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Centre for Environmental Rights

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

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

The Taskforce on Climate-related Financial Disclosures (TCFD) sets out its Recommendations under four core elements. It also guides companies on how to comply with each of these elements.


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?


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 the company’s strategy to manage those risks?

Risk Management

Disclosing how banks and emitters 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 does the company use to inform its strategy and monitor progress?

Investors, banks, and the public can assess if a company is sufficiently prepared to mitigate the risks of climate change by evaluating the company’s disclosures, against the guidance provided by the TCFD, under each of these elements.

Assessment Elements

Full Disclosure 5 evaluates the disclosures of ten of the highest emitters of greenhouse gases and five banks against seventeen elements to determine if they comply with the four Core Elements of the TCFD Recommendations.

Disclosures Considered
A disclosure is a statement by the company in its annual financial reports, sustainability reports, and submissions to the Carbon Disclosure Project (CDP). These are publically available documents that companies use to notify investors, banks, and the public of their performance. We use the disclosures made in these documents to inform us of the company’s exposure to climate risks and its strategy to mitigate the risks.
Navigate the Findings
We group and consolidate the findings for each company and bank under each of the seventeen elements. These elements are presented as questions, with the results set out as answers. Each of these seventeen elements is organised under the relevant Core Elements of the TCFD Recommendations. We provide a brief description of why the element is important, a short analysis of company compliance, and an example of best practice.


Company Performance

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.

Note that our findings are accurate as at August 2019. Since then, new annual reports, sustainability reports, and CPD submissions may have been made available by the companies and banks we’ve assessed. The findings for Sasol are, however, accurate as at November 2019.