Tri-State CRI submitted a letter today in response to the Securities and Exchange Commission concept release related to Sustainability Disclosure required by Rule S-K.  In its comment, available here, the Tri-State CRI made the case that companies should be required to disclose more information about key areas of sustainability because it is material information for investors.  This disclosure would facilitate and support our Members’ investment decision making, engagement strategies, and proxy voting.

The Tri-State CRI highlighted specific elements of disclosure that would be appropriate related to Human Rights, Climate Change, Sustainable Agriculture, Water, Financial Practices, and Diversity.  For example, we encouraged disclosure related to human rights risk assessment, Greenhouse Gas emission reduction goals, and governance of sustainability issues.  The Coalition appreciated the opportunity to provide our input, and through this process, we hope to see the SEC require companies to publish more consistent, comparable, and thorough information about environmental, social, and governance criteria that may present long-term systemic risks.