歐洲銀行管理局：2020年可持續金融報告（英文版）（48頁）.pdf

1、 EBA STAFF PAPER SERIES N. 6 JANUARY 2020 SUSTAINABLE FINANCE MARKET PRACTICES by Adrienne Coleton, Maria Font Brucart, Pilar Gutierrez, Fabien Le Tennier incorporation of sustainability into business strategies; governance, policies and risk management applicable to ESG risks; ESG and climate-relat

2、ed disclosures; and green financial products. KEYWORDS ESG, ESG risks, sustainable finance MARKET PRACTICES SUSTAINABLE FINANCE Page 3 EBA STAFF PAPER SERIES CONTENTS Introduction 5 Initiatives to date 5 Why are banks reacting to the sustainable finance issue? 6 Definitions of environmental, social

3、and governance criteria 7 Definitions of ESG factors 8 International initiatives 8 Banks own definitions of ESG factors 10 Are there common definitions? 10 Strategy 11 Incorporation of sustainability into business strategy 11 Direct and indirect impacts of activities financed by banks 13 Challenges

4、14 Governance, policies and risk management 15 Environmental, social and governance risks 16 Approaches to risk management 16 Climate-related risk management by banks 17 Physical and transition risks 19 Time horizon 20 Scenario analysis 22 Disclosures 23 Environmental, social and governance disclosu

5、res 24 Climate-related disclosures 25 Implementation of the TCFD recommendations at international level 25 Implementation of TCFD recommendations at the EU level 27 Benefits and challenges of TCFD implementation according to EU banks 30 Commissions non-binding guidelines 31 Other comments raised by

6、institutions and the way forward 31 Green products 31 Green finance and development of a green financing framework 31 Market developments 33 Green bonds 33 Green assets/loans 33 External verification and ESG issuer ratings 34 The EBAs monitoring of green finance market developments 35 Green bond iss

7、ues 36 Green assets 38 Development of a green finance framework as a next step? 38 MARKET PRACTICES SUSTAINABLE FINANCE Page 4 EBA STAFF PAPER SERIES Conclusions 39 Annex 40 References 44 MARKET PRACTICES SUSTAINABLE FINANCE Page 5 EBA STAFF PAPER SERIES Introduction Sustainable finance has become p

8、art of the lexicon of both supervisors and financial institutions in recent times. It has been described as the provision of finance to investments taking into account environmental, social and governance considerations.1 To that end environmental considerations have been referred to as climate chan

9、ge mitigation and adaptation, as well as the environment more broadly and the related risks (e.g. natural disasters). Social considerations have been referred to as issues of inequality, inclusiveness, labour relations, investment in human capital and communities. Finally, the governance of public a

10、nd private institutions, including management structures, employee relations and executive remuneration, has a pivotal role in ensuring the inclusion of social and environmental considerations in the decision-making process.2 This paper aims to assess the understanding of environmental, social and g

11、overnance (ESG) considerations within the banking context and examines the current market practices in this area. To that extent this paper sets out the various definitions of ESG factors and also sets out how these then are converted into and treated as ESG risks. This paper relies upon the lessons

12、 learnt from a survey developed by the EBA to gain insights into current market practices with regard to credit institutions approach to incorporating ESG considerations into their frameworks. The survey, conducted from May - June 2019, especially aimed to collect information from credit institution

13、s on current practices in the following fields: definitions of ESG factors; incorporation of sustainability into business strategies; governance, policies and risk management applicable to ESG risks; ESG and climate-related disclosures; and green financial products. The survey was conducted on a vol

14、untary basis and yielded responses from 39 banks. The results referred to in this paper originate from that survey unless stated otherwise. In addition to this survey, this paper also relies upon publicly available information obtained from various institutions and bodies websites and reports, as we

15、ll as observations resulting from pilot studies and other initiatives. This work was undertaken with the underlying objective of gaining an understanding of market practices with regard to: (i) the development of a uniform definition of ESG risks; (ii) the development of appropriate quantitative and

16、 qualitative criteria for the assessment of the impact of ESG risks on the financial stability of institutions; (iii) the arrangements, strategies, processes and mechanisms to manage ESG risks; and (iv) methods and tools to assess the impact of ESG risks on lending and financial intermediation activ

17、ities. Initiatives to date The growing awareness of the area of sustainable finance has come about as part of a global response to climate issues. There has been reaction to this on international and European levels. From an international perspective, governments have agreed and committed themselves

18、 to ambitious targets, as outlined in both the Paris Agreement on climate change and the United Nations (UN) Sustainable Development Goals (SDGs). The 2015 Paris Agreement,3 which nearly 200 countries have agreed to, seeks to strengthen the global response to climate change in a bid to limit the inc

19、rease in global average temperature to well below 2C above pre- 1 See European Commission: https:/ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable- finance_en last accessed 1 October 2019 2 See https:/ec.europa.eu/info/business-economy-euro/banking-and-finance/green-finance_en

20、 last accessed 14 November 2019 3 United Nations Framework Convention on Climate Change, The Paris Agreement, December 2015. MARKET PRACTICES SUSTAINABLE FINANCE Page 6 EBA STAFF PAPER SERIES industrial levels. In order to reach this goal a transition to a low-carbon economy is required. From a mark

21、et perspective this transition may result in an uncertain landscape of risks and opportunities.4 The 2030 Agenda for Sustainable Development was adopted by all UN Member States in 2015. It consists of 17 SDGs with 169 associated targets in a bid to end poverty and hunger everywhere; to combat inequa

22、lities within and among countries; to build peaceful, just and inclusive societies; to protect human rights and promote gender equality and the empowerment of women and girls; and to ensure the lasting protection of the planet and its natural resources.5 At the European level this has been translate

23、d into the European Commissions action plan.6 The action plan consists of three objectives, which are: (i) to reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth; (ii) to manage financial risks stemming from climate change, environmental degrada

24、tion and social issues; and (iii) to foster transparency and long-termism in financial and economic activities. These objectives are supported by 10 actions, which include: (i) establishing an EU classification system for sustainable activities; (ii) creating standards and labels for green financial

25、 products; (iii) fostering investment in sustainable projects; (iv) incorporating sustainability when providing financial advice; (v) developing sustainability benchmarks; (vi) better integrating sustainability in ratings and market research; (vii) clarifying institutional investors and asset manage

26、rs duties; (viii) incorporating sustainability into prudential requirements; (ix) strengthening sustainability disclosure and accounting rule-making; and (x) fostering sustainable corporate governance and attenuating short-termism in capital markets. These initiatives have been supported and recogni

27、sed by banking supervisors and regulators, which have demonstrated the importance of sustainability issues through the establishment of various task forces such as the Financial Stability Boards Task Force on Climate-related Financial Disclosures (TCFD), which was set up to develop voluntary, consis

28、tent climate-related financial risk disclosures for use by companies for the provision of information to investors, lenders, insurers and other stakeholders. In addition, the Network for Greening the Financial System (NGFS), a network consisting of central banks and supervisors, was established with

29、 the purpose of meeting the goals of the Paris Agreement and enhancing the role of the financial system in managing risks and mobilising capital for green and low-carbon investments in the context of environmentally sustainable development. Why are banks reacting to the sustainable finance issue? Re

30、action to sustainability issues has not just been the preserve of international governments and organisations. Reaction is currently happening within banks. It has been stated that, because of pressure from customers and investors, as well as regulators, banks have already begun to recognise that th

31、ere are sustainability risks and they have begun supporting the transition to a more sustainable economy through the integration of sustainability factors into their risk management models and governance frameworks.7 This statement is, to a certain extent, supported by our survey responses, which fo

32、und that banks base the motivation behind their sustainability strategy upon many factors, including making use of new business 4 United Nations Environment Programme Finance Initiative, 2018, Extending our horizons: assessing credit risk and opportunity in a changing climate: outputs of a working g

33、roup of 16 banks piloting the TCFD recommendations, Part 1: Transition-related risks and opportunities, p. 8. 5 Transforming our world: the 2030 Agenda for Sustainable Development, September 2015. Available at: https:/sustainabledevelopment.un.org/post2015/transformingourworld last accessed 20 Decem

34、ber 2019 6 Communication from the Commission to the European Parliament, the European Council, the Council, the European Central Bank, the European Economic and Social Committee and the Committee of the Regions, Action plan: financing sustainable growth, COM/2018/097, 8 March 2018 Available at: http

35、s:/eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX:52018DC0097 last accessed 20 December 2019 7 Alexander S.K. and Fisher P., 2018, Banking regulation and sustainability. Available at SSRN: or http:/dx.doi.org/10.2139/ssrn.3299351, p. 2 last accessed 20 December 2019 MARKET PRACTICES SUSTAINABLE

36、FINANCE Page 7 EBA STAFF PAPER SERIES opportunities to satisfy customer needs and supporting business with a positive social, environmental and reputational impact. The order of ranking is detailed in Table 1. Table 1: Banks motivations behind their sustainability strategies Motivation Ranking Suppo

37、rting ethical business 1 Business opportunities 2 Anticipating regulatory changes 3 Customer and investor demands 4 Anticipating changes in economic and risk factors 5 Reputational costs 6 Anticipating changes in clients behaviour 7 Promoting human capital 8 Definitions of environmental, social and

38、governance criteria The term ESG was first coined in the landmark study Who Cares Wins by the UN Global Compact8 nearly 15 years ago. This laid the foundations for environmental, social and governance investing. The term ESG is used throughout this report; however, how it is interpreted is dependent

39、 upon how it is determined, i.e. whether it pertains to an ESG Factor, an ESG issue or an ESG risk. From a high-level perspective, a factor is a characteristic of a stock or asset for which the exposure to that particular characteristic is known. The ESG issue is essentially the issue an asset may f

40、ace; the issue may vary depending upon the asset type, the sector, size, geographic location and the stage in the life cycle. The issues may originate outside the asset itself but may affect its ability to perform (i.e. temperature rise, increased water scarcity, changing regulations or tariffs). Th

41、e asset itself may cause issues and impact upon the surrounding environment or communities (e.g. pollution, water effluent, quality of life, labour conditions).9 Thus, these can have impacts upon an asset or the asset can have impacts that create ESG issues; these in turn can have financial conseque

42、nces for the investor, the bank and the counterparty.10 Thus, what was an ESG-related factor or issue becomes an ESG risk11 for the bank to manage. 8 UN Global Compact, 2004, Who cares wins: connecting financial markets to a changing world: recommendations by the financial industry to better integra

43、te environmental, social and governance issues in analysis, asset management and securities brokerage. Available at: https:/www.unglobalcompact.org/docs/issues_doc/Financial_markets/who_cares_who_wins.pdf last accessed 20 December 2019 9 Weber B. and Rendlen B., 2019, Guidance note: Integrating ESG

44、factors into financial models for infrastructure investments, WWF and B Capital Partners. Available at: http:/awsassets.panda.org/downloads/wwf_guidance_note_infra_.pdf last accessed 20 December 2019 10 Weber B. and Rendlen B., 2019, Guidance note: Integrating ESG factors into financial models for i

45、nfrastructure investments, WWF and B Capital Partners. Available at: http:/awsassets.panda.org/downloads/wwf_guidance_note_infra_.pdf last accessed 20 December 2019 11 ESG risks are discussed further in this paper as part of risk management. MARKET PRACTICES SUSTAINABLE FINANCE Page 8 EBA STAFF PAPE

46、R SERIES Definitions of ESG factors A fundamental part of the market practices survey was to determine the current definitions of ESG factors that banks are using. The survey results demonstrated that, given that there is no common definition, banks have been relying upon various international frame

47、works and standards to define ESG factors, although some of them use their own definitions. This demonstrates that there is a current lack of commonality with regard to ESG factors. This raises issues because, if banks are using different definitions of ESG factors, then there may be different outpu

48、ts from a risk management perspective and differences in the outcomes of disclosures. To determine if there is any commonality in existing approaches, the international definitions and banks own definitions of ESG factors were analysed. International initiatives To date there are multiple variations

49、 on the theme of what an ESG factor is. One of the often-quoted frameworks in which ESG factors are defined is the United Nations Principles for Responsible Investing (UNPRI), which have been used as examples in various reports and impact statements.12 The UNPRI define ESG factors as outlined in Table 2.13 Table 2: Examples of UNPRI definitions of ESG factors Env