Consultations & letters 2021
Consultations and letters
| Region | Month | Consultation or letter | PRI response |
|---|---|---|---|
| US | February |
PRI Statement for the Record for House Financial Services Subcommittee Hearing |
The PRI submitted a Statement for the Record for the House Financial Services Subcommittee on Investor Protection, Entrepreneurship and Capital Markets hearing entitled, "Climate Change and Social Responsibility: Helping Corporate Boards and Investors Make Decisions for a Sustainable World". The PRI believes consistent, comparable information from mandatory corporate disclosures is the most efficient way for investors and the public to access necessary information about ESG risks and opportunities and make informed investment decisions. |
| France | February |
Public consultation on the Decret proposal for amending ART 29 of Energie Climate Law (former ART 173) |
As the EU Regulation on sustainability‐related disclosures in the financial services sector (SFDR) allows member states who wish so to adopt or maintain more ambitious requirements (Recitals 28), this revision of the law is an opportunity for France to maintain its leadership on these topics and to help accelerate investor awareness and action. PRI supports efforts to align the new disclosure framework with the recommendations of the Task Force of Climate Related Financial Disclosures (TCFD), specifically the inclusion of detailed criteria related to alignment with Paris Agreement objectives. |
| US | February |
PRI Comment on FTC Proposed Rulemaking on Hart-Scott-Rodino Premerger Notification Requirements |
The PRI submitted a comment to the Federal Trade Commission in response to its proposed rulemaking to amend the premerger notification requirements under the Hart-Scott-Rodino Antitrust Act. The PRI believes the Commission should clarify that efforts to engage with public companies on ESG matters do not fall under premerger notification obligations under the Act. |
| EU | February |
Consultation or letter: 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. |
| EU | February |
Public consultation on the Proposal for an Initiative on Sustainable Corporate Governance |
The PRI supports the Commission’s aim to better align the interests of companies, their shareholders, managers, stakeholders and society. We recommend the Commission to provide clarity and consistency on director duties across the EU; undertake a rigorous legal and impact analysis to support any EU legislation on director duties; establish a legal duty for companies to undertake environmental and human rights due diligence; and all the while ensure consistency across proposed reforms within DG JUST and other EU directorates. |
| UK | February |
Financial Reporting Council | Future of Corporate Reporting |
The PRI welcomes the intent to strengthen accountability to stakeholders, and encourages the development of statutory non-financial reporting in the UK corporate reporting framework, though cautions against separating financial, ESG and sustainability reporting across multiple reports. |
| EU | January |
Public Consultation on the review of the Alternative Investment Fund Managers Directive (AIFMD) |
The PRI makes two overall recommendations. Firstly, the European Commission should avoid additional disclosure requirements in individual directives for different fund types, and instead focus on clarifying and harmonizing the SFDR and Taxonomy disclosure regulations. Secondly, the Commission should undertake legal and impact analysis to determine whether to introduce a specific mandatory requirement related to sustainability impact for AIFMs. Any impact-related regulation should have a consistent approach across investor types. |
| South Africa | January |
CRISA Code for Responsible Investment in South Africa Revision |
The PRI strongly support contents of the revised draft code, including but not limited to: an outcomes-based approach that encourages pursuit of positive outcomes across impact, inclusion, innovation and resilience, and an “apply and explain” disclosure standard that allows sufficient flexibility to be applied proportionately across different assets and types of organisations. PRI’s central recommendation is that the CRISA Committee should establish more robust oversight of the Code for greater effectiveness by formalising the process to become a signatory to the Code. |
| Hong Kong SAR | January |
Hong Kong SFC consultation on the management and disclosure of climate-related risks by fund managers |
The PRI welcomes the SFC’s proposal for mandatory climate-related reporting through amendments to the existing Fund Manager Code of Conduct (FMCC). The PRI recommends that SFC updates carbon foot printing methodology with the latest TCFD technical guidance and recommendation, and clarifies that asset managers should also collect and disclose financed (Scope 3) GHG emissions. The PRI also recommends that HKEX should tighten company disclosure rules to match the proposed revision to the FMCC on climate change. |
| Canada | January |
Strengthening Canadians' Retirement Security - Proposals to Support the Sustainability of and Strengthen the Framework for Federally Regulated Pension Plans |
It is the PRI's view that, to protect Canadian pension plan participants and beneficiaries, and increase transparency for all capital markets participants, the Department of Finance Canada and Canadian Securities Administrators should define ESG reporting requirements, and the Department of Finance Canada should clarify that fiduciary duties require ESG integration. The PRI would also encourage consistent regulation on these topics across federal and provincial governments. |
| UK | January |
Joint letters to UK Prime Minister and Transport Secretary on climate policy |
PRI and several UK asset owners have written to the UK government calling for continued climate ambition in advance of COP26, including progress on land use challenges, energy efficiency and smoothing the transition to zero-emissions vehicles. |
| EU | January |
EFRAG consultation on ad personam mandate on potential need for changes to the governance and funding of EFRAG |
The PRI recognises and supports the EU’s leadership role in developing standards for corporate reporting on sustainability performance, but recommends that these standards are not developed in isolation. Similarly, PRI recommends that the EU and EFRAG actively participate in international standard setting processes that focus on financial materiality and adopts those standards once developed. |
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