Agefi – Mai 2019 :
After twenty years of building a legislative framework to enhance the stability of the financial sector, regulators are not willing to let go of the pressure. Now that the European and national authorities have been granted the necessary powers to shape the financial landscape, regulators are looking beyond crisis prevention:the next regulation aims to fuel change for a greener society.
The Action Plan for Financing Sustainable Growth
In March 2018, the European Commission published the Action Plan for financing sustainable growth. It details future legislative work to steer the financial sector towards the COP 21 goals set by the Paris Accords in 2015. To meet these targets in greenhouse gas emission cuts, renewable energy and energy savings, the financing gap is estimated to 270 Bln per year, in addition to current investment level(1). The plan aims to reorientate investment flows towards these sustainable development needs, improve sustainability in risk management, and increase transparency and long-termism in corporate governance.
First, the commission will introduce a taxonomy, labels and standards to help investors identify financial products that support sustainable targets. The plan also includes a list of amendments to current regulations: Benchmark and Credit Rating Agency regulations, IDD and MiFID II. This will impact benchmark and index providers, financial advisory, Credit rating agencies, institutional investors and asset managers, who will have to take into consideration ESG factors in their methodology and decision processes. Finally, the action plan aims to foster long-term strategies in corporate governance, by improving non-financial information in corporate reporting and including environmental considerations in the prudential framework. It will also take a critical approach to new accounting standards whether these have a positive or negative impact on environment.
Nine months later, during the COP24 in Katowice, a record 415 institutional investors, managing over 32 trillion $, urged world governments to accelerate the changes to achieve low carbon transition and other environment targets set by COP21’s agreement in Paris. Investors call for an acceleration of private sector investment into the low carbon transition and phasing out of thermal coal power and fossil fuel subsidies worldwide. This recommendation clearly echoes with the EC action plan to guide investment flows toward sustainable investment supports. Finally, the call also advocates an improvement of climate related financial disclosures. The current focus of corporate reporting on financial information is no longer sufficient. Investors now want to get the global picture, including environmental, social and human capital aspects.
Two elements clearly stand out from these announcements. To promote a greener finance, the investors and the industry need a reliable and transparent definition and classification for sustainable financial products, and a corporate reporting that goes beyond financial figures.
A taxonomy of sustainable investments
Since a couple of decades, financial performance is not the only criteria to evaluate the success of an investment strategy. Individual and institutional investors increasingly take into account ethical, environmental and philanthropic factors into their investment decision process. ESG products are definitely a growing market for product manufacturers. Independent rating providers such as MSCI, Sustainalytics, … assess issuers on a number of ESG criteria, used by investors to select products aligned with their strategy
But ESG comes in many flavors. A basic approach is to screen out undesirable companies that are not deemed socially or environmentally responsible, including tobacco, alcohol or oil industries, arm manufacturers. A more positive approach consists in actively seeking for enterprises that, by their policies and strategy choices, achieve environmental and/or social targets. The latter requires a more information and in-depth analysis of the corporate strategy and actions. It also achieves better results in identifying sustainable investments. As an example, biodiesel companies are considered as sustainable and usually pass the ESG screening, while fossil oil companies do not. But some biodiesel producers have a larger carbon footprint than their “dirty” competitors because they use food crops.
Furthermore, national authorities interpretation of ESG criteria also differ from country to country. This patchwork of constraints slows down the development of sustainable cross border products.
Consequently, a European Ecolabel for financial products would be welcomed by the industry. Though, some questions remain open: it is still unclear whether the ecolabel will focus on environmental aspects (as its name suggests) and leave out social criteria. The approach is also under debate, the industry advocates for a descriptive approach that focus on transparency and processes rather than strict limitations in the product development. Such a positive approach is believed to achieve a better allocation of capital flows and it would also leave larger room for interpretation and competition.
The industry also points out that the level of available information to perform the due diligence required by the positive approach is not always sufficient. This analysis requires more than financial figures. This is why the improvement of corporate reporting is necessary to promote green investment.
Beyond financial reporting
The goal of integrated reporting is to offer stakeholders a complete story about corporate performance. By enhancing its reporting with tangible values, firms can influence shareholders and other stakeholders positively, and help building a longterm management approach. The idea is not new: integrated reporting is being increasingly adopted by companies and countries. It is mandatory in South Africa and Brazil, and encouraged in Europe. In France, ESG and climate policy reporting mandatory since 2016. However, it is by nature much more complex to unify integrated reporting across industries than financial reporting, so no benchmark or standard is set for the moment. Consequently, it is still tempting to use integrated reporting as a communication and marketing vector rather than the transparency tool it should be. The number of initiatives developed to promote integrated reporting and non-financial and environment related disclosures is growing : the Climate disclosure standards Board (CDSB), the Global Reporting initiative (GRI), the International integrated reporting council (IIRC), the Sustainability accounting standards board (SASB)… Well-known standard organizations like ISO and IASB also derived their own interpretation.
This patchwork of standards and approaches has mostly brought confusion. A common project called “the corporate reporting dialogue(2)” was started in 2018 to align the frameworks with the recommendations of the task force for climate related Financial Disclosures (TCFD) . The TCFD, created by FSB, published a recommendation report in June 2017(3), based on 4 principles:
This ongoing dialogue project analyses the scope of each framework, and the definition of materiality. The initial output of this project is expected by Q3 2019 and no doubt it will serve as basis for the work of the European commission. In any case, the regulation has to set a compelling standard to bring transparency in corporate reporting, which can be prejudicial to their reputation. If not, integrated repoting may remain yet another component of greenwashing communication, and be useless to promote a greener finance.
1) See EIB, ‘Restoring EU competitiveness’, 2016. The estimate, until 2020, include investments in modernising transportation and logistics, upgrading energy networks, increasing energy savings, renewables, improving resource management, including water and waste
Par Thomas Dufresne, consultant du Groupe Square