July 14, 2016
The disclosure of information about environmental performance and social investments of companies strengthens competitiveness and ensures sustainable prosperity, not only for this quarter and this year, but for generations to come. Disclosing and managing the sustainability and public policy issues most likely to have financial impact helps companies mitigate risk and identify opportunities for sustainable growth.
Not disclosing performance on material sustainability issues will certainly not encourage the management of these issues and leave value unrealized or unprotected. The SEC has an opportunity to harmonize its required disclosures with global standards and, reduce corporate disclosure fatigue, eliminate selective disclosure, and improve investor decision making by referencing globally recognized standards already in use as a way for companies to comply with disclosure requirements.
Most BCCCC members are US companies operating globally. Given that EU Directive 2014/95 will go into effect In December 2016, we advise for our members a harmonized approach to reporting. The Directive does not introduce a requirement on the reporting framework that should be used to report, however, companies are encouraged and expected to rely on one of the internationally recognized instruments such as the Global Reporting Initiative (GRI) Framework , the UNGC Principles, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, ISO 26000, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy and European Eco-Management and Audit Scheme (EMAS).
We suggest that the SEC strive for harmonization where possible and embrace parallel guidance on reporting to encourage comparability and adoption. We support harmonization as we see that it will achieve the objectives of making disclosures more comparable and efficient as companies are disclose information in multiple contexts and formats.