Consultations and letters

Region Date Consultation or letter PRI 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

US

June 2022

PRI response to the Securities and Exchange Commission consultation on The Enhancement and Standardization of Climate-Related Disclosures for Investors

The PRI supports the Securities and Exchange Commission in taking this vitally important action in line with its mission to protect investors and ensure fair, orderly and efficient markets. The PRI makes recommendations for the Commission to improve the proposed rule on Scope 3 emissions, transition plan and physical risk disclosure and climate scenarios and cross-industry disclosures aligned with TCFD.


See response

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

US

May 2022

PRI comment to the State Department on the National Action Plan for Responsible Business Conduct

The PRI recommends that the State Department considers the role of investors in the National Action Plan. The PRI supports improved disclosure on human rights and worker-related information along with clarification that human rights considerations fall within the fiduciary duties of investors.


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

Global

May 2022

Call to Action to G7 Leaders for a Just, Affordable, and Urgent Transition

The PRI supports the recommendations of four key policy areas—across finance, climate and nature, energy and social issues—to drive a just, affordable, and urgent energy transition, in order to transform our economies and improve security, sustainability and quality of life for citizens in G7 countries and the world over.


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

US

April 2022

PRI comment on the SEC’s proposed public company cybersecurity disclosure

The PRI supports the proposed disclosure requirements for publicly listed companies regarding cybersecurity risks and governance. The PRI supports the inclusion of disclosure requirements related to governance, such as disclosure of policies and procedures, board oversight and expertise, as well as management’s role in mitigating cybersecurity risks.


See response

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

April 2022

US Policy Briefing: SEC Proposed Rulemaking on Climate-Related Disclosures

On March 21, the SEC proposed climate-risk disclosure requirement. This briefing document provides an overview of the proposed rule in preparation for their comments on the climate disclosure rule.


See briefing document

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

Canada

March 2022

Independent Review Committee on Standard Setting in Canada

The PRI supports the creation of an independent, transparent and publicly accountable Canadian Sustainability Standards Board (CSSB) to work alongside existing domestic accounting and assurance boards and liaise with the new International Sustainability Standards Board under the IFRS Foundation.


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

India

March 2022

The PRI responded to the Securities and Exchange Board of India (SEBI) Consultation Paper on ESG Rating Providers

The PRI supports SEBI’s proposal to require ESG rating providers operating in India to be accredited and recommends that appropriate measures be adopted to support effective governance, minimise potential conflicts of interest and improve transparency for rating methodologies and communications


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

Australia

February 2022

The PRI responded to APRA’s consultation on it’s standards for investment governance – SPS 530.

The PRI recommends that SPS 530 should better reflect RSE licensee’s obligations to consider and mitigate material market-wide risks, particularly where sources of those risks stem from ESG-related issues. [delete paragraph gap] Additionally, the PRI recommends that explicit guidance be provided to RSE licensees in either SPS or SPG 530 on how they should consider and mitigate ESG-related risks at both the idiosyncratic and market-wide levels.


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 (ENG)
Voir la lettre d’appui (FR)

EU

February 2022

Multi-stakeholder statement on ensuring effective EU legislation on mandatory human rights and environmental due diligence

- Over 100 companies, investors, business associations and initiatives are calling for the EU to swiftly adopt an effective legislative proposal on mandatory human rights and environmental due diligence, within the Sustainable Corporate Governance initiative.


See response

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

EU

January 2022

The PRI has provided feedback to the European Commission on its proposal for the review of insurance sector rules (Solvency II review).

The PRI welcomes the review’s focus on addressing long-term sustainability risks in the insurance sector. However, more ambitious measures will be needed to align financial flows with the EU’s new sustainability objectives.


See response

EU

January 2022

Multi-stakeholder statement on CSRD reform and EU standards

The call to policy-makers for swift agreement on the EU Corporate Sustainability Reporting Directive highlights the importance and urgency of the reform to achieve the objectives set in the EU Green Deal and the sustainable finance agenda. The 12 signatories of the statement also firmly support the development and implementation of EU corporate sustainability reporting standards based on the double materiality concept.


See statement

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

UK

January 2022

The PRI respond to a consultation from DWP on proposals on Paris-aligned climate reporting and investment stewardship for occupational pension schemes.

The PRI welcomes the proposed reforms to Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021, and maintains that a focus on beneficiaries’ views and preferences is of paramount importance when discussing good stewardship for pension schemes.


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.


English and Chinese

UK

December 2021

Opposition against UK government’s considerations to proceed with Cambo oil field

Call on the UK government to reject the Cambo oil field in the North Sea, and to prevent any further investment and licenses for new oil and gas fields in the UK Continental Shelf


See response

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

US

December 2021

PRI Response to Department of Labor Proposed Rule Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

The PRI supported adoption of the Proposed Rule as it provides fiduciaries the clarity and autonomy necessary to appropriately consider climate-related and other ESG factors in their investment decisions and to exercise shareholder rights in line with their fiduciary duties and overarching investment strategy.


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 full letter

China

October 2021

MEE consultation on enterprise environmental disclosure

The PRI recommended that the MEE should extend the scope of reporting institutions to cover all large companies, listed companies and debt issuers, require climate related targets and quantitative measures, coordinate with other financial regulators to create a consistent reporting framework across corporate and FIs, and align with other global and regional standards including the work by the IFRS Foundation and EU CSRD.


See full response in English and Chinese

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

Global

September 2021

The PRI respond to the Financial Accounting Standards Board (FASB) on their draft future standard-setting agenda.

The PRI welcomed FASB’s consideration of future standard-setting actions on disclosure of ESG matters and their effect on financial statements and the disaggregation of corporate income tax disclosure on a country-by-country basis.


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

Canada

September 2021

PRI comments on the Government of Canada’s People-Centred Just Transition discussion paper

PRI encouraged the Canadian Government to pass people-centred just transition legislation which states the objective to accelerate Paris-aligned climate action in ways that will impact the real economy and deliver the Sustainable Development Goals.

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

EU

September 2021

Investor Statement of Support for EU Corporate Sustainability Reporting Directive (CSRD)

The PRI welcomed the European Commission’s proposal for a new Corporate Sustainability Reporting Directive (CSRD) revising the Non-Financial Reporting Directive (NFRD), and its aim to elevate sustainability information to the same level as financial information.


See response

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

EU

September 2021

PRI consultation response on EFRAG’s proposed Due Process Procedures.

The PRI welcomed the proposed processed and makes two main recommendations, suggesting to maximise user and preparer input and to engage and contribute global sustainability reporting initiatives.


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

UK

September 2021

The PRI respond to a consultation from the FCA on proposals to introduce climate-related financial disclosure rules and guidance for asset managers, life insurers, and FCA-regulated pension providers at both the product and entity-level.

The PRI outlined support for several recommendations made by the FCA, including the proposal to require disclosure by in-scope firms at both the entity and product level.


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

Canada

July 2021

PRI support for Bill S-216, Act to enact the Modern Slavery Act and to amend the Customs Tariff

In order to align the act with international standards and emerging regulation in other jurisdictions, the PRI recommended four alterations to the bill that are crucial for institutional investors to avoid subjecting them and their portfolio companies to deviating national standards.


See response

Australia

July 2021

The PRI respond to APRA prudential practice guide on climate change financial risks

PRI recommended that APRA clarifies and strengthens the guidance on how climate change risks should be considered in investment governance frameworks and management of investments, and proposes a mechanism for transition to mandatory disclosure requirements.


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

UK

July 2021

The PRI respond to a consultation from BEIS on restoring trust in audit and corporate governance

The PRI supported recommendations around strengthening malus and clawback conditions on directors’ remuneration arrangements and providing clarity on existing requirements for auditors, but suggesting that the regulator provide clarity on the content and structure of the Audit and Assurance Policy.


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

US

June 2021

PRI’s comment on the Detailed Guidance for New York Domestic Insurers on Managing the Financial Risks from Climate Change

The PRI supported 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

US

June 2021

Letter in Support of H.R. 1187 Corporate Governance and Investor Protection Act

The PRI supported the ESG Disclosure Package, the Climate Risk Disclosure Act and bills that would require compensation, tax, and political spending disclosure, which are increasingly relevant to investor decision making.


See full letter

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

EU

June 2021

Joint letter on Renewed Sustainable Finance Strategy on Stewardship and Shareholders Right Directive

The PRI, EUROSIF and SHARE ACTION have sent a joint letter to EU commissioners and vice president calling for stewardship to be included in the upcoming Renewed Sustainable Finance Strategy and for an early revision of the Shareholder Rights Directive (SRD II).


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

Sign On Letter on SEC Request for Comment on Climate Change Disclosures

The PRI organized a sign-on letter for signatories and supporting organizations in support of standardized, mandatory disclosure of material climate and environmental, social and governance (ESG) information, to fulfill a fiduciary obligation to fully consider material information and make informed investment decisions for long-term value creation.


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

China

June 2021

CSRC consultation on periodic reporting rules for listed companies

The PRI recommends that the CSRC should introduce mandatory, standardized reporting requirements that can align with global standards, include disclosure on climate-related targets and quantitative measures, include forward looking disclosure in line with the TCFD recommendations, coordinate with other ministries to further extend the scope of reporting institutions, and create a consistent reporting framework across corporate and financial institutions.


See full response in English and Chinese

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

Speech at the European Parliament – Public hearing on Sustainable Finance organised by ENVI and ECON committees

Mr Nathan Fabian, Chair of the Platform on Sustainable Finance and Chief Responsible Investment Officer at the PRI, gave evidence in a public hearing at the European Parliament about the need for sustainable finance policy reforms in the EU and beyond. The speech summarises the challenges of policy changes and needs for market practice evolution.


See speech

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 full letter

Australia

May 2021

PRI response to the Joint Standing Committee on Trade and Investment Growth Inquiry

The PRI welcomes the Joint Standing Committee’s Inquiry into the prudential regulation of investment in Australia’s export industries. The PRI is supportive of policies which provide investors with better information to assess ESG risks and opportunities in all investments, including in export industries, given the speed of change and ambition of the climate policy positions of Australia’s key trade partners.


See response

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 Guidelines for Investor and Company Engagement consultation

The PRI welcomes the revised version by the Council of Experts of the Guidelines for Investor and Company Engagement, which explicitly recognises the importance of sustainability, board responsibility and diversity in creating long-term corporate value. We recommend that the Council of Experts provide greater clarity on how these guidelines should be used by investors and companies to implement the Stewardship Code and the Corporate Governance Code.


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

UK

May 2021

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

US

April 2021

2021 US Policy Briefing: SEC Requests Comments on Climate Change Disclosures

On March 15, the Acting Chair of the Securities and Exchange Commission, Allison Herren Lee, issued a statement requesting public comment on climate change disclosures, acknowledging the lack of consistent and comparable climate change information for investors under existing SEC regulations. This briefing document provides information for signatories in preparation of their comments on climate change and ESG disclosures to the Commission.


See briefing

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)

US

April 2021

PRI Signatory Sign-on Letter to the SEC on the Request for Climate Information

The PRI’s signatory sign-on letter in response to the SEC’s request for climate information. The PRI encourages signatories to sign the letter and help advocate for mandatory ESG and climate disclosure. This letter will remain open through June 7, 2021.


See response

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

EU

April 2021

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 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

US March 2021

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 2021

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 full response

EU March 2021

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.


See full response

UK March 2021

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 2021

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 2021

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 2021

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.


See full response

US February 2021

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 2021

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.


See full response

EU February 2021

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 full response

UK February 2021

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.


See full response

EU January 2021

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 full response

South Africa January 2021

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.


See full response

Hong Kong SAR January 2021

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 full response

Canada January 2021

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.


See full response

UK January 2021

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 2021

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

Global December 2020

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 2020

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 2020

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

US

September 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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

Request for extension of comment deadline


See full request

Israel September 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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

US June 2020

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

Request for extension of comment deadline


See full response

UK June 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 2020

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 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 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 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 full response

Japan January 2020

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 2020

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


2015 - 2019

Archived consultations and letters 2015 - 2019

Region Date Consultation or letter PRI response
US December 2019

Signatory sign on letter: SEC's proposed changes to shareholder proposals and proxy advisory firms

The PRI and the undersigned signatories oppose the proposed changes to Rule 14a-8 and proxy voting advice. The PRI encourages signatories to sign on through the collaboration platform. This letter will remain open through January 31st, 2020.


See full letter

UK November 2019

Law Commission | Scoping study on intermediated securities

The PRI supports the Law Commission’s study into this area. The current system of intermediation creates barriers to investors properly exercising their voting rights and thus hinders their active ownership responsibilities. It also impedes the incorporation of beneficiaries’ sustainability preferences, a core component of fiduciary duty.


See full response

US October 2019

US November Securities and Exchange Commission | Comment on proposed changes to Regulation S-K items 101, 103 and 105

The PRI is concerned that many of the proposed changes are not beneficial to investors, particularly on the issue of materiality, the shift in multiple disclosure items to a principles-based approach, and the failure to address investors’ demand for enhanced climate risk disclosure.


Read the letter

US October 2019

An open letter to our US signatories on public policy engagement

The PRI's CEO, Fiona Reynolds, writes to US signatories on the PRI's public policy priorities in the United States.


See full letter

UK September 2019

The Pensions Regulator | Future of Trusteeship and Governance

ESG issues are likely to have an increasingly material effect on returns in the coming years, and policies and regulations relating to these issues are rapidly growing. TPR needs to prepare trustees for this shift by, in particular:

  • Setting minimum levels of knowledge and training for trustees on ESG issues
  • Ensuring trustees of relevant schemes are informed of processes around winding up to encourage consolidation


See full response

UK September 2019

Home Office | Transparency in supply chains

The PRI welcomes the UK government’s commitment to strengthening section 54 of the Modern Slavery Act, and believe that the most effective measures for doing so include:

  • Mandating companies to report on the six areas currently suggested in the Act
  • Improving implementation of the Act, for example through a central registry of statements, and sanctions.


See full response

UK September 2019

The Pensions Regulator | Draft guidance consultation in response to CMA recommendations

To improve investment consultation service provision on ESG-related issues, the PRI recommends the guidance includes:

  • Case studies on common challenges trustees face on ESG
  • Sample objectives that more proactive pension funds may set for their consultants on ESG


See full response

New Zealand September 2019

Ministry of Business, Innovation and Employment: Review of KiwiSaver default provider arrangements

Responsible investment has a crucial role in delivering the aims of the Kiwisaver Act, mainly increasing individuals’ wellbeing. As such our recommendations to the Ministry of Business, Innovation and Employment are:

  • All default KiwiSaver providers should integrate ESG issues in their investment practices, processes and decision-making, consistent with their investment time horizons.
  • All default KiwiSaver providers should understand and take account of beneficiaries’ and savers’ sustainability-related preferences.
  • The Ministry should provide guidance on KiwiSaver disclosure requirements on ESG issues, including climate change.


See full response

UK July 2019

Treasury Select Committee | Decarbonisation of the UK economy and green finance

Following oral testimony before the Treasury Committee, the PRI has provided written evidence on the policies needed to achieve net zero emissions in the UK. The PRI’s recommendations include:

  • A more joined-up approach to developing climate policy across government
  • De-risking low-carbon investments by scaling up available finance in infrastructure and tech innovation funds
  • Provide a clear and stable direction regarding future carbon policy, such as clarity on carbon pricing beyond 2021 and a net zero national capital raising plan


See full response

US July 2019

House Financial Services Committee

The PRI commends the Subcommittee for calling this hearing to consider legislative approaches to require issuer disclosure of ESG data. Investors need access to consistent, comparable disclosure of material ESG data to make informed investment decisions.


See full response

US July 2019

Securities and Exchange Commission

The PRI urges the Commission to promote long-term investing by ensuring investors have access to the information and tools necessary to incorporate material ESG factors into investment decisions. Short-termism in today’s markets leads to a series of negative externalities including market volatility and inefficiencies in capital allocation.


See full response

Hong Kong July 2019

Hong Kong Stock Exchange | Consultation on the review of the ESG disclosure reporting guide and related rules

PRI recommends that material ESG information is published in the annual report and reported alongside financial indicators; ESG disclosure is placed under oversight by the board; the board sets quantified and dated ESG targets; that primary ESG metrics are required. In addition, we recommend industry-specific and forward looking disclosures aligned with the TCFD framework.


See full response

UK July 2019

Financial Conduct Authority (FCA)

The PRI recommends that the FCA regulate Independent Governance Committees (IGCs) directly and require providers, rather than IGCs, to be the primary source of reporting for scheme beneficiaries.


See full letter

UK July 2019

Financial Conduct Authority (FCA) | Consultation on extending the remit of Independent Governance Committees

The PRI welcomes extending the remit of IGCs to include material ESG factors, stewardship and integration of member views.


The PRI recommends that the FCA produce guidance to improve the quality of reporting for beneficiaries of contract-based schemes, and places a stronger imperative on providers to integrate member views.


See full response

UK April 2019

Financial Conduct Authority (FCA) and Financial Reporting Council (FRC) | Discussion paper on Building a regulatory framework for effective stewardship

In light of regulatory changes proposed to encourage greater stewardship in the UK, the FCA and FRC jointly published a discussion paper on what further barriers to effective stewardship remain and how they might be overcome. The PRI recommends:


  • maintaining the proposed definition of stewardship, which reflects corresponding duties in the UK and beyond and emerging practices among some investors; and
  • featuring the outcomes achieved by stewardship activities more prominently in the proposed “key attributes”.

Proxy advisors and investors work together to address market actors’ concerns and strengthen their contribution to an effective stewardship culture.



See full response

Colombia April 2019

Superintendencia Financiera de Colombia |  Comment on Technical Document of Good Practices

The PRI recommends that AFPs clarify that FCPs should incorporate ESG issues consistent with the time frame of the beneficiary, and that the ESG preferences of beneficiaries should be understood and incorporated. The PRI recommends that the Superintendencia Financiera de Colombia, and AFPs, refer to the PRI’s Limited Partners’ Responsible Investment Due Diligence Questionnaire (DDQ) as a starting point for engaging FCPs. 


See full response

UK April 2019

Department for Work and Pensions (DWP) | Consultation on Investment Innovation and Future Consolidation

In February, the DWP opened a consultation to support greater pension fund investment in illiquid assets, and recommends that smaller direct contribution schemes consider consolidation. The PRI welcomes the consultation and recommends expanding the reporting scope for consolidation to include larger schemes.


See full response

UK March 2019

Financial Reporting Council (FRC) | Consultation on a revised Stewardship Code

In January, the FRC proposed substantial revisions to the UK Stewardship Code, in its first update since 2012. The PRI strongly welcomes many of the proposed changes, particularly the explicit recognition of the importance of ESG considerations and the introduction of an annual reporting requirement. The PRI’s priority recommendations are:

  • The Code places a greater emphasis on the outcomes of stewardship activities.
  • The guidance should provide best practice examples of stewardship of other asset classes and be updated regularly.
  • Service providers’ responsibility to provide ESG-related services to clients should be explicitly recognised.
  • The FRC should avoid duplication between the reporting framework of the Stewardship Code and internationally-used frameworks.


See full response 

UK March 2019

Financial Conduct Authority (FCA) | Consultation on the implementation of the revised Shareholder Rights Directive

The PRI welcomes the regulatory baseline that the implemented Directive will introduce for disclosure of active ownership activities. The PRI recommends strengthening this baseline by requiring disclosure on a mandatory rather than comply or explain basis.


See full response

IOSCO March 2019

IOSCO consultation report on sustainable finance in emerging markets and the role of securities regulators 

This report and its recommendations will support securities regulators in promoting the development of responsible investment practices in  emerging markets. The PRI recommends that securities regulators introduce mandatory ESG disclosures, aligned with international standards and existing best practice, including explicit reference to TCFD implementation and reporting.


See full response

OECD March 2019

IOPS consultation on draft supervisory guidelines on the integration of ESG factors in the investment and risk management of pension funds

The draft guidelines will support pension fund supervisory authorities incorporate ESG requirements in investment regulations.
The PRI recommends that IOPS clarifies the definition of ESG integration in the guidelines and proposes that pension fund supervisors introduce regulations on ESG disclosures by pension funds and their asset managers.


See full response

EU March 2019

European Securities and Markets Authority (ESMA) | Consultation on Disclosure Requirement applicable to Credit Ratings

The PRI welcomes the Guidelines on Disclosure Requirements Applicable to Credit Ratings as a significant step forward in transparency, by encouraging better signposting of how ESG factors may contribute to a credit rating opinion, rating outlook or related action.


The PRI recommends that ESMA amends its guidelines to better reflect that:


  • ESG Disclosure should stress how ESG factors contributed to the improvement or the deterioration of the credit quality of the entity or instrument rated
  • ESG factors are among many material elements considered to form a credit rating opinion
  • The disclosure requirements should apply to ratings opinions, rating outlooks and rating action


See full response

EU February 2019

European Securities and Markets Authority (ESMA) | Consultation on integrating sustainability risks and factors in MiFID II

In June 2017, the European Commission sent a request for technical advice to ESMA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under MiFID II.


The PRI supports many aspects of the proposed technical advice from ESMA. However, the PRI strongly recommends that the draft technical advice also provide clarity on investor duties, as set out in Article 21(1) of MiFID II.


See full response

EU

February 2019

European Securities and Markets Authority (ESMA) | Consultation on integrating sustainability risks and factors in the UCITS Directive and AIFMD .

In June 2017, the European Commission sent a request for technical advice to ESMA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under UCITS Directive and AIFMD.


The PRI supports many aspects of the proposed technical advice. However, we strongly recommend that the draft technical advice also clarifies investor duties, as set out in Article 14(1) of the UCITS Directive and Article 12(1) of AIFMD.


See full response

France 

January 2019

Autorité des Marchés Financiers (AMF) |  Roadmap on Sustainable finance

The PRI strongly welcomes the AMF’s Roadmap on Sustainable finance. Our priority recommendations are:


  • The AMF, together with ACPR, should provide guidance on ESG integration and strengthen its oversight by publishing an annual overview of the market.
  • The AMF should articulate its activities supporting active ownership and increase transparency of (proxy) voting, as well as improve shareholder filing and accountability of the French stewardship code.


See full response in French

UK

January 2019

Financial Conduct Authority (FCA)” | Climate change and green finance

In October 2018, the FCA published a discussion paper on how the issues of climate change and green finance relate to the regulator’s objective of ensuring that markets work well.


The PRI’s priority recommendations are:

  • Financial regulators including the FCA, should issue official guidance that climate change is a material financial risk and thus required to be reported under existing UK law.
  • The FCA, together with other financial regulators, should integrate the TCFD recommendations throughout the existing corporate governance and stewardship reporting frameworks.
  • A comply-or-explain approach should be avoided.
  • The burden for issuers of these extensions to UK law can be reduced by implementing them over a two-year period and leveraging the FCA and PRA Climate Risk Forum.


See full response

EU

January 2019

European Insurance and Occupational Pensions Authority (EIOPA) | Consultation Paper on Technical Advice on the integration of sustainability risks and factors in the delegated acts under Solvency II and IDD

In June 2017, the European Commission sent a request for technical advice to EIOPA to supplement the initial package of legislative proposals and assist the Commission on potential amendments to the delegated acts under Solvency II and the Insurance Distributor Directive.


The PRI finds that ambiguity around investor duties has been a key barrier and therefore strongly welcomes the legal clarity proposed in EIOPA’s draft technical advice. The PRI recommends that the amendments be further aligned with the High-Level Expert Group recommendations on investor duties, governance and risk management.


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Canada

January 2019

Government of Canada | Interim report of the expert panel on sustainable finance

In April 2018, the Government of Canada announced the creation of the Expert Panel on Sustainable Finance, tasked with building on the work of similar initiatives around the world, including the Task Force on Climate-related Financial Disclosures, and developing recommendations on the types of finance and investment structures that will help build the low-carbon economy. The PRI’s priority recommendations are:


  • The Government of Canada should endorse the TCFD recommendations without delay. This should be part of a Canadian strategy on Sustainable Finance.
  • Department of Finance Canada should clarify that fiduciary duties require ESG integration.
  • Department of Finance Canada should ensure effective implementation, oversight and monitoring of responsible investment-related regulation.

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US November 2018 SEC | Comment on SEC Staff Roundtable on the Proxy Process The shareholder proposal process is critical to the functioning of the investment intermediation chain, and proxy advisory firms play an important role in the shareholder voting process, providing investors with high quality, impartial analysis of corporations. The PRI believes that the current proxy advisory process should not be changed, and that the current ownership requirements and resubmission thresholds are set at the appropriate levels and should not be changed.

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South Africa October 2018 Johannesburg Stock Exchange (JSE) |  Public input on possible improvements to its regulatory approach to new and existing listings on the JSE The PRI supports the introduction of mandatory training for members of the audit committee on their responsibilities prior to listing and as a continuing obligation post listing, including training on systemic issues, such as the urgent need to tackle climate change. The PRI supports the increased focus on the corporate governance report. The PRI recommends that JSE endorse the Task Force on Climate-related Financial Disclosures framework, and encourage its use through the corporate governance framework.

See full position
Brazil October 2018 PREVIC  | Public consultation of the investment rules in resolução CMN 4881/2018 Articles 27, VI and VII should be updated to require the consideration of ESG risks and opportunities, consistent with the timeframe of the investor.

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Australia September 2018 APRA | Review of the prudential framework for superannution funds The prudential framework could be improved by better alignment with the Principles for Responsible Investment, to be more effective in achieving its policy objective of achieving better risk management outcomes and managing material risks in the best interests of beneficiaries.

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UK  September 2018 OSCR | Charity investment guidance We welcome the OSCR’s guidance for Scottish charity trustees regarding rules and responsibilities associated with investing their assets, however, we recommend that the guidance makes a clear distinction between:
i) the consideration of ESG issues as a necessary component of making investment decisions to manage financial risk and return in the best interests of the charity, and;
ii) investment decisions which take ethical and other non-financial factors into account.

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US August 2018 SEC |  Enhancing investment adviser regulation The PRI recommends that the SEC clarify that economically-relevant ESG factors are part of a prudent investment decision, and a requirement of an advisers’ duty of care and duty of loyalty. The PRI recommends this is codified under section 206 of the Advisers Act. The PRI supports ILPA’s recommendation that the SEC rescind the Heitman Capital Management no-action letter

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EU August 2018 European Commission DG FISMA | May 2018 legislative proposals on investor dislcosure, taxonomy and benchmarks The PRI strongly supports all four of the Commission’s recent regulatory proposals. Theproposals are strongly aligned with the Six Principles that investors agree to implement when theybecome PRI signatories. The PRI believes the Commission’s approach is comprehensive. Wewelcome the opportunity to contribute to the Commission’s work through the High Level ExpertGroup (HLEG) and The Expert Group (TEG) on Sustainable Finance.

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UK August 2018 The PRI respond to a call for evidence from BEIS on reviewing the purpose and function of the Financial Reporting Council (FRC). The PRI welcomes the opportunity to respond to this call for evidence. The PRI makes recommendations with consideration of the future UK Stewardship Code, including the recommendation to explicitly reference the TCFD as a framework for best practise climate-related financial disclosures.

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UK August 2018 CMA | Comments on the investment consultants market investigation provisonal deicison report The PRI welcomes the publication of the CMA’s Provisional Decision Report (18 July 2018). Our comments are largely restricted to chapters 1, 2 and 13 on remedy package and provisional decision on remedies: how proposed remedies fit with financial and other regulatory requirements on providers.

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US August 2018 SEC | Transaction fee pilot The PRI notes concerns that rebates can detrimentally impact long-term institutional investors, including U.S. and international retirement plans.

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Italy August 2018 MEF, directorate IV | Transposition of IORPii (directive EU2016/2341) Il PRI accoglie l’iniziativa del Dipartimento del Tesoro del Ministero dell’Economia e delle FinanzeItaliano per la trasposizione della direttiva UE 2016/2341. In particolare, lodiamo l’ambizione dellatrasposizione della direttiva che include in molteplici articoli le tematiche ESG e che continua illavoro cominciato con il Dlgs.252/2005. Siamo certi che la trasposizione della direttiva creerà uncontesto d’azione positivo in attesa della proposta legislativa UE sulle investors disclosures.

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China July 2018 AMAC | Guidelines to green investing The proposals in the draft guidelines are consistent with the recommendations of the recent PRI and UNEP FI report, Investor Duties and ESG Integration in China, published with the IIGF and The Generation Foundation in March 2018.

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Australia July 2018 ASX Corporate Governance Council | 4th edition corporate governance principles and recommendations The PRI welcomes the proposed amendments to Recommendations: 1.5, 1.6, 3.3, 3.4, 4.4 and 7.4. The PRI strongly supports the revision of Principle 3 including; the focus on corporate culture, and recognition that social license to operate is one of the most valuable assets of any listed entity. In addition we recommend extending some parts of the Code’s the proposed commentary to recommendations 1.5, 1.6, 4.4. and 7.4.

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US July 2018 SEC | 2018-2022 strategic plan The PRI welcomes the opportunity to comment on the U.S. Securities and Exchange Commission’s (SEC) Draft Strategic Plan for 2018 – 2022. The PRI strongly recommends the SEC facilitate enhanced financially relevant ESG disclosures, in particular on climate change, as an additional initiative under Section 1.

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UK July 2018 DWP | Pension trustees’ investment duties (Investment Regulations) The PRI strongly endorses the proposed amendment to the Investment Regulations to clarify that the consideration of ESG factors is a core part of prudent investment decision-making.

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EU June 2018 European Commission DG FISMA | MiFID II suitability requirements The PRI notes that under the existing MiFID II framework, firms providing investment advice and portfolio management are required to obtain information about the client … to provide services and products that are suitable for the client (suitability assessment). Without considering the client’s ESG preference, this process is incomplete.

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South Africa May 2018 FSB | Draft directive on sustainability reporting and disclosure requirements The Draft Directive provides a comprehensive check-list of items that should be covered by investment policy statements. It also requires the reporting of such information through pension funds’ financial statements and annual trustee report to beneficiaries. The Draft Directive provides practical guidance to pension funds that should further help implement Regulation 28 and increase accountability to beneficiaries.

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France  April 2018 AFEP MEDEF | Corporate governance code for listed companies The PRI’s overarching recommendation is that the incorporation of sustainability considerations is further developed and strengthened in the Afep-Medef Code. We make two further overarching recommendations regarding this consultation process.

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Japan April 2018 FSA/TSE | Guidelines for investor-company engagement The PRI recommends that the Code makes explicit reference to ESG issues in Board decision making and long-term value creation. This will ensure consistency with expansion of the Stewardship Code guidance to explicitly reference the importance of ESG factors.

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Japan April 2018 FSA/TSE | Japanese corporate governance code We particularly welcome emphasis on companies’ sustainable growth to increase value over the long-term. We recommend strengthening the incorporation of sustainability considerations, with explicit reference to the need for company boards to consider ESG issues for long-term value creation. This will ensure consistency with the Council’s previous expansion of its guidance under the Stewardship Code to explicitly reference the importance of ESG factors.

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UK March 2018 CMA | Comments on the investment consultants market investigation first working paper We believe that the competition and customer issues identified in the Working Paper are limiting the extent to which ESG issues are part of consulting advice and investment strategies. The PRI’s findings to this effect, including the barriers and potential solutions, are explained in our Investment Consultant Services Review. We believe the Working Paper’s remedies would help address these barriers.

See full letter.
UK February 2018 FRC | UK corporate governance code The central recommendation of the PRI’s response is that the FRC should pay more attention to ESG issues throughout the UK Corporate Governance and the UK Stewardship Code. In particular, the UK Stewardship Code should explicitly state that environmental and social issues are important drivers of long-term investment value, and are part of the fiduciary duty that investors owe to their clients and beneficiaries.

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UK February 2018 CMA | Investment consultants market investigation The PRI’s recent Investment Consultant Services Review finds that most investment consultants and their asset owner clients are failing to consider ESG issues in investment practice – despite a growing evidence base that demonstrates the financial materiality of ESG issues to portfolio value. Neglecting ESG issues can lead to asset owners mispricing risk and making poor investment decisions. This is why effectively managing ESG issues is a core part of the fiduciary duties owed by asset owners, and their advisers, to beneficiaries.

See full repsonse.
EU January 2018 European Commission DG FISMA | Institutional investors and asset manager duties Many of the world’s largest institutional investors have made public commitments to integrate ESG issues in investment decision making, for example, by signing the Principles for Responsible Investment (PRI). Many policy makers have also acknowledged the financial materiality of ESG factors, for example, by requiring pension funds to disclose their approach to ESG issues. However, as discussed later in the PRI’s consultation response, the PRI finds policy and regulatory effectiveness is hampered by weak implementation and weak signals.

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UK January 2018 Parliament Environment Audit Committee | Green finance inquiry The UK green finance taskforce and EAC’s inquiry is an opportunity leverage capital markets to support the delivery of UK policy goals and consolidate UK leadership in developing new green financial markets. In order to capitalise on this opportunity and better align financial markets with the UK’s carbon reduction and green finance objectives, PRI recommends measures on: fiduciary duty, TCFD and policy frameworks.

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UK January 2018 Parliament Work and Pensions Committee | Defined ambition pensions inquiry We believe that the proposed CDC funds could play a role in addressing the inadequacy of provisions for retirement income that currently exists across the UK. The PRI offers the following recommendations to enable and encourage the integration of ESG factors into investment
decision-making in the UK capital market, to benefit the UK pensions market and proposal for CDC pension funds.

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US December 2017 FASB | Proposed accounting standards update to income taxes We welcome the proposed disclosure of disaggregated information on taxes from companies. We would encourage consideration of additional reporting requirements that would enhance tax transparency.

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UK  October 2017 FRC | Non-financial reporting guidance The PRI welcomes the updated guidance and  strongly recommends that the FRC: endorse the TCFD recommendations; and integrate the TCFD recommendations into the guidance on the strategic report.

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Canada September 2017 Department of Finance | Federal financial sector framework The PRI recommends that the Department pay more attention to the incorporation of ESG issues, goes beyond ESG integration to consider how the financial system works in aggregate in delivering sustainability outcomes and that the Department set up its own expert group on sustainable finance in the Canadian context.

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Canada August 2017 CSA | Climate disclosure review The PRI welcomes the Canadian Securities Administrators (CSA) climate change disclosure
review. Climate change is a financially material risk that requires disclosure. The PRI encourages the CSA to support the standardisation of climate change disclosure thereby increasing the availability and use of comparable climate-related, financial and risk management information.

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Japan August 2017 TSE | English information survey As part of TSE’s efforts in promoting dialogue between listed companies and overseas investors, we recommend for Japan Exchange Group (JPX) to publicly sign the United Nations Sustainable Stock Exchanges initiative and implement environmental, social and governance (ESG) guidance for listed companies, consistent with other peer exchanges.

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Canada May 2017 OSC | 2017 - 2018 Draft statement of priorities The PRI recommends the OSC consider: introducing mandatory say on pay, clarifying ESG disclosure requirements for companies, working with IOSCO to harmonise ESG reporting standards, enhancing gender disclosure requirements.

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Europe March 2017 European Commission DG FISMA | Mid-term review of the Capital Markets Union The Commission should also ensure that sustainability remains part of financial policy-making processes beyond the time horizon of the HLEG. We note proposals for a ‘sustainability test’ for all future legislation. We would also encourage the Commission to consider formal governance to monitor and guide the development of sustainable finance across the EU.

Full response here.
Global February 2017 FSB | TCFD: Phase 2 consultation We urge the Task Force and FSB to accelerate their efforts, with a stronger on follow-up actions to drive implementation over the coming years. We recommend the following priorities, informed by feedback from PRI signatories on the Task Force’s draft recommendations.

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UK  February 2017 FCA | Asset management market study (interim findings) We strongly support the FCA’s Asset Management Market Study. Regarding the scope of the study, we consider that the FCA’s study is too narrow in its coverage of environmental, social and governance issues and fails to directly address ESG issues as a potential driver of competition and a growing unmet investment industry need.

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UK  February 2017 BEIS | Corporate governance reform green paper There are key two areas of work undertaken by the PRI which inform our response to BEIS green paper on reforming corporate governance:
1. PRI commissioned research and investor dialogue with companies on corporate
governance issues, including executive pay.
2.  PRI’s UK Roadmap, which makes a series of recommendations to achieve full integration of ESG issues in the investment decision-making of UK investors.

See full response.
UK  January 2017 Law Commission | Defined contribution pension funds and social investment Throughout this response, we note practical and legal challenges faced by funds considering ESG issues, irrespective of the expected financial implications. We highlight one for the Commission’s particular attention – the absence of clear guidance on determining ‘significant financial detriment’. In our experience, this causes Trustees to be excessively conservative in their approach. 

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Brazil December 2016 BOVESPA | Corporate Governance Review PRI has two overarching recommendations: PRI encourages BM&FBovespa to clearly communicate that good governance requires companies to be aware of, and manage environmental and social risks and opportunities and to ensure that the special listing segments drive better ESG disclosure.

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Germany December 2016 Regierungskommission | German Corporate Governance Code The PRI welcomes the opportunity to comment on the revisions to the German Corporate Governance Code and makes the following recommendations…

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UK December 2016 TPR | 21st Century Trusteeship and Governance We welcome the opportunity to contribute to this discussion. Below, we propose ways in which Trusteeship and Governance could be improved to encourage stronger consideration of ESG issues, in the long term best interests all market participants.

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EU November 2016 European Parliament, ECON Committee | Corporate tax disclosure We encourage you to consider the following: establishing a comprehensive disclosure regime for corporations including details of tax policy, governance, risk management and performance. Further details are provided below; and aligning future disclosure requirements with evolving international standards on Country by Country Reporting (CbCR).

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US October 2016 DOL ESBA | 1210-AB63 rule: annual reporting and disclosure The proposed rule will improve governance and transparency of employee benefit plans. The rule will ensure employee benefit plans review and report on a comprehensive range of risks, appropriate to the nature, scale and complexity of the plan, and in doing so provide better investment outcomes to plan members.

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EU September 2016 European Comission DG FISMA |  – Revision of the IORP directive PRI recommends; 1. The Council should support the ECON committee’s amendments to recital (41) and articles 22, 26, 29 and 32. 2. The Council should clarify that the prudent person principle requires asset owners to pay attention to long-term factors, including ESG factors, in investment decision making and the decision-making of their agents. 3. The EU and Member States should support regulators to effectively supervise the Directive. Best practice sharing between regulators should be encouraged.

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UN  September 2016 UNFCCC | Roadmap for global climate action The PRI Executive welcomes the opportunity to submit its views to this consultation.

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Brazil July 2016 AMEC | Stewardship Code PRI welcomes the development of the Stewardship Code which covers
both stewardship and ESG incorporation practices.

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South Africa July 2016 IoD SA | King Code IV: retirement sector supplement Regarding the retirement sector supplement, we have three key recommendations.

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US July 2016 SEC | Regulation S-K business and finance disclosure requirements PRI calls on the Commission to update Regulation S-K to ensure high quality, substance over-form disclosure of ESG factors.

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EU June 2016 European Commission DG JUST | Anlaysis on the state of the market for long-term, sustainable investment The PRI recommends that the European Commission develop and publish an
action plan to remove barriers to long-term, sustainable investment.

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South Africa May 2016 IoDSA | Revision of the King Code PRI agrees that the main objectives of the revision relating to presenting a clear, coherent
standard for integrated corporate governance, have been met and we make the following recommendations…

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Australia April 2016 ISA / IAST | Fraser review: Board governance of not-for-profit superannuation funds The Fraser review, as part of the recommendations for any Not-for-Profit fund governance code.

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UK April 2016 BIS | Non-financial reporting directive A comprehensive, meaningful picture of a company’s position and performance must include both financial and non-financial factors4. We welcome the Non-Financial Disclosure Directive, which will substantially increase the availability of relevant information to investors.

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Singapore February 2016 SGX | Consultation on sustainability reporting The PRI is responding to this consultation as ESG factors are material to issuers’ performance and improved transparency is critical for investors to make informed investment decisions.

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UK February 2016 GEO | Gender pay gap reporting We encourage you to work with leading institutional investors to ensure that they are aware, and making use of the new disclosures on gender pay.

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Hong Kong June 2015 SFC Principles of Responsible Ownership The PRI encourages the Securities and Futures Commission to require institutional investors to report annually on compliance with the Principles of Responsible Ownership.  

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Japan January 2015 FSA Corporate Governance Code The PRI supports the objectives of the proposed Corporate Governance Code. The PRI believes that along with active stewardship, this will contribute to higher standards of corporate governance, and ultimately, sustainable long-term growth.   

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UK April 2015 DWP Proposed changes to the Investment Regulations Trustees should state how they evaluate long-term risks which explicitly include ESG factors. ESG factors are material considerations in all investment decisions.  

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