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Greening Finance: embedding sustainability in financial decision making Contents

3Climate risk reporting

47.Despite the 2015 Paris Agreement on climate change and official warnings about the extent of climate change risk, almost three quarters of large companies worldwide do not acknowledge the financial risks of climate change in their annual financial reports, according to the KPMG 2017 Survey of Corporate Responsibility Reporting.66 More than half of 497 institutional investors surveyed by HSBC said they were receiving ‘highly inadequate’ information from companies about their risk of disruption from climate change and opportunities to benefit from the shift to low-carbon technologies.67

The Task Force on Climate-related Financial Disclosures (TCFD)

48.In April 2015, G20 Finance Ministers and Central Bank Governors asked the Financial Stability Board to review how the financial sector can take account of climate-related risks. The Financial Stability Board established a 32 member international Task Force on Climate-related Financial Disclosures (TCFD) chaired by Michael R. Bloomberg with members from large banks, insurance companies, asset managers, pension funds, non-financial companies, accounting firms, and credit ratings agencies. In June 2017, the Task Force published its recommended framework for financial disclosures on climate-related risks and opportunities by companies and investors. The Task Force recommended that organisations across sectors and jurisdictions provide disclosures in their public annual financial filings in four areas:

Benefits of disclosures

49.Our inquiry identified benefits of implementing TCFD recommendations fully in the UK. ‘London’s systemically important role’ in the global financial system, means that ‘the UK Government has an opportunity to green finance in a way that no other government has’, according to Dr Ben Caldecott of Oxford University’s Sustainable Finance Programme. He says that ‘getting markets to integrate climate change and the environment into decision-making will help financial institutions appropriately manage risk. This will help them to reduce losses and will also improve the resilience of the financial system as a whole’.69 Furthermore, we heard that:

Finally, as Bank of England Governor Mark Carney has put it, ‘having information on [climate] risks would allow investors to back their convictions with their capital, whether they are climate optimists or pessimists, evangelicals or sceptics.’75

50.During our inquiry we looked at how recommendations on climate-related financial disclosures could be implemented in the UK. We asked several key questions about this process:

We will examine the evidence we received answering these questions in the following sections.

Who should TCFD apply to?

51.The Task Force on Climate-related Financial Disclosures (TCFD) developed four widely adoptable recommendations on climate-related financial disclosures that are applicable to organizations across sectors and jurisdictions. Its final report stated that:

‘Importantly, the Task Force’s recommendations apply to financial-sector organizations, including banks, insurance companies, asset managers, and asset owners. Large asset owners and asset managers sit at the top of the investment chain and, therefore, have an important role to play in influencing the organizations in which they invest to provide better climate-related financial disclosures.’76

52.The Government said in its submission to us that it recognises ‘the wide range of organisations that these recommendations cover’, but that it is ‘conscious of increasing burdens on UK businesses’. It says it ‘has endorsed the recommendations and encouraged all publicly-listed companies to implement them, in line with the TCFD’s voluntary approach.’77 We asked Ministers what action they had taken to ‘encourage’ companies to adopt the recommendations, but they were unable to list any specific actions.78

53.Sixty-three UK incorporated organisations have so far committed to support or adopt the TCFD recommendations, according to the Climate Disclosures Standards Board (see appendix 1 for full list) including both publicly-listed companies and pension funds.79 Of the 25 largest pension funds, which we wrote to as part of the inquiry, seven schemes have committed to report in line with the TCFD recommendations, another eight say they are considering how to respond and ten schemes have no current plans to report in line with TCFD.

54.We asked the Chair of HSBC’s pension fund and advisor to the Task Force on Climate-related Financial Disclosures, Russell Picot, whether it was appropriate to focus solely on listed companies:

‘If this is going to work, we need all the players in the investment chain to play their part. So obviously listed companies and companies that access the public equity or debt markets need to produce high quality, quantitative data and information about climate risk. At the other end of the spectrum, the asset owners need to be including climate risk in their risk management and they need to be asking for information about climate risk in their portfolios. Therefore, you create the tension in the investment chain for the asset owners pulling on the chain through the fund managers who ask the listed companies for the information. I focus at least as much on the role of the asset owners and the need for asset owners to be seeking this information, to be reflecting on it and publishing in either accounts or through stewardship reports or something to their own beneficiaries.’80

55.However, the BAE Systems Pension Fund argued in its letter to us that requiring asset owners to report in line with TCFD would not be of use to pension savers:

‘As a Trustee Board we are committed to communicating clearly with our members and we take great care and effort in doing so in an appropriate way. Engaging pension scheme members is a challenge faced by all pension schemes and we remain to be convinced that providing members with information suggested by the TCFD report will improve member outcomes. Greater clarity is needed in explaining what members would do with this additional information.’

56.There are 89 Local Government Pension Scheme (LGPS) funds in England and Wales. In recent years, the Government has looked for ways to achieve economies of scale in LGPS funds—with the primary aim of improving returns and reducing deficits but also enabling greater capacity for investment in infrastructure. This has resulted in proposals to pool LGPS funds announced in the Summer Budget 2015.81 Eight new investment pools have been proposed so far. The industry-led Green Finance Taskforce established by the Government said that requiring public sector investments to be held to the TCFD recommendations ‘in due course’ would protect public investment against climate impacts and further build on UK expertise in low carbon financing.82

57.Implementing the recommendations of the Task Force on Climate-related Financial Disclosures would put climate change on board room agendas and provide companies and investors with the information to take a longer-term perspective when it comes to the potential risks and opportunities it poses. The Government says it has ‘encouraged publicly-listed companies’ to report on the risks and opportunities of climate change, but Ministers do not appear to have taken any specific actions to do this other than publicly endorsing the recommendations.

58.Given the long time-scales and large sums of money involved in the management of pension funds, it is important that climate risk reporting applies equally to asset owners (such as pension funds) and their investment managers, not just listed companies as the Government has suggested. Requiring asset owners to report would ensure that trustees and investment managers actively engage with how companies are managing climate change risks.

59.The full range of financial entities listed by the TCFD should be making climate-related financial disclosures. We need to see a ‘green thread’ running through the investment chain. This would ensure that climate risks and opportunities are considered at every point in the investment chain. The Government should set out in its response to this report what specific actions it will take to encourage take up.

How the top 25 pension funds manage climate change risk

60.In late February we wrote to the 25 largest UK pension funds, responsible for some £550bn of long term investments, to seek evidence as to how climate change risk was—or was not—incorporated into these investors’ long-term investment decision-making.83 The Committee also sent the letter to the Parliamentary Contributory Pension Fund and received an unsolicited response from the London Pension Fund Authority. We thank all 27 funds for their responses, which are now published on our website. We split the responses into three broad categories (detailed in a table in an Annex to this report).

61.A ‘more engaged’ group had clearly identified climate change as a long-term risk (and opportunity), often some years ago, and were actively managing it. This group tended to demonstrate a strong sense of organisational purpose. Although the funds manage multiple risks, climate change was identified as particularly challenging and in need of specific attention as a long-term threat to beneficiaries’ pensions. This group showed a strong commitment to the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). One respondent—the West Midlands Pension Fund—had already reported in its 2017 Annual Report on the climate-related risks and opportunities facing its fund in line with the TCFD recommendations.

62.Several of the funds in this group had carried out carbon footprint analysis, recognising the financial risk that climate policy evolution may bring. A few had participated in an investment consultant’s research study Investing in a Time of Climate Change to gain insight into the investment implications of climate change. Many in this group had sought investment opportunities, often unlisted, that gave them exposure to renewable energy, infrastructure and the transition to the low carbon economy. Their boards, or equivalent governance body, were noticeably involved. Climate change was placed on the risk register by some, or specifically referenced in the Statement of Investment Principles. Government and regulatory activity tended to be seen as supporting the desired direction of travel rather than as unhelpful intervention. The Pensions Regulator’s integrated risk management framework (combining sponsor covenant, funding and investment) was referenced by some, with actuarial advice used as input to this risk management assessment. It was encouraging to note references to the sponsor covenant, with climate change identified by some trustees as a relevant risk factor in this context. Many of the funds in this group showed extensive engagement with, and contribution to, the collaborative initiatives of organisations such as Institutional Investors Group on Climate Change (IIGCC), CDP (formerly known as the Carbon Disclosure Project) and the Transition Pathways Initiative (TPI). Many of these responses referenced future commitments, as well as what had already been achieved. It was notable that the Local Authority pension funds were all amongst the ‘more engaged’ group.

63.The second group had engaged with the issues and were making some progress. They acknowledged climate change as a risk, but often saw it as one of the many ESG factors they had to contend with. Policies might be in place, but there was less evidence of significant activity around implementation of climate risk management. There was greater caution about committing to TCFD reporting, though the evolution of TCFD-aligned reporting for Principles of Responsible Investment (PRI) signatories under the PRI annual Reporting Framework was sometimes cited. There was a greater tendency to see regulation in this area as something of a burden, rather than supporting investors to meet their responsibilities in addressing the urgent challenge of climate change.

64.The last group were less engaged. They tended to see climate change risk as another Environmental Social and Governance (ESG) factor. Climate change did not appear to have been considered specifically as a strategic risk by the Board. Management of climate change risk was often left to investment managers. There was little reported evidence of strategic input or oversight from the pension scheme’s governing body. This group had no current plans to report on climate risks and opportunities in line with recommendations on climate-related financial disclosures. Some of the pension funds with a sponsoring employer likely to be directly affected by the transition to a low-carbon economy were in this group.

65.As previously noted, seven schemes have committed to report in line with the TCFD recommendations, indeed one of those has done so already. Another eight are actively considering how to respond, but ten schemes have no current plans to report in line with TCFD.

66.It is apparent from the responses of the ‘more engaged’ group of pension funds to the Committee’s letter that significant progress is being made by some pension funds, including commitments to TCFD reporting. However, a minority of the top pension funds do not appear to have given climate change much strategic thought. This creates risks for beneficiaries. We believe this patchwork approach shows the need for TCFD reporting to become a mandatory requirement for all large asset owners by 2022.

Supporting reporters on scenario analysis

Scenario Analysis: a process for identifying and assessing a potential range of outcomes of future events under conditions of uncertainty. In the case of climate change, scenarios allow an organization to explore and develop an understanding of how the physical and transition risks of climate change may impact its businesses, strategies, and financial performance over time.

67.To understand the potential risks and opportunities that climate change poses to an organisation it is necessary to analyse a range of possible scenarios—modelling possible temperature rises and the market, social and regulatory response. The Task Force for Climate-related Financial Disclosures (TCFD) recommended that organisations incorporate scenario analysis into their strategic planning process:

‘The disclosure of organizations’ forward-looking assessments of climate-related issues is important for investors and other stakeholders in understanding how vulnerable individual organizations are to transition and physical risks and how such vulnerabilities are or would be addressed. As a result, the Task Force believes that organisations should use scenario analysis to assess potential business, strategic, and financial implications of climate-related risks and opportunities and disclose those, as appropriate, in their annual financial filings.’84

68.The Task Force provides guidance to organisations on using scenario analysis as a tool, but it does not provide a set of suggested scenarios—although it says organisations should include a 2°C or lower scenario in line with the Paris Agreement.85 The Bank of England said that scenario analysis and planning is the area of TCFD with the clearest need for further development.86 Alex White from the Aldersgate Group described feedback they had received that some companies ‘did not know where to start’ with scenario analysis:

‘ … in the conversations we have had so far with corporates who are looking at implementing TCFDs in their own company practice, there is still a lot of uncertainty as to how that will look for them. One of the very positive recommendations in the TCFDs is the forward-looking scenario analysis. Where carbon footprinting looks backwards, this looks at the forward risks, which is very useful to both the company and the investor, but at the moment lots of companies are saying, “What scenarios do we choose? You say a 2-degrees scenario but what does that look like? What does that world look like? What timeline should we be working with? How do we do this?” I think there needs to be a great deal of guidance from Government.’87

Dr Ben Caldecott said however that scenario analysis was already widely used by business:

‘There are clearly ways in which Government regulators can support the preparers to become familiar with scenarios and some of the recommendations of the TCFD, but I would just say that a lot of businesses do do scenario planning and they do think about managing a whole bunch of different risks. In the spirit of the TCFD, this should be integrated completely into that existing scenario analysis and planning that they do. I don’t think it need be such a burden if it is seen in that way.’88

Likewise, the research and communications consultants Culmer Raphael & Iken Associates argued that ‘it is not identification of future climate impact scenarios that is the most challenging aspect, but rather the assessment of likely financial impacts at an organisational level.’ It points out that large banks and insurers already use a scenario-based approach to calculate capital requirements.89

Reference scenarios

69.Evidence we received suggests that there is a role for public bodies or international agencies to play in providing off-the-shelf scenarios to help companies and investors consider climate change risks for their businesses. Carbon Tracker noted that for disclosure to be made useful for investment decisions the outputs need to be consistent and comparable because investors need to understand the relative risks facing companies. ‘Only then can they model how these risks can and should be priced.’90 It argued that this requires the use of a reference scenario that should be set within the regulatory structure to ensure disclosures are comparable.

70.Aviva said that Government should work with regulators and the Committee on Climate Change ‘to develop a set of standard base scenarios for companies to draw on so that investors can be confident that the analysis is consistent, comparable and robust’.91 The London Stock Exchange Group, ClientEarth and Carbon Tracker all suggested that the UK could support companies and reduce the costs of compliance by producing reference or baseline scenarios, which companies and investors could then supplement with their own analysis:92

‘A reference scenario not only aids the markets, it reduces costs to issuers by providing the building blocks for disclosure. The use of a reference scenario, built upon climate targets, would be the first of its kind for capital markets disclosure, setting the UK out as a leader in the field, whilst minimizing the costs of listing on the UK’s exchanges.’93

71.Both the Intergovernmental Panel on Climate Change and the International Energy Agency produce scenario sets outlining possible future pathways for climate change and global energy use.

72.To ensure that climate-related financial disclosures are comparable and reduce the cost of reporting for companies and investors, the Government should work with the Committee on Climate Change to determine the appropriate way to produce a range of baseline policy and climate change scenarios that can be used off-the-shelf as reference scenarios by companies and asset owners.

Voluntary vs mandatory

73.There was debate during the inquiry as to whether reporting against the TCFD standards should remain voluntary or be made mandatory. The Government acknowledged in its submission that ‘the effectiveness of the TCFD recommendations will necessarily be contingent on their adoption by industry and by the accurate, consistent application of the disclosure framework’.94 Nevertheless, at present it is only advocating a voluntary approach to implementation. The Government has asked for views on whether in the long-term any of the TCFD-recommended disclosures should become mandatory, as part of the Department for Business Energy and Industrial Strategy’s (BEIS) consultation on Streamlined Energy and Carbon Reporting. The Minister of State for Energy and Clean Growth Rt Hon Claire Perry MP said at her appearance before us that the Government would:

‘review the results of the consultation and review the work of the Green Finance Taskforce and come to a conclusion’ on how ‘to make the [TCFD proposals] stick in a way that is not burdensome and does not create lots of disincentives’.95

74.The Bank of England did not challenge the Government’s current view on TCFD implementation, saying that at this stage it is important for TCFD adoption to be voluntary:

‘the TCFD designed their recommendations with the aim of creating a virtuous circle whereby firms voluntarily adopt the recommendations, investors respond by making clear which disclosures are of particular value, and firms learn by doing as good practice emerges. The Task Force intends to report on the first year of implementation to the G20 Leaders’ Summit in Argentina in November 2018, including by identifying good practice which may have wider application. Good quality disclosures will ultimately be driven by firms innovating and investor pressure incentivising firms to take their lead from the best quality disclosures.’96

75.However, the prevailing view in the evidence we received was that it was necessary for TCFD reporting to be made mandatory if reporting was to become widespread and generate sufficient comparable information.97 It was argued that companies and investors should be given a period of two to five years to adjust and develop their reporting practice, but that the TCFD’s recommendations would eventually need to be required on a ‘comply or explain’ basis.98

Comply or explain is a regulatory approach to corporate governance and financial supervision whereby rather than setting out binding laws, financial regulators set out a code, which listed companies may either comply with, or if they do not comply, explain publicly why they do not. The principle of ‘comply or explain’ means that companies are accountable to shareholders who can exercise sanctions rather than being accountable to a regulator.99

76.The London Stock Exchange Group (LSE) told us it is supportive of the Government’s announcement endorsing the TCFD proposals and recommended a ‘comply or explain’ approach to implementation. It says HM Government’s approach to disclosure by companies had been well balanced and supports the UK’s ‘reputation for robust and responsible reporting standards’. The LSE said:

‘While we do not suggest additional prescriptive corporate reporting burdens on listed companies, there are some areas where carefully designed government action would help catalyse better data for investors. We recognise the effectiveness and market leadership of the “comply or explain” approach adopted in the UK with regard to disclosure and governance standards, and recommend that the same approach be followed in the implementation of the TCFD recommendations both for financial institutions and listed companies.’100

77.Carbon Tracker said that although it recognized ‘the value in initially affording organisations some flexibility’, it said that ‘to deliver consistent, comparable and decision-useful disclosure’ there would have to be a mandatory element.101 Echoing this point, E3G said that ‘patchy and inconsistent information is not useful to investors, lenders or underwriters’.102 ClientEarth added that without the threat of enforcement the ‘incentives for companies to comply with TCFD recommendations in a comprehensive and consistent way may be limited’.103

78.Durham University Business School pointed out in its submission that there is ‘a significant body of academic research which finds that companies apply voluntary reporting recommendations and frameworks selectively’ and that mandatory disclosures which are not enforced, are not complied with.104 It cited poor reporting following the Companies Act 1985 which had required organisations with more than 250 employees to disclose details about their employment of disabled persons. Aviva and Christian Aid also cited evidence that ‘voluntary initiatives do not work’.105 Christian Aid said that the introduction of carbon emissions reporting illustrated this:

‘The Climate Change Act 2008 gave powers to introduce mandatory reporting by all companies within 4 years. Research found that a voluntary initiative by companies started well but plateaued quickly. Investors complained that this voluntary patchwork of information did not create a level playing-field or provide consistent enough information to guide investment choices. […] A government consultation in 2012 showed overwhelming support for mandatory reporting, and the government finally introduced mandatory reporting in April 2013–though only for listed companies. As the understanding and acceptance of climate risk has moved on dramatically since then, there is no justification for the UK pursuing a voluntary approach [on TCFD].106

79.The Aldersgate Group argued that a voluntary approach will not galvanise the market quickly enough and ensure full comparability for market participants. After holding a roundtable event in January to discuss TCFD with large businesses, they raised a number of concerns that companies have about implementation. Attendees said that greater streamlining between TCFDs and other forms of reporting would make the administrative burden on companies more manageable. Corporate attendees at its event felt that they did not have enough information to undertake scenario analysis or to understand what scenarios are appropriate (as discussed in the previous section). The Aldersgate Group suggested the government takes a transitional approach, allowing companies to adjust to TCFD-style reporting. It says a date should be set for mandatory reporting aligned with the TCFDs for all qualifying companies with a roadmap and interim milestones to allow industry to prepare and streamline their reporting processes.107

Using new legislation or the existing regulatory framework

80.We heard that there are two ways that climate-related reporting could effectively be made mandatory. The Government could introduce new laws or the Government and regulators could update corporate governance guidance and use existing laws more effectively. Alice Garton of ClientEarth explained:

‘There could be two ways, either a new law, such as [the French] Article 173, or we use the existing framework. Our view is that climate risk should be treated like any other business risk and it should be monitored by companies within their existing governance procedures. We should use the existing corpus of rules and guidance primarily … For example, the Corporate Governance Code consultation coming up at the moment, and the Stewardship Code consultation, the FCA has a number of ways that they can integrate climate risk into their existing corpus. They send “Dear CEO” letters around existing risks; for example, cyber security. They could do a similar thing on climate change.’108

Article 173: In 2015, France became the first country to introduce mandatory climate-related risk reporting when it passed the Energy Transition for Green Growth Act, which also included measures to reduce emissions, shift to renewables and increase the price of carbon. Article 173 of the Act required organisations with a balance sheet of more than 500 million euros—including asset managers, insurance companies, listed companies, and pension and social security funds—to disclose in their annual reports how they integrate climate change concerns and Environmental, Social and Governance (ESG) criteria into their investment policies and risk management. The regulation concerns all asset classes: listed assets, venture capital, bonds, physical assets, etc. The law came into force on 1 January 2016 and is being implemented on a “comply or explain” principle, providing investors with broad flexibility in choosing the best way to fulfil the law’s objectives.

81.Some witnesses expressed the view that new legislation could be used to implement TCFD recommendations or to provide a backstop if regulators, companies and investors fail to implement TCFD fully by the early 2020s.109 Most of the evidence we received, however, favoured using existing laws and governance mechanisms to implement TCFD, for example, by requiring reporting using existing governance codes and guidance on a ‘comply or explain’ basis. Some argued that the existing Companies Act 2006 already made climate risk reporting mandatory, where risks are clearly financially material, and that this could be better enforced in order to implement TCFD.

The Companies Act 2006

82.ClientEarth noted that the advantage of new laws like Article 173 is that ‘they immediately get on the boardroom agenda, because a law pierces through the everyday busyness of corporates and directors’, but said that the UK already has a ‘world-leading’ corporate governance law in the form of the Companies Act 2006.110 It explained that Section 172 of that Act requires ‘companies in their annual reports to report on the principal risks and uncertainties to their business, and long-term factors and trends that affect their businesses, where they are material.’ Some submissions argued that the Government should use the Companies Act to implement the TCFD recommendations on climate-related financial disclosure by clarifying that existing disclosure rules do apply to the physical and transition risks associated with climate change.111

83.Carbon Tracker argued that for some companies ‘compliance with the Strategic Report components of the Companies Act 2006, which requires disclosure of principal risks and uncertainties, should result in the identification of climate change or the energy transition as a material risk’.112 However, the environmental lawyers ClientEarth told us that it had seen ‘a number of examples of failures by regulators, such as the Financial Reporting Council (FRC), to properly scrutinise and enforce existing corporate disclosure law as they relate to climate change.’113 Alice Garton from ClientEarth told us:

‘Our view, as lawyers, is that there are more than enough laws out there. They are just not being used effectively, and what we are seeing is that climate change has moved from an ethical environmental issue to a core business issue. That core message is not being picked up by regulators themselves because they are also caught in short-term horizons.’114

The Companies Act 2006 provides a comprehensive code of company law for the UK, codifying Directors’ duties and the legal rules for the administration of companies. The Act includes extensive reporting and disclosure requirements for ‘quoted companies’, and created a separate reporting regime for ‘small companies’. It requires disclosure of principal risks and uncertainties.

84.Evidence to the inquiry suggested that there would need to be active participation of the UK financial regulators to update guidance on this. Carbon Tracker said the Government’s endorsement is a positive first step, but ‘it now needs to move from high-level government support to specific support and active involvement from financial regulators, such as the FCA.’115 The Principles for Responsible Investment (PRI) called on the Government to ‘explicitly clarify that where climate [change] is identified as a material risk, it should be included within companies’ annual reports’.116 It suggested that new TCFD guidance is published jointly by the Government and BoE, FRC, FCA and tPR. This guidance could then be integrated into and referenced in the relevant UK rules and codes, such as the listing rules, prospectus rules, Corporate Governance Code and Stewardship Code.

Recommendations of the Green Finance Taskforce

85.The industry-led Green Finance Taskforce, established by the Government as part of the Clean Growth Strategy, published a report in March 2018 recommending that the UK Government and its financial regulators should integrate the TCFD recommendations throughout the existing UK corporate governance and reporting framework.117 It called on the Government and relevant financial regulators to clarify in their guidelines that disclosing climate change risks is already mandatory under existing law and practice where they are financially material. In 2020 the Government should then review the extent of disclosure to monitor market adoption amongst both issuers and users.118

86.We can see the advantages in giving companies and investors time to adapt and develop how they report on climate risks and opportunities. But only if reporting is mandatory are we likely to see comprehensive and comparable climate risk disclosures.

87.The Government should set a deadline that it expects all listed companies and large asset owners to report on climate-related risks and opportunities in line with the TCFD recommendations on a comply or explain basis by 2022. The UK’s existing framework of financial law and governance could and should be used to implement climate-related risk reporting as the Green Finance Taskforce has recommended. For example, the Government should issue guidance making it clear that the Companies Act already requires companies to report on climate change where it is a material financial risk to their business. Companies and investors with high exposure to carbon intensive activities should already be reporting on climate risks in their annual reports as a matter of course.

66 https://assets.kpmg.com/content/dam/kpmg/xx/pdf/2017/10/kpmg-survey-of-corporate-responsibility-reporting-2017.pdf

67 https://www.ft.com/content/0c485f68-96eb-11e7-a652-cde3f882dd7b

68 The Task Force on Climate-related Financial Disclosures, Final Report (June 2017)

69 Oxford Sustainable Finance Programme (GFI0034)

70 E3G (GFI0016)

71 Summary of roundtable event on 9th January 2018

72 Oxford Sustainable Finance Programme (GFI0034)

73 https://www.ft.com/content/51e60772-5bf5-11e7-b553-e2df1b0c3220

74 Aviva (GFI0024)

75 https://www.ft.com/content/51e60772-5bf5-11e7-b553-e2df1b0c3220

76 The Task Force on Climate-related Financial Disclosures, Final Report (June 2017)

77 HM Treasury and Department for Business Energy and Industrial Strategy (GFI0027)

78 Q457–Q462

79 Information supplied to the committee by the Climate Disclosure Standard’s Board in an email (April 2018)

80 Q215

81 http://www.pensionsage.com/pa/BLUE-BUDGET-2015-Govt-to-work-with-LGPS-to-pool-investments.php

82 Green Finance Taskforce, Accelerating Green Finance (March 2018)

83 https://www.parliament.uk/business/committees/committees-a-z/commons-select/environmental-audit-committee/news-parliament-2017/green--finance-chairs-cooments-17-19/

84 The Task Force on Climate-related Financial Disclosures, Final Report (June 2017)

85 https://www.fsb-tcfd.org/wp-content/uploads/2017/06/TCFD-Public-FAQs-062817.pdf

86 Bank of England (GFI0038)

87 Q27

88 Q224

89 Iken Culmer Raphael (GFI0010)

90 Carbon Tracker Initiative (GFI0005)

91 Aviva (GFI0024)

92 Q222 and Q336

93 Carbon Tracker Initiative (GFI0005)

94 HM Treasury and Department for Business Energy and Industrial Strategy (GFI0027)

95 Q463–465

96 Bank of England letter to the Chair, 1 February 2018

97 Aldersgate Group (GFI0003), Aviva (GFI0024), Carbon Tracker Initiative (GFI0005), ClientEarth (GF0012) Christian Aid (GFI0015), Durham University Business School (GFI0036), Green Alliance (GFI0011), Iken Culmer Raphael (GFI0010), Q27, Q56, Q218

98 Aldersgate Group (GFI0003), UKSIF (GF0002), Q58-Q60

99 http://lexicon.ft.com/Term?term=comply-or-explain

100 London Stock Exchange Group (GFI0021)

101 Carbon Tracker Initiative (GFI0005)

102 E3G (GFI0016),

103 ClientEarth (GFI0012)

104 Durham University Business School (GFI0036)

105 Aviva (GFI0024), Christian Aid (GFI0015)

106 Christian Aid (GFI0015)

107 Aldersgate Group (GFI0003

108 Q218

109 E3G (GFI0016), Overseas Development Institute (GFI0018), Q218

110 Summary of roundtable event on 9th January 2018

111 Carbon Tracker Initiative (GFI0005) ClientEarth (GFI0012), Principle for Responsible Investment (GFI0029)

112 Carbon Tracker Initiative (GFI0005)

113 ClientEarth (GFI0012)

114 Q232

115 Carbon Tracker Initiative (GFI0005)

116 Principle for Responsible Investment (GFI0029)

117 Green Finance Taskforce, Accelerating Green Finance (March 2018)

118 Green Finance Taskforce, Accelerating Green Finance (March 2018)



Published: 6 June 2018