Additional cautionary statement regarding ESG and climate-related data,
metrics and forward-looking statements
The Annual Report and Accounts 2023 contains a number of forward-
looking statements (as defined above) with respect to the Group’s
(including the group’s) ESG targets, commitments, ambitions, climate-
related pathways, processes and plans, and the methodologies and
scenarios the Group (including the group) uses, or intends to use, to
assess the Group’s (including the group's) progress in relation to
these ('ESG-related forward-looking statements').
In preparing the ESG-related information contained in the Annual
Report and Accounts 2023, the group has relied on a number of key
judgements, estimations and assumptions of the Group and the
processes and issues involved are complex. The Group has used ESG
(including climate) data, models and methodologies that it considers,
as of the date on which they were used, to be appropriate and
suitable to understand and assess climate change risk and its impact,
to analyse financed emissions - and operational and supply chain
emissions, to set ESG-related targets and to evaluate the
classification of sustainable finance and investments. However, these
data, models and methodologies are often new, are rapidly evolving
and are not of the same standard as those available in the context of
other financial information, nor are they subject to the same or
equivalent disclosure standards, historical reference points,
benchmarks or globally accepted accounting principles. In particular, it
is not possible to rely on historical data as a strong indicator of future
trajectories in the case of climate change and its evolution. Outputs of
models, processed data and methodologies are also likely to be
affected by underlying data quality, which can be hard to assess and
the Group expects industry guidance, market practice, and regulations
in this field to continue to change. The Group (including the group)
also face challenges in relation to its ability to access data on a timely
basis, lack of consistency and comparability between data that is
available and its ability to collect and process relevant data.
Consequently, the ESG-related forward-looking statements and ESG
metrics disclosed in the Annual Report and Accounts 2023 carry an
additional degree of inherent risk and uncertainty.
Due to the unpredictable evolution of climate change and its future
impact and the uncertainty of future policy and market response to
ESG-related issues and the effectiveness of any such response, the
Group (including the group) may have to re-evaluate its progress
towards its ESG ambitions, commitments and targets in the future,
update the methodologies it uses or alter its approach to ESG
(including climate) analysis and may be required to amend, update and
recalculate its ESG disclosures and assessments in the future, as
market practice and data quality and availability develop.
No assurance can be given by or on behalf of the group as to the
likelihood of the achievement or reasonableness of any projections,
estimates, forecasts, targets, commitments, ambitions, prospects or
returns contained herein. Readers are cautioned that a number of
factors, both external and those specific to the Group (including the
group), could cause actual achievements, results, performance or
other future events or conditions of the group to differ, in some cases
materially, from those stated, implied and/or reflected in any ESG-
related forward-looking statement or metric due to a variety of risks,
uncertainties and other factors (including without limitation those
referred to below):
– Climate change projection risk: this includes, for example, the
evolution of climate change and its impacts, changes in the
scientific assessment of climate change impacts, transition
pathways and future risk exposure and limitations of climate
scenario forecasts;
– ESG projection risk: ESG metrics are complex and are still subject
to development. In addition, the scenarios employed in relation to
them, and the models that analyse them have limitations that are
sensitive to key assumptions and parameters, which are
themselves subject to some uncertainty, and cannot fully capture
all of the potential effects of climate, policy and technology-driven
outcomes;
– Changes in the ESG regulatory landscape: this involves changes in
government approach and regulatory treatment in relation to ESG
disclosures and reporting requirements, and the current lack of a
single standardised regulatory approach to ESG across all sectors
and markets;
– Variation in reporting standards: ESG reporting standards are still
developing and are not standardised or comparable across all
sectors and markets, new reporting standards in relation to
different ESG metrics are still emerging;
– Data availability, accuracy, verifiability and data gaps: the Group’s
(including the group’s) disclosures are limited by the availability of
high-quality data in some areas and the Group’s (including the
group’s) own ability to timely collect and process such data as
required. Where data is not available for all sectors or consistently
year on year, there may be an impact to the Group’s (including the
group’s) data quality scores. While the Group (including the group)
expects its data quality scores to improve over time, as companies
continue to expand their disclosures to meet growing regulatory
and stakeholder expectations, there may be unexpected
fluctuations within sectors year on year, and/or differences
between the data quality scores between sectors. Any such
changes in the availability and quality of data over time, or the
Group’s (including the group’s) ability to collect and process such
data, could result in revisions to reported data going forward,
including on financed emissions, meaning that such data may not
be reconcilable or comparable year-on year;
– Developing methodologies and scenarios: the methodologies and
scenarios the Group (including the group) uses to assess financed
emissions and set ESG-related targets may develop over time in
line with market practice, regulation and/or developments in
science, where applicable. Such developments could result in
revisions to reported data, including on financed emissions or the
classification of sustainable finance and investments, meaning that
data outputs may not be reconcilable or comparable year-on year;
and
– Risk management capabilities: global actions, including the
Group’s (and the group’s) own actions, may not be effective in
transitioning to net zero and in managing relevant ESG risks,
including in particular climate, nature-related and human rights
risks, each of which can impact the Group (including the group)
both directly and indirectly through its customers, and which may
result in potential financial and non-financial impacts to the Group
(including the group). In particular:
– the Group (including the group) may not be able to achieve its
ESG targets, commitments and ambitions (including with
respect to the positions set forth in the Group’s thermal coal
phase-out policy and its energy policy, and its targets to reduce
its on-balance sheet financed emissions and, where applicable,
facilitated emissions in its portfolio of selected high-emitting
sectors), which may result in the Group’s (including the
group's) failure to achieve some or all of the expected benefits
of its strategic priorities; and
– the Group (including the group) may not be able to develop
sustainable finance and ESG-related products consistent with
the evolving expectations of its regulators, and its capacity to
measure the environmental and social impacts from its
financing activity may diminish (including as a result of data and
model limitations and changes in methodologies), which may
affect its ability to achieve its ESG targets, commitments and
ambitions, including its net zero ambition, its targets to reduce
its on-balance sheet financed emissions and, where applicable,
facilitated emissions in its portfolio of selected high-emitting
sectors and the positions set forth in its thermal coal phase-out
policy and energy policy, and increase the risk of greenwashing.
Additional Information
152 The Hongkong and Shanghai Banking Corporation Limited Annual Report and Accounts 2023