Click here to access the submission

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.'

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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.