Notes (Cont'd)
Chapter 8 – ESG and Climate Change in the Shadow of COVID-19: “E,” “S” & G Are Here to Stay 159 For example, a March 2020 Bloomberg study, which found that discussions about climate change during first-quarter earnings calls by Standard & Poor’s 500 companies dropped 50% compared with the previous quarter. Olivia Raimonde and Hailey Waller, “CEOs Drop Climate Change Talk to Focus on Surviving Covid-19,” Bloomberg (July 1, 2020), online: https://www.bloomberg.com/news/articles/2020-07-01/ ceos-drop-climate-change-talk-to-focus-on-surviving- covid-19. 160 For example, the United Kingdom’s Financial Conduct Authority (FCA) issued a consultation paper in March 2020, proposing that all firms with a U.K. premium listing be obligated to include in their annual reports: (i) confirmation as to whether they had made TCFD-consistent disclosures; (ii) identification of instances where they had not adhered to the TCFD’s recommendations (along with an explanation for such departures from the framework); (iii) identification of climate disclosure made in documents other than their annual reports (along with the rationale for doing so); and (iv) identification of precisely where in the annual report, or any other document, the issuer’s climate disclosure may be found. In Canada, the consultation report issued in July 2020 by Ontario’s Capital Markets Modernization Taskforce recommended mandatory disclosure of material ESG information that is compliant with either the TCFD or the SASB frameworks. See Capital Markets Modernization Taskforce, supra note 153, at 27. 161 The TCFD reports that as of February 2020, over 1,027 public and private organizations, in multiple sectors and jurisdictions, have expressed support for the TCFD framework. See TCFD News Release, “More than 1,000 Global Organizations Declare Support for the Task Force on Climate-related Financial Disclosures and its Recommendations” (February 12, 2020), online: https://www. fsb-tcfd.org/wp-content/uploads/2020/02/PR-TCFD-1000- Supporters_FINAL.pdf. 162 Davies Governance Insights 2019 , online: https://www.dwpv. com/en/Insights/Publications/2019/Davies-Governance- Insights-2019, chapter 2. 163 A recent study by the Chartered Professional Accountants of Canada (CPA) analyzing the carbon disclosure made by leading Canadian public companies in their regulatory filings found that nearly all companies had made disclosures in at least one of the TCFD’s recommended categories, while only one company made disclosure in every recommended category and sub-category.
CPA, “Summary Report: Study of Climate-related Disclosures by Canadian Public Companies” (January 2020), online: https://www.cpacanada.ca/-/media/site/operational/rg- research-guidance-and-support/docs/02370-rg-study- climate-related-disclosures-summary-report-feb-2020. pdf?la=en&hash=A5AA7444524D2F7A1AF99FB378FE EEB114F63DA6, at 2. 164 Emerging disclosure frameworks are increasingly using the TCFD as their foundation. For example, on January 22, 2020, a task force sponsored by the International Business Council of the World Economic Forum released for stakeholder consultation a white paper titled “Toward Common Metrics and Consistent Reporting of Sustainable Value Creation,” which outlines a core set of material metrics and recommended disclosure already present in existing standards and frameworks: notably, those of the GRI (Global Reporting Initiative), SASB (Sustainability Accounting Standards Board), CDP (formerly the Carbon Disclosure Project) and TCFD. More details concerning the various Climate Disclosure frameworks are available in Davies Governance Insights 2019 , online: https://www.dwpv. com/en/Insights/Publications/2019/Davies-Governance- Insights-2019, chapter 2. 165 Global Reporting Initiative, “How to Report the TCFD Recommendations Using the GRI Standards” (September 30, 2019), online: https://www.globalreporting.org/ SiteCollectionDocuments/2019/CDPD/GRI%20TCFD%20 Webinar.pdf. 166 CDSB and CDP, “The Building Blocks: Connecting CDP Data with the CDSB Framework to Successfully Fulfil the TCFD Recommendations” (May 2020), online: https://www.cdsb. net/sites/default/files/the_building_blocks_guidance_web_ version.pdf. 167 Canada, “Prime Minister Announces Additional Support for Businesses to Help Save Canadian Jobs” (May 11, 2020), online: https://pm.gc.ca/en/news/news- releases/2020/05/11/prime-minister-announces-additional- support-businesses-help-save. 168 Ibid. On July 16, 2020, the Canadian federal government continued to advance action on climate change as a priority when it released its “Strategic Assessment of Climate Change,” intended to provide guidance to proponents of projects to which the federal Impact Assessment Act (IAA) applies regarding the greenhouse gas and climate change information required for assessments under the IAA. 169 IIGCC, “Consultation: Net Zero Investment Framework” (August 5, 2020), online: https://www.iigcc.org/resource/net- zero-investment-framework-for-consultation/.
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