If you haven’t seen the announcement about our upcoming July 13 Climate Disclosure Event (and associated offer) – “The New SEC Climate Disclosures: Key Action Items Now” – you need to check it out. Demand to attend is so high that we had to obtain additional “seats” on our virtual platform!
One item on the agenda is a preview of our model disclosure, which was a heavy lift to create. John Jenkins got the ball rolling and wrote up his initial thoughts in this blog over on TheCorporateCounsel.net. He handed the baton to me and I agree with these two points from him:
– The Boilerplate Potential is High. When disclosure requirements lay out the path that regulators want companies to take and are designed to shame those that don’t, companies tend to follow that path. An unfortunate consequence of that approach is the potential for lemming-like behavior that will likely result in a lot of boilerplate disclosure. And yes, a lot of this stuff lends itself to boilerplate, even though that’s an outcome the Staff says it wants to avoid.
– You Can’t Do This Yourself. The proposed rules will require compliance with extraordinarily granular disclosure requirements dealing with matters that are beyond the expertise of the lawyers and accountants who traditionally take the lead in preparing SEC filings. That means that many companies – even those that currently provide climate disclosure – will need to add capabilities, enhance disclosure controls and procedures, and expand the group responsible for SEC reporting to include people with experience in climate-related disclosures and metrics.
The bulk of work I did is on Item 1504 – Emissions Metrics. I don’t want to steal the thunder from our event, so I will be a little vague and evasive here on my thoughts. Suffice it to say that John’s characterization of the proposed disclosure being “extraordinarily granular” is accurate indeed. Previous experience with voluntary GHG reporting is valuable, but I’m no longer convinced it will help to the extent discussed in the proposed release. While TCFD experience may provide a reasonable basis for Items 1501 – 1503 and 1506, SEC’s proposed approach to Items 1504 – 1505 is substantially different (as the SEC acknowledged) and will require meaningful effort even for those experienced with voluntary GHG disclosures.
If you expect to be involved in drafting your company’s climate disclosure – or will be helping gather and prepare emissions data for it – you need to join us on July 13. It will be worth your while.
To make this event an even bigger value, attendees are eligible for $100 off our 1st Annual Practical ESG Conference AND $200 towards an annual subscription to PracticalESG.com! Email sales@ccrcorp.com or call 1-800-737-1271 to claim this offer.
Register today for this FREE event, and please share it with anyone on your team or in your network who may be interested. That includes ESG, Sustainability & Impact Officers, Environmental Health & Safety Officers, Investor Relations & Public Relations professionals, in-house and outside counsel who are advising boards or preparing disclosures, and anyone involved with ESG strategies and disclosures. To register for this event and learn about our model disclosure, click here.
