KEY CONSIDERATIONS ON ESG DISCLOSURE POLICY 
DESIGN FOR CHINA 
INTRODUCTION 
The United Nations-backed Principles for Responsible Investment (PRI) is the world’s leading 
initiative on responsible investment. The PRI has over 2500 signatories (pension funds, insurers, 
investment managers and service providers) globally with approximately US $85 trillion in assets 
under management.  
Responsible investment explicitly acknowledges the relevance to the investor of environmental, 
social and governance (ESG) factors in investment decision-making for the long-term health and 
stability of financial markets.  
ABOUT THIS BRIEFING 
This briefing provides technical guidance as part of the PRI’s work on ESG disclosure in China, with 
support from the UK China PACT Programme. It is based on the research and recommendations of the 
report ESG Data in China: Recommendations on Primary ESG indicators. This research showed that 
while there was broad alignment between international and Chinese corporate environmental, social 
and governance (ESG) data disclosure practices, the disclosures being provided by Chinese companies 
are not standardised and not readily comparable across markets, industries and portfolios. The report 
commented that this lack of comparability limits investors’ ability to integrate ESG data into their 
investment decisions, and acts as a barrier to increased investment in green and sustainable assets.  
The report therefore recommended that Chinese financial regulators introduce a mandatory 
environmental, social and governance (ESG) disclosure framework, requiring all major companies to 
report on a series of standard ESG indicators and to supplement these quantitative metrics with 
related information on governance, strategy and risk management. 
In addition to this report, PRI was asked by the China Securities Regulatory Commission (CSRC) to 
provide guidance on the specific regulations or regulatory clauses that would be required to 
implement these recommendations. 
This briefing is the PRI’s response to that request. It identifies the key questions and considerations 
that would need to be addressed by any regulator seeking to introduce corporate ESG disclosure 
requirements. It also recommends draft wording that could be adopted for Chinese legislation on 
corporate ESG reporting. 
While this briefing has been informed by our work on similar legislations in other jurisdictions, there 
is not yet a single ‘best practice’ ESG disclosure legislation. Different countries have taken different 
approaches depending on their specific contexts, e.g. the maturity of ESG or sustainability reporting

ESG Disclosure policy – Key considerations on policy design for China 
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in the domestic market, national environmental, social and economic priorities, pre-existing reporting 
requirements such as industry codes or stock exchange disclosure requirements, the needs and 
interests of investors. Current efforts of international organisations and industry stakeholders, 
including PRI and ICGN’s project on Meaningful Data, aim to establish global, standardised and 
comparable corporate ESG reporting. The CSRC should therefore ensure that the disclosure policy they 
put in place could be re-aligned with any future global standardised ESG disclosure recommendations. 
This note focuses on overarching implementing legislation. In jurisdictions where similar regulation 
has been adopted, it has tended to be supplemented by more detailed guidance over time, covering 
aspects such as calculation methodologies and reporting formats. Such materials, while important, fall 
outside the scope of this briefing.

ESG Disclosure policy – Key considerations on policy design for China 
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KEY CONSIDERATIONS ON ESG DISCLOSURE POLICY IN CHINA 
When designing legislation on mandatory ESG reporting requirements, policymakers need to start by 
answering a number of important questions. We set these questions out below together with some 
reflections on the factors that Chinese regulators need to consider when implementing an ESG 
disclosure requirement for companies. 
 
Key Question 1: Rationale 
What is the purpose of the legislation? 
These objectives will define the specific data and information to be reported, and will define the companies 
that are expected to report. 
The reasons for introducing mandatory ESG disclosure requirements can include some or all of: providing 
better information to investors, providing information to other stakeholders, encouraging and enabling 
better corporate oversight and management of sustainability-related issues, and increasing investment in 
green and sustainable assets. 
Proposed implementation for China 
As discussed in the ESG Data in China: Recommendations for Primary ESG Indicators, in order to provide 
usable and comparable ESG data to investors, companies should be required to report on a standardised set 
of primary ESG disclosure indicators. 
More generally, the report suggested that the introduction of mandatory ESG disclosure requirements for 
all listed companies would: 
• 
Support the building of reliable ESG data series, which could be supplemented by other indicators over 
time. 
• 
Provide useful information to Chinese and international investors to make investment decisions 
through the provision of standardised ESG data. 
• 
Enhance management and board oversight of performance on key ESG issues within listed companies. 
• 
Increase investment in green and sustainable assets. 
• 
Support international ESG disclosure standardisation efforts. 
 
Key Question 2: Legal 
What is the legal basis for the regulation? 
Many countries already have formal disclosure requirements regarding the disclosures that companies need 
to provide in their annual reports and accounts and similar documents. 
It is often most efficient, in terms of the speed of adoption and implementation, to add ESG disclosure 
requirements to these pre-existing corporate disclosure requirements. These may be introduced as 
amendments to existing legislation or as a separate regulation underneath existing legislation. It also shows 
that ESG reporting is an integral part of business reporting. 
Proposed implementation for China

ESG Disclosure policy – Key considerations on policy design for China 
4 
 
In December 2017, the CSRC issued Standards for the Content and Formats of Information Disclosure of 
Companies Publicly Issuing Securities No.2 - Content and Formats of Annual Reports.  
It is suggested that the ESG disclosure requirements be integrated into these Standards, thereby harnessing, 
and aligning with, existing implementation and enforcement processes.  
 
Key Question 3: Timing 
When do companies need to report? 
Companies are usually given a grace period of 1-2 years before they are expected to comply with ESG 
reporting requirements. The decision will depend on contextual factors such as existing reporting practice 
and the extent to which such data are already gathered and reported by companies. 
Companies should report their ESG-related information at the same time as they report their financial and 
related information. This allows investors to integrate the two different data sets, e.g. through normalising 
certain ESG data by revenues or staff numbers. 
Proposed implementation for China 
The ESG Data in China: Recommendations for Primary ESG Indicators report noted that many large Chinese 
companies already report on similar ESG topics, including on the proposed core indicators. Therefore, for 
most companies, mandatory reporting requirements could be introduced quite quickly, perhaps even 
commencing in the first financial year following the introduction of the reporting requirements. 
The CSRC may, however, wish to offer some flexibility to companies that have not previously reported. For 
example, in the first year of reporting, companies could report indicators on a comply or explain basis, 
where they explain how they intend to address any gaps in their reporting. 
Companies should report on their sustainability-related information at the same time as they report their 
financial and related information.  
 
Key Question 4: Company Universe 
Who is required to report? 
Different countries have taken different approaches to defining who is required to report. Many have 
started with a relatively small group of larger companies (usually listed companies) and then progressively 
extended the scope to cover smaller companies, unlisted companies and other entities (e.g. government 
agencies). 
Policymakers need to consider the following questions: 
• 
Should the universe include some or all of: publicly listed companies, private (unlisted) companies, 
charities, government departments, state-owned enterprises, other entities? 
• 
Should the disclosure requirements only apply to companies already required to provide other 
disclosures, or should the universe of companies be extended? 
• 
What size company is expected to report? Different jurisdictions have adopted different approaches 
but common inclusion thresholds relate to: 
o 
Turnover (e.g. companies might need to have a turnover of at least US$50 million), and/or

ESG Disclosure policy – Key considerations on policy design for China 
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o 
Balance sheet size (e.g. companies might need to have a balance sheet of at least US$20 
million), and/or 
o 
Number of employees (e.g. companies might need to have at least 250, or even 500, 
employees). 
Proposed implementation for China 
It is suggested that the regulation applies to the same universe of companies that is required to disclose 
under Standards for the Content and Formats of Information Disclosure of Companies Publicly Issuing 
Securities No.2 - Content and Formats of Annual Reports (Revised in 2017). 
This universe may be extended over time (see also Key Question 11 below). 
 
Key Question 5: Reporting boundaries 
What is the scope of reporting? 
In general, ESG data should cover 100% of the issuing entity and ESG reporting should employ the same 
principles as financial reporting. If a company has partial ownership of certain subsidiaries, the data should 
be reported on a percentage ownership basis in order to accurately reflect the proportional exposure the 
company has to these businesses. 
Companies should also disclose the proportion of company activities that are consistent with sustainability 
criteria in sustainability taxonomies. 
There are other options for reporting (e.g. an organisation could report on all activities where it has 
financial control or where it has operational control). There are cases where these approaches are valuable 
(e.g. in the extractive industries, companies often provide additional disclosures on facilities where they 
have operational control); however, such disclosures do not necessarily link to the financial accounts.  
Proposed implementation for China 
The ESG data reported should cover 100% of the issuing entity and employ the same principles and cover 
the same scope as financial data. If a company has partial ownership of certain subsidiaries, the data should 
be reported on a percentage ownership basis in order to accurately reflect the proportional exposure the 
company has to these businesses. 
 
Key Question 6: Reporting period 
Over what time period should companies report? 
Most ESG reporting requirements encourage companies to report data over a 12-month period, and 
encourage companies to align their ESG reporting period with their financial year reporting period. This 
alignment enables comparison of financial performance with other aspects of the company’s performance.  
Proposed implementation for China 
Companies should align their ESG reporting period with their financial year reporting period.

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Key Question 7: Report content 
What data and information are to be reported? 
The specific information to be reported will depend on the objectives of the reporting regulation. In some 
cases, the interest will be in the relevance of ESG or sustainability issues to a company’s strategy, with the 
emphasis on financial materiality and on the management of the business and financial risks and 
opportunities associated with these issues. In other cases, the interest will be in a company’s overall social 
and environmental performance and impacts (and how these are managed), or in specific aspects of a 
company’s social and environmental performance (e.g. greenhouse gas emissions, diversity). 
While the specific information to be reported will differ, regulators and other actors will be interested in 
understanding a company’s exposure to or impact on the ESG issue(s) in question, their strategy for 
managing the issue(s) in question, the actions they have taken and their performance on the issue(s) in 
question. They will also want to able to put these exposures and impacts into context and may want to 
complement these ESG data with relevant business information such as turnover, the countries and markets 
of operation, the number of staff and contractors and the quantity, weight or volume of product outputs. 
Proposed implementation for China 
The ESG Data in China: Recommendations for Primary ESG Indicators report recommended that companies 
report a set of primary standardised indicators that allow for comparability across industry sectors, 
portfolios and time-series, alongside financial indicators, based on the same reporting scope. Such data 
should be linked to companies’ business models, their corporate strategy (including financial and 
sustainability objectives and thresholds) and risk factors. Finally, ESG data should be analysed and explained 
in comparison to sectoral averages and historical performance; 
The ESG Data in China: Recommendations for Primary ESG Indicators report proposed the following specific 
indicators:  
• 
Greenhouse gas (GHG) emissions 
o 
Total GHG emissions (scope 1,2,3) in tonnes 
• 
Air pollutants 
o 
Air emissions of NOx, SOx, POP, VOC, HAP, PM in kg 
• 
Water 
o 
Total water withdrawal (m3) 
o 
% of water recycled 
• 
Energy 
o 
Total energy consumed (GWh) 
o 
% of renewable energy 
• 
Waste (water, solid, hazardous) 
o 
Total waste from operations (tonnes) 
o 
% of hazardous waste 
o 
% of waste recycled 
o 
Water discharges of Nitrogen, Phosphorus and Persistent Organic Pollutants (kg) and 
Biochemical Oxygen Demand (mg/L) 
• 
Workforce 
o 
Workforce composition by gender 
o 
Training hours per employee 
o 
Wages paid 
• 
Health and safety

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7 
 
o 
Injury rate (TRIR) 
o 
Fatality rate (for direct and contract employees) 
• 
Governance quantitative indicators 
o 
% of women on the Board 
o 
Decentralization of authority President/CEO 
o 
CEO pay ratio 
In addition, companies should describe: 
• 
The scope of reporting. 
• 
The calculation methodology used (including details of data sources and assumptions). 
• 
Any changes to scope or methodology that might affect investors’ ability to assess trends in 
performance over time. 
• 
Where changes to scope or methodology have a material effect on the date reported, companies 
should update at least the last three years’ worth of data. 
While the ESG Data in China: Recommendations for Primary ESG Indicators report did not specify the 
contextual or supporting disclosures that might be provided, similar requirements in other jurisdictions 
have encouraged companies to provide information on: 
• 
The company’s business model. 
• 
The relevance of ESG issues to the company’s strategy and risk profile. 
• 
The policies the company has adopted in related to the issues in question. 
• 
The commitments, objectives and targets the company has set in relation to these issues, and the key 
performance measures (KPIs) it uses to tracks its performance against these. 
• 
The actions taken by the company to manage these issues. 
• 
The company’s performance on each of these issues.  
 
Key Question 8: Report location/format 
Where do companies need to report? 
In broad terms, companies can report ESG-related information in one or more of: 
• 
Their annual report (or equivalent publication): It is increasingly common for larger listed companies to 
include explicit references to ESG themes within their annual reports. The inclusion of ESG-related 
information issues into annual reports allows the process of gathering and verifying this data to be 
integrated into the processes and information controls that are already in place. It also means that ESG 
data is readily available to investors at the same time as wider information about the company. In 
practice, due to concerns about length and complexity, companies tend to discuss relatively few ESG 
issues in their annual reports, and so may not cover all aspects that are of interest to investors or to 
other stakeholders. 
• 
Their standalone sustainability report (or a dedicated section of the company website): A standalone 
sustainability or CSR report provides a clear ‘home’ for ESG content, enabling this information to be 
consolidated in a single location. However, the limitation of such reports is that they can imply that 
sustainability-related information and performance is seen as separate from the core business of the 
company.  
• 
Their integrated report: The concept of an integrated report is that ESG information and data are 
presented in an integrated manner within the annual report. Such a report can offer investors a more 
rounded, concise and holistic insight into business performance and impact over the short, medium and

ESG Disclosure policy – Key considerations on policy design for China 
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long term. However, a focus on what management sees as the most business critical ESG areas may 
mean that investors do not get the breadth of information they need.  
Companies can make this information available in a variety of ways – through their own websites, in hard 
copy, through social media and through third-party registers (e.g. government registers, other databases). 
Proposed implementation for China 
The ESG Data in China: Recommendations for Primary ESG Indicators report recommended that the core 
ESG indicators and related information should be reported in corporate annual reports, using the same 
reporting scope as the annual report. This information should be distributed and made available in the 
same way as corporate annual reports. 
 
Key Question 9: Specific technical issues 
What sort of exemptions might be considered? 
Regulators may decide that certain companies are exempt from the reporting requirements or that not all 
of the reporting requirements apply to all firms. This may be for example on the basis of the size or other 
requirements discussed above. 
Regulators may also decide that companies do not need to report on all elements of the legislation. This can 
take different forms: 
• 
Comply or explain exemptions, where companies can either report the required information or provide 
a statement explaining what information has been omitted and why. Comply or explain legislation 
often requires companies to describe the steps they will take to fill any such gaps. 
• 
De minimis exemptions where companies do not need to report if they can demonstrate that their 
impact on the issue in question is minor or that the costs of gathering and reporting the information 
exceed any benefits that accrue. 
• 
Commercial in confidence exemptions where companies do not have to report if the disclosure of 
information might be commercially or otherwise prejudicial to their interests. 
While there is a general recognition that having data independently assured leads to higher quality data, 
regulators may decide not to impose such requirements (e.g. if assurance is seen as too expensive) or may 
delay the imposition of such requirements (e.g. they start by encouraging reporting and then, based on the 
quality and quantity of the reported information, decide whether there is a need to introduce assurance or 
other additional data quality requirements). 
Proposed implementation for China 
This issue was not considered in the ESG Data in China: Recommendations for Primary ESG Indicators 
report. However, given the universe of companies and current reporting practice in China, it is suggested 
that: 
• 
All companies covered by Standards for the Content and Formats of Information Disclosure of 
Companies Publicly Issuing Securities No.2 - Content and Formats of Annual Reports be required to 
report. 
• 
All companies are expected to report all indicators. As this is a widely (domestically and internationally) 
accepted set of core indicators, it is reasonable to expect all companies to report this information.

ESG Disclosure policy – Key considerations on policy design for China 
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However, for companies with a small footprint, reporting may be facilitated through the development 
of some straightforward guidance and tools such as default emission factors. 
• 
Companies are allowed a one year exemption if they have not previously reported an indicator. They 
are, however, expected to explicitly acknowledge that they are not reporting and explain the actions 
they will be taking to ensure that they can report in the forthcoming year. 
• 
Companies may claim an exemption for information that is considered commercial in confidence. 
However, such exemptions should be seen as exceptional and the presumption should be that all 
affected companies will report against all of the indicators. 
It may be premature to introduce mandatory data assurance requirements but it is suggested that this be 
considered as part of the Review (see Key Question 11 below), with a presumption that such requirements 
will be introduced following the review unless there are compelling reasons why this should not be the 
case. 
 
Key Question 10: Enforcement 
Who is responsible for enforcement? 
What enforcement processes are envisaged? 
What sanctions may be applied in the event of non-compliance? 
Generally, ESG reporting requirements are additional to other, pre-existing reporting requirements. It often 
makes sense to integrate these requirements into existing regulatory requirements and to use the exiting 
institutional structures and processes for enforcement.  This integration can help to ensure that new ESG 
reporting requirements are treated with the same degree of seriousness and attention as other reporting 
requirements. 
Proposed implementation for China 
It is suggested that CSRC uses the enforcement powers and processes that underpin Standards for the 
Content and Formats of Information Disclosure of Companies Publicly Issuing Securities No.2 - Content and 
Formats of Annual Reports. 
 
Key Question 11: Review and monitoring 
What sort of review and monitoring processes should be adopted? 
It is good practice to build structured, formal review processes into regulatory processes. It both allows for 
regulation to be adapted and changed in response to experience, and it also means that regulators are held 
to account for ensuring the effective implementation of the legislation. 
The questions that could be considered in reviews include: 
• 
Have companies complied with the legislation (e.g. have they reported)?  
• 
What actions have been taken to encourage non-reporters? 
• 
Have companies provided the quality of disclosures that are required by investors and other 
stakeholders? 
• 
What are the barriers to better reporting (in terms of quantity and quality)?

ESG Disclosure policy – Key considerations on policy design for China 
10 
 
• 
Have the wider objectives of the regulation been delivered (e.g. are stakeholders such as investors 
actually using the information provided, is capital flowing to companies with better ESG performance)? 
• 
How could the operation of the regulation be made more effective? 
• 
Is the regulation still relevant or does it need to evolve (e.g. the addition of additional reporting 
requirements, the introduction of assurance requirements)?  
Proposed implementation for China 
It is suggested that the legislation include a formal review which is to be conducted one to three years from 
the adoption of the legislation. The review should consider: 
• 
The level of compliance with the legislation (e.g. have they reported). 
• 
Whether companies have provided the quality of disclosures that are required by investors and other 
stakeholders. 
• 
The barriers to better reporting (in terms of quantity and quality) and how these might be overcome. 
• 
Whether the wider objectives of the regulation have been delivered. 
• 
How the operation of the regulation could be made more effective. 
• 
Whether additional reporting requirements should be introduced. 
• 
Whether there is a need to introduce of assurance requirements.

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11 
 
DRAFT CLAUSES 
The following Table proposes draft wording for the implementation of the recommendations of the 
ESG Data in China: Recommendations for Primary ESG Indicators. As discussed above, it is assumed 
that these clauses will be integrated into an updated version of the Standards for the Content and 
Formats of Information Disclosure of Companies Publicly Issuing Securities No.2 - Content and Formats 
of Annual Reports and the style and form of the draft clauses has been written so that these clauses 
can be incorporated directly. 
 
Key Questions 
Draft Clauses 
Purpose/Objectives 
What is the purpose of 
the legislation? 
[Chapter 1: General Provisions] 
 
New Article to follow Article 3: 
“The information to be reported includes information on the social and 
environmental policies, performance and impacts of the company as set out in 
these Standards, including discussion of those aspects that have or may have a 
significant impact on investor decisions.” 
Legal 
What is the legal basis 
for the regulation? 
No specific text proposed but, as noted above, it is expected that these clauses 
will be integrated int the Standards for the Content and Formats of Information 
Disclosure of Companies Publicly Issuing Securities No.2 - Content and Formats of 
Annual Reports.  
Timing 
When do companies 
need to report? 
Modification to Article 9 (the modification is in italics and underlined): “ A 
company shall, within 4 months as of the end of the each accounting year, publish 
the full text of the annual report, including the items on the environmental and 
social performance of the company referred to in Clause XX, on the website 
designated by CSRS; and at… 
 The reporting requirements on the environmental and social performance of the 
company shall commence on [date to be specified by CSRC]’.  
Company universe 
Who is required to 
report? 
No new text required. The universe of companies required to report is as defined 
in Article 2. 
Reporting boundaries

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What is the scope of 
reporting? 
No new text required. 
The existing Clause 22(3) (“The Company that formulates consolidated financial 
statements shall fill in or calculate the aforesaid data and indicators with the data 
in the consolidated financial statements.”) applies to all disclosures required by 
the legislation. 
Reporting Period 
Over what time period 
should companies 
report? 
See suggested modifications to article 9 above, and note reference to timeframes 
in proposed new Section YY below.     
Report content 
What data and 
information are to be 
reported? 
It is suggested that a new Section YY be added to follow Chapter II, Section 3. 
 
Clause AA: The Company shall report in quantitative terms on each of the 
following specific indicators, for the same scope as applies to the remained of the 
Annual Report:  
• 
Greenhouse gas (GHG) emissions 
o 
Total GHG emissions (scope 1,2,3) in tonnes 
• 
Air pollutants 
o 
Air emissions of NOx, SOx, POP, VOC, HAP, PM in kg 
• 
Water 
o 
Total water withdrawal (m3) 
o 
% of water recycled 
• 
Energy 
o 
Total energy consumed (GWh) 
o 
% of renewable energy 
• 
Waste (water, solid, hazardous) 
o 
Total waste from operations (tonnes) 
o 
% of hazardous waste 
o 
% of waste recycled 
o 
Water discharges of Nitrogen, Phosphorus and Persistent Organic 
Pollutants (kg), and of Biochemical Oxygen Demand (mg/L) 
• 
Workforce 
o 
Workforce composition by gender 
o 
Training hours per employee 
o 
Wages paid 
• 
Health and safety 
o 
Injury rate (TRIR) 
o 
Fatality rate (for direct and contract employees) 
• 
Governance quantitative indicators 
o 
% of women on the Board 
o 
Decentralization of authority President/CEO 
o 
CEO pay ratio

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13 
 
 
Clause BB For each of these indicators, the Company shall describe: 
• 
The scope of reporting. If the scope of reporting is not the same as for the 
entity covered by the Annual Report, the Company shall explain the reasons 
for the difference and discuss the implications for the users of the 
information. 
• 
The calculation methodology used (including details of data sources and 
assumptions). 
• 
Any changes to scope or methodology that might affect investors’ ability to 
assess trends in performance over time. 
• 
Where changes to scope or methodology have a material effect on the date 
reported, the Company should provide at least three years’ of updated data. 
 
Clause CC: The Company shall describe:  
• 
The relevance of ESG issues to the company’s strategy and risk profile. 
• 
The policies the company has adopted in related to the issues in question. 
• 
The commitments, objectives and targets the company has set in relation to 
these issues, and the key performance measures (KPIs) it uses to tracks its 
performance against these. 
• 
The actions taken by the company to manage these issues. 
• 
The company’s performance on each of these issues.  
 
Clause DD: For [insert first year], companies may choose not to report on certain 
indicators if they have not previously done so. However, these companies will 
explicitly acknowledge that they are not reporting and will explain the actions 
they will be taking to ensure that they can report in the forthcoming year. In the 
second year, all of the companies covered by these Standards will be required to 
report against all of the requirements in Clauses AA, BB and CC. 
 
Clause EE: On or before [date – within 3 years of the adoption of these Clauses] 
CSRC will conduct a formal review, including consideration of feedback from 
relevant stakeholders, on Clauses AA to DD. The review will, amongst other 
relevant matters, consider: 
• 
The level of compliance with the legislation. 
• 
Whether companies have provided the quality of disclosures that are 
required by investors and other stakeholders. 
• 
The barriers to better reporting (in terms of quantity and quality) and how 
these might be overcome. 
• 
Whether the wider objectives of the regulation have been delivered. 
• 
How the operation of the regulation could be made more effective. 
• 
Whether additional reporting requirements should be introduced. 
• 
Whether there is a need to introduce assurance or other audit requirements. 
Report location/format

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14 
 
Where do companies 
need to report? 
No new text required, although note the modification to Clause 9 above. The ESG-
related information should be reported in the same locations and at the same 
time as the annual report 
Specific technical and design issues 
What sort of 
exemptions might be 
considered? 
Proposed modification to Clause 7 (on auditing): ”These requirements do not 
apply to the information reported under Clauses AA-DD.” 
Enforcement 
Who is responsible for 
enforcement? 
No new text required. 
What enforcement 
processes are 
envisaged? 
What sanctions may be 
applied in the event of 
non-compliance? 
Review processes 
What sort of review 
processes should be 
adopted? 
See Clause EE above. 
 
 
 
The PRI has experience of public policy on ESG disclosure and responsible investment across multiple 
markets and is available to further support the work of the CSRC on promoting investment and ESG 
disclosure.  
Any question or comments can be sent to policy@unpri.org.