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The Hidden Risks of Climate Change for Canadian Banks
OCTOBER 2015
Banking on 2°
www.share.ca | 2 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
Authors: 	 Shannon Rohan, Director of Responsible Investment, SHARE
	 Hasina Razafimahefa, Research Assistant, SHARE
Reviewers:	 Peter Chapman, Executive Director, SHARE
	 Kevin Thomas, Director of Engagement, SHARE
	 Aaron Ziulkowski, Senior ESG Analyst, Walden Asset Management
	 Dr. Rory Sullivan, Senior Research Fellow, University of Leeds
Any errors or omissions are solely the responsibility of the authors.
Published by the Shareholder Association for Research and Education (SHARE), October 2015
SHARE (Shareholder Association for Research and Education) is a Canadian leader in responsible investment.
SHARE advises institutional investors on the development and implementation of responsible investment
practices. Created in 2000, SHARE provides proxy voting, shareholder engagement, board education and
research on emerging responsible investment issues. SHARE has been engaging with Canadian banks on
climate change related risks and opportunities since 2012 on behalf of our institutional investor clients with
approximately $14 billion in assets under management.
For more information on SHARE, please visit: www.share.ca
Except where noted, this work is licensed under a Creative Commons Attribution-
NonCommercial-NoDerivatives 4.0 International License.
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 3 |
EXECUTIVE SUMMARY	 4
INTRODUCTION	 5
CLIMAGE CHANGE-RELATED RISKS 	 6
FOR CANADA’S BANKS	
	 Regulatory Risks	 7
	 Physical Risks	 7
	 Reputational Risks	 7
	 Systemic Risks	 8
	 Competitive Risks	 8
HOW CANADA’S BANKS ARE RESPONDING 	 9
TO CLIMATE CHANGE	
	 Strategy 	 9
	 Risk Management 	 9
	Performance	 10
	Disclosure	 10
INVESTOR RECOMMENDATIONS FOR 	 11
ADDRESSING CLIMATE CHANGE
CONCLUSION 	 12
ENDNOTES	 13
Banking on 2°
The Hidden Risk s of Climate Change for Canadian Bank s
“The decisions we make now will determine the future of our economy and our climate. If we
choose low-carbon investment we can generate strong, high-quality growth – not just in the
future, but now. But if we continue down the high-carbon route, climate change will bring
severe risks to long-term prosperity.”
Lord Nicholas Stern, Chair of the Centre for Climate Change Economics and Policy
www.share.ca | 4 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
EXECUTIVE SUMMARY
Climate change is one of the defining economic, environmental and social issues of our time.
There is broad global consensus that to avoid the worst and most catastrophic effects of climate
change we must limit the rise in the average global surface temperature to two degrees Celsius
above pre-industrial levels. In order to achieve this, we need to transition towards resilient, low
carbon societies and economies.
Canada’s banks have an important stake in addressing this challenge. Bank’s financing activities
span all sectors of the economy, making them particularly vulnerable to climate change
related risks. However, to date, Canada’s banks have not sufficiently integrated climate change
considerations into long-term business strategies and risk management processes. To help fill
this gap, we provide a framework for how Canada’s banks can improve their performance in
addressing climate change.
Investor Recommendations for Addressing Climate Change
Establish a Climate Change Strategy
Develop a climate change statement outlining an institutional commitment to limit the
average surface temperature rise to 2°Celsius. The statement should outline how the
bank addresses climate change, the steps it is taking to reduce the climate impacts of
its operations and financing activities and how the bank is contributing to an energy
transition.
Integrate Climate Change Considerations into Risk Management
Analysis of business and portfolio sensitivity (including asset stranding) to climate
change and carbon regulation scenarios.
Carbon footprints of lending and investment portfolios measured and analyzed.
Establish Carbon Reduction Targets And Incentives To Achieve Them
Performance targets to reduce operational and financed GHG emissions established
that align with IPCC models to limit warming to 2°Celsius.
Executive compensation and incentive packages include performance in reducing GHG
emissions from operational and financed sources.
Disclose Meaningful Information To Investors
Energy financing reports published that outline lending to the energy sector with a
breakdown of financing to coalmines, oil sands, oil and gas extraction, gas- and coal-
fired power generation and renewable energy.
Carbon price or price ranges used in asset valuations and project assessments
published.
Public policy positions related to climate change and corporate lobbying activities
including payments to trade associations disclosed.
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 5 |
INTRODUCTION
Climate change is one of the defining economic, environmental and social issues of our time.
According to the Intergovernmental Panel on Climate Change (IPCC), scientific evidence for
warming of the climate system is unequivocal.1
In its Fourth Assessment Report, the IPCC
concluded that there is more than 95 percent probability that human activities are responsible
for the emissions of heat-trapping Greenhouse Gases (GHG), which raise global temperatures. 2
Climate change has already had observable effects on the environment. In Canada, the impacts of
a changing climate are evident in observed trends including temperature increases (on average
Canada has warmed by more than 1.3°C since 1948), higher average annual precipitation rates
(mean rainfall has increased by about 12%), changes in the frequency of extreme temperature
and precipitation events, changes in the distribution of some animal and plant species, declining
Arctic sea ice cover (decreased by 8% since 1979) and decreased snow-cover duration.3
Many
of the most severe and costly impacts of climate change are those related to the projected rise
in the frequency and magnitude of extreme weather events and associated natural disasters.
Climate scientists warn that these impacts will increase in frequency and intensity without
substantial and sustained cuts in GHG emissions.4
There is broad agreement, crystalized in the agreements reached by governments in 2010 at
the United Nations Climate Conference in Cancun,5
that in order to avoid the worst and most
catastrophic effects of climate change we must limit the rise in the average global surface
temperature to two degrees Celsius above pre-industrial levels. In order to achieve this, we need
to transition to a low-carbon economy. A key step in this transition will be the 21st Session of the
Conference of the Parties to the United Nations Framework Convention on Climate Change (COP
21) to be held in Paris in December 2015. The purpose of the conference is to reach a universal,
legally binding agreement that will enable the international community to combat climate
change and boost the transition towards resilient, low-carbon societies and economies. A key
theme for COP21 is how to mobilize investments of $100 billion per year by developed countries,
from both public and private sources, to enable this transition.6
Canada’s banks are involved in a range of activities that may be affected by climate change.
These include retail banking, mortgage lending, business lending, project finance, asset
management and investment banking. Because of the potential impacts of climate change
on these financing activities, shareholders are interested in understanding how the banks are
managing these risks including their overall exposure to carbon-intensive assets and how they
are aligning their longer-term business strategies to a low-carbon economy. This paper outlines
the impacts that climate change-related risks could have for the banking sector and provides a
set of recommendations for how the banks can more effectively manage climate-change related
risks and catalyze the transition to a low carbon economy. Our analysis focused on Canada’s five
largest banks: Bank of Montreal (BMO), Canadian Imperial Bank of Commerce (CIBC), Royal Bank
of Canada (RBC), Scotiabank and Toronto-Dominion Bank (TD).
www.share.ca | 6 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
CLIMATE CHANGE-RELATED
RISKS FOR CANADA’S BANKS
The global economy faces significant and diverse economic risks from climate change.7
Canada’s
banks are particularly vulnerable to the risks associated with climate change because of their
portfolio exposure to carbon-intensive industries. Figure 1 below outlines the climate change-
related risks that Canadian banks are exposed to and the potential impacts of those risks for the
banks in terms of asset valuations, operational costs, reputation, new markets and cash flows.
Figure 1: Potential Impacts of Climate Change on Bank’s Financing Activities
IMPACTS
Asset
Mispricing
Elevated Credit
and Default Risk
Retail Banking
Mortgage Lending
Asset Management
Investment Banking
Access to New MarketsChange in
Cash Flows
Higher Operational
Costs
$!
CLIMATE CHANGE-
RELATED RISKS
BANK FINANCING
ACTIVITIES
Regulatory
Risk
Physical
Risk
Systemic
Risk
Competitive
Risk
Reputational
Risk
Retail Banking
Mortgage Lending
Asset Management
Investment Banking
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 7 |
Regulatory Risks
While a global agreement to restrict GHG emissions has yet to be reached, significant
developments in regional and national policies addressing climate change are already occurring.
According to the 2015 Global Climate Legislation Study, by the end of 2014 there were 804
climate change laws and policies in 98 countries, which together produce approximately 93% of
global greenhouse gas emissions.8
The number of national laws and policies that directly relate to
climate change mitigation and adaptation has risen from only 54 laws and policies in 1997 to 426
in 2009 and by the end of 2014 to over 800. The asset valuation methodologies currently used
by the banking sector do not sufficiently account for the potential impacts of climate change
regulations. For example, asset valuations of fossil fuel companies tend to assume that all known
reserves will be exploited. A study by Carbon Trust and McKinsey showed that more than 50% of
the market value assigned to oil and gas companies resides in the value of long-term cash flows
to be generated from their reserves in a timeframe beyond ten years.9
However, according to
the International Energy Agency, no more than one-third of proven reserves of fossil fuels can
be consumed prior to 2050 if the world is to achieve the 2-degree goal.10
The potential for asset
stranding in response to carbon reduction regulations will impact financial institutions with
exposure to fossil fuel companies, with potential impacts for asset valuations, credit and default
risk and ultimately cash flows.
Physical Risks
Banks’own operations and their lending portfolios are exposed to risks associated with
the physical impacts of climate change. For example, physical damage to corporate assets
connected to extreme weather events may lead to an increase in defaults in commercial lending
portfolios. Real estate, agribusiness and infrastructure have been assessed as being particularly
vulnerable. Mortgage portfolios in geographical areas at high risk of flooding, for instance may
face devaluation risks and have higher payment defaults. Banks’operational infrastructure is
also vulnerable to the physical impacts of climate change. Incorporating the physical risks of
climate change into bank risk management frameworks is important to account for portfolio and
operational exposure and to mitigate these risks by adjusting investment decisions.
Reputational Risks
The banking sector has become a target of environmental campaigns over their financing of
carbon-intensive projects such as mountaintop removal in coal production, coal-fired power
generation and oil sands extraction.11
As public awareness and concern about climate change
grows, it is reasonable to assume that continued fossil fuels financing and misalignment with
a transition to a low carbon economy will present increasing reputational risks to banks. For
example, in their 2014 Banking on Coal report, BankTrack noted that banks from Canada, Japan,
France, Switzerland, Germany and Australia, provided more than 5 billion Euros in coal financing
during the period 2011 to 2013.12
Of particular note, all five Canadian banks acknowledged in
their most recent CDP disclosures the reputational risks associated with their financing of carbon-
intensive industries .
www.share.ca | 8 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
Systemic Risks
The Canadian banking sector is exposed to systemic risks associated with the transition away
from fossil fuels and towards a low-carbon economy. Rapid shifts in technologies, regulations,
and carbon pricing could have substantial impacts on the demand for fossil fuels globally. As
the recent oil price shocks have demonstrated, declining fossil fuel demand and/or prices can
create dramatic and unexpected impacts across the entire Canadian economy. Considering these
systemic risks and integrating them into risk management frameworks is critical for Canada’s
banks if they are to fully understand the impacts of different regulatory and physical climate
scenarios on their business models.
Competitive Risks
The shift to a low-carbon economy is generating important opportunities across economic
sectors where green products and services are growing in demand. Financial institutions that are
not building their capacity and investing in product innovation to respond to these opportunities
may face a competitive disadvantage. Conversely, financial institutions that are analyzing the
impacts of climate change on their portfolios and tilting their financing to those sectors that will
benefit from a low-carbon economy may enjoy a competitive advantage in the marketplace.
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 9 |
HOW CANADA’S BANKS
ARE RESPONDING TO
CLIMATE CHANGE
SHARE analyzed publicly available information from Canada’s five largest banks including
websites, corporate responsibility reports, SEDAR filings and CDP13
disclosures for
2013 and 2014 to understand how each bank is responding to climate change. We
looked specifically at each bank’s approach to strategy, risk management, performance
and climate risk disclosure. Here we provide a brief summary of the state of practice
by Canada’s five largest banks and provide some good practice examples from other
jurisdictions.
Strategy
For investors to manage and assess long-term risks to their portfolios they need to
understand how the companies in which they invest are integrating climate change risks
and opportunities into business strategy development and implementation. Emerging
good practice includes prioritizing climate change at the board level, establishing
an institutional commitment to accelerating the shift to a low-carbon economy and
integrating climate change performance into executive mandates and compensation.
Leaders are also analyzing different regulatory and physical climate scenarios in order
to effectively integrate climate change considerations into risk management, business
development and asset valuations.14
The primary focus of Canada’s five largest banks is mitigating their own operational
emissions. The drivers for addressing climate change appear to be primarily short-
term and focused on opportunities to generate cost-savings, with some of the banks
increasingly looking at business opportunities to take advantage of consumer demand.
To date, the banks have not provided investors with sufficient information on how they
are analyzing the sensitivity of their business models and long-term business strategies to
different future economic, regulatory and physical climate scenarios.
Risk Management
To measure and manage risk, investors need information from companies on how they
are considering climate change-related risks, including the potential impacts of climate
change on their own operations as well as those associated with their financing activities.
In the case of Canada’s banks, the biggest risks from climate change are those that will
impact their lending, investment and financing portfolios. TD, Scotiabank, RBC and BMO
report incorporating climate change considerations into company valuations and credit
risk assessments, although they provide little information to investors on how they do
this, what carbon price or price ranges they use or what percentage of their portfolios face
specific risks such as asset stranding.
Good Practice Example:
Strategy
Nedbank South Africa
In its climate change position
statement, Nedbank outlines
a climate change strategy that
includes a commitment to redirect
a portion of the bank’s lending
flows to accelerate decarbonisation
of the economy explicitly at a
rate that is commensurate with
the national carbon budget, i.e.
South Africa’s equitable share of
the global commitment to avoid a
2 degree Celsius average surface
temperature rise. The bank’s
strategy to meet this commitment
comprises of a carbon screen of
its lending portfolio and increased
lending to low-carbon sectors.
Good Practice Example:
Risk Management
European Investment Bank
In 2010, EIB started adopting
a shadow carbon price for its
investments in energy projects of
€25/tCO2e. The price increases by
€1 every year, reaching
€45/tCO2e in 2030.
www.share.ca | 10 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
In their CDP disclosures TD, RBC, BMO and Scotiabank indicated that they consider the physical
impacts of extreme weather events for their own operations with some of them making
specific reference to facilities in climate sensitive regions such as the Caribbean. All five banks
reference short-term risks from uncertainty around new regulation as well as potential impacts
of energy efficiency regulation and carbon taxes. However, all of the banks considered the risks
associated with such regulation to be low based on their perception that the pace of regulating
carbon to date has been slow. In their most recent CDP disclosures the banks acknowledge the
reputational risks associated with their financing of carbon-intensive industries, although it is
not clear how any of the banks are managing this risk. We find that Canadian banks’disclosures
of their consideration of systemic risks associated with climate change and the potential impacts
of transitioning to a low carbon economy on their overall business model fall short of what is
needed by investors to make informed investment decisions.
Performance
Canada’s banks have focused their efforts on mitigating their operational emissions, with
some of the banks looking more closely at financial product innovations to respond to
growing consumer demand for green products. TD is the only bank that provides monetary
incentives to its corporate executive team for meeting targets related to energy reduction,
carbon reduction and promotion of carbon solutions within the bank’s business strategy. All
of the banks lend to the renewable energy sector and the cumulative value of that lending is
approximately $6.4 billion. However, none of the banks report similar figures for their lending
to fossil fuel companies, making it impossible to determine the degree to which bank financing
is contributing to an overall shift towards renewable energy sources. None of the banks
have established targets to reduce the carbon footprints or carbon intensity of their lending,
investment or financing portfolios.
Disclosure
For investors to analyze how banks are managing the risks associated with climate change,
they need better information. For example, reporting the value of each bank’s financing to
GHG intensive industries including coalmines, oil sands, oil and gas extraction and power
generation alongside the value of their financing for renewable energy provides investors with
valuable information about their exposure to carbon intensive assets and the degree to which
they are shifting financing towards greener industries. In addition, investors need information
about the assumptions banks are making about carbon prices in their asset valuations and
credit risk analyses. Current disclosure by Canada’s banks remains focused on metrics that are
less relevant to risk, such as their operational GHG emissions as well as emissions associated
with employee business travel, deliveries to bank properties, waste generation and leased
assets. None of Canada’s banks currently disclose the value of their financed emissions, which
are emissions associated with lending, investing and project finance. If the banks are not
measuring the carbon exposure of their portfolios then they are probably not effectively
managing the associated risks.15
Good Practice Example:
Performance
Bank of America
Bank of America committed in 2004
to reduce the emissions rate in its
utility portfolio by 7% by 2008. Since
that goal was reached, the bank
continues measuring and reporting
annually on the carbon intensity
of its utility portfolio and plans to
re-evaluate its reporting when a
national regulation of GHG emissions
is established.
Good Practice Example:
Disclosure
Royal Bank of Scotland
To set a benchmark for financial
services disclosure, since 2010 RBS
has published an energy financing
report depicting its total lending to
the energy sector with a breakdown
between the fossil fuel and renewable
subsectors. RBS also discloses the
carbon risks from its lending to its
top 25 power and oil & gas clients by
mapping the lending exposure to
their carbon intensity.
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 11 |
As the business consequences of climate change mount, investors are beginning to
consider the investment risks across their portfolios and new opportunities associated
with climate change solutions. An important dimension of this for investors is to better
understand how the companies in which they invest, including Canada’s banks, are
managing the potential impacts of climate change on their core business activities and
aligning their policies and practices with a low-carbon economy. Reducing operational
emissions is not sufficient. Investors need better information from Canada’s banks
on how they are embedding climate change into risk management, asset valuation,
investment decision-making and long-term business planning. The following table
provides a framework for how Canada’s banks can improve their performance in
addressing climate change.
Investor Recommendations for Addressing Climate Change
Establish a Climate Change Strategy
Develop a climate change statement outlining an institutional commitment to limit the
average surface temperature rise to 2°Celsius. The statement should outline how the
bank addresses climate change, the steps it is taking to reduce the climate impacts of
its operations and financing activities and how the bank is contributing to an energy
transition.
Integrate Climate Change Considerations into Risk Management
Analysis of business and portfolio sensitivity (including asset stranding) to climate
change and carbon regulation scenarios.
Carbon footprints of lending and investment portfolios measured and analyzed.
Establish Carbon Reduction Targets And Incentives To Achieve Them
Performance targets to reduce operational and financed GHG emissions established
that align with IPCC models to limit warming to 2°Celsius.
Executive compensation and incentive packages include performance in reducing GHG
emissions from operational and financed sources.
Disclose Meaningful Information To Investors
Energy financing reports published that outline lending to the energy sector with a
breakdown of financing to coalmines, oil sands, oil and gas extraction, gas- and coal-
fired power generation and renewable energy.
Carbon price or price ranges used in asset valuations and project assessments
published.
Public policy positions related to climate change and corporate lobbying activities
including payments to trade associations disclosed
INVESTOR RECOMMENDATIONS
FOR ADDRESSING CLIMATE CHANGE
www.share.ca | 12 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
CONCLUSION
Investors are invited to use this document as part of their stewardship activities to gauge bank
performance in addressing climate change and to engage with the banks in their portfolios on
climate-change issues. Active engagement by investors encourages Canada’s banks to recognize
the potential business impacts of climate change and demonstrate that they are managing and
adapting to climate change-related risks and opportunities accordingly.
www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 13 |
Endnotes
1
	 IPCC (2013). Climate Change 2013: The Physical Science Basis – Summary for Policymakers.
2
	 Ibid.
3
	 Natural Resources Canada, From Impacts to Adaptation: Canada in a Changing Climate (2008),
online: www.nrcan.gc.ca/environment/resources/publications/impacts-adaptation/reports/
assessments/2008/10253.
4
	 IPCC (2013). Climate Change 2013: The Physical Science Basis. Summary for Policymakers.
5
	 Known as the Cancun Agreements. More information at: http://cancun.unfccc.int/cancun-
agreements/main-objectives-of-the-agreements/#c33.
6
	 See www.cop21.gouv.fr/en/cop21-cmp11/cop21-main-issues.
7
	 For example, The Stern Review on the Economics of Climate Change found that if we do not act,
the overall costs of climate change could be equivalent to losing between 5 and 20% of global GDP
per year and that the costs of action – reducing GHGs to avoid the worst impacts of climate change
– could be limited to around 1% of global GDP each year. See www.wwf.se/source.php/1169157/
Stern%20Report_Exec%20Summary.pdf.
8
	 M. Nachmany et. al. (2015) Global Climate Legislation Study: Summary for Policy Makers. Available
from: www.lse.ac.uk/GranthamInstitute/legislation/2015-global-climate-legislation-study-at-a-
glance.
9
	 Carbon Trust (2008) Climate Change – A Business Revolution? How Tackling Climate Change Could
Create or Destroy Company Value. Co-analysis with Mc Kinsey & Co. Available from:
www.carbontrust.com/media/84956/ctc740-climate-change-a-business-revolution.pdf.
10
	 International Energy Agency (2012) World Energy Outlook. Available from: www.iea.org/publications/
freepublications/publication/English.pdf.
11
	 CDP (2011) CDP 500 Global Report. Available from: www.cdproject.net/CDPResults/CDP-G500-2011-
Report.pdf.
12
	 BankTrack (2014) Banking on Coal: Bank Financing of Coal Mining and Coal Power and Why it Must
Stop. Available from: www.banktrack.org/manage/ems_files/download/banking_on_coal_2014_pdf/
banking_on_coal_2014.pdf.
13
	 The CDP sends annual information requests to the world’s largest companies on behalf of 822
institutional investors with US$95 trillion in assets. Disclosed information is made available by the
CDP for integration in business, investment and policy decision-making. BMO, CIBC, Scotiabank and
TD all responded to the 2014 CDP Information Request. RBC responded to the 2013 CDP information
request and has stated it will answer the CDP on a biennial as opposed to annual basis.
14
	 Norges Bank Investment Management (2014) Climate Change Strategy: Expectations for Companies.
Available from: www.nbim.no/en/responsibility/responisble-investments/climate-change.
15
	 GHG Protocol (2014) Concept Note: GHG Protocol Financial Sector Guidance. Available from:
www.ghgprotocol.org/files/ghgp/Concept%20Note%20GHG%20Protocol%20Financial%20
Sector%20Guidance%20final.pdf.
www.share.ca | 14 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks
1055 West Georgia Street
26th Floor PO Box 11171
Royal Centre
Vancouver, BC V6E 3R5
T: 604 408 2456
F: 604 408 2525
E: info@share.ca
www.share.caOCTOBER 2015
The Hidden Risks of Climate Change for Canadian Banks
Banking on 2°

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Climate Change and Bank Paper FINAL

  • 1. The Hidden Risks of Climate Change for Canadian Banks OCTOBER 2015 Banking on 2°
  • 2. www.share.ca | 2 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks Authors: Shannon Rohan, Director of Responsible Investment, SHARE Hasina Razafimahefa, Research Assistant, SHARE Reviewers: Peter Chapman, Executive Director, SHARE Kevin Thomas, Director of Engagement, SHARE Aaron Ziulkowski, Senior ESG Analyst, Walden Asset Management Dr. Rory Sullivan, Senior Research Fellow, University of Leeds Any errors or omissions are solely the responsibility of the authors. Published by the Shareholder Association for Research and Education (SHARE), October 2015 SHARE (Shareholder Association for Research and Education) is a Canadian leader in responsible investment. SHARE advises institutional investors on the development and implementation of responsible investment practices. Created in 2000, SHARE provides proxy voting, shareholder engagement, board education and research on emerging responsible investment issues. SHARE has been engaging with Canadian banks on climate change related risks and opportunities since 2012 on behalf of our institutional investor clients with approximately $14 billion in assets under management. For more information on SHARE, please visit: www.share.ca Except where noted, this work is licensed under a Creative Commons Attribution- NonCommercial-NoDerivatives 4.0 International License.
  • 3. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 3 | EXECUTIVE SUMMARY 4 INTRODUCTION 5 CLIMAGE CHANGE-RELATED RISKS 6 FOR CANADA’S BANKS Regulatory Risks 7 Physical Risks 7 Reputational Risks 7 Systemic Risks 8 Competitive Risks 8 HOW CANADA’S BANKS ARE RESPONDING 9 TO CLIMATE CHANGE Strategy 9 Risk Management 9 Performance 10 Disclosure 10 INVESTOR RECOMMENDATIONS FOR 11 ADDRESSING CLIMATE CHANGE CONCLUSION 12 ENDNOTES 13 Banking on 2° The Hidden Risk s of Climate Change for Canadian Bank s “The decisions we make now will determine the future of our economy and our climate. If we choose low-carbon investment we can generate strong, high-quality growth – not just in the future, but now. But if we continue down the high-carbon route, climate change will bring severe risks to long-term prosperity.” Lord Nicholas Stern, Chair of the Centre for Climate Change Economics and Policy
  • 4. www.share.ca | 4 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks EXECUTIVE SUMMARY Climate change is one of the defining economic, environmental and social issues of our time. There is broad global consensus that to avoid the worst and most catastrophic effects of climate change we must limit the rise in the average global surface temperature to two degrees Celsius above pre-industrial levels. In order to achieve this, we need to transition towards resilient, low carbon societies and economies. Canada’s banks have an important stake in addressing this challenge. Bank’s financing activities span all sectors of the economy, making them particularly vulnerable to climate change related risks. However, to date, Canada’s banks have not sufficiently integrated climate change considerations into long-term business strategies and risk management processes. To help fill this gap, we provide a framework for how Canada’s banks can improve their performance in addressing climate change. Investor Recommendations for Addressing Climate Change Establish a Climate Change Strategy Develop a climate change statement outlining an institutional commitment to limit the average surface temperature rise to 2°Celsius. The statement should outline how the bank addresses climate change, the steps it is taking to reduce the climate impacts of its operations and financing activities and how the bank is contributing to an energy transition. Integrate Climate Change Considerations into Risk Management Analysis of business and portfolio sensitivity (including asset stranding) to climate change and carbon regulation scenarios. Carbon footprints of lending and investment portfolios measured and analyzed. Establish Carbon Reduction Targets And Incentives To Achieve Them Performance targets to reduce operational and financed GHG emissions established that align with IPCC models to limit warming to 2°Celsius. Executive compensation and incentive packages include performance in reducing GHG emissions from operational and financed sources. Disclose Meaningful Information To Investors Energy financing reports published that outline lending to the energy sector with a breakdown of financing to coalmines, oil sands, oil and gas extraction, gas- and coal- fired power generation and renewable energy. Carbon price or price ranges used in asset valuations and project assessments published. Public policy positions related to climate change and corporate lobbying activities including payments to trade associations disclosed.
  • 5. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 5 | INTRODUCTION Climate change is one of the defining economic, environmental and social issues of our time. According to the Intergovernmental Panel on Climate Change (IPCC), scientific evidence for warming of the climate system is unequivocal.1 In its Fourth Assessment Report, the IPCC concluded that there is more than 95 percent probability that human activities are responsible for the emissions of heat-trapping Greenhouse Gases (GHG), which raise global temperatures. 2 Climate change has already had observable effects on the environment. In Canada, the impacts of a changing climate are evident in observed trends including temperature increases (on average Canada has warmed by more than 1.3°C since 1948), higher average annual precipitation rates (mean rainfall has increased by about 12%), changes in the frequency of extreme temperature and precipitation events, changes in the distribution of some animal and plant species, declining Arctic sea ice cover (decreased by 8% since 1979) and decreased snow-cover duration.3 Many of the most severe and costly impacts of climate change are those related to the projected rise in the frequency and magnitude of extreme weather events and associated natural disasters. Climate scientists warn that these impacts will increase in frequency and intensity without substantial and sustained cuts in GHG emissions.4 There is broad agreement, crystalized in the agreements reached by governments in 2010 at the United Nations Climate Conference in Cancun,5 that in order to avoid the worst and most catastrophic effects of climate change we must limit the rise in the average global surface temperature to two degrees Celsius above pre-industrial levels. In order to achieve this, we need to transition to a low-carbon economy. A key step in this transition will be the 21st Session of the Conference of the Parties to the United Nations Framework Convention on Climate Change (COP 21) to be held in Paris in December 2015. The purpose of the conference is to reach a universal, legally binding agreement that will enable the international community to combat climate change and boost the transition towards resilient, low-carbon societies and economies. A key theme for COP21 is how to mobilize investments of $100 billion per year by developed countries, from both public and private sources, to enable this transition.6 Canada’s banks are involved in a range of activities that may be affected by climate change. These include retail banking, mortgage lending, business lending, project finance, asset management and investment banking. Because of the potential impacts of climate change on these financing activities, shareholders are interested in understanding how the banks are managing these risks including their overall exposure to carbon-intensive assets and how they are aligning their longer-term business strategies to a low-carbon economy. This paper outlines the impacts that climate change-related risks could have for the banking sector and provides a set of recommendations for how the banks can more effectively manage climate-change related risks and catalyze the transition to a low carbon economy. Our analysis focused on Canada’s five largest banks: Bank of Montreal (BMO), Canadian Imperial Bank of Commerce (CIBC), Royal Bank of Canada (RBC), Scotiabank and Toronto-Dominion Bank (TD).
  • 6. www.share.ca | 6 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks CLIMATE CHANGE-RELATED RISKS FOR CANADA’S BANKS The global economy faces significant and diverse economic risks from climate change.7 Canada’s banks are particularly vulnerable to the risks associated with climate change because of their portfolio exposure to carbon-intensive industries. Figure 1 below outlines the climate change- related risks that Canadian banks are exposed to and the potential impacts of those risks for the banks in terms of asset valuations, operational costs, reputation, new markets and cash flows. Figure 1: Potential Impacts of Climate Change on Bank’s Financing Activities IMPACTS Asset Mispricing Elevated Credit and Default Risk Retail Banking Mortgage Lending Asset Management Investment Banking Access to New MarketsChange in Cash Flows Higher Operational Costs $! CLIMATE CHANGE- RELATED RISKS BANK FINANCING ACTIVITIES Regulatory Risk Physical Risk Systemic Risk Competitive Risk Reputational Risk Retail Banking Mortgage Lending Asset Management Investment Banking
  • 7. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 7 | Regulatory Risks While a global agreement to restrict GHG emissions has yet to be reached, significant developments in regional and national policies addressing climate change are already occurring. According to the 2015 Global Climate Legislation Study, by the end of 2014 there were 804 climate change laws and policies in 98 countries, which together produce approximately 93% of global greenhouse gas emissions.8 The number of national laws and policies that directly relate to climate change mitigation and adaptation has risen from only 54 laws and policies in 1997 to 426 in 2009 and by the end of 2014 to over 800. The asset valuation methodologies currently used by the banking sector do not sufficiently account for the potential impacts of climate change regulations. For example, asset valuations of fossil fuel companies tend to assume that all known reserves will be exploited. A study by Carbon Trust and McKinsey showed that more than 50% of the market value assigned to oil and gas companies resides in the value of long-term cash flows to be generated from their reserves in a timeframe beyond ten years.9 However, according to the International Energy Agency, no more than one-third of proven reserves of fossil fuels can be consumed prior to 2050 if the world is to achieve the 2-degree goal.10 The potential for asset stranding in response to carbon reduction regulations will impact financial institutions with exposure to fossil fuel companies, with potential impacts for asset valuations, credit and default risk and ultimately cash flows. Physical Risks Banks’own operations and their lending portfolios are exposed to risks associated with the physical impacts of climate change. For example, physical damage to corporate assets connected to extreme weather events may lead to an increase in defaults in commercial lending portfolios. Real estate, agribusiness and infrastructure have been assessed as being particularly vulnerable. Mortgage portfolios in geographical areas at high risk of flooding, for instance may face devaluation risks and have higher payment defaults. Banks’operational infrastructure is also vulnerable to the physical impacts of climate change. Incorporating the physical risks of climate change into bank risk management frameworks is important to account for portfolio and operational exposure and to mitigate these risks by adjusting investment decisions. Reputational Risks The banking sector has become a target of environmental campaigns over their financing of carbon-intensive projects such as mountaintop removal in coal production, coal-fired power generation and oil sands extraction.11 As public awareness and concern about climate change grows, it is reasonable to assume that continued fossil fuels financing and misalignment with a transition to a low carbon economy will present increasing reputational risks to banks. For example, in their 2014 Banking on Coal report, BankTrack noted that banks from Canada, Japan, France, Switzerland, Germany and Australia, provided more than 5 billion Euros in coal financing during the period 2011 to 2013.12 Of particular note, all five Canadian banks acknowledged in their most recent CDP disclosures the reputational risks associated with their financing of carbon- intensive industries .
  • 8. www.share.ca | 8 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks Systemic Risks The Canadian banking sector is exposed to systemic risks associated with the transition away from fossil fuels and towards a low-carbon economy. Rapid shifts in technologies, regulations, and carbon pricing could have substantial impacts on the demand for fossil fuels globally. As the recent oil price shocks have demonstrated, declining fossil fuel demand and/or prices can create dramatic and unexpected impacts across the entire Canadian economy. Considering these systemic risks and integrating them into risk management frameworks is critical for Canada’s banks if they are to fully understand the impacts of different regulatory and physical climate scenarios on their business models. Competitive Risks The shift to a low-carbon economy is generating important opportunities across economic sectors where green products and services are growing in demand. Financial institutions that are not building their capacity and investing in product innovation to respond to these opportunities may face a competitive disadvantage. Conversely, financial institutions that are analyzing the impacts of climate change on their portfolios and tilting their financing to those sectors that will benefit from a low-carbon economy may enjoy a competitive advantage in the marketplace.
  • 9. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 9 | HOW CANADA’S BANKS ARE RESPONDING TO CLIMATE CHANGE SHARE analyzed publicly available information from Canada’s five largest banks including websites, corporate responsibility reports, SEDAR filings and CDP13 disclosures for 2013 and 2014 to understand how each bank is responding to climate change. We looked specifically at each bank’s approach to strategy, risk management, performance and climate risk disclosure. Here we provide a brief summary of the state of practice by Canada’s five largest banks and provide some good practice examples from other jurisdictions. Strategy For investors to manage and assess long-term risks to their portfolios they need to understand how the companies in which they invest are integrating climate change risks and opportunities into business strategy development and implementation. Emerging good practice includes prioritizing climate change at the board level, establishing an institutional commitment to accelerating the shift to a low-carbon economy and integrating climate change performance into executive mandates and compensation. Leaders are also analyzing different regulatory and physical climate scenarios in order to effectively integrate climate change considerations into risk management, business development and asset valuations.14 The primary focus of Canada’s five largest banks is mitigating their own operational emissions. The drivers for addressing climate change appear to be primarily short- term and focused on opportunities to generate cost-savings, with some of the banks increasingly looking at business opportunities to take advantage of consumer demand. To date, the banks have not provided investors with sufficient information on how they are analyzing the sensitivity of their business models and long-term business strategies to different future economic, regulatory and physical climate scenarios. Risk Management To measure and manage risk, investors need information from companies on how they are considering climate change-related risks, including the potential impacts of climate change on their own operations as well as those associated with their financing activities. In the case of Canada’s banks, the biggest risks from climate change are those that will impact their lending, investment and financing portfolios. TD, Scotiabank, RBC and BMO report incorporating climate change considerations into company valuations and credit risk assessments, although they provide little information to investors on how they do this, what carbon price or price ranges they use or what percentage of their portfolios face specific risks such as asset stranding. Good Practice Example: Strategy Nedbank South Africa In its climate change position statement, Nedbank outlines a climate change strategy that includes a commitment to redirect a portion of the bank’s lending flows to accelerate decarbonisation of the economy explicitly at a rate that is commensurate with the national carbon budget, i.e. South Africa’s equitable share of the global commitment to avoid a 2 degree Celsius average surface temperature rise. The bank’s strategy to meet this commitment comprises of a carbon screen of its lending portfolio and increased lending to low-carbon sectors. Good Practice Example: Risk Management European Investment Bank In 2010, EIB started adopting a shadow carbon price for its investments in energy projects of €25/tCO2e. The price increases by €1 every year, reaching €45/tCO2e in 2030.
  • 10. www.share.ca | 10 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks In their CDP disclosures TD, RBC, BMO and Scotiabank indicated that they consider the physical impacts of extreme weather events for their own operations with some of them making specific reference to facilities in climate sensitive regions such as the Caribbean. All five banks reference short-term risks from uncertainty around new regulation as well as potential impacts of energy efficiency regulation and carbon taxes. However, all of the banks considered the risks associated with such regulation to be low based on their perception that the pace of regulating carbon to date has been slow. In their most recent CDP disclosures the banks acknowledge the reputational risks associated with their financing of carbon-intensive industries, although it is not clear how any of the banks are managing this risk. We find that Canadian banks’disclosures of their consideration of systemic risks associated with climate change and the potential impacts of transitioning to a low carbon economy on their overall business model fall short of what is needed by investors to make informed investment decisions. Performance Canada’s banks have focused their efforts on mitigating their operational emissions, with some of the banks looking more closely at financial product innovations to respond to growing consumer demand for green products. TD is the only bank that provides monetary incentives to its corporate executive team for meeting targets related to energy reduction, carbon reduction and promotion of carbon solutions within the bank’s business strategy. All of the banks lend to the renewable energy sector and the cumulative value of that lending is approximately $6.4 billion. However, none of the banks report similar figures for their lending to fossil fuel companies, making it impossible to determine the degree to which bank financing is contributing to an overall shift towards renewable energy sources. None of the banks have established targets to reduce the carbon footprints or carbon intensity of their lending, investment or financing portfolios. Disclosure For investors to analyze how banks are managing the risks associated with climate change, they need better information. For example, reporting the value of each bank’s financing to GHG intensive industries including coalmines, oil sands, oil and gas extraction and power generation alongside the value of their financing for renewable energy provides investors with valuable information about their exposure to carbon intensive assets and the degree to which they are shifting financing towards greener industries. In addition, investors need information about the assumptions banks are making about carbon prices in their asset valuations and credit risk analyses. Current disclosure by Canada’s banks remains focused on metrics that are less relevant to risk, such as their operational GHG emissions as well as emissions associated with employee business travel, deliveries to bank properties, waste generation and leased assets. None of Canada’s banks currently disclose the value of their financed emissions, which are emissions associated with lending, investing and project finance. If the banks are not measuring the carbon exposure of their portfolios then they are probably not effectively managing the associated risks.15 Good Practice Example: Performance Bank of America Bank of America committed in 2004 to reduce the emissions rate in its utility portfolio by 7% by 2008. Since that goal was reached, the bank continues measuring and reporting annually on the carbon intensity of its utility portfolio and plans to re-evaluate its reporting when a national regulation of GHG emissions is established. Good Practice Example: Disclosure Royal Bank of Scotland To set a benchmark for financial services disclosure, since 2010 RBS has published an energy financing report depicting its total lending to the energy sector with a breakdown between the fossil fuel and renewable subsectors. RBS also discloses the carbon risks from its lending to its top 25 power and oil & gas clients by mapping the lending exposure to their carbon intensity.
  • 11. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 11 | As the business consequences of climate change mount, investors are beginning to consider the investment risks across their portfolios and new opportunities associated with climate change solutions. An important dimension of this for investors is to better understand how the companies in which they invest, including Canada’s banks, are managing the potential impacts of climate change on their core business activities and aligning their policies and practices with a low-carbon economy. Reducing operational emissions is not sufficient. Investors need better information from Canada’s banks on how they are embedding climate change into risk management, asset valuation, investment decision-making and long-term business planning. The following table provides a framework for how Canada’s banks can improve their performance in addressing climate change. Investor Recommendations for Addressing Climate Change Establish a Climate Change Strategy Develop a climate change statement outlining an institutional commitment to limit the average surface temperature rise to 2°Celsius. The statement should outline how the bank addresses climate change, the steps it is taking to reduce the climate impacts of its operations and financing activities and how the bank is contributing to an energy transition. Integrate Climate Change Considerations into Risk Management Analysis of business and portfolio sensitivity (including asset stranding) to climate change and carbon regulation scenarios. Carbon footprints of lending and investment portfolios measured and analyzed. Establish Carbon Reduction Targets And Incentives To Achieve Them Performance targets to reduce operational and financed GHG emissions established that align with IPCC models to limit warming to 2°Celsius. Executive compensation and incentive packages include performance in reducing GHG emissions from operational and financed sources. Disclose Meaningful Information To Investors Energy financing reports published that outline lending to the energy sector with a breakdown of financing to coalmines, oil sands, oil and gas extraction, gas- and coal- fired power generation and renewable energy. Carbon price or price ranges used in asset valuations and project assessments published. Public policy positions related to climate change and corporate lobbying activities including payments to trade associations disclosed INVESTOR RECOMMENDATIONS FOR ADDRESSING CLIMATE CHANGE
  • 12. www.share.ca | 12 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks CONCLUSION Investors are invited to use this document as part of their stewardship activities to gauge bank performance in addressing climate change and to engage with the banks in their portfolios on climate-change issues. Active engagement by investors encourages Canada’s banks to recognize the potential business impacts of climate change and demonstrate that they are managing and adapting to climate change-related risks and opportunities accordingly.
  • 13. www.share.caBanking on 2° The Hidden Risks of Climate Change for Canadian Banks 13 | Endnotes 1 IPCC (2013). Climate Change 2013: The Physical Science Basis – Summary for Policymakers. 2 Ibid. 3 Natural Resources Canada, From Impacts to Adaptation: Canada in a Changing Climate (2008), online: www.nrcan.gc.ca/environment/resources/publications/impacts-adaptation/reports/ assessments/2008/10253. 4 IPCC (2013). Climate Change 2013: The Physical Science Basis. Summary for Policymakers. 5 Known as the Cancun Agreements. More information at: http://cancun.unfccc.int/cancun- agreements/main-objectives-of-the-agreements/#c33. 6 See www.cop21.gouv.fr/en/cop21-cmp11/cop21-main-issues. 7 For example, The Stern Review on the Economics of Climate Change found that if we do not act, the overall costs of climate change could be equivalent to losing between 5 and 20% of global GDP per year and that the costs of action – reducing GHGs to avoid the worst impacts of climate change – could be limited to around 1% of global GDP each year. See www.wwf.se/source.php/1169157/ Stern%20Report_Exec%20Summary.pdf. 8 M. Nachmany et. al. (2015) Global Climate Legislation Study: Summary for Policy Makers. Available from: www.lse.ac.uk/GranthamInstitute/legislation/2015-global-climate-legislation-study-at-a- glance. 9 Carbon Trust (2008) Climate Change – A Business Revolution? How Tackling Climate Change Could Create or Destroy Company Value. Co-analysis with Mc Kinsey & Co. Available from: www.carbontrust.com/media/84956/ctc740-climate-change-a-business-revolution.pdf. 10 International Energy Agency (2012) World Energy Outlook. Available from: www.iea.org/publications/ freepublications/publication/English.pdf. 11 CDP (2011) CDP 500 Global Report. Available from: www.cdproject.net/CDPResults/CDP-G500-2011- Report.pdf. 12 BankTrack (2014) Banking on Coal: Bank Financing of Coal Mining and Coal Power and Why it Must Stop. Available from: www.banktrack.org/manage/ems_files/download/banking_on_coal_2014_pdf/ banking_on_coal_2014.pdf. 13 The CDP sends annual information requests to the world’s largest companies on behalf of 822 institutional investors with US$95 trillion in assets. Disclosed information is made available by the CDP for integration in business, investment and policy decision-making. BMO, CIBC, Scotiabank and TD all responded to the 2014 CDP Information Request. RBC responded to the 2013 CDP information request and has stated it will answer the CDP on a biennial as opposed to annual basis. 14 Norges Bank Investment Management (2014) Climate Change Strategy: Expectations for Companies. Available from: www.nbim.no/en/responsibility/responisble-investments/climate-change. 15 GHG Protocol (2014) Concept Note: GHG Protocol Financial Sector Guidance. Available from: www.ghgprotocol.org/files/ghgp/Concept%20Note%20GHG%20Protocol%20Financial%20 Sector%20Guidance%20final.pdf.
  • 14. www.share.ca | 14 Banking on 2° The Hidden Risks of Climate Change for Canadian Banks 1055 West Georgia Street 26th Floor PO Box 11171 Royal Centre Vancouver, BC V6E 3R5 T: 604 408 2456 F: 604 408 2525 E: info@share.ca www.share.caOCTOBER 2015 The Hidden Risks of Climate Change for Canadian Banks Banking on 2°