Jun. 15, 2022
June 15, 2022
When approving this disclosure rule, please be sure to include the following:
Ensure that free, prior, informed consent (FPIC) is obtained and recognized as material when consulting with Indigenous communities and any marginalized and frontline groups on resource extractive projects.
Require companies to disclose how they manage climate and community risks related to their business operations and climate mitigation and energy transition processes.
Include reference to the United Nations Declaration on the Rights of Indigenous Peoples in line with other reporting frameworks such as the Global Reporting Initiative and the Sustainability Accounting Standards Board.
Include nature-related financial impacts in climate risk disclosures as modelled by the Task Force on Nature-Related Financial Disclosure.
Require disclosure of Scope 3 greenhouse gas emissions from large companies value chains since in many cases, the majority of emissions are from Scope 3.
Do not allow companies to decide whether or not their Scope 3 emissions are material and remove the safe harbor from liability for false Scope 3 reports.
I urge the SEC to approve the strongest climate disclosure rule and look forward to a positive outcome that supports human rights and communities, the environment, and the economy.