July 29th, 2024
Sustainability Standards Board of Japan
Fukoku Seimei Building 20F, 2-2Uchisaiwaicho, 2-Chome, Chiyoda-ku
Tokyo, Japan 100-0011
Re: Comment on Exposure Drafts of SSBJ Sustainability Disclosure Standards
Dear Chair Kawanishi,
Boston Trust Walden Company is an independent, employee-owned investment management firm withapproximately $15.8 billion in assets under management1. Our firm has been integrating
environmental, social, and governance (ESG) factors into investment decisions since 1975—one of thelongest track records of any institutional investment manager.
At Boston Trust Walden, we seek to invest in enterprises with strong financial underpinnings,
sustainable business models, prudent management practices, and a governance structure that
supports these objectives. Consideration of ESG factors is part of our fiduciary duty to ensure client
assets are invested in a set of securities well situated to produce attractive risk-adjusted returns overa long-term investment horizon.
Since 2017, Boston Trust Walden has served as a member of the Sustainable Accounting Standards
Board (SASB) Investor Advisory Group, now the ISSB Investor Advisory Group, to support thedevelopment of a globally recognized framework for consistent, comparable, and reliable disclosureof financially material, decision-useful sustainability-related information. We are supportive ofjurisdictional efforts to adopt disclosure requirements aligned with the IFRS Sustainability DisclosureStandards and welcome the opportunity to provide comment to the ongoing consultation.
With respect to the ongoing consultation by the Sustainability Standards Board of Japan (SSBJ), Boston
Trust Walden would like to highlight the following key points for consideration.
•We applaud the SSBJ for substantially aligning the Exposure Drafts of the Sustainability
Disclosure Standards (proposed SSBJ EDs) with the requirements of IFRS S1 & S2, save forcertain alternatives that companies may choose to apply. Access to consistent, comparable,
and reliable information is critical to our ability to comprehensively incorporate ESG factors
into investment decisions. While the growth in the absolute number of companies producing
some form of sustainability reporting has been noteworthy, the quality of disclosure remains
inconsistent and generally lacks decision-useful context that investors need to accurately pricesecurities. We recognize the proposed SSBJ EDs represent a significant milestone in pursuitof the goal for a global baseline of sustainability-related information.

•We encourage the SSBJ to limit any substantial changes to the proposed SSBJ EDs that deviate
from IFRS S1 & S2. Maintaining faithfulness to IFRS S1 & S2 through the ongoing consultationis critical to enhancing investor access to timely, consistent, and comparable sustainability
disclosures while reducing jurisdictional fragmentation and simplifying reporting obligations
for issuers.

1 AUM as of June 30. 2024, includes AUM of wholly-owned subsidiary Boston Trust Walden Inc.

Boston Trust Walden Company, a Massachusetts Bank and Trust Company
1 Beacon Street, 34th Floor Boston, Massachusetts 02108 (617) 726-7250 www.bostontrustwalden.com

A growing number of jurisdictions and regulators have adopted or are actively considering
adopting sustainability disclosure standards based on IFRS S1 & S2. For example, California’s
Climate-Related Financial Risk Act and Climate Corporate Data Accountability Act, the BaselCommittee on Banking Supervision’s proposed Pillar 3 disclosure framework for climaterelated financial risks, and the Office of the Superintendent of Financial Institutions’ (OSFI)
update to Guideline B-15 are all grounded in the reporting requirements of IFRS S2. The ISSB
has also published guidance to aid reporters in meeting disclosure requirements through theEuropean Financial Reporting Advisory Group’s (EFRAG) Corporate Sustainability Reporting
Directive (CSRD).
By maintaining faithfulness to IFRS S1 & S2 and limiting any substantial changes to theproposed SSBJ EDs that deviate from IFRS S1 & S2, the proposed SSBJ EDs will strengthen
the comparability of information for investors while also streamlining reporting requirements
and reducing the reporting burden for preparers.
•We encourage the SSBJ to include guidance regarding ‘resources and relationships’ (IFRS S1,paragraph B4) and ‘dependencies and impacts’ (IFRS S1, paragraph B5) within the SSBJ
Application Exposure Draft (Application ED). This guidance, omitted from the Application ED,
provides critical framing for the scope of information companies are expected to consider
when evaluating material sustainability risks and opportunities. Cross-jurisdictional
consistency in the assessment of sustainability risk and opportunities is as critical to achieving
a global baseline for sustainability-related financial disclosures as consistency in the resulting
information disclosed. While the SSBJ has interpreted paragraphs B4 and B5 of IFRS S1 torelate to a concept of ‘impact materiality,’ and therefore presumably less applicable to thelong-term value creation of companies, we note that the IFRS Foundation is actively developing
educational materials to further explain these paragraphs within the concept of materiality asdefined in IFRS S1.

•We encourage the SSBJ to amend the proposal in paragraph 69 of the Application ED torequire reporters to publish sustainability-related financial disclosures at the same time as thefinancial statements to which they relate. Given the scope of the proposed SSBJ EDs seek only
to include material sustainability-related financial information on significant sustainabilityrelated risks and opportunities, we believe it is necessary that reporting occurs in parallel withtraditional financial reporting. Doing so enables investors to integrate such information more
readily and accurately within investment decision making. Notably, IFRS S1 already provides
transition relief on this issue to enable jurisdictions and companies to adequately prepare.
Investors and companies both need credible risk information to make prudent financialdecisions. In practice, for both investors and companies, it is challenging to integratesustainability-related financial information into decision-making processes comprehensivelyand holistically without considering this information in tandem with financial statements.
Moreover, requiring sustainability-related financial disclosures be provided alongside thefinancial statements enhances the likelihood of assurance, maximizing user trust andconfidence in the information disclosed.

•Relatedly, we encourage the SSBJ to remove allowances to include sustainability-related
financial disclosures covering different reporting periods than the financial statements towhich they relate. While we recognize that these allowances were introduced to reduce thedata collection and reporting burden for companies where regulations require a different datacalculation period than the traditional reporting period of its sustainability-related disclosures(and the related financial statements), we believe this jurisdictional-specific deviation from therequirements of IFRS S1 may jeopardize the consistency and comparability of financiallymaterial, decision-useful sustainability-related information on a global basis. Again, it ischallenging for both investors and companies to integrate sustainability-related financial
information into decision-making processes comprehensively and holistically if the reporting
period is not directly aligned with corresponding financial statements.
We encourage the SSBJ to consider implementing temporary reliefs, rather than permanentdeviations from IFRS S1, for the instances cited in paragraph 71 of the Application ED andparagraph 53 of the Climate Exposure Draft. Doing so would provide companies the necessary
time to amend data collection and reporting protocols while enhancing the decision-usefulnature of information provided within the SSBJ Sustainability Disclosure Standards.
As an asset manager integrating sustainability-related information into investment decision-making
since 1975, we are greatly encouraged by the prospects of the IFRS Sustainability DisclosureStandards to improve the consistency, comparability, reliability, and decision-usefulness ofsustainability-related risks and opportunities disclosure globally. These aims will only be fulfilled if
individual jurisdictions adopt the requirements of the IFRS Standards in full, prioritizing any use of
temporary reliefs over the omission of certain disclosure requirements.
We encourage the Sustainability Standards Board of Japan’s consideration of our feedback and areavailable to discuss further, if helpful. We can be reached at aaugustine@bostontrustwalden.com andjfernandez@bostontrustwalden.com.
Sincerely,Amy D. Augustine
Director of ESG Investing

Jared Fernandez
Senior ESG Analyst & Manager, Proxy Voting