We believe the recommendations by the FSB Task Force on Climate-related Financial Disclosures will contribute positively towards achieving greater certainty about the type of climate related information that preparers of financial information should disclose. Moreover, FESE members actively engage in the UN Sustainable Stock Exchanges initiative to promote sustainable capital markets through which companies are encouraged to perform greater disclosures of relevant ESG issues.

FESE supports high-quality, comparable, consistent, investor-relevant disclosures by listed issuers. We agree that on many occasions imposing a greater disclosure burden on public issuers is appropriate and justified which is also true for requiring issuers to disclose material ESG risks. However, we would not support imposing disproportionate disclosure obligations on listed issues and we would caution against imposing non-market-related disclosure obligations on listed issuers alone. We believe that the relative attractiveness of public markets should be preserved and that it should not be possible to avoid complying with further disclosure requirements by remaining private as this would disincentivize listing and result in decreased overall corporate transparency.

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