A year has passed since the SEC issued an interpretive release describing the kinds of climate change related disclosures that the Commission believes should be reported by all publicly traded companies, but many questions still remain regarding how to comply. With annual 10-K filings due at the end of this month, concrete examples of best practices in disclosures could be very helpful. Potentially useful is a new report by Ceres that examines the state of disclosures in FY 2009 SEC filings to identify specific examples of how well companies are disclosing information that is important to investors.
The report identifies five categories of climate risks and opportunities: regulatory risk and opportunity; indirect consequences or business trends; physical impacts; greenhouse gas emissions; and strategic analysis of climate risk and emissions management. Using a system to rank various disclosures within these categories as poor, fair, and good – no company’s practices qualified as “excellent” – the report provides specific examples of what works and what does not.
The report also includes an 11-point checklist with recommendations for improving disclosures. The recommendations include integrating consideration of climate risk and opportunity throughout the firm, creating a board-level committee with specific responsibility for climate change risks, and using specific numbers and dollar figures in disclosures to quantify emissions, risks and opportunities whenever possible.
Of course, the report is not legal advice on what any company should disclose to the SEC, and Ceres has no authority to require companies to follow its suggestions. Ceres is a network of investors, environmental organizations and other public interest groups with a mission to integrate sustainability into capital markets. Not surprisingly, the report promotes that agenda, ranking the more specific disclosures higher, and encouraging increased transparency in companies' reports.
Other reports and resources also provide guidance in this area: both general statements of investor expectations such as the Global Framework for Climate Risk Disclosure and the ASTM Standard on Financial Disclosures Attributed to Climate Change; as well as sector-specific rules and guidance like the National Association of Insurance Commissioners’ Insurer Climate Risk Disclosure Survey, and the Global Climate Disclosure Frameworks for the oil and gas, automotive, and electric utility sectors.