Consultations and letters

EU

November 2023

PRI statement on appropriate and practicable inclusion of the financial sector in the CSDDD

In advance of the next trilogue discussion between European Commission, Parliament and Council, the PRI has published a final statement calling for appropriate and practicable inclusion of the financial sector in the Corporate Sustainability Due Diligence Directive. This statement is based on previous position papers and recent conversations with signatories. It will be sent to all relevant policymakers in negotiations. If you have any feedback or want to learn more, email hazell.ransome@unpri.org.

See statement

Global

October 2023

UN Working Group on Business and Human Rights call for input on Investors, ESG and Human Rights

The PRI welcomes the intention from the UN Working Group to provide practical guidance to states, businesses, financial institutions, civil society, and other stakeholders on how to align better ESG approaches with the UNGPs in the context of financial products and services. We recommended that the final report of the Working Group references: - The necessity to fully integrate social issues into the economic transition, including through sustainable finance and real economy policy regulation. - The need for policy reform to enable the improvement of the sustainability outcomes of investments. - The systemic relevance of human rights and social issues, including growing inequalities.

See response

US

October 2023

PRI letter to New York Governor supporting adoption of a human capital management disclosure bill

PRI submitted a letter to Governor Kathy Hochul of New York, supporting the adoption of Assembly Bill A5981. If signed, the bill would require companies operating in the state of New York to file their EEO-1 reports with the NY Secretary of State. Companies' data on the race, gender, and ethnicity of employees would then be made publicly available. By requiring companies to file their EEO-1 data for public release, New York can support investor efforts to identify and address HCM-related issues across their portfolios. Certain companies are already required to report this information annually to the Equal Employment Opportunity Commission, and as such, sharing this information with the State of New York—and with investors—requires no additional effort.

See letter

Japan

October 2023

PRI response to JFSA’s invitation for public comments regarding the Draft Basic Guidelines on Impact Investment

The PRI supports the JFSA’s efforts to integrate sustainability impacts across the financial sector. PRI recommends that the JFSA strengthen these efforts by considering policy measures that can more holistically encompass the various approaches it can take to mainstream investing for sustainability impact.

See response in English and Japanese

Australia

September 2023

Joint Investor Statement on Corporate climate transition plans

The PRI, together with IGCC and CDP, released a joint statement calling on the Federal Government to establish a clear framework for developing and disclosing transition plans which supports a whole of economy just transition aligned with limiting global temperatures to 1.5°C.

Statement

Canada

September 2023

The Canadian Securities Administrators (CSA) consulted on Proposed Amendments to Form 58-101F1 Corporate Governance Disclosure of National Instrument 58-101 Disclosure of Corporate Governance Practices and Proposed Changes to National Policy 58-201 Corporate Governance Guidelines

The PRI’s response supports the CSA’s intention to mandate corporate governance disclosure requirements of non-venture issuers to include aspects of diversity beyond the representation of women on boards and in executive officer positions, and makes a series of recommendations, including alignment with DEI metrics in the CBCA, and the consolidation and streamlining of the various corporate disclosure forms to develop a wider, holistic corporate sustainability disclosure regime built upon the formal adoption of ISSB Standards S1 and S2.

See response

EU

September 2023

PRI letter to the European Parliament, the European Commission and the Council of the European Union

The PRI calls on the EU institutions to ensure the inclusion of sustainability elements in the final text of the Solvency II directive.

See letter

UK

September 2023

PRI response to the Financial Reporting Council (FRC) over proposed changes to the UK Corporate Governance Code

The PRI welcomes the proposed changes to the UK Corporate Governance Code. The PRI is particularly supportive of revisions seeking to prompt more outcomes-based reporting, increased transparency on director appointments and the inclusion of narrative (sustainability) reporting within the remit of audit committees. We encourage the FRC to introduce provisions on the disclosure of sustainability related skills and experience of board members and governance arrangements for the oversight of sustainability matters.

See reponse

Australia

September 2023

PRI and Australian peak bodies responded to ISSB agenda priorities

The PRI, together with several of Australia’s peak bodies, highlighted the importance of the ISSB leading and working with jurisdictions to build capacity and support the effective implementation of IFRS S1 and S2. The submission further encouraged the ISSB to take a collaborative and coordinated approach with existing and developing frameworks in its future work plan.

See reponse

UK

August 2023

PRI response to the Department for Business and Trade (DBT) and the Financial Reporting Council (FRC) review into non-financial reporting requirements

The PRI welcomes this review as an opportunity for the DBT and FRC to increase the consistency, reliability, and comparability of non-financial corporate reporting. We make recommendations on reporting criteria, ISSB implementation, and highlight the value of non-financial reporting.

See reponse

EU

July 2023

PRI reaction statement and quote on adoption of ESRS 1 and ESRS 2

PRI welcomes this delegated act as an important step towards investors having access to the data they need to assess sustainability risks, opportunities and impacts of investee companies. Through improved transparency of materiality assessments, investors will be able to keep a watchful eye on investee reporting and will expect comprehensive disclosures based on accurate and science-based materiality assessments. However, to guarantee investor’s access to the data they need to comply with their own mandatory reporting obligations and allocate capital in line with sustainability goals, we urge the European Commission to commit to making key climate disclosure indicators, and environmental and social indicators relevant to SFDR mandatory to disclose in the first review of this delegated act.

See reponse

HK SAR

July 2023

HKEX consultation paper on enhancement of climate-related disclosures under the ESG framework

The PRI strongly welcome the proposals of HKEX, the requirements under consultation are closely aligned with exposure draft IFRS S2 Climate-related Disclosures and ISSB decisions related to this Standard. Our response welcomes areas of alignment with the ISSB’s proposals, and highlights where we believe further alignment is needed. We also recognize investors' data needs beyond climate and on wider sustainability issues.

See reponse

EU

July 2023

The European Supervisory Agencies have published for consultation some targeted changes to the SFDR technical standards (RTS). These changes relate to the disclosures of principal adverse impacts (and related indicators) and disclosures at financial product level.

Whilst PRI supports the proposed expanded social PAI indicators and climate target-setting proposals, policymakers will need to maintain consistency with the final ESRS standards as adopted by the European Commission to ensure investors have sufficient data to produce meaningful reports as per their SFDR obligations.

See response

Australia

June 2023

The PRI responded to the consultation document issued by the Climate Change Authority on its advice for the next Australian Nationally Determine Contribution among other matters.

The PRI-Coordinated Collaborative Sovereign Engagement on Climate Change recommends the benefits of an accelerated, orderly and Paris-aligned NDC for Australia’s sovereign climate risk profile, economic competitiveness and future cost of capital should be reflected by the Authority in its final advice to the Federal Government.

See response

Global

June 2023

PRI response to the TNFD’s consultation on the fourth (v0.4) iteration of its beta framework.

PRI strongly welcomes the latest version of the TNFD disclosure recommendations and the supporting assessment LEAP approach. PRI further formulates five recommendations related to materiality, priority locations, core global metrics, financial core metrics, and guidance.

See response

Global

May 2023

The PRI submitted a response to the UN Working Group on Business and Human Rights' call for inputs: Extractive sector, just transition and human rights.

The PRI welcomes the Working Group’s intention to provide the UN General Assembly with further information to ensure that the economic transition is just and takes into consideration the basic rights of all individuals, including the wide range of stakeholders involved in the mining sector value chain.

See response

EU

May 2023

Joint Business Networks’ Letter to the European Parliament on supporting an ambitious Nature Restoration Law.

The PRI, together with other leading Business Networks, call for a robust, ambitious, and coherent outcome from the EU Nature Restoration Law negotiations. This entails policy that supports the EU Green Deal’s nature and climate ambitions, and its alignment with the Paris Agreement and CBD COP15 Kunming-Montreal Agreement on biodiversity.

See letter

US

May 2023

PRI Response to the Financial Accounting Standards Board (FASB) proposed accounting standards update for income taxes

The PRI supports the proposed changes to Topic 740 of the FASB Accounting Standards Codification® on requiring more granular and specific information regarding rate reconciliation and income taxes paid. We further recommend the FASB considers additional amendments in the future to meet the evolving needs of investors around income tax disclosures. The benefits to investors would be greatly enhanced if these proposed changes were to be accompanied by disclosures on key jurisdiction-level information such as revenues and operating results on a similar level of disaggregation.

See reponse

Australia

April 2023

PRI response to the Treasury’s consultation on public country-by-country reporting.

PRI response to the Treasury’s consultation on public country-by-country reporting PRI response: PRI strongly welcomes the Treasury’s exposed draft on public reporting of country-by-country (CBC) information. Australia would take a leadership position by becoming the first jurisdiction to mandate the public disclosure of full CBC information. The Australian Treasury’s proposed disclosure regime will have a significant impact on investors’ ability to assess the risk profile of an entity’s tax affairs and incorporate tax issues in their decision-making processes.

See letter

Australia

March 2023

The PRI responded to Treasury’s consultation on legislating the objective of superannuation

The PRI welcomes the Australian Government’s proposal to legislate an objective for the superannuation system, which includes the concept of sustainability. However, the PRI highlights that the proposed definition of “sustainable” is relatively narrow and potentially misaligned with existing duties. Accordingly, the PRI recommended the definition of sustainable better take into account the superannuation system’s reliance on a strong economy and its role in supporting the economy’s stability, as well as the environmental and social systems the economy relies upon.

See response

Australia

March 2023

Together with other industry associations and leading financial institutions, the PRI issued a joint finance industry statement welcoming the Australian Government’s proposal to reform the Safeguard Mechanism.

While welcoming the proposals, the statement notes that the emissions reductions required under the Safeguard Mechanism are not yet aligned with actions needed to limit global warming to 1.5 degrees. The statement outlines specific measures to bolster and complement the mechanism and to ensure it would be a floor, not a ceiling, to facilities’ decarbonisation measures.

See statement

Australia

March 2023

The PRI responded to APRA’s consultation on draft investment governance guidance for superannuation funds SPG 530  

The PRI welcomes APRA’s proposals to update SPG 530 and clarify its expectations about how RSE licensees address ESG factors. Although the proposed amendments provide a much-needed update to the previous version, additional guidance is required to comprehensively align with current market practice and support RSE licensees to discharge their legal duties. The PRI therefore recommends that SPG 530 specifically references the need for RSE licensees to assess and mitigate system-level ESG risks and provide guidance on the investment and stewardship activities needed to do so, including through the intentional pursuit of sustainability-related outcomes.

See response

UK

February 2023

PRI response to UK Transition Plans Taskforce (TPT) Consultation Survey

The PRI welcomes the work of the Transition Plan Taskforce (TPT) to drive robust, credible, and interoperable transition plans and disclosure frameworks from finance and real economy actors. The PRI agrees with the TPT’s approach in building and aligning to the International Sustainability Standards Board (ISSB) Climate Exposure Draft, the Task Force on Climate-Related Financial Disclosures (TCFD) framework, and recommendations from the High-Level Expert Group (UN HLEG) on the Net Zero Commitments.

See response

EU

February 2023

PRI response to ESMA consultation on ESG-related fund names

The PRI is supportive of ESMA’s efforts to ensure that funds’ names reflect their investments’ characteristics and objectives. We encourage EU policymakers to clarify how key underlying concepts (particularly sustainable investment) should be applied in practice, before setting quantitative thresholds. The proposals could also be made more relevant to different investment strategies and accurately reflect the tools investors have to create change (particularly stewardship).

See response

Global

February 2023

PRI response to IOSCO consultation on compliance and voluntary carbon markets.

The PRI Executive welcomes IOSCO’s work to develop sound carbon markets that are well-equipped to achieve their core environmental objectives. Carbon markets are a necessary tool to achieve net-zero and IOSCO’s work in this area signals their growing relevance. Although carbon markets have proliferated in recent years, there is still work to be done to unlock their full potential.

See response

Global

February 2023

PRI's response to the OECD consultation on the targeted update of the Guidelines for Multinational Enterprises.

The PRI welcomes the proposed update to the OECD MNE Guidelines, including: the expansion of the scope of due diligence from a focus on supply chains to encompass wider business relationships; the recognition that “an enterprise’s relationship to adverse impacts is not static”, and the specification that investee companies are part of a company’s business partners; and the expansion of the provisions relating to environmental issues to require risk-based environmental due diligence, including the recognition of the need to adopt a just transition lens in assessing the potential or actual adverse impacts to workers, communities, and consumers. Areas for improvement include expressly mentioning the role of institutional investors in supporting the implementation of responsible business conduct, strengthening the guidelines on ensuring transparency and integrity in lobbying activities by encouraging enterprises to report further details on their practices, and acknowledging the systemic issue of tax avoidance and profit-shifting and the proactive role that multinationals should play in tackling it.

See response

Japan

January 2023

PRI response to JFSA’s invitation for public comments regarding proposed partial amendments to the comprehensive supervisory guidelines for financial instruments business operators, etc. regarding ESG investment trusts

The PRI supports the JFSA’s efforts to address concerns of “greenwashing” among publicly offered investment trust funds with express ESG claims. PRI recommends that the JFSA provide clearer explanations on key concepts and stay aware of international developments in this area.

See response in English and Japanese

EU

January 2023

Joint Business and Investor Letter supporting an ambitious and robust Energy Performance of Buildings Directive (EPBD) ahead of the ITRE committee vote on 9 February 2023.

The PRI, together with the Corporate Leaders Group (CLG), Climate Group, the Institutional Investors Group on Climate Change (IIGCC), and several other business and investor groups, encourages the Members of the European Parliament Committee on Industry, Research and Energy (ITRE) to take an ambitious and robust position on the Energy Performance of Buildings Directive in its committee vote on 9 February 2023.
To provide a clear enabling policy environment for private sector investment in buildings’ energy efficiency and deep retrofits, the PRI supports minimum energy performance standards (MEPS) for both residential and commercial buildings as a key element in the EPBD revision, as well as harmonising the Energy Performance Certificate system to ease planning and measuring progress across the EU building stock.

See letter

EU

January 2023

PRI response to ESA consultation on greenwashing in the financial sector.

The PRI has responded to the European Supervisory Authorities (ESA) consultation on greenwashing in the financial sector. Supporting the ESAs proposed features of greenwashing, we encourage EU policymakers to complete existing standards and policies to further promote clarity, transparency and accountability in the EU framework.

See statement

Australia

December 2022

The PRI responded to Treasury’s consultation on empowering the AASB to deliver sustainability standards.

The PRI supports the Australian Government’s intention to implement sustainability standards and ensure large business are transparent and accountable to investors. The PRI encourages the Government to base these standards on the ISSB’s final sustainability and climate-related financial disclosure standards and implement additional legislation to require mandatory disclosures. The PRI further recommends that any entity implementing the standards be appropriately governed and resourced.

See response

EU

November 2022

PRI statement on draft European Sustainability Reporting Standards

This PRI statement welcomes the latest draft European Sustainability Reporting Standards (ESRS) by the European Financial Reporting Advisory Group (EFRAG) and sets out five priority elements that co-legislators and the European Commission should retain within the final standards.

See statement

UK

November 2022

The PRI provides comments on a consultation from the Department for Levelling Up, Housing and Communities (DLUHC). This consultation seeks views on proposals to require administering authorities of the Local Government Pension Scheme (LGPS) to have effective governance, strategy, risk management and accompanying metrics and targets for the assessment and management of climate risks and opportunities

In our response, the PRI welcomes the proposal from DLUHC to require LGPS schemes to assess, manage and disclose climate-related risks in line with the recommendations of the Taskforce on Climate-related Financial Disclosures (TCFD). In particular we welcome proposals to align new requirements for LGPS AAs with existing requirements for occupational pension schemes, as set out by the DWP earlier this year.

See response

EU

November 2022

Joint investor statement of support for an ambitious and effective European directive on corporate sustainability due diligence (CSDD)

The PRI, Eurosif, Investor Alliance for Human Rights and 142 undersigned signatories (representing approximately 1.5 trillion USD in AUM) welcome the European Commission’s CSDD proposal. This statement raises 5 key recommendations to create an ambitious and effective directive, which works for investors, complements the existing EU legislation and is aligned with international standards including the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises.

See statement

Australia

November 2022

The PRI responded to the review by Attorney-General’s department of the Modern Slavery Act 2018 (Cth).

The PRI commends the Australian Government for its commitment to improve the Act and highlights concerns with the modern slavery statements already submitted. Accordingly, the PRI recommends the Minister and departments undertake a quality review. Additionally, the PRI recommends the Act include an express requirement for entities to carry out a due diligence process.

See response

Australia

November 2022

The PRI responded to APRA’s consultation on its prudential standards for strategic planning and member outcomes – SPS 515

The PRI recommends that SPS 515 should be updated to ensure RSE licensees are explicitly required to consider system-level risks when setting strategic objectives and, along with SPG 515, enhanced to support RSE licensees to assess members’ sustainability objectives. Further guidance should also be provided on how RSE licensees can set and pursue goals to shape real-world sustainability outcomes.

See response

UK

October 2022

PRI's response to a call for evidence by BEIS on the government's approach to delivering its net zero target.

The PRI welcomes the opportunity to respond and makes recommendations showcasing the ability of net zero targets to deliver maximum economic growth and investment, and to support UK energy security and affordability.

See response

Global

October 2022

PRI response to review of the G20/OECD principles of corporate governance

The G20/OECD Principles are being reviewed in light of recent evolutions in capital markets and corporate governance policies and practices. PRI welcomes many aspects of the reviewed Principles and makes recommendations on executive remuneration, whistleblowing, the responsibilities of the board, DEI, stewardship, investor collaboration and sustainability reporting.

See response

Canada

September 2022

PRI response of the Office of the Superintendent of Financial Institutions (OSFI) on Draft Guideline B-15: Climate Risk Management

The PRI welcomes OFSI’s signal to the Canadian and international markets in aligning the B-15 guideline with the most recent TCFD guidance and referencing disclosure against ISSB disclosures. The PRI makes recommendations on greater coordination with ISSB, CSSB, and CSA, as well as ensuring that disclosures are included in financial statements, transition plans aligned with targets, and voluntary scenario analysis.

See response

EU

September 2022

Joint letter from PRI, CDP, IIGCC, and Eurosif on Fit for 55 trilogues

The CEOs of PRI, CDP, and IIGCC – under the auspices of The Investor Agenda – in collaboration with Eurosif published an open letter to Frans Timmermans, Pascal Canfin, and Jaroslav Zajíček regarding the trilogue negotiations on a number of EU “Fit for 55” files. The letter emphasises the need to swiftly implement an ambitious Fit for 55 package that will save energy, accelerate the expansion of renewables, catalyse low-carbon innovation, and mobilise private capital towards sustainable outcomes, all while ensuring a just transition.

See letter

UK

September 2022

Joint letter from PRI, IIGCC, and UKSIF: CEOs of leading investor groups call on new government to uphold net zero ambition

The CEOs of PRI, IIGCC, UKSIF and 8 leading UK investors published an open letter to the UK Prime Minister and officials outlining the case for upholding net zero ambition. The PRI and investor signatories emphasises the need for a clear delivery plan for the transition of the real economy and financial services, with credible sectoral roadmaps underpinned by the near-term policies, actions and milestones needed to shift financial flows towards net zero.

See letter

South Africa

September 2022

PRI response to the South African Reserve Bank’s draft national Climate Risk Scenarios

PRI warmly welcomes the South African Reserve Bank’s important work on developing regional Climate Risk Scenarios and supports its objective to build capacity across the financial sector to better mitigate the financial risks and other impacts on South Africa’s economy. The importance for climate risk modelling focused on local conditions is essential for financial markets to more accurately assess and price in risks. This will enable investors to allocate capital more efficiently and to play their part in helping to achieve the Paris Agreement.

See response

Japan

September 2022

PRI response to JFSA’s invitation for public comments regarding the Draft Code of Conduct for ESG Evaluation and Data Providers

PRI welcomes JFSA's proposal to introduce a Draft Code of Conduct for ESG Evaluation and Data Providers. PRI recommends that JFSA implements appropriate accountability and enforcement mechanisms, commits to periodic reviews and revisions of the code, and provides clarity on key concepts and the extent of the overall scope of applicability to ensure alignment and coherence among the market.

See response in English and Japanese

Australia

September 2022

PRI response to Treasury's consultation on strengthening Australia’s multinational tax avoidance and tax transparency rules

The PRI welcomes the Treasury’s intention to address the tax avoidance practices of multinational enterprises (MNEs) and improve transparency through better public reporting of MNEs’ tax information. The PRI recommends that reporting entities be required to report relevant tax-related information for all countries of operation, not just a limited set of jurisdictions; and that reporting standards should align as much as possible with disclosure 207-4 (Country-by-country reporting) of the GRI 207 standard.

See response

Global

August 2022

Joint PRI, IFAC and WBCSD statement calling for alignment between sustainability reporting standard setters and frameworks

The PRI, IFAC, WBCSD and undersigned organisations call on major standard-setting efforts to align and support a global baseline for sustainability-related information – by aligning on key concepts, terminologies and metrics upon which disclosure requirements are built.

See statement

US

August 2022

PRI comment to the SEC on Investment Company Names

The PRI supports the SEC’s proposed rule and its efforts to ensure that funds’ names reflect their investments in the fund and address materially misleading or deceptive fund names. The PRI recommends that the SEC Define the term "characteristics" and clarify the expectations for funds on how to determine an investment focus with such characteristics.

See response

EU

August 2022

PRI responses to EFRAG consultations on Exposure Draft European Sustainability Reporting Standards

The PRI welcomes the publication of Exposure Draft European Sustainability Reporting Standards (ESRS) by the European Financial Advisory Group (EFRAG) and is broadly supportive of their content. Our recommendations seek to ensure that reporting under the ESRS meets the information needs of responsible investors.

See response

Australia

July 2022

PRI response to the AASB’s request for comment on the ISSB’s Exposure Drafts IFRS S1 and S2

The PRI strongly supports the development of a global baseline of sustainability disclosures and encourages the AASB to engage closely with the ISSB in the development of IFRS S1 and S2. The PRI recommends that the Federal Government introduce legislation that requires mandatory disclosure of sustainability information by listed and large propriety companies by 2024, and authorises the AASB to issue standards for such sustainability information. Those standards should be based on the final IFRS standards as a minimum baseline.

See response

UK

June 2022

The PRI responded to a call for evidence by HM Government to support the update to the Green Finance Strategy. The call for evidence seeks views around four objectives; capturing the opportunity of green finance; mobilising finance for the UK’s energy security, climate and environmental objectives; greening the financial system; and leading internationally.

The PRI are supportive of plans to update the Green Finance Strategy and welcome the opportunity to respond to this call for evidence. In our response, we outline some high level recommendations around maintaining ambition for reporting and disclosure frameworks such as SDR and the UK Green Taxonomy, as well as ensuring consistent messaging between policymakers, both within the UK and internationally. We also call for a shift towards a regulatory environment that permits and enables sustainability outcomes-focused investment.

See response

UK

June 2022

Joint open letter from IIGCC, the PRI and UKSIF: Leading investor groups call for natural gas to be excluded from the UK’s ‘green taxonomy’

The CEOs of IIGCC, PRI and UKSIF published an open letter to the UK Prime Minister outlining the case against including natural gas in the UK’s taxonomy. The PRI and other signatories emphasise the need for a credible, science-based taxonomy that is fully aligned with the UK’s ambitious net zero strategy. Gas may be necessary as a ‘bridge’ during the transition, but it should not be labelled as ‘green’.

See letter

EU

June 2022

PRI response to the European Commission consultation on ESG ratings and incorporation of ESG in credit ratings.

The PRI welcomes increased attention by the European Commission to the market for ESG ratings and data products and the providers of these products, given the important role these products play in investment processes. PRI recommends the Commission focuses regulatory action on improving transparency of methodologies and processes, and ensuring providers have appropriate governance processes in place.

See response

Global

May 2022

Race to zero 2022 criteria consultation

This consultation has been designed by the High-Level Climate Champions, the UNFCCC and the Expert Peer Review Group for the Race to Zero.

See response

US

May 2022

PRI comment to the Department of Labor on protecting American retirement savers from climate-related risks

The PRI welcomes the Department of Labor’s consultation as the Department is duty-bound to take active steps to address potential impacts of climate-related financial risk to American savers.

See response

US

April 2022

PRI template comment for signatories to respond to the SEC’s proposed climate disclosure rule

The PRI encourages its signatories to submit comments to the SEC on the proposed climate disclosure rule. This template serves as a starting point for signatories looking to prepare their own comment letters.

See letter

EU

April 2022

Joint PRI and Eurosif letter on necessity for net-zero disclosures in CSRD

The PRI and Eurosif have written to European Parliament, Commission and Council of the EU, on behalf of the sustainable investment industry, to emphasise the need for a CSRD framework that promotes meaningful transition efforts on the part of companies and provides investors with effective tools to steer capital towards sustainability leading companies. It is crucial that, at the end of the trilogue negotiations, CSRD mandates companies to prepare transition plans and disclose the scenarios used for these plans as well as the key assumptions underpinning these scenarios.

See letter

US

March 2022

The PRI responded to Municipal Securities Rulemaking Board’s (MSRB) request for info on ESG practices

The PRI is encouraged by MSRB’s request for information as it considers how best to incorporate ESG-related information in its regulatory and oversight duties. PRI recommended MSRB work to encourage standard ESG disclosure and relevant information across the municipal securities market to provide investors with consistent, comparable information.

See response

EU

March 2022

The PRI responded to the European Securities Market Authority (ESMA) call for evidence on market characteristics for ESG rating providers in the EU.

The PRI welcomes increased attention by regulators such as ESMA to the market for ESG ratings and data products and the providers of these products, given the important role these products play in investment processes. PRI recommends regulators focus on improving transparency of methodologies and processes, and ensuring providers have appropriate governance processes in place.

See response

US

March 2022

PRI Comment on Pay vs. Performance

The PRI submitted a comment to the SEC in response to the reopening of the comment period for Pay vs. Performance. The PRI supports the disclosure of a company-selected measure as well as the list of the five most important performance measures, as these additions would allow registrants the flexibility to show whether ESG performance measures significantly impact executive pay.

See response

UK

March 2022

The PRI provides comments on a consultation from the Department for Business, Energy & Industrial Strategy (BEIS) on proposals to design a climate compatibility checkpoint for future oil and gas licensing in the UK Continental Shelf.

In our response, the PRI welcomes the proposal to apply a climate checkpoint to North Sea oil and gas production and encourages the government to set stringent and ambitious tests to the licensing of oil and gas exploration in the UK.

See response

Canada

February 2022

PRI response to the Canadian Securities Administrators draft regulation 51-107 respecting disclosure of climate-related matters

The PRI encourages the CSA to mandate disclosure of Scopes 1 and 2 and most relevant Scope 3 emissions categories using the GHG Protocol, as well as scenario analysis. The CSA should aim to phase in the holistic implementation of the 11 TCFD recommendations, reflecting the 2021 Guidance on Metrics, Targets and Transition Plans.

See response
See sign-on letter in English
Voir la lettre d’appui en Français

China and EU

January 2022

International Platform on Sustainable Finance (IPSF) consultation on Common Ground Taxonomy (CGT)

The PRI recognises that taxonomies are a key tool for redirecting financial flows towards economic activities that meet robust sustainability standards and are aligned with high-level policy commitments, therefore, the CGT could be a useful tool to increase the interoperability of taxonomies, on the condition that clarifications and improvements are made regarding its purpose, science-basis, methodology and presentation of criteria.

See response

UK

January 2022

The PRI respond to a consultation from the FCA that seeks initial views on new sustainability disclosure requirements (SDR) for asset managers and FCA-regulated asset owners, as well as a new classification and labelling system for sustainable investment products.

The PRI support the FCA’s proposed approach on the design principles, coherence and inoperability, product labels and disclosure layers, and classification and labelling for a full range of investment products, but recommends that the FCA revise the potential categories of the classification and labelling system, and reconsider how best to draw on the EU Sustainable Finance Disclosure Regulation (SFDR).

See response

China

January 2022

China consultation on regulations of insurance asset management companies

To ensure that IAMCs are appropriately managing ESG related risks and opportunities as a part of their obligations to clients, the PRI recommends that the proposed regulation should make clear that IAMCs must consider ESG factors in their corporate governance, risk management, investment activities, stewardship, and disclosure practices.

See response in English and Chinese

US

December 2021

The PRI responded to the SEC's Proposed Rule, “Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers”

The PRI supported the proposed rule to enhance the availability and utility of information on proxy voting, including on executive compensation.

See response

EU

December 2021

The PRI sent letters to finance ministers of all 27 member states about alternatives to including gas-fired power and nuclear energy in the EU Sustainable Taxonomy

The PRI urged finance ministers to publicly support the consideration of alternative policy solutions to recognise gas-fired electricity and nuclear energy as transition activities outside of the EU Sustainable Taxonomy, as set out in its position paper.

See letter

Australia

October 2021

The PRI responded to the Association of Superannuation Funds of Australia’s discussion paper on climate change.

The PRI recommended that clearer regulatory guidance is needed to enable superannuation funds to mitigate systemic climate risks, and encourages ASFA to guide superannuation funds on how to achieve net zero targets and, to that end, recommends ASFA support more effective stewardship practices.

See response

Japan

September 2021

PRI Comments on METI’s consultation on the 6th Basic Energy Plan for Japan

The PRI welcomed the proposed updates to Japan’s Basic Energy Plan, including its upward revision of renewables in the overall power output to 36-38% by 2030, and highlight the policy actions needed to support Japan in successfully meeting its climate targets and transforming towards a net zero economy.

See response

China

September 2021

PRI letter to Beijing Stock Exchange

The PRI welcomed the establishment of the exchange and recommend that BSE take steps to further promote responsible investment among listed companies, support mandatory ESG disclosure and provide guidance on climate-related targets and measures for listed companies in China, and become a signatory to the Sustainable Stock Exchange initiative.

See letter in English and Chinese

UK

September 2021

The PRI respond to a consultation from the FCA on a series of proposed reforms to improve the effectiveness of UK primary markets and how it might continue to develop to ensure they remain competitive and dynamic.

The PRI recommended that the FCA maintain the one-share, one-vote requirement in the UK premium listing segment and the FCA maintained the free float at 25% for the UK premium listing segment.

See response

Australia

September 2021

The PRI responded to the House of Representatives Standing Committee on Economics inquiry into the implications of common ownership and capital concentration in Australia

The PRI recommended that it is too premature for policymakers to respond to any hypothetical consequences of capital concentration and common ownership and no policy response should by introduced that may limit investors’ stewardship rights.

See response

US

September 2021

PRI Letter to Congressional Leaders calling for bold climate funding in budget legislation

The PRI called for any budget legislation to fully fund efforts to limit carbon emissions to set a precedent for bold climate action, consider climate impact across every committee, which represents an oppprtunity to create sustainable jobs and support a just transition.

See response

EU

September 2021

IOSCO Consultation on ESG Ratings and Data Product Providers

The PRI welcomed increased attention by regulators to the market for ESG ratings and data products and the providers of these products, but recommends that regulators focus on improving transparency and ensuring appropriate governance arrangements.

See response

Germany

September 2021

BaFin Consultation on requirements for sustainable funds

The PRI welcomes the ambition of these new guidelines to mitigate the risk of greenwashing through better accountability and transparency. Our key recommendations are:

1. Increase market harmonisation and coherence through enhanced collaboration at member state and EU-level
2. Clarify the relationship between the guidelines and ongoing EU legislation
3. Recognise the positive sustainability impact of investor stewardship
4. Clarify the definition of “sustainable investments”
5. Strengthen the ESG safeguards
6. Improve the “sustainable investment strategy” definition

See response

Global

August 2021

IOSCO Consultation on Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management.

The PRI recommended that the purpose of this work be clarified to support regulators and policymakers to align financial policy with sustainability goals, a taxonomy for sustainable activties, coherence at the policy design, implementation, and monitoring levels, and asset specific impelemntation.

See response

Global

July 2021

The PRI respond to a consultation from the Financial Stability Board’s Taskforce on Climate-related Financial Disclosures (TCFD) on metrics, transition plans and portfolio alignment.

The PRI recognised the significant step forward in the Taskforce’s guidance to preparers, but recommended improving the comparability of disclosures, internal carbon pricing, addressing systemic risk.

See response

South Africa

July 2021

Call for Stakeholder Inputs, Draft National Green Finance Taxonomy

The PRI recommended to maintain consistency with the EU Taxonomy and y scientific evidence; clarify the ambition of the GFT and consider a mandatory framework in the future; increase usability of the draft GFT; ensure future additions to the GFT have robust, science-based technical screening criteria; do not sacrifice ambition for the sake of practicality; instead, work to improve data availability; be clear about targets and transition; and re-assess the presentation of minimum social safeguards.

See response

EU

July 2021

PRI statement on the EU’s Strategy for Financing the Transition to a Sustainable Economy.

The PRI welcomed the EU’s Strategy for Financing the Transition to a Sustainable Economy, and made recommendations on investor duties to integrate sustainability outcomes, stewardship rules that better reflect sustainability outcomes, financing the transition to net zero, a coherent framework for human rights and social issues, and fostering international convergence

See response

US

June 2021

PRI Response to SEC Request for Comment on Universal Proxy

The PRI supports the establishment of universal proxy cards for contested elections of board directors and encourages the Commission to take further action to ensure shareholder equality and access throughout the proxy process.

See response

UK

June 2021

PRI respond to a call for evidence issued by the Committee for Work and Pensions on pensions stewardship and COP26

The PRI recommended that pension schemes that have made an emission reduction commitment should set near term targets and report on progress and highlight the importance of a consistent TCFD-aligned framework across the investment chain.

See response

UK

June 2021

PRI respond to a call for evidence issued by DWP on consideration of social risks and opportunities by occupational pension schemes

The PRI recommends that DWP work with The Pensions Regulator (TPR) to provide examples of decision-useful social indicators commonly used by investors, based on existing market practice and international developments, and that DWP engage with trustees to understand how they consider beneficiaries’ future quality of life and social impacts of investments.

See response

Australia

June 2021

PRI Response to the Australian Treasury consultation on Greater Transparency of Proxy Advice

The PRI considers the use and engagement of proxy advisory firms to be a prudent and cost-effective method for research on ESG risks to investors, and views the existing legal obligations are adequate.

See response

US

June 2021

PRI Response to SEC Request for Comment on Climate Change Disclosures

The PRI recommends that disclosure should be improved as part of a larger effort to facilitate the more thorough provision to investors of ESG information that has investment relevance. Investors need comprehensive, comparable and decisionuseful data from companies on climate change and a range of ESG issues

See response

EU

June 2021

European Commission consultation on the obligation for certain companies to publish non-financial information under the article 8 Taxonomy regulation delegated act

The PRI welcomes the draft Article 8 delegated act and provides 5 overarching recommendations:

1. Ensure consistency between disclosure requirements and sustainable finance policies, especially the Taxonomy RTS.
2. Bring the timeline of the review clause forward and consider extending capex plans for certain projects.
3. Remove the requirement to report a breakdown of numerators and denominators for financial undertakings.
4. Include all investments in the denominator of financial undertakings’ KPIs and allow voluntary disclosures of non-NFRD/CSRD companies in the numerators.
5. Provide guidance on minimum social safeguards disclosures.

See response

EU

May 2021

PRI Investor sign-on letter to European Rapporteurs on public country-by-country reporting

PRI welcomes the EU initiative to mandate public country-by-country reporting for multinational companies. This policy measure is timely given the EU proposal for a new Corporate Sustainability Reporting Directive, and vital to strengthen tax transparency and accountability while reducing the prevalence of tax avoidance practices that continue to challenge global economies and their pursuit of sustainability goals. Our letter sets out three key recommendations to ensure that the upcoming regulation is robust, works as intended, and can set the tone for policies of a similar nature in other jurisdictions.

See letter

EU

May 2021

PRI response to the European Supervisory Authorities’ consultation on Taxonomy-related product disclosures

The PRI welcomes the draft Regulatory Technical Standards (RTS), as they provided much needed clarity to investors preparing for their disclosures against the Taxonomy under the SFDR. Investor disclosures against the Taxonomy will bring much needed clarity to investment products' alignment with environmental objectives, and together with the SFDR, will provide an important level-playing field among financial market participants

See response

Japan

May 2021

PRI response to Japan Corporate Governance Code Revision consultation

The PRI welcomes the proposed draft of the revised version of the Corporate Governance Code, which explicitly recognises the importance of board independence, diversity and sustainability in creating long-term corporate value and sets out higher corporate governance standards for TSE Prime Listed Companies.

See response

China

April 2021

China consultation on the interim regulations on the carbon emission trading system

The PRI welcomes the consolidation of existing ETS regulations into a new State Council regulation. The PRI recommends enhancing the effectiveness and coverage of the national ETS by setting out a timetable for transitioning to a fixed cap emission trading scheme, introducing the auctioning of allowances, and announcing a target 2030 floor price of $60 per tonne of CO2.

See response (English and Chinese)

Japan

April 2021

PRI letters to Japanese ministers on climate policy

The PRI sent letters to key ministers (Minister of Finance, Minister of Economy, Trade and Industry, Minister of Environment, and Ministry of Health, Labour and Welfare) to communicate our recommendations on climate policy.

EU

April 2021

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

Global

April 2021

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

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.

See response

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 response

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 letter

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 letter

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.

See response

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.

See response

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.

See response

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 letter

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 response

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 response

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 response

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 response

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 response

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 response

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 response and Commission's analysis of data

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 response

Investor groups call on companies to reflect climate-related risks in financial reporting

Open letter calling on companies to ensure that their financial reports and accounts reflect the recent opinion from the International Accounting Standards Board (IASB) and are prepared using assumptions consistent with the Paris Agreement on climate change.

See letter

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 response in English and Chinese

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 response

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

Renewed Sustainable Finance Strategy

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

See response

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

Request for extension of comment deadline

See response

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 response

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

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 response

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 response

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 response

US

February 2020

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 2020

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 response

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.

See response