For the above reasons, we support the FCA's proposal to amend the content of the CPR to incorporate an atmospheric viability test alongside a commercial viability test that considers climate risks and guides mineral companies to disclose the financial implications of these risks in their prospectuses. [...] In addition to the proposed common disclosures, we urge the FCA to require the following disclosures: - Whether the bond is being issued in line with the issuer’s framework. [...] Assessments of green bonds that primarily focus on the use of proceeds potentially risk isolating the assessment of the bond from the wider strategy of the company. [...] While the selection of KPIs, the calibration of SPTs and bond characteristics are covered in the FCA’s recommended disclosures, we would welcome disclosures on links between the KPIs/SPTs and the issuer’s transition plan and further expectations on post-issuance reporting and verification. [...] Accordingly, disclosures on the process and rationale for the selection of KPIs should be made with explicit reference to the company’s transition plan, where appropriate, and the selection of SPTs should be made with explicit reference to transition plans, where appropriate, as well as “the strategy of the issuer” as currently proposed.
Authors
- Pages
- 14
- Published in
- United Kingdom
Table of Contents
- Y - 2
- N - 3
- Q35. Do you agree with the proposed minimum climate-related disclosures in the prospectus annexes YN. Please give your reasons. If not what should be changed 4
- N - 4
- Q36 Do you agree with our proposed approach to transition plans YN. Please give your reasons. If your reasons relate to cost or other concerns please provide further detail. 5
- Y - 5
- Q37 Do you have any other comments on the design of our proposed climate disclosure rule 5
- Q38 Do you agree with our proposed approach to addressing sustainability-related information beyond climate through the Technical Note 5
- Q40 Should we provide additional guidance relating to climate disclosures for mineral companies including mining and oil and gas Please give your reasoning and if so how should we do so 6
- Y - 6
- Rationale for Enhanced Climate-Related Disclosures for Mineral Companies 7
- 1. Atmospheric Viability Test addresses a disclosure gap for investors 7
- 2. CPRs commercial viability test should explicitly incorporate the financial 8
- 3. Connectivity to Financial Statements is important for better decision-making 8
- 4. Applicability to Debt 9
- Y - 10
- Q42. Do you agree with the additional voluntary disclosures we are proposing to introduce in prospectuses for UoP bonds Are there other disclosures that you think we should consider 12
- Q43. Do you agree with the additional voluntary disclosures we are proposing to introduce in prospectuses for SLBs Are there other disclosures that you think we should consider 13
