Subject: File No.
From: Maxim Vergeichik
Affiliation: Technical Advisor, United Nations Development Program (UNDP)

March 23, 2021

In response to question 15, The \"E\" (Environment) in the ESG abbreviation would ideally need to encompass two sub-standards: (1) climate, (2) nature. The latter could cover impacts and dependences that companies have (and would need to disclose to the finance sector) on ecosystems and biodiversity. While for climate standardized disclosure frameworks seem to have advanced recently (e.g. TCFD), for nature related disclosure there current is a process on-going for setting up a standardized disclosure framework task-force, known as TNFD (Taskforce for Nature-related Financial Disclosures), which brings businesses, financial sector, and regulators, NGOs and international organizations together to develop a meaningful approach. UNDP is one of the four founding partners of this initiative SEC might consider connecting to this process, with a view to subsequently make use of the upcoming TNFD framework for its purposes as a regulator. Additional information: tnfd.info