Briefings & consultations 2020

Briefings

Region  Month Briefing  PRI briefing 

US

December

PRI 2021 US Policy Priorities

The PRI’s 2021 policy priorities focus on six areas we see as actionable and achievable to support greater adoption of the Principles and advancement of sustainable finance.


See briefing here

EU

November

EU Regulation on sustainability-related disclosures in the financial services sector

The regulation (EU) 2019/2088 (Sustainability Disclosures Regulation) introduces new requirements and clarifies the sustainability-related disclosure obligations in the financial services sector. This updated briefing explains the reporting requirements under the regulation, complementary reporting requirements under the taxonomy regulation and provides guidance on the identification of principal adverse impact.


See briefing here

EU

October

Delivering net zero emissions in the European Union

This briefing sets out key priorities to set the EU on a pathway to deliver a net zero emissions economy by 2050; and to do so in a way that is economically, politically and technologically achievable and ultimately beneficial. It is based on research from PRI’s Inevitable Policy Response project.


See briefing here

Japan

October

Sustainable finance policy briefing

This briefing presents an overview of Japan’s sustainable finance policy framework, as well as recommendations on further policy reforms on a national sustainable finance strategy, stewardship and corporate governance, ESG and climate disclosures, and asset owner regulations.


See briefing here

US

September

Fiduciary Duties Regarding Proxy Voting and Shareholder Rights

On August 30, the Department of Labor (DOL) issued a notice of proposed rulemaking entitled, “Fiduciary Duties Regarding Proxy Voting and Shareholder Rights.” The proposal aims to clarify the obligations of fiduciaries covered by the Employee Retirement Income Security Act of 1974 (ERISA) with regard to the exercise of proxy voting and shareholder rights, generally. This briefing document summarizes the proposal and provides information on how to respond.


See briefing here

China

September

ESG disclosure investor survey

This briefing presents the results of the investor survey on ESG disclosure in China led in May 2020, as well as the latest analysis on policy and market trends around ESG disclosure


See briefing here (English)(Chinese)

EU

September

Multiannual Financial Framework (MFF) and Next Generation EU

This position paper sets out recommendations for areas that need to be further defined to ensure the European recovery will be in line with the Paris Agreement objectives, ensure the European Green Deal and its objective of making Europe climate-neutral by 2050 are met, can be measured and lay the foundation to build back better.


See briefing here

US

August

How government and investors can deliver net-zero in the US

This report sets out priorities for US federal climate policy which are economically feasible, readily implementable, and necessary. Policy reform can also represent a growth opportunity to enhance US competitiveness and retool large sections of the US economy.


See briefing here

US

June

Financial factors in selecting plan investments

On June 23, the Department of Labor issued a notice of proposed rulemaking entitled “Financial Factors in Selecting Plan Investments” (“Proposal”) aimed at clarifying the obligations related to consideration of environmental, social and governance (ESG) factors by fiduciaries who oversee private sector pension and defined contribution plans covered by the Employee Retirement Income Security Act (ERISA). This briefing document summarizes the proposal and provides information on how to respond.


See briefing here

EU

June

PRI Roundtable on the European Green Recovery

On 2 July, the PRI will host a roundtable to discuss Europe's green recovery, exploring the proposed recovery package and the key opportunities for investors to contribute to a sustainable and equitable recovery. This briefing provides an overview of the context and intended outcome of the roundtable.


See briefing here

UK

June

How government and investors can deliver net zero in the UK

This briefing sets out the key policy priorities to put the UK on a trajectory to meet net zero emissions by 2050, and the role that investors can play. These priorities are consistent with a green recovery from the COVID-19 crisis.


See briefing here

EU

April

Report: Investor priorities for the EU Green Deal

The report sets out recommendations to ensure that investors can scale up their contribution to the EU Green Deal and sustainability goals more broadly. The report is part of a research programme run by the PRI throughout 2019 and early 2020, drawing from interviews with investors and the PRI’s own programmatic research.


See report here

EU

January

EU Sustainable Finance: Where next?

This briefing provides an overview on the progress to date on EU Sustainable Finance Policy and presents an outlook of the political implication of the European Green Deal.


See full briefing

Consultations and letters

Region Month Consultation or letter PRI response
Global December

IFRS Foundation Consultation Paper on Sustainability Reporting

The PRI welcomes the IFRS Foundation’s proposal for a Sustainability Standards Board (SSB). This is an important step towards globally consistent and comparable corporate sustainability reporting. The PRI recommends that a future SSB covers all sustainability topics, builds on existing initiatives and adopts a modular approach to harmonisation that recognises the different perspectives and needs across jurisdictions and stakeholders. As a next step, we recommend that the IFRS establish a roadmap with a clear timeline and outlook on the development process for a global sustainability reporting framework.


See full response

EU December

European Commission Consultation on Taxonomy Delegated regulation for technical screening criteria for Climate Mitigation and Adaptation

The PRI welcomes the publication of the Taxonomy Delegated regulation (DR). This represents a crucial step forward in the implementation of the EU Taxonomy. The PRI is concerned that amendments have or will be made to the Taxonomy DR which will negatively impact its ambition to create a sustainable financial system. We encourage the Commission to reassess any weakening of criteria and to ensure that the final adopted text is consistent with the high ambition as set out in the Taxonomy Regulation.


See full response

Russia November

Consultation on the Russia green taxonomy

The PRI welcomes the development of a green taxonomy in Russia. The PRI recommends applying common design principles for international taxonomy harmonisation as described in the EU TEG final taxonomy report.


See full response - English Russian

China September

Consultation on the Green Finance Regulation of the Shenzhen Special Economic Zone

This regulation will support local financial institutions to promote the development of responsible investment practices in the Shenzhen Special Economic Zone. The PRI recommends that the regulation clarifies investors should incorporate ESG factors in investment processes and disclose how they do so.


See full response

Peru November

Draft regulation on private pensions investment

PRI’s key recommendation is to clarify the definition of investor duties in Peru, including requiring the incorporation of ESG factors into investment analysis and decision-making processes, consistent with their investment time horizons.


See full response

EU October

Ad personam mandate on Non-Financial Reporting Standard Setting

The PRI fully supports the development of a European non-financial reporting standard and recommends to ensure the widest possible transparency and involvement of relevant stakeholders as well as an approach that allows to define overarching goals and desired outcomes first and attempts to align elements of existing standards second while ensuring the structure and governance of a non-financial standard supports the Sustainable Finance Taxonomy and other frameworks like the SFRD as important tools for investors.


See full response

India October

Securities And Exchange Board of India’s Call For Comments On Business Responsibility And Sustainability Reporting (BRSR)

The PRI’s key recommendations to SEBI are that BRSR disclosure requirements should lead to data that is consistent, comparable and reliable. BRSR should require companies to disclose all material issues and all high-risk locations of plants/operations. SEBI should also contribute to the international dialogue on ESG reporting harmonisation and standardisation.


See full response

UK October

Department for Environment, Food and Rural Affairs | Due diligence on forest risk commodities

The PRI welcomes the intent to curb deforestation, though recommends that due diligence for importing businesses should not be limited to ensuring compliance with local laws, but rather should ensure no contribution to unsustainable deforestation.


See full response

UK October

Department for Work and Pensions | Taking action on climate risk: improving governance and reporting by occupational pension schemes

The PRI supports most of the proposals made by DWP, and recommends requiring scenario analysis of both orderly and disorderly scenarios, and some modifications to the proposed metrics.


See full response

UK October

Financial Conduct Authority | Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations

The PRI recommends that TCFD-alignment disclosures are brought in on a mandatory basis for all listed issuers, rather than comply or explain for a subset of issuers.


See full response

US October

Department of Labor Rule Proposal, "Fiduciary Duties Regarding Proxy Voting and Shareholder Rights"

The PRI's comment on the DOL's Rule Proposal. If adopted, the Amendments would significantly burden fiduciaries’ exercise of proxy voting rights, with no compelling justification, with detrimental effects on the value of investments by plans governed by ERISA. The PRI therefore respectfully requests the DOL withdraw the Proposal.


See full response

EU September

Consultation for the European Central Bank’s Guide on climate-related and environmental risks

The PRI welcomes the ECB’s guidance. Banks are integral to the function of the global economy, and so must better manage, and disclose their management of, climate risks to be more resilient. The PRI recommends the ECB to provide greater clarity on the use of climate scenarios and to further integrate the EU Taxonomy into the guidelines.


See full response

Canada September

Ontario Capital Markets Modernization Taskforce: Consultation Report July 2020

The PRI supportive of the Taskforce’s efforts to improve disclosure on material ESG information, executive compensation, corporate board diversity and increase transparency for investors on conflicts of interest for proxy advisory firms. However, we have some concerns regarding the Taskforce's recommendations on the issuer's role in the shareholder proposal process.


See full response

US September

Letter to the SEC on the Improper Exclusion of Evidence on the Impact of the Proposed Amendments to Rule 14a-8 on Retail Investors

The PRI and investor organizations submitted a letter to the SEC regarding the exclusion of evidence on the impact of the proposed amendments to Rule 14a-8 (Shareholder Proposal Rule), and requested the Commission re-open the comment period to provide the public an opportunity to address the data.


See full response and Commission's analysis of data

US September

Department of Labor Rule Proposal, "Fiduciary Duties Regarding Proxy Voting and Shareholder Rights"

Request for extension of comment deadline


See full request

Israel September

Consultation on corporate responsibility and ESG risk disclosures

The PRI recommends that the Israel Securities Authority (ISA) develops a standardised, mandatory ESG disclosure framework for listed companies. In addition, the PRI recommends that ISA engages in global efforts to standardise ESG disclosure regulations across countries.


See full response

EU September

European Supervisory Authorities: Joint Consultation Paper on ESG Disclosures

The PRI strongly supports the aims and objectives of this Regulation, to help end-investors understand the sustainability impact of products and encourage investor management of adverse impacts. However, we have some concerns regarding the design of the RTS.


See full response in ESA template and standalone pdf

UK August

BEIS Select Committee| Post-pandemic economic growth

The PRI recommends that the UK develop a more comprehensive and long-term approach to a green recovery, prioritising certain sectors, ensuring consistency with a just transition, and leveraging private finance.


See full response

China August

Consultation on the CSRC Listed Companies Information Disclosure regulation

The PRI recommends that the regulation includes a requirement to disclose material ESG information, including discussion of strategy, governance and risk management of material ESG issues that may affect the company’s performance, as part of the mandatory issuer disclosures.


See full response in English and in Chinese

China August

Green Bonds catalogue consultation

The PRI welcomes the consolidation of the existing green bond standards in China into one comprehensive national standard. The PRI also welcomes the clarification that ‘clean coal’ assets do not qualify as green. The PRI recommends to develop technical screening criteria to assess alignment with the Paris Agreement, and whether projects classified as green avoid significant harm to other environmental and social objectives.


See full response in English and in Chinese

Singapore August

Environmental Risk Management Guidelines consultation

The PRI welcomes the publication of the guidelines and recommends to include in their scope broader systemic and sustainability risks that may affect investment portfolios. The PRI also recommends that MAS incorporates the environmental risk management guidelines within relevant existing financial regulations, in alignment with the TCFD framework.


See full response

UK July

Department for Transport | Ending new sales of petrol, diesel and hybrid cars

The PRI supports bringing the proposed sales ban date forward to 2032 and implementing a package of policy measures which will accelerate the growth in sustainable vehicle sales in the UK while reducing the number of vehicles on UK roads overall.


See full response

US July

Department of Labor Rule Proposal, “Financial Factors in Selecting Plan Investments”

The PRI's comment on the DOL's Rule Proposal. The PRI is concerned that, if finalized, the Proposal will create confusion among ERISA fiduciaries and asset managers, chill fiduciaries’ efforts to integrate material ESG factors into their investment practices and could be costly for retirement savers and investment managers. We therefore respectfully request that the DOL withdraw the Proposal.


See comment

EU July

Proposed Amendments to Solvency II Delegated Regulation, Proposed Amendments to MiFID Delegated Directive, Proposed Amendment to MiFID Delegated Regulation, Proposed Amendments to UCITS Commission Directive and Proposed Amendments to IDD Delegated Regulations

The PRI strongly supports action by EU institutions to clarify the relationship between investor duties and sustainability, and the Commission’s aim to increase dialogue between financial institutions and their institutional and retail clients around the sustainability preferences clients may hold. Failure to consider sustainability in investment practice, or to respond to the sustainability preferences of clients or beneficiaries, is a failure of investor’s duties.


See full response

EU July

Renewed Sustainable Finance Strategy

To support the success of this strategy, the PRI makes four overarching recommendations, with further detailed commentary.


See full response

US June

Department of Labor Rule Proposal, ““Financial Factors in Selecting Plan Investments”

Request for extension of comment deadline


See full response

UK June

Labour Party | Green Recovery Consultation

The PRI sets out four key areas for an inclusive green recovery in the UK, focusing on areas with a high economic multiplier – transport, land use, energy efficiency and power.


See full response

EU June

2030 Climate Target Plan

The PRI welcomes the opportunity to submit a consultation response on the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal. The PRI recommends to increase the EU’s 2030 target to reduce greenhouse gas domestically to at least 55% and suggests to focus action on priority sectors and policy areas pointed out in the response.


See full response

EU June

Consultation on the review of the non-financial reporting directive (NFRD)

The PRI welcomes the opportunity to submit a consultation response under the review of the Non-Financial Reporting Directive and makes recommendations how the NFRD and the EU non-financial reporting standards can increase the availability of high quality, relevant and comparable data.


See full response

US May

Heather Slavkin Corzo Remarks on the COVID-19 Pandemic on US Capital Markets

Remarks by Heather Slavkin Corzo, Head of US Policy, Principles for Responsible Investment to the Subcommittee on Investor Protection, Entrepreneurship and Capital Markets of the House Committee on Financial Services on Examining the Impacts of the COVID-19 Pandemic on US Capital Markets, May 26, 2020.


Remarks by Heather Slavkin Corzo

China May

Energy Law Consultation

The PRI welcomes the inclusion in the new law of the topics of climate change and low-carbon transition. Setting up a comprehensive policy framework for the energy sector is an important step for China in managing a sustainable energy transition aligned with the Paris agreement.


See full response in English and Chinese

US May

SEC Request for Comments on Fund Names

The PRI's comment argues two main points: 1. ESG integration is universal, and as such, should not be included in the fund names rule. (And to enable good practice, the SEC should require corporate ESG disclosure). 2. Where the fund has a specific ESG objective, that could be included in the fund name on a case-by-case basis.


See full response

EU May

Interim Report of the Sustainable Finance Committee of the German federal government

The PRI welcomes the opportunity to submit comments on the Interim Report: “The Significance Of Sustainable Finance To The Great Transformation”. The interim report suggests that policy making should align with sustainability goals such as the Paris Climate Agreement and the Sustainable Developments Goals (SDGs). The PRI strongly supports this approach. The PRI recommends that the sustainable finance committee provide further clarity on the processes necessary to achieve alignment.


See full response

US April

SEC Proposed Rule: Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information

The PRI's comment on the SEC's Proposed Rule: Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information in Regulation S-K. The PRI is concerned about two issues in particular with the Proposed Rule: First, its failure to quantify the costs and benefits of the proposed new principles-based disclosures in the MD&A of issuers’ annual filings, and second, its failure to require any new climate-risk disclosures in the Proposed Rule.


See full response

UK April

Environmental Audit Committee | Possible Future Inquiries

The PRI responded to a call for evidence on potential future focus areas for the EAC over the upcoming year. The PRI recommended focusing in particular on:

  • The sustainability of the pension system, in particular contract-based pension schemes and master trusts
  • Holding government accountable for meeting afforestation targets
  • Ensuring a smooth transition from traditional vehicles to electric vehicles over the next decade

See full response

OECD March

OECD | BEPS Action 13 public consultation (2020 review)

Working together in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), over 135 countries are implementing 15 Actions to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.

In response to the OECD consultation on BEPS Action 13, the PRI commends OECD’s coordinated efforts in tackling tax avoidance through the BEPS initiative and recommends that the requirements for country-by-country reporting be extended to public disclosure.


See full response

OECD February

Business responsibilities and investment treaties

The PRI provides comments to the chapter 5, “Investor, business, trade union and civil society action”, specifically on the topic of “sustainable or ‘environmental, social and governance’ (ESG) investing”.


See full response

US

February

SEC Sign-On Letter

The PRI organized a sign-on letter for signatories and supporting organizations to oppose both of the SEC's Proposed Rules.


SEC Sign-On Letter

US

February

SEC Shareholder Proposal Rule

The PRI's comment on the SEC's Proposed Rule on Rule 14a-8. The PRI believes that the rule would significantly impede the accountability of management to their shareholders. (Shareholder Proposal Rule).


See full response

US

February

SEC Proxy Voting Advice

The PRI's comment on the SEC's Proposed Rule on Proxy Voting Advice. The PRI has serious concerns that the Proposed Rule would significantly weaken the role institutional investors play in corporate governance.


See full response

Japan January

Financial Services Agency| Stewardship Code consultation

The PRI welcomes the introduction of sustainability into the stewardship responsibilities of Code signatories. The PRI’s key recommendations include:


  • Sustainability should be defined as including externalities and impacts generated by company activities.
  • Provisions on proxy advisors should avoid introducing delays into the compressed proxy advice process.
  • The FSA should clarify rules around acting in concert and collaborative engagement on ESG issues.

See full response

Chile January

General Rule 386 – environmental and social disclosures consultation by CMF

The PRI welcomes the proposed update of General Rule 386 by CMF. The update introduces mandatory disclosures on key environmental and social issues which will contribute to building standardised and comparable ESG data for investors in the Chilean market.


Full response here

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