BRUSSELS, 30 November 2021
To address the climate emergency, we need an urgent shift of both private and public sector resources towards a low-carbon economy. Financial institutions are not only going to be impacted by climate change but are also going to be a big part of the solution. Banks’ financing of sustainable business, investments and activities will help reduce and mitigate the impact of climate change given our sector’s proximity to clients.
As part of the Glasgow Financial Alliance for Net Zero (GFANZ), the UN convened an industry-led initiative – the Net Zero Banking Alliance. The alliance brought together banks representing over a third of global banking assets, including the three European banks with the highest exposure to fossil fuels. This is important because, with just five per cent of banks, we cover forty-five per cent of overall emissions.
NZBA banks are not only committing to aligning their portfolios with net-zero emissions by 2050, but also to setting intermediary targets, focusing on priority sectors where they can have the most significant impact, in a transparent and publicly accountable way. While GFANZ was viewed with skepticism by some, initiatives like this will no doubt have a spillover effect on the corporate sectors and contribute to risk mitigation as they target aligning with Paris objectives, thus decreasing the transition risks. We are proud to be the first official supporter of NZBA by which we commit to further stepping up our efforts to accelerate and facilitate the banking sector transition to net zero.
Banks’ allocation of resources towards a low-carbon economy is key in financing the transition. This shift can only be made, if we put in place incentives which guide the underlying economy. We can only tackle the climate crisis through collective action across the public and private sectors. The progress is heavily dependent upon governments delivering on their action plans and industrial strategies. We need greater clarity and predictability on policy actions as well as greater national political ambition to align the underlying economic incentives with the Paris Agreement in the short to medium term.
Europe is leading the sustainability transformation on many fronts. The decarbonization of Europe will however not suffice to prevent a global climate catastrophe by itself. Europe needs to turn its focus outside and provide expertise and resources if we are to guide and lead the transition to net-zero. This is also necessary because the financial system is global. Nearly a quarter of EU banks’ exposures concern entities outside of the EU. Global cooperation and harmonization are key to preventing market fragmentation and facilitating the flow of capital where most needed.
One can debate the success of the Glasgow climate conference. The glass can be seen half full or half empty. The plethora of pledges, both private and public, needs to be translated into concrete actions. Looking back, COP26 will be judged on actions, not words.
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BRUSSELS, 30 November 2021
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The views, thoughts, and opinions expressed in the text belong solely to the author, and not to the author’s employer, organization, committee, or other group or individual.
The EU Taxonomy is a classification scheme that aims to provide clear and science-based definitions of what economic activities could be considered environmentally sustainable (“green”). It has been designed to identify and target activities with a substantial positive contribution to environmental objectives, thus the thresholds to define “what is green” are rather demanding and in several instances go beyond the existing sectoral legislation – which is expected to be revised over time. The Taxonomy is, however, not a mandatory list of activities in which to invest. It also does not suggest that what is not considered as Taxonomy aligned, which currently is the vast majority of the EU economy, is unsustainable. However, there is no further differentiation of non-aligned activities. While the taxonomy defines what is “green” there is no distinction between activities/companies that have a credible transition path (“greening”) from others that have not yet adapted their business strategies to tackle the challenges to reach a Net-Zero European Economy by 2050, as addressed by the EBF in March 2021.
Labelled initially as a “dictionary and disclosure tool” to provide clarity mainly for investors, with time, the EU Taxonomy is growing both in scope and ambition as a tool to deliver on the European Green Deal. The taxonomy is now going to be mandatory also for banks that will have to report the extent to which their activities are taxonomy aligned.
The United Nations Environment Programme Finance Initiative (UNEP FI) and the European Banking Federation (EBF) are collaborating on a report that aims to facilitate banks in their efforts to apply the EU Taxonomy to their lending activities.
In our interview with Daniel Bouzas Luis, Regional Coordinator for Europe at UNEP FI, we asked Daniel about his views on the EU Taxonomy and whether and how it can be employed as a “transition tool”.
Could the EU Taxonomy be used to engage companies whose activities are not aligned with the Taxonomy?
The first objective of the Taxonomy was to tackle greenwashing. With common definitions on what can be considered environmentally sustainable and specific ways for companies to report, the Taxonomy is expected to improve reporting as it is simultaneously a classification and a reporting tool. As a framework, it provides clarity to companies in determining, on a scientific basis, whether their activities have a significantly positive environmental impact.
The Taxonomy is one very specific way of looking at what a company’s current performance looks like, as it generates a very specific activity per activity overview but can also be used as a tool to plan improvements. A full alignment with the taxonomy provides the highest-level performance a company can aim for to be aligned with the environmental goals of the European Commission – for those activities that are in the scope of the taxonomy (eligible activities). In fact, the Taxonomy technical screening criteria (TSC) indicate how a green and sustainable Europe should look like in the future and allow companies to adjust their strategies with the EU objectives. More precisely, it forces companies to take a deeper look at their activities in a scientific way and assess their impact on the environment. This is crucial in determining a credible transition pathway – assessing where the performance is up to the standard, where it needs to be improved and how. The increased clarity benefits banks as a result as well, as they too adjust their financing activities towards their own sustainability targets.
How do the technical screening criteria (TSC) and ‘do no significant harm’ (DNSH) aspects of the current Taxonomy fit into the transition framework?
The Taxonomy will be developed for six environmental objectives: climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, and pollution prevention and control. The TSC for each objective are then being designed as the “golden standard” thresholds and metrics to provide clear direction for companies to develop pathways towards aligning with the 2050 targets the EU and its Member States have committed to (as per the Green Deal, Climate Law, etc.).
It is, however, also important to keep in mind that many companies will require an intermediate target for their activities as a stepping stone on their way to aligning with 2050 targets.
From a financial institution’s perspective, the taxonomy could be seen as a tool to engage with their customer on their transition pathway – to align with the EU objectives – thus mitigating the transition risk both for the customer and for the bank.
What do you make of the Platform on Sustainable Finance’s recommendation to expand the current Taxonomy?
With the focus on the highest level of environmental performance, we are missing a wide range of activities that cannot be considered green but neither harmful. With the expansion of the Taxonomy to cover all economic activities, we will be able to understand the improvements in the performance of activities. However, it is a complex task with many open questions such as whether, for instance, minimum social safeguards (MSSs) will be assessed for this intermediate category and whether the benefits of tracking the movements within the “middle category” of activities with no significant environmental impact would outweigh the possible cost. On the other hand, to enable the transition of those activities that can improve their environmental performance, we will need to develop a system to understand whether such activities are on a credible transition pathway.
How do you assess the readiness of banks to engage in this process with their clients?
Many banks across Europe are already engaging with their clients with regards to how they are performing against specific environmental targets. In this respect, the Taxonomy represents a common tool that determines, in an objective way and based on a scientific approach, which activities are in line with the 2050 net-zero objectives. This ultimately will facilitate banks’ engagement and ensure the allocation of finance to activities with a truly positive impact.
At UNEP FI we will continue supporting our members in the implementation of the Principles for Responsible Banking, their Net-zero commitments under the Net-Zero Banking Alliance, but we will also continue providing them with key tools as not to only enable them to comply with regulatory requirements, but also benefit in the long term. I believe that with EBF we have a shared objective here and we look forward to our continued cooperation.
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Massimiano Tellini, Head of Circular Economy at Intesa Sanpaolo Innovation Center, shared some insight on how the Circular Economy Lab fosters innovation by bringing together all the right stakeholders to help companies achieve a circular business model.
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The Circular Economy lab was created in 2018 through a strategic agreement between Intesa Sanpaolo and Fondazione Cariplo and is run by Intesa Sanpaolo Innovation Center in collaboration with Cariplo Factory. The Circular Economy Lab has the ambition to support concrete action around the topic of circularity. The objective is to provide concrete solutions for companies aiming to become circular; this is achieved through the three pillars of the Lab, which are: connection, innovation, and education. The Lab acts as a convening place where we engage with companies. Then through the Intesa Sanpaolo Innovation Center first and the bank of Intesa Sanpaolo at a second stage, the companies interact with the broader community, including universities, SMEs, start-ups, and many others. Intesa Sanpaolo serves as an intermediate platform to foster these relationships and inspire innovation. The Lab uses this process to guide companies through the re-design of their business models. It differs from the traditional banking approach as the Lab is involved not in providing financing (which is in the exclusive domain of the bank) but rather in designing innovative projects which may then translate into new investments to be made. Thus, the Lab engages with clients before any financing need is identified, and explores opportunities with them in a variety of creative ways, including workshops.
First of all, circularity does not focus mainly on the environmental component but rather on a business model’s re-design, which itself is enabled by technologies and regenerative approaches which are aimed at decoupling economic and social development from the recursive exploitation of finite natural resources and regenerating the natural capital. There is, indeed, a substantial difference between the aim of trying to minimise a company’s detrimental impact on the environment and that of becoming a positive impactful player engaged in innovative business practices such as research, innovation investments, and re-designed relationships among other value chain actors. A concrete example of this type of innovative interaction can be illustrated through the story of an Italian wine company that now innovatively manages its secondary raw materials thanks to a strategic collaboration with a relevant Italian regional utility company – which resulted in a joint venture able to produce a bio-based polymer. This is just one of many examples of how the Lab can foster collaboration aimed at promoting circularity.
The first big challenge is truly understanding what the circular economy means. Currently, the definition commonly attributed to the circular economy is limited to waste management. Therefore, the first challenge for entrepreneurs and investors is comprehending what circular economy means in terms of opportunities and potential. The Intesa Sanpaolo Banking Group is offering standard finance with an innovative approach, which, through circular economy screening criteria co-designed in close collaboration with the Ellen MacArthur Foundation (the most authoritative global player promoting the acceleration of the systemic transition towards the CE) seeks to orient capital towards truly CE innovative projects. In addition to the financing phase, innovation – more specifically, open innovation – is where the Circular Economy Lab plays a pivotal role by helping the Bank’s clients engage in ecosystem interaction with different players to conceive and possibly re-design their business practices and models. Another challenge is disseminating the correct culture and knowledge concerning this new economic paradigm to nurture new generations of entrepreneurs, leaders, and talents needed to bring the circular economy transition to life.
COVID-19 has had profound and pervasive consequences on every domain of society and the economy. The world of financial institutions is now coming to terms with a long-overdue rethinking exercise about its potential to be a driving force for good and fair prosperity for all. When you look at the effects of COVID across regions, you see that people everywhere have had time to pause and reflect, which has resulted in companies going back to the basics and focusing on positive impact while doing business. The pandemic has exponentially accelerated the transition that was already ongoing by exposing the risks of typically linear business, market & economic activities, for example by impacting value chains and availability of natural resources and industrial raw materials. In this respect, circularity is innovative in nature and philosophically different from sustainability: the latter strives to make the (current linear) system more sustainable, whereas circularity aims at changing the system entirely!
Ultimately, from the perspective of climate change and biodiversity loss, the current systemic crisis cannot be faced alone, given the unprecedented scale and complexity of the adverse effects being generated. This is why the approach adopted for the activities of our CE Lab has been designed around the open innovation and pre-competitive collaboration principles, so as to make it the partner of choice for the evolution of the “Made in Italy” brand towards the CE paradigm.
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Why was the COP26[1] so important? It’s a test for the level of ambition of countries to fight against climate change against a background of mounting scientific knowledge that highlights the shrinking room of maneuver.
The COP26 outcome: on the positive side, important progress has been made, particularly by the private sector.
On the negative side, some reached pledges have been softened and remain accountable only through moral suasion. Critics argue that this is insufficient.
What can we hope for in the future? Reinforced moral suasion through more frequent updates of the NDCs, carbon pricing through global markets development and going beyond the voluntary nature of Paris.
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[1] COP26 Glasgow – Final agreement
[2]https://www.globalcarbonproject.org/carbonbudget/21/files/GCP_CarbonBudget_2021.pdf
[3] https://ec.europa.eu/commission/presscorner/detail/en/SPEECH_21_5770
[4] https://ukcop26.org/glasgow-leaders-declaration-on-forests-and-land-use/
[5] https://www.state.gov/u-s-china-joint-glasgow-declaration-on-enhancing-climate-action-in-the-2020s/
[7] https://www.ft.com/content/f13bce2b-8a2b-4289-9281-9c6acf34f472
[8] https://www.gfanzero.com/press/amount-of-finance-committed-to-achieving-1-5c-now-at-scale-needed-to-deliver-the-transition/
[9] https://www.state.gov/launching-the-first-movers-coalition-at-the-2021-un-climate-change-conference/
[10] https://www.britannica.com/event/Kyoto-Protocol
[11] https://www.politico.eu/article/eu-carbon-border-adjustment-mechanism-turkey-paris-accord-climate-change/
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There are some preconditions for banks to play their role in the sustainable finance domain:
Institutions are specifically called upon to consider the noteworthy lack of data currently available on these issues: the situation is already evident in relation to the environmental factor (and therefore referring to the environment and climate), but it seems to us that the Platform’s expansion to include social issues will face the same problems.
Data collection will have to be carried out based on information standards which will have to be defined at the EU level, but also at the global level. It would be good if non-financial standards on a global level (the IFRS Foundation should set them) consider the European experience, which represents an innovative model.
Maximum collaboration with companies is needed to increase the transparency of the sustainability profiles of economic activities and to generate good quality ESG data.
We must be aware that if enterprises (including banks!) do not adequately report their own sustainability profiles, this can be interpreted as a lack of transparency and thus produce consequences that are probably worse than those connected to an honest representation of gaps to be bridged. This is as true for businesses as it is for banks.
Together we need to identify the most meaningful indicators to collect in order to keep the scale of effort manageable while still obtaining a correct ESG profile of our customers: however, this is a complex issue because the answer depends on the economic sector, location, the vulnerability factor, etc. To draw a historical parallel, it is as if we were in the early stages of medicine when it was not yet known which laboratory analysis would be best for evaluating and monitoring a particular aspect of an individual’s health. Today we know that cholesterol tells us about a lot for certain pathologies and blood sugar for others. Similarly, for ESG evaluations, we will have to identify the most suitable information from what is available for determining whether a company is well-positioned and, what seems even more difficult, to choose the information that is predictive of potentially reduced or increased ESG related financial risks.
The role of trade associations of non-financial companies is key to increasing awareness and encouraging reporting that is useful for companies to describe their sustainability profile in a manner that is structured and consistent with standards. Supporting companies on this path means first helping them enhance the different paths of excellence already in place and bringing them to a common understanding. It also means growing the demand for sustainable finance banking and financial products and services.
We should not forget that achieving the challenging environmental and social sustainability goals in Europe also depends on the ability of the capital market to channel the necessary resources from private investors to complement the public funds. In recent years, thanks in part to European regulatory pressure (e.g., the disclosure requirements for market participants and the integration of ESG factors in the rules of investment services, etc.), the capital markets have made significant progress in developing investment products that integrate sustainability objectives. A key role in this context is played by green and sustainable bonds, for which the market is growing in terms of issuers and volume, confirming the ability of the capital markets to give clear signals on how sustainability, especially environmental sustainability, is reflected in investments and in the real economy.
Banks, in their role as lenders, as well as capital markets issuers and intermediaries, support sustainable economic initiatives, from an environmental and social point of view. The setting of EU market standards at a European level, as recently proposed by the European Commission, will certainly contribute to further developing the green bond market in Europe. Real progress on the CMU Action Plan is urgently needed if we want the Capital Market Union to support the success of the Sustainable Finance Action Plan.
EU banks can play a key role in sustainable finance but could find themselves squeezed between the increasing demands of the regulators and supervisors and the difficulties faced by enterprises in providing the relative sustainability data.
The timing imposed on banks for providing ESG information under the various regulatory measures on sustainable finance could create a substantial misalignment between what European legislation currently requires and the practical possibility of banks to fulfil these obligations, especially for data to be made available by their counterparts.
Banks are rightly scrutinized by their stakeholders on their activities to support the transition. At the same time, they should not be required to shut out certain sectors from financing entirely, especially those sectors that may currently not be well-positioned but can still move forward with the transition from an environmental and climate point of view. We are not just talking about Sustainable Finance, but also financing the transition or Transition Finance.
Finally, it’s interesting to notice how Article 87a of the Commission’s Proposal for the new CRR/CRD seems to ask banks to adapt their business models to the relevant policy objectives of the Union and broader transition trends towards a sustainable economy. Something very new that needs to be better understood.
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