We are thankful for the opportunity to make submissions on the Canadian Association of Pension Supervisory Authorities’ (CAPSA‘s) draft Guideline on Environmental, Social and Governance Considerations in Pension Plan Management (ESG Guideline).

The Canada Climate Law Initiative (CCLI) supports the three very broad principles contained in the Guideline; however, our view is that the baseline it sets by including only three principles is too low and not in alignment with regulatory developments internationally. CCLI believes that pension climate governance should have specific requirements, as we discuss in our letter to CAPSA.