Letter to the Society of Lloyd’s on ESG guidance and transparency in climate change policy

Letter to the Society of Lloyd’s regarding transparency in climate change policy

In October 2021, the Society of Lloyd’s (the “Society”) announced a new commitment for the Lloyd’s market to achieve net-zero emission by 2050. However, the Society has not published the detail of the action it is asking market participants to take to meet that commitment. That detail was included in ESG guidance issued to Lloyd’s managing agents, but the Society has (to date) not made that guidance public.

This letter from ClientEarth to the Society:

• Calls on the Society to be transparent in its climate policies, including by disclosing its ESG guidance.
• Warns the Society that making its public net-zero commitment, without providing the underlying detail of what the commitment involves, can risk greenwash and misleading the public around the nature and credibility of the climate action being taken. The Society’s public statements on its net-zero commitment indicate that it is taking effective action to transition the Lloyd’s market to net-zero on a science based pathway, but (absent publication of the guidance) there is no way of checking whether Lloyd’s is actually doing so.
• Asks the Society to set the public record straight on whether the targets set in its ESG Report 2020 for exiting certain fossil fuels (coal, tar sands and Arctic oil) are still part of its climate policies. Recent statements suggest that Lloyd’s may no longer be committed to these targets, but the Society has not clearly confirmed whether it has departed from them.
• Summarises the legal duties on the Society and Lloyd’s Council members to: (a) not mislead in relation to their climate action; and (b) set and disclose a credible climate policy, as well as the risk of breaching those duties if the underlying detail of Lloyd’s policies does not fully reflect their public commitments.

• Sets out some minimum standards that any net-zero commitment by the Society should fulfil, based on its legal duties.