It is the old cliché. What gets measured gets managed. And for a long time that has been a mantra in the field of getting to grips with greenhouse gas emissions and moves toward a lower-carbon economy. All the efforts in the fields of accounting for sustainability and integrated reporting have it at their heart. But it has been as much a cultural change as it has been a financial one. And that sort of change takes more time than people imagine at the outset.
But with the publication of the recommendations of the Task Force on Climate-related Financial Disclosures the whole process moves forward.
The task force was set up by the Financial Stability Board to ‘develop voluntary, consistent climate-related financial disclosures that would be useful to investors, lenders, and insurance underwriters in understanding material risks’. And this is where the recommendations have a real chance of bringing about change.
The evolution of the nature of climate-related concerns from original worries about global resources to more tangible issues on the range of risks and opportunities involved is important. It means that what might have been once downplayed as high-minded concerns now moves into the realms of serious risk assessment and resulting action. It is an important shift.
On a fundamental level, as the report says: ‘Users of such climate related disclosures commonly cite the lack of information on the financial implications around the climate-related aspects of an organisation’s business as a key gap’. It is this gap that the recommendations seek to close. And there is nothing in the recommendations which would startle anyone involved with financial disclosure.
Their importance is in pulling the ideas together and giving them some more mainstream impetus. Nor will they get in the way of other bodies, like the International Integrated Reporting Council or the Climate Disclosure Standards Board for example. The hope is that the recommendations will enable such bodies to come into common alignment.
‘Preparers, users and other stakeholders’, says the report, ‘share a common interest in encouraging such alignment as it relieves a burden for reporting entities, reduces fragmented disclosure, and provides greater comparability for users’. And the hope is that the recommended disclosures across the fields of governance, strategy, risk management and metrics and targets will aid that process. As should the various principles laid out for effective disclosures.
The approach echoes the UK’s mainstream rules that directors should verify that their accounts are ‘fair, balanced, and understandable’ in the principle that climate-related financial disclosures should be ‘clear, balanced, and understandable’. Senior financial managers and directors have to be involved and take responsibility and so do other stakeholders.
Under what Russell Picot, the Task Force’s Special Advisor, refers to as ‘three problems, one solution’ he included first: issuers, lenders, insurers, and second: investors, and also now: regulators, all of whom need to understand the risks. There is also an emphasis on how, in a sense, the process will be the educator.
In producing the mainstream financial filings, suggested Picot, the CFO will likely be involved and that would also mean that the chairman of the audit committee would be part of the conversation. All this would lead to a discussion in the boardroom which would in itself be a valuable and useful addition to the process. As would the strong institutional engagement that Picot envisaged coming through in conversations around the UN’s sustainable development goals. The task force is taking the process slowly.
The initial consultation period may have been a less than ideal period including the December/January holiday period and ending in early February, with a final report intended for June, followed by a presentation to the G20 Summit. ‘There is, said Picot, ‘no expectation of immediate implementation’. Far from it. The intention is to go with the flow. ‘The market will sift through the information and then a clear sense of what is most useful will emerge’, he suggested. It would be a question of ‘building disclosure over time to allow experimentation’. That, he said, ‘would be very important’. There is a clear view that this whole field and what the task force has proposed is a step change. And the way to achieve it is to take people with them rather than impose solutions.