As outlined in SASBs recent SEC comment letter: Climate risk can be broken down into three broad categories: physical (e.g., extreme weather), transition (e.g., technological and market shifts), and regulatory (e.g., government imposition of carbon price or other regulation). If the SEC intends to require broad ESG disclosure, it should be candid about its goals and provide a solid basis for any rulemaking initiatives, so that it does not exacerbate regulatory risk. Among other things, the Regulation introduces the concept of principal adverse impact of investment decisions on sustainability factors and requires disclosure where a covered firm has elected to take these into account. The Template developed by the ESG IDP establishes a baseline [] Please read our, ESG IDP Methodology for Identifying Credit-Materiality, Alternative Credit Managers Launch ESG Integrated Disclosure Tool, ESG IDP Vice Chair Jeff Cohen Explains Our Industry-specific Methodology. International Integrated Reporting Council (IIRC) . Alternative credit managers launch ESG integrated disclosure tool | News and press | PRI 8th November 2022 - A group of leading alternative asset managers and industry bodies in the private and broadly syndicated credit markets have today announced the launch of the ESG Integrated Disclosure Project (ESG IDP) template. (go back), 4See CDP, Why disclose as a company, available here. "OHA is excited for the launch of the ESG IDP as a tool to promote ESG integrated analysis, engagement, and harmonize ESG data collection and reporting in broadly syndicated loan and private credit markets," said Jeff Cohen, Managing Director, Head of ESG & Sustainability at Oak Hill Advisors and ESG IDP Vice Chair. The SEC could establish a temporary non-enforcement period during which companies can work on data collection, internal processes, and controls. The environmental, social, and governance (ESG) disclosure landscape is evolving rapidly. Whether they wish to preserve or expand it, both traditionalists and progressives agree that the existing disclosure framework was designed for a specific purpose and in its current form is ill-suited to the informational needs of stakeholders and society at large. Its success now requires adoption, which we strongly urge, together with the other ESG IDP supporters., Michael Kashani, Head of ESG Credit at Apollo and the inaugural Chair of the ESG IDP, stated, I am thrilled to be a part of the ESG IDP as it represents an important step in addressing ongoing ESG disclosure challenges in the private credit markets. Required fields are marked *. We believe that the technology-enabled disclosure of the EDCI metrics within the template will provide better information for both LPs and GPs to drive improvements over time on critical issues., Radhika Mehrotra, Associate Director, Capital Markets, CDP North America, said: CDP recognizes the value of the ESG Integrated Disclosure Project (ESG IDP) and how it aims to increase the availability and comparability of material ESG disclosure for both LPs and GPs investing in the private and broadly syndicated credit markets., Gemma Lawrence-Pardew, Head of Sustainability, Director Legal, Loan Market Association, stated: Reliable and accurate ESG information is vital in order for investors to channel capital into sustainable activities and companies. Jiri Krol, Global Head of the Alternative Credit Council, said: SMEs and mid-market businesses require a more proportionate approach to ESG disclosure than large public corporates. The ESG IDP is an industry initiative led by the Alternative Credit Council, Loan Syndications and Trading Association and United Nations-supported Principles for Responsible Investment that brings together leading lenders to improve market transparency and accountability. Key takeaways. We use cookies to improve your experience on this website. This receivership has far-reaching effects on companies across many, March 10, 2023 - On March 8th, the LSTA and LMA jointly hosted their annual London conference. (go back) Moreover, they were promulgated pursuant to a call by the European Parliament to create disclosure requirements that take account of the multidimensional nature of corporate social responsibility (CSR) and the diversity of the CSR policies implemented by businesses matched by a sufficient level of comparability to meet the needs of investors and other stakeholders as well as the need to provide consumers with easy access to information on the impact of businesses on society. In her view, [t]he SEC would be acting, by contrast, without predicate acts by political bodies endorsing the substantive ends sought. In the current era of partisanship, SEC actions to adopt broad new requirements for policy purposes without a solid foundation of authority are likely to be swiftly challenged. The ESG Integrated Disclosure Project provides a clear and transparent approach for the disclosure of ESG information, and provides clarity to companies regarding the information investors need. Potential liability for ESG disclosures would be significant under the draft bill: It is the sense of Congress that ESG metrics, as such term is defined by the Commission are de facto material for purposes of disclosures under the Securities Exchange Act of 1934 and the Securities Act of 1933. As it is clearly incorrect that ESG metricsno matter how they are ultimately definedwould de facto be material to all issuers under the federal securities laws, this last provision seems intended to create a vast new category of private rights of action. David A. Katzis partner and Laura A. McIntosh is consulting attorney at Wachtell, Lipton, Rosen & Katz. Over time, they have been incorporated in a growing number of ESG assessment frameworks. If the only people who feel safe to comment are those who want the agency to join the fight against climate change and those whose business models would benefit from new regulation, we will miss hearing from those voices who can alert us to the hidden costs and unintended consequences of our actions. ESG IDP represents an important step in addressing ESG disclosure challenges in the private credit markets, said Michael Kashani, Head of ESG Credit at Apollo Global Management and ESG IDP Chair. Set yourself apart with in-demand ESG skills covering everything from ESG fundamentals to financial analysis to human capital management, and earn an ESG Certificate upon completion. For more information, visit www.lendingforgrowth.org. If consequential new policy is to be made, or the mandate of the SEC expanded, there should be public debate regarding the need for predicate legislative action such as was taken in the European Union. Chief among them is the opportunity to participate in the decision making process that ultimately establishes loan market standards, develops market practices, and influences the markets direction. We are pleased that Novata was able to move so quickly to integrate the template in their platform so that firms can leverage this framework as they collect their ESG data.". [2] In the words of the FSB, [d]isclosure of climate-related financial information is a prerequisite for financial firms not only to manage and price climate risks appropriately but also, if they wish, to take lending, investment or insurance underwriting decisions based on their view of transition scenarios. Approximately two thirds of FTSE 100 companies referenced TCFD in their 2019 annual reports, an increase from 39% in 2018. The tool includes a set of general, industry-agnostic questions which offer a baseline ESG assessment of the borrowers business, as well as industry-specific questions, that have been sourced from the SASB standards. Successfully Handling Ransomware and Other Cybersecurity Incidents, Corporate Practice of Medicine Financings, Private Credit Industry Conference on Direct Lending and Middle Market Finance, Morningstar LSTA Leveraged Loan 100 Index Stats, Collapse of SVB and What it Means for the Loan Market Presentation, Collapse of SVB and What it Means for the Loan Market Replay, 2023 LSTA and LMA Joint London Conference Presentations. The PRI was launched in April 2006, and since then the number of signatories has grown from 100 to over 3,000. Investors increasingly demand disclosures within established ESG frameworks. SEC efforts to drive corporate policy also could implicate fundamental corporate law and governance issues. 17 Mar 2023 Financial Services How software-driven revolution will redefine the automotive industry 17 Mar 2023 Automotive The template is accessible to anyone. While the SEC no doubt wishes to avoid driving more public companies to go private in reaction to ESG rulemaking, the implications of such an approach must be carefully considered. The LMA are delighted to support such a valuable project.. The LSTA is a not-for-profit trade association that is made up of a broad and diverse membership involved in the origination, syndication, and trade of corporate loans. 2022 saw the launch of a first-of-its-kind effort for credit markets - the ESG Integrated Disclosure Project (ESG IDP). [Source]. This post is based on a recent Paul Weiss memorandum by Mr. Bergman, Mr. Karp, Mr. Rosen,Ariel J. Deckelbaum,Jeh Charles Johnson, and Loretta E. Lynch. The SEC has a longstanding reputation as a fair and neutral regulator. We believe that the most useful ESG disclosures will be grounded in the specific issues that are relevant to the particular company, as opposed to generic ESG disclosures that may or may not apply in a companys individual circumstances.. The new tool aims to offer a series of benefits to private credit market stakeholders, including improving the consistency of disclosures for investors to help identify and assess industry-specific ESG risks in their portfolios, and providing borrowers with greater certainty on the ESG indicators that are most relevant to lenders, and to focus on specific disclosures. The purpose of an ESG disclosure is . [8] The PRI called on investors to engage in discussions around corporate reporting and to consider how data are used in the investment chain. JP Morgan estimated that assets in ESG funds doubled in 2020, to over $7.2 trillion. -2.2% one-year net investment return. The ACCs core objectives are to provide guidance on policy and regulatory matters, support wider advocacy and educational efforts and generate industry research with the view to strengthening the sectors sustainability and wider economic and financial benefits. These new metrics help promote greater harmonization and consistency of disclosure of key ESG indicators for borrowers in private credit and syndicated loan transactions. ESG Financial Regulation is Coming. It is likely, too, that the SEC will consider whether private companies should also be required to make ESG disclosure requirements. For more information, visitwww.lsta.org. CDP Global (formerly the Carbon Disclosure Project) is an international non-profit organization that has established an environmental disclosure platform, which collects standardized information from companies on climate change and the use of natural resources such as water and soft commodities. FunctionAccounting & FinanceBusiness Development & SalesCustomer SupportFacilitiesHR & TalentInvestingLegalMarketing & CommunicationsOperationsProcurement & ContractingR & DStrategySupply Chain & DistributionSustainabilityTechnologyOther, ESG investing news, analysis, research and information. Supported by the United Nations, it works to understand the investment implications of ESG factors and to support its international network of investor signatories in incorporating these factors into their investment and ownership decisions. 4437037 Mark Segal November 8, 2022 A group of alternative asset managers announced today the launch of the ESG Integrated Disclosure Project (ESG IDP) template, a new tool aimed at providing a standard format for ESG disclosures for the private credit market. This point is a matter of concern to issuers, as reflected in the comment letter submitted by Uber Technologies: [W]e encourage the Commission to consider requiring that companies perform a company-specific materiality assessment to identify the ESG issues most relevant to their businesses. The ESG IDP aligns with sponsor interests and addresses questionnaire fatigue felt by companies., Catherine Isabelle, Senior Director, Responsible Investment, PSP Investments and Lead of the EDCIs Private Debt Working Group, member of the EDCI Steering Committee, said: The ESG Data Convergence Initiative (EDCI) supports the inclusion of EDCI metrics within the ESG Integrated Disclosure Project template. The ACC is an affiliate of AIMA and is governed by its own board which ultimately reports to the AIMA Council. The ESG Integrated Disclosure Project template is intended to provide a standard format for ESG-related disclosures and to offer companies a baseline from which to develop their ESG reporting capacity. The project is led by the Alternative Credit Council-the private credit affiliate of the Alternative Investment Management Association-the . In November the ACC, LSTA and PRI launched the ESG integrated Disclosure Project (ESG IDP) to establish a global baseline for ESG disclosure across the private and broadly syndicated credit markets through the harmonization of widely adopted frameworks and standards. In a move to improve transparency and consistency regarding environment, social and governance disclosures for private companies and credit investors, a group of alternative asset managers have launched a template for ESG disclosure. [9]. This carries significant risks both for the SEC and for market participants. Today, 150 financial institutions, representing over $24tn in assets under management, have called on world leaders to adopt an ambitious post-2020 Global Biodiversity Framework at the UN Biodiversity Conference COP15. For more information, please visit https://www.novata.com/. ESG reporting by borrowers in the private credit and syndicated loan markets has not advanced quickly enough to effectively meet growing investor and regulatory demands. It may be helpful for the SEC to begin by requiring principles-based disclosure while companies develop the internal workstreams necessary to generate and audit the data underlying ESG metrics. In November the ACC, LSTA and PRI launched the ESG integrated Disclosure Project (ESG IDP) to establish a global baseline for ESG disclosure across the private and broadly syndicated credit markets through the harmonization of widely adopted frameworks and standards. As investors, regulators, and broader stakeholders continue to intensify expectations for meaningful performance disclosure around how business strategies consider ESG risks and opportunities, the role of Finance could not be more central. Jointhe ESG Today daily newsletter and get all the top ESG stories, like this one. There are many responsible investment practices that are now widely practised among the PRIs investment manager signatories. Alternative Asset Managers Release Tool for ESG Disclosure, S&P Global Settles Mortgage-backed Security Case with SEC, 2023 Retirement Plan Adviser of the Year Finalists, Senators Propose Repealing Social Security Cuts to Public Pensioners, Human Interest Targeting 401(k)s for Hourly Workers, Financial Finesse to Launch Financial Literacy Certification Program for All US College Athletes, A Reminder to Avoid Fraudulent Hardship Withdrawals, With SECURE 2.0, the Cash Balance DB Plan May Be Back, Many Providers Are Prioritizing Participant Financial Advice in 2023, OneAmerica Teams Up With Benartzi on New Retirement Income Product, An SEC Update: Marketing Rule Implementation and Reg BI Enforcement, 2022 RPAY - George Fraser, Fraser Group at RBG. Timely and reliable data is critical to effective ESG performance management. The ESG Integrated Disclosure Project template was created by the Alternative Credit Council, the private credit affiliate of the Alternative Investment Management Association, the Loan. Profile Advisors for LSTARich Myersrmyers@profileadvisors.com, AIMADrew NicolAssociate Director, Research and Communicationsdnicol@aima.org, PRIRojn KiadehActing Head of Pressrojin.kiadeh@unpri.org, Apollo Global ManagementJoanna RoseGlobal Head of Corporate Communicationscommunications@apollo.com, Oak Hill AdvisorsNatalie HarvardHead of Investor Relations & Partnernharvard@oakhilladvisors.com. If ESG-focused funds continue to attract capital at growing rates, issuers may face more pressure to adapt their disclosures accordingly. The number of ESG disclosure standards and frameworks continues to grow. Hubbell Incorporated (est. Furthermore, good faith estimates, assumptions, and predictions should be protected in order to maximize the decision-useful information provided to investors. Investors are increasingly recognising the need for biodiversity and nature-related data, even as still nascent information streams prove difficult to navigate. We are delighted to officially launch this resource harmonization is the critical next step in improving the availability of consistent, reliable ESG information and furthering the responsible growth of ESG in credit markets., Carmen Nuzzo, Head of Fixed Income at the PRI, stated: Taking the cue from the PRIs ESG Factor Map, which pointed out the substantial overlapping of many competing ESG standards and frameworks, this new template will allow private creditors to have a bigger voice during the investment process. Lloyd warned, however, that it is important for stakeholders to understand that a wider project with more of a focus on integrated reporting would involve "trade-offs" on other aspects of the ISSB's work and resources. Conflicts in CLOs: Non-Existence is No Excuse! Novatas framework builder is the proprietary in-platform tool used to create custom reporting frameworks that allow users to easily request ESG reports to each firms individual needs. Producing ESG disclosures and other communications aligned with leading frameworks (e.g., GRESB, CDP, DJSI) Designing ESG performance targets and accompanying strategies and achievement plans The U.S. Securities and Exchange Commission has indicated that ESG disclosure regulation will be a central focus of recently confirmed SEC Chair Gary Genslers tenure. This conference was aimed at senior and middle management professionals working in the UK, Europe, and the US and it was an ideal opportunity to, Alternative Credit Managers Launch ESG Integrated Disclosure Tool, LSTA/Refinitiv Mark-to-Market Pricing Data, Morningstar LSTA Leveraged Loan Index Analysis, Register for The Corporate Lawyers Guide to Credit Agreements. (go back), 9SASB, Press Release, Promoting Clarity and Compatibility in the Sustainability Landscape: GRI and SASB announce collaboration (July 12, 2020), available here. A growing, disruptive cutting-edge technology is actually helping humans and society. "The ESG IDP is an important initiative to harmonize lender requests for ESG information and identify the ESG factors that are most material to lenders, in turn enabling consistent expectations for the borrower community," said Lorraine Spradley Wilson, Chief Impact Officer and Head of ESG at Novata. This page aims at providing clarity on the difference between the two, as well as the current offering landscape. The Novata platform provides customers with a clear on-ramp for selecting ESG metrics, painless data collection and data insights and analytics tools to inform investment decisions. The ESG Integrated Disclosure Project (ESG IDP) sought to prioritize the most relevant ESG questions for credit investors. 1888) is a $4.9 billion revenue global manufacturer of electrical and utility solutions that support energy infrastructure, grid modernization, electrification, resource . What are the Principles for Responsible Investment? ESG Integrated Disclosure Project (ESG IDP), https://www.businesswire.com/news/home/20221129005429/en/. This week we cover February's Softer Secondary; Sustainability Guidance; ISO Rosetta Stone. If ESG disclosure is mandated for the purpose of driving changes in corporate behavior, then it may be likened to other types of regulation, such as taxes, that affect corporate behavior and require democratic legitimization. As regulators largely were slow to grasp the direction of travel in the ESG space, which was exacerbated in part by the sheer breadth of the topic (and perhaps more importantly the sheer breadth of the disparate elements that comprised the E, the S and the G), international and non-governmental organizations stepped in to fill that void, principally in respect of the E. We describe below the principal disclosure regimes that have developed in recent years. Posted by David A. Katz and Laura A. McIntosh, Wachtell, Lipton, Rosen & Katz, on, Harvard Law School Forum on Corporate Governance, by Lucian A. Bebchuk and Roberto Tallarita (discussed on the Forum, by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita (discussed on the Forum, by Alan Ferrell, Hao Liang, and Luc Renneboog (discussed on the Forum, by Leo E. Strine, Jr. (discussed on the Forum, The Illusory Promise of Stakeholder Governance, Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American EconomyA Reply to Professor Rock, ESG Disclosure Simplification Act of 2021. The ESG IDP is an important initiative to harmonize lender requests for ESG information and identify the ESG factors that are most material to lenders, in turn enabling consistent expectations for the borrower community, said Lorraine Spradley Wilson, Chief Impact Officer and Head of ESG at Novata. If you continue to use this site we will assume that you are happy with it. It is unclear how much ESG-related information is financially material in the conventional sense, meaning that broad ESG disclosure requirements risk being seen as policymaking rather than content-neutral regulation. 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The ESG IDP aligns with sponsor interests and addresses questionnaire fatigue felt by companies., Catherine Isabelle, Senior Director, Responsible Investment, PSP Investments and Lead of the EDCIs Private Debt Working Group, member of the EDCI Steering Committee, said: The ESG Data Convergence Initiative (EDCI) supports the inclusion of EDCI metrics within the ESG Integrated Disclosure Project template. While the SEC traditionally has required disclosure of financially material information, its new leaders are clearly considering requiring reporting of ESG-related information whether or not it is financially material. By simplifying and harmonising existing market practices, this new industry-led initiative will reduce the burden on borrowers while improving the materiality and comparability of ESG disclosure for investors. Home / News & Resources / News / Alternative Credit Managers Launch ESG Integrated Disclosure Tool. We are delighted to officially launch this resource harmonization is the critical next step in improving the availability of consistent, reliable ESG information and furthering the responsible growth of ESG in credit markets., Carmen Nuzzo, Head of Fixed Income at the PRI, stated: Taking the cue from the PRIs ESG Factor Map, which pointed out the substantial overlapping of many competing ESG standards and frameworks, this new template will allow private creditors to have a bigger voice during the investment process. As such, there is no one set of metrics that properly covers all ESG issues for all companies. The ESG IDP module, housed in Novatas framework builder, provides a simple and intuitive way for users to collect ESG information needed to fulfill their loan and credit reporting responsibilities. 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