Memorandum for the Petitioners 1135
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.634
8.187. The physical and economic impacts of climate change and the
transition to a zero-carbon economy present foreseeable, material, and
financial risks for nearly all industries and sectors within mainstream
investment horizons.635
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:
r
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.636
8.189. The TCFD recommendations also suggest that companies
disclosure cover the following areas: governance, strategy, risk management
and metrics, and targets.637
r
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.638 However, this type of disclosure does not replace the
need for due diligence requirements of “knowing and showing,” as outlined
by the UNGPs.
Ibid.
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 andfinancial
stability, Speech given at Lloyd’s of London, available
at https:// www.bankofengland.co.uk/speech/2015/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 Changeslide 18.
637
Id , slide 10.
638
Marjanac, S ., supra note 136, p. 40 .
634
635
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