on three sectors: finance,
oil and gas and mining. If these valuations are wrong then we
are putting our banking system and the London capital markets
at risk from significant changes to the fossil fuel demand."[57]
Other analysts, such as HSBC, have also identified such risks:
Because of its long-term
nature, we doubt the market is pricing in the risk of a loss of
value from this issue ... Capital-intensive, high-cost projects,
such as heavy oil and oil sands, are most at risk ..."[58]
Michael Liebreich of Bloomberg New Energy Finance,
similarly, foresaw "some rather messy adjustments":
I think it is probably more
analogous to sub-prime than to any sort of bubble, where you hold
these assets, you think they are good, and suddenly it becomes
clear that they are not. At that point, the readjustment, the
rebalancing of portfolios and so on, feeds on itself as people
undertake fire sales to rebalance and then that pushes down the
market values even further below book values.[59]
29. We heard different views about when such a readjustment
would take place. Ian Simm of Impax Asset Management told us that
the most likely way that a carbon bubble would "feed through
to destruction of value" would be "through the imposition
of carbon taxes or carbon prices, as they affect the break-even
point of carbon resource extraction".[60]
The City of London Corporation told us "There is a very real
risk of a carbon bubble", but added that "the policy
and legal changes required for it to burst are complex and largely
reliant on international agreement."[61]
David Russell of the Universities Superannuation Scheme questioned
whether policymakers would in fact act to implement policies that
cause a bubble to burst, citing the failure of the EU Emissions
Trading System.[62]
However, James Leaton of Carbon Tracker believed that an existing
"patchwork of regulation" meant that a carbon bubble
was not dependent on a "whether or not we get a global deal
in 2015".[63]
30. Michael Liebreich told us that he thought it
was important to "understand the dynamic of the system much
better",[64]
and said there was a role for higher reporting requirements and
'stress testing':
There are believable scenarios
where you could see a rapid adjustment. Whether it is an oil price
drop, whether it is a bad hurricane season, leading to the Americans
moving more quickly on policy, there are scenarios where you can
see quite a rapid adjustment. I would certainly suggest stress
tests to look at: does that mean that people start breaching covenants?
Having to engage in fire sales? What does it do? Are there other
contagion issues? Can one rebalance portfolios? One should at
least be looking at that. So I think disclosure and stress tests
would be the first thing.[65]
Stephanie Maier of Aviva Investors told us that there
are potentially serious long-term issues if capital is misallocated,
and the Bank of England has a responsibility to investigate the
potential impact of climate change.
When you look at the proportion
of the FTSE 100 that is invested in these energy-intensive, carbon-intensive
stocks, it is potentially a more systemic issue than that. One
of the things we like to see the Bank of England do is assess
the extent of climate change and the high-carbon exposure that
the UK has, and what impact that has on financial stability. If
it is a systemic risk, how do you start addressing it? We do not
want to see a point where you fall off the cliff and these assets
become devalued. You want to find a way to understand the true
value of these assets.[66]
31. We asked the Bank of England whether they considered
the carbon bubble to be a risk and how they were monitoring it.
They told us that the Financial Policy Committee met regularly
to review the risks to UK financial stability and that it had
not identified risks to financial stability from a carbon bubble.[67]
This follows a Bank of England response on a carbon bubble risk
in February 2012, when it noted that "there could be such
a risk if the impact of policies aimed at reducing returns in
high carbon areas were not already being priced into the market".[68]
The Financial Policy Committee of the Bank of England should
regularly consult with the Committee on Climate Change to help
it monitor the risks to financial stability associated with a
carbon bubble.
CARBON REPORTING
32. Investors get some of the information they need
from companies' annual reports and accounts. The Government has
introduced regulations to replace the requirement on quoted companies
to publish a 'business review' with a requirement to produce a
'strategic report'.[69]
These regulations include a requirement to provide information
on the company's environmental impact to the extent that this
affects the development, performance and position of the company.
The regulations also implement the Government's commitment (as
announced at the June 2012 'Rio+20' UN Summit) to introduce mandatory
reporting of greenhouse gas emissions by UK companies.[70]
In our October 2011 report on Preparations for the Rio+20 Summit,
we concluded that while many companies had identified that sustainable
development was in their own interests, others needed to be incentivised
to fully address the environmental and social aspects of sustainable
development, and we recommended that the Government should push
for Rio+20 to agree a mandatory regime for sustainability reporting.[71]
And in our June 2013 report on the Outcomes of the Summit we welcomed
the Government's decision to introduce mandatory emissions reporting
for large UK-listed companies announced at the Summit.[72]
33. Stephanie Maier of Aviva Investors highlighted
the benefits of carbon reporting in terms of driving more sustainable
behaviour by companies.[73]
Michael Mainelli told us that environmental reporting could become
more sophisticated in identifying "sustainability risks",[74]
to allow investors to more fully understand those risks. Some
companies are also using 'shadow pricing' to manage these risks
in their operations.[75]
The UN has set out Principles for Responsible Investment,[76]
and there are a number of international initiatives to improve
the quality of information available to investors to assess the
sustainability of investments, including 'financed emissions'—carbon
produced as a result of a company's financial investments.[77]
34. James Leaton of Carbon Tracker told us that requiring
companies to provide detailed reports on their exposure to carbon
would help inform investors:
The financial system, and
the regulator ... need to send stronger signals to the market
to factor in these risks to enable investors to shift capital.
That relates to greater transparency around the carbon content
of reserves that companies have an interest in, and also asking
those companies to stress test their business model against different
warming scenarios from 2 degrees upwards.[78]
Aviva Investors told us that they would like all
large companies to report on their material sustainability issues
through their reports and accounts to allow investors to easily
assess whether all potential risks have been taken into account.
Despite the UK's narrative reporting requirements, their assessment
ranked London 14th amongst the world stock exchanges
in terms of sustainability disclosure. They considered that a
standard for Stewardship, similar to the ISO standard on environmental
management, would raise the credibility of the stewardship work
that fund managers undertake.[79]
35. New carbon reporting arrangements for companies
can help investors understand carbon impacts, and could help stimulate
greater focus on these issues amongst customers and suppliers
to help add pressure on companies to adopt more sustainable practices.
The Government should work with companies to ensure that reporting
requirements provide investors with all of the information they
require to assess carbon risk, and develop the standard reporting
requirements further.
Fiduciary duty
36. ShareAction told us that some investors cite
'fiduciary duty', the legal requirement to act solely in another
party's interests, as a reason for not factoring the impacts of
climate change into their investment strategies. "Fiduciary
investors will wish to ensure that they are looking after ...
savers' long-term best interests."[80]
James Leaton of Carbon Tracker believed however that short-term
considerations were given priority over long-term stability:
[The] whole system has various
short-term drivers, whether it is the performance incentives for
the fund managers based on quarterly performance, the recommendations
from analysts, which are based again on the short-term revenue
flows from that company and their ability to generate revenues
in the short term. So that is not very good at factoring in long-term
risks. To them, 'long-term' is perhaps more than a year or more
than three years, and that does not necessarily reflect the investment
strategy of some of those large institutional investors, the pension
funds.[81]
37. In 2012, the Kay Review of Equity markets
and long-term decision-making recommended that the Law Commission
review guidance on fiduciary duty. The Law Commission expect to
publish their conclusions by June 2014,[82]
although its 'initial views' published in May 2013 were that "despite
the uncertainty of this area of law ... any attempts to codify
fiduciary duties would be impractical."[83]
ShareAction nevertheless believed that:
legislative clarification
is needed to confirm that there is no legal bar to trustees focussing
on long-term, sustainable wealth creation, and that trustees can
take into account their beneficiaries' wider non-financial interests
provided that this is prudent.[84]
38. Ian Simm of Impax Asset Management told us that
as an asset manager he had "quite limited room for manoeuvre",
and described how the mandates given by pension funds, including
target returns, were "tightly specified".[85]
Donald McDonald, head of the BT Pension Fund, also told us that
their primary duty was to ensure that "the right pension
is paid to the right people at the right time", but explained
that as they were investing for people who would draw pensions
in many years time, "climate change is a major risk factor
that has to be taken into consideration." He stressed the
need to take a balanced approach to manage risk across many in
different future scenarios.[86]
The BT Pension Fund had set up a 'carbon-tilted index':
We take the FTSE All-Share
Index but we then introduce a tilt factor into that to reduce
the carbon exposure. Basically, that is tracking or doing very
slightly better than the normal index, but with 18% less carbon.[87]
Catherine Howarth of ShareAction concluded that the
Law Commission needs to give further guidance on this area:
The evidence coming out of
pension schemes is that in fact they take a very narrow view and
are very confused about what the law allows them to do, so we
are presenting the Commission with evidence that in practice,
on the ground, pension fund trustees feel quite constrained and
that they might be in breach of legal obligation if they do not
take a very narrow view.[88]
39. UK Sustainable Investment and Finance told us
"sustainable and responsible investment is becoming increasingly
popular owing to growing awareness that it is difficult to separate
issues of financial return and risk from topics such as the environmental/carbon
impact, energy security or other factors."[89]
The Law Commission observed that studies have
shown a link between Environmental Social and Governance (ESG)
factors and performance, and concluded that "the answer is
clearly that pension trustees may use wider factors":
... an ESG driven approach
is not simply about avoiding the next company crisis. It works
on the basis that companies do better in the long term if they
are well-run and sustainable, and have loyal suppliers, customers
and employees. Thus ESG factors in this context are about improving
financial outcomes for the beneficiaries: they are not about ethical
preferences.[90]
40. However, the key question is the extent to which
investors must take these factors into account. The Kay
Review (paragraph 37) concluded that "institutional investors
acting in the best interests of their clients should consider
the environmental and social impact of companies' activities".[91]
The Law Commission suggested that investors would not have to
implement an approach that takes into account ESG factors, but
should at least show that they have considered it:
We think that this is a sensible
conclusion. Even if the duty of adequate consideration does not
require this, trustees are also under a duty of care. As part
of this duty, we think that trustees should consider, in general
terms, whether their policy will be to take account of ESG factors
in their decision-making, bearing in mind the resources available
to them. The law, however, allows trustees discretion not to take
an ESG approach if after due consideration they consider that
another strategy would better serve the interests of their beneficiaries.[92]
All investors are required to follow a fiduciary
duty in their investment decisions, but that can be interpreted
in different ways by different investors. It is important that
investors factor the risks of exposure to carbon into their decision-making
and consider the climate impacts of investments, as part of their
wider social and environmental responsibilities.
19 Low Carbon Finance Group, Submission to the European
Union: A framework for climate and energy policies. Back
20
Ev w1, para 2 Back
21
Q40 Back
22
Q200 Back
23
Ev w20, para 18 Back
24
Q166 Back
25
Q169 Back
26
Q171 Back
27
Q59 Back
28
Q168 Back
29
Ev 73 Back
30
Committee on Climate Change Next steps on electricity market reform,
(May 2013), p9 Back
31
Committee on Climate Change Next steps on electricity market reform,
(May 2013), p12 Back
32
Committee on Climate Change Next steps on electricity market reform,
(May 2013), pp55-56 Back
33
Q172 Back
34
Ev 79 Back
35
Q172 Back
36
Q172 Back
37
Q211 Back
38
Q192 Back
39
Ev 95 Back
40
DECC Electricity market reform: Allocation of Contracts for Difference,
January 2014, para 20 Back
41
Environmental Audit Committee, Ninth Report of Session 2013-14,
Energy Subsidies,HC 61 Back
42
Ev w43, para 15 Back
43
Committee on Climate Change Next steps on electricity market reform
(May 2013), p8 Back
44
Committee on Climate Change Next steps on electricity market reform
(May 2013, p54 Back
45
Committee on Climate Change Next steps on electricity market reform
(May 2013), p49 Back
46
Committee on Climate Change Next steps on electricity market reform
(May 2013), p49 Back
47
Speech to the Spectator Energy Conference, December 2013 Back
48
Q256 Back
49
Department of Energy and Climate Change, Electricity Market Reform: Allocation of Contracts for Difference
(January 2014), p11 Back
50
Q210 Back
51
Environmental Audit Committee, Ninth Report of Session 2013-14,
Energy Subsidies, HC 61 Back
52
Environmental Audit Committee, Twelfth Report of Session 2010-12
A Green Economy, HC 1025 Back
53
Q2 Back
54
Carbon Tracker and Grantham Institute on Climate Change and the
Environment, Unburnable Carbon 2013: Wasted capital and stranded assets,
p4 Back
55
Q4 Back
56
Carbon Tracker and Grantham Institute on Climate Change and the
Environment Unburnable Carbon 2013: Wasted capital and stranded assets,
p4 Back
57
Ev 72 Back
58
HSBC, Oil & carbon revisited: Value at risk from 'unburnable reserves
(January 2013) Back
59
Q42 Back
60
Q171 Back
61
Ev w42, para 11 Back
62
Q48 Back
63
Q7 Back
64
Q63 Back
65
Q63 Back
66
Q171 Back
67
Ev w47 Back
68
Environmental Audit Committee, Twelfth Report of Session 2010-12,
A Green Economy, HC 1025, para 70 Back
69
The Companies Act 2006 (Strategic Report and Directors' report) Regulations 2013
Back
70
All UK companies listed on the Main Market of the London Stock
Exchange. It excludes non-UK registered companies, companies listed
on AIM and privately owned companies. Back
71
Environmental Audit Committee, Eighth Report of Session 2010-12
Preparations for the Rio +20 Summit, HC 1026 Back
72
Environmental Audit Committee, Second Report of Session 2013-14
Outcomes of the UN Rio +20 Earth Summit, HC 200 Back
73
Q154 Back
74
Ev 74 Back
75
Carbon Disclosure Project Use of internal carbon price by companies as incentive and strategic planning tool,
(December 2013) Back
76
United Nations Principles for Responsible Investment (http://www.unpri.org/)
Back
77
These are counted as 'scope 3' emissions and are not included
in current reporting requirements. Back
78
Q3 Back
79
Ev 112 Back
80
Share Action Green Light report- Resilient portfolios in an uncertain world,
p2 Back
81
Q26 Back
82
The Law Commission Back
83
The Law Commission Consultation Paper 215 Fiduciary Duties of investment intermediaries
(2013) Back
84
Ev 97 Back
85
Q177 Back
86
Q45 Back
87
Q51 Back
88
Q179 Back
89
Ev w39 Back
90
The Law Commission Consultation Paper 215 Fiduciary Duties of investment intermediaries
(2013), p146 Back
91
J Kay, The Kay Review of UK Equity Markets and Long-Term Decision Making: Final Report
(2012), para 10.20. Back
92
The Law Commission Consultation Paper 215 Fiduciary Duties of investment intermediaries
(2013), para 10.66 Back
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