Thanks to the committee for inviting me to appear and to contribute to its study. I can only express the hope that other parliaments around the world will follow your example and tackle this subject.
[English]
My name is Nathan de Arriba-Sellier. I work as the director of the Erasmus Platform for Sustainable Value Creation, as noted by the chair, in the Netherlands, from where I join you today.
I have a Ph.D. from Leiden University and Erasmus University Rotterdam. Before my current position, I was the research director of the Yale initiative on sustainable finance and a lecturer in financial law and policy at Yale University, just somewhere south of where you stand.
To introduce this testimony, I would like to recall a few facts.
Since 2005, Canada has reduced its greenhouse gas emissions by 7%, performing well below other countries in Canada's peer group. Furthermore, Canada is not yet on track to uphold its legal commitments under the Canadian Net-Zero Emissions Accountability Act. In fact, Yale's environmental performance index—the EPI—ranks Canada 166th in the world when it comes to projections of reaching net zero by 2050.
In the meantime, climate change continues unabated, and the window for limiting global warming to 1.5° Celsius is closing, as mentioned by the United Nations no later than this weekend.
Partly as a result, the Canadian financial system is highly exposed to climate risks, both physical and transition risks. I don't need to remind you of the examples of physical risks that regularly and increasingly in a most exponential way threaten your constituents.
Transition risks are also on the rise, regardless of what Canada decides to do or not. The Canadian economy and financial system is and will be influenced by external initiatives, such as the U.S. Inflation Reduction Act, the European Green Deal and the policies of the People's Republic of China, which have rapidly made it the world's largest producer of renewable energy and electric vehicles.
Solutions will not come from the market. Already in 2007, as Lord Nicholas Stern, professor at the London School of Economics, rightly pointed out, “Climate change is a result of the greatest market failure the world has seen.” ESG hype or not, the market has been incapable, so far, of addressing its own failure. This fact has been most recently evidenced by the so-called “Big Five” Canadian banks who, in spite of their net-zero commitments, have increased their financing of fossil energies, unlike their European or American counterparts.
[Translation]
Solutions must therefore be dictated by public authority, all the more so as the Government of Canada, not corporations, is bound by the Paris Agreement.
Timid prudential supervision initiatives such as guideline B-15 of the Office of the Superintendent of Financial Institutions, or OSFI, have been established in the financial sector.
I would like to review with you several of the initiatives now under way.
First, let's discuss the sustainability disclosure standards proposed by the Canadian Sustainability Standards Board, the CSSB.
It is vital that there be accountability for greenhouse gas emissions, including scope 3 emissions, because failure to do so would be tantamount to distorting the true carbon footprint of the companies concerned. There's a strong consensus on this.
As a result, the International Sustainability Standards Board, the ISSB, has unanimously adopted that standard. Are those standards alone enough? The answer is no, but they are a necessary first step because you can't manage what you haven't measured.
We must also ensure that financial and sustainability disclosures made by companies are consistent.
Then there's the Canadian taxonomy.
First, I encourage you to take advantage of the reform of the Canadian Business Corporations Act to ensure that the taxonomy is included in the publication obligations for enhancing transparency. This does not mean that all companies must comply with the taxonomy, but rather that they must publicize the degree to which they invest in taxonomy-aligned activities.
Second, I draw your attention to the fact that it's important to exclude fossil energy activities, whatever they may be. Why? Because a taxonomy sends a signal to investors and businesses regarding economic activities that support the transition to carbon neutrality. Including fossil fuels undermines the credibility of the Canadian taxonomy, as was the case of the European taxonomy with regard to gas. I refer you to the scientific conclusions of the International Panel on Climate Change. Every year counts, and fossil fuels are not part of the solution.
Lastly, Senator Rosa Galvez introduced Bill , An Act to enact the Climate-Aligned Finance Act. I support that bill, and I encourage the committee and the House of Commons to take it up as soon as parliamentary procedure permits. Once passed, it will advance Canada toward carbon neutrality and significantly reduce the transition risks to which the Canadian economy and financial system are exposed.
In conclusion, I wish to draw your attention to monetary policy, which is often a blind spot in these debates. Monetary policy has a role to play in the strategic framework of government as a whole. Acting within its mandate, the Bank of Canada can assist in preventing and reducing climate risks while supporting the transition to carbon neutrality.
I will be pleased to provide you with further details on these various aspects and to answer any other questions you see fit to ask.
Thank you.
Thank you for the opportunity to address you today.
[English]
My name is Keith Stewart. I am the senior energy strategist for Greenpeace Canada and a sessional lecturer at the University of Toronto, where I teach a course on energy and environmental policy.
I've been meeting with Canadian banks about their funding of fossil fuels since 2008, so if I seem a trifle impatient, it's because after the first decade or so of delay, a certain amount of frustration does set in.
It's also been nine years since Mark Carney gave his “tragedy of the horizon” speech on how the financial sector has a short-term focus built into how it operates, wherein three years is considered long term.
This structural myopia makes bankers largely blind to climate risks or, worse, they can see the risks and have even begun to measure them, but their incentive structure doesn't allow them to respond appropriately, so we stumble towards disaster. This myopia can be overcome, but it will require elected officials to step in. This is not new terrain for governments, as we've been regulating banks to protect them from themselves since 1929.
On climate change, the banks have been very clear: They are not going to be leaders. They are not going to do this on their own. We see it in their balance sheets. Canada's big five banks are still among the largest funders of fossil fuels in the world. According to a recent international report, they funnelled more than $130 billion to fossil fuel companies in 2023 and have put over $1 trillion into oil, gas and coal companies since the Paris Agreement was signed. That's a trillion dollars dedicated to making the climate crisis worse, which dwarfs what the federal government has been spending to try to put out the climate fire.
We also see their unwillingness to lead in their backing away from their net-zero commitments in the face of an assault on ESG investing in the United States. They can claim to have the courage of their convictions, but those convictions seem to change, depending on whether they are writing to a Republican state treasurer in Texas about how much they support funding fossil fuels or testifying before this committee last spring about how much they care about stopping climate change.
We also see a lack of leadership in their lobbying efforts, which have sought to slow down the energy transition. They say they want an orderly transition even if the greatest source of disorder is climate-fuelled extreme weather that results in fires, floods, roads washed away, homes destroyed and drought-stricken fields.
Whether it was Jasper in July or Florida last month, the costs of inaction are all around us, and we should not look away.
A wise women once said that when someone tells you who they are, believe them. Banks are telling us that they are committed to follow, not lead, on climate change, yet financial regulation is still a missing piece in Canada's climate strategy.
We are here today asking you to once again save the bankers from themselves, and thereby help save the rest of us from climate chaos, by using all of the regulatory and legislative tools at your disposal to align Canada's financial system with the Paris climate agreement.
To this end, I join with my colleagues in the environmental movement to express our hope that your report will include recommendations to, first, keep fossil fuels out of any sustainable finance taxonomy; second, develop regulations under existing law to require all federally regulated financial institutions and large federally regulated corporations to implement climate transition plans that align with the 1.5-degree goal of the Paris Agreement; and, third, support the adoption of comprehensive legislation such as Bill , which is the climate-aligned finance act.
We recently saw some movement on the taxonomy that's under development. The taxonomy and disclosure rules are important, but as planned, they will only provide information that others can use to hopefully do the right thing.
We need to stop hoping big money will do the right thing and make it mandatory for them to stop being a part of the problem and start becoming a big part of the climate solution.
Thank you for your time and consideration.
:
Good morning and thank you for inviting me here today.
I represent the Québec Environmental Law Centre, or QELC, the only non-profit organization in Quebec that provides independent environmental law expertise.
Today I'm going to discuss the risks associated with greenwashing, specifically the dissemination of false, deceptive and unproven information on environmental characteristics. Greenwashing is a major problem because it prevents investors from making informed decisions; it also slows down the transition and erodes market confidence. Greenwashing can also destabilize the financial system, particularly by causing the premature sale of financial assets.
Greenwashing has unfortunately introduced significant risks into Canada's financial sector. For example, many emerging financial instruments, such as green bonds, sustainability bonds and voluntary carbon credits, are not subject to any minimum content or procedural requirements.
As you are no doubt aware, Bill , which was adopted this past June, constitutes one step toward combatting greenwashing. Organizations are now required to back up environmental allegations with evidence. In other words, if you say that something is “green”, you must be able to prove it, which is a good thing. However, these measures apply solely to voluntary disclosures regarding environmental benefits. Consequently, they may not be applicable to certain allegations, such as those concerning environmental risks as opposed to impacts.
These measures obviously require no disclosure of information to investors and impose no common language on how to communicate that information. Lastly, although organizations are required under the act to provide evidence in support of their allegations, that evidence need not be disclosed to the public, which complicates the task of identifying greenwashing cases.
A few days ago, the government announced two measures that could help improve the situation. First, it stated that it would require large federally regulated businesses to publicly disclose information concerning climate change, which could well include a certain form of disclosure of GHG emissions by those businesses.
This is a positive measure, but, to ensure that it's effective, it must concern the disclosure of both environmental risks and impacts. Citizens, consumers and investors want to know the environmental impacts of businesses' activities and want that information to be disclosed in a clear and standardized format. General disclosure rules that enable businesses to omit or conceal unfavourable information must absolutely be avoided. Disclosures must also go beyond climate issues and include, for example, biodiversity, pollution, natural resource extraction and so on.
The second measure that the government announced a few days ago is that an independent consulting group will be created and will be responsible for developing a financial taxonomy. That taxonomy, which won't be made public for a year, will establish a classification system and official criteria for projects characterized as “green” or “transitional”. That measure has considerable potential as well. However, for this taxonomy to meet its objectives, three elements, some of which have already been mentioned by my colleagues, will be essential: first, it must include credible, science-based criteria that would prevent the greenlighting of environmentally harmful projects; second, it must be mandatory that it prevent the emergence of weaker rival taxonomies—to date, only one voluntary taxonomy has been announced, which I don't think is enough; third, it must have a governance structure that guarantees that its criteria remain resistant to future political pressure.
Once the taxonomy has been adopted, and taking for granted that it's a proper taxonomy, it will quickly have to be incorporated in the regulatory ecosystem, by requiring, for example, that organizations disclose their degree of alignment, standardize the labelling of financial products, require Crown corporations to establish objectives based on the taxonomy, and so on.
To supplement those two measures, we suggest that the disclosure requirements of federal financial institutions be made more binding, more specific and more comprehensive, in particular, by converting current prudential obligations to regulatory obligations and by compelling disclosure of climate impacts, not solely of risks, but also of information on other environmental aspects such as biodiversity.
Lastly—and we can discuss this further during the meeting—we recommend that the sustainable finance activities of the Financial Consumer Agency of Canada be expanded and that the distribution and use of voluntary carbon credits, those credits that some of us use to offset the impact of our air travel, for example, be regulated. We believe that this field should also be regulated.
I'll stop there. Thank you.
:
Thank you for having me.
I'm going to start from the perspective of what I'm not: I'm not a climate scientist. I'm not an expert on banking. I'm not a macro-economist. I'm not an academic researcher. I'm a dabbler. I dabble in lots of different things, and I've spent 40-plus years observing how businesses and investors behave. What I've discovered is that psychology and perception have a lot more effect on that behaviour than economic models.
As an outsider, I'm going to give you my perspective on what I've seen happen around climate change. This might not be diplomatic, but I might as well cut to the chase.
Here's what I've seen over the last 20 years: Climate change is the most publicized, the most warned about and the most discussed existential crisis that I've ever seen. You're saying that this is merited; that's fine.
Second, governments all over the world claim to care about climate change. In fact, every year they gather together, as in the most recent meeting, COP28. Hypocrisy runs rampant in this space, as in what was said in Dubai. They talk about how they're going to change the world. They set targets that everybody knows will not be met. I'll guarantee you that there'll be a COP29, perhaps in Riyadh, where we will repeat the whole process again.
Companies and businesses all claim to be green. They claim to care about the climate. I'm going to gag the next time I see the words “net zero” in a company's financial statement or an airline asks me to pay an extra $40 if I want to reduce my carbon footprint.
In this process, they've been aided and abetted by consultants and experts who fed them the buzzwords. Let's face it: ESG is an acronym. It doesn't even merit the notion of an idea or a concept—it's an acronym.
Sustainability is just as much of an acronym. These consultants have told these companies that they can have their cake and eat it too, that they can be green and be more valuable.
There's the same phenomenon with investors. They've pumped in trillions of dollars. Don't tell me enough money hasn't been invested in green spaces. There have been trillions of dollars, again with the promise that they can deliver higher returns while being good.
Consumers have been given lots of different ways in which they can show how wonderful they are. They can buy green products. They can invest in green funds. They can misbehave all day, come back home, buy an ESG fund and say, “I'm okay again.”
Here's, I think, the most sobering reality. After 20 years, trillions of dollars and all of this talk, if you look at how much of our energy comes from fossil fuels, it's barely budged. In fact, you know that our dependence on fossil fuels decreased more between 1975 and 1995 than it has in the last 20 years. The reason for that was the one alternative energy source that most green energy people claim to hate, which is nuclear energy.
Over the last 20 years, our dependence on fossil fuels has gone from 85% to 81.5%. We've reduced dependence by 3.5%, and we paid $10 trillion for that amazing fact. I'll let you do the math on that. If you really want to get the fossil fuel dependence down to 50%, you work out how much it'll cost. This notion that you can get good without sacrifice is the heart of why all of this space is in trouble.
I'm not in any position to give you advice on what you should do with your bank and your pension funds, but I'll tell you what I think. I think you've got to stop with this apocalyptic stuff. Do you really think that telling people that the world will end in 35 years is going to make them behave better? That's like telling somebody that they have 60 days to live and saying, “Behave healthfully.” It's not going to happen. Even if you believe that the world will end if climate change is not met, telling people that is the worst possible strategy psychologically.
Second, remove virtue from this discussion. This notion that if you believe that climate change is important, you're a good person, and if you don't, you're a bad person is contaminating the discussion. It's making perfect the enemy of good.
Let's face it: Much of the research on ESG and sustainability is not worth the paper is written on, but the research that takes a closer look has concluded that shades of grey are better than black and white, that investing in brown innovation is better than investing in green innovation and that accepting shades of grey, incremental change, is going to be much more effective than this: “Hey, if you don't do this, we'll die.”
:
Thank you very much. This is a very interesting question. Of course, I don't think we have the time to go through all of them or much of them in five minutes.
What I would say is that I share some of the comments that were just made about the fact that ESG is a melting pot of anything and everything, but climate is a real risk. In this respect, you can see policies that actually can move the needle. For instance, the European Union just adopted the corporate sustainability due diligence directive, which obliges every large company to have a net-zero transition plan. That can be powerful.
As I alluded to in my opening statements, I do believe that the move towards disclosure regulation is welcome as long as sustainable disclosures are aligned on financial disclosures. For instance, companies cannot trumpet net-zero commitments without actually reflecting them in their financial statements, which I think is analogous to what Professor Damodaran was saying.
Another policy that could be useful, for instance, is EU banking policy. EU banking regulation has recently been amended to require that banking directors have sufficient expertise on climate risks and climate change as well as a transition plan, etc. Again, that can also be important and impactful.
:
I would share some of the frustration that has been expressed about voluntary programs that are asking people to do the right thing because it's the right thing to do. What companies respond to is profit, motivation and regulations—obeying the rules.
What we really need to do is have rules that shape the financial terrain in a way that we are actually investing in climate solutions. Is there a cost to taking action on climate change? Yes. Is there a cost to not taking action on climate change? Absolutely.
There are a variety of things that can be done under existing regulations. Some of my colleagues have put forward detailed proposals on ways in which requiring net-zero transition plans or climate transition plans for companies would help shape that. We have also suggested things like changing capital risk requirements and imposing double materiality.
There are a variety of tools that can be used by governments. We have examples in the EU and other places that we can look to, but we really have to align where the money is going with where we need to be to protect people. That's not happening right now, because of an obsession with short-term interests. It's government's job to take that longer-term perspective and help shape the field so that we're all pulling in the same direction, rather than pouring all of the money over here into things that are going to make the problem worse—fossil fuels—while the government is trying to offset it with its own spending.
We actually need to align private and public finance and things like the climate-aligned finance act or the climate transition plans that have been proposed. These are tools that can be used to bring those two together, move in the same direction and accelerate the energy transition that's going to protect us from those climate risks, and also protect our economy from what Professor de Arriba-Sellier said were the transition risks, one of which is the risk of falling oil demand in the world when oil's our number one export. If we don't surf that wave properly, we will get crushed.
Thank you.
:
No, it isn't, for two reasons.
First, it applies solely to voluntary disclosures. If a company voluntarily decides to state that it's green or sustainable or that it meets environmental, social and governance criteria, or whatever, it will have to prove that. However, if a business decides to report nothing, then it provides no information that the market can rely on to make a decision. Consequently, that doesn't solve the information asymmetry problem.
Second, companies are required to provide evidence whenever they state something, such as when they claim that they're green, but they aren't required to disclose evidence to that effect. Imagine if my financial adviser told me tomorrow morning to invest in a product that met environmental, social and governance criteria, or in a sustainable product, and assured me I could do so confidently because those businesses were required under the act to prove that the products in question were green. If I asked him to show me proof of that, he might tell me he couldn't do it.
:
Yes, the devil is always in the details.
As Mr. Damodaran said, if you get to make up your own definition of what's green, you're going to get a million definitions. With the taxonomy, it's important to remember that this is not like saying that you're not allowed to invest in fossil fuels, ever; it's saying that if you're going to declare that something is green, then we should have a high bar for that. It's pretty clear that there's a strong debate within government and outside government over whether or not to include fossil fuels in that.
The Canadian Association of Petroleum Producers argues that natural gas exports should be qualified as green because you might reduce coal emissions somewhere else. What we're saying is to keep that bar high and have it aligned with the 1.5° science-based opinion. The IEA and the UN have both put out guidelines on how to manifest that. The UN high-level expert group on the net-zero commitments of non-state entities has an Excel sheet that you can download. It's a checklist of things that are compatible and things that are not.
A lot of that work has been done, but there's a political push to get fossil fuels in because fossil fuels are a very powerful force in our politics. If you're going to be science-based, you should keep that out. The government has punted this to a committee, so a lot will depend on the makeup of that committee.
We're looking to that, but I would say that I would rather have no taxonomy than a bad one.
:
There is a case I know very well, the EU taxonomy. It was supposed to be the early mover, the gold standard of taxonomies, as they said at the time. The inclusion of gas in taxonomy, which has been political, and was necessitated perhaps in the wake of the Russian invasion of Ukraine, led to this taxonomy losing a lot of credibility in the investment community.
It's very important that if you set a taxonomy, you respect a certain number of criteria. The EU taxonomy has some criteria that should be included, and maybe they should be respected a bit more. There is challenge before courts in the EU, for instance, and this taxonomy has set criteria that are science-based, including that there is a “do no significant harm” principle—i.e., any of the activities that are covered by the taxonomy cannot lead to significant harm to environmental objectives like climate change mitigation. Inclusion of fossil fuels will, of course, lead to significant harm to climate-change mitigation, and there's also the precautionary principle.
I'm not sure whether the precautionary principle is a principle under Canadian law. I know that in many jurisdictions and in international law, it's a principle of law. It is an important principle, because there are some things that we can't really foresee. For instance, the effect of methane flaring has been documented for years, but it's come to light relatively recently how devastating it was in terms of CO2 equivalence.
It's important that these three principles—being science-based, doing no significant harm and adhering to the precautionary principle—be respected in a future Canadian taxonomy, if taxonomy varies.
:
Thank you very much, Mr. Chair.
Welcome to the witnesses.
The committee has been fortunate to hear from economists from the OECD and Canada as well, all of whom have said that Canada should definitely take action on sustainable finance because it's a matter of international competitiveness. We're seeing foreign capital flowing into countries that have adopted the taxonomy and mandatory disclosure for large businesses.
I would really like us to discuss in greater depth the importance of the announcement that the government made in October, on October 9 to be more precise, on the two major pillars of green finance. There's obviously the taxonomy of green finance, transition finance and mandatory disclosure.
Mr. de Arriba‑Sellier, I'll go to you first. Would you please describe for us the benefits of such a taxonomy in Europe for the economies of those countries and the competitiveness of European companies seeking to attract foreign capital?
I think that taxonomies, in both Europe and elsewhere, give companies a sense of the direction public policies are taking. The taxonomies themselves are a support, particularly for public policies. In Europe, other regulations on the disclosure of information, the duty of care and the obligations of banks and so on have been developed based on a taxonomy.
In the case of developing countries such as China and Brazil, which have adopted taxonomies too, we also see monetary policies, credit policies, economic investment policies and fiscal policies that could even support the taxonomy, and that could indeed be conducive to a positive investment dynamic. Ultimately, it could support both the fight against climate change and economic development as well.
:
Yes, Canadian banks and pension funds are major investors in fossil fuels.
I think the risk is twofold. There's the risk that involves making climate change worse and the physical impacts that come with that. We've seen that risk when we look at all the destroyed infrastructure from these more extreme storms, etc.
Then there is what we call the transition risk. If we keep making the heavy investments in Canada and abroad with Canadian banks, insurers, etc., in fossil fuels, and the world successfully makes a turn away from fossil fuels—which is, for instance, what the IEA is going to do—even with no new climate policies, we'll see a reduction in the market for fossil fuels and we'll be left with a bunch of white elephants.
We're going to end up paying the cost for that. We're going to end up having to clean up all of the old wells on the public's dime, because the companies will go bankrupt. They're already very good at transferring those costs to us. That's a huge risk to the rest of us as well.
:
Thank you very much, Mr. Chair.
Thank you very much to the witnesses for this relevant information.
Mr. Beaulieu, you've spoken at length, and rightly so, about greenwashing. Some people say they have good intentions or project a good image, but that ultimately isn't really true of certain companies and individuals.
I'd like you to tell us about the approach that many companies, organizations and even individuals have adopted in this matter. They take planes, travel, attend conferences around the world, in deserts, and, when they come home, they buy trees or carbon credits to ease their conscience.
I'd like to hear your opinion of greenwashing in those situations.
:
That's a very interesting question because we increasingly see greenwashing around us. I recently noticed it at a truckers' festival, where all those GHG emissions were offset and people claimed to be eco-friendly. You can be glad they offset their GHG emissions, but, in the end, it was still a major polluting event that shouldn't have been considered eco-friendly or sustainable.
You can introduce very specific measures to restrict both the cases in which people can use these credits and the kinds of allegations that can be made when using the credits. For example, minimum conditions for distributing or using credits can be defined. You can state all the minimum criteria that must be met to be certain that credits are of high quality. You can also restrict the circumstances in which they may be used. For example, should we allow an airline to offer carbon-neutral flights? Perhaps we shouldn't allow that. Perhaps we should permit the use of credits as a good measure by ensuring that we clearly explain that credits don't make flights carbon neutral, that aviation is still a polluting industry and that a transition is necessary. The use of carbon credits should be clearly delineated.
What California has done is very interesting. It has passed legislation requiring all businesses that distribute or use carbon credits or offsets to disclose information on their quality. This then provides the government with information on criteria and quality, and they determine the purposes for which those credits can be used. Canada should do the same thing by amending the Competition Act, for example. Amendments have recently been made to that act and others should follow. We should also make regulations or pass a separate act, as California has done, to determine clearly how those credits are to be used.
I agree that significant risks are involved in the use of carbon credits and offsets. Everyone around this table seems to feel that credits can present quite significant greenwashing risks. We should clearly determine how they are to be used.
:
It's not the case. A taxonomy just creates a label.
If you want to issue a green bond, everybody knows what should be in a green bond. If you want to issue a transition bond, everybody knows what's in a transition bond. You might still want to issue a regular bond or a brown bond—call it whatever you like—but at least for these specific criteria, we know what it means. Everybody agrees on the criteria that must be met. This allows us to avoid this “disclosure diarrhea” that Mr. Damodaran mentioned.
This way, we're sure we're all playing by the same rules. We know what the words mean. If some people then want to invest in green, good for them. If some people want to keep traditional investment strategies, well, we won't say, “Good for them”, but they still have the opportunity to do it.
Anyway, it would be provincial regulators regulating these bonds at the end of the day. The taxonomy cannot achieve that in its current framework.
:
I think it is in principle, but it is not that simple. I was actually going to discuss this at the end of the meeting, but I will take the opportunity to do it now.
We could invite the ministers to both meetings next week, but we can't be sure they will be able to accept. If they can't, we will have to postpone the next meetings on finance so we can try to find dates when the ministers can be here, or we will have to invite only their officials.
That is a whole discussion. I think that if we want to finish the study on the financial system next week, Mr. van Koeverden will have to agree that we not start the pre‑study before the week of November 18, given that the week of November 11 is a break week. So we would have to agree that we will try our luck with the two ministers for next week. If that doesn't work, we will forget about it or invite the officials.
Ms. Collins, I know you want to speak to the motion, but the discussion is about the amendment.
Mr. van Koeverden, would you accept a friendly amendment so we can finish the study on finance next week?
:
Thank you for the invitation to appear before you today, Mr. Chair.
I would like to start with a brief description of my background, which will help to understand my testimony better.
I spent five years working at the OECD, the Organisation for Economic Co‑operation and Development, and then almost 15 years at the Department of Finance in Ottawa. I also held the position of chief economist at Industry Canada. So I can say that I have seen and observed how the system works from the inside, since I have personally contributed to making the system work, the system in which private short-term objectives take precedence over longer-term objectives that focus on the common good, such as climate or population aging. I have gained a bit of perspective since then and I have concluded that public policies that are more impactful, when it comes to economic policies or finance, are necessary. I will come back to this a little later.
From a more personal perspective, I am teaching students in their twenties this fall, four times a week, most of them suffering from eco‑anxiety because of the growing harmful effects of climate change. Last week, I gave a presentation to the students at a CEGEP, young people about 17 years old, who have virtually no voice on this in our institutions. They want to know why too few people in previous generations, including my own, mobilized and did something about it. The baby boomers owe young people an enormous debt. They privatized wealth and socialized costs.
In a more personal context, I know the committee is also aware of the fact that greenhouse gases rose by 1.3% in 2023. We went down the wrong path, and this is making things even worse, in my opinion, based on what I said earlier.
The other thing I would also like to say is that I think the countdown starts in 2030, and that is the most important thing. We have to change our public policies and get on the right course in the fight against climate change by 2030. This is extremely important. The IPCC, the Intergovernmental Panel on Climate Change, keeps telling us this and hammering it into us. Personally, I always highlight this aspect in my public speaking and in my climate research.
Anyone with an understanding of economics or finance knows that economics and finance are closely related. One person's savings fuel another person's investments. And yet sustainable development and sustainable finance are nothing but oxymorons for the time being. Maximizing returns in the short term is actually and quite simply not compatible with a climate strategy. This has been clearly demonstrated in the work done by Alain Grandjean, Julien Lefournier or Gaël Giraud in Europe, for example, on green finance.
In a free market, we can compare a company adopting environmental rules that are stricter than other companies' to handicapping itself when it comes to competitiveness and costs. Given the existing rules, that would be fatal.
The government therefore has to do what it is here to do: secure the common good by legislating. Countries that are ahead of the curve in this regard are going to protect what they have gained. That is why, for example, Europe has deployed the first phase of its carbon tax at the borders, to correct for discrepancies in regulatory stringency. The United Kingdom will be doing this in 2027. As you know, this means imposing tariffs on carbon, which means on carbon-intensive imported goods.
The Government of Canada has put a robust carbon pricing scheme in place in addition to an ambitious path that is set to reach $170 per tonne of CO2 in 2030. That price is lower than what most economic cost analysis models show. It should be much higher. Given that Canada already has a robust carbon pricing system, Canadian businesses might not incur the tariff adjustment that will be implemented in the European Union. This would give our businesses an advantage over competitors who do not already have a carbon pricing system similar to the European Union's.
The other thing I want to say was raised by the previous panel—
:
Great. Thank you very much for the invitation for me to contribute to this very important topic.
From the outset, I should say that I'm a strong ESG advocate. I understand the importance of taking ESG factors into account for both society and long-term financial value. However, my views on this topic will be somewhat more nuanced. I hope these nuances will be of help to this committee.
The text of the motion refers to alignment with the Paris Agreement and promoting “the reduction of inherent risks”. It's important to be clear on what these risks are. These could be risks to society, which we often call impact, or risks to the portfolio of a financial institution, which is often called dependency. Obviously, in many cases these overlap. A lot of my own research is on the overlap between what's good for society and what's good for shareholders, but they don't always overlap, and it's important to be mindful of these trade-offs. For example, if there's limited government action, then investing in fossil fuels poses limited risk to your portfolio. In fact, boycotting fossil fuels could lead to more risk, even though this is a risk to wider society.
I also recognize that it mentions alignment with the Paris Agreement. However, there is evidence suggesting that we might be going for 2.7°C rather than 1.5°C. It's not actually clear whether it's prudent to have a portfolio that will do well in a 1.5°C scenario. The question then is, what should the objective be? Should we only take into account risks to the portfolio, or do we think financial institutions have a moral or societal obligation to take into account risks to wider society? It's not clear.
It's clearly not for me to say what the objective should be, but let me give some guidance as to what might be the implications of different objectives.
In terms of banks—part of the motion mentions “banking institutions”—they do need to be solvent for their depositors and also for wider society. Otherwise, losses could be leading to some pain in bailing out the banks. It may well be that the investment lending decisions that are good for climate change might not actually be good for the portfolio. If they were good for the portfolio, then, as Professor Damodaran was saying in the early session, why do we need regulation to encourage banks to take this into account? They would do this anyway. As well, why climate risk and why not the risk of a cyber-attack or a pandemic? There are lots of other material risks for banks.
For pension funds, which are also mentioned, again it's not clear what the objective should be. The objective might be to maximize retirement income for pensioners. Now, for me as a pensioner, I actually don't have that as my objective. I invest in climate-conscious funds, but I can choose to sacrifice my return. I am able to afford it. Other people might not be able to, so it may be that their objectives are purely financial.
Now, let's say we do care about impact and that we do want the objective to be more than just financial returns but impact on wider society. It's not clear how we achieve this. One view is divestment. Indeed, net-zero alignment, or Paris alignment, often refers to a portfolio that divests fossil fuels, but there's a lot of academic evidence suggesting that divestment, particularly in equity markets, has limited impact. If you sell and somebody else buys, given the fluidity and the liquidity of capital markets, the actual cost of capital impact is pretty small.
Another view is engagement. Engagement many times can be micromanagement. It might be that investors who could be uninformed are imposing more one-size-fits-all rules on companies, whereas a company might be better placed to understand the risks that are most material to it.
Finally, let's say we do care about the impact on wider society. The impact on wider society is more than just the impact on the environment. I agree again with Professor Damodaran about the concerns of black and white thinking.
I just got back from the World Economic Forum in Dubai, where we were facing the just transition. One woman from Africa got up and said that in Africa, 600 million people do not have access to electricity. We were talking about a just transition when 600 million of her citizens have nothing to transition from. Another person referred to a doctor in Sierra Leone. There was a power cut, and babies died in a neonatal unit. These are issues that maybe we in the west don't acknowledge. Given that the committee is in Canada, maybe the focus is on Canada, but we often view the west versus Africa in black and white terms. There might be people in Canada who have energy poverty.
Now, this is absolutely not to say that climate change is not a serious issue; it is absolutely a serious issue. I've devoted a large part of my career to addressing this issue, but I'm hopefully highlighting some of the concerns and some of the difficult trade-offs that might come about from pursuing this.
:
Thank you for inviting the Canadian Bankers Association to appear this afternoon to participate in the committee study of the environment and climate impacts related to the Canadian financial system.
My name is Bryan Radeczy, and I am director of financial stability with the CBA. I'm joined today by Darren Hannah, senior vice president, financial stability and banking policy.
The CBA represents more than 60 domestic and foreign banks employing over 280,000 Canadians who help drive Canada's economic growth and prosperity. We advocate public policies that contribute to a sound, thriving banking system to ensure that Canadians can succeed in their financial goals.
Climate change is a critical issue of our time, and banks in Canada are committed to doing their part to address it. Banks understand that the financial sector is central to securing an orderly transition to a low-carbon economy while also ensuring the continued resilience of our country's financial system. This includes working with clients across industries to help them decarbonize and pursue energy transition opportunities.
By financing the climate transition, banks are helping Canada meet its net-zero ambitions while also helping society meet interim energy demands in a volatile global context. Our six largest banks participated on the federal government's sustainable finance action council. We acknowledge the updates provided by the government earlier this month on plans for developing a Canadian taxonomy, and we look forward to further progress in this area.
A taxonomy should provide greater clarity and certainty for businesses investing in new technologies and projects for the energy transition and for the financial institutions supporting them. Notably, even in the absence of a Canadian taxonomy, our largest banks have made commitments in the hundreds of billions of dollars. This is reinforced by the commitments made by our six largest Canadian banks as members of the Net-Zero Banking Alliance.
Our banks prepare and issue climate and sustainability reports on an annual basis, with details on their missions, targets and progress towards achieving targets, along with information on their sustainable finance activities. Our banks are also engaged with regulators and standard setters, both domestically and internationally.
Following the release of the Basel Committee on Banking Supervision's climate principles in June of 2022, our Canadian banking regulator, the Office of the Superintendent of Financial Institutions, finalized its guideline B-15, on climate risk management, in March 2023. OSFI went a step further than the Basel committee at the time by including a set of minimum mandatory climate-related financial disclosure expectations spanning governance, strategy, risk management, and metrics and targets.
These disclosures are based on the Financial Stability Board's task force on climate-related financial disclosures, which our largest banks have been voluntarily implementing for a number of years. Our largest banks are now mandated to meet OSFI's disclosure expectations starting as of their 2024 fiscal year-end, with our small and medium-sized banks being similarly obligated starting as of their 2025 fiscal year-ends.
At a broader level, the International Sustainability Standards Board set about developing standards that would create a global baseline of sustainability disclosures. The ISSB built on the work of the task force on climate-related financial disclosures and published their inaugural standards in June 2023, including a climate-related disclosure standard. OSFI had already incorporated this standard into guideline B-15 in March of this year. Importantly, the ISSB standards are intended for broader application across industry systems, should they be adopted by national jurisdictions.
While OSFI has already taken steps in this regard, it is also notable that a new Canadian Sustainability Standards Board was established and consulted earlier this year on their inaugural standards that closely mirror the ISSB standards. We look forward to the CSSB finalizing its standards, which we hope will be adopted by other regulators and sectors across Canada.
To this end, we also acknowledge the government's interest in mandating climate-related financial disclosures for large federally incorporated private companies and in considering ways for small and medium-sized businesses to voluntarily release climate disclosures as well.
Investors and analysts are looking for harmonized international disclosures that facilitate comparability. We are encouraged that Canadian regulators and standard setters are engaging with their peers internationally and are already in the process of adopting global baseline standards in Canada.
A Canadian taxonomy will also be important in incentivizing greater levels of sustainable finance. Governments, regulators, standard setters, banks and the private sector all have a role to play in taking concrete actions that support the energy transition in Canada. We believe it is important to recognize the progress that has been made to date, but we acknowledge that more work remains to be done.
Thank you, and we look forward to your questions.
:
I think it's to forget about this ESG label.
Here's the problem with ESG: It bundles everything under the ESG umbrella in the same way. However, some of these things overlap and some of them don't, so it's important to consider them separately.
What is one thing where the impact on society comes back and benefits the company's profits? It's human capital. Some of my early work is on how treating your worker well ultimately leads to greater profits down the line. That is something I call an internality. Even in the absence of government regulation, a company bears the consequences of its human capital investments.
Something like climate change is an externality through which you benefit wider society and might benefit other companies, but if you're a fossil fuel company, it is costly to reduce production significantly.
Those are the cases in which, if you are to tell a company to produce less or do this, it may well be at the expense of financial returns, and remember that financial returns don't just go to nameless, faceless capitalists: They could go to pensioners and they could go to depositors, if you're a bank, so we do need to consider financial returns, and when there are trade-offs, we need to acknowledge them rather than think that everything is going to be a win-win.
:
I think it would be extremely difficult to come up with a taxonomy. I'm not sure who is the supreme being to decide which things are material and which are not, and which ones to weight and which ones to not.
This is how ESG has become such a problem. Certain industries—let's say defence—were said to be bad, and now they're said to be good. This is because our weight on the different criteria will change over time.
Most recently, I've joined the sustainability advisory council of Novo Nordisk, which has come up with these weight-loss drugs. We've decided to send some of these drugs to developing countries, even though this leads to less revenue for us. Now, that is bad for our carbon footprint, because it means shipping these drugs to developing countries, yet there's a huge benefit in terms of reducing obesity. Actually, if you reduce obesity, then you can reduce climate change down the line, because if people don't develop diabetes, then they don't need to go to a hospital for dialysis three times a week.
Any taxonomy is typically going to ignore many of these criteria. It's really difficult to know where the bright line is to say what's good or what's bad. I would not like to be the regulator that claims that it has all of the knowledge to rule on these complicated issues.
:
It would be, and then I'd have a lot of power to decide which companies succeed and which do not.
In the earlier session, somebody said, “Well, it's a taxonomy. It's just a description. It's value-neutral.” It is not value-neutral.
I understand that the EU taxonomy in articles 6, 8 and 9 was supposed to just be descriptive in using blue, green and red—you want to invest in blue, green and red funds. This is not how things have gone. If you're an article 9 fund, you're much more likely to get capital than if you're an article 8 fund, so if we classify certain activities as green, those will get more capital than the ones that don't have that classification, and it may well be that companies will spend a lot of effort in ticking the box and getting the classification rather than doing the right thing.
Actually, in some of my own research on a different topic—diversity, equity and inclusion—what I find is that when demographic diversity, which often comes into taxonomies, has no relation to true equity and inclusion within the workforce—to inclusiveness in corporate culture—we can focus on the things that hit the taxonomy without actually creating value for wider society.
Mr. Delorme, I smiled when you talked about your career at the Department of Finance and at the OECD, the Organisation for Economic Co‑operation and Development, since it is very similar to my own.
The committee has had the pleasure of hearing from Mr. Miller, a representative of the OECD who spoke to us about the progress made by the OECD, and from Mr. Usher, from the United Nations.
If I may, I would like to address the issue of the competitiveness of the Canadian economy on the international stage. I think this is an important issue. My Conservative colleagues often talk about abandoning the carbon pricing system, which would, as you said, expose us to European tariffs on our exports. There are others who question sustainable finance, and this could make Canada less attractive to foreign investors.
Can you tell us more about the possible consequences of doing nothing on these two subjects?
:
The motivation of big corporations and the banking sector—and again, this makes sense—is not to address climate change, or, in any event, that is not their main objective. Nor are they addressing homelessness. So private enterprise has to be made to bite the bullet and focus on a much more distant horizon.
I was not able to say this earlier, but I will be very brief. We did a study on the ESG criteria last year, and we found, first of all, that there are inadequate ESG criteria in all companies. There is very high potential for greenwashing. And that is the economist speaking. Are we really able to measure progress on the environmental, social and governance levels? Mr. Edmans talked about this in his testimony earlier, that we have to combine these three points of the triangle.
Second, are we able to monitor progress quantitatively? When we apply this grid, we see that for the ordinary person, it is impossible, with what we have right now, in the financial reports, to really give big corporations or the banking sector their assurances that ESG criteria are robust criteria. That is extremely important, because we talk about ESG criteria a lot. We wrap ourselves up in these criteria, but they are not robust enough yet. Mr. Edmans talked about this earlier as well.
It's not clear that regulation would address the issue.
You're absolutely right; that's what we found as the current status quo. Asset managers are not going to be taking into account issues they don't believe are material.
However, what can lead them to doing this are constraints from their own clients. If there's a fund mandate saying that you have to invest in sector X and you're not allowed to invest in sector Y, that is something that absolutely can move them to investing in a different way, but that will come from the clients of those funds, not necessarily from regulation.
What might be the issue of having regulation do it is it will go back to the previous discussion of taxonomies. It's very difficult to decide what is good or what is not good. Maybe a client can decide for themselves, but I'd be rather nervous about a regulator deciding on behalf of all clients.
That has happened, actually, for my industry of education. A while ago, you had “no child left behind” in the U.S., where they said, “Let's try to have a taxonomy and let's measure which schools are good and which ones are bad and allocate capital to the well-performing schools and keep it away from the poorly performing schools,” just like the idea of allocating capital towards the transition, but this then led to many schools teaching to the test.
When you have such a complex issue and there are so many moving parts, it is quite difficult for regulators to have a taxonomy that takes these all into account. It's incumbent on the clients to express their wishes to fund mandates in order to guide investors on where they should be allocating their capital.
My question is for Mr. Hannah, from the Canadian Bankers Association.
A little earlier, today at noon, in this committee, Julien Beaulieu, a lawyer from the Centre québécois du droit de l'environnement, questioned the proposal for voluntary reporting. He believed that mandatory reporting would be preferable so it would be possible to determine exactly what efforts were being made from one company to another and whether the targets were being met.
Just now, however, someone said that voluntary reporting was just as effective, and pointed out that people were more committed when they were acting voluntarily rather than being forced to do it.
I would like to know what you think about voluntary reporting of measures taken to reduce emissions and to invest in green businesses, which do not prevent anyone from investing in other businesses.
Thank you to all the witnesses for being here.
Professor Edmans, I have a question for you.
You have been repeating, often in response to questions, the need to leave it up to the consumer or client to make choices about where they invest. To that end, a taxonomy or a reporting and disclosure requirement provides information to consumers and investors, as well as some consistency and simplicity, because not all investors can read through the reports and figure this all out.
If people are going to make true and clear choices about what they want to invest in, do you believe this kind of transparency disclosure or taxonomy, which simplifies how an investor can look at these companies' investments, is necessary?