Gibson Dunn Environmental, Social and Governance Update (Summer 2024)

Client Alert  |  September 16, 2024

We are pleased to provide you with Gibson Dunn’s ESG update covering the following key developments during July and August 2024. Please click on the links below for further details.

I. GLOBAL

  1. The Network for Greening the Financial System (NGFS) publishes two complementary reports on nature-related risks

On July 2, 2024, NGFS published two reports. The first report is the final version of the Conceptual Framework for nature-related financial risks, which will provide policy guidance for central banks and financial supervisors. The NGFS published its initial version of this report in September 2023, but the final Conceptual Framework includes two cases to exemplify the application of the risk assessment framework to freshwater and forest ecosystems.

The second report outlines the key emerging trends related to nature-related litigation, including cases concerning biodiversity loss, ocean degradation and carbon sinks, and explores the potential relevance for central banks and the financial system. The two reports are complementary: the Conceptual Framework outlines the broad framework for nature-related risks, the second report aims to raise awareness more specifically about nature-related litigation risks.

  1. The Taskforce on Nature-related Financial Disclosures (TNFD) and Glasgow Financial Alliance for Net Zero (GFANZ) to launch separate consultations on nature and transition plans

On July 4, 2024, the TNFD, a global organization established to provide companies with a framework to quantify and disclose nature-related financial risks and opportunities, announced a new consultation which will focus on what a nature transition plan should include and how it should be disclosed. It will ask organizations to “describe the effect nature-related dependencies, impacts, risks and opportunities” have had on the organization’s business strategy and financial planning. The TNFD plans to publish its final guidance in Q2 of 2025.

GFANZ’s consultation will focus on how nature could be further considered in its net-zero transition plan (NZTP) framework, which will cover how nature-related levers can support net-zero implementation. The GFANZ has 36 members from across the net-zero alliances working on this initiative and aims to publish voluntary supplemental guidance on nature in NZTP in Q1 of 2025.

  1. NGFS publishes information note “Improving Greenhouse Gas Emissions Data”

On July 16, 2024, the NGFS published an information note on improving greenhouse gas (GHG) emissions. The NGFS focuses on GHG emissions data because it is one of the most significant data gaps and is a key factor in monitoring progress towards the transition to a low-carbon economy.

In its note, the NGFS expert network presents practical examples of how NGFS members use GHG emissions data, for example to classify bond issuers based on emission intensity. Such classification of bonds presents numerous practical challenges, such as discrepancies in the calculation of emissions metrics. NGFS’ guidance provides a set of collaborative measures and best practices that can tackle these challenges.

Among other items, the note states that financial institutions need to accelerate their collection of data on financed emissions. It also suggests that central banks, supervisors and regulators could provide information through their websites to increase supervised entities’ awareness of the importance of sustainability indicators.

  1. NGFS publishes their 2023 Annual Report

On July 25, 2024, the NFGS published its Annual Report for the year 2023. In this Annual Report, NGFS announced a growth in membership numbers with 13 new members and two new observers. Among the main issues that the NGFS focused on in 2023 was the potential use of transition plans from a micro prudential perspective, the enrichment of its long-term climate scenarios to prepare a theoretical note which would help develop a first set of short-term climate scenarios to help the financial system assess the economic impact of climate-related risks and held a number of knowledge and best practices sharing workshops, including on climate-related disclosures for central banks. 2023 was also a prolific year for publications as the NGFS also launched works on nature-related risks and a report on blended climate finance on ways to deploy private capital for climate mitigation and adaptation.

  1. Science Based Targets initiative (SBTi) publishes papers as part of its consultation on the SBTi Corporate Net-Zero Standard

On July 30, 2024, the SBTi published four technical papers as an early step in the process of reviewing the SBTi Corporate Net-Zero Standard. The publications focus on reviewing the approach to scope 3 emissions which on average account for 75% of a company’s emissions.

The scope 3 discussion paper outlines the SBTi’s initial considerations for refining scope 3 emissions targets, which includes encouraging companies to focus on reducing critical emission sources instead of relying on carbon credits. The paper outlines scenarios where carbon credits from outside the value chain may support evidence of corporate decarbonization or offset residual emissions, but stresses that credits should not replace direct value chain decarbonization.

  1. The International Accounting Standards Board (IASB) provides illustrative examples on reporting climate-related effects and other uncertainties in financial statements

On July 31, 2024, the IASB published a consultation document with eight different examples on how companies can apply the IFRS Accounting Standards when reporting on the effects of climate-related and other uncertainties in their financial statements, aiming to provide guidance on how the requirements in the Standards should be applied to provide investors with better information about this sort of risks. The illustrative examples come in response to requests from stakeholders concerned that the information they were reporting was insufficient or inconsistent with information provided outside the financial statements, particularly information reported in other general purpose financial reports. The examples focus on areas such as materiality judgments, disclosures about assumptions, credit risk, decommissioning and restoration provisions and disaggregated information. The IASB has opened a consultation process to invite stakeholders to provide feedback on the proposed examples. The deadline for submitting comment letters is November 28, 2024.

In case you missed it…

  1. Banks get International Capital Market Association (ICMA) and Loan Market Association (LMA) guidance on using bonds to fund sustainability-linked loan portfolios

On June 25, 2024, the ICMA and LMA jointly published new Guidelines for Sustainability-linked Loans Financing Bonds (SLLBs). The guidelines recommend transparency and disclosure for issues of SLLBs. For SLLBs to align with the guidelines, issuers must adhere to the four core components, which cover:

  1. the use of proceeds;
  2. the process for sustainability-linked loans evaluation and selection;
  3. the management of proceeds;
  4. and the reporting of information on portfolios.

Per the guidelines, issuers should also explain the alignment of their SLLBs in a framework document and ensure that external reviews are carried out and made publicly available.

II. UNITED KINGDOM

  1. The King’s Speech sets out 40 bill proposals from the new Labour government under which the party aim to boost industry growth and bring major changes to workers’ rights

On July 17, 2024, King Charles delivered the new UK Prime Minister’s legislative agenda in the King’s Speech at the state opening of parliament. Prime Minister Sir Keir Starmer has proposed 40 bills which he claims will commence “a decade of national renewal”. Amongst the bills outlined were several planning and transport proposals including the renationalization of Britain’s rail operators, greater power for local councils to develop their own bus services and the removal of potential obstacles to new housing developments in selected areas.

A notable proposal in the energy sector are plans for a new state-run company, GB Energy, which will be set up to manage and operate Britain’s clean energy projects. The new Labour government also intends to improve worker rights by banning zero-hours contracts which they consider exploitative, end “fire and rehire” practices as a means of employers unilaterally amending workers’ terms and conditions, making flexible working a day one right for all workers and improving access to parental leave and sick pay for new employees. The proposals would also remove previous Conservative legislation which placed restrictions on the ability of trade unions to take strike action which has been welcomed by unions.

  1. The new Labour government sets a record budget for this year’s renewable energy auction

On July 31, 2024, the UK’s Energy Secretary announced a £1.5 million budget for this year’s renewable energy auction, an increase of £500 million from last year’s budget. Each year the UK government holds an auction to encourage companies to bid for green energy projects to supply the UK national grid with electricity, for which they will receive a guaranteed price for the electricity generated from the government. Last year, there were no bids for offshore wind power projects as they were considered unviable due to their low price. In response, the former Conservative government significantly increased the guaranteed price for such projects last year. The new Labour government aims to quadruple Britain’s offshore wind power by 2030, and therefore the majority of this year’s budget will be directed towards such projects.

  1. Financial Conduct Authority (FCA) publishes downloadable labels for distributors subject to Sustainability Disclosure Requirements and investment labeling regime

On July 31, 2024, firms subject to the FCA’s labeling scheme were allowed to begin using the fund labels, which aim to tackle greenwashing. Firms are required to notify the FCA when using an investment label and have until December 2, 2024 to ensure the labeling of their funds are compliant.

The labeling scheme includes four labels for sustainable funds:

  1. Sustainability Improvers: funds that invest in assets that may not currently be sustainable but aim to improve their sustainability profile over time;
  2. Sustainability Impact: funds that invest in assets with clearly “pre-defined, positive, measurable impact in relation to an environmental and/or social impact”;
  3. Sustainability Focus: funds that invest in other sustainable assets; and
  4. Sustainability Mixed Goals: funds that invest in a combination of assets from the above three categories.

To comply with the FCA labeling rules, asset managers need to demonstrate that at least 70% of the fund’s assets support the label of choice.

  1. New bill proposed to regulate ESG rating agencies

On August 8, 2024, the UK’s Chancellor of the Exchequer announced a bill proposed by the new Labour government to regulate ESG rating agencies. ESG rating agencies are unregulated, electing to follow a voluntary code of conduct instead. This bill aims to enhance transparency and accountability in the ESG space and alleviate current concerns about the lack of consistency amongst ESG ratings provided by different agencies. ESG ratings play a key role in the direction of sustainability investments and the current inconsistency has led to investor confusion. It is envisaged that this new legislation will make it easier for investors to make informed decisions, as well as mirroring similar regulatory measures being taken in the EU.

  1. Royal Institute of Chartered Surveyors (RICS) issues new guides on Whole Life Carbon Assessment (WLCA) for the built environment

The RICS 2nd edition was published in September 2023 and is effective from July 1, 2024. RICS members now need to follow the 2nd edition standard’s requirements when completing a WLCA.

The transition from the 1st to the 2nd edition of the RICS WLCA marks a move towards a more comprehensive and integrated approach to carbon measurement in the built environment. The RICS’ guides support the new ‘Whole life carbon assessment, RICS – 2nd Edition’ tool, which was created to meet the requirements of the RICS 2nd edition. The tool will enable measurement of whole-life carbon emissions, manage carbon budgets, reduce life cycle emissions and deliver a net-zero future for the built environment.

The tool can be applied to any type of construction or built asset in the UK involving (i) new constructions or new-build assets; (ii) demolition of existing and construction of new assets; (iii) retrofit or refurbishment of existing assets; and (iv) fit-out of built assets. However, it cannot be used for infrastructure assets or civil engineering works.

  1. Oceana UK files legal challenge, calling recent oil & gas license “unlawful”

Oceana UK has filed a case at the High Court challenging fossil fuel exploration licenses in UK waters. In the claim, Oceana alleges that the previous UK government’s decision to issue 31 new oil and gas licenses in May 2024 was unlawful because it failed to consider the extreme impact of oil spills on marine life, as well as on several other grounds. Oceana and other members of the Ocean Alliance Against Offshore Drilling have now written to Ed Miliband, the Secretary of State for Energy Security and Net Zero in the new Labour government, urging the new government to concede the case and signal a commitment to, and clear departure from, reliance on fossil fuels.

III. EUROPE

  1. European Parliament publishes study on the current implementation of the Sustainability-related Financial Disclosures Regulation (SFDR)

On July 3, 2024, the European Parliament published a study on the SFDR. The study was provided by the Policy Department for Economic, Scientific and Quality of Life Policies at the request of the Committee on Economic and Monetary Affairs.

The SFDR is the centerpiece of the sustainable finance strategy for funds and other financial products. However, its provisions are too complex and don’t interact effectively with provisions shaping corporate reporting, indexes, or client preferences. The study states that a revised SFDR should aim to include more recognizable product labels or categories which will: enable transition investments; smoothly interact with corporate reporting; and expand the scope of disclosure obligations.

  1. The European Securities and Markets Authority (ESMA) issues Public Statement on the European Sustainability Reporting Standards (ESRS)

On July 5, 2024, ESMA published a statement on the ESRS in addition to its final report on the guidelines on enforcement of sustainability information. The public statement on the first application of the ESRS acknowledges the significant changes for the sustainability reporting practices due to the new EU requirements.

Both the statement and the report underline the areas of focus for in-scope companies preparing to issue their first sustainability statements due to be published in 2025 in accordance with the Corporate Sustainability Reporting Directive (CSRD). Significant points include the establishment of governance arrangements and internal controls, designing and conducting materiality assessments, and creating connectivity between financial and sustainability information.

  1. Corporate Sustainability Due Diligence Directive (CSDDD) published in Official Journal

On July 5, 2024, the Official Journal of the European Union published the CSDDD, following its adoption by the European Parliament and the Council of the EU earlier this year. The CSDDD introduces a due diligence duty on large EU companies and non-EU companies with significant EU activity to address adverse human rights and environmental impacts in their own operations, their subsidiaries and their supply chains.

EU member states must transpose the CSDDD rules into national measures by July 26, 2026.

From July 26, 2027, the CSDDD measures will become applicable in stages, based on whether the company is based in the EU, its number of employees and turnover.

Companies can start to prepare by:

  1. conducting risk assessments to identify actual and potential adverse impacts within their own operations, subsidiaries and value chains;
  2. adopting measures to prevent or where this is not possible, minimize the identified adverse impacts; and
  3. preparing suitable and fair contractual assurances to be included in direct and indirect business partner agreements.
  4. New monitoring rules agreed for the EU Emissions Trading System (ETS)

On August 29, 2024 EU Member States represented in the Climate Change Committee endorsed an amendment to the Monitoring and Reporting Regulation proposed by the Commission.

The revisions agreed introduce zero-rating of emissions from the combustion of renewable fuels of non-biological origin, recycled carbon fuels and synthetic low carbon fuels in the EU ETS, subject to compliance with the criteria set out in the Renewable Energy Directive, ensuring that such emissions are properly accounted for.

The changes to the rules also include zero-rating of biomass fuels concerning the use of a recently established EU-wide database; detailed monitoring and reporting requirements for alternative aviation fuels; harmonization of small emitter thresholds; and monitoring and reporting requirements for non-CO2 aviation effects per flight.

  1. The Association for Financial Markets in Europe (AFME) calls for UK’s green alignment with EU on its partnerships with the financial sector to deliver green growth

In its new paper, published last month, the AFME welcomed the UK’s new Labour government’s plans to make the UK a leading center for green finance while simultaneously encouraging the government to recognize that, in order to create opportunities for finance and investment to support green growth, conditions need to be in place to enable the real economy to transition. The AFME recommended that the government prioritize: (i) progression of UK Sustainability Reporting Standards which are aligned with the standards developed by the International Sustainability Standards Board; (ii) consulting on the adoption of transition plan disclosures for listed and unlisted companies; and (iii) following up on the recommendations of the Transition Finance Market Review to facilitate transition finance.

Further AFME recommendations include: (i) scaling up the role of blended finance; (ii) linkage of the UK ETS with the EU ETS; and (iii) before moving forward with delivering a UK Greem Taxonomy, wide engagement with companies and financial institutions to ensure that there is a clear use case for one.

  1. The European Securities and Markets Authority (ESMA) publishes Guidelines on funds’ names using ESG or sustainability-related terms

On August 21, 2024, ESMA, ESMA, the EU’s financial markets regulator and supervisor, published the translations in all official EU languages of its Guidelines on funds’ names using ESG or sustainability-related terms. The Guidelines are aimed at ensuring that investors are protected against unsubstantiated or exaggerated sustainability claims in fund names, and to provide asset managers with clear and measurable criteria to assess their ability to use ESG or sustainability-related terms in fund names. The Guidelines will start to apply on November 21, 2024. Funds created on or after such date will be immediately subject to the Guidelines, while existing funds will be entitled to a six-month transitional period. By October 21, 2024, national competent authorities must notify ESMA whether they: (i) comply; (ii) do not comply, but intend to comply; or (iii) do not comply and do not intend to comply with the Guidelines.

IV. NORTH AMERICA

  1. U.S. Attorneys General seek answers from asset managers regarding support for environmental shareholder proposals

On August 29, a group of 24 attorneys general sent letters targeting the “twenty-five large asset managers . . . who”—between 2020 and 2023—had “voted 75% or more of the time” in support of proposals that Institutional Shareholder Services (ISS) had recommended votes “for” and which Ceres had flagged in its climate-related proposals database. The letter raises concerns that these asset managers had failed in their fiduciary duties by outsourcing their voting responsibilities to ISS or others.

  1. Large asset managers report declining support for environmental and social shareholder proposals during 2024 proxy season

On August 29, Vanguard released its 2024 U.S. Regional Brief disclosing its investment stewardship activities for the past proxy season. Vanguard-advised funds supported none of the 400 environmental and social shareholder proposals considered at U.S. portfolio companies’ meetings. The lack of support was attributed to Vanguard determining that “the proposals did not address financially material risks to shareholders,” “were overly prescriptive in their requests,” or repeated “previously filed proposals that companies [had] taken action to address.” Vanguard also noted that in some cases, it did not find a governance practice or disclosure gap that the proposal would address.

On August 14, BlackRock released its 2024 Investment Stewardship Voting Spotlight regarding its proxy voting and engagement activities in the most recent proxy season. BlackRock supported only 20 of the 493 global environmental and social proposals it voted on during the 2024 proxy season, as a “majority of [such] proposals . . . were overreaching, lacked economic merit, or sought outcomes that were unlikely to promote long-term shareholder value.” BlackRock also noted that some proposals concerned risks that companies had already addressed.  The month before, BlackRock released new Climate and Decarbonization Stewardship Guidelines describing its approach to voting “on behalf of funds with explicit decarbonization or climate-related investment objectives.”

For more information on trends from the 2024 proxy season, including shareholder proposals, see our recent client alert.

  1. Indiana sends BlackRock cease and desist order

On August 23, the office of the Secretary of State, Securities Division of Indiana issued a cease and desist order naming several BlackRock entities as engaged in alleged securities fraud in violation of Indiana law. In particular, the order alleges BlackRock made “various untrue statements of material fact” regarding its use and implementation of ESG standards. BlackRock had previously been placed on a watch list by the state’s Treasurer following the enactment of a law prohibiting the state’s public retirement system from investing assets with firms that use ESG principles in investment decisions.

  1. Interfaith Center on Corporate Responsibility (ICCR) asks Business Roundtable for information on its opposition to the SEC’s climate rules

On August 22, 2024, ICCR announced it had sent a letter to the Business Roundtable (BRT) regarding the amicus brief it filed in June 2024 opposing the SEC’s climate rules. In particular, ICCR noted that the BRT’s position in the brief did “not appear to be aligned with the positions and values of many BRT members” and sought more information about the “governance process” that led to the brief’s submission.

  1. Missouri Court strikes down anti-ESG investment rules

On August 14, 2024, a federal district court in Missouri granted summary judgment and a permanent injunction in favor of the Securities Industry and Financial Markets Association (SIFMA) in its challenge to certain state anti-ESG investment rules. The rules had required securities professionals and firms to collect signed consent forms from investors in the state before including social or nonfinancial objectives in investment advice or securities recommendations. The court held the rules were preempted by federal law and violated the First and Fourteenth Amendments.

  1. Additional briefing submitted in U.S. Securities and Exchange Commission (SEC) climate rules litigation

On August 6, the SEC filed its consolidated response brief in the multi-district litigation challenging the climate-related disclosure rules adopted last Spring (and summarized here). The SEC asserted it had sufficient Congressional authority to adopt the rules; that it complied with the requirements of the Administrative Procedure Act when proposing and adopting the rules; and that the rules are consistent with the First Amendment of the U.S. Constitution. Filings by amici both in support and in opposition to the climate rules were subsequently filed on August 19, 2024. Oral argument has not yet been scheduled.

  1. California State Teachers’ Retirement System (CalSTRS) reports climate-related expectations for portfolio companies and 2024 climate-related voting

On August 1, CalSTRS reported that during the 2024 proxy season, it had focused on climate risk disclosure and voted against the boards of directors at more than 2,250 companies. The press release also summarized the pension fund’s expectation that portfolio companies:

  1. publish sustainability-related disclosure aligned with the International Financial Reporting Standards;
  2. disclose Scope 1 and Scope 2 greenhouse gas emissions; and
  3. for high-emitting companies, including those on the Climate Action 100+ list, to set “appropriate targets to reduce GHG emissions.”
  1. ISS and Glass Lewis release 2024 policy surveys

On August 1, ISS Governance opened its annual benchmark policy survey, soliciting investor views on environmental and social topics such as Scope 3 GHG emission reduction target disclosure and the relevant factors to consider for climate- and workforce-diversity-related shareholder proposals. Responses were due by September 5, 2024.

Glass Lewis opened its 2024 policy survey in July. ESG-related questions focused on whether companies should consider transitioning to a B Corporation; if it is appropriate for an entity’s financial auditor to also be responsible for sustainability reporting assurance; what factors are relevant when voting on Say on Climate proposals or shareholder proposals more generally; whether the identity of a shareholder proposal proponent is relevant in voting decisions; whether information related to climate transition strategies and oversight would be helpful in proxy reports; and what factors would drive a vote against non-financial reporting by certain EU countries. Responses were due by August 30, 2024.

The results of these surveys are expected to inform future updates of ISS and Glass Lewis policies, research, and vote recommendations.

  1. ISS ESG announces new emission intensity solution

On July 31, ISS ESG announced its new industry average emission intensity data as an addition to its current climate solutions offering. The data focuses on supporting insurance companies and banks in their compliance with mandatory disclosures on climate matters.

  1. Republican lawmakers send letter to Climate Action 100+ signatories

On July 30, the chairmen of the House Judiciary Committee and the Subcommittee on the Administrative State, Regulatory Reform and Antitrust issued a press release regarding letters they sent to over 130 government pension programs, companies, and retirement systems seeking information as to “their involvement with the woke ESG cartel Climate Action 100+.”

  1. SEC issues Spring 2024 regulatory agenda

On July 8, the SEC released its Spring 2024 regulatory agenda. Compared to the Fall 2023 agenda, the SEC delayed proposed rules on human capital management from April 2024 to October 2025 and proposed rules on corporate board diversity from October 2024 to April 2025. The agenda also pushed back the timing for adoption of final rules seeking disclosure requirements from investment companies and advisers on ESG factors from April 2024 to October 2024. These timeframes are not hard deadlines for future SEC rulemaking, and the SEC retains flexibility to change this timing further in future agendas.

In case you missed it…

The Gibson Dunn Workplace DEI Task Force has published its updates for July and August summarizing the latest key developments, media coverage, case updates, and legislation related to diversity, equity, and inclusion.

V. APAC

  1. Climate Bonds Initiative (CBI) and the Institute for Global Environmental Strategies (IGES) develop a Transition Strategies Toolkit

On July 29, 2024, CBI and IGES collaboratively released the Transition Strategies Toolkit, a guidance tool based on scientific evidence to promote transition finance in Japanese industries. The toolkit provides guidance for Japanese companies to develop and implement credible, science-based transition plans and for investors to promote investments that support the transition to decarbonization. The Transition Strategy Toolkit builds on the Guidance for Assessing Transition Plans published by CBI in 2023 which outlined key features and frameworks for reliable transition planning. Based on this guidance, the Transition Strategy Toolkit is primarily intended to promote understanding of the basic characteristics and elements that Japanese companies should incorporate when developing transition plans in response to climate change.

  1. Australia’s opposition party calls for an end to the country’s nuclear energy ban

Australia’s opposition party has called for a change in the law to reverse the country’s 1998 ban on nuclear power and has instead pledged commitment to the construction of new nuclear plants. The current government is focused on the rapid phase-out of coal and scale-up of renewable energy sources, passing legislation which targets: a 43% cut in carbon emissions from 2005 levels by 2030; net zero emissions by 2050; and delivery of 82% of electricity from renewable sources by 2030. The government has described the opposition’s nuclear aspirations as too expensive, too slow to build and too risky. Energy policy is likely to remain a prominent issue in Australia in the lead up to next year’s election.

  1. China voices its opposition to the European Union Deforestation Regulation (EUDR)

The EUDR, which is set to take effect in December 2024 and is designed to limit deforestation, requires geolocational data for all forest products imported into the EU. China, a key supplier of forest products such as timber, paper and pulp, has recently voiced its opposition, citing security concerns with the sharing of such data. A potential withdrawal of China from compliance with the EUDR could materially disrupt global supply chains. This development follows resistance from the US, which is pushing for delayed implementation of the EUDR on the basis that it will impose “impossible standards” and act as a non-tariff trade barrier.

Please let us know if there are other topics that you would be interested in seeing covered in future editions of the monthly update.

Warmest regards,
Susy Bullock
Elizabeth Ising
Perlette M. Jura
Ronald Kirk
Michelle M. Kirschner
Michael K. Murphy
Selina S. Sagayam

Chairs, Environmental, Social and Governance Practice Group, Gibson Dunn & Crutcher LLP

For further information about any of the topics discussed herein, please contact the ESG Practice Group Chairs or contributors, or the Gibson Dunn attorney with whom you regularly work.

The following Gibson Dunn lawyers prepared this update: Lauren Assaf-Holmes, Natalie Lamb, Georgia Derbyshire, Magdalena Augé, Alex Eldredge*, Elizabeth Ising, Cynthia Mabry, Michelle Kirschner and Selina S. Sagayam.

Gibson Dunn lawyers are available to assist in addressing any questions you may have regarding these developments. Please contact the Gibson Dunn lawyer with whom you usually work, the authors, or any leader or member of the firm’s Environmental, Social and Governance practice group:

Environmental, Social and Governance (ESG):

Susy Bullock – London (+44 20 7071 4283, [email protected])
Elizabeth Ising – Washington, D.C. (+1 202.955.8287, [email protected])
Perlette M. Jura – Los Angeles (+1 213.229.7121, [email protected])
Ronald Kirk – Dallas (+1 214.698.3295, [email protected])
Michelle Kirschner – London (+44 20 7071 4212, [email protected])
Michael K. Murphy – Washington, D.C. (+1 202.955.8238, [email protected])
Selina S. Sagayam – London (+44 20 7071 4263, [email protected])

*Alex Eldredge, a trainee solicitor in the London office, is not admitted to practice law.

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