Jun. 11, 2021
Dear SEC, I write to urge you to develop a comprehensive framework to ensure companies report more consistent, complete and comparable information relevant to their long-term risks, opportunities and performances; voluntary reporting leaves significant data gaps, particularly among medium and small company. ESG disclosure should be mandatory for all reporting issues in the U.S., and should have comprehensive information to allow us, the investors, to get a holistic understanding of company practices. Furthermore, the ESG disclosures should allow comparisons among organizations with sectors, regions, portfolios or industries. Wherever possible, I believe that the disclosures should be harmonized with international standards; otherwise comparability mismatches will ensue and generate less useful information for investors. The disclosure system should be designed to evolve as new issues emerge. Furthermore, I strongly think that climate risk is not priced by financial markets because people don't have the information needed to assess physical risk. Human capital disclosures should at a minimum, require EEO-1 reports, pay gap rations for all demographics, employee turnover and composition of the workforce. Investing should take a long term view; it's our future, the future of our planet and our civilization that are at stake. Thank you.