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Co-operative Societies and TCFDs

13 December 2021

COP26 was a crucial moment in the fight against climate change. TCFD reporting is an important part and something all organisations ought to plan for.

It has been a month since COP26 concluded in Glasgow and organisations have now had the opportunity to digest what was discussed. As COP26 highlighted, environmental, social, and governance (ESG) factors are increasingly important and needs to be a strategic priority for businesses, with an increased demand from stakeholders wanting to see an ESG strategy in place before they decide to do business with you.

Financial Stability Board’s Taskforce for Climate Related Financial Disclosures (TCFD) are an important part of every ESG strategy, helping businesses to improve their own understanding of their long-term climate-related risks and opportunities.

What are the TCFD recommendations

The TCFD published a final report in 2017 that set out overarching recommendations in four thematic areas. Namely:

-     Governance

-     Strategy

-     Risk Management

-     Metrics and targets

Vision for TCFD reporting

The TCFD final report clearly aims to encourage wide reporting, not limited to any one sector or legal structure. The Report provides adoptable recommendations on climate related financial disclosures that are applicable to organisations across sectors and jurisdictions”.

Indeed, the UK Government appears to agree that the end-goal is for TCFD reporting across sectors. The UK Taskforce has developed a Roadmap towards mandatory TCFD-aligned disclosures across non-financial and financial sectors of the UK economy over the coming years.

Supplemental guidance is available for non-financial sectors with the highest likelihood of climate-related financial impacts. These include Real Estate Management and Development; Beverages; Agriculture; Packaged Foods and Meats; Paper and Forest Products; Automobiles and Components.

Introduction of mandatory reporting

In keeping with the FSB’s priority on large asset organisations, the Roadmap presents a coordinated strategy for seven categories of organisation: listed commercial companies; UK-registered companies; banks and building societies; insurance companies; asset managers; life insurers and FCA-regulated pension schemes; and occupational pension schemes.

The first group to see any changes are listed public companies with the introduction in December 2020 of a new rule from the FCA obliging in-scope firms to disclose, on a comply or explain basis, against the recommendations of the TCFD.

Following these new measures for listed companies, it is anticipated that new rules will be introduced for large private companies with over 500 employees and £500 million in turnover in April 2022.

Position of co-operatives

The reporting requirements and associated timescales for co-operative societies have not yet been confirmed. However, co-ops have been part of the wider discussions with government about TCFD disclosures.

The Co-operative Group were included on the list of respondents to the government consultation on improving governance and reporting by occupational pension schemes, which considered TCFD reporting. The Co-operative Group were quoted as being “supportive of measures”.

In the run up to COP26, Co-operatives UK held co-operatives up as ethical and environmental organisations. In a joint declaration on behalf of the sector, co-operative business called on the UK government to make end-to-end carbon footprint reporting mandatory for all large business.

Whilst reporting on TCFD looks to remain voluntary for co-operative societies for the time being, with such support for climate-related reporting at a national level, local co-operatives may wish to begin considering how they would report on TCFD in future. You may find that if you contract with an organisation which has TCFD reporting obligations that they may ask you if you have a climate change policy.

For practical advice on what your organisation’s next steps maybe, please contact Claire Taylor.

If you would like to discuss any aspect of this article further, please contact Claire Taylor or any member of our Charities and Social Economy team on 0113 243 6100.

You can also keep up to date by following Wrigleys Charities and Social Economy team on Twitter.

The information in this article is necessarily of a general nature.  The law stated is correct at the date (stated above) this article was first posted to our website. Specific advice should be sought for specific situations. If you have any queries or need any legal advice please feel free to contact Wrigleys Solicitors.


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Claire Taylor


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