Consultations and letters
| Region | Date | Consultation or letter | PRI 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. |
|
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. |
|
EU |
January 2022 |
Multi-stakeholder statement on CSRD reform and EU standards |
Civil society, investors and asset managers have published a multi-stakeholder statement “Why we need to get improved corporate sustainability data by 2024” calling policy-makers for swift agreement on the EU Corporate Sustainability Reporting Directive and supporting accompanying EU standards. The statement 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. |
|
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). |
|
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. |
|
China |
January 2022 |
China consultation on regulations of insurance asset management companies |
The PRI welcomes the amendments which attach great significance to corporate governance and risk management 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. |
|
UK |
December 2021 |
A letter to BEIS Secretary of State in opposition to proceed with the Cambo oil field |
I write to 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. To support the development of a new oil field is inconsistent with the UK’s commitment to the Paris Agreement, the UK 6th Carbon Budget, the UK’s credibility as the COP26 Presidency and the world’s commitment to limit warming to below 1.5°C to avoid the worst effects of climate change. |
|
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 writes in support of the proposed rule “Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers” (Proposed Rule) to enhance the availability and utility of information on proxy voting, including on executive compensation. |
|
US |
December 2021 |
PRI Response to Department of Labor Proposed Rule Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights |
The PRI strongly supports 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. |
|
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. Adding those sectors to the list of sustainable economic activities under the EU taxonomy would undermine its scientific integrity, the consistency and credibility of the EU’s broader sustainable finance regulatory framework, and the trust of market participants as key contributors to implementing the EU’s climate policy and sustainability goals. |
|
China |
October 2021 |
MEE consultation on enterprise environmental disclosure |
The Administrative Measures and Format Guidelines under consultation are meant to unify domestic environmental disclosure standards and requirements, strengthen the support of pollution control, as well as carbon peaking and carbon neutrality goals, and empower cross-ministry collaboration and information sharing. The PRI recommends 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. |
|
Australia |
October 2021 |
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. |
|
Global |
September 2021 |
The PRI respond to the Financial Accounting Standards Board (FASB) on their draft future standard-setting agenda. |
The PRI welcomes 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. The PRI’s key recommendations are:
|
|
Japan |
September 2021 |
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 2021 |
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 2021 |
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 2021 |
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 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 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 2021 |
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 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 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 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 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 2021 |
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 2021 |
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 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:
|
|
Global |
August 2021 |
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:
|
|
Canada |
July 2021 |
PRI support for Bill S-216, Act to enact the Modern Slavery Act and to amend the Customs Tariff |
The Principles for Responsible Investment (PRI) welcomes the Bill S-216, Act to enact the Modern Slavery Act and to amend the Customs Tariff and the current study of the bill by the Standing Senate Committee on Banking, Trade and Commerce. In order to align the act with international standards and emerging regulation in other jurisdictions, the PRI recommends four alterations to the bill that are crucial for institutional investors to avoid subjecting them and their portfolio companies to deviating national standards. |
|
Australia |
July 2021 |
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 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 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 2021 |
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 2021 |
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 2021 |
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 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. |
|
US |
June 2021 |
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 2021 |
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 2021 |
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 2021 |
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 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). |
|
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. |
|
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, helping us to fulfill our fiduciary obligation to fully consider material information and make informed investment decisions for long-term value creation. |
|
US |
June 2021 |
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 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. |
|
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:
|
|
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. |
|
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. |
|
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. |
|
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 |
|
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. |
|
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. |
|
UK |
May 2021 |
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 |
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 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. |
|
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. |
|
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. |
|
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. |
|
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. |
| 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. |
| Singapore | March 2021 |
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 2021 |
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 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
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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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| US | September 2020 |
Department of Labor Rule Proposal, "Fiduciary Duties Regarding Proxy Voting and Shareholder Rights" |
Request for extension of comment deadline |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| 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. |
| EU | July 2020 |
To support the success of this strategy, the PRI makes four overarching recommendations, with further detailed commentary. |
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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. |
| US | June 2020 |
Department of Labor Rule Proposal, ““Financial Factors in Selecting Plan Investments” |
Request for extension of comment deadline |
| 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. |
| EU | June 2020 |
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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| 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. |
| 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. |
| 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. |
| US | May 2020 |
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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| 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. |
| US | April 2020 |
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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| 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:
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| 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. |
| OECD | February 2020 |
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”. |
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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. |
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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). |
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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. |
| 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:
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| 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. |
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. |
| 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. |
| 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. |
| 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. |
| 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:
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| 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:
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| 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:
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| 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:
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| 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:
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| 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. |
| 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. |
| 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. |
| 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. |
| 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.
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| 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:
Proxy advisors and investors work together to address market actors’ concerns and strengthen their contribution to an effective stewardship culture. |
| 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. |
| 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. |
| 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:
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| 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. |
| 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. |
| 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. |
| 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.
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| 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. |
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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. |
|
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:
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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:
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|
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. |
|
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:
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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.
See full response . |
| 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.
See full response. |
| 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.
See full response. |
| 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. See full response. |
| 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
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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. See full response. |
| 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.
See full response . |
| 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.
See full response. |
| 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.
See full response. |
| 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. See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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…
See full repsonse. |
| 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.
See full response. |
| 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).
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| UN | September 2016 | UNFCCC | Roadmap for global climate action |
The PRI Executive welcomes the opportunity to submit its views to this consultation.
See full response. |
| Brazil | July 2016 | AMEC | Stewardship Code |
PRI welcomes the development of the Stewardship Code which covers
both stewardship and ESG incorporation practices. See full response. |
| South Africa | July 2016 | IoD SA | King Code IV: retirement sector supplement |
Regarding the retirement sector supplement, we have three key recommendations.
See full response. |
| 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.
See full reponse. |
| 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. See full response. |
| 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… See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
| 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.
See full response. |
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