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Centre for Environmental Rights

Introduction

The Truth About South African banks’ and companies’ ability to identify and address climate risks

You may want to know if your bank is placing your money at risk by using it to support high greenhouse gas emitting companies. As a shareholder, you may want to know whether the company you are invested in is aware of the risks and opportunities that it faces as a consequence of climate change.

Full Disclosure 5 assesses whether ten of the largest emitters of greenhouse gases in South Africa, and the five major banks, disclose and manage their climate-related risks effectively. The report considers the extent to which these companies report on climate change, and the quality of their existing disclosures, in line with the Recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).

TCFD Core Elements

Investors, banks, and the public need to know whether companies make informed, strategic decisions to manage their climate-related risks.

TCFD Recommendations evaluate whether a company’s disclosures reveal that it is sufficiently resilient in the face of climate change. The evaluation is based on four core elements:

Governance

Disclosing bank and emitter governance around climate-related risks and opportunities.

Who in the company is responsible for identifying risks and implementing the company’s strategy?

Strategy

Disclosing the actual and potential impacts of climate-related risks and opportunities on the banks’ and emitter’s businesses, strategy, and financial planning.

What are the impacts of climate-related risks and what is strategy to manage those risks?

Risk Management

Disclosing how banks and emitters and identify, assess, and manage climate-related risks.

How does the company identify and manage its climate-related risks?

Metrics and Targets

Disclosing the metrics and targets used to assess and manage relevant climate-related risks and opportunities.

What metrics are used to inform the strategy and monitor progress?

Ask the Right Questions

Full Disclosure 5 poses seventeen questions to ten green-house gas emitters and five banks to assess whether they comply with the four Core Elements of the TCFD Recommendations.

The answers are informed by the companies’ statements in their annual financial reports, sustainability reports, and submissions to the Carbon Disclosure Project (CDP). These documents are officially used to inform investors, banks, and the public of a company’s performance, which is why they should be used to inform us about the company’s exposure and efforts to mitigate the risks posed by climate change.

Methodology

Dig Deeper

The relevant disclosures of each company are set out in individual company assessments as answers to our questions. These profiles set out the information used to inform our consolidated findings.

Company assessments

Governance

Disclosing bank and emitter governance around climate-related risks and opportunities.
TCFD Guidance on Governance

Key Findings

In eight (out of 15) companies assessed, the board is responsible for overseeing climate risks, indicating accountability for climate-related risks at the most senior level of the company. In two companies, management level appointees or committees oversee climate risks.

At the remaining five companies, it is unclear who is responsible for overseeing, assessing, and managing climate-related risk making it difficult to hold responsible persons to account.

At four (out of 15) companies, good long-term corporate behaviour is incentivised by incorporating climate-related performance metrics into the board’s remuneration policies.

Board Oversight

The board and management should play an important role in overseeing, assessing and managing climate-related risks. Details of who is responsible for monitoring risks and how they monitor those risks can determine whether adequate attention is being given to the issues. By disclosing this information in public reports, the responsible individuals may be held accountable for their management of climate-related risks.

Who has oversight of climate-related risks and opportunities?

Board8 Not disclosed5 Non-board executive(s)2

Recommended Disclosures (a) and (b)

The TCFD recommends that organisations disclose:

  1. The board’s oversight of climate-related risks and opportunities
  2. Management’s role in assessing and managing climate-related risks and opportunities.

Analysis

Eight out of fifteen companies explicitly mention that the board is responsible for overseeing climate risk. If they said the board is responsible for broader “sustainability”, “environmental issues”, or “ESG”, that is not sufficient. Two companies indicated that Climate-related issues are managed by management-level appointees or committees, while responsibility for climate risks was not clearly disclosed by five companies.

Best Practice

Anglo American’s description of its board processes for overseeing climate change touches on all the key areas under the TCFD’s guidance including how the board monitors and oversees progress against goals and targets for addressing climate-related issues.

Extract from Anglo American’s Climate change: Our plans, policies, and progress report, 2016:

“Matters relating to climate change and energy are included in each quarterly report to the committee, and also feature periodically as stand-alone items on the agenda. Matters discussed by the Committee in 2016 are disclosed on page 18 of the 2016 Anglo American Sustainability Report. The Chari of the Sustainability Committee provides a summary of the Committee’s discussions at the Board, which addresses the most material issues raised by the Committee. The CEO performance scorecard and reports to the Board also include performance indicators on energy and GHG emissions.

In addition to the discussions at the Sustainability Committee, the Audit Committee reviews the company’s material risks, including climate change, twice a year. The Remuneration Committee takes into account financial as well as sustainability indicators in its decision-making process.”

Remuneration Policy

Ensuring that senior executives are incentivised to behave appropriately with respect to climate change is a key governance issue. Incorporating climate-related performance indicators into executive remuneration should assist in holding management to account by aligning incentives with long-term strategy.

Does the remuneration policy include performance metrics used to measure and manage climate-related risks?

No10 Yes4 Unclear1

Recommended Disclosure (a), under Metrics and Targets*

The TCFD recommends that the key metrics used to measure and manage climate-related risks are disclosed and, where climate-related issues are material, whether and how these performance metrics are incorporated into remuneration policies is described.

Analysis

Only four out of the fifteen companies considered in this report have a remuneration policy that includes performance metrics relating to emissions reduction. This is despite the fact that the majority of companies report offering incentives for the management of climate-related issues in their CDP disclosures.

Climate-related performance metrics might include energy or emission reduction targets. These targets and metrics are usually provided in the Annual or Integrated Report, but CDP disclosures also provide additional information

* This disclosure is covered under the Core Element ‘Metrics and Targets’ in the TCFD Recommendations. It has been analysed under ‘Governance’ for the purposes of the Full Disclosure 5 report.

Best Practice

Eni’s Path to Decarbonisation report provides a clear description of how related performance metrics are incorporated into remuneration policies.

“The CEO’s Short-Term Incentive Plan (STI) includes objectives associated with climate strategy that are consistent with the guidelines defined in the Strategic Plan. Under the Short-Term Incentive Plan, a portion of the bonus matured is deferred over a three-year period, subject to further performance conditions, in order to assess sustainability over the medium term. In particular, 25% of the STI is composed by environmental sustainability and human capital objective, half of this refers to reducing the GHG emissions intensity rate of operated hydrocarbon production, in line with the 2025 target announced to the market. This objective is also assigned to top management and managers with responsibilities associated with the emissions reduction.

Strategy

Disclosing the actual and potential impacts of climate-related risks and opportunities on the banks’ and emitter’s businesses, strategy, and financial planning.
TCFD Guidance on Strategy

Key Findings

In 10 out of 15 companies assessed, climate-related risks are viewed as a “material business risk”. The TCFD recommends that these companies disclose the impact of the climate risks on their business, strategy, and financial planning.

Only African Rainbow Minerals, Sappi, and South32 set out how short- medium- and long-term climate-related risks will impact their business, strategy, and financial planning, in their publicly available (mainstream) annual reports.

Six (out of 15) companies disclose how climate risks and opportunities are incorporated into their strategy through efforts such as mitigation, adaptation, resource efficiency, pollution reduction and transition plans.

Out of all 15 companies, ArcellorMittal and ABSA bank do not disclose a strategy for mitigating climate related risks, despite identifying climate change risks for their businesses (albeit to a limited extent).

Only Anglo American and South32 sufficiently describe the scenarios used to inform their strategy. Sasol uses its own scenario but does not adequately address whether its strategy is based on a 2°C or lower scenario, nor does it adequately address areas such as critical inputs and assumptions, timeframes, and potential implications recommended by the TCFD.

12 companies do not describe the scenarios used to inform their strategies, casting doubt over whether their strategies (if any) are sufficient to address climate-related risks.

Risk Disclosure

The companies considered in this report are likely to be highly exposed to climate risks and opportunities as either major greenhouse gas emitters or through their lending activity. Information on what risks and opportunities these companies face and how they affect the organisations’ business, strategy, and financial planning can be used to inform investors’ expectations of the future performance of the companies.

Does the company identify climate change as a material business risk?

Yes10 No5

Additional Disclosure

The TCFD recommends that companies disclose “the actual and potential impacts of climate-related risks and opportunities on the organization’s businesses, strategy, and financial planning where such information is material”.

Analysis

Ten out of fifteen companies assessed explicitly mentioned as a material or principal risk in the annual or integrated report, while the remaining five do not.

The TCFD recommends that companies should not “prematurely conclude that climate-related risks and opportunities are not material based on perceptions of the longer-term nature of some climate-related risks.”

Has the company outlined the risks and opportunities from climate change?

CDP only8 Limited4 Mainstream reports3

Recommended Disclosure (a)

The TCFD recommends that an organisation describes the climate-related risks and opportunities that it has identified over the short, medium and long term and the impact that they will have on businesses, strategy and financial planning.

Analysis

Climate-related financial disclosures should be provided in mainstream annual financial filings.

Three out of fifteen companies assessed provide detailed disclosure, including timeframes and impacts, with timeframes in mainstream annual reporting, while eight provide their disclosures in their CDP reports. The remaining four provide detailed disclosure in their CDP with some disclosure in mainstream reports, but there is limited detail on timeframes and/or impacts provided.

Best Practice

South32 provides a clear description of its climate-related risks and opportunities in its Approach to Climate Change 2018. This covers policy issues, such as carbon pricing; legal issues such as litigation risk; reputation; shareholder action; technology changes; market changes; and physical risks. These are presented in a table and include time horizons.

Topic Time Horizons Most Relevant Scenario Risks Mitigation and Opportunities
Policy Short, medium and long term

Medium and long term

GC [Global Cooperation (two-degrees)]

RCC [Runaway Climate Change (four degrees)]

Carbon pricing policies including carbon taxes, cap and trade systems and any other regulatory carbon pricing mechanisms may increase costs for companies with liable carbon emissions. We include a short-run regional and long-run global carbon price in our capital allocation and investment evaluations. This contributes to effective and well-informed decisions to manage risks beyond current pricing policies.

Further detail is provided on page 19.

In addition, our voluntary carbon emission reduction targets drive internal processes to identify, evaluate, and implement a range of operational emissions reduction projects on an ongoing basis.

Short, medium and long term

Medium and long term

GC

 

RCC

As our stakeholders, including customers and suppliers, are likely to be subject t similar changes in policy, we may face changing commercial requirements to meet regulatory changes in jurisdictions outside of our own operating environments. Our scenario analysis incorporates potential policy-based impacts on our supply chain to test resilience of our portfolio to these risks. Insights gained from this process are used as an input into our ongoing strategic plans.

We have also calculated and disclosed our annual Scope 3 emissions to ensure that we are aware of the scale and sources o our supply chain emissions. Further detail is provided on page 10.

Short, medium and long term

Medium and long term

GC

 

RCC

Water and biodiversity regulation may become more stringent as pollution concerns or scarcity pressures increase. Through our focus on innovation and technology, we are working to reduce our land requirements, biodiversity impacts, waste, carbon and water usage over time. As our internal voluntary performance standards drive resource efficient operations, we aim to be ahead of policy change and avoid the risk that more stringent future policies could pose.
Legal Medium and long term GC and RCC Increased litigation against governments and companies, either seeking compensation for damages caused to them because of climate change impacts or to force greater action on climate change. We consider that our proactive approach to climate-related risk assessment, risk management and disclosure, along with our diversified portfolio, assist in minimising our relative exposure to climate change-related litigation. However, we monitor legal developments in this space and seek advice on major developments when required.

Strategies and Resilience

According to the TCFD, “the disclosure of organisations’ forward-looking assessments of climate-related issues is important for investors and other stakeholders in understanding how vulnerable individual organisations are to transition and physical risks and how such vulnerabilities are or would be addressed.”

Does the company describe how its strategy might change to address climate change risks and opportunities?

Limited7 Yes6 No2

Recommended Disclosure (b)

The TCFD recommends organisations describe how resilient their strategies are to climate change and that they consider disclosing how their strategies might change to address climate-related risks and opportunities.

Analysis

Six out of the fifteen companies assessed disclose how climate risks and opportunities are incorporated into strategy through efforts such as mitigation, adaptation, resource efficiency, pollution reduction and transition plans. Seven provide limited disclosures with some disclosure of how climate risks and/or opportunities are incorporated into strategy, but with insufficient detail. Two companies do not disclose any details of how climate risks and opportunities are incorporated into their business strategies.

Does the company describe the climate change scenarios used to inform strategy and financial planning?

No12 Yes2 Limited1

Recommended Disclosure (c)

The TCFD recommends that organisations describe “how resilient their strategies are to climate-related risks and opportunities, taking into consideration a transition to a lower-carbon economy consistent with a 2°C or lower scenario and, where relevant to the organization, scenarios consistent with increased physical climate-related risks.”

Analysis

Companies should present three or four scenarios, including a “2°C or lower” scenario, which is a scenario aligned to the objectives of the Paris Agreement to hold the increase in the global average temperature to 2°C above pre-industrial levels. The TCFD also recommends that Nationally Determined Contributions (NDCs), which are the goals of each country to reduce national emissions under the Paris Agreement, as another useful scenario, particularly “in jurisdictions where NDCs are a commonly accepted guide for an energy and/or emissions pathway”, which is arguably the case in South Africa.

Only two of the fifteen companies assessed describe the range of scenarios used (including a 2°C or lower scenario), critical inputs and assumptions, timeframes, and potential implications., in their scenario analysis. One company discloses that scenarios are used, but only limited descriptions are provided and does not describe whether a 2°C or lower scenario is used.

Concerningly, the majority of companies do not provide any indication of “how resilient their strategies are to climate-related risks and opportunities, taking into consideration a transition to a lower-carbon economy consistent with a 2°C or lower scenario.”

Best Practice

Citi Group, which is one of 16 banks participating in the UN Environment Finance Initiative (UNEP-FI) banking sector TCFD pilot project, released its first climate disclosure report in November 2018. The Finance for a Climate-Resilient Future report provides climate scenario analysis of both transition risks and physical risks. Citi is one of the first banks to provide climate scenario analysis, which considers both transition and physical risks.

BHP Billiton’s Our Climate Change: Portfolio Analysis (2015) and Climate Change: Portfolio Analysis – Views after Paris (2016) provide detailed scenario analysis. This includes an assessment of the potential impact on long-term commodity demand in a 2°C world and the potential impact on earnings before interest, tax, depreciation and amortisation (EBITDA).

Risk Management

Disclosing how banks and identify, assess, and manage climate-related risks.
TCFD Guidance on Risk Management

Key Findings

Of the 15 companies considered in this report, most (12) describe their process for managing climate-related risks. They explain how decisions to mitigate, transfer, accept or control these risks are made.

At Sappi and Exxaro, there is no evidence that climate-related risks form part of company-wide risk management programme or specific climate-related risk management process.

Risk Identification, Assessment, and Management

Companies should set out the processes that are followed for identifying, assessing, and managing their climate-related risks. These processes may be scrutinised by investors and stakeholder to ensure the accuracy, legitimacy, and effectiveness of the organisation’s risk profile and risk management activities.

Does the company have a process to manage climate-related risks?

Yes12 No2 Unclear1

Recommended Disclosures (a), (b) & (c)

The TCFD’s recommended disclosure is for the organisation’s processes for managing climate-related risks to be described, including how decisions to mitigate, transfer, accept or control these risks are made.

Analysis

The majority of companies considered in this report (twelve out of fifteen) have a risk management process to manage climate-related risks and disclose that climate-related risks form part of company-wide risk management programme or specific climate-related risk management process.

Best Practice

Eskom states “Strategic risks, which are most significant in affecting our ability to achieve our strategic objectives, are identified at organisational level.” “Divisions are responsible for identifying and managing business risks as well as the strategic risks allocated to them. All risks, including emerging risks, are considered by the Board, through ARC.” (IR 2019, p 49) “Inability to meet climate change mitigation targets impacting our licence to operate’ and ‘Failure to implement climate change adaptation measures, which could affect plant performance’ are strategic risks” (IR 2019, p 54)

At Nedbank, Climate change is categorised as a business risk and reputational risk (IR2018, p 37), which are two of Nedbank’s top 10 risks. “The board, through the Group Risk and Capital Management Committee, governs risks across the bank’s Enterprise wide Risk Management Framework (ERMF), which includes the risk strategy, policies, procedures, limits and exposures, among others. ” (IR2018, p19)

Metrics and Targets

Disclosing the metrics and targets used to assess and manage relevant climate-related risks and opportunities.
TCFD Guidance on Metrics and Targets

Key Findings

Seven companies have an absolute target to reduce greenhouse gas emissions, while Exxaro has uses an intensity target. Seven companies do not have any target for reducing their emissions at all.

Four of the 15 companies have long term targets that extend to 2025 and beyond. Notably, Eskom, which emits most of South Africa’s greenhouse gases, has no target to reduce its emissions.

14 out of 15 companies disclose their direct, and indirect emissions, which is a necessary metric for determining risks and the strategy to mitigate those risks. 11 companies also disclose the indirect emissions from their value chains.

Eskom only discloses its direct emissions. This means that the emissions from the generation of purchased energy (such as from coal IPPs) and business activities (such as transport and distribution and business travel) are not reported.

Emissions and Reduction Targets

Companies should report on the current extent of their greenhouse gas emissions, and their targets to reduce emissions. This information can help stakeholders understand how a company measures and monitors its climate related risks as part of their mitigation strategies.

According to the TCFD, “organizations with significant emissions are likely to be impacted more significantly by transition risk than other organizations. In addition, current or future constraints on emissions, either directly by emission restrictions or indirectly through carbon budgets, may impact organizations financially”.

Does the company disclose its GHG emissions?

Scope 1, 2 and 311 Scope 1 and 23 Scope 11

Recommended Disclosure (b)

The TCFD Recommends the disclosure of Scope 1, Scope 2 and, if applicable, Scope 3 GHG emissions. It is suggested that historical data and “generally accepted industry-specific GHG efficiency ratios” are provided.

Analysis

Eleven of the fifteen companies assessed report on their Scope 1, 2 and 3 emissions for the current year and at least the previous year.

Scope 1—Direct emissions from owned or controlled sources;
Scope 2—Indirect emissions from generation of purchased energy;
Scope 3—Indirect emissions in the value chain of the reporting company such as those from business activities such as purchased goods and services, business travel; use of sold products; transportation and distribution.

Scope 3 emissions, which are indirect emissions in both the upstream and downstream value chain, are regarded as particularly important in high-emitting sectors as these are central to their lifecycle carbon footprints and mean that they have high exposure to regulation of emissions. The Science Based Targets Initiative requires a Scope 3 target if these emissions represent more than 40% of an organisation’s overall emissions.

Three of the companies report only their Scope 1 and 2 emissions for the current year and at least the previous year, while one company only reports its Scope 1 emissions.

Has the company set GHG emission reduction targets?

No7 Absolute7 Intensity1

Recommended Disclosure (c)

The TCFD recommendations call for the disclosure of key climate-related targets such as those relating to GHG emissions, water usage and energy usage.

Analysis

GHG emission reduction targets can be absolute or intensity-based. Absolute targets are stronger as, under an intensity target, emissions can increase as along as emission intensity decreases.

Seven out of the fifteen companies assessed indicate that they use stronger, absolute targets for reducing their greenhouse gas emissions. While one company uses as intensity-based target, the remaining seven do not have a target in place at all.

Is there a long-term GHG emission reduction target?

No11 Yes4

Recommended Disclosure (c)

The TCFD indicates that organisations should consider including the timeframes over which the target applied. Long-term targets are considered to be those over five years.

Analysis

Only four out of the fifteen companies assessed have an absolute or intensity-based target over five years in duration.

The lack of long-term energy reduction targets makes it difficult to assess alignment with the draft post-2015 National Energy Efficiency Strategy (NEES), which calls for a 16% reduction in the manufacturing sector by 2030 relative to a 2015 baseline and a total annual energy saving of 40PJ by mining companies. The 2005 NEES required a 15% energy reduction in the industrial and mining sectors by 2015 relative to a 2000 baseline. According to Sasol, industry voluntarily agreed at the end of 2015, when the 15% reduction target expired, to an additional 1% annual reduction.

None of the companies covered in this report have set a science-based target approved by the Science Based Targets initiative. A science-based target is “in line with the level of decarbonisation required to keep global temperature increase below 2 degrees Celsius compared to pre- industrial temperatures, as described in the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC AR5).”

The methodology for science-based targets is still under development for a number of sectors, including financial institutions, and chemicals and petrochemicals, but this does not prevent a company from publicly committing to set a science-based target.

Best Practice

South32, which has set a target of being carbon neutral by 2050, highlights its plans for decarbonisation in its Approach to Climate Change 2018 report.

These plans, which are still under development, will initially focus on its GHG-intensive operations at Worsley Alumina and Illawarra Metallurgical Coal, which account for around 60% of its current Scope 1 emissions. The plans will assess potential use of low carbon technology and alternative energy sources and identify investment requirements for each operation. These will be integrated into business and project plans, while residual emissions will be offset.

Does the company provide their internal carbon price?

No13 Yes2

Recommended disclosure (a)

The TCFD calls on organisations to provide their internal carbon price where relevant. A price on carbon is considered to be one of the best ways to cut carbon emissions and meet the Paris’ agreements target of holding global average temperature increases to 2°C.

Analysis

A price on carbon can shift the social and economic externalities created by carbon emissions on to the party responsible for the emissions. South Africa’s Carbon Tax law will imposes a carbon price on emitters, but using an internal carbon price can improve investment decisions and aid planning.

Although CDP submissions indicate that several companies are using an internal carbon price to improve investment decisions and aid planning, only one company provides any detail on this in its mainstream reports.

Best Practice

South32 provides a ‘Scope 3 Greenhouse Gas Emissions Methodology’ report that clearly sets out how its Scope 3 emissions are calculated. This includes inclusions, exclusions, the rationale, data sources, and calculation method.

Shell’s 2017 Sustainability Report provides “10 years of comparable GHG emissions data with an accompanying explanation of the scope (including omissions), methodology (including the standard applied and emission factors used) and boundary (equity and operational control basis)”. It also shows how acquisitions, reduction activities, change in output and divestments affected GHG changes between 2016 and 2017

The CDP’s 2017 Putting a price on carbon report notes that “corporate disclosure of details about the scope of a company’s emissions the metric is applied to, the degree of influence it has on decision-making, and the impact it has already had (i.e. has it shifted capital towards energy efficiency measures, low-carbon initiatives, energy purchases, or product offerings?) will further support an investor’s ability to assess the depth of a company’s internal carbon price.”

The report highlights French utility ENGIE as a company that is disclosing how its internal carbon price impacts on business decisions. ENGIE’s CDP 2017 submissions states that it “has decided to no longer pursue new developments in coal, believing that a carbon price will steadily be established in the world’s various regions and that coal-fired power plants will be adversely affected in the future.”

Additional Information

Banks

Does the bank have a publicly-available policy on funding coal mining and coal-fired power?

No3 Partial2

Additional Disclosure

Over 100 major global financial institutions have introduced policies restricting financing of either coal-fired power stations or thermal coal mining. Under pressure from civil society and other stakeholders, several of the banks covered in this report have announced that they will no longer provide funding to two new coal-fired independent power producers (IPPs).

Analysis

Three of the five banks assessed have a publicly-available policy in place to address funding of coal mining and coal-fired power. The remaining two have a publicly-available policy addressing either funding of coal mining or coal-fired power.

Major Emitters

Does the company disclose its participation in the DEA's voluntary carbon budget programme?

Yes7 No2 CDP only1

Additional Disclosure

The Carbon Tax Act provided for various allowances up to a maximum total percentage. Participation in the DEA’s voluntary carbon budget programme provides for a 5% allowance.

Analysis

The Department of Environmental Affairs’ (DEA) voluntary carbon budget programme is being run ahead of the introduction of mandatory budgets, which is expected after 2021. Participation results in an additional 5% allowance under the Carbon Tax. However, there is also minimal information provide by either government or the participating companies on the voluntary carbon budget programme, particularly in terms of how the budgets were calculated, which companies are participating and performance against the budgets.

Seven of the ten greenhouse gas emitters assessed disclose their participation in their mainstream reports, while one discloses its participation in its CDP submissions. The remaining two do not disclose their participation in the voluntary carbon budget programme.

Does the company disclose the extent of liability under the carbon tax?

Partial5 CDP only4 No1

Additional Disclosure

The Carbon Tax, which was introduced in June 2019, imposes a tax on GHG emissions at the base tax rate of R120 per tonne of CO2e. The rate will increase at CPI+2% until 31 December 2022 and at CPI after this date.

Analysis

None of the ten greenhouse gas emitters assessed disclosed their liability under the Carbon Tax with additional information on whether the rate being used is R120/tonne of CO2 or is the rate after various allowable deductions. Five partially disclosed their liability in their mainstream reports – they did not provide any additional information on the rate used. Four only disclosed their partial liability in their CDP submissions.