Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub

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Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
Embarking on
the TCFD journey
A briefing guide
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
Introduction & contents

Embarking on the TCFD journey                    Contents
Luminous has developed this briefing             What is TCFD reporting?                                  2
guide for UK-listed companies starting           When does TCFD reporting become mandatory?               3
out on their TCFD reporting journey.
                                                 What level of detail is initially required to comply?    4
TCFD reporting refers to the set of              What new information, if any, is likely to be required?  6
recommendations published by the
                                                 What information are other companies providing?          8
Task Force on Climate-related Financial
Disclosures in 2017. In November last year,      What does good look like?                                9
the Financial Conduct Authority (FCA)            Summary recommendations                                 12   Harriet Rumball
announced that reporting against the                                                                           Senior Investor
                                                 What are the next steps?                                14   Engagement Consultant
recommendations will become mandatory            Appendix15
in the UK from 2022, with disclosures to                                                                       Luminous
be included in the Annual Report.                                                                              Acknowledgements: Luminous is most grateful to Sarah Abbot
                                                                                                               and Helen Wickham of Berkeley Group plc, Jon Harrington of
While some of the TCFD recommendations                                                                         Britvic plc, Richard Eadie of Severn Trent plc, Hannah Armitage of
                                                                                                               the Financial Reporting Council’s (FRC) Financial Reporting Lab
overlap with existing non-financial                                                                            and Simon Weaver of KPMG for their valuable and generous input
reporting requirements, others do not                                                                          on the research for this paper.
and are likely to require new disclosures.
This guide is designed to help companies
navigate the recommendations, identify
where existing activity and data is
relevant, and pinpoint where new
information is required.
We deliberately refer to this as a journey
because the TCFD recommendations
will apply on a ‘comply or explain’ basis
(at least initially) and they are sufficiently
flexible to allow companies add to and
enhance their disclosures over time.
We hope this guide will provide a helpful
and timely starting point for companies
embarking on this journey.

1
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
What is TCFD reporting?

TCFD stands for the Task Force         The framework consists of 11
on Climate-related Financial           recommendations on climate-related
Disclosures. It was established        financial disclosures structured
in 2015 by the Financial Stability     around four thematic areas:
Board under the leadership of
                                       •   Governance
Mark Carney, then Governor of the
                                       •   Strategy
Bank of England. In the context
                                       •   Risk Management
of corporate reporting, the term
                                       •   Metrics and Targets
refers to a framework published
by the Task Force in 2017 for          The recommendations are designed to
use by companies to provide            be adoptable by all organisations for
information about their climate-       inclusion in companies’ annual financial
related financial risks to investors   filings, i.e. the Annual Report for
and other stakeholders.                UK-listed companies.

2
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
When does TCFD reporting
become mandatory?
UK premium listed companies                Is TCFD reporting relevant to all           An important part of the recovery from
with reporting periods beginning           listed companies?                           Covid will be to stimulate and support
on or after 1 January 2021 are now                                                     investment… To support this, we need
                                           The groundswell of support from
required by the FCA to adopt TCFD                                                      to see a strong focus on public metrics
                                           governments and capital markets
reporting in their Annual Report.                                                      that set out the climate impacts of both
                                           regulators for measures to address
The requirement will be rolled out                                                     investment and corporate activities.”
                                           climate change is now evident globally.
more widely from the following
                                           Without needing to expand on this           Thus, even where climate-related
year onwards.
                                           trend, the recent launch by the Bank        reporting may not feel immediately
Immediately following the FCA’s            of England of climate stress tests for      relevant to all companies, it appears
announcement on mandatory TCFD             commercial lenders from June 2021 is        likely that the provision of capital may
reporting in November 2020, the            relevant here.                              increasingly be linked to compliance
Financial Reporting Council (FRC)                                                      with frameworks such as TCFD.
                                           In his speech at the Green Horizon
also announced its support for
                                           Summit on 9 November 2020,
companies to report against the TCFD
                                           Andrew Bailey, Bank of England
recommendations. For reference,
                                           Governor, commented:
at the same time it announced its
encouragement for companies also           “What we cannot measure we cannot
to report against the Sustainability       manage, so it is important that financial
Accounting Standards Board (SASB)          firms and their clients use the TCFD
metrics, these being metrics designed      framework and the latest tools available
to help companies report financially       to measure, model and disclose the
material sustainability information        climate risks and opportunities they
to investors on a sector-specific basis.   are exposed to today and in different
“We encourage companies to report on       future climate scenarios…
these areas within their next reporting    As we have set out in our supervisory
cycle,” the FRC commented. However,        expectations, firms must assess how
reporting against SASB metrics is not      climate risks could impact their
mandatory for the time being.              business and review whether additional
                                           capital needs to be held against this…

3
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
What level of detail is initially
required to comply?
The FCA has confirmed that reporting
against TCFD recommendations will
                                          “The flexibility the TCFD framework offers
                                          is valuable in allowing each company         “ The flexibility the TCFD framework
initially be introduced on a ‘comply or
explain’ basis. This will be important
                                          to set out its own metrics and targets
                                          and showcase how it approaches risk             offers is valuable in allowing each
in allowing companies to start on the
journey towards TCFD reporting, with
                                          management. A company can also
                                          showcase both risks and opportunities           company to set out its own metrics
further detail provided over time.
To date, TCFD reporting has been
                                          relating to climate change in an
                                          appropriate context. TCFD allows                and targets and showcase how it
presented in the form of an index
table or a narrative, or a combination
                                          companies to set new targets as
                                          the business develops or add new                approaches risk management.”
                                          targets as external situations develop.
of both. While it typically features
                                          COVID-19 is a good example of when
cross-referencing to various sections                                                  Sarah Abbot
                                          businesses may want to bring in
of the Annual Report, the inherent                                                     Financial Reporting Manager
                                          additional targets or amend their
flexibility provided by the TCFD                                                       Berkeley Group plc
                                          existing targets to take account of
framework means that additional
                                          external factors.”
commentary, beyond an index of
disclosures, can – and probably
should – be provided.
The benefit of this flexibility was
clearly explained by Sarah Abbot,
Financial Reporting Manager of FTSE
100 Berkeley Group, which reported
against TCFD for the first time in its
2020 Annual Report:

4
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
What level of detail is initially required to comply?
continued

Alongside Berkeley Group, Luminous
spoke to two of its other clients which
                                          Where Severn Trent has committed
                                          to publishing science-based targets,        “ We include in our Annual Report
have been early adopters of TCFD
reporting, each at sightly different
                                          Britvic has already done so and
                                          described the process as beneficial            and Accounts which Directors
stages in their reporting journey
but sharing a clear commitment to
                                          to the business:
                                          “The climate crisis is the defining issue
                                                                                         possess sustainability – and,
climate-related reporting and the
TCFD framework:
                                          of our time and the greatest challenge
                                          to sustainable development, affecting
                                                                                         in particular, climate change –
Severn Trent commented:                   every country, business and person on
                                          the planet.
                                                                                         experience and expertise.”
“Climate change is a key consideration
in our business planning and we have      “At Britvic, our commitment to
a long history of reducing carbon         achieving our science-based carbon          Richard Eadie
emissions, having held the Carbon         reduction targets has concentrated our      Head of Corporate Strategy, Sustainability and Group Transformation
Trust accreditation for over a decade.    focus and helped us embed climate-          Severn Trent plc
We include in our Annual Report and       related decision-making across our
Accounts which Directors possess          business. Specifically, our approved
sustainability – and, in particular,      science-based targets mean reducing
climate change – experience and           our Scope 1 and 2 emissions by 50%
expertise and last year announced our     and our Scope 3 emissions by 35% by
triple carbon pledge of net zero carbon
emissions, 100% electric vehicles,
                                          2025. We have also pledged to be a
                                          carbon-neutral business by 2050.            “ Our commitment to achieving
and 100% of energy from renewable
sources, by 2030.
                                          “Clearly, we are already committed
                                          to working towards incorporating the
                                                                                         our science-based carbon
“Importantly, we also took the
decision to report against the TCFD
                                          TCFD recommendations in full and we
                                          also plan to integrate it in our internal
                                                                                         reduction targets has concentrated
recommendations for the first time.
We published our TCFD disclosures in
                                          decision making processes.”
                                                                                         our focus and helped us embed
our Sustainability Report along with a
commitment to develop science-based
                                                                                         climate-related decision-making
targets and are looking forward to
building on our TCFD reporting going
                                                                                         right across our business.”
forward.”
                                                                                      Sarah Webster
                                                                                      Director of Sustainable Business
                                                                                      Britvic plc
5
Embarking on the TCFD journey - A briefing guide - TCFD Knowledge Hub
What new information,
if any, is likely to be required?
Given existing non-financial
reporting requirements, some
                                      Hannah Armitage, Project Manager
                                      at The Financial Reporting Council’s          “ There is a clear need for
of the TCFD recommendations
are already being met by listed
                                      Financial Reporting Lab, acknowledged
                                      this but highlighted that, as more               standardisation in global
companies, for instance around
greenhouse gas (GHG) emissions
                                      companies report on TCFD, the
                                      volume of data available will increase           frameworks but reporting against
under Metrics and Targets. Others
are likely to be underway, for
                                      which should, in turn, open up this
                                      area of data provision:                          frameworks like TCFD and SASB is
instance around Governance,
while others still are likely to
                                      “There is a clear need for
                                      standardisation in global frameworks
                                                                                       an important interim step.”
be achievable (at least in part)      but reporting against frameworks like
within existing structures and        TCFD and SASB is an important interim
processes, for instance around                                                      Hannah Armitage
                                      step. Climate scenarios are complex           Project Manager
Risk Management.                      but as more companies consider these,         The FRC’s Financial Reporting Lab
That said, it is likely that new      and as disclosures are increasingly
information will be required by       standardised, more data will emerge
most companies around scenario        which should help make benchmarking
planning in response to the TCFD      and scenario planning more accessible.”
Strategy recommendations and, given   The FRC’s statement on Non-Financial
its complex and technical nature,     Reporting Frameworks can be found at
some investment in specialist data    www.frc.org.uk/news/november-2020/
modelling is likely to be required.   frc-nfr-statement. In addition, its support
                                      for IFRS Foundation consultation paper
                                      on international sustainability reporting
                                      standards can be found at www.gov.
                                      uk/government/publications/joint-
                                      statement-of-support-for-ifrs-foundation-
                                      consultation-on-sustainability-reporting/
                                      initial-response-to-ifrs-foundation-
                                      trustees-consultation

6
What new information, if any, is likely to be required?
continued

                                             Figure 1. Identifying likely new information requirements versus likely relevant existing corporate disclosures
Based on the TCFD graphic opposite we         Governance                                     Strategy                                            Risk Management                                  Metrics and Targets
have sought to identify where companies
                                              Disclose the organisation’s                    Disclose the actual and potential impacts of        Disclose how the organisation identifies,        Disclose the metrics and targets used
reporting for the first time are likely to    governance around climate–                     climate–related risks and opportunities on          assesses and manages climate-related risks.      to assess and manage relevant climate-
require new information in order to           related risks and opportunities.               the organisation’s businesses strategy, and                                                          related risks and opportunities where such
comply, as opposed to referencing                                                            financial planning where such information                                                            information is material.
                                                                                             is material.
relevant existing disclosures:
                                              Recommended disclosures
                                              a) D escribe the Board’s oversight of       a) D
                                                                                               escribe the climate-related risks                a) Describe the organisation’s processes        a) Disclose the metrics used by the
                                                  climate-related risks and opportunities.    and opportunities the organisation                     for identifying and assessing climate-           organisation to assess climate-related
                                              b) Describe management’s role in assessing     has identified over the short, medium                  related risks.                                   risks and opportunities in line with
                                                  and managing climate-related risks and      and long term.                                     b) Describe the organisation’s processes            strategy and risk management processes.
                                                opportunities.                               b) D
                                                                                                 escribe the impact of climate-                     for managing climate-related risks.          b) D isclose Scope 1, Scope 2 and, if
                                                                                                related risks and opportunities on               c) Describe how processes for identifying,          appropriate, Scope 3 GHG emissions,
                                                                                                the organisation’s businesses, strategy              assessing, and managing climate-related          and the related risks.
                                                                                                and financial planning.                              risks are integrated into the organisation’s c) Describe the targets used by the
                                                                                             c) D
                                                                                                 escribe the resilience of the organisation’s       overall risk management.                         organisation to manage climate-related
                                                                                                strategy, taking into consideration different                                                         risks and opportunities and performance
                                                                                                climate-related scenarios, including a 2°C                                                            against targets.
                                                                                                or lower scenario.

                                              Luminous commentary on new and/or existing information required
                                              a) and b)                                      a) F
                                                                                                 or many companies, shorter-term                a), b) and c)                                    a) If climate is already included as a principal
                                              Mechanisms and processes at both Board            key risks and opportunities related to           It is likely that the mechanisms and                 risk or is included in a company’s emerging
                                              and executive management levels are               climate change will probably have been           processes for risk identification,                   risk register (or equivalent), it is likely that
                                              likely already to be in place for ESG/CSR/        identified, if material, but additional data     management and mitigation will serve,                appropriate metrics have already been
                                              sustainability issues. With timely planning,      to assess longer-term implications may           at least initially, to address climate-related       identified/are in use.
                                              these could be extended, as required,             be required. A holding statement on              risk where it is material.                       b) Most companies will already make
                                              to include climate-related issues.                the company’s intentions/plans may                                                                   Scope 1 and 2 disclosures (and Scope 3
                                                                                                therefore be required.                           The TCFD recommendations make a
                                                                                                                                                 distinction in their supporting commentary          where appropriate) as part of their
                                                                                             b) A
                                                                                                 s above, if material, it is probable that      between physical risks (such as flooding)           GHG emissions disclosures and, since
                                                                                                companies can explain how they have              and transitional risks (such as regulatory          April 2019, to meet the Streamlined
                                                                                                responded in terms of strategy and               changes in response to climate change) and          Energy and Carbon Reporting (SECR)
                                                                                                financial planning to shorter-term risks         these should therefore be considered here.          compliance requirements.
                                                                                                and opportunities. A description of how                                                           c) M
                                                                                                                                                                                                      any companies will already have some
                                                                                                they intend to evolve these in the longer                                                            targets in place and may wish to commit
                                                                                                term may also be possible based on                                                                   to identifying more in due course.
                                                                                                existing information.
                                                                                                                                                                                                    Science–based targets, probably
                                                                                             c) H
                                                                                                 owever, an explanation of how
                                                                                                                                                                                                    requiring specialist third–party input,
                                                                                                companies would respond to specific
                                                                                                                                                                                                    have tended to be considered for year
                                                                                                temperature/climate changes is likely
                                                                                                                                                                                                    two of TCFD reporting or thereafter,
                                                                                                to require new information, probably
                                                                                                                                                                                                    as a next step in enhancing reporting.
                                                                                                achieved with the help of a specialist third
                                                                                                party. As above, a holding statement
                                                                                                on the company’s intentions/plans
                                                                                                may therefore be required.

7
What information are
other companies providing?
Set out in the Appendix are some
(but by no means all) of the key
                                             Naturally, companies in sectors such
                                             as financial services, oil and gas, and        Establishing science-based targets is
disclosures made by a selection of
companies to illustrate – at a glance
                                             fashion are likely to have been earlier
                                             adopters of TCFD disclosures and to be         likely to require specialist input.
– the type of content that could be          providing a greater level of detail based on
considered for inclusion in year one.        scenario analysis, financial metrics and,
                                             in some instances, science-based targets.
The intention here is to give a flavour of
the kind of information companies are        For reference, emissions reduction
providing, the level of their ambition in    targets are defined as ‘science-based’
terms of disclosures and how they are        if they are developed in line with the
explaining their position where more         scale of reductions required to meet the
information will be provided over time.      goals of the Paris Agreement or COP 21
                                             (as it was adopted at the 21st Conference
                                             of the Parties (COP 21) which took
                                             place in Paris in 2015) of limiting global
                                             warming to well-below 2°C above pre-
                                             industrial levels, and pursuing efforts to
                                             limit warming to 1.5°C.
                                             Establishing science-based targets is likely
                                             to require specialist input.

8
What does good look like?
                                          Figure 3. HSBC Annual Report 2019
More advanced TCFD reporting                Strategic    report
                                                Annual Report       | How
                                                              and Accounts 2021we do business                                                                                                                                   How we do business                                                                                                  AVEVA Group plc Annual Report and Accounts 2021

from early adopters provides a good                                                                                                                                                                                                              Strategic Report
                                                                                                                                                                                                                                                 – Governance Report
                                                                                                                                                                                                                                                 – Financial Statements
                                                                                                                                                                                                                                                                                                                                                                                                     b
reference point for best practice.                                                                                                                                                                                              Task Force on Climate-related Financial Disclosures (‘TCFD’) continued
                                            TaskChief
                                                 Force  on Climate-related Financial Disclosures (‘TCFD’)

                                                                                                                                                                                                                                                                                                                                                                                                                   Strategic report
                                                      Executive’s Review
An example here is Landsec, which                                                                                                                                                                                               Developing our approach to transition risk                         from over 750 customers within the six higher            are designed to help us identify key areas of
                                            We all have a role to play in limiting climate              climate risk forum and an ESG Steering                 disclosure. We also partnered with climate
includes specific financial disclosures     change and supporting the transition to a                   Committee also provides executive oversight            change experts at MIT to produce exploratory                     We have started to develop and publish new                         risk transition sectors, which represented 34%           vulnerability to climate change, the associated

                                                   Insight into the
                                                                                                        of climate commitments. We have formally
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                                                                                                                                                                                                                                                                                                                                                            activity. We also aim to review our policies
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                                                   Boardroom.
                                            represents our third disclosure under the                   the Senior Managers Regime for the           year? could occur, the resulting investment                                Transition risk faccuptatus
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                                                                                                           For further details on how we incentivise
                                                                                                           senior management and how climate-related eni untur.risk statement in 2020.
                                                                                                           disclosures inform our strategy, see page 15.
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                                                                                                                                                                                                                                                                                 and our
                                                                                                                                                                                                                                                                             omnihil      moluptaerisk transition sectors. We first obtained a
                                                                                                                                                                                                                                                                                                                                                              Memberships
                                            Chief Executive and the Group Chief Financial                                                           Assitatem   faccuswe
                                                                                                                                                             In 2019,    in also
                                                                                                                                                                             pediam    ut pa
                                                                                                                                                                                 trained   over 800 employees
                                                                                                                                                                                                                                exposure to themsa nisarevolorpo
                                                                                                                                                                                                                                                           disclosed      in table
                                                                                                                                                                                                                                                                     rrorem            1.
                                                                                                                                                                                                                                                                                 hicipsandam       client’s total revenue carbon intensity from a             Founding member, the Climate
                                            Officer are required to be members of the                                                               essinti antemquam
                                                                                                                                                             on climate riskremtoutstrengthen
                                                                                                                                                                                    et ut       engagement with
For those starting out, it might be         Board. In 2019, the Group Chief Risk Officer
                                            was also a member of the Board. With effect
                                                                                                        Strategy
                                                                                                        As part of our priority to support the transition
                                                                                                                                                             customers.
                                                                                                                                                    dolupta dolores
                                                                                                                                                             manage
                                                                                                                                                    alique ium
                                                                                                                                                                            For further
                                                                                                                                                                        nonserum     fugia
                                                                                                                                                                        sustainability
                                                                                                                                                                volor reperios
                                                                                                                                                                                          information on how we
                                                                                                                                                                                  iunturrisks,
                                                                                                                                                                                           ad see pages 42 to
                                                                                                                                                                                                                                Figures in this quat
                                                                                                                                                                                                                                                 table occat.
                                                                                                                                                                                                                                                        capture all lending activity
                                                                                                                                                                                                                                to customers within these sectors, including
                                                                                                                                                                                                                                                                                                   third-party provider, CDP. The revenue carbon
                                                                                                                                                                                                                                                                                                   intensity ratio is effectively the carbon that is
                                                                                                                                                                                                                                                                                                                                                              Finance Leadership Initiative

                                                                                                                                                                                                                                those that are Can       you giveresponsible
                                                                                                                                                                                                                                                                          an example of emitted per million dollars of revenue. It was                        Founding member, Chapter Zero:
helpful to look at HSBC (Figure 3.),        from 1 January 2020, this role ceased to be
                                            a Board member but the Group Chief Risk
                                                                                                        to a low-carbon economy, we pledged to que dolum     43 dolla    ESG Update
                                                                                                                                                                 of ourneceria
                                                                                                        provide $100bn of sustainable finance, consenducia is ente parum is
                                                                                                                                                                                        .
                                                                                                                                                                                 tusdaerissin
                                                                                                                                                                                                                                                environmentally
                                                                                                                                                                                                                                                how s.172
                                                                                                                                                                                                                                as well as sustainable
                                                                                                                                                                                                                                This means that helped
                                                                                                                                                                                                                                                           financingconsiderations
                                                                                                                                                                                                                                                              shape a
                                                                                                                                                                                                                                                    green financing
                                                                                                                                                                                                                                                                          activities.
                                                                                                                                                                                                                                                                           forparticular
                                                                                                                                                                                                                                                                                large
                                                                                                                                                                                                                                                                                                   calculated as emissions from both direct and               The Directors’ Climate Forum
                                                                                                        facilitation and investment by 2025. At theniscitatisWe                                                                                                                                    indirect emissions, known as scope 1 and 2
which provides a clear and concise          Officer will still attend Board meetings. In this
                                            role, the Group Chief Risk Officer raises any               end of 2019, we reached $52.4bn of that autatatiis
                                                                                                        goal, of which $43.6bn relates to green or
                                                                                                                                                              nosreport
                                                                                                                                                             operations
                                                                                                                                                                          on the
                                                                                                                                                                    rehenda
                                                                                                                                                                           via
                                                                                                                                                                               nonemissions
                                                                                                                                                                               CDP
                                                                                                                                                               aut que que et eicit
                                                                                                                                                             score   of A-luptaquaepe
                                                                                                                                                                                     nihit
                                                                                                                                                                                      and
                                                                                                                                                                                               of our own
                                                                                                                                                                                           achieved a leadership
                                                                                                                                                                                         rate
                                                                                                                                                                           for our 2019 CDP disclosure.
                                                                                                                                                                                                                                companies that  decision?
                                                                                                                                                                                                                                                   work in higher transition
                                                                                                                                                                                                                                sectors is included.
                                                                                                                                                                                                                                                Metus,  Forcusfurther
                                                                                                                                                                                                                                                                 del il information
                                                                                                                                                                                                                                                                         ma dit, suntbus cum
                                                                                                                                                                                                                                                                                                   emissions, divided by total revenue. We then
                                                                                                                                                                                                                                                                                                   weighted the revenue-carbon intensity ratio by
                                                                                                                                                                                                                                                                                                                                                              Member, the FCA and PRA’s Climate
                                                                                                                                                                                                                                                                                                                                                              Financial Risk Forum (‘CFRF’)
                                            concerns directly by providing verbal or written
two-page summary.                                    During this year, which has
                                            updates on a regular basis to the Board and
                                            Group Management Board.
                                                                                                        sustainable products. In 2019, HSBC was
                                                                                                        named the World’s Best Bank for Sustainable
                                                                                                                                                    occullorro maximil
                                                                                                                                                    con rest ut et, ariae pedicabo. Unt,
                                                                                                                                                             Since the revision of the energy policy, we
                                                                                                                                                    volorep tatur, odi sunt lacearunt.
                                                                                                                                                                                                                                on how we designate
                                                                                                                                                                                                                                                ditatis es
                                                                                                                                                                                                                                ‘higher transition
                                                                                                                                                                                                                                                           counterparties
                                                                                                                                                                                                                                                               estiam verovid
                                                                                                                                                                                                                                                     risk’, see footnote
                                                                                                                                                                                                                                                il earibusam       cor moluptam
                                                                                                                                                                                                                                                                                  as et quidum our exposure
                                                                                                                                                                                                                                                                                2 on fuga.
                                                                                                                                                                                                                                                                                                           nt voloreto that   client,
                                                                                                                                                                                                                                                                                                                        ma quid     etwithin
                                                                                                                                                                                                                                                                                                                                       laccusthe  sector.
                                                                                                                                                                                                                                                                                                                                               apid
                                                                                                                                                                                                                                                                                                           voluptia dolo vit volore optae net, ut
                                                                                                                                                                                                                                                                                                                                                     qui
                                                                                                                                                                                                                                                                                                                                                              Chair, climate risk working group
                                                                                                                                                                                                                                                                                                                                                              A Name
                                                     been significantly shaped by the                   Finance by Euromoney.                                have not agreed any project financing for any                      the previous page.
                                                                                                                                                                                                                                                Ipsusant. Quid mo experum ium                      Next steps                                                 of the CFRF
                                                                                                                                                                                                                                                                                                           apic tem fuga.                                     Chief Executive Officer
                                            The Board and regional executive                                                                        Was reporting
                                                                                                                                                             new coal-firedon power
                                                                                                                                                                               more plants anywhere.                                            aperrum aut que necum initat quis In 2020, we intend to continue to explore
                                                     disruption
                                                            provide oversight caused                    by COVID-19,                                                                                                            In 2019, to better   understand       how our clients                      utem                                                  For further details of our sustainability-
                                            committees                           of our                 We recognise that many customers are difficult decisions arising                                                                        sum    nonsedit quoditas             experum asin  what data    is re mo tempore
                                                                                                                                                                                                                                                                                                                   available            modit,
                                                                                                                                                                                                                                                                                                                                to provide  us ut  hariae
                                                                                                                                                                                                                                                                                                                                                with             related memberships, see www.hsbc.com/
                                                                                                        making shifts towards the low-carbon                    For further details of our sustainability                       are managing nobis
                                                                                                                                                                                                                                                 transition    risk, we had more than greatervollupt        insightatesequid        quisportfolio
                                                                                                                                                                                                                                                                                                                      of our clients’     derciende
                                            strategic commitments and are advised                                                                   from COVID-19            a challenge                                                                 doluptat.                                                                                               our-approach/esg-information/
                                            by ourconsideration
                                                      climate business councils. The of the impact of   economy and that our industry needs to for the Board?   risk policies covering specific sectors, see:                   3,000 engagements with customers through                                   sus. We
                                                                                                                                                                                                                                                                                                   emissions.    Obisalso
                                                                                                                                                                                                                                                                                                                        dolorit
                                                                                                                                                                                                                                                                                                                             aim escit   laborestoantis
                                                                                                                                                                                                                                                                                                                                   to continue     review        sustainability-memberships.
                                                                                                                                                                www.hsbc.com/our-approach/risk-and-                                             Os que
                                                                                                                                                                                                                                meetings or phone          liquis
                                                                                                                                                                                                                                                        calls,      et, cuscipitius
                                                                                                                                                                                                                                                                across     all sectors,ra nem our retail   earunti    nonseon  pori  imo quuntio quas
                                            Risk Management Meeting of the Group                        work together to find new ways to measure                                                                                                                                                             exposures           a geographical    basis
                                                     Board             decisions                   on stakeholders
                                                                                                                                                    Metus, cus responsibility/sustainability-risk.
                                                                                                                                                                 del il ma dit, suntbus
                                                                                                        these activities.                                                                                                       to discuss theirquam     as essi
                                                                                                                                                                                                                                                   approach         que debit,
                                                                                                                                                                                                                                                                 to climate           illabor
                                                                                                                                                                                                                                                                                change.                    acepel
                                                                                                                                                                                                                                                                                                   in respect        tistiorehazard
                                                                                                                                                                                                                                                                                                               of natural      sint isrisk,
                                                                                                                                                                                                                                                                                                                                        dolupitium   aut
                                                                                                                                                                                                                                                                                                                                            for example
                                            Management        Board (‘RMM’)     provides                                                            cum ditatis es estiam verovid et
                                                                                                                                                                          For further details about the sustainability of       We also developed
                                                                                                                                                                                                                                                erchitasa questionnaire
                                                                                                                                                                                                                                                             quid mi, aut to        improve
                                                                                                                                                                                                                                                                                elecust     exped considering
                                                                                                                                                                                                                                                                                                           esequidfloodea risk
                                                                                                                                                                                                                                                                                                                           qui for
                                                                                                                                                                                                                                                                                                                                aci properties
                                                                                                                                                                                                                                                                                                                                     nos dolecullest,
                                                                                                                                                                                                                                                                                                                                                that we
                                                     and        the        long-term                     success               ofDisclosure
                                                                                                                                      the
                                            oversight of climate risk through the                                                                          quidus, cusour     own
                                                                                                                                                                           et ut   operations,
                                                                                                                                                                                 aut  fugia dolumsee www.hsbc.com/
                                                                                                           In 2019, HSBC participated      in the CDP                     our-approach/building-a-sustainable-future/           our understanding      of our customers’
                                                                                                                                                                                                                                                que volorei       uritis a velles climate
                                                                                                                                                                                                                                                                                        aligent quihave provided financing on. These reviews
                                            ‘top and     emerging   risk’ report, which is                                                                 que pa consenimolor         rem vellabo                                                                                                         Ut re pernam cor simporrum et que
                                                                                                           (formerly   the  Carbon              Project)                  sustainable-operations.                               transition strategies.
                                                                                                                                                                                                                                                beat mo  Wedolupta
                                                                                                                                                                                                                                                                received  iumresponses
                                                                                                                                                                                                                                                                                 ati occuptas
                                                     company has come working                               under     group very
                                            reviewed on a monthly basis. A dedicated                                                                       reptaquo      ditas ea  volesedis   aut   eost                                                                                                  acepel tistiore sint is dolupitium aut
                                                                                                                              to develop financial sector                                                                                       rerestium et que laceatem is mos
                                                                                                                                                           aut a nobitaerro eturis dollandae                                                    endis aut incturent volore ma quid                         esequid ea qui aci nos dolecullest,
                                                     close scrutiny.                                                                                       rae voluptae dunt laniae. Luptam,
                                                                                                                                                           sequodis aut ab int, tempore, ut as
                                                                                                                                                                                                                                                 et laccus apid qui voluptia dolo vit                  How relevant was the timing
                                                                                                                                                                                                                                                volore optae net, ut apic tem fuga.            of key    decisions
                                                                                                                                                                                                                                Table 2: Customers’        questionnaire responses and pilot        carbon   intensityin   such a
                                                                                                                                                                                                                                                                                                                        metrics
                                                     The Board strongly welcomed
                                            Table 1: Wholesale loan exposure to transition risk sectors                                                    enimolu ptatiunt et essi nonemolor
                                                                                                                                                           simet et dolor aut etus, et untis                                                    utem re mo tempore modit, ut hariae            rapidly changing commercial
                                                                                                                                                                                                                                                                                               and economic        environment?
                                                     the      opportunity                      the       section              172
                                                                                                    Oil and        Building and                            suntiberum delita  Power     and adi
                                                                                                                                                                                   sedipsant    Metals and                                      vollupt atesequid quis derciende    Oil and   Building    and                                                    Power and        Metals and
                                                                                                                                                                                                                                                sus. Obis dolorit escit labores antis          Metus, cus del il ma
                                                                                                                                                                                                                                                                                        gas construction              dit, suntbusAutomotive
                                                                                                                                                                                                                                                                                                                  Chemicals        cum                             utilities         mining              Total
                                            Transition risk sector                                       gas construction              Chemicals         Automotive               utilities aut re,
                                                                                                                                                           ventemp oreperu ntionsequi                 mining           Total
                                                     statement                  presents                 to     provide
                                                                                                                                                                                                                                                                                               ditatis es estiam verovid et quidum
                                            % of total wholesale loans                              ≤ 3.8%                 ≤ 3.9%           ≤ 3.9%
                                                                                                                                                           si nonseque net raectium ad quae
                                                                                                                                                                 ≤ 3.2%            ≤ 3.2%             ≤ 2.7% ≤ 20.6%            Proportion of earunti
                                                                                                                                                                                                                                                sector fornonse  pori imo quuntio quas
                                                                                                                                                                                                                                                             which                      33%               37%maio offic tecum
                                                                                                                                                                                                                                                                                               il earibusvid               27% eium      39%                              30%               44%           34%
                                                                                                                                                           laborio dolecep raestrum et labo. Ita                                questionnairesacepel
                                                                                                                                                                                                                                                  were tistiore
                                                                                                                                                                                                                                                         completedsint4 is dolupitium aut
                                                     investors                and wider stakeholders
                                            and advances to customers                                                                                                                                                                                                                          harita quis dem. Ipsunt.
Figure 2. Landsec Annual Report 2020        and banks       in 2019  1,2,3                                                                                 quo ea volorum que verest et dolorpo                                                 esequid ea qui aci nos dolecullest,
                                                                                                                                                                                                                                Proportion of questionnaire responses                   84%               51%              85%           64%                              94%               62%           72%
                                                                                                                                                                                                                                                                                               Arumet volenih itaque quossunt
                                                     with
                                            % of total           anloans
                                                          wholesale
                                            and advances to customers
                                                                          insight into≤ 3.9%             the processes     ≤ 3.8%           ≤ 3.9%         Which ≤ 3.4% tough decision
                                                                                                                                                                                    ≤ 3.0% are you
                                                                                                                                                           most proud of making in the
                                                                                                                                                                                                        ≤ 2.8%     ≤ 20.8%      that reported Did
                                                                                                                                                                                                                                                eitheryou
                                                                                                                                                                                                                                                stakeholders
                                                                                                                                                                                                                                policy or a management
                                                                                                                                                                                                                                                             review
                                                                                                                                                                                                                                                        having   a board the impact on
                                                                                                                                                                                                                                                              plan4 of key decisions           modis autem as eostiistia duntum
                                            and banksthein 2018
                                                              Board has in place to capture
                                                                  1,2,3                                                                                    last year and why?                                                                   more closely this year than
                                                                                                                                                                                                                                Sector weight as proportion of high                     18%
                                                                                                                                                                                                                                                                                               quiaeperfere ommodicient. Ximus
                                                                                                                                                                                                                                                                                                          19% sunt que volestibus
                                                                                                                                                                                                                                                                                               veratec tatur,              19%           15%                              15%               13%          100%
                                                                                                                                                           Metus, cus del il ma dit, suntbus                                    transition risk ever?
                                                                                                                                                                                                                                                 sector 4
                                            1 Amountssection             172
                                                          shown in the table        matters,
                                                                              include                        its objectives
                                                                                        green and other sustainable
                                              quantifying our exposure to higher transition risk sectors and the transition risk metrics will evolve over
                                                                                                                                                           cum ditatis
                                                                                                                       finance loans, which support the transition
                                                                                                                                                           quid
                                                                                                                                                                    to the es
                                                                                                                                                              timecomnia
                                                                                                                                                                   as moredus
                                                                                                                                                                              estiam verovid
                                                                                                                                                                           low-carbon
                                                                                                                                                                             datamos
                                                                                                                                                                                        economy.
                                                                                                                                                                                       alicatium
                                                                                                                                                                                  becomes
                                                                                                                                                                                                  etThe methodology for
                                                                                                                                                                                             available and is incorporated in
                                                                                                                                                                                                                                                Metus, cus del il ma dit, suntbus cum
                                                                                                                                                                                                                                Pilot as % of total  sector
                                                                                                                                                                                                                                                ditatis
                                                                                                                                                                                                                                                             4
                                                                                                                                                                                                                                                         es estiam verovid et quidum    38%il
                                                                                                                                                                                                                                                                                               doluptatus eiciist, eum quiant eium
                                                                                                                                                                                                                                                                                               volores tibeat.
                                                                                                                                                                                                                                                                                                          41% Sum re ventur30% rest quis 52%                              42%               46%           41%
                                                     in
                                              our risk     reviewing
                                                         management    systems  and   that
                                                                                      processes.  information                     and       its
                                            2 Counterparties are allocated to the higher transition risk sectors via a two-step approach. Firstly, where
                                                                                                                                                           labo. Neque endae preic torporro
                                                                                                                                                               the main business
                                                                                                                                                                                                                                Proportion of earibusam       co considerations
                                                                                                                                                                                                                                                pilot that report   carbon          helped
                                                                                                                                                                                                                                                                                        49%
                                                                                                                                                                                                                                                                                               sum volumqui dolendam secti verem
                                                                                                                                                                                                                                                                                                          53%              38%
                                                                                                                                                                                                                                                                                               que odis et odi quid et eatempelendi
                                                                                                                                                                                                                                                                                                                                         48%                              38%               30%           44%
                                                                                                                                                                            vendisofnis
                                                                                                                                                                                     a group
                                                                                                                                                                                         et autoflatur,
                                                                                                                                                                                                  connected counterparties
                                              is in aidentification                      of the          outcomes                  ofofthe
                                                                                                                                                           ipsantionse                                                          intensity metricshape    a particular
                                                                                                                                                                                                                                                   through    CDP 4 decision? dolorrum
                                                      higher transition risk sector, all lending to the group  is included irrespective   the sector of each individual obligor within the group. Secondly, where the                           si unti corum dolut quam quid que re           que pelignat.
                                                                                                                                                           odiscias vellesequi imporuptio. Ore
                                              main business of a group of connected counterparties is not in a higher transition risk sector, only lending to individual obligors in the higher transition risk sectors         Weighted averagelabo. carbon    emissions                688               408              517           301                            7,235               787
                                                     key
                                              is included.
                                                               decisions                  it  makes.
                                            3 Total wholesale loans and advances to customers and banks amount to $680bn (2018: $668bn).
                                                                                                                                                           si doluptas con reici con explicto
                                                                                                                                                           rem deni te porepudamus aliatur ma
                                                                                                                                                                                                                                                       Itatur aut  as sit autatis molorem
                                                                                                                                                                                                                                per million dollars of revenue (total
                                                                                                                                                                                                                                                recatiis vitem inume eaquiatat vid
                                                                                                                                                                                                                                client emissions/revenue weighted
                                                                                                                                                                                                                                                                                               Antia corepudae volorum aspis
                                                                                                                                                                                                                                                                                               expliquam de dit laut que se inus
                                                                                                                                                          sequia nam nobitiur asi tempores                                      by exposure)    maio
                                                                                                                                                                                                                                              4,5      offic tecum   eium   harita  quis       qui  nihiciatest, quat. Im  derem. Sit                              Read more, see our XXXX section
                                                                                                                                                                                                                                                                                                                                                                   on pages XX-XX
                                                                                                                                                          rem. Ut verferunt que volluptatis mil                                                 dem. Ipsunt.                                   volorios amenis con nobitate lat.
                                                                                                                                                          il ipsamus ni ducimol uptate molupta                                  4 All percentages are weighted by exposure.
                                                                                                                                                                                                                                5 Customer responses to CDP have been used to formulate the carbon intensity metrics in table 2. If a client does not complete the CDP questionnaire, information
                                                                                                                                                                                                                                  is not included in the metrics. The CDP questionnaire is voluntarily completed by clients between April and July of a given year and may not all be from a single
                                                                                                                                                                                                                                  point in time. Figures obtained from CDP have not been separately validated. The carbon intensity ratio is calculated by CDP using both reported figures and
                                                                                                                                                                                                                                  estimated data. Carbon emissions are measured in tonnes of carbon dioxide equivalent (tCO2e) and revenue is measured in millions of US dollars.

                                            22        HSBC Holdings plc Annual Report and Accounts 2019                                                                                                                                                                                                                          HSBC Holdings plc Annual Report and Accounts 2019                            23

9
What does good look like?
continued

                                                                                                                                                                                                                  Figure 4. Berkeley Group Annual Report 2020
A more pragmatic approach          forstrategic
                           Our group      those planning team is responsible for using data from                                Metrics and targets                                                                     Annual Report and Accounts 2021

making disclosures for the     first     time
                           the BP Energy Outlook and implementing the insights in our strategic
                           frameworks, including our net zero ambition and mid-term RIC targets.
                                                                                                                                Recommendation: Disclose the metrics and targets used to assess
                                                                                                                                and manage relevant climate-related risks and opportunities where
could be informed by companies               such
                           We recognize that climate-related risks are an important consideration
                           in developing our strategy. Climate-related risks are incorporated into
                                                                                                                                such information is material.                                                              Task Force on Climate-related Financial Disclosures
                                                                                                                                We present the principal group-wide metrics and targets used to assess
as Berkeley Group, whichBP’s provides           a see How we manage risk on page 69.
                                governance process,
                                                                                                                                and manage climate-related risks and opportunities on page 17. This
                                                                                                                                                                                                                        Chief Executive’s Review
concise one-page summary         and
                           Risk management
                                           signals
                           Recommendation: Disclose how the organization identifies,
                                                                                                                                includes the targets we set out in 2018 in our RIC framework.

                                                                                                                                                                                                                        Insight into the
                                                                                                                                In addition, in 2019 BP announced that sustainable GHG emissions                           Berkeley welcomes the recommendations of the Financial Stability Board’s (FSB) HaveTask Force
                                                                                                                                                                                                                                                                                                                     youon   Climate-related
                                                                                                                                                                                                                                                                                                                           found   reporting Financial
                                                                                                                                                                                                                                                                                                                                                on
further disclosures to follow      over time,
                           assesses and manages climate-related risks.
                                                                                                                                reductions would be included as a factor in the reward of around
                                                                                                                                                                                                                           Disclosures (TCFD). Berkeley reports on climate-related governance, strategy, risk management, and metrics and targets in
                                                                                                                                                                                                                                                                                                             section 172 duties a useful
                                                                                                                                                                                                                           a stand-alone report as found on our website (www.berkeleygroup.co.uk/about-us/sustainability/reports-and-case-studies)
                                                                                                                                                                                                                                                                                                             process in its own right this
                           Our processes for identifying and managing climate-related risks are                                 37,000 eligible employees across the group and around the world,
right (Figure 4.)                                                                                                                                                                                                          and within our annual response to CDP’s Climate Change Programme. Both climate change mitigation and adaptation are

                                                                                                                                                                                                                        Boardroom.
                           integrated into BP’s risk management policy and the associated risk                                  including executive directors. This target was 10% of the group’s annual                                                                                                     year?
                                                                                                                                                                                                                           key areas of focus for Berkeley, featuring prominently within the Our Vision business strategy.
                                                                                                                                                                                                                                                                                                                    Faceptatur? Metus, cus del il ma dit,
                                          management procedures. BP’s risk management system is designed                        cash bonus scorecard and we exceeded the target set of 1.0Mte                                                                                                           suntthrough
                                                                                                                                                                                                                                                                                                             que idem
                                                                                                                                                                                                                           Berkeley continues to take actions to further implement the TCFD recommendations          theexerit fugit of
                                                                                                                                                                                                                                                                                                                         evolution   rerferiatur
                                                                                                                                                                                                                                                                                                                                        our
The index of disclosures provided         to address all types of risks and as part of this system our operating                (1.4Mte). In 2020 we plan to increase the percentage of remuneration                                                                                                    assincilBerkeley
                                                                                                                                                                                                                                                                                                                 idus sum sim   faccumet   aut

                                                                                                                                                                                                                        An introduction
                                                                                                                                                                                                                           processes and reporting mechanisms. The table below summarises the key areas where            has already   made
                                          businesses are responsible for identifying and managing their risks.                  which is linked to emissions reductions for our leadership and eligible                    progress and where we have reported on these.                                que volor aut qui nonsed utempor
by BP (Figure 5., below) is another       Risks which may be identified include potential effects on operations                 employees. Our aim is to mobilize our workforce to become advocates
                                                                                                                                                                                                                           Governance
                                                                                                                                                                                                                                                                                                                    samet etur aut omnimenem rerum et
                                                                                                                                                                                                                                                                                                                eumrisks
                                                                                                                                                                                                                                                          The Board has ultimate responsibility for climate-related  quisciis
                                                                                                                                                                                                                                                                                                                          and destiae  molupti oribus
                                                                                                                                                                                                                                                                                                                              opportunities.

                                                                                                                                                                                                                        to our section 172
                                          at asset level, performance at business level and developments at                     for our net zero ambition.
example of clear communication            regional level from extreme weather or the transition to a lower
                                                                                                                                    For information on our 2020 remuneration policy, see page 110.
                                                                                                                                                                                                                           Disclose the
                                                                                                                                                                                                                           organisation’s governance
                                                                                                                                                                                                                                                          A nominated Executive Director, Karl Whiteman, has direct
                                                                                                                                                                                                                                                          and wider sustainability topics.
                                                                                                                                                                                                                                                                                                                et qui responsibility for climate
                                                                                                                                                                                                                                                                                                                       nobis iur? Quibusam    conechange
                                                                                                                                                                                                                                                                                                                prem utemquaepe velest odit, se
                                                                                                                                                                                                                                                                                                                                                   pra
                                          carbon economy.
which supports more detailed                                                                                                                                                                                               around climate-related                                                               lanis rero es dolut   erro odicitthere
                                                                                                                                                                                                                                                                                                                                                  volupta

                                                                                                                                                                                                                        statement
                                                                                                                                                                                                                                                          To ensure climate-related actions are incorporated into  Berkeley’s  daily activities,
                                                                                                                                                                                                                           risks and opportunities.       is a Group Sustainability Team focused on identifyingilluptatem    ra coreped
                                                                                                                                                                                                                                                                                                                 strategic risks          ut fugitatis
                                                                                                                                                                                                                                                                                                                                 and opportunities,
                             As part of our annual planning process we review the group’s principal
narrative disclosures againstrisks the    four Climate change and the transition to a lower
                                   and uncertainties.
                             carbon economy has been identified as a principal risk, see page 69.
                                                                                                                                                                                                                                                          place within Berkeley’s operating companies to support
                                                                                                                                                                                                                                                                                                                mod que deliqui
                                                                                                                                                                                                                                                          performance monitoring and reporting. Dedicated sustainability           invenienimin
                                                                                                                                                                                                                                                                                                                              practitioners
                                                                                                                                                                                                                                                                                                                    local management
                                                                                                                                                                                                                                                                                                                rehendic
                                                                                                                                                                                                                                                                                                                                                   conse
                                                                                                                                                                                                                                                                                                                                            are also
                                                                                                                                                                                                                                                                                                                                          and project
                                                                                                                                                                                                                                                                                                                           tem inciderferum
                                                                                                                                                                                                                                                                                                                                                      in
                                                                                                                                                                                                                                                                                                                                               dest que
                                                                                                                                                                                                                                                          teams in meeting their responsibilities to implement Berkeley’s
                                                                                                                                                                                                                                                                                                                eni untur. Our Vision strategy, identify
main areas of the recommendations.
                             This covers various aspects of how risks associated with the energy                                                                                                                                                          climate change risks and opportunities facing their business and to drive continual
                                                                                                                                                                                                                                                          improvement in performance.                           Assitatem faccus in pediam ut pa
                             transition could manifest. Similarly, physical climate-related risks such
For reference, this sits within     a larger
                             as extreme   weather are covered in our principal risks related to safety                                                                                                                                                        Read more on pages 76 to 77 and 90.
                                                                                                                                                                                                                                                                                                                    essinti antemquam rem ut et ut
                                                                                                                                                                                                                                                                                                                    dolupta dolores nonserum fugia
                             and operations.
narrative set of TCFD disclosures:                                                                                                                                                                                         Strategy
                                                                                                                                                                                                                           Disclose the actual
                                                                                                                                                                                                                                                                                                               alique
                                                                                                                                                                                                                                                          Climate change mitigation and adaptation are key areas       ium volor
                                                                                                                                                                                                                                                                                                                   of focus      reperios featuring
                                                                                                                                                                                                                                                                                                                            for Berkeley,  iuntur ad
                                                                                                                                                                                                                                                          prominently within the Our Vision business strategy. que dolum dolla neceria tusdaerissin
                                                                                                                                                                                                                           and potential impacts                                                                    consenducia is ente parum is
                                                                                                                                                                                                                                                          A detailed climate change adaptation risk identification exercise was undertaken in 2014 to
                                                                                                                                                                                                                           of climate-related risks                                                             niscitatis nos rehenda non nihit
                                          Figure 5. BP Annual Report 2019                                                                                                                                                  and opportunities
                                                                                                                                                                                                                                                          inform strategic commitments as part of Our Vision, facilitated by specialist consultants and
                                                                                                                                                                                                                                                                                                                autatatiis aut que que et eicit rate
                                                                                                                                                                                                                                                          involving key representatives from across the business. The key risks identified for the homes
                                                                                                                                                                                                                           on the organisation’s                                                                occullorro
                                                                                                                                                                                                                                                                                                                     water maximil
                                                                                                                                                                                                                                                                                                                            shortage.luptaquaepe
                                                                                                                                                                                                                        During this year, which has
                                                                                                                                                                                                                                                          and places we develop include flooding, overheating and                      These have
                                               TCFD index table                                                                                                                                                            businesses, strategy,          remained the key risks and areas of focus in terms of con rest ut et,
                                                                                                                                                                                                                                                                                                                the product   weariae
                                                                                                                                                                                                                                                                                                                                 buildpedicabo.
                                                                                                                                                                                                                                                                                                                                        since theUnt,
                                                                                                                                                                                                                                                                                                                                                 risk
                                                                                                                                                                                                                           and financial planning                                                               volorep tatur, odi sunt lacearunt.
                                                                                                                                                                                                                        been significantly                       shaped by the
                                                                                                                                                                                                                                                          assessment was first undertaken.
                                               TCFD recommended disclosure                                                                                                                     Where reported              where such information
                                                                                                                                                                                                                           is material.               In addition to recognising the importance of adaptingWas           reporting
                                                                                                                                                                                                                                                                                                                  our homes              on more
                                                                                                                                                                                                                                                                                                                                and places     to be resilient
                                               Governance
                                               Disclose the organization’s
                                                                                   a. Describe the board’s oversight of climate-related
                                                                                      risks and opportunities.
                                                                                                                                                                                                     Page 42.
                                                                                                                                                                                                                        disruption caused                        by COVID-19,
                                                                                                                                                                                                                                                      to future climate change risks, Berkeley is focused ondifficult
                                                                                                                                                                                                                                                                                                                 taking action
                                                                                                                                                                                                                                                      resulting from our direct activities and those resultingfrom
                                                                                                                                                                                                                                                                                                                              decisions
                                                                                                                                                                                                                                                                                                                         COVID-19
                                                                                                                                                                                                                                                                                                                  from the
                                                                                                                                                                                                                                                                                                                                  to reducearising
                                                                                                                                                                                                                                                                                                                             use of the a homes
                                                                                                                                                                                                                                                                                                                                                the emissions
                                                                                                                                                                                                                                                                                                                                             challenge
                                                                                                                                                                                                                                                                                                                                                     and
                                               governance around climate-          b. Describe the management’s role in assessing and                                                                Page 42.           consideration homes            of the           impact of
                                                                                                                                                                                                                                                      developments we create as evidenced by our carbon for
                                                                                                                                                                                                                                                              commitments.
                                                                                                                                                                                                                                                                                                                      the
                                                                                                                                                                                                                                                                                                                 positive   Board?
                                                                                                                                                                                                                                                                                                                           and   net zero carbon

                                                                                                                                                                                                                        Board decisions                     onwillstakeholders
                                               related issues and opportunities.      managing climate related risks and opportunities.                                                                                                                                                                         Metus, cus del il ma dit, suntbus
                                                                                                                                                                                                                                                      Berkeley                                                  cum ditatis
                                                                                                                                                                                                                                                                      be undertaking more detailed climate-related             es estiam
                                                                                                                                                                                                                                                                                                                        scenario   analysisverovid
                                                                                                                                                                                                                                                                                                                                              to evolveet our

                                                                                                                                                                                                                        and the long-term                          success of the
                                               Strategy                            a. Describe the climate-related risks and opportunities       Achieving the Paris goals, page 13 – for a discussion of the                                         understanding of climate-related risks and opportunities. quidus, cus et ut aut fugia dolum
                                               Disclose the actual and potential      the organization has identified over the short,                      different pathways and time horizons considered                                                 Read more on pages 16 to 17 and 30 to 45.            que pa consenimolor rem vellabo
                                               impacts of climate-related risks
                                               and opportunities on the
                                                                                      medium, and long term.                                      RIC framework, page 41 – for an outline of opportunities.
                                                                                                                                                   Risk factors, pages 70-71 – description of principal risks.
                                                                                                                                                                                                                        company
                                                                                                                                                                                                                          Risk Management
                                                                                                                                                                                                                                               has come               under very
                                                                                                                                                                                                                                                      Climate change is considered a principal risk to Berkeley.
                                                                                                                                                                                                                                                                                                                reptaquo ditas ea volesedis aut eost
                                                                                                                                                                                                                                                                                                                aut a   nobitaerro
                                                                                                                                                                                                                                                                                                                      The             eturis dollandae
                                                                                                                                                                                                                                                                                                                           Group Sustainability       Team
                                               organization’s business, strategy
                                               and financial planning where
                                                                                   b. Describe the impact of climate-related risks and              Risk factors, pages 70-71 – description of principal risks.         close        scrutiny.
                                                                                                                                                                                                                          Disclose how   the
                                                                                                                                                                                                                          organisation identifies,
                                                                                                                                                                                                                                                      identifies  strategic climate change   risks and
                                                                                                                                                                                                                                                      regular review of issues and trends. Active collaboration
                                                                                                                                                                                                                                                                                                                rae voluptae
                                                                                                                                                                                                                                                                                                       opportunities
                                                                                                                                                                                                                                                                                                                sequodis
                                                                                                                                                                                                                                                                                                                                 dunt laniae.
                                                                                                                                                                                                                                                                                                                       facing Berkeley
                                                                                                                                                                                                                                                                                                                            aut ab int,
                                                                                                                                                                                                                                                                                                                     with external
                                                                                                                                                                                                                                                                                                                                                 Luptam,
                                                                                                                                                                                                                                                                                                                                           through
                                                                                                                                                                                                                                                                                                                                          tempore,
                                                                                                                                                                                                                                                                                                                                      experts,
                                                                                                                                                                                                                                                                                                                                                       the
                                                                                                                                                                                                                                                                                                                                                 and ut as
                                                                                      opportunities on the organization’s businesses,
                                                                                                                                                                                                                        The     Board      risks.strongly          welcomed                                     enimolu    ptatiunt   et essi nonemolor
                                               such information is material.                                                                                                                                              assesses and manages        representation at conferences and events help to ensure        up-to-date     knowledge.     Identified
                                                                                      strategy, and financial planning.                                                                                                                               risks and opportunities    are shared with the Board andsimet
                                                                                                                                                                                                                                                                                                                  included   within
                                                                                                                                                                                                                          climate-related                                                                               et dolor  autthe   strategic
                                                                                                                                                                                                                                                                                                                                       etus,   et untisrisk

                                                                                                                                                                                                                        the opportunity the                        section          172
                                                                                   c. Describe the resilience of the organization’s strategy,                             Achieving the Paris goals, page 13.                                         register reviewed by the Audit Committee.                 suntiberum delita sedipsant adi
                                                                                      taking into consideration different climate-related                                             Our strategy, page 16.                                               Read more on pages 66 to 79.                         ventemp     oreperu    ntionsequi     aut re,
                                                                                      scenarios, including a 2°C or lower scenario.
                                                                                                                                                                                                                        statement
                                                                                                                                                                                                                          Metrics and Targets
                                                                                                                                                                                                                                                presents
                                                                                                                                                                                                                                                      Berkeley
                                                                                                                                                                                                                                                                   to
                                                                                                                                                                                                                                                                 reports
                                                                                                                                                                                                                                                                         provide
                                                                                                                                                                                                                                                                          on greenhouse   gas   (GHG)  emissions
                                                                                                                                                                                                                                                                                                                si nonseque net raectium ad quae
                                                                                                                                                                                                                                                                                                                laborio
                                                                                                                                                                                                                                                                                                                  for     dolecep
                                                                                                                                                                                                                                                                                                                      which   we  areraestrum
                                                                                                                                                                                                                                                                                                                                       responsibleet labo.  Ita
                                                                                                                                                                                                                                                                                                                                                        on an
                                               Risk management
                                               Disclose how the organization
                                                                                   a. Describe the organization’s processes for identifying
                                                                                      and assessing climate-related risks.
                                                                                                                                                                               Risk management, page 44.
                                                                                                                                                                                      Upstream, page 50.                investors            and wider
                                                                                                                                                                                                                          Disclose the metrics        annual basis. stakeholders                                quo eachange,
                                                                                                                                                                                                                                                                      To minimise Berkeley’s contribution to climate      volorumwe  que  verest
                                                                                                                                                                                                                                                                                                                                        have
                                                                                                                                                                                                                                                      carbon intensity reduction target under Our Vision that is reviewed every two years to
                                                                                                                                                                                                                                                                                                                                                   et dolorpo
                                                                                                                                                                                                                                                                                                                                               an operational

                                                                                                                                                                                                                        with      an      insightensure intocontinual
                                                                                                                                                                                                                                                                   theimprovement.
                                                                                                                                                                                                                                                                           processes
                                                                                                                                                                                                                          and targets used
                                               identifies, assesses and                                                                                                             Downstream, page 56.                  to assess  and manage
                                                                                                                                                                                                                                                                                                                Whichtotough
                                                                                                                                                                                                                                                                                         Berkeley has also committed         procuringdecision       are you
                                                                                                                                                                                                                                                                                                                                          100% renewable
                                               manages climate-related risks.                                                                                     Other businesses and corporate, page 63.                                                                                                      most proud
                                                                                                                                                                                                                                                      electricity for its UK operations and offsetting our remaining      emissions ofsince
                                                                                                                                                                                                                                                                                                                                        making        in the
                                                                                                                                                                                                                                                                                                                                               2017/18.
                                                                                                                                                                                                                        the    Board
                                                                                                                                                                                                                                  risks and has in         place          to    capture
                                                                                                                                                                                                                          relevant climate
                                                                                                                                                                                                                          related                     Berkeley   has broader   targets for the homes and places lastwe year    and
                                                                                                                                                                                                                                                                                                                        develop,       why? the provision
                                                                                                                                                                                                                                                                                                                                   including
                                                                                   b. Describe the organization’s processes for managing                                         Risk management, page 44.
                                                                                                                                                                                                                                                      of energy efficient lighting and appliances, as well as Metus,
                                                                                                                                                                                                                                                                                                                enabling  cus del il to
                                                                                                                                                                                                                                                                                                                            homes     maoperate
                                                                                                                                                                                                                                                                                                                                          dit, suntbus
                                                                                                                                                                                                                                                                                                                                                    at net zero
                                                                                                                                                                                                                        section          172 matters,                 its objectives
                                                                                                                                                                                                                          opportunities where
                                                                                      climate-related risks.
                                                                                                                                                                                                                          such information            carbon by 2030.                                           cum ditatis es estiam verovid et
                                                                                   c. Describe how processes for identifying, assessing,                                      Risk management, page 44.                                               We are currently working with an external consultant quid        comnialonger-term
                                                                                                                                                                                                                                                                                                                                dus mos alicatium
                                                                                                                                                                                                                        in reviewing that                   information                 and its
                                                                                                                                                                                                                          is material.                                                                           to develop                     science-based
                                                                                      and managing climate-related risks are integrated                                  How we manage risk, pages 68-69.                                             targets  for our activities                               labo. Neque endae preic torporro

                                                                                                                                                                                                                        identification of the                      outcomes               ofandthe
                                                                                      into the organization’s overall risk management.                                          Risk factors, pages 70-71.                                                                                                      ipsantionse vendis nis et aut latur,
                                                                                                                                                                                                                                                           Read more     on pages 46 to 47        138 to 139.
                                                                                                                                                                                                                                                                                                                odiscias vellesequi imporuptio. Ore

                                                                                                                                                                                                                        key     decisions           it  makes.
                                               Metrics and targets                 a. Disclose the metrics used by the organization to                   Relevant group-wide metrics and targets, page 17.                                                                                                      si doluptas con reici con explicto
                                               Disclose the metrics and targets       assess climate-related risks and opportunities in line                                                                                                                                                                    rem deni    te porepudamus        aliatur  ma
                                                                                                                                                                                                                          Berkeley will continue to work with external experts to develop science-based targets,       climate-related     scenario    analysis
                                               used to assess and manage              with its strategy and risk management process.                                                                                                                                                                      sequia nam
                                                                                                                                                                                                                           and related disclosures in line with the recommendations of the TCFD. We have complied withnobitiur asi tempores
                                                                                                                                                                                                                                                                                                                       the Streamlined   Energy
                                               relevant climate-related risks      b. Disclose Scope 1, Scope 2, and, if appropriate,                                         GHG emissions data, page 40.                                                                                                rem.Report
                                                                                                                                                                                                                           and Carbon Reporting (SECR) framework in our emissions reporting in the Directors’  Ut verferunt que138
                                                                                                                                                                                                                                                                                                                      on pages  volluptatis
                                                                                                                                                                                                                                                                                                                                    to 139. mil
                                               and opportunities where such           Scope 3 GHG emissions, and the related risks.                                                                                                                                                                                 il ipsamus ni ducimol uptate molupta
                                               information is material.                                                                                                                                                    64         Berkeley Group 2020 Annual Report
                                                                                   c. Describe the targets used by the organization to                                             RIC framework, page 41.
                                                                                      manage climate-related risks and opportunities and                    (Also note: Net zero ambition and aims, page 6).
                                                                                      performance against targets.

10                                        44              BP Annual Report and Form 20-F 2019
climate-related issues is Simon Carter,         for analysing:                                 Sustainability Committee, which
                                                                                                                                                                                      Chief Financial Officer. Simon chairs                                                          consists of senior managers from
                                                                                                                                                                                                                                      – Climate-related risks to the Risk
                                                                                                                                                                                      our Risk and Sustainability Committees,                                                        across the business including
                                                                                                                                                                                                                                        Committee, which consists of the
                                                                                                                                                                                      ensuring continuity and accountability.                                                        strategy, asset management,
                                                                                                                                                                                                                                        Executive Committee and leaders
                                                                                                                                                                                      As part of assuming these responsibilities,                                                    and leasing. The delivery of the
                                                                                                                                                                                                                                        from business units, including
                                                                                                                                                                                      Simon took part in The Prince of Wales’s                                                       sustainability programme, including
                                                                                                                                                                                                                                        procurement and property

What does good look like?
                                                                                                                                                                                      Business & Sustainability Programme                                                            our net zero targets, is overseen by
                                                                                                                                                                                                                                        management. Each business unit
                                                                                                                                                                                      at the Cambridge Institute for                                                                 this Committee, which reports to the
                                                                                                                                                                                                                                        maintains a comprehensive risk
                                                                                                                                                                                      Sustainability Leadership.                                                                     Board’s Corporate Social
                                                                                                                                                                                                                                        register, which is reviewed quarterly
                                                                                                                                                                                                                                                                                     Responsibility Committee.
                                                                                                                                                                                      The Board is updated on climate-related           by the Risk Committee. Climate risks
                                                                                                                                                                                      issues at least annually and has                  are identified through a process

continued
                                                                                                                                                                                      ultimate oversight of risk management.            involving trend analysis and
                                                                                                                                                                                      Significant and emerging risks are                stakeholder engagement. Identified
                                                                                                                                                                                      escalated to the Audit Committee and              risks are incorporated into our risk
                                                                                                                                                                                      climate risk is tracked as part of our            framework and managed by the
                                                                                                                                                                                      Catastrophic Business Event risk                  appropriate business areas.
                                                                                                                                                                                      category (see page 84).                         – The TCFD Steering Committee
                                                                                                                                                                                      Our Board CSR Committee meets                     reports to the Risk and Sustainability
                                                                                                                                                                                      three times a year and oversees the               Committees, both of which meet
                                                                                                                                                                                      delivery of the sustainability strategy,          quarterly. Ultimate oversight is at
                                                                                                                                                                                      including the delivery of the Pathway             Board level, with our new Corporate
                                                                                                                                                                                      to net zero and the management                    Social Responsibility Committee
                                                                                                                                                                                      of climate-related risks.                         playing a role from May 2019. Any
                                                                                                                                                                                                                                        resulting disclosure requires approval
                                                                                                                                                                              Figure 7. British Land Annual Report 2020                 by the Audit Committee.

When approaching cross-referencing           • O
                                                rganisational charts
                                                                                                                                                                                                                                                                       Board of Directors
and an index of disclosures, two               A simple but effective organisational
                                                                                                                                                                                                        Board
practical points are worth considering:        chart is provided by Barclays (Figure 6)                                                                                                                                                             Audit Committee
                                                                                                                                                                                                                                                                                   Corporate Social Responsibility (CSR)
                                                                                                                                                                                                                                                                                               Committee
                                               and an alternative is from British Land
First, many larger listed companies will
                                               (Figure 7).                                                                                                                                                                                          Risk Committee                          Sustainability Committee
already provide a response to the CDP’s
annual questionnaire on climate change,      • O
                                                pportunities as well as risks                                                                                  TASK FORCE ON CLIMATE-RELATED     FINANCIAL DISCLOSURES (TCFD)
                                                                                                                                                                                 Executive and Management

                                                                                                                                                                Climate-Related Financial
                                                                                                                                                                                                                                                                  TCFD Steering Committee

forests and water security to provide an       There is a tendency for companies to                                                                                                                                                      Members include representatives from across the business: Asset management,
                                                                                                                                                                                                                                           Development, Finance, Investment, Procurement, Property management,
                                                                                                                                                                                                                                                        Risk management, Strategy and Sustainability
assessment of their environmental impact.      focus primarily or exclusively on risk
This is likely to contain information that     in their TCFD reporting. Care should                                                                             Disclosures
is relevant to TCFD reporting. However,        therefore be taken to ensure that both
                                                                                                                                                           Figure 8. British Land Annual Report 2020                                                                  British Land Annual Report and Accounts 2020         43
rather than simply referencing their           risks and opportunities are considered.
CDP responses, companies should use                                                                                                                             The Board recognises the systemic threat posed by climate change and the need for urgent mitigating action. We have a track record
                                             • A
                                                clear roadmap to full disclosure                                                                               of improving environmental performance, we were one of the first real estate companies to introduce stretching carbon reduction

them as a starting point for their own                                                                                                                          targets that go beyond the demands of the Science Based Targets initiative for Scope 1 and 2 emissions, and we are a founding

                                               The example (Figure 8.) from British                                                                             signatory of the Better Buildings Partnership’s Climate Change Commitment. Since 2009, we have reduced our operational carbon
                                                                                                                                                                intensity by 73%, and we are announcing an ambitious set of climate targets as part of our new pathway to net zero (see page 40).
TCFD disclosures.
                                               Land is a helpful reference point for                                                                            Our roadmap to full disclosure in 2021/22
Second, it is always helpful if the data       those ready to commit to a fuller level                                                                          2019/20                Establish governance                          Scoped potential risks                         Potential risks identified
                                                                                                                                                                                                                                                                                       Roadmap agreed
referred to in the TCFD disclosure is          of disclosures.
                                                         GOVERNANCE                                                                                                                    Board-level oversight                         Two climate workshops, including:
located in the same publication, typically                                                                                                                                             1. Established the CSR Committee              – low carbon transition

                                                        Our governance framework
                                                                                                                                                                                       2. Net zero strategy reviewed at                  risk scenario

the Annual Report, or in full in one                                                                                                                                                      the Board away days
                                                                                                                                                                                       Operational Accountability
                                                                                                                                                                                                                                     – physical risk scenario

location on the corporate website to                                                                                                                                                   1. TCFD Steering Committee
                                                                                                                                                                                          established
avoid a time-consuming search for                                                                                                                               Progress

information and the risk of valuable                   Figure 6. Barclays Annual Report 2020                                                                    – Our newly-formed TCFD Steering Committee undertook two climate risk scenarios workshops, where facilitators from Forum for
                                                                                                                                                                     the Future took the group through the latest climate science and ran breakout sessions on climate risk identification and
                                                                                                                                                                     organisational responses.
data being overlooked.                                                                                                                                          – As part of the new sustainability strategy, we worked with experts to develop our pathway to net zero, including aggressive
                                                                                                                                                                     climate and energy targets. Our updated Sustainability Brief will enable asset-level delivery of this approach.
                                                                                           Barclays PLC Board                                                   – The Board’s strategy away days in 2019/20 included the review and discussion of our new sustainability strategy including the
Specific aspects of others’ reporting may                                                                                                                            pathway to net zero.

also be helpful to consider. These might
include the following:                                                               Group Executive Committee
                                                                                                                                                                2020/21                Establish exposure

                                                                                                                                                                                       Physical:                                     Transitional:
                                                                                                                                                                                       – Audit asset resilience                      – Policy development
                                                                                                                                                                                       – Potential compound impact                   – Supplier resilience
                                                                                                                                                                                       – Identify opportunities                      – Identify opportunities

                                                            Environmental and Social Impact                                Group Risk
                                                              Committee Chair: Group CEO                                   Committee
                                                                                                                                                                2021/22                Organisational response

                                                                                                                                                                                       Portfolio level:                                Adapting corporate strategy
                                                                                                                                                                                       Quantified exposure                                                                              Mitigation targets
                                                                                     Sustainability
                                                           TCFD Forum                                                                                                                  to each risk event                              Adapting financial planning
                                                                                       Forums
                                                                                                                                                                                                                                       Incorporate into enterprise                 Risk management metrics
                                                                                                                                                                                                                                       risk management

                                                                                                                                                                For more information, see our 2020 Sustainability Accounts at www.britishland.com/data
                                                        Board deep dives in 2019                         plausible climate stress. This analysis will
                                                                                                         support the Group’s response to the
                                                        The Board’s agenda in 2019 has been                                                                     42       British Land Annual Report and Accounts 2020
                                                                                                         forthcoming Bank of England industry-wide
                                                        significantly influenced by a comprehensive
                                                                                                         stress test. This progress was welcomed
                                                        ‘listening tour’, undertaken by our new
11                                                      Chairman following his arrival at Barclays in
                                                                                                         whilst acknowledging the need for risk
                                                                                                         management practices generally to evolve
                                                        March, before he became Chairman in May.
                                                                                                         further across the whole industry in respect of
                                                        Nigel Higgins held around 50 meetings with
                                                                                                         climate change risk.
                                                        shareholders and other stakeholders as part of
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