Please find above our submission to the SEC in response to its request for comment on its proposed rule: 'The Enhancement and Standardisation of Climate-Related Disclosures for Investors.'
In the submission we show our support for the proposed rules and make three specific recommendations:
1. Require companies to split both their revenue and their CAPEX figures into ‘green’ and ‘brown’.
2. Make Scope 3 emissions reporting mandatory and provide companies with a ratcheting timeframe by which this reporting becomes mandatory.
3. Propose that companies publish data on the Potential Avoided Emissions (PAE) of their products.