July 22, 2024
Delivered via email to 2024ed01@ssb-j.jp
Dear Sir/Madam,
Re: Consultation on SSBJ Exposure Drafts
British Columbia Investment Management Corporation (BCI) is an investment manager with over
CAD $233 billion in assets under management, and one of the largest institutional investors in Canada.
Our investment activities help finance the pensions of approximately 725,000 people in our province,
including university and college instructors, teachers, health care workers, firefighters, police officers,
municipal and other public sector workers. On behalf of these pension beneficiaries, we provide longterm capital to companies around the world that we believe will deliver strong and stable financial
returns.
As a long-time supporter of the Sustainability Accounting Standards Board (SASB), and subsequently theInternational Sustainability Standards Board (ISSB), BCI welcomes the opportunity to provide feedback
to the Sustainability Standards Board of Japan (SSBJ) on its Exposure Drafts released in March 2024. Thisdevelopment is a significant milestone in the establishment of a global baseline of climate andsustainability-related financial disclosures for the capital markets in Japan.
Global alignment of sustainability-related financial disclosures
As a large institutional investor, with a globally diversified portfolio, BCI strongly believes in the benefitof globally consistent, comparable, and reliable sustainability-related financial disclosures. This
information is crucial to support investment decision making and allows investors to confidently assess
and manage associated risk exposure. BCI believes the best way to achieve the desired global baseline
across jurisdictions is through full alignment with the ISSB’s standards. These standards, IFRS S1 and S2
specifically, build on existing and broadly accepted frameworks and standards, such as the Task Forcefor Climate-Related Financial Disclosures (TCFD) recommendations and the SASB industry-specificstandards.
The IFRS standards have been endorsed by the International Organization of Securities Commissions(IOSCO) enhancing the prospect of global consistency, and success hinges upon the extent to which
global jurisdictions adopt the standards as they are. Deviations from both the climate and sustainability
standards, such as carve-outs, introduce the likelihood of reduced comparability and increase theburden and cost on issuers. We note that the ISSB’s approach includes the phasing in of requirements
which allow companies time to prepare for the new requirements.

July 22, 2024

With that view, we are pleased to see the close alignment between the ISSB standards and the proposed
standards from the SSBJ. Limiting modification of the IFRS S1 and S2 reduces fragmentation andincreases comparability for investors that deploy capital in many jurisdictions. BCI strongly supports theapproach of the SSBJ to incorporate all requirements from IFRS S1 and S2 into the SSBJ proposed
requirements. The addition of jurisdictional specifications chosen is also reasonable in our view.
BCI’s only caution for the SSBJ is the removal of B4 and B5 in the IFRS S1 standard as it relates toresources and relationships as well as dependencies and impacts. We do see these paragraphs asimportant and note their absence in the SSBJ exposure drafts. Without them, we are concerned thatcompanies may not consider their entire value chain in disclosing material sustainability information.
From our perspective, both upstream and downstream sustainability issues can have a material impacton financial performance so our preference would be to see further alignment with IFRS in thatparticular section.
Thank you again for the opportunity to opine on this important endeavour. We appreciate the attention
that the SSBJ is paying to this with the release of these exposure drafts. Strong alignment between IFRSSI and S2 and the SSBJ Exposure Drafts can place Japan in a leadership position and will be attractive toglobal investors like ourselves.
For any clarifications related to this submission please contact Susan Golyak, Director, ESG atsusan.golyak@bci.ca
Sincerely,Daniel Garant
EVP & Global Head, Public Markets
cc
Susan Golyak, Director, ESG

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