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TCFD/ASIC Status Reports & Climate Risk Disclosure

Like with most development in business management, one of the main concerns is sizing up external expectations – what and when. This naturally depends on a variety of factors, but a good indicator for the direction and speed of uptake can be the recently released reports on the status of TCFD implementation in Australia by ASIC and globally by the Financial Stability Board’s Task Force.

Neither study assesses the quality or depth of climate-related financial disclosures. Instead, they look at the alignment of existing corporate reporting with the 11 TCFD disclosures. Which means, if you address their main concerns, your organisation is likely to be providing better disclosure than the average company – even if the underlying management practice is far from perfect. This creates no regrets and inevitably leads to inaction. Here are some strategies which have some of the biggest impact on perception:

1. Consolidate information where investors expect them: in your financial filings. If this is not possible, cross reference your financial fillings to the corresponding sources. Fragmented climate risk disclosure practices make comparisons difficult. Studies find that most companies publish information across multiple reports—financial filings, annual reports, and sustainability reports.

2. Be specific and provide context. ASIC notes that general, isolated, high-level statements (as opposed to specific) risk disclosure is not useful to investors and the TCFD highlights the importance of linking climate-related projects and actions to the company’s overall strategies. If you are at the beginning of your journey speak to your process and roadmap rather than providing platitudes and generic statements.

3. Concentrate your reporting efforts on the key areas: financial impacts and strategy resilience. Few companies disclose the financial impacts of climate-related issues on their company. Even fewer address business strategy resilience under different scenarios, such as a 2 degree warming, or how a company’s strategy might address potential climate-related risks and opportunities. This is what this exercise ultimately is about as it supports more appropriate pricing of risks, and the allocation of capital in the global economy. If you haven’t undertaken a full scenario analysis start with qualitative aspects, or speak to strategic processes that could be adapted to include climate-related issues.

4. Drum up internal buy-in to become a public supporter of the TCFD. There are currently only 39 official TCFD supporters in Australia, so your company will still stand out. Publicly declaring your support is a natural first step and you are not expected to implement the full set of recommendations straight away. The TCFD recognises that climate-related disclosure is a journey that will evolve over time. The Task Force will prepare a second status report for the Financial Stability Board in mid-2019, so get the ball rolling now to be included in their next update.

The reports stress how disclosures vary across industries and regions and that companies’ areas of focus vary significantly. However, with a concentrated effort your disclosure can be above average, even if there is still work to be done implementing climate-related governance and management.

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