Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules
Reynolds Holding
APRIL 21, 2022
Of most importance for financial institutions, the identified categories also include downstream activities such as “investments” (Category 15 of the GHG Protocol’s Scope 3 emissions categories), which would capture financed emissions ( i.e. , emissions from companies to which the financial institution provides debt or equity financing).
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