Policy Consultations

Where relevant, the FAIRR Initiative seeks to respond to policy-related consultations and the work of our investor members. You can find a list of the most recent consultations below.

If there are other policy-related consultations where we can offer advice or support, please let us know by getting in touch.

Consultation Responses in 2023

Request for Information: National Biotechnology and Biomanufacturing Initiative

FAIRR’s response to the request for information highlighted the US government’s potential to invest in emerging protein biotechnologies and scale up of biomanufacturing in order to mitigate the ESG risks associated with existing agricultural practices.

Consultation Responses in 2022

European Commission - Draft Delegated Regulation

In 2022, the EU Regulation (EU) 2019/6 to reduce the misuse and overuse of antibiotics by the animal protein sector came into effect. In FAIRR’s consultation response we recognise that, if supported properly by this Delegated Act and the subsequent implementing Act, this new regulation has a great potential to shift the current dire trajectory on AMR. As antimicrobial resistance (AMR) knows no boundaries and contributes to millions of deaths a year, EU leadership on this issue is a much-needed intervention in bringing a major future global health and economic crisis under control. FAIRR’s detailed response can be found here:

International Sustainability Standards Board (ISSB)

The ISSB’s commitment to producing and enhancing a comprehensive global baseline of sustainability disclosures for the capital markets is a welcome development. FAIRR's response to the IFRS Consultation on the Exposure Draft for the IFRS Sustainability Disclosure Standard: IFRS S2 Climate-related disclosures can be viewed here:

European Financial Reporting Advisory Group (EFRAG)

The European Financial Reporting Advisory Group’s (EFRAG) opened a public consultation on the first set of draft European Sustainability Reporting Standards (ESRS). FAIRR commend the European Financial Reporting Advisory Group on the publication of the first set of draft standards, as investors increasingly need robust standards for the disclosure of sustainability-related information. FAIRR’s detailed response to selected questions from the consultation can be found here:

The Partnership for Biodiversity Accounting Financials (PBAF)

There is a growing awareness among financial institutions (FIs) that both the impacts and the dependencies on biodiversity are highly relevant, both from a risk and an opportunity perspective. The FAIRR Initiative has responded to PBAF’s consultation and highlighted the importance of discussing the TNFD, sustainable proteins and land-use considerations.

European Bank for Reconstruction and Development (EBRD)

Following EBRD’s commitment to aligning its activities with the Paris Agreement by the end of 2022, FAIRR chose to respond and highlight the importance of aligning indirectly financed investments with this goal also. FAIRR’s response highlighted the importance of aligning “best practice” with that of the Science-Based Targets Initiative and highlighted the scope of company disclosure, based on experience with the Coller FAIRR Protein Producer Index.

Department for Environment, Food and Rural Affairs (DEFRA)

DEFRA launched its consultation on the implementation of its world-leading due diligence provisions in the Environment Act to help tackle illegal deforestation in UK supply chains. The FAIRR Initiative highlighted the challenges in protein supply chains and linked the consultation to FAIRR's research and data, available via the Coller FAIRR Protein Producer Index.

Consultation Responses in 2021

European Commission's Platform on Sustainable Finance (PSF)

The PSF was established to assist in the development of sustainable fiscal policies, such as the EU taxonomy. The EU Taxonomy represents a key tool to ensure that finance is directed towards sustainable activities and projects, including achieving the EU’s target of reaching net-zero emissions. Our response calls for antibiotic risk to be included as part of the ‘Do No Significant Harm’ criteria and highlights the impact of intensive animal agriculture on biodiversity and deforestation.

The European Investment Bank (EIB)

As well as being the lending arm of the European Union, the EIB is the biggest multilateral financial institution in the world and one of the largest providers of climate-related finance. This consultation relates to the EIB’s vision for 2030, namely its Environmental and Social Sustainability Framework, and includes comments on its approach to sustainability for the environment, as well as social impacts, such as human rights.

United Nations Framework Convention on Climate Change (UNFCCC)

The UNFCCC's Standing Committee on Finance (SCF) is holding a forum on ‘Finance for Nature-based Solutions’ to provide a wide range of stakeholders with a platform to promote linkages and coherence in climate finance. Our response has highlighted the need to consider investment in nature-based solutions in collaboration with the private sector, current barriers to financing nature-based solutions and the topic of a just transition for food system workers.

Taskforce for Nature-Related Financial Disclosures (TNFD)

The FAIRR Initiative agrees with the broad goals outlined in the consultation document. However, we also recommend giving more attention to how nature-related financial risks should be treated and distinguishing between risk types to increase the visibility of likely solutions. Further improvements that were identified include carrying out an early assessment of nature-related metrics and establishing links between the TNFD work and the UN CBD process.

United States' Securities and Exchange Commission (SEC)

The FAIRR Initiative has supported the SEC’s increased interest in ESG disclosures and endorsed the need for mandatory and standardised disclosure on these issues. We highlighted the current lack of clarity and comparability in environmental disclosure and recommended making this mandatory. We suggested that the SEC developed rules in collaboration with third-party providers of voluntary disclosure frameworks whilst increasing its ambition and rigour in the new standards developed.

European Bank for Reconstruction and Development (EBRD)

The FAIRR Initiative has concluded that the current list of “Paris-aligned” projects does not align with the consensus on the transformations needed to limit warming to 1.5 degrees. On agriculture, we asked for more detail relating to "fishing and aquaculture" and "non-ruminant livestock with negligible lifecycle GHG emissions" in Paris-aligned activities. Particular areas for consideration include feed production, sustainable proteins, and effluent and manure management.