ARE COMPANIES BEING TRANSPARENT

IN THEIR TRANSITION?
2021 Climate Transition Plan Disclosure

March 2022 1
EXECUTIVE SUMMARY

Of the
1 In 2021, 13,100+ organizations disclosed to CDP and our analysis found
that only one-third of these (4,002) reported developing a low-carbon
transition plan1. Moreover organizations have a significant way to go as

13k+ less than 1% (135) reported on all 24 key indicators (available in the CDP
Climate Change questionnaire) of a credible climate transition plan.

2
organizations that About 4,800 organizations disclosed how climate-related risks and
disclosed, only opportunities influenced their strategy, but only about half of these companies

1/3
also reported that they have developed a low-carbon transition plan.

(4,002) claimed to
have developed
3 Financial services, power and fossil fuels were the three industries
with the highest rates of climate transition plan disclosure, with 5% of
organizations in each of these industries reporting on the 24 key climate
a low-carbon transition plan indicators. Whereas the transportation services and apparel
transition plan industries had the lowest disclosure rates with less than 0.3% disclosing.

In reality, only
4 While almost all organizations disclosed emissions reduction targets, less
than 35% are credible or validated by the Science Based Targets initiative
(SBTi). Only 6% of all reporting organizations, disclosed details of a net-

135 zero target.

organizations
(less than 1%)
5 Disclosure of climate transition-related financial planning details was
strong (71%). However, this varied significantly across industries; and high-
emitting industries (such as fossil fuels and transportation services)
reported on all
consistently underperformed.
24 key indicators
of a climate
transition plan as
identified by CDP 6 No G20 country had more than 4% of organization's headquartered in
its jurisdiction disclose on the 24 key indicators of a credible climate
transition plan.

7 Organizations based in Singapore, the Netherlands & Spain had the

highest disclosure rates2 – however with an average of only 4% of all
organizations in these countries disclosing to the 24 key climate transition
plan indicators, more work is needed.

1 ‘Low carbon transition plan’ and ‘Climate Transition plan’ are used interchangeably in this report and in the Climate Change Questionnaire
2 Disclosure rate = Total number of disclosures in the 100% disclosure threshold as a proportion of total disclosure (across all thresholds), per country
INTRODUCTION

This report provides an overview of the current state of climate transition plan relevant information
disclosed through CDP's 2021 Climate Change Questionnaire. The data analyzed in this report
spans over 13,000 corporates in 13 industries and 117 countries.

This report is not an assessment of an organization’s transition towards a 1.5°C world – instead, it is an evaluation
of whether organizations are disclosing sufficient (and relevant) information that will enable stakeholders (investors,
buyers, policy makers, regulators, etc.) to ascertain whether an organization’s climate transition plan is ambitious and
if it demonstrates strategic shifts towards a low carbon economy.

In our discussion paper on climate transition plans, we identified the following key elements that constitute a credible
climate transition plan.

Governance Value chain engagement

Scenario analysis Financial planning
& low carbon initiatives

Scope 1, 2 & 3 accounting

Policy engagement Risks & Opportunities Targets
with verification

These elements can be identified via disclosure on 24 key climate transition-focused indicators in the 2021 Climate
Change questionnaire (see Appendix). The CDP Climate Change questionnaire collects data on these indicators and
this is the basis on which CDP has established full climate transition plan disclosure – please refer to CDP’s Technical
Note on Climate Transition Plans for more detail.

A climate transition plan is a time-bound action plan that clearly outlines how an organization will achieve its strategy to pivot
its existing assets, operations and entire business model towards a trajectory that aligns with the latest and most ambitious
climate science recommendations, i.e., halving greenhouse gas (GHG) emissions by 2030 and reaching net-zero by 2050 at
the latest, thereby limiting global warming to 1.5°C.

Environmental disclosure alone is not enough – it needs to lead to accountability and transformation; hence, the
relevance of climate transition plans, as part of a business’s overall strategy.

3
DISCLOSURE OF CLIMATE TRANSITION PLANS
AND STRATEGY

A climate transition plan should outline how an organization plans to align with a 1.5°C world.
CDP asks all disclosing companies if climate-related risks and opportunities influenced their
organization’s strategy. In 2021, one-third of disclosing organizations (4,002) reported that
they have developed a low-carbon transition plan.

Further in the questionnaire, we ask where and how climate-related risks and opportunities have influenced their
strategy. About 4,800 organizations disclosed this (or that evaluation was in progress) in their supply chain and/
or value chain, products and services, operations, and investment in research & development (R&D). However,
only about half of these organizations also reported that they have developed a low-carbon transition plan.
This suggests that many organizations have not yet developed a climate transition plan that will demonstrate to
investors, customers and other stakeholders how they plan to realize their strategy to mitigate climate risks and realize
opportunities of aligning with a 1.5°C world.

About 50% of organizations in the power industry and 45% of organizations in the financial industry reported
developing a climate transition plan and disclosed details of climate’s influence on their strategy, while only about 26%
of organizations in the manufacturing and retail industries reported such details.

Figure 1. 2021 disclosure to all 24 climate transition plan indicators – by disclosure threshold

1,890 2,514 8,581

135
0-19% 20-79% 80-99% 100%

# Total number of organizations

SUMMARY OF DISCLOSURE TO ALL 24 KEY
INDICATORS

1%
Along its sustainability journey, an organization will typically set
emissions reduction targets, commit to monitoring its progress on
climate, and reduce its exposure to climate-related risks. Further to
of organizations
these actions, a climate transition plan serves as a strategic planning
disclosed on all 24 key
instrument that helps organizations align their various climate actions.
climate transition plan
Only 1% of all organizations disclosed on all 24 key climate transition plan

84%
indicators, which highlights that most organizations can significantly improve
disclosure of their climate transition plans. Additionally, 84% of all disclosing
organizations responded to less than 80% of the key indicators which signals that
of organizations better disclosure is required to enhance reporting quality, and to assist data users in
responded to less interpreting climate transition plan credibility. As it stands, the key issue is a lack of
than 80% of the key adequate reporting on these indicators; however with the guidance being developed
indicators by CDP on climate transition plans and their importance, we expect to see an increase
in disclosure of credible climate transition plans. This is important as stakeholders
(investors, customers and employees) expect organizations to demonstrate how
they plan on tackling the climate crisis and therefore those organizations that are not
creating credible climate transition plans will get left behind.

Figure 2. Sectoral breakdown across disclosure threshold - climate transition plan indicators
Percentage
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Apparel 375

Biotech, health care & pharma 317

Financial services 504

Food, beverage & agriculture 1009

Fossil fuels 170

Hospitality 74

Infrastructure 503

Manufacturing 5103

Materials 1226

Power 216

Retail 611

Services 2360

Transportation services 644

0 500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500

Number of organizations

≤20% 21-79% 80-99% 100% Total organizations 5

DISCLOSURE TO CLIMATE TRANSITION
PLAN ELEMENTS

Figure 3 shows the percentage of organizations that disclose to all applicable key
indicators within each element of a climate transition plan. More than 70% of
organizations disclosed sufficient details on financial planning, governance, and
More than policy indicators. While disclosure is relatively strong in these areas, fewer than 20%

70%
of organizations disclosed sufficient detail on the transition-related elements of
targets and risks & opportunities. The following section will first analyze the drivers
behind poor disclosure against targets. As financial planning is important, due to
of organizations stakeholder demand for financial planning evidence, further analysis of this disclosure
disclosed sufficient is also below3.
details on financial
planning, governance,
and policy indicators
Figure 3. 2021 disclosure to the climate transition plan elements
– by percentage threshold

Targets

Risks & opportunities

Scope 1, 2, 3
Account & Verification

Strategy

Value chain

Financial planning

Governance

Policy

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

3 CDP conducted stakeholder research into key elements of a credible climate transition plan of which, financial planning was the second most prevalent element -
Climate Transition Plan Discussion Paper
TARGETS

A climate transition plan should contain time-bound, verified science-

based targets (SBTs) which are in line with the latest climate science.
Organizations should set near-term SBTs to halve emissions by 2030
Only and can also set a net-zero long-term target – by 2050 at the latest.

741
organizations
Disclosure rates for targets were significantly lower than any other climate
transition plan element. We analyzed disclosure against absolute emissions
reduction targets, targets set to reduce the emissions intensity of an organization’s
disclosed an absolute activities, and net-zero target(s). Only 741 organizations disclosed an absolute or
or intensity target intensity target AND a net-zero target, amounting to 6% of the total sample.
AND a net-zero target,
amounting to 6% of the Despite disclosure of absolute or intensity targets across nearly the entire sample,
total sample we know that disclosure of targets alone does not signal ambition of these
organizations, or alignment with a 1.5°C world. Of the organizations that disclosed
at least one type of emissions reduction target, only 4,510 (less than 35%)
Only

4,510
disclosed credible targets that meet CDP’s criteria (which is, to cover at least 70%
of emissions set between 5-15 years - or have been validated by SBTi). To date, only
1,164 organizations have set SBTs validated by SBTi, which we consider to be the
gold standard for ambitious and credible target-setting.
organizations (less
than 35%) disclosed
credible targets Though there is considerable discussion around ‘net-zero’ transition plans,
short-term emissions reduction targets are fundamental in achieving a 1.5°C
world. Only 6% of organizations fully disclosed details of their net-zero targets,
drastically lower than disclosure of absolute or intensity targets. It is important
Only

6%
to acknowledge the context within which organizations can set net-zero targets.
Net-zero standards and validated targets are not readily available for all industries,
although considerable progress has been made to increase the accessibility of
of organizations fully validated net-zero target(s). In 2021, SBTi launched its net-zero standard that gives
disclosed details of organizations a blueprint on how to bring their net-zero plans in line with science and
their net-zero targets allows for validation of targets.

7
FINANCIAL PLANNING

As part of its strategy to achieve a 1.5°C world, an organization should outline time-bound financial
planning details required to make its transition. Stakeholder demand is rapidly increasing for
transparent and granular reporting on capital expenditure (CAPEX) and other financial planning
details. The Task Force on Climate-Related Financial Disclosure (TCFD) recommends organizations
disclose financial planning information amongst guidance to disclose the impacts of climate-related
risks and opportunities on the organization’s business and strategy.

In alignment with the TCFD, CDP asks all disclosing organizations to report on where and how climate-related risks
and opportunities influenced their financial planning. To satisfy the minimum criteria for financial planning disclosure,
an organization must have reported on at least one area of its financial planning (such as CAPEX, revenues, assets,
etc.) and provided an explanation for how it has been influenced by climate issues. Disclosure was strong with 86% of
organizations across all industries reporting on this indicator.

CDP asks organizations in high-impact industries to disclose additional information around financial planning.
Specifically, we ask all organizations within energy intensive industries to disclose five-year CAPEX plans broken down
by power source, and by products and services. We also ask certain high-emitting industries to disclose investments in
low-carbon R&D over the last three years. These disclosures provide insight into an organization’s ambition in securing
low-carbon revenue streams or realizing the potential of emerging technologies to facilitate a transition to a low-carbon
economy. These two data points tell different stories but are equally important to the formulation of robust and credible
climate transition plans.
Disclosure of CAPEX in the energy intensive industries4
Of the 184 disclosing organizations within the electric utilities industry, 75% of organizations disclosed details of
their CAPEX plans for power generation and 68% disclosed details of CAPEX plans for products & services. The fossil
fuel industry had particularly poor disclosure with only 43% disclosing CAPEX plans for power generation and
only 14% disclosing details of their CAPEX plans for products and services. This weak disclosure amongst fossil
fuels organizations signals a need for better information on plans for low-carbon revenue streams, and the growth (or
decline) of certain energy sources.

Disclosure of investment in R&D in high-emitting industries

Finally, we analyzed details of investments in low-carbon R&D over the last three years, which is requested of
organizations in high-emitting industries. 1,885 organizations, with the largest proportion in manufacturing (530),
materials (519), transportation services (251), infrastructure (202), fossil fuels (123), and power industries (116) disclosed.

Investment in low carbon R&D had the poorest disclosure out of all financial planning indicators, with only 45% of
applicable organizations disclosing all details of their investment in low-carbon R&D. Power and infrastructure had
relatively strong disclosure against this average, with 66% and 59% of organizations disclosing respectively. Notable
industries with weak disclosure were transportation services (41%) and manufacturing (37%). This relatively weak
disclosure indicates a lack of transparency, but also raises concerns about investment in technologies and innovations
that could facilitate the low-carbon transition. This is particularly relevant for transportation services and manufacturing
as they are vital players in allowing consumers to transition via their products and services. A broader portfolio of low-
carbon products and services empowers consumers to leverage their buying power necessary for the transition.

Disclosure to the financial planning element

While 71% of responding organizations disclosed to all applicable key financial planning indicators, many
organizations were not requested to report on the industry-specific questions regarding CAPEX plans or investment in
R&D in 2021. As stakeholder demand grows for increased financial planning evidence within climate transition plans,
we will seek to collect additional disclosures from all organizations.

Taking this into account, there are still some industries that performed moderately well when requested to disclose to
these additional indicators. These were manufacturing with 68%, infrastructure with 66% and power with 62% of
organizations disclosing sufficiently.

Some of the poorest performing industries were transportation services with only 45%, and fossil fuels with only
54% of organizations disclosing sufficiently to all applicable financial planning indicators. Over a quarter of
organizations in transportation services (27%) failed to disclose any critical details of CAPEX plans, investment in
low-carbon R&D and climate-related risks and opportunities influencing financial planning. Similarly, 10% of fossil
fuel organizations failed to disclose on any financial planning indicators, with 37% only disclosing on half of the
applicable indicators. In total, 47% of organizations in the fossil fuels industry failed to disclose sufficiently on the
applicable financial planning indicators. The gap in this disclosure for these industries is concerning as they will be
critical to propelling the low-carbon transition and will require substantial capital to achieve it.

4 According to the CDP-ACS system organizations with activities in energy utility networks, nuclear power generation, renewable power generation, thermal power generation and waste power
generation are allocated a industry specific Electric Utilities Questionnaire
9
INDUSTRY TRENDS

To better understand climate transition plan disclosure performance across various industries,
CDP analyzed overall industrial disclosures.

Across 13 industries, financial services, power & fossil fuels were the front runners with 5% of all organizations
in each of these industries disclosing on the 24 key transition plan indicators. However, with a 5% disclosure rate
(relative to other industry disclosures), there are still significant gaps within all industries. When scrutinizing the lowest
disclosure rates, the transportation services and apparel industries had the poorest disclosure on the 24 key indicators
of a credible climate transition plan with less than 0.3% of organizations disclosing.

Major players in high-emitting industries, such as oil & gas, are not changing their business models fast enough. This
risks making global targets unachievable unless they change now. To negate the risk of not meeting our global climate
ambitions, more pressure needs to be applied to organizations in the fossil fuels and power industries in relation to climate
transition plan disclosure. Of the 135 organizations who reported through all indicators, 14% of these were within
the fossil fuel and power industries. With global energy demand expected to rise (by population and economic growth
particularly in developing economies), it is vital that there is an increase in disclosure as enhanced disclosure could help
mitigate the transition being derailed in an attempt to meet increased energy demand.

5%
of organization in the financial
14%
of 135 organizations who The lowest disclosure
services, power and fossil fuel reported to all indicators raters were in the
industries disclosed on the 24 key were in the fossil fuel transportation services
climate transition plan indicators and power industries and apparel industries.
 GEOGRAPHIC TRENDS

CDP receives disclosures from organizations across 117 countries. When evaluated for disclosure to
all key indicators of a climate transition plan, Japan and the UK were the geographic leaders: with 19
Japanese organizations and 16 UK organizations disclosing to all key indicators.
Globally, Singapore, the Netherlands & Spain had the highest disclosure rates to all key indicators – however with an
average of 4% of all organizations in these countries disclosing to all the key indicators, more work is needed.
Please see Figure 4, below, for a regional breakdown of disclosure performance to all 24 climate transition plan indicators.

Figure 4. Disclosure performance to all 24 climate transition plan indicators – by country (Top 20)

100% 2917 3000

90%
2500
80%

Number of organizations
70%
2000
Percentage

60%
50% 1407
1500
40%
1053
986 1000
30% 867

20% 581 500

383 380 370 344
10% 301 275 267 242 198 152 145 136 134 118
0% 0
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Fr

Sw
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≤20% 21-79% 80-99% 100% Total organizations Ho

Organizations from five countries (China; Japan; Taiwan, China; UK; USA) represented over half of those that disclosed
to at least 80% of the indicators. Japan performed the best with 38% of all Japanese organizations within the ‘>80%
disclosure’ threshold. On the other hand, China performed the worst, with 8% of organizations within this threshold.
This is important to note as, despite China accounting for the second highest disclosures by any country, the bulk of
these disclosures do not contain key information within the 24 climate transition plan indicators. Additionally, despite
having the highest number of organizations from any country disclosing, the USA had the second lowest performance
(11%) when assessed for the proportion of organizations within the '>80% disclosure’ threshold.

G20 narrative
No G20 country had more than 4% of organizations headquartered in its jurisdiction disclose to all the key
indicators of a credible climate transition plan. According to The Climate Transparency 2021 Report the G20 is
responsible for approximately 75% of GHG emissions. To prevent the global temperature rising above 1.5°C, the G20
therefore has an important role to play by committing to emissions reduction targets, and demonstrating its strategy to
achieve these ambitions, via credible climate transition plans. Of the G20 countries, Spain (4%), France (3%) and Japan
(2%) had the highest proportion of organizations that disclosed on all the key indicators – with Indonesia, Saudi Arabia,
Argentina and Macao, China having the lowest proportion of disclosure. Please see the Appendix for total regional
disclosure (and threshold breakdown).

UK
Given the UK Government will be making climate transition plans for listed organizations and financial institutions
mandatory by 2023, a marked increase in UK climate transition plan disclosure is expected. In 2021, 17% of all UK
organizations disclosed to at least 80% of the key indicators. Of these 188 organizations, 16 disclosed to all key
indicators. Most UK organizations (82%) disclosed to some (<80% threshold) of the key indicators.
11
CONCLUSION

Although a third of all disclosing organizations reported

developing a low carbon transition plan, when assessed against
CDP’s key climate transition plan indicators, many of these
disclosures fell short.

Despite this, it is encouraging to see interest in the uptake of climate transition

plans from stakeholders and organizations. With an increase in investor demand
via initiatives such as the Say on Climate campaign, and forthcoming transition
plan disclosure regulation in the UK, an evolving landscape will be a key driver of
increased (and improved) transition plan disclosure. In 2022, stakeholders will
expect overall transition-focused disclosure to exceed the current baseline of 16%
of disclosing organizations providing details to at least 80% of the key indicators.
These ambitions will be facilitated and supported by robust and widespread
governance mechanisms to increase the number (and credibility) of climate
transition plan disclosures.

CDP recognizes that climate transition plans will be a vital mechanism for
transition to a net-zero carbon economy. This is why transition planning features
in the new CDP 2021–2025 strategy, placing transparency and accountability at
its heart and incentivizing the disclosure of climate transition plans.
APPENDIX

Appendix 1: Key transition-focused indicators in the 2021 Climate Change Questionnaire

Climate Transition CDP 2021 Climate Change Question

Relevance to Climate Transition Plans
Plan Element and Question Code

An organization should have board-level oversight of its

(C1.1b) Provide further details on the board’s transition plan with defined governance mechanisms in place
oversight of climate-related issues. to ensure delivery of the plan. Climate issues should be a
scheduled item at all or some board meetings.
Governance
(C1.3a) Provide further details on the incentives To incentivize conscious action and commitment in realizing the
provided for the management of climate- plan’s goals, it is recommended that executive remuneration is
related issues. aligned with the organization’s transition plan goals.

(C4.1a) Provide details of your absolute

emissions targets and progress made against
those targets. A transition plan should be underpinned by ambitious near-
and long-term science-based targets which are in line with
(C4.1b) Provide details of your emissions the latest climate science to achieve a 1.5 degree world.
intensity target(s) and progress made against
Targets those target(s).

A transition plan should aim to achieve science-based net-

(C4.2c) Provide details of your net-zero target(s). zero targets in line with the latest climate science to achieve a
1.5-degree world by 2050 at the latest.

Robust scenario analysis is an important strategic planning

(C3.2a) Provide details of your organization's
Scenario tool that can be used to inform the development of a climate
use of climate-related scenario analysis.
transition plan.
Analysis

Disclosing details of material climate risks posed to an

(C2.3a) Provide details of risks identified with
organization, including the potential financial impact and the
the potential to have a substantive financial or
cost to respond to these risks, indicates a robust transition
strategic impact on your business.
plan is in place.
Risks and
Opportunities (C2.4a) Provide details of opportunities Disclosing details of material climate opportunities posed to
identified with the potential to have a an organization, including the potential financial impact and
substantive financial or strategic impact on the cost to realize these opportunities, indicates a robust
your business. transition plan is in place.

(C3.1) Have climate-related risks and

This question gives the clearest indication if an organization
opportunities influenced your organization’s
reports that they have a transition plan in place.
strategy and/or financial planning?

An organization should have a defined shareholder

feedback mechanism in place for regular feedback on the
(C3.1a) Is your organization’s low-carbon
plan and progress against it. In some jurisdictions or for
Strategy to transition plan a scheduled resolution item at
some organizations, AGMs are not a possible route for this
Annual General Meetings (AGMs)?
Achieve Net shareholder feedback. In 2022, this question will ask more
Zero broadly about feedback mechanisms, not limited to AGMs.

A transition plan should outline how an organization will

(C3.3) Describe where and how climate-related
achieve its strategy to pivot its products and services,
risks and opportunities have influenced your
supply/value chain, investment in R&D, and operations to a
strategy.
1.5-degree world.
13
Climate Transition CDP 2021 Climate Change Question
Relevance to Climate Transition Plans
Plan Element and Question Code

Transition plans should include a description of the financial

(C3.4) Describe where and how climate-related planning for existing assets, operations, and the entire
risks and opportunities have influenced your business model to transition to a 1.5-degree world. The
financial planning. most indicative areas are revenue, capital expenditures, and
operational expenditures.

(C-EU9.5a) Break down, by source, your total Understanding total planned CAPEX for power generation
planned CAPEX in your current CAPEX plan for and products & services in the next 5 years reflects the
power generation. ambition of the disclosing organization to align its business
trajectory towards a 1.5°C aligned path. This also signals its
Financial (C-EU9.5b) Break down, by source, your total flexibility to continue the current technology/product portfolio
Planning planned CAPEX and your current CAPEX plan at lower financial returns in a transition period to low-carbon
for products and services. technologies.

(C-CE9.6a/C-CG9.6a/C-CH9.6a/C-CN9.6a/C- Actions being taken by high intensity industries are key in the
CO9.6a/C-EU9.6a/C-MM9.6a/C-OG9.6a/C- transition to a low-carbon economy. Specifically, the level
RE9.6a/C-ST9.6a/C-TO9.6a/C-TS9.6a) Provide of investments in low-carbon R&D provides an indication
details of your organization’s investments in of which future earning capacity of core business might be
low-carbon R&D for your industry activities affected, and the extent to which future resilience to climate-
over the last three years. related issues can be incorporated in businesses.

(C6.1) What were your organization’s gross global

Scope 1 emissions in indicator tons CO2e?
A climate transition plan should be accompanied by a
(C6.3) What were your organization’s gross global complete, accurate, transparent, consistent, and relevant
Scope 2 emissions in indicator tons CO2e? inventory of all three scopes of emissions. Organizations
should calculate and disclose all material categories of Scope 3
Scope 1,2,3 (C6.5) Account for your organization's gross and provide an explanation for categories that are not relevant.
Accounting with global Scope 3 emissions, disclosing and
Verification explaining any exclusions.

A climate transition plan should be accompanied by a

(C10.1) Indicate the verification/assurance status
complete annual inventory Scope 1, 2, & 3 emissions that is
that applies to your reported emissions.
verified by a third party.

Organizations are facing resiliency risks in the value chain that

have material environmental and financial implications; hence,
value chain engagement plays a significant role in realizing
a climate transition plan. Organizations with significant
(C12.1a) Provide details of your climate-related emissions in their supply chain can leverage their buyer power
supplier engagement strategy. and engage their suppliers towards a 1.5°C-aligned transition.
A climate transition plan should include time-bound actions
Value Chain to decarbonize business processes within the value chain,
Engagement including supply chain engagement that covers at least 25% of
its suppliers by procurement spend or Scope 3 emissions.

(C4.5a) Provide details of your products and/

A climate transition plan should include time-bound actions to
or services that you classify as low-carbon
decarbonize business processes, such as growing the revenue
products or that enable a third party to avoid
earned from its products and services portfolio.
GHG emissions.

For many organizations, a successful transition will depend

on an accommodative policy landscape, thus organizations
(C12.3a) On what issues have you been should advocate for climate-positive policies that impact
engaging directly with policy makers? their relevant industry(s). A climate transition plan should
demonstrate that an organization's public policy engagement
aligns with its climate ambitions and strategy.
Policy
(C12.3f) What processes do you have in place to Ensuring that an organization’s internal activities are supported
ensure that all of your direct and indirect activities by fully aligned external policy engagement (policy, law,
that influence policy are consistent with your regulation, and trade associations) demonstrates an ambitious
overall climate change strategy? effort towards achieving a 1.5°C world.
Appendix 2: Total industry disclosure (and threshold breakdown) - by industry

Industry > 80% threshold 79 - 20% threshold <20% threshold Total count

Apparel 42 258 75 375

Biotech, health care & pharma 65 200 52 317

Financial services 254 232 18 504

Food, beverage & agriculture 124 689 196 1009

Fossil fuels 59 93 18 170

Hospitality 16 50 8 74

Infrastructure 148 280 75 503

Manufacturing 581 3471 1053 5105

Materials 266 806 154 1226

Power 81 108 27 216

Retail 125 378 108 611

Transportation services 282 1490 588 2360

Services 85 418 141 644

Grand Total 2128 8473 2513 131145

5 The total count does not equal 13,120 – this is because 6 outlier organizations (these organizations were in Corporate Tags and International Bodies industries) have been removed from the total sam-
ple.
15
Appendix 3: Total disclosure (and threshold breakdown) - by country

>80% 79 - 20% < 20% >80% 79 - 20% < 20%

Country Total Country Total
threshold threshold threshold threshold threshold threshold

Afghanistan 1 1 Denmark 20 57 15 92

Åland Islands 1 1 Dominican Republic 2 2 4

Argentina 1 37 24 62 Ecuador 17 2 19

Australia 26 99 27 152 Egypt 16 5 21

Austria 19 51 10 80 El Salvador 3 3

Bahamas 1 1 Estonia 2 1 3

Bahrain 1 1 Fiji 1 1

Bangladesh 16 16 Finland 30 74 13 117

Belarus 1 1 France 112 205 63 380

Belgium 20 53 17 90 Germany 92 402 87 581

Bermuda 3 5 1 9 Greece 4 16 3 23

Bolivia (Plurinational Guam 1 1

State of)
2 2
Guatemala 8 3 11
Brazil 59 607 320 986
Guernsey 1 1 2
British Virgin Islands 1 1
Guyana 2 2
Bulgaria 3 2 5
Honduras 3 3
Cambodia 4 4
Hungary 1 18 10 29
Cameroon 1 1
Iceland 1 3 4
Canada 43 211 47 301
India 50 168 49 267
Cayman Islands 4 2 6
Indonesia 4 49 21 74
Chile 8 34 13 55
Ireland 30 38 10 78
China 116 1051 240 1407
Isle of Man 1 1
China, Hong Kong
Special Administrative 14 96 24 134 Israel 2 17 4 23
Region
Italy 49 237 84 370
China, Macao Special
6 4 10
Administrative Region Jamaica 1 1
China, Taiwan 123 209 51 383 Japan 333 475 68 876
Colombia 8 31 10 49 Jersey 1 1
Costa Rica 1 13 5 19 Jordan 1 4 5

Croatia 3 1 4 Kazakhstan 2 2

Cyprus 1 2 3 Kenya 5 2 7

Czechia 2 12 9 23 Kuwait 1 3 4
 >80% 79 - 20% < 20% >80% 79 - 20% < 20%
Country Total Country Total
threshold threshold threshold threshold threshold threshold

Latvia 1 1 San Marino 1 1

Lebanon 1 1 Saudi Arabia 1 7 1 9

Liberia 1 1 Serbia 3 1 4
Lithuania 2 9 11 Singapore 8 48 15 71
Luxembourg 5 12 3 20 Slovakia 1 4 3 8
Madagascar 2 2 Slovenia 1 11 4 16
Malaysia 2 54 19 75
South Africa 36 34 3 73
Malta 1 2 3
Spain 53 177 45 275
Marshall Islands 1 1
Sri Lanka 6 6
Mauritius 3 1 4
Sweden 42 123 33 198
Mexico 16 264 64 344
Switzerland 33 95 17 145
Monaco 1 1
Thailand 15 40 9 64
Mongolia 1 1
Trinidad and Tobago 1 3 4
Morocco 1 1 2 4
Tunisia 2 2
Mozambique 1 1 2
Turkey 39 56 23 118
Netherlands 26 96 14 136
Tuvalu 1 1
New Zealand 12 17 29
Uganda 2 2
Nigeria 10 2 12

Norway 35 35 5 75 Ukraine 5 5

Oman 2 1 3 United Arab Emirates 3 18 3 24

Pakistan 16 6 22 United Kingdom 188 708 157 1053

Panama 5 3 8 United Republic of

Tanzania
1 1
Peru 1 13 7 21
United States of
America
327 1892 705 2,924
Philippines 1 16 6 23

Poland 2 79 28 109
Uruguay 4 6 10

Venezuela (Bolivarian
Portugal 15 15 6 36 Republic of)
1 1

Puerto Rico 3 3 Viet Nam 15 7 22

Qatar 1 1
Grand Total 2130 8476 2514 13120
Republic of Korea 72 132 38 242

Romania 2 16 11 29

Russian Federation 15 31 5 51
17
 DISCLOSURE INSIGHT ACTION

Authors Communications Lead

Nicolette Bartlett Maddy Bravery

Chief Impact Officer Communications Manager
[email protected] [email protected]

Emma Jenkins
Transition Plans Manager
[email protected]

Sylvester Bamkole
Senior Climate Analyst –
Disclosure Content
[email protected]

Scott Twigg
Campaign Project Officer
[email protected]

Tom Coleman
Manager – Climate Change

CDP Worldwide If you are looking for more information

Level 4 on Climate Transition Plans please
60 Great Tower Street email [email protected].
London EC3R 5AZ
Tel: +44 (0) 20 3818 3900
[email protected]
www.cdp.net

ABOUT CDP
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Visit cdp.net or follow us @CDP to find out more.

February 2022