#materiality

How Should Arctic Drilling Be Defined? The 3 Key Problems with Formulating Investment Exclusions

By Zuzanna Lewandowska and Dr. Kristjan Jespersen

◦ 7 min read ◦

Oil and gas development in the Arctic has long been a subject of controversies, due to the vulnerability and pristineness of the arctic ecosystem, as well as the challenges that the region faces because of climate change. In the light of growing pressure from stakeholders, legislators, and the public, an increasing number of banks, insurers, and investors have been committing to restricting financing of arctic drilling. Typically, this is addressed by formally excluding the funding of oil and gas development in the Arctic from the firm’s investment universe.

However, several key issues with the current formulations of financial actors’ investment exclusions, make the restrictions potentially ineffective in curbing oil and gas expansion in the Arctic. Firstly, the exclusions typically apply only to financing and coverage, allowing for unrestricted provision of corporate support. Secondly, imprecise financial proxies are used to specify the activity levels at which an exclusion should be applied. For example, exclusions are often based on a revenue threshold, which does not cover early-stage exploration activities that typically do not generate revenue. Lastly, most restriction policies do not refer to a specific definition of the Arctic, which allows for the use of a case-by-case approach when making financing decisions. Where a definition of the Arctic is used, justification is rarely provided for why a specific exclusion zone had been chosen.

*Arctic restriction policies of 10 banks listed among the top supporters of arctic expansionists from 2016 to 2020 (Source: Reclaim Finance, 2021).*

Problem 1: How should the Arctic be defined?

Figure 1 below shows the geographic definitions of the Arctic which arctic restriction policies are most commonly based on. It is evident that they differ significantly in terms of scope.

*Definitions of the Arctic (Source: Nordregio, 2021).*

When choosing which definition of the Arctic to use in their exclusions, financial actors are presented with a difficult choice.

Selecting a wide-reaching exclusion zone, such as the arctic region monitored by the Arctic Monitoring Assessment Programme (AMAP), helps ensure that all assets located in the Arctic are covered. This said, however, such broad exclusions place investors at risk of missing out on profitable investments in ambiguous locations such as the Barents Sea, which has been argued to not be significantly different from the Norwegian sea in terms of oil spill response preparedness or ecosystem vulnerability. This dilemma becomes especially relevant in the context of asset managers’ fiduciary duty.

At the same time, if the exclusion is based on a definition of the Arctic which is too narrow, the policy is rendered largely ineffective, as it fails to restrict the financing of arctic oil and gas projects which continue to have negative environmental and social impacts. Which definition of the Arctic should be used as basis of a restriction policy, needs to establish based on a nuanced understanding of the geographic distribution of material issues associated with oil and gas development in the area.

Problem 2: Identifying the negative impacts of arctic drilling

To be able to argue for a targeted exclusion as part of a responsible investment policy, financial actors must credibly prove that the environmental and social impacts of a given activity are particularly dire. Indeed, the discussion is still ongoing as to what extent the documented harmful social and environmental processes in the Arctic can be categorized as by-products of arctic drilling, rather than as cumulative consequences of other activities.

One of the most common environmental concerns regarding arctic drilling is that it contributes to the melting of the polar ice caps. However, research has found that while black carbon emissions from oil and gas exploration in the Arctic reduce the ice cover’s reflective properties, polar caps are primarily melting due to the increases in global temperatures. As such, one could argue that for an exclusion to significantly tackle the issue of polar ice cap melting, it should extend to investments in all fossil fuel developments worldwide.

The negative environmental impacts which have been uniquely linked to arctic drilling (e.g., offshore oil spills, black carbon emissions, and biodiversity threats) are notably difficult to capture within a territorial exclusion zone. This is due to the lack of consistent data on their dynamically changing distribution.

*Black carbon emissions in arctic waters in 2015 (Source: ICCT, 2019).*

The issue with addressing the negative social impacts of arctic drilling (e.g., land conflicts, threats to food security) in an exclusion policy, is that similar issues are faced by local and indigenous populations in other vulnerable areas, where oil and gas extraction also takes place, and where investments are not subject to restrictions. Here, a notable example would be the Amazon.

An additional complication results from the differing perspectives on arctic oil and gas development, with many local stakeholders crediting it with having improved infrastructure and employment opportunities in the region.

Problem 3: A double materiality perspective – addressing the risks to oil and gas development operations in the Arctic

From a risk management perspective, a comprehensive investment restriction policy should also account for the unique material risks to profitability of oil and gas projects in the Arctic, which make financing and coverage more volatile. This also falls in line with the double materiality approach to impact assessment.

The most significant material risks to oil and gas operations which are distinctive to the Arctic are caused by permafrost thawing, sea ice and icebergs, and extreme weather conditions. Similarly to negative environmental impacts, the dynamic nature of these arctic risk factors makes them difficult to capture within a geographic exclusion zone.

*The monthly arctic sea ice index for December 2021 (Source: National Snow & Ice Data Center).*

What have we learned?

Based on the discussion of the complexities associated with arctic exclusions, it can be concluded that the weakness of key financial actors’ arctic policies is that they deploy ex ante investment restrictions as standalone policy solutions. Arguably, exclusions can be an effective instrument, but only as part of a comprehensive responsible investment strategy, which covers all stages of the investment process and addresses the extensive information needs regarding material issues.

A well-formulated exclusion can help streamline the pre-investment negative screening process by filtering out investments which:

Have been proven to be associated with unique material risks and negative impacts,
Can be identified with high precision, accounting for the dynamic changes and complexities in the underlying material issues.

Those of the material risks and impacts which cannot be captured in an exclusion policy should be addressed using other pre-investment (positive and negative screening, information requests and questionnaires) and post-investment (active ownership and thematic engagements) measures.

Such a nuanced approach to policy exclusions could provide a powerful responsible investment tool for financial actors in areas and sectors which require additional due diligence.

About the Authors

Zuzanna Lewandowska is a student researcher in ESG and Sustainable Investments at Copenhagen Business School. She studies responsible investment strategies and the state of the art of measuring and reporting information on ESG factors. She has a background in international business and strategy, global market intelligence, and policy consulting.

Kristjan Jespersen is an Associate Professor at the Copenhagen Business School. He studies on the growing development and management of Ecosystem Services in developing countries. Within the field, Kristjan focuses his attention on the institutional legitimacy of such initiatives and the overall compensation tools used to ensure compliance.

Photo by Annie Spratt on Unsplash

Adventures in Materiality. Notes from the first CBS Sustainability Seminar

By Steen Vallentin.

On October 31, 2017 the new CSB Sustainability seminar series was launched
With a room full of practitioners and academics, the topic “Materiality and Quantification” in CSR and sustainability reporting was discussed
Diverse input for discussions were given by presentations by CBS, DTU and a practitioner in corporate sustainability reporting

Approximate reading time: 4-5 minutes

All we need is Materiality?
Materiality is arguably gaining significance in corporate approaches to CSR and sustainability. While strong narratives remain important, they do not suffice in a world filled with increasing amounts of data calling for transparency and factual assessment of corporate accomplishments, progress or decline. There can, however, be a price to pay for an increasing reliance on metrics and measurements. What happens to ethical and moral concerns, to fundamental values and the sense of overall purpose if CSR/sustainability is reduced to a technical matter of taking numbers and ticking boxes? This was the topic of the first in a new series of CBS Sustainability Seminars. Here is some background on the topic and the seminar series, plus some notes on the presentations of the day.

The rise of materiality in CSR and sustainability
Sustainability reporting and efforts to assess the materiality of corporate responsibilities toward the people and the planet are undergoing interesting transformations these years. Not only is sustainability reporting becoming a more and more widespread practice internationally, due to mandatory disclosure requirements and the institutionalization of standardized reporting formats such as GRI and integrated reporting. We are also, among other developments, witnessing corporate efforts to integrate adherence to the UN Sustainable Development Goals into non-financial reporting formats, including materiality assessment, and companies committed to set and communicate science based emission reduction targets (see Science Based Targets).

The new cbsCSR sustainability seminar series: research-based & multidisciplinary
Hence, “Materiality and Quantification” was an obvious choice as topic for the first event in the new series of CBS Sustainability seminars that will be taking place from the Fall of 2017 and onwards. The inaugural seminar took place on October 31 and featured three speakers: Professor Andreas Rasche from CBS, Frances Iris Lu (CBS and Maersk) and associate professor Niki Bey from the Technical University of Denmark (DTU).

The purpose of the seminar series is to forge closer ties between researchers at CBS and professionals from companies and organizations – to enable collaboration and easier access to each other’s knowledge and resources on an ongoing basis. And to build stronger relations among researchers at CBS. The USP of the network is that it is research-based and multi-disciplinary. One aim is to help bridge divides between knowledge silos and facilitate dialogue between different knowledge disciplines. Another aim is to broaden the scope of how we think and speak about sustainability, and to explore how far we can take this concept – in different indicated by its three pillars: environmental, economic, social. To this end, the seminar series will present many speakers from CBS and other research environments that would not ordinarily see their research as part of a sustainability agenda.

Materiality assessments are no moral assessments
In the first seminar, however, we were on familiar ground with regard to sustainability. Based on a forthcoming research paper (using data from the Netherlands and co-authored with Koen van Bommel and André Spicer), Andreas Rasche showed how sustainability reporting has gradually developed into being a more and more standardized and technical practice. A key concept in this research is commensuration, which refers to the process of transforming different qualities into a common metric. It reduces and simplifies ‘thick’ information into metrics that are comparable to other metrics. Over time, commensuration stimulates a standardization of the meaning of sustainability. When something is turned into a metric and standardized, it often leads to a crowding out of moral questions and concerns. Subsequently, sustainability reporting can be a driver of ‘amoralization’ processes by which questions of morality, values and purpose are replaced by technical performance measures. On the one hand, this technical and instrumental turn can be part of the explanation for why sustainability reporting has become so popular (because it sidelines ambivalence and difficult moral quandaries). This need not be an entirely negative outcome, as pointed out by a participant, because it can be an indicator of increasing business integration of sustainability. We do, however, on the other hand, need to be aware of the possible downsides of this proposed ‘technicalization of sustainability’.

Moving beyond ethical idealism – the price to pay for conquering the mainstream?
While this finding is based on a longitudinal empirical study, I have made a similar point in a conceptual paper reflecting on the effects of instrumentalization in the realm of CSR more broadly. To quote myself (at length):

“As a result [of instrumentalization], it is now all too easy to speak of CSR without making any mention of ‘ethics’ or bringing up moral issues or dilemmas; a development that can lead to a strangely depersonalized understanding of responsibility and which raises questions about the relevance of ethics for CSR altogether. Whether this is a problem or not is of course debatable. On the one hand, it can be considered as a sign of progress in the sense that the CSR debate (and CSR as corporate practice) has decidedly moved beyond ethical idealism and the subjectivity/arbitrariness that may be associated with individual values and choices. CSR has developed into a socially embedded, highly institutionalized and material phenomenon. On the other, it is worth pondering what, if anything, has been lost on the path to (apparent) victory in the public realm of ideas. Is the displacement of ‘ethics’ a sign that the responsibility discourse has lost its normative bearings and that this has been the price to pay for conquering the mainstream?”

A practitioner’s perspective on values & materiality: We can have it all – (can we?)
Frances Iris Lu gave a presentation of the evolution of materiality and materiality assessments in recent years, drawing on her experience from KPMG and Mærsk. She showed how materiality assessments can often, in practice, be rather loose exercises bereft of analytical rigor, but also how it is possible to add more rigor to the process. One key feature (and possible limitation) of a conventional materiality assessment is that it tends to focus strongly on the risk as opposed to the opportunity side of responsibility, making it difficult to reconcile with policies aiming to create (shared) value.

To bridge this gap, and to make room for the company values in the account of materiality, Mærsk has created a new ‘materiality beyond the matrix’ model. Frances presented this new and more comprehensive and multi-faceted model which accounts for materiality under the three headings: Risk, Shared Value, and Responsibility. Challenging the amoralization narrative presented by Andreas, Frances argued that we are seeing a sort of pendulum swing taking place in sustainability right now where values and purpose are getting more attention – alongside the continued focus on metrics.

Materiality and Quantification in practice: The Life Cycle Assessment Lens
Finally, Niki Bey brought the quantification of sustainability through Life Cycle Assessments (LCA) into the discussion. LCA is used as a general framework to avoid the problem of cost shifting across impact categories (e.g. using less plastic might ultimately increase food waste). Although the LCA is never completely objective, we need to try to approach matters of sustainability systematically and to focus on available facts – how far can we get in terms of what we know and what we can measure, instead of focusing on subjective criteria.

A participant mentioned enthusiastically that the LCA is the most important decision-tool she has ever worked with because it makes people able to move up and down in perspective and allow them to see the bigger picture in regard to sustainability and corporate responsibilities. While LCA is usually applied as a relative measure that can be used to compare and choose between different courses of action, it can also be applied in an absolute fashion, as with the Planetary Boundaries.

Overall, the seminar brought out as many questions as it did answers. We look forward to continuing this and other adventurous discussions in future CBS Sustainability seminars.

Steen Vallentin is Director of the CBS Centre for Corporate Social Responsibility (cbsCSR) and Associate Professor in the Department of Management, Society and Communication at Copenhagen Business School.

Pic by Miguel A. Amutio, edited by BOS.