分行业碳信息披露框架建议（英文版）---环境保护基金.pdf

Timely Ac cur ac y S t andar d SUGGESTIONS ON THE FRAMEWORK FOR CLIMATE-RELATED INFORMATION DISCLOSURE INDUSTRY-SPECIFIC Abstract Climate-related information disclosure at corporate levels is key for addressing climate change. As the core element of climate information, carbon emission data is increasingly valued by all market entities. Various stakeholders are devoting efforts to promoting climate-related information disclosure these years, while enterprises are getting a better understanding of information disclosure. However, the climate-related information disclosure of high-emitting enterprises is greatly impeded due to the lack of systematic guidelines and infrastructure construction. Meantime, the weak and inconsistent carbon accounting carried out by financial institutions also limits the ability of investment and financing activ- ities to promote green and low-carbon transition in industries. Based on the status quo of climate-re- lated information disclosure within China, this paper proposes suggestions for climate-related infor- mation disclosure for key emission industries and financial institutions to provide relevant references for climate-related information disclosure in China.Introduction Chapter I Chapter II 1. 1. 2. 2. 3. 4. 01 02 03 05 06 07 09 11 13 Contents Status quo of Climate-related information disclosure in China An overview of international experiences climate-related information disclosure The climate-related information disclosure work has been gradually advanced in China, and the participation of enterprises has increased Listed companies in China lack initiative in climate-related information disclosure, and the quality of disclosed data needs to be improved The disclosure of Scope 3 carbon emissions is very important face great challenge at the present stage Suggestions on the framework for climate-related information disclosure of different industries Suggestions and characteristic indicators for information disclosure in high carbon emission industries Suggestions and characteristic indicators for carbon emission information disclo- sure by financial institutionsChina’s environmental information disclosure started from 2007, a far-reaching process.According to the history of environmental information disclosure system in China, as early as April 2007, the State Environmental Protection Administration had issued the Measures for the Disclosure of Environmental Information for Trial Implementation, proposing that enterprises should, in the principle of combining voluntary disclosure and compulsory disclosure, accurately disclose corporate environmental information in time; the competent depart- ments for environmental protection should establish and improve the environmental information disclosure system. In December 2014, the Ministry of Environmental Protection issued the Measures for the Disclosure of Environmental Information of Enterprises and Public Institutions, proposing that enterprises and institutions should truthfully disclose their environmental information in time in the principle of combining mandatory disclosure and voluntary disclosure; the competent department of environmental protection should establish and improve the working mechanism to guide and oversee the environmental information disclosure by enter- prises and public institutions. In recent years, carbon emission disclosure has gradually become an important part of environmental information disclosure in China.In May 2021, the Ministry of Ecology and Environment issued the Environmen- tal Information Legal Disclosure System Reform Plan, which proposed to gradually establish and improve mandatory environmental information disclosure by enterprises, and required that entitiesincluding key pollutant discharging units, the listed companies, and bond-issuing companies which are required for imple- ment mandatory clean production audits, should disclose corporate environmental information in annual reports and other relevant reports in accordance with laws and regulations, so as to implement their legal obligations for mandatory disclosure of environmental information. In December 2021, the Ministry of Ecology and Environment issued the Measures on the Management of Mandatory Corporate Environmental Information Disclosure, and subsequently issued a supporting document the Standards for the Format of Mandatory Corpo- rate Environmental Information Disclosure, in which it is clarified that the legal disclosure of corporate annual environmental information should include information on carbon dioxide emission; for companies regulated by carbon markets, the disclosed information should also include the actual carbon dioxide emissions of the current year and the actual emissions of the previous year, compliance status, the compilation and release of annual greenhouse gas GHG emission reports, etc. Different industries have different carbon emission sources and accounting scopes. The suggestions on climate-related information disclosure of different industries in accordance with industrial characteristics are of great significance for improving the information disclosure system in China.For different information disclosure requirements for high carbon emission industries and high value-added industries such as finance, we can not only constrain the emission behavior of high emission enterprises from the sources, a non-manda- tory way to promote low-carbon production and operation of enterprises, but also guide the behavior of high value-added industries such as finance at the resource side, and provide incentives to the low-carbon behavior of downstream enterprises. Emissions from high-carbon-emitting industries are mainly Scopes 1 and 2, which can be calculated according to the emission accounting report guidelines for industries and enterprises issued by the authorities, to realize a relatively complete carbon emission disclosure of the production and operation of industries and enterprises; for high value-added industries such as finance, Scope 3 carbon emissions are a critical link to reflect the impact of financial institutions on the environment. The disclosure of Scope 3 carbon emission information is of great importance for regulators and stakeholders to learn about the impact of finan- cial institutions’ lending and investment activities on climate in a comprehensive and multi-dimensional manner, so as to allocate financial capital more efficiently and further promote the transformation into a low-carbon society. Introduction 1 According to the Green House Gases Protocol jointly released by WBCSD and WRI, GHG emissions are classified into three scopes by their sources. Scope 1 emissions are direct GHG emissions that occur from sources that are controlled or owned by an organization e.g., emissions associated with fuel combustion in boilers, furnaces, vehicles. Scope 2 emissions are indirect GHG emissions associated with the purchase of electricity, steam, heat, or cooling. Scope 3 emissions are all indirect emissions not included in scope 2 that occur in the value chain of the reporting company, including both upstream and downstream emissions. 01Status quo of Climate-related information disclosure in China Chapter I At present, there are two main models for promoting climate-related information disclosure internation- ally. One is the initiative-based voluntary climate-re- lated information disclosure, which includes main- stream frameworks such as TCFD, SASB, CDP and GRI. These initiatives have their own characteristics. Specifically, TCFD has developed a framework appli- cable to multiple industries; SASB has designed frameworks and standards for different industries specifically; CDP has adopted a questionnaire form and enriched the relevant contents based on TCFD; GRI covers more ESG-related topics. However, in general, the existing voluntary disclosures usually fail to provide sufficient and effective information, while the cost for financial institutions to obtain relevant data is high, resulting in the consistency and clarity of the current voluntary climate informa- tion disclosed by enterprises to be improved. 03 Table 1 Global mainstream voluntary climate-related information disclosure frameworks Cross-sectoral climate disclosure framework Low High High Industry-speciflc sustainablity disclosure framework Sector-specific climate questionnaire Description Sector Specificity Diselesure Coverage TCFD SASB GRI CDP Cross-sectoral ESG disclosure framework with specthic standards for oil， gas and coal Four-part frame- work covering governance, strategy, risk management, and metrics and targets Framework covers environment, social capital, human capital, business model and innovation, and governance Questionnaire covers TCFD framework with additional categories on carbon pricing, emission methodlogy and verification, among others Framework covers a wide array of ESG topics from emissions to workplace diversity to occupation health Low 1. An overview of international experiences climate-related information disclosure Chapter I Status quo of Climate-related information disclosure in China04 Table 2 Countries and regions which implement mandatory climate-related information disclosure Another mode of climate-related information disclo- sure is mandatory climate-related information disclosure backed by government regulations. In order to ensure that climate change-related data is of sufficient quality to support various investment decisions, countries and regions such as the EU and Japan have established their own mandatory climate-related information disclosure systems based on the TCFD framework, but the coverage varies. For example, Japan requires disclosure by all listed companies within the main board of the Tokyo Stock Exchange, while the UK requires disclosure by all listed companies with 500 or more employees. In terms of when the policies come into effect, manda- tory disclosure has been implemented in Japan and the UK in April 2022, and in New Zealand from 2023, and the EU provides sufficient lead time for compa- nies in the region to begin implementing the manda- tory disclosure requirements by 2024. Japan New Zealand United Kingdom European Union Proprsed 2021 Introduced November 2021 Passed October 2021 Finalized January 2022 Reporting begins 2024 Reporting begins April 2022 Reporting begins April 2022 Reporting begins 2023 Incorporates TCFD All large companies in EU and all Eurpean stock-ex- change listed companies Companies listed on the Tokyo Stock Exchangs “Prime“ market Conpanies with 500 employees publicly traded in the UK All banke, credit unions, building societies, and investment managers with more the NZ1 billion Aligned with TCFD Aligned with TCFD Aligned with TCFD Chapter I Status quo of Climate-related information disclosure in ChinaCompanies to establish the basic framework of ESG information disclosure in China, to 2020, when the State Council issued the Guidance on Building a Modern Environmental Governance System to explicitly require enterprises to disclose environ- mental governance information, ESG-related policies in China have guided in the “carbon peaking and carbon neutrality goals“. The number and quali- ty of ESG reports are on an overall upward trend. The ESG Rating Analysis Report 2020 of A-share Listed Companies shows that the number of ESG reports issued by A-share listed companies in China has increased from 371 to 1,021 from 2009 to 2020, and the overall ESG indicator disclosure rate of listed companies is also gradually increasing. The Environ- mental, Social, and Governance Reporting Guidelines issued by the Hong Kong Stock Exchange has made more specific requirements on the disclosure content of ESG reports and made it mandatory for listed companies to disclose. 05 Figure1 Growth in the number of ESG reports issued by A-share listed companies 371 1021 0 200 400 600 800 1000 1200 2009 2020 175 2 . The climate-related information disclosure work has been gradually advanced in China, and the participation of enterprises has increased In the context of striving for the goals of carbon peaking and carbon neutrality, enterprises have gradually realized the importance of addressing the risks and challenges of climate change to their long-term development. In recent years, China has made some progress in climate-related information disclosure, and enterprises have continuously enhanced their awareness of climate-related infor- mation disclosure. From the perspective of disclosure channels, there are two main modes of climate-related information disclosure for listed enterprises in China at this stage, one is to disclose through ESG reports and the other is to participate in the Carbon Disclosure Project CDP. From the development history of ESG in China, from 2018, when the Securities Regulatory Com- mission revised the Guidelines on Governance of Listed Chapter I Status quo of Climate-related information disclosure in China Growth in the number of ESG reports issued by A-share listed companies Number of enterprises disclosedcompanies were invited to make disclosures in the CDP while 1,349 disclosed their environmental infor- mation, compared to 664 in 2018 and 1,048 in 2019, an increase of 58 and 27 respectively, with the number of disclosed companies growing faster than the global average level. 06 In the context of striving for carbon neutrality in China, the performance of listed companies in low-carbon development has become an important factor for investors to make decisions, and the public has higher expectations for listed companies to disclose their carbon emission data. However, few companies take the initiative to disclose carbon emission data, and the quality of carbon emission data disclosed varies considerably. 3 . Listed companies in China lack initiative in climate- related information disclosure, and the quality of disclosed data needs to be improved Talking about the participation of Chinese enterpris- es in CDP projects, the participating enterprises cover industries with low scope 1 and scope 2 carbon emission levels, such as banking and insur- ance, as well as industries with high emission levels, such as metals and mining. The CDP 2020 China Listed Companies Report shows that 1,987 Chinese Chapter I Status quo of Climate-related information disclosure in China Figure 2 Comparison of CDP and CSR information disclosure of Chinese enterprises 664 1048 1349 0 200 400 600 800 1000 1200 1400 2018 2019 2020 58 27 Disclosures made by Chinese companies via CDP information platform Number of enterprises disclosed07 In November 2021, the first domestic list focusing on carbon emissions of listed companies, “China Listed Companies Carbon Emissions Ranking 2021“, was released. According to the lists, few listed companies took the initiative to disclose carbon emission data. For example, among the 51 A-share listed companies on the l