合规手册加速银行ESG风险管理

© Oliver WymanINTRODUCTION1ESGrisksisdefinedhereastherisksofanynegativeimpactontheinstitutionstemmingfromthecurrentorprospectiveimpactsofESGfactorsonitscounterpartiesorinvestedassetsIn recent years, banks and the financial sector in general have experienced a notable increase inthe focus on environmental, social, and governance (ESG) risks and their potential to significantlyaffect the financial and non-financial performance of financial institutions.1The trend has beenfurther amplified by enactment of the European Union’s Corporate Sustainability ReportingDirective (CSRD). This new set of regulations compels companies in all industries, including acrossthe financial sector, to quantify and disclose their greenhouse gas emissions as well as plans toreduce them. The mandates are phased in, with the first reporting for the largest companiesbeginning in 2025 based on data from fiscal year2024.As a result, banks need to incorporate ESG into their compliance and control frameworks. Andfor the first time, they must integrate climate-related and environmental risks into the strategy,governance and oversight, and risk management, with non-compliance posing significantfinancial and reputationalrisks.A recent Oliver Wymanstudy among 24 leading European and international banks showed theemergence of a dual focus of their compliance departments:•Pushing toward sustainability.Compliance needs to develop an ownership mindset for thebank’s path to sustainability and become a thought leader on thesubject.•Safeguarding against greenwashing.Banks must navigate a complex landscape havinggiven environmental commitments while regulations are still being developed or rolled out.Greenwashing involves companies making unsubstantiated claims about their products orservices to convince consumers that they are environmentally friendly, as serious risk forbanks and itscustomers.The purpose of this paper is to provide a playbook for compliance departments to mitigategreenwashing risk and elevate their strategic role on ESG riskmanagement. © Oliver WymanTHE CURRENT STATE OF ESGGOVERNANCE IN EUROPEAN BANKS2“CompliancenewroleinmanagingESGrisks,“OliverWyman,September20233“Guideonclimate-relatedandenvironmentalrisks,“ECB,November2020Despite the growing significance of ESG in the corporate world, organizational governancesurrounding this topic remains ambiguous across European and international banks. Accordingto a recent survey of European banks conducted byOliver Wyman, ESG and sustainabilitypriorities do not have a clearly defined place within the operations of the so-called Three Linesof Defense model.2The Three Lines of Defense focus on management, risk management andcompliance, and internal audit. Over 60% of banks indicated that there is uncertainty aroundwhich of these lines of defense is responsible for enforcing ESG and sustainability considerations,leaving open the possibility for items to getoverlooked.The European Central Bank (ECB) has established requirements for banks to incorporateclimate-related and environmental risks and is actively monitoring industry performance.3Itsthird assessment revealed that the quality of implementation remains inadequate. Banks haveuntil the end of 2024 to comply with all the ECB requirements, and failure to do so for selectedareas by the end of the first quarter of 2024 could result in severe penalties, including dailysanctions that could amount to 5% of the daily net turnover, or approximately €500,000 per dayfor an average bank. This presents a significant compliance risk for banks that should be activelymanaged through established complianceframeworks.While over the last years Compliance in Europe have taken a more reactive approach toward ESG,the recent increase in regulatory focus on ESG will force them to switch to a more proactive rolein assessing climate-related and sustainability risks. This wouldinclude:•Providing compliance advice•Executing independent oversight•Facilitating compliance with relevant rules and regulations, including those related to climateand the environment © Oliver WymanKEY FOCUS AREAS FOR COMPLIANCE DEPARTMENTS TODAYRecent ESG regulation, primarily enactment of the CSRD, is triggering banks to start updatingand upgrading the compliance department’s remit and procedures related to ESG. While ourrecent study showed that participating banks have taken some initial steps across the complianceoperating model, particularly in the review of policies and procedures and risk assessment, onlyhalf have addressed overhauls of training and a minority have taken on reportingfunctions.Exhibit 1: Compliance programme upliftsPercentage of banks indicating revisions in the respective part of the compliance programmeto help manage ESGrisksDevelopmentof policies andprocedures92% of participatingbanksProgress1ProgressRegulatory change71% of participatingbanksProgressAdvisory75% of participatingbanksMonitoring, testingand surveillance63% of participatingbanksProgressProgressTraining54