Reporting according to EU Taxonomy

However, implementation of these documents is beyond the financial capacity of the public sector, so it is necessary to engage private capital and redirect it towards a sustainable economy. The EU Taxonomy is supposed to be a tool that supports taking right investment decisions and, at the same time, supports sustainability.

The taxonomy is a key instrument for assessing the sustainability of business activities. It provides a standard definition of environmentally sustainable activities, in order to ensure better monitoring, reporting and make better decisions about commitments.

In line with the general trend towards more extensive disclosures concerning climate-related financial risks, BNP Paribas Bank Polska SA supports efforts to increase transparency in disclosures towards a more sustainable financial institutions framework and standards.

Based on the requirements of Article 8 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 („Taxonomy”), the Bank is required to publish information on how and to what extent its activities are related to business activities that qualify as environmentally sustainable under Articles 3 and 9 of the mentioned Regulation.

Article 10 of Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of the information on environmentally sustainable business activities to be disclosed by undertakings subject to Article 19a or 29a of Directive 2013/34/EU1 and specifying the methodology to comply with that disclosure obligation („Delegated Regulation 2021/2178”) creates a special provision introducing simplified disclosure rules during a transitional period. For financial undertakings, the special reporting rules are set for the period from 1 January 2022 to 31 December 2023. The transitional period is intended to prepare for future reporting of key performance indicators.

With reference to the scope of information disclosed during the transitional period, in addition to quantitative indicators, the Bank is required to publish the following qualitative information as referred to in Annex XI of Delegated Regulation 2021/2178.

As a first step, for the purpose of fulfilling the obligation under Article 8 of the Taxonomy, the Bank identified the Clients that are subject to the obligation to publish non-financial information under Article 19a or 29a of Directive 2013/34/EU. The proper identification of these entities determined how the scope of assets taken into account in the calculation of the quantitative indicators was determined. In accordance with Article 7(3) of Delegated Regulation 2021/2178, exposures to companies not covered by the obligation to make non-financial statements are excluded from the numerator of the key performance indicators calculated in the future. In view of the above, the Bank applied an analogous approach in 2022 for the calculation of the quantitative indicators, i.e. based on exposures to companies subject to the non-financial reporting obligation. At the same time, it should be noted that no uniform list of entities obliged to prepare non-financial statements (by an authorised public authority) was developed, which significantly hindered the fulfilment of the reporting obligations under the Taxonomy. As a result, the Bank was obliged to independently, based on expert knowledge and available market data, determine the group of customers who are subject to the obligation to prepare non-financial statements.

In the next step, the data concerning assets were reconciled to the data presented in the FINREP consolidated report. The exposures included all customer receivables, including those arising from leasing and factoring, as well as from derivatives and securities. The calculation of ratios was performed on a net basis.

Subsequently, for the purpose of assessing the eligibility of economic activities as environmentally sustainable (in line with the Taxonomy), the Bank analysed the activities identified in Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives. In the analysis of eligibility with the Taxonomy, the Bank used information on business activities linked to PKD codes (according to the statistical classification of economic activities), using information it already has in its resources. The analysis of business activity was based on information on leading customer activity.

In terms of restrictions, it should be pointed out that the obligation to publish statements on non-financial information comes into force on the same date for financial institutions and non-financial institutions. The timeframe, therefore, prevents the use of the data contained in the reports of non-financial entities that are customers of the Bank. At the same time, Delegated Regulation 2021/2178 does not indicate how financial companies should use the Customer data they hold, or how they should source it for the required disclosures. Therefore, in the current legal and factual state, there is no clear basis for applying a universal formula regarding the source of data that the Bank should use for the purposes of calculating the quantitative indicators referred to in Article 10 of the Delegated Regulation.

The key dimension of the Bank’s responsibility is to support sustainable development of the economy in the long term and to build lasting relationships with clients and other stakeholders of the Bank. We offer products and services tailored to the changing needs of our clients, while responding to global challenges and local market conditions. In order to improve monitoring, reporting and to allow making better decisions on its sustainability commitments, the Bank uses the Taxonomy. It provides the Bank with a tool to support the systematisation of the Bank’s environmentally sustainable business activities.

For more information on sustainable finance and products with a positive social and environmental impact, please refer to Business perspective and Environmental perspective chapters.

We constantly monitor CSR/ESG risks in the companies we finance. Each financing decision is preceded by an ESG analysis. We check how the company we finance affects the environment, society and corporate governance. We pay particular attention to financing sectors that are recognised as sensitive in terms of ESG factors. In each sector recognised by the Bank to be particularly sensitive in terms of sustainability, CSR Policies and Principles are implemented, defining the requirements for clients operating in these sectors. In the case of the most harmful sectors in terms of sustainability, the Bank makes strategic decisions to withdraw from serving clients belonging to these sectors.

In 2021, in response to the requirements of the EBA/GL/2020/06 Guideline of 29 May 2020 on loan origination and monitoring, the Bank developed ESG assessment questionnaires, which were implemented in the credit process. The purpose of the assessment is to identify any risks related to ESG factors affecting the financial situation of clients, as well as the impact of clients’ economic activities on ESG factors (dual materiality principle). The Principles of ESG Risk Management at BNP Paribas Bank Polska S.A. have also been developed. Additionally, BNP Paribas Group applies Equator Principles (EP) in place to identify, assess and manage the risk related to financing a given project and its environmental and social impact. The principles provide minimum standards for conducting due diligence on projects.

For more information on ESG risk management, please refer to Management foundations chapter, while for more information on sensitive sectors and CSR Policies, please refer to Business perspective chapter.

In 2021, we continued to implement the 2018-2021 Fast Forward Strategy and its integral part, i.e. the CSR and Sustainability Strategy. At the same time, in 2021 we developed the 2022-2025 strategy, in which sustainability is one of the key dimensions.

For more information the Bank’s business strategy, including a description of the environmental responsibility commitments towards the market that the Bank is implementing and will reflect in the new strategy, please refer to Management Foundations chapter.