The AICD has made a submission to APRA on its draft Prudential Practice Guide CPG 229 Climate Change Financial Risks.
We were broadly supportive of the Practice Guide.
In our view, the statements in the Guide on the role of the board and risk management frameworks are generally reasonable and reflect good practice on risk management. The Practice Guide also appears to recognise the distinction between the role of the board and of management. The recognition that entities will need to scale their response to climate change risk, and particularly their use of scenario planning, according to organisational size and sector is also important.
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