NetZeroWeekTM – Do pension schemes have a duty and a role to play in addressing the threat of climate change? |
By Joe Condy, Chartered MCSI Investment Consultant at Quantum Advisory Climate change is an enormous challenge and threat globally. Large investors, such as pension schemes, can have a significant influence in addressing this challenge. NetZeroWeekTM provides a reminder of the risks we face and actions that can be taken. In this article, we aim to answer two important questions:
• Do pension schemes have a duty to address the threat of climate change; and As long-term investors, trustees of pension schemes should consider the potential risks of climate change on their ability to meet their fiduciary duties.
NetZeroWeekTM - What is it?
Climate Change and Net Zero Net zero essentially means achieving an overall balance between the greenhouse gases we emit and the greenhouse gases we take out of the atmosphere. Think of it like achieving balance on a weighing scale. At the moment, we emit far more emissions than we remove. Therefore, the weighing scales are tilted, and the planet is warming. The consensus among scientists is that this could have many detrimental impacts on our planet and societies over the long term. This ultimately prompted the Paris Agreement, an international treaty adopted to combat climate change. The main aim is to limit global warming to well below 2 degrees Celsius above pre-industrial levels, ideally aiming for 1.5 degrees Celsius. So, we have established that climate change is a problem which needs addressing somehow but…
How do we balance the “scales”?
1. Reduce emissions We can also improve our energy efficiency. This might include retrofitting and decarbonising buildings, increasing the use of public transport, decarbonising the manufacturing processes of widely used materials (cement and plastics for example), adopt circular economy habits (reduce, reuse and recycle) and more.
2. Remove emissions But you may be wondering – what does any of this have to do with the pensions and investment industry?
Do pension schemes have a “duty” to address the problems posed by climate change? However, the reality is, government budgets worldwide are “stretched”, to put it lightly. Therefore, they are increasingly looking towards the private sector, including pension schemes, for support in implementing their “green/climate change policies”. Not least here in the UK. Why? The pensions sector is a major allocator of capital. As at the end of September 2023, the market value of UK pension scheme assets alone totaled c.£1.8 trillion. To some, it may come as no surprise that governments, particularly in the UK for example, are encouraging pension schemes to invest in a way that helps governments meet their policy objectives and to consider the risks that climate change poses not only on the scheme itself but on the wider economy. But what duties do trustees have exactly? Some might argue that the only responsibility that pension schemes have is ensuring that member benefits can be paid as they arise (in the case of Defined Benefit schemes) and ensuring that members have access to investments that will meet their investment objectives, allowing them to save for their future retirement (in the case of DC schemes). Therefore, investment strategies should be designed in a manner which optimises these outcomes, regardless of the knock-on effects on the wider economy. On the other hand, whilst they agree that these are their main duties, they may also argue that climate change poses significant risks to the ability to fulfil these duties. Therefore, we should be actively considering the potential risks and seeking to mitigate/minimise them as far as possible. Both arguments have their own merit and like many things in life, the answers are not black or white. It is near impossible to predict exactly how climate change will impact stewards of capital to fulfill their duties over the long-term. We can take educated guesses and try to quantify the risk in some way, like many trustees have been required to do so through their Taskforce for Climate-Related Financial Disclosures reporting obligations. However, there has been much debate about the usefulness of the quantitative modelling and analysis provided in these reports and it’s not always about the numbers… In February this year, the Financial Markets Law Committee issued a paper which sought to clarify the legal position, the uncertainties and difficulties that exist over what trustees’ “fiduciary duties” demand from a sustainability and climate change perspective. Whilst the conclusion was not as instructive as some may have hoped, the main message was as follows:
• Trustees must first and foremost balance return against risk, considering financially material factors followed by non-financial factors. This implies that trustees should explore how material climate change risks are to the scheme, by using both quantitative data and “narrative” based considerations. Should they conclude that the risks are financially material, or if they think the scheme members are concerned about this issue, then trustees have an obligation to take these considerations into account when setting investment policies and strategies for the pension schemes that they govern. Furthermore, omitting the subject of climate change from consideration because of its uncertainty is not a viable option. This extract from the paper sums this point up nicely: “In constructing strategy, principles and policies, and throughout the management of the (pension) fund, it is proper for pension fund trustees to situate their pension fund within the wider economy. In doing so, sustainability and the subject of climate change, can, along with other factors, be considered by pension fund trustees when seeking to achieve the purpose of the scheme.” What role can pension schemes play in addressing the problem (or mitigating the risks)? From a governance perspective, the new General Code of Practice which came into force in March this year introduces new requirements for all trustees of pension schemes to consider climate change risk. This includes formally disclosing their policy on climate change, which is a now a requirement under the General Code and ensuring that climate change risk is being fully considered when the investment strategy is set. Whilst the latter is not a requirement, it is recommended by the Pensions Regulator. We would always advocate having the proper governance structures in place to review all risks faced by pension schemes, and adding climate change to the agenda sounds reasonable. On the assumption that trustees deem the risks posed by climate change to be financially material or meet the criteria to be a non-financial factor to consider, there are actions that trustees can take to address the problem and/or mitigate the risk within pension schemes. There is some debate in the industry between reducing the scheme level carbon footprint and actually influencing real world decarbonisation.
1. Reducing scheme level carbon footprint
However, some may argue that whilst the headline emissions figure will be lower, and climate transition risks at a scheme level are potentially lower, this does not solve or address the issue of influencing real world decarbonisation. By excluding certain sectors and tilting towards companies that are already more carbon-efficient, this reduces the capital pool available to high-emitting sectors which are crucial to fund their transition. This is discussed below. On the first point, investing in new and emerging technologies through private market or infrastructure funds is now achievable for many pension schemes. This might include investments in natural capital, renewable energy projects and private companies who are pioneering new technologies. The second point, which is somewhat controversial to some, is “transition” investing. This recognises that without certain high-emitting industries, the goal of achieving net zero is far more difficult. The reality is, some crucially important sectors are notoriously difficult to decarbonise (for example, cement and steel) and so supplying the capital that will help them achieve this over time, and engaging with these types of companies, is critical if we are to achieve the net zero target. In reality, all of these approaches are intertwined. A pension scheme may have an allocation to passive equity funds which track a “climate-aware” index, whilst also having an allocation to private market assets. Some trustees might take the view that investing in the entire economy and ensuring that the asset managers they employ use their voice to encourage change across the board is the most effective solution to the “big” problem. It is difficult to argue against this case.
Conclusion
To answer the question: “Do pension schemes have a duty and a role to play in addressing the threat of climate change?”, whilst we do not think that trustees have an explicit duty to address the problem, we do think they must consider the potential risks that climate change may pose on their ability to achieve their fiduciary duty. |
|
|
|
STAR EXCLUSIVE: BPA Pricing Actuaries | ||
Flex / hybrid 2-3 dpw office-based - Negotiable |
Ceded Re Pricing Actuary | ||
London - £150,000 Per Annum |
Senior Actuary | ||
London - £180,000 Per Annum |
Financial Reporting in Reinsurance | ||
London / hybrid 2 days p/w office-based - Negotiable |
Home Insurance Director | ||
North West/Hybrid - £140,000 Per Annum |
Head of Long-tail Global | ||
UK/USA - £200,000 Per Annum |
Challenge the pensions industry! | ||
UK Flex / hybrid 2dpw office-based - Negotiable |
Pensions Data Science Actuary | ||
Offices UK wide, hybrid working - Negotiable |
Head of Pricing | ||
London - Negotiable |
Global Specialty Pricing Actuary | ||
London - £95,000 Per Annum |
Client-facing DC investment manager | ||
London / hybrid 3 dpw office-based - Negotiable |
Aylesbury Actuaries | ||
Aylesbury / hybrid 3dpw office-based - Negotiable |
Make an impact in protection pricing ... | ||
London / hybrid 2 days p/w office-based - Negotiable |
BPA Implementation Manager | ||
North / hybrid 50/50 - Negotiable |
Head of Reserving | ||
London - £160,000 Per Annum |
In-force Longevity Actuarial Analyst | ||
London / hybrid 2 dpw office-based - Negotiable |
Make a difference within reinsurance ... | ||
London / hybrid 2 dpw office-based - Negotiable |
Be at the cutting-edge of life & heal... | ||
London / hybrid 2 dpw office-based - Negotiable |
Longevity Pricing Analyst | ||
London / hybrid 2 dpw office-based - Negotiable |
Develop your career in life reinsuran... | ||
London / hybrid 2 dpw office-based - Negotiable |
Be the first to contribute to our definitive actuarial reference forum. Built by actuaries for actuaries.