Jun. 14, 2021
I am President and CEO of The Shared Earth Foundation, a small family foundation which supports organizations that protect endangered species and their habitats. It is important to me that my portfolio invest in companies whose work is compatible with and supports my own mission. To help me make more informed decisions on what companies I should invest in, it’s important that I know their full risks from and impacts on Climate Change. The SEC must develop a comprehensive framework to help ensure that companies report more consistent, compete and comparable information relevant to their long-term risks, opportunities and performance. As we all know too well, voluntary reporting leads to significant data gaps, purposeful and not so, especially among medium and small companies. ESG disclosure must be mandatory for all reporting issuers in the United States. ESG disclosure must have comprehensive information to allow investors to gain a holistic understanding of company practices. ESG disclosures should allow comparisons among organizations within sectors, regions, industries or portfolios. Harmonize where possible, with existing international standards to prevent comparability mismatches that leave the information generated less useful for investors framework should be designed to evolve i a timely manner as new issues emerge. Please know that climate risk is not currently priced by financial markets because people don’t have the information they need to assess physical risk. Finally, human capital disclosures should at minimum require EEO-1 reports, pay gap ratios for all demographics, employee turnover and composition of the workforce WITHOUT THIS INFORMATION MY INVESTMENT DECISIONS ARE ESSENTIALLY BLIND TO THE DATA I NEED TO INVEST IN HARMONY WITH MY FOUNDATION GOALS. I appreciate your attention to this comment. Caroline D. Gabel President and CEO The Shared Earth Foundation 113Hoffman Lane Chestertown, MD 21620 410 810 4027 sharedearthfdn@gmail.com https://protect2.fireeye.com/v1/url?k=913357b1-cea86eae-9133b307-8630ffab37ab-38427a3b5da066c0&q=1&e=ddfbd9ce-3685-40d0-8fb6-d685de2413f0&u=http%3A%2F%2Fwww.sharedearth.org%2F