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ESG Challenge: Scott Beckerman, Comerica Interview — Transcript

by Alliance for Responsible Capitalism · 6,010 words · 893 segments · language en · Watch on YouTube

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0:03hi Scott thanks so much for taking the
0:05time to talk with me today uh could you
0:07please introduce yourself in your role
0:09at Comer and any any other introductory
0:12words you'd like to start us off with
0:15sure thank you for the opportunity first
0:17of all um I'm Scott Beckerman I am the
0:20director of corporate sustainability
0:22here at cerica bank um CER for those of
0:26you who may not be familiar we a larger
0:29Regional Bank here in the US uh with key
0:32operations in Texas California Michigan
0:36Florida and Arizona as well as a number
0:38of other states in the in the Southeast
0:41and and Mountain West so sort of an
0:43interesting footprint um but again in
0:46that that Regional Bank space uh here in
0:49the United States um as we get started I
0:52just want to share you know I've been at
0:54ker here for uh 22 years been in the
0:57role of sustainability director for
0:59nearly a Dozen Years years and have led
1:01a bank uh sustainability professional
1:04round table for about a decade so the
1:07thoughts I'm sharing today are based on
1:09that experience but I do want to
1:10acknowledge that the responses I provide
1:12are my own and it may not be completely
1:14reflective of comic overall as an entity
1:17but hopefully I can share some
1:18insightful observations based on that
1:21experience and my time in the
1:23industry thank you Scott I'm sure I'm
1:26sure you have a lot to say so let's
1:28start with what are the climate risks
1:30that CER is facing right now sure um
1:34climate risks are really kind of a
1:36multifaceted issue for us and and we
1:38also recognize that they're constantly
1:40evolving and and changing but generally
1:43we break them into the traditional
1:45categories of physical and transition
1:47risks you know physical those we
1:49typically think about around the effects
1:51of SE severe weather um know storms wild
1:54fires Etc um transition risks are those
1:57that might be triggered by regulation or
2:00in consumer preferences and all of those
2:02sorts of of risks or issues that we may
2:04face so when we think about those two
2:07kinds of risks we also have to think
2:09about um how they could impact us one
2:13one way is you know direct impact on our
2:15op operations say you know storm event
2:20um forcing us to to have to close our
2:23locations as a hurricane rolls through
2:25or a new regulation you know prompting
2:28us to have to take certain actions um
2:32but the other and probably more
2:34significant uh impact for banks is to
2:37think about how all of these risks
2:39impact our customers and then in turn
2:42how how might those customer impacts
2:44then affect us and that is certainly the
2:47more um difficult question to assess uh
2:51and one that the industry is is really
2:54you know struggling with and and
2:56diligently working on um many banks have
3:00have hundreds of thousands uh or even
3:03with the larger Banks millions of
3:05customers and understanding you know all
3:08of those different impacts depending on
3:10what type of customer are we have and
3:12and what their needs are um that's a
3:16it's a tall order um but I think it it
3:18speaks to the significance of the
3:21banking industry and the financial
3:22services industry more broadly um and
3:26and how we engage with our customers on
3:28on issues like climate
3:32out of
3:33curiosity we know the the southeast has
3:36been pummeled by a couple of nasty
3:38storms in the last couple of weeks even
3:41uh do you have any examples of how your
3:43customers have been affected or how ker
3:45operations have been affected yeah
3:48largely um we've been very fortunate and
3:51in our operations have not been um
3:54impacted other than you know short-term
3:56closures as as storms roll through um
4:00Banks being highly regulated even U you
4:02know the ability to close a bank branch
4:04for a day is is controlled by our our
4:07banking Regulators um so uh that's a a
4:11very regulated thing certainly our our
4:14customers um all customers in in those
4:17locations are impacted um their ability
4:21to prepare uh to understand the need to
4:24prepare for for severe weather events um
4:28you know I think it highlights
4:30what we saw the difference between the
4:31the storms and the impacts in places
4:33like North Carolina where they were not
4:36as
4:38um expecting of the impacts um whereas
4:42in in Florida I think they're a little
4:43bit more accustom and they're developing
4:45resilience strategies and um you know I
4:48think with with to some extent there was
4:50remarkable accuracy in some of the Storm
4:52Prediction um so we're starting to see
4:55how those things impact uh customers
4:58whether they be tradition retail
5:01customers you know homeowners and the
5:03like or or businesses which is a really
5:06important part of ofer's um business mix
5:10as well so um certainly lots of impacts
5:13but the the ability for um particularly
5:17businesses to take a resilient approach
5:20uh I think we have seen the importance
5:22of that with these with these most
5:24recent
5:25storms great thank you so what is CER
5:29syst stainability strategy and how does
5:31it account for these different
5:33dimensions of climate risk yeah it's a
5:36it's a great question so we have a
5:38longstanding and and very broad uh we
5:41call it our environmental policy
5:42statement uh which covers environmental
5:45sustainability issues and that includes
5:48of course climate change U but also
5:50resource conservation um along with
5:53transparency and accountability and
5:55touch on those a little bit more but um
5:58that's those are the elements of our of
5:59our policy statement but specifically on
6:02on climate change we we have a
6:04three-point strategy which is really
6:06number one supporting our customers so
6:09we're committed to working with all of
6:11our customers to meet their evolving
6:14needs in a greening economy whatever
6:15those needs might be um we want to be
6:18there to to support their their
6:20financial needs um you know if they need
6:23to make new Investments if they need to
6:26uh update their their existing business
6:29or or structures you know we want to be
6:31there to help facilitate that our second
6:34point is around integrating climate and
6:37and that's really about working to
6:39integrate climate matters into our
6:41strategy overall business strategy um
6:44into our lines of business and our
6:46products and services that we offer and
6:48our overall approach to risk management
6:50and and taking something like climate
6:53and embedding it across an
6:55organization um you know maybe it sounds
6:57simple but tactically there's a lot to
7:00that um to make sure that that first of
7:03all we understand what the different um
7:06elements or risks or opportunities might
7:08be and then find ways to to effectively
7:12um seize on the opportunities and and um
7:16mitigate the risk that we may have and
7:19then lastly and this is probably the
7:21we'll call it the simple one uh
7:23relatively speaking but not simple uh
7:26which is reducing our own emissions
7:27footprint so we operate uh over 400
7:31buildings um which you know have have
7:34their own set of operational greenhouse
7:36gas emissions and we've been on a
7:39long-term uh strategy to try to drive
7:41those down and um be smarter about how
7:44we operate our our facilities and and
7:47rationalizing our footprint um to reduce
7:51our own greenhouse gas emissions and I
7:53think you know by doing that and by
7:55having a history of doing that we can
7:57then be better understanding of
7:59customers as they work to do the same
8:01sort of thing um but tying the strategy
8:05back to the risks you know really by
8:07supporting our customers needs we should
8:09be help them we should be able to help
8:11them reduce their own risks and that in
8:14turn reduces our risk so really by
8:17embedding climate matters into our
8:19overall business approach it is a really
8:22effective risk management
8:24tool um and then lastly you know by
8:27continuing to reduce our own emiss where
8:30at least incrementally even if it's only
8:32a tiny little bit um you know trying to
8:35make a positive contribution on on
8:37overall greenhouse gas
8:40reductions so thinking about the the
8:43scope of your customers emissions um the
8:48the range of your sustainability
8:51strategy what are barriers to full
8:55implementation and to accelerating a
8:58transition towards a lower e lower
9:01carbon economy um and what changes at
9:06the level at the broader policy level
9:09industry level economy level would you
9:12like to see or do you think would be
9:14necessary to to further that
9:17acceleration yeah so when it comes to
9:20you know strategy and and barriers and
9:22things like that you know to some extent
9:24all strategies are are a bit
9:26aspirational right um and a good
9:29business has to be mindful of the world
9:32around it and the business environment
9:34as it constantly changes um
9:37unfortunately environmental issues and
9:39climate matters in particular have been
9:42caught up in the storm of politics here
9:44in the US
9:46um for the most part I think all sides
9:49will agree that we have challenges
9:51related to the environment and with
9:53climate change I I think the the level
9:55of you know agreement on that is is
9:57pretty high
9:59but where the differences emerge and and
10:01where it becomes problematic is the
10:04debates over the extent of the problem
10:06and then more importantly what needs to
10:08be done about the problems and in other
10:10words the menu of potential Solutions
10:12right that's where we see the Deep
10:14Division and those divisions can
10:17certainly make broad corporate progress
10:20on an issue like climate definitely more
10:23difficult um publicly owned companies
10:27like ours uh tend to create Brave
10:29stability when it comes to policy um if
10:33a business knows the objective that we
10:36have to meet we can design strategies
10:38and initiatives to meet those
10:40expectations but when those are
10:42uncertain or constantly changing or very
10:45from location to location things get
10:48complicated and when you ratchet up the
10:51complexity it adds cost it slows things
10:55down and with climate change we don't
10:57have a lot of extra time um to slow
11:00things down so that's a particular
11:03concern
11:04um then you throw on top of it in the US
11:07issues like shareholder Primacy which
11:10further complicates matters like climate
11:12change and calls into question the issue
11:14of balance you know are we meeting
11:16financial performance expectations and
11:19stakeholder expectations on
11:21climate what if we do if those aren't
11:24aligned and and how far can we go in One
11:27Direction or the other before running
11:28into problems
11:30so I think part of the reason we find
11:32ourselves in the place we are today on
11:33climate policy is a failure to get
11:37things done at the national level over
11:39probably decades right that has pushed
11:42policy development to The Regulators at
11:46the national level so an example of that
11:48being the sec's climate disclosure Rule
11:50and the the limbo that it is currently
11:53in um but it's also pushed regulation
11:56and policy advancement to the state
11:58level where it can be easier to get
12:00things done um again easier but not
12:02necessarily easy um the result of that
12:06though is that you get this Patchwork
12:08Approach at the state and even local
12:10levels of government um in some
12:12locations we're being encouraged to do
12:14something climate positive in other
12:16locations were forbidden from doing that
12:19same thing um so that lack of a
12:22consistent stable National approach to
12:25climate change is a challenge for
12:27business um it's challenge for our
12:29industry and and for many others um as
12:33we try to make the progress that we need
12:35to um but having to be mindful and and
12:39slow down and um you know take different
12:43approaches in different places um to
12:45make sure that we're meeting all of our
12:47you know compliance
12:49obligations uh while still um meeting
12:52all the needs of our
12:54stakeholders and we'll come back to some
12:57of the specifics of that patchwork in a
12:59little bit um but this conversation is
13:02happening in the context of the ESG
13:05dilemma design Challenge and you can't
13:07talk about ESG without talking about
13:09data um Cera has signed on to the
13:12partnership for carbon accounting
13:14financials and recently published a
13:16first disclosures report showing all
13:18deployed loans and their Associated
13:21emissions so tying this a little bit
13:23into the the uh sustainability strategy
13:26and how you're helping your customers so
13:29what is the role of reporting in moving
13:32the needle on climate impacts and
13:35perhaps what is comerica's uh motivation
13:39for joining the the partnership for
13:42accounting carbon accounting financials
13:44yeah yeah peaf it's a mouthful um we we
13:47call it peaf so um it's TR but it's true
13:52what gets measured gets managed and by
13:55being able to measure things like our
13:57finance emissions using the p
14:00methodology um we start to get the
14:02information we need and and our
14:04stakeholders are seeking to better
14:07understand where our impacts are um so
14:10that data is really important and and
14:12we're a big um believer in in the fact
14:15that disclosure drives progress or
14:19action so um but once we have that data
14:22then you know we can decide okay do we
14:25need to or do we want to adjust our
14:27strategy what is data telling us um one
14:31of the struggles right now frankly is
14:33that um we're in the very early days of
14:36financed emissions
14:38calculations and the Precision around
14:41those calculations as we share in our
14:43reporting we fully acknowledge that it
14:46is very limited at this point um they're
14:49relying on very high level estimates
14:53um and there are significant limitations
14:56in the the approaches and the data
14:58available to to us today but I do expect
15:01that that is going to improve um perhaps
15:03very rapidly so that we do get to a
15:06point of more comparable precise
15:09actionable data uh in in the future um
15:13and I think that's going to going to
15:15come you know fairly quickly as things
15:18like the California climate disclosure
15:20laws require you know scope three
15:22disclosures of of things like financed
15:24emissions and so I think you know we're
15:27going to be forced into to um we
15:30collectively as a as as the business
15:32Community into providing better
15:34disclosures there um and continuing as
15:38peaf has done to establish consistent
15:41Frameworks so that companies are are
15:44developing data in using the same
15:46framework using the same way it's
15:49transparent um one of the things I
15:51really like about paaf is their um data
15:54quality scores that that go with your
15:57disclosure so that you can tell
15:59you know how granular are we getting
16:01with this data is this actual Direct
16:04Customer data that's been third party
16:06verified great that's one thing is it
16:09relying on very highlevel um industry
16:12based emissions factors um that's a
16:15different thing and a different level of
16:17of um of precision so being able to
16:21understand the the inherent data quality
16:23in disclosures I think is is important
16:26um but we joined pcaf fairly early
16:29um one of the things one of the reasons
16:32it's it's aligned with our commitment to
16:35uh transparency and
16:36accountability um another is that we
16:39knew this was going to take some time
16:41it's it's
16:42complicated um it's difficult to align
16:46um systems within large institutions to
16:48to get the information you need in a in
16:51a new sort of way and use it in a new
16:53sort of way um so we we knew that that
16:56would take some time um and we wanted to
16:59be able to be a part of the um
17:01development of of the standards and the
17:04application of the of the the PF
17:06methodologies so all of those things
17:09drove us to be a fairly early adopter
17:12there um but again by it it it does tie
17:14back to our focus on on transparency and
17:18and
17:18accountability uh on climate and and
17:21really all environmental
17:23matters great let's pivot now to
17:26thinking about stakeholders um who are
17:30your stakeholders that are most engaged
17:32on coer sustainability strategy yeah so
17:36stakeholders it's a really interesting
17:38discussion I wouldn't say that one group
17:40is particularly more or less engaged
17:42overall than any other um but they're
17:45all engaged in different ways um in part
17:48because all of our different
17:50stakeholders have different wants they
17:52have different needs and
17:53objectives um you might have a customer
17:57who wants to ensure that we have the
17:58right right products and services to
18:00help them meet their transition Finance
18:03needs um you have employees and
18:05employees want to work in a green
18:07building um investors want transparency
18:11and and clear understanding of metrics
18:13and strategies and so forth
18:16um all of those things are important um
18:20sometimes they're aligned sometimes
18:22they're they're not aligned or or just
18:24focused on on different um different
18:27needs or different parts of ESG broadly
18:30or or climate a little bit more
18:33specifically um if if people are really
18:35interested in digging in on on our
18:37stakeholder engagement process for ESG
18:40matters we we spend some time talking
18:42about that in our corporate
18:43responsibility report so plug for
18:46comerica.com
18:48sustainability and uh you can pull up
18:50our our uh most recent corporate
18:53responsibility report and we kind of
18:54dive in on on how we do stakeholder
18:56engagement and um you know the results
19:00of of some of those engagements more
19:02broadly on on all the different esj
19:04topics that were that were
19:07managing we'll make sure to put a link
19:09to the sustainability reports in The
19:11annotation for this interview so
19:13students can access that easily but
19:15let's let's dig in because you mentioned
19:18that the stakeholder groups have
19:21different ways of engaging so i' I'd
19:24like to go perhaps kind of made Group by
19:27group and hear your your take on what
19:31are their expectations how they
19:33communicate those expectations to coer
19:36and who they interact with um so perhaps
19:40starting with your customers what are
19:43their expectations what divergences do
19:45you see and how do they engage with
19:48Comer yeah and and customers are are
19:51probably you probably pick the trickiest
19:53one to to start with
19:56um Comer's customer
19:59base is very very diverse um both
20:03geographically um and and in particular
20:06the the type of customer a traditional
20:08retail banking customer youur I um that
20:12they go into your local bank branch or
20:15or you know more often actually use the
20:17ATM or the web banking or your your
20:19phone app uh to to meet all your banking
20:22needs um that's one set of of uh
20:26needs um very different than say a um a
20:32large business or even in in that large
20:35business is going to be very different
20:37than a small business and depending on
20:39what industry they're working in um that
20:43that you know changes things
20:45entirely when it comes to working with
20:48our our business customers which has
20:50been a big Focus um which is a big focus
20:54of of coer just overall as our our role
20:57as um supporting uh
21:01business it's my experience has been you
21:05know our our business people want to be
21:06free to focus on their business right
21:09and and sometimes um things that
21:13distract them from doing that um are are
21:17disruptive and and can be pushed to the
21:19side so you know to the extent that we
21:22can be there to help simplify what they
21:26need to do to be more climate ready to
21:29support you know transition needs um I
21:33think that's that's our role we're not
21:35there to tell them what to do um we're
21:38there to to help um meet their needs
21:42when they identify them and I think
21:44that's a that's an important distinction
21:47and one that frequently gets lost um or
21:51gets Mis I'll say mismanaged in the
21:53banking industry you see a lot of um
21:56pressure on banks to drive the green
21:59finance and and transition Finance um
22:03but at the same time we may really want
22:06to do that but we can't Finance projects
22:08or companies that don't exist and I
22:11think that gets lost you know the the
22:13banks are the facilitators of Finance
22:16we're not there you know picking winners
22:18and losers um we're there to to finance
22:21viable
22:23companies um and the challenge with a
22:26lot of the climate related um businesses
22:29is many of them tend to still be very
22:31early
22:32stage um which don't traditionally fall
22:35into the banking industry uh for sources
22:38of capital um and you know if we go out
22:42and said we wanted to finance a whole
22:43bunch of startups directly um I think
22:46our bank Regulators would come back to
22:48us and say are you guys okay um because
22:52that's not that's not the traditional
22:54role of banking here in the US so again
22:57managing those those expect ations um
23:00you know directly with our customers
23:02with um other stakeholders that really
23:05are wanting to see Banks Drive the um
23:08Drive the transition um you we have to
23:11keep those those sorts of things in mind
23:15um so I think that's you know in our
23:19customers you know our colleagues that
23:21engage directly with our customers that
23:23can be you know the the person um in
23:26that local bank branch or it can be a
23:29relationship manager that has managed
23:32one of our U Middle Market companies
23:34through you know multiple generations of
23:37of
23:38ownership um and have those really
23:40long-term relationships and deep
23:43understandings of the customer and their
23:45business so depending on those different
23:47um engagement points um you know we have
23:50to have different strategies that that
23:52can help with that um and so lots of
23:55people are involved it stresses the
23:57importancy for
23:59consistency in our messaging and and
24:01ensuring that we're sharing information
24:04uh with our teams um so that they can in
24:07turn share those with
24:09customers um so that might be the the
24:12customer side um then certainly you know
24:16other engagement points or teams within
24:20coera certainly our investor relations
24:22team has a big responsibility here um in
24:26understanding what our investment or our
24:28inv interests are um but it can come
24:32through our government Affairs office
24:34our external Affairs or Community
24:35oriented areas um our purchasing team
24:39with the supply chain um corporate
24:41Communications with media Outlets Human
24:44Resources with colleagues so on and on
24:46and on you know really um the comment um
24:50that I've heard repeated over and over
24:51is you know every job is a climate job
24:54yeah I mean it it really is kind of true
24:56even at a bank you know every
24:59um has a role to play here um on climate
25:03issues and and depending on that role it
25:06could be very different um but but it is
25:09it is across the entire
25:12organization um but just maybe one other
25:15note on on stakeholder groups is that um
25:20even within a stakeholder category like
25:22investors a certain investor May really
25:24want to lean in on climate and may
25:26really want to know what you're doing
25:28what plans are you know do you have a
25:30net zero commitment what is you know
25:32really digging deep on things like
25:34Finance submissions um others may want
25:38to know that you're just you're moving
25:39in line with your peers you're not doing
25:42anything outside of that you're not
25:44you're not falling behind but you're
25:46just you know you're not you're not
25:48falling out of the pack I will say and
25:51that it's some of their investor
25:52interest um so understanding how
25:54different investors have different
25:56priorities um same thing is really true
25:59with the communities in which we operate
26:01in some communities they're really
26:03interested in making sure everybody has
26:06access to banking
26:07services um others might be on the front
26:10lines of the physical impacts of climate
26:12change um some will be both right so as
26:16a bank we need to be prepared to address
26:18and and balance all of those issues um
26:21as we as we work in our in our
26:24communities and with our different
26:26stakeholders perhaps two more group
26:28groups to highlight um you talked about
26:30the different how your different
26:32employee groups are interfacing with
26:35other stakeholders but what about the
26:37employees themselves what are their
26:39expectations on climate and then perhaps
26:42as well The Regulators what are the uh
26:45how do you engage Regulators effectively
26:47on climate issues and what um what are
26:50their
26:51expectations yeah so um employees uh on
26:55any issue are you're going to have um
26:57Divergence
26:58expectations um but but generally uh
27:02speaking our our colleagues are really
27:05engaged on on climate um we have green
27:10teams um that operate on a regional
27:12basis which are looking to um Drive
27:16understanding um so they do a lot of
27:18educational events they'll also do
27:20community service events and and really
27:23you know find ways to to act out their
27:28uh um their priorities in in the
27:30communities that they're they're living
27:32and and serving um so which is wonderful
27:35uh wonderful to see and and be a part of
27:39um we do a lot of um Employee Engagement
27:44around um different topics we have our
27:47own
27:48in-house um sustainability awareness
27:51program that we've developed to really
27:53take people from learning about
27:56sustainability to to doing
27:58sustainability and it's focused on their
28:00personal lives but we also know that you
28:03know if you if you commit to
28:05sustainability actions in your personal
28:07life you're going to bring those to work
28:09um and you're going to find ways to
28:11deploy that in your role again whatever
28:13it may be everyone has a has a role to
28:16play there so um so that's been a really
28:19uh really fun fun thing for us to be
28:21able to develop over the years and and
28:23engage we have about a thousand of our
28:25colleagues participating in our
28:27sustainability awareness
28:28program um so that's that's one way that
28:32we um stay engaged with our customers or
28:35excuse me with our colleagues uh because
28:38that we know it is important to to very
28:40many of
28:41them with respect to Regulators that's a
28:45a a little trickier one you know we we
28:48are obviously 100% committed to
28:50Regulatory Compliance and and we do um
28:53those sorts of of things that we um are
28:56required to do but
28:58climate and sustainability is really you
29:00know with any environmental matter is is
29:03beyond compliance right that's um we
29:06need to be thinking about how do we how
29:08do we leverage the compliance
29:11requirements that we have and use those
29:13to drive sustainable business value
29:16so Regulators again as I mentioned um it
29:20can vary place to place state to state
29:24um we are of a size where we are not yet
29:27regular ated by a um Federal Banking
29:32agency specifically on climate um but
29:35that doesn't mean that they aren't
29:37interested and that we don't need to be
29:39minding uh what we're doing and how
29:41we're doing it understanding our risks
29:43and opportunities so um we can't get too
29:48deep into how we do that um because of
29:50the the confidential nature of of
29:53banking regulatory oversight but um
29:57suffice it to I think it's a it's an
29:59issue that's just going to continue to
30:00grow in importance uh grow in prominence
30:04you can certainly look to uh what a lot
30:07of the larger banks are doing and have
30:09have done um for example the the climate
30:12stress testing that was done about a
30:14year ago and amongst the six largest US
30:17Banks and and the reporting that started
30:19to come out on that uh over the summer
30:22so there's a there's a lot going on in
30:24the space and and I don't think that
30:26that's going to uh dimin as time goes
30:29on that's a perfect lead in to a point
30:33that came up earlier which is how you
30:35manage diverging expectation in the
30:38states where you operate so we know the
30:42te California Texas Florida Arizona have
30:46very different expectations about what
30:48services a bank should provide how does
30:51coer currently navigate these Divergent
30:55expectations and how do you see any
30:58Common Ground among these opposing
31:02interests I you know I think the the one
31:04thing that I would say the perhaps the
31:07only common ground is the constant state
31:09of change right whether it's um in a
31:12place like California that is advancing
31:14more Progressive climate approaches or a
31:17state like Texas which is looking to um
31:21you know protect some of the the
31:23Homegrown Texas economy um and and
31:26things like the oil and gas gas uh
31:28Industries which have been very
31:30important to the the state and its
31:32economic activity over the over the
31:34decades so for different reasons they
31:36have different priorities and and like
31:39you said we need to be able to navigate
31:41those um I don't believe to date that
31:44we've had to make any tough choices on
31:47say exiting a line of business or a
31:49geographic Market um because of those uh
31:53because of those state level uh
31:55differing state level approaches um we
31:58remain grounded by our corporate
32:00strategy and our core values and
32:02ultimately those guide our responses
32:04should a situation like that uh arise
32:08but certainly we have seen a number of
32:10other uh Banks and financial
32:12institutions who have found themselves
32:14prohibited from doing business with say
32:16a state government um and I believe in
32:19in most if not all of those situations
32:22the the banks have held to their
32:24positions and their values and and exed
32:28those markets um you know maybe they
32:30didn't have a choice um but you know
32:33they they have uh these these banks have
32:36held to their their strategies and their
32:39values and I think it highlights the
32:41fact that companies need to be looking
32:44at their own longer term strategy and
32:47values and not being blown about by
32:49political winds which you know are
32:52relatively short term and can change
32:55relatively quickly uh and and those
32:58companies that find themselves Guided by
33:02The Winds of Change at any given point
33:04in time are
33:05gonna have a really difficult time
33:08sustaining long-term value because
33:10they're constantly changing their
33:12strategies so I think wise companies are
33:14thinking long term um they're holding to
33:17their strategies and you know in many
33:21cases recognizing that sustainability
33:25and climate can drive business
33:28opportunity um and if you're not paying
33:30attention they can certainly Drive um
33:32unacceptable levels of of business risk
33:35so you know being mindful of that
33:38incorporating that into long-term
33:40strategies I I think insulates against
33:43some of the um variations that we're
33:47seeing in in state level um but at the
33:50end of the day you still have to comply
33:52right with the different state
33:53requirements or even local requirements
33:55and and you have to have that awareness
33:58um and that is that is know that can be
34:00taxing on businesses it takes a lot of
34:02effort to to stay on top of all of that
34:05um and so it it does have it does have
34:09impacts on businesses for
34:11sure how does cerica engage on climate
34:16policy and do you have any best
34:18practices that you'd like to highlight
34:21sure um you know we engage on climate
34:24policy in really a number of different
34:26ways um first is probably being active
34:30with our banking related trade
34:33associations um these organizations are
34:35increasingly setting up groups dedicated
34:38to ESG issues like climate and really
34:41providing Focus input on policy and
34:44Regulatory measures um and that can
34:47provide a meaningful and trusted voice
34:49in the policy space for legislators and
34:52Regulators I think the banking trade
34:54Industries historically have been very
34:57well resp Ed um and and taken a a pretty
35:01consistent approach on on a wide range
35:03of banking
35:05issues um but at the same time trade
35:08associations can be tricky they often
35:11need to speak for a very diverse group
35:13of members um a local community bank
35:16with one branch might have a very
35:19different um set of needs and and
35:22priorities than a than a global bank um
35:25that's operating in in many many
35:28countries across the world so you're
35:30never going to have 100%
35:32alignment uh with your trade Association
35:35on policy um but it is really important
35:38to be engaged so that they can
35:41understand how different uh
35:43organizations within their coverage have
35:46differing needs um and I do think ESG
35:50issues and and climate in particular
35:53it's a it's a new set of issues um
35:57that you know typically trade
36:00associations are are pretty firm on you
36:04know regulation is adds complexity adds
36:07cost so regulation is bad that's a gross
36:10of oversimplification but that's
36:12historically perhaps been the approach
36:16um but with issues like climate and ESG
36:20I think we're having to start to think
36:22about things differently um because
36:24companies have strategies that have Comm
36:27committed to sustainability goals to
36:30diversity goals all sorts of things um
36:33which are really important to the the
36:35core values of those
36:37organizations so you know having the
36:39trade associations come out and and be
36:41able to reflect both traditional
36:44business needs and and new ESG
36:47priorities it's a new world for them too
36:50uh in many cases so that that can be
36:52tricky but it is a it is a way for the
36:55industry to speak uh with respected
36:58voice um as long as there's a good
37:02understanding that you know never 100%
37:04alignment you know different people
37:06different members may have different
37:08priorities so that means we also need to
37:10be involved in different areas too and
37:13and we find involvement with peer groups
37:16and sustainability
37:18organizations helping us share industry
37:21related opportunities and challenges in
37:23the climate space to be really important
37:25so we want to be visible we want to be
37:27vocal in the space we want to share you
37:30know transparently the the opportunities
37:33that we see and the challenges that we
37:35see um and and be able to share our
37:38views not just for policy makers but
37:40really with all of our stakeholders to
37:42to help them understand the the subtle
37:45challenges that that we may face as a
37:48company or as a industry um that aren't
37:51necessarily top of mind uh to them so
37:54being able to share that is is really
37:56important for good policy development um
38:00and then i' finally I'd say I think are
38:03public disclosures maybe are a quiet but
38:06really meaningful way to demonstrate our
38:09policy or our priorities uh to policy
38:12makers it's it is who we are it's our
38:15statements of of what we value of the
38:17progress that we make of the challenges
38:19that we Face of the opportunities that
38:22we see um so those public disclosures
38:25again back to our commitment to transp
38:27and accountability those are really
38:29important um in in our
38:35um a really reflection of our our values
38:38uh that can be useful to policy
38:42makers thank you for that overview and
38:44and for your thoughtful Reflections are
38:47there any final points you would like to
38:49add or a message you would like to leave
38:50us with yeah I I just I really
38:53appreciate again the opportunity to
38:55share to share my thoughts with uh with
38:58you in this form this is a really
39:00important topic uh and I certainly
39:02appreciate all the work that will be
39:05done um on this project and
39:08and working on driving Solutions so that
39:12we can all enjoy a more prosperous and
39:14sustainable future um so this is this is
39:18really important stuff I I appreciate
39:20the The Forum uh and again appreciate
39:23all the work that goes into this and and
39:25uh look forward to seeing some the
39:28outcomes thank you Scott thank you

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