The Pensions Regulator has launched a campaign to ensure that trustees are meeting their ESG and climate change reporting obligations.

Trustees of occupational pension schemes with 100+ members are required to prepare:

  • A statement of investment principles (“SIP”) which, among other things, must include the trustees’ policy in relation to financially material ESG and climate change considerations.
  • An annual implementation statement setting out how certain aspects of the SIP have been followed during the scheme year.

Both documents must be published on a website that is accessible free of charge by the general public. Trustees must report on compliance with this obligation in the scheme return.

Continue Reading ESG and climate change – new Pensions Regulator campaign

A recent attention-grabbing report by the Guardian, Die Zeit and SourceMaterial claimed that “more than 90% of rainforest carbon offsets by biggest certifier are worthless“. This prompted a swift detailed rebuttal by Verra – the world’s largest certifier of offsets and the organization subject to the criticism – who argued that the Guardian’s

On 25 January 2023, the new CEO of the UK Competition and Markets Authority (“CMA”), Sarah Cardell, set out one way in which the CMA will seek to ensure that the UK’s transition to a net zero economy will not be held up by competition law concerns. Significantly, Sarah Cardell again emphasised that environmental sustainability is a strategic priority for the CMA. This is an invitation for businesses to start pushing harder on the CMA’s open door, for which Mayer Brown’s ESG team is on hand to help.

Continue Reading Climate change: the CMA’s open door

FTSE Russell – a leading provider of benchmarks that are used extensively by investors across the globe – has removed 34 companies from the FTSE4 Good All-World benchmark (the “FTSE4Good Index”). The companies were removed for failing to meet climate performance standards imposed by the newly introduced ‘Climate Change Score’ system, which is based on parameters created by the Transition Pathway Initiative (“TPI”), an initiative backed by 132 investors with over US$50 trillion in assets under management.

Continue Reading Climate performance – FTSE4Good Index looks to hold companies to higher environmental standards

On January 17, 2023, the Board of Governors of the Federal Reserve System (“Federal Reserve”) launched its pilot climate scenario analysis exercise (“CSA”) by publishing instructions for the six US banking organizations that will participate.

As part of the CSA, participating organizations will submit data templates, supporting documentation, and responses to qualitative questions to the

On December 23, 2022, the Federal Acquisition Regulatory Council (“FAR Council”) extended its 60-day comment period an additional 30 days from January 13 to February 13, 2023, for its proposed rule on Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk. (We previously provided an in-depth analysis on the proposed rule.)

For more information

On 6 December 2022, the Council of the European Union (the “Council“) and the European Parliament (the “EP“) reached a provisional agreement on a proposal to minimise the risk of deforestation and forest degradation with products that are imported into, or exported from, the EU (the “Agreed Position“). The

The 15th meeting of the Conference of the Parties to the United Nations Convention on Biological Diversity (COP15) is taking place in Montreal, Canada, until next Monday (December 19).  It has been attracting much attention due to negotiations on the Post-2020 Global Biodiversity Framework (GBF), which is hoped to be agreed upon in the next few days. This would be an important milestone has base been described as the “biodiversity equivalent of the 2015 Paris Agreement on climate change”.  The aims is to halt and reverse biodiversity loss by 2030 and establish long-term goals by 2050.

Continue Reading Observations from the COP15 (Biodiversity Conference) Halfway Point

On December 8, 2022, the Basel Committee on Banking Supervision (“BCBS”) released guidance to clarify how climate-related financial risks may be captured in existing capital and liquidity requirements for banking organizations (“Climate FAQs”). The Climate FAQs are noteworthy because they indicate that standard setters believe climate-related financial risks should be included in bank capital requirements

COP27 has now come to a close. Against the global backdrop of political and economic turbulence, many questions were asked as to what could realistically be expected as outcomes of COP27. We now have the answers to those questions.

Continue Reading COP27 Postscript – much ado about nothing?