Public policy consultations

Cardano welcomes the work undertaken by the Taskforce on Social Factors committee and welcomes the consultation and guide.

Our approach to social factors encompasses the following:

• Integrating Social Issues
• Social Foundations as a Guiding Framework
• Stewardship
• Impact Investments and Social Bonds
• Collaboration

We provided our feedback to the consultation on the Transition Plan Taskforce Disclosure Framework and Implementation Guidance. This sector-neutral framework provides recommendations for developing gold-standard transition plans. Our comments are intended to ensure that the framework and guidance can be effectively implemented by UK companies while being investable for a range of institutional investors, therefore allowing for sufficient capital flows to support the UK’s decarbonisation objectives.

We believe that the FCA’s proposed way forward for SDRs is elegant and well done. Conceptually, we are in agreement with the FCA’s approach. Our comments are intended to ensure the framework is investable for a range of institutional investors and therefore to allow for sufficient capital flows to support sustainability goals.

We have recently provided a response to the consultation on Local Government Pension Scheme (England and Wales): Governance and reporting of climate change risks.

As a sustainability advisor to LGPS and private pension schemes, we hope that our recommendations and observations in the attached are helpful.

We provide our initial reflections on the ISSB general-requirements exposure draft and climate-related exposure draft. Our primary suggestion to the ISSB is that the drafts need to address real-world impact (or “double materiality”), not the current sole focus on enterprise value.

We have recently written to SEC to commend the Commission for its Proposed Rule aimed at providing investors with climate change-related financial information from issuers of public securities.

The Commission’s Proposed Rule would represent a step-change in the quality and comparability of climate change-related disclosures.

In April 2022, following the V0.1 beta release of the Taskforce for Nature-related Financial Disclosures framework, we have written to the co-chairs to provide feedback and support for further iterations of the framework.

In January 2022, Cardano responded to the FCA discussion paper: DP21/4 Sustainability Disclosure Requirements (SDR) and investment labels.

In December 2021, Cardano responded to the DWP consultation: Climate and investment reporting, the introduction of alignment metrics and stewardship-related disclosure.