Jun. 14, 2021
To the SEC, My family and I are writing you as interested impact investors to comment regarding the need for comprehensive and comparable climate and ESG issuer disclosure for investors. These following issues need to be considered seriously: The need for mandatory ESG reporting is essential. Voluntary reporting leads to significant data gaps, especially among medium and small companies. This lack of information affects us investors as well, in decision making. Mandatory ESG disclosure should be required for all reporting issuers in the United States. This will lead to a stronger base for companies in the long run. This is confidence building for investors. The SEC needs to develop a comprehensive functioning framework to help ensure that companies report more consistent, complete and comparable information relevant to their long-term risks, opportunities and performance. Without this, as investors we are handicapped. Impact investing is a vote of conscience but also of practical effectiveness. It is ineffective to not have this framework. ESG disclosure of comprehensive information should be available to allow investors to gain a holistic understanding of company practices. Again, education in terms of a more comprehensive understanding for the investor is logical and critical. ESG disclosures should allow comparisons among organizations within sectors, regions, industries or portfolios. This impacts and improves quality by stimulating honorable positive competition. The SEC needs to harmonize, where possible, with existing international standards to prevent comparability mismatches that leave the information generated less useful for investors framework. This should be designed to evolve in a timely manner as new issues emerge. This is affective organizing. It is disturbing that currently this gap in standards exists and keeps us at a disadvantage. Human capital disclosures should at minimum require EEO-1 reports, pay gap ratios for all demographics, employee turnover and composition of the workforce. Climate risk is not currently priced by financial markets because people don't have the information they need to assess physical risk. Climate risk needs to be equally considered as it will definitely be impacting our future in ways that we need to currently address with foresight. As an impact investor my family and I want to be informed and help participate financially in effective ways to improve the health and conditions of this planet which is at risk. We would like to see you, the SEC, take these kinds of steps, as well, by initiating the above steps. You have the power to improve our current planetary situation which in turn will improve all mankind. Sincerely, Pauli Robinson The Robinson Family