Wellington selectively participates in industry groups and trade associations that occasionally provide collective feedback to regulators on issues that directly impact responsible investment or the asset management industry at large. For example, members of our Legal and Compliance team have participated in discussions with the Investment Company Institute (ICI) to listen to and provide feedback to inform the collective view on shareholder rights issues, including shareholder proposals and the role of proxy advisory firms, so that these views may be relayed to the U.S. Securities and Exchange Commission (SEC) in the form of comment letters. Wellington is largely in agreement with the balanced view presented by ICI on this issue. In addition, Wendy Cromwell, Vice Chair, Director, Sustainable Investment, and PRI board director, signed PRI's sign-on letter to the SEC, opposing these changes, on behalf of Wellington. The letter has been posted in the SEC's comment files.
In addition, members of our Compliance team are participating in the Investment Association's collaboration to provide guidance to the UK investment management industry implements the new requirements of the EU Shareholder Rights Directive implementation by the Financial Conduct Authority (FCA).
Wellington signed the Global Investor Statement to Governments on Climate Change, reiterating support for coordinated policy development to accelerate investment in the low-carbon transition and to enhance climate-related financial reporting. Chris Goolgasian, Director of Climate Research, was asked to be a member of the Commodity Futures Trading Commission (CFTC) Market Risk Advisory Climate Risk Subcommittee and is an active member. This subcommittee aims to identify challenges to managing climate risks and ways to bolster scenario analysis, reporting, and governance efforts, and to explore potential policy initiatives and best practice for risk disclosure.