This is the time of year when corporate directors sweat. They are anxiously finalizing the annual report and proxy materials that will present the company’s financial results and risks for all to see.
This year directors have an added challenge: meeting investor expectations to disclose material climate-related risks.
The pressure from investors is real. Blackrock, one of the world’s largest asset managers, sent letters to 120 companies urging them to disclose material financial risks related to climate change and is making climate-risk disclosure one of it’s “engagement priorities” this year.
How does a board begin to disclose something as new as climate risk?
Most will start with the Task Force on Climate-related Financial Disclosures (TCFD). Its June 2017 report offered detailed recommendations and a technical appendix on the use of scenario analysis to describe climate risks.
Still, even the most well-intentioned companies will find it challenging to implement all of the TCFD recommendations. Many can take the first steps though, by presenting their governance and risk-management processes and describing how they measure and monitor climate-related risks.
After all, they have done something like it before. This isn’t the first time a prominent private-sector group has offered guidance on how companies can present a complex financial risk.
The Group of Thirty did so in 1993, when the “new” risk involved financial instruments called derivatives.
Chaired by Paul Volcker, former head of the Federal Reserve, and J.P. Morgan CEO Dennis Weatherstone, the Group of Thirty Task Force on Global Derivatives has been forgotten by just about everyone except finance professors and the nerdiest risk managers. But it served an important purpose in its time, just like the TCFD today.
Indeed, what Volcker said in the report about derivatives risk in 1993 could apply just as well to climate risk in 2018:
“[T]here can be no doubt that each organization’s conscious and disciplined attention to understanding, measuring, and controlling risk along the lines suggested should help ensure that the risks to individual institutions and to markets as a whole are limited and manageable. To that end, the Study’s first recommendation emphasizes the role of senior management.”
The Group of Thirty Task Force was a global group of practitioners formed at the urging of central banks and international policymakers – just like the TCFD. Most significantly, it introduced a methodology – known as “Value at Risk” (VaR) – that became the foundation for measuring, monitoring and reporting financial risk. In the same spirit, the TCFD introduced Scenario Modeling as a methodology for managing climate risk.
The Group of Thirty report marked the beginning of a formal, integrated function for financial risk management, not only for banks and financial firms, many of which had the role in some form, but for ordinary corporations. The TCFD report seems likely to do the same for climate risk management.
There’s another example, too. In more recent years, public companies have made increasingly detailed disclosures about executive pay. That experience can provide a pathway for communication on climate risks.
Compensation disclosures have become more informative and useful. Many incorporate strong design principles, relevant data and clear language, which are essential for winning investor support. Ultimately, corporate boards will seek to accomplish precisely these things when presenting material climate-related financial risks.
Over time, climate disclosure seems likely to bring about broader changes in the way companies communicate about climate risk. Themes, metrics and messages about climate will be more consistent across financial reports, investor presentations, websites and other materials.
There will be less use of the vague, boilerplate language that passes for climate reporting today.
And for companies that want to seize a leadership position on this issue, climate will be discussed as a strategic opportunity and not simply as an operating risk or compliance task.
The investment discussion will broaden, too, as climate risk considerations become part of the evaluation process for mainstream portfolio managers and not simply those running specialty ESG funds.
Better disclosure of material climate risks is the first step.