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ESG Controls & Procedures May Include ESG Disclosure Committee

By Randi Morrison posted 11-15-2021 07:59 PM

  

Should Public Companies Establish an ESG Disclosure Committee?” from Bass Berry & Sims walks through considerations relevant to determining whether to establish a management-level committee focused on ESG disclosures that is distinct from the company’s SOX disclosure committee.

In addition to the trend toward SOX disclosure committees also reviewing sustainability-related disclosures, as noted in the “Disclosure committee report - Practices and trends” report included in last week's Society Alert, this recent publication from Skadden Arps and the Society: “Enhancing Disclosure Controls and Procedures Relating to Voluntary Environmental and Social Disclosures” (reported on here) addresses the formation of a new disclosure committee or use of the company’s existing disclosure committee and related considerations as part of a broader mix of disclosure controls & procedures for voluntary environmental and social disclosures. This recent publication from the Society and Thompson Hine: "ESG Governance: Board and Management Roles & Responsibilities" (reported on here) discusses, among other things, approaches to management-level ESG committees and ESG governance disclosure.

See “Pressure-Testing Your ESG Commitments” (Corporate Counsel) and additional resources on our Disclosure Committees and Sustainability pages.

                                     This post first appeared in the weekly Society Alert!

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