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<p>My Lords, we are undertaking a post-implementation review of the Occupational Pension
Schemes (Climate Change Governance and Reporting) Regulations 2021. We aim to conclude
the review this year.</p><p> </p><p> </p><p>We recognise that recent reports, including
“Climate Scorpion-the sting is in the tail” have shown the limitations of the models
currently available for scenario analysis. Therefore, we welcome work within the industry
to ensure that scenario analysis models are decision useful and will look to acknowledge
the issue in the review.</p><p> </p><p> </p><p>However, we do not believe that the
Government should mandate which models should be used by Pension Schemes. It is important
that modelling which takes into account of ESG is allowed to develop and evolve as
data availability increases.</p>
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