The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...

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The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...
The way ahead
for the UK’s green
mortgage market
The Green Finance Institute looks at the evolution of this
growing market to date and the innovation, policy and
regulatory levers that will ensure it fulfils its promise

                                                     greenfinanceinstitute.co.uk
The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...
Green Mortgages
 Green Finance Institute

                                            number of properties that are already       national policy framework that supports
Introduction                                energy efficient, more mortgage             retrofits at scale and the availability of
                                            products and other loans must target        preferential financing to pay for them.
                                            the retrofit market to fund the                 In this article, the Green Finance
                                            transformation of the UK’s existing         Institute (the Institute) will look at the
                                            housing stock on the scale required.        evolution of the UK’s green mortgage

T   he UK’s nascent green mortgage
    market is showing signs that it is
ready for lift off. Encouraged by the
                                               This lack of demand and supply has
                                            created something of a chicken and
                                                                                        market to date, in both the retrofit and
                                                                                        green build space, explore the market-
                                            egg problem. It’s harder for lenders to     led innovation that is currently
innovation of their peers in this space,    create innovative new products without      underway, and the policy and
eleven banks and building societies in      understanding the potential demand,         regulatory support required to turn the
the UK have launched green mortgage         while more homeowners are unlikely to       residential mortgage funding currently
products since the beginning of 2020        retrofit their homes without a consistent   trickling into this promising market into
alone.                                                                                  a flood. 
   The opportunity for lenders in this
space is huge. The UK Committee on
Climate Change has estimated that
£250 billion needs to be invested in UK
home upgrades by 2050, which means          The evolution of the market
there is the potential for significant
capital flows in green mortgages in the
coming years. Meanwhile, there are
other levers in play, with policy makers,   E   cology Building Society became the
                                                first UK lender to offer green
                                            mortgages back in 2006, when it
                                                                                        example, a 0.25% discount is applied to
                                                                                        Ecology’s standard variable rate for
                                                                                        each Energy Performance Certificate
NGOs      and      financial   regulators
increasingly demanding that lenders         introduced its C-Change discount            (EPC) grade that the property improves.
examine the energy efficiency of their      mortgages. Through this product,            “We’ve been involved in initiatives since
mortgage portfolios.                        Ecology offers discounted mortgage          early 2000s to try to support the green
   Yet significant challenges remain,       rates to homeowners building or             mortgage market,” says Paul Ellis,
including a lack of demand from             converting sustainable homes, or            Ecology’s     CEO.     “Our     C-Change
homeowners to undertake energy              undertaking retrofits and energy            discounts try to drive behavioural
efficient retrofits on anything like the    improvements.                               changes by giving customers a price
scale needed for the UK government to          For sustainable homes and retrofits,     signal that improvements are worth
meet its goal of upgrading all UK homes     the size of the discount that               doing.” In total, Ecology originated £39.3
to an EPC rating of C by 2035. With many    homeowners receive depends on the           million of new green mortgages in 2020
green mortgages focusing on the small       outcome once the project is completed.      and Ellis thinks that number will grow
                                            For retrofit discount mortgages, for        consistently over the next two years.      
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The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...
Green Mortgages
     Green Finance Institute

      For a long time, Ecology was the UK’s      homeowners who made certain energy           introduce green mortgages in 2020, and
    only green mortgage lender, until 2018,       improvements to their homes. The             more government initiatives soon
    when Barclays launched its Green Home         scheme was a breakthrough for the            followed. In November 2020, the UK
    Mortgage, which gave buyers of new            market, as it reassured lenders that the     government          announced           that
    homes with EPC ratings of A or B a            amount of homeowners undertaking             companies would be mandated to
    discounted interest rate on two-year          energy efficient retrofits of their homes    report their climate risks, in line with the
    and five-year fixed rate mortgages. It        would continue to grow, creating, in turn,   Task Force on Climate-related Financial
    became the first high street bank to          increased demand for green mortgages         Disclosures (TCFDs), by 2025.
    launch a green mortgage, and in doing         and other retrofit loans.                        The Bank of England has announced
    so, demonstrated to other major                   The Green Finance Institute launched     that it will begin climate-related stress
    mortgage lenders that structuring and         its Green Home Finance Principles in the     tests on UK banks and insurers in June
    launching a green mortgage was both           same month, supported by a number of         this year and in February 2021, the UK
    possible and also commercially viable.        lenders     and     the    Loan     Market   government’s Department of Business,
       The following year, new government         Association, which provide financial         Energy and Industrial Strategy finished
    policies provided more support to the         institutions with a consistent and           its consultation period on the proposed
    market. In July 2019, the UK government       transparent methodology for allocating       policy that UK lenders disclose the
    launched its Green Home Finance               finance towards retrofitting works in UK     energy efficiency of their mortgage
    Innovation Fund competition, which            homes.                                       portfolios. Since the beginning of 2021,
    awarded grants to three new green                 A combination of these drivers, plus     Paragon Bank, Foundation Home Loans,
    finance projects that incentivised            competition from other lenders, led          Kensington Mortgages, Santander and
    energy efficiency retrofits in homes.         Nationwide Building Society, Newbury         Halifax have all launched their first
       This was followed by the launch of the     Building Society, Just Group, Saffron        green mortgage products. 
    short-lived Green Home Grants Scheme,         Building     Society,    NatWest      and
    in September 2020, providing grants for       Monmouthshire Building Society to

                                                                                               Advisor at Santander. “The EnergyFact
    Today’s green                                                                              report aims to be more inclusive. Many
                                                                                               of our mortgage customers can get a
    mortgage                                                                                   tailored assessment of how to improve

    landscape                                                                                  their home.” Eventually, Santander
                                                                                               would like to use the bank’s scale to
                                                                                               negotiate better energy deals or retrofit

    T   he table below shows the number of
        UK lenders that currently offer green
    mortgages today and the different
                                                                                               prices for its customers.
                                                                                                  All lenders interviewed for this article
                                                                                               agreed         that    financing       the
    types of product that are available.                                                       transformation of the UK’s existing
    These are broadly divided between                                                          housing stock through energy-efficient
    those that offer discount mortgage            what improvements homeowners can             retrofits, rather than rewarding buyers
    rates to customers building or buying         make to reduce their home’s carbon           for purchasing the very small number of
    homes that are highly energy efficient;       footprint, the work needed to achieve        existing homes that are already green,
    and those that offer extra lines of credit,   this, and how they can save money on         is going to be crucial to increase green
    discounted mortgage rates or cash             their energy bills, while making their       mortgage volumes and reduce carbon
    back on existing loans to homeowners          home warmer.                                 emissions in the built environment. Only
    that improve the energy efficiency of            For Santander, this is part of a          3% of UK homes have an EPC rating of A
    their homes.                                  strategy to improve the average EPC          or B, according to the latest quarterly
       A third flavour is Santander’s             rating of its entire mortgage book,          release from the Ministry of Housing,
    EnergyFact home energy reports,               where 55% of its customers live in           Communities and Local Government,
    introduced last month with Countrywide        homes with an EPC rating of D. “The next     while the Climate Change Committee
    Surveying     Services,   available     to    10 years will be critical to decarbonise     has found that 19 million UK
    customers that want to move their             the heating of UK buildings and green        homeowners live in properties with an
    existing Santander mortgage to a new          mortgage propositions that only target       EPC rating below C.
    property or take on additional borrowing      new-build homes with A or B EPC ratings         NatWest, which launched its first
    for home improvements on an existing          are not going to move the needle,” says      green mortgages last October, offering
    mortgage. The EnergyFact reports show         Richard Hirst, Climate Change Strategy
                                                                                                                                              
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The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...
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    Green Finance Institute

   Company                       Product Name                Launch                        Requirements of product                     Eligibility and further information
    Name                                                      Year
                                                                          Discount to     Additional Energy      Property    Cashback
                                                                          existing        borrowing Efficiency   bought
                                                                          mortgage or     for existing of property must be
                                                                          new low-        customers must be      energy
                                                                          interest rate              improved    efficient
                                                                          mortgage

    Ecology Building Society      C-Change Discount           2006                                                                      •   3 types: Energy Improvements Discount, Retrofit Discount, Sustainable Homes Discount.
                                                                                                                                        •   95% of their residential mortgage customers already eligible.
                                                                                                                                        •   Discount applied upon completion of the project.

                                  Energy Improvements         2018;                                                                     •   Often accept projects that standard lenders may not.
                                  Mortgage                    updated                                                                   •   Discounts provided from the date evidence of energy improvement works are completed.
                                                              2021                                                                      •   If eligible, C-Change Discounts (above) can apply.

    Barclays                      Green Home Mortgage         2018                                                                      •   Must be a new-build property (with an EPC A or B) from a select group of house builders.
                                                                                                                                        •   EPC or PEA must be submitted at the stage of application.

    Nationwide Building Society   Green Additional Borrowing March                                                                      •   Only available to existing customers.
                                  mortgage                    2020                                                                      •   At least 50% of borrowing must be spent on energy efficiency improvements.

    Newbury Building Society      GoGreen Further Advance     July                                                                      •   Available to existing borrowers to transfer their existing mortgage onto.
                                                              2020                                                                      •   At least 50% of borrowing must be spent on specific energy efficiency improvements.

    Just Group                    Green Lifetime Mortgage     July 2020                                                                 •   Feature available for the 'Just For You Lifetime Mortgage 2.5 LTV' series.
                                  Feature                                                                                               •   Reduces the standard interest rate by 0.10% for the duration of the loan.
                                                                                                                                        •   EPC must be submitted at the application stage. All customers will receive £50 cashback when the advance
                                                                                                                                            completes to contribute to cost of EPC.

    Saffron Building Society      Retro Fit Mortgage          Sept.                                                                     •   Proof of energy efficiency upgrades (to minimum EPC E) required.
                                                              2020                                                                      •   If proved, customers will be given a discount on their monthly mortgage payments for the remainder of the
                                                                                                                                            two-year deal.

    NatWest Group                 Green Mortgages             Oct.                                                                      •   £250 cashback paid to solicitor on day customer drawdowns mortgage.
                                                              2020                                                                      •   Valid EPC rating of A/B required.

    EeMAP Initiative              Aim to develop an “energy   Ongoing                                                                   •   An EU-wide market-led initiative intended to channel private capital into energy efficiency investments.
                                  efficient mortgage”

    BNP Paribas                   Green Mortgage              Since                                                                     •   Collaborating with E.ON to develop and pilot such a product, under the EeMAP Initiative umbrella.
                                                              2018

    Monmouthshire Building        Green Mortgage – under      Pilot                                                                     •   To pilot product in low-carbon Sero Homes' housing development Parc Eirin, South Wales.
    Society                       the VALUER project          launch
                                                              2020

    Paragon Bank                  Green further advance       February                                                                  •   Four products for portfolio landlords who have applied and been accepted for a Green Homes Grant.
                                  range                       2021                                                                      •   All four products have no application fee, no product fee and include a free valuation.

    Foundation Home Loans         Green Reward Mortgage       February                                                                  •   Available to portfolio and non-portfolio landlords for their properties with an EPC C or above. Designed to
                                                              2021                                                                          reward landlords who have made environmentally-friendly choices.
                                                                                                                                        •   £750 cashback upon completion and a reduced 0.75% product fee.
                                                                                                                                        •   If work has been done, they can re-mortgage immediately rather than wait the usual 6 months.

    Kensington Mortgages          eKo Cashback Mortage        February                                                                  •   Available to all individuals across all properties in the UK.
                                                              2021                                                                      •   Evidenced increase of at least 10 Standard Assessment Procedure (SAP) points required to qualify.
                                                                                                                                        •   Up to 12 months to make the energy improvements and claim cashback reward.
                                                                                                                                        •   £1000 cash paid upon qualification. Also comes with free valuations, and free legal advice on remortgages.

    Halifax                       Green Living Reward         March                                                                     •   £500 cashback when homeowners make one or more eligible home improvements using a TrustMark
                                                              2021                                                                          registered supplier;
                                                                                                                                        •   Customers must have registered for the reward by 31st May 2021.
                                                                                                                                        •   Have created a home Energy Saving Tool for customers to create a personalised action plan for their homes.
                                                                                                                                        •   Existing customers and new customers all eligible.

    Santander                     EnergyFact Report           March                                                                     •   Santander, in partnership with Countrywide Surveying Services, has launched EnergyFact - a free, practical
                                                              2021                                                                          home energy report. The free report provides existing Santander mortgage customers with guidance to
                                                                                                                                            improve the energy efficiency of their home

                                                                                                                                                                                                                                                          
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The way ahead for the UK's green mortgage market - The Green Finance Institute looks at the evolution of this growing market to date and the ...
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    Green Finance Institute

 discounted interest rates and cash back
  to customers purchasing new homes             The current policy and
  with an EPC rating of A and B, plans to
  extend its range over the next couple of
                                                regulatory landscape
  years. “We’re really pleased with the
  uptake in demand from customers
  since the launch and we want to also
  make this product available to
  customers remortgaging their home,”
                                                T   he way to bolster demand and
                                                    capacity in this market is through
                                                consistent,       robust,      long-term
                                                                                            until 2025. Ellis does not consider the
                                                                                            Future Homes Standard to be equivalent
                                                                                            to Zero Carbon Homes and would have
  says Lloyd Cochrane, NatWest’s Director       government policy and regulation,           preferred the former initiative to be
  of Proposition, Home Buying and               which is why many organisations             retained. “We could have been building
  Ownership. “We also want to develop a         viewed the cancellation of the Green        zero carbon homes now and developing
  product so people with existing               Homes Grant Scheme last month as a          the supply chain already, but that was
  mortgages can borrow more to make             step in the wrong direction. Although       abandoned,” he says. “Instead, we’re
  energy-efficient investments in their         there     were    problems     with   the   actually building homes now which we
  home.” He adds that the bank is also          administration of the scheme, including     will have to retrofit to meet the Future
  building a site for customers to receive      a shortage of qualified contractors, the    Homes Standard.”
  a list of the top things they can do to       short-lived scheme did provide lenders         However, banking and building
  save money and improve their carbon           with more certainty of demand and           society members of the Institute’s
  emissions based on their postcode.            encouraged green mortgage innovation.       Coalition for the Energy Efficiency of
     Although Ecology Building Society has         “The government’s decision to cancel     Buildings (CEEB) generally welcome the
  always funded retrofits, renovations and      the programme will have ripple effects      current government proposal that UK
  conversions, Ellis says that the building     across the sector, but we believe it’s a    mortgage lenders disclose the EPC
  society has been making more loans            clear example to government that            ratings of their portfolios as one of the
  that improve the existing housing stock       collaboration with all parts of the value   positive long-term policy changes that
  over the last couple of years. It             chain is critical in the design and         are needed.
  introduced a new variable rate                implementation       of    future   grant      “It raises that EPC metric in the
  renovation mortgage this February,            schemes,”       says    Emma      Harvey,   awareness of boards and will drive
  offering       deeper      discounts     to   Programme Director at the Green             action throughout the industry,” says
  homeowners doing home renovations             Finance Institute.                          Cochrane, who adds that NatWest has
  that improve the EPC rating of the               The 2019 Conservative manifesto          an ambition for 50% of its mortgage
  property. The result is that Ecology has      committed over £9 billion of investment     book to have an EPC rating of C or
  done as much lending in the first three       to retrofitting homes, so bringing more     above by 2030. These energy efficiency
  months of 2021 on renovations as it did       of that funding forward is now essential.   disclosures could also spur the creation
  in the whole of last year.                    The government’s announcement that          of more innovative financial products to
     Yet while the need to finance home         public funding for the ‘able to pay’        help homeowners retrofit their properties,
  retrofits is clearly there, for many green    housing market will be limited in future    whether those are green mortgages,
  mortgage lenders, it’s still hard to assess   makes it even more critical for the         unsecured retrofit loans or other
  the extent of customer demand. “Most          private sector to deploy capital into the   products.
  people in the UK understand their next        retrofit and green built space.                Nevertheless, there is concern that
  car or the one after that needs to be            As Ellis points out, past government     the imposition of target EPC ratings
  electric or a hybrid, but don’t have the      funding programmes that supported           could have unintended consequences,
  same awareness that they need to              energy efficient homes have also been       potentially discouraging the improvement
  make their home more energy efficient         too short and aligned to annual             of properties with low EPC ratings and
  to reduce the carbon from their home in       budgets. Without the certainty of them      penalising the owners of those homes.
  the same way,” says NatWest’s                 continuing, it is hard for homeowners,      “The concern is that this could drive
  Cochrane. “Homeowners also need               and even contractors, to commit.            poor practices from lenders, who start to
  clarity on what the solutions are, with          Ellis cites the example of the UK        cherry pick those borrowers with
  access to trained retrofit professionals      government’s Zero Carbon Homes plan,        preferential EPC ratings,” says Mick
  that do work to required standards so         which would have made all new homes         Taylor, Head of Proposition Development,
  that consumers have faith in the supply       carbon neutral by 2016. The plan ended      Regulation and Industry Liaison at
  chain. These issues are interrelated. The     in 2015 and was replaced by the UK          Santander. “That would create a two-
  finance can be there, but the demand          Future Homes Standard, which will           tier system where homeowners with
  and the capacity to fulfil retrofits isn’t    ensure that new homes produce 75% to        lower ratings would find it harder to
  yet.”                                        80% less carbon, but won’t be enforced      move to a new mortgage provider.”
                                                                                                                                         
                                                                   5
Green Mortgages
     Green Finance Institute


    The outlook

    T    here are many more steps the UK
         government could take to stimulate
    demand for retrofit financing, as
    outlined by the Coalition for the Energy
    Efficiency of Buildings (CEEB) in its report
    last May. Stamp duty that is linked to
    EPC ratings, where homeowners pay
    less for buying more energy efficient
    properties, or receive a stamp duty
    rebate for undertaking an energy
    efficient retrofit within a set period, is one
    idea.
        Mandatory         minimum         energy
    efficiency standards, which already exist        Finance Innovation Fund, could help           that property,” says Santander’s Taylor.
    in the private rented sector, could be           financial institutions that are also          “That’s a challenge that will require a
    extended to the sale of owner occupied           dealing with COVID -19 and the Libor          collaborative       approach        across
    properties,      where      purchasers      of   and Brexit transitions address potential      industries and where the Institute’s
    properties that do not meet the                  capacity constraints.                         Building Renovation Passport working
    standard could negotiate the property               Beyond supportive policy and               group will be useful.”
    price to pay for the energy efficiency           regulation, industry-wide standards              If these hurdles can be overcome and
    renovations they will subsequently have          must be applied throughout the green          the right policies and regulations
    to perform. Removing or reducing VAT             mortgage market to maintain its               enforced, lenders see significant growth
    on energy efficiency measures could be           consistency and integrity and ensure          potential for this embryonic market over
    another stimulus.                                that lenders do not greenwash                 the next five years, with a wide variety of
        A concerted public awareness                 mortgages for CSR benefits. The               lenders, large and small, supporting a
    campaign         would      prompt       more    Institute’s     Green     Home     Finance    diverse range of products. As well as
    homeowners          to     recognise       the   Principles      provide    an    important    financing for new and existing green
    opportunities to make energy efficient           framework here, outlining how loan            builds, retrofits and the provision of
    improvements to their homes. As the              proceeds should be used, how                  energy reports, more products could
    CEEB outlined in its March report,               improvements should be assessed, how          emerge that are sensitive to the wide
    providing homeowners with bespoke                funds should be managed, and how              range of environmental characteristics
    Building Renovation Passports would              activity should be reported. The              in UK properties and the many unique
    enable them to identify and undertake            evolution of this market must produce a       scenarios that homeowners experience.
    the most impactful renovations on their          race to the top, both in standards and in        Lenders willing to invest in product
    property      and       access      qualified    innovation.                                   innovation, underwriting and the
    contractors who can do the work. Early              This    will    require   collaboration    expansion of their green mortgage book
    steps have been taken by the industry to         between government and lenders,               today will play a key role in shaping
    develop these solutions, including               energy suppliers, retrofit contractors,       what this young, exciting and critically
    Santander’s EnergyFact report.                   homebuilders, and other stakeholders to       important market will look like in years to
        On the supply side, there are many           share best practices and develop an           come, and ultimately, the influence it will
    steps that could stimulate the green             ecosystem of providers that can finance       have on the decarbonisation of UK
    mortgage market. A national loan                 and      implement         green     home     homes.
    guarantee scheme, an interest rate               improvements at scale, and ensure
    offsetting scheme, or favourable capital         those implementations are verified and
    treatments for green mortgage loans,             measured.
    could all help banks and building                   “To comply with the Green Home
    societies offer more attractive interests        Finance Principles, we need to validate
    rates to customers and boost loan                how our funds are being used, then
    volumes. More funding to support new             verify that the retrofit has resulted in an
    product innovation, like the Green Home          improvement to the energy efficiency of
                                                                                                                                                 
                                                                         6
Green Mortgages
     Green Finance Institute

   Q&A
    with Emma Harvey, Programme Director, Green Finance Institute

    B   efore joining the Green Finance Institute, Emma Harvey worked for several different divisions of Barclays Bank, and worked
        on the launch of the bank’s pioneering Green Home Mortgage. She discusses below how the UK’s green mortgage market
    has evolved since then and what further initiatives will support its growth.

                                                Before we launched the Barclays’                 The EU Energy Efficiency Mortgages
                                                mortgage, research in the US had also            Initiative (EEMI) is also important
                                                demonstrated a link between energy               because it was the first initiative to bring
                                                efficiency and the probability of default        together multiple stakeholders to
                                                on mortgages that were secured                   develop the energy efficient mortgage
                                                against those properties. Subsequently,          market. The end goal of the initiative is
                                                the Bank of England has published                to establish an energy efficient
                                                research that verifies this correlation.         mortgage securitization market across
                                                That’s important, because if the                 Europe. It also provides a very useful
                                                mortgage has a lower probability of              definition of what a green mortgage is,
                                                default, the bank holds less capital             which the Institute’s Green Home
                                                against that loan, and can offer lower           Finance Principles point to as one of the
    How did Barclays’ first green mortgage      interest rates without eroding its return        market’s best practices.
    in 2018 influence the development of        on equity. That can lead to a self-
    this market?                                sustaining green mortgage market,                What else can spur product innovation
    As the first major UK high street bank to   where lower risk loans mean that                 at lenders?
    bring an innovative product to market,      lenders are able to offer lower pricing.         It’s really important to gain buy-in at the
    the Barclays green mortgage created a                                                        senior level, while also empowering the
    ripple effect across the industry. It       As the market grows, this benefit may            bankers that develop these products.
    demonstrated that you can launch a          wash itself out, because this correlation        Financial institutions need to be ahead
    green mortgage, offer customers a           may be a socio-demographic indicator,            of demand for green mortgages,
    lower interest rate to support green        rather than the result of people saving          particularly to fund home retrofits, so
    choices, and verify a property’s high-      on their energy bills each month, but it’s       that finance is not a barrier but rather an
    energy performance rating. Before the       still an important trend to note.                enabler when demand increases. There
    Barclays     product,     it  was    also                                                    needs to be a culture of innovation and
    challenging to point to market demand       What other factors, other than UK                a willingness to try new ideas, in order to
    when developing a green mortgage.           policy and regulation, could encourage           catalyse new financial solutions.
    Now other organisations can see there       the development of this market?
    is demand and a supply of green             The work of the Coalition for the Energy         It’s also about harnessing the
    finance coming forward, which makes it      Efficiency of Buildings at the Green             enthusiasm of young bankers who are
    easier for banking and financier            Finance Institute has already catalysed          really passionate about climate and see
    members of the Coalition for the Energy     and stimulated market-led innovation.            a fantastic opportunity to do something
    Efficiency of Buildings to innovate.        Since it was established in 2019, its            good. That’s why we see so many
                                                demonstration projects, developed with           talented professionals in the early
    Was it also important to demonstrate        members, have shown that financial               stages of their career moving into
    that green mortgages could be               institutions can generate commercially           sustainable and green finance. Let’s
    commercially viable?                        attractive, risk-adjusted returns by             capture that enthusiasm and get it
    Yes, because even a couple of years         financing the retrofit market. By bringing       moving in the retrofit space. 
    ago, there was the misnomer that            together 300 members, drawn from all
    ‘green’ meant a negative impact to the      sectors of the economy that support the
    bottom line. Instead, we’ve seen green      retrofit value chain, it has also fostered
    products in the retail space, and the       cross-sector collaboration, which is critical,
    capital and syndicated loan markets,        and ensured that the financial solutions
    which really do generate attractive         it recommends work for all parties.
    returns.

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