TCFD Climate Disclosure Policy¶


Code	`REP-012`
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¶

This policy governs the institution's obligation to produce an annual TCFD-aligned climate disclosure. The disclosure is structured around the four TCFD pillars. Where automation is possible, the platform generates content directly from live model outputs. Where institutional judgement is required, the platform provides editable templates and routes the completed document through compliance officer review before storage.

Governance (institution responsibility)¶

The institution shall document board and management oversight of climate risk, including: which board committee has oversight, meeting frequency, how climate risk informs strategy decisions, and how management identifies and escalates material climate risk. The platform provides a structured template for this section; content is institution-authored and must be reviewed and approved by the compliance officer before the disclosure is finalised.

Strategy (partially automated)¶

The platform auto-populates the material climate risks identified through MOD-152 assessments — physical risk portfolio metrics and transition risk sector concentration — as the factual basis for this section. The institution authors the narrative on how those risks affect the business model and strategy over short, medium, and long time horizons. The institution narrative must be reviewed and approved by the compliance officer.

Risk management (auto-populated)¶

The platform auto-populates how climate risks are identified (physical hazard API integration for mortgage collateral, ANZSIC sector classification for business lending), assessed (risk tier assignment, portfolio concentration metrics against RAF thresholds), and integrated into the existing risk management framework (RAF dashboard indicators in MOD-150, MOD-034 stress scenarios, CRO threshold alerts). No institution-authored content is required in this section; the platform derives it from live configuration and model outputs.

Metrics and targets (fully automated)¶

The platform auto-generates the following metrics for each annual disclosure period:

Portfolio physical risk exposure percentage by tier (low / medium / high / very high)
High-transition-risk sector concentration as a percentage of total business lending exposure
Climate stress test capital impact expressed as CET1 basis points, for both the physical risk scenario and the transition risk scenario
Year-on-year trend for each metric over the prior three annual periods
Any climate-related targets set by the institution in platform configuration, with progress against target

Annual schedule and record retention¶

The report is generated on a configured schedule aligned to the institution's financial year-end. Lead time is configurable to allow compliance officer review before public release. Each completed disclosure is stored as an immutable versioned record in bank-reports-prod S3 with a content hash. No version may be deleted. All versions are retained indefinitely and must be accessible for regulatory examination for a minimum of 7 years.

Regulatory note¶

The NZ CRD Act 2021 mandates TCFD disclosure for in-scope NZ financial institutions. ASIC has clarified that existing Corporations Act disclosure obligations apply to material climate risk. APRA CPG 229 sets expectations for climate risk disclosure in ICAAP and annual reports. This policy builds to all three; it 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	`AUTO`	TCFD-aligned climate disclosure report generated from live model outputs on annual schedule — metrics and targets section fully automated.

Part of Climate & ESG Risk · Governance overview Compiled 2026-05-22 from source/entities/policies/REP-012.yaml