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Global Summit 2022 [Session 1]: Zero ambitions - what is the role of boards on climate?

Updated: Dec 29, 2022

On 12 October 2022, Climate Governance Initiative (CGI) hosted the Global Summit 2022: Ambition to Action, a 24-hour virtual conference spanning the globe and bringing together highly motivated board members and other eminent speakers who champion effective climate governance.

Climate Governance Malaysia is the secretariat for the ASEAN Climate Governance Network (ACGN) – which is supported by all institutes of directors in the region curated a series of 4 sessions for this 24-hour global summit.

The first session of the series was "Zero Ambitions: What is the Role of Boards on Climate?"

Investors and regulators see climate goals as essential to risk management and growth – and expect boards to drive to change. What action should a successful board in ASEAN be taking from the perspective of a global or regional investor? How is regulation changing the responsibilities of directors? How will investors balance the benefits of engagement with the pressure they face to divest?

This session explored the role of boards in delivering the decarbonisation of economies and seek to define best practices for regional firms, featuring the following distinguished speakers and panellists:

  • ·Karina Litvack, Founder & Chairperson, Climate Governance Initiatives (Welcome Note)

  • ·Prof Jim Skea, IPCC Working Group III, Co-Chair (Keynote speaker)

  • ·Prof Dr. Djisman Simandjuntak, Rector of Universitas Prasetiya Mulya, Chairman of the Board of Directors of CSIS Foundation, Co-Founder IICD & Former Trustee Board and IICD Fellows, Indonesia (Keynote speaker)

  • Charlie Penner, Former Head of Active Engagement, Engine No.1 (Keynote speaker)

  • Michele Kythe Lim, CEO, Institute of Directors Malaysia (Moderator)

  • Jamie Allen, Secretary General, Asian Corporate Governance Association, Hong Kong (Panellist)

  • Stephen Miller, President & Group CEO, ST Telemedia, Singapore (Panellist)

  • Amar Gill, Managing Director & Head of Investment Stewardship, APAC, BlackRock Hong Kong (Panellist)

Highlights from this session

Welcome Note by Karina Litvack, Founder & Chairperson, Climate Governance Initiatives (CGI)

"Boards must lead and inspire the whole organisation to take climate change seriously. They must reach out and engage external parties like policymakers, civil society, customers, suppliers and the whole ecosystem and work together to find solutions to the challenges facing climate change. Directors need to understand the responsibility and opportunity of climate change." Karina Litvack

1. Why is Asia important?

Asia is the fastest-growing region. It provides an opportunity to realize an effective climate transition with the adoption of new technologies, and the opportunity to leapfrog and learn from the errors of Europe and North America made before them. It is a part of the world that is extraordinarily exposed like the recent flood in Pakistan for example. This is why Asia is on top of the agenda and all eyes must be on Asia.

2. What do businesses and boards of directors in this part of the world need to realise urgently?

Boards need to realise that climate change is their responsibility, not just the government's. It is an overall responsibility of society. No one can do it alone. Boards must pick it up and drive this agenda or else it won’t happen at the pace and on the scale that is required.

3. What do you see as the best practices of climate governance that directors could take on board?

The board must realise and understand the urgency of the climate challenges. Boards must lead and inspire the whole organisation to take climate change seriously. They must reach out and engage external parties like policymakers, civil society, customers, suppliers and the whole ecosystem and work together to find solutions to the challenges facing climate change.

Directors need to understand the responsibility and opportunity of climate change.

Keynote Speech by Prof Jim Skea, Intergovernmental Panel on Climate Change (IPCC) Working Group III, Co-Chair

"It is a little sign of optimism when we inject the message of hope into the picture, many countries are now adopting a Net Zero target but what we have at the moment is a gap, it is not an emission gap in terms of Net Zero pledges, it is an implementation gap instead." Prof Jim Skea

The IPCC prepares comprehensive Assessment Reports about the state of scientific, technical and socio-economic knowledge on climate change, its impacts and future risks, and options for reducing the rate at which climate change is taking place. It also produces Special Reports on topics agreed to by its member governments, as well as Methodology Reports that provide guidelines for the preparation of greenhouse gas inventories.

The IPCC is working on the Sixth Assessment Report which consists of three Working Group contributions and a Synthesis Report. The Working Group I contribution was finalized in August 2021, the Working Group II contribution in February 2022 and the Working Group III contribution in April 2022.

Working Group One produced reports on physical science. The report made it clear that human beings are unequivocally the cause of climate change that we are all observing at the moment.

Working Group 2 looks at the impact on adaptation and vulnerability that have drawn attention to the fact that we can already observe the effect of climate change on both the natural systems and human systems. We can see it in terms of floods, loss of marine life and forest fire around the world. Things that people can really observe and relate to. These changes can only get worse unless we do something about climate change. For example, we can see the deterioration in crop yields is much greater than the loss of species and loss of human infrastructure and cities and elsewhere.

Working Group III looks at the mitigation of challenges of reducing emissions. We clearly send out messages to stop climate change Global Emission after reaching Net Zero during the second half or close to the middle of the 21st century.

It is a little sign of optimism when we inject the message of hope into the picture, many countries are now adopting a Net Zero target but what we have at the moment is a gap, it is not an emission gap in terms of Net Zero pledges, it is an implementation gap instead. In terms of seeing the kind of measure taking place on the ground that would allow these Net Zero pledgers to be met. We just have the possibility of limiting warming to 1.5 degrees but these opportunities will go unless we take dramatic action quickly.

We have in the Working Group III report on mitigation. Moving forward to limit the worst effects of climate change we need action across all sectors of the economy, we need to transform the energy system with particular emphasis on the role of renewable energy. In demand sectors like transportation, we need efficiency but we also need a move to a different form of energy, particularly on a move from oil, and fire transport with an internal combustion engine to electrification that will allow us to take advantage of low to zero carbon electricity.

Buildings in many parts of the world can be made much more efficient and future cities can be designed in different ways to take advantage of green infrastructure i.e., more use of trees and blue infrastructure like filling the cities with more water that helps us cool down and help to reduce energy requirements. In the industrial sector, there is a prospect of getting to Net Zero emissions from some of the bigger challenging processes in steel and cement.

Finally, we do need to face up to the issue that we will need to remove carbon dioxide from the atmosphere to compensate for particularly difficult sectors and this can be done in the so-called nature-based solutions to a greater extent than IPCC is considered. Things like planting trees are very obvious but also agricultural culture practices that build up carbon in soils will help with both adapting and mitigating climate change.

We do have a chance to make a difference.

Keynote Speech by Prof Dr Djisman Simandjuntak, Rector of Universitas Prasetiya Mulya, Chairman of the Board of Directors of CSIS Foundation, Co-Founder IICD & Former Trustee Board and IICD Fellows, Indonesia

"Companies need to quantify their carbon footprint not only within the companies but along with the value chain." Prof Dr Djisman Simandjuntak

We are now facing very fundamental issues. Fundamental Corporate Re-setting is important because of climate change. The losses in biodiversity, and an increase in inequality despite SDG 2030 because of the shifting global economy, particularly in Asia. Asia is very important when dealing with climate change.

China, Indonesia and India are the most populous countries and the three major emitters of carbon dioxide. The government have agreed on a number of basic agreements like the Paris Agreement, and the Agreement on Biodiversity so the issues we are facing now are not an agreement gap but the action gap on the business side because of a lack of awareness due to a knowledge gap or technology gap.

To narrow the gap, the corporate needs strategic internalization of climate change and related issues and impacts, including a moratorium on biodiversity losses and making a firm a positive force of inclusion. There is no big bang or metamorphosis in mitigation. The corporate will have to go through the evolutionary way to Net Zero 2050.

Companies need to quantify their carbon footprint not only within the companies but along with the value chain. It is important to draw an evidence-based corporate agenda. For example, in the Enterprise Roadmap company may include a target to least material consumption for a given goal and good uses of market power. Companies may minimize material consumption for every unit of need.

The OECD reported that we are consuming 80 gigatons of materials every year. And it is estimated to increase to 170 gigatons by 2060. Companies need to create and sustain re-setting momentum on a daily, weekly, monthly, quarterly, and annually on signature programs into carbon-less intensive businesses. This is where boards play an important role to drive a new corporate culture like carbon efficient habits of the entire workforce.

ASEAN countries should work together on the governance scorecard and climate scorecard and reach out to [other] ASEAN corporations to be supportive of this idea.

Keynote Speech by Charlie Penner, Former Head of Active Engagement, Engine No.1

"Climate change doesn’t follow any party affiliation. The benefits of energy transition include cheaper, more reliable, and fewer geopolitical boundaries." Charlie Penner

1. Asia is the factory for the world, keeping inflation down, with consumers outsourcing their carbon footprint and environmental destruction to this part of the world. What would you say to businesses – whether multinationals or those in the supply chain - which are betting against society succeeding?

On a short-term basis, it’s very difficult for individual countries much less the global community to address the challenges of climate change. But from a long-term perspective, particularly if you look at the changing economic alternatives to a heavily carbonised economy, it makes sense to think over the long-term that those dynamics could change.

Capital allocation and good strategic decision-making involve taking account of risks. Companies are failing to address this long-term risk that the global economy is gradually decarbonising. You need board members, strategy, and a management team that are cognisant of those risks and have the skill-sets to be able to adequately address them.

2. You gained the foothold on the board of Exxon mobile based largely on the strength of your argument that failing to plan the impact of climate change could spell the demise of the business these are the risks that you are talking about. But from a slightly different perspective, would you say that mitigating environmental harm is part of corporate responsibility?

Absolutely, mitigating environmental harm is part of corporate responsibility. It will affect their long-term competitive positioning in the market.

I am a firm believer that a company’s mission is to maximise value for its investors. If companies think long-term about environmental and social issues, including a negative impact on the environment, society, workers and consumers will perform better in the long-term.

3. Can you walk us through the thought process behind Engine No1. ?

The basic thought process was that you have a company which really was an outlier even within the oil & gas industry in terms of its performance for stakeholders and its approach to longer-term risk factors. The concept is you could make a compelling case to investors solely on the investor-to-investor level that change was needed. The company’s long-term future is very crucial and must be positioned correctly to address the challenges of the future.

With respect to why change board members as opposed to the CEO, we didn’t make the challenge that the CEO needed to be replaced. Secondly, in the USA, there is no management board and executive board. There is only one board and it is the responsibility of the board to oversee the company’s strategy and that includes choosing who is the management team. The board of directors of Exxon at that point of time didn’t have anyone with energy experience except for the CEO, thus the challenge was to change the board.

4. What should the board of directors in Asia be watching for in terms of climate change?

Climate change doesn’t follow any party affiliation. The benefits of energy transition include cheaper, more reliable, and fewer geopolitical boundaries, not party affiliation. I hope over time that gets recognised.

The following questions were discussed at the panel discussion: Over the past few years, we have seen a marked shift in the attitudes of policymakers and an acceleration in the announcement of regulatory measures to address climate change as well as increasing pressure and expectations on companies – and therefore their boards – to have in place business strategies and plans that clearly spell out the steps they are taking to adapt to economic transition risks or eliminate contribution to climate change. It is apparent from legal and regulatory developments that directors are duty-bound to proactively and urgently apprise themselves of all aspects of climate change that can affect their companies. Boards must take responsibility; mobilise resources to manage the full spectrum of climate-related risks by integrating them into their corporate strategies & actions and ensure proper disclosure of such risks. Climate change has evolved from an “ethical, environmental” issue to one that presents foreseeable financial and systemic risks and opportunities. This evolution has substantially changed the relevance of climate change to the governance of companies, which has implications on the fiduciary duties of directors as iterated in the “Legal Opinion on Directors’ Duties and Disclosure Obligations under Malaysian Law in the Context of Climate Change Risks and Considerations” commissioned and recently released by the Commonwealth Climate and Law Initiative (CCLI). 1. What are some of the strategic options can directors take in managing these climate risks (i.e., emissions reduction targets) and taking advantage of associated opportunities? Directors and companies do not need to reinvent the wheel in terms of thinking about climate risks from a strategic perspective. There are currently available frameworks such as the World Economic Forum framework and Task Force on Climate-Related Financial Disclosure (TCFD) Framework. There are a lot of other frameworks that have been done by companies around the region and around the world that are available for companies to refer to and study. For example, in the TCFD framework, companies need to think about governance, what is the proper structure at the board level for discussion on climate risks and opportunities. What sort of board do they need? Do they need a specialised committee? It is really important to emphasize the role of management because management is full-time in the company. The management team are the major part of the engine room for thinking about strategic issues. Thus, companies need to have the right people and structure in management. The second point on strategy is an issue of really thinking through at the board and management level, what are the material risks facing the company, and how do you address those over the short, medium and long term. For example, regarding the Physical risks of climate change, the board needs to be thinking through these issues and also thinking about if there are any new commercial opportunities they can benefit from in terms of products and services or new ways of doing what they are currently doing. Bringing risk management issues into the risk management framework. An example of an Australian company that runs toll roads, what they are developing for major assets that they call CR AMP – Climate Risks Adaptation and Management Program for major assets really thinking through what are the different impacts using things like scenario analysis on what are the different impacts on different climate change outcome will have on different assets. What are the plans they are going to put in place to adapt? On metric and target, what is more compelling to investors is the interim target of 2030. A lot of companies have emission reduction targets and other targets for 2030. Companies must ensure that those targets are relevant and verified by science-based methods. It is also important to have a pathway to 2030, it is not enough to say we are going to reduce emissions by 50% but how are you going to get from here to there for the next eight years and what are the interim targets between now and 2030? It will be useful for companies to take the TCFD framework and World Economic Forum framework and really think through this strategically and in a very structured way. 2. How would this impact, and factor into strategy formulation, business planning and CAPEX more broadly? You don’t go from zero to 100 immediately, it is a long-term process. This is a multi-year process from the boards, and management. It is an evolution in terms of skill set, understanding, and development. For strategy, it has become apparent whether you are looking at merger and acquisition or entering a new line of business, ESG incorporation into those assessments and analysis is critical. The board will have the management to execute this so the development of management skills and attention to this often gets overlooked. Board must be aware that without the right talent you are not going to achieve the target. Thus, the board need to look at the execution capability of the management team as they develop the strategy. 3. Do you think that these mandatory disclosure standards will provide sufficient information regarding your portfolio companies’ climate risks? What material risks would you look at for your portfolio companies? What would you recommend for them to comply with TCFD? A lot of companies in this region look at regulations and disclosure requirements with a compliance mindset. The risks are the requirements of the listing rules in markets may differ and companies will take the lowest level of disclosures as what they need to provide. There is a role for regulators to play as well and that is where the new standards are evolving. The International Sustainability Standards Board (ISSB) has two papers of consultation on standards which are targeted to be finalised by early next year. It has a very promising baseline of reporting requirements for sustainability that we hope the exchanges across the world will adopt so that the companies are all starting to report on what is materials, and what is relevant for the business that is comparable from one market to another for given sectors. Even before regulators start to introduce disclosure requirements, companies that want to show that they are really ahead on sustainability challenges can start with TCFD. On the risks for companies in the evolution of this space, technology is evolving very quickly. In South Australia, 80% of the energy of electricity is now renewable. So you need to have a very capable battery as backup, stable generation of renewable into the system but it is getting there very quickly. So, the biggest risk for companies is that they are not keeping abreast with the new technologies that have become economically viable thus, boards and management must always keep the tap on. 4. What are the best practices in incorporating or integrating climate-related risk into your risk management process? In the Telco business as the company moves from 3G to 4G and now 5G one of the unattended consequences of 5G is a very large increase in power consumption. The way that the radio network works for 5G often has multiple antenna arrays on one site, it is great in terms of customer experience and technical standards and capabilities but the operating system will go up in terms of power consumption. Telcos have to offset through the efficiency of operating systems and offsetting the generating power consumption that can be more focused on local targeting. For example, turning off some cell sites during off-peak hours. When looking at changes and evolution of technology and capabilities, you must simultaneously have to look at the implications for climate and how you can operate efficiently. For a data centre, if a company wants to maintain a social license to operate, the company must commit to renewable energy and have to be developed on a platform basis. Different geographies have different capabilities e.g., in Singapore, there are no capabilities just due to the land size to generate renewable energy, so how can a company look at that from a corporate strategy point of view? Companies may have to take the whole of the Asia Pacific or the whole of ASEAN approach. There are many emerging opportunities for nature-based solutions that were referred to as the cross-border transmission of green electricity and potentially cross-border trading of the verifiable wreck. All of these are now coming in simultaneously rather than as an afterthought or as a consequence. 5. Some quantified climate-related metrics such as GHG emissions, transition risks, physical risks, and climate-related opportunities are being extensively used in corporate disclosure. How should all these be translated into something meaningful and useful in assessing and managing relevant climate-related risks and opportunities? Having a meaningful target is not self-referential. Companies need something that is aligned with the Paris Agreement ideally and probably need to bring in external expertise to help develop the target which is science-based to help validate the target and measurements. That process takes time so we encourage companies to move on sooner rather than later. 6. Do we need a “Climate Change” director or sustainability committee? Mitigating climate risk falls squarely within the board’s jurisdiction, and shareholders who are dissatisfied with a company’s climate strategy can oppose the re-election of the directors responsible for that strategy — or support a dissident slate of nominees who are prepared to develop a credible plan. Last year, Engine No. 1 defeated Exxon Mobil in a historic proxy battle by electing three directors to Exxon’s board after arguing the oil giant was a climate laggard. The crucial questions to be asked by investors shall focus on the board’s accountability and directors’ skill to mitigate these climate risks. There is a need for a committee to look in detail at sustainability. Whether it is a sustainability committee or not, each company to look at what is needed by the company and investors. Some companies have sustainability committees at the board level and management level while others delegate this to the audit committee or risk audit committee company to decide what is best for them. However, if a company is going to delegate to the existing committee, companies must ensure the committee has the skills, time and energy to think it through properly. Do the company need sustainability directors? Probably not because there is danger in having overly specialised roles in directives thus it is important to have a range of skills at the board level and bring in people with a sufficient level of knowledge on sustainability. 7. How would you advice companies to set the roadmap to achieve their targets? When companies start planning for their sustainability journey, capability development at both the director level and management level will take time. Companies may start with Scope 1, and Scope 2 and get the measurement underway, understanding what you are contributing to GHG and other requirements. By identifying your contribution and requirements, you can start taking direct action on things that are within your control and measure the impact. 8. How do you include climate change in your balance scorecard as part of executive remuneration? A company needs to go through the measurement and target process first before it becomes a valid element of people’s KPIs. Companies must ensure management is comfortable being measured against those KPIs and that the boards are comfortable setting the KPIs. That goes to the REM committee. The REM committee must seek inputs from the risks committee and sustainability committee before making any proposal or recommendations. 9. Do you agree that zero target ambition is something “good for the brand” but not foundational to company strategy? How to make climate strategy execution real and achievable? According to Climate Action 100+, 69% of focus companies[1] have committed to achieve net zero emissions by 2050 or sooner, however only 17% of focus companies have set medium-term emissions reduction targets aligned with 1.5°C. When it comes to climate change, the real stakeholder is actually your employees. Young employees want to work for companies that have climate change or sustainability commitments, thus there is a bottom-up element of commitment to climate change and good purpose in this area. If boards do not hold the companies for accountability, the employees certainly will. Thus, it is valid to set long-term ambitions but very clearly companies have to work backwards from the set targets. It has to be a cross functions approach to get a comprehensive step-by-step approach over the next couple of years. 10. Is climate change being taken seriously by boards in ASEAN, it is nice to have and not a priority? Is it going to be achievable in ASEAN? There have been changes in the last 2 years. Previously, investors had to request their investing companies to start TCFT reporting. Investors have to push on sustainability reporting and the company plans on climate change, risk and opportunity. Today, companies would have a sustainability committee not only at the board level but also at the management level and usually the committee reports to the CEO. Now companies are inviting investors to speak to their boards about what investors think they should be doing and what the investing companies are looking for and more and more independent directors are brought into the conversation. It has evolved quite a bit over the last couple of years. Much of it is driven by the regulators. In markets like Malaysia and Singapore where the regulators are setting a higher benchmark, companies are also asking for more from their investors. Across ASEAN, there has been significant improvement. 11. What more need to be done in terms of competency or regulation side? There is still a lot that needs to be done. For example, management capability, and the expectation of the companies if the focus is on the board. However, the most important thing is the directors must be asking the right questions to the management. Boards need to engage and consult external parties to get the latest and accurate information. Board needs to be discussing with consultants, and experts on how the industry is evolving so that they are able to ask the right questions to the management. Board needs to be equipped with competency and knowledge. 12. Is say-on-climate votes facilitating greenwashing? What actions can be taken to curb greenwashing? Say on Climate - ESG ratings and score provider MSCI found that 58% of say-on-climate votes in 2021 were only one-time events with only 24% of votes set to have annual follow-ups. Edelman survey reported that nearly three out of four institutional investors do not trust companies to achieve their stated sustainability, ESG, or diversity, equity, and inclusion (DEI). On the other hand, investors who lack the expertise and necessary resources may not be able to effectively scrutinize climate plans while companies might try to justify those plans in future years by pointing to the fact that they have received shareholder approval. Some companies put this on their agenda although not much in ASEAN. Where the disclosure will differ from one company to another. It is useful for companies to get a sense of whether investors think that they are doing enough for the climate. What is more important is for the company to have real engagement by senior management and the board with the stakeholders, the expert on how technology is evolving and with investors so that the board gets direct communication from investors and their concerns on the sector and for investor to also have direct communication from the board on how they are addressing the issues and how they determine what are the right strategies for the company. Climate vote is not another substitute for good engagement by companies. We’ve been covering governance for a long time and there’s always the risk that the market tries to bring in. You ask the investor to vote on the appropriate pay which leads to a hugely long remuneration report. There is a huge amount of time spent by the investors reading this report but some may understand it while some are not. If companies are producing their TCFD reports it probably becomes a catalyst for companies to do things more quickly. It also allows investors to come up with the learning curve more quickly. The granular details of Scope 2 and Scope 3 and another aspect of climate change disclosure. Broadly it is a positive trend and not greenwashing. In Singapore, it started four or five years ago, but the big impetus really has happened over the last two to three years. Through government ministries, SGX and SID. The importance of criticalities to countries like Singapore, Maldives, and the Pacific Islands is not a loss to any other countries. Say on climate comes back to the early reference which comes to - is the board doing this because they fundamentally believe in it, therefore, you have the right intent and approach or is it a compliance issue? The company that takes avail themselves to intent probably will be applauded rather than scrutinised in the compliance approach that will get people in trouble. If you look at the inflows into climate funds, it has been increasing over the last two to three years. If companies do not want to be scrutinized under Say on Climate, the board needs to go from compliance to intent. 13. How to move the board beyond compliance? It is very much a carrot & stick approach. For example, if you listen to an explanation from various green fund managers about what they do and how they think about it, there is an opportunity set that’s evidence. Some companies are taking it from the opportunity point of view. For example, they reimagine their business, reimagine how they organised themselves, reimagine how they procure some green achievement might be modest in their individual circumstances but just the sheer act of reviewing the core functionality of your core purpose often leads to material improvement in underlying operations and capabilities. It is a very noticeable and beneficial effect. 14. Do we have the time to not prioritise fast-tracking Scope 3 emission inventories? From an investor point of view, the risk of requiring Scope 3 reporting immediately is, if companies are providing information and data where there are assumptions that vary from one company to another and data may not be comparable or meaningful. So more important than Scope 3 data is how the company are thinking about what will be the sensible way of gauging the Scope 3 footprint. For investors, Scope 1 and Scope 2 are mandatory. Investment companies like BlackRock are voting against companies in carbon-intensive sectors across the world including APAC. If companies are not producing Scope 1 and Scope 2 disclosures on emissions, their long-term and medium terms targets, Scope 1 and Scope 2 will be seen as voting issues while scope 3 is an engagement issue with companies. 15. What about attestations on the disclosure? Does it talk about independent verification or assurance on disclosure? Currently, we see more verification attestations from audit firms and specialist consulting firms who do verification attestations. However, it is not moving as fast as it should be. A lot of companies are not having their ESG or Sustainability Reports assured. Auditors are still debating on the standards they need to use like ISAE 3000 standards and there are also issues on differences between those standards and double A accountability standard. There are also different approaches taken by auditors vs specialists. Attestation firms need to have an education and awareness building on what are the different options and the role of different assurers. Assurance really needs to move pretty quickly from being a voluntary exercise in every market currently to at least making it mandatory for the larger more exposed companies or the bigger emitters. There is also a need for investors to engage with companies. Most Assurances are limited assurance because there is no pressure from the government or market for reasonable high-level assurance. There are also other issues with the company gathering data for a higher level of assurance. Besides that, the cost is huge and companies are not entirely convinced that CPA firms have the capacity and skills. When companies are dependent on 3rd party information on Scope 3, it is very difficult for a company to attest equally to the audit firms to also attest. Scope 1 definitely needs to be verified, Scope 2 somewhere in between and Scope 3 overview basis need to be worked through. There is no clear conclusion around attestation for scope 3 at this point. Please find the recording here.

[1] 166 biggest greenhouse-gas emitters -


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