There may not be an obvious answer to whether an objectively reasonable investor would consider a particular company ' s GHG emissions data important in making an investment or voting decision , but there obviously would be significant pressure on a decision not to provide emissions disclosure on the basis that it is not material .
Other questions that companies might ask themselves include the following :
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What climate-related risks do we face , and have they materially affected , or are they reasonably likely to materially affect , our strategy , results of operations or financial condition ?
� What , if anything , have we done to mitigate or adapt to our material climate-related risks ?
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Have we set any climate-related goal or target , and , if so , has it materially affected , or is it reasonably likely to materially affect , our business , results of operations or financial condition ?
� What information that we are not currently disclosing will the new rules require us to disclose ?
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For information that we are currently disclosing , will the new rules require that information to be established , assembled or disclosed differently , or disclosed more expansively or granularly , from how we are doing it now ? If so , how ?
Which required disclosures might be particularly challenging for our company , such that they might merit special or prioritized focus ?
5 . Begin to evaluate existing systems and resources related to climate-related information , and identify changes that will need to be made .
Companies , particularly large accelerated filers , in some industries , such as energy or manufacturing , likely already have systems in place to collect much of the data called for by the new rules , and many public companies have been publishing voluntary disclosures in the form of ESG reports for years .
However , smaller companies in such industries may not currently have the resources necessary to devote to compliance with the new rules . Likewise , companies in non-GHG-intensive industries , such as financial services , previously may not have had the need , or had a more limited need , for such systems .
And even those companies that are experienced in collecting and disclosing climate-related data and other information likely will need to expand their systems to cover a much broader universe of information , and ensure that controls and procedures meet standards for disclosures in SEC-filed documents and are appropriate for enhanced scrutiny and potential liability that will come with including such disclosures .
Companies may need to invest significantly in new personnel with appropriate expertise and in new technology , and they will need to expand their disclosure controls and procedures — including design , implementation , and testing of such controls and procedures — to cover new sets of information that are wide-ranging , potentially voluminous and , in many cases , highly detailed .
Accordingly , public companies should begin to assess their existing capabilities and identify the changes they will need to make to comply with the new rules to ensure that the changes can be effected in accordance with the compliance timeline .