Consultations & letters 2020

Consultations and letters

Region Month Consultation or letter PRI response
Canada September

Ontario Capital Markets Modernization Taskforce: Consultation Report July 2020

The PRI supportive of the Taskforce’s efforts to improve disclosure on material ESG information, executive compensation, corporate board diversity and increase transparency for investors on conflicts of interest for proxy advisory firms. However, we have some concerns regarding the Taskforce's recommendations on the issuer's role in the shareholder proposal process.


See full response

US September

Letter to the SEC on the Improper Exclusion of Evidence on the Impact of the Proposed Amendments to Rule 14a-8 on Retail Investors

The PRI and investor organizations submitted a letter to the SEC regarding the exclusion of evidence on the impact of the proposed amendments to Rule 14a-8 (Shareholder Proposal Rule), and requested the Commission re-open the comment period to provide the public an opportunity to address the data.


See full response and Commission's analysis of data

US September

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

Request for extension of comment deadline


See full request

Israel September

Consultation on corporate responsibility and ESG risk disclosures

The PRI recommends that the Israel Securities Authority (ISA) develops a standardised, mandatory ESG disclosure framework for listed companies. In addition, the PRI recommends that ISA engages in global efforts to standardise ESG disclosure regulations across countries.


See full response

EU September

European Supervisory Authorities: Joint Consultation Paper on ESG Disclosures

The PRI strongly supports the aims and objectives of this Regulation, to help end-investors understand the sustainability impact of products and encourage investor management of adverse impacts. However, we have some concerns regarding the design of the RTS.


See full response in ESA template and standalone pdf

UK August

BEIS Select Committee| Post-pandemic economic growth

The PRI recommends that the UK develop a more comprehensive and long-term approach to a green recovery, prioritising certain sectors, ensuring consistency with a just transition, and leveraging private finance.


See full response

China August

Consultation on the CSRC Listed Companies Information Disclosure regulation

The PRI recommends that the regulation includes a requirement to disclose material ESG information, including discussion of strategy, governance and risk management of material ESG issues that may affect the company’s performance, as part of the mandatory issuer disclosures.


See full response in English and in Chinese

China August

Green Bonds catalogue consultation

The PRI welcomes the consolidation of the existing green bond standards in China into one comprehensive national standard. The PRI also welcomes the clarification that ‘clean coal’ assets do not qualify as green. The PRI recommends to develop technical screening criteria to assess alignment with the Paris Agreement, and whether projects classified as green avoid significant harm to other environmental and social objectives.


See full response in English and in Chinese

Singapore August

Environmental Risk Management Guidelines consultation

The PRI welcomes the publication of the guidelines and recommends to include in their scope broader systemic and sustainability risks that may affect investment portfolios. The PRI also recommends that MAS incorporates the environmental risk management guidelines within relevant existing financial regulations, in alignment with the TCFD framework.


See full response

UK July

Department for Transport | Ending new sales of petrol, diesel and hybrid cars

The PRI supports bringing the proposed sales ban date forward to 2032 and implementing a package of policy measures which will accelerate the growth in sustainable vehicle sales in the UK while reducing the number of vehicles on UK roads overall.


See full response

US July

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

The PRI's comment on the DOL's Rule Proposal. The PRI is concerned that, if finalized, the Proposal will create confusion among ERISA fiduciaries and asset managers, chill fiduciaries’ efforts to integrate material ESG factors into their investment practices and could be costly for retirement savers and investment managers. We therefore respectfully request that the DOL withdraw the Proposal.


See comment

EU July

Proposed Amendments to Solvency II Delegated Regulation, Proposed Amendments to MiFID Delegated Directive, Proposed Amendment to MiFID Delegated Regulation, Proposed Amendments to UCITS Commission Directive and Proposed Amendments to IDD Delegated Regulations

The PRI strongly supports action by EU institutions to clarify the relationship between investor duties and sustainability, and the Commission’s aim to increase dialogue between financial institutions and their institutional and retail clients around the sustainability preferences clients may hold. Failure to consider sustainability in investment practice, or to respond to the sustainability preferences of clients or beneficiaries, is a failure of investor’s duties.


See full response

EU July

Renewed Sustainable Finance Strategy

To support the success of this strategy, the PRI makes four overarching recommendations, with further detailed commentary.


See full response

US June

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

Request for extension of comment deadline


See full response

UK June

Labour Party | Green Recovery Consultation

The PRI sets out four key areas for an inclusive green recovery in the UK, focusing on areas with a high economic multiplier – transport, land use, energy efficiency and power.


See full response

EU June

2030 Climate Target Plan

The PRI welcomes the opportunity to submit a consultation response on the EU climate ambition for 2030 and for the design of certain climate and energy policies of the European Green Deal. The PRI recommends to increase the EU’s 2030 target to reduce greenhouse gas domestically to at least 55% and suggests to focus action on priority sectors and policy areas pointed out in the response.


See full response

EU June

Consultation on the review of the non-financial reporting directive (NFRD)

The PRI welcomes the opportunity to submit a consultation response under the review of the Non-Financial Reporting Directive and makes recommendations how the NFRD and the EU non-financial reporting standards can increase the availability of high quality, relevant and comparable data.


See full response

US May

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

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


Remarks by Heather Slavkin Corzo

China May

Energy Law Consultation

The PRI welcomes the inclusion in the new law of the topics of climate change and low-carbon transition. Setting up a comprehensive policy framework for the energy sector is an important step for China in managing a sustainable energy transition aligned with the Paris agreement.


See full response in English and Chinese

US May

SEC Request for Comments on Fund Names

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


See full response

EU May

Interim Report of the Sustainable Finance Committee of the German federal government

The PRI welcomes the opportunity to submit comments on the Interim Report: “The Significance Of Sustainable Finance To The Great Transformation”. The interim report suggests that policy making should align with sustainability goals such as the Paris Climate Agreement and the Sustainable Developments Goals (SDGs). The PRI strongly supports this approach. The PRI recommends that the sustainable finance committee provide further clarity on the processes necessary to achieve alignment.


See full response

US April

SEC Proposed Rule: Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information

The PRI's comment on the SEC's Proposed Rule: Management’s Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information in Regulation S-K. The PRI is concerned about two issues in particular with the Proposed Rule: First, its failure to quantify the costs and benefits of the proposed new principles-based disclosures in the MD&A of issuers’ annual filings, and second, its failure to require any new climate-risk disclosures in the Proposed Rule.


See full response

UK April

Environmental Audit Committee | Possible Future Inquiries

The PRI responded to a call for evidence on potential future focus areas for the EAC over the upcoming year. The PRI recommended focusing in particular on:

  • The sustainability of the pension system, in particular contract-based pension schemes and master trusts
  • Holding government accountable for meeting afforestation targets
  • Ensuring a smooth transition from traditional vehicles to electric vehicles over the next decade

See full response

OECD March

OECD | BEPS Action 13 public consultation (2020 review)

Working together in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), over 135 countries are implementing 15 Actions to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.

In response to the OECD consultation on BEPS Action 13, the PRI commends OECD’s coordinated efforts in tackling tax avoidance through the BEPS initiative and recommends that the requirements for country-by-country reporting be extended to public disclosure.


See full response

OECD February

Business responsibilities and investment treaties

The PRI provides comments to the chapter 5, “Investor, business, trade union and civil society action”, specifically on the topic of “sustainable or ‘environmental, social and governance’ (ESG) investing”.


See full response

US

February

SEC Sign-On Letter

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


SEC Sign-On Letter

US

February

SEC Shareholder Proposal Rule

The PRI's comment on the SEC's Proposed Rule on Rule 14a-8. The PRI believes that the rule would significantly impede the accountability of management to their shareholders. (Shareholder Proposal Rule).


See full response

US

February

SEC Proxy Voting Advice

The PRI's comment on the SEC's Proposed Rule on Proxy Voting Advice. The PRI has serious concerns that the Proposed Rule would significantly weaken the role institutional investors play in corporate governance.


See full response

Japan January

Financial Services Agency| Stewardship Code consultation

The PRI welcomes the introduction of sustainability into the stewardship responsibilities of Code signatories. The PRI’s key recommendations include:


  • Sustainability should be defined as including externalities and impacts generated by company activities.
  • Provisions on proxy advisors should avoid introducing delays into the compressed proxy advice process.
  • The FSA should clarify rules around acting in concert and collaborative engagement on ESG issues.

See full response

Chile January

General Rule 386 – environmental and social disclosures consultation by CMF

The PRI welcomes the proposed update of General Rule 386 by CMF. The update introduces mandatory disclosures on key environmental and social issues which will contribute to building standardised and comparable ESG data for investors in the Chilean market.


Full response here