May 7, 2010
Dear Sir or Madam,
I appreciate the opportunity to submit a comment to the work of your "Investor as Owner Subcommittee" regarding item (iii) of the agenda: "briefing on the Investor as Owner Subcommittee's environmental, social, and governance disclosure workplan".
On behalf of the German Federal Environment Ministry and with participation of leading sustainable investors and analysts, who influence sustainable assets of about USD 2.5 trillion with offices in all important industrial countries, I have defined the three most important "Sustainable Development Key Performance Indicators" (SD-KPIs) for the business development of 68 industries in the next five years (according to the MSCI/Standard and Poor's Global Industry Classification Standard, GICS).
The participants in this study ("SD-KPI Standard 2010-2014") have been Credit Agricole Cheuvreux, Dexia Asset Management, Ethix SRI Advisors, GES Investment Services, Hermes Equity Ownership Service (Stephen M. Davis, Ph.D., the chair of your Subcommittee, is non-executive chair of Hermes EOS), imug/EIRIS, KLD Research Analytics, RiskMetrics Group (KLD and RMG have been acquired by MSCI), Sarasin, Social Investment Forum Japan, Societe Generale, Sustainalytics and Vigeo.
SD-KPIs have been called a "minimum reporting standard" for sustainability information in annual reports or management commentaries according to the EU accounting law by the German Federal Environment Ministry.
For leading European pensions funds with about USD 600 billion of assets under management long-term investments based on the "SD-KPI Standard 2010-2014" offer high outperformance potential in comparison to broader sustainable research approaches.
The copyrighted "SD-KPI Standard 2010-2014" is attached and can be downloaded for free at www.SD-M.de in the section "SD-KPIs". - An article about the "SD-KPI Standard 2010-2014" can be found on the website http://www.institutionalshareowner.com/article.mpl?sfArticleId=2873 of the SRI World Group, USA.
I hope that the "SD-KPI Standard 2010-2014" might help you in your further work regarding environmental, social, and governance disclosure and would very much appreciate if you could keep me informed about your important work in the future.
Kind regards
Dr. Axel Hesse
Economist and Senior Consultant
SD-MŽ (www.SD-M.de)
Germany
Copyright material redacted. Author cites copyrighted material: "The copyrighted "SD-KPI Standard 2010-2014" is attached and can be downloaded for free at www.SD-M.de in the section "SD-KPIs". - An article about the "SD-KPI Standard 2010-2014" can be found on the website http://www.institutionalshareowner.com/article.mpl?sfArticleId=2873 of the SRI World Group, USA."