Consultations & letters 2021

Consultations and letters

Region Month Consultation or letter PRI response

UK

May

BEIS Consultation mandatory climate-related financial disclosures by publicly quoted companies, large private companies and LLPs

The PRI welcomes BEIS proposals on enhancing climate-related reporting requirements. However, in their current form, they will fail to provide the comprehensive and comparable disclosures for market participants to adequately manage exposure to climate risk.


See response

EU

April

PRI statement on clarification of fiduciary duties and consideration of sustainability preferences in the EU

The PRI supports the action to clarify fiduciary duty rules for asset managers, insurance undertakings, and other investors and their relation to the assessment of sustainability risks. This clarification, although already accounted for by many investors in their interpretation of fiduciary duties, is a crucial step forward to steer entire capital markets towards improved sustainability practices. The PRI also strongly supports the Commission’s work to require dialogue between financial institutions and their institutional and retail clients around the sustainability preferences clients may hold.


See statement

EU

April

PRI supports the publication of final taxonomy delegated act

The PRI welcomes this publication as a significant step forward for capital markets. As the world’s leading proponent of responsible investment, the PRI advocates for global sustainable financial systems, supported by Taxonomies of sustainable economic activities defined by common, science-based, technology neutral technical screening criteria. Investors need a credible Taxonomy to make informed, long-term investment decisions aligned with the Paris Agreement goals.


See statement

Global

April

PRI Statement on corporate sustainability disclosures

The PRI welcomes the proposal for a new EU Corporate Sustainability Reporting Directive as the most recent milestone in a series of encouraging developments on corporate sustainability reporting, including the IFRS Foundation’s proposal to establish a Sustainability Standard Board (SSB) and the initiatives led by the US SEC.


See statement

US March

PRI comment on Nasdaq Proposed Rule Change to Adopt Listing Rules Related to Board Diversity

The PRI submitted a comment to the SEC in response to a proposed rule to require US Nasdaq listed companies to disclose board diversity data and to have at least two diverse board members. The PRI supports the proposed rule change and believes that it is a meaningful first step forward in long-overdue changes in the U.S. financial industry and society broadly.


See full response

Singapore March

Green finance industry taskforce taxonomy consultation

The PRI welcomes the development of a green finance taxonomy in Singapore. Key recommendations include adding environmental objectives on circular economy and pollution prevention. The PRI also recommends that the Taxonomy is used to assess whether an economic activity is aligned with the environmental objectives or not, using science-based, technology neutral, technical screening criteria. To ensure the taxonomy allows for an objective assessment of the environmental sustainability of economic activities no exceptions should be included.


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EU March

Targeted consultation on the establishment of a European single access point (ESAP) for financial and non-financial information publicly disclosed by companies

The PRI welcomes this initiative. PRI signatories consistently report to the PRI that a lack of consistent, reliable and comparable ESG data is a substantial barrier to their responsible investment practice. The ESAP can enhance data accessibility and credibility and therefore help investors identify ESG risks and opportunities, understand sustainability performance in the context of social and environmental goals and implement sustainable finance disclosure obligations. That said, its value for investors will also depend on whether the information reported meets their needs.


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UK March

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

The PRI welcomes the leadership shown by DWP in raising awareness of climate-related risks, and supports a number of the revisions made in light of industry feedback on the August 2020 consultation. As climate metrics evolve, PRI supports the inclusion of updated guidance on these metrics as a high priority for the interim 2023 review.


See full response

China March

CSRC consultation on the Guidelines on Investor Relations Management of Listed Companies

The PRI welcomes the inclusion of ESG information in the Guidelines. The PRI recommends that the CSRC should publish a comprehensive, standardised and mandatory ESG reporting framework to provide further reporting guidance for listed companies.


See full response in English and Chinese

US February

PRI Statement for the Record for House Financial Services Subcommittee Hearing

The PRI submitted a Statement for the Record for the House Financial Services Subcommittee on Investor Protection, Entrepreneurship and Capital Markets hearing entitled, "Climate Change and Social Responsibility: Helping Corporate Boards and Investors Make Decisions for a Sustainable World". The PRI believes consistent, comparable information from mandatory corporate disclosures is the most efficient way for investors and the public to access necessary information about ESG risks and opportunities and make informed investment decisions.


See full letter

France February

Public consultation on the Decret proposal for amending ART 29 of Energie Climate Law (former ART 173)

As the EU Regulation on sustainability‐related disclosures in the financial services sector (SFDR) allows member states who wish so to adopt or maintain more ambitious requirements (Recitals 28), this revision of the law is an opportunity for France to maintain its leadership on these topics and to help accelerate investor awareness and action. PRI supports efforts to align the new disclosure framework with the recommendations of the Task Force of Climate Related Financial Disclosures (TCFD), specifically the inclusion of detailed criteria related to alignment with Paris Agreement objectives.


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US February

PRI Comment on FTC Proposed Rulemaking on Hart-Scott-Rodino Premerger Notification Requirements

The PRI submitted a comment to the Federal Trade Commission in response to its proposed rulemaking to amend the premerger notification requirements under the Hart-Scott-Rodino Antitrust Act. The PRI believes the Commission should clarify that efforts to engage with public companies on ESG matters do not fall under premerger notification obligations under the Act.


See full letter

EU February

European Commission consultations on updating the EU Emission Trading System (ETS) and EU Effort Sharing Regulation

PRI response: The PRI welcomes the leadership shown by the European Commission to address climate change and supports the new 2030 emission reduction target of 55% on the 1990 baseline. To achieve this, stronger policy mechanisms are required. These consultations are a crucial opportunity to revise the EU ETS Directive and Effort Sharing regulation and ensure their contribution to the EU climate and energy policy goals. Based on PRI’s climate policy work in the EU and other markets, we make 4 recommendations.


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EU February

Public consultation on the Proposal for an Initiative on Sustainable Corporate Governance

The PRI supports the Commission’s aim to better align the interests of companies, their shareholders, managers, stakeholders and society. We recommend the Commission to provide clarity and consistency on director duties across the EU; undertake a rigorous legal and impact analysis to support any EU legislation on director duties; establish a legal duty for companies to undertake environmental and human rights due diligence; and all the while ensure consistency across proposed reforms within DG JUST and other EU directorates.


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UK February

Financial Reporting Council | Future of Corporate Reporting

The PRI welcomes the intent to strengthen accountability to stakeholders, and encourages the development of statutory non-financial reporting in the UK corporate reporting framework, though cautions against separating financial, ESG and sustainability reporting across multiple reports.


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EU January

Public Consultation on the review of the Alternative Investment Fund Managers Directive (AIFMD)

The PRI makes two overall recommendations. Firstly, the European Commission should avoid additional disclosure requirements in individual directives for different fund types, and instead focus on clarifying and harmonizing the SFDR and Taxonomy disclosure regulations. Secondly, the Commission should undertake legal and impact analysis to determine whether to introduce a specific mandatory requirement related to sustainability impact for AIFMs. Any impact-related regulation should have a consistent approach across investor types.


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South Africa January

CRISA Code for Responsible Investment in South Africa Revision

The PRI strongly support contents of the revised draft code, including but not limited to: an outcomes-based approach that encourages pursuit of positive outcomes across impact, inclusion, innovation and resilience, and an “apply and explain” disclosure standard that allows sufficient flexibility to be applied proportionately across different assets and types of organisations. PRI’s central recommendation is that the CRISA Committee should establish more robust oversight of the Code for greater effectiveness by formalising the process to become a signatory to the Code.


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Hong Kong SAR January

Hong Kong SFC consultation on the management and disclosure of climate-related risks by fund managers

The PRI welcomes the SFC’s proposal for mandatory climate-related reporting through amendments to the existing Fund Manager Code of Conduct (FMCC). The PRI recommends that SFC updates carbon foot printing methodology with the latest TCFD technical guidance and recommendation, and clarifies that asset managers should also collect and disclose financed (Scope 3) GHG emissions. The PRI also recommends that HKEX should tighten company disclosure rules to match the proposed revision to the FMCC on climate change.


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Canada January

Strengthening Canadians' Retirement Security - Proposals to Support the Sustainability of and Strengthen the Framework for Federally Regulated Pension Plans

It is the PRI's view that, to protect Canadian pension plan participants and beneficiaries, and increase transparency for all capital markets participants, the Department of Finance Canada and Canadian Securities Administrators should define ESG reporting requirements, and the Department of Finance Canada should clarify that fiduciary duties require ESG integration. The PRI would also encourage consistent regulation on these topics across federal and provincial governments.


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UK January

Joint letters to UK Prime Minister and Transport Secretary on climate policy

PRI and several UK asset owners have written to the UK government calling for continued climate ambition in advance of COP26, including progress on land use challenges, energy efficiency and smoothing the transition to zero-emissions vehicles.


See full letter

EU January

EFRAG consultation on ad personam mandate on potential need for changes to the governance and funding of EFRAG

The PRI recognises and supports the EU’s leadership role in developing standards for corporate reporting on sustainability performance, but recommends that these standards are not developed in isolation. Similarly, PRI recommends that the EU and EFRAG actively participate in international standard setting processes that focus on financial materiality and adopts those standards once developed.


See full response