Investor Listing Standards Proposal
Ceres launched the INCR Listing Standards Drafting Committee in 2012 to develop a consultation paper that would seek investor comments on potential listing requirements on sustainability reporting. The resulting feedback from more than 100 investors around the world helped shape the Investor Listing Standards Proposal: Recommendations for Stock Exchange Requirements on Corporate Sustainability Reporting, which was submitted to NASDAQ OMX in 2013 for an initial review. The proposal provides recommendations for integrating sustainability disclosure requirements into guidance and listing rules for U.S. and global stock exchanges. The proposed standards pinpoint sustainability information essential to the investment process and provide companies flexibility while giving investors a more consistent presentation of data across markets, which is a key issue for evaluating sustainability risks and opportunities in investment decision-making.
The proposal highlights three priorities for a listing rule on sustainability disclosure:
1 A materiality assessment in a company’s annual report, where management will discuss its approach to determining the company’s material ESG issues, and the issues coming out of that assessment;
2 ESG disclosure, on a “comply or explain” basis, on 10 key ESG topics in the format and location of the company’s choosing;
3 A hyperlink in the annual report to an ESG Disclosure Index (table), based on the Global Reporting Initiative (GRI) Content Index or its Equivalent, indicating where existing ESG information can be found.
The Investor Listing Standards Proposal was submitted to the World Federation of Exchanges (WFE) and its 60+ exchange members in March 2014; Ceres collected feedback from exchanges and presented it to the WFE’s Sustainability Working Group leadership for its consideration in producing ESG reporting guidance. More information on the WFE is available here.
If leading exchanges in key markets, such as the US, Canada, and the UK, were to implement ESG disclosure requirements, Ceres believes other exchanges would follow their lead. With this idea in mind, along with the support of our investor members, we’ll continue to push for mandatory listing rules on ESG disclosure for all publicly listed companies. To help achieve this goal, we’ll use the WFE’s guidance to convince exchanges to implement its recommendations, especially in North America. We’ll also encourage exchanges with guidance to transition to listing rules.
We’ll continue to build investor support for these goals with our communications strategy, which includes investor blogs, op-ed pieces, and our monthly newsletter. We’ll also keep providing investors with memos and other material to support their responses to consultations on proposed ESG guidance and listing rules, as well as other relevant matters.
On the regulatory front, we’ll persevere with our attempts to make inroads with the International Organization of Securities Commissions (IOSCO) on advancing its preliminary consideration of corporate sustainability reporting principles and disclosure standards. A key piece of this work will be encouraging collaboration between the WFE and IOSCO.