Accordingly, manufacturing companies will likely need to consider and quantify the impact of environmental factors on both the upstream and downstream aspects of their business and the metrics by which to measure and report that impact. While the rule proposal is simply that - a proposal - manufacturers should expect much of the proposed package to become part of the agency’s mandatory disclosure regime. The Commission is under considerable pressure from investors and Congress to take action as promptly as possible. The SEC has announced a very small window (no more than 60 days) in which to receive comments to this rule proposal. Appropriate maintenance of any such system would require rigorous assessment of the adequacy of design and operating effectiveness of those controls. If adopted, the rule would impose on publicly-held manufacturers significant obligations not only to make these disclosures but also to establish an extensive system of disclosure and accounting controls needed to ensure the periodic capture, assessment, and dissemination of a company’s exposure to climate-related risk and impact on the environment. The SEC’s efforts to promote greater transparency on corporate environmental impact culminated on March 21, 2022, with the promulgation of a proposed rule setting forth a sweeping array of new requirements for detailed disclosure of those risks and costs, with particular attention to greenhouse gas (GHG) emissions. Sandy Winer | Clarkson | Kirwan | Pearson | Slack | Tomasi | Vedvig | response to increasing demand by the investment community over the last dozen years, the Securities and Exchange Commission (SEC) has published guidance calling for greater disclosure by public companies of the risks and costs of climate change on their businesses.
Subscription Model Regulation Trends and TakeawaysĬorporate Environmental Impact: SEC Proposes Detailed Climate-Related Disclosures Introduction.The Latest Patent Developments in China: What Manufacturers Need to Know.2022 Antitrust Outlook for Manufacturers - Significant Changes Under the Biden Administration.Companies that Source from or Operate Abroad Government Scrutiny of Supply Chains Increases Compliance Expectations for U.S. Strategic IP for Protection of Product Manufacturers.Mexico Nearshoring Trends Across the Manufacturing Landscape.CPSC Continues Enforcement Push in the First Quarter of 2022.Manufacturing Employers Face Significant Labor Challenges in 2022.Industry 4.0 Heralds a Sea Change in IP Protection for Manufacturers.Flexible Strategies for Managing Uncertainty in Manufacturing Supply Chains.Hot Topics in Consumer Product False Advertising Class Actions: An Increased Focus on Ethics, Sustainability, and Safety Claims.Human Rights Compliance in Supply Chains.Corporate Environmental Impact: SEC Proposes Detailed Climate-Related Disclosures.As the global economy faces the third year of the pandemic, manufacturers are no longer focused on figuring out when things will return to “normal.” Instead, they are applying lessons learned from the past few years to become even more agile and resilient as they evolve their operations to succeed in this “new normal.” Foley’s Manufacturing White Paper explores the shifts in the manufacturing sector in the detailed sections below.
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