Letter to Lloyd’s on its inadequate ‘ESG’ policy

December 13, 2021

On the same day that Insure Our Future leaked Lloyd’s ESG guidance, Client Earth has published a letter to Lloyd’s critiquing the inadequacy of this guidance.

View Client Earth’s letter to Lloyd’s

This letter to Lloyd’s sets out why Lloyd’s ESG guidance is wholly inadequate to set the Lloyd’s market on a science-based pathway to net zero. In particular, the guidance:

  • Is not binding on managing agents, leaving them free to disregard the guidance and Lloyd’s stated net-zero ambition;
  • Lacks transparency, as individual managing agents and syndicates will not need to disclose their climate targets or progress;
  • Does not set any targets for short or medium-term emissions reduction, which allows managing agents to take little or no meaningful action in the near future; and
  • Does not set any targets for phasing out cover for fossil fuels, and in fact rows back from Lloyd’s previous public commitments to phasing out cover for coal, tar sands and Arctic oil.

As a result, Lloyd’s publicised net-zero ambition risks being greenwash, and Lloyd’s risks breaching its legal duties to manage the market’s exposure to climate risks.

Client Earth previously wrote to Lloyd’s on 14 June 2021, summarising its legal duties in relation to climate change. They wrote again on 3 November 2021 calling on Lloyd’s to make its ESG guidance publicly available and summarising Lloyd’s legal duties not to make misleading statements about its action on climate.


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