We expect companies to provide complete, comparable, and methodologically robust information that allows investors to assess climate-related risks and low-carbon transition plans. In particular, we look for:
- Climate-related disclosure aligned with ISSB/IFRS S1–S2, TCFD, or equivalent frameworks, including:
- governance mechanisms; identification and assessment of physical and transition climate risks; integration of these risks into corporate strategy, risk management, and financial planning; key metrics and targets. Such disclosures should be clearly sign-posted within existing reports or presented in a dedicated standalone report. Companies should also disclose their transition strategy, describing the key actions required to achieve their GHG reduction targets within defined timeframes.
- Disclosure of Scope 1 and Scope 2 emissions and material Scope 3 categories in line with the GHG Protocol. We expect Scope 3 disclosure only for those categories that are material to a company’s business model. Given methodological complexity, companies should focus on the subset of the 15 categories that genuinely represent their emissions profile.
- Disclosure of medium- and long-term GHG reduction targets for Scope 1 and Scope 2, as well as for material Scope 3 categories. Targets should specify timelines, baseline years, scopes of coverage, and alignment with the company’s overall strategy.
- We expect such targets to be science-based, aligned with pathways consistent with limiting global temperature rise to 1.5°C where possible.
2. Board Oversight of Climate-Related MattersWe expect the board to have clear and effective oversight of climate-related and low-carbon transition risks and opportunities, including responsibility for approving the company’s climate strategy, monitoring progress against GHG reduction targets, and integrating climate considerations into long-term planning.
Where the company does not disclose evidence of board-level (or board committee) oversight of climate-related risk management, we may vote against the chair of the board or other relevant directors responsible for oversight.
Voting Against Directors (Director Elections)XXX may vote against the chair of the board or other relevant independent directors where a company does not demonstrate adequate governance, disclosure, or strategic alignment with the low-carbon transition. Our assessment is based on the completeness and quality of corporate disclosures, the credibility of the company’s climate strategy and targets, and the effectiveness of board-level oversight of climate-related matters.
Companies are expected to provide sufficiently robust climate-related disclosures. These should be aligned with ISSB/IFRS S1–S2, TCFD, or equivalent frameworks and include decision-useful information on governance, strategy, risk management, metrics and targets. We also expect disclosure of Scope 1 and Scope 2 emissions, as well as material Scope 3 categories, consistent with the GHG Protocol.
We also expect companies to set credible, medium- and long-term GHG reduction targets for Scope 1 and Scope 2 emissions, and for material Scope 3 categories where relevant. These targets should be aligned with a 1.5°C transition pathway and based on recognized scientific methodologies (e.g., science-based targets), providing clear milestones and transparency around the baseline, timeframe, and scope of application.
Boards should demonstrate clear and effective oversight of climate-related and low-carbon transition risks and opportunities. This includes transparent disclosure of how climate matters are embedded in board or committee responsibilities, how management is held accountable for delivering on transition plans, and how climate considerations inform strategic and financial decision-making.
