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ClientEarth argues that the UK's Capacity Market (CM) may be over-procuring capacity and risks subsidising fossil fuels, thereby undermining the coal phase-out and the Paris Agreement. The organisation recommends making Emissions Performance Standard (EPS) and LCP BREF compliance mandatory for CM entry, removing very long-term contracts to prevent fossil-fuel lock-in, and reducing financial barriers for demand-side response (DSR) and storage. It further suggests introducing a specific 'climate and competition' objective for the CM and reforming the cost-recovery methodology to provide sharper price signals for DSR. ClientEarth also calls for an independent resource adequacy assessment that accounts for the growth of distributed energy resources and interconnection.

ClientEarth calls on EU Member States and the European Parliament to veto a European Commission proposal that seeks to change the conditions for using endocrine disruptors (EDCs) in pesticides. The document argues that the Commission is attempting to replace a ban based on 'negligible exposure' with one based on 'negligible risk', which ClientEarth claims is an illegal encroachment on the powers of the EU legislature and is not supported by new scientific evidence.

ClientEarth has challenged Deloitte LLP's audit of Bodycote PLC's 2017 Annual Report, asserting that the report contains material misstatements due to the omission of climate change and low carbon transition risks. ClientEarth contends that as an energy-intensive industrial manufacturer, Bodycote is materially exposed to these risks, yet the Annual Report only provides mandatory greenhouse gas emissions disclosures and a general corporate responsibility discussion. The organization argues that Deloitte, despite being a supporter of the Task Force on Climate-related Financial Disclosures (TCFD) and possessing institutional expertise on climate risks, failed to apply professional scepticism and judgement under International Standards on Auditing (ISAs). Specifically, ClientEarth suggests Deloitte breached ISA (UK) 200, 315, and 720 by not ensuring the strategic and directors' reports were prepared in accordance with legal requirements regarding the description of principal risks and future business trends. ClientEarth has submitted a complaint to the Financial Reporting Council (FRC) and requested that Deloitte explain its processes for integrating climate-related knowledge into its audit programmes.

ClientEarth has challenged Ernst & Young LLP (EY) regarding its audit of EnQuest PLC's 2017 Annual Report and Accounts. ClientEarth contends that EnQuest failed to disclose material risks and trends associated with climate change and the low carbon transition, which should have been identified by EY under International Standards on Auditing (ISAs). The letter argues that EY's own institutional knowledge and public support for the Task Force on Climate-related Financial Disclosures (TCFD) make its failure to flag these omissions particularly problematic. ClientEarth has submitted a complaint to the Financial Reporting Council (FRC) and requested that EY explain its processes for integrating climate risk knowledge into its audit programmes.

ClientEarth has notified KPMG of its intent to complain to the Financial Reporting Council (FRC) regarding the audit of Balfour Beatty PLC's 2017 Annual Report. ClientEarth argues that Balfour Beatty failed to provide an adequate description of principal risks, main trends, and long-term viability by omitting the impacts of climate change and the low carbon transition. The letter asserts that KPMG, despite its public support for the Task Force on Climate-related Financial Disclosures (TCFD) and its own institutional expertise, failed to apply professional scepticism and judgement as required by International Standards on Auditing (ISAs). ClientEarth specifically questions KPMG's processes for ensuring climate knowledge is integrated into audit programmes and how it identifies material inconsistencies or misstatements in strategic and directors' reports.

ClientEarth has challenged PwC's audit of EasyJet PLC's 2017 Annual Report, alleging that the report contains material misstatements due to the omission of climate change-related risks and the low carbon transition. ClientEarth contends that as an international airline, EasyJet is materially exposed to these trends, yet the report only provides mandatory greenhouse gas emissions disclosures and a general 'corporate responsibility' discussion. The organization argues that PwC, despite its public support for the Task Force on Climate-related Financial Disclosures (TCFD) and its own expertise in climate risk, failed to apply professional scepticism and judgement as required by International Standards on Auditing (ISAs). ClientEarth has submitted a complaint to the Financial Reporting Council (FRC) and questioned PwC on its processes for integrating climate knowledge into audit programmes and identifying material inconsistencies in strategic reports.

ClientEarth and Seas At Risk recommend that the European Commission reject or strictly condition landing obligation exemptions that lack sufficient scientific evidence. They argue that 'temporary' exemptions should be limited to one year and tied to binding roadmaps for improving selectivity and survivability. The authors highlight a decline in the quality of data submitted for de minimis exemptions and warn that failing to account for dead discards in 'high survival' exemptions could increase fishing mortality and jeopardize Maximum Sustainable Yield (MSY) objectives.

ClientEarth warns the Aviva Staff Pension Scheme trustees that treating climate change as a general ESG issue rather than a specific material financial risk may expose them to legal challenges for breach of fiduciary duty. The letter outlines the financial risks of high-carbon assets, the opportunities in the low-carbon transition, and emerging market standards among OECD asset owners. It provides a detailed set of recommended actions, including reallocating capital away from coal and risky fossil fuels, adopting TCFD-aligned reporting, and implementing active stewardship policies to ensure the long-term security of members' retirement outcomes.

ClientEarth warns the BAE Systems Main Scheme trustees that ignoring climate risk could lead to legal challenges for breach of fiduciary duty. The letter outlines material financial risks associated with fossil fuels, the opportunities of a low-carbon transition, and emerging market standards among OECD asset owners. It provides a detailed set of recommended actions, including reallocating capital away from coal and high-risk fossil fuels, adopting TCFD-aligned reporting, and pursuing active stewardship of portfolio companies.

ClientEarth warns the BP Pension Fund trustees that ignoring climate-related financial risks may constitute a breach of fiduciary duty and jeopardize member retirement outcomes. The letter outlines material risks associated with fossil fuel assets, highlights emerging market standards for climate-aware investing among OECD asset owners, and provides a detailed set of recommended actions for the fund to safeguard its assets and align with the Paris Agreement.

ClientEarth warns the Electricity Supply Pension Scheme trustees that failing to manage climate-related financial risks may constitute a breach of fiduciary duty. The letter highlights that many of the scheme's group trustees currently lack explicit climate policies, often delegating ESG considerations to managers without formal determination of risk. ClientEarth provides evidence that fossil fuel assets, particularly coal, are highly exposed to transition and physical risks, while low-carbon indices have shown competitive or superior returns. It further notes a growing market standard among OECD asset owners toward divestment and robust climate governance. The document concludes with a detailed set of recommended actions, including reallocating capital away from coal and risky fossil fuels, adopting TCFD-aligned reporting, and pursuing active stewardship of portfolio companies.

ClientEarth warns the Ford Pension Fund trustees that failing to consider climate change as a material financial risk may constitute a breach of fiduciary duty. The letter outlines the financial risks of fossil fuel assets, the opportunities in low-carbon investments, and emerging market standards among OECD asset owners. It concludes with a detailed set of recommended actions, including asset reallocation away from coal and the adoption of TCFD-aligned reporting.

ClientEarth argues that the Lloyds Bank Pension Scheme trustees may be failing their fiduciary duties by not sufficiently addressing climate risk. The letter outlines the material financial risks of climate change, particularly for fossil fuel assets, and the opportunities in the low-carbon transition. It provides a framework for action, including reallocating assets away from coal and high-carbon sectors, adopting TCFD-aligned reporting, and pursuing active stewardship of portfolio companies.

ClientEarth warns the Mineworkers’ Pension Scheme trustees that failing to address climate-related financial risks may constitute a breach of fiduciary duty. The letter outlines the material risks associated with fossil fuel assets, the opportunities in the low-carbon transition, and emerging market standards for asset owners. It provides a detailed set of recommended actions, including reallocating capital away from coal and high-carbon assets, adopting TCFD-aligned reporting, and pursuing active stewardship of portfolio companies.

ClientEarth warns the National Grid UK Pension Scheme trustees that treating climate risk merely as part of general ESG issues may be insufficient to meet their legal obligations. The letter outlines material financial risks associated with fossil fuels, the potential for returns from low-carbon investments, and emerging market standards for asset owners. It concludes with a set of recommended actions, including reallocating capital away from coal and high-carbon assets, adopting TCFD-aligned reporting, and pursuing active stewardship of portfolio companies.

The document argues that climate change represents a material financial risk that pension trustees must consider to fulfill their legal duty to act in the best interests of members. It highlights the vulnerability of fossil fuel assets, the potential for low-carbon investment returns, and emerging market standards among OECD asset owners. ClientEarth provides a detailed framework for the scheme to evaluate risk, reallocate assets away from coal and high-risk fossil fuels, and implement active stewardship and TCFD-aligned reporting.

ClientEarth warns the Rolls-Royce Pension Scheme trustees that treating climate risk merely as a general ESG issue may expose them to legal challenges for breach of fiduciary duty. The letter asserts that climate change is a material financial risk, particularly for fossil fuel assets, and that transitioning to low-carbon investments can protect portfolios without sacrificing returns. It provides a detailed framework for action, including reallocating capital away from coal and high-risk fossil fuels, adopting TCFD-aligned reporting, and implementing active stewardship policies to ensure portfolio companies align with the Paris Agreement.

ClientEarth warns the Shell Contributory Pension Fund trustees that failing to strategically manage climate risk may breach their fiduciary duty to act in the best interests of members. The letter asserts that climate change is a material investment risk and provides evidence that fossil fuel assets, particularly coal, are highly exposed to financial losses. It highlights emerging market standards among OECD asset owners, including the use of TCFD frameworks and divestment policies. ClientEarth recommends specific actions: evaluating physical and transitional risks, reallocating capital away from coal and risky fossil fuels, and pursuing active stewardship to align portfolio companies with the Paris Agreement.

ClientEarth argues that the Tesco Pension Scheme trustees may be breaching their fiduciary duties by failing to identify and mitigate specific climate change risks. The letter asserts that climate risk is a material financial risk and provides evidence that fossil fuel assets, particularly coal, are highly exposed to losses. It further claims that low-carbon investing does not compromise returns and that market standards are shifting toward robust climate governance and divestment. ClientEarth recommends a series of actions, including reallocating capital away from coal and risky fossil fuels, adopting TCFD-aligned reporting, and implementing active stewardship policies to ensure portfolio resilience.

ClientEarth evaluates the European Commission's communication on 2019 fishing opportunities, welcoming the move toward FMSY targets and the use of ICES landings advice for the Baltic and North Sea. However, the organization expresses significant concerns regarding the use of FMSY ranges in multiannual plans, the lack of transparency in reporting, and the potential for lowering ambitions for stocks categorized as 'bycatch'. It specifically warns against the removal of Total Allowable Catches (TACs) and the use of socio-economic arguments to delay the 2020 MSY deadline.