Consultations & letters 2021
Consultations and letters
| Region | Month | Consultation or letter | PRI response |
|---|---|---|---|
|
Australia |
October |
The PRI responded to the Association of Superannuation Funds of Australia’s discussion paper on climate change. |
The PRI recommends that clearer regulatory guidance is needed to enable superannuation funds to mitigate systemic climate risks. The PRI encourages ASFA to guide superannuation funds on how to achieve net zero targets and, to that end, recommends ASFA support more effective stewardship practices. |
|
Japan |
September |
PRI Comments on METI’s consultation on the 6th Basic Energy Plan for Japan |
The PRI comments welcome 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 concrete policy actions needed to support Japan in successfully meeting its climate targets and transforming towards a net zero economy. |
|
Canada |
September |
PRI comments on the Government of Canada’s People-Centred Just Transition discussion paper |
PRI encourages 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. PRI recommends that Canadian just transition legislation:
|
|
China |
September |
PRI letter to Beijing Stock Exchange |
The newly launched Beijing Stock Exchange (BSE) intends to improve China's multi-layered capital market structure and channel more capital into innovation-oriented SMEs. The PRI sent a letter to welcome 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. |
|
EU |
September |
Investor Statement of Support for EU Corporate Sustainability Reporting Directive (CSRD) |
In this statement the PRI and its 54 undersigned signatories (representing approximately 9.2 trillion USD in AUM) welcome 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. The statement sets out six key aspects of the CSRD proposal which co-legislators should take into consideration to align the CSRD with the EU sustainable finance strategy and enable investors to actively contribute to the EU’s high ambition for a green recovery and emission reduction targets of at least 55% by 2030 and carbon neutrality by 2050. |
|
UK |
September |
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 commend the FCA for issuing this consultation. In our response, we outline our recommendation that the FCA maintain the one-share, one-vote requirement in the UK premium listing segment rather than introducing dual class shares structures or otherwise, at minimum, adopt sunset provisions. We also recommend the FCA maintained the free float at 25% for the UK premium listing segment. |
|
EU |
September |
PRI consultation response on EFRAG’s proposed Due Process Procedures. |
PRI response: The PRI welcomes the proposed processed and makes two main recommendations, suggesting to maximise user and preparer input and to engage and contribute global sustainability reporting initiatives. |
|
Australia |
September |
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 recommends 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. |
|
UK |
September |
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 outlines 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. We also commend the FCA for their proposals that closely follow guidance laid out by the TFCD. The PRI make a number of recommendations, such as which metrics should be considered “core” or “additional” and that alongside metric disclosures, issuers should disclose estimates of the underlying data quality. We also recommend that the FCA explore opportunities for firms with less than £5 billion in AUM to report on climate related disclosures line with TCFD recommendations at a future date. |
|
US |
September |
PRI Letter to Congressional Leaders calling for bold climate funding in budget legislation |
The PRI sent letters to House and Senate leaders calling for any budget legislation to fully fund efforts to limit carbon emissions. Letters were sent to Democrat and Republican leaders of the House and Senate, the Senate Committees on Budget, Banking, Finance, Energy and Natural Resources, Environment and Public Works and House Committees on Budget, Ways & Means, Financial Services, Energy and Commerce and Natural Resources. |
|
EU |
September |
IOSCO Consultation on ESG Ratings and Data Product Providers |
The PRI welcomes increased attention by regulators 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. |
|
Germany |
September |
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:
|
|
Global |
August |
IOSCO Consultation on Sustainability-Related Practices, Policies, Procedures and Disclosures in Asset Management. |
The PRI welcomes IOSCO’s timely and important work on promoting sustainability-related disclosures rules for asset managers. Our key recommendations are:
|
|
Australia |
July |
The PRI respond to APRA prudential practice guide on climate change financial risks |
PRI recommends 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. |
|
Global |
July |
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 Principles for Responsible Investment welcomes the TCFD’s new consultation. Metrics and targets are integral to decision-useful climate-related reporting. The proposed new guidance on climate-related metrics, targets, and transition plans represents a timely contribution from the TCFD and are a significant step forward in the Taskforce’s guidance to preparers. |
|
UK |
July |
The PRI respond to a consultation from BEIS on restoring trust in audit and corporate governance |
The PRI welcomes the opportunity to respond to this consultation. The PRI outlines support for several recommendations made by BEIS, including those around strengthening malus and clawback conditions on directors’ remuneration arrangements and providing clarity on existing requirements for auditors. The PRI also outline a number of recommendations, such as suggesting that the regulator provide clarity on the content and structure of the Audit and Assurance Policy. |
|
South Africa |
July |
Call for Stakeholder Inputs, Draft National Green Finance Taxonomy |
The PRI welcomes the draft Green Finance Taxonomy (GFT), its alignment with the EU Taxonomy and the detail it provides to help investors understand key concepts and undertake taxonomy disclosures. The PRI’s key recommendations are maintain consistency with the EU Taxonomy and more importantly scientific evidence; clarify the ambition of the GFT and consider a mandatory framework in the future; increase usability of the draft GFT by clarifying the seven-step process, the climate adaptation and vulnerability assessments and the methodology for taxonomy alignment disclosures; 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. |
|
EU |
July |
PRI statement on the EU’s Strategy for Financing the Transition to a Sustainable Economy. |
On 6 July, the European Commission published the EU’s Strategy for Financing the Transition to a Sustainable Economy. The PRI welcomes this new ambitious strategy, which further strengthens the EU’s sustainable finance policy framework and sets a clear policy agenda for 2021-2024. |
|
US |
June |
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. |
|
US |
June |
PRI’s comment on the Detailed Guidance for New York Domestic Insurers on Managing the Financial Risks from Climate Change |
The Principles for Responsible Investment (PRI) welcomes the New York State Department of Financial Services (DFS) Proposed Guidance for Domestic Insurers on the Financial Risks from Climate Change. However, the PRI recommends the Department strengthen the reporting requirements’ alignment with the Task Force on Climate-Related Financial Disclosures (TCFD) framework. |
|
UK |
June |
PRI respond to a call for evidence issued by the Committee for Work and Pensions on pensions stewardship and COP26 |
The PRI welcomes the opportunity to respond to this call for evidence. The PRI provide evidence to support their recommendation that pension schemes should participate in the ‘Race to Zero’ campaign and collaborative investor-company engagements. Further to this, the PRI recommend that pension schemes that have made an emission reduction commitment should set near term targets and report on progress. The PRI also highlight the importance of a consistent TCFD-aligned framework across the investment chain. |
|
US |
June |
Letter in Support of H.R. 1187 Corporate Governance and Investor Protection Act |
The PRI expresses strong support for the ESG Disclosure Package in the form of the H.R. 1187 Corporate Governance and Investor Protection Act. H.R. 1187 includes the ESG Disclosure Simplification Act, the Climate Risk Disclosure Act and bills that would require compensation, tax, and political spending disclosure, which are increasingly relevant to investor decision making. |
|
UK |
June |
PRI respond to a call for evidence issued by DWP on consideration of social risks and opportunities by occupational pension schemes |
The PRI welcomes the leadership shown by DWP in issuing this call for evidence and raising awareness of trustees’ attention to social factors. The PRI provide evidence to support their recommendation 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. Further to this, the PRI recommend that DWP engage with trustees to understand how they consider beneficiaries’ future quality of life and social impacts of investments. |
|
EU |
June |
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). |
|
Australia |
June |
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. |
|
US |
June |
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, helping us to fulfill our fiduciary obligation to fully consider material information and make informed investment decisions for long-term value creation. |
|
US |
June |
PRI Response to SEC Request for Comment on Climate Change Disclosures |
The PRI's comment on the SEC's Request for Comment on Climate Change Disclosures. The PRI welcomes the leadership shown by the US SEC in its renewed focus on climate and ESG issues and in bringing forward this consultation on climate disclosure. |
|
China |
June |
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. |
|
EU |
June |
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:
|
|
EU |
May |
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. |
|
EU |
May |
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. |
|
Australia |
May |
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. |
|
EU |
May |
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 |
|
Japan |
May |
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. |
|
Japan |
May |
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. |
|
UK |
May |
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. |
|
|
US |
April |
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. |
|
China |
April |
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. |
|
US |
April |
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. |
|
Japan |
April |
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 |
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. |
|
EU |
April |
PRI supports the publication of final taxonomy delegated act |
The PRI welcomes this publication as a significant step forward for capital markets. As the world’s leading proponent of responsible investment, the PRI advocates for global sustainable financial systems, supported by Taxonomies of sustainable economic activities defined by common, science-based, technology neutral technical screening criteria. Investors need a credible Taxonomy to make informed, long-term investment decisions aligned with the Paris Agreement goals. |
|
Global |
April |
PRI Statement on corporate sustainability disclosures |
The PRI welcomes the proposal for a new EU Corporate Sustainability Reporting Directive as the most recent milestone in a series of encouraging developments on corporate sustainability reporting, including the IFRS Foundation’s proposal to establish a Sustainability Standard Board (SSB) and the initiatives led by the US SEC. |
| US | March |
PRI comment on Nasdaq Proposed Rule Change to Adopt Listing Rules Related to Board Diversity |
The PRI submitted a comment to the SEC in response to a proposed rule to require US Nasdaq listed companies to disclose board diversity data and to have at least two diverse board members. The PRI supports the proposed rule change and believes that it is a meaningful first step forward in long-overdue changes in the U.S. financial industry and society broadly. |
| Singapore | March |
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. |
|
| EU | March |
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. |
|
| UK | March |
Department for Work and Pensions | Taking action on climate risk: improving governance and reporting by occupational pension schemes - response and consultation on regulations |
The PRI welcomes the leadership shown by DWP in raising awareness of climate-related risks, and supports a number of the revisions made in light of industry feedback on the August 2020 consultation. As climate metrics evolve, PRI supports the inclusion of updated guidance on these metrics as a high priority for the interim 2023 review. |
| China | March |
CSRC consultation on the Guidelines on Investor Relations Management of Listed Companies |
The PRI welcomes the inclusion of ESG information in the Guidelines. The PRI recommends that the CSRC should publish a comprehensive, standardised and mandatory ESG reporting framework to provide further reporting guidance for listed companies. |
| 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 |
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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