All consultation submissions
ShareAction feedback on the EU proposal for an Initiative on Sustainable Corporate Governance
11 February 2021
For too long, companies have focused on short-term financial performance compared to their long-term development and sustainability aspects. ShareAction strongly supports the European Commission’s intention to introduce an initiative on sustainable corporate governance that will ensure environmental and social interests are fully embedded into business strategies. Our three key priorities for the proposal will be essential for its success:
- Establish a legal duty for companies to undertake environmental and human rights due diligence.
- Clarify directors’ duties to ensure that the sustainability matters are duly considered at a strategic level and put forward transparently in the company’s overall strategy.
- Strengthen directors’ duties towards stakeholder interests.
Feedback to EU Taxonomy criteria on climate change adaptation & mitigation
18 December 2020
ShareAction has provided feedback to the EU Taxonomy draft Delegated Acts on the Technical Screening Criteria for climate change adaptation and mitigation.
Please find our full response in the document attached.
The EU Taxonomy has been hailed globally as a milestone in creating the much-needed tools for financing the transition to a low-carbon economy. For this tool to effectively facilitate reaching the EU emission reduction targets and commitments under the European Climate Law to meet climate-neutrality by 2050, it needs to fully endorse the ambition of the Technical Expert Group’s (TEG) recommendations, if not going even further.
Our key recommendations concern the following areas:
– Maintain the proposed climate change mitigation criteria for electricity generation of 100g CO2/kWh to effectively exclude natural gas without abatement (CCSU)
– Exclude the burning of all forest biomass for energy as well as reverse the inclusion of all bioenergy feedstocks with higher lifecycle emissions compared to fossil-fuels
– Explicitly exclude hydrogen produced with non-renewable power
– Reconsider the inclusion of activities such as short-term forestry rotation, livestock and small hydropower
– The inclusion of sea and coastal water transport should be conditional on the examination by the Platform on Sustainable Finance
– Exclude the burning of refuse-derived fuel (RDF) in cement plants, as recommended by the TEG
We have also supported a civil society joint-statement on the draft Delegated Acts, which is available here.
ShareAction input to the consultation by the European Supervisory Authorities regarding ESG disclosures under the Sustainable Finance Disclosure Regulation
2 September 2020
We have long advocated for a financial system that is transparent and provides its investors and society with meaningful information about its impacts on communities and the environment. After all, effective disclosure is the first step towards building a financial system that fully integrates sustainability factors to unleash its positive potential. To this end, the draft Regulatory Technical Standards (RTS) are a very significant step in the right direction, and introduce a useful conceptual framework for disclosure.
We welcome the approach of defining mandatory indicators that are considered to always lead to a principal adverse impact and then to guide Financial Market Participants (FMPs) on how to disclose on additional adverse impacts in a harmonised and comparable manner. We are however concerned on the lack of requirements to justify the choice of the two additional adverse impact indicators FMPs will have to report against. We urge the ESAs to consider adding a number of additional indicators to the Principal Adverse Impacts table (Table I, Annex II), in particular climate indicators that are forward-looking.
Amending sectoral legislation to integrate end-investors’ sustainability preferences
8 July 2020
ShareAction, the responsible investment advocacy group, welcomes the opportunity to provide feedback to the draft Delegated Acts presented by the European Commission on the obligation of investment firms, investment funds, mutual funds and insurance firms to advise clients on social and environmental aspects of financial products, amending UCITS, MiFID II and IDD.
Raising the bar on corporate disclosure with an ambitious NFRD-Review
17 June 2020
ShareAction has responded to the public consultation on the review of the Non-Financial Reporting Directive (NFRD).
Response to LGPS consultation on responsible investment guidance
10 January 2020
ShareAction responds to a consultation on the Local Government Pension Scheme’s guidance on responsible investment.
Response to the Law Commission’s consultation on intermediated securities
29 November 2019
ShareAction responds to the Law Commission’s review into the system of intermediated securities and obstacles to responsible investment along the investment chain.
Response to DEFRA’s consultation on its National Food Strategy
4 November 2019
ShareAction responds to DEFRA’s consultation on its National Food Strategy, highlighting the need to address childhood obesity and working conditions in agricultural supply chains.
Response to the Pension Regulator’s consultation on trusteeship and governance
10 October 2019
ShareAction responds to the Pension Regulator’s consultation on trusteeship and governance outlining how better understanding of ESG risk, and greater diversity on trustee boards, can secure better outcomes for pension scheme members.
Response to Treasury inquiry on green finance
2 August 2019
ShareAction responds to the Treasury’s consultation on how to decarbonise the UK economy at the pace required of the climate crisis.
Response to FCA Consultation on IGCs
15 July 2019
ShareAction supports proposals to require publication of policies on ESG, stewardship, and scheme members’ views & calls for regulatory guidance on TCFD reporting.
FCA & FRC Building a regulatory framework for effective stewardship
7 May 2019
Our response to the discussion paper on building a regulatory framework for effective stewardship: recommendations include to extend ‘stewardship’ to include the environment.
FCA consultation on proposals to improve shareholder engagement
9 April 2019
In this consultation response, we call for voting disclosure to be made mandatory under SRD II.
FRC: Proposed Revisions to the UK Stewardship Code
9 April 2019
We respond positively to the proposed revisions, while making some suggestions for further improvement to the Code.
FCA consultation on climate change & green finance
31 January 2019
We focus on the need to implement the recommendations of the Taskforce on Climate-related Financial Disclosures and on asset owner disclosures.
DWP consultation on pensions dashboard
28 January 2019
We support a pensions dashboard as the first step in the journey towards better engagement between pension schemes and members.
Pension Costs and Transparency Inquiry
18 September 2018
Our submission to this inquiry argues that more transparent schemes can ensure greater engagement with savers and mitigate ESG-related financial risks.
Response to FRC review call for evidence
6 August 2018
This response identifies areas for improvement in the current Stewardship code, and raises concerns about the level of funding the FRC receives for stewardship.
Clarifying and strengthening trustees’ investment duties
17 July 2018
This resource contains our submission to the UK Government’s consultation into pension trustees’ duties to take into account ESG factors in investments and stewardship.
Response to FCA/TPR Consultation on Regulating the Pensions and Retirement Income Sector
19 June 2018
ShareAction responded to the FCA/TPR’s consultation. We emphasised the importance of transparency and availability of information to savers, so they can take action to ensure they receive good outcomes.
Response to BEIS Consultation on Insolvency and Corporate Governance
11 June 2018
ShareAction responded to the BEIS consultation, arguing for a clearer Stewardship Code with more focus on ESG, and more substantive regulation to ensure signatories carefully consider compliance and reporting.
Response to FRC consultation on Proposed Revisions to the UK Corporate Governance Code
28 February 2018
ShareAction responded to the FRC consultation, supporting moves to simplify the Code and suggesting links between the Governance Code and the Stewardship Code be strengthened to drive businesses to consider their impact on wider stakeholders.
Response to EC Public Consultation on Institutional Investors and Asset Managers’ Duties Regarding Sustainability
6 February 2018
ShareAction has responded to the European Commission’s consultation. We have emphasised that ESG factors and consideration of beneficiaries’ interests constitute a central component of the proper discharging of investors’ duties.
Response to DWP Consultation on Occupational Pensions: Improving Disclosure of Costs, Charges and Investments
20 December 2017
The DWP consulted on proposals to guarantee pension savers the rights to information about costs and charges incurred by their scheme, and where their money is being invested.
Response to the FRC Consultation on Draft Amendments to the Strategic Report
24 October 2017
ShareAction responded to the Financial Reporting Council’s consultation on draft amendments to the guidance on the strategic report. Central to our recommendations was the call for the FRC to ask all companies to report against the key areas of non-financial information which are applicable across all sectors.
Response to ESMA’s Consultation on Certain Aspects of the MiFID II Suitability Requirements
17 October 2017
In this consultation response to the European Securities and Markets Authority, ShareAction argues for the inclusion of the non-financial interests of retail investors in how advisers go about ascertaining the interests of their clients.
Response to CP17/18: Consultation on implementing asset management market study remedies and changes to Handbook
12 September 2017
ShareAction responded to the FCA’s consultation on some of the remedies to its asset management study. We are interested in the proposals to improve independence and transparency of fund managers.
Response to the Questionnaire of the High Level Expert Group on Sustainable Finance
8 September 2017
Responding to the High Level Expert Group’s interim report on sustainable finance in July, ShareAction submits its concrete recommendations to inform the Group’s final report expected by the end of 2017.
Response to FCA on Proposal to Create a New Premium Listing Category
1 September 2017
ShareAction is submitting a response to the FCA’s consultation on creating a new premium listing category for state-owned enterprises. We have answered all questions bar 7, 9, and 11.
Public consultation on the operations of the European Supervisory Authorities
23 May 2017
The work of ESAs will be especially significant in the context of Brexit. Our submission focused on supervisory convergence, fiduciary duty, credit-rating agencies, and the centrality of sustainability to financial stability.
Green Paper on Security and Sustainability in Defined Benefit Pension Schemes
12 May 2017
ShareAction submitted a consultation response to the Department of Work and Pension (UK) regarding the Green Paper on Security and Sustainability in Defined Benefit Pension Schemes, focusing on questions two and three.
BEIS Industrial Strategy Green Paper
13 April 2017
ShareAction submitted a response to the Green Paper on Building our Industrial Strategy, focusing on questions relating to factors constraining companies and fund managers from making longer-term investment decisions.
Department for Work and Pensions – Initial Questions for the Review of Automatic Enrolment
23 March 2017
European Commission – Capital Markets Union: Midterm Review
22 March 2017
Financial Conduct Authority – Asset Management Market Study: Interim Report
22 March 2017
Department for Business, Energy & Industrial Strategy – Green Paper on Corporate Governance Reform
22 March 2017
The Department for Work and Pensions – Defined benefit pensions inquiry
10 October 2016
The Department for Work and Pensions – NEST: Evolving for the Future
5 October 2016
The Pensions Regulator – 21st Century Trusteeship and Governance paper
12 September 2016
The Pensions Regulator – Consultation on guides to support Code of Practice 13
13 May 2016
Department for Business Innovation and Skills – Consultation on non-financial reporting
6 May 2016
European Commission – Non-binding guidelines for reporting of non-financial information by companies
15 April 2016
European Commission, DG Justice and Consumer Affairs – consultation on long-term and sustainable investment
15 March 2016
Department for Communities & Local Government – Revoking and replacing the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2009
19 February 2016
Financial Reporting Council, Draft Plan & Budget and Levy Proposals 2016/17
12 February 2016
The Pensions Regulator – Governance and administration of occupational defined contribution trust-based schemes
29 January 2016
Better Workplace Pensions: Reducing Regulatory Burdens
1 December 2015
HM Treasury Consultation on Strengthening the Incentive to Save
1 September 2015
Closing the Gender Pay Gap Consultation
1 September 2015
European Commission Green Paper on a Capital Markets Union
1 May 2015
FCA and DWP Call for Evidence on Transaction Costs disclosure
1 May 2015
Response to consultation on changes to the Investment Regulations following the Law Commission’s report “Fiduciary Duties of Investment Intermediaries
1 April 2015
DWP consultation on ‘Better workplace pensions: Putting savers’ interests first’
1 November 2014
House of Commons Work and Pensions Committee inquiry on progress with automatic enrolment and pension reforms
1 October 2014
ShareAction’s Response to FCA Consultation CP14/16: Proposed Rules for Independent Governance Committees
1 October 2014
HM Treasury consultation on Freedom and Choice in Pensions
1 June 2014
DWP consultation on Quality standards in workplace defined contribution pension schemes
1 May 2014
Law Commission Consultation on Fiduciary Duties of Investment Intermediaries: Response from ShareAction
1 January 2014
BIS consultation on Corporate Responsibility
1 September 2013
DWP Call for Evidence: Quality Standards in Workplace Defined Contribution Pension Schemes
1 September 2013
BIS consultation on Transparency & Trust: Enhancing the transparency of UK company ownership and increasing trust in UK business
1 September 2013
NAPF Stewardship Disclosure Framework Consultation
1 July 2013
Law Commission Stakeholder Paper on Investors’ Fiduciary Duties
1 June 2013
OECD’s Consultation on Draft High-Level Guidelines for Long-Term Investment
1 May 2013
FCA’s Discussion Paper 13/1 on transparency
1 April 2013
DWP consultation on The Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
1 April 2013
Written Evidence to BIS Select Committee Inquiry into the Kay Review
1 January 2013
Response to the FSA’s ‘Journey to the FCA’ document
1 December 2012
Response to BIS Consultation on Draft Narrative Reporting Regulations
1 November 2012
Suggested Reviews: Review of the UK Stewardship Code
1 July 2012
Review of the UK Stewardship Code
1 July 2012
Red Tape Challenge – Social Investment
1 June 2012
HM Treasury’s inquiry into corporate governance and remuneration
1 May 2012
Written Evidence: DWP Select Committee’s inquiry into governance and best practice in workplace pensions
1 April 2012
Written Evidence: Kay Review of UK Equity Markets and Long-termism
1 April 2012
BIS Consultation ‘Executive Pay: Enhanced Shareholder Voting Rights’
1 April 2012
DWP Consultation, ‘Improving transfers and dealing with small pension pots’
1 March 2012
HM Treasury Consultation, ‘Bank Executive Remuneration Disclosure’
1 February 2012
BIS/FRC Consultation, ‘Proposals to reform the Financial Reporting Council’
1 January 2012
EIOPA Consultation on the IORP Directive
1 December 2011
BIS Discussion Paper on Executive Remuneration
1 November 2011
Kay Review of UK equity markets, ‘Call for Evidence’
1 November 2011
BIS Consultation, ‘The future of narrative reporting: consulting on a new reporting framework’
1 November 2011
HM Treasury’s Consultation, ‘A new approach to financial regulation: the blueprint for reform’
1 September 2011
DWP Select Committee’s inquiry on auto-enrolment
1 August 2011
European Commission Green Paper, ‘The EU Corporate Governance Framework’
1 July 2011
Financial Reporting Council’s Consultation, ‘Gender Diversity on Boards’
1 July 2011
DEFRA, ‘Corporate reporting of greenhouse gas emissions’
1 June 2011
Dept for Work and Pensions’ Consultation, ‘Regulatory differences between occupational and workplace personal pensions’
1 April 2011
The Pensions Regulator’s Consultation, ‘Enabling good member outcomes in work-based pension provision’
1 April 2011
HM Treasury’s Consultation, ‘Reforming Financial Regulation: Building a Stronger System’
1 April 2011
Financial Reporting Council’s Consultation, ‘Effective Company Stewardship’
1 March 2011
Joint Submission with Client Earth
Charity Commission Consultation, ‘Charities and Investment Matters’
1 February 2011
Submission: BIS Consultation, ‘A Long-term Focus for Corporate Britain’
1 January 2011
Ministry of Justice Consultation, ‘Guidance about commercial organisations preventing bribery’
1 November 2010
Scottish Executive Consultation, ‘Public Bodies Climate Change Duties: Putting them Into Practice’
1 November 2010
BIS Consultation, ‘The future of narrative reporting’
1 October 2010
HM Treasury Consultation, ‘A new approach to financial regulation: Judgement, focus, stability’
1 October 2010
European Commission Green Paper, ‘Corporate Governance in Financial Institutions and Remuneration Policies’
1 August 2010
Financial Services Authority’s Quarterly Consultation (proposals relating to Stewardship Code)
1 August 2010
Financial Services Authority’s Consultation on Effective Corporate Governance
1 April 2010
DEFRA Reporting Guidelines for Greenhouse Gas Emissions
1 December 2009
(Joint Submission with Christian Aid and Oxfam)
The Walker Review of Corporate Governance in UK Banks and Other Financial Industry Entities
1 September 2009
The Pensions Regulator – Ideas & Evidence on Responsible Ownership
1 July 2009
Personal Accounts Delivery Authority Investment Consultation
1 May 2009
DWP Consultation on Pension Scheme Disclosure
1 May 2009
Pensions Regulator Consultation on Refreshed TKU Code of Practice and Scope Guidance
1 December 2008
Draft OECD Guidelines for Pension Fund Governance
1 September 2008