Consultation Responses

Publications

Consultation Responses


    • Task Force on Climate-Related Disclosure Phase II Consultation
      22nd February 2017
      LAPFF supports the recommendations of the FSB Taskforce and considers all market participants should be encouraged to aim for full implementation. The Forum further considers that guidance could go beyond promoting disclosure of scenario that reflects a 1.5 – 2 degree future, to recommending that companies should be positioning themselves for a low carbon future by disclosing a strategic business transition plan. LAPFF response to Taskforce Phase II Consultation
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    • ‘Engaging for a Low Carbon Transition’ - new report published by LAPFF and Carbon Tracker Initiative
      21st July 2016
      Following a highly successful launch on 21 July, LAPFF and Carbon Tracker Initiative have published their new report ‘Engaging for a Low Carbon Transition’ which sets out why a 2˚C business model can be less risky than ‘business-as-usual’ for oil and gas companies.   The study explains what this means for shareholder value and gives very practical ‘hands on’ guidance on how to engage with companies on the low carbon transition and the degree to which investments are ‘two-degree’ compliant.   The report can be accessed here and the press release is available here.  
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    • Task Force on Climate Disclosure’s Phase I Consultation
      16th March 2016
      Task Force on Climate Disclosure’s Phase I Consultation The Forum encourages a forward-looking focus on detailed quantitative and qualitative reporting, supported by additional narrative where necessary, across five elements: operational emissions; strategic resilience; research and development; the governance of company policy implementation on climate change and key performance indicators; and public policy. Within this framework, LAPFF strongly encourages scenario and sensitivity analysis, to rigorously test companies’ assumptions, and to provide a comparable and consistent approach to disclosure.
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    • Consultation Paper on Review of the Hong Kong Stock Exchange ESG Reporting Guide
      15th September 2015
      Consultation Paper on Review of the Hong Kong Stock Exchange ESG Reporting Guide LAPFF has responded to a consultation paper issued by the Hong Kong Stock Exchange on its Environmental, Social and Governance (ESG) Reporting Guide calling for mandatory reporting of carbon emissions. The Forum has welcomed and endorsed the move towards a ‘comply or explain’ approach for other aspects of reporting and considers this may set a model for other exchanges for reporting on the governance of material environmental and social issues. Response HK ESG consultation
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    • LAPFF Response to DEFRA on ghg reporting
      27th April 2012
      LAPFF supports the new regulations requiring companies to report their greenhouse gas emissions and recommends that the government provide consistent guidance regarding the specific methodology required to calculate emissions, October 2012. LAPFF Response to DEFRA on ghg reporting
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    • DEFRA consultation on mandatory carbon reporting
      14th August 2011
      DEFRA consultation on mandatory carbon reporting LAPFF response to the DEFRA consultation on introducing regulations requiring companies to report on carbon emissions, July 2011
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    • Ethnic Diversity of UK Boards
      7th March 2017
      LAPFF’s supports the main interim findings of the Parker Review on Ethnic Diversity of UK Boards. The Forum’s response focuses on the importance of board diversity for investors and the role that investors play in ensuring that companies are working towards having more ethnically diverse boards. Ethnic Diversity of UK Boards LAPFF Response to the Parker Review
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    • Consultation on Gender imbalance in corporate boards in the EU
      16th November 2016
      Consultation on Gender imbalance in corporate boards in the EU Response advocates for a 'comply or explain' approach to increasing the number of women on corporate boards, May 2012. LAPFF Cover Letter to 30% Club Submission 30% Club response to EU gender imbalance  
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    • LAPFF response to FRC consultation on Strategic Report
      15th November 2016
      LAPFF is a member of the Investor Group of the 30% Club, a group of Chairmen voluntarily committee to bringing more women onto UK corporate boards. The submission focuses on paras 6.68 to 6.71 of the exposure draft. 30% Club response to FRC Strategy Report consultation LAPFF response to FRC consultation on Strategic Report  
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    • House of Lords Consultation on Gender Balance
      15th November 2016
      House of Lords Consultation on Gender Balance The 30% Club, which LAPFF is an investor supporter, advocates for voluntary measures to increase the number of women on UK corporate boards, June 2012. 30% Club Response to House of Lords on Board Diversity   Consultation on Gender imbalance in corporate boards in the EU Response advocates for a 'comply or explain' approach to increasing the number of women on corporate boards, May 2012. LAPFF Cover Letter to 30% Club Submission 30% Club response to EU gender imbalance  
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    • Government Equalities Consultation on Closing the Gender Pay Gap
      6th September 2015
      Government Equalities Consultation on Closing the Gender Pay Gap LAPFF is a member of the Investor Group of the 30% Club which has responded to the consultation. The 30% Club is a group of Chairmen voluntarily committed to bringing more women onto UK corporate boards. 30% Club response to the Pay Gap consultation  
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    • Consultation on Corporate Human Rights Benchmark
      28th May 2015
      LAPFF has responded to a consultation on the development of a corporate human rights benchmark calling for increased reporting of examples pertaining to the implementation of corporate human rights policies and systems. LAPFF finds that often annual reports and CSR reports provide great detail and evidence of the existence of policies and systems but very little information on how these tools work in practice. In order to assess the actual impact of the tools, an explicit request for examples would be extremely helpful in understanding whether financial, operational and reputational risks are likely, and if so, what they are likely to be. Download.PDF LAPFF response on Corporate Human Rights Benchmark
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    • Corporate Governance Reform
      7th March 2017
      LAPFF’s response focuses on how to ensure that executive pay is properly aligned to long-term performance and on giving greater voice to employees and consumers in the boardroom.  It also sets out where there are major problems with the FRC as the regulator of governance, accounts and financial reporting.   LAPFF Response to BEIS Green Paper on Corporate Governance  
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    • Robust Safeguards Needed in Sky – 21st Century Fox Deal to Protect Public Shareholders, says LAPFF
      13th December 2016
      The news that 21st Century Fox has made a takeover bid for Sky comes as no surprise to many and LAPFF has long envisaged this being the objective of the 21st Century Fox, its largest shareholder, and the Murdoch family. The news that 21st Century Fox has made a takeover bid for Sky comes as no surprise to many and LAPFF has long envisaged this being the objective of the 21st Century Fox, its largest shareholder, and the Murdoch family.   Read more
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    • LAPFF response to FSA re UK Listing Authority
      15th November 2016
      Group submission supporting the upholding of minority rights and proposing amendments to listing rules for additional investor protection, April 2012. LAPFF response to FSA re UK Listing Authority   BIS Consultation on Executive Pay and Shareholder Voting Rights LAPFF expresses its views on shareholder voting rights and a binding vote on executive remuneration, April 2012. LAPFF response to BIS on Shareholder Voting Rights  
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    • LAPFF response to FRC Corporate Governance Code Consultation
      14th June 2014
      LAPFF welcomes some proposed changes to the Code such as those relating to new regulatory initiatives on directors’ remuneration, but flags up concerns in the wording of other areas such as on going concern. LAPFF response to FRC Corporate Governance Code Consultation
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    • LAPFF response to FRC consultation on Strategic Report
      15th November 2013
      LAPFF is a member of the Investor Group of the 30% Club, a group of Chairmen voluntarily committee to bringing more women onto UK corporate boards. The submission focuses on paras 6.68 to 6.71 of the exposure draft. 30% Club response to FRC Strategy Report consultation LAPFF response to FRC consultation on Strategic Report
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    • LAPFF response to FRC consultation on executive pay
      13th November 2013
      LAPFF supports clawback and malus provisions for directors pay but has concerns that setting out that the purpose of pay is to ‘attract, retain and motivate’ perpetuates some common misunderstandings about how the market for executive talent operates. LAPFF response to FRC consultation on executive pay
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    • LAPFF response to SEC Consultation on Pay Ratio Disclosure
      11th November 2013
      LAPFF supports SEC action to facilitate meaningful corporate disclosure of executive pay ratios and flags up various points to consider in developing guidance for the implementation methodology. LAPFF response to SEC Consultation on Pay Ratio Disclosure
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    • BIS discussion paper on company ownership, transparency and trust
      13th September 2013
      BIS discussion paper on company ownership, transparency and trust LAPFF replies to BIS' proposal to enhance corporate transparency by improving the ability to know who really owns and controls UK companies. LAPFF response to BIS' discussion paper
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    • Amendments to Part IV of The Toronto Stock Exchange Company Manual
      6th October 2011
      LAPFF response to amended areas that are of relevance to the Forum's activities, October 2011. Download .PDF
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    • EC Green Paper: EU Corporate Governance Framework
      16th July 2011
      EC Green Paper: EU Corporate Governance Framework LAPFF response to the EC Corporate Governance paper. The EC paper focuses on three main areas: boards of directors, shareholders’ engagement and the “comply or explain” approach, July 2011.
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    • IAS consultation on the impact of IFRS in the EU
      16th November 2016
      LAPFF, together with a group of nine UK organisations has made a joint submission to the European Commission on the impact of International Financial Reporting Standards. The participating institutions include individual asset management firms, pension funds and associations. IAS consultation on the impact of IFRS in the EU LAPFF and investor coalition joint response to EC on impact of IFRS
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    • EFRAG – call for comments on draft endorsement advice on IFRS 9
      16th November 2016
      LAPFF has responded to the draft endorsement advice by the European Financial Reporting Advisory Group (EFRAG) on the proposed replacement of EU-IAS 39 with IFRS 9. LAPFF believes that EFRAG has been lacking objective and transparent legal criteria for assessing the true and fair view principle of the law for IFRS endorsement and as a result has not been following the correct model of true and fair view in endorsing IFRS.   EFRAG – call for comments on draft endorsement advice on IFRS 9 LAPFF response to the draft endorsement advice by the European Financial Reporting Advisory Group (EFRAG)
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    • FRC Consultation – Auditing and ethical standards implementation of the EU Audit Directive and Audit Regulation
      18th December 2014
      FRC Consultation – Auditing and ethical standards implementation of the EU Audit Directive and Audit Regulation LAPFF does not support any further powers being given to the FRC without substantial governance reform of the FRC resulting in demonstrable independence of the FRC from the auditing profession, and has written to BIS accordingly. LAPFF response to FRC consultation
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    • FRC consultation on Sharman and Going Concern
      6th November 2013
      FRC consultation on Sharman and Going Concern LAPFF supports the original Sharman proposals, not the FRC proposed amendments. Recent FRC statements on the quality of audits at UK banks would suggest that auditors should be undertaking their basic task properly as opposed to providing assurance against financial reporting standards LAPFF response to FRC consultation on Sharman and Going Concern
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    • Letter to the UK Competition Commission on Auditor Rotation
      20th May 2013
      Letter to the UK Competition Commission on Auditor Rotation LAPFF reiterates support for a regulatory backstop to audit firm tenure to further the protection of auditor independence as well as limits to non-audit fees.
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    • FRC Consultation on Sharman Implementation
      4th February 2013
      FRC Consultation on Sharman Implementation The Sharman Panel recognises that assessing going concern requires prudent accounting policies, and that this assessment is not consistent with IFRS in several material respects. In LAPFF’s opinion, the parties who have been setting and endorsing accounting standards have been missing the fundamentals of prudent accounting and true and fair view altogether. LAPFF response to the FRC on the Sharman implementation
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    • FRC Consultation on Revision to ISA 700
      4th February 2013
      FRC Consultation on Revision to ISA 700 LAPFF welcomes the requirement for the auditor’s report to address risks of material misstatement, materiality and a summary of the audit scope in the form it is proposed and identifies beneficial outcomes for both shareholders and auditors. LAPFF response to the FRC ISA 700 consultation
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    • FRC Consultation on Financial Reporting Disclosure
      15th October 2012
      FRC Consultation on Financial Reporting Disclosure It is the Forum's view that the consultation is trying to address problems of disclosure overload with IFRS, which are symptoms of its defects, rather than tackling the core problem that IFRS is not delivering a true and fair view. LAPFF response to the FRC on Financial Reporting Disclosure
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    • LAPFF Response to the FRC on Corporate Governance Code
      22nd May 2012
      LAPFF Response to the FRC on Corporate Governance Code   Treasury Select Committee Consultation on Corporate Governance and Remuneration LAPFF response argues that effective financial governance relies on properly audited accounting information, May 2012. LAPFF response to Treasury Select Committee
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    • Treasury Select Committee Consultation on Corporate Governance and Remuneration
      16th May 2012
      Treasury Select Committee Consultation on Corporate Governance and Remuneration LAPFF response argues that effective financial governance relies on properly audited accounting information, May 2012. LAPFF response to Treasury Select Committee
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    • LAPFF response to the Task Force on Climate Disclosure’s Phase I Consultation
      15th November 2016
      In response to the Department for Communities and Local Government’s (DCLG) invitation to comment on the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2016, the Local Authority Pension Fund Forum (LAPFF) has responded with a number of comments and observations aimed at taking the regulations forward; ensuring they are practical and robust; and facilitating a good working relationship between Government and administering authorities.  Download .PDF For details, see the: DCLG letter and consultation response  
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    • Proxy Voting Disclosure by UK Asset Managers
      14th November 2016
      LAPFF analysis of public disclosure of voting records by UK asset managers, April 2009. Download.PDF
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    • DWP Changes to Investment Management Regulations
      15th April 2015
      DWP Changes to Investment Management Regulations The LAPFF response is confined to matters that also relate to the investment activities of local authority pension funds and that have implications for LGPS investment regulations currently in place. LAPFF response to DWP consultation
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    • Law Commission Fiduciary Duty Consultation
      14th January 2014
      Law Commission Fiduciary Duty Consultation The LAPFF response to the Law Commission consultation presents a LGPS perspective on key issues of stewardship, short termism and beneficiaries' interests. LAPFF response to Fiduciary Duty Consultation
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    • IIRC consultation on draft of International IR framework
      15th July 2013
      LAPFF concurs with IR that corporate reporting needs to evolve to provide concise communication on strategy, governance, performance and prospects and the link to short, medium and long-term value creation. IIRC consultation on draft of International IR framework LAPFF response to the draft International IR framework
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    • DCLG Investment in Partnerships Consultation
      16th December 2012
      DCLG Investment in Partnerships Consultation LAPFF expresses support for the proposed 30% limit to investing in partnership, arguing that it will facilitate greater investment. LAPFF response to DCLG on investment in partnerships
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    • ICSA Consultation on engagement between companies and investors
      2nd November 2012
      ICSA Consultation on engagement between companies and investors LAPFF welcomes the ICSA approach but suggests that an overly bureaucratic approach to engagement can dilute the investor message and lead to less productive outcomes in company meetings. The Forum sees no need for any intermediary mediation service and prefers direct engagement with company officials, November 2012. LAPFF Response to ICSA on company engagement
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    • FRC consultation on Effective Company Stewardship
      16th March 2011
      FRC consultation on Effective Company Stewardship LAPFF Response to 'Effective Company Stewardship: Enhancing Corporate Reporting and Audits’, March 2011
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    • EC Consultation on Disclosure of Non-Financial Information by Companies
      16th January 2011
      EC Consultation on Disclosure of Non-Financial Information by Companies LAPFF Response to EC Consultation on Disclosure of Non-Financial Information by Companies, January 2011
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    • BIS Consultation on Short Termism
      15th January 2011
      BIS Consultation on Short Termism LAPFF Response to BIS Review on Corporate Governance and Short Termism, January 2011
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