2022-10-24
Added · Updated
The Dutch Central Bank (DNB) provides supervisory expectations for financial institutions, including insurers, pension funds, and investment firms, to integrate climate and environmental risks into their core processes. The Guide establishes four focal areas for management: business model and strategy, governance, risk management, and information provision. Institutions are required to conduct materiality analyses and manage risks proportionately based on their size, complexity, and exposure. While the good practices included are not binding, they serve as indicative examples for the supervisory dialogue regarding sound and ethical operational management.
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Guide to managing climate and environmental risks
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Contents Introduction Climate and environmental risks Focal points for the management of climate and environmental risks
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction 1 The term “financial institutions” is used in a generic sense in this document and includes both financial companies governed by the Financial Supervision Act and pension funds governed by the Pensions Act. 2 See, inter alia An energy transition risk stress test for the financial system of the Netherlands (2018), Values at Risk? (2019), Indebted to nature (2020) and Balancing sustainability (2021). 3 In accordance with Section 3:17 of the Financial Supervision Act and Section 143 of the Pensions Act. 4 The study entitled “Balancing sustainability” examined the extent to which banks, pension funds and insurers integrate sustainability risks into their knowledge processes in the fields of strategy, governance, risk management and information provision. 5 For example, good practices and Q&As were published for insurers on how to include climate risks in the ORSA (2019) and for investment firms and institutions on the management of climate and environmental risks (2021), only Dutch version available. A consultation on good practices for the pension sector was also conducted in 2022, only Dutch version available. 6 See NGFS (2020). 7 As the good practice for investment firms and institutions has been previously consulted, it is decided to not include this in the English consultation version. In the final edition of this guide, this good practice will be included. 8 The Dutch Authority for the Financial Markets (AFM), as the authority supervising the operational management of investment firms and institutions, ensures that they conduct a policy to manage the risks that may detrimentally affect the treatment of customers and participants. This includes managing climate and environmental risks. 9 The ECB Guide applies to “systemic institutions” as part of the Single Supervisory Mechanism. DNB has also declared the ECB Guide applicable to “less systemic institutions”. Climate change and environmental degradation can pose risks to Dutch financial institutions. DNB expects financial institutions to understand all material risks and to manage them appropriately. This also applies to climate and environmental risks. In this Guide, we provide tools to manage these risks. Climate change and environmental degradation can pose risks to Dutch financial institutions1 . These risks may result from physical damage due to climate change and environmental degradation or from financial institutions having to adapt to stricter climate and environmental policies, new technology and/or changing market and consumer sentiment2 . DNB expects financial institutions to understand and manage all material risks, including climate and environmental risks. Institutions must have sound and ethical operational management3 . DNB research4 shows that financial institutions are aware of climate and environmental risks but are still taking only
limited account of them in their core processes. We have also announced that we will further specify our expectations with regard to sustainability risk management in 2022 and submit them to the financial sector for consultation, thereby meeting the demands from the sector. In this Guide, we provide tools to manage climate and environmental risks. The Guide builds on previous policy statements on the management of these risks which have been published in recent years for specific sectors and components of the management framework5 . We are thus following the recommendation of the Network for Greening the Financial System (NGFS) to draw up “supervisory expectations”6. Financial institutions can use these tools proportionately by adopting a risk-based approach. The Guide should be viewed in conjunction with the applicable laws and regulations. The Guide relates to prudential supervision and will be updated periodically. The tools are intended for insurers, pension funds, premium pension institutions, investment firms and institutions, and electronic money and payment institutions. In the case of investment firms and institutions, only the sector-specific tabs apply7 . These incorporate the Good Practice published in 20218 . The tools provided in the Guide have been aligned where possible with the “supervisory expectations” of the European Central Bank applicable to the banking sector9. In the light of legislative and regulatory developments and new insights into the proper management of climate and environmental risks, additional explanatory notes and practical examples
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management will be added to this Guide periodically. For example, we are currently working on a good practice for payment and securities institutions with regard to climate risk management. Reader’s guide This Guide comprises a cross-sector part and sector-specific explanatory notes and good practices. The next tab outlines the legislative and regulatory framework for the management of climate and environmental risks and its application in supervisory activities This is followed by a more detailed explanation of climate and environmental risks. The Guide describes focal points for integrated climate and environmental risk management. These cover the areas of business model and strategy, governance, risk management and information provision. The sector-specific tabs (accessible by clicking the sector buttons at the end of each chapter) contain good practices for the relevant sector. These are practical examples that, in our view, are good examples of integrated climate and environmental risk management. They are intended as a source of inspiration on how institutions can give substance to the cross-sector focal points.
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Legislative framework and applicability 10 The Guide focuses on climate and environmental risks as a subcategory of sustainability risks. This scope may be expanded over time. 11 The Dutch Authority for the Financial Markets (AFM) is responsible for supervising compliance with the obligations in the SFDR and the CSRD. 12 The sector-specific tabs in this Guide provide more information on these ESAs’ laws and regulations of relevance to the sector. 13 Good practices are indicative and institutions are free to take a different approach as long as they comply otherwise with the laws and regulations. To learn more about the status of our policy statements, go to the Explanatory guide to DNB’s policy statements on Open Book on Supervision. Legislative framework Under Section 3:17 of the Financial Supervision Act and Section 143 of the Pensions Act, Dutch financial undertakings and pension funds respectively are obliged to have sound and ethical operational management. In addition, more detailed specific regulations are in force for various sectors with regard to the management of prudential risks. These can be found in the sector-specific tabs. Institutions are thus expected to manage material risks. Since climate and environmental risks can be a source of financial and non-financial risks, supervised institutions are required to manage material climate and environmental risks. At European level there is an increasing amount of legislation and regulation in the field of sustainability10. For example, the European Commission has drawn up the Action Plan for Financing Sustainable Growth to make sustainability an integral part of risk management and encourage transparency and long-term thinking. This package includes: the EU taxonomy, a classification system for sustainable economic activities; the Sustainable Finance Disclosure Regulation (SFDR), containing sustainability disclosure requirements for financial market participants; and the Corporate Sustainability Reporting Directive (CSRD), with reporting requirements for listed and large companies on ESG aspects11. European Supervisory Authorities (ESAs) are also increasingly embedding sustainability in their laws and regulations12. Application in supervision This Guide provides tools to enable the sector to embed climate and environmental risks in core processes. The tools include focal points for integrated climate and environmental risk management in the areas of business model and strategy, governance, risk management and information provision. These focal points have been further detailed in sector-specific good practices: practical examples that in our view can effectively fulfil the obligations in the laws and regulations13. These may be (possibly anonymised) practical examples that we have observed in institutions or stylised examples. Institutions can use these
examples and apply them proportionately according to the nature, size and complexity of the institution. The good practices in this Guide are not binding, but they will be referred to in the supervisory dialogue between DNB and the institution on climate and environmental risk management.
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Box 1: proportionate approach to the management of climate and environmental risks We monitor sound and ethical operational management in a proportionate and risk-based manner in accordance with laws and regulations. This means we take into account the nature, size and complexity of the institution, as well as the materiality of the risks to the institution. The same applies to the management of climate and environmental risks. Whether climate and environmental risks are material to an institution depends on the characteristics of its business model, operating environment and risk profile. As a minimum, we expect an institution to analyse the extent to which climate and environmental risks are material to the institution (see Box 2 containing focal points for the materiality analysis). An institution must accordingly identify these risks and assesses their materiality. It must then manage the material risks. An institution adopts a proportionate and risk-based approach to managing climate and environmental risks that is geared to the size of the institution and the materiality of its exposure to climate and environmental risks. For example, a qualitative and less granular approach may suffice for a small institution with low material exposures, whereas larger institutions or institutions with material exposures will adopt a more sophisticated approach. We recognise that climate and environmental risks have particular characteristics and that a gradual entry path may be necessary to raise the management to the desired maturity level over time. Legislative framework for sectors Insurer
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Climate and environmental risks 14 Financial risks also include market, liquidity and credit risks as well as underwriting and interest rate risks. Non-financial risks include business model/strategic risk, governance risk and operational risk. Reputational risk and legal risk are considered part of operational risk. 15 Ecosystems are complex and dynamic systems of plants, animals and microorganisms, as well as the non-living environment, interacting as a functional unit. See inter alia the DNB study Indebted to nature – Exploring biodiversity risks for the Dutch financial sector This Guide addresses climate and environmental risks. These are the financial and non-financial risks14 that may arise from financial institutions’ exposure to the effects of climate change and environmental degradation. Climate change can lead to extreme droughts, floods and storms, among other things. Examples of environmental degradation include water or air pollution, desertification, deforestation and loss of biodiversity and ecosystem services15. Climate and environmental risks may be driven by physical and transition risk factors:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management The extent to which climate and environmental risk factors permeate or interact with the institution may differ from sector to sector and also depend on the institution’s business model. The sector-specific tabs contain a table with examples of how these risk factors feed through into existing financial or non-financial risks. In addition to these direct impacts, financial institutions may encounter indirect or second-order effects. The (negative) impact on the financial system may in turn worsen the macroeconomic conditions. The feedback arrows between the economy and the financial system in Figure 1 illustrate these second-order effects.
Figure 1. Climate and environmental risks as a source of prudential risks
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Characteristics of climate and environmental risks Climate and environmental risks have specific characteristics that are important in the integrated management of these risks. Climate and environmental risks are systemic in nature and have a non-linear impact. Historical data is therefore often of limited value in assessing the risks. In addition, they are characterised by the enormous scope and scale of the impacts, uncertain timing ranging from the short to long (or very long) term and dependence on short-term action and policy measures. Finally, climate and environmental risks are relatively new in the financial sphere and new developments and insights are emerging in rapid succession. Impact of risks on sectors Insurer Electronic money or payment institution
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Focal points for the management of climate and environmental risks With this Guide, we highlight four focus areas of possible relevance to financial institutions in achieving integrated management of climate and environmental risks. The focus areas relate to (1) business model and strategy, (2) governance, (3) risk management and (4) information provision. For each focus area, focal points have been identified that are applicable to climate and environmental risk management across sectors. Institutions are also offered good practices, as an example of effective application of a focal point. These can be found on the sector-specific tabs. When applying these it is important to keep in mind the proportionality and materiality of the risks to the institution. Box 2: Materiality analysis Financial institutions should manage material risks appropriately. The same applies to material climate and environmental risks. Whether climate and environmental risks are material to the institution can be determined by means of a materiality analysis. When conducting a materiality analysis, the institution can take the following focal points into account:
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Focal area 1: Business model and strategy Mapping the potential impact of climate and environmental risks on the business environment and business model Institutions should consider all material risks to which the business model may be exposed. These risks may arise from developments in the business environment, among other things. Climate change and environmental degradation can affect this environment and pose risks to the business model. For instance, increased flood risk can make a region’s business climate less attractive. An institution dependent on income from this region may have lower earning power in the long run. At the same time, climate change and environmental degradation can provide opportunities that maintain the institution’s earning power. Adopting a granular and long-term perspective when identifying risks (and opportunities) A good way to identify risks (or opportunities) for the business model is to identify them at the level of sectors, geographical areas and services in which the institution operates or wishes to operate. In doing so, the institution can indicate the timeframe within which these risks are likely to materialise. Some climate and environmental risks may occur within the regular planning cycle, such as reputational effects or extreme weather events. Other risks, such as technological breakthroughs, may come into play and affect the business model in the longer term. Including climate and environmental risks in strategy formulation and implementation Material climate and environmental risks may impact the effectiveness of the existing and future strategy. To investigate this, the institution can use forwardlooking tools, such as stress tests and scenario analyses. Material risks arising from the analyses are taken into account when formulating or updating the strategy. Establishing performance indicators To implement and monitor the strategic goals regarding climate and environmental risks, an institution can establish performance and risk indicators. The indicators allow the institution to make adjustments to the implementation of its strategy and take action. Depending on the activities and materiality, specific indicators can be drawn up for relevant parts of the institution and portfolios. These could include indicators such as the organisation’s carbon footprint or the share of sustainable assets in the strategic investment policy. Good practices for sectors Insurer
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Focal area 2: Governance 16 By this we mean the highest executive body (the management, board of directors or management board) and the supervisory body (the supervisory or oversight board) of the institution, as applicable. 17 Climate and environmental risks are only taken into account in fit and proper assessments at banks, insurers and pension funds, not at investment firms and institutions or electronic money and payment institutions. Policymakers16 Embedding climate and environmental risks in governance and policy frameworks It is important that policymakers, making up the senior level of the institution, embed climate and environmental risks in the governance, strategy, risk appetite and risk management framework. As these risks can affect the institution in multiple ways, it is important to do this on an integrated basis. In this way they can ensure that these risks receive sufficient attention within the organisation and are adequately addressed. In doing so, they also promote a culture of values, standards and behaviour that contributes to conscious consideration of climate and environmental risks. Policymakers also engage in a dialogue with relevant stakeholders so that their interests and views are included in the considerations. Assigning responsibilities for climate and environmental risks within the institution’s own policymaking bodies Assigning tasks and responsibilities for climate and environmental risks in the institution’s own policymaking bodies stresses the importance of this theme and demonstrates a commitment to climate and environmental risks from “the top”. To ensure that climate and environmental risks are properly embedded, it is possible to examine which structure, working method and/or mutual division of tasks is appropriate within the institution’s own bodies. Various options are possible, including setting up a specific management or supervisory board committee for climate and environmental risks. Ensuring sufficient fitness with regard to climate and environmental risks It is important that policymakers have sufficient knowledge, experience and skills with regard to climate and environmental risks to assess the exposure of the institution to these risks and make balanced decisions about them. We also pay particular attention to this when assessing the fitness of policymakers and other officers for whom we conduct fit and proper assessments (see Box 3)17. As these risks are relatively new, complex and diverse, building fitness and propriety is particularly important. Since developments are fast-moving in this area, for example around new legislation, it is advisable to pay constant attention to this. Box 3: Climate and environmental risks as part of fit and
proper assessments In fit and proper assessments at banks, insurers and pension funds, climate and environmental risks are taken into account when assessing fitness and propriety. Among other things, we expect prospective members of the management board, supervisory board, supervisory authority or other sole or joint policymakers to have knowledge of these risks, the relevant laws and regulations and to know how these risks may affect the institution. We also assess whether he/she has sufficient competences to properly assess these risks and include them in decision-making, such as a helicopter view, environmental sensitivity and strategic direction. We apply this expectation proportionately, taking into account the specific post, the institution’s nature, size, complexity and risk profile and the composition and performance of the body as whole. See: Climate-related risks are now a part of fit and proper assessments (dnb.nl).
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Organisation Allocating responsibilities and resources for climate and environmental risk management within the organisational structure By explicitly assigning roles and responsibilities and distributing them in a balanced way across functions, it is possible to make well-informed decisions on climate and environmental risks. The nature of these risks requires institutions to take account of major uncertainties surrounding the timing and impact of climate change and environmental degradation in decision-making. This makes it particularly important to include input from the relevant functions involved in the management of climate and environmental risks. Sufficient financial and human resources, including the required knowledge and skills, are important for the adequate performance of the functions. As developments are occurring rapidly in this area, it is advisable that the adequacy of resources, expertise and skills to manage climate and environmental risks is assessed on a regular basis. Aligning remuneration policies and practices with the climate and environmental risk strategy and management By aligning remuneration policies and practices with the institution’s strategy, goals, long-term targets and risk appetite, it is possible to encourage behaviour that can help achieve the institution’s climate and environmental targets. This could involve, for example, compliance with the institution’s own climate or footprint targets. Achieving such targets generally requires a gradual entry or exit path of several years. Good practices for sectors Insurer
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Focal area 3: Risk management Explicitly including climate and environmental risks in the existing risk appetite framework The risk appetite framework is the starting point for the design of the risk management cycle. By including in this framework all material and other risks to which the institution is exposed (now and in the future), an institution can indicate which climate and environmental risks it accepts in order to attain its strategic goals and which it does not. As input for integrating climate and environmental risks in this framework, the institution can investigate which risk categories are affected by climate and environmental risks and to what extent. For risks it considers material, the institution defines a targeted risk appetite and takes targeted measures. These could include a risk tolerance for market risk caused by asset impairment due to stricter climate policies. Particularly in view of the new and dynamic nature of climate and environmental risks and the related regulations, it is sensible to review this framework regularly. Integrating climate and environmental risks in the existing risk management cycle Incorporating climate and environmental risks in the existing management cycle (see
Figure 2) ensures that they receive regular attention. In this cycle, the institution
identifies, assesses, mitigates, monitors and evaluates its exposure to the relevant risks in the light of the established risk appetite. In its policy, management information and risk reports, the institution can provide a written demonstration of the way it manages risk through these steps in the management cycle. The identification and assessment builds on financial institutions’ legally required risk assessments18. 18 The Own Risk and Solvency Assessment (ORSA) in the insurance sector, the Own Risk Assessment (Eigen Risico Beoordeling – ERB) in the pensions sector and the Internal Capital and Liquidity Adequacy Assessment Process (ICLAAP) for investment firms and institutions.
Figure 2: risk management cycle
Risk identification
Risk monitoring
Risk assessment
Risk mitigation
Risk management cycle
Risk attitude
Building a comprehensive picture of climate and environmental risks in the identification phase In the identification phase it is useful for the institution to build a comprehensive picture of the climate and environmental risks that affect the aforementioned business model and strategy, but also how these risks will affect the current balance sheet and organisation in the short term. This identification enables the institution to understand the climate and environmental risks to which it is exposed. Looking from different perspectives and considering interactions between risks helps to build a comprehensive picture.
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Using scenario analyses and stress tests to estimate exposure to climate and environmental risks Scenario analyses and stress tests can be useful tools given the uncertainties and complexities associated with both short-term and long-term climate and environmental risks. For the shorter regular planning period, these tools can be used to identify the impact of these risks on capital (and required capital). Business impact analyses and continuity tests can also be used to test the resilience of critical operational processes to climate and environmental risks. Longer-term scenario analyses are useful particularly to test the resilience of the business model. Examples are scenarios of temperature rises of 1.5-2 versus 3 or more degrees Celsius, or a scenario in which the transition to a sustainable economy is disorderly. These can also be analyses of a qualitative nature that can provide input for strategic planning and decision-making. See also Box 4. Establish appropriate risk tolerances and indicators for measuring and assessing climate and environmental risks For example, based on the appetite, these could include tolerances for exposures to sectors or geographical areas that are highly sensitive to climate and environmental risks and hence a source of, for instance, market or counterparty risks. To monitor the risk appetite, it is important that tolerances are clearly defined and, where possible, measurable using indicators. To form a complete picture of the risk, it may be necessary to define multiple indicators for a single risk. For example, these could be indicators derived from certain concentration risks on investments and loans or indicators reflecting the potential impact of physical risks on outsourcing. Where there is no quantitative data, it is possible to use qualitative indicators based on expert judgement. For each risk indicator, it is possible use probability and impact analyses to assess whether the identified risk level falls within the risk tolerance and hence the risk appetite. checklist for preparing and conducting scenario analyses:
Phase Action Explanation
1 Define goal Understanding long-term risks to the business model, or short-term financial risks. Input for risk management or strategic policy discussions. 2 Choose scenarios Type (dependent on purpose): qualitative or quantitative, trend, exploratory or stress. Number: 2 or more, at least 2-degree temperature rise scenario. 3 Assumptions, measure and parameters Assumptions: internal or aligned with recognised third parties (NGFS, KNMI, et al.). Measure: choice of emissions, temperature rise. Parameters: type of transition (orderly and timely, disorderly or no transition). Make prudent assumptions in a stress scenario. 4 Time horizon Short and medium horizon (up to 10 years) for financial risks and impact on soundness of the institution in regular planning horizon. Long horizon (>10 years) for qualitative estimates for impact on business environment and business model. 5 Method and procedure Method: calculation model or storyline behind the scenarios. Procedure: include stakeholder engagement, workshops with experts. Managing climate and environmental risks that fall outside the risk tolerance If the potential impact of climate and environmental risks falls outside the established risk tolerance, it is important to indicate how these risks will be mitigated within a specified period. For example, an institution can reduce its carbon footprint or opt for impact investing in companies that invest in renewable energy. It is useful to evaluate the effectiveness of the mitigation tools used, and to make this measurable and monitor it where possible. Where measures are unlikely to be sufficient to align the risk profile with the risk appetite, appropriate follow-up steps are defined.
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Monitoring and periodically reporting exposure to climate and environmental risks By monitoring climate and environmental risks on the basis of the established risk indicators, it is possible to monitor these risks and their development. For institutions that have committed to certain climate targets or alliances, it is important that they monitor the progress of these commitments to remain credible and avoid reputational risks. Risk reporting helps the policymaking body to take informed decisions on the management of material climate and environmental risks. Frequent evaluation of the climate and environmental risk management cycle Developments in climate and environmental risks are occurring rapidly. There is increasing knowledge and understanding of the risks and their modelling, data coverage is growing and legislation is increasing. It is therefore important that an institution frequently evaluates its climate and environmental risk management cycle. In this evaluation, questions may arise such as: Is the list of identified risks still complete? Is the materiality estimate of the risks still correct? Is the impact of the risks being properly measured? Are the mitigation measures effective? By setting a target maturity level, the institution can identify what future steps are still needed to improve the risk management cycle. Good practices for sectors Insurer
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Focal area 4: Information provision19 19 Information provision is an area in which supervision is shared with the Dutch Authority for the Financial Markets (AFM). AFM supervises the legal requirements in the field of information provision. DNB focuses on prudential reporting and the prudential implications of external reporting, such as reputational risks due to insufficient or inadequate information provision 20 The ESRS were developed by the European Financial Reporting Advisory Group (EFRAG). The International Sustainability Standards Board (ISSB) is also currently working on reporting standards (IFRS Sustainability Disclosure Standards) to serve as a global baseline. While not legally enforceable in the EU, these standards play a role in aligning European reporting standards. 21 See here for the draft version of the ESRS put out to consultation; and here for the draft of the ISSB. Setting up appropriate data infrastructure for climate and environmental risks An appropriate data infrastructure for climate and environmental risks helps the institution to identify these risks. For proper embedding and an integrated approach, it is important to link the collected data on climate and environmental risks to existing models and processes. An important part of that infrastructure is determining the data requirement, which partly depends on the business model and the size of the institution. This data can serve as input for internal reporting to guide strategic decisions, as well as external reporting such as the annual report and prudential reports. DNB recognises that data and methodologies are still being developed and are sometimes incomplete. By working on a best-effort basis and keeping up with developments, the data infrastructure can be raised to an increasingly mature level. Paying attention to new reporting standards when determining the data requirement Various initiatives are under way to increase transparency concerning sustainability in the financial sector. One of the main reporting standards for climate and environmental risks currently being developed stems from the European Corporate Sustainability Reporting Directive (CSRD); these are the European Sustainability Reporting Standards (ESRS)20. Institutions covered by the rules must include in their external reporting information on the effects of ESG factors on the company and the corresponding effects of the company on people and the environment. This includes ESG information on the strategy, governance and business model, materiality analysis, risks and opportunities and performance indicators. These standards also mention data indicators to measure climate and environmental risks21. Institutions are advised to align their data
needs as closely as possible with these European reporting standards and make clear where they use their own, additional or different, metrics and methods. This applies both to institutions covered by the reporting obligation and to those not covered by it. Providing meaningful information on material climate and environmental risks Providing information on climate and environmental risks increases market participants’ understanding of the risk profile and resilience of financial institutions. Good information provision is particularly important for institutions that are committed to achieving climate and environmental goals. For example, if an institution commits to policy goals to fund (or refrain from funding) certain activities, it can provide sufficient clarity on matters such as the plans, goals and thresholds used as well as the portfolios and/or activities involved and the associated progress. It is also important that the institution provides details of the metrics and methods used. Such transparency is important to avoid reputational damage. Good practices for sectors Insurer
Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Focal points for management Electronic money and payment institution Sectors Insurers Pension funds
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Impact of climate and environmental risks on electronic money and payment institutions The table below shows an example of how climate and environmental risk factors can affect existing financial and non-financial risk areas of an electronic money or payment institution. The same risk factor can affect several risk areas simultaneously. The table is intended purely as an illustration to provide a starting point for the materiality analysis. The ultimate impact depends among other things on the size and distribution of the physical and transition risks, as in the case of the institution’s business model This impact and its materiality will have to be determined by the institution itself in its materiality analysis.
Table showing examples of how climate and environmental risks feed through to the risk profile of an electronic money or payment
institution (non-exhaustive)
Risk channel Subtype Operational risk
Physical Acute or chronic Serious climate and environmental events can damage the premises, data centres and operations, among others, of an electronic money or payment institution. Transition Policy, technology and market sentiment New policy/technology and changing market sentiment with regard to climate and the environment may put pressure on the reputation of an electronic money or payment institution, for example with regard to the fulfilment of climate targets such as aiming for climate-neutral operation by 2050. Back to main text
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Legislative framework for pension funds The legislation and regulations governing pensions are laid down in the Pensions Act, the Pension Fund (Financial Assessment Framework) Decree, the Pensions Act and Obligatory Occupational Pension Schemes Act Implementing Decree and the Financial Supervision Act. Whereas the main text of the Guide specifically concerns climate and environmental risks, the legislation speaks of: “risks arising in the field of the environment and climate, human rights and social relations”. This scope is broader, and in line with the scope applied by EIOPA in IORP II, namely “ESG factors”. ESG stands for Environmental, Social and Governance factors. For example, following the implementation of the IORP II Directive in the Pensions Act in early 2019, pension funds have been obliged to incorporate ESG risks in the risk management framework and their own risk assessment. Pension funds must also state in their annual reports how they take account of ESG factors in their investment policy and must share this information more widely under the SFDR – for example on their website. In 2019 EIOPA published an opinion with explanatory notes for supervisory authorities on what they can expect from pension funds with regard to the management of climate risks. As far as DNB is concerned, the good practices of pension funds are good examples of ways to comply with the above legislation while also fulfilling the focal points in
Chapter 4. The good practices refer explicitly to the legal articles in some places.
The following page provides an overview of relevant legislation relating to ESG.
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management
Section 5:68 of the Financial Supervision Act
and Section 21a of the Market Abuse
(Financial Supervision Act) Decree.
Pension funds are subject to one explicit prohibition: on investing in companies involved in the production of cluster munitions. Sections 18 and 18b of the Pension Fund (Financial Assessment Framework) Decree. The risks relating to the environment and climate, human rights and social relations in the investment portfolio and their management are included in a pension fund’s risk management. As a long-term investor, a pension fund will have to deal directly with the impacts of environmental, economic or social developments on the future value of investments. The associated risks are therefore
part of the risk management and the own-risk assessment.
Section 21 of the Pensions Act and Section 48
of the Obligatory Occupational Pension
Schemes Act, Section 2 of the Pensions Act Implementing Decree The employee or participant receives basic information about the pension scheme (Pension 1-2-3) within three months of the start of pension accrual. Section 2 of the Pensions Act and Obligatory Occupational Pension Schemes Act Implementing Decree states what is meant by this, such as information on how the pension fund takes account of the environment and climate, human rights and social relations in its investment policy.
Section 135 (4) of the Pensions Act and
Section 130 (3) of the Obligatory Occupational
Pension Schemes
Act
A pension fund must state in its management report how its investment policy takes account of the environment and climate, human rights and social relations. An accountability body (Section 115a of the Pensions Act and Section 110e of the Obligatory Occupational Pension Schemes Act) or stakeholder body (Section 115c of the Pensions Act) of a pension fund has authority to give an opinion on the management board’s actions on the basis of the management report, the financial statements and other information, including the findings of the internal supervision on the policy implemented by the management board, as well as on policy choices for the future.
Section 145 (1) of the Pensions Act, Section
29b of the Pension Fund (Financial Assessment Framework) Decree The statement of investment principles includes the way in which the investment policy takes account of the environment and climate, human rights and social relations. This could include the way in which energy consumption, climate, raw material availability, health, safety and good corporate governance are taken into account in the investment policy.
Section 33 of the Pensions Act; Section 42
of the Gatekeeper Improvement Act;
Section 11 of the Pensions Act Implementing
Decree, Gatekeeper Improvement Act
(Pension Funds Code)
Pension funds are required to report on compliance with the Pension Funds Code in their annual report. If a provider has not complied with the principles or does not intend to comply with them in the current and subsequent financial year, it must state the reasons in the management report. Among other things, the Pension Funds Code requires management boards to ensure stakeholder support for responsible investment choices. Back to main text
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Impact of climate and environmental risks on pension funds The table below shows an example of how climate and environmental risk factors can affect existing financial and non-financial risk areas of a pension fund. The same risk factor can affect several risk areas simultaneously. The table is intended purely as an illustration to provide a starting point for the materiality analysis. The ultimate impact will depend among other things on the scale and distribution of physical and transition risks, like the pension fund’s business model. This impact and its materiality will have to be determined by the institution itself in its materiality analysis.
Table showing examples of how climate and environmental risks feed through into a pension fund’s risk profile (non-exhaustive)
Risk channel Financial risk Reputational risk Social risk Physical Damage to property and assets in high-risk locations. Global warming is having a negative impact on the liveable world. Transition Depreciation of assets of carbon-intensive companies due to policy measures such as carbon tax/ negative impact on revenue model of companies due to product substitution (e.g. car industry). Participants’ preferences are changing; they do not want to invest in fossil energy or carbon-intensive sectors. Back to main text
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practices for management of climate and environmental risks by pension funds 21 The good practice has been written from the perspective of a pension fund operating a defined benefit agreement. However, the good practice also provides guidance on risk management for premium pension institution or pension fund with a defined contribution plan.
1. Business model and strategy
Good practice: identifying the impact of climate and environmental risks on the business environment and business model A pension fund board21 (“board”) wants to know the impact of climate and environmental risks on its business environment and business model. It wants to include this impact in its strategic investment policy and risk management cycle. In order to gain a fuller understanding, the board analyses the shortand long-term impacts of climate change, deforestation and biodiversity loss on its investments. The investments are broken down by sectors with sufficient granularity to allow relevant impact analysis. The board also looks at opportunities to invest in sectors that invest in new technology, for example. In addition to the impact that climate and environmental risks have on investments on the balance sheet, the board examines which risks its investments actually create for the climate and the environment, known as “double materiality” or “social risk”. The increased attention that participants and society pay to these risks may lead to reputational risk or lawsuits concerning the investment policies pursued. Mitigating measures considered for social risk include signing the IMVB Covenant or the Paris Agreement targets. However, these can also be an additional source of risk. If the board fails to honour the signed commitments, this may lead to a loss of support among the participants and hence additional reputational and legal risk. The board must also bear in mind possible dilemmas that may surface during a broad impact analysis. An investment that has a positive impact on carbon reduction may simultaneously have an undesirable negative impact on social aspects, for example, resulting in reputational risks. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: surveying participant preferences In determining the social risk that the pension fund is prepared to accept, the preferences of its members are an important variable. The pension fund therefore conducts period surveys and panels on participants’ investment preferences with regard to climate and environmental risks. These show that a large proportion of participants do not want the board to invest on their behalf in companies that (i) have high carbon emissions, (ii) do not invest in cleaner technology, (iii) produce controversial weapons or tobacco, (iv) damage biodiversity or (v) operate in countries that violate human rights. Furthermore, a large proportion of participants want the pension fund board to sign the climate agreement. In response to these preferences, the fund decides to put more companies on the exclusion list and to seriously consider signing the climate agreement. As the board is ultimately responsible for the investment policy, it makes its own assessment based on the results of the participant survey and is transparent about them. In a newsletter to participants, the board presents the results of the participant survey, how the board takes preferences into account in its policy choices and reports on their impact. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Targets:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: ensuring that policymakers are fit to manage climate and environmental risks A board has drawn up minimum requirements in terms of knowledge of climate and environmental risks and opportunities for the management board and the supervisory board of a pension fund. These minimum requirements have been incorporated in the job profiles The management board has adopted the principle that it and the supervisory board have insight into and an understanding of the key developments in the field of climate and the environment, the related legislation and regulations, what society and stakeholders expect from the institution and what that means for operational management. With a view to maintaining an adequate level of knowledge, the management board of another pension fund periodically organises knowledge sessions on climate and environmental themes for the management board, the supervisory board and the key function holders in risk management, actuarial and audit. Discussions are also held with several asset managers to broaden their perspective. Topics include the causes of climate change, laws and regulations, national and international climate policies, standards and frameworks, and the use of models and scenario analyses for climate and environmental risks. External experts are regularly invited to these knowledge sessions, to train and “challenge” session participants to pinpoint the climate and environmental risks and opportunities for the institution. The management board and the supervisory board periodically evaluate whether the knowledge standards are being met and identify where is a need for training and education. The management board of a third pension fund establishes an advisory board with external and internal experts to gather knowledge, experience and advice on integrating climate risks and opportunities into policy frameworks on a more permanent basis.
2. Governance
We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: assigning responsibilities for climate and environmental risk management within the organisational structure The pension fund board has clearly formulated the responsibilities of all bodies in terms of climate and environmental risk management and in the SRI policy, as shown in Table 1.
Table 1: example of assigning responsibilities for climate and environmental risk management within a pension fund.
Bodies Responsibility Process
Management board The management board discusses how best to assign the responsibilities for climate and environmental risks. The board has joint (ultimate) responsibility for the SRI policy and its implementation. One director is the portfolio holder for the Climate theme. The board discusses the SRI policy and its implementation at least quarterly. This includes the following subjects:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
3. Risk management
Good practice: formulating an ESG risk appetite A pension fund has formulated a qualitative ESG risk appetite with regard to the pension fund’s reputational, compliance, operational and financial risk. The pension fund’s formulation for reputational and financial risk is set out below. Reputational risk appetite 1: “We have a low risk appetite for exposure to reputational risk arising from investments that the fund board and participants find morally objectionable.” Reputational risk appetite 2: “We have a medium risk appetite for reputational risk arising from non-compliance with the IMVB Covenant.” Financial risk appetite: “Climate change and biodiversity loss must not have a major impact on the financial position of the pension fund.” Social risk appetite: “We have a low risk appetite for failure to fulfil the Paris Agreement.” We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks The following table shows a number of risks from the shortlist (non-exhaustive)::
We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks pension balance sheet is complex and inevitably involves uncertain assumptions. It is prudent is to take sufficient account of uncertainty when making the assumptions.
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Based on these assessments, the pension fund has set all three (gross) risks at high.
Table 6
ESG risk Risk Risk appetite Within appetite? Risk response Notes
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks for example by conducting an investment policy aimed at outperforming a benchmark in terms of its ESG score or carbon footprint. Such an approach may fit in with a sustainable investment policy and may lower the risk profile (relative to the benchmark).
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: frequent evaluation of the entire ESG risk management cycle The pension fund decides to evaluate its ESG risk management on an annual basis. Is the list of identified risks still complete? Is the materiality estimate of risks still correct? Is the impact of the risks being properly measured? Are the mitigation measures effective? Is the exclusion list still appropriate? We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
4. Information provision
Good practice: setting up an appropriate data infrastructure for climate and environmental risks Some time ago, following a gap analysis, a pension fund board started setting up a data infrastructure and collecting data required to analyse risks and opportunities of climate and environmental change. It started by measuring the carbon footprint of its investments. The pension fund board decided to adhere to internationally recognised methodologies, such as that of PCAF (Partnership for Carbon Accounting Financials). For its investments it uses an external data provider in accordance with the PCAF methodology. The carbon footprint data is used internally for decision-making, such as optimising the investment mix. The pension fund board takes into account the carbon footprint of different asset classes in its strategic investment policy. The carbon emission data is also used for external reporting, such as the annual report, in order to comply with EU legislation and regulations on Environmental Taxonomy (SFRD). Here too the pension fund board uses a data vendor and the NACE code22 can be used to determine the extent to which the business activities of its investments are “green”. 22 The NACE code is a code assigned by the European Union and its member states to a certain class of commercial or non-commercial economic activities. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Legislative framework for insurers In addition to the legal framework in the main text of the Guide, the European Delegated Regulation (EU) 2015/35 (Solvency II Delegated Regulation) – which has direct effect – is also relevant to insurers falling within the scope of the Solvency II Directive. Whereas this Guide specifically concerns climate and environmental risks, Solvency II refers to sustainability risks. This includes social and governance risks in addition to climate and environmental risks. The European Commission amended parts of the Solvency II legislation in 2021. This led to an amendment to Delegated Regulation (EU) 2015/35 (Solvency II Delegated Regulation) with regard to the integration of these sustainability risks in insurers’ governance and risk management. The amendments came into force on 2 August 2022 and concern the following articles:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Impact of climate and environmental risks on insurers The table below shows an example of how climate and environmental risk factors can affect an insurer’s existing financial or non-financial risk areas. The same risk factor can affect several risk areas simultaneously. The table is intended purely as an illustration to provide a starting point for the materiality analysis. The ultimate impact depends among other things on the scale and distribution of physical and transition risks, like the insurer’s business model. This impact and its materiality will have to be determined by the institution itself in its materiality analysis.
Table showing examples of how climate and environmental risks feed through into an insurer’s risk profile (non-exhaustive)
Risk Subtype Market risk Underwriting risk Operational risk Business model & strategy Physical Acute or chronic Prolonged droughts and floods can result in loss of value of investments and can increase volatility in commodity markets, for example. Extreme rain and hail storms or flooding of secondary flood defences can result in insurance claims. Extreme weather can pose a threat to insurers' buildings and operations. Climate change may cause large price increases for non-life insurance and possibly lead to risks becoming uninsurable. This may affect the viability of the insurer. Transition Policy, technology, market sentiment, reputation Changes in climate and environmental policy, disruptive technologies and changing market sentiment may lead to stranded assets in carbon-intensive industries and other turmoil in financial markets. Additional claim risk due to over-representation of liability insurance in carbon-intensive industries, for example. Reputational risk and social pressure if climate targets are not sufficiently concrete or ambitious and do not match actual practice. New regulations may make it impossible to supply products or services to “brown” operators, affecting the insurer's results. Back to main text
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practices for management of climate and environmental risks of Insurers 23 A business-as-usual scenario can be interpreted as “a scenario in which no additional climate change mitigation policies are implemented; this would be a scenario in which physical risks will likely increase significantly in the long run”. Source: Network for Greening the Financial System (NGFS), June 2020, Guide to climate scenario analysis for central banks and supervisors.
1. Business model and strategy
Good practice: using scenario analysis in strategic planning The management board of the insurer wants better insight into the material negative impact and opportunities of climate change in order to incorporate them in its strategy. In line with the TCFD recommendation, scenario analysis is used as part of the strategic planning. The institution opts for scenarios based on global qualitative and quantitative changes, drawing inspiration from the scenarios of the IPCC and the International Energy Agency. It takes the twodegree warming scenario in 2050 and compares it with the business-as-usual23 situation. To streamline the discussion, external experts with diverse backgrounds are invited. For each scenario, the board considers the strategic position for the company as a whole and, for each market segment, considers how to deal with it in terms of premium setting and product development. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: a non-life insurer integrates climate risk into its strategy The management board of an insurer draws up a company-wide strategy for the medium to long term. Addressing the impact of climate change on the organisation and its environment is high on its priority list. The insurer adjusts its product range and investments accordingly. After analysing existing frameworks and initiatives, the insurer chooses to conform to a number of frameworks. The sustainability principles are derived from the United Nations Global Compact (UNGC). For its investments, the insurer bases itself on the Net-Zero Asset Owner Alliance, the Sustainable Development Goals (SDGs) and the Dutch financial sector’s Climate Commitment. The reporting is based on the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD). For the pricing of insurance products, the insurer aims to take into account climate adaptation measures such as toughened glass in greenhouses. In its ESG strategy, the insurer has set the goal of reducing the carbon footprint of investments to net zero by 2050. This goal is translated into climate performance indicators, linked to SDG 13 “Climate Action”, among others, which the board uses to monitor progress and determine whether the strategy needs to be adjusted. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
2. Governance
Good practice: policymakers embed material climate and environmental risks in existing governance and policy frameworks The management board and supervisory board of an insurer have assigned the risks and opportunities related to climate and environment to the portfolio of a management board member and a supervisory board member. The portfolio holders are supported by a task force consisting of a management board member, a supervisory board member, a senior manager and an external advisor. The management board and the supervisory board consider further integration of climate and environmental risks and opportunities into existing frameworks and processes within the institution to be necessary, and to this end have set up a specific management board and supervisory board committee for climate and environmental risks and opportunities, in which managers with expertise in managing these risks and external experts in the field participate in addition to a number of management board and supervisory board members. This committee informs the management board and the supervisory board of the results of its deliberations and considerations. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider these good practices because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: promoting awareness of climate and environmental risks In addition to the knowledge sessions and training courses aimed at increasing knowledge of climate and environmental risks, the management board of an insurer has appointed “ambassadors” in parts of the organisation where climate and environmental risks arise. These ambassadors are tasked with raising climate awareness within the organisation. The ambassadors discuss sustainability initiatives on a quarterly basis to update each other on developments in their part of the organisation. This ensures an integrated approach to climate and environmental aspects. These discussions are chaired by the sustainability manager. The results of the discussions are shared with the director whose portfolio includes sustainability and the management of climate and environmental risks. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
3. Risk management
Good practice: explicitly including climate and environmental risks in existing risk appetite framework An insurer has translated the defined risks (see Chapter 1) due to climate and environmental change into existing risk categories. For example, the physical and transition risk of investments has been assigned to “market risk” and the “reputational risk” category has been expanded to include the risk of climate commitments not being met. The insurer has defined as its strategic principle that it wants demonstrable social value through its insurance and investment activities, with the interests of stakeholders (particularly the policyholder) having the highest priority. The insurer therefore decides to monitor the “ESG effect” over the next three years by benchmarking against the portfolio used in the recent ALM / SAA24. It agrees to subsequently examine the ESG effect and to take possible actions on that basis. The strategy is specified in the risk appetite as follows:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: using scenario analyses and stress tests to estimate the exposure to climate and environmental risks Example (building on the example above) The insurer creates a working group made up of first- and second-line members to develop a feeling for the probability of climate risks as well as their impact. In line with the outcomes of the ORSA (conducted in line with DNB's 2019 Q&A), the working group assesses the likelihood and impact of physical and transition risks and reputational damage if climate or environmental targets are not met. For the probability and impact of the risks it uses a scale with four levels:
low, medium, high and very high.
Probability Impact
Low:
interval greater than 10 years
Low:
financial loss (<€10k) and reputational damage; no actions by supervisory authority. Medium:
interval 5 to 10 years
Medium:
financial loss (€10-100k); some reputational damage; single measure by supervisory authority High:
interval 1 to 5 years
High:
financial loss (>€100k) or reputational damage; more severe measure by supervisory authority Very high:
interval less than 1 year
Very high:
financial loss (>€1m) or major reputational damage; severe measures by supervisory authority The risk matrix is then used to estimate the gross risk. Gross risks Probability Impact Low Medium High Very high Low Medium High Very high Mitigation depends on the gross risk score. Low Acceptable risk; normal attention Medium Tolerable risk; additional monitoring High Worrying risk; short-term management Very high Unacceptable risk; direct management The observation leads to a matrix of probability and impact and the final scores for the gross risks. The gross risk for extreme weather has a medium score. In the actions, we see that the investment risk associated with carbon taxes in the short term and the reputational risk in the case of deviations between ambition and practice need to be mitigated immediately.
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: using scenario analyses and stress tests to estimate the exposure to climate and environmental risks To gain an idea of the impact of transition risk associated with climate change, the institution draws up a transition scenario that translates the changing climate and environment into conventional risks such as market and underwriting risk. The scenario is modelled on scenarios’ from the DNB transition stress test27. The scenario involves an abrupt, disorderly transition to a climate-neutral economy. Government intervention causes the carbon emission price to surge and the value of carbon-intensive investments to fall. This scenario is applied to the entire balance sheet to determine the impact on the financial position. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: frequent evaluation of the climate and environmental risk management cycle The insurer integrates the climate and environmental risks in its risk management cycle. To understand the steps needed to improve the risk management, the insurer conducts scenario analyses and a gap analysis. The differences between the current and desired state lead to a number of actions. The table below contains examples from this action list. Cycle Description Risk Risk level Action Time limit Identification ESG data from two sources is used. The ESG data can be improved by adding additional sources. Reputational damage due to a possibly incomplete picture of ESG risks. Investigate expansion of sources for ESG data. 1 year Identification No attention is paid to the social or S component of ESG. Reputational damage because profiling as an ESG insurer does not match practice. Expand scope of risks to include 'S'. Start with exploratory research. 3 years Risk attitude There are no scenarios for biodiversity loss; this must be remedied rapidly. Financial risk due to investments dependent on animal pollination. Develop risk attitude, (qualitative) risk appetite and a scenario for biodiversity loss. 6 months Assessment Available data on insured properties is insufficient for flood risk. Underwriting risks due to incomplete picture of insured risks. Expanding location and vulnerability data 1 year Mitigation Asset manager’s exclusion policy does not match the desired exclusions. Reputational damage caused by difference between stated ambitions and practice. Examine role of exclusions in mitigating climate risks. Coordination with asset manager and exploration of alternatives. 2 years Mitigation The exclusion policy in one scenario allows losses greater than the risk tolerance. Reputational damage due to nonfulfilment of ambitions and financial risk due to unknown large exposure. Refine exclusion policy. 3 months We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks
4. Information provision
Good practice: setting up an appropriate data infrastructure for climate and environmental risks Some time ago, following a gap analysis, an insurer started setting up a data infrastructure and collecting data required to analyse the risks and opportunities of climate and environmental change. It started by measuring the carbon footprint of its investments. In doing so, the insurer decided to align with internationally recognised methodologies, such as that of PCAF (Partnership for Carbon Accounting Financials). For its corporate bonds and loans it uses an external data provider in accordance with the PCAF methodology. The carbon footprint data is used internally for decision-making, for example to optimise the investment mix. The insurer takes the carbon footprint of the different asset classes into account its strategic asset allocation. The carbon emission data is also used for external reporting purposes such as the annual report in order to comply with EU legislation and regulations on the Environmental Taxonomy (NFDR/CSRD). Here too the insurer board uses a data vendor and the NACE code28 can be used to determine the extent to which the business activities of its investments are “green”. The insurer recognises that more data is needed to price its products correctly, such as data on the location of properties insured against flood risks. 28 The NACE code is a code assigned by the European Union and its member states to a certain class of commercial or non-commercial economic activities. We consider this a good practice because:
Introduction Legislative framework and applicability Climate and environmental risks Contents Sectors Focal points for management Introduction Contents Sectors Legislative framework and applicability Climate and environmental risks Good practice: external reporting on non-financial information In the annual report, an insurer devotes attention to non-financial information in addition to financial information, striving for integrated reporting and complying with the Global Reporting Initiative (GRI) standard. The insurer reports on how it addresses climate change in accordance with, among others, the Decree laying down further rules on the content of the annual report, the Decree on disclosure of non-financial information and the EU Non-Financial Reporting Directive (NFRD). The insurer provides disclosures under the double materiality principle29 in the NFRD Directive In doing so, it considers the impact of climate change on financial risks on the one hand and the insurer’s impact on people and the environment on the other. The insurer also reports periodically on how investments meet sustainability targets in accordance with the Sustainable Finance Disclosure Regulation (SFDR). The insurer also reports on its progress in complying with the Principles for Sustainable Insurance, to which it has committed. The insurer is transparent about the potential impact and effect, and about the way in which the management has taken these results into account. The institution has asked the external auditor to report inconsistencies in the reported sustainability information. See also:
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Source: De Nederlandsche Bank — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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