On July 29, the Society submitted this comment letter in response to the International Sustainability Standards Board (ISSB) exposure drafts relating to standards for general sustainability-related disclosures and climate-related disclosures. In that the proposed ISSB standards raise many of the concerns the Society recently articulated in its comment letters submitted to the SEC in response to former Commissioner Allison Herren Lee’s request for public input on climate change disclosures and the Commission’s proposed rule on climate-related disclosures, our ISSB comment letter (which includes our SEC comment letters in the Appendix) largely references relevant provisions of those comment letters, as well as concerns raised in our recent engagement with representatives of the Value Reporting Foundation (now part of the International Financial Reporting Standards (IFRS) Foundation, as noted below).
The Society thanks Travelers Companies, Inc. Vice President, Chief Sustainability Officer and Group General Counsel and former Society Sustainability Practices Committee Chair (and current Society board member), Yafit Cohn; NextEra Energy, Inc. Vice President – Governance and current Society Sustainability Practices Committee Chair, Scott Seeley; Latham & Watkins Partner Betty Huber; and Latham & Watkins Associate Brett Frazer, for their invaluable engagement and drafting participation. The Society also thanks IFRS Foundation Director of Corporate Outreach and Society member Neil Stewart for his ongoing engagement with the Society on these consultations.
The Value Reporting Foundation, composed of SASB and the Integrated Reporting Framework, has now been consolidated into the IFRS Foundation. The ISSB is one of the two standard-setting boards of the IFRS Foundation. The other standard setting board is the International Accounting Standards Board (IASB). See SASB’s “Answering your top five questions about the ISSB and SASB Standards.”
Access additional comment letters submitted to the ISSB on the draft general sustainability-related disclosure standards and climate-related disclosure standards here and here, respectively, and additional resources on our Sustainability and Climate Risk & Disclosure page.
This post first appeared in the weekly Society Alert!