Lloyd’s of London Environmental, Social and Governance Guidance Summary

ClientEarth criticizes the Society of Lloyd’s ESG Guidance for being non-binding and lacking transparency, short-term targets, and a fossil fuel phase-out plan. The letter asserts that the Guidance represents a retreat from previous commitments and risks legal breaches regarding climate risk management and public disclosure.

• The ESG Guidance is not binding on managing agents, meaning they can disregard the Society's net-zero ambitions without formal consequence, receiving only "thematic feedback for consideration".
• There is a significant lack of transparency because the Guidance does not require individual managing agents or syndicates to disclose their climate policies, targets, or the emissions from their underwriting and investment portfolios, providing only "aggregated data for the whole Market".
• The Guidance fails to establish clear short or medium-term emissions targets or a science-based pathway to limit warming to 1.5°C, allowing agents to set a 2050 target without taking immediate action.
• The Guidance represents a reversal of previous commitments regarding the phase-out of coal, tar sands, and Arctic oil (the "Fuel Targets"), as it no longer mandates their exclusion and does not refer to them in its sustainable underwriting section.
• ClientEarth argues that relying on engagement with policyholders without strict exclusion policies is ineffective for fossil fuel companies, noting that 91% of the largest oil and gas companies generate over 90% of their revenue from fossil fuel activities.
• The Society and Council members are allegedly at risk of breaching legal duties to manage climate risks and duties not to mislead the public, as public claims of concrete action contradict the ineffectual nature of the Guidance.

APA

ClientEarth (2021). Lloyd’s of London Environmental, Social and Governance Guidance Summary. https://www.clientearth.org/media/rddktl5f/letter-to-lloyd-s-on-esg-guidance-december-2021-redacted-signatures.pdf

Chicago

ClientEarth. Lloyd’s of London Environmental, Social and Governance Guidance Summary. 2021. https://www.clientearth.org/media/rddktl5f/letter-to-lloyd-s-on-esg-guidance-december-2021-redacted-signatures.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Lloyd’s of London Environmental, Social and Governance Guidance Summary |date=13 December 2021 |url=https://www.clientearth.org/media/rddktl5f/letter-to-lloyd-s-on-esg-guidance-december-2021-redacted-signatures.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021lloyds, author = {{ClientEarth}}, title = {{Lloyd’s of London Environmental, Social and Governance Guidance Summary}}, publisher = {ClientEarth}, year = {2021}, month = dec, url = {https://www.clientearth.org/media/rddktl5f/letter-to-lloyd-s-on-esg-guidance-december-2021-redacted-signatures.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }