All policy resources
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.
Feedback on EU proposal for a European single access point for corporate data
19 January 2021
ShareAction strongly supports the European Commission’s intention to present a legislative proposal to build a European single access point for corporate data. We see four key priorities for the single access points which will be essential for its success: 1) The single access point’s database must include small companies, non-listed companies, and the data provided must include sustainability data; 2) The public access point should put sustainability data on an equal footing with financial data and give non-financial information the same visibility; 3) The access point must be publicly accessible and free of charge for all citizens; 4) The platform should allow for sector-specific information.
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.
Civil Society Statement: Ten Priorities for the Climate Taxonomy Draft Delegated Act December 2020
15 December 2020

Following the release of the European Commission’s draft Delegated Act (hereafter identified as ‘draft DA’) on the EU Sustainable Taxonomy, we, a coalition of NGOs, think-tanks, experts, scientists, shareholder associations, and sustainable investment associations representing millions of citizens in Europe and the global South, are writing to stress our strong support for an EU sustainable taxonomy rooted in climate and environmental science.
The global climate strikes have consistently made a simple demand: listen to the science. We agree. Just as experts and evidence have been key assets in addressing the COVID-19 pandemic, so too must they, and not sectoral interests, determine our policies to fight the climate crisis. While we recognise that the draft DA has taken into account the recommendations of the Commission’s Technical Expert Group (TEG) on the climate taxonomy to a large extent, we would like to voice substantial concerns that the draft DA has ignored or weakened the TEG’s scientific advice for several activities. We outline the ten most important areas that need to be revised to produce a taxonomy that is based on scientific evidence, supports fully sustainable economic activities, accelerates the shift from unsustainable to sustainable activities, and truly reduces the risk of greenwashing. In addition to these ten priorities, we strongly support the development of an unsustainable taxonomy, which is crucial to reliably identify risky sectors and accelerate their transition.
Alliance for Corporate Transparency Joint Position on NFRD Reform
15 December 2020
The Alliance for Corporate Transparency, of which ShareAction is a member, strongly welcomes the European Commission’s commitment to reform the EU Non-Financial Reporting Directive and explore the development of future mandatory EU non-financial reporting standards.
These processes offer a unique opportunity to address the gaps and shortcomings of corporate sustainability reporting, which in turn will support smoother achievement of EU goals.
Laying the Track: The Race to Zero – The role of asset managers in tackling the biodiversity crisis
10 December 2020
Task Force on Climate-related Financial Disclosures: A ShareAction Briefing for MPs
30 October 2020
Laying the Track: The Race to Zero – The role of asset managers in tackling the climate crisis
14 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.
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
Virtual AGMs in the wake of Covid-19
26 March 2020
Pension Schemes Bill 2019-20: A ShareAction briefing
16 March 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
General Election 2019: ShareAction Manifesto Asks
4 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
Response to Treasury inquiry on 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
Policy Briefing on the Impact of Biomass on Climate
1 May 2019
FCA consultation on proposals to improve shareholder engagement
9 April 2019
FRC: Proposed Revisions to the UK Stewardship Code
9 April 2019
Open letter to MEPs on Taxonomy regulation
27 March 2019
Accelerating Progress & Reaching Scale: Proposals for the future of the Sustainable Finance Agenda
28 February 2019
Will Employees Benefit?
12 February 2019
FCA consultation on climate change & green finance
31 January 2019
DWP consultation on pensions dashboard
28 January 2019
Letter to EU policymakers on disclosure regulation
19 November 2018
Event report: Human Rights Metrics (25 September 2018)
17 October 2018
Pension Costs and Transparency Inquiry
18 September 2018
Response to FRC review call for evidence
6 August 2018
Letter Exchange with Vice-President Dombrovskis, March-July 2018
23 July 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
Promoting Sustainable Finance Through the ESAs Package
1 April 2018
Pensions for the Next Generation: Communicating What Matters
17 March 2018
Human Rights and Finance: What Next for European Union Policy?
8 March 2018
NGO Recommendations for the EU Sustainable Finance Action Plan
8 March 2018
Response to FRC consultation on Proposed Revisions to the UK Corporate Governance Code
28 February 2018
Civil Society Response to the Final Report of the High Level Expert Group on Sustainable Finance
20 February 2018
Who Watches the Watchers? Transparency and Accountability in Workplace Personal Pensions
17 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
NGO Recommendations for the EU Sustainable Finance Action Plan
4 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
Update on the Interpretation of Fiduciary Duty in the UK
12 October 2017
Reforming the Investment System to Promote Good Work
11 October 2017
Reforming the Investment System to Secure a Low-Carbon Future
11 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
The Role of the European Securities and Markets Authority in Sustainable Finance – Cover letter
23 May 2017
The Role of the European Securities and Markets Authority in Sustainable Finance
23 May 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
Stronger Stewardship, Stronger Business: Lessons from ShareAction’s survey
5 April 2017
Building a Resilient and Sustainable Europe: Lessons from ShareAction’s survey
5 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
Letter to DG FISMA on IORPS
8 March 2017
Capital Markets Union Mid-Term Review 2017
21 February 2017
Institutions for Occupational Retirement (IORPs) Directive – Significant Progress on Responsible Investment
13 January 2017
Event Summary: “Brexit: An opportunity to create a more sustainable financial system and Capital Markets Union?”
20 December 2016
Joint Briefing – Shareholder Rights Directive
8 November 2016
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
New UK Pensions Regulator code of practice: a step forward for responsible investment
1 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
Letter to EU Permanent Representation on IORPs
18 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
10 Steps to a Sustainable Investment Sector
1 December 2015
Better Workplace Pensions: Reducing Regulatory Burdens
1 December 2015
Letter to MEPs in the Economic and Monetary Affairs Committee on IORPs
24 November 2015
HM Treasury Consultation on Strengthening the Incentive to Save
1 September 2015
Closing the Gender Pay Gap Consultation
1 September 2015
The OFT’s Report on the Defined Contribution Pensions Market
1 September 2015
Proposed Revisions to the EU Institutions for Occupational Retirement Provision (IORP) Directive
1 September 2015
European Commission plans for a Capital Markets Union
1 June 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
Proposed Revisions to the EU Shareholder Rights Directive
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
A Manifesto for Responsible Investment
1 July 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
Pensions Bill 2013: An opportunity to raise standards
1 June 2013
Queen’s Speech 2013: The future of pensions
1 May 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
The Missing Link: Lessons from the ‘Shareholder Spring’
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
Final Report of the Kay Review of UK Equity Markets
1 August 2012
Suggested Reviews: Review of the UK Stewardship Code
1 July 2012
Review of the UK Stewardship Code
1 July 2012
Lessons from LIBOR: Wider implications of the rate-fixing scandal
1 July 2012
Executive Pay: Analysis of the government’s reforms
1 June 2012
Financial Services Bill: Briefing for peers on Lords Amendment 107
1 June 2012
Red Tape Challenge – Social Investment
1 June 2012
‘Your Say on Pay’ Campaign
1 May 2012
HM Treasury’s inquiry into corporate governance and remuneration
1 May 2012
Queen’s Speech Briefing
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
The Enlightened Shareholder: Clarifying investors’ fiduciary duties
1 March 2012
DWP Consultation, ‘Improving transfers and dealing with small pension pots’
1 March 2012
HM Treasury Consultation, ‘Bank Executive Remuneration Disclosure’
1 February 2012
Financial Services Bill: Second Reading Briefing
1 February 2012
BIS/FRC Consultation, ‘Proposals to reform the Financial Reporting Council’
1 January 2012
Securing Jobs and Growth: Can pension savings aid the economic recovery?
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
Big Society Capital: Unlocking mainstream finance for social impact investment
1 October 2011
The Governance Gap: Ensuring a level playing field for pension savers
1 September 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
JustPay! Living Wage Campaign
1 May 2011
Protecting our Best Interests: Rediscovering Fiduciary Obligation
1 May 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
The 2011 Budget and Plan for Growth
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
Mandatory carbon reporting: A litmus test for the ‘greenest government ever’
1 November 2010
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
Investor Stewardship
1 September 2010
The Operating and Financial Review: Improving Company Reporting on Environmental & Social Risk
1 September 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
Managing Environmental Risk: The Deepwater Oil Spill & its Impact on UK pensions
1 June 2010
Coalition Programme for Government
1 May 2010
The FRC Stewardship Code
1 May 2010
Building a sustainable financial system: institutional investors and climate change
1 May 2010
Financial Services Authority’s Consultation on Effective Corporate Governance
1 April 2010
Responsible Investment: an Introduction
1 January 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