CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
G R E AT
E X P E C TAT I O N S
C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

A financial service sector benchmark study
CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
G R E AT E X P EC TAT I O N S : C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
FOREWORD
           Climate change is here to stay. Global warming as well as changes to the overall
           climate system have become topics that will remain with us well into the future.
           The probability and frequency of serious consequences like extreme weather
           events, heavy precipitation, tropical storms, and a rise in sea level will continually
           increase, having potential impacts that include a reduction in global harvests and
           a negative impact on global GDP. However, sustainability is not limited to climate
           issues. Other environmental, social and governance aspects are also of critical
           importance and can lead to further risks for society and the global economy.

           Capgemini acknowledges the importance of sustainable business and an according
           individual behavior. We strongly support sustainability both within our company as
           well as with our clients’ transformations (see: CG Sustainability).

           Climate-related and environmental (CR-E) risks continue to grow rapidly and
           are already considered the greatest risks in the current global risk landscape
           (see World Economic Forum’s Global Risk Landscape 2020). Management of these
           risks is therefore essential in all industries, particularly for the financial industry.
           But assessing these risks has its own challenges. On the one hand, they have to be
           differentiated according to categories such as region, industry and supply chain
           patterns. On the other hand, their impact is permanently changing, irregular and
           can occur very seldomly while data histories are often missing. These complicate
           the collection of data and the meaningful analysis of risk patterns. To manage
           CR-E risks, institutions need to analyse these risks across all risk types and integrate
           them into their risk management framework. In addition to this, authorities also
           recommend that these risks be integrated into stress tests and long-term
           scenario analysis.

           Increasing public scrutiny with regard to sustainability aspects and risks together
           with higher transparency – enabled also by growing disclosure requirements –
           is causing additional pressure on the management of the institution’s own CR-E
           risks. Furthermore, the regulatory environment is rapidly evolving, fueled by the
           European climate and energy targets. Current discussions on CR-E risks go so far
           as to consider extending the usual outside-in view to include an insight-out view,
           which would reflect the institution’s potential impact on environment and society.

           Our study aims to give orientation about the current status of how banks
           are adapting with regard to climate and environmental risks and thus
           support our clients to set priorities on their transformation paths in this
           fast-changing and challenging environment.

           Joachim von Puttkamer
           Global Head of Banking,
           Head of Financial Services DACH

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
AGENDA

         FOREWORD                                           3

         SURVEY APPROACH AND
         MANAGEMENT SUMMARY                                 5

         I N T R O D U C T I O N R E G U L ATO R Y
         BACKGROUND                                         6

         S T R AT E G Y – I M PA C T O N B U S I N E S S    8

         GOVERNANCE & RISK                                 10

         D ATA & R E P O R T I N G                         12

         SUMMARY AND DISCUSSION                            14

         A U T H O R & CO N TA C T S                       16

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
SURVEY APPROACH AND
MANAGEMENT SUMMARY

The objective of this study is to provide a snapshot                      Participants operate as universal banks, direct banks,
of the as-is maturity level within financial institutions                 and cooperative banks as well as special financial service
with regards to the thirteen expectations delineated in                   providers. The participants are located across Austria,
the “Guide on climate-related and environmental risks”                    Germany, the Netherlands, and Switzerland. Considering
(CR-E risks) by the ECB1. For this purpose, a questionnaire               that the financial service sector acts as a multiplier in the
was developed with more than 30 questions, including                      economy and that the combined balance sheet size of
qualitative statements, split into three main categories:                 the participating financial institutions is more than EUR
(1) Strategy, (2) Governance & Risk, and (3) Data &                       5 trillion, the impact of the participants in the economy
Reporting.                                                                is deemed as broad.

Key findings of this study are:

    Maturity of the                          More than half of              Overall governance              Data and ratings are an
    approach towards                         the institutions see           structures for CR-E risks       essential component
    the inclusion of                         their business models          are heterogenous and            of understanding and
    sustainability differs                   at least moderately            not well developed.             managing CR-E risks,
    between the four                         and 38% extremely              Only 50% of participants        and the lack of both
    countries. The                           affected by CR-E               implement measure to            availability and quality
    Netherlands are ahead                    risks. Simultaneously,         manage CR-E risks but           represents one of the
    in this regard. ESG-                     institutions recognize         the execution of these          main pain points of the
    related topics are                       that by positioning            measures is governed            participants. Efforts to
    already deep in the                      themselves as pioneers         by different bodies in          obtain any of both are
    strategy, governance                     internally and externally      different institutes and        plagued with high costs
    and subsequently in the                  they can send a                is sparsely tracked. The        and low comparability.
    whole organizational                     powerful signal to the         sole exception being the        Particularly institutions
    structure. Global or at                  market participants and        inclusion of CR-E risks         operating globally see
    least EU-wide standards                  drive an economy-wide          into the risk culture by        reliable and comparable
    and regulations could                    realignment on more            78% of participants.            sources of data as
    foster the efforts for                   than just core industries.     Furthermore,                    necessary to rate
    other countries as well.                                                institutions struggle           products, financing, and
                                                                            to allocate CR-E risks          other offered services
                                                                            to one specific risk            along the value chain
                                                                            category. They are seen         of financial institutions
                                                                            as a facet to all – credit,     constantly and
                                                                            market, operational and         transparently.
                                                                            liquidity – risks.

A brief overview of the regulatory background and activities contextualizes relevance of the findings which are provided
subsequently and are structured around the three topics of Strategy, Risk & Governance, and Data & Reporting.

1
    See ECB (2020) Guide on climate-related and environmental risks

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
G R E AT E X P EC TAT I O N S : C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

R EG U L ATO RY B AC KG R O U N D

Climate change is one of the                                The economy must react to the                              three focus topics in their audit
most important topics in the                                existing and upcoming challenges.                          in 20203. By the end of 2020 the
world right now. Instead of being                                                                                      ECB published the final version
just a temporary occurrence,                                Global regulators also have                                of its guide on climate-related
sustainability will be permanently                          high expectations for market                               and environmental (CR-E) risks4.
on the agenda. Larry Fink,                                  participants. These expectations                           The EBA added climate related
Chairman and C.E.O of Blackrock,                            should drive the change towards                            risks to their stress test for 20225.
reinforced his powerful message                             a greener economy. Particularly,                           Taking these developments into
from last year with this year’s letter                      banks have a multiplicator effect                          account, the extent to which
to the world’s C.E.O.s. Climate                             on the markets. Local regulators,                          financial service sector practices
change will be “a defining factor in                        for example the BaFin, added                               of European institutions are in
companies’ long-term prospects”2.                           sustainability as one of the                               line with regulatory expectations

Figure 1 | Cumulative number of publications* (part one)

                                                                                                                                                          25
       ∑ ~ 10                            ∑ ~ 25                                                                                 18
                                                                                                      14

                |10                                                  5

                 Q4                                Q1                                Q2                               Q3                             Q4
                2019                                                                                 2020

              12/2019                                   02/2020                                     06/2020                   10/2020
              EC                                        EC                                          EU                        EBA
              The European                              Summary Report                              Taxonomy                  Discussion paper
              Green Deal                                of the Public                               Regulation                on management
                                                        Consultation                                                          and supervision of
                                                        on the Review                                                         ESG risks for credit
                                                        of the NFRD                                                           institutions and
              12/2019                                                                                                         investment firms
              EBA
              Action plan on
              sustainable
              finance
                                           01/2020                                 04/2020                            09/2020              11/2020
                                           EBA                                     ESMA, EBA                          EBA                  ECB
                                           Sustainable Finance                     & EIOPA                            Survey: Pillar 3     Guide on
       11/2019                             Market Practices                        Joint Consultation                 disclosures on       climate-related
       EC                                                                          Paper: ESG disclosures             ESG risks            and environmental
                                                                                                                                           risks Supervisory
       Regulations on sustainability
                                                                                                                                           expectations relating
       related disclosures in the
                                                                                                                                           to risk management
       financial services sector
                                                                 *Amount is not exhaustive         Publications in effect                  and disclosure

2
    See Larry Fink's 2021 letter to CEOs, (accessed 22 Feb 2021), bit.ly/Larry _Fink_CEO_Letter
3
    See BaFin supervisory priorities for 2020, (accessed 22 Feb 2021), bit.ly/BaFin_supervisory _priorities_2020
3
    ibid.
4
    See ECB (2020) Guide on climate-related and environmental risks

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CLIMATE RELATED AND ENVIRONMENTAL RISKS - A financial service sector benchmark study - Capgemini
set by the authorities is one of                         sustainability have been increasing                 (RTS) and will specify certain
today’s most relevant topics for                         over the past years visible in Figure 1.            aspects in this regard. The time
the financial services sector.                           As the number of regulatory papers                  is now for financial services
                                                         has already increased from 10 in                    participants to take measures
Although the ECB expectations                            2019 to roughly 25 in 2020, it is                   and incorporate CR-E risks and
and other proposed regulatory                            likely to reach the figure of 35 or                 other facets of sustainability
changes have not yet become                              more in 2021. The status of many                    in their implementation and
formally binding, they are expected                      of these publications is set to                     change plans.
to become relevant in the near                           change in the coming year, e.g. the
future. Additionally, they are                           EU Taxonomy6, which was published
part of the SREP considerations.                         in 2020, will trigger a large amount
The publications that deal with                          of regulatory technical standards

Figure 1 | Cumulative number of publications* (part two)

                                                                                                                       35

                                                                                         25
       ∑ ~ 35                                      18

                                10

                Q1                              Q2                              Q3                          Q4                             Q1
                                                               2021                                                                       2022

         01/2021                                        Q1/2021                                      Q1/2021
         EC                                             EBA                                          EC
         Study on                                       Final Draft on                               Draft Publication
         sustainability-                                management                                   of the NFRD
         related ratings,                               and supervision
         data and research                              of ESG risks for
                                                        credit institutions
                                                        and investment
                                                        firms
                                                                                                                                   Q1/2022
                                                                                                                                   EU
                                                                                                                                   Application of
                                                                                                                                   the requirements
                                   02/2021                                           Q1/2021                                       for climate-related
                                   ESMA, EBA                                         EBA                                           objectives by the
                                                                                                                                   EU Taxonomy
                                   & EIOPA                                           Final Draft on the
                                   Final Draft on                                    Pillar 3 disclosures
                                   ESG Disclosures                                   on ESG risks

                                                                                                            Upcoming publication    *Amount is not exhaustive

6
    For more details see Sustainable finance taxonomy – Regulation (EU) 2020/852.

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G R E AT E X P EC TAT I O N S : C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

S T R AT EG Y – I M PAC T O N B U S I N E S S

CR-E risks affect the entire                              Figure 2 | How severely do CR-E risks affect               Figure 3 | Have you adapted your business
                                                          the business model of your institution?                    strategy based on CR-E risks?
organization. Therefore, it is
important to create and promote
                                                             Not at all           11 %
appropriate strategies on top
                                                              Slightly                   17 %
management level. Consequently,
the first part of the interview was                       Moderately                        22 %
dedicated to Strategy aims to                                Severely             11 %
provide insights on the awareness                          Extremely                                      39 %
regarding CR-E risks at the                                                                                                                                      44 %
supervisory and management                                                                                             56 %
board level of financial institutions.                    Second, bank management also
This topic is particularly relevant                       sees that sustainability offers them
for these key individuals because it                      an opportunity to exploit new
affects their organisation’s business                     market opportunities.
strategy in the short, medium and
long term7. This survey segment is                        One such opportunity is the
comprised of five questions that                          growing demand for products                                   No      Yes
focus on the impact CR-E risks                            with a green profile. Organisations
have on a bank’s business model.                          are facing greater societal pressure
These questions also explore if                           as demand from institutional                               Thus, an evolved public image is
CR-E risks foster change of a bank’s                      clients for sustainable investments                        necessary to thrive within this new
business strategy and provide                             continues to grow. Additionally,                           market environment. For instance,
insight on the main drivers behind                        there is an increasing expectation                         banks are publicly announcing
such change. Also included are the                        from retail clients for organisations                      sustainability strategies with clear
area’s most substantially affected                        to improve their Environmental,                            commitments to limit or prohibit
by CR-E risks. If CR-E risks related                      Social and corporate Governance                            their investments in specific
initiatives were underway at the                          (ESG) profiles.                                            economic sectors, such as tobacco,
participant’s institutions, projects                                                                                 the arms industry, and oil and gas.
were identified.                                                                                                     Some institutions have even
                                                          "First time since                                         announced their divestments
More than 70% of respondents                                financial crisis that a                                  of portfolio in these industries.
see their firms’ business models
                                                            topic offers potential
at least moderately affected by                                                                                      "A low CO2 footprint
CR-E risks (Figure 2). In fact,                             for positive impact
56% of interviewees stated that                                                                                        as a bank is nice to
their firms adapted their business                          and reputation".
strategies to account for the
                                                                                                                       have but the real
increasing influence of these risks                       This growing demand for green                                impact comes with
(Figure 3). The rationale behind
this development is two-fold.
                                                          products goes hand in hand
                                                          with increased retail customer
                                                                                                                       a green portfolio".
First, related regulatory obligations                     identification with banks
are becoming more demanding and                                                                                      By these actions banks seek a new
                                                          demonstrating ESG values. Banks                            level of client identification with
bank management expects further                           can capitalise on this by choosing
extensions of these regulatory                                                                                       their overall business strategy,
                                                          to pioneer business strategies that                        known previously only from
obligations.                                              focus on sustainability and foster                         packaged goods and fashion
                                                          ESG values.                                                industry8.

7
  See European Central Bank, (2020), Guide on climate-related and environmental risk.
	See Business Insider (2020), Sustainability sells: Why consumers and clothing brands alike are turning to sustainability as a guiding light, (accessed 22 Feb 2021)
8

  bit.ly/Sustainability _sells

8
Deutsche Bank, for instance,                       Figure 5 | Do you have ongoing projects in
                                                   the planning stages to prepare for expected
set out ambitious goals in its                     supervisory requirements?
2020 “Climate Statement” to
achieve a portfolio of sustainable
investments under management                                      11 %
of over EUR 200 billion by 2025,                                                 17 %
to exit from coal mining industry
by 2025 and to prohibit new oil
and gas project financing for
specific regions9.

Overall, banks recognise that
they are driving an industry-wide
realignment due to the significant
impact of CR-E risks on most
business areas. The regulatory                                         72 %
consideration of CR-E risk has
a significant impact on three                        No
core industries (Figure 4), as                       Yes, already for 2020
                                                     Yes, in planning for 2021
large amounts of greenhouse
gas can be saved in these
indispensable industries.                          Other banks have developed
                                                   sustainability strategies constantly
Figure 4 | In which area or areas do you see       over the past years and created
the most substantial effects?                      general bank-wide target operating
                                                   models (TOM) focused on
                                                   sustainability. The other end of the
                                                   spectrum is represented by banks
                                                   that have only recently initiated
                                                   such changes, figuratively missing
      Real          Food &           Energy        their jump onto the regulatory
     estate       agriculture                      requirement train at an early stage.
                                                   Now time is limited to implement
It is therefore not surprising                     all requirements.
that 72% of financial institutions
responded they have actively                       Both, an appropriate governance
addressed expected regulatory                      structure and an adequate risk
requirements in projects in 2020                   management framework, are
(Figure 5). Furthermore, 11% are                   crucial prerequisites for any
planning to continue their efforts                 organisation expecting to thrive in
in 2021. In general, this peer group               this changing market, in addition to
is widely spread with respect to the               the regulatory induced challenges.
timeline with which sustainability
projects are being implemented.
A salient example is an ongoing
project to fulfil aims related to
sustainability that originated
in 2015.

9
    See Deutsche Bank, (2020), Climate Statement

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G R E AT E X P EC TAT I O N S : C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

GOVERNANCE & RISK

An adequate set up of governance                      Of those institutes that have                  The second category reflects the
and risk management structures                        explicit measures, 33% state that              self-commitment to, for example,
in an organization is crucial                         these are not positioned in any                reduce the institution’s carbon
to successfully reflect the                           committees or panels while 22%                 footprint, in some cases to the
adaptations needed to succeed in                      indicate to have created a new                 point of carbon neutrality. As
a changing regulatory and business                    committee or panel dedicated                   mentioned in the section above,
environment. Ten questions of the                     exclusively to the governance of               the general sentiment is that real
questionnaire were dedicated to                       these measures (Figure 7). The                 economic and social impact will
assessing the current penetration                     remaining 45% have modified or                 primarily be achieved with a green
of CR-E risks into these structures.                  extended the mandates of existing              portfolio, and thus the KPIs should
The questions were concerned with                     bodies to manage CR-E risks.                   reflect this ambition. Nonetheless,
if and how measures to manage                                                                        as discussed below, internal
these risks had already been                          Figure 7 | Are these measures already          changes can be leveraged as a
implemented, if key performance                       implemented in committees and/or panels?       signal to other market participants.
indicators (KPIs) and key risk
indicators (KRIs) were in place,                                                                     Participants were also queried
their inclusion into the risk culture                                                                on whether they had already
and the consideration of CR-E                                  22 %                                  developed KRIs to manage and
risks into the risk appetite. This                                                                   measure CR-E risks. To account for
                                                                                            33 %
part of the survey concluded with                                                                    the known paucity of data available,
questions regarding in which                                                                         qualitative and quantitative KRIs
risk categories CR-E risks are                                                                       were differentiated. 72% of the
considered and if they are                                                                           interviewed institutes stated to
part of any stress scenarios.                                                                        have no KRIs at all, while only 6%
                                                                                                     answered that they have both
The results show that 50% of                                                                         quantitative and qualitative KRIs.
the interviewed institutions have                                   45 %
implemented measures to manage
CR-E risks in their governance                                                                       "You have to put
(Figure 6); an example given by a                       No      Yes, existing committees
                                                        Yes, new committee
                                                                                                       your house in order
respondent is the implementation
of institution-wide Sustainable                                                                        to have meaningful
Finance Regulations (SFR).                            Dedicated bodies for the                         conversations with
                                                      management of CR-E risk promote
Figure 6 | Have you already implemented               an executable decision-making                    the client".
measures to manage CR-E risks in your                 process and the enforcement of
governance?
                                                      discipline. In both cases adequate             The remaining 22% are evenly
                                                      monitoring and the subsequent                  split among those with only
                                                      informed decision-taking can only              qualitative or only quantitative
                                                      take place if any measures are                 KRIs. Seeing as more than two
                                                      reflected in appropriate KPIs. As is,          thirds of respondents have not yet
                                                      half of the interviewed institutes             implemented any KRIs, it is then
                                                      responded that they have KPIs in               not surprising that only 33% of the
                                                      place, and these can be roughly                interviewees declared that CR-E
 50 %                                    50 %         divided in two categories. The first           risks are part of their risk appetite,
                                                      category is comprised of those                 although some of the remaining
                                                      KPIs that follow the evolution                 67% added that the risk appetite
                                                      of the portfolio by reflecting                 statement (RAS) is currently
                                                      the substitution away from non-                being amended accordingly.
                                                      desirable industries (such as tobacco          Top management defines the
                                                      gambling, and coal mining) into                roles and responsibilities across
  No      Yes
                                                      others perceived to be more                    the organization, and in the case
                                                      sustainable.                                   of risk, usually based on the

10
Three Lines of Defence (3 LoD)                              Figure 9 | Which types of risk do you consider                    are considered in all other risk
                                                            when assessing CR-E risks?
model. Almost every participant                                                                                               categories as well, albeit not in the
already applies this model in                                                                                                 same magnitude. As stated by one
                                                                                    100,0 %
its organization. For 44% of                                                                                                  participant, CR-E risks should not
interviewed institutes internal                                                                 81,3 %                        be perceived as a new risk type,
                                                         Percentage of respondent
audit, as the 3rd LoD, considers                                                                            68,8 %            but rather as a different aspect
aspects of CR-E risks in their annual                                                                                         within each risk category and as
                                                                                                                     50,0 %
process. One third of the remaining                                                                                           such, should be considered equally
56% responded that such a                                                                                                     in all categories to capitalize on
development is planned in 2021.                                                                                               existing processes.

The participants seem to agree that                                                                                           One of the expectations that
an internal evolution is a germane                                                  Credit    Operational   Market   Liquid   was expanded upon during the
                                                                                     risk        risk        risk     risk
part of creating a trustworthy and                                                                                            consultative process prior to the
plausible position in the market.                                                                                             publication of the final guide
As succinctly stated during the                             A different study by Capgemini                                    concerns stress scenarios.
interviews by a participant: “You                           Invent also showcased the                                         This expansion confirms the
have to put your house in order                             relevance of the “ecological                                      importance attached to stress
to have meaningful conversations                            footprint” of business, for clients                               scenarios not only be the regulator
with the client”.                                            as well as for staff10.                                          but by the market. When asked if
                                                                                                                              CR-E risks were already included
Figure 8 | Do you consider CR-E in your                     As for the question in which                                      into such scenarios, only 39% of
risk culture?                                               risk categories CR-E risks are                                    participants (Figure 10) answered
                                                            considered, there are two aspects                                 in the affirmative. This relatively
                                                            that can be highlighted.                                          low number given the importance
                                                                                                                              attached to this exercise, is,
                                                                                                                              according to the participants,
                                     22 %
                                                            "Sustainability is                                               due to the large data requirements
                                                              rather a facet to                                               associated with such a test and the
                                                                                                                              current low data availability and
                                                              every risk type                                                 quality.
                                                              instead of a new
                                                                                                                              Figure 10 | Have you incorporated CR-E into
                                                             risk type".                                                      specific stress scenarios yet?

           78 %
                                                            First, the EBA suggests11 to
                                                            consider any risk associated with
                                                            ESG factors on the conditions of
     No   Yes                                               borrowers and all participants do
                                                            so by accounting for CR-E risks as                                  39 %
One way of doing is so is to foster                         being part of credit risk. Second,
a coherent risk culture. 78% of the                         CR-E risks are perceived as being
surveyed institutions (Figure 8)                            mostly natural events, and thus a
                                                            relatively large number of institutes                                                                  61 %
already consider CR-E risks in their
risk culture. The majority of the                           consider CR-E risks within the
remaining 22% aim to include CR-E                           operational risk category (Figure 9)12.
risks in their risk culture soon.                           Nonetheless, CR-E risks

                                                                                                                                No     Yes

10
   	See Capgemini Research Institute (2020), Digital Mastery – How organizations have progressed in their
    digital transformations over the past two years, (accessed Feb, 2021), bit.ly/Digital_Mastery
11
    See EBA (2020), Final Report – Guidelines on loan origination and monitoring
12
    This question was not relevant for 11% of the participants

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G R E AT E X P EC TAT I O N S : C L I M AT E R E L AT E D A N D E N V I R O N M E N TA L R I S K S

DATA & R E P O R T I N G

Data and reporting are
always challenging topics for
                                                          Figure 11 | Do you already have or are you
                                                          in the process of building a specific data pool            "Data availability
organisations, and this is certainly
                                                          for CR-E risk?
                                                                                                                       and integrity is
evident from a sustainability point
of view. In light of this, the ECB                                                                                     key to understand,
has provided specific guidance
                                                                                               22 %                    and adjust the
on CR-E risks by dedicating two
expectations to these topics13.                                33 %                                                    management
Also, a high number of regulatory
papers focus on data, reporting,
                                                                                                                       of climate risks".
and financial disclosure14. This
survey addresses issues directly,                                                                     17 %
                                                                                                                     Recently published research from
formulating questions around                                                                                         the European Commission covered
internal and external reporting                                                                                      a large study on data and ratings15
as well as on the creation of a                                                                                      which showcased the difficulty
data pool through internal or                                                28 %                                    of collecting data and deriving
external sources.                                                                                                    comparable ratings. It is no wonder
                                                                                                                     that financial markets participants
                                                             Not yet     Yes, by purchasing external data
                                                                                                                     are struggling in this regard. On
"Publicly available                                         Yes, through internal data
                                                             Yes, both                                              the one hand, the compilation and
  reliable data sources                                                                                              aggregation of ESG-related data is
                                                                                                                     a costly and, most often, a manual
                                                          All participants mentioned data
  would enable us to                                      as one of the crucial factors to
                                                                                                                     effort. On the other hand, external
                                                                                                                     providers often offer biased data
  move faster".                                           observe, steer, and manage CR-E
                                                                                                                     derived through opaque evaluation
                                                          risks. However, 22% (Figure 11)
                                                                                                                     methodologies16. Both lead to a
                                                          of the respondents have not yet
                                                                                                                     lack in comparability across the
                                                          started to build up a dedicated data
                                                                                                                     data that can be large enough to
                                                          pool. Almost 45% rely on either
                                                                                                                     hinder the discourse and slow
                                                          gathering data internally or buying
                                                                                                                     down the development of
                                                          external data from providers. One
                                                                                                                     measures.
                                                          third of the participants already
                                                          do both.

Figure 12 | Key Issues and improvement potential around ESG data and ratings17

                                                            Timeliness, Accuracy,                                      Company Sustainability
     Transparency
                                                            and Reliability                                            Disclosures

...of ESG ratings regarding:                              ... of updates to companies´                               Lack of standards undermine the
•	methodologies deployed                                 profiles within various ESG-related                        usefulness of company sustainability
   (scope, metrics, weightings)                           rating data & research provider                            disclosures to investors and puts strain
•	quality assurance processes.                           outputs and systems.                                       on companies
Improvement results/wishes:                               Improvement results/wishes:                                Improvement results/wishes:
•	more effective output utilization                      •	better ESG data quality and consistency                 •	commonly accepted formalized
•	understanding ratings divergence                       •	ability to directly correct own information                naming structure to describe ESG-
•	selecting ratings that align with their                •	fewer concerns over metrics and                            related products and services
   own objectives                                            aspects of assessment                                   •	better performance assessment
                                                                                                                        companies

13
   See ECB (2020) Guide on climate-related and environmental risks, pp. 4-5.
14
  	See for example EBA – Survey: Pillar 3 disclosures on ESG risks, ECB (2020) ECB report on institutions’ climate-related and environmental risk disclosures or TCFD –
   Disclosure Guidance on Risk Management Integration and Disclosure.
15
   See EC (2021) Study on sustainability-related ratings, data and research.
16
   ibid.
17
   Internal reseach by Capgemin Invent (2020)

12
In sum, the demand on financial               Two thirds of the respondents          Figure 14 | Do you publish a sustainability
                                                                                     report?
service providers to provide more             already have an internal reporting
transparent, timely, accurate,                process in place for CR-E risks
reliable, and consistent raw data.            (Figure 13). In most cases these
Making data publicly available                reports go directly to the                         17 %
could be a first step towards                 management and supervisory
sophisticated data collection.                board as sustainability topics are                                             28 %
One such example can be found                 now of high interest for the top
in the Netherlands, where real                management. For some institutions
estate data is made publicly available        these reporting efforts are handed      16 %
with detailed information that                to the operational departments
can be used to assess ESG-ratings             where dedicated targets are
properly.                                     tracked and managed. In these
                                              organisations, the expectations
For the purposes of internal                  of regulators and supervisors                                    39 %
reporting, institutions are expected          are prevalent throughout the
to report aggregated risk data.               entire organisation, reflecting
                                                                                       No       Yes, as a separate individual report
In principle, the same approach               the institution’s high CR-E risk         Yes, as a part of the annual financial statements
can be applied for proper reporting           maturity level.                          Y
                                                                                        es, both
of CR-E risks, offering regulators
and public stakeholders alike CR-E            Institutions are also expected to      Transparency of market
risk data through established                 publish meaningful information         participants will foster a proper
reporting channels.                           and key metrics on climate-            management of climate-related
                                              related and environmental risks.       and environmental risks. Further-
Figure 13 | Do you already have an internal
                                              The requirements with regards          more, it will help consumers as
reporting in place for CR-E risks?            to disclosure and transparency of      well as relevant stakeholders and
                                              financial market participants have     shareholders to simultaneously
                                              already begun to increase, and         comprehend the efforts taken by
                                              the speed of this development is       the institution in the direction of a
                                              expected to pick up rapidly starting   better climate-adjusted portfolio
                                              from 2022 onwards.                     and business model.
                                     33 %
                                              Slightly more than one fourth
                                              of respondents do not have a
                                              sustainability report yet. But 72%
                                              already have an individual report or
     67 %                                     a dedicated section in the annual
                                              financial statement.

  No     Yes

                                                                                                                                      13
G R E AT E X P EC TAT I O N S : C L I M AT E - R E L AT E D A N D E N V I R O N M E N TA L R I S K S

SUMMARY AND DISCUSSION

The study was conducted to                             A fit for purpose set up of                       Another difficulty stressed by the
provide a DACH plus NL wide                            governance and risk management                    participants is the consideration
snapshot of financial institutions                     structures is crucial to successfully             of CR-E risks in risk categories
with respect to CR-E risk. The                         reflect any adaptations. Half of                  and their inclusion into stress
focus was on current strategies,                       the respondents already have                      scenarios. These issues can be
approaches to governance and risk                      governance and management                         exacerbated by a lack of data
management, as well as data and                        measures designed to manage CR-E                  availability and quality. More than
reporting maturity levels. Most                        risks, although not necessarily in                75% of participants have started to
respondents reported that their                        dedicated committees or panels.                   build a dedicated data pool, either
firms’ business models are at least                    Nonetheless, the respondents                      by leveraging internal resources
moderately affected by these                           have set in place KPIs and KRIs to                or by buying data from external
risks, with the majority having                        disclose and manage these risks.                  vendors. Good data availability and
adapted their firms’ strategies                        Institutions recognise that internal              quality are central for the creation
accordingly. Respondents confirm                       sustainability measures are an                    of management metrics and the
a growing awareness of CR-E                            important signal to other market                  enhancement of internal and
risks and the related potential                        participants.                                     external reporting capabilities.
pitfalls and opportunities
presented by an adapted business
strategy. Additionally, banks
are conscious about increasing
regulatory requirements.

     The following recommendations are drawn from the findings:
     Strategy:                                         Governance & risk:                              Data & reporting:
     •	Use the current situation to                   •	Develop a risk culture that                  •	Capitalise on the existing
        generate positive social and                      reflects sustainability and                     internal data aggregation
        economic impact                                   leverage it as a positive signal to             practices to optimize the
                                                          the market and with your staff                  data repository
     •	Implement internal changes that
        enhance the credibility and the                •	Incorporate CR-E risks within                •	Leverage the maturity of the
        trustworthiness on your brand                     other risk categories to leverage               internal reports to establish or
                                                          existing processes                              enhance external reporting
     •	Establish yourself as an
        innovator in the market by                     •	Prepare for regulatory
        driving sustainability projects                   challenges proactively by
        (e.g. Target Operating Model)                     incorporating CR-E risks into
        early                                             stress scenarios

Unsurprisingly, the financial services sector has begun to adapt to the challenges that come with CR-E risks. Still,
there is a lot of ground to cover. Top-down governance mechanisms, including stringent reporting lines need to be
enriched with CR-E risk awareness to manage and steer in a sophisticated way. Data is an enabling factor and must
therefore be collected in a plausible and reliable way. A lot of this data (e.g. in KYC-related data pools) lies already
within the institutions, as stated by some participants, and could be reused to establish a proper database for CR-E
risks. Furthermore, adjusting the current methods to integrate CR-E risks in the overall landscape properly should
be included in every upcoming change project if not yet happened. Future target operating models of the financial
services sector will have to acknowledge CR-E risks in every part of the organisation.

14
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F O R M O R E I N F O R M AT I O N ,
P L E A S E C O N TA C T:

Author                      APAC                                  North America

Marco Meyer                 Samuel Levy-Basse                     Jennifer Lindstrom
marco.meyer@capgemini.com   samuel.levy-basse@capgemini.com       jennifer.lindstrom@capgemini.com

                            Belgium                               Norway

                            Ilda Dajci                            Liv Fiksdahl
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                            DACH                                  Spain

                            Joachim von Puttkamer                 Carmen Castellvi
                            joachim.von.puttkamer@capgemini.com   carmen.castellvi@capgemini.com

                            France                                Sweden & Finland

                            Julien Assouline                      Johan Bergström
                            julien.assouline@capgemini.com        johan.bergstrom@capgemini.com

                            India                                 UK

                            Lalit Desiraju                        Nathan Summers
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                            Netherlands

                            Alexander Eerdmans
                            alexander.eerdmans@capgemini.com

16
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