Date: June 25, 2014

Issue: GRGI

To: International 

Filing Type: International 

Description: The GRGI welcomes the opportunity to comment on the Investors Listing Standards Proposal: Recommendations for Stock Exchange Requirements on Corporate Sustainability Reporting (“Proposal”). However, the GRGI has significant concerns that the Proposal conflicts with existing legal requirements for the materiality of disclosures and creates a “one-size-fits-all” approach that is too prescriptive for the nuanced and balanced needs of businesses and their investors. The Proposal also has the potential to conflict with efforts by regulators to improve disclosure effectiveness and enhance communications between businesses and their investors. Accordingly, the GRGI believes that the discussion of material disclosures of non-financial information should be had by domestic securities regulators rather than through exchange listing standards.

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