It’s ironic that the SEC’s 2010 interpretation of a previous Climate Change 10-k Disclosure ruling of the material impacts to a business is equivalent to a 10k foot race. One thinks the race winner is to be a sustainability leader, but businesses, investors, Wall Street, and legal counsel see risk as well as opportunity. It’s a complex race in 2012 for public companies.
For those of us in the field of sustainability consulting, knowing the perceived constraints to transparent and honest disclosure, the politics of the SEC and other regulatory agencies will enable us to do more informed work with our clients and their stakeholders. Public or private we need to work within a whole dynamic system.
An excellent panel discussion – SEC Climate Change Disclosure Requirements and what you need to know took place in late November at Baruch’s Zicklin Center for Corporate Integrity.
The panelists painted a landscape of conflicting behaviors from all stakeholders interpreting climate change impacts. Part of the issue is the lack of a clear framework for companies about what to disclose or what is material. But I see these as the questions a company might need to discuss, bringing together legal counsel, accounting and business unit leaders. Each holds a valuable perspective. Be proactive and set the race course or wait to follow what others set in your industry.
Climate Change Disclosure Documents:
Download SEC Climate Change Disclosure Ruling Interpretation
Download CERES Disclosing_Climate_Risks_Feb_2011-1
Enlightening questions and comments from the panel discussion:
“climate change or any other sustainability issues are interchangeable”
“the insurance industry is particularly impacted by climate change – think Japan’s earthquake and tsunami”
“is reporting integrated from board to employees?”
“GE Ecoimagination is not visible in SEC filings”
“how will products create less climate change?”
“where do rating agencies enter?”
“is the accounting profession behind disclosures?”
Panelists:
Karoline Barwinski - Research Associate, Assistant Vice President with the ESG Investment Program at ClearBridge Advisors
Jim Coburn, JD - Senior Manager, Investment Programs, Ceres
Adam Kanzer, JD - Managing Director and General Counsel of Domini Social Investments and Vice President and Chief Legal Officer of the Domini Funds
Moderator: Michael J. Greis – Principal, Riverbend Advisors
Companies mentioned:
AES - disclosed $17mm in carbon reduction
Chiquita - disclosed farms affected by floods
Climate Disclosure Standards Board
COSTCO - committed to sustainable seafood species based on consumer demand
Estee Lauder - thorough disclosure example
Puma - mapped their entire supply chain for material impacts
PWC – Carbon Reporting Standards
Siemens - Environmental portfolio of products and solutions
Timberland - CEO promotes sustainability
If you are in the NYC area and interested in sustainability please join us at ODNNY’s - OD and the Sustainable Enterprise with panelists from CSRwire.com, BSR and Deloitte’s Sustainability & Climate Change practice.
Make 2012 the year your enterprise wins the 10-K Climate Change Disclosure race and stays sustainable.
~ Victoria G. Axelrod
