japanja
Disclosing sustainability risk in portfolios

Disclosing sustainability risk in portfolios

17-03-2021 | インサイト
A new regulatory framework will shake up sustainable investment across the EU this year. One of the requirements of the Sustainable Finance Disclosure Regulation is to compel asset managers to disclose the sustainability risks that are inherent in their investments. In this Q&A, Wouter Kuijpers, Senior Counsel for Legal Developments, and Nico Becx, Senior Financial Risk Manager, answer some of the questions that clients have so far posed.
  • Wouter Kuijpers
    Wouter
    Kuijpers
    Senior Counsel Legal Developments
  • Nico Becx
    Nico
    Becx
    Senior Financial Risk Manager

What is changing under the new regulation?

A key component of the EU’s new Sustainable Finance Disclosure Regulation (SFDR) requires investors to better disclose key sustainability related risks in their investment strategies. Crucially, they also have to disclose the likely impact that this may have on returns over time. With decades of experience in ESG integration, the necessity to consider such risks in the investment process is nothing new to Robeco. But across the asset management industry, more granular disclosures are still required, and this may trip up those who haven’t prepared for it.
サステナビリティに関する最新の「インサイト」を読む
サステナビリティに関する最新の「インサイト」を読む
配信登録

What does it mean in practical terms?

The new regulations broadly require asset managers to integrate sustainability risks in policies, procedures and governance structures throughout their entire organization. They need to be fully transparent about the incorporation of sustainability in their strategies, as well as disclosing how they integrate sustainability risks into their investment decision‐making process. This entails detailed reporting about investment processes and risk management practices, as well as on portfolios’ sustainability profiles. It is a lot of work!

How do you define sustainability risks?

Broadly speaking, sustainability risks can be defined as environmental, social or governance (ESG) factors that could cause an actual or a potential materially negative impact on the value of an investment. Well known examples range from climate-related risks such as those posed by high-carbon businesses, to significant social issues and poor governance. Importantly, such risks can materialize at the global, regional, entity and product levels, which means they occur across the whole spectrum. Similarly, different risks may affect different asset classes in different ways.

Aren’t there opportunities as well?

While sustainability factors can also have positive impacts (opportunities), the sustainability risks for the purpose of integration can be seen as the negative materialization of these ESG factors. Sustainability as a risk factor typically apply to all investments, while sustainability opportunities are typically relevant to the products that have an ESG objective. For asset managers, it is therefore pivotal to carefully assess the financial materiality of sustainability risks, following a proportionate and risk-based approach.

What does Robeco do?

Robeco routinely integrates relevant sustainability risks into all aspects of its investment strategies across the entire range of fundamental equity, fixed income, quantitative and bespoke sustainability funds. We also integrate ESG into tailored client solutions such as mandates, and across the organization itself. This includes investment analyses and decisions, risk management, product governance and client suitability assessment processes, along with Robeco’s governance around it.

What is the biggest risk?

The risk that climate change poses is undisputed. The effects of global warming has risen to the top of the agenda among the media, investors and wider society, fueled by stories of uncontrollable fires and floods. We look at the financial risks posed by an investment that may contribute to, or be affected by, global warming. Following the adoption of the Paris Agreement, governments are endeavoring to transition to low-carbon and more circular economies on a global scale. The European Green Deal aims to make Europe the first climate-neutral continent by 2050. Investors are expected to play a key role in this respect, as enshrined in the EU Sustainable Finance Action Plan and the SFDR.

Isn’t climate risk limited to high-carbon investments?

No – Robeco considers climate change to be an all-encompassing risk that is financially material for all its investment strategies. This is underscored by our commitment to the recommendations laid down by the Task Force for Climate-Related Financial Disclosures (TCFD), as well as our commitments to the Dutch Climate Accord. We also made our own net zero pledge to decarbonize all our portfolios by 2050. The transition to a low-carbon and more circular economy itself contains risks for the companies changing their business models, while physical damage caused by extreme weather impacts just about everyone. There is also the risk of litigation for weather-related damage, and insurance claims.

If everything is changing, how can this kind of risk be assessed?

Robeco takes a forward-looking approach to running climate change scenario analyses that can measure risks using both proprietary tools and third-party data providers. The main problem with data is that by definition, it is backward looking. Therefore, we use more forward-looking scenario analysis such as Climate Value-At-Risk (VAR) to assess the likely impact of risks on the returns of the holdings. Yet, while assessing such risks is a great start, it is critical that investors act to mitigate these risks over the long term. To do this, our investment teams make use of a wide array the sustainability building blocks available to them, built up over our many years of experience in sustainable investing.

Why not just exclude anything that is a clear climate risk?

We already exclude companies that clearly cannot change their business models to something more climate friendly, such as thermal coal. We also now exclude those companies involved with oil sands or Arctic drilling, subject to certain thresholds. Our exclusion policy also screens out areas where we feel fundamental shifts in markets resulting from ESG-related issues will make certain activities untenable in the future. But the problem here is that once a company is excluded, it is no longer possible to engage with them to try to improve their business model. You also can’t vote against them at annual meetings, or file shareholder resolutions. Subsequently, we much prefer to mitigate sustainability risk by engaging with them. We have found this particularly effective in persuading the oil giants to move towards renewables.

Do you announce everything that Robeco does?

Yes – we have a strong commitment to disclosing our policies, as we believe that transparency forms part of a commitment to sustainable investing. Robeco’s approach is summarized in our sustainability risk policy available on our main website. In addition, information on sustainability risk is also available in fund documentation, providing clients and investors with insight into the relevant sustainability risks on a product level. All policies about exclusions, voting, engagement and everything else are published, and usually updated quarterly where necessary, such as in our Active Ownership documentation.

Is this revolution or evolution?

While the EU regulation offers a significant shake-up, the integration of sustainability risks is an evolving field. The available data, expertise and technology to identify, measure and mitigate sustainability risks and the related ability to deeper understand them will therefore likely increase over time. What the EU regulation has done has been to both accelerate progress in this area, and make disclosures compulsory. But it’s not a perfect science. For investors, it is important to regularly review and, where relevant, recalibrate their sustainability risk integration processes in order to ensure that these remain fit with these innovations. So in that sense, it’s all still work in progress.
Sustainable Finance Action Plan
Sustainable Finance Action Plan
Overview

重要事項

当資料は情報提供を目的として、Robeco Institutional Asset Management B.V.が作成した英文資料、もしくはその英文資料をロベコ・ジャパン株式会社が翻訳したものです。資料中の個別の金融商品の売買の勧誘や推奨等を目的とするものではありません。記載された情報は十分信頼できるものであると考えておりますが、その正確性、完全性を保証するものではありません。意見や見通しはあくまで作成日における弊社の判断に基づくものであり、今後予告なしに変更されることがあります。運用状況、市場動向、意見等は、過去の一時点あるいは過去の一定期間についてのものであり、過去の実績は将来の運用成果を保証または示唆するものではありません。また、記載された投資方針・戦略等は全ての投資家の皆様に適合するとは限りません。当資料は法律、税務、会計面での助言の提供を意図するものではありません。

ご契約に際しては、必要に応じ専門家にご相談の上、最終的なご判断はお客様ご自身でなさるようお願い致します。

運用を行う資産の評価額は、組入有価証券等の価格、金融市場の相場や金利等の変動、及び組入有価証券の発行体の財務状況による信用力等の影響を受けて変動します。また、外貨建資産に投資する場合は為替変動の影響も受けます。運用によって生じた損益は、全て投資家の皆様に帰属します。したがって投資元本や一定の運用成果が保証されているものではなく、投資元本を上回る損失を被ることがあります。弊社が行う金融商品取引業に係る手数料または報酬は、締結される契約の種類や契約資産額により異なるため、当資料において記載せず別途ご提示させて頂く場合があります。具体的な手数料または報酬の金額・計算方法につきましては弊社担当者へお問合せください。

当資料及び記載されている情報、商品に関する権利は弊社に帰属します。したがって、弊社の書面による同意なくしてその全部もしくは一部を複製またはその他の方法で配布することはご遠慮ください。

商号等: ロベコ・ジャパン株式会社  金融商品取引業者 関東財務局長(金商)第2780号

加入協会: 一般社団法人 日本投資顧問業協会