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TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

DealLawyers

DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

Section16.net

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

If you think that SEC (or other nations’) upcoming regulations on GHG disclosures are the only thing that might require your company to calculate and report on GHG emissions, think again. Amazon let it be known in its recently-released 2022 sustainability report that:

“Beginning in 2024, we’re updating our Supply Chain Standards to require suppliers to share their carbon emissions data with us and set carbon goals. We’ll use our scale, investment, and innovation to provide tools and resources to help them reach their goals – whether that’s transitioning to renewable energy or accessing more sustainable materials.”

We’ve cautioned before about how much work is needed to develop GHG emissions estimates. Amazon suppliers who have been sitting on the sidelines waiting for SEC’s final release may find themselves in a difficult position in having to come up to speed more quickly than expected. Notice that Amazon will also require suppliers to “set carbon goals” as well – meaning that those suppliers should give thoughtful consideration to carbon reduction plans, methods, milestones and the associated risks. I expect Amazon will provide some type of phase-in, prioritization or transition period to allow for differences in status/capabilities, and the company did state that they will “provide tools and resources to help” – but even so, it’s a pretty heavy lift as there are only 4.5 months left in 2023. I know I’m a broken record here, but if this initiative impacts you/your company and you haven’t already started the process, you should get going now.

Photo credit: Sundry Photography – stock.adobe.com

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile