As these are new requirements on schemes, The Pensions Regulator (TPR) has analysed a selection of reports and published its findings to help raise standards across industry.
The review found many examples of good strategic decision-making and that more than 60% of reports in TPR’s sample had some form of net zero goal with a target date of 2050 or earlier.
Mark Hill, TPR’s Climate and Sustainability Lead, added: “Climate change disclosures should be the product of good risk management.
“That's why we want schemes to know what ‘good’ looks like and improve their management of climate-related risks and opportunities.
“Even if not yet in scope for disclosures, schemes should act now and read this report to help them in their strategic decision-making.”
Review findings
As well as detailed feedback for trustees and those preparing climate disclosures, the report includes observations on good practice and improvements, split out by each main reporting section.
The review also found examples of trustee action on climate risk including:
• updating defined contribution default lifestyle strategies to include sustainable funds
• increasing allocation to low carbon tracker funds or companies with 'high levels of green revenue'
• exploring opportunities such as forestry, green bonds or committing funds to private market renewables
• encouraging fund managers to engage with top carbon dioxide emitters
And when preparing reports, TPR said trustees should consider:
• Context: Providing information, such as scheme size, structure of DB sections, DC popular default funds, early in the report helps put it in context for readers.
• Materiality: Where reports referred to specific investment mandates, explaining their size in relation to total scheme assets helps readers understand an issue’s materiality.
• Generic wording: Including specifics on policies, steps to manage risks and information from advisers could improve reports.
• Developments between reports: Reusing parts of previous reports is sensible, providing legal requirements are met. These elements should be supplemented with a summary of developments and activities during the reporting year.
• Length: The quality of reports did not necessarily correlate with their length. Reports reviewed varied in length, up to 94 pages with an average of 38 pages.
• Member summaries: Some reports had excellent plain English summaries.
• Action plans: Where trustees used the reporting process to identify additional work, they should set a plan, monitor and update on progress in their next report.
Scenario analysis
TPR said it had observed some good practice on scenario analysis but also areas of concerns.
It added future reports could be improved by trustees:
• considering a qualitative analysis based on clear narratives while quantitative analysis is still developing in the market
• providing commentary on the challenges and limitations of the scenario analysis they have undertaken
• taking into account the challenges and limitations of their analysis when drawing conclusions about their scheme’s exposure to risks
TPR suggested points trustees could discuss with their advisers, including latest market developments and whether any developments mean it is appropriate scenario analysis is re-run.
Net zero targets
More than 60% (19 out of 30) of the reports in TPR’s sample had some form of net zero goal with a target date of 2050 or earlier. While there is no requirement for trustees to set a net zero target, TPR said such targets can be consistent with sensible risk management.
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