1. Proposed Rules
2. Existing rules on environmental and social disclosure
3. The need for expanded SEC corporate environmental and social disclosure
4. Symposiums
5. Sample complaints filed at the SEC for lack of environmental/ social disclosure
6. Studies on companies systematic lack of environmental disclosure
7. Studies on investors' use of non-financial information in decision-making
8. Links
9. International developments in the field of environmental/social financial accounting

- Official SEC rules
- Environmental financial accounting (article, 2000)
- EPA Alert on corporate environmental disclosure regulations (2001)

The need for expanded SEC corporate environmental and social disclosure

- Fooling Investors and Fooling Themselves: How Aggressive Accounting Leads to Environmental Accounting Fraud (paper, 2004)
- The Gap in GAAP: An Examination of Environmental Accounting Loopholes (paper, 2003)
- Off the Books: How Corporations Hide Environmental and Human Rights Liabilities (short film, 2002) and explanatory materials
- After Enron: How Accounting and SEC Reform Can Promote Corporate Accountability While Restoring Public Confidence (journal article, 2002)
- The SEC's Big Challenge (op-ed, 2001)

Symposiums

2004 Capitol Hill Symposium

Coming Clean: Corporate Disclosure of Environmental Issues in Financial Statements. This July 15, 2004 bipartisan symposium was sponsored by 13 Members of Congress on corporate disclosure of material environmental information in financial statements and SEC filings. Read the summary and agenda of the event, along with reports and articles about corporate disclosure of environmental issues.

2003 Capitol Hill Symposium

Environmental and Social Disclosure and the SEC: Meeting the Information Needs of Today's Investors. The July 10, 2003 symposium was sponsored by 12 Members of Congress and featured remarks from Sens. Corzine (D-N.J.) and Nelson (D-Fla.), as well as SEC Commissioner Harvey Goldschmid and Connecticut State Treasurer Denise Nappier. An agenda plus background materials, a press release with speaker statements, and a rulemaking petition are available. A complete summary of the event is also available.

Sample complaints filed at the SEC for lack of environmental/ social disclosure

- Dow Chemical: Trillium Asset Management and Boston Common Asset Management sought an SEC investigation of on Dow's allegedly misleading statements regarding environmental and personal injury liabilities. (2004)
- Abbot Laboratories: Healthcare Without Harm filed a complaint at Abbot Laboratories on the company's lack of disclosure with respect to the health risks posed by PVC in medical supplies. (2001)
- Scotts Company: Friends of the Earth-US teamed up with Friends of the Earth-UK filed a complaint alleging that the company neglected to disclose impending environmental regulations to investors in its annual report. (2001)
- Bunge, Ltd.: Friends of the Earth filed a complaint regarding Bunge Ltd's inadequate disclosure of environmental liabilities in its registration statement. (2001)
- PetroChina: Friends of the Earth alleged that PetroChina did not adequately disclose issues regarding political risk in its registration statement. (2000)
- Crown Petroleum: The United Steelworkers of America alleged that Crown Petroleum did not report the financial losses to the company caused by a boycott. (1999)
- Phelps Dodge: The United Steelworkers of America filed a complaint alleging that the company failed to report material environmental liabilities in their annual report. (1998)

Studies on companies systematic lack of environmental disclosure

- Silence is Golden, Leaden & Copper, an examination of the disclosure of material environmental information in the hardrock mining industry (2004)
- Duty to Disclose, a review of food companies' SEC filings, revealing a lack of reporting on the risks of genetically engineered ingredients (2004)
- SEC Should Explore Ways to Improve Tracking and Transparency of Information, a report by the Government Accountability Office (2004)
- Cooking the Books, Scorching the Planet, a 2003 survey of auto, oil & gas, petrochemicals, utilities and insurance companies' climate change disclosure (2004)
- Coming Clean, a report by World Resources Institute on forestry companies' lack of environmental disclosure (2000)
- EPA survey results, demonstrating that 74% of companies do not disclose required information on government-initiated environmental legal proceedings (1988)

Studies on investors' use of non-financial information in decision-making

- Enhanced Analytics For A New Generation of Investor: How the Investment Industry Can Use Extra-Financial Factors in Investing, issued by the UK-based University Superannuation Scheme. Argues that because many investors pay attention to salient and measurable information, they can easily overlook less conspicuous, and less tangible data that provide a broader perspective on corporate and stock market performance
- AICPA Investor Survey, which found that 78% of individual investors want more information on corporate responsibility (2000)
- Measures that Matter, a Ernst & Young study reporting that 40% of large investors' asset allocation decisions are based on non-financial information (1988)

Links

- Investor Network on Climate Risk - calls on the SEC to issue an interpretation on climate risk disclosure.
- California Public Employees' Retirement System - calls for strengthened SEC environmental reporting rules
- Center for Political Accountability and 11 State Treasurers and Pension Trustees - advocates for new SEC rules on corporate disclosure of political contributions
- The Rose Foundation and 50 pension funds, mutual funds, labor funds and foundations - wants on the SEC to adopt new environmental liabilities reporting rules
- Publish What You Pay – advocates for international accounting standards that would require resource extraction companies to disclose payments to national governments.
- Securities and Exchange Commission – official SEC website
- Financial Accounting Standards Board – official FASB website
- American Institute for Certified Public Accountants – official AICPA website
- International Organisation for Securities Commissions – official IOSCO website
- International Accounting Standards Board – official IASB website
- Environmental Disclosure Special Committee: American Bar
- Association Section of Environment, Energy and Resources – focuses on SEC and financial statement disclosure of environmental matters, including the requirements of Sarbanes-Oxley

International developments in the field of environmental/social financial accounting

- (International) Summary of national accounting standards requiring environmental/social reporting – an excerpt from a KPMG International Survey of Corporate Responsibility Reporting 2005

- (Canada) Corporate Disclosure, Social and Environmental Information: memo prepared by Gil Yaron of SHARE for the Ontario Securities Commission summarizing Canadian environmental and social disclosure rules

- (Canada) Disclosing the Financial Impact of Climate Change and Other Environmental Issues: a draft interpretive release for public comment issued by the Canadian Institute of Chartered Accountants

- (UK) The Operating and Financial Review, Practical Guidance for Directors: a government-commissioned guide to preparing OFRs for UK-listed companies. An OFR is equivalent to Management Discussion & Analysis reporting in the US, in which companies must discuss material “stakeholder” issues

- (UK) Reporting Standard 1, The Operating and Financial Review: standard issued by the UK Accounting Standards Board to provide guidance on preparing OFRs

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