Section of Environment, Energy, and Resources
Environmental Disclosure Committee
Links
The following links and resources are useful in researching and tracking developments in environmental disclosure.
Legally Mandated Disclosure
SEC Regulation S-K
Standard instructions for filing forms under Securities Act of 1933, Securities Exchange Act of 1934, and Energy Policy and Conservation Act of 1975
Statement of Financial Accounting Standards Number 5 - Accounting for Contingencies (www.fasb.org/pdf/fas5.pdf)
EPA Enforcement & Compliance History Online (ECHO) (www.epa.gov/echo)
ECHO provides compliance and enforcement information for approximately 800,000 EPA-permitted facilities nationwide. The site includes permit, inspection, violation, enforcement action, and penalty information about the facilities.
The Rose Foundation (www.rosefdn.org)
The Rose Foundation is an organization dedicated to linking the environment to a healthy economy. In September 2002 the Rose Foundation filed a rulemaking petition with the SEC seeking further regulation of environmental disclosures. The petition can be found on their website.
Voluntary Disclosure
Global Framework for Climate Risk Disclosure
In May, 2005, a global partnership of 14 institutional investors and other organizations representing trillions in assets formed the Climate Risk Disclosure Initiative ("CRDI"). The CRDI includes the California Public Employees' Retirement System (CalPERS), the California State Teachers' Retirement System, Ceres, and the Investor Network on Climate Risk (INCR). In October, 2006, the CRDI released the Global Framework for Climate Risk Disclosure to provide specific guidance to companies regarding the information they provide to investors on the financial risks posed by climate change. The partnership also published an accompanying guide for using the Framework. The Framework consists of four areas of disclosure:
- Total historical, current, and projected greenhouse gas emissions
- Strategic analysis of climate risk and emissions management
- Assessment of physical risks of climate change
- Analysis of risk related to the regulation of greenhouse gas emissions
The Climate Registry (http://www.theclimateregistry.org)
The Climate Registry is a nonprofit partnership created in May, 2007, comprised of corporations, nonprofits, cities and counties from the U.S., Canada and Mexico committed to developing an accurate, complete, consistent and transparent greenhouse gas emissions measurement protocol that is capable of supporting voluntary and mandatory greenhouse gas emission reporting policies for its Members and Reporters. In April, 2008, it unveiled the General Reporting Protocol, which offers a roadmap for consistently calculating, verifying and reporting the emissions. Members may also use the group's General Verification Protocol and an online tool.
The Carbon Disclosure Project (http://www.cdproject.net/)
The Carbon Disclosure Project (CDP) is an independent not-for-profit organization aiming to create a lasting relationship between shareholders and corporations regarding the implications for shareholder value and commercial operations presented by climate change. CDP provides a coordinating secretariat for institutional investors with combined assets of over $57 trillion under management. On their behalf it seeks information on the business risks and opportunities presented by climate change and greenhouse gas emissions data from the world's largest companies: 3,000 in 2008. The CDP website is the largest repository of corporate greenhouse gas emissions data in the world.
US Federal Trade Commission Guides for the Use of Environmental Marketing Claims (the Green Guides), 16 CFR Part 260. (http://www.ftc.gov/bcp/grnrule/guides980427.htm)
The Green Guides were published in 1992 in order to provide guidance to companies making environmental marketing claims. Although the Green Guides are not law, the FTC may take corrective action if conduct inconsistent with the positions articulated in these guides is considered to be unlawful under Section 5 of the FTC Act which prohibits "unfair or deceptive acts or practices" including false or misleading advertising.
CERES (www.ceres.org)
CERES is a U.S. coalition of environmental, investor and advocacy groups that promotes corporate environmental responsibility. The Coalition was prominent in the establishment of the Global Reporting Initiative (GRI) (see link below). The Coalition also encourages companies to endorse the CERES Principles as a public statement of dedication to environmental accountability and improvement.
Global Reporting Initiative (www.globalreporting.org)
The Global Reporting Initiative is a multi-stakeholder process, an independent institution whose mission is to develop and disseminate globally applicable sustainability reporting guidelines. These guidelines are for voluntary use by organizations for reporting on the economic, environmental, and social dimensions of their activities, products, and services. The 2002 GRI guidelines, which are the second iteration of the reporting template, are available at the GRI website.
Commission for Environmental Cooperation (www.cec.org)
The Commission for Environmental Cooperation (CEC) is an international organization created by the governments of Canada, Mexico and the United States under the North American Agreement on Environmental Cooperation (NAAEC). The CEC was established to address regional environmental concerns, help prevent potential trade and environmental conflicts, and to promote the effective enforcement of environmental law. The Agreement complements the environmental provisions of the North American Free Trade Agreement (NAFTA).
Ethical Corporation Online (www.ethicalcorp.com)
Ethical Corporation, through publication of Ethical Corporation magazine, running ethicalcorp.com, and hosting several conferences, is an information source for issues surrounding corporate social, environmental and financial responsibility.
Friends of the Earth - Corporate Accountability (www.foe.org/camps/intl/corpacct/index.html)
Friends of the Earth is the U.S. branch of an international network of grassroots environmental groups. In the disclosure arena, FOE promotes greater corporate social responsibility through the International Right-to-Know policy and advocates the increased integration of environmental and social data into financial and corporate decision-making. The group has also published various studies and reports evaluating the adequacy of corporate environmental disclosures.
Innovest (www.innovestgroup.com)
Innovest is an investment research and advisory firm specializing in analyzing companies' performance on environmental, social, and strategic governance issues. Recent publications include a summary of socially responsible investing developments and practices, as well as several industry-specific reports.
The International Corporate Environmental Reporting Site (www.enviroreporting.com)
A general information site focused on corporate environmental reporting. The site includes international news updates and links to related sites.
World Resources Institute (www.wri.org)
WRI, an environmental think tank, explores issues at the intersection of environmental protection and economic development. Their projects range from local to global in scale and include research into industry-specific risks and issues. For example, in 2002, WRI published "Emerging Environmental Risks and Shareholder Value in the Oil & Gas Industry."
United Nations Environment Programme
UNEP Activities in Business and Industry (www.unep.org/themes/business/)
The UNEP Business and Industry division encourages government and industry to develop and adopt policies, strategies and practices that are cleaner and safer, make efficient use of natural resources, ensure environmentally sound management of chemicals, reduce pollution and risks for humans and the environment, enable implementation of conventions and international agreements, and incorporate environmental costs. The Business and Industry division also links to the United Nations Global Compact and the Global Reporting Initiative.
UNEP Activities in Environmental Assessment (http://www.unep.org/themes/assessment/)
UNEP oversees projects such as the Global Environment Outlook, an overview of environmental developments over the past decades, and UNEP.net, a gathering of environmental information based on themes and regions.
