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Carbon disclosure ushers in a window period


From the global economic recovery and inclusive growth in the post COVID-19 period, to the achievement of the Sustainable Development Goals (SDGs) by 2030, with the introduction of the China's “30·60” decarbonization goal, sustainable development has become the mainstream of global development. In China, the ESG investment philosophy and the transformation of company management are being further developed with the participation of stakeholders such as regulators, investors, listed companies, research institutions, rating agencies, media, etc.


As a well-known player in China's booming ESG, GoldenBee’s ESG team has released the annual ESG Progress Watch Report for the third year. In this report, we hope to help readers quickly capture major changes in the development of ESG in China, and we will also focus more on how to improve ESG practices of enterprises.


With the introduction of the China's “30·60” decarbonization goal and the accelerated formulation of related projects, environmental information disclosure is gradually strengthened and standardized. Enterprise carbon disclosure is facing great attention as well as strict requirements.


In May 2021, Ministry of Ecological Environment issued the Program for the Reform of the Environmental Information Disclosure System in Accordance with the Law, stipulating that relevant document format for information disclosure of listed companies and bond issuing enterprises should be revised by 2022. Mandatory disclosure requirements for environmental information should be incorporated into the stock issuance of listed companies. Relevant requirements should be implemented in the prospectus and declaration documents. Mandatory disclosure requirements for environmental information should also be incorporated into information disclosure for enterprise bonds, corporation bonds and non-financial enterprise debt financing tools.

In June 2021, China Securities Regulatory Commission (CSRC) issued revised Guidelines for the Format of Annual and Semi-annual Reports of Listed Companies, encouraging companies to voluntarily disclose measures and effects to reduce their carbon emissions on the basis of mandatory disclosure requirements for relevant environmental information.


Nasdaq, London Stock Exchange and Singapore Exchange all require listed companies to disclose information on risks and management of climate change, as well as carbon intensity data, in the ESG guidelines. In addition, climate change has also been included in the ESG rating framework by MSCI, FTSE Russell and Dow Jones, with relevant climate change index being established for investors' reference.

The updated ESG Reporting Guide and related listing rules of The Stock Exchange of Hong Kong Ltd. (SEHK) add indicators of "climate change", which require listed companies in Hong Kong to disclose policies on identification and mitigation of significant climate-related issues which have impacted, and those which may impact, the issuers. GHG emission data are also required to have mandatory disclosure.


GoldenBee Insights

Systematic management of corporate carbon disclosure should be elevated to a more important position. On one hand, enterprises should fully grasp the environmental information disclosure regulations and guidelines, follow up the carbon information disclosure management trends and regulatory process, and gradually establish carbon information monitoring, collecting, accounting, analysis, and disclosure system, to meet information disclosure requirements and market disclosure expectations. On the other hand, companies should match international disclosure frameworks such as TCFD recommendations, SASB standards, CDSB guidelines, and actively identify climate-related risks, opportunities and financial impacts, to help companies make decisions, avoid climate risks, seize business opportunities, ensure long-term sustainability, and to provide investors with effective non-financial information such as corporate environment and climate to enhance investment value.



GoldenBee collected the Corporate ESG Reports published from January 1, 2021 to May 31, 2021 by SEHK, gathered information and made statistical analysis on six perspectives including special policies/governance, risk/opportunity analysis and assessment, systematic responding measures, targeting, special disclosure, and initiative participation.

Specific analysis covers information disclosure on 14 indicators, including specific policies/governance, risk/opportunity analysis and assessment, systematic response, goal setting- carbon neutrality, goal setting-peaking carbon dioxide emissions, special disclosure-TCFD, special disclosure-CDP, participation in the Science Based Targets initiative (SBTi), participation in the Renewable Energy 100% (RE100), participation in the Caring for Climate (C4C), and participation in the CLIMATE NEUTRAL NOW.



Of the 2580 listed entities, 2,124 did not disclose any carbon information, accounting for 82.33%; 178 companies disclosed only one indicator, accounting for 6.9%. The majority of enterprises disclosed 2-3 indicators, with the proportion of 8.87%, and the disclosure of 4 or more items accounted for 2.9%, of which only 13 enterprises covered all the indicators, accounting for only 0.5%.


Enterprise carbon management information disclosure is far from sufficient, showing only sporadic and fragmented carbon-related information. Systematic and normal disclosure mechanism is not yet established. There is still a large gap in climate-related matters, carbon management governance policy, management practices, data collection and information disclosure, which need to be enhanced in ESG management by listed companies.



Energy and power, transportation and communications, real estate, construction, manufacturing, extractive, financial insurance industries have better performance (above the average level) in carbon disclosure.

In terms of specific industries, enterprises in energy and power industry responded better to all the indicators, while those in the transportation, real estate, construction, extractive and other industries showed similarities in systematic response to climate issues, risk/opportunity analysis and assessment, and the development of specific policies/governance. The ESG management of financial and insurance industries was also significantly affected by climate policies and "double carbon" goal.



The highest disclosure rates were for systematic responses to climate change and carbon management, at 13.67%, and 8.75% for management targets.

Of these, 2.86% enterprises disclosed management targets for carbon neutrality and peaking carbon dioxide emissions, and 8.32% mentioned climate and carbon-related risk opportunity analysis and assessment in their reports.

The proportion of enterprises disclosing special policy and governance information was 7.7%; enterprises involved in special disclosure of carbon information, such as TCFD and CDP disclosure, was relatively low, with a total of 2.28%.


The proportion of disclosure involving climate-related alliances/initiatives was only 1.47%.


GoldenBee Insights

China's 14th Five-Year Plan (2021-2025) has a detailed plan on how to achieve carbon neutralization goals. The transition to energy decarbonization and the consequent upgrading of industrial structure and consumption restructuring will profoundly demonstrate the long-term and sustainable impact of climate policy and carbon management on ESG investment as well as industrial growth patterns.


Disclosure and transparent communication of carbon information have become the priorities and key issues of ESG management. Enterprises in energy and power, transportation, real estate, construction, financial insurance and public utilities industries have taken the lead in grasping trends and making changes.


We believe that, on one hand, the disclosure regulations by exchanges and regulatory bodies, the attention to climate issues and carbon management factors from investors, and the market pressures brought about by rating results will promote enterprises to disclose more information on carbon management. On the other hand, the disclosure of carbon management information will in turn push enterprises to establish a better ESG management scheme from governance policies, risk and opportunity analysis and assessment, management initiatives, goal setting, and participation initiatives, to enhance corporate resilience and sustainable development capacity.


More information on ESG Progress Watch Report comes soon.

For the full report, please contact Ms. Dai Yibo, vice president of GoldenBee.

Email: yibo.dai@goldenbeechina.com


Producer | GoldenBee ESG research team

Statement: The information cited in the report comes from public sources, and GoldenBee does not guarantee its absolute accuracy and completeness. The ideas presented in the report come from the research team's analytical judgment based on open information and experience.

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