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Number of employees:([ID284])
AuM benchmarked:([ID60])
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Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published? (see specific privacy statement)(contributions-publication)
1. The TEG believes that the sustainability disclosure requirements for all benchmarks in the methodology and in the benchmark statement should be distinguished by type of asset classes. Do you agree with this approach?([ID23])
2. Do you believe that non-significant benchmarks should disclose less information than significant benchmarks, in line with the proportionate approach set out in the benchmark regulation (Regulation (EU) 2016/1011)?([ID34])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Equities (annex I) ([ID86])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Fixed Income - Corporates & Securitised (ABS) (annex II) ([ID87])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Fixed Income – SSA (annex III) ([ID88])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Commodities (annex IV) ([ID89])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Infrastructure (annex V) ([ID90])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Private Equity, Private Debt, Infrastructure (annex VI) ([ID47])
3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII). On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs): : Hedge Funds (annex VII) ([ID48])
3.b Please indicate any KPI(s) you would not favor to include from the KPIs listed in section 3 of the Report:([ID3])
3.c) Please indicate any KPI(s) you would recommend to add to the KPIs listed in section 3 of the Report:([ID9])
4. Do you agree with the mandatory disclosure of ESG ratings for equity and fixed-income benchmarks?([ID25])
5. If relevant, please explain the impact of the disclosure of ESG ratings for equity and fixed income benchmarks on you, especially in terms of the costs and benefits implied:([ID26])
6.a The TEG has drawn up templates for the disclosure of ESG information in the benchmark statement and in the methodology (see templates 1 and 2 in Appendix D of the Report). On a scale from 1 to 5, please express your view regarding the format of these templates (1 indicating the lowest level of satisfaction regarding the format):([ID37])
6.b Would you have any suggestions to improve the format of the templates?([ID27])
6.c On a scale from 1 to 5, please express your view as to the cost of producing these templates (1 indicating the lowest level of cost of implementation):([ID43])
7 Do you agree that the template for ESG factors in the benchmark statement should be updated at least on a quarterly basis?([ID49])
If you responded "no" to question 7, what update frequency would you prefer? Do you have any further comments?([ID50])
8. Do you agree with the disclosures on overall degree of alignment with the objectives of the Paris Climate Agreement (template 3 in Appendix D)?([ID75])
8.b Would you have any suggestions to improve this template 3 (in terms of content and format)?([ID77])
9. Do you think that the CTB & PAB should disclose more information than the information requested in section 4.1 of the Report?([ID252])
If you responded "yes" to question 9, please provide any further comments and/or suggestions:([ID253])
10. What is the overall impact of the above technical advice on ESG disclosures, especially in terms of costs to benchmark administrators and benefits to investors? Please provide clear indication to which stakeholder your answer belongs.([ID76])
11. Do you see a need for guidance from the TEG on ESG data related charges similar to what is set out in the shareholder rights directive II.([ID173])
12. Do you think the CTB and the PAB differ methodology-wise sufficiently from each other?([ID178])
13.a Please express your agreement with the proposed minimum requirements for CTB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Minimum Scope 1+2(+3) carbon intensity reduction of 30 % compared to investable universe ([ID185])
13.a Please express your agreement with the proposed minimum requirements for CTB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Scope 3 phase-in (2 – 4 years) ([ID186])
13.a Please express your agreement with the proposed minimum requirements for CTB. Use the scale from 1 to 5 (with 1 indicating no agreement): : The green brown share ratio shall at least be equivalent to the green share/brown share ratio of the investable universe ([ID187])
13.a Please express your agreement with the proposed minimum requirements for CTB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Minimum exposure to sectors highly exposed to climate change issues is at least equal to market benchmark value ([ID188])
13.a Please express your agreement with the proposed minimum requirements for CTB. Use the scale from 1 to 5 (with 1 indicating no agreement): : At least 7% of annual decarbonisation: in line with or beyond the decarbonisation trajectory from the IPCC’s 1.5°C scenario (with no or limited overshoot) ([ID189])
13.b Please provide any comments on recommended changes or additions to the minimum requirements listed in question 13.a:([ID190])
14.a Please express your agreement with the proposed minimum requirements for PAB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Minimum Scope 1+2(+3) carbon intensity reduction of 30 % compared to investable universe ([ID198])
14.a Please express your agreement with the proposed minimum requirements for PAB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Scope 3 phase-in (2 – 4 years) ([ID199])
14.a Please express your agreement with the proposed minimum requirements for PAB. Use the scale from 1 to 5 (with 1 indicating no agreement): : The green brown share ratio shall at least be equivalent to the green share/brown share ratio of the investable universe ([ID200])
14.a Please express your agreement with the proposed minimum requirements for PAB. Use the scale from 1 to 5 (with 1 indicating no agreement): : Minimum exposure to sectors highly exposed to climate change issues is at least equal to market benchmark value ([ID201])
14.a Please express your agreement with the proposed minimum requirements for PAB. Use the scale from 1 to 5 (with 1 indicating no agreement): : At least 7% of annual decarbonisation: in line with or beyond the decarbonisation trajectory from the IPCC’s 1.5°C scenario (with no or limited overshoot) ([ID202])
14.b Please provide any comments on recommended changes or additions to the minimum requirements listed in question 14.a:([ID204])
15. Do you think that it would be relevant to extend the minimum requirements to sovereign indices?([ID210])
16. Do you believe that the requirement set out in the amending regulation (article 23a) for CTB & PAB to select, weight or exclude underlying asset that follow a decarbonisation trajectory should be further clarify in a minimum requirement?([ID214])
If you responded "no" to question 16, which kind of minimum requirement would you like to see in the delegated act?([ID215])
17. Do you think the scenario selected to drive the decarbonisation trajectory – IPCC 1.5° with no or limited overshoot – is the most appropriate one?([ID219])
If you responded "no" to question 17, please provide any further comments and/or suggestions:([ID220])
18. Do you think the minimum standards suggested in the report leave enough flexibility for market players to further innovate in the field of climate indices aligned with ambitious climate trajectories?([ID231])
If you responded "no" to question 18, please provide any further comments and/or suggestions:([ID232])
19. Do you agree having different denominators (e.g. total capital, revenue) for the calculation of the GHG intensity depending on the use case (table 6 in Section 5.3.3 in the Report)?([ID236])
If you responded "no" to question 19, please provide any further comments and/or suggestions:([ID237])
20. Do you believe that the definition of total capital (i.e. 'the sum of the book values of common stock, preferred equity, long term debt and minority interest') for the calculation of the GHG intensity is accurate?([ID241])
If you responded "no" to question 20, please provide any further comments and/or suggestions:([ID242])
21. What is the overall impact of the technical advice on CTBs and PABs, especially in terms of costs to benchmark administrators and benefits to investors?([ID254])
22. Do you see merits in further aligning the proposed benchmarks methodologies with the principles of the taxonomy once the latter is approved?([ID8])
Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:(file-upload)
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Are you replying as a(n):

Please specify in what other capacity your are replying:
Name of your organisation:
Is your organisation included in the Transparency Register?
(If your organisation is not registered, we invite you to register here, although it is not compulsory to be registered to reply to this consultation. Why a transparency register?)
If so, please indicate your Register ID number:
Number of employees:
AuM benchmarked:
AuM owned:
Where is your organisation based?

Please specify in what other region is your organisation based:
Contributions received are intended for publication on the Commission’s website. Do you agree to your contribution being published?
(see specific privacy statement)

1. The TEG believes that the sustainability disclosure requirements for all benchmarks in the methodology and in the benchmark statement should be distinguished by type of asset classes. Do you agree with this approach?

2. Do you believe that non-significant benchmarks should disclose less information than significant benchmarks, in line with the proportionate approach set out in the benchmark regulation (Regulation (EU) 2016/1011)?

3.a The TEG has identified different types of KPIs of the benchmarks for the respective asset classes (see Section 3 of the TEG report on climate benchmarks and ESG benchmarks’ disclosures - 'the Report' - Annex I to VII).

On a scale from 1 to 5, please express your view as to the level of satisfaction for the suggested KPIs for the respective asset class of benchmarks (1 indicating the lowest level of satisfaction regarding the KPIs):

3.b Please indicate any KPI(s) you would not favor to include from the KPIs listed in section 3 of the Report:

3.c) Please indicate any KPI(s) you would recommend to add to the KPIs listed in section 3 of the Report:

4. Do you agree with the mandatory disclosure of ESG ratings for equity and fixed-income benchmarks?

5. If relevant, please explain the impact of the disclosure of ESG ratings for equity and fixed income benchmarks on you, especially in terms of the costs and benefits implied:

6.a The TEG has drawn up templates for the disclosure of ESG information in the benchmark statement and in the methodology (see templates 1 and 2 in Appendix D of the Report).

On a scale from 1 to 5, please express your view regarding the format of these templates (1 indicating the lowest level of satisfaction regarding the format):

6.b Would you have any suggestions to improve the format of the templates?

6.c On a scale from 1 to 5, please express your view as to the cost of producing these templates (1 indicating the lowest level of cost of implementation):

7 Do you agree that the template for ESG factors in the benchmark statement should be updated at least on a quarterly basis?

If you responded "no" to question 7, what update frequency would you prefer? Do you have any further comments?

8. Do you agree with the disclosures on overall degree of alignment with the objectives of the Paris Climate Agreement (template 3 in Appendix D)?

8.b Would you have any suggestions to improve this template 3 (in terms of content and format)?

9. Do you think that the CTB & PAB should disclose more information than the information requested in section 4.1 of the Report?

If you responded "yes" to question 9, please provide any further comments and/or suggestions:

10. What is the overall impact of the above technical advice on ESG disclosures, especially in terms of costs to benchmark administrators and benefits to investors? Please provide clear indication to which stakeholder your answer belongs.

11. Do you see a need for guidance from the TEG on ESG data related charges similar to what is set out in the shareholder rights directive II.

12. Do you think the CTB and the PAB differ methodology-wise sufficiently from each other?

13.a Please express your agreement with the proposed minimum requirements for CTB.

Use the scale from 1 to 5 (with 1 indicating no agreement):

Minimum Scope 1+2(+3) carbon intensity reduction of 30 % compared to investable universe

Scope 3 phase-in (2 – 4 years)

The green brown share ratio shall at least be equivalent to the green share/brown share ratio of the investable universe

Minimum exposure to sectors highly exposed to climate change issues is at least equal to market benchmark value

At least 7% of annual decarbonisation: in line with or beyond the decarbonisation trajectory from the IPCC’s 1.5°C scenario (with no or limited overshoot)

13.b Please provide any comments on recommended changes or additions to the minimum requirements listed in question 13.a:

14.a Please express your agreement with the proposed minimum requirements for PAB.

Use the scale from 1 to 5 (with 1 indicating no agreement):

Minimum Scope 1+2(+3) carbon intensity reduction of 30 % compared to investable universe

Scope 3 phase-in (2 – 4 years)

The green brown share ratio shall at least be equivalent to the green share/brown share ratio of the investable universe

Minimum exposure to sectors highly exposed to climate change issues is at least equal to market benchmark value

At least 7% of annual decarbonisation: in line with or beyond the decarbonisation trajectory from the IPCC’s 1.5°C scenario (with no or limited overshoot)

14.b Please provide any comments on recommended changes or additions to the minimum requirements listed in question 14.a:

15. Do you think that it would be relevant to extend the minimum requirements to sovereign indices?

16. Do you believe that the requirement set out in the amending regulation (article 23a) for CTB & PAB to select, weight or exclude underlying asset that follow a decarbonisation trajectory should be further clarify in a minimum requirement?

If you responded "no" to question 16, which kind of minimum requirement would you like to see in the delegated act?

17. Do you think the scenario selected to drive the decarbonisation trajectory – IPCC 1.5° with no or limited overshoot – is the most appropriate one?

If you responded "no" to question 17, please provide any further comments and/or suggestions:

18. Do you think the minimum standards suggested in the report leave enough flexibility for market players to further innovate in the field of climate indices aligned with ambitious climate trajectories?

If you responded "no" to question 18, please provide any further comments and/or suggestions:

19. Do you agree having different denominators (e.g. total capital, revenue) for the calculation of the GHG intensity depending on the use case (table 6 in Section 5.3.3 in the Report)?

If you responded "no" to question 19, please provide any further comments and/or suggestions:

20. Do you believe that the definition of total capital (i.e. 'the sum of the book values of common stock, preferred equity, long term debt and minority interest') for the calculation of the GHG intensity is accurate?

If you responded "no" to question 20, please provide any further comments and/or suggestions:

21. What is the overall impact of the technical advice on CTBs and PABs, especially in terms of costs to benchmark administrators and benefits to investors?

22. Do you see merits in further aligning the proposed benchmarks methodologies with the principles of the taxonomy once the latter is approved?

Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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