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Public policy consultations

Considering Social Factors in Pension Scheme Investments: Guide from the Taskforce on Social Factors

OUR RESPONSE

Cardano welcomes the work undertaken by the Taskforce on Social Factors committee and welcomes the consultation and guide.

Our approach to social factors encompasses the following:

  • Integrating Social Issues
  • Social Foundations as a Guiding Framework
  • Stewardship
  • Impact Investments and Social Bonds
  • Collaboration

Transition Plan Taskforce Disclosure Framework and Implementation Guidance

OUR RESPONSE

We provided our feedback to the consultation on the Transition Plan Taskforce Disclosure Framework and Implementation Guidance. This sector-neutral framework provides recommendations for developing gold-standard transition plans. Our comments are intended to ensure that the framework and guidance can be effectively implemented by UK companies while being investable for a range of institutional investors, therefore allowing for sufficient capital flows to support the UK’s decarbonisation objectives.

Sustainability Disclosure Requirements (SDR) and investment labels

OUR RESPONSE

We believe that the FCA’s proposed way forward for SDRs is elegant and well done. Conceptually, we are in agreement with the FCA’s approach. Our comments are intended to ensure the framework is investable for a range of institutional investors and therefore to allow for sufficient capital flows to support sustainability goals.

Local Government Pension Scheme (England and Wales): Governance and reporting of climate change risks

OUR RESPONSE

We have recently provided a response to the consultation on Local Government Pension Scheme (England and Wales): Governance and reporting of climate change risks.

 

As a sustainability advisor to LGPS and private pension schemes, we hope that our recommendations and observations in the attached are helpful.

International Sustainability Standards Board (ISSB) Consultation

OUR RESPONSE

We provide our initial reflections on the ISSB general-requirements exposure draft and climate-related exposure draft. Our primary suggestion to the ISSB is that the drafts need to address real-world impact (or “double materiality”), not the current sole focus on enterprise value.

The Enhancement and Standardization of Climate-Related Disclosures for Investors

Our response

We have recently written to SEC to commend the Commission for its Proposed Rule aimed at providing investors with climate change-related financial information from issuers of public securities.

The Commission’s Proposed Rule would represent a step-change in the quality and comparability of climate change-related disclosures.

Taskforce for Nature-related Financial Disclosures

Our response

In April 2022, following the V0.1 beta release of the Taskforce for Nature-related Financial Disclosures framework, we have written to the co-chairs to provide feedback and support for further iterations of the framework.

Sustainability Disclosure Requirements (SDR) and Investment Labels

In January 2022, Cardano responded to the FCA discussion paper: DP21/4 Sustainability Disclosure Requirements (SDR) and investment labels.

Setting expectations and empowering savers – consultation on policy, regulations and guidance

In December 2021, Cardano responded to the DWP consultation: Climate and investment reporting, the introduction of alignment metrics and stewardship-related disclosure.

Enhancing climate-related disclosures

In September 2021, Cardano responded to the FCA TCFD consultation: CP21/17 Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers.

EC Platform on Sustainable Finance – Social Taxonomy call for feedback

Cardano responded to the Platform’s call for feedback in September 2021. We welcome the proposed EU Social Taxonomy. The paper sets out a framework for determining an approach to ‘substantial contribution’ to social issues. This is an important step forward.

Proposed Guidance on Climate-related Metrics, Targets, and Transition Plans

Cardano  responded to the TCFD’s online questionnaire. In this document, we summarise our response posted on June 2021.

Consideration of social risks and opportunities by occupational pension schemes

In this document Cardano Risk Management Limited respond to the consultation on “Consideration of social risks and opportunities by occupational pension schemes” as published by the Department for Work and Pensions in March 2021.

  • Acting Chair Commissioner Lee: Consultation on Climate Change Disclosures

    Cardano Risk Management Limited response to Acting U.S. Securities and Exchange Commission Chair Commissioner Lee’s Consultation on Climate Change Disclosures posted on March 15, 2021.

  • Taking action on climate risk: improving governance and reporting – further recommendations

    This supports our initial response to the consultation with further recommendations to the Department for Work and Pensions’ consultation on “Taking action on climate risk: improving governance and reporting by occupational pension schemes” as published in January 2021.

  • Taking action on climate risk: improving governance and reporting

    We welcome the regulations which although ambitious are necessary. Read our full response to the consultation on “Taking action on climate risk: improving governance and reporting by occupational pension schemes” as published by the Department for Work and Pensions on 26 August 2020.