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Statements and submissions

UPP comments on jurisdictional sustainability disclosure consultations (2024)

UPP supports the efforts of different jurisdictions to align with the International Financial Reporting Standards (IFRS) Foundation’s International Sustainability Standards Board (ISSB) IFRS S2 Climate-related Disclosures (IFRS S2) and IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) (ISSB Standards). In its submissions, UPP emphasized the importance of standardized sustainability disclosures to investors globally.

2024 Global Investor Statement to Governments on the Climate Crisis

September 2024

UPP signed a global statement calling for policy changes in alignment with 1.5-degree world to accelerate capital flow to clean energy and nature-based climate solutions. The Statement encourages action in areas such as ISSB alignment, removal of fossil fuel subsidies, climate-resiliency, biodiversity, and just net zero transition.

Investor Action on AMR (IAAMR) Public Investor Statement

September 2024

UPP signed a joint investor statement calling for accelerated global action to mitigate antimicrobial resistance (AMR) risks ahead of the second-ever UN General Assembly’s High-Level Meeting on AMR in September. The statement is the main channel for investor input into the meeting.

Joint response to consultation by the Canadian Sustainability Standards Board on sustainability and climate disclosure standard exposure drafts

June 2024

We jointly wrote to the Canadian Sustainability Standards Board (CSSB) in support of their proposal to improve and standardize sustainability-related and climate-related disclosure requirements for Canadian companies. The other authors were CPP Investments, British Columbia Investment Management Corporation (BCI), Caisse de dépôt et placement du Québec (CDPQ), Healthcare of Ontario Pension Plan (HOOPP), Investment Management Corporation of Ontario (IMCO), OMERS, Ontario Teachers’ Pension Plan (OTPP), OPTrust, and PSP Investments.

UPP submission to Canadian Sustainability Standards Board on sustainability and climate disclosure standard exposure drafts

June 2024

UPP submitted comments supporting the Canadian Sustainability Standards Board's (CSSB) efforts to adopt the International Financial Reporting Standards (IFRS) Foundation’s International Sustainability Standards Board (ISSB) IFRS S2 Climate-related Disclosures (IFRS S2) and IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) (ISSB Standards) almost in their entirety for use in Canada.

Investor Statement in Support of Climate Action 100+

May 2024

UPP joined global asset owner peers in this statement of support for the collaborative engagement work of Climate Action 100+ in addressing climate risk. This Statement reiterates our commitment to participate in the initiative and responds to the recent departures from CA100+ by asset managers.

Global Joint Statement on Adoption of ISSB Standards

May 2024

UPP joined 120 global financial markets actors in signing on to a call for commitment from authorities across jurisdictions to adopt the International Sustainability Standards Board Standards to provide a global baseline of economy-wide sustainability information disclosure.

Joint investor submission to Government of Canada consultation on methane regulations

February 2024

UPP made a joint submission with nine other investors to the Government of Canada consultation on proposed methane regulations. We encouraged the government to move forward swiftly to adopt the proposed regulations to provide long-term regulatory certainty, prepare the Canadian economy for the low-carbon future, and help mitigate climate-related risks for investors.

Joint investor statement on UK Corporate Governance and Investor Protections

February 2024

UPP joined global investors with USD $77 trillion in assets under management in signing a public statement to UK authorities convened by the International Corporate Governance Network. The statement expresses concern with proposed reforms to the UK listing regime and emphasizes the importance of robust investor protection and corporate governance standards to the UK’s attractiveness as a global financial centre.

UPP submission to Government of Canada consultation on regulatory framework for oil and gas greenhouse gas emissions cap

February 2024

UPP submitted comments in support of implementation of the proposed emissions cap framework. We emphasized that managing emissions from the sector is necessary to prepare the Canadian economy for the low-carbon future and mitigate systemic risk. We recommend clarifications to ensure effective carbon pricing and support informed investment planning.

UPP response to consultation on CAPSA Guideline: Pension Plan Risk Management

September 2023

UPP submitted a comment to CAPSA welcoming the inclusion of ESG guidance within the risk management Guideline and supporting the overall approach. We encouraged CAPSA to review and update the Guideline at least every five years.

UPP response to Canadian Securities Administrators consultation on proposed corporate governance reforms related to diversity

September 2023

UPP submitted comments in support of the approach outlined in Form B which would provide comparable data and disclosure on equity, diversity, and inclusion beyond gender. We also encouraged the CSA to introduce requirements that issuers set representation targets for board and executive positions.

IIGCC proxy advisor working group sends letter to ISS

August, 2023

UPP was one of 36 global investors who signed a letter to proxy service provider ISS organized by the International Investor Group on Climate Change (IIGCC) calling for improved climate-related proxy voting research and further integration of climate into its Benchmark Policy. The letter asks for increased transparency and a more comprehensive approach to assess board climate accountability and transition plans, as well as more clear and consistent vote recommendations for shareholder-proposed resolutions.

CEOs of leading Canadian pension plan investment managers support inaugural International Sustainability Standards Board (ISSB) standards 

June, 2023

UPP was among 11 of Canada’s leading pension plan investment managers, representing more than $2 trillion in assets under management, to call on companies focused on long-term value to embrace the new International Sustainability Standards Board (ISSB) disclosure framework, launched this week.

UPP response to consultation on the Ontario Securities Commission draft Statement of Priorities for 2023-2024

December, 2022

UPP urged the OSC to adopt a national instrument on climate-related disclosure that is interoperable with international best practice. We supported the priority for expanded diversity disclosure requirements and recommended including policies and targets. We also supported the integration of Indigenous perspectives in OSC work and encouraged adequate resourcing of this priority.

CDP Science-Based Targets Campaign

October, 2022

We joined more than 270 signatories representing more than US $36 trillion in assets to sign letters to 1,061 companies calling on them to set science-based emissions reduction targets aligned with 1.5°C warming scenarios.

Joint submission to Government of Canada consultation on options to cap oil and gas greenhouse gas emission

September, 2022

We joined 9 other Canadian financial institutions to express support for additional federal policy measures to reduce emissions in line with Canada's 2030 and 2050 targets. We emphasized that managing emissions is critical to mitigate systemic risk, that failure of Canada's oil and gas sector to decarbonize could exacerbate access to capital challenges, and that reducing and eliminating methane emissions should be an immediate priority.

UPP response to consultation on CAPSA Guideline: ESG Considerations in Pension Plan Management

September, 2022

We commended the Canadian Association of Pension Supervisory Authorities (“CAPSA”) for undertaking this important work and putting forward the draft Guideline. We particularly welcome the clarification that using ESG factors to provide financial insight is consistent with an administrator’s fiduciary duty and suggested some improvements to ensure actions are encouraged alongside considerations and to ensure pension plan disclosures address both ESG considerations and stewardship activities.

2022 Global Investor Statement to Governments on the Climate Crisis

September, 2022

We joined more than 500 signatories representing more than US $30 trillion in assets to sign a statement urging governments around the world to implement specific priority policy actions to ensure their plans and policies are aligned with the goal of limiting the global temperature rise to 1.5C, they support the implementation of the Global Methane Pledge to reduce emissions by at least 30 percent from 2020 levels by 2030, scale up the provision of climate finance for mitigation and adaptation, and strengthen climate disclosures across the financial system.

Joint response to consultation by the International Sustainability Standards Board on sustainability-related and climate-related disclosures for investors

July, 2022

We jointly wrote a letter to the International Sustainability Standards Board (ISSB) in support of their proposal to improve and standardize sustainability-related and climate-related disclosures for investors. The other authors were Alberta Investment Management Corporation (AIMCo), British Columbia Investment Management Corporation (BCI), Caisse de dépôt et placement du Québec, Healthcare of Ontario Pension Plan, Investment Management Corporation of Ontario (IMCO), OMERS, Ontario Teachers’ Pension Plan, and PSP Investments.

Joint response to consultation by the U.S. Securities and Exchange Commission’s (SEC)’s on proposed enhancement and standardization of climate-related disclosures for investors

June, 2022

We jointly wrote a letter to the SEC in support of their proposal to improve and standardize climate-related disclosures for investors. The other authors were Alberta Investment Management Corporation (AIMCo), British Columbia Investment Management Corporation (BCI), Caisse de dépôt et placement du Québec, Healthcare of Ontario Pension Plan, Investment Management Corporation of Ontario (IMCO), OMERS, Ontario Teachers’ Pension Plan, and PSP Investments.

30% Club Canadian Investor Group: updated statement of intent

March, 2022

We joined 20 other Canadian investors signing a statement that calls on publicly-traded companies to take prompt and considered action to achieve and exceed a minimum of 30% women on boards and at the executive management level and to enhance the presence of other underrepresented groups on their boards and among their executive managers.

Joint letter to members of the Canadian Securities Administrators

March, 2022

Along with seven other investors and with the assistance of the Shareholder Association for Research and Education we jointly wrote to securities regulators across Canada to request enhanced requirements regarding 1) the disclosure of the representation of underrepresented groups on corporate boards and in executive officer positions, and 2) mandatory target setting for representation of women and underrepresented groups on boards and in executive officer positions, and timelines for implementation.

UPP response to consultation on proposed National Instrument 51-107 Disclosure of Climate-related Matters

February, 2022

We expressed support for enhanced disclosure requirements and encouraged the Canadian Securities Regulators to impose more stringent requirements than proposed that would better address the urgency of our need to transition to a sustainable, resilient, low-emissions society and the rapidly increasing climate-related disclosure expectations of issuers and investors globally.

Canadian Investor Statement on Climate Change coordinated by the Responsible Investment Association

October, 2021

We joined more than 35 other Canadian investors signing a statement that calls on companies to act on material climate risks including through their industry association and lobbying activities and commits us as investors to take actions to support the goal of achieving global net-zero emissions by 2050 or sooner.

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