1. BlackRock’s voting “democratization” will gain popularity & eventual adoption by State Street & Vanguard, thereby adding yet another drain on management’s investor engagement resources
Larry Fink’s 2022 letter to CEOs outlines an unprecedented systematic change to proxy voting and marks a potentially disruptive inflection point within the conventional proxy voting process.1 According to BlackRock, “this option gives institutional clients in separately managed accounts (SMAs) the ability to exercise their voting decisions on the topics or at the companies that matter most to them.” In other words, BlackRock has opened the door to an entirely new roster of complex stakeholders.
BlackRock’s client base now possesses the ability to directly vote on climate-related and human-capital-related issues. Mr. Finks’ letter specifically reinforces that “this new ecosystem will also pose challenges for CEOs and their companies. Those of us who lead public companies will have a broader set of shareholders with whom to engage. Companies may need to develop new models of engaging with asset owners on their most important voting matters. This may take time to evolve.”
The already intricate world of proactive shareholder engagement just became more complicated. We believe there lies a potential for this broader shareholder class to incorporate new and perpetuate existing adverse biases against the energy sector. The best counter to this approach centers on tactical data organization, mapping to influential disclosure frameworks, data verification, and pre-emptively understanding where potential disclosure and ESG-related performance vulnerabilities exist.
Combined with the impending SEC Climate Disclosure mandate, procuring material ESG data in an organized fashion and rectifying inaccurate ESG scores is also critical. We have already witnessed a dramatic uptick in votes against board members2, and we believe this move from Blackrock initiates a momentous trend that will soon be joined in on by the other members of the “Big Three,” namely State Street and Vanguard.
2. GPs will be required to provide specific ESG-related quantitative data not only to proactively convey material differentiators but just to keep fundraising efforts alive
The regulatory landscape has finally caught up with the disclosure expectations for both debt and equity investors. The SEC Climate Disclosure Mandate is the most obvious example; however, capital markets participants must also account for the corresponding ripple effects stemming from the Sustainable Finance Disclosure Regulation in Europe and the Office of the Comptroller of the Currency updated climate risk management process.3 Regardless of our perspectives and opinion on climate disclosure, the global regulatory market has begun requiring it.
Because of the added complexity now mixed into investor messaging and engagement, we believe the disclosure expectations associated with public companies will quickly trickle into private markets in 2023. We are already beginning to observe large influential investors inform private equity clients that their respective “pencils will drop” if certain ESG-related data points are not provided consistently and quantitatively.
In other cases, requiring ESG data is nothing more than a “check-the-box” exercise. Nonetheless, although not mandated by current U.S. law or regulation, ESG-related data points are still a required part of many large influential investors’ due diligence process. Once again, we advise clients to continue pushing back on burdensome disclosure, but that does not imply ignoring regulatory mandates or investor expectations.
3. Shareholder proposals will become even more focused on ESG data
We expect Blackrock, State Street, and Vanguard to become more aggressive in requesting climate disclosures and directives from public companies. Blackrock voted against 255 directors in 2021 (up from 55 in 2020) and failed to support the management of 319 companies for climate-related reasons in 2021 (up from 53 in 2020).4 In their 2022 proxy voting summary, Blackrock “saw a 133% increase in the number of environmental and social shareholder proposals, many of them more prescriptive than in prior years.”5 Importantly, ~25% of Blackrock’s assets under management are also invested in issuers with science-based targets or equivalent and are striving to hit 75% by 2030.6
Proxy Voting Guidelines released by the “Big 3” place substantial weight on climate disclosure
State Street announced in 2022 that they will launch a targeted engagement campaign with the most significant emitters in their portfolio to encourage and enhance disclosure aligned with their expectations for climate transition plans, which covers ten specific categories, including decarbonization strategy, capital allocation, climate governance, and climate policy.
Beginning in 2023, State Street will “hold companies and directors accountable for failing to meet these expectations.”7 Vanguard has publicly stated on a repeated basis, “we use engagements to better understand public company boards’ oversight of climate risks and opportunities, their climate mitigation plans, and whether their disclosures are effective, comprehensive, and provide shareholders with decision-useful information, including progress on the goals companies have set.”8 This perspective is materialized through Vanguard’s adoption of their “Say on Climate” approach, which includes:
In short, companies, both private and public, must enhance their respective sophistication with GHG modeling, measurement and mitigation.
4. Public companies will strongly pressure their private company partners for ESG data points and policies
Vanguard, BlackRock, and State Street cast about a quarter of votes at S&P 500 companies’ shareholder meetings and it is estimated they could potentially control 40% of those votes within two decades.9 While Vanguard owns approximately $65B in fossil fuel investments,10 BlackRock owns over $260B.11 This exposure, combined with the voting trends previously mentioned, implies the Big Three by themselves possess a tremendous influence on disclosure, not just with S&P 500 companies, but nearly ALL publicly traded companies. Recent studies estimate that nearly 40% of the investable U.S. stock market is now held by passive investors.12 Presumably, BlackRock, State Street and Vanguard represent a substantial portion of this specific investor class.
Additionally, more than one-third of the world’s largest publicly traded companies now have net zero targets, up from one-fifth in December 2020. However, an estimated 65% of corporate targets do not yet meet minimum procedural reporting standards.13 This dynamic leads us to believe there will be immense pressure on public companies to convey as close to a complete picture of emissions exposure as possible – not just for the company, but throughout their entire supply chain.
This trend has already begun – we have worked with several private companies who have initiated and/or expedited ESG-related disclosures due to larger public partners, customers, and vendors mandating such data and information within their respective procurement processes.
5. Water metrics will quickly become an incredibly close second to emissions-related disclosures
Theoretically, society can function over an extended time if emissions continue rising. It wouldn’t be ideal– but society’s functionality is not materially impacted in the near term given the current emissions trend. That said, if the current global emission trend continues, the emissions story for the United States, empirically speaking, looks incredibly promising and optimistic.
Water, on the other hand, does not share such a positive outlook. Not only will drought adversely impact agriculture but given the dependency on hydropower in the western United States, a lack of water stewardship efforts can potentially negatively impact the energy mix. Most importantly, we need to wonder how long society can functionally operate without adequate access to water. Our guess is that such a consideration would be measured in days.
The emissions profile for the United States is trending in an optimistic fashion14
We are observing the broader stakeholder community, including investors, increasing their focus on water stewardship. Two of the largest reservoirs in America, which provide water and electricity to millions, are in danger of reaching ‘dead pool status.’ Lake Mead, in Nevada and Arizona, and Lake Powell, in Utah and Arizona, are currently at their lowest levels ever.15 ‘Dead pool’ status would mean the water level in the dams was so low it could no longer flow downstream and power the hydroelectric power stations.
Water stewardship will increasingly become a top priority over the next 12-18 months
Pragmatically, it does beg the question of why stakeholders seemingly place a disproportionate weight on emissions at the expense of water. Nearly all of California and the central region of the U.S. reflect at least severe drought status as of the beginning of November.16 We observe investors, particularly LPs, recalibrating evaluations to enhance the need for water-related disclosures and data.
6. Scope 3 will not be included in the SEC climate disclosure mandate but will also not go away
The Securities and Exchange Commission missed what was generally considered a self-imposed October deadline. As highlighted by Bloomberg Law, the SEC continues to sift through thousands of public comments and factors in a June Supreme Court ruling that potentially endangers the agency’s normally broad authority to regulate Wall Street.17
We now anticipate the SEC Climate Disclosure Mandate to pass before the end of 1Q23
The delay was attributed to a “technical glitch” that supposedly prevented some feedback on the proposal. Undoubtedly, Scope 3 is the most controversial of the reporting requirements. According to multiple public reports18, Mr. Gensler feared the provisions would bolster court cases to scrap the climate disclosure rules, but Commissioners Caroline Crenshaw and Allison Lee remained adamant in pushing the Scope 3 requirement forward. Lee is no longer on the commission, but her successor, Jaime Lizarraga, has stated repeatedly that investors need carbon footprint disclosures.19
Other recent regulatory developments also provide supporting evidence that Scope 3 reporting is not going to wane any time soon. On November 10, 2022, the Biden-Harris Administration introduced action to address greenhouse gas emissions and protect the Federal Government’s supply chains from climate-related financial risks.20 The proposed “Federal Supplier Climate Risks and Resilience Rule,” would require major Federal contractors to publicly disclose their greenhouse gas emissions and climate-related financial risks and set science-based emissions reduction targets.
We feel Scope 3 remains undefined, ambiguous, and immaterial to establishing valuation premiums and/or asset pricing. In short, our internal analysis supports our opinion that Scope 3 reporting mandates are a waste of resources and represent nothing more than an emotional lever utilized to promote divestment agendas.
On average, companies that report Scope 3 only disclose approximately six of the thirteen categories21
7. The advancement of the carbon markets, particularly offsets, will aggressively continue
The global economy remains fixated on decarbonization, and such focus is only going to intensify. A 2021 World Bank report noted that the “potential of carbon pricing is still largely untapped, with most carbon prices below the levels needed to drive significant decarbonization.”22 The variety of climate-focused announcements, particularly in Europe, have catapulted carbon prices to record highs. For example, regardless of their energy reliability and affordability debacle, Germany’s new coalition government has decided to continue alignment on a decarbonization pathway to 1.5 degrees Celsius.23
As carbon prices rise, companies will increasingly need to set internal carbon prices, which means assigning a cost to their own greenhouse gas emissions. As several regulators see it (including the SEC Climate Disclosure Mandate), a company can utilize internal carbon pricing to offset future risks from climate change when making business or investment decisions. The demand for offsets and the continued development of the carbon ecosystem is further reinforced by several reports indicating companies are not even close to attaining net zero by 2030 or 2050. Of the companies that have implemented a net zero target, less than 10% are currently on pace to achieve it.24 That number becomes even more shocking when you realize that over two-thirds of the S&P 500 currently has some sort of emissions-reduction target in place.25
For management teams to mitigate reputational risk and maintain material credibility, the offset market will have to be assertively tapped into within the next three years. Net zero is essentially the combination of operational efficiencies deriving from disciplined capital allocation and a carbon offset solution. Since operational efficiencies are inherently capped, either because of capital access or asset limitations, we envision an inevitable proverbial “run” on offsets as the market increasingly realizes that net zero on an aggregated macro-operational level is not a realistic or practical reality.
In the current state, offset supply exceeds demand but as demand dynamics materialize over the next twenty- four months, we envision stricter regulatory requirements and investor underwriting within the carbon ecosystem. This will also most likely set in motion a robust secondary market whose inventory is dominated by publicly traded mega-caps who have vast cash reserves on the balance sheet.
8. An “emissions avoided” metric will grow in popularity and utility
For the individuals who feel mandating Scope 3 disclosure is foolish, just wait until you begin to hear about Scope 4. As a quick reminder, Scope 3 emissions are generally defined as the indirect emissions that derive from a company’s value chain. An emerging trend brewing among certain investors, both on the private and public side, is increasingly centered on Scope 4, or the avoided emissions happening outside of a product’s life cycle or value chain. Proponents of Scope 4 reporting typically argue that integrating a Scope 4 metric is crucial when an investor prefers a holistic approach to a firm’s contribution to the Paris Agreement climate goals.
It is worth repeating that we feel both mandating Scope 3 and Scope 4 disclosure is an ineffective and inefficient burden on resources and is not material to determining valuation premium or discount. We also feel that Scope 3 inclusion within the SEC Climate Disclosure mandate will be delayed, but not eliminated. However, we are also realists in the sense that the broader energy space still lacks distinct control over its respective narrative and must aggressively continue efforts to mitigate the learning curve existing among pragmatic and sensible stakeholders.
9. ESG scores will increase in influence but will remain inherently flawed
Spending on ESG data is growing over 20% per year and became a billion-dollar industry in 2021.26 The world’s increased obsession with decarbonization combined with the continued preference for quantitative perspectives has catapulted the demand for ESG-related data points. The capital markets still have not pinpointed a distinct methodology for objectively measuring emissions progress, and for the time being, ESG scores are one of the temporary band-aids attempting to highlight trends.
Unfortunately, as the PEP ESG team has consistently pointed out over the last two years, ESG data, particularly MSCI, is inherently flawed. It is critical to differentiate economic realities and ratings. In most cases, these two concepts are mutually exclusive. Scores do not represent value drivers and value drivers, in most cases, are not adequately integrated within scoring methodologies.
ExxonMobil displayed lower ESG Governance scores than FTX Trading27
Based on our internal analysis, we feel MSCI is more concerned with promoting divestment agendas as opposed to maintaining a differentiating degree of empirical integrity within their platform.28 ESG scores are also increasingly influenced by the public disclosure of policies and protocols we generally take for granted in the United States. Specifically, thoughtful policies on human rights, anti-slavery, and supplier code of conduct will continue to influence overall scoring.
PEP ESG has been incredibly successful in aligning inaccurate ESG scores with economic reality
Nonetheless, several of our clients have been told by investors that eligibility within a portfolio is not possible until ESG scores (across the board) improve. Fortunately, our team understands the rubric and the variety of systematic methodological flaws associated with the scoring process. We have been successful in aligning ESG scores with economic reality, typically resulting in improved ratings for our clients. Regardless of this success, management teams must preemptively and proactively utilize self-identified non-fundamental data to establish economic realities amongst pragmatic generalists.
10. Europe’s Sustainable Finance Disclosure Regulation will quickly trickle into the SEC’s policy on greenwashing
It turns out that just because an asset manager claims to be green does not necessarily mean they are. Several analyses conclude that more than half of the climate-themed funds, which describe themselves with phrases like “low carbon,” “energy transition,” and “clean energy,” fall short of the vision laid out in the Paris treaty.29 As is the case with several other ESG-related considerations, the marketing and PR departments have been provided with too much latitude when it comes to naming conventions within the capital markets. The same could be said for their coinciding influence on the existing energy policy as well. Regarding investor marketing efforts, the Sustainable Finance Disclosure Regulation (“SFDR”) aims at reigning in this rope.
SFDR essentially separates the investment universe into three distinct categories and places the burden of proof upon the asset manager to define which bucket pertains to a given strategy. While “Article 6” represents the investment universe in its entirety, “Article 8” and “Article 9” represent ESG-related attributes and impact strategies, respectively. In other words, asset managers will have to proactively acquire and aggregate specific ESG-related data points to maintain eligibility for certain “green” designations. If asset managers are on the hook for quantitative reporting, then their respective holdings will be also.
Since the SEC has been laser-focused on greenwashing over the last two years, we easily envision a scenario where the regulators in the United States adopt a version of SFDR.30 As a result, maintaining access to both the credit and insurance markets will inherently become more reliable upon quantitative ESG-related reporting and disclosures.
11. Quantitative climate-focused metrics will permanently revise credit underwriting due diligence processes
European banks and insurers already have existing requirements to disclose information on material risks under European and UK legislation. Increasingly, European regulators deem climate-related risks as material. A key example of this development stems back to 2019 when the Bank of England’s Prudential Regulation Authority (“PRA”) issued a “supervisory statement” that established expectations for banks and other regulated firms regarding their consideration of climate risk.31 The specific set of required disclosures very much resembles the Task Force on Climate-Related Disclosures (“TCFD”) and includes governance arrangements, risk management, stress testing and scenario analysis.
The PRA has made it clear that it expects banks and other regulated firms to fully implement the supervisory expectations by the end of 2021. The PRA expects firms to use long-term scenario analysis to inform strategy setting, risk assessment and identification. The PRA intends to scrutinize the metrics and targets that firms are using, their comparability and how they are incorporated into existing risk and governance frameworks. The PRA expects banks and regulated firms to explain what steps they have taken to confirm that, where necessary, capital levels are sufficient to cover the risks to which the firm is, or might be, exposed.32
Given the general trend of European regulation trickling down into the United States and the SEC’s endorsement of TCFD, we feel it is a matter of time before U.S. banks increase the utility of climate-related metrics within credit underwriting.
12. The SEC will attempt to pass through additional incremental human capital management disclosures
In a June 7, 2022, rulemaking petition to the SEC, the Working Group of Human Capital Accounting Disclosure asked the commission to write a rule that would require public companies to give pertinent information to investors so they can assess the extent to which companies invest in their employees. The petition began, “The Working Group on Human Capital Accounting Disclosure respectfully submits this petition under Rule 192(a) of the Securities Exchange Commission Rules of Practice. We ask that the Commission develop rules to require public companies to disclose sufficient information to allow investors to assess the extent to which firms invest in their workforce”.33
The “Working Group” consists of ten academics which includes SEC Commissioners Joe Grundfest and Robert Jackson, Jr. and former SEC general counsel, John Coates who outlined the proposed disclosure table below.34
We feel Human Capital Management templates will eventually enter public disclosures
According to the petition, there has been “an explosion” of companies “that generate value due to the knowledge, skills, competencies, and attributes of their workforce. Yet, despite the value generated by employees, U.S. accounting principles provide virtually no information on firm labor”. The petition requests that the SEC “develop rules to require public companies to disclose sufficient information to allow investors to assess the extent to which firms invest in their workforce”—in the same way that “SEC rules have long facilitated analysis of public companies’ investments in their physical operations.”35
This in large part mirrors the argument promoting non-fundamental reporting laid out by the Sustainability Accounting Standards Board, i.e., “SASB.” A key foundational premise rationalizing the need for human capital management disclosure stems from the disproportional amount of value that now derives from the intangible asset base. In other words, as the proportion of intangible asset value grows on the balance sheet, so does the corresponding need for such disclosure.
Proponents cite several analyses which highlight that in 1975, less than 20% of the S&P 500’s market value was derived from intangible assets such as patents, copyrights or proprietary technology. Today, approximately 90% of the S&P 500’s market value is considered intangible, according to a study on the intangible asset market by Ocean Tomo.36 As is the case with climate-related disclosure, we are categorically against an increased disclosure mandate, but can easily envision a regulatory scenario where it is required.
13. Cyber security disclosure expectations and mandates will also increase in 2023
Two notable developments occurred this year underscoring our feelings that cybersecurity disclosure requirements are imminent. On April 4, the Department of State announced a new agency – the Bureau of Cyberspace and Digital Policy. This bureau includes three policy units: International Cyberspace Security, International Information and Communications Policy, and Digital Freedom.37
The SEC also released proposed rules on cybersecurity risk management, strategy, and governance earlier in the year.38 The proposed amendments would require current reporting about material cybersecurity incidents and periodic reporting to provide updates about previously reported cybersecurity incidents.
The proposal also would require periodic reporting about the following:
While this proposal is controversial on a variety of fronts, namely potentially releasing cyber vulnerabilities to the public, we feel some semblance of the rule will ultimately pass within the next twenty-four months.
14. The Carbon Disclosure Project (“CDP”) survey will grow inutility among global investors
According to their website, CDP is a “not-for-profit charity that runs the global disclosure system for investors, companies, cities, states, and regions to manage their environmental impacts. Over the past 20 years, we have created a system that has resulted in unparalleled engagement on environmental issues worldwide.”39 Earlier in November, CDP and the International Sustainability Standards Board (“ISSB”) announced that CDP will incorporate the IFRS S2 Climate-related Disclosures requirements into its global environmental disclosure platform. The announcement means that CDP’s 17,000+ voluntary users will disclose data structured to IFRS S2 in the 2024 disclosure cycle.40
Many capital markets influencers, including BlackRock, generally consider the “ISSB” (International Sustainability Standards Board) as the future of global sustainability reporting. ISSB was essentially born from consolidating what was known as SASB and CDSB (“Climate Disclosure Standards Board”). The CDSB framework was the basis for recommendations released by the TCFD.41
Yes, there are way too many acronyms jockeying for reporting supremacy, and this exercise quickly becomes a constraint on resources, namely patience. Strategically, clients should interpret these developments as the continued support and emergence of TCFD reporting. Simultaneously, the CDP survey will act as the “scoring arm” of the TCFD reporting framework.
15. Capital markets participants will rethink the utility and pragmatism of net zero commitments
At some point (hopefully) in the not-too-distant future, pragmatic participants within the capital markets are going to realize that the pursuit of net zero is much more meaningful and material than attaining it. Simply put, introducing new functional innovative technologies should begin to drown out marketing fluff and virtue signaling. Unfortunately, there are several ways to game the net zero system and it is clear to us that the concept of net zero has been hijacked by the marketing and PR departments to win social points. True net zero implies business activity and production dramatically decreases throughout the entire supply chain, which is not a viable, aspirational or even realistic solution. Some companies may be able to achieve it through innovation, but systematic adoption of net zero across all industries is an unrealistic goal.
The incentive structure associated with net zero does not necessarily place as much emphasis on the actual innovation and technology required. Broadly speaking, net zero promotes more of a divestment agenda for fossil fuels. Science-Based Targets Initiative, i.e., SBTi, does not even recognize or validate targets set by the fossil fuel industry.42
The emissions profile of the United States has dramatically improved over the last two decades43
Empirically speaking, the world cannot replace fossil fuels within the next ten, twenty or even fifty years. Given the energy mix today and the reliance developing countries continue to have on fossil fuels, we should not be thinking about substitution, but how fossil fuels can be complemented. Moreover, net zero considerations do not account for the variety of geo-political and socio-economic catalysts that influence global energy policy.
The world’s energy mix is ~85% oil, coal and gas44
Therefore, the incentive structure should align more with management teams who can simultaneously display attractive financial returns and improved emissions, safety, waste and water profiles. The data indicates this is already taking place. We feel pursuing net zero for the sake of achieving net zero (as opposed to methodically investing in viable technologies) will inevitably increase the cost of capital and the scarcity value of capital to the point which impedes the long-term ability to foster innovative capabilities. In other words, we should not prioritize rhetoric, marketing and biased agendas over innovation, capital discipline and sound policy.
As the energy sector continues its rebound over the next couple of years, we feel generalist investors will increasingly embrace a pragmatic approach to energy investing and place a greater emphasis on capital deployment strategies that result in a material improvement in emissions performance as opposed to superficial goals. That said, such a shift in mindset will not alleviate pressures on management teams to quantitatively track emissions, human capital, water, and biodiversity data – winning incremental quality capital will still, in part, be contingent on conveying ESG-related expectations.
ACTION ITEMS – RETAKING THE NARRATIVE IS CRITICAL
There remains a tremendous headwind impacting the conventional energy space that is neurotically fixated on eliminating the industry. Unfortunately, the groups responsible for these headwinds also exercise tremendous control over the broader investment narrative and continue to not only influence capital access, but energy policy as well. However inaccurate they turn out to be, once their respective viewpoints are baked into regulatory practice, it will be incredibly difficult to reverse. We feel 2023 is most likely the final opportunity for the energy sector to proactively reclaim the investment narrative. The regulatory environment generally moves at a glacier space, but once it settles on incremental regulatory measures, reversing course and retracting measures rarely occur.
Given the ESG-regulatory wheels are already in motion, and moving at an incredibly swift pace, management must attempt to rectify the existing narrative in the most objective fashion possible. Fighting the battle with superlatives, anecdotes or any other subjective instrument is going to drastically fall short. The conventional energy realm is already playing from behind and the market has not at all accepted the moral case for energy as a viable substitute for disclosure. To mitigate the existing gap, we feel management teams must pre-emptively and proactively take the following action items:
Wherever we stand on the issues, they are not going away, and in many ways, the hand is stacked against the conventional energy industry. The pursuit of quality capital was already a difficult ordeal – adding this degree of complexity into the mix means management teams must implement a much more thoughtful and data-driven approach into their respective messaging. The companies that adopt this perspective will proactively mitigate adverse impacts while the companies that do not will find themselves constantly playing from behind.
Sources
2 https://news.bloomberglaw.com/esg/blackrock-voted-against-255-directors-for-climate-related-issues
3 https://www.occ.gov/news-issuances/bulletins/2021/bulletin-2021-62.html
4 https://news.bloomberglaw.com/esg/blackrock-voted-against-255-directors-for-climate-related-issues
6 https://www.reuters.com/article/climate-change-blackrock-target-idCAKCN2M60EV
7 https://www.ssga.com/us/en/institutional/ic/insights/ceo-letter-2022-proxy-voting-agenda
11 https://www.cbsnews.com/news/blackrock-texas-fossil-fuels-boycott/
12 https://foster.uw.edu/wp-content/uploads/2022/07/1b-Sammon-Chinco-new-title.pdf
13 https://zerotracker.net/insights/pr-net-zero-stocktake-2022
15 https://www.nationalgeographic.com/science/article/partner-content-americas-looming-water-crisis
16 https://droughtmonitor.unl.edu/data/pdf/20221101/20221101_usdm.pdf
18 https://cooleypubco.com/2022/10/20/final-climate-rules-months-away/
20 https://www.sustainability.gov/federalsustainabilityplan/fed-supplier-rule.html
22 https://blogs.worldbank.org/climatechange/state-and-trends-carbon-pricing-2021
26 https://esgclarity.com/esg-data-spending-is-growing-20-per-year/
28 The PEP ESG Team has an entire presentation dedicated to this analysis – contact esg@pickeringenergypartners.com for more information
29 https://time.com/6095472/green-esg-investment-funds-greenwashing/
30 https://www.sec.gov/news/statement/lee-statement-esg-052522
33 https://www.sec.gov/rules/petitions/2022/petn4-787.pdf
34 https://www.jdsupra.com/legalnews/working-group-petitions-sec-to-mandate-3614379/
37 https://www.state.gov/establishment-of-the-bureau-of-cyberspace-and-digital-policy/
38 https://www.sec.gov/news/press-release/2022-39
41 https://www.ifrs.org/about-us/consolidated-organisations/
44 https://ourworldindata.org/energy-mix
