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Climate Risk Management Policy

Code CLQ-007
Domain Climate & ESG Risk
Owner Chief Risk Officer
Status Draft
Applicability Platform
Jurisdiction NZ + AU
Business domain BD03
Review date 2027-04-18

Regulations: NZ FMC Act

Purpose

The platform shall provide continuous, automated assessment of climate-related financial risk across the lending portfolio. Physical risk (property-level hazard exposure for mortgage collateral) and transition risk (high-carbon sector concentration) shall be assessed automatically and included in the Risk Appetite Framework dashboard. Manual climate risk assessments are an exception escalation path, not the default.

Obligations

Physical risk

The platform shall maintain a live physical risk assessment for all mortgage collateral using a configured third-party property hazard data source. Each property shall be classified by physical hazard tier. The CRO shall be alerted automatically when portfolio physical risk concentration in any tier breaches the configured RAF threshold.

Transition risk

All business lending counterparties shall be classified by ANZSIC sector code. Sectors shall be mapped to climate transition risk tiers. High-transition-risk sector concentration shall be monitored continuously against RAF limits.

Climate stress testing

A physical risk scenario and a transition risk scenario shall be incorporated into the stress testing engine (MOD-034). Results shall be included in the ICAAP stress section.

TCFD disclosure

An annual TCFD-aligned climate disclosure shall be generated on the configured schedule. The Metrics & Targets section shall be auto-populated from live model outputs. The Governance and Strategy narrative sections shall be institution-completed templates. Each completed disclosure shall be stored as an immutable record.

Regulatory note

The NZ Climate-related Disclosures Act 2021 requires TCFD-aligned disclosure for in-scope NZ institutions. APRA CPG 229 sets equivalent AU supervisory expectations. This policy builds to both. Specific metric requirements will be updated when the NZ Disclosure Standard and any AU CPS 229 binding standard are finalised.


Satisfying modules

Module Name Mode Description
MOD-152 Climate risk assessment CALC Physical and transition risk scores computed continuously across the lending portfolio and integrated with the stress testing engine — no manual climate risk assessment required.

Part of Climate & ESG Risk · Governance overview Compiled 2026-05-22 from source/entities/policies/CLQ-007.yaml