Janine Guillot, CEO, Value Reporting Foundation has written to the US Securities and Exchange Commission outlining the Foundation’s ongoing support for efforts to build alignment in the reporting landscape, with the merger of the IIRC and SASB a significant step towards simplification.

The letter set out seven key positions and recommendations the Value Reporting Foundation has for the US Securities and Exchange Commission, given the crucial role the Value Reporting Foundation believes the SEC can play in advancing the coherence that both investors and businesses have called for in sustainability disclosure:

• Sustainability information is market infrastructure essential to making informed investment and voting decisions
• The SEC should consider the full range of sustainability factors that investors analyze in their assessments of enterprise value, in addition to climate change
• Industry-specific disclosure is critical to investment decision making, including with respect to climate risk
• Strong governance and a robust, transparent due process are essential to ensure sustainability standards can evolve along with the market
• Existing standards and frameworks – including the SASB Standards and the recommendations of the Task Force on Climate-related Financial Disclosures – can help the SEC establish a common structure for sustainability-related financial disclosure that includes an appropriate mix of qualitative and quantitative information, as well as cross-industry and industry specific metrics
• The use of third-party standards that meet specified criteria (e.g. SASB Standards) can have a range of benefits, including the provision of investor-focused disclosure on the sustainability issues reasonably likely to be financially material for the typical company in an industry
• The SEC should continue to engage in the efforts of the IFRS Foundation to ensure international coherence.