Ashurst Governance & Compliance Update – Issue 83

Corporate Governance

1. ICO publishes guidance on AI-powered cyber threats

The Information Commissioner's Office has published a guide to the practical steps which companies can take to strengthen their resilience against AI-powered cyber threats. This has been published in light of cyber criminals increasingly using artificial intelligence to carry out attacks that are faster, more advanced and harder to detect.

The ICO believes that all organisations must be proactive in taking steps to prepare themselves for emerging threats and that by investing in cyber resilience and ensuring appropriate security measures are in place, companies can build public trust and confidence in how an organisation protects the personal data it holds.

The five practical steps focus on:

• Understanding the threat posed by AI.
• Getting foundational cyber security right and then layering defences on top.
• Restricting system access points.
• Improving detection, monitoring and incident response.
• Protecting personal data, particularly through data minimisation and storage limitation.

Cyber readiness and response featured as one of Ashurst Perkins Coie's Key Board Priorities for 2026. You can access the related podcast here. All of our 2026 Board Priorities can be found here.

2. Updated guidance on accessing the register of members¹

The Chartered Governance Institute UK & Ireland (CGI) has issued an update to its guidance note on the proper purpose test under sections 116 to 119 of the Companies Act 2006 (2006 Act).

Any person may request to inspect, and obtain a copy of, a company's register of members, provided the request includes specified information, that is set out in an appendix to the guidance, including the purpose for which the information contained in the register is to be used (section 116, 2006 Act). The company may apply to court if it considers that the request has not been made for a proper purpose. What is a proper purpose is dependent on the particular facts and circumstances of each case.

The CGI, formerly known as the Institute of Chartered Secretaries and Administrators (ICSA), published guidance in June 2007 to assist companies in assessing whether a purpose set out in a section 116 request is proper.

The High Court has held that a company failed to prove that an application by a third party to obtain a copy of the company's register of members was not for a proper purpose because the purpose was a commercial one or would be commercially disadvantageous to the company's shareholders (Aviva plc v Litani LLC [2025] EWHC 3134 (Ch)).

The updated guidance considers the principles arising from a number of cases, including Aviva plc.

The updated guidance includes non-exhaustive lists of purposes that the CGI considers proper or improper and contains best practice recommendations for companies who receive section 116 requests. These recommendations include:

• Where access to information on one or a limited number of shareholders is sufficient, the company should limit access to that information.
• Where the register is provided for research purposes only, the company should impose conditions such as prohibiting direct contact with shareholders and disclosure of individual personal information to third parties.
• Where the company is in any doubt about whether the purpose is proper, it should make further enquiries and seek assurances from the party making the request and keep an audit trail.

The CGI suggests that companies should develop internal processes to deal with section 116 requests, particularly as the requirement that the register must be supplied or an application to court made within five working days of receipt.

Corporate Crime and Economic Transparency

3. Crime and Policing Act 2026: A new dawn for corporate criminal liability

Section 250 of the Crime and Policing Act 2026 (CAPA) comes into force on 29 June 2026 and will significantly extend the scope of corporate criminal liability in the UK. For more detail, see our briefing here.

Under CAPA, organisations will be criminally liable if a senior manager commits any criminal offence while acting within the actual or apparent scope of their authority.

CAPA will repeal the senior manager provisions in section 196 of the Economic Crime and Corporate Transparency Act 2023 – which only covered specified economic crime offences (such as bribery or fraud) – and expand them to apply to a much wider range of criminal offences. See our previous briefings here and here for further background.

4. Register of overseas entities: draft regulations re-issued²

The draft Register of Overseas Entities (Protection and Trusts) and Limited Liability Partnerships (Application of Company Law) (Amendment) Regulations 2026 (draft regulations) have been re-issued together with an explanatory memorandum.

The Economic Crime (Transparency and Enforcement) Act 2022 (2022 Act) established the register of overseas entities (ROE) regime. In particular, the 2022 Act created a ROE maintained by Companies House that records the true beneficial owners and managing officers of overseas entities that own land or property in the UK.

In August 2025, the Trust Disclosure Service was established by Companies House, allowing third parties to apply and access unpublished trust information held on the ROE if they have a legitimate interest. There have been a few practical difficulties with the application process for requesting unpublished trust information that the draft regulations seek to address.

A previous version of the draft regulations was issued and laid before Parliament on 22 April 2026 before being withdrawn on 13 May 2026.

The draft regulations amend the following legislation relating to the ROE:

• Regulation 4 (Access to trust information) of the Register of Overseas Entities (Protection and Trusts) (Amendment) Regulations 2025 (SI 2025/231) established the Trust Disclosure Service allowing third parties to apply to access unpublished trust information held on the register. The draft regulations:
  • remove the requirement for the application to include the trust name (as this is not publicly available); and
  • provide that, where an applicant has not shown a legitimate interest to access trust information relating to a person under the age of 18, information relating to that individual will be withheld, while other trust information will be disclosed.
• Regulation 7 (Application to protect information relating to a relevant individual) of the Register of Overseas Entities (Delivery, Protection and Trust Services) Regulations 2022 (SI 2022/870) allows individuals whose information appears on the ROE to apply to remove their home address from the public register.
  • The draft regulations remove the requirement in certain cases to provide evidence that the applicant lives at the address and introduces a requirement for a service address to be provided to replace the residential address.
  • The draft regulations are materially the same as those laid before Parliament on 22 April 2026, but that earlier version amended regulation 2 (Interpretation) to add a definition of "relevant individual" following the replacement of section 25 of the 2022 Act with section 168 of the Economic Crime and Corporate Transparency Act 2023. This earlier amendment made to regulation 2 has been removed from the re-issued draft regulations. As a result, the definition of "relevant individual" remains unchanged.

The draft regulations also amend regulation 31D (Required particulars) of the Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009 (SI 2009/1084) to remove service address requirements for registrable persons and registrable relevant legal entities. Companies House does not currently have the systems to receive this information, but the explanatory note states that requirements will be reinstated in due course.

Equity Capital Markets

5. AIM Rules for Companies - proposed changes

The London Stock Exchange has published AIM Notice 62, consulting on proposed amendments to the AIM Rules for Companies and the AIM Disciplinary Procedures and Appeals Handbook. The consultation builds on the November 2025 Feedback Statement on Shaping the Future of AIM (see our Feedback Statement update here for background).

Proposed amendments include the following:

• Reducing admission burdens. The working capital statement requirement would be removed in favour of targeted disclosure on capital resources available, financial obligations and proposed future 12-month fundraising needs. Additionally, UK AIM companies would be permitted to adopt UK GAAP in place of IFRS, incorporation by reference into admission documents would be allowed and guidance on lock-in arrangements would be clarified.
• Easier fundraisings and retail participation. A new Capital Access Window would enable AIM companies undertaking equity fundraisings to request a voluntary temporary trading suspension, allowing closer management of the fundraising process and facilitating broader investor engagement, including with retail investors.
• Supporting acquisition activity. Proposed amendments to AIM Rule 14 would narrow the reverse takeover definition, so that a transaction which exceeds 100% in any of the class tests but does not result in a fundamental change of business, board or voting control would instead be treated as a substantial transaction. The substantial transaction class test threshold would be raised from 10% to 25%, in line with the Main Market approach, and Nominated Advisers would be able to request that trading is not suspended on announcement of a proposed reverse takeover in certain circumstances. The profits class test would also be removed from Schedule 3 (other than for related party transactions).
• Flexibility for innovative and growing companies. Non-standard director remuneration arrangements meeting specified criteria would no longer require a fair and reasonable opinion from the Nominated Adviser. To enable founders to retain control, the issue of special voting shares would be permitted, subject to constitutional limitations.
• Greater agency for AIM companies. Changes to AIM Rule 26 would provide that an AIM company should consider a recognised corporate governance code for the purpose of guidance and informing its approach to corporate governance arrangements, but it is not required or expected to comply or explain against that code. Proposed key areas for disclosure are also included, namely - board composition; directors’ role and responsibilities; remuneration and performance; risk and controls framework; and approach to investor relations. The QCA has published a response to the draft AIM Rules in which it highlights concerns around the potential ambiguity of proposed AIM Rule 26. 
• Attracting international companies. The existing AIM Designated Market route would be replaced with a new Express Market route, designed to enable companies from a broader jurisdictional base to join AIM. In addition, an accelerated admission process would be available for certain Main Market companies. A new dual market admission route would also be introduced.
• Leveraging Nominated Adviser expertise. The AIM Rule 11 disclosure obligation would be replaced with a new disclosure rule centred on the value of the Nominated Adviser's experience to support the AIM company in understanding the potential market impact of developments in its business.
• Buyer beware. An express statement of the buyer beware principle would be added to the Introduction to the AIM Rules for Companies.

AIM Rules for Nominated Advisers - proposed changes

The Exchange has also published AIM Notice 63 to consult on certain administrative and clarificatory amendments to the AIM Rules for Nominated Advisers following the proposed changes to the AIM Rules for Companies. It also introduces a new Nominated Adviser Technical Note on the Exchange's expectations of Nominated Advisers in performing their obligations, as trailed. The Technical Note will take effect immediately other than for those areas which are subject to AIM Rule changes.

Next steps

The consultations close on 2 July 2026. A further consultation on the contents of an AIM admission document is expected in due course. 

6. Key Capital Markets developments laid out in latest Regulatory Initiatives Grid

The Financial Services Regulatory Initiatives Forum has published its Regulatory Initiatives Grid which maps the regulatory pipeline for the UK financial services industry for the next two years. This 10th edition of the Grid is stated to reflect the Forum's ongoing alignment with the government's growth agenda.

Key capital markets initiatives include:

• Disclosure Guidance and Transparency Rules Review
  
  Following the significant reforms to the UK listing regime in 2024 and the implementation of the new Public Offers and Admissions to Trading regime - including the FCA's new Prospectus Rules: Admissions to Trading on a Regulated Market (PRM) - in January, the FCA is commencing a review of its Disclosure Guidance and Transparency Rules (DTRs). The review will consider the value of the current rules for issuers and investors, as well as exploring whether changes are needed to enhance the attractiveness of UK public markets, while maintaining high standards and market integrity. The FCA plans to publish a public document in Q3 2026.

• UK Listing Rules: Investment Entities Review
  
  The FCA is bringing forward a review of certain elements of the UK Listing Rules (UKLRs) as they relate to specific types of investment entities. During its Primary Markets Effectiveness Review, the FCA examined which types of investment entities could be eligible for listing - and since the UKLRs took effect, the FCA has received feedback indicating that the eligibility criteria, particularly concerning risk-spreading, may be unduly restrictive. As trailed in AGC Update, Issue 80 – Item 2, the FCA intends to evaluate whether changes are warranted in this respect. The FCA will also undertake targeted work to assess how rules, in the context of company law, ensure that boards support strong shareholder rights and engagement and manage conflicts of interest. It is anticipated that the FCA's proposals will be outlined in a consultation paper in Q2 2026, with the review to be concluded by the end of Q4 2026.

• Dematerialisation
  
  By way of reminder, the Dematerialisation Market Action Taskforce (DEMAT) was created to advance reforms to the UK's shareholding framework, overseeing the transition to a fully digitised system of shareholding. The DEMAT Chair is expected to report by summer 2026 with a proposed go-live date for step 1 of DEMAT's three-step process, together with an implementation plan detailing the steps industry participants need to take. Step 1 - the replacement of certificated share registers with digitised registers - is targeted for completion before the end of 2027. For more detail on DEMAT, see AGC Update, Issue 72 – Item 8.
  
  Relatedly, the Quoted Companies Alliance has published a paper setting out the concerns it has, particularly for smaller-listed companies to be aware of.

• Sustainable Finance
  
  Further to its consultation on aligning listed issuers’ sustainability disclosures with international standards (CP 26/5), the FCA confirms that it is aiming to finalise its rules and publish a policy statement in autumn 2026. An overview of the FCA's proposals can be found in our update here.

7. FCA publishes reminder of key Handbook amendments

The FCA has published Handbook Notice No 140 detailing, amongst other things, amendments that have been made to the UKLRs and Glossary by three FCA instruments. All changes are in force.

The key updates include:

• Listing applications process
  
  The listing applications process for admitting new securities to the Official List under UKLR 20 has been streamlined and the requirements made clearer. The changes complement the new approach to listing applications - under which further issuances of securities already recorded in the Official List are automatically listed - and remove residual complexity for issuers.

• Miscellaneous amendments
  
  Minor amendments to certain other UKLR provisions - not connected with the listing applications process - have been made, together with various amendments to the Glossary of definitions.
  
  The FCA consulted on these changes in Quarterly Consultation Paper 50 (CP 25/35) - see AGC Update, Issue 76 - Item 3.

• Notification requirements - changes to capital
  
  Following Quarterly Consultation Paper 51 (CP 26/8), the requirement in UKLR 6.4.4R(4) (and equivalent rules in other chapters) for issuers to notify a RIS as soon as possible of the results of any new issue of securities or any public offer of existing securities has been removed. The related provision at UKLR 6.4.5R (and its equivalents) - which permitted delayed notification in certain circumstances – has also been deleted.
  
  These changes eliminate the potential overlap with the new requirement under PRM 1.6.4R for issuers to notify a RIS of any admission to trading of additional securities within 60 days of admission. For further information on Quarterly Consultation Paper 51 (CP 26/8), see AGC Update, Issue 80 - Item 4.
  
  The FCA has also issued useful guidance on how the notification requirement under PRM 1.6.4R interacts with the month-end reporting obligation on total voting rights under DTR 5.6.1. Where DTR 5.6.1R is triggered around the same time as an admission to trading, the FCA recommends that issuers make separate notifications under PRM 1.6.4R and DTR 5.6.1R, each filed with a distinct headline code, notwithstanding a degree of informational overlap. The FCA has indicated that it will explore options to streamline these requirements as part of its ongoing DTR review (see item 6 above).

Companies House

8. Retention periods for dissolved company records under review

Companies House has announced that it is reviewing the retention period for dissolved company records, following concerns that records should be held for longer than 20 years. Currently Companies House retains records of dissolved companies for 20 years at which time selected records are transferred to the 'appropriate' Public Record Office – e.g. The National Archives for companies registered in England and Wales. Any records not transferred are destroyed.

Companies House has paused the transfer and destruction of records while its policy is under review. It is still possible to search for information on the Find and update company information and Search for a dissolved company services. As before, access to company records not available online can be requested on payment of a fee.

Any changes to the retention period will be subject to public consultation.

Payment Practices Reform

9. Commercial Payments Bill introduced into Parliament

As announced in the King's Speech, the Commercial Payments Bill has been published and introduced to Parliament. Accompanying Explanatory Notes can be found here. Note that the Bill has also been referred to as the 'Small Business Protections Bill'.

The Bill contains numerous measures to improve commercial payment practices and address the persistent late payment of commercial debts in the UK. These were trailed by the Department of Business and Trade (DBT) in March 2026 which we covered in AGC Update, Issue 81 – Item 1.

In overview, the Bill amends and enhances existing laws on late payments by introducing the following:

• Statutory maximum payment terms of 60 days (with exceptions).
• Mandatory interest on late payments at 8% above the Bank of England base rate.
• A window for raising invoice disputes, after which suppliers will be entitled to a fixed sum if purchasers raise invoice disputes.
• Additional investigatory and adjudication powers for the Small Business Commissioner and a power to take enforcement action against larger businesses that persistently engage in poor practices (including issuing fines up to a maximum of 1% of annual turnover in the UK).
• A ban on deducting and withholding retention payments under construction contracts.

The DBT has also published guidance on the Bill.

Other business-focused legislation introduced by the King's Speech includes the 'Competition Reform Bill', which intends to make competition investigations faster and more predictable and the 'Regulating for Growth Bill', which intends to strengthen the duty on regulators to prioritise economic growth. The centrepiece for financial services is the Enhancing Financial Services Bill (published on 19 May 2026 as the Financial Services and Markets Bill), which delivers key elements of the 2025 Leeds Reforms. See our update for further information. The 'Representation of the People Bill' will also tighten restrictions on who can make political donations to registered political parties with implications for corporates which wish to do so. Briefing notes to the King's Speech can be found here.

Narrative and Financial Reporting

10. FRC publishes report on structured digital reporting

The FRC has published its latest review of structured digital reporting, Structured Digital Reporting: Insights 2025/26, together with an accompanying factsheet. The report is based on a market-wide analysis of digital reports filed by UK-listed companies, supplemented by detailed reviews of 30 annual reports.

The FRC notes that most filings are well structured and comply with requirements. However, the review identifies a number of recurring issues that limit the usefulness of structured data for investors, regulators and other users:

• Companies frequently apply only a single, high-level tag to disclosures covering multiple accounting topics, where more granular or multiple tags are required, creating inconsistencies in the data.
• Unnecessary custom tags ("extensions") are being created, particularly for alternative performance measures, equity movements and cash flow items, which fragments comparable information across the market.
• Where extensions are used, they are often too broad or imprecise, limiting their analytical value.
• Tags are sometimes applied on the basis of label wording rather than underlying accounting meaning, resulting in disclosures being associated with incorrect concepts or identical figures being tagged inconsistently.
• Errors in earnings per share reporting are common, typically arising from incorrect scaling (e.g. reporting £45 rather than 45 pence).

The FRC also identifies a number of process and compliance issues. These include a failure to make structured reports readily accessible on company websites or in a viewer-friendly format; validation errors and warnings not being fully resolved before filing; late filing of structured reports (affecting around 10% of sample companies); and failures to ensure successful publication on the National Storage Mechanism (NSM).

The FRC recommends that companies use the FCA's mandatory tag list to support completeness checks, prioritise standard tags over custom extensions, conduct post-submission checks on the NSM and build sufficient time into the filing process to identify and resolve validation errors. The FRC has directly notified companies where significant issues were identified through its review.

Sustainability

11. UK government's SECR review makes recommendations to simplify companies' energy and carbon reporting

The UK government has published a Post-Implementation Review of the SECR Regulations 2018, which considers whether and to what extent the streamlined energy and carbon reporting (SECR) requirements have achieved their original objectives, whether those objectives remain appropriate and the extent to which they could be achieved with less regulation.

The review recommends that the regime is retained as it has mainly met its objectives and had delivered measurable benefits including contributing to reductions in electricity and gas use among in-scope companies and disclosure of energy and carbon data by 79% of companies that would not have otherwise published that data. The regime has also increased internal awareness of energy use and emissions and supports investor scrutiny as part of a wider reporting and policy environment. While forward-looking frameworks (such as the Taskforce for Climate-related Financial Disclosures (TCFD) and the EU's Corporate Sustainability Reporting Directive (CSRD)) are considered more significant in driving strategic decision-making, the government believes that SECR provides essential baseline data and governance infrastructure that underpins those regimes. The review recommends reforms to simplify and improve the regime and reduce administrative burden on in-scope companies.

The review follows a 2023 call for evidence on the benefits, costs, and practicalities of Scope 3 greenhouse gas emissions reporting and the SECR regime (see AGC Update, Issue 59 – Issue 9), which was intended to inform the move to reporting using the UK Sustainability Reporting Standards (UK SRS) that were endorsed in February 2026. The review states that improvements to the scheme will be explored via the government's planned consultation later in 2026 on Modernising Corporate Reporting (see Government endorses ISSB sustainability reporting standards to create UK SRS). Potential changes include:

• updating guidance to clarify eligibility thresholds, site inclusion, and group reporting boundaries;
• introducing a standardised disclosure template to improve consistency and comparability;
• aligning SECR definitions and metrics with the International Sustainability Standards Board (ISSB), CSRD and TCFD to reduce duplication; and
• exploring light touch forward-looking elements such as optional targets or qualitative narratives.

12. TISFD publishes draft disclosure recommendations framework for consultation

The Taskforce on Inequality and Social-related Financial Disclosures (TISFD) has published a "beta" draft of its Framework on recommendations for disclosures of 'people-related information' for public feedback. The TISFD is a voluntary, UN-backed, taskforce supported by organisations from across business, finance, labour, civil society and international organisations.

The draft Framework is intended to support businesses to identify and report inequality and people-related impacts, dependencies, risks and opportunities (IDROs). The Framework adopts the structure of the TCFD's four pillars and its 12 recommendations largely mirror those of the TCFD. It aims to reduce duplication in reporting by building on and complementing existing disclosure standards including the ISSB, the Global Reporting Initiative (GRI) and the European Sustainability Reporting Standards (ESRS).

The draft Framework includes conceptual foundations, such as definitions and concepts needed to understand the relationships between business, finance, people and inequality, as well as draft disclosure recommendations across governance, strategy and impact and risk management pillars. The TISFD has taken a system-level risk approach to inequality as it recognises that inequality and other people-related issues are shaping business performance, investment outcomes and the stability of economies and markets where they accumulate across sectors and markets. Having information on people-related IDROs is key for investors as these issues can affect long-term portfolio performance and, because they can be systemic issues, diversification may not be possible.

The Framework enables people-related issues (including inequality, human and labour rights and wellbeing) to be considered alongside climate and nature issues as relevant to financial disclosures.

Feedback on the beta version of the Framework should be submitted before 31 July 2026. The TISFD intends to publish the final Framework by the end of 2027. Businesses are encouraged to take part in piloting the Framework. Further information on this will be available later in 2026.

13. SBTi publishes new Corporate Net-Zero Standard

The Science-based Targets Initiative (SBTi) has published version 2.0 of its Corporate Net-Zero Standard, which is intended to drive business transformation by embedding science-based targets into core decision-making across operations, value chains and capital allocation.

Key changes introduced by the new version of the Corporate Net-Zero Standard, which has been in development since 2024, include:

• A range of target-setting options to reflect different business contexts and strengthen the link to transition planning. In contrast to the existing version of the Corporate Net-Zero Standard, which requires near and long-term targets to be set, version 2.0 requires companies to set two or more near-term (5-year) targets and they can choose to set an over-arching net-zero target.
• A stronger focus on implementation of targets including enhanced transparency on reporting progress and continuous improvement.
• Target-setting on a 'best efforts' basis, which will allow companies that have not met their SBTi-verified targets to continue within the SBTi framework. In such cases, companies are expected to use all available levers to work towards the targets and achieve emissions reductions and be transparent about the barriers they are facing and the actions being taken to mitigate them.
• Differentiated requirements based on company size. Category A companies (i.e. large companies from all jurisdictions and medium-sized companies from high-income countries) will be subject to more requirements such as setting near-term Scope 3 targets and developing and maintaining a transition plan. For Category B companies (i.e. small companies from all jurisdictions and medium-sized companies from low-income countries), these items will be optional.
• An implementation hierarchy that prioritises direct emissions reductions in company operations and value chains over broader pooled and sector-level actions.
• The introduction of a voluntary 'Ongoing Emissions Responsibility' recognition mechanism for high-integrity carbon credits as credits cannot be used to achieve science-based targets. The mechanism (which will be voluntary for Category A companies until 2035) is intended to encourage companies to address the impact of their ongoing emissions in the short-term (e.g. through funding emissions reductions or removals). After 2035, Category A companies will have to neutralise their residual emissions by their net-zero target year.

Use of Corporate Net-Zero Standard version 2.0 to submit targets to the SBTi for validation will become mandatory from 1 February 2028. Companies may elect to use either the current version 1.3.1 or version 2.0 from Q1 2027 until 31 January 2028. Companies currently working towards setting targets using the current version 1.3.1 should continue to use that version. Companies that have already set science-based targets using version 1.3.1 and companies that are in the process of using version 1.3.1 to set targets can take advantage of both the current flexibilities in version 1.3.1 and the changes in version 2.0.

The SBTi has also published several resources to support version 2.0 including a Guide for companies in transition to Corporate Net-Zero Standard version 2.0, which explains the differences between previous versions of the Corporate Net-Zero Standard and version 2.0.

14. EU consults on making CS3D work in practice

The European Commission has launched a consultation on guidelines for the Corporate Sustainability Due Diligence Directive (CS3D) ((EU) 2024/1760).

The CS3D, which was amended by Directive 2026/470 (Omnibus I) (see Ashurst Perkins Coie Governance & Compliance Update – Issue 79), requires very large EU companies and non-EU companies with a significant market presence in the EU to identify, prevent, mitigate, and bring to an end adverse impacts on human rights and the environment across their own operations, subsidiaries, and value chains.

The guidelines are intended to help in-scope companies understand how to fulfil their due diligence obligations and to inform value chain partners, including businesses in non-EU countries, on how to engage with the due diligence process.

The European Commission is seeking input on a wide range of topics, including:

• model contract clauses for voluntary use in business partner relationships;
• risk-based due diligence processes, including scoping, in-depth assessment and prioritisation;
• third-party verification standards and independence requirements; and
• guidance on penalties and supervisory coordination.

The consultation closes on 24 July 2026. The European Commission plans to adopt the guidelines in Q1 2027.

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Authors: Will Chalk, Partner; Shan Shori, Expertise Counsel; Becky Clissmann, Sustainability Counsel; Marianna Kennedy, Senior Associate.