Taskforce For Climate-related Financial Disclosures
Taskforce forClimate-relatedFinancialDisclosuresWhere do I start?May 2021Click to launch
Content overview2 Where do I start?1Introduction and scope of this guide12TCFD – the basics23FCA listing rules requirements and guidance – TCFD reporting44Reporting in practice65TCFD requirements beyond premium listed companies86Further information and contacts12Appendix14
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix1. Introduction and scope of this guideThe global debate about the role of business has turned aspotlight on organisations’ environmental, social andgovernance (‘ESG’) policies. There are growing calls frominvestors, regulators and other stakeholder groups for betterinformation on how these issues have been considered,particularly in relation to climate change.The recommendations of the Taskforce on Climate-relatedFinancial Disclosures (‘TCFD’) have now begun to beincorporated into the UK regulatory framework and are thefocus of this guide, which covers: The basic elements of the TCFD framework How it is now incorporated into the Financial ConductAuthority (‘FCA’) Listing Rules for premium listedcompanies (excluding investment trusts) for periodsbeginning on or after 1 January 2021 Key aspects of reporting against the framework inpractice The relevance of the TCFD framework for organisationsother than premium listed companies1 Where do I start?TCFD and the financial impacts ofclimate changeAlthough it includes narrative disclosures, the TCFDframework is above all about disclosing and accounting forthe financial impacts of climate change on businesses.Where applicable – for example assessing whether assetsare impaired – these impacts should be factored intofinancial statements (and audits) today. Climate change is notonly a long-term issue affecting companies in the future, it isone that needs consideration today.Climate change and existing reportingrequirementsIt is important to recognise that climate change andenvironmental matters generally are also often relevant toother existing requirements under the UK narrative reportingframework, including principal and emerging risks and: The statement on how directors have had regard to theirduties under section 172 of the Companies Act (whichrequires its impact on the environment to be considered aspart of promoting the long-term success of a company) The non-financial information statement (which requiresreporting on environmental matters ‘to the extentnecessary for an understanding of the company’sdevelopment, performance and position and the impactof its activity’) Streamlined Energy and Carbon Reporting (whichincludes information on energy usage and greenhousegas emissions that is directly relevant to TCFDdisclosures)Looking aheadThe UK government has published a roadmap of planneddevelopments in climate-related reporting out to 2024-25,which would ultimately extend it beyond premium listedcompanies to many other types of company, pensionschemes, asset managers and others. Information on this isgiven in section 5 of this document.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix2. TCFD – the basicsThe TCFD was established by the global Financial Stability Board ‘to develop voluntary, consistent climate-related financial disclosures that would be useful to investors, lenders,and insurance underwriters in understanding material risks. its members were selected by the Financial Stability Board and come from various organisations, including largebanks, insurance companies, asset managers, pension funds, large non-financial companies, accounting and consulting firms, and credit rating agencies’. [TCFD Final Report,page iii]The Final Report of Recommendations was published by the TCFD in June 2017 and sets out a framework of four core elements (sometimes referred to as ‘pillars’), supported by elevenrecommended disclosures:Recommendations and Supporting Recommended DisclosuresGovernanceStrategyRisk managementMetrics and targetsDisclose the organisation’s governancearound climate-related risks andopportunities.Disclose the actual and potential impacts ofclimate-related risks and opportunities onthe organisation’s businesses, strategy, andfinancial planning where such information ismaterial.Disclose how the organisation identifies,assesses, and manages climate-relatedrisks.Disclose the metrics and targets used toassess and manage relevant climate-relatedrisks and opportunities where suchinformation is material.Recommended disclosuresRecommended disclosuresRecommended disclosuresRecommended disclosuresa. Describe the board’s oversight ofclimate-related risks and opportunities.a. Describe the climate-related risks andopportunities the organisation hasidentified over the short, medium, andlong term.a. Describe the organisation’s processesfor identifying and assessing climaterelated risks.a. Disclose the metrics used by theorganisation to assess climate-relatedrisks and opportunities in line with itsstrategy and risk management process.b. Describe management’s role inassessing and managing climate-relatedrisks and opportunities.b. Describe the impact of climate-related risksand opportunities on the organisation’sbusinesses, strategy, and financial planning.b. Describe the organisation’s processesfor managing climate-related risks.b. Disclose Scope 1, Scope 2, and, ifappropriate, Scope 3 greenhouse gas(GHG) emissions, and the related risks.c. Describe the resilience of theorganisation’s strategy, taking intoconsideration different climate-relatedscenarios, including a 2 C or lowerscenario.c. Describe how processes for identifying,assessing, and managing climaterelated risks are integrated into theorganisation’s overall risk management.c. Describe the targets used by theorganisation to manage climate-relatedrisks and opportunities and performanceagainst targets.2 Where do I start?
123I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting2. TCFD – the basics (Cont.)Further guidance has been published by the TCFD toaccompany the framework: the TCFD Annex (Implementingthe Recommendations of the Taskforce on Climate-relatedFinancial Disclosures) in particular builds out what toconsider when putting together the recommendeddisclosures. More information on this and the other TCFDguidance can be found in section 3 below.The TCFD also releases status reports that highlight thelatest reporting trends in relation to the four core elementsand eleven recommended disclosures and include helpfulpublished examples of reporting. The full suite of TCFDdocuments can be found at www.fsb-tcfd.org/publications.3 Where do I start?456TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix3. FCA listing rules requirements and guidance – TCFD reportingThrough Policy Statement 20/17, the FCA amended theListing Rules so that premium listed companies (other thaninvestment trusts) must report on a ‘comply-or-explain’ basisagainst the TCFD framework for periods beginning on orafter 1 January 2021.The Listing Rules include ‘requirements’ (paragraphsindicated by a final ‘R’) and ‘guidance’ (paragraphs indicatedby a final ‘G’). Both of these are summarised below and insection 4. The guidance provides more details on what therequirements are intended to mean for companies and theymust have regard to it.The TCFD’s own guidance on applying the four coreelements and eleven recommended disclosures of theframework is referred to by the FCA in the Listing Rulesguidance paragraphs, which set out how the various TCFDpublications are to be taken into account.The FCA requirementsThe FCA guidanceUnder Listing Rule 9.8.6(8)R, premium listed companiesmust include a statement setting out:LR 9.8.6BG ‘.in determining whether climate-relatedfinancial disclosures are consistent with the TCFDRecommendations and Recommended Disclosures, a listedcompany should undertake a detailed assessment of thosedisclosures which takes into account: whether they have made disclosures consistent withthe TCFD’s recommendations and recommendeddisclosures in their annual financial report; where they have not made disclosures consistent withsome or all of the TCFD’s recommendations and/orrecommended disclosures, an explanation of why, and adescription of any steps they are taking or plan to taketo be able to make consistent disclosures in the future –including relevant timeframes for being able to makethose disclosures;where they have included some, or all, of their disclosuresin a document other than their annual financial report,an explanation of why; and where in their annual financial report (or other relevantdocument) the various disclosures can be found.1. Section C of the TCFD Annex entitled ‘Guidance for AllSectors’;2. (where appropriate) Section D of the TCFD Annex entitled‘Supplemental Guidance for the Financial Sector’ [i.e.Banks, Insurance Companies, Asset Owners and AssetManagers]; and3. (where appropriate) Section E of the TCFD Annexentitled ‘Supplemental Guidance for Non-FinancialGroups’ [i.e. Energy, Transportation, Materials andBuildings and Agriculture, Food and Forest Productgroups]’.The implication of LR 9.8.6BG is that these Sections of the TCFD Annex should be considered in detail aspart of a company’s assessment of its disclosures, emphasising the importance of the Annex to the overallframework. A summary of the TCFD Annex relevant to all companies applying the TCFD framework hastherefore been provided in the Appendix to this guide. Sections D & E of the Annex provide additionalguidance under each of the eleven recommended disclosures for the types of organisation noted inLR 9.8.6BG (2) & (3) above.4 Where do I start?
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix3. FCA listing rules requirements and guidance – TCFD reporting (Cont.)The FCA guidance (Cont.)LR 9.8.6CG then lists a number of other TCFD guidance documents that the FCA considers are relevant to a company’s assessment of its disclosures:Guidance documentSummaryTCFD Technical Supplementon the Use of ScenarioAnalysis in Disclosure ofClimate Related Risks andOpportunities (2017)The Technical Supplement recognises that the use of scenario analysis is currently limited for climate-related risks but advocates it as an importanttool in assessing the potential impacts on organisations – particularly as they are likely to emerge over the medium to longer term, and their precisetiming and magnitude are uncertain.TCFD Guidance on RiskManagement Integration andDisclosure (2020)This Guidance provides a model for integrating the management of climate change-related risk with a company’s main risk management processesand disclosures. It sets out five key takeaways for this:The Supplement begins by setting out why scenario analysis is useful, what a scenario is, and how selected companies have used scenarios. It goeson to discuss the application of scenario analysis; key parameters, assumptions, and analytical choices organisations should consider when theyundertake scenario analysis; and some of the key benefits and challenges. Common understanding. Basic agreement across the company on climate change concepts and their potential impacts. Interconnections. All relevant functions, departments, and experts must be involved. Temporal orientation. Physical and transition risks should be analysed across short, medium and long-term timeframes for operational andstrategic planning, potentially extending beyond traditional planning horizons. Proportionality. The integration of climate-related risks into existing risk management processes should be proportionate in the context of thecompany’s other risks, the materiality of its exposure to climate-related risks, and the implications for the company’s strategy. Consistency. The methodology used must be consistent over time to allow clarity in the analysis of developments and drivers of change over time.TCFD Guidance on ScenarioAnalysis for Non-FinancialCompanies (whereappropriate) (2020)This Guidance is intended to extend and deepen the 2017 version (see above). The focus is on a ‘practical, process-oriented way for businesses touse climate-related scenario analysis’ and the main targets are large and mid-sized non-financial companies.The advocated approach emphasises how scenario analysis can inform strategic management and enhance the resilience of a company’s strategy toclimate change, both of which can be key to TCFD disclosures.The implication of LR 9.8.6CG is that these guidance documents are relevant but might not have to be considered in the same level of detail in every case.5 Where do I start?
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix4. Reporting in practiceCompanies need to consider both the TCFD framework itselfand how the FCA has implemented it through the ListingRules. We have considered some of the practicalimplications of this below under four headings:a. Case-by-case reportingb. Elements of TCFD reporting expected of all premiumlisted companiesc. ‘Report and explain’d. Placement and structure of disclosures6 Where do I start?a. Case-by-case reportingThe TCFD framework is not a one size fits all model. It is forindividual companies to assess the extent of the impact thatclimate change will have on them, and how and when itshould be reflected in the financial statements as well as thenarrative disclosures.The first step in practice is likely to be an initial riskassessment using a company’s existing governance and riskmanagement arrangements, supplemented where necessaryby additional specialists, and covering: physical risks(including direct damage to assets and operationaldisruption) and transition risks (such as policy, legal,technology, and market changes); short, medium andlong-term implications; and the implications for others in thesame supply chain. This initial assessment should bereflected in the weight that the company places on each ofthe four elements of the TCFD framework and the wholeprocess should then inform the approach to disclosure.Both the TCFD and FCA recognise that reporting needs to bedone on the basis of such a case-by-case assessment. Inparticular the FCA states in the Listing Rule Guidance that:LR 9.8.6DG ‘For the purposes of LR 9.8.6R(8), in determiningwhether climate-related financial disclosures are consistentwith the TCFD Recommendations and RecommendedDisclosures, a listed company should consider whetherthose disclosures provide sufficient detail to enable users toassess the listed company’s exposure to and approach toaddressing climate-related issues. A listed company shouldcarry out its own assessment to ascertain the appropriatelevel of detail to be included in its climate-related financialdisclosures, taking into account factors such as:1. the level of its exposure to climate-related risks andopportunities; and2. the scope and objectives of its climate-related strategy,noting that these factors may relate to the nature, sizeand complexity of the listed company’s business’.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix4. Reporting in practice (Cont.)b. Elements of TCFD reporting expected of all premiumlisted companiesc. ‘Report and explain’d. Placement and structure of the disclosuresIn the guidance in Listing Rule LR 9.8.6EG the FCA makes itclear that all in-scope listed companies should ordinarily beable to make disclosures consistent with the TCFD’srecommendations on governance and risk management butthat the same is not necessarily true of the other two coreelements of the framework, strategy (only parts of which arealways expected) and metrics & targets:Although the FCA refers to its reporting requirement as‘comply or explain’ in Policy Statement 20/17, this languageis not used in Listing Rule LR 9.8.6(8) in the same way that itused in Listing Rule LR 9.8.6(6) in relation to reportingagainst the Provisions of the UK Corporate GovernanceCode. Unlike the corporate governance reportingrequirement the TCFD reporting is expected to be a singlestatement in which a company sets out how the frameworkhas been implemented, including any areas in whichdisclosure has not been made. It may therefore be helpful tothink of it as a ‘report and explain’ requirement, with theemphasis on what the company has done, while also settingout what is missing and explaining why.The TCFD states in its Final Report that organisations‘should provide [the required] disclosures in theirmainstream [i.e. public] annual financial filings’, otherthan where there is a local regulatory issue with this or wherethe nature of an organisation’s reporting is not similar to alisted company’s annual report. In the Listing Rules, however,the FCA allows for some or all of the TCFD reporting to be ina document other than the annual report and this approachhas already been taken in some voluntary early disclosures.Where disclosures need to be very extensive it might, forinstance, be helpful for the overall structure and flow of theannual report to include some of the detail in a sustainabilityor other report.LR 9.8.6EG ‘(2) In particular, the FCA would expect that alisted company should ordinarily be able to make disclosuresconsistent with:a. the recommendation and recommended disclosures ongovernance in the TCFD Recommendations andRecommended Disclosures;b. the recommendation and recommended disclosures onrisk management in the TCFD Recommendations andRecommended Disclosures; andc. recommended disclosures (a) and (b) set out underthe recommendation on strategy in the TCFDRecommendations and Recommended Disclosures, tothe extent that the listed company does not face transitional challenges in relation to such disclosures’.This is entirely consistent with the message that eachcompany must apply the framework on a case-by-casebasis, which will mean starting with the initial assessmentdiscussed above.7 Where do I start?Companies should, however, bear in mind that informationwhich is considered to be material to the strategic reportmust be included in that report, and cannot be provided onlyin a separate report or on a website. Many companiesinclude an ‘index table’ linking to other disclosures to meetthe requirement for a non-financial information statementwithout being clear as to whether the items referred to arematerial. If a similar approach is taken to reporting on theTCFD framework, strategically material information onclimate change must be included within the strategic report.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix5. TCFD requirements beyond premium listed companiesIn line with the government roadmap and existing regulatory initiatives, TCFD reporting is being extended to a number of other types of organisations in addition to premium listedcompanies. The largest extension of scope would come from the recently published consultation by the UK government, but a number of other regulators are also introducing reporting.a. Consultation Extension of scope to private companies, companies registered in AIM and LLPsSummary of requirementsApplicable toDate applicableWhere and how to reportIt is proposed that reporting would be against the fourcore elements of the TCFD framework, but not against theeleven disclosure recommendations or the TCFD guidancedocuments. Disclosure of scenario testing would also notbe expected within the annual report.Organisations that would need to report as a result of theproposals are as follows:Periods beginningon or after 6 April2022.For companies, it is proposed thatthe reporting would be in the nonfinancial information statementelement of the strategic report. The requirements would be supplemented by a setof Q&As.All UK companies that are currently required to produce anon-financial information statement, being UK companiesthat have more than 500 employees and have transferablesecurities admitted to trading on a UK regulated market(meaning primarily equity or debt listings on the MainMarket of the London Stock Exchange), bankingcompanies or insurance companies (Relevant PublicInterest Entities (PIEs)); UK registered companies with securities admitted to AIMwith more than 500 employees; UK registered companies which are not included in thecategories above, which have more than 500 employeesand a turnover of more than 500m; and LLPs which have more than 500 employees and aturnover of more than 500m.For companies, these thresholds are consistent with one ofthe proposed methods of extending the definition of a PublicInterest Entity in the separate government consultation:Restoring trust in audit and corporate governance.8 Where do I start?For LLPs the reporting would be inthe Energy and Carbon Report (if theydo not produce a strategic report).Reporting against the four coreelements is described as mandatorybut the proposed level of disclosure islimited and would still be subject tothe case-by-case assessment ofrelevance discussed in section 4 ofthis guide.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix5. TCFD requirements beyond premium listed companies (Cont.)b. New requirements Prudential Regulation Authority (PRA)Summary of requirementsApplicable toDate applicableWhere and how to reportPRA Supervisory Statement SS3/19 (April 2019) andsubsequent PRA Dear CEO letter (July 2020) based onthe thematic review.PRA-regulated banks, building societies and insurers.The PRA has seta deadline of theend of 2021 forfirms to be able todemonstrate thatthey have fullyembedded SS3/19in their approachto managingclimate-relatedfinancial risks.Strategic report and Pillar 3 riskdisclosures in the annual report.ProcessIn SS3/19 the PRA: Recognised that climate change affects firms byincreasing underwriting, reserving, credit, or marketrisks; Called for a strategic approach that is ‘proportionate tothe nature, scale, and complexity of its business’;and Identified specific expectations in relation to firms’governance and risk management around climatechange, including that the board should allocateresponsibility to a suitable Senior ManagementFunction; build it into their Internal Capital AdequacyAssessment Process (ICAAP) or Own Risk andSolvency Assessment (ORSA) processes; and usescenario analysis where proportionate.9 Where do I start?The PRA approach is currently lessprescriptive than the Listing Rulesrequirements or those proposed inthe BEIS consultation above anddoes not mandate the use of theTCFD framework (though, as noted, itdoes encourage firms to engage withit). Many regulated firms will be inscope for one or other of those setsof requirements too.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix5. TCFD requirements beyond premium listed companies (Cont.)b. New requirements Prudential Regulation Authority (PRA) (Cont.)Summary of requirementsApplicable toDate applicableWhere and how to reportDisclosurePRA-regulated banks, building societies and insurers.The PRA has seta deadline of theend of 2021 forfirms to be able todemonstrate thatthey have fullyembedded SS3/19in their approachto managingclimate-relatedfinancial risks.Strategic report and Pillar 3 riskdisclosures in the annual report.SS3/19 noted that banks and insurers have existingrequirements to disclose information on material riskswithin their Pillar 3 disclosures and on principal risks anduncertainties in their Strategic Report (as required underthe UK Companies Act), but they should also ‘considerwhether further disclosures are necessary to enhancetransparency’. In this regard, they expect firms ‘toconsider engaging with the TCFD framework andother initiatives in developing their approach toclimate-related financial disclosures’ and fordisclosures to mature over time.PRA/BoE thematic reviewThis focuses on the progress firms have made withimplementing their approaches, and notes that disclosurehas been limited by firms’ capabilities to date. Inparticular, data limitations mean that not all firms will beable to ‘embed an end-state analysis of climaterelated financial risks within your firm’s capitalframeworks by end-2021’ but that they ‘should be ableto explain what steps your firm has taken to ensurethat, where appropriate, capital levels adequatelycover the risks to which your firm is, or might be,exposed’.10 Where do I start?The PRA approach is currently lessprescriptive than the Listing Rulesrequirements or those proposed inthe BEIS consultation above anddoes not mandate the use of theTCFD framework (though, as noted, itdoes encourage firms to engage withit). Many regulated firms will be inscope for one or other of those setsof requirements too.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix5. TCFD requirements beyond premium listed companies (Cont.)c. Consultation Department for Work and Pensions (DWP)Summary of requirementsApplicable toDate applicableWhere and how to reportThe DWP consulted (‘Taking action on climate risk:improving governance and reporting by occupationalpension schemes’) in August 2020 on proposedrequirements for larger occupational pension schemesand authorised master trusts to publish climate riskdisclosures, including reporting against the TCFDframework. Following the passage of The PensionSchemes Bill 2021 they then consulted in January 2021 ondraft regulations and statutory guidance produced in lightof the outcome of the August policy consultation. Nonstatutory guidance for trustees has also been publishedby the Pensions Climate Risk Industry Group.From 1 October 2021 (‘Wave 1’)Governance,strategy,risk management,and accompanyingmetrics and targetsin place fromOctober 2021(Wave 1) or October2022 (Wave 2).A link to a ‘TCFD Report’ on apublicly available website must bemade from the annual report.The January 2021 consultation includes requirementsapplying the four core elements of the TCFD framework tothe specific circumstances of occupational pensionschemes. It also sets out that: Trustees must take a reasonable and proportionateapproach, meeting requirements ‘as far as they areable’ (the meaning of which is addressed further in thestatutory guidance); and Scenario analysis must be carried out in the first yearin which the climate change governance requirementsapply and then at least every three years.11 Where do I start? Occupational pension schemes with 5bn assets. Authorised master trusts. Authorised scheme providing collective money purchasebenefits.From 1 October 2022 (‘Wave 2’) Occupational pension schemes with 1bn assets.Consulting in 2024 on whether to extend to all occupationalschemes.Must publish aTCFD report within 7months of the end ofthe scheme yearwhich is underwayon 1 October 2021(Wave 1) or1 October 2022(Wave 2).The DWP has embedded the conceptof a proportionate response in itsapplication of the TCFD framework,which will guide the nature and extentof reporting.
1234I ntroduction and scopeof this guideTCFD – the basics CA listing rulesFReporting in practicerequiremetnts andguidance – TCFD reporting56TCFD requirementsbeyond premium listedcompanies Further informationand contactsAppendix6. Further information and contactsExternal GuidancePwC GuidanceGuidanceSummaryLink to GuidanceGuidanceSummaryLink to GuidanceFinancial StabilityBoard (FSB) – TCFDGuidance This publications hub contains all theTCFD guidance, including the finalTCFD report, that has been releasedby the FSB.FSB TCFD PublicationsExcellence inSustainabilityReporting An overview of good practice insustainability reporting, with tips forimproving your reporting.Excellence inSustainabilityReporting 2020 Includes all the documents referredto in this guide.A quantitative analysis of theperformance of the companies scored. Includes the latest 2020 Status Report. Report outlining the roadmap tomandatory climate-relateddisclosures.A summary of what should bereported and why, set in theframework of the TCFD guidance. Basic, intermediate and advanced tipsfor improving your reporting. A quantitative analysis of theperformance of the companiesscored as a part of this review. Summary of the questionsbusinesses should be asking. Examples of physical and transitionalrisks, and discussion around thepressures from regul
Under Listing Rule 9.8.6(8)R, premium listed companies must include a statement setting out: whether they have made disclosures consistent with the TCFD's recommendations and recommended disclosures in their annual financial report; where they have not made disclosures consistent with some or all of the TCFD's recommendations and/or
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A flow of the current MMI process is available in APPENDIX 2. Blue sky taskforce The objective of the MMI Blue Sky Taskforce is to determine key opportunities to reduce risk in the MMI market that could be undertaken by a coordinated industry effort. Taskforce Membership/Participation- The named individuals attended at least one meeting
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