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CSO.
Quarterly – Oversees implementation of the Climate Action Plan, including the integration of climate-related regulation into business operations. – Oversees the Net-Zero Program, which is coordinated by the Net-Zero Steering Group. – Is supported by the Sustainability and Climate Implementation Group, which (monthly) brings together the key experts and practitioners from the business divisions and Group Functions.
– Establishment and implementation orchestration of the firm’s climate action plan, further integrating the TCFD recommendations and other climate-related matters throughout the Group.
Group Risk Control (GRC) GCRO Ongoing – Develops and implements principles and an appropriate independent control framework for SCR within the firm and is responsible for its integration into the firm’s overall risk management and risk appetite frameworks. – Oversees SCR activities, including the climate risk program.
– Continued development of the climate risk program and the SCR policy framework.
ESG Disclosure Forum Sustainability CFO Every six weeks – Identification, oversight and coordination of sustainability-related reporting and disclosure requirements.
– Review and analysis of forthcoming / evolving sustainability disclosure regulations and their pertinence to the firm.
ESG Data and Methodology Forum.
ESG Chief Data Officer (Chief Sustainability Office)
Monthly – Develops and implements UBS’s ESG data strategy in line with the firm’s overall data strategy.
– Adoption of ESG data and metrics governance. – Implementation of group-wide market data sourcing and mastering strategy. – Development of high-quality and re-usable ESG data sets. – Definition of a strategic ESG data & reporting architecture.
Sustainability and Climate Risk Program.
CRO for Sustainability Ongoing – Integrates sustainability and climate risks into the firm’s risk management framework and standard processes.
– Further implementation of a multi-year transformation initiative to focus on delivering to regulatory expectations of climate risk into risk management and stress-testing frameworks.
Nature Working Group Head External Engagement (Chief Sustainability Office)
Every three weeks – Considers nature / biodiversity policy, regulatory and market developments. – Supports the business divisions and Group Functions in developing nature- and biodiversity-related activities.
– Update of 2021 Statement on Nature. – Beta releases of the Taskforce on Nature-related Financial Disclosures. – Policy, regulatory and market developments connected to the COP 15 Biodiversity meeting.
Sustainable Finance Group CSO.
Convened by Lead Sustainable Finance.
Monthly – Discusses sustainable finance activities and initiatives across the firm, bringing – Sustainable finance market, industry and regulatory key trends and developments.
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Governance body.
Lead and other membership information.
Sustainability / climate agenda frequency.
Purpose and responsibilities related to sustainability- and climate-related issues.
Topics considered in 2022.
Group (Chief Sustainability Office) together key sustainable finance and investing leads from the business divisions. – Supports and orchestrates development of cross-divisional sustainable finance business initiatives, as well as enabling capabilities.
– Sustainable finance business priorities 2022 and objectives 2023. – Sustainable finance product guidelines and framework. – Commercial themes and initiatives. – Sustainable finance product / solutions offering. – Sustainable finance metrics and reporting (internal / external). – Sustainability training.
Sustainability Advisory Group CSO.
Convened by Head External Engagement (Chief Sustainability Office)
Monthly – Discusses sustainability initiatives across the firm, bringing together key sustainability leads from Group Functions.
– Risk frameworks for sustainable finance. – Partnerships for key sustainability related activities (e.g., net zero). – Communications activity and other stakeholder engagement.
CDIO Management Team.
GEB Lead for CDIO Semi-annually at least – Oversees CDIO strategy for operational sustainability. – Reviews environmental performance of the firm. – Signs off on operational sustainability objectives and targets.
– Sustainability objectives for 2023. – ISO 14001 external audit results. – Climate action plan.
GCS Management Forum.
Head of CDIO Group Corporate Services (GCS)
Quarterly – Oversees GCS strategy for operational sustainability. – Reviews environmental performance of the firm. – Proposes operational sustainability objectives and targets for sign-off to the CDIO management team.
– Operational action plans for the individual global environmental goals.
– Sustainability objectives for 2023.
– Result from ISO 14001 external audit.
– Climate action plan.
Sustainable Finance Forum Personal & Corporate Banking (P&C) / Wealth Management Switzerland (WMCH)
Chief Operating Officer P&C and Region Switzerland jointly with the Chief Risk Officer P&C.
Quarterly – Oversees and facilitates the sustainability strategy and its implementation across the Personal & Corporate Banking segments and Wealth Management Switzerland, in alignment with the goals and ambitions of the Group. – Reviews supporting strategic sustainability partnerships and collaborations. – Fosters alignment and collaboration across segments and aligned functions.
– Net zero. – Sustainable lending operating model.
AM SI Prioritization Forum.
Head of Sustainable Investing, Executive Team functional heads.
Quarterly, adhoc as required – Steers and guides the SI strategy program within AM. – Sets key priorities, direction and key decisions to be adhered to by the SI program. – Provides guidance on strategic alignment of ESG-related regulatory requirements.
– Net zero. – Product shelf. – Impact capability. – Client reporting. – Regulatory disclosure.
Asset Management (AM) Stewardship Committee.
Head of Investments Quarterly, adhoc as required – Provides oversight of the proxy voting standards / process and corporate governance practices in accordance with the Asset Management proxy voting policy and procedures.
– Approved and resolved where needed, proxy votes proposed to deviate from UBS Proxy Voting policy guidelines.
AM SI Methodology Forum.
Head of Sustainable Investing Quarterly, adhoc as required – Provides oversight of methodology / investment process criteria applied in the Sustainable Investing framework (including exclusions, ESG integration, sustainable focused and impact offering) across investment areas.
– Regulatory investment process criteria. – Policy updates. – Net zero and other frameworks / methodologies.
Global Wealth Management (GWM) SI/II Forum.
Chief Investment Office (CIO) Quarterly – Drive the Global Wealth Management SI/II franchise. – Acknowledge ambitions.
– Provided input into various aspects of the franchise, including products and strategy. – Ambition setting.
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Governance body.
Lead and other membership information.
Sustainability / climate agenda frequency.
Purpose and responsibilities related to sustainability- and climate-related issues.
Topics considered in 2022.
GWM Sustainability Scores Methodology Board.
CIO At least annually – Discuss and decide on material changes to the methodology underlying the CIO sustainability scores.
– Development of SDG-alignment scores. – Further integration of climaterelated data in CIO sustainability scores.
Investment Bank (IB) Management Team.
President Investment Bank At least quarterly – Reviews the Investment Bank’s sustainability strategy and related objectives, including DE&I, climate, etc. – Monitors the Investment Bank’s progress against its sustainability strategy and related objectives. – Monitors the Investment Bank’s execution of the firm’s overall climate strategy, including the net-zero commitment.
– Diversity, equity and inclusion. – Sustainability strategy and progress. – Net-zero commitment and associated implementation steps. – Changes to SCR policy. – Regulatory developments pertaining to sustainability and finance. – Non-financial risks in relation to Sustainable Finance. – Sustainable finance. – Training and employee awareness regarding sustainability and sustainable finance.
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Controlling risks and metrics.
GCRG Sustainability Expert Group.
Our Group Compliance, Regulatory & Governance (GCRG) function is responsible for the ongoing monitoring of the adequacy of our control environment for non-financial risks (NFR) and sets out requirements for the design and operation of 1st LoD (Line of Defense) and 2nd LoD controls across Operational Risk, Compliance and Financial Crime Prevention. GCRG is actively engaged across UBS’s Risk Committee structure and supervisory board governance. It drives the review and, where necessary, the required adaptations to our NFR frameworks to align the independent control and oversight capabilities with existing and new regulations and changes across business activities.
In 2022, GCRG established the Sustainability Expert Group (the SEG, with senior representatives from across the divisional, regional and functional GCRG units, supported by senior experts across Group Legal, Group Risk Control, Sustainability CFO and Group Sustainability and Impact. In 2022, we focused our activities on initiating a range of enhancements to our ESG NFR risk assessment and process control coverage whilst undertaking appropriate reviews of the integration of ESG factors into the NFR control framework. This included considerations relevant to the consistent assessment, monitoring and escalation of high inherent reputational risk – incorporating ESG factors.
In this context GCRG maintains a quarterly dynamic ESG NFR Assessment, which acts as both the basis for its global view on ESG NFR in UBS, as well as a key input for the decision-making for the SEG priorities and associated risk reviews. We performed multiple ESG-related NFR assessments, focusing in particular on the effectiveness of processes and controls designed to mitigate greenwashing risk. This included reviews of relevant framework elements such as reputational risk, as well as specific deep-dives into product lifecycle management across the business divisions, including marketing material and product disclosure. With regards to control coverage more specifically, GCRG also enhanced core global controls relating to new business initiatives, client onboarding and oversight of marketing materials related to sustainability, and integrated ESG topics into the standard regulatory change event process for firm-wide coverage. › Refer to “Non-financial risk” in the “Risk management and control” section of our Annual Report 2022 for more information.
Sustainable Finance Legal.
Global Sustainable Finance Center of Legal Excellence, a part of our Group Legal division, provides legal and strategic advice on sustainability-related matters to the GEB sponsor for sustainability and impact, the Chief Sustainability Office, the business divisions, and other group functions. The team works closely with lawyers supporting the business divisions and Group Functions.
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Our sustainability and climate risk policy framework.
Our sustainability and climate risk policy framework is embedded in our culture and it: – applies across all business divisions, Group Functions, locations, and legal entities; – is integrated into management practices and control principles and overseen by senior management; and – supports the transition toward a net-zero future.
Introduction.
The firm’s Sustainability and Climate Risk (SCR) unit (as part of Group Risk Control), manages material exposure to sustainability and climate risks. It also advances our firmwide SCR initiative to build in-house capacity for the management of sustainability and climate-related risks.
At UBS, sustainability and climate risk is defined as the risk that UBS negatively impacts, or is impacted by, climate change, natural capital, human rights, and other environmental, social, governance (ESG) matters. Sustainability and climate risk may manifest as credit, market, liquidity, and/or non-financial risks for UBS, resulting in potential adverse financial, liability and/or reputation impacts. These risks extend to the value of investments and may also affect the value of collateral (e.g., real estate). Climate risks can arise from either changing climate conditions (physical risks) or from efforts to mitigate climate change (transition risks).
Our principles and standards apply across all business divisions, group functions, locations, and legal entities. They define roles and responsibilities for 1LoD (1st Line of Defense, i.e., client and supplier onboarding, transaction due diligence, periodic know-your-client reviews), for 2LoD (2nd Line of Defense, i.e., sustainability and climate risk transaction assessments), and for the GEB (that sets the sustainability and climate risk appetite standards of the firm). Our work in key societal areas, such as minimizing effects of climate change, protecting the environment and respecting human rights, is part of this. Living up to our societal responsibilities contributes to the wider goal of sustainable development. As a global firm, we take responsibility for leading the debate on important societal topics, contribute to the setting of standards and collaborate in and beyond our industry.
Managing sustainability and climate risk is a key component of our corporate responsibility. We apply a sustainability and climate risk policy framework to all relevant activities. This helps us identify and manage potential adverse impacts on the climate, environment and to human rights, as well as the associated risks affecting our clients and us. We have set standards for product development, investments, financing and supply chain management decisions. We have identified certain controversial activities we will not engage in, and certain areas of concern where we will only engage in under stringent criteria. As part of this process, we are committed to engaging with clients and suppliers to better understand their processes and policies and to explore how climate-, environment- and human-rights-related risks and impacts may be mitigated.
Most recently, UBS has developed guidelines and frameworks for Sustainable Lending, Bond and GHG Emissions Trading Products and services. These guidelines support UBS's growth strategy for sustainable products and services and the work to ensure that sustainability-related criteria is met.