Scale climate action across a multi-sector group

Submitted through the COP31 Sustainable Transformation Awards · SKD Türkiye (WBCSD Global Network Partner)

Fiba Group operates across 10 countries and 5 sectors — finance, energy, real estate, retail and hospitality — with 17 main subsidiaries and more than 8,600 employees.

Subsidiaries operated under different regulatory and reporting regimes and had varying levels of maturity in measuring their environmental performance. Before 2023, the group had no standard emissions calculation method and no common climate risk framework.

The diversity of the group created a need for greater standardisation across environmental management and reporting. Differences in subsidiary methodologies made it difficult to aggregate emissions consistently, compare climate exposure across businesses and respond to evolving regulatory expectations. At the same time, subsidiaries were often addressing similar methodological questions separately.

The group launched the programme in 2023 to replace that fragmentation with shared governance, data and risk infrastructure. Using 2023 as the baseline year, the programme follows a group-wide sequence: measure, manage, reduce and scale. Its objectives are to build a credible greenhouse-gas inventory, integrate climate risk into decisions and prepare every subsidiary for a low-carbon transition.

Location of the initiative: headquartered in Türkiye, with group operations in 10 countries including the Netherlands, Germany, Switzerland, Malta, Moldova, Romania, Russia, Ukraine, and China.

The programme's premise is simple: a diversified group cannot manage a transition it cannot monitor. By establishing shared rules while leaving operational action with each subsidiary, the group turns fragmented environmental reporting into decision-grade infrastructure for emissions reduction and climate risk management.

The programme provides a group-wide framework that supports consistent measurement, informed target setting and continuous improvement, combining common methodologies and oversight structures with capacity building, peer learning and subsidiary-level action.

• Board-led governance, group-wide delivery:

  The Sustainability (ESG) Committee, which reports to the board of directors, sits at the top of the governance structure; sets the group's sustainability agenda by determining sustainability strategy and goals, defining the roadmap, and overseeing performance monitoring. The Sustainability (ESG) Directorate serves as a bridge between the holding and subsidiaries, coordinating the group-level strategy and execution. 243 representatives from 17 subsidiaries and 3 social investment institutions sit across 17 ESG Working Groups — 7 environmental, 6 social, 4 governance groups — each meeting at least four times a year to coordinate implementation, develop common approaches, share good practices and monitor progress.

• From shared principles to credible data:

  The group launched its Environmental Policy to set out its operating principle: measure, manage, reduce, scale. Greenhouse gas emissions are calculated under the GHG Protocol; climate risks are assessed using the approach of the Task Force on Climate-related Financial Disclosures (TCFD). Climate-related risks are tracked across 7 main and 14 sub-categories and integrated into the group’s broader financial and operational risk management processes through regular assessments.

• Building internal expertise and a learning culture:

  Since the programme's launch, the group has delivered targeted training and workshops for technical teams, working-group members and senior leaders. The working groups also provide a structured forum for subsidiaries from different sectors to exchange experience, share practical solutions and learn from one another. Together, these mechanisms strengthen internal expertise and foster a culture of peer learning and continuous improvement across the group.

• Subsidiary-to-group: central rules, local action:

  The operating model is described as subsidiary-to-group. Each subsidiary develops actions appropriate to its own operations, while common methodology, data quality standards, and reporting discipline are maintained centrally. A bank, a hotel and a renewable-energy producer therefore pursue different interventions, while the centre maintains common definitions, data-quality expectations and reporting discipline. This balance between central control and local relevance is the programme's core design feature.

• Building transparency through phased assurance:

  Environmental data is monitored and reported annually, while independent verification and assurance are being progressively expanded across the group, building a bottom-up assurance capability from subsidiary to group level. In addition to the voluntary group sustainability report, subsidiaries in banking, renewable energy, asset management and pensions have begun publishing stand-alone reports aligned with the Turkish Sustainability Reporting Standards and completing their own audit processes.

• Embedding stakeholder input into strategy and prioritisation:

  Stakeholder perspectives are incorporated into the development and review of the group’s sustainability strategy and priorities. As part of the latest strategy revision, the double materiality assessment involved 42 interviews with 125 internal and external stakeholders, including senior management, employees, financial institutions, business partners, civil society, academia and the entrepreneurship ecosystem. The assessment identified 16 priority topics, which were reviewed and integrated into the group’s sustainability strategy by the Sustainability (ESG) Committee.

Figure 1: Fiba Group's sustainability governance model: board oversight, the Sustainability (ESG) Committee and Directorate, the 17 ESG working groups and the subsidiary ESG representatives who apply the group methodology locally.

Sustainability Impact

Climate

The programme’s performance is tracked through 5 indicators: Scope 1, Scope 2 and Scope 3 emissions and the reporting boundary; the number of companies subject to independent assurance; the maturity of climate risk management; renewable energy generation and consumption; and the environmental transformation initiatives implemented by subsidiaries.

Coverage is the primary result. Scope 1 and Scope 2 emissions are now monitored regularly in every subsidiary, where previously no group-wide standard existed. The number of subsidiaries calculating Scope 3 emissions rose from 4 at the 2023 baseline to 11 in 2024 and all 17 in 2025.

Scope 1 and Scope 2 emissions at group level fell from 285,153 tCO2e in 2024 to 47,905 tCO2e in 2025 — a reduction of 83.2%. Almost all of that came from a portfolio decision rather than operational abatement: the transfer of the group's entire shareholding in a coal mining company and a solid fuel company, taken as part of a responsible investment approach.

Scope 3 entered group reporting for the first time in 2025, at 305,805 tCO2e, bringing total group emissions to 353,710 tCO2e. Scope 3 categories are reported based on their materiality to each business and its value chain, reflecting the group's diverse sectoral profile.

Figure 2: Scope 3 reporting principles: for each subsidiary, which of the 15 GHG Protocol Scope 3 categories are calculated, planned for calculation, of limited materiality or not applicable.

Independent verification of emissions data has been completed at the holding company and 5 subsidiaries, and independent assurance processes have been completed at a further 4 entities.

Renewable generation is the group's largest positive contribution. Renewable energy generation across the group reached 1,688,295 MWh in 2025, of which 1,685,920 MWh came from Fiba Renewables.

Nature

The programme is gradually expanding its focus to include nature-related topics.

The group developed a Biodiversity Impact Monitoring Framework and established a dedicated working group involving representatives from 7 subsidiaries and 1 social investment institution, alongside wildlife experts and environmental engineers.

Water stress was analysed across all 254 group locations in Türkiye and abroad using the baseline water stress indicator in the World Resources Institute’s Aqueduct Water Risk Atlas. This gives a common basis for comparing exposure between subsidiaries operating in very different climates.

External collaboration connects internal capability with wider conservation efforts. The group has conducted biodiversity awareness activities with KuzeyDoğa Derneği and supported TÜSİAD’s report on carbon sinks, drawing on the expertise of established conservation and business organisations.

Social

Capacity building is how the programme reaches people rather than reports.

The mandatory, group-wide 30-minute ESG101 introductory course achieved a 94% completion rate among local employees, reaching 4,555 employees.

The Sustainability (ESG) Directorate organised additional advanced training for participants in the 7 environmental working groups, totalling 901 hours for 103 individual participants, and convened 39 environmental working group meetings, strengthening technical capability, peer learning and solution development across the portfolio. In 2025, 50 leaders drawn from the board, holding company directors and subsidiary senior management received 6 hours of sustainability training delivered by an external professional services firm, in order to strengthen the role of climate considerations in decision making.

The expertise and knowledge developed within the organisation does not stop at the workforce. The sustainability directorate submitted research and proposals to the parliamentary environment committee during the preparation of Türkiye's climate law. The group's sustainability director was also selected as an Eisenhower Fellow in 2025 and has transferred insights on climate adaptation gathered from contacts with approximately 70 leaders in the United States back into the group and its ecosystem. Collaborations with local NGOs also support the integration of the climate agenda into education curricula.

The group serves 21 million customers in its financial businesses and 82 million in its non-financial businesses. Embedding low-carbon considerations into products and operations therefore creates a multiplier effect reaching individual and corporate customers, subsidiaries, employees and business partners.

Business Impact

Benefits

The clearest financial benefit is access to sustainability-linked finance. In 2025 the holding company concluded its first loan agreement carrying sustainability key performance indicators, which brought environmental performance directly into financing conditions. Fiba Renewables secured European Bank for Reconstruction and Development (EBRD) financing for a hybrid plant project, and a cooperation protocol was signed with the EBRD for a green-certified, roughly 500-bed student residence at Özyeğin University.

Comparable data improves capital allocation. Once subsidiaries in different sectors and countries report on one methodology, climate risk and emissions performance can be weighed against each other in investment decisions rather than assessed case by case.

Regulatory readiness is delivered once rather than 17 times. Common methodology, data standards and reporting discipline mean that a subsidiary facing a new sustainability reporting requirement draws on group infrastructure instead of building its own — reducing both cost and the risk of inconsistent disclosure.

The programme has also opened revenue-side opportunities in the financial businesses. Fibasigorta (Fiba’s insurance subsidiary) launched two climate-focused insurance products, while HDI Fibaemeklilik (Fiba’s pensions management subsidiary) introduced an ESG Sustainability Fund Basket that invests at least 80% of its portfolio in sustainability-themed funds. Fiba Portföy (Fiba’s portfolio management company) is also developing a sustainability-focused fund.

Independent verification and assurance help make financing benefits more durable by strengthening confidence in published data.

Costs

The cost base is capability, not capital equipment. It comprises the central Sustainability Directorate that coordinates the programme; staff time committed across the subsidiaries; the processes used to collect, consolidate and manage environmental data; and fees paid to external providers for verification, assurance, training, and reporting at the holding company and subsidiary levels.

The group does not disclose a single consolidated programme cost, because the resources are distributed across the subsidiaries rather than held in one central budget. Costs are contained by standardising the methodology once and reusing it, and by sharing good practice between businesses that face similar problems in different countries. Capability is built internally rather than purchased separately by each subsidiary through external advisory support.

Impact Beyond Sustainability And Business

Co-benefits

Individual subsidiaries have delivered results that the common framework makes visible and comparable. The first output of that sequence appears in the 2025 report, which discloses 22 environmental targets set by 5 subsidiaries for the first time.

Fiba Renewables reached 730 MW of installed capacity, generated 1.68 TWh in 2025 and avoided more than 1 million tCO2e in that year alone. It thereby met the 9 million tCO2e cumulative avoided-emissions target it had set for 2025 and is working towards 15 million by 2030 and 30 million by 2040. Its 2040 net-zero target has been approved by the Science Based Targets initiative. It also retained its A score in the CDP Climate Change programme and was included in CDP’s 2025 Supplier Engagement A List.

In the financial businesses, Fibabanka implemented a climate risk and ESG integration programme, began managing its Scope 2 emissions through certified renewable electricity, and supported the commercialisation of Committed, a carbon-neutral solutions venture, through its investment. Nexent Bank, the group's Netherlands-based bank, has established a 2050 net zero roadmap. The bank phased out direct financing for thermal coal by the end of 2024 and enforces risk appetite limits and prohibited activities for the broader fossil fuel industry.

In the non-financial businesses, Swissôtel The Bosphorus continued advanced carbon footprint reduction and efficiency work; Starmall, a shopping mall investment in China, generated 2,375 MWh from a rooftop solar installation; and Anchor Group, a real estate investment with properties in Romania, supplied 5,210 MWh of renewable electricity to its tenants through supplier agreements — extending access to low-carbon energy to its tenants rather than limiting it to its own operations.

Through its venture arm, the group also supports climate- and environment-focused start-ups in Türkiye and abroad, which extends the effect beyond the boundary of the group's own emissions.

Potential side-effects

Better measurement can look like worse performance. Expanding Scope 3 coverage from 4 subsidiaries at the 2023 baseline to all 17 in 2025 raises reported emissions even where nothing has changed physically, because more of the value chain becomes visible. Improved coverage and higher headline figures can occur together, making clear and contextualised reporting particularly important.

Central standardisation carries an implementation burden for smaller subsidiaries, whose data capacity is the binding constraint. Applying one methodology across very different maturity levels risks either overloading the weakest businesses or diluting the standard. The group manages this through central coordination, standard methods, regular trainings, and internal control mechanisms.

A programme built on committees and working groups depends on continued senior attention. Board-level oversight, coordination by the Sustainability Directorate and leadership training help maintain its connection to strategic and operational decision-making, while enabling the programme to continue evolving over time.

Typical Business Profile

The model suits holding companies, investment groups and multinational parents whose subsidiaries operate in different sectors, countries and regulatory regimes, and where the group needs comparable environmental data for capital allocation, financing and disclosure rather than a single operational abatement programme.

It is most relevant where the parent has enough governance authority to impose a common methodology, but not enough operational control to run the subsidiaries' environmental programmes directly, which is the usual position of a holding company with 17 businesses across 10 countries.

Delivery engages a central sustainability directorate, board-level committee oversight, subsidiary sustainability committees, sustainability and risk management teams, finance and treasury functions, and the operational teams in each subsidiary that own the primary data.

Approach

The programme was built in stages, not all at once. That experience generalises into nine steps.

1. Establish board-level ownership first. Create a sustainability committee reporting to the board that meets at least 3 times a year to assess climate change, environmental risk, regulation and sustainability performance, set group priorities and integrate them into business decisions.

2. Appoint named representatives in every subsidiary. Identify ESG representatives across the group and organise them into thematic working groups — here 243 representatives across 17 groups, 7 of them environmental — so that the central directorate has a counterpart in each business.

3. Issue one methodology and one policy. Adopt the GHG Protocol for emissions and the TCFD approach for climate risk, and publish a group environment policy stating the operating principle, so that subsidiaries are not choosing methods independently.

4. Start with the emissions every subsidiary can measure. Bring Scope 1 and Scope 2 into regular monitoring everywhere before extending to Scope 3: comparable partial coverage is more useful than inconsistent full coverage.

5. Extend value chain accounting deliberately. Raise the number of subsidiaries calculating Scope 3 emissions in planned steps — here from 4 at the 2023 baseline to all 17 in 2025 — and accept that reported emissions will rise as visibility improves.

6. Verify externally, and in sequence. Take emissions data through independent verification and then assurance, starting with the holding company and the largest subsidiaries, so that credibility is established where the numbers matter most.

7. Build a climate risk register with a fixed structure. Track risks across defined headings — here 7 main and 14 sub-headings — and assess them at regular intervals jointly with the risk management teams that already run the enterprise risk process.

8. Invest in capability at every level. Run mandatory introductory training for all employees, technical training for sustainability teams and dedicated sessions for senior leadership — and measure completion, not attendance.

9. Attach the results to financing and products. Use sustainability key performance indicators in loan agreements and development bank financing, and translate the capability into customer-facing products where the group has the businesses to do so.

Stakeholders Involved

• Project leads: The programme is owned at board level. The Sustainability (ESG) Committee, which reports to the board of directors, meets at least three times a year to assess climate change, environmental risks, regulatory developments, social initiatives and sustainability performance, determines group priorities and supports their integration into business decisions. It is chaired by the vice chairman of the board, has 3 members and 5 participants, and met 3 times in 2025 alongside 11 senior management meetings. Coordination is carried out by the holding company's sustainability directorate, which is responsible for strategy, targets, action plans and performance monitoring, translates strategy into roadmaps and leads the preparation of the annual sustainability report. Each subsidiary maintains its own committees and teams reporting to its general manager, and every subsidiary has a designated ESG representative so that coordination and reporting stay consistent across the group.

• Company functions: The 17 ESG working groups, subsidiary sustainability committees and designated ESG representatives are the mechanism through which sustainability reporting, greenhouse gas emissions management, climate risk and resource efficiency processes are aligned across the group. Risk management teams assess the group's climate risk register at regular intervals alongside the sustainability function, which keeps climate inside the enterprise risk process rather than beside it, while finance and treasury link environmental performance to financing conditions.

• Main providers: Emissions calculation, verification, assurance, reporting and training are carried out with external technical and professional services providers at both group and subsidiary level. Training for sustainability teams draws on civil society organisations, academics and independent specialists; environmental footprint reduction work is conducted with specialist teams, academia and public institutions.

• Other: The group works through collaborative platforms including the UN Global Compact, SKD Türkiye and TÜSİAD, and is represented on the UN Global Compact supervisory board.

Key Parameters To Consider

• Baseline year: 2023, the year the programme was launched. Environmental data is monitored annually, while independent verification and assurance are being expanded progressively across the group.

• Scale: 17 main subsidiaries in 10 countries and 5 sectors; 17 ESG working groups with 243 representatives, including 7 environmental working groups that met 39 times in 2025.

• Methodology: the GHG Protocol for greenhouse gas emissions, the TCFD approach for climate risk, and the WRI Aqueduct methodology for water stress.

• Principal constraints: the different maturity levels of the subsidiaries, their data collection capacity, the variability of operational priorities and differences in local legislation. These are managed through central coordination, standard methodologies, regular training and a performance monitoring system.

• Boundary sensitivity: emissions reported at group level are sensitive to portfolio and boundary changes. Scope 1 and 2 emissions fell from 285,153 tCO2e in 2024 to 47,905 tCO2e in 2025, a reduction driven mainly by divestment rather than by operational improvement, while Scope 3 entered group reporting for the first time in 2025 at 305,805 tCO2e.

Implementation And Operations Tips

Fix the methodology before setting the target. A group target agreed across subsidiaries using different calculation methods cannot be aggregated or verified, so comparability has to come first — even though it is the less visible achievement.

Expect reported emissions to rise as coverage improves. Moving from 4 subsidiaries at the 2023 baseline to all 17 in 2025 calculating Scope 3 emissions makes the inventory larger, and this requires clear, contextualised reporting to explain an increase that reflects better measurement rather than worse performance.

Use working groups as the transfer mechanism. With subsidiaries at very different maturity levels, a business that has already solved a problem is a cheaper and more credible source of help than an external adviser.

Give the programme a financial consequence early. Bringing sustainability key performance indicators into a loan agreement changed the internal status of the data: figures that affect financing terms are reviewed with a different level of care than figures that appear only in a report.

Build target-setting capacity alongside target development. Combine target-setting with clear methodologies, practical training and defined ownership so subsidiaries can translate group priorities into credible, measurable commitments.

External Links

Subsidiaries' sustainability reports:

• Fiba Renewables

• Gelecek Varlık Yönetimi

• Fibabanka

• HDI Fibaemeklilik