Securities and Exchange Commission (SEC) rules require companies
to disclose impacts or risks that are material to their business.
In September 2007 and again in November 2009, a coalition of
leading institutional investors petitioned the SEC to issue
guidance on existing SEC disclosure obligations as they relate to
climate change. Following this pressure, on January 27, 2010, the
SEC approved an interpretive release that addresses when
legislative or business developments relating to climate change
trigger disclosure obligations. Although the interpretative release
has not yet been issued, the SEC has indicated that disclosure
obligations may be triggered when a company evaluates, and
determines to be material to its business, (1) the impact of
existing (or in certain circumstances, proposed) legislation and
regulation relating to climate change; (2) the risks or effects of
international accords and treaties relating to climate change; (3)
the potential or actual
