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The Task Force on Climate-related Financial Disclosures (TCFD) was established by the Financial Stability Board (FSB) of the G20 in December 2015. It was created to draft recommendations for consistent and comparable climate-related corporate reporting. The corresponding recommendations report was published in June 2017. The proposed reporting is designed to support the various capital market players in fulfilling their role in promoting climate action by creating transparency in the way companies handle the risks and opportunities presented by climate change. In order to take the time horizon of climate change into account the focus is on the medium-term to long-term strategic orientation of the reporting companies. We have been actively supporting the TCFD since November 2017 and are publishing a TCFD index for the first time this year.

Recommended disclosure

Approach and examples


a) Describe the board's oversight of climate-related risks and opportunities.

At the Supervisory Board level, the Strategy and Sustainability Committee advises the Executive Board on matters of sustainability. These include sustainable corporate governance and our ESG business activities.

b) Describe management's role in assessing and managing climate-related risks and opportunities.

The Group Sustainability Board (GSB) is the central decision-making body for sustainability issues, including climate change along our value chain. The seven-member committee is made up of the Chair and one member from each Management Board area. It meets four times a year. Its tasks include strategic guidance on decisions regarding ESG initiatives (possibly with the Board of Management), setting targets and timetables, reviewing measures, and suggest project proposals on sustainability and progress in ESG ratings.

The Group ESG Strategy department is responsible for strategic analysis of climate-related challenges and global trends. It identifies and reviews ESG market trends, product initiatives and business opportunities together with the business units. Likewise, the department reviews our ESG profile and implements our climate strategy. Group ESG Strategy manages our ESG reporting with FA&C and supports cross-divisional ESG product initiatives. The Executive Board and the members of the GSB are informed about current developments every two months.



a) Describe the climate-related risks and opportunities the organization has identified over the short, medium, and long term.

We are currently planning to adapt our process for identifying climate risks. At present time we are examining climate risks as part of our operations. Our strategy regarding ESG can be found in our Combined management report within chapter “ESG: Commitment and opportunity for Deutsche Börse”.

b) Describe the impact of climate-related risks and opportunities on the organization's business, strategy, and financial planning.

The required transition to a climate-neutral economy creates diverse opportunities for us as a market infrastructure provider to offer products and services. At the same time, this will enable us to further diversify our product portfolio and meet our customers' growing demand for climate-related data and products. For this reason, we are developing new products and services that will further increase our net revenue and strengthen our market position. Our products and services increase market transparency and enable market participants to better evaluate and price climate opportunities and risks, which in turn has a positive impact on our net revenue and financial planning.

Opportunities divided into Pre-Trading, Trading & Clearing and Post-Trading:

Increasing market transparency
Increasing visibility and depiction of a two-degree-compatible economy through the indices

Trading & Clearing
World’s leading hub for IPOs of 2-degree-compatible companies and promotion of (young) companies 
Platform to transfer climate-related risks and und trade with emission allowances as well as segment for two-degree-compatible investments
Settlement of new investments of EEX through clearing houses to avoid high default risks

Through issuance into the international market (XS ISIN), international central securities depositories and custody volumes benefit indirectly from the LuxSE Green Exchange and can further increase listing venues and Xetra voluminal
EU-wide green investment fund labels and European green bond standards can both be used to capture custodial opportunities
Climate-related risks are currently documented in our operational risks, see section “Operational Risk” within chapter “Risk management” of our Combined management report. We planning to identify further climate-related risks.

c) Describe the resilience of the organization’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario.

We have not conducted a Group-wide climate scenario analysis to date. As part of the ESG stress tests, we analyze natural catastrophes that could lead to personnel/workplace losses.

Risk Management


a) Describe the organization’s processes for identifying and assessing climate-related risks.

The organizational structure and reporting channels of our risk management are explained in our Combined management report in the section “Implementation in the Group’s organizational structure and workflow”.
We are at the moment looking at the effects of physical climate change in the context of our operational risks.

b) Describe the organization’s processes for managing climate-related risks.

The management of climate-related risks is governed by our Risk Management Framework. With regard to long-term risks, we analyze the probability and financial impact of risk events - including climate risks - in so-called risk maps on a quarterly basis. We are focusing on these impacts as part of our operational risks at the moment. For more information, please refer to section “Operational Risk” within the chapter “Risk management” of our Combined management report.

c) Describe how processes for identifying, assessing, and managing climated-related risks are integrated into the organization’s overall risk management.

The management of climate-related risks is described within the section “Operational Risk” in the chapter “Risk management” of our Combined management report. We implement targeted measures to reduce operational risks. These include emergency and contingency plans, measures for information security and the physical security of employees and buildings, as well as compliance regulations and procedures. In addition, Deutsche Börse Group has insurance policies in place to partially cover the potential financial consequences of events causing operational loss. Natural disasters, accidents, terrorism, or sabotage are also operational risks that could, for example, destroy or severely damage a data center or office building. The precautions taken to maintain business operations are intended to avert significant financial losses.

Metrics & Targets


a) Disclose the metrics used by the organization to assess climate-related risks and opportunities in line with its strategy and risk management process.

We consider climate-related risks and opportunities along the value chain. Therefore, we distinguish between the company and product perspective. From the company perspective, we consider our own CO2 emissions. From the product perspective, we currently focus on our net ESG revenues. Group-wide CO2 emissions and ESG net revenues are disclosed under the Key Figures and Targets category. Since 2021, we have linked, among other factors, the CO2 reduction and ESG net revenue growth to Executive Board remuneration. For more detailed information, please refer to the Remuneration report. We are currently analyzing further suitable metrics and targets to increase transparency with regard to climate risks and opportunities.

b) Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 greenhouse gas (GHG) emissions and the related risks.

For Scope 1-3 emissions, please refer to our detailed presentation in our GRI index.

c) Describe the targets used by the organization to manage climate-related risks and opportunities and performance against targets.

We want to become climate-neutral by 2025, i.e. we will reduce our CO2 emissions per workspace by at least 70 per cent by 2023 (base year 2019). The remaining 30 per cent of emissions will be offset by external emission reduction projects. We intend to validate our path to climate neutrality with the Science Based Targets Initiative (SBTi). Further validation will be carried out via ESG rating agencies and the Carbon Disclosure Project (CDP).