IFRS S2
Climate risk management framework
Part D of the HKEX ESG Reporting Code asks you to describe how climate risk is governed and managed — not to assert that it is. We build the framework that makes that description true, and disclosable.
The four pillars, and where companies come unstuck
Part D follows the IFRS S2 structure: governance, strategy, risk management, and metrics and targets. Most Hong Kong issuers can write something for each. The difficulty is that the disclosure has to describe processes that actually operate, and a reader can usually tell the difference between a framework in use and a framework written for the report.
The most frequent gap is risk management. Climate risks are identified in a workshop, listed in the ESG report, and never enter the enterprise risk register, the capital approval process or the internal audit plan. A reviewer who asks how a climate risk moved through your existing governance will find no trail.
What we build
- A climate risk identification process tied to your operations, assets and value chain
- Assessment criteria that place climate risk on the same scale as your other principal risks
- Integration into the existing risk register, ERM cycle and internal audit plan
- Board and committee terms of reference reflecting climate oversight
- Management-level roles, reporting lines and escalation thresholds
- A disclosure pack mapping each Part D requirement to the evidence supporting it
Governance that survives a change of personnel
We write the framework so it operates without us: documented criteria, defined owners, a calendar of when each step happens, and reporting templates the risk or company secretarial function can run themselves the following year. Frameworks that depend on the consultant returning every year are not frameworks.
What the engagement includes
- Climate risk identification across physical and transition risk
- Risk assessment criteria and scoring approach
- Integration design into your existing ERM framework
- Board and committee governance documentation
- Roles, responsibilities and escalation mapping
- Part D disclosure mapping with supporting evidence
- Handover documentation and a first-year operating calendar
Who this is for
LargeCap issuers facing mandatory Part D disclosure; Main Board issuers preparing before mandatory phase-in; groups whose existing climate disclosure was written without an underlying process.
Request a quotationCommon questions
We already disclose under TCFD. Does that carry over?
Largely, in structure — IFRS S2 was built on the TCFD pillars. What tends to be new is the specificity: quantified financial effects, industry-based metrics, and evidence that risk management is integrated rather than parallel. We start by mapping what carries forward.
Who needs to be involved from our side?
Typically risk, finance, operations and company secretarial, plus whoever owns the ERM framework. The framework fails if it is built only with the sustainability team, because the processes it has to plug into belong to other people.
Related services
Climate Scenario & Financial Impact Analysis
Assess the resilience of your business under different climate scenarios and evaluate potential financial implications.
Read moreGreenhouse Gas Accounting & Decarbonisation
Develop reliable greenhouse gas inventories and establish practical carbon reduction pathways across Scope 1, 2 and 3.
Read moreBoard Advisory & Corporate Governance
Empower boards and senior management to fulfil evolving ESG and climate governance responsibilities while strengthening long-term oversight.
Read moreReady to scope this?
Tell us your listing status and reporting year end. We come back with a defined scope, a fee and a realistic timeline — not a brochure.