IN THE SHADOWS Who is opposing the EU taxonomy for polluting activities EXECUTIVE SUMMARY
he EU sustainable taxonomy aims at This report analyzes the answers to this identifying activities that contribute to consultation. Its key findings are: Tthe ecological transition, in accordance with European climate and environmental • Financial institutions are the larger IN THE SHADOWS objectives. It is a vital piece of the European block opposing a taxonomy for polluting Who is opposing the EU taxonomy for polluting activities transition strategy that aims at gearing activities, with 74 institutions making up financial flows toward activities that 45% of its opponents. Research: significantly contribute to the transition. • Though the financial sector is divided, Paul Schreiber influential players and their professional However, transitioning to a more sustainable federations or associations are leading system entails replacing our polluting the charge against a taxonomy for Authors and contributors: activities and investments with green polluting activities. This position is often Paul Schreiber alternatives. Yet, the Sustainable Taxonomy clearly inconsistent with financial players’ Lucie Pinson does not identify the activities that climate commitments. Eren Can Ileri “significantly impair” the transition. What • The prominent role of financial good are new solar panels and wind turbines professional federations is problematic. if we continue to operate coal power plants They appear to be used by prominent Page editing: and use more fossil fuels? members to further an anti-climate Jordan Jeandon, Graphic designer agenda, while other members tacitly To realize how critical this loophole is, we assent. Doing so, they adopt positions Publication date: just have to remind us that, from 2016 – and opposed to those of their more climate- December 2020 the Paris Agreement - to 2019, international aware members. banks have provided nearly $2.7 trillion in • Financial institutions use four main financing for fossil fuels. And fossil fuels are misleading arguments to oppose a not the only polluting activity there is. taxonomy for polluting activities, thus In partnership with: protecting high-GHG activities. The EU Commission is aware of this critical • High-emitting companies, backed by inconsistency and proposed to include a major economic federations and industry “taxonomy for economic activities that are groups, are also actively mobilized against most exposed to the transition due to their a taxonomy for polluting activities. current negative environmental impacts ”1 Building on financial players’ mobilization, to its renewed Sustainable Finance Strategy. they could significantly influence the Nonetheless, the Commission has not work done in EU institutions and block committed to anything and, much like when this necessary piece of legislation. building its Sustainable Taxonomy, it faces tremendous pressure from financial and The climate catastrophe is here. The EU must industry lobbies to give up on it. overcome anti-climate lobbying and develop a taxonomy for polluting activities. On their Even though 203 of the 648 respondents side, financial institutions truly committed to supported a taxonomy for polluting contribute to the fight against climate change activities to the consultation opened on must break free from anti-climate lobbying the EU sustainable finance strategy, 1692 and support the EU in this process. opposed it. The remaining 276 respondents did not explicitly expressed themselves on this issue3.
2 3 3 THE FINANCIAL SECTOR DIVIDED Developing criteria for significantly harmful institutions coming for the • 21 banks insurers and asset managers, emission levels will help financial sector opposed a including Allianz, Aviva, and Triodos Bank. taxonomy for “polluting” activities. • 22 financial interest groups, like “ 74 investors, companies, issuers They make for 45% of the opponents with Accountancy Europe and Finance For (see Annex I): Tomorrow. and project promoters to • 14 banks, insurers, and asset managers, • 18 financial authorities, notably the understand the necessary like Amundi, BNP Paribas, Crédit Agricole, Autorité des Marchés Financiers (AMF), Deutsche Bank, HSBC, Société Générale the European Central Bank (ECB), the speed and depth of the and State Street. European Insurance and Occupational • 38 financial interest groups, including the Pensions Authority (EIOPA) and the transition task ahead. European Banking Federation (EBF), the European Securities and Markets Authority Insurance Europe, the French Banking (ESMA). Federation (FBF), the French association • 11 financial service providers, including Excerpt from the of asset managers (AFG) and the French Deloitte, Euronext, and the London Stock EU Technical Expert Group Insurance Association (FFA). Exchange. on sustainable finance’s • 4 financial authorities with the Czech • 15 institutions or citizens6 that reported final report” National Bank, the Danish and Polish to work in the financial sector but did not Supervisory Authorities, and the Estonian disclose any other information on their Ministry of Finance. identities. • 10 financial service providers including Moody’s ESG and S&P Global. Taking a closer look at the respondents, a • 8 institutions or citizens4 that reported clear tendency emerges from this analysis: to work in the financial sector but did not 1. Private financial players and their disclose any other information on their interest and professional groups tend to identities. fight against a taxonomy for polluting activities. Fortunately, not all financial institutions are 2. European regulators, public financial trying to protect their ‘business as usual.’ 875 authorities and groups specifically built financial institutions are backing a taxonomy to work on sustainable finance tend to for polluting activities and account for 42% favor such a taxonomy. of its supporters (Annex II):
Opponents to a taxonomy for polluting activities
Other/Unknow 8% Other sectors 30% Financial sector 45%
Energy sector 18%
4 5 Members of French financial federations opposing or supporting a taxonomy for polluting activities
French financial federation Opponents Supporters
Fédération Bancaire Française Crédit Agricole CIB7 ; BNP Allianz Banque (FBF) Paribas8 ; Société Générale9
Candriam France; BNP Paribas Asset Management France; Association Française de la Amundi Asset Management; Aviva Investors France; Allianz Gestion financière (AFG) HSBC Global Asset Management Global Investor France France; Société Générale; Crédit Agricole Indosuez Gestion
Crédit Agricole Assurances; HSBC Fédération Française de Assurances vie; Swiss Re; Société Allianz France; Aviva Assurances; l’Assurance (FFA) Générale Assurances; BNP MAIF SEVERAL WAYS TO Paribas Cardif
The double talk of financial actors is even more obvious when comparing their position on OPPOSE THE TAXONOMY the taxonomy to the climate initiatives they adhere to. Several key members of international climate coalitions or initiatives expressed opposition to a taxonomy for polluting activities. rofessional federations and groups often on the federation’s weight to do so. Some The following chart analyzes the position of the members of four major climate initiatives: hold a key place in EU consultations financial players that pledged to protect Pand a striking number of them oppose climate belong to professional or interest a taxonomy for polluting activities. In the groups that oppose the taxonomy. AXA Members of major climate initiatives opposing or finance sector, they gather large numbers France and Groupama did not participate in supporting a taxonomy for polluting activities of banks, insurers, or asset managers that the consultation but hold sit on the boards entrust them to defend their interests. When of both the AFG and FFA that opposed the Climate initiave Opponents Supporters they advocate for or against a regulation, taxonomy. public authorities assume that they accurately Aegon10 ; Amundi; BNP Paribas Allianz; Aviva Investors; Caisse represent their members. Furthermore, the position of financial Asset Management; Candriam des Dépôts; MAIF; Mirova; professional and interest groups can lead to Climate Action 100+ (CA100+)) Investors Group; HSBC Global Danske Bank; Invesco; Federated However, these groups are often dominated inconsistencies. For example, Allianz France, Asset Management11 ; Schroders; Hermes12 by a limited number of members. Several Aviva Assurances and la MAIF are in favor of Swiss Re financial players that opposed the taxonomy a taxonomy for polluting activities but the Net-zero Asset Owner Alliance Swiss Re Allianz; Aviva; Caisse des Dépôts hold an influential position in professional FFA opposes it. (NZAOA) groups that followed the same path: Philippe Allianz Global Investors14 ; Aviva Aegon; BNP Paribas Asset Brassac - from Crédit Agricole - directs Financial players that seriously want to act Investors; Barclays Bank UK Institutional Investors Group on Management; Candriam; HSBC Retirement Fund; Caisse des the French Banking Federation (FBF); on climate change cannot stay blind to their Climate Change (IIGCC) Global Asset Management13 ; Dépôts; Danske Bank; Triodos BNP Paribas Asset Management, Amundi federations and associations’ anti-climate Swiss Re Investment Management Asset Management and HSBC Global Asset lobbying. All that do not agree with these Swiss Re15 ; Société Générale; Management France are all on the board of the entities should secede. Standard Charter Bank; Allianz Science Based Target (SBTI) HSBC Holdings; BNP Paribas; French association of asset managers (AFG); Investment Management Swiss Re, Société Générale Assurances and While France dreams itself as the capital Crédit Agricole BNP Paribas Cardif sits on the board of the of “sustainable finance,” three main French French Insurance Association (FFA). financial professional federations opposed Financial players need to be coherent: one cannot promote its climate commitments while the taxonomy for polluting activities, driven working in the shadows to obstruct environmental regulation. Meaningful climate initiatives Of course, professional federations’ positions by several of their prominent members and should at least bound members to engage in pro-climate lobbying and urge them to leave any are also the result of a “silent majority” benefiting from the passiveness or quiet federation or interest group that refuse to do so. Going further, climate initiatives should require that did not individually and publicly take approval of others: their members to engage with companies that lobby to weaken climate and environmental position against the taxonomy but rely rules or to stop supporting them. 6 7 Justifications given by financial players to oppose a taxonomy for polluting activities
Banks, insurers and asset managers opposing 1 2 3 4
Aegon N.V. x x
Amundi Asset Management x x
BNP PARIBAS x x
Candriam x x
Credit Agricole Group x x x
Deutsche Bank AG x x
HSBC Holdings x x
Intesa Sanpaolo S.p.A. x
Schroders plc x x
Société Générale x x
State Street Corporation x FOUR WRONG REASONS TO Swiss Re x Union Asset Management Holding AG x OPPOSE THE TAXONOMY UniCredit x
inancial institutions opposing the generate new risks for financial institutions Ftaxonomy use 4 main arguments: (notably stranded assets). Reasons given by financial interest groups to oppose a taxonomy for polluting activities 1. The EU should focus on achieving the 4. The EU should focus on a transition sustainable taxonomy and a “positive approach, that take the progressive approach” that leads to more fuwnding nature of the transition into account. Financial interest groupes 1 2 3 4 to activities needed for the ecological “Shades of green” can be introduced to the transition. taxonomy to determine which activities Association Française de la Gestion financière (AFG) x x x are closer to the transition than others but 2. The Sustainable Taxonomy already no exclusions should be used. BusinessEurope x x contains exclusions for polluting activities, with the “do not significantly The following charts summarize the use of European Banking Federation x x harm” (DNSH) principle. Adding another these arguments by all the banks, insurers taxonomy is not necessary. and asset managers opposing the regulation Insurance Europe x x x and a few other key opponents among their 3. A taxonomy for polluting activities federations and professional associations: Fédération Française de l’Assurance (FFA) x x would demonize/punish high emissions companies that need funding to transition Fédération Bancaire Française (FBF) x x x x and therefore block their transition and/or 8 9 These four arguments are misleading at best: and companies to define clear phase- out strategies. The taxonomy is activity • An approach that only focus on increasing based and not company based, it funding to “green” activities does not does not prevent any company from allow to transition: getting financed. The current taxonomy Finishing the work on the sustainable regulation already references to enabling A green taxonomy needs to be taxonomy and building a taxonomy for activities and transitional activities. A complemented by a taxonomy polluting activities are two different taxonomy for polluting activities would workstreams to build complementary toughen financing conditions for the for environmentally harmful tools. European supervisors clearly most polluting activities but companies “ activities. emphasized the need for a taxonomy for willing to transition would be able to find polluting activities. funding by developing activities that are More funding to activities necessary to the compatible with the transition. In a word, transition will do little without reducing a taxonomy for polluting activities only Isabel Schnabel, Member of the the support provided to high-carbon pushes companies to be coherent when Executive Board of the ECB activities. Moreover, using a taxonomy defining their climate strategies. for polluting activities to decrease the Furthermore, activities in such a ” funding of highly polluting activities taxonomy would have high “stranded allows financial institutions to redirect it asset” potential because of their negative to transition-friendly activities. climate impacts and not because of the taxonomy itself. A taxonomy for polluting • The exclusion of activities from the EU activities increases transparency allowing Sustainable Taxonomy is not equivalent financial institutions to better access and to a taxonomy for polluting activities: manage their exposure to these activities, Financial institutions tend to say that the supervisors to account for it in their Sustainable Taxonomy “already exclude” prudential framework and Europeans to activities, an odd criticism providing know where their money lends. that the whole point of this taxonomy is to identify the “sustainable” activities • A taxonomy for polluting activities is part necessary to the transition and that not of a “transition” approach: all economic activities are. As we previously stressed, transitioning The “do not significantly harm” (DNSH) implies phasing-out high emission principle of the sustainable taxonomy activities while scaling up “green” states that activities listed as sustainable alternatives. A taxonomy for polluting because they contribute to one of the activities is a necessary tool to identify taxonomy’s objectives cannot significantly which activities to phase-out first. This harm another objective. Therefore, while taxonomy would be of great use for all a taxonomy for polluting activities would approaches based on a global warming specifically identify which activities are trajectory or “shades of green”, that incompatible with the transition, the several financial institutions put forward. DNSH does nothing of the sort but only However, not everything is green. To ensures that no activities that are branded quote the EU Technical Expert Group on as sustainable have adverse impacts on sustainable finance: “emissions levels in the environment. some economic activities are currently too high and threaten to continue to be too • A taxonomy for polluting activities would high throughout the economic transition not block the transition of high-GHG to be consistent with Europe’s emissions- companies and would reduce financial reduction goals“. risks: By identifying activities that are incompatible with the ecological transition, a taxonomy for polluting activities will push financial institutions
10 11 Other high-GHG sectors are actively involved. like the French Mouvement des Entreprises The 50 companies and economic interest de France (MEDEF) and Association française groups that mainly come from these sectors des entreprises privées (AFEP), the German block the taxonomy for polluting activities Industry Association or the Confederation of (see Annex IV): Swedish Enterprise - to the taxonomy. • 4 companies, ArcelorMittal, Aurubis, Henkel and KGHM Polska. The converging interest of opponents from • 36 interest groups, including the MEDEF, the financial and economic sectors could the Federation of Finnish Enterprises and significantly influence the European decision the European Steel Association (EUROFER). to build or give up on a taxonomy for polluting • 10 companies or citizens16 that did not activities. It could notably influence the disclose any information on their identities. new sustainable platform set up by the EU Among these companies, the most visible Commission to develop the EU sustainable opponents are from the steel/metal/mineral taxonomy and explore a possible taxonomy sector. Other noticeable opponents come for polluting activities. from the agriculture, transport and building Though 13 NGOs and regulators that support sectors. such a taxonomy are members of this platform, The whole government of fossil-dependent so are 6 companies and professional groups Poland opposes a “polluting” taxonomy17. that strongly oppose it. Allianz is the only non-NGO or regulator to support a taxonomy The weight and influence of high-GHG for polluting activities in this platform. A activities in the economy is highlighted professional group – BusinessEurope – is by the opposition of major economic even member of the subgroup that will work federations and national industry groups – specifically on polluting activities.
Members of the EU sustainable platform opposing or supporting a taxonomy for polluting activities
OPPONENTS TO THE Opponents Supporters
TAXONOMY PROTECT • UN PRI • World Wildlife Fund (WWF) • Birdlife • Allianz SE POLLUTERS • OMV Aktiengesellschaft • Finance Watch • European Construction Industry Federation (FIEC) • Global Reporting Initiative (GRI) • Eurofer • European Banking Authority (EBA) • European Insurance and Occupational Pensions he four arguments used by financial Repsol, RWE, Uniper. • BusinessEurope • Business and Science Poland Authority (EIOPA) institutions to oppose a taxonomy for • 13 interest groups, notably Eurogas, • BNP Paribas • European Securities and Markets Authority (ESMA) Tpolluting activities all have one major FuelsEurope, IOGP, and the World Nuclear • Transport & Environment (T&E) impact: they protect high emission activities. Association. • European Central Bank (ECB) High-GHG sectors and activities would logically The convergence of interest between major • IUCN be the first impacted by this taxonomy. financial players and fossil fuel companies • EIT Climate KIC was evident at the Climate Finance Day Already more than active on the sustainable 2020, when Paris airport company’s CEO and taxonomy, energy companies and their Europlace director’s call to lobby against a interest groups are the second biggest strict taxonomy, was followed by Total’s CEO’s opponents to a taxonomy for polluting plea for gas to be included into the sustainable activities. 29 of them are against a taxonomy taxonomy which was approved by the CEOs (see Annex III): of Natixis and SFIL. • 16 companies, including EDF, Engie, Eni,
12 13 CONCLUSION METHODOLOGY
pponents to a taxonomy for polluting More and more financial institutions do not activities are fully aware of the climate hesitate to talk about this issue and try to Data analysis Ocrisis but decided to respond to the present themselves as leaders of the transition, growing environmental pressure by protecting notably by creating or entering international Reclaim Finance – in partnership with the Change Finance Coalition - their “business as usual” for as long as they climate initiatives. However, many of them still analyzed the 649 contributions to the EU Sustainable Finance Strategy can. lobby against much-needed climate regulation focusing on question 82, that asked participants whether they support or quietly let their professional or interest or oppose a taxonomy of polluting activities21. The report does not Financial and economic private players still groups do this anti-climate lobbying for them. analyze the responses of the 276 respondents that did not explicitly very much belong to a high carbon economy. expressed their position on a taxonomy for polluting activities by The opposition of financial federationsThere is no time for financial institutions’ answering question 82. Responses to this consultation are publicly and associations, industry groups and inconsistencies or deceitfulness. To respond available here. professional federations, is a striking example to the climate emergency and be coherent of how the “tragedy of horizons” materialize. with their climate pledges: As respondents can choose to send an anonymous response, Reclaim In France, the three main financial professional Finance could not identify all the respondents that opposed this federations (FBF, FFA, AFG), the federation 1. The European Union – and Commissioner taxonomy. 21 anonymous participants expressed themselves against of employers (MEDEF) and the association of McGuinness – should support and prioritize a taxonomy of polluting activities. Large Companies (AFEP), as well as the two an ambitious taxonomy for polluting major power companies (EDF and Engie) all activities, that includes all fossil fuels. The contributions of private individuals, academics and NGOs have oppose a taxonomy for polluting activities. been considered but are not mentioned in the focus categories of this 2. Financial players should break away from brief and counted in each category. A total of 4022 NGOs expressed The climate crisis is here, and we have only professional federations, associations themselves in favor of a taxonomy for polluting activities (Annex V) ten years to cut our GHG emissions by at least or interest groups that engage in anti- and 3 against it23. 4 trade unions - ETUC, European Transport Workers’ 60% and 30 years to reach carbon neutrality18. climate lobbying, either by championing Federation, Confederación Sindical de Comisiones Obreras (CS Fiercely protected by financial opponents the weakening of current regulation or by CCOO), Nordic Financial Unions (NFU) - also supported it and none to the taxonomy for polluting activities, the opposing its improvement. opposed it. power sector needs to phase out coal by 2030 in Europe and the OECD and 2040 worldwide, 3. Climate initiatives – such as the CA100+, and oil and gas 10 years later19. If financial IIGCC or the Net-zero Asset Owner On the use of the term “brown taxonomy” institutions and energy companies defend Alliance – should ban their members Reclaim Finance choose to replace the term “brown taxonomy” – often natural gas development, demand for this from conducting in anti-climate lobbying, used by financial institutions and in the EU consultation documents24 fossil fuel need to decrease by at least 40% by directly or through subsidiaries or – by “a taxonomy for polluting activities.” The use of “brown” to talk 2030 to stay on a 1.5°C track according to IPCC professional/interest groups, and urge about high-GHG and/or polluting activities that are incompatible with scenarios20. them to engage with companies that do so. the ecological transition perpetuates a racist vocabulary in finance.
14 15 Annex I Annex II Financial institutions, authorities and groups that oppose the Financial institutions, authorities and groups that support the taxonomy for polluting activities taxonomy for polluting activities
Financial public Financial analysis, Financial public Financial analysis, Financial players Financial interest groups Financial players Financial interest groups authorities data, or services authorities data, or services
• Candriam • Assuralia • The Danish • Diversifikator • Mattig-Levercom • Accountancy Europe • National Bank of • Ernst & Young • Credit Agricole • European Banking Federation Financial GmbH Management • Federation of European Risk Belgium • Deloitte Group • European Association of Co-operative Supervisory • Deutsche Börse Partners Management Associations (FERMA) • Bank of Finland • Impak Finance • Amundi Asset Banks Authority Group (DBG) • Danske Bank • European Mortgage Federation - • The Ministry of • Rating-Agentur Management • Insurance Europe (Finanstilsynet) • European Energy • ELEVA Capital European Covered Bond Council Finance, Finland Expert RA • BNP PARIBAS • PensionsEurope • Czech National Exchange AG • MAIF - Mutuelle (EMF-ECBC) • Banque de France • Assilea. • Société Générale • JBCE (Japan Business Council in Bank • Hellenic d’Assurance des • Eurosif - the European Association of and Autorité de Italian Leasing • Deutsche Bank AG Europe) • Estonian Exchanges – Instituteurs de Sustainable Investment Forums Contrôle Prudentiel Association. • Union Asset • European Fund and Asset Management Ministry of Athens Stock France • The European Development Finance et de Résolution • Capitals Coalition Management Association (EFAMA) Finance Exchange S.A. • Meridiam Institutions Association • European Banking • Euronext Holding AG • BusinessEurope • Polish Financial • Capital • Venturexpert • BETTER FINANCE Authority • Refinitiv • UniCredit • Federation of European Securities Supervision International Capital • CFA Institute • European Securities • Principles for • Intesa Sanpaolo Exchanges Authority Limited • Caisse Des Depots • Insurance & Pension Denmark and Markets Responsible S.p.A. • European Savings and Retail Banking • S&P Global Group • Finance Denmark Authority (ESMA) Investment • Aegon N.V. Group (ESBG) • Moody’s ESG • Bpifrance • International Chamber of Commerce, • Autorité des • Impact Investing • Swiss Re • AMICE Solutions Group • Mirova Banking Commission marchés financiers Institute • Schroders plc • Business & Science Poland (BSP) • Environmental • Allianz SE • Finance for Tomorrow by Paris (AMF) • London Stock • HSBC Holdings • Fédération Bancaire Française Liability Solutions • Cantor Fitzgerald Europlace • European Central Exchange Group • State Street • ASPIM Europe Ltd. Ireland • AFPDB - Association Française des Bank Corporation • French Insurance Federation • PwC IL • Unione di Banche Produits d’investissement de Détail • EIOPA, European • Aktiengesellschaft • AFG - Association Française de la • FIA Italiane S.p.A. et de Bourse Insurance and • European Gestion financière • Invesco • German Insurance Association Occupational Construction • German Banking Industry Committee • Triodos Bank • Insurance Ireland Pensions Authority Industry • Verband öffentlicher Versicherer NEUN. • Japanese Bankers Association • Sustainable Federation (FIEC) • Deutscher Derivate Verband (DDV), • Grupo Credito • Pensioenfederatie Finance Committee • Eurofer German Derivatives Association Agricola • Global Alliance for Banking on Values of the Federal • BusinessEurope • Association of German Guarantte • Altamar Capital • Swedish Bankers´Association Government - • Business and Banks (Verband Deutscher Partners • NFU - Nordic Financial Unions Germany Science Poland Bürgschaftsbanken) • Standard • Loan Market Association • Department of • BNP Paribas • DVFA e.V. - Deutsche Vereinigung für Chartered Bank • Conseil Supérieur de l’Ordre des Finance, Ireland Finanzanalyse und Asset Management • Federated Hermes Experts-Comptables (CSOEC), • Malta Financial • Irish Funds Industry Association • ICAEW Compagnie Nationale des Services Authority • Banking & Payments Federation Ireland • Aviva Commissaires aux Comptes (CNCC) • Dutch Authority • Assogestioni • Barclays • Eumedion for the Financial • Federazione Banche Assicurazioni Markets e Finanza – FeBAF (Italian Banking, • Norwegian Ministry Insurance and Finance Federation) of Finance • ALFI (Association of the Luxembourg • Finansinspektionen Fund Industry) • Sveriges riksbank • ABBL/ACA • Swedish Ministry of • Dutch Fund and Asset Management Finance Association (DUFAS) • United Nations • Związek Banków Polskich Environment • Swiss Finance Council Programme Finance • UK Finance Initiative • The Investment Association • Association for Financial Markets in Europe (AFME) • SIFMA Asset Management Group • Institute of International Finance • Fondsverband BVI tätig • EuropeanIssuers
16 17 Annex III Annex IV Energy companies and interest groups that oppose the taxonomy for Other companies and interest groups that oppose the taxonomy for polluting activities polluting activities
Energy companies Energy interest groups Companies Interest groups
• OMV Aktiengesellschaft • Association of Austrian Electricity Companies • Henkel AG & Co KGaA • CEMBUREAU • VERBUND AG • IOGP - International Association of Oil & Gas • Aurubis AG • Wirtschaftsvereinigung Stahl • CEZ Group Producers • KGHM Polska Miedź Spółka Akcyjna • Austrian Federal Economic Chamber (WKÖ) • Valmet Oyj • FuelsEurope • ArcelorMittal • Industrial Minerals Association (IMA-Europe) • EDF • Euroheat & Power • European Construction Industry Federation (FIEC) • Orano • Eurelectric • Community of European Railway and Infrastructure • ENGIE SA • EFIEES - European Federation of Intelligent Energy Companies (CER) • SUEZ Efficiency Services • European Community Shipowners’ Association • RWE AG • Eurogas • European Association of Paritarian Institutions -AEIP • Uniper SE • Finnish Energy • The European Steel Association (EUROFER) • EnBW AG • BDEW Bundesverband der Energie- und • Copa-Cogeca • Mytilineos S.A. Wasserwirtschaft e.V. • CSR Europe • Eni s.P.a • CEWEP - Confederation of European Waste-to- • UNIFE - The European Rail Supply Industry • PGE Polska Grupa Energetyczna S.A. Energy Plants • EPRA - European Public Real Estate Association • Repsol S.A • Unione Petrolifera • American Chamber of Commerce to the EU • NATURGY ENERGY GROUP • European Federation of Energy Traders (EFET) • The Critical Raw Materials Alliance • World Nuclear Association • Confederation of Danish Industry • the Federation of Finnish Enterprises (Suomen Yrittäjät) • Confederation of Finnish Industries EK • Finland Chamber of Commerce • Fédération nationale des Travaux Publics (FNTP) • MEDEF • AFEP (French Association of Large Companies / Association française des entreprises privées) • Wirtschaft e.V.econsense - Forum for Sustainable Development of German Business e.V.» • AGFW e.V. • Verband der Chemischen Industrie e.V. (VCI) • Verband Deutscher Maschinen- und Anlagenbau e.V. (VDMA) • ZIA Zentraler Immobilien Ausschuss e.V. • Deutsches Aktieninstitut e.V. • Genossenschaftsverband Bayern • Bundesverband der deutschen Industrie, BDI • Zentralverband des Deutschen Handwerks e.V. • Confindustria • WiseEuropa – Fundacja Warszawski Instytut Studiów Ekonomicznych i Europejskich on behalf of Polish Sustainable Finance Platform • Confederation of Swedish Enterprise • Jernkontoret – The Swedish Steel Producers´ Association • Swedish Forest Industries Federation
18 19 Annex V NGOs in favor of a taxonomy for polluting activities REFERENCES Notes NGOs 1. We use the term “a taxonomy for polluting activities” to name this taxonomy, often referred to as a “brown taxonomy.” We explain why we avoid using the term “brown-taxonomy” in the methodology of this report. 2. 169 contributions total, including 3 from NGOs and 1 from an EU citizen that are not considered in categories of this • ClientEarth briefing. • Swiss Sustainable Finance • SPAINSIF FORO ESPAÑOL DE INVERSIÓN SOSTENIBLE 3. The remaining 276 respondents either responded that they did not know whether a taxonomy for polluting activities • Asociatia Consumers United/Consumatorii Uniti was necessary or not or did not responded to the related questions. • ActionAid International 4. As these contributions are anonymous, Reclaim Finance could not determine whether they came from citizens or • Forest Peoples Programme organizations. • World Benchmarking Alliance 5. In total, 89 respondents from the financial sector responded yes to a taxonomy for polluting activities, two of them • SOMO (Stichting Onderzoek Multinationale Ondernememingen) being EU citizens. • Global Reporting Initiative (GRI) 6. As these contributions are anonymous, Reclaim Finance could not determine whether they came for a citizen or an • Fair Finance International organization. • Milieudefensie / Friends of the Earth Netherlands 7. CA Indosuez Wealth Management and CA Consumer Finance are also members. • Society for International Development - Secretariat 8. BNP Paris Personal Finance; BNP Paribas Wealth Management Monaco; BNP Paribas Réunion; BNP Paribas Personal • Stichting IUCN Nederlands Comité (IUCN NL) Finance; BNP Paribas Nouvelle Calédonie; BNP Paribas Lease Group; BNP Paribas Antilles Guyane are also members. • Secours Catholique - Caritas France 9. Société Générale Private Banking and Société Générale Calédonienne de Banque are also members. • CDP Europe 10. Aegon Asset Management is also a member. • Naturschutzbund Deutschland e.V. 11. HSBC Bank Pension Scheme is also a member. • r3.0 - Redesign for Resilience & Regeneration 12. Hermes Equity Ownership Services and Hermes Investment Management are also members. • Forum Nachhaltige Geldanlagen e. V. 13. HSBC Bank Pension Trust is also a member. • Climate Disclosure Standards Board (CDSB) 14. Allianz Investment Management is also a member. • CorA Network for Corporate Accountability 15. Swiss Re committed to “business ambition for 1.5°C”. • Ecopreneur.eu 16. As these contributions are anonymous, Reclaim Finance could not determine whether they came for a citizen or an • ShareAction Europe • BirdLife Europe and Central Asia organization. • E3G 17. Response from the Ministry of Economy, Finance and Climate. • Frank Bold Society 18. See IPCC SR1.5°C Path 1 and 2 Scenarios. • CEE Bankwatch Network 19. See OCI’s analyses of the IPCC 1.5°C report’s implications for fossil fuels. • Reclaim Finance 20. See IPCC SR1.5°C P1 and P2. • Société Française des Analystes Financiers 21. “Question 82. In particular, do you think that existing actions need to be complemented by the development • 2° Investing Initiative of a taxonomy for economic activities that are most exposed to the transition due to their current negative • European Coalition for Corporate Justice (ECCJ) environmental impacts (the so-called “brown taxonomy”) at EU level, in line with the review clause of the political • WWF European Policy Office agreement on the Taxonomy Regulation?” • Greentervention ASBL 22. Including one anonymous NGO. • Finance Watch 23. Green Finance Observatoryb ASBL, Bellona Europa, European Partners for the Environment • Positive Money Europe 24. Other EU documents sometimes use the term “significantly harmful” taxonomy. • World Animal Protection • Global Witnes • Transport and Environment (European Federation for Transport and Environment) (T&E) • Diakonia • Swedwatch Credits Pixabay | Nakasone - Pexels | Vlasov - Pexels | Aleksandar Pasaric - Pexels| Unsplash | Leo - Unsplash | Todd Trapani - Pexels
20 21 IN THE SHADOWS Who is opposing the EU taxonomy for polluting activities
Reclaim Finance is an NGO affiliated with Friends of the Earth France. It was founded in 2020 and is 100% dedicated to issues linking finance with social and climate justice. In the context of the climate emergency and biodiversity losses, one of Reclaim Finance’s priorities is to accelerate the decarbonization of financial flows. Reclaim Finance exposes the climate impacts of some financial actors, denounces the most harmful practices and puts its expertise at the service of public authorities and financial stakeholders who desire to to bend existing practices to ecological imperatives.