BNM Climate Change and Principle-based Taxonomy - What this means for FIs Hong Chin Pheng

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BNM Climate Change and Principle-based Taxonomy
What this means for FIs

Hong Chin Pheng
Deputy Director
Financial Conglomorate Supervision Department
Bank Negara Malaysia
CCPT as a Key Building Block in Supporting an Orderly Transition
 Key Considerations
 1   Provide a framework that facilitates robust and consistent assessments of economic activities and their associated impacts on climate and the
     broader environment
 2   Consider the state of economic development and different stages of transitioning across economic agents

 3   Support transition of economic activities that currently do not contribute to climate change objectives

                                                                        Progressive classification system to acknowledge concrete transition
             5 Guiding Principles (GP)
                                                                                              efforts and commitments

1 Climate Change                                                                                                       Economic Activity
                                                                                                                                              Overall
                                                                                     Classification                                          Business
                              4
      Mitigation                   Remedial
        (GP1)                     Measures to                                                                           GP1         GP2     GP3      GP4
                                   Transition                                       Supporting
2 Climate Change                     (GP4)                          Activities with positive impacts on climate
                                                                                                                  C1   GP1 or GP2 or both    ✓
      Adaptation                                                   change, and causing no significant harm to
                                                                                  the environment
                              5
        (GP2)
                                    Prohibited                                     Transitioning
                                     Activities                                                                   C2   GP1 or GP2 or both    ✘       ✓
                                                                    Activities causing significant harm to the
3    No Significant                   (GP5)                          environment but remedial measures            C3           ✘             ✘       ✓
      Harm to the
     Environment
                                                                               taken to reduce harm
         (GP3)                                                                       Watchlist                    C4   GP1 or GP2 or both    ✘       ✘
                                                                    Activities causing significant harm to the
                                                                    environment and no remedial measures          C5            ✘            ✘       ✘
                                                                               taken to reduce harm

                                                                               2
Supervisory Expectations

       FIs to play nurturing role

        • Accelerate customers’ (including value chain) transitioning towards more sustainable practices
        • Active channelling of resources towards low carbon and sustainable activities

             Conduct further due diligence on customers’ business operations

              • FIs to better understand how customers’ business model and operations contribute to climate risk mitigation/adaptation objectives
                and impact on the broader environment
              • Leverage on external sources to proxy customers’ GHG emission data, or external validation/certification, if necessary

                   Integration of climate considerations (whole-of-bank approach)

               •   Embed climate considerations in business strategy, operations and decision makings
               •   Incorporate climate-related risks in risk appetite, overall risk management framework and lending/investment policies
               •   Conduct stress testing/scenario analysis and incorporate results in internal capital target setting as part of ICAAP.
               •   Explore relevant metrics/ targets and develop new products that aid management of climate-related risks.

              Continuous staff capacity building

               • Strengthen technical and assessment capabilities in climate-related risks to undertake effective risk assessment and customer due
                 diligence

       Increased commitment on climate-related disclosures

         • Intensify readiness for greater climate-related risks disclosures, aligning with TCFD recommendations
         • Advocate improved sustainability disclosures by customers’

                                                                           3
Action Plans to Ensure Effective Implementation of CCPT

                                                    Establishment of a
                                                   CCPT Implementation
                                                          Group

                                                                                        FIs to report on
                 Explore CCPT for
                                                                                        exposures based on
                 insurance/ takaful
                                                                                        CCPT classification
                    underwriting

                                                                                                     Continued supervisory
                                                                                                     engagements and
                                                                                                     review/stocktake for
                                                                                                     alignment of
    Socialisation with FIs
                                                                                                     supervisory
    and other relevant
                                                                                                     expectations and
    stakeholders post-
                                                                                                     progress of CCPT
    issuance of CCPT
                                                                                                     implementation
                                                            Key
                                                         Priorities

                                Participation in the Development of ASEAN Regional Taxonomy

                                                                4
Illustration of CCPT classification process
                   Q1: Does the purpose of the facility/transaction/funding contribute to:
 At the                 • Climate change mitigation (substantially avoid, reduce or enable), and/or [GP1]
 transaction            • Climate change adaptation (increase own resilience or enable others to adapt) [GP2]
 level:
                                                   Yes                                                                   No
 At the            Q2: Does the economic activity or the overall business                Q2: Does the economic activity or the overall
 transaction       potentially cause significant harm to the broader                     business potentially cause significant harm to the
 and issuer        environment? [GP3]                                                    broader environment? [GP3]
 levels:                DNSH                  May cause significant harm                                  May cause significant harm

 At the                                 Q3: Remedial measures taken to
                                                                                         Q3: Remedial measures taken to promote transition
 transaction                            promote transition and reduce
                                                                                         and reduce harmful practices? [GP4]
 and issuer                             harmful practices? [GP4]
 levels:                                         Yes                      No                              Yes                        No

                           C1                    C2                       C3                              C4                         C5

                      Supporting                         Transitioning                                              Watchlist

Source: Adaptation from “Overview and Recommendations for Sustainable Finance Taxonomies” paper by ICMA     Case 1: Green Building
        (May 2021).
                                                                                                            Case 2: Fossil Fuel

                                                                                                            Case 3: Oil Palm
                                                                                  5
Case 1 : Refinancing a Green Building

        Background                  Transaction Level                         Overall Business Level

                                    GP1          GP2         GP3       GP4*            Scenario 1
• An SPV – Refinance existing
  credit facility to part finance
                                                             • Borrower had assessed and improved the building’s design to
  construction of a green           • Purpose of
  building for own use.                                        reduce adverse impact on climate change
                                      financing meets
                                                             • Sustainability due diligence was conducted as part of the FIs
• Issued a provisional Green          climate change
  Building Index (GBI) Design         mitigation objective     approval process
  Assessment certification and        (subject to a          • Compliance with the FIs internal real estate and construction   C1
  applying for the final GBI          minimum GBI silver       sector guides’ requirements, sustainable financing policy and
  award.                              rating, based on the     controversy check
                                      FI’s risk appetite).
• Complies with applicable                                   • Satisfactory report from Environmental Management Plan
  requirements such as              • GBI mainly focuses       and Occupational Safety & Health Management Plan.
  Environmental Management            on evaluating the
  Plan and Occupational               environmental
                                                                        GP4            Scenario 2
  Safety & Health                     performance of         GP2
  Management Plan.                    buildings, not the
                                                             • Borrower facing allegations of improper waste management.
                                      building’s adaptive
• Adopts strict policy to ensure                             • FI assessed that the customer has put in place remediation
                                      capacity to climate-
  compliance with ESG                                          measures and demonstrated serious commitment to improve
                                      related hazards.
  standards which includes
                                                               its waste management practices with actionable, time-bound
  ensuring no deforestation,
  forced labour or                                             and transparent remediation plans.                              C2
  development-induced               Legend :                 • This includes the development and implementation of a
  displacement of local                  Meets GP              company policy to require recycling and proper disposal of
  communities.                           Does not meet GP      construction waste.
                                         Not Applicable
                                     *
                                                                                          Back to Main Slide
                                                               6
Case 2 : Financing in Fossil-Fuel Related Activities
          Background                  Transaction Level                              Overall Business Level
                                                                   Scenario 1 (Bond Issuance)
• Customer involved in both
  upstream and downstream
                                    GP1        GP2                  GP3        GP4
• Good track record in terms of
  demonstrating commitments in       • Purpose – to facilitate
  addressing climate change and        diversification on           • Customer engages in other upstream and downstream oil
  the associated environmental         renewal energy.                and gas activities that do have potential negative effects on
  impacts                                                             the environment.
                                     • Meets GP1 as directly
• Demonstrated a clear                 supports climate             • However, customer has clear plans and practices in place        C2
  sustainability strategy e.g. to      change mitigation but          to support transition efforts towards a low carbon and
  achieve net zero carbon              not adaptation.                climate resilient economy.
  emissions by 2050
• Commitment to reduce GHG
  emissions, focusing on                                           Scenario 2 (Revolving Credit)
  liquefied natural gas while
  transitioning towards renewable   GP1         GP2                 GP3         GP4
  energy solutions.
                                     • Purpose – facilitate         • Customer’s activities do have potential negative effects on
• Complies to EQA 1974 and             expansion of                   the environment.
  ISO 14001:2003 Environmental         upstream business
  Management Systems                                                • Nonetheless, customer has clear plans and is adopting
                                     • Do not contribute to           sustainable practices to support the transition efforts
  certification for 80% of its
  exploration with target to           climate change                 towards a low carbon and climate resilient economy such         C3
  achieve 100% by a committed          mitigation or                  as commitment to reduce GHG emissions and focus on
  timeline                             adaptation objective           supplying low carbon fuels.

                                    Legend :     Meets GP
                                                                                                Back to Main Slide
                                                Does not meet GP    7
Case 3 : Financing for Expansion of Oil Palm Plantation
        Background                     Transaction level                                Overall Business Level
• Mid-sized customer requests                                                    GP4             Scenario 1
  for project financing to fund
                                   GP1           GP2                 GP3
  new cultivation on existing     MSPO certified and has           Taken actions on remedial actions to reduce harm to the environment
  agriculture land and            taken measures to reduce         and subjected to periodic due diligence on progress of actions.
  implement measures to           GHG emissions:
  support the adoption of                                          i) No use of open burning for cultivation and waste disposal
  sustainable practices.          i) Systematically collect,
                                      accumulate and transfer
                                                                   ii) Management of water table in existing peat areas to reduce peat
                                                                        subsidence rate i.e. release of GHG emission from peat soil
                                                                                                                                              C2
• Has obtained MSPO                   oil palm biomass for
  certification covering 7 MGP*                                    iii) Use palm oil mill effluent as a substitute for inorganic fertiliser
  for oil palm plantation and 6       processing by biofuel
                                      producer
  MGP for its oil palm mills as                                     GP3         GP4              Scenario 2
  follows:                        ii) Use of hybrid vehicles for
                                      maintenance work and         On top of the remedial actions above, customer is also implementing
  ✓ Management commitment                                          international best practices to substantially limit harm to
    & responsibility                  transportation of palm
                                      fruits                       environment:
  ✓ Transparency                                                   i) No new deforestation and no new cultivation on peatland
  ✓ Comply with legal req.        Has also taken measures to       ii) Maintain a ground cover of natural vegetation in existing peatland
  ✓ Social responsibility,        increase climate resilience:          to keep surface moist, minimize irreversible drying and reduce
                                                                        GHG emission
                                                                                                                                              C1
    health, safety and            i) Install water harvesting
    employment conditions            system (e.g. redirecting      iii) Construct water management and drainage systems to maintain
                                     water from drainage and            acceptable level of water table for existing peatland
  ✓ Environment, natural
                                     storage of rainwater as       iv) No new cultivation on steep terrains (slope of 25 degree or more)
    resources, biodiversity and
    ecosystem services               contingency for dry spells    v) Conduct periodic soil testing to determine its organic matter and
                                     periods)                           pH structure, and maintain soil fertility
  ✓ Best practices
                                  *MGP – Malaysian Sustainable       Legend :     Meets GP
  ✓ Development of new               Palm Oil General Princtiple                                      Back to Main Slide
                                                                         8        Does not meet GP
    planting
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