All consultation submissions
BEIS consultation on mandatory TCFD
4 May 2021
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.
Second feedback on EU proposal for a European single access point for corporate data
15 April 2021
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.
Scottish Government Climate Change Engagement Strategy consultation
31 March 2021
Feedback to European Banking Authority on Remuneration Policies
19 March 2021
FRC 2021/22 strategy consultation
12 March 2021
Department of Work and Pensions Climate Risk Governance and Reporting Consultation
12 March 2021
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.
Treasury Select Committee Future of Financial Services inquiry
19 February 2021
Treasury Future Regulatory Framework review
19 February 2021
ShareAction feedback on the EU proposal for an Initiative on Sustainable Corporate Governance
11 February 2021
- 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.
FRC Future of Corporate Reporting consultation
5 February 2021
Feedback to EU Taxonomy criteria on climate change adaptation & mitigation
18 December 2020
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.
TPR Pensions of the Future consultation
16 December 2020
Welsh Parliament consultation on the Well-being of Future Generations Act (Wales) 2015
27 November 2020
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.
DWP Climate risk reporting by occupational pension schemes consultation
7 October 2020
DEFRA consultation on Due Diligence on Forest Risk Commodities
5 October 2020
FCA consultation on climate-related financial disclosures for listed issuers
1 October 2020
ShareAction input to the consultation by the European Supervisory Authorities regarding ESG disclosures under the Sustainable Finance Disclosure Regulation
2 September 2020
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.
TPR consultation on DB investment code of practice
2 September 2020
BEIS Select Committee Future of Audit inquiry
1 September 2020
BEIS Response to Post-pandemic Economic Growth Inquiry
28 August 2020
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.
Treasury Select Committee follow-up inquiry on Decarbonisation and Green Finance
28 August 2020
Environmental Audit Committee inquiry on Greening the post-Covid Recovery
14 August 2020
Labour Party Policy Commission on Work, Pensions and Equality
20 July 2020
Amending sectoral legislation to integrate end-investors’ sustainability preferences
8 July 2020
Raising the bar on corporate disclosure with an ambitious NFRD-Review
17 June 2020
BEIS Reforming Regulation Initiative survey
11 June 2020
BEIS Select Committee consultation on possible future inquiries
29 May 2020
Labour Party consultation on Internationalising the Green New Deal
21 April 2020
Environmental Audit Committee consultation on possible future inquiries
15 April 2020
Response to LGPS consultation on responsible investment guidance
10 January 2020
Response to the Law Commission’s consultation on intermediated securities
29 November 2019
Response to DEFRA’s consultation on its National Food Strategy
4 November 2019
Response to the Pension Regulator’s consultation on trusteeship and governance
10 October 2019
Treasury Select Committee inquiry on Decarbonisation and Green Finance
2 August 2019
Response to FCA Consultation on IGCs
15 July 2019
FCA & FRC Building a regulatory framework for effective stewardship
7 May 2019
FCA consultation on proposals to improve shareholder engagement
9 April 2019
FRC: Proposed Revisions to the UK Stewardship Code
9 April 2019
FCA consultation on climate change & green finance
31 January 2019
DWP consultation on pensions dashboard
28 January 2019
Pension Costs and Transparency Inquiry
18 September 2018
Response to FRC review call for evidence
6 August 2018
Clarifying and strengthening trustees’ investment duties
17 July 2018
Response to FCA/TPR Consultation on Regulating the Pensions and Retirement Income Sector
19 June 2018
Response to BEIS Consultation on Insolvency and Corporate Governance
11 June 2018
Response to FRC consultation on Proposed Revisions to the UK Corporate Governance Code
28 February 2018
Response to EC Public Consultation on Institutional Investors and Asset Managers’ Duties Regarding Sustainability
6 February 2018
Response to DWP Consultation on Occupational Pensions: Improving Disclosure of Costs, Charges and Investments
20 December 2017
Response to the FRC Consultation on Draft Amendments to the Strategic Report
24 October 2017
Response to ESMA’s Consultation on Certain Aspects of the MiFID II Suitability Requirements
17 October 2017
Response to CP17/18: Consultation on implementing asset management market study remedies and changes to Handbook
12 September 2017
Response to the Questionnaire of the High Level Expert Group on Sustainable Finance
8 September 2017
Response to FCA on Proposal to Create a New Premium Listing Category
1 September 2017
Public consultation on the operations of the European Supervisory Authorities
23 May 2017
Green Paper on Security and Sustainability in Defined Benefit Pension Schemes
12 May 2017
BEIS Industrial Strategy Green Paper
13 April 2017
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
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
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