On 20 April 2022, the UK Financial Conduct Authority (“FCA”) published its Policy Statement PS 22/3 on disclosures regarding diversity and inclusion targets for the boards and executive committees of UK-listed companies. These measures reflect the growing importance of Environmental, Social and Governance (“ESG”) considerations, and have gained particular traction in the financial services sector,
Having completed a two-year training contract at the firm’s London office, Summreen Mahween is an associate in the Corporate Practice Group.
She works on a range of transactional and commercial matters, predominantly advising public and private companies on mergers and acquisitions, corporate restructurings, commercial advisory work, and general corporate governance. Her practice also focuses on capital markets transactions. Whilst her clients are wide-ranging, Summreen has a particular focus on the life sciences and technology industries.
She also has significant experience in financial services and regularly writes about, and advises on, ESG-related developments in the banking sector. Her pro bono work principally consists of advising non-profit organisations on various Business and Human Rights matters.
The OGA’s ESG Task Force
In response to these competing tensions operating on oil and gas companies, the UK’s Oil and Gas Authority (“OGA”) convened a Task Force to set out a number of disclosure and investor reporting requirements for operators and licensees. Whilst those recommendations will not create any regulatory or mandatory reporting obligations for UK oil and gas companies, the UK Government will closely examine them and may use them as guidelines for any potential future legislation in this area.
The Task Force’s initial focus was on the ‘E’ of ESG. In its report on March 8, 2021, it made a number of recommendations for reporting requirements for companies, including:
- Requiring operators and licensees to disclose climate related data in their financial reports, and/or websites;
- Calling on the industry to be mindful of the gap between investor expectations and what is currently reported, encouraging greater disclosure & transparency;
- Stipulating that disclosure should be both quantitative and qualitative with signalled improvements over time; and
- Encouraging senior leadership teams to model the required behaviors internally.
The UK Government recently announced that it is developing legislation that would make it illegal for large businesses operating in the UK to use certain commodities that have not been produced in line with local laws, and require in-scope companies to conduct due diligence to ensure that their supply chains are free from illegal deforestation…