Nov. 08, 2018
November 8, 2018 Brent J. Fields Secretary United States Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 Via email to rule-comments@sec.gov Re: Request for rulemaking on environmental, social, and governance (ESG) disclosure (File No. 4-730) Dear Mr. Fields: Boston Trust & Investment Management Company and our sustainable investment practice, Walden Asset Management (“Boston Trust/Walden”), is an investment management firm working with institutional and private wealth clients who have nearly $9 billion in assets (as of October 31). We focus on high quality companies with sustainable business models and we systematically integrate environmental, social and governance (ESG) considerations into investment decision-making. We believe our investment process would benefit from having access to consistent and comparable ESG information from all corporate issuers and thus we support this request for rulemaking on ESG disclosure. Regardless of company size or industry, performance on material ESG factors contributes to long-term business success and creation of shareholder value. The lack of comprehensive, comparable, and reliable ESG data hinders our efforts to fully assess companies’ management of risks and opportunities. For decades, Boston Trust/Walden has engaged with companies in our clients’ portfolios to improve ESG disclosure. Our experience is that information gained by management through ESG reporting has direct benefits for the company by providing opportunities to build brand and reputational value, attract and retain talent, and better manage potential regulatory, litigation and other risks. Tracking and reporting ESG information can also assist management in increasing operational efficiencies, enhancing competitiveness, and identifying new revenue generating opportunities. Thus far, U.S. regulatory requirements and voluntary efforts have failed to produce the consistent and comparable data that our firm and a growing group of investors need with respect to ESG practices and performance. For example, according to US SIF (The Forum for Sustainable and Responsible Investment), more than 1 out of every 5 dollars under professional management in the United States is invested in some type of Sustainable, Responsible, or Impact (SRI) investing strategy. Also, the UN Principles for Responsible Investment represents nearly 2,000 signatories that represent over $80 trillion in assets globally. UN PRI members publicly commit to: “seek appropriate disclosure on ESG issues by the entities in which [they] invest” and to “incorporate ESG issues into investment analysis and decision making.” Boston Trust/Walden is an active member of the UN PRI as well as US SIF, the latter of which has called for robust ESG disclosure reporting since 2009. We ask the Commission to require all registrants to report annually on a comprehensive, uniform set of ESG indicators comprised of both universally applicable and industry-specific standards. With respect to reporting standards, we encourage the Commission staff to review several leading sustainability disclosure guidelines and frameworks, including US SIF’s proposal, the Global Reporting Initiative (GRI), CDP (formerly known as the Carbon Disclosure Project), the Climate Disclosure Standards Board, the UN Guiding Principles Reporting Framework, the Sustainability Accounting Standards Board (SASB), the International Integrated Reporting Council (IIRC), UN Global Compact, Dow Jones Sustainability Index and stock exchange listing requirements for sustainability disclosures, among others. We believe the SEC will find these resources useful in understanding the growing importance of ESG reporting to investors as well as the various approaches and frameworks available to guide corporate reporting. Thank you for your attention to the important topic of ESG disclosure. Sincerely, Carly Greenberg, CFA C: Timothy Smith, SVP, Director of ESG Shareowner Engagement, Walden Asset Management Carly M. Greenberg, CFA Senior ESG Analyst Walden Asset Management One Beacon Street, 33rd Floor | Boston, Massachusetts 02108