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Article | Pensions Briefing

Climate and ESG reporting – tick-box exercise or game-changer?

By Hannah Gonsalves , Lou Harris , Natalie Chiang and Janine Bennett | September 4, 2023

Pension fund managers need to consider how they present themselves to members and align their message with the corporate sponsor. Are they just checking boxes, or trying to make a real impact?
Employee Engagement |Pension Board and Trustee Consulting|Pensions Corporate Consulting|Pensions Risk Solutions|Pensions Technology|ESG and Sustainability|Retirement
ESG In Sight

We see a broad spectrum of attitudes from our clients about the relevance of climate change on their businesses, pension fund investment strategies and push towards digital (and therefore more carbon neutral) – some are doing the minimum as required by law, while others are wholly aligning their pension fund strategy to their corporate climate agenda and net zero target.

Members are increasingly interested (and worried) about climate change and want the agency to invest their pension benefits/savings in a way that aligns with their own personal agenda (defined contribution schemes) or know their scheme is using its influence for the greater good (defined benefit schemes).

The Taskforce on Climate-Related Financial Disclosures (TCFD) report gives trustees an opportunity to demonstrate their ‘value for members’ through their investment strategy. But taking pension scheme members on the sustainability journey is more than a TCFD report, it’s about overall reputation.

All savers deserve to be in well-governed schemes which protect their retirements by appropriately managing and reporting on ESG and climate related risks and opportunities.”

Nicola Parish | Executive Director of Frontline Regulation, TPR

We can help trustees promote their good work to their members by producing well-written, beautifully designed TCFD reports that set out, in member-friendly language, what their pension fund is doing to mitigate climate change. And we can support them in efforts to reduce carbon through developing and delivering digital transformation.

With many more pension fund managers having to produce a report, now is the time for them to think about how they want to present themselves to their members and how they align that narrative to the corporate sponsor. Box-tickers or game-changers?

The current landscape

The Pensions Regulator (TPR) is ramping up its enforcement of public website disclosures, particularly in relation to environmental, social and governance (ESG) and climate-related disclosures. It is essential that trustees are aware of their duties and the potential penalties if they fail to comply.

Trustees are required to publish, on a public website, a number of documents including a Statement of Investment Principles, Implementation Statement and, where required, a TCFD report and extracts of the Chair’s statement. Trustees must also include details of the website on their scheme returns, so that the TPR can check that they are complying with their disclosure duties.

“All savers deserve to be in well-governed schemes which protect their retirements by appropriately managing and reporting on ESG and climate related risks and opportunities. These reporting disclosures represent compliance with the basic requirements in relation to ESG and climate change.” Nicola Parish, Executive Director of Frontline Regulation at the TPR, February 2023.

Customers, employees and the wider public are using the power of their investment clout to compel change.”

Carl Hess | Chief Executive Officer, WTW

What TPR wants

The Regulator wants to see that trustees have met the requirements of the climate regulations[1]. They will look for clear evidence that trustees:

  • Are taking proper account of climate change when making decisions about their scheme
  • Have seriously considered the risks and opportunities that climate change will bring to their scheme and have decided what to do as a result
  • Have carried out analysis in a way that is consistent with the TCFD recommendations so that members and others can be confident in it

What employees want

Campaigns across the wider society are educating people about the power of their investments. As a result, employees are becoming increasingly interested (and worried) about climate change and the effect their pension is having on the planet.

“Customers, employees and the wider public are using the power of their investment clout to compel change.” Pushing back, moving forward (Economist, 2022, Carl Hess/WTW sponsored).

Employees want reassurance that the trustees of their pension scheme are investing their money responsibly and protecting their retirement benefits from the risks of climate change.

And let’s not forget that easy to use digital services are now the way many people prefer to run their lives, and their pension is no exception.

What’s in it for trustees?

We see a range of attitudes from trustees about the risk of climate change to their scheme and sponsoring employer. Two thirds of FTSE 100 companies have signed up to the United Nations Race to Zero campaign, a global alliance committed to achieving net zero by 2050, and many have set themselves earlier targets. So, the pressure is high on trustees to align on their approach and their narrative with the corporate.

Some are doing the minimum as required by law, while others are wholly aligning their pension fund strategy to their corporate climate agenda.

What’s important to you will depend on many factors, including whether you’re more focussed on:

  • The trustee looks good to members – which helps to build perception around trustworthiness, understanding of needs/attitudes, acting in the best interest for all members
  • Or the scheme looks good to current employees and prospective employees, and also aligns with the wider corporate objectives, giving the scheme a competitive edge against rival companies

There is also some pride in being a progressive scheme within the industry. Done well, improves member engagement, and employee retention

As employee experience – engagement experts – we elevate and add value to this process by looking at:

  1. 01

    Insights

    We create a dialogue with members and find out what matters most to them using our Engage survey technology and Virtual Focus Groups. Better member insights help you create a better member experience. Through the Climate and Resilience Hub team we can also deliver trustee training and TCFD gap analysis.

  2. 02

    Strategy

    We work closely with trustees to develop a narrative framework that is not at risk of ‘green washing’ and that caters to the long-term sustainability strategy, investment principles and how they are being implemented. We also advise and deliver on digital transformation.

  3. 03

    Communication

    We have a content bundle, including the video ‘Your pension, people and the planet’ to create connection and context for members about why climate matters with their pension, we make SIP, Imp and TCFD content work harder and have a member friendly TCFD template reviewed and developed with the Climate Hub team, and provide the scheme/company with a competitive edge in the industry.

Some final food for thought…

  • Climate regulations[2] require trustees of eligible pension schemes to take steps to identify, assess and manage climate-related risks and opportunities in a proportionate way and report on what they have done. These reporting requirements align with the recommendations of the Taskforce on Climate-Related Financial Disclosures (TCFD).
  • According to Nicola Parish, Executive Director of Frontline Regulation at TPR : “All savers deserve to be in well-governed schemes which protect their retirements by appropriately managing and reporting on ESG and climate related risks and opportunities. These reporting disclosures represent compliance with the basic requirements in relation to ESG and climate change, so it’s disappointing some trustees are failing to meet them. Trustees who fail to comply risk us taking enforcement action against them and I expect to see an improvement in compliance levels.”
  • The Pensions Regulator is currently analysing scheme return data to check that trustees are publishing the required data on ESG.
  • And, with over 60% of FTSE 100 companies [as at November 2021] now signed up to the United Nations Race to Zero campaign, more and more employees expect their pension scheme to align to their employer’s commitments to achieve net zero by 2050 or earlier.
  1. The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (as amended) and the Occupational Pension Schemes (Climate Change Governance and Reporting) (Miscellaneous Provisions and Amendments) Regulations 2021 Return to article
  2. The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (as amended) and the Occupational Pension Schemes (Climate Change Governance and Reporting) (Miscellaneous Provisions and Amendments) Regulations 2021 Return to article
Contacts

Hannah Gonsalves
Director, Member Communications
email Email

Senior Director, Employee Experience, Pensions

Natalie Chiang
email Email


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