PRI policy consultation responses, briefings and letters 2016

Consultation responses

Region	Month	Consultation	PRI 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	IoDSA \| 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.

Briefings and letters

Region	Month	Briefings and letters
US	November 2016	Breifing: addressing ESG factors under ERISA	The PRI is pleased to present two legal perspectives on integrating ESG issues into investment decision-making under the ERISA guidelines. See full briefing.
G20	September 2016	Briefing: Greening institutional investment \| G20 GFSG input paper	This paper takes stock of institutional investor experience with mobilising green capital for green investment and mainstreaming green factors across asset classes. It identifies key drivers for action and barriers preventing progress for input to the G20 Green Finance Study Group (GFSG). See full briefing.
US	September 2016	Letter FAO: House Committee on Financial Services \| H.R. 5311	Under Rule 14a-2(b)(3) of the Exchange Act, proxy advisory firms are already required to disclose any significant relationship with a soliciting company or shareowner proponent or material interest in a matter that is the subject of a voting recommendation. The PRI believes this requirement already provides transparency for investors and companies. Therefore the additional provisions of H.R. 5311 are not necessary. See full letter.