energy efficiency rating labels

How will financial institutes navigate the Age of Greenwashing?


Part 1: The Age of Greenwashing series addresses how to identify and mitigate greenwashing risks from a corporate reporting, asset management as well as advisory perspective.


In brief

  • Greenwashing risks are caused by potential expectation gaps between various stakeholders.
  • The proliferation of various regulations, guidance and standards draw more attention to the topic.
  • Consequently, greenwashing risks are increasing exponentially because everybody is talking about it! 

In this Age of Greenwashing blog series, we will focus on financial institutes and how investors, clients and other stakeholders can be misled if green or other sustainable commitments are not adequately met. We will shed light on the greenwashing risks with a particular focus on the developments of the regulatory framework in Europe and Switzerland today. 

Why has greenwashing risk increased exponentially?

The current transition to a sustainable, low-carbon and resource-efficient circular economy requires financial institutes to position themselves accordingly, be it on a corporate level with e.g. Net Zero commitments or with their sustainable product and service offering. In addition to identifying risks and opportunities from a risk and return point of view, firms now also need to consider externalities or “double-materiality”. Key stakeholders like investors, governments, regulators, clients and employees are also interested in the environmental and social footprint of financial institutes and may expect certain repurposing of financial services aligned with the goals of the Paris Agreement to reorient capital flows from fossil-brown to green.

In essence, greenwashing refers to an expectation gap and greenwashing risks are increasing exponentially because everybody is talking about it, thus drawing attention to the gaps. This trend will continue to grow as a response to ever-increasing real-life pressure to adapt to the large green transformation and in line with various standards being developed on this topic in parallel. 

Corporate greenwashing risks

Based on the Counterproposal to the Responsible Business Initiative (RBI), large Swiss public interest companies (public companies and financial institutes supervised by FINMA) with a total balance sheet of >CHF 20 million and/or revenue of >CHF 40 million and an annual average of 500 full-time employees will soon be subject to a statutory sustainability reporting obligation in Switzerland for the first time. In Europe the Corporate Sustainability Reporting Directive (CSRD), which will replace the Non-Financial Reporting Directive (NFRD), will reduce the applicability thresholds from 500 employees to 250 employees. This will lead to a considerable increase in the number of companies required to prepare a sustainability report in the EU and will also affect numerous EU subsidiaries of Swiss companies.

Climate stands at the forefront of ESG disclosure standardisation and related greenwashing risks. As part of the implementation of the Task Force on Climate-Related Financial Disclosures (TCFD) quality and transparency initiative and Net Zero strategies, financial institutes are increasingly seeking high-quality "green" assets. Companies that have progressed further along their sectoral transformation paths compared to their competitors are seen by investors as potential winners of the green transformation and, accordingly, as interesting investments. The increased transparency and comparability of relevant data will facilitate the assessment of climate-related risks and opportunities and the credibility of green transformation plans in the future. Many large Swiss financial institutes have already (voluntarily) adopted the TCFD recommendations today. This will support the general trend to disclose material Scope 3 emissions, including financed emissions that are by far the most significant emissions for the finance sector. TCFD is also the blueprint for various global corporate reporting initiatives (e.g., from the International Sustainability Standards Board (ISSB) and the U.S. Securities and Exchange Commission (SEC)).

Corporate greenwashing risks arise in connection with external commitments that do not fully address the company’s footprint or are not implemented as promised. They will also increasingly occur now as various voluntary reporting standards become mandatory and such standards often will not be aligned. Upcoming regulations will further speed up the trend from qualitative storytelling to quantitative and comparable sustainability reporting covering a broad variety of ESG topics. Along with this comes an increased pressure to centrally steer reporting and put in place a sound control environment from a group governance perspective (e.g., via the CFO function).

Hot spots of greenwashing risks to be monitored include credibility of (sufficiently ambitious) transition pathways and carbon credits used for offsetting emissions. 

However, the credibility of e.g., Net Zero commitments can be enhanced if a financial institute applies established industry-standards for GHG accounting (e.g., GHG Protocol, Partnership for Carbon Accounting Financials (PCAF)) and Net Zero target setting (e.g., Science Based Targets initiative (SBTi)). Additionally, verification of data inputs (e.g., by independent firms) as well as validated Net Zero targets (e.g., by SBTi) will improve the robustness and credibility of climate targets and simultaneously reduce the risk of providing misleading information to stakeholders.

Greenwashing risks in asset management and financial services

For financial institutes, it is difficult to prove that they cause real world change unless they can clearly demonstrate the allocation of their invested capital to a defined purpose that is not further diluted. Consequently, it should be made clear to investors that a positive contribution or additionality can mainly be achieved via direct capital allocation (e.g., private equity), engagement with investee companies (e.g., public equity) and broad stewardship activities by influencing other stakeholders (e.g., policy makers).

Core greenwashing risks can be mitigated by clearly disclosing to investors the key difference between ESG approaches used for financial materiality considerations and ESG approaches that actually have (or clearly intend to have) a measurable impact on sustainability. It should be noted that the European definition of a sustainable investment is much stricter than the Swiss (and global) labelling of sustainable investment strategies; therefore, this automatically increases the reputational risks even if European standards do not directly apply. 

The Disclosure Regulation (SFDR) contains ESG-specific transparency requirements to be disclosed to (potential) investors via various channels (i.e., website, pre-contractual documents (e.g., prospectus), periodic reports) and must be read together with additional environmental transparency requirements based on the EU Taxonomy Regulation. These transparency requirements contain disclosure obligations on an entity and product level and apply to entities manufacturing financial products (Financial Market Participants) or providing investment or insurance advice (Financial Advisors). Financial Market Participants include e.g., fund managers, insurance-based investment product providers, pension product providers and institutions providing portfolio management (discretionary mandates) so, broadly speaking, any type of asset manager also covered by the recently published Asset Management Association Switzerland (AMAS) self-regulation in Switzerland.

In investment advisory and portfolio management service processes, the product related ESG disclosures must be matched with sustainability preferences expressed by clients. The key challenge here is to enable a meaningful dialogue between clients and client advisors, both of whom are typically not experts on various ESG implementation approaches. Managing realistic client expectations is particularly challenging in situations where clients have ambitious ESG preferences and client advisors are hesitant to transparently disclose the limitations of their current product offering.

Financial institutes are challenged to set up robust product governance processes and critically assess their current sustainable product shelf. They are well advised to apply conservative definitions to terms like “sustainable”, “impact”, “carbon-reduction” and “Paris aligned” and ensure their consistent use, both internally and externally vis-à-vis clients.

Summary

In the Age of Greenwashing series, we will dive deeper into these product and service specific greenwashing topics by considering various EU regulations (CSRD, SFDR, EU Taxonomy Regulation, amendments to the Markets in Financial Instruments Directive (MiFID II) and Insurance Distribution Directive (IDD)) as well as RBI and the Swiss (self-)regulation recently published by FINMA, AMAS, Swiss Sustainable Finance (SSF) and the Swiss Bankers Association (SBA).

 

Acknowledgement: Many thanks to Heidi Gysi for her valuable contribution to this article.


About this article

Contributors