NAM Lays Out ESG Disclosure Priorities
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Across the country, manufacturers are deeply involved in efforts to improve their climate stewardship and take action on a wide range of environmental, social and governance (ESG) issues. Manufacturers are leaders in everything from combatting climate change to enhancing diversity and inclusion in the workforce—and in ensuring that investors understand everything that goes into this critical work.
Recently, the Securities and Exchange Commission began considering a disclosure framework that could require companies to provide standardized information on their climate and ESG commitments. The agency has opened a comment period to receive public input on what the framework could include, and the NAM is making sure that manufacturers’ voices are heard.
NAM Senior Director of Tax and Domestic Economic Policy Charles Crain recently spoke to us about this issue, describing manufacturers’ priorities and concerns. Here’s what you need to know.
The challenge: Many companies already voluntarily disclose a great deal of information about their climate and ESG efforts—both because they are proud of the work they do, and because they believe it’s important for investors to have all the information available, Crain says. However, a one-size-fits-all SEC mandate could create more problems than it solves by imposing costly or overly broad requirements that do not provide useful information to shareholders.
Our move: This week, the NAM laid out the manufacturing industry’s perspective for the SEC, including a list of principles that should guide the agency’s decision-making. Those principles include the following:
- Materiality: The NAM believes that companies should be required to disclose information only if it is material to their business—that is, company-specific, relevant, useful information that would change a reasonable investor’s view of a company.
- Flexibility: Different items are material for different companies. Disclosures shouldn’t be one-size-fits all, but should instead include the kind of company-specific information that will reflect the diversity of risks and opportunities that businesses face and thus be useful to investors.
- Clarity and comparability: The current lack of standardization can create costs and uncertainty for both companies and investors. Within a flexible, materiality-driven framework, the SEC can enhance the clarity and comparability of climate and ESG information disclosed by businesses.
- Limiting company costs and liability: New SEC mandates shouldn’t overburden companies with high costs or a strict liability burden—both of which could result in limited or boilerplate reporting that isn’t useful to investors. Many of companies’ climate and ESG goals are aspirational and rely on evolving reporting methodologies, and the SEC shouldn’t disincentivize aggressive goal-setting on these issues.
- Appropriate scope and reasonable timelines: The data the SEC is describing isn’t just sitting on the shelf. In order to disclose climate and ESG information under a new framework, many companies could have to build out data collection infrastructure, go deep into the supply chain, and get information through standardized methodologies that may not currently exist. This process will be time-consuming and difficult, and the SEC will need to tailor any requirements accordingly and give companies time to adapt.
- Don’t reinvent the wheel: Many companies are already disclosing climate and ESG information based on existing methodologies, and there are plenty of third-party standards for reporting this data. Rather than starting from scratch, any SEC framework should align with existing practices that many companies are already using.
Next steps: The SEC will consider the NAM’s recommendations, along with other feedback, as it works toward a potential rule proposal—and the NAM will continue to engage with the SEC throughout the process.
Manufacturers Unveil Competitiveness Agenda Ahead of Midterm Elections
“Competing to Win” offers a path for bringing the country together around policies, shared values and a unified purpose
Washington, D.C. – Ahead of the midterm elections, the National Association of Manufacturers released its policy roadmap, “Competing to Win,” a comprehensive blueprint featuring immediate solutions for bolstering manufacturers’ competitiveness. It is also a roadmap for policymakers on the laws and regulations needed to strengthen the manufacturing industry in the months and years ahead.
With the country facing rising prices, snarled supply chains and geopolitical turmoil, manufacturers are outlining an actionable competitiveness agenda that Americans across the political spectrum can support. “Competing to Win” includes the policies manufacturers in America will need in place to continue driving the country forward.
“‘Competing to Win’ offers a path for bringing our country together around policies, shared values and a unified purpose,” said NAM President and CEO Jay Timmons. “The NAM is putting forward a plan filled with ideas that policymakers could pursue immediately, including solutions to urgent problems, such as energy security, immigration reform, supply chain disruptions, the ongoing workforce shortage and more. Manufacturers have shown incredible resilience through difficult times, employing more workers now than before the pandemic, but continued resilience is not guaranteed without the policies that are critical to the state of manufacturing in America.”
The NAM and its members will leverage “Competing to Win” to shape policy debates ahead of the midterm elections, in the remainder of the 117th Congress and at the start of the 118th Congress—including in direct engagement with lawmakers, for grassroots activity, across traditional and digital media and through events in key states and districts as we did following the initial rollout of the roadmap in 2016.
The document focuses on 12 areas of action, and all policies are rooted in the values that have made America exceptional and keep manufacturing strong: free enterprise, competitiveness, individual liberty and equal opportunity.
Learn more about how manufacturers are leading and about the industry’s competitiveness agenda at nam.org/competing-to-win.
The National Association of Manufacturers is the largest manufacturing association in the United States, representing small and large manufacturers in every industrial sector and in all 50 states. Manufacturing employs more than 12.8 million men and women, contributes $2.77 trillion to the U.S. economy annually and accounts for 58% of private-sector research and development. The NAM is the powerful voice of the manufacturing community and the leading advocate for a policy agenda that helps manufacturers compete in the global economy and create jobs across the United States. For more information about the NAM or to follow us on Twitter and Facebook, please visit www.nam.org