绿灰和气候转型计划：我们品诚梅森和Milliman联合10月论坛的笔记摘要

Greenwashing andclimatetransition:Summary of notes from ourPinsentMasonsand Millimanjoint Octoberforum Nick Spencer, FIACharlie Howell,FIA, CERA We would like to thank those who joined us at our joint SustainabilityFinancial Services Forum with Pinsent Masons. These brief notes areoffered as an aide-memoire for those who could attend and an overviewof the key topics for those who couldn’t. The forum covered both FG24/3: from the Financial Conduct Authority (FCA), “Finalised non-handbook guidanceon the anti-greenwashing rule (AGR)1and the Transition Plan Taskforce’s Disclosure Framework and AssetOwner Sector Guidance.2It started with an overview of the challenges and limitations of climate scenariosfollowed by an overview of the greenwashing guidance. It then covered the Transition Plan Framework beforereviewing the operational and compliance implications. We have summarised each section in turn, including a key slide, followed by some highlights from the ensuingand broad-reaching discussions, closing with some recommendations and next steps. ClimatescenariolimitationsandIFoAriskalert Published climate scenarios, such as those from the Network for Greening the Financial System (NGFS) or theInternational Energy Agency (IEA), often fail to capture the full spectrum of complexities, uncertainties and tail risksassociated with climate change. These shortcomings are covered in recent papers from the Institute and Faculty ofActuaries (IFoA)3and highlighted initsJune 2024 risk alert.4Whilst the risk alert only directly refers to theresponsibilities of IFoA actuaries, we believe the core message applies to all organisations. The alert states thatactuaries should not only seek to understand the limitations of climate scenarios but should also effectivelycommunicate the limitations and uncertainties. Key messages from the IFoA papers are summarized in Figure 1. Source:IFoA, Milliman. Planetrealityandnaturedecline An often-overlooked element of sustainability risks is attention to biodiversity and nature risks. There has been analarming decline in nature, evidenced by a 73% drop in wildlife populations since 1970 and extinction rates farexceeding the typical, prehuman levels.5The impacts, and potential futures, were illustrated in an article from theInternational Institute for Applied Systems Analysis (IIASA), “Bending the curve of biodiversity loss,”6included withpermission in Figure 2. The economic ramifications of these environmental changes are becoming increasingly evident. The recentreport from the Green Finance Initiative, “Assessing the Materiality of Nature-Related Financial Risks for the UK”7states that nature-related risks present an equal if not greater risk to the UK economy over the next 10 years thanclimate change risks. Nature-related risks are those that are linked to the direct and societal dependencies onnature and to nature impacts. The report showed that they have the potential to result in impacts as large as theglobal financial crisis or, in a stress scenario, the COVID-19 pandemic. Moreover, there is increasing recognitionthat “you can’t be net zero without being nature positive.”8Yet few, if any, financial service firms are paying equalattention to nature-related risk as to climate-related risks. Greenwashing andregulatorycompliance TheFCAfinalised the FG24/3 Anti-Greenwashing Rule (AGR) guidance9in May 2024. Greenwashing, or thepractice of making misleading sustainability claims, is a major regulatory and reputational risk. Pinsent Masons’"House of Greenwashing" framework (Figure 3) provides a stylistic view of where greenwashing can appear in anorganisation and illustrates the foundations required to mitigate the risk of greenwashing. Enforcement action brought by regulators has emphasised failures within internal processes, behaviour, andconduct—mostly inadvertent. Identifying where an organisation is most at risk of greenwashing, or where theremight be material failures, requires reviews to be carried out across a number of different areas. Transitionplans The Transition Plan Taskforce (TPT) was created to establish the best practice, “gold standard”for effective climatetransition plans.10It has developed sector-specific guidance11for both asset owners and managers covering theirstrategies and objectives across investment, engagement, products and operations. In this way, the finance sectorcan act as a lever for, andanaccelerator of, climate transition. Whilst the principles and focus are quite intuitive, addressing the practicalities in the detail can highlight some of thechallenges, as shown in Figure 4. Operational andcomplianceimplications The challenges of operationalising the FCA’s “anti-greenwashing rule” and the TPT’s transition plan guidance arisesfrom the multifaceted approach that is needed. Work needs to blend both compliance (legal) requirements with thetechnical “planet reality”and investment detail. The detail is deep. For example, those responsible need tou