氣候以外的風險 – 從TCFD到TNFD

香港地球之友綠色金融顧問

氣候變化一直在可持續發展討論中佔據重要位置,而在未來數年內也將繼續成為綠色金融世界的熱門話題。但是,作為負責任的世界公民我們還需要關注到其他重要議題並為他們尋找解決方案。

生物多樣性所面臨的喪失是氣候變化外的另一場危機,正為世界的經濟和社會帶來巨大的挑戰。我們必須了解保全生物多樣性所面對的困難,更重要的是我們要量度和評估其損失所帶來的風險和影響。

在2019年初舉行的世界經濟論壇達沃斯會議上,應付生物多樣性損失的議題被提出。

在同年下半年,WWF和AXA聯合撰寫了一份報告,討論將大自然因數融入在投資策略中。該報告列出了生物多樣性喪失的風險,並呼籲建立衡量這些風險的機制。

經過認真的會議和各方之間的討論,與大自然相關的財務披露工作小組(Task Force of Nature-related Financial Disclosure, 簡稱 TNFD)於2020年7月宣布成了。TNFD提出要金融機構了解,評估和報告與自然相關的風險建議。

雖然整個報告框架仍在工作中,但我們可能會看到類似五年前成立的與氣候相關財務披露專責小組(TCFD)的氣候披露框架。TCFD已逐步成為世界各監管部門和金融機構所建議的標準氣候披露報告框架。

根據目前的時間表,一個非正式工作組正在研究TNFD框架。目標是在2021年開發框架並在2022年對其進行測試。我們期待看到TNFD框架的細節。


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Risks beyond climate – from TCFD to TNFD

Green Finance Advisor of Friends of the Earth (HK)

Climate change has been the front and centre for discussion on sustainability and is likely to stay as a hot topic for the world of green finance for years to come. However, being responsible citizens of the world there are other important topics we need to find solutions. The loss of our nature is another crisis that is equally challenging for us and is bringing immense economic and societal challenges to our world. To overcome these challenges we have to understand and more important to measure the risk and the impact of the loss of our nature.

In the Davos meeting of World Economic Forum held in early 2019 the idea emerges to address these issues. Later in the year WWF and AXA worked a report to discuss about integrating nature into investment strategists. The report laid out the risks from biodiversity and called for the establishment of a mechanism for them. After a serious of meetings and discussions among different parties the Task Force of Nature-related Financial Disclosure was announced in July 2020. The Taskforce or TNFD in short called for companies and financial institutions to understand, assess and report the nature-related risks. While the reporting framework is still on the work, we may see that to mirror Taskforce of Climate-related Financial Disclosure (TCFD), which was developed five years ago and has gradually become the most preferred framework by regulators and financial institutions for reporting climate-related risks.

Under the current schedule, an informal working group is working on the TNFD framework. The target is to have the framework developed in 2021 and tested in 2022. We are looking forward to the details of it.


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What is SFDR?

Michele Leung, Green Finance Advisor of Friends of the Earth (HK)

EU Sustainable Finance Package is one of the most ambitious legislative plan globally that aims to shift capital flows towards sustainable investment to achieve sustainable and inclusive growth. The impact is not limited to the EU, as investment managers outside the EU may be impacted or wish to follow if they manage European assets. It is also very likely that other jurisdictions are also looking at putting in similar measures in place.

Sustainable Finance Disclosure Regulation (SFDR) is one of the ten points from EU Action Plan, which is clarifying institutional investors and asset management duties. Essentially, its objective is to harmonize ESG disclosure standards, requiring financial market participants to integrate sustainability risk in the investment process and to report on such integration at both the entity and product level. In February 2021, the European Supervisory Authorities released their Final report on draft Regulatory Technical Standards (RTS), providing details on content, methodologies and presentation of disclosures under the SFDR, which included a set of 64 adverse impact indicators, including 18 principal adverse sustainability impact indicators ad 46 additional environmental and social indicators.  Based on the draft RTS, financial market participants serving EU investors may be required to make disclosures at an entity level of all of the 18  principal adverse impact indicators , two from additional set of adverse impact indicators (one environmental and one social) and any other indicators used to assess the sustainability impacts.

Re the timelines, principle-based disclosures are required from beginning in March 2021, and then it will be more challenging in Jan 2022 as detailed and prescriptive disclosures (i.e. adverse impact indicators) will be due.

Market participants has raised concerns on the data availability, aggressive timeline and also the inefficiency and cost if to collect data directly from companies. For example, among the required metrics, the disclosure rate is the lowest for gender pay gap, biodiversity and water emissions.  They are now seeking for guidance and best practices to start their new journey, many of which are now establishing their dedicated project team and IT structure, while knowing the limit is data availability.

One possible solution is to rely on third party vendors, which in fact, have launched tailored and robust SFDR solutions that help investors to source the data more holistically and to respond both qualitatively and quantitatively. In absence of disclosure, the third party vendors can conduct company outreach, provide estimation and supplementary data to bridge the gap.

To learn more, please register and join our First Earth Forum on 22 April 2021!


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Earth Forum Special: How Are High-Impact Firms Doing in Low-carbon Transition?

World Benchmarking Alliance (WBA)

Three months into 2021, the world seems to slowly be moving towards a return to normalcy. In countries everywhere, people are expressing cautious optimism about our ability to collectively tackle the COVID-19 pandemic thanks to the determination and ingenuity of the scientific community, which has provided newfound hope through vaccination technology. And while concerns around vaccine equity remain high, recent developments – such as the agreement between rival US pharmaceutical companies, Johnson & Johnson and Merck, to collaborate on vaccine production – have reinvigorated perceptions of trust in the ability of institutions, including business, to contribute to a sustainable recovery.

Indeed, business has never been better positioned to rise to the occasion. The recently released 2021 Edelman Trust Barometer startlingly reveals that across 27 countries, business is the only trusted institution, placing higher than NGOs, government, and media on issues that include driving economic prosperity, encouraging long-term thinking over short-term profits, and embracing sustainable practices.

The regional findings of the report are similarly revealing. Consider China for example, where trust in business remains remarkably high, despite dropping 12 points between 2020 and 2021. This data is critical given the central role that business has to play in rebuilding our global economy and achieving the UN Sustainable Development Goals (SDGs). This is especially important in China, which makes up around 19% of global GDP and will be central to ensuring that nobody is left behind in the pursuit of a more sustainable future.

At the World Benchmarking Alliance (WBA), we are building a movement to measure and incentivize business performance towards this future through the development of free, publicly available benchmarks. Our work is rooted in seven systems transformations and focuses on how the world’s 2,000 most influential companies (SDG2000) can drive progress on this agenda across their value chains. These companies are global in nature, spanning 80 countries, employing 102 million people, and representing $46 trillion in revenue. 246 are directly headquartered in China but many more have indirect impact in China due to their supply chains or other business operations.

The global nature of these companies requires us to work in partnership with others to ensure that our benchmarks are built on best available science, reflect societal expectations, and positively influence company behavior. That’s why we are built as a diverse, multi-stakeholder Alliance of over 200 organizations representing business and industry platforms, financial institutions, reporting platforms and standards setters, civil society organizations, research and academia, multilateral bodies, and sustainability consultancies. And while our Allies are global, they are currently concentrated in the global north. With only three organizations currently based in China, our ability to influence Chinese companies, or business engagement in China more broadly, remains limited.

Earlier this year, WBA updated our SDG2000 and included – for the first time – a mapping of how these companies engage with our Allies as network members, platform signatories, assessed or benchmarked companies, and framework or standards reporters. Our analysis found that while 87% of companies were engaged with at least one Ally, only 276 of the 2,000 companies currently engage with five or more Allies. In China, this discrepancy is even more pronounced, with only 5 of the 246 Chinese companies engaging with five or more Allies, despite all of them engaging with at least one Ally. This data suggests that most companies, including those based in China, are insufficiently aware of the role partnerships play in achieving a more sustainable future. Given the magnitude of these companies and their impact across the SDG agenda, a multitude of partnerships is needed, requiring both companies and Allies to step up their mutual engagement.

WBA has been proud to work with Friends of the Earth (HK) over the past 18 months on strengthening our engagement with companies in China on this agenda. As our first Chinese-based Ally, FoE (HK) has been instrumental in supporting our efforts in the region. This includes convening dialogues and roundtables with Chinese utilities companies, for example, on needs and opportunities for increased ambition and action using the methodology and benchmark data from WBA’s Electric Utilities Benchmark. It also includes more targeted policy and advocacy engagement, including submitting a joint statement of support for mandatory emission disclosure by companies in response to the public consultation of the National Energy Administration’s 14th Five-Year Energy Planning Development. These efforts have been critical to laying the groundwork for more substantive engagement moving forward, including around the development of our Oil & Gas Benchmark later this year and on efforts to ensure a just transition in China on the road to decarbonization.

These efforts need be replicated, however, to achieve impact at scale in the region. In recent weeks, WBA has been proud to welcome two more Chinese-based Allies, Ascent Partners and Green Light Year – both of who we forward to working with over the coming years to help guide, and hold to account, Chinese companies for their performance.

As we begin to emerge from the worst of the crisis and transition towards rebuild and recovery, collaboration will be critical to restoring our trust in institutions, empowering business to lead, and ensuring a just and inclusive future for all.

To learn more, please register and join our First Earth Forum on 22 April 2021!


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恒生指數大變身

香港地球之友綠色金融顧問 黃思靈

恒生指數公司於3月1日公佈優化恒生指數諮詢總結的詳情,諮詢建議提出時有一條關於恒指成份股選股考慮的題目,但在總結報告裡並未有被提及。問的是:在挑選恒生指數成份股時,除了考慮市值、流動性和行業代表性外,還有什麼其他值得考慮的因素?由於收到關於這題目的回覆不多,所以也就沒有在諮詢總結裡特別滙報。有趣的是,當中有回覆人士提到加入ESG考量。

其實早在上一次諮詢時恒指公司已經提出過同樣的議題,不過觀乎兩次的諮詢結果,看來對香港來說,ESG仍然有待發展。有人建議對恒指候選公司設最低ESG評分要求,但由於目前社會裡未有一套廣泛接受的ESG評級,倉卒加入此條件似乎較為草率。同時亦有人士表示恒指作為市場指標,應以公司的市值、成交等客觀因素選股,ESG比較主觀且主題性,應另外編算相關標的,而非擾亂恒指的選樣方法。支持和反對兩方各有說法,但目前普遍認為此議題尚未成熟,應否或何時執行仍然有待商榷。

另外在本次諮詢總結裡,恒指公司亦提出把所有成份股的個股權重上限劃一至8%,就是說同股不同權和第二上市的成份股權重上限將從本來的5%提高至8%。同時由於恒指把上市歷史要求由2年縮短至3個月。新規下,估計會納入更多同股不同權和第二上市的公司。假設恒指加到80隻成份股,這些公司的整體比重將由目前約13%增至接近19%。

有人視同股不權和第二上市公司如同甘露,因它們大部份為新經濟企業,有無限發展空間。但亦有人憂慮這些公司的企業管治,不放心投資到它們身上。早前財政司司長陳茂波亦提到,正在研究是否允許特殊目的收購公司(SPAC)到港上市。而SPAC往往被稱為空白支票公司,為了與別家合併而透過首次公開上市(IPO)集資,因而能夠更快速上市,但可見對一般投資大眾而言風險可能更高。SPAC將來不知會否符合恒生指數的資格。或許恒指公司可考慮參考其他指數公司的做法,提供另外一條不含此等另類公司的恒生指數,讓各用家自行選擇,畢竟青菜蘿蔔,各有所愛,不用順得哥情失嫂

優化恒指最終五大方案

1. 擴大市埸覆蓋率
• 最終成份股數目固定為100隻,目標於2022年年中前增加至80隻成份股
2. 擴充行業的代表性
• 按7個行業組別選出成份股
3. 適時納入上市新股
• 縮短上市歷史要求至3個月
4. 保持香港公司代表性
• 維持20至25隻香港公司成份股
5. 改善成份股權重分佈
• 對所有成份股採用8%的權重上限

資料來源:恒生指數公司


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