All consultation submissions

BEIS consultation on audit and corporate governance

12 July 2021

ShareAction responds to the Department of Business, Energy and Industrial Strategy’s (BEIS) consultation, Restoring trust in audit and corporate governance: Consultation on the Government’s proposals.

We make seven key recommendations to ensure the Government’s proposals on audit and corporate governance go further, including:

The UK should match the ambition of the EU on corporate sustainability reporting
A new resilience statement should be introduced and apply to all companies
The FRC should introduce a new Public Interest Report and the Government should consider public interest reporting in its 2023 review

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DWP consultation on “S” factors in pensions schemes

17 June 2021

ShareAction responds to the Department for Work and Pensions’ consultation on the Consideration of social risks and opportunities by occupational pension schemes.

We call on the Government to require schemes to take action to ensure relevant “S” data initiatives are adequately funded, embed a social taxonomy in the UK regulatory framework and accelerate work around investor due diligence. We also comment on the Just Transition and recommend a joined-up approach to financial regulation with a “placed-based” focus in the real economy.

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BEIS consultation on mandatory TCFD

4 May 2021

ShareAction responds to the Department of Business, Energy and Industrial Strategy’s (BEIS) consultation, Consultation on requiring mandatory climate-related financial disclosures (TCFD) by publicly quoted companies, large private companies and Limited Liability Partnerships (LLPs).

We advocate for disclosure in line with TCFD’s 11 recommendations, mandatory scenario analysis and compulsory reporting of Scope 3 emissions, to take urgent action on climate risk.

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Second feedback on EU proposal for a European single access point for corporate data

15 April 2021

ShareAction has provided its second feedback on the EU’s proposal for a single access point for financial and non-financial information publicly disclosed by companies.

ShareAction continues to strongly support the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. We have highlighted in this consultation response that the access point should put sustainability data on an equal footing with financial data and ensure the data is publicly available for all stakeholders.

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Scottish Government Climate Change Engagement Strategy consultation

31 March 2021

ShareAction responds to a Scottish Government strategy consultation on climate change engagement, with reference to the Glasgow COP26 summit.

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Feedback to European Banking Authority on Remuneration Policies

19 March 2021

Significant changes to the dominant business model which is based on prioritising short-term profits at the expense of gender equality, is urgently needed. To develop remuneration policies that are gender equal, investment firms need to close the gender pay gapacross their workforce and account for how their business operations are inhibiting better female participation. We therefore strongly support the European Banking Authority’s efforts to ensure investment firms have in place gender neutral remuneration policies for all staff as part their internal governance arrangements.

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FRC 2021/22 strategy consultation

12 March 2021

ShareAction responds to the FRC’s strategy consultation for 2021/22.

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Department of Work and Pensions Climate Risk Governance and Reporting Consultation

12 March 2021

ShareAction responds to the Department of Work and Pensions’ (DWP) consultation, Taking action on climate risk: improving governance and reporting by occupational pension schemes.

We welcome the important step taken by DWP in developing a regulatory framework for mandatory TCFD reporting by pension schemes. However, we outline further measures needed to take action on climate risk, including developing a framework that addresses how investment portfolios are Paris-aligned and urging the UK Government to take a clear and joined-up approach to implementing TCFD.

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Treasury Select Committee Future of Financial Services inquiry

19 February 2021

ShareAction responds to a Treasury Select Committee inquiry into post-Brexit regulation of UK financial services.

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Treasury Future Regulatory Framework review

19 February 2021

ShareAction responds to the Treasury’s review of how the post-Brexit UK financial services industry is regulated.

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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.

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FRC Future of Corporate Reporting consultation

5 February 2021

ShareAction responds to an FRC consultation considering the future of corporate reporting regimes.

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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.

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TPR Pensions of the Future consultation

16 December 2020

ShareAction responds to a consultation on TPR’s 15 year strategy.

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Welsh Parliament consultation on the Well-being of Future Generations Act (Wales) 2015

27 November 2020

ShareAction outlines the role responsible investment can play in the implementation of the Well-being of Future Generations Act (Wales) 2015.

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Feedback Inception Impact Assessment on EU Sustainable Corporate Governance

8 October 2020

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 main recommendations are:

1) Review executive remuneration for it to also be linked to longer-term sustainability targets
2) Complement the definition of directors’ duty of care with the necessary enforcement and implementation mechanisms against a backdrop of ever-decreasing direct ownership, short share-holding periods and issues with the exercise of voting rights.
3) Adopt an effective mandatory due diligence framework based on existing practice such as the OECD Due Diligence Guidance for Responsible Business Conduct.

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DWP Climate risk reporting by occupational pension schemes consultation

7 October 2020

ShareAction responds to a DWP consultation on proposals to improve climate risk reporting and governance by trustees of occupational pension schemes.

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DEFRA consultation on Due Diligence on Forest Risk Commodities

5 October 2020

ShareAction responds to a DEFRA consultation on proposals to improve due diligence in supply chains in relation to forest risk commodities.

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FCA consultation on climate-related financial disclosures for listed issuers

1 October 2020

ShareAction responds to an FCA consultation, outlining why mandatory climate-related financial disclosure should be applied beyond listed issuers.

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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.

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TPR consultation on DB investment code of practice

2 September 2020

ShareAction responds to TPR’s proposals for its investment code of practice for DB pension schemes.

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BEIS Select Committee Future of Audit inquiry

1 September 2020

ShareAction comments on proposals in the Kingman and Brydon Reviews for a future UK auditing regime.

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BEIS Response to Post-pandemic Economic Growth Inquiry

28 August 2020

ShareAction has provided feedback to the Department of Business, Energy and Industrial Strategy Select Committee’s Post-pandemic economic growth inquiry.

The Government’s recovery package should prioritise the principles of resilience, security and sustainability. To do this, we recommend the Government improve the economic security of those in lower incomes, require companies to consider the long-term risks and impacts of their business strategies and make future financial support for business conditional on the adherence to a number of sustainable initiatives.

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Treasury Select Committee follow-up inquiry on Decarbonisation and Green Finance

28 August 2020

ShareAction responds to a follow-up to the Treasury Select Committee’s 2019 inquiry, examining the impact of Covid-19 on decarbonisation and green finance.

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Environmental Audit Committee inquiry on Greening the post-Covid Recovery

14 August 2020

ShareAction outlines why responsible investment is needed to secure a green economic recovery from the Covid-19 pandemic.

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Labour Party Policy Commission on Work, Pensions and Equality

20 July 2020

ShareAction responds to a Labour Party Policy Commission, outlining policies to ensure the pensions industry factors in ESG issues more effectively.

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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.

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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).

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BEIS Reforming Regulation Initiative survey

11 June 2020

ShareAction responds to a BEIS survey, outlining priorities for regulatory reform in order to promote responsible investment.

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BEIS Select Committee consultation on possible future inquiries

29 May 2020

ShareAction outlines its proposals for an inquiry into mitigation of financial risk associated with factors such as labour rights and obesity.

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Labour Party consultation on Internationalising the Green New Deal

21 April 2020

ShareAction responds to a consultation by the Leader of the Labour Party, Sir Keir Starmer, outlining why a ‘Green New Deal’ must include reform of the investment system.

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Environmental Audit Committee consultation on possible future inquiries

15 April 2020

ShareAction outlines its proposals for a follow-up inquiry to the Committee’s 2018 Green Finance inquiry.

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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.

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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.

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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.

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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.

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Treasury Select Committee inquiry on Decarbonisation and Green Finance

2 August 2019

ShareAction responds to the Treasury Select Committee’s inquiry into how to decarbonise the UK economy at the pace required of the climate crisis.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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