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One example of where greenwashing risks can emerge is in the context of Net Zero commitments, which have quickly become mainstream. However, behind the performative element of the announcement, there must also be a sound plan for implementation covering the material part of the business. Removals and offsetting should only be a subsidiary measure for remaining emissions that could not be reduced with other measures. The SBTi’s Net Zero Standard provide guidance and tools to set science-based net-zero targets that are in line with planetary boundaries. Validation of targets by SBTi makes climate targets robust and credible while at the same time reduces the greenwashing risk of information provided. As further reinforcement, established industry-standards for GHG accounting (e.g., GHG Protocol, PCAF, Swiss Climate Scores) can be additionally applied. Even with the mentioned best practice standards there are a lot of potential greenwashing traps and unanswered questions as long as no clear carbon accounting standards are available. For financial institutes it is difficult to prove that they cause real world change, but their clear intention to do so should also be a core element of implementing climate strategies. A positive contribution or additionality can mainly be achieved via direct capital allocation (e.g., private equity), engagement dialogue with investee companies (e.g., public equity) and through broad stewardship activities by influencing other stakeholders (e.g., policy makers or via peer alliances).
Another example of where greenwashing risks can arise is in the context of reporting on Scope 3 GHG emissions (indirect emissions from up or downstream in the value chain) in addition to the Scope 1 (direct owned/controlled emissions) and 2 (indirect emissions from purchased energy) reporting. Reporting on scope 3 emissions is a clear step towards more accurate and representative emissions reporting and the inclusion of such emissions is strongly recommended by industry standard setters (e.g., TCFD, SBTi) and even required by some regulations (e.g., EU CSRD). Especially for the finance sector, financed emissions are by far the most significant emissions. That being said, scope 3 emissions are notoriously difficult to capture and measure due to a lack of reliable and accurate data and standardized methodology. It is, therefore, important to keep up with continually developing data and guidance (e.g., GHG Protocol, SBTi and, most recently, ISSB) and respective changing stakeholder expectations in this regard. While data on listed equities and bonds is broadly available in comparison, other asset classes’ data such as private equity and real estate is currently more challenging to source (e.g., missing information on energy efficiency of buildings for the calculation of financed emissions from mortgages). In addition to data availability, the quality and granularity thereof can also pose pitfalls. The use of approximations (e.g., sectoral or regional approximations) address the challenges short term and allow for an initial estimate. Nonetheless, a financial institution should continue to work on improving data availability, quality, granularity, and robustness to increase the accuracy of its measures going forward. The Finance function is becoming increasingly important in this regard as non-financial (ESG) data shall become as robust as financial data embedded in the same sound control frameworks.
Beyond voluntary commitments, an institution should also ensure its organization is set up in a way to mitigate greenwashing risks. Even if an institution chooses not to follow the key elements of a proper TCFD implementation (i.e., Governance, Strategy, Risk Management, Metrics and targets), its dimensions can also in the context of greenwashing act as a useful checklist to ensure an institution’s organization and methodologies are well-designed and cohesive.