Transcription
Ameriprise Financial, Inc. - Climate Change 2021C0. IntroductionC0.1(C0.1) Give a general description and introduction to your organization.Ameriprise Financial is a leading diversified financial planning and services company with a network of more than 10,000 financial advisors in the U.S. and extensive assetmanagement, advisory and insurance capabilities. As a longstanding leader in financial planning and advice in the U.S., a global asset manager and an insurer,understanding and meeting clients' needs is our top priority. At Ameriprise, we have been helping people feel confident about their financial future for more than 125 years.Columbia Threadneedle Investments, the global asset management group of Ameriprise, is a leading global asset manager that provides a broad range of investmentstrategies and solutions for individual, institutional and corporate clients around the world. The company manages more than 590 billion of assets across developed andemerging market equities, fixed income, asset allocation solutions and alternatives. In addition, Ameriprise provides life and annuity products through RiverSource LifeInsurance Company.Ameriprise is a values-driven firm. Our values of client focus, integrity always, excellence in all we do, and respect for individuals and communities in which we live and workguide our actions. Our culture and our people are central to our long-term sustainability. Our financial strength, steady investment and robust enterprise risk managementprogram are critical elements of preserving and creating sustainable, long-term shareholder value. We are committed to the prudent management principles that underpin ourfirm. From our tone at the top and culture of compliance to the extensive corporate governance framework of independent oversight of our Board of Directors, Ameriprise andour stakeholders are well served by our strong governance capabilities, systems and policies.In terms of climate, like other financial services firms, Ameriprise is a low Scope 1 and 2 greenhouse gas (GHG) emitter. We incorporate responsible environmental practicesin the management of our facilities and have earned strong ENERGY STAR ratings for the actions we've implemented to improve energy efficiency. The main contributor toour Scope 1 and 2 GHG emissions is our corporate real estate. Our corporate-controlled real estate includes the Ameriprise Financial Center and the Ameriprise ClientService Center, the two buildings that make up our Minneapolis, Minnesota campus, and which we maintain operational control. The emissions data we include in this surveyis for these two buildings.From a risk management perspective, at the enterprise level, Ameriprise considers climate risk to be a long-term strategic risk. At Ameriprise, Columbia Threadneedle andRiverSource Life, we continue to evolve our climate change strategy and capabilities to manage risks and opportunities, and to meet current and evolving regulatoryrequirements.C0.2(C0.2) State the start and end date of the year for which you are reporting data.ReportingyearStart dateEnd dateIndicate if you are providing emissions data for past reportingyearsSelect the number of past reporting years you will be providing emissions dataforJanuary 12020December 312020No Not Applicable C0.3(C0.3) Select the countries/areas for which you will be supplying data.United States of AmericaC0.4(C0.4) Select the currency used for all financial information disclosed throughout your response.USDC0.5(C0.5) Select the option that describes the reporting boundary for which climate-related impacts on your business are being reported. Note that this option shouldalign with your chosen approach for consolidating your GHG inventory.Other, please specify (Operational control – Ameriprise Minneapolis Headquarters and Client Service Center facilities)CDPPage 1 of 31
C-FS0.7(C-FS0.7) Which organizational activities does your organization undertake?Investing (Asset manager)Investing (Asset owner)Insurance underwriting (Insurance company)C1. GovernanceC1.1(C1.1) Is there board-level oversight of climate-related issues within your organization?YesC1.1a(C1.1a) Identify the position(s) (do not include any names) of the individual(s) on the board with responsibility for climate-related issues.Position of Please explainindividual(s)Board-levelcommitteeThe Nominating and Governance Committee of the Ameriprise Financial Board of Directors oversees the firm's enterprise-level corporate social responsibility (CSR) efforts. The Committee reviewsand discusses with senior management the content of the Company’s annual CSR report and any proposed material revisions to the report, as well as shareholder feedback, the evolving practices inthe financial services industry in the United States, and the company’s related policies and reporting metrics. Our 2021 Responsible Business Report includes information on our climate positioningand risk management processes and is available at e.pdf Our approach to climate andconsideration as a long-term strategic risk also ensures that climate change is incorporated within overall risk discussion and oversight.ChiefExecutiveOfficer(CEO)Our chairman and CEO meets with members of the Ameriprise Corporate Social Responsibility Steering Committee (SteerCo) and members of the Ameriprise Executive Leadership Team to reviewprogress on sustainability initiatives and recommendations for advancement of CSR efforts. This includes our climate-related strategy and energy efficiency initiatives. In consultation with our ChiefRisk Officer and the SteerCo, the CEO helps drive climate strategy and related risk management processes. SteerCo membership includes senior leaders from Corporate Communications,Community Relations, Human Resources, Investor Relations, Real Estate, Responsible Investment at Columbia Threadneedle Investments (Columbia Threadneedle), Risk Management, and ourGeneral Counsel's Organization, including our Corporate Secretary. Ultimately, decisions about how the company will continue to evolve our climate strategy, actions and disclosures, are made bythe CEO, Chief Risk Officer and members of the Executive Leadership Team.C1.1b(C1.1b) Provide further details on the board’s oversight of climate-related issues.Frequencywithwhichclimaterelatedissues areascheduledagendaitemGovernance Scope ofPlease explainmechanisms board-levelinto whichoversightclimaterelatedissues areintegratedScheduled Reviewing– someand guidingmeetingsstrategyReviewingand guidingmajor plansof actionReviewingand guidingannualbudgetsReviewingand guidingbusinessplansClimaterelated risksandopportunitiesto our ownoperationsThe impactof our ownoperationson theclimateThe Nominating and Governance Committee of the Ameriprise Board oversees our corporate social responsibility (CSR) efforts, including our climate-related initiatives. Forexample, at the January 2021 meeting, the committee reviewed the Ameriprise Responsible Business Report, which includes our climate-related strategy and work. Thechairman of the Committee, who also serves as Lead Independent Director, also participated on investor calls where climate change risk management and disclosureswere discussed. As noted previously, climate change is viewed as a long-term strategic risk within our Enterprise Risk Management process. Management regularlyupdates the Board on the regulatory environment and emerging risks. The Board discusses with management, the general auditor and independent auditors the company’senterprise-wide risk assessment and risk management processes, including: Prevailing material risks and exposures Actions being taken to mitigate these risks Thedesign and effectiveness of our processes and controls in light of evolving market, business, regulatory and other conditions.C1.2CDPPage 2 of 31
(C1.2) Provide the highest management-level position(s) or committee(s) with responsibility for climate-related issues.Name of the position(s) and/orcommittee(s)Reporting lineResponsibilityCoverage of responsibilityFrequency of reporting to the boardon climate-related issuesChief Executive Officer (CEO)Reports to the board directlyAssessing climate-related risks andopportunitiesRisks and opportunities related to ourown operationsAs important matters ariseChief Risks Officer (CRO)CEO reporting lineAssessing climate-related risks andopportunitiesRisks and opportunities related to ourown operationsAs important matters ariseOther, please specify (VicePresident, Real Estate)Finance - CFO reporting lineBoth assessing and managing climaterelated risks and opportunitiesRisks and opportunities related to ourown operationsNot reported to the boardChief Investment Officer (CIO)Investment - CIO reporting lineAssessing climate-related risks andopportunitiesRisks and opportunities related to ourinvesting activitiesNot reported to the boardOther, please specify (CTIInvestment - CIO reporting lineResponsible Investment leadership)Both assessing and managing climaterelated risks and opportunitiesRisks and opportunities related to ourinvesting activitiesNot reported to the boardFacility managerFinance - CFO reporting lineManaging climate-related risks andopportunitiesRisks and opportunities related to ourown operationsNot reported to the boardCorporate responsibility committeeOther, please specify (Ameriprise Corporate Social Both assessing and managing climateResponsibility Steering Committee)related risks and opportunitiesRisks and opportunities related to ourown operationsAnnuallyOther, please specify (RiverSourceLife Risk Management)Other, please specify (Reports to head ofRiverSource Life subsidiary)Risks and opportunities related to ourinsurance underwriting activitiesNot reported to the boardAssessing climate-related risks andopportunitiesC1.2a(C1.2a) Describe where in the organizational structure this/these position(s) and/or committees lie, what their associated responsibilities are, and how climaterelated issues are monitored (do not include the names of individuals).The Nominating and Governance Committee of the Ameriprise Board oversees our corporate social responsibility (CSR) efforts. Our CSR Steering Committee (SteerCo)works closely with members of the company's Executive Leadership Team, and provides a twice annual update to the CEO, and an annual update to the Nominating andGovernance Committee.The SteerCo is well-positioned to monitor climate-related risks and opportunities. Climate-related issues are discussed by the SteerCo at their bi-monthly meetings. TheSteerCo also produces the company's annual Responsible Business Report, which includes our climate positioning and risk management processes. SteerCo membershipincludes senior leaders from Corporate Communications, Community Relations, Human Resources, Investor Relations, Real Estate, Responsible Investment (RI) atColumbia Threadneedle Investments (Columbia Threadneedle), Ameriprise Wealth Management, RiverSource Life, and our General Counsel's Organization, including ourCorporate Secretary. In addition, the SteerCo includes representation from our Operational Risk Management Committee, chaired by our Chief Risk Officer (CRO).The CRO is responsible for the company’s global risk management processes. The CRO reports on material risks to the Ameriprise Board of Directors. The CRO considersrisks within our diversified business model, including risks and opportunities related to our business as a wealth manager, asset manager and insurer. More broadly, the CROdesigns and executes our risk management approach within our operational and enterprise risk management capability. Climate is considered a long-term strategic risk withinthis framework. We are working to advance our capabilities and strengthen the linkages between our risk organization and our approach to CSR, including climate strategy.As a financial services firm, Ameriprise is a low GHG-emitter. We work to monitor and manage emissions from our operations. From an organizational standpoint, the RealEstate team, including the Vice President and facility managers, monitors, tracks and manages our energy use and emissions. Our Real Estate team accounts for theoperational impacts from acute or chronic weather changes that may impact our employees, offices or facility projects. The team also complies with all relevant regulatorypolicies that may impact our operational footprint. For example, municipal ordinances regarding environmental performance and reporting.Columbia Threadneedle, the global asset management group of Ameriprise, is a signatory of the Principles for Responsible Investment (PRI). The Head of ResponsibleInvestment Policy and Head of Stewardship are senior leaders within our Responsible Investment business and report within Investments. Additionally, they are members ofthe Ameriprise CSR SteerCo. Our global RI team works alongside our investment professionals facilitating environmental, social and governance analysis into our investmentprocesses for our portfolio managers' consideration when making investment decisions for the funds and accounts they manage.Columbia Threadneedle manages the assets of the RiverSource Life general account. RiverSource Life benefits from the RI capabilities and approach at ColumbiaThreadneedle, which includes assessing the actions/plans of portfolio companies as they work to meet their emissions goals and how this impacts the current and prospectivecarbon intensity of the portfolio. RiverSource Life is also beginning to consider climate risk as part of its overall risk management approach.C1.3(C1.3) Do you provide incentives for the management of climate-related issues, including the attainment of targets?Provide incentives for the management of climate-related issuesRow 1 YesCDPCommentNon-monetary recognition relates to our facilities team and are associated with energy efficiency projects, as detailed below.Page 3 of 31
C1.3a(C1.3a) Provide further details on the incentives provided for the management of climate-related issues (do not include the names of individuals).Entitled to incentiveType of incentiveActivity inventivizedCommentFacilities managerNon-monetary rewardEnergy reduction projectOur real estate team receives recognition for energy reduction initiatives in performance reviews.C-FS1.4(C-FS1.4) Does your organization offer its employees an employment-based retirement scheme that incorporates ESG principles, including climate change?Row1We offer an employment-based retirement scheme that incorporates ESG principles, including climatechange.CommentYes, as an investment option for some plans offeredYes, a broad selection of ESG strategies are available through our self-directed brokerageoption.C2. Risks and opportunitiesC2.1(C2.1) Does your organization have a process for identifying, assessing, and responding to climate-related risks and opportunities?YesC2.1a(C2.1a) How does your organization define short-, medium- and long-term time horizons?From (years)To (years)CommentShort-term01Realized risks are also sometimes defined within a 0-18 month timeframe.Medium-term13Long-term3100C2.1b(C2.1b) How does your organization define substantive financial or strategic impact on your business?Ameriprise considers climate as a long-term strategic risk within our Enterprise Risk Management (ERM) process. Within this framework, the Enterprise Risk ManagementCommittee (ERMC) provides oversight for firm-wide strategic, financial and operational risk.Through our ERM process, the company evaluates substantive financial impacts on a quarterly basis. Each business unit identifies and assesses material operational risks aspart of an annual risk and control self-assessment. Business unit leads score each risk on three dimensions: probability of occurrence, financial impact and controlenvironment.Consideration of climate risk within the ERM process began in 2020 and continues to evolve over time.C2.2CDPPage 4 of 31
(C2.2) Describe your process(es) for identifying, assessing and responding to climate-related risks and opportunities.Value chain stage(s) coveredDirect operationsUpstreamRisk management processIntegrated into multi-disciplinary company-wide risk management processFrequency of assessmentMore than once a yearTime horizon(s) coveredLong-termDescription of processAt the enterprise level, Ameriprise considers climate risk to be a long-term strategic risk. The company reviews long-term strategic risks on an ongoing bases, and formallyreviews them as part of its enterprise risk management process annually. In addition, the company reviews strategic risk and the actions to mitigate the potential impact ofthose risks as part of its long-range planning process. Ameriprise, and its subsidiaries, Columbia Threadneedle and RiverSource Life, continue to evolve their climateapproach and capabilities to manage risks and opportunities, as well as meet current and evolving regulatory requirements.C2.2a(C2.2a) Which risk types are considered in your organization's climate-related risk assessments?Relevance Please ncludedAs a diversified financial services firm, our businesses are heavily regulated. Virtually all aspects of our business, including the activities of our subsidiaries, are subject to various federal,state and international laws and regulations. Examples include the European Commission’s regulations that impact all EU domiciled accounts managed by Columbia Threadneedle, andthe evolving approaches being considered in the U.S., including at the U.S, Securities and Exchange Commission (SEC) and state insurance edAs a diversified financial services company, Ameriprise is subject to risks and uncertainties that reflect an evolving regulatory environment. As an example, the SEC is considering publicinput from investors, registrants, and other market participants on climate change disclosure. In May 2020, the SEC Investor Advisory Committee approved recommendations urging theCommission to begin an effort to update reporting requirements for issuers to include material, decision-useful environmental, social, and governance (ESG). In December 2020, the ESGSubcommittee of the SEC Asset Management Advisory Committee issued a preliminary recommendation that the Commission require the adoption of standards by which corporateissuers disclose material ESG risks. As investor demand for climate change risks, impacts, and opportunities continues to grow, we expect that the SEC will be evolving its regulations torequire more thorough ESG reporting.Technology Relevant,alwaysincludedTechnology is a key component of our business, and any risk would be assessed against the ability to deliver the technology component of that particular area, including climate. As anexample, physical risks related to technology infrastructure are considered annually when IT conducts a risk assessment, vertically and horizontally across the organization.LegalRelevant,alwaysincludedAs a financial services firm, our operations are generally not subject to climate or environmentally related litigation claims. However, as with other financial services firms, the level ofregulatory activity and inquiry concerning our businesses remains elevated. On occasion, Ameriprise receives requests for information from the SEC, the Financial industry regulatoryAuthority, the OCC, the U.K. Financial Conduct Authority, the FRB, state insurance and securities regulators, state attorneys general and various other domestic and foreign regulators.Failure to comply with laws, regulations or policies applicable to the business could result in negative actions by regulatory authorities resulting in civil penalties or reputational damagewhich could have a material adverse effect on our business. Ameriprise assesses regulatory requirements on an ongoing basis to ensure compliance with all obligations, includingapplicable environmental and climate-related laws and other requirements.MarketRelevant,alwaysincludedWe monitor evolving industry trends to inform our business strategy and identify market risks, which may include changes in client demand. As ESG investment trends evolve, clients maybe interested in allocating a higher percentage of their investments to Responsible Investment (RI)/Environmental, Social and Governance (ESG) strategies and solutions over time. Theinvestment approach for our asset management business, Columbia Threadneedle (CTI), is underpinned by its research intensity and belief that sharing insights across asset classes andgeographies generates a richer perspective on global, regional and local investment landscapes. Consistent with this core belief, Responsible Investment (RI) research and data areintegrated and embedded into our global research capability, facilitating the integration of material ESG factors into our research processes. In fact, part of our extensive fundamentalresearch includes an innovative, proprietary RI ratings tool that combines an assessment of a company’s financial stewardship with a view on how well it manages ESG risks as identifiedby the Sustainability Accounting Standards Board (SASB). By combining both aspects into a single, forward-looking score, the tool reflects CTI’s conviction that prudent management offinancial and ESG factors are important to a company’s ability to create long-term, sustainable value. Columbia Threadneedle reported 32 billion in RI AUM at year-end 2020 and isworking to grow this business. We have a 15-person RI specialist team in London and Minneapolis. As part of this effort we announced the acquisition of Bank of Montreal’s (BMO’s) EMEAasset management business, which is scheduled to be completed in Q4 2021. BMO is a recognized leader in RI, and this was one of the key drivers of the acquisition. As we bring our twobusinesses together, we will leverage established capabilities, processes and frameworks within both organizations to progress our combined approach. Integrating BMO’s RI/ESGapproach alongside Columbia Threadneedle’s established capability and practices will be a priority, and we expect this work will enable significant progress in terms of our climate changestrategy and environmental management approach. In addition to the RI capability within CTI, Ameriprise offers clients and advisors a range of RI/Thematic ESG products and solutionsfrom third-party asset managers within mutual fund, ETF and separate account investment vehicles.Reputation Relevant,alwaysincludedOur reputation is one of our most important assets. Our ability to attract and retain customers, investors, employees and advisors is highly dependent upon external perceptions of ourcompany. Damage to our reputation could cause significant harm to our business and prospects. Reputational damage may arise from numerous sources, including litigation or regulatoryactions, failing to deliver minimum standards of service and quality, compliance failures, any perceived or actual weaknesses in our financial strength or liquidity, political, social orenvironmental issues, and technological or security breaches. Additionally, a failure to develop new products and services, such as those related to ESG demand, could harm ourreputation. To help mitigate reputational risks related to climate, our investors are increasingly monitoring opportunities and risks related to Responsible Investment/ESG strategies,recognizing that the field is evolving to one that combines an expectation of improved performance related to sustainability factors and alignment with one's values. Additionally, Ameriprisemaintains environmental transparency through its Responsible Business Report and participation in this survey.AcutephysicalRelevant,alwaysincludedThe occurrence of climate-related natural disasters and catastrophes, including severe weather are considered risk factors for our business and could adversely affect our operations andthe financial condition of our business. Such acute physical risks may damage our facilities, preventing our service providers, employees and financial advisors from performing their roles,or otherwise disturbing our ordinary business. These risks may also impact us indirectly by changing the condition and behaviors of our customers, business counterparties and regulators,as well as by causing declines or volatility in the economic and financial markets. Our real estate team monitors the acute physical risks that may affect the facilities in our sincludedOur real estate team monitors chronic shifts in climate that may affect the facilities in our operational footprint. For example, severe weather such as heat waves, winter weather or severeseasonal storms may impact our energy efficiency. We partner with our local utilities in Minneapolis and participate in load shedding to help reduce overall demand. We also participate inXcel Energy's Commercial Efficiency Program to evaluate and implement energy efficiency projects. In addition, in 2020 we purchased 22 million kWh of Minnesota-sourced renewableenergy certificates (RECs) to offset the 2020 energy consumption of our 1.8 million square foot Minneapolis campus. Flexibility in our building design also helps to mitigate chronic climaterisks. Both buildings on our Minneapolis campus are ENERGY STAR certified and have received the U.S. Green Building Council's Leadership in Energy and Environmental Design(LEED) certification.C-FS2.2bCDPPage 5 of 31
(C-FS2.2b) Do you assess your portfolio’s exposure to climate-related risks and opportunities?WePlease k) Not Not Applicable Applicable Investing(Assetmanager)YesInvesting(Assetowner)No, but we As part of our commitment to advance our efforts related to climate change and strategy, we continue to advance our climate capabilities, understanding the leading frameworks at theplan to do enterprise and subsidiary levels, including our asset management business and our insurance business.so in thenext twoyearsInsuranceunderwriting(Insurancecompany)No, but we As part of our commitment to advance our efforts related to climate change and strategy, we continue to advance our climate capabilities, understanding the leading frameworks at theplan to do enterprise and subsidiary levels, including our asset management business and our insurance business.so in thenext twoyearsOtherproductsandservices,pleasespecifyNo, but we As part of our commitment to advance our efforts related to climate change and strategy, we continue to advance our climate capabilities, understanding the leading frameworks at theplan to do enterprise and subsidiary levels, including our asset management business and our insurance business.so in thenext twoyearsWithin Columbia Threadneedle, climate-related risks and opportunities form some of the ESG factors that are assessed through our research and stewardship activities. Ourinvestment/research teams consider the risks and opportunities posed by the energy transition across sectors, and our method for prioritizing company engagements uses data pointsfrom the Transition Pathway Initiative. Climate-related risks and opportunities are also a feature, where material, Columbia Threadneedle’s proprietary Responsible Investment ratings builton the SASB framework that includes climate risk factors in 72 of 77 industries. In addition, Columbia Threadneedle is developing enhanced models with a more forward-looking focus,which will enable us to deliver more dynamic, evidenced-based approaches to managing client and portfolio risks and opportunities related to climate strategy. These models reflect thework and analytics being completed in response to the EU Sustainable Finance reforms and include carbon lock-in models, carbon pathway analysis and related thematic outcomeanalysis.C-FS2.2c(C-FS2.2c) Describe how you assess your portfolio’s exposure to climate-related risks and opportunities.Portfolio Assessment Descriptioncoverage typeBanklending(Bank) Not NotApplicabl Applicable e Not Applicable Investing(Assetmanager)Unknown QualitativeClimate related risks and opportunities form some of the ESG factors that are assessed through our research and stewardship activities. Columbia Threadneedle investmentteams currently have a workstream focused on the risks and opportunities posed by the energy transition across sectors, and our method for prioritizing companyengagements uses data points from the Transition Pathway Initiative. Climate related risks and opportunities are also a feature, where material, in our proprietaryResponsible Investment ratings built on the SASB framework that includes climate risk factors in 72 of 77 industries. Various funds also use fossil fuel exclusion policies,and/or positive inclusion methodologies for clean energy stocks and bonds, but these are a minority of the assets under management currently.Investing(Assetowner) Not NotApplicabl Applicable e Not Applicable Insurance Not Notunderwriting Applicabl Applicable (Insurance e company) Not Applicable Otherproductsandservices,pleasespecify Not Applicable Not NotApplicabl Applicable e C-FS2.2dCDPPage 6 of 31
(C-FS2.2d) Do you assess your portfolio’s exposure to water-related risks and opportunities?WePortfolio Please ending(Bank) Not Not Not Applicable Applicable Applicabl e Investing(Assetmanager)YesInvesting(Assetowner)No, we NotAs an asset owner we do not generally consider exposure to water-related risks or opportunities as part of our assessment.don’tApplicablassess this e Minorityof theportfolioIn reference to how we assess our “portfolio’s” exposure, our asset management business, Columbia Threadneedle (CTI), considers water-related risks, where material, inCTI’s proprietary
The company manages more than 590 billion of assets across developed and emerging market equities, fixed income, asset allocation solutions and alternatives. In addition, Ameriprise provides life and annuity products through RiverSource Life Insurance Company. Ameriprise is a values-driven firm.
