This page details InfluenceMap’s feedback provided to Chronos Sustainability Limited with regards to its Responsible Climate Change Lobbying Assessment Framework. Chronos has partnered with AP7, BNP Paribas Asset Management and the Church of England Pensions Board to develop a framework to assist investors and other stakeholders in assessing whether and to what extent corporate lobbying is aligned with the goals of the Paris Agreement on Climate Change. Feedback is currently being sought ahead of the finalization of the framework.
InfluenceMap's Comments
The proposed framework represents a significant step forward in understanding the types of activity associated with strong corporate performance on climate change policy engagement. InfluenceMap now considers it critical to focus the framework to ensure the prioritization of robustly assessed indicators that cover 'real-world' policy engagement activities. The consultation provides an explicit opportunity to help shape this focus.
InfluenceMap's full response to the consultation is available in the download link below. Our key high-level comments are summarized here:
(1) Prioritize real-world indicators on actual company performance: The proposed framework includes a range of indicators covering commitments, governance, action, and reporting. While this ambitious scope is encouraging, care should be taken to ensure that the most fundamental bits of information pertaining to a company’s real-world performance on climate change policy engagement are not crowded out. These fundamental indicators include the extent to which a company is actively engaging on climate policy, and the extent to which this engagement, including the lobbying activities of the company's industry associations, is aligned with the goals of the Paris Agreement. Accurate and independently verified assessments of these points are critical as a precursor to fully understanding many of the remaining indicators. However, they are only partially covered by the proposed framework. A solution could be to reorder and/or rephrase the indicators to fully address and prioritize this information.
(2) Rephrase the indicators to encourage a robust rather than simplistic assessment approach: The indicators are currently phrased to suggest binary ‘yes/no’ responses in actual assessment processes. InfluenceMap's work on this issue strongly suggests that overly simplistic indicators, particularly those based only on a review of direct corporate reporting, would leave the process vulnerable to being gamed by companies. This issue could be resolved by rephrasing some indicators to signal investor intent to externally verify corporate disclosures on policy engagement.
(3) Make the policy engagement benchmark clearer: Under the proposed framework, companies are required to align their climate policy engagement with the "goals of the Paris Agreement, with the stated aim of restricting global temperature rise to 1.5⁰C". Such a phrasing leaves companies a wide berth to define which policy pathways they believe contribute towards these goals. A solution would be to articulate an external benchmark, for example "the IPCC and policy proposed by government bodies mandated to implement the Paris Agreement". Without articulating an authoritative, external benchmark, it is likely that companies opposed to the necessary shift away from polluting economic practices will pursue their own policy choices whilst subsequently claiming these are Paris-aligned. InfluenceMap's research shows this has been an effective policy engagement play book for parts of the corporate sector opposed to robust climate action, with the end result being scant effective climate policy in place.
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The public consultation on the proposed 'Responsible Climate Change Lobbying Assessment Framework' is open until May 21st 2021. This consulation provides an opportunity to focus the framework on real-world indicators to assess company performance, as outlined above.
Click here to access the proposed Responsible Climate Change Lobbying Assessment Framework
Click here to respond to the public consutation by May 21st 2021