Memorandum for the Petitioners |135
methodology by which companies can voluntarily disclose climate-related
financial risks to the market, in the interests of improving financial stability
through the disclosure of information regarding material risks.©4
8.187.The physical and economic impacts of climate change and the
transition
financial
to
risks
a zero-carbon
for nearly
investment horizons.®*
economy
present
all industries
and
foreseeable,
sectors
within
material,
and
mainstream
8.188.Respondent Carbon Majors should at a minimum rely on the
TCFD’s specific guidance on how to quantify and disclose climate risks,
including the:
1.
Risks from the physical impacts of climate change;
2.
Transition risks, which arise from the transition to a low
carbon economy and include the risk of stranded assets;
and
3.
Associated litigation risks, which
could arise from the
above risks themselves, or from liability claims.©°
8.189.The TCFD recommendations also suggest that companies’
disclosure cover the following areas: governance, strategy, risk management
and metrics, and targets.®7
8.190.For the respondent Carbon Majors, implementing the TCFD
recommendations will assist them in meeting some of their existing legal
obligations in respect of climate-related disclosure.
Disclosing in
accordance with the TCFD’s guidance will also assist respondents to prepare
for the coming transition to a low carbon economy, by preparing executives
for a range of possibly disruptive futures, as well as prepare the companies for
the physical disruption that will occur from increasing extreme weather events
and rising sea levels.°® However, this type of disclosure does not replace the
need for due diligence requirements of “knowing and showing,” as outlined
by the UNGPs.
634 Ibid.
635 So much that in 2015, Bank of England Governor and head of the G20 Financial Stability Board Mark
Carney declared that climate-related financial risk threatens the very stability of the global financial system.
See Mark Carney (29 September 2015), Breaking the tragedy of the horizon—climate change and financial
stability, Speech given at Lloyd’s of London, available
at https://www.bankofengland.co.uk/speecl/20 1 5/breaking-the-tragedy-of-the-horizon-climate-change-andfinancial-stability (last accessed on 12 September 2019).
636 Exhibit “GGGGGGG” to “GGGGGGG-20,” Printed PowerPoint Presentation of Brenda Ekwurzel,
entitled “Presentation for the Republic of the Philippines Commission on Human Rights National Inquiry
on Climate Change,” slide 18.
7 Id, slide 10.
638 Marjanac, S., supra note 136, p. 40.
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