Consultations & letters 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.

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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.

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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.

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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.

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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

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.

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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.

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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

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.

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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.

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

Request for extension of comment deadline

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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.

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

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

Remarks by Heather Slavkin Corzo

SEC Request for Comments on Fund Names

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

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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.

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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.

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US

February

SEC Sign-On Letter

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

SEC Sign-On Letter

US

February

SEC 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.

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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