6.2 Governance

Institutions should clearly identify and allocate responsibilities for the development, validation, implementation and monitoring of the plans. When assigning roles and responsibilities at the appropriate level of seniority, institutions should take into account the interrelation and influence that the transition planning process should have on other processes such as the broader business strategy and risk appetite.

The management body should be responsible for the approval of the plans and should oversee their implementation, including being regularly informed of relevant developments and progress achieved in relation to the institution’s targets and taking decisions on remedial actions in case of significant deviations.

For the purposes of integrating ESG risks across the three lines of defence in line with Section 5.4:

• a) the first line of defence should be responsible for establishing a dialogue with counterparties about their own transition strategies and assessing consistency with the institution’s objectives and risk appetite, based on clear engagement policies as set out in paragraph 109 e(i). To this end, institutions should ensure that relevant staff possess sufficient expertise and capabilities to assess the extent to which the transition strategies of counterparties, including their transition plans where available, will enhance their resilience to ESG risks and align with the institution’s targets;
• b) the risk management function should ensure that the risk limits set in the risk appetite statement as part of the risk management framework are consistent with all aspects of the institution’s plan, including sectoral policies ;
• c) the IAF should review the institution’s plan as part of the risk management framework and assess whether it complies with legal and regulatory requirements and whether it is consistent with the risk strategy and risk appetite of the institution as regards ESG risks. To this end, the IAF should consider whether the plan allows the institution to detect and address changes in its risk profile, how the institution addresses deviations from its targets, and whether the underlying assumptions, methodologies and criteria have been selected and used with integrity.

6.2.2 Internal processes and capacity

Institutions should ensure meaningful and regular interaction and exchanges at all levels of the organisation to ensure that insights and feedback from internal stakeholders can be taken into account in the process of formulating, implementing and reviewing the plans. To this end,

39 institutions should at least involve units, departments and functions responsible for strategic planning, risk management, sustainability disclosures, legal services and compliance in the elaboration of the plans, and should assess which additional units, departments and functions should be involved.

In line with Section 5.4, institutions should ensure they possess sufficient capacity, expertise and resources to develop and implement their transition planning process as well as to regularly assess the robustness of their plans and monitor their implementation. Institutions should map existing gaps in skills and expertise and take remedial actions where necessary.

6.2.3 Data management

Institutions should have in place sound governance processes to collect, validate and aggregate the data that are needed to inform their transition planning efforts and monitor their implementation, including by using available public information and counterparties’ transition plans as set out in Section 4.2.2.