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ESG Disclosure: Engagement Framework

By Randi Morrison posted 08-11-2019 10:44 PM

  

At the Society's National Conference in June, Society Sustainability Practices Committee Chair and The Travelers Companies Associate Group General Counsel Yafit Cohn shared with the Small & Mid-Cap Companies Committee how she went about assisting Travelers with developing a comprehensive approach to navigating the evolving and complex ESG landscape. Instrumental in that process was gaining an understanding of investors' needs and preferences as respects the company's ESG disclosures.

To assist other companies in developing an investor outreach program on this topic to inform their broader ESG initiatives, Yafit directed us to her remarks to the SEC’s Investor Advisory Committee (IAC) in December 2018 (previously reported here - see "SEC Chair Clayton & Others Weigh in on ESG Disclosure"), which include the categories of questions Travelers asked investors, as follows:

As noted earlier, a foundational part of that process was meeting with our large institutional investors, representing half of our shares outstanding, to solicit their views, preferences, and guidance with respect to ESG disclosure. In broad strokes, we sought to understand the following:

  • What do investors mean when they refer to “ESG”?
  • Are investors incorporating ESG into investment decisions and, if so, how?
  • What sources of information are investors consulting in making ESG determinations?
  • Are investors using data and ratings from ESG data providers and surveys, and if so, which
  • ones and to what extent?
  • Do investors look at companies’ ESG or sustainability reports, and if so, do they have a preference for certain reporting frameworks?
  • Which ESG factors do investors think are most relevant to a property & casualty insurance company? What makes a strong sustainability report, and what advice do investors have for companies seeking to enhance their ESG reporting?

The questions - as well as the company's takeaways from that exercise (summarized in Yafit's remarks) - are instructive for other companies to consider, build upon, and tailor to their own industries and specific facts & circumstances.

          Access additional information & resources on our Sustainability/ESG page. This post first appeared in the weekly Society Alert!

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