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Sarbanes-Oxley Compliance The U.S. Sarbanes-Oxley Act of 2002, combined with the Securities Exchange Commission's Regulation S-K, are dramatically affecting corporate financial and environmental reporting systems of publicly traded companies. Sarbanes-Oxley requires that directors take responsibility for keeping a system of disclosure controls and procedures and that the chief officers assume personal liability for the accuracy of corporate statements. The SEC's Regulation S-K Item 303 contains a general requirement to disclose "any known trends" that are reasonably likely to have a material effect on a company's "financial condition." The eventual impact of these developments on environmental reporting in general, and GHG reporting specifically, is not yet clear. Certainly, the seemingly inevitable trend toward GHG emissions controls will materially affect many companies. As a result, it makes sense for these firms to be thinking about how to anticipate these impacts for Sarbanes-Oxley and SEC Regulation S-K purposes. TC+ES is well-positioned to support companies' needs and objectives in this area and can help your firm navigate this complicated policy and market landscape. Based on our core competencies in environmental law, carbon risk management, and strategic planning, TC+ES has developed a package of products and services specifically geared towards companies' greenhouse gas reporting and planning needs. Cli-Mit Scorecard© helps companies generate and interpret the information they need to assess the potential materiality of their GHG emissions. The corporate benchmarking results are useful in positioning a company for new environmental tracking and reporting requirements. Cli-Mit Terrain Navigator©, using pre-positioned response strategies tied to quantifiable changes in a company's risk profile over time, allows companies to avoid speculative near-term investments, while still achieving early mover advantage in the future. Cli-Mit Terrain Index© is an expert model of GHG market, policy, and related trends. The Index monitors, evaluates, and documents the changing risk and opportunity context within which a company operates. The information generated through the Index is ideally suited to environmental materiality and trend reporting, and can play a key role in determining when to activate the pre-positioned strategies that make up the Cli-Mit Terrain Navigator©. Individually or in combination, this specialized suite of TC+ES products and services can cost-effectively support companies' evolving environmental reporting and strategy needs. |
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