The TCFD, initiated by Bank of England Governor Mark Carney and Chaired by Michael Bloomberg, is supported by companies like BHP Billiton and Unilever, and financial institutions responsible for assets of $US20 trillion ($26.6 trillion). In December, it released a draft set of recommendations for how companies and investors should disclose a whole manner of climate risks to their business.

Risks fall into two main categories. 'Physical risks' include the impacts of climate change like extreme weather, altered rainfall patterns and sea-level rise, and 'transition risks' which include policy and market changes that are inevitable if we are to maintain a habitable climate.

The principle is compelling. If we're going to meet the goals of the Paris climate change agreement and hold global warming well below two degrees, a rapid decarbonisation of the economy will be required. Asking coal, oil and gas companies to explain just how they plan to be compatible with that future economy is a fair enough question.

The trouble is moving beyond the obvious need for greater disclosure, to investors actually insisting that the TCFD recommendations be implemented. Despite institutional investors and many superannuation funds telling us that engagement is a far better form of action than divesting from a company, their efforts to convince companies to improve disclosure of climate-related risks have been largely unsuccessful. Currently, just two ASX companies disclose analyses of their performance under a scenario where climate change is kept below two degrees - AGL Energy and BHP Billiton. And we can critique the robustness of those analyses on another day.

Why Santos? It's one of Australia's largest pure-play fossil fuel companies and in many ways going backwards on disclosure after deciding to not even produce a sustainability report this year. Santos don't disclose climate change mitigation scenario analysis, they don't have targets to reduce their own emissions, and their discussion of climate-related risks is severely limited. Late last year, investors specifically asked Santos to improve its disclosure, yet six months have passed, and it has delivered nothing.