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Retailers' Guide to Sustainability

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While the U.S. waits for the U.S. Securities and Exchange Commission's (SEC) sustainability disclosure proposals to emerge, large retailers that meet the designated criteria set out by the SEC for which companies will be required to report should not rest on their laurels when it comes to preparatory activities and future-proofing their reporting data. The proposed rule, unveiled in March 2022, would require publicly traded companies to disclose their greenhouse gas emissions and any climate-related financial risks to their operations within financial reports. This plan is considered to be monumental by many leaders in the finance and ESG space for the unusual nature in which it requires climate- related information and data to cut across all areas and sections of the traditional financial disclosure process and capital market regulation. It is a clear signal of how important climate and environmental concerns have become in the world of capital markets and the global economy. PREPARING FOR SEC CLIMATE DISCLOSURES MOST RECENT UPDATES AND PROGRESS AS OF SUMMER 2023: We can expect a final rule in October 2023: The SEC is currently making final adjustments to its proposed corporate climate disclosure rules. Former SEC Commissioner, Robert Jackson has indicated that the final publication of the climate disclosures is likely to be pushed back to Q3 of this year. Timelines will shift back due to delays: Given the new time frame, financial statements and disclosures under the rule would not be due until 2024 Expect amendments to initial drafts: Media reports and public statements by SEC Chair, Gary Gensler, indicate that the SEC is considering scaling back on scope 3 emissions requirements. Other amendments may include where emissions disclosures are provided within statements and a watering down of the materiality definition. Sustainability & Energy Management Simplified

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