Consultation responses
| Region | Month | Consultation | PRI 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. |
Briefings and letters
| Region | Month | Briefings and letters | |
|---|---|---|---|
| US | November 2017 | Letter FAO: House Committee on Financial Services | HR 4015 - Corporate governance reform and transparency act 2017 | The PRI has serious concerns that H.R.4015 would significantly weaken the role institutional investors play in the corporate governance of U.S. companies. See full letter. |
| Canada | July 2017 | Government of Alberta | Business corporations act | The PRI has strong concerns with the current shareholder proposal filing rules in Alberta. We recommend for the Government of Alberta to amend the Regulations under the ABCA to establish a shareholder proposal filing threshold that is substantively the same as that set out in the federal Canada Business Corporations Act and associated Regulations. See full response. |
| US | April 2017 | Letter FAO: House Committee on Financial Services | Rule 14a8 - financial choice act | The PRI has strong concerns that multiple aspects of the Financial Choice Act would significantly weaken the role institutional investors play in the corporate governance of US companies, jeopardise long-term value-creation. In particular, we strongly recommend opposing any attempt to modify or limit the Securities and Exchange Commission’s shareholder proposal rule, SEC Rule 14a-8. See full letter. |
| EU | February 2017 | Breifing: Revised shareholder rights directive | requirements for institutional investors, asset manager, proxy advisors and companies | The revised Shareholder Rights Directive (2007/36/EC) recognises that shareholders often exert short-term pressure on investee companies, at the expense of longer term value creation and ESG issues. The Directive seeks to mitigate this by addressing some principal agent problems in the investment chain. See full briefing. |
