170 Canada, “Final Report of the Expert Panel on Sustainable Finance: Mobilizing Finance for Sustainable Growth” (June 14, 2019), online: https://www.canada.ca/en/environment- climate-change/services/climate-change/expert-panel- sustainable-finance.html. 171 Ibid . 172 On May 19, 2020, the Bank of Canada also released a staff discussion paper titled “Scenario Analysis and the Economic and Financial Risks from Climate Change,” providing further confirmation that climate-related risks are being carefully considered by the Bank of Canada. The discussion paper is available online: https://www.bankofcanada.ca/wp-content/ uploads/2020/05/SDP-2020-3.pdf. 173 Transition risk assessments and alternatives analyses are required for projects with total annual emissions of at least 100,000 tonnes of carbon dioxide equivalent. 174 Canadian EPFI’s include Bank of Montreal, Bank of Nova Scotia, Canadian Imperial Bank of Commerce, Export Development Canada, Manulife, Royal Bank of Canada and TD Bank Financial Group. Equator Principles, “The Equator Principles: Guidance on Implementation of the Equator Principles During the Covid-19 Pandemic” (June 2020), online: https://equator-principles.com/wp- content/uploads/2020/06/Guidance_on_the_imlementation_ of_the_EP_during_the_covid19_pandemic.pdf. 175 The value of disclosure to BlackRock’s decision-making process was made explicit through BlackRock’s commitment to use proxy voting to hold accountable those companies that are not adequately disclosing and managing sustainability- related risks. BlackRock’s co-founder and CEO Larry Fink went so far as to describe climate change as the “defining factor” in a company’s long-term prospects, and pushed companies to make climate disclosure in line with TCFD and SASB guidelines, warning that BlackRock would vote against management and board directors who fail to discharge this obligation. 176 BlackRock, Inc., “Our Approach to Sustainability” (July 2020), online: https://www.blackrock.com/corporate/literature/ publication/our-commitment-to-sustainability-exec-summary- en.pdf. 177 State Street Global Advisors, “CEO’s Letter on our 2020 Proxy Voting Agenda” (January 28, 2020), online: https:// www.ssga.com/library-content/pdfs/insights/CEOs-letter-on- SSGA-2020-proxy-voting-agenda.pdf. 178 OMERS, “Proxy Voting Guidelines” (April 1, 2020), online: https://assets.ctfassets.net/ iifcbkds7nke/76hZIwR6HOvjFxMWpODjgC/ eab3221c3068048e8b6efd1902b1b91d/OMERS-Proxy- Voting-Guidelines-April-2020-FINAL.pdf, at 28-29.
179 CPP Investment Board, “Proxy Voting Principles and Guidelines” (February 13, 2020), online: https://www. cppinvestments.com/the-fund/sustainable-investing/proxy- voting. 180 Alberta Investment Management Corporation, “Proxy Voting
Guidelines & Corporate Governance Principles” (January 2020), online: https://assets.ctfassets.net/
lyt4cjmefjno/1Xc2BDu3jejmzIBKVjXh82/316ecc27d1ae98a 25343d88d3e2e19d9/AIMCo_-_Proxy_Voting_Guidelines_-_ January_2020.pdf, at 14-15. 181 Ontario Teachers’ Pension Plan, “2020 Corporate Governance Principles and Proxy Voting Guidelines,” online: https://www.otpp.com/documents/10179/20940/-/ bf03be90-a413-433f-bc4a-24a266ae17bb/2020%20 Corporate%20Governance%20Principles%20and%20 Proxy%20Voting%20Guidelines.pdf. 182 Ibid , at 50. 183 CDP, “CDP Temperature Ratings,” online: https://www.cdp.net/ en/investor/temperature-ratings. 184 Ibid . 185 Patrick Bolton and Marcin T. Kacperczyk, “Carbon Premium Around the World” (March 13, 2020), online: https://dx.doi. org/10.2139/ssrn.3550233. 186 But not in Africa, Australia or South America. 187 Supra note 185. Conversely, Bolton and Kacperczyk reported that institutional investors’ divestment policies are focused primarily on a company’s emission intensity levels, suggesting that such policies are failing to minimize exposure to climate change risk, and are instead simply filtering companies by the efficiency of their fossil fuel use. This disconnect between the climate disclosure metrics that correlate to the carbon premium and those on which divestment decisions are based highlights the need for companies to increase efforts to educate the public on the significance of each element of climate disclosure. 188 HESTA, “HESTA Announces Net Zero by 2050 Aim as Part of Ambitious Climate Change Plan” (June 26, 2020), online: https://www.hesta.com.au/about-us/media-centre/HESTA- announces-net-zero-by-2050-aim-climate-change-plan.html. 189 Norges Bank Investment Management, “Exclusion Decisions and Decisions to Revoke Exclusion” (May 13, 2020), online: https://www.nbim.no/en/the-fund/news-list/2020/exclusion- decisions-and-decisions-to-revoke-exclusion/.
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Governance Insights 2020
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