February 28, 2023
Japanese Bankers Association
JBA comments on the TPT Disclosure Framework and the TPT Implementation Guidance
Questions

Comments

The TPT Framework includes a definition of a transition plan. How would you describeb) Overall, the definition provides a sound basis for transition planning, but there arethis definition?

relevant omissions.

Definitiona) The definition is complete and provides a sound basis for transition planning.
b) Overall, the definition provides a sound basis for transition planning, but there are
relevant omissions.
c) The definition does not provide a sound basis for transition planning.
d) Don’t knowThe definition does not address the need both for action against a timeline andensuring that a company’s business model is consistent with the transition plan.
Ensuring that a company is held to account against both time-bound targets andbusiness transformation is an important measure for reaching net-zero by 2050.

If b) or c): Please explain why you gave that answerThe definition should address the need for a just transition to Net Zero, ensuringthat the benefits and costs of a transition to a green economy are shared fairly
across society.

1Questions

Comments

Where & how to disclose: Preparer Feedback
Not sure

In both the TPT Framework and the Implementation Guidance, we recommend that
entities:
a. Publish a standalone transition plan,b. Update the standalone transition plan at least every three years or sooner where
there have been substantive changes, andc. Report progress against the plan and all other content in the plan that is deemed tobe material to investors, consistent with corporate reporting norms, as part of annual
TCFD- or ISSB-aligned disclosures in general purpose financial reporting

If your entity has prepared a transition plan, or is planning to prepare a transition plan:
to what extent to you agree with the recommendation to:a. Publish a standalone transition plano Strongly agreeo Agreeo Neither agree nor disagreeo Disagreeo Not sure2

Questions

CommentsGiven that the disclosure standards by the ISSB or by each jurisdiction such as
the U.S. SEC will require preparers to disclose transition plans, requiring the
publication of a standalone transition plan may be a burden for preparers. In

Please explain your selection for a, including by providing relevant information on theorder to avoid fragmentation, we would like to suggest that the framework allow

costs and benefits of preparing a standalone plan

preparers to disclose their transition plan as an integrated part of the strategicpillar in the overall sustainability reporting process based on the ISSB framework
or TCFD.

b. Update the standalone transition plan at least every three years

Agreeo Strongly agreeo Agreeo Neither agree nor disagreeo Disagreeo Not sure
Please explain your selection for b, including by providing relevant information on thecosts and benefits of periodically updating the standalone plan3

Questions

Comments

c. Report progress against the plan and all other material content,

Agreeconsistent with corporate reporting norms, as part of annual TCFD- or ISSBaligned disclosureso Strongly agreeo Agreeo Neither agree nor disagreeo Disagreeo Not sure-

Please explain your selection for c, including by providing relevant information on thecosts and benefits of extracting material information for inclusion in general purpose
financial reporting
Where & how to disclose: User Feedback

HelpfulIn both the TPT Framework and the Implementation Guidance, we recommend that
entities:
a. Publish a standalone transition plan,b. Update the standalone transition plan at least every three years or sooner where4Questions

Comments

there have been substantive changes, andc. Report progress against the plan and all other content in the plan that is deemed tobe material to investors, consistent with corporate reporting norms, as part of annual
TCFD- or ISSB-aligned disclosures in general purpose financial reporting.

If your entity is a user of transition plans, how helpful do you find theserecommendations?

a. Publish a standalone transition plano Very helpfulo Helpfulo Neither helpful nor unhelpfulo Very unhelpfulo Not sure5Questions

Comments

We agree that publishing a standalone transition plan is helpful and thatstandardisation of these is useful from both a user’s and a preparer’s perspective.
It is also important however that there is clarity on which level of consolidation atransition plan is required. From the perspective of a third-country headquartered

Please explain your selection for a, including by providing relevant information on thegroup, being able to publish a single transition plan for the group at the level ofdrawbacks and benefits of using a standalone plan

the parent entity would make for more accurate disclosures.
More information should be provided on the rationale for a standalone reportalongside the annual report and if this report can be combined with other reports
of a risk or sustainability nature, which could allow for more harmonisation withother requirements globally.

Helpfulb. Update the standalone transition plan at least every three years
o Very helpfulo Helpfulo Neither helpful nor unhelpfulo Very unhelpfulo Not sure6

Questions

CommentsThree years is a sensible cycle, which balances the need for regular updates on
actions against the targets in the transition plan. But, we also recognise that
updates should be material and that requiring this at more regular intervals could
add additional burdens on resources and fail to show significant progress against
a plan.



Please explain your selection for b, including by providing relevant information on the

Financial institutions are also users of company transition plans, e.g. financial
institutions assess energy company transition plans to judge if companies will be

drawbacks and benefits of using a standalone plan that is periodically updated

an important part of the energy mix in the future, either because companies havea good transition plan and financial institutions expect companies to transition
and make up part of the mix in a low-carbon future, or because companies have
intrinsic advantages that will mean they can provide the remaining fossil energy
in the mix in the future. A standalone transition plan updated every three years
with reported progress would be helpful for completing those assessments.

7

Questions

Comments
Very helpful

c. Report progress against the plan and all other material content,
consistent with corporate reporting norms, as part of annual TCFD- or ISSBaligned disclosureso Very helpfulo Helpfulo Neither helpful nor unhelpfulo Very unhelpfulo Not sure8

Questions

CommentsThe streamlining of corporate reporting is helpful for both the user and the
preparer. It is very helpful to report on progress against transition plans as part of
the annual TCFD- or ISSB- aligned disclosures included in a company’s annual

Please explain your selection for c, including by providing relevant information on thereport. This will ensure that information is displayed consistently in a single

drawbacks and benefits of accessing transition plan related information in generallocation.

purpose financial reporting

Although progress against the transition plan may not be updated annually likeother reporting metrics, publishing the latest progress as part of a company’s
annual report will ensure that this information is easily accessible and reviewed
alongside other relevant financial and non-financial disclosures.

Where & how to disclose: Reporting Norms
a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.

The Implementation Guidance contains guidance on the implications of five key
reporting norms from the TCFD and ISSB for transition plans. If your entity has
prepared a transition plan, or is planning to prepare a transition plan: do you think theguidance provided is useful in supporting effective disclosure and sufficiently detailed?

Reporting Boundaries
a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.
b. The guidance is useful in supporting effective disclosure but lacks sufficient detail.
c. The guidance is not useful in supporting effective disclosure.
d. Don’t know

9Questions

Comments-If b) or c): Please explain why you gave that answer

a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.

Links between climate-related disclosures and financial statements
a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.
b. The guidance is useful in supporting effective disclosure but lacks sufficient detail.
c. The guidance is not useful in supporting effective disclosure.
d. Don’t know-If b) or c): Please explain why you gave that answer
Materialityb. The guidance is useful in supporting effective disclosure but lacks sufficient detail.

a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.
b. The guidance is useful in supporting effective disclosure but lacks sufficient detail.
c. The guidance is not useful in supporting effective disclosure.
d. Don’t knowThe treatment of materiality is a sensible one as it follows accepted practices ingeneral purpose financial reporting. However, more consideration may be neededIf b) or c): Please explain why you gave that answer

around how this interacts with other developing requirements that take a broader
view of materiality.

10Questions

Comments

The materiality assessment is very relevant from the perspective of G-SIBs. What
we read from the UK approach is that the materiality assessment for the purposeof transition planning is effectively derived from our TCFD/ISSB reporting looking
at the financial risk assessment. However, it would be helpful to clarify the criteria
and perimeters for globally operating institutions to perform a materiality
assessment, and that indeed the methodology can be derived from the
ISSB/TCFD reporting framework.

Incorporation of interdependent issues such as social impacts, nature andb. The guidance is useful in supporting effective disclosure but lacks sufficient detail.

adaptationa. The guidance is useful in supporting effective disclosure and is sufficiently detailed.
b. The guidance is useful in supporting effective disclosure but lacks sufficient detail.
c. The guidance is not useful in supporting effective disclosure.
d. Don’t knowIt would be helpful to clarify how best to approach interdependencies in thecontext of the materiality assessment for transition planning, as well as from ageographical level.

If b) or c): Please explain why you gave that answer

With regard to the assessment of nature-related impact and dependencies, wehope that the Guidance will be enhanced with the specific metrics in accordancewith future discussions at the Task Force on Nature-related Financial Disclosures.

11Questions

Comments
a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.

Treatment of Uncertainty
a. The guidance is useful in supporting effective disclosure and is sufficiently detailed.
b. The guidance is useful in supporting effective disclosure but lacks sufficient detail.
c. The guidance is not useful in supporting effective disclosure.
d. Don’t know-If b) or c): Please explain why you gave that answer
The Framework: Overalla) Yes, I agree with the overall framework.
In the TPT Disclosure Framework we set out recommendations for entities to reportagainst five elements and 19 sub-elements of a transition plan. Do you agree with theoverall framework?
Please note that there will be a chance to provide feedback on the disclosure
recommendations for individual sub-elements.

a) Yes, I agree with the overall framework.
b) Yes, I broadly agree with the overall framework, but I have comments orsuggestions.
c) No, I do not agree with the overall framework.

12Questions

Comments-If b) or c): Please explain why you gave that answer
The Framework: Preparer Feedback
1. Foundations

Somewhat difficult
In the TPT Disclosure Framework we provide disclosure recommendations aimed toassist entities to disclose credible, useful, and consistent transition plans.If your entity
has prepared a transition plan, or is planning to prepare a transition plan, pleaseassess the expected level of difficulty of implementing each sub-element:
1.1

Objectives and Priorities

o Very difficulto Somewhat difficulto Not at all difficulto Don't knowPlease explain your selection to 1.1 Objectives and Priorities:

This would be possible for some financial institutions to do, although it would
require additional work for them to develop targets for GHG emissions for theentire book as these currently cover only some sectors. As such, it may be easier

13

Questions

Comments
to develop targets for some sectors than for others. This is dependent on thedata available from clients, which also varies.
Additional administrative work may be needed to update constitutional
documents. However, this is achievable.

1.2 Business model implications

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowIn some financial institutions, a statement of direction about the business model
implications and need to pivot to other sectors is achievable easily. However,more detailed targets around resource allocation and operational and capital
expenditure will be difficult to commit to at this stage and may require more

Please explain your selection to 1.2 Business Model Implications:work. Furthermore, it is right that wider implications such as the naturalenvironment are considered at a broader level, as policy and industry standards
are much less developed than for climate.
2. Implementation Strategy
Somewhat difficult

2.1 Business Planning and Operationso Very difficulto Somewhat difficult

14

Questions

Comments

o Not at all difficulto Don't knowThese recommendations are quite similar to the current business plans offinancial institutions, which include putting in place origination guidelines for new
clients, formalizing engagement with existing clients and setting targets for
specific sectors.

Please explain your selection to 2.1 Business planning and operations:

While detailed targets around GHG emissions are possible and welcome for somefinancial institutions, it is right that climate-related targets and nature-related
statements are separated, recognizing that nature-related financial disclosures areat a much earlier stage.

2.2 Products and Services

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowThe level of difficulty of implementing this sub-element will depend on the
granularity of the disclosure requirement.

Please explain your selection to 2.2 Products and ServicesFor financial institutions, while green-linked products will make up a proportion of
new services offered to clients, many of our transition goals will be delivered uponby encouraging clients to transition their businesses through existing15

Questions

Comments
relationships, as well as targeting our services at new clients and growing thebusiness in other areas.

2.3 Policies and Conditions

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowFor financial institutions, the management of our lending and investment activity
will be crucial. This will involve certain restrictions on lending. While financial
institutions have origination guidelines for certain sectors, including power andenergy, this is not currently the case across all sectors.

Please explain your selection to 2.3 Policies and Conditions

However, for client engagement, policies currently exist to assess client transition
plans and therefore make structured engagement recommendations to help
clients transition in some financial institutions.

Furthermore, work to-date has been targeted at climate-related goals, whereas
policies on other nature-related impacts are at an earlier stage.

Very difficult

2.4 Financial Planningo Very difficulto Somewhat difficult

16

Questions

Comments

o Not at all difficulto Don't knowIt is difficult for financial institutions to currently assess the financial implicationsof their transition plan on the business as this is a new and developing area.
While they will have some assumptions, there is a lack of data in this area andcurrently it would be difficult to disclose this. The expectation is that this would

Please explain your selection to 2.4 Financial Planning:

improve over time as we gather more data.


Therefore, as it is still uncertain to what extent preparers can explain therelationship between financial planning and transition planning, including cash
flow, the final framework should allow flexibility for preparers.

2.5 Sensitivity Analysis

Very difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't know

The UK TPT raises the point of interdependencies (including social, nature andadaptation) at a very high level. We expect this will be an area that most financial

Please explain your selection to 2.5 Sensitivity Analysis

institutions will be struggling with. It is an area not sufficiently covered in thecontext of transition planning and we will need further public sector guidance,17

Questions

Comments
looking at the materiality assessment as well as geographical considerations and
NDCs.


Scenario analysis is in need of further sophistication due to the fact that scenario
analysis methods and data are still developing internationally, especially in light of
the lack of forward-looking information and data. In this context, Sensitivity
Analysis, which is a further stage of scenario analysis, is considered to be asdifficult as scenario analysis.

Some financial institutions currently undergo climate risk stress testing exercisesthat look at the resilience of their clients and their own portfolio under various
policy scenarios, and therefore the possible financial impact. This is not currently
embedded in a transition plan, but it may be possible that it can be informed bythis. However, further work would be needed to explore how.

3. Engagement Strategy
3.1 Engagement with Value Chain

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowPlease explain your selection to 3.1 Engagement with Value Chain:

It would be possible for some financial institutions to disclose engagement withsome parts of their value chain, but for other areas it would be difficult to18

Questions

Comments
quantify the impact that this has as there are many interdependencies notcontrolled by the financial institution. It may be possible in the future, but it iscurrently too early to quantify the impact this will have across the whole value
chain.

3.2 Engagement with Industry

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowThis is sensible and it should be possible to disclose details of memberships ofindustry bodies and our general involvement in them. However, it may be difficult
to disclose all details of engagements with industry representatives and bodies, as
this would be very extensive and onerous to report. An overview of memberships

Please explain your selection to 3.2 Engagement with Industry:and regular engagements should be possible. However, while internal policies
would not contradict any of the stated aims in element 1: Foundations, it would
be incumbent on the industry bodies themselves to ensure that their policies are
consistent with this element.
-

Where relevant, how would you suggest we change the disclosure recommendation?

19

Questions

Comments

3.3 Engagement with Government, Public Sector and Civil Society

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowAs above, it would be possible for some financial institutions to disclose theirgeneral approach and details of regular engagements. However, many of theseengagements are ad hoc and as such would be difficult to disclose.

Please explain your selection to 3.3 Engagement with Government, Public Sector and

Civil Society

We support the aims of the disclosure framework. Any engagement with publicbodies will ensure that future regulatory disclosures and climate-related
regulatory policy is both actionable and consistent with the aims of the Paris
Agreement.

4. Metrics and Targets
Somewhat difficult
4.1 Governance, Business and Operational Metrics and Targets
o Very difficulto Somewhat difficulto Not at all difficulto Don't know

20Questions

Comments

Some financial institutions have climate-related operational targets. Therefore,
disclosure recommendations would be sensible. Their climate-related operational

Please explain your selection to 4.1 Governance, Business and Operational Metrics andtargets include measuring the percentage of clients assessed for climate risk,

Targets

percentage of clients assessed as high climate risk, and the percentage of ourportfolio invested in carbon-related assets, as well as the number of hours ofsustainability training completed.

4.2 Financial Metrics and Targets

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't know
Likewise for climate-related financial metrics, these recommendations seemsensible. However, we are still in the early stage of setting medium and interim

Please explain your selection to 4.2 Financial Metrics and Targets

targets and need more discussion and convergence on the metric used to assess
progress towards reaching the target.
Somewhat difficult

4.3 GHG emissions Metrics and Targets
o Very difficulto Somewhat difficult

21

Questions

Comments

o Not at all difficulto Don't knowSome financial institutions have GHG targets, so would be able to disclose GHG
targets as part of their transition plan. However, this would be difficult to disclosein line with the disclosure recommendations in the TPT draft. The
recommendations for disclosure of GHGs are exhaustive, with information
requested across scopes, scope categories and absolute vs intensity. Although the
TPT draft is written to be sector-agnostic, this could be particularly difficult for
financial institutions. Rather than broad catch-all requirements, we would

Please explain your selection to 4.3 GHG emissions Metrics and Targets:recommend following best-practice guidance for particular sectors (e.g. banks set
GHG targets in line with NZBA guidance).


The ISSB will include the Scope 3 GHG emissions in the disclosure requirements,
but will provide relief in disclosing the Scope 3 GHG emissions. To be consistent,
we would appreciate it if the framework would include relief measures such as atransition period and ‘safe harbour’ provisions.

Very difficult

4.4. Carbon Creditso Very difficulto Somewhat difficulto Not at all difficulto Don't know

22Questions

Comments

It is currently very difficult for financial institutions to disclose their intended useof carbon credits as an institution to achieve priorities and objectives. This
includes both the indirect effect of providing carbon credit services to clients andPlease explain your selection to 4.4. Carbon Credits

the effect of this on their transition plan. It may be possible that financial
institutions will use carbon credits as an institution in the future, but this is not
currently the case.

5. Governance
5.1 Board Oversight and Reporting

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowIn some financial institutions, there is currently Board reporting on various
aspects of their sustainability strategy, and this is becoming increasingly
quantitative. However, we are still in the early stage of incorporating the review

Please explain your selection to 5.1 Board Oversight and Reporting:and monitoring process for transition plans into the Board Oversight andReporting framework.
Somewhat difficult

5.2 Roles, Responsibility and Accountabilityo Very difficult

23

Questions

Commentso Somewhat difficulto Not at all difficulto Don't knowPlease explain your selection to 5.2 Roles, Responsibility and Accountability:

In some financial institutions, this is already a feature of current internal planningand would be relatively easy to disclose.

5.3 Culture

Somewhat difficulto Very difficulto Somewhat difficulto Not at all difficulto Don't knowIn some financial institutions, this would be relatively straightforward – they arefocusing significant attention and resources on culture initiatives and much of thisis in the ESG space. They have a clear purpose, mission and value statements to

Please explain your selection to 5.3 Culture:

support their goals and would be able to evidence initiatives to this effect.
However, we are still in the early stage of incorporating transition plans into ourculture.
Somewhat difficult

5.4 Incentives and Remunerationo Very difficulto Somewhat difficult

24

Questions

Comments

o Not at all difficulto Don't knowIn some financial institutions, while departmental targets relating to sustainabilitylinked business are being incorporated, implementing and disclosing individual

Please explain your selection to 5.4 Incentives and Remuneration:

executive remuneration related to transition plan indicators would be difficult.
Further consideration will also be needed for market expectations and evaluationof the effectiveness of these targets.
Somewhat difficult

5.5 Skills, Competencies and Trainingo Very difficulto Somewhat difficulto Not at all difficulto Don't knowTraining is particularly important for ensuring that employees can deliver on anorganisation’s transition plan, particularly senior leaders at board level. It would
be interesting to see how an organisation is delivering this training. However, weare still in the early stage of implementing such training for transition plans.

Please explain your selection to 5.5 Skills, Competencies and Training:In some financial institutions, they have a dedicated role to provide this forcolleagues, with a clear plan and objectives. The Guidance could include astronger reference to the training needs for the specialist staff who are going to25

Questions

Comments
be more hands on in drafting, delivering and reporting on our transition plan
commitments in their day-to-day roles.

The Framework: User Feedback
1. Foundations
In the TPT Disclosure Framework we provide disclosure recommendations aimed to

Very usefulassist entities to disclose credible, useful, and consistent transition plans.
Please assess the extent to which you expect disclosures in line with ourrecommendations to be useful for informing your decisions:

1.1 Objectives and Priorities
o Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 1.1 Objectives and Priorities:
1.2 Business model implications

This is an important element of all transition plans and will provide crucial
information on a company’s transition objectives.

Usefulo Very usefulo Usefulo Not useful26

Questions

Comments

o Don't knowPlease explain your selection to 1.2 Business Model Implications:This will provide useful context to understand how the transition plan relates tothe business model.

2. Implementation Strategy
2.1 Business Planning and Operations

Very usefulo Very usefulo Usefulo Not usefulo Don't knowtransition plan.

Please explain your selection to 2.1 Business planning and operations:

2.2 Products and Services

This is important information for how a company will deliver against theirUsefulo Very usefulo Usefulo Not useful27

Questions

Comments

o Don't knowPlease explain your selection to 2.2 Products and Services
2.3 Policies and Conditions

This will be interesting information, but is unlikely to be a key metric for financial
institutions.

Usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 2.3 Policies and Conditions
2.4 Financial PlanningThis is less important from a user perspective, but useful and important forcomparing consistency across the market.

Very usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 2.4 Financial Planning:
2.5 Sensitivity Analysis

From a financial institution perspective, this is a very important element, which
will allow us to assess where opportunities may lie, but also to plan as a business.

Usefulo Very usefulo Useful

28

Questions

Comments

o Not usefulo Don't knowPlease explain your selection to 2.5 Sensitivity Analysis

This will be useful information, but it will require more examples in themarketplace to make meaningful comparisons.

3. Engagement Strategy
3.1 Engagement with Value Chain

Usefulo Very usefulo Usefulo Not usefulo Don't knowThis will be less useful for financial institutions from a user perspective, but isimportant for companies that have a large amount of Scope 3 emissions.

Please explain your selection to 3.1 Engagement with Value Chain:

3.2 Engagement with Industry

Usefulo Very usefulo Useful

29

Questions

Comments

o Not usefulo Don't know-

Please explain your selection to 3.2 Engagement with Industry:
3.3 Engagement with Government, Public Sector and Civil Society

Not usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 3.3 Engagement with Government, Public Sector andFrom the perspective of a bank making investment decisions, this is useful, but
not essential. However, this is important information for other stakeholders andCivil Society

will foster greater transparency.

4. Metrics and Targets
4.1 Governance, Business and Operational Metrics and Targets

Very usefulo Very usefulo Usefulo Not usefulo Don't know

30Questions

Comments

Please explain your selection to 4.1 Governance, Business and Operational Metrics andinformation.

Targets
4.2 Financial Metrics and Targets

This is a key measure of how a business is run, so it is very important

Very usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 4.2 Financial Metrics and Targets
4.3 GHG emissions Metrics and Targets

This is very important information.

Very Usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 4.3 GHG emissions Metrics and Targets:

This is important for some sectors more than others. For high emitting sectors
where financial institutions have internal reduction targets such as oil and gas,
this will be important.

4.4. Carbon Credits

Usefulo Very usefulo Useful

31

Questions

Comments

o Not usefulo Don't knowPlease explain your selection to 4.4. Carbon Credits

This will be interesting to know, but most importantly, it should state whether acompany is factoring carbon credits into their emissions reductions.

Furthermore, emissions targets should be relevant for the business model of theentity making the disclosure and should follow industry best-practice guidelines.

5. Governance
5.1 Board Oversight and Reporting

Usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 5.1 Board Oversight and Reporting:
5.2 Roles, Responsibility and Accountability

This is important, but not crucial.

Usefulo Very usefulo Usefulo Not usefulo Don't know
Please explain your selection to 5.2 Roles, Responsibility and Accountability:

32This is important, but not crucial.

Questions

5.3 Culture

Comments

Usefulo Very usefulo Usefulo Not usefulo Don't knowThis will be interesting information, but may be difficult to independently verify. It
is possible that a company will be self-selecting with this information.

Please explain your selection to 5.3 Culture:Furthermore, from a user perspective, financial institutions are more likely tofocus on a client’s ambition levels, targets and progress rather than theirgovernance arrangements and approach to culture and training.

5.4 Incentives and Remuneration

Usefulo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 5.4 Incentives and Remuneration:

Useful, but it is still difficult to assess whether remuneration and inventive targets
help to drive results in the area of sustainability. It is more important to compare
these policies against the performance of a company on its transition metrics.

33

Questions

Comments
Useful

5.5 Skills, Competencies and Trainingo Very usefulo Usefulo Not usefulo Don't knowPlease explain your selection to 5.5 Skills, Competencies and Training:
The Framework: Suggestions
1. Foundations-

In the TPT Disclosure Framework we provide disclosure recommendations aimed toassist entities to disclose credible, useful, and consistent transition plans.
If you regard yourself as a user of transition plans, please assess the extent to which
you expect disclosures in line with our recommendations to be useful for informing
your decisions:
Where relevant, how would you suggest we change the disclosure recommendation for
1.1 Objectives and Priorities?
Where relevant, how would you suggest we change the disclosure recommendation for
1.2 Business model implications?

34-

This is helpful information, including any training provided at Board level.

Questions

Comments

2. Implementation Strategy

Short, medium and long term should all be defined to allow for straightforward
comparison between transition plans prepared by different entities, rather than

Where relevant, how would you suggest we change the disclosure recommendation forleaving the choice of time period to the entity’s discretion. Short term could be

2.1 Business Planning and Operations?

defined as within 3 years. Our suggestion for medium term is either by 2030, or
up to 7-10 years in the future; long term would be thereafter.

Where relevant, how would you suggest we change the disclosure recommendation for-

2.2 Products and Services?
Where relevant, how would you suggest we change the disclosure recommendation for-

2.3 Policies and Conditions?
Where relevant, how would you suggest we change the disclosure recommendation for-

2.4 Financial Planning?


Changes in assumptions from previous iterations of the entity’s transition plan (orother publicly shared statements) should be explained and justified. This makes it
easier for readers of consecutive plans to understand how factors outside theWhere relevant, how would you suggest we change the disclosure recommendation for
2.5 Sensitivity Analysis?

entity’s control may have changed.
The degree of sensitivity testing for each element should be explained andjustified.

3. Engagement Strategy

35

Questions

Comments-

Where relevant, how would you suggest we change the disclosure recommendation?
for 3.1 Engagement with Value Chain
Where relevant, how would you suggest we change the disclosure recommendation for-

3.2 Engagement with Industry?
Where relevant, how would you suggest we change the disclosure recommendation for-

3.3 Engagement with Government, Public Sector and Civil Society?
4. Metrics and Targets
A breakdown by business units regarding this Metrics and Targets is preferable sothat users can check the progress of companies' transition not by company but by
each business unit.



Any changes from previously published metrics and targets should be clearly

Where relevant, how would you suggest we change the disclosure recommendation for

explained and justified. We would suggest that for ease of understanding,

4.1 Governance, Business and Operational Metrics and Targets?

achievements against targets to date should be included, ideally including
comparisons with achievements at the date of the previous iteration of the plan(noting that plans are expected to be updated every three years at the latest).


To make comparative reviews easier, targets should explicitly reference the short,medium and long term roadmaps.

Where relevant, how would you suggest we change the disclosure recommendation for
4.2 Financial Metrics and Targets?

36Same as above.

Questions

CommentsThe disclosure recommendations for 4.2 should require intensity and/or absolute

Where relevant, how would you suggest we change the disclosure recommendation fortargets. Targets should cover the most material scopes and scope categories

4.3 GHG Emissions Metrics and Targets?

(upstream/downstream) for the business activity (not ‘upstream anddownstream’).

Where relevant, how would you suggest we change the disclosure recommendation for-4.4. Carbon Credits?
5. Governance
Where relevant, how would you suggest we change the disclosure recommendation for-

5.1 Board Oversight and Reporting?
Where relevant, how would you suggest we change the disclosure recommendation for-

5.2 Roles, Responsibility and Accountability?
Where relevant, how would you suggest we change the disclosure recommendation for-

5.3 Culture?
Where relevant, how would you suggest we change the disclosure recommendation for-

5.4 Incentives and Remuneration?
Where relevant, how would you suggest we change the disclosure recommendation for
5.5 Skills, Competencies and Training?
The Framework: Additional Comments
Are there any other comments that you would like to provide on the TPT Disclosure
Framework?

37--

Questions

Comments

The Guidance: Implementing the Sub-Elements
1. Foundations
In the Implementation Guidance we provide additional interpretative guidance for each-

sub-element, aimed to help preparers assess and implement the guidance. Theinterpretative guidance sits beneath an overview of ‘TCFD additionality’ for each subelement.

Do you agree with the content of the interpretative guidance for each sub-element?
Please consider the granularity of the information requested when you consider theoverall content.

1.1 Objectives and Priorities
o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer

38

Questions

Comments-

Where relevant, how would you suggest we change the interpretative guidance?
1.2

Business model implications-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know
You said that you [broadly agreed; disagreed] . Please explain your answer

Where relevant, how would you suggest we change the interpretative guidance?
2. Implementation Strategy
2.1 Business Planning and Operations-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know

39

Questions

Comments-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
2.2 Products and Services-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
2.3 Policies and Conditions-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know40

Questions

Comments-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
2.4 Financial Planning-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?

-

2.5 Sensitivity Analysis
o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.

41

Questions

Comments

o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
3. Engagement Strategy
3.1 Engagement with Value Chain-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?

42

Questions

Comments

3.2 Engagement with Industry-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
3.3 Engagement with Government, Public Sector and Civil Society-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with thecontent of the interpretative guidance but would like to provide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the interpretative guidance?
4. Metrics and Targets

43Questions

Comments

4.1 Governance, Business and Operational Metrics and Targets-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?

4.2 Financial Metrics and Targets
o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know

You said that you [broadly agreed; disagreed] . Please explain your answer-

44

Questions

Comments-

Where relevant, how would you suggest we change the disclosure recommendation?
4.3 GHG emissions Metrics and Targets-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?

-

4.4. Carbon Creditso Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know

45

Questions

Comments-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
5. Governance-

5.1 Board Oversight and Reportingo Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
5.2 Roles, Responsibility and Accountability-

o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.

46

Questions

Comments

o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
5.3 Culture-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
5.4 Incentives and Renumerationo Yes, I agree with the content of the-interpretative guidanceo I broadly agree with the content of the interpretative
guidance but would like to provide comments.o No, I disagree with the content of theinterpretative guidance.o Don't Know

47

Questions

Comments-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
5.5 Skills, Competencies and Training-o Yes, I agree with the content of the interpretative guidanceo I broadly agree with the content of the interpretative guidance but would like toprovide comments.
o No, I disagree with the content of the interpretative guidance.
o Don't Know-

You said that you [broadly agreed; disagreed] . Please explain your answer-

Where relevant, how would you suggest we change the disclosure recommendation?
The Guidance: The four stages

In the Implementation Guidance we provide additional guidance for preparers,
outlining four key stages to preparing a transition plan. At each stage, the guidance
outlines process steps for the entity to disclose against the TPT Framework.
Do you agree with the content of the Implementation Guidance for each stage?

48

Yes, I agree with the content of the guidance.

Questions

Comments

Stage 1: Baselining current positiono Yes, I agree with the content of the guidanceo I broadly agree with the content of the guidance but would like to provide
comments.
o No, I disagree with the content of the guidance.
o Don't KnowPlease explain your selection
Stage 2: Setting Ambition-o Yes, I agree with the content of the guidanceo I broadly agree with the content of the guidance but would like to provide
comments.
o No, I disagree with the content of the guidance.
o Don't Know-

Please explain your selection

49

We can appreciate that TPT’s guidance is built upon the TCFD guidance.

Questions

Comments

Stage 3: Developing an Action Plan-o Yes, I agree with the content of the guidanceo I broadly agree with the content of the guidance but would like to provide
comments.
o No, I disagree with the content of the guidance.
o Don't Know-

Please explain your selection-

Stage 4: Ensuring Accountability for Delivery
o Yes, I agree with the content of the guidanceo I broadly agree with the content of the guidance but would like to provide
comments.
o No, I disagree with the content of the guidance.
o Don't Know

Please explain your selection50

Questions

Comments

The Guidance: The four stages – Part 2
Yes, the guidance has the right level of granularity.

In the Implementation Guidance we provide additional guidance for preparers,
outlining four key stages to preparing a transition plan. At each stage, the guidance
outlines process steps for the entity to disclose against the TPT Framework.
Is this guidance sufficiently granular?

Stage 1: Baselining current positiono No, the guidance is not sufficiently granular.
o Yes, the guidance has the right level of granularity.
o No, the guidance is too granular.
o Don't KnowPlease explain your selection

We can appreciate that TPT’s guidance is built upon the TCFD guidance. We
think the framework should not be too granular at the moment.

Stage 2: Setting Ambitiono No, the guidance is not sufficiently granular.
o Yes, the guidance has the right level of granularity.
o No, the guidance is too granular.
o Don't Know

51

Questions

Comments-

Please explain your selection
Stage 3: Developing an Action Plan-o No, the guidance is not sufficiently granular.
o Yes, the guidance has the right level of granularity.
o No, the guidance is too granular.
o Don't Know-

Please explain your selection
Stage 4: Ensuring Accountability for Delivery-

o No, the guidance is not sufficiently granular.
o Yes, the guidance has the right level of granularity.
o No, the guidance is too granular.
o Don't Know-

Please explain your selection
The Guidance: Additional Comments



Are there any other comments that you would like to provide on the TPT

Since granting external assurance or verification over the entire transition plan issubstantially difficult given the current uncertainty, the framework should focus

Implementation Guidance?

on ensuring that preparing companies review their transition trajectories every52

Questions

Comments
three years so that investors, as users, can reliably track progress over timerather than requiring external assurance of verification.

Overall FeedbackAs a general comment, we support that the Proposals are in line with therecommendations by the Glasgow Financial Alliance for Net Zero and build on thework of the TCFD and the ISSB to help the global convergence andIs there any additional information that you would like to communicate to the TPT

standardization of transition plans.

about these consultation documents?

To enhance “Accountability” to evaluate the actionable steps stated in thetransition plan, it would be helpful for the framework to include pilot cases toshow how granular progress reporting is expected for each action.

(End)53