2020年改進歐盟非財務報告中與環境和氣候相關的信息披露 - CDSB（英文版）（18頁）.pdf

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1、Falling short? Why environmental and climate-related disclosures under the EU Non-Financial Reporting Directive must improve May 2020 Falling short? Exective summary 01 Executive summary CDSB has reviewed the 2019 environmental and climate-related disclosures of Europes 50 largest listed companies,

2、with a combined market capitalisation of US$4.3 trillion, under the EU Non-Financial Reporting Directive (NFRD also referred to as the Directive). The purpose of this report is to inform policymakers of the changes needed to improve environmental disclosures under the Directive, to ensure it meets i

3、ts purpose of increasing the relevance, consistency and comparability of company reporting. It also aims to support corporate report preparers in enhancing their disclosures under the Directive by identifying good practice case studies and tips, drawn from the findings of CDSBs review. Supported by

4、the LIFE Programme of the European Union, the review consisted of a question set developed by CDSB to assess the strengths and weaknesses of companies disclosures. This was based on consideration of the core content categories of the NFRD (i.e. business model, policies and due diligence, outcomes, p

5、rincipal risks and key performance indicators), and reviewing progress in implementing the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). Mainstream reports (i.e. annual report and accounts) were reviewed, alongside information disclosed elsewhere where it was cle

6、arly referenced from the mainstream disclosure. The current state of EU environmental and climate-related disclosure Overall, our review shows some signs of improvement in the environmental and climate-related disclosure of Europes largest companies. The vast majority now provide at least some discl

7、osure aligned to the content categories of the NFRD. However, we find that reporting often still fails to offer investors a clear understanding of companies development, performance, position and impact, as it lacks the necessary quality, comparability and coherence. In the absence of this, investor

8、s remain unable to fully integrate environmental and climate- related considerations into their decision-making. Additionally, although some sectors showed demonstrable progress in adoption of the TCFD recommendations, overall implementation continues to lag behind the five-year implementation path

9、set out by the Task Force. Given that these observations are true of Europes 50 largest listed companies, who could reasonably be expected to provide the highest quality disclosures, it is therefore clear that the current requirements of the NFRD are not yielding the outcomes desired from the Direct

10、ive. CDSB is an international consortium of business and environmental NGOs. We are committed to advancing and aligning the global mainstream corporate reporting model to equate natural capital with financial capital. We do this by offering companies a framework for reporting environmental informati

11、on with the same rigour as financial information. In turn, this helps them to provide investors with decision-useful environmental information via the mainstream corporate report, enhancing the efficient allocation of capital. Regulators also benefit from compliance-ready materials. Recognising that

12、 information about natural capital and financial capital is equally essential for an understanding of corporate performance, our work builds the trust and transparency needed to foster resilient capital markets. Collectively, we aim to contribute to more sustainable economic, social and environmenta

13、l systems. For more information, visit or follow the Climate Disclosure Standards Board on LinkedIn and Twitter CDSBGlobal We welcome your input and discussions. If you would like to comment on this document, please contact us at . About the Climate Disclosure Standards Board (CDSB) Copyright 2020 C

14、limate Disclosure Standards Board (CDSB) and CDP Worldwide (Europe) gGmbH. All rights reserved. Dissemination of the contents of this report is encouraged. Please give full acknowledgement of the source when reproducing extracts in other published work. All information in this report is provided wit

15、hout warranty of any kind, express or implied. The authors disclaim any responsibility for the information or conclusions in this report. The authors accept no liability for any loss arising from any action taken or refrained from being taken as a result of information contained in this report. Stre

16、ngths 1.KPIs 2. Policies and due diligence 3.Business model Weaknesses 1. Principal risks 2.TCFD 3.Materiality process Risk matters Risk disclosures relating to environmental and climate- related matters were highlighted as a key weakness for over three quarters of companies reviewed. Whilst 90% of

17、companies did disclose at least one principal risk relating to climate or environment, only 54% considered both transition and physical risks as outlined in the TCFD recommendations, and just 6% defined the short, medium and long-term time horizons over which the identified risks would impact the or

18、ganisation. Many companies failed to consider the strategic and financial impacts of risks for their business, assessing only the impact of their business on the environment and climate, demonstrating that they have yet to adopt fully the risk lens set out in the TCFD recommendations. Materiality ma

19、tters Our review found that 42% of companies omitted potentially material environmental or climate-related information for their sector, while 30% disclosed immaterial information that was not aligned to their own materiality assessments, policies or principal risks. Just 4% currently use financial

20、materiality to determine the environmental and climate-related content included in their mainstream reports. A lack of focus on investor materiality is likely to have contributed to some of the challenges identified in this review, including considering the impacts of principal risks on the business

21、, the absence of indicators that link financial and non-financial information, and lengthy disclosures which attempt to address the needs of too many stakeholders. For each company CDSB reviewed, the top 3 strengths and weaknesses of the disclosure were recorded and categorised, demonstrating a clea

22、r pattern in areas of good practice and improvement. The most commonly identified strength and weakness categories are presented below: Recommendations Building upon the findings of our review, we put forward recommendations for policymakers and regulators and for companies, to ensure that the NFRD,

23、 and corporate disclosures made under it, deliver the information needed to drive meaningful progress in delivering the EU Green Deal. Key findings Overall, our findings highlight that substantive improvements are still required in the quality, comparability and coherence of disclosures in order for

24、 the Directive to achieve its objective of providing investors and wider stakeholders with relevant, consistent and decision-useful disclosures. Falling short? Exective summary 0302 Falling short? Exective summary Business model Only 3 in 10 companies fully disclose the environmental and climate-rel

25、ated aspects of their business model Outcomes All companies reported some types of outcomes, however, variations in disclosure format limit the comparability of information, both between companies and over time Policies and due diligence Companies demonstrated confusion over key terms from the Direc

26、tive and often failed to provide context-specifi c information on their policies and processes Principal risks 9 in 10 disclosed their principal environmental and climate-related risks, but 1 in 5 disclosed no related operational, strategic or fi nancial impacts Key performance indicators Less than

27、1 in 3 companies reported metrics directly linking environmental and fi nancial activities and performance TCFD While companies in the fi nancial and energy sectors showed progress in aligning to the TCFD, few disclosed their overall resilience to diferent climate scenarios Materiality 1 in 3 compan

28、ies failed to clarify how the materiality of environmental and climate-related information in the mainstream report had been determined Disclosure location 4 in 5 companies included their non-fi nancial statement in their mainstream report ! The European Commission is currently reviewing the NFRD, c

29、onsidering options to enhance its effectiveness in ensuring investors, civil society and other interested parties have access to the information they need. Drawing upon the findings of our review, CDSBs recommendations for policymakers and regulators should be adopted in the revised Directive to sup

30、port improved effectiveness: 1. Remove the exemption allowing the non-financial statement to be reported outside the mainstream report, as this will support accessibility, consistency and comparability of disclosures and our review demonstrates that, for most, this is already the norm; 2. Review the

31、 principal risk requirements of the Directive to ensure emphasis is placed on risks and impacts to the business (not simply by the business). Member State policymakers should consider the interface between the NFRD and other risk disclosure requirements implemented nationally to support companies in

32、 making cohesive disclosures; 3. Incorporate climate into the wording of the Directive to ensure companies consider climate-related matters explicitly in their disclosures, including the associated financial impacts; 4. Define key terms used in the Directive, such as policies and due diligence to en

33、sure a common understanding and application of the Directives content categories; 5. Embed the TCFD recommendations into the Directive to drive stronger linkage of non-financial and financial reporting, and a more unified, harmonised and convergent approach; and 6. Ensure that supervision of non-fin

34、ancial information is at the same level as for financial information, in order to provide authoritative feedback to corporate report preparers. Recommendations for policymakers and regulators As companies prepare their next annual disclosures, they should closely consider the findings of CDSBs revie

35、w and the good practices highlighted in this report, to identify opportunities to further improve their reporting, taking into account the following points: 1. Ensure linkages are drawn across the Directives content categories. Use your policies to structure and inform your programmes; report clearl

36、y and simply against your progress in achieving them; 2. Clarify the materiality of environmental and climate-related issues to your business, explaining how your mainstream, and wider sustainability reporting if appropriate, is informed by your view on materiality; 3. Disclose environmental and cli

37、mate-related information deemed to be financially material in your mainstream report, to ensure it is available to an investor audience and can be considered holistically alongside your overall strategic and financial performance; and 4. Align your environmental and climate-related disclosures with

38、the TCFD core elements, ensuring that risks and opportunities from climate change over the short, medium and long-term have been assessed and that you have considered the resilience of your organisation under different climate scenarios. Recommendations for corporate report preparers Contents Introd

39、uction Introduction 05 Findings part 1: Environmental disclosure under the NFRD content categories a) Business model 08 b) Policies and due diligence 10 c) Outcomes 12 d) Principal risks 14 e) Key performance indicators (KPIs) 17 Findings part 2: TCFD and additional considerations TCFD disclosures o

40、f Europes largest companies 21 Materiality 23 Location and format of disclosures 24 Conclusions and recommendations Conclusions 26 Recommendations 27 Appendices Appendix 1: Methodology 29 Appendix 2: List of companies reviewed 30 References 31 To answer these questions, CDSB reviewed the 50 largest

41、listed European companies 2018 reporting (published in 2019 for the 2018 financial year) and assessed in detail the environmental and climate-related content. The review was conducted manually by a set of expert reviewers using questions built around the requirements of the Directive alongside the r

42、ecommended disclosures of the TCFD. Further detail on the methodology and review sample can be found on page 29. This report sets out the key findings of our review, structured according to the core content categories of the Directive (i.e. business model, policies and due diligence, outcomes, princ

43、ipal risks and KPIs), with sections considering the aspects of TCFD, materiality and disclosure location and format in further detail. Throughout the report, good practice examples, good practice tips for report preparers, and proposals for policymakers and regulators are provided by content categor

44、y. Our key recommendations for policymakers, regulators and companies are provided on page 27, intended to support both the upcoming revision of the NFRD over 2020, and ongoing improvement in disclosures by corporate report preparers in the interim. In 2019 European companies published their second

45、annual disclosures under the EU Non-Financial Reporting Directive (NFRD, also referred to as the Directive). Since entering into force in 2017, the Directive has required certain large companies across Europe to prepare a non-financial statement disclosing their business model, policies, outcomes, p

46、rincipal risks and key performance indicator (KPIs) on a range of non-financial topics, including but not limited to environmental mattersi. The Directive provided for inclusion of the non-financial statement within the management reportii, however it also included an exemption allowing for disclosu

47、re in a separate report, providing it was published within six months of the management report. In November 2018, CDSB released its first review of corporate environmental and climate-related disclosures under the NFRD, commonly referred to as the First Steps Report1, finding that concerted action w

48、as required by policymakers, regulators and companies to provide better quality information to investors and markets. It then set out recommendations to achieve this. Building upon the approach of the First Steps Report, this review set out to assess progress made by European companies in disclosing

49、 environmental and climate-related information in the second year of reporting under the Directive. It aimed to provide an update on the level of alignment to the core content categories of the Directive, but also to consider the quality of such disclosures in greater detail, to assess if the NFRD in its current form meets its objective of providing investors and wider stakeholders with decision-useful sustainability information. Since the release of the European Commissions (EC) guidelines on reporting climate-related information in Jun