Consultation Responses

IR Society responses to regulatory updates

IR Society News Consultation Responses Policy & Positions 5 June, 2024

Society responds on re-bundling research fees

In this IR Society response, which draws on the findings from our 2023 member poll on investment research, we emphasise the importance of research for valuations and the London markets, noting the impact of MiFID II unbundling on the quality of coverage and the industry perspectives provided. We are therefore generally supportive of the FCA's proposals for increased payment optionality as this could lead to increased/improved quality of coverage for small- and mid-caps, provided the associated ‘guardrails’ are proportionate and aligned with the equivalent US and proposed EU regimes.

IR Society News Consultation Responses Policy & Positions Research & Surveys 5 January, 2024

Society submits evidence on Scope 3 emissions reporting

This IR Society response draws on the findings from recent member research on Scope 3 and SECR reporting.

IR Society News Consultation Responses Policy & Positions 5 October, 2023

Society responds to the Voluntary Code for ESG ratings agencies

This IR Society response draws on the findings from the ESG data/ratings survey carried at Easter this year among our IRO Members, which illustrate a level of dissatisfaction with the current quality of engagement between companies and ESG data and ratings agencies. We hope this principles-based Voluntary Code of Conduct that is being developed for providers of ESG data and ratings will be helpful for our members, given the amount of time/resource IR departments currently spend dealing with these agencies.

IR Society News Consultation Responses Policy & Positions Research & Surveys 13 September, 2023

Society responds to the FRC’s Corporate Governance Code proposals

In this IR Society response, which draws on the findings from recent member research on the FRC's proposals of most relevance to IROs, the Society is generally supportive of the proposed reforms, but calls for more flexibility and less prescription in certain areas, for example, audit committee oversight of narrative and sustainability reporting given many corporates already have a sustainability committee. The Society expresses support for increased transparency around malus and clawback arrangements, although calls for more clarity around disclosure of their ‘usage’. The Society also identifies several areas where more detailed guidance would be helpful, including ‘good’ outcome reporting, ‘significant’ appointments for ‘over-boarding’ disclosures, audit committee engagement with shareholders and oversight of narrative/sustainability reporting.

IR Society News Consultation Responses Policy & Positions 30 June, 2023

Society responds to the FCA Listing Rule Proposals in CP23/10

In this IR Society response, which draws on the findings from recent IRO member research on the FCA's proposed changes to the Listing Rules and on current levels of investment research in the UK, the Society was generally supportive of the proposed reforms given most IRO respondents thought the FCA proposals would reduce regulatory barriers for companies and bolster UK competitiveness. However, the Society highlights concern that a lack of shareholder approvals for major transactions could lead to significant legal and advisory costs in the early days, until a more streamlined approach based on successful transactions establishes best practice, and that a generous transition period could be needed for current standard listings to allow them to comply with the more onerous ‘single category’ continuing obligations. The Society also mentions that liquidity, depth of markets, and comparable peers are thought of by IRO respondents as the most important factors in deciding where to list the proposals, with regulation and valuations also seen as significant factors. The response also highlights some more significant issues that the Society believes may also influence the attractiveness and competitiveness of the London markets, including the UK market’s sensitivity to Directors' remuneration and compensation structures, the quality and timeliness of Investment Research, the need to encourage funds flow into UK asset managers, the suggestion of establishing a framework that better enables companies to identify all short-sellers so that they can engage with them (if they wish), and the UK’s overlapping disclosure and filing obligations which could benefit from being streamlined and simplified.

IR Society News Consultation Responses Policy & Positions 30 June, 2023

Society responds to the ESG data and ratings HM Treasury Consultation

In this IR Society response, which draws on the findings from recent IRO member research on ESG data and ratings, which underline the importance of ESG ratings to corporates, illustrate a level of dissatisfaction with the quality of engagement between companies and ratings agencies, and indicate strong support for their regulation (90% of respondent IROs think they should be regulated by the FCA). The response also: • recommends that the UK regime is based on recommendations from IOSCO, to avoid regulatory arbitrage across jurisdictions; • calls for consistency and harmonisation with overseas equivalent regulations eg the EU’s recently published Proposal for regulating ESG ratings providers; and • recommends an appropriate transitional period, a phased approach so that smaller agencies have a longer transition period and an ongoing initial ‘start up’ period for new providers.

IR Society News Consultation Responses Policy & Positions 24 April, 2023

Society responds to the Review of Investment Research

The IR Society response to this call for evidence indicates that it will be conducting some further member research on current levels of coverage, and also refers to our 2021 MIFID II survey that illustrated the impact on sell-side coverage and quality, the reduced role of corporate broking services and the significant increase in direct interaction between IR departments and investors which has ensued.

Consultation Responses 24 April, 2023

Society responds to the Review of Investment Research

The IR Society response to this call for evidence indicates that it will be conducting some further member research on current levels of coverage, and also refers to our 2021 MIFID II survey that illustrated the impact on sell-side coverage and quality, the reduced role of corporate broking services and the significant increase in direct interaction between IR departments and investors which has ensued.

IR Society News Consultation Responses Policy & Positions 28 February, 2023

Society responds on the proposed UK Transition Plan disclosure framework

The IR Society response supports the proposals but calls for more flexibility in the way transition plans are published so that companies are permitted to include them in their annual report or other relevant reports (eg sustainability or climate reports), instead of being required to publish them as standalone reports.

IR Society News Consultation Responses 9 February, 2023

Society responds to the FRC Audit Committee Standards

The IR Society response to the FRC seeking liaison to help shape the upcoming reforms aimed at increasing shareholder engagement with audit and risk.

IR Society News Consultation Responses Policy & Positions 8 August, 2022

Society responds to Proposed European Sustainability Reporting Standards

The IR Society response to the Proposed European Sustainability Reporting Standards issued by EFRAG.

IR Society News Consultation Responses Policy & Positions 1 August, 2022

Society responds to ISSB Sustainability Reporting proposals

The IR Society welcomed the publication of the ISSB Exposure Drafts IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information, which is based on those developed by the Task Force on Climate-Related Financial Disclosures (TCFD) and the Sustainability Accounting Standards Board (SASB), and called for as much harmonisation and convergence with existing and emerging standards and frameworks in reporting as possible. The Society also noted that international collaboration in the development of any global baseline for sustainability reporting will be essential for the creation of a disclosure system that can be implemented globally with a consistent approach across markets, thereby optimising reporting efficiency for companies falling under multiple reporting regimes. The Society called for flexibility around the location of sustainability-related financial disclosure, provided the core information is still required to be included within the annual report and accounts, and suggested that any sustainability-related disclosure requirements should recognise that reporting entities may not to be able to obtain complete and accurate, or even estimated, data from entities in the value chain that are beyond the reporting entity’s control.

IR Society News Consultation Responses Policy & Positions 1 August, 2022

Society responds to ISSB Climate Reporting proposals

The IR Society welcomed the publication of the ISSB Exposure Draft IFRS S2 Climate-related Disclosure, which is based on those developed by the Task Force on Climate-Related Financial Disclosures (TCFD) and the Sustainability Accounting Standards Board (SASB), and called for as much harmonisation and convergence with existing and emerging standards and frameworks in reporting as possible. The Society also noted that international collaboration in the development of any global baseline for climate reporting will be essential for the creation of a disclosure system that can be implemented globally with a consistent approach across markets, thereby optimising reporting efficiency for companies falling under multiple reporting regimes. The Society called for flexibility around the location of climate-related financial disclosure, provided the core information is still required to be included within the annual report and accounts, and suggested that any climate-related disclosure requirements should recognise that reporting entities may not to be able to obtain complete and accurate, or even estimated, data from entities in the value chain that are beyond the reporting entity’s control.

IR Society News Consultation Responses Policy & Positions 18 July, 2022

Society responds on UK Transition Plan proposals

The IR Society responded to the UK’s Transition Plan Taskforce’s call for evidence, supporting the sector-neutral approach and calling for transition plan disclosure requirements to be high level and principles-based, to be underpinned by more detailed non-mandatory guidance (including practical examples). Metrics should be included in such non-mandatory guidance, to give companies the flexibility to determine their own data points / Key Performance Indicators for how they measure progress. The Society called for flexibility around the location of transition plan disclosures, provided the core information is still required to be included within the annual report and accounts, and suggested that any transition plan requirements should recognise that reporting entities may not to be able to obtain data relating to energy usage and emissions from entities in the value chain that are beyond the reporting entity’s control.

Consultation Responses 16 June, 2022

SEC Climate-Related Disclosures

The IR Society has today responded to the SEC consultation on proposed climate-related disclosures, calling on the SEC to allow the use of the ISSB climate standard to meet the requirements of the SEC’s proposed rule for foreign issuers such as Form 20-F filers and companies with ADRs (American Depositary Receipts). This would be especially beneficial for those whose home market is likely to require the ISSB standards (like the UK), as it would avoid the need for duplicative reporting.

Consultation Responses 20 October, 2021

FCA Consultation: Diversity and inclusion on company boards and executive committees

IR Society response to CP21/24 ‘Diversity and inclusion on company boards and executive committees’

IR Society News Consultation Responses 13 July, 2021

BEIS Consultation on ‘Restoring trust in audit and corporate governance’

The IR Society response to the BEIS Consultation on 'Restoring trust in audit and corporate governance'

Consultation Responses 2 April, 2019

Proposed Revisions to the UK Stewardship Code

The IR Society response to the FRC's consultation on Proposed Revisions to the UK Stewardship Code

Consultation Responses 28 February, 2018

Proposed Revisions to the UK Corporate Governance Code.

The IR Society response to the FRC's Proposed Revisions to the UK Corporate Governance Code.