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.

The Investor Relations Society

5th Floor, 30 Coleman Street

London, EC2R 5AL

John Glen MP – co-Chair Transition Plan Taskforce

Amanda Blanc – co-Chair Transition Plan Taskforce

Submitted via email to secretariat@transitiontaskforce.net

15 July 2022

Dear co-Chairs Glen and Blanc,

A Sector-Neutral Framework for private sector transition plans

Thank you for giving us the opportunity to comment on the call for evidence regarding A Sector-Neutral Framework for private sector transition plans, available here. This response is made on behalf of the UK’s Investor Relations Society (‘the IR Society’).

The IR Society represents members working for publicly listed companies and consultancies to assist them in the development of effective two-way communication with the markets and to create a level playing field for all investors. It has over 850 members, drawn mainly from the UK, including the majority of the UK FTSE 100 and many of the FTSE 250 constituents, and also including some companies listed overseas.

The IR Society’s mission is to promote best practice in investor relations; to support the professional development of its members; to represent their views to regulatory bodies, the investment community and Government; and to act as a forum for issuers and the investment community.

Overarching/general comments

We recognise the vital importance of decarbonisation and welcome your initiative to provide guidance to companies as they seek to play their part in its delivery and to inform investors and wider stakeholders about their activities. Companies have already embraced this need, whether through voluntary initiatives or in response to regulations, with early TCFD reporting by many listed companies a recent example. When setting their objectives and offering disclosure, companies will benefit from the guidance in this consultation paper.

We do note that there are a range of proposals currently under discussion, international proposals from the SEC, the European Financial Reporting Advisory Group (EFRAG), and the ISSB, as well as the UK’s Sustainability Disclosure Requirements (SDRs) and the UK Green Taxonomy. We are responding to these international sustainability reporting proposals, but we have a general concern that a number of companies will face many reporting demands. We support the introduction of a global baseline for sustainability standards by the ISSB (based on TCFD and SASB), which would provide a framework for the reporting of sustainability information. We also advocate international collaboration on its adoption and implementation in order to avoid unnecessary overlap in reporting requirements for companies falling under multiple reporting regimes.

From our perspective, the main purpose of transition plan disclosure is to facilitate investor assessment of the climate impact and remedies of their current and potential investee companies by providing them with key decision data. In turn they can then hold companies to account for their transition plans. We fully recognise the interest of the wider stakeholder community in the corporate contribution to achieving net zero, but from our perspective the key immediate users of transition plans are investors.

We support a sector-neutral approach and welcome the proposed framework. However, regarding the level of prescription in the sector-neutral framework, there is a balance to be struck between the benefits of disclosure requirements being high level/principles-based (so they have longevity and permit continuity of approach among entities already reporting on their transition plans) and the benefit that many companies might perceive in being offered a clear template. In our view, the right balance can be struck with high level principles-based transition plan disclosure requirements that are 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.

In our view, reporting entities should also be given the flexibility to choose whether to include their transition plans in their entirety within the annual report and accounts, or also to publish them in a standalone document(s), provided the core information is still required to be included within the annual report and accounts, so that it remains the single source for all key disclosures. Issuers should themselves be able to determine how and where to disclose information on transition planning within the annual report and accounts, rather than specific locations being prescribed.

Regarding verification, we are wary of external third-party assurance being mandated at this stage. Many corporates may choose to have independent assurance to demonstrate the credibility of their transition plans, but we believe that this can be a decision for individual corporates in light of the additional burden and potentially substantial costs involved.

We suggest any transition plan requirements should recognise that it may not always be possible for reporting entities to control or obtain data relating to energy usage and emissions from entities in the value chain that are beyond the reporting entity’s effective control, either operationally or through equity ownership. Similarly, it may not be possible to control or obtain data from others in the value chain such as suppliers/customers. We therefore suggest permitting such reporting entities to explain why they don’t have effective control and/or why they have been unable to obtain the data where estimates are disclosed. This is particularly likely to be an issue in the shorter term, when the necessary data flows have yet to be embedded in systems or reflected in contracts/commercial relationships.

We question the inclusion of ‘non-climate related external impact KPIs’ in this particular proposed framework.

Looking ahead, we have encountered a range of views whether additional sector-tailored templates are necessary to drive good sector disclosure. One view is that they may be helpful to tackling complex issues. Others argue that sector-neutral templates are enough , that tailored templates may increase the risk of ‘boiler plate’ disclosure and also may not keep pace with developments in metrics and targets.

Answers to specific questions

Introduction to the TPT

Rationale and definition

You state that “A transition plan sets out how an organisation will adapt as the world transitions towards a low carbon economy. It should set out a) high-level targets the organisation is using to mitigate climate risk, including greenhouse gas reduction targets (e.g. a net zero commitment), b) interim milestones, and c) actionable steps the organisation plans to take to hit those targets.”

You add that “This definition may evolve as the work of the TPT develops.”

Q1. Do you agree with the proposed definition of a transition plan? If not, why, and what alternative definition would you suggest?

We essentially agree with the proposed definition of a transition plan, but have the following comment.

The proposed definition makes reference to adapting to a low carbon economy, and setting GHG reduction targets, for example, a net zero commitment (our emphasis). In our view, more explicit reference should be made to transitioning to “net zero”, rather than it being implicit in the definition. In order to be credible, net zero commitments also need to be timescale-specific, although it should be up to the company to define the timeframe as they will be best placed to determine what is deliverable. We acknowledge that the interim milestones are probably an equally important and more immediate metric for investors, as well as a signal of corporate intent monitored by wider stakeholders.

Q2. From your perspective, who are the key users of transition plans?

As stated in our introductory remarks, the Investor Relations Society primarily exists to serve the interests of its members who are typically working for publicly listed companies, or for their advisers, to assist them in their communications with investors and the wider markets. In that context, from our perspective the key immediate users are investors, although we fully recognise the interest of the wider stakeholder community in the corporate contribution to achieving net zero, (including employees, providers of finance, ratings agencies (credit and ESG), employees, suppliers, customers, governments, regulators, other NGOs and local communities) and believe this information will be highly relevant to them too. However, overall, we believe transition plan disclosure requirements should primarily reflect the information needs of investors, otherwise they risk becoming too unwieldly and diverse.

Q3. From your perspective, what are the key use cases for transition plans?

Again from our perspective, we believe it is to permit investors to assess more rigorously the climate impact and remedies of their current and potential investee companies, allowing them to integrate this into their investment decision-making by providing them with key decision data. In turn, they can then hold companies to account for their transition plans.

A plan clearly represents a pathway for the company itself to follow in meeting the expectations of investors and its societal obligations, as well as a statement of its intent to take the necessary action. Furthermore it offers guidance and information to employees, suppliers and customers who will be impacted by progress towards that goal.

Q4. How should the TPT select which sectors to develop tailored transition plan templates for? Following that logic, what financial sub-sectors and real economy sectors should the TPT prioritise? In what order should these be addressed?

We support the sector-neutral approach. The suggested framework seems straightforward, easy to interpret, useful and capable of application to most sectors, with companies adapting it to fit their particular sector and circumstances (which will help the evolution of best practice). We await the sector-tailored templates and one view is that they may assist companies in dealing with the complexity of some of the transition planning issues they face. However we have received other comments that sector-neutral frameworks are sufficient and that additional sector-tailored templates may not be necessary to drive good disclosure . If these are developed, the concern is that they may increase the risk of ‘boiler plate’ disclosure, and there is also the risk that they will not keep pace with developments in metrics and targets (for example, due to advances in technology). We favour a flexible approach allowing companies to choose their own path and believe there is already significant non-mandatory sector-specific guidance to allow companies to help shape their transition plan disclosures (for example, SASB, GRI, CDP, SBTi). In our view, any sector-specific templates issued by the TPT drawing upon these frameworks should also be non-mandatory.

Mandate and structure of the TPT

Q5. Given the mandate set out in the TPT’s Terms of Reference, to what extent, and how, should the TPT consider issues beyond a firm’s contribution to an economy-wide decarbonisation? Why?

In our view, the TPT should focus on the transition to net zero, although inevitably considerations of energy security and cost of living will probably feature in policy thinking.

Q6. Which of these issues [see Q5] are ‘must-haves’ that need to be addressed in all transition plans, and which are ‘desirable’, which add depth or breadth but are not central to a transition plan?

We make no response to this question.

Q7. Do you envisage any tensions between entity-level decarbonisation and economy-wide decarbonisation goals? If so, can you provide examples and any suggestions as to how the UK TPT may address these in its guidance.

There is a potential issue where companies divest of carbon-intensive assets to companies or investors that are not subject to a rigorous transition planning framework. The divesting company would reduce its own carbon footprint, but the emission will remain in place until the acquiring company or investor takes action. This would be addressed through any proposed transition planning framework applying to all significant companies, whether listed or private, and by maximum alignment in international rules.

We have concerns that there may be a risk of double counting and that there is a need for fair allocation in respect of Scope 3 emissions to avoid this i.e. emissions may be double-counted if they are included in transition plans as scope 3, but they are also disclosed as scope 1 emissions for entities who are the end users and included as scope 1 in end-user transition plans, as for example in the case of the extractive industries. This is complicated by the international nature of production/consumption, where the scope 3 emissions may be generated in a different jurisdiction from the original production/extraction.

International collaboration

Q8. What other financial or non-financial, mandatory or voluntary frameworks and processes are you aware of that the TPT should consider as it proceeds?

We support the introduction of a global baseline for sustainability standards by the ISSB (based on TCFD and SASB), which would provide a framework for the reporting of sustainability information in parallel with traditional financial reporting. We also advocate international collaboration on its adoption and implementation in order to avoid unnecessary overlap in reporting requirements for companies falling under multiple reporting regimes. We think the TPT and other climate transition plan disclosure proposals should aim to be consistent with the ISSB proposals for transition plan disclosure.

We are aware that EFRAG and the SEC are also proposing to introduce transition plan reporting. Under the current text of the SEC’s proposed rule, companies would need to disclose any existing targets around emission reductions, energy use, nature conservation, or revenues from low-carbon products. The SEC would want disclosure of the transition plans to achieve those targets, including specific information on the use of offsets or renewable-energy credits. The SEC consultation asked whether foreign issuers should be permitted to instead provide ISSB-compliant disclosures, and we supported this proposition in our response.

EFRAG’s current proposed European Sustainability Reporting Standards (ESRSs) are not fully interoperable with the ISSB standards, but may have application in the UK because the overarching Corporate Sustainability Reporting Directive (CSRD) will require UK companies generating Euros 150 million turnover or more in the EU to make equivalent disclosures. We have concerns that this could also drive a required separate level of disclosure.

We also note the Transition Pathways Initiative (www.transitionpathwayinitiative.org) provides independent, open-access data showing whether the world’s largest high-emitting companies are adapting their strategies to align with international climate goals, to enable investors to enhance their investment decision-making, create new financial products and change corporate behaviour.

We note the GRI does not include specific requirements on transition plans, which can instead be reported under GRI 3-3 Management of material topics.

The Sector-Neutral Framework

Objectives

Q9. Where would you prefer for companies to disclose information on their transition plans? Please explain your reasoning, including on how the suggested location relates to the intended audience. [The Call for Evidence outlines the following possibilities:

Be integrated into existing annual financial disclosures;
Form part of standalone sustainability reports;
Be disclosed as standalone strategy documents; or
Be disclosed in full as a standalone strategy document, but with high-level elements also appearing as part of the strategy disclosure in the annual financial report.]

In our view, the annual report and accounts (ARA) should remain the single source for all key disclosures. However, reporting entities should also be given the flexibility to choose between including their transition plans in their entirety within the ARA (which may suit many smaller reporting entities), or also to publish them in a standalone document(s). The latter is already the approach of many larger reporting entities or those in particular sectors who wish to publish more detailed plans. For example, the ESG/Sustainability Report is a potential place to expand on disclosures made in the ARA, and we are aware of some companies that also issue a separate climate report (in addition to an ESG/Sustainability Report and their ARA). The proviso should be in our view that the core information is still required to be included within the ARA. This should ensure that the ARA remains a cohesive and comprehensive narrative, with appropriate cross-referencing to the transition plan disclosure elsewhere, but allows larger companies to publish more detailed plans without over expanding their ARA. We therefore favour option a) above, but with some optional flexibility for additional, more detailed disclosures to be made elsewhere.

Additionally, in our view, the TPT should allow issuers to determine how and where to disclose information on transition planning within the ARA itself, rather than prescribing specific locations.

Q10. How prescriptive should the Sector-Neutral Framework be, recognising the need to balance flexibility in how firms disclose transition plans with more prescriptive templates that seek to facilitate comparability of firms’ transition plans?

We agree there is a balance to be struck between, on the one hand, the need for disclosure requirements to be high level/principles-based and the benefit that many companies might perceive in being offered a clear template.

The advantages of the high level/principles-based approach include that it would:

allow continuity of approach among entities that are already reporting on their transition plans; and
ensure the Standards ‘stand the test of time’, especially in relation to metrics/targets that will constantly evolve.

On the other hand, there is a potential benefit in clear guidance to assist smaller corporates that are beginning their transition planning journey. However, it is also important to remember that, while methodologies and knowledge continue to develop, it could be counter-productive to set granular mandatory disclosure requirements, and it is important not to turn transition planning into a box-ticking, compliance exercise. In our view, the right balance can be struck with high level, principles-based transition plan disclosure requirements that are underpinned by more detailed non-mandatory guidance (including practical examples), to help corporates comply without disproportionate burden or cost.

The benefits of avoiding too much prescription as described above, outweigh any potential concern around lack of consistency/comparability for users of transition plans, given the specific detail in transition plans tends to be unique to the particular company reporting and thus wouldn’t necessarily be entirely consistent or comparable with those of other companies.

We acknowledge that it is important that there is as much ongoing consistency in transition plan disclosure as possible by individual companies over time, with explanations given where methodology or measurement have changed from prior years.

Q11. Should the TPT seek to standardise the data and metrics used to communicate ambition and measure progress in transition plans? If so, what are the standards for data and metrics that you would recommend including in the Sector-Neutral Framework and in supplementary sectoral guidance?

As mentioned at Q10 above, metrics and targets are likely to evolve and it is important to avoid stifling innovation and evolution in the methodology used to underpin transition plans, so we would be cautious about the extent of standardisation. Companies should have the flexibility to determine their own data points / Key Performance Indicators for how they measure progress, and best practice will evolve within sectors, so disclosures will tend to naturally align. Therefore, we suggest data and metrics should be included in separate supporting non-mandatory guidance.

Q12. Question for small and medium-sized enterprises: what specific challenges do you foresee for SMEs seeking to prepare or use transition plans? How can the guidance and framework prepared by the TPT address these concerns?

We represent larger entities for the most part, so do not consider it appropriate to offer a comment on small- and medium- sized enterprises (SMEs).

Q13. Question for preparers only: if your firm does not already disclose information of the type outlined in this Call for Evidence, what are the reasons for that? For example, are there concerns about legal or possible market risks arising from disclosure? How could the work planned by the TPT address these concerns?

Based on the insights we have received from preparers, we believe it is likely that companies not currently disclosing their transition plans are typically at the relatively smaller end of the company size scale or are in low impact sectors. Typical challenges faced are the cost and complexity of assembling the data as well as the existing demands from other regulatory and reporting requirements. For example, in the case of companies where a significant proportion of their overall footprint are Scope 3 emissions by customers, the challenges of accurate data gathering and forecasting can be extreme and materially impact the overall transition plan. Furthermore, for industries such as airlines, where aviation fuel is the biggest driver of emissions reduction, this is a global challenge and with both technology and cost assumptions as well as timeframes measured in decades, forecasting is wholly out of control of the operator.

We are also aware that international regulatory and/or legal restrictions can also give rise to difficulties. As an illustration, some jurisdictions require prior consent for the release of information about activities within their borders, for example, overseas disclosure of emissions.

Q14. Transition plans provide an opportunity to ensure the benefits of the climate transition are widely felt by UK households and consumers. How can the guidance developed by the TPT balance the need to minimise costs whilst encouraging companies to develop strategies to maximise benefits for all?

A flexible and phased introduction of planning and reporting requirements could assist in meeting the need to minimise associated cost. It would allow companies to build their internal capability in a proportionate fashion.

Principles

Q15. Do you agree with the proposed principles? Why or why not? [The proposed principles are:

Align with an economy-wide net zero transition - Targets, expected emissions trajectories and plans should be compatible with meeting a particular global temperature target by a particular time, ideally a 1.5 °C low or no-overshoot scenario by 2050. The plan should cover the whole organisation and any exclusions must not be material to the company and/or to the natural environment;
Focus on concrete actions which emphasise the near-term and are backed up by clear governance mechanisms - The plan should set out actions to be taken in the next three to five years and interim milestones that can be used to assess progress and explain how these actions are in line with the transition to a net zero economy. The plan should be integrated into, and coherent with, the overall business and investment strategy and backed up by clear governance processes; and
Enable periodic reporting and verification in a transparent manner - Verification should be enabled in respect of annual reports on progress through adoption of quantifiable and timebound key performance indicators, with a defined stakeholder feedback mechanism.]

We essentially agree with the principles above, but have a few points to make below.

In our view, the principles should expressly mention the need to seek to achieve an actual reduction and eventual cessation/elimination of physical emissions, rather than relying on removals/offsets (which should be left for the small percentage of activity where zero emissions are not possible).

We also suggest that Principle (ii) should be less prescriptive about the specific timeframe for actions to be taken (rather than specifying “three to five years”). This is because it may be appropriate for some companies to take near-term action in less than three years, whilst for other companies an appropriate timeframe may stretch beyond five years. We believe it should therefore be for the reporting entity to determine an appropriate timeframe for the near-term action needed in order to meet their longer-term ambitions, with an explanation of why their chosen timeframe is appropriate.

The principles could be clearer that transition plans should be reviewed on a regular, perhaps annual basis. Given how quickly advances are being made, it is very likely that technology will have been developed or improved, meaning initial interim targets could need updating.

However, we are wary of Principle (iii) mandating external third-party verification. Some corporates will voluntarily wish to have independent assurance to demonstrate the credibility of their transition plans, but we believe that this can be a decision for individual corporates and we believe this need not be mandated at this stage in light of the additional burden and potentially substantial costs involved.

Q16. Are there any principles that you would add to the list above? Why?

Companies should outline the assumptions they are making in preparing their transition plans, for example they could be required to make it clear where their plans are relying on technology that is not yet available or commercial. One view we have encountered is that CAPEX and OPEX costs for companies reliant on energy transition for decarbonisation are almost impossible to forecast with any degree of accuracy over the decades needed for transition, whilst current supply is minimal and often at a multiple of current fuel prices. As a consequence, companies will inevitably struggle with forecasting and in particular for time horizons which are a multiple of their normal long term financial planning horizons. We acknowledge that Management activities and plans includes a Sensitivity analysis, including an “overview of the dependencies on external developments (e.g., policy changes, technological advances)”. In our view, this needs to be given more prominence and the uncertainties acknowledged.

Nevertheless, in order for transition plans to provide investors with the most decision-useful information, the costs associated with the plan should also be included, as far as estimable. We acknowledge that OPEX and CAPEX are included within the ‘Financial Plan’ sub-element of Management activities and plans (see our comments at Q20/21 below). However, given costs are fundamental to a transition plan, in our view total annual expenditure could also be included within the principles.

We would also advocate the need for actual reduction/elimination of emissions (rather than relying on removals/offsets), and the need for a regular review (see Q15 above), both of which could be made clear in the principles.

Q17. Which of these principles would you regard as ‘must-haves’ or as ‘desirable’?

See our comments at Q15 and Q16 above.

Q18. Principle 1 notes that a transition plan should cover the whole organisation. There may be challenges for internationally active firms in meeting Principle 1, given that different jurisdictions will have different economy-wide transition pathways. How can the TPT design its standard and guidance in a way that accommodates credible transition plans consistent with the broader strategy of a firm, but reflects differences between approaches taken in different jurisdictions?

This could be mitigated if different jurisdictions align with the ISSB proposals for transition plan disclosure, which would provide consistency and should reduce differences with other jurisdictions. Also, the TPT could take the lead by using high level principles-based transition plan disclosure requirements that are underpinned by more detailed non-mandatory supporting guidance, as we suggest at Q10 above.

Elements

Q19/20. Do you agree with the proposed elements? Why or why not?

[The proposed elements are: a. Ambition; b. Target setting; c. Management activities and plans; d. Internal policies; e. Products and services; f. Engagement: Value chains/portfolio; g. Engagement: Public sector; h. Engagement: Industry peers; i. Measurement and monitoring; j. Skills, incentives and accountability; and k. Governance, roles and responsibilities.]

This is a comprehensive and helpful list, but in our view it inclines towards being over-granular and risks transition plans becoming boiler plate. In our view, the key elements are:

a. Ambition;

b. Target setting;

c. Management activities and plans, which includes the Financial plan to highlight the cost implications to the extent estimable;

e. Products and services;

f. Engagement: Value chains/portfolio;

i. Measurement and monitoring; and

k. Governance, roles and responsibilities (which, for example, could include j. skills, incentives and accountability).

Q20/21. Are there any elements that you would add to the list [below – sic – above?] Why?

Given the costs associated with a transition plan are fundamental to an assessment of whether it is credible, in order for transition plans to provide investors with the most decision-useful information, the costs associated with the plan should be disclosed. We acknowledge OPEX and CAPEX are currently contained in the Financial Plan sub-element of Management activities and plans, but in our view costs should be given more prominence. For example, the Financial Plan could be required to include an aggregate CAPEX and OPEX figure to give a sense of the absolute costs to deliver the plan on an annual basis,. See also our comments above that costs disclosure should also be added to the principles, (see Q16 above).

Q21/22. Which of these elements would you regard as ‘must-haves’ or as ‘desirable’ for credible transition plans? In which instances should an entity assess materiality to determine whether an element is considered must-have and/or what level of disclosure detail is required?

As we mention at Q20/21 above, in our view, the key “must have” elements are:

a. Ambition;

b. Target setting;

c. . Management activities and plans, which includes the Financial plan to highlight the cost implications to the extent estimable;

e. Products and services;

f. Engagement: Value chains/portfolio;

i. Measurement and monitoring; and

k. Governance, roles and responsibilities (which, for example, could include j. skills, incentives and accountability).

Looking at it through the investor lens, in our view judgements on materiality are most likely to apply to disclosures around Scope (sub-element of b ‘Target Setting’), Impact Of Products (sub-element of e ‘Products and Services’) and Engagement with portfolio companies, customers and suppliers (sub-element of f Value Chain).

Q22/23. Are there elements where you see substantial barriers to implementation? If so, which ones and why? Are you able to suggest alternatives which are both credible and practical?

It is important to note that there can be practical issues around control, and therefore there is a potential challenge for reporting entities to obtain data (such as emissions data) from other entities in the value chain including associates, joint ventures, unconsolidated subsidiaries or affiliates, and suppliers/customers.

In the case of real estate companies, tenants often have responsibility for the repair and maintenance of leased assets, for example buildings. The landlord/asset owner therefore may have very little control over improving the building’s green credentials and its energy use. It can also be difficult to obtain energy use data from tenants so estimates are necessary. We suggest any transition plan requirements should recognise that it may not always be possible for reporting entities to control or obtain data relating to energy usage and emissions from entities that are beyond the reporting entity’s effective control, either operationally or through equity ownership. Similarly, it may not be possible to control or obtain data from others in the value chain such as suppliers/customers. Under these circumstances, we suggest permitting such reporting entities to explain why they don’t have effective control and/or why they have been unable to obtain the data where estimates are disclosed. This is particularly likely to be an issue in the shorter term, when the necessary data flows have yet to be embedded in systems or reflected in contracts/commercial relationships.

Another example of difficulty in implementation we have been presented with is that facing companies involved in the transport/automotive/logistics sectors, where they are very reliant on the development of alternatives to the internal combustion engine, as well as the extent of charging/refuelling infrastructure and the availability of sustainable power or fuel.

We also note potential challenges with the inclusion of some of the sub-elements, for example:

e. Products and services, which includes the sub-elements ‘Plans to increase portfolio of low-carbon products and services’ and ‘Emissions impact of changes to products and services’ where there may be commercial sensitivities, and
i. Metrics and monitoring progress, which includes “setting and regularly reporting non-climate related external impact KPIs”. We suggest transition plans should focus on the transition to net zero, and we therefore question the inclusion of non-climate related external impact KPIs in these proposals.

We hope you find these comments useful. Please do not hesitate to make contact if you have any questions.

Your sincerely,

Nigel Pears

Chair of the Investor Relations Society’s Policy Committee

(Email: enquires@irsociety.org.uk, Tel: + 44 (0) 20 7379 1763)

Published 18 July, 2022