BlueMark comment letter to SEC on climate change disclosures

BlueMark comment letter to SEC on climate change disclosures

This comment letter was also published on the SEC website here. The full text is included below.

Re: Public Statement: Public Input Welcomed on Climate Change Disclosures, Acting Chair Allison Herren Lee, March 15, 2021.

Chair Gensler,

I am writing this comment letter on behalf of BlueMark, a specialist provider of impact verification services for investors and companies. BlueMark was founded in January 2020 to meet the market demand for reliable, independent verification of the impact in impact investments, brought on by the rapid growth in this segment of the capital markets. To date, BlueMark has completed over 35 verifications for institutional investors of varying types and sizes on both their impact management practices (their systems, processes, and capabilities to manage impact as an integral component of the investment process) and impact performance (their reported impact results).

My own background includes 15 years at JP Morgan where I ran several risk management groups, including for the credit portfolio and emerging markets trading businesses, as well as the firm’s sovereign credit ratings advisory business. This experience provided me a first-hand perspective regarding how capital allocation decisions are made and the critical building blocks supporting development of new markets, including smart regulation, adoption of robust voluntary industry standards, and a mechanism to hold actors accountable to both.

Our view on the SEC’s role in climate change disclosures

Like many other investors and investor groups, we support the SEC’s intention to improve the consistency, reliability and quality of climate change disclosures by corporate issuers – and a variety of standards and frameworks exists for the SEC to draw from. We believe such a move is consistent with the SEC’s mission to 1) protect investors; 2) ensure fair, orderly, and efficient markets; and 3) facilitate capital formation.

However, this mission cannot be fulfilled with disclosures alone. Third-party assurance also plays an important role in driving market discipline and accountability, while also increasing the efficiency of asset allocation decisions. We have written about the importance of robust thirdparty verification in previous comment letters about related regulatory efforts. As we wrote in our comment letter to the IFRS Foundation regarding their proposal to create a Sustainability Standards Board (SSB):

“It is imperative that the Foundation allows for a range of service providers – beyond the traditional accounting firms – to provide external assurance services to verify the accuracy and completeness of sustainability reporting. We strongly believe that specialized firms like BlueMark bring an expertise and perspective to third-party assurance that extends well beyond the typical sustainability metrics to include the full range of qualitative and quantitative information necessary to form a complete understanding of sustainability practices and performance.”

We are pleased to have this opportunity to also contribute to the SEC’s efforts on climate change disclosures.

Addressing question #10 on the auditing and assurance of climate change disclosures

The growing threat of greenwashing and impact-washing—whereby what investors and companies actually do to address sustainability issues contradicts or falls short of what they say they do—is a major barrier to market confidence and the efficient flow of capital. According to the 2020 Annual Impact Investor Survey from the Global Impact Investing Network (GIIN), the biggest challenge facing impact investors over the next five years is “concerns about impact washing” (66%), followed by the market’s “inability to demonstrate impact results” (35%) and the “inability to compare impact results with peers” (34%). The survey also found that “comparability and validation of impact performance can address investor’s concerns regarding impact washing.”

We believe that smart regulation—which leverages voluntary standards and specialized, thirdparty impact assurance in addition to direct government regulation and policy—will help to solve for these challenges by bringing increased transparency, accountability, and discipline to the impact investing market.

The impact investing industry has already made some progress in adopting both robust voluntary standards and engaging third-party verification providers like BlueMark. For example, the Operating Principles for Impact Management (“Impact Principles”) were introduced in April 2019 as a set of best practices for how to integrate impact considerations throughout the investment lifecycle, from strategy design to portfolio management to exit. These Principles also include a requirement that all signatories seek independent verification of their alignment. Today, about 130 impact investors of various types and sizes, representing nearly $400 billion in combined impact-labeled assets under management, have signed onto these Impact Principles.

CDP, which runs a disclosure system that investors, companies, cities, states and regions use to manage their environmental impacts, also encourages submissions to include a third-party verification completed in accordance with recognized verification standards. According to CDP, more than 590 investors with a combined $110 trillion in assets have requested that companies disclose through CDP.

Other standard-setters are working on instituting similar verification requirements, including the Principles for Responsible Investment (PRI) and the SDG Impact Standards recently introduced by the United Nations Development Programme (UNDP). The impact investing market has matured rapidly in recent years as more investment managers adopt these standards, thereby helping protect asset owners and ensuring more capital flows to best-in-class impact investors.

We believe the SEC can help catalyze the adoption of these standards and frameworks by issuing guidance that encourages companies and investors to seek third-party assurance as a way to hold themselves accountable and make markets more fair and efficient. Such guidance could include:

  • Information on the types of disclosures required, including on both practices (processes) and performance (results)
  • Clarification of the relevant standards to which disclosures should be aligned (e.g., CDP, GRI, SASB, TCFD, etc.)
  • Encouragement for issuers and investment managers to engage third-party assurance providers rather than an internal audit approach to enable standardization and avoid conflicts of interest
  • Regular reviews of assurance processes and statements to ensure quality control, spotlight industry trends and proactively address any issues

While the immediate focus is on climate change disclosures, we believe it is imperative that the SEC cast a wider lens to encourage greater transparency and disclosure of other relevant ESG issues beyond climate change. Such issues may include diversity of board, management, and staff; pay ratios; political spending; etc. The SEC can also play an important role in signaling corporate responsibility to consider issues relevant to a broader set of stakeholders than shareholders alone, especially given the interconnectedness between climate change and other urgent social and economic issues.

Indeed, BlueMark’s verification services are designed with this broader stakeholder perspective in mind, directly responding to the needs of impact investors. Other types of investors–whether employing an ESG, sustainable or impact investment strategy–are also increasingly demanding this information as an input into investment decision-making. The number of investors that now seek company disclosures in alignment with SASB or TCFD are proof of this demand, and a sign of the growing importance of consistent and comparable disclosures in the years ahead.

We welcome any questions on the contents of this letter, and we look forward to working with both regulators and standard-setters to bring increased transparency and stability to financial markets.


Christina Leijonhufvud

CEO & Co-Founder of BlueMark

Managing Partner & Co-Founder of Tideline

ANNOUNCEMENT – “BlueMark Launches First-of-its-Kind Benchmark for Best Practices in Impact Management”

ANNOUNCEMENT – “BlueMark Launches First-of-its-Kind Benchmark for Best Practices in Impact Management”

BlueMark Launches First-of-its-Kind Benchmark for Best Practices in Impact Management

New tool designed for financial market participants looking to differentiate between impact leaders and impact learners

Benchmark based on 30 impact verifications of investor alignment with the Operating Principles for Impact Management, as highlighted in BlueMark’s second annual “Making the Mark” report


MAY 10, 2021 — BlueMark, a leading provider of independent impact verification services for investors and companies, announced the creation of a first-of its-kind benchmark for tracking best practices in impact management. Designed to root out impact-washing, BlueMark’s benchmark allows market participants to readily differentiate between impact leaders and learners.

The benchmark is based on aggregated data and insights from 30 impact verifications for investors with a combined $99 billion in impact assets under management on their alignment with the Operating Principles for Impact Management (“Impact Principles”), the leading market standard for impact management practices. Each BlueMark impact verification involves conducting multiple interviews with client teams and reviewing hundreds of pages of investment policies, transaction documents, data, and reports. The full report, “Making the Mark: The Benchmark for Impact Investing Practice,” which was developed with support from The Rockefeller Foundation, is available at

The benchmark includes three distinct categories that define the practices of leading, median and learning impact investors, providing a dynamic understanding of what it means to rigorously manage for impact. While the research sample analyzed by BlueMark reflects impact investors that have committed to pursue alignment with the Impact Principles, thereby embracing industry best practices, there are still revealing differences in how different investors approach impact management.

  • Practice Leaders – Practice Leaders are in the top quartile of the sample (75th percentile and above). These standard-bearers implement all of the core elements of impact management, as well as several leading-edge practices that may go above and beyond best practices. They are also committed to further learning and improvement that helps to continually advance the bar for best practice.
  • Practice Median – The Practice Median reflects the impact management practices of the median impact investor in the research sample (50th percentile). Investors at the Practice Median implement many of the core elements of impact management, but also have significant room for development.
  • Practice Learners – Practice Learners are in the bottom quartile of the sample (25th percentile and below). These investors have well-articulated impact intentions, but they lack some of the core impact management practices needed to generate positive impact. Many are early in their impact investing journeys, while others have yet to embed impact considerations at key stages of the investment process.

“The idea of a benchmark is essential to the continued institutionalization and maturation of the impact investing market,” said Christina Leijonhufvud, CEO of BlueMark and lead author of the report. “By establishing a shared consensus on best practices in impact management, we have created a valuable tool that we hope market participants can use to improve their own practices and to see where they stand against their peers.”

The 30 impact verifications cover a broad range of investor types and asset classes and highlight key opportunities and challenges for practitioners. Key findings include:

  • Growing consensus around the SDGs. 93% of impact investors in the sample align their investments with the Sustainable Development Goals (SDGs), and 48% specifically align with the 169 targets underlying the SDGs
  • Alignment of incentives with impact still in early stages. 43% directly align staff incentive systems with impact performance, including 17% that tie annual bonuses to impact and 3% that tie carry to impact
  • More effort needed to systematically avoid harm. 90% identify select ESG risks in their investment decisions, but only 43% systematically engage investees to address ESG gaps and unexpected risks
  • Impact performance needs to be more inclusive of stakeholders. 57% compare actual with expected impact performance, yet just 11% solicit input from key stakeholders to understand their impact performance
  • Impact management is a continuously iterative process. 32% monitor and review unexpected positive and negative impacts, and 30% use learnings from impact performance reviews to improve investment decisions and portfolio management

“For impact investing to have the power it can, the world and investors need to be able to see and measure impact—transparency is central to its integrity,” said Dr. Rajiv J. Shah, President of The Rockefeller Foundation, one of the founding investors in BlueMark. “Impact verification will help us hold investors accountable for both their claims and their practices.”

BlueMark will continue to update the Practice Benchmark as the firm completes additional verifications. BlueMark is also working on developing a similar benchmark for measuring and tracking impact performance.

The impact investing organizations that have had their impact management systems verified by BlueMark include: Bain Capital Double Impact, Big Society Capital, BlueOrchard Finance, Calvert Impact Capital, CDC Group, Community Investment Management, Closed Loop Partners, DEG – Deutsche Investitions- und Entwicklungsgesellschaft mbH, European Bank for Reconstruction and Development (EBRD), EDFI Management Company (EDFI-MC), FinDev Canada, Finnish Fund for Industrial Cooperation (Finnfund), Franklin Templeton Social Infrastructure Fund, FullCycle Management, Investment Fund for Developing Countries (IFU), Kohlberg Kravis Roberts & Co. (KKR), LeapFrog Investments, LGT Venture Philanthropy Foundation, Nuveen, Partners Group, PG Impact Investments, Prudential Financial (Impact & Responsible Investing), Quona Capital Management, The Osiris Group, UBS Group, and Women’s World Banking Asset Management.

BlueMark will host a virtual event on “How To Be An Impact Leader” on May 13, 2021 featuring: Tomi Amosun, Managing Partner at Summit Africa; Elizabeth Boggs-Davidsen, Vice President of the Office of Development Policy at the U.S. Development Finance Corporation (USDFC); Cecilia Chao, Managing Director for Bain Capital’s Double Impact team; Maria Kozloski, Senior Vice President of Innovative Finance at The Rockefeller Foundation; and Jeremy Rogers, Chief Investment Officer for Big Society Capital. Please register at


About BlueMark

BlueMark is a leading provider of impact verification with a mission to strengthen trust in impact investing and to increase accountability for impact. BlueMark is an independent subsidiary of Tideline, a certified women-owned advisory firm in impact investing. Learn more at

About Tideline

Tideline, a majority women-owned impact investing consultancy, provides expert, tailored and actionable advice to clients developing impact investment strategies, products and solutions. Learn more at

About The Rockefeller Foundation

The Rockefeller Foundation advances new frontiers of science, data, and innovation to solve global challenges related to health, food, power, and economic mobility. As a science-driven philanthropy focused on building collaborative relationships with partners and grantees, The Rockefeller Foundation seeks to inspire and foster large-scale human impact that promotes the well-being of humanity throughout the world by identifying and accelerating breakthrough solutions, ideas, and conversations. For more information, sign up for our newsletter at and follow us on Twitter @RockefellerFdn.


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ANNOUNCEMENT – “BlueMark Launches First-of-its-Kind Benchmark for Best Practices in Impact Management”

STATEMENT – “Tideline Managing Partner Ben Thornley and BlueMark CEO Christina Leijonhufvud Issue Statement on SEC Risk Alert and SFDR”

Tideline Managing Partner Ben Thornley and BlueMark CEO Christina Leijonhufvud today issued a joint statement in response to recent regulatory developments in the U.S. and EU aimed at clamping down on greenwashing and impact-washing in the investment management industry.

Here is the full text of the statement:

Both the SEC in the U.S. and the ESA in Europe have begun to tackle the risk to investors of misleading impact and ESG claims. As a result, investment managers making impact and ESG claims need to be prepared for the business risk and liability implications if they are not confident there is consistency between claims and practices.


These efforts aimed at clamping down on greenwashing and impact-washing in the investment management industry are welcome developments and represent key steps towards improved labeling standards for ESG and impact investing products.


The introduction of Sustainable Finance Disclosure Regulation (SFDR) requirements in the EU and the SEC’s recent ‘Risk Alert’ on ESG investing reflect a growing call for investors to back up their impact and sustainability claims with evidence. Regardless of which label an investor chooses to use—ESG, responsible, sustainable, impact, etc.—the message from regulators is clear that investors must have the right policies and practices in place to back up what they claim to be doing or the results they claim to be achieving.


We at Tideline and BlueMark have been working with impact investors for nearly a decade to build credible impact management systems that can stand up to scrutiny. We believe that any investor that chooses to self-identify as an impact investor must have an impact management system to ensure that impact considerations are integrated into every phase of the investment process, from strategy design and due diligence to portfolio management and performance reporting.


This “do what you say” mantra is essential to preserving trust in impact investing, and is a big part of why Tideline launched BlueMark in 2020 as a provider of independent impact verification services. By bringing increased transparency and accountability to the impact investment market, we are driving efficiency, clarity and transparency in the manager/investor relationship and ensuring that impact promises lead to real impact results. We are encouraged by the work of financial regulators to contribute to improved transparency and accountability in ESG and impact investing.


While more work is still needed to harmonize around global standards, regulators are signaling that there needs to be a bar for what is considered a credible ESG or impact strategy. Independent verification can help investors meet that bar by providing third-party assurance of investor claims and practices. From the threat of new regulations to the difficulties of complying with existing regulations, investors will continue to need a resource to help mitigate and address both reputational risks and legal liability.


About BlueMark

BlueMark, a Tideline company, provides independent impact verification services for investors and companies. With a mission to strengthen trust in impact investing, BlueMark’s services are designed to meet the need for reliable, third-party assurance of impact claims and practices. Learn more at

About Tideline

Tideline is a specialist consultant for the impact investing industry providing expert, tailored and actionable advice to clients developing impact investment strategies, products and solutions. Learn more at