Case study: How SAB takes action on its PRB commitments

2.1 Impact Analysis (Key Step 1)

Show that your bank has performed an impact analysis of its portfolio/s to identify its most significant impact areas and determine priority areas for target-setting.

SAB has utilized the portfolio impact analysis tools from the UNEPFI’s Context module, Consumer Banking Identification module, and Institutional Banking Identification module to analyze its activity portfolio, which includes Wealth and Personal Banking (WPB), representing Consumer Banking, and Corporate and Institutional Banking (CIB), representing Corporate Banking. The primary region of operation for SAB is the Kingdom of Saudi Arabia.

The impact analysis focused on the CIB lending portfolio, which comprises 75% of the total, while WPB accounts for the remaining 24%. Capital Market activities and subsidiaries have been excluded from this analysis, since they represent less than 3% of SAB’s 2023 revenue. To align with the PRB framework recommendations, SAB will primarily target its CIB portfolio for impact analysis and target-setting.

SAB included the entire lending portfolio as of December 31, 2023 in the Portfolio Impact Analysis Tools, with 24% allocated to WPB lending and 75% to CIB lending, predominantly in the Kingdom of Saudi Arabia. A comprehensive breakdown of SAB’s lending portfolio at the end of 2023 is provided, showing exposures for both WPB and CIB. A more detailed breakdown was employed for the Portfolio Impact Assessment tool.

For more information on its corporate portfolio, SAB has released a Sector Portfolio Review, available on its ESG website.

In 2022, SAB conducted a sustainability materiality assessment as part of its ESG strategy development, taking into account consultations with relevant stakeholders, as detailed in other sections of its report. Further information on the materiality assessment is available in SAB’s 2022 ESG Report. Additionally, SAB has enhanced prior assessments with tools and principles established under the UN PRB.

SAB also aligns with the impacts, targets, and strategic goals of the sustainable development objectives of the Kingdom of Saudi Arabia by collaborating with regulatory stakeholders such as the ESG Saudi Banks Advisory Committee (EBAC), established by the Saudi Central Bank (SAMA), and the Corporate Sustainability Policy Development Working Group initiated by the Ministry of Economy and Planning (MEP). SAB has also been recognized by the MEP as a Sustainability Champion.

From the combined findings of external engagements, the materiality assessment, and the Portfolio Impact Analysis Tools for Banks, SAB has identified the most critical impact areas for sustainable development in Saudi Arabia as follows: 1) Availability, Accessibility, Affordability, Quality of Resources & Services; 2) Climate Stability; 3) Circularity; and 4) Infrastructure.

SAB has pinpointed Availability, Accessibility, Affordability, Quality of Resources & Services as a significant impact area with the greatest positive influence, specifically addressing water, energy, housing, education, food, health and safety, information, mobility, and healthcare & sanitation.

Climate stability is recognized as the second impact area with notable negative implications. SAB has initiated various measures to manage and mitigate this risk, as described in its 2023 ESG Report.

The process for prioritizing impact areas has met internal governance standards, involving cross-functional stakeholder engagement from the ESG Office, Business, and Risk divisions. The ESG Steering Committee later endorsed the results.

Current objectives and achievements related to ongoing sustainability targets include:

• SAB aims to allocate SAR 34 billion towards sustainable financing and investments by 2025, having already deployed SAR 12.6 billion by year-end 2023. For instance, SAB financed the Marafiq Red Sea project, which supplies utilities for the Red Sea Company, including water systems, a wastewater treatment facility, solar-powered energy, and a district cooling system. Additionally, SAB is financing the largest green hydrogen project in the world at NEOM and supporting numerous renewable energy initiatives under KSA’s National Renewable Energy Programs.
• SAB is dedicated to fostering the growth of the SME sector in alignment with the Saudi 2030 Vision.
  • The bank has supported MSMEs by engaging with the Real Estate Development Fund (REDF), Tourism Development Fund (TDF), and the National Technology Development Programme (NTDP).
  • Through the Kafalah program, SAB facilitates financing for MSMEs in collaboration with the Saudi Industrial Development Fund (SIDF), allowing for funding of up to SAR 15 million to eligible clients, with a focus on Shariah-compliant solutions.
  • SAB also partners with Monsha’at, the General Authority for Small and Medium Enterprises, to co-finance banks’ customers along with the SME Bank of Saudi Arabia.
• SAB is committed to achieving Net Zero in its operations (scope 1 and 2, as well as operational scope 3 emissions) by 2035.
• SAB aims for Net Zero in its value chain, especially for financed emissions (scope 3), by 2060 or sooner.
• SAB has transitioned to a LEED gold-certified smart building to reduce operational emissions.
• SAB is collaborating with the National Centre for Vegetation Development (NCVC) to contribute to the 10 Billion Trees initiative, targeting the planting of 1 million trees by 2030, and is supporting the establishment of a local seed propagation centre for seedlings suited to the native climate.

2.2 Target Setting (Key Step 2)

Show that your bank has set and published a minimum of two targets which address at least two different areas of most significant impact that you identified in your impact analysis.

The targets have to be Specific, Measurable (qualitative or quantitative), Achievable, Relevant and Time-bound (SMART).

As part of its ESG Strategy established in 2022, SAB has committed to directing financing toward a just and sustainable economy by:
• Assisting its customers in transitioning to a more sustainable and diversified economy through its products and services;
• Increasing sustainable financing and investments to SAR 34 billion by 2025, thereby supporting the Kingdom’s Vision 2030;
• Measuring the carbon footprint of its portfolio and striving for Net Zero by 2060 or earlier, with a strong emphasis on a fair transition;
• Aligning its operations and supply chain with ambitious science-based targets and achieving key milestones by 2030, with the goal of reaching Net Zero in its operations by 2035;
• Planting 1 million trees to offset 0.9 million tons of CO2.

The process of setting targets and establishing baselines for SAB’s selected impact areas and their connections to existing targets is work-in-progress and will be communicated in the forthcoming PRB disclosures as recommended by the PRB timelines.

3.1 Client engagement

Does your bank have a policy or engagement process with clients and customers in place to encourage sustainable practices?

Does your bank have a policy for sectors in which you have identified the highest (potential) negative impacts?

Describe how your bank has worked with and/or is planning to work with its clients and customers to encourage sustainable practices and enable sustainable economic activities. It should include information on relevant policies, actions planned/implemented to support clients’ transition, selected indicators on client engagement and, where possible, the impacts achieved.

SAB prioritizes its customers as key stakeholders and strives to build a sustainable customer base, ensuring ongoing satisfaction in the short, medium, and long term. In alignment with its goals and the Kingdom’s established ESG objectives and Vision 2030, SAB aims to be the leading ESG bank for all citizens and residents.

Through sustainable financing, SAB plans to utilize SAR 34 billion earmarked for this purpose, focusing on:

• Funding initiatives that help clients transition to sustainable and low-carbon activities
• Offering products and services, including underwriting, direct lending, and trade and receivables finance, which consist of defined use of proceeds requirements aligned with established market principles
• Providing sustainability-linked facilities where SAB plays a role in structuring sustainability performance targets

Scope 3 emissions represent a critical component of SAB’s carbon footprint. Although significant, they are also the most challenging to assess and manage. Specifically, financed emissions pose a particular challenge; therefore, SAB has initiated projects to evaluate its scope 3 emissions comprehensively. Financed emissions refer to the greenhouse gases (GHGs) emitted by the companies to which SAB lends. SAB’s long-term objective is to achieve Net Zero across its entire portfolio. To realize this goal, SAB must first understand its financed emissions to effectively decarbonize the bank and its entire value chain (scope 3, category 15). The bank has started a baselining exercise that consists of three stages:

• In place Transition Engagement Questionnaire
• Ongoing Scope 3 baseline of selected hard to-abate sectors
• Outlook Scope 3 baseline across all sectors

Transition Engagement Questionnaire

As an initial step, SAB launched a Transition Engagement Questionnaire (TEQ). This tool enables frontline teams to gather relevant information to assess physical and transition risks and facilitates discussions between frontline staff and clients regarding the most pertinent ESG risks and opportunities. The primary goal of the TEQ is to collect relevant data from customers in difficult-to-abate sectors. In the second step, SAB has prioritized a select number of these sectors for review, diligently gathering emissions data to quantify its scope 3 emissions, with the aim of completing this exercise in the first half of 2024. The outcomes will inform SAB’s strategy on targets and will be part of future engagements with stakeholders. The final step of SAB’s transparency initiative is to establish a scope 3 baseline across all sectors, projected to occur within a mid-term timeframe, with specific timelines determined in due course. Once SAB gains a comprehensive overview of its portfolio’s carbon footprint, it will enhance its sustainability and climate strategy to establish decarbonization targets for its lending activities.

Financed Emissions

In line with its commitment to achieving Net Zero status by 2060 or sooner, SAB is reviewing its financed emissions baseline for select sectors in 2024. By disclosing its financed emissions footprint, SAB aims to lead by example and provide transparency to key stakeholders. Establishing the financed emissions baseline involves various methodological decisions, including the selection of sectors, clients, and products to include, as well as which parts of the value chain to focus on. SAB considers what is most suitable for its portfolio and operating environment in the Kingdom, utilizing industry standards such as those developed by the Partnership for Carbon Accounting Financials (PCAF). Measuring financed emissions is complex due to limited public emissions disclosure among companies in the Kingdom; thus, SAB must rely on proxies and modelled estimates according to industry norms. Over time, SAB expects improvements in emissions data quality and accuracy as more companies disclose their emissions. Initiatives like the Saudi Exchange’s voluntary ESG disclosure guidelines and the Saudi Central Bank’s evaluation of IFRS ISSB sustainability standards represent encouraging steps toward the disclosure of financed emissions, which SAB will take into account moving forward. As SAB navigates the complexities of measuring and disclosing financed emissions, it remains dedicated to transparency, accountability, and sustainability.

5.1 Governance Structure for Implementation of the Principles

Does your bank have a governance system in place that incorporates the PRB?

Please describe the relevant governance structures, policies and procedures your bank has in place/is planning to put in place to manage significant positive and negative (potential) impacts and support the effective implementation of the Principles.

ESG governance is fundamental to SAB’s business operations, influencing every aspect as the bank pursues its strategy for profitable and equitable growth alongside its commitment to achieving Net Zero by 2060. This is why ESG responsibilities are incorporated into the Balanced Scorecards, ensuring they are integrated into all functions of the bank, including those of the Managing Director & CEO and their direct reports.

SAB’s robust ESG governance framework, processes, and structures form the basis of its comprehensive ESG strategy. The integration of ESG considerations is an organization-wide effort that impacts all functions. Nevertheless, distinct roles, responsibilities, and oversight mechanisms at the board, committee, and management levels ensure effective supervision of ESG and climate-related risks.

• The Board of Directors
  The Board of Directors plays a key role in promoting SAB’s long-term sustainable performance and growth. It retains overall responsibility for ESG matters, including climate issues. Both the Board and senior leadership are involved in developing and overseeing the ESG strategy and receive ESG training. The Board approves the ESG risk appetite and prioritizes the creation of sustainable shareholder value. Additionally, it offers feedback on targets, endorses the ESG report, and regularly receives updates on ESG performance and sustainable finance, relying on information from the ESG Steering Committee and other relevant ESG forums. SAB’s Board of Directors has established several Board and Management Committees focused on advancing ESG goals and implementing the strategy. However, ultimate accountability remains with the Board, ensuring robust ESG governance. The Board and senior leadership actively participate in shaping the ESG strategy and are provided with an ESG orientation.
  • The Board of Directors delegates specific responsibilities, including those related to ESG, to designated Board Committees:
    • The Executive Committee (EXCOM)
    • The Audit Committee (AUCOM)
    • The Nomination and Remuneration Committee (NRC)
    • The Board Risk Committee (BRC)

• ESG Steering Committee
  The ESG Steering Committee serves as a key support mechanism for executives in the development and delivery of SAB’s ESG strategy. As a direct subcommittee of the Executive Committee (EXCOM), the ESG Steering Committee plays a crucial role in facilitating comprehensive governance, oversight, management, and coordination of all SAB’s ESG-related endeavours. By leveraging the authority delegated to it by the EXCOM, the Committee exercises holistic governance and ensures that all commitments outlined in the approved ESG strategy are effectively implemented within the bank’s risk appetite and corporate governance framework. The selection of committee members is a collaborative effort led by the Managing Director and the Company Secretary, aiming to ensure diverse and inclusive representation. The current ESG Steering Committee members include:
  • Managing Director (Chair)
  • Chief Financial Officer
  • Chief Risk Officer
  • Chief Operating Officer
  • Chief Corporate and Institutional Banking Officer
  • Chief Retail Banking and Wealth Management Officer
  • Chief Treasury Officer
  • Company Secretary
  • Chief Human Resource Officer

The Committee also includes permanent invitees, such as:

• • Chief Strategy Officer
  • Head of Corporate Communication

In 2023, the ESG Steering Committee convened seven times, addressing key topics that included:

• • ESG strategy implementation progress
  • Sustainable financing
  • Financed emissions
  • ESG disclosures
  • External collaborations on ESG topics domestically

These discussions are essential in advancing SAB’s ESG strategy and informing ongoing ESG performance tracking, the bank’s sustainability outlook, and planned ESG initiatives.

• ESG Office
  The ESG Steering Committee is supported by the ESG Office, which handles the daily operations related to the execution of the ESG Strategy in collaboration with all functions throughout the bank. This includes ESG reporting and disclosures, managing ESG expenditures and cost control, governing ESG activities, and monitoring and tracking ESG metrics. The ESG Office is tasked with developing and recommending suitable governance for ESG initiatives in partnership with relevant departments across the bank. Recognizing that sustainability is vital to all business functions, the ESG Office assists Human Resources in enhancing sustainability knowledge and skills through upskilling and capability-building initiatives.

Sustainable Finance:
Sustainable finance is primarily initiated within the bank’s business divisions, including Corporate and Institutional Banking (CIB), Wealth and Personal Banking (WPB), and Treasury. This process is integrated into a broader sustainable finance governance structure comprising three levels:

• The foundational layer consists of “Transaction Review Forums.” Organized by division, these forums assess, track, and resolve sustainable finance matters at the transaction or customer level. For instance, the CIB Sustainable Finance Forum ensures compliance within corporate portfolios and client transactions by involving representatives from business units, risk management, and compliance.
• The intermediate layer focuses on “Review, Definition Setting, and Monitoring.” Sustainable finance issues are documented, tracked, and aggregated by the Finance department, guided by the Sustainable Finance Data Dictionary, which directly links to SAB’s Product Governance. This governance delineates which products can be developed by the business divisions. The ESG Office facilitates the connection between the Data Dictionary and Product Governance.
• The top layer is responsible for “Review and Oversight” of sustainable finance initiatives. The Finance department reports on sustainable finance to the ESG Steering Committee, along with the Data Dictionary. This information is then communicated to the Board Executive Committee and ultimately to the Board of Directors. These bodies provide strategic direction, conduct performance assessments, and address elevated issues according to established protocols and procedures.

At the core of SAB’s approach to sustainable finance is the Sustainable Finance Data Dictionary. This comprehensive resource outlines the principles that guide ESG-focused products and their alignment with international standards. Products must undergo a rigorous due diligence process before being included in the Data Dictionary to mitigate risks and ensure adherence to the highest standards. For further details about the Sustainable Finance Data Dictionary, please visit SAB’s ESG page.

 

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References:

This case study is based on published information by SAB, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original please revert to the following link:

https://www.sab.com/esg/SAB 2023 UN PRP Disclosures.pdf