Apr. 16, 2019
April 2019 Mr. Brent J. Fields Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: File No. 4-730, Request for rulemaking on environmental, social and governance (ESG) disclosure Dear Mr. Fields, Quaero Capital is an independent, specialist fund management firm which brings together independently minded investment managers who use original research to provide actively managed strategies for clients in the institutional and wholesale markets. Investing responsibly is at the centre of our investment philosophy and process. Quaero Capital welcomes the opportunity to comment on the request for rulemaking on ESG disclosure, and encourages the U.S. Securities and Exchange Commission (SEC) to develop a comprehensive framework for requiring issuers to disclose identified ESG aspects of each public-reporting company’s operations. As a signatory to the U.N. supported Principles for Responsible Investment (PRI), we support the PRI’s letter submitted March, 2019. For years, investors have been calling upon the SEC to require companies to disclose various types of ESG risks from climate, to human capital management, to political spending, to tax, to human rights, to gender pay ratios. Moreover, in response to increasing demands from investors for long- term performance and risk management information, companies are attempting to provide this information voluntarily. It is time for the SEC to issue comprehensive, standard guidance for public companies’ disclosure of ESG risk. The SEC has clear statutory authority to require this type of disclosure, and doing so will promote market efficiency, protect the competitive position of American public companies and the U.S. capital markets, and enhance capital formation. While many companies struggle to provide investors with ESG information that is relevant, reliable, and decision-useful, the companies that do choose to volunteer ESG information do so in a manner that is episodic, incomplete, incomparable, and inconsistent. By issuing standard disclosure rules, the SEC will reduce the current burden on public companies and provide a level playing field for the many American companies engaging in voluntary ESG disclosure. The SEC received over 26,500 comments in response to its 2016 Concept Release on Business and Financial Disclosure Required by Regulation S-K, the overwhelming majority of which expressed a demand for more and better disclosure in general. Petitions and stakeholder engagement seeking different kinds of ESG information suggest, in aggregate, that it is time for the SEC to regulate in this area. Quaero Capital encourages the Commission to promptly initiate rulemaking to develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful environmental, social, and governance information. Best regards Georgina Parker ESG Analyst Quaero Capital S.A. Rue de Lausanne 20bis CH-1201 Genève www.quaerocapital.com This message is not intended for persons who are citizens of, domiciled or resident in, or entities registered in a country or a jurisdiction in which its distribution, publication, provision or use would violate current laws and regulations. The content of this message is confidential and can only be read and/or used by its addressee. QUAERO CAPITAL is not liable for the use, transmission or exploitation of the content of this message. Therefore, any form of reproduction, copying, disclosure, modification and/or publication of the content is under the sole liability of the addressee of this message, and no liability whatsoever will be incurred by QUAERO CAPITAL. The addressee of this document agrees to comply with the applicable laws and regulations in the jurisdictions where he/she uses the information reproduced in this document. If you have received this communication in error, please delete the e-mail and destroy any copies of it. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. Although email contents and attachments have been checked for any computer viruses or other harmful items, QUAERO CAPITAL does not accept any liability for loss or damage as a result of any such problems.