Thailand SEC consultation on ISSB Roadmap

We refer to the invitation from the Securities and Exchange Commission, Thailand (the SEC) to participate in the Public Consultation Aor Sor Yor. 5-/2567 on the Principle of Thailand Sustainability Disclosure Roadmap regarding the International Sustainability Standards (ISSB Roadmap). We appreciate the opportunity to provide feedback as the SEC develops its implementation roadmap.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with BHT 60.99 trillion at 30 June 2024, of which BHT83.13 billion was invested in the shares of 165 Thai listed companies.

As a long-term investor, we consider our returns over time to be dependent on sustainable economic, environmental and social development, as well as on well-functioning, legitimate and efficient markets. We are active investors in over 65 countries and require reliable, consistent and comparable sustainability-related financial information across global capital markets. We strongly support the IFRS Sustainability Disclosure Standards (ISSB standards) as the global baseline of investor-focused standards for sustainability-related financial disclosures that are connected and complementary to financial statements. This is critical for us to formulate a holistic view of a company’s performance and prospects over time and facilitates cross-border capital flows.

We welcome the full incorporation of the ISSB standards into the roadmap and support the size-based approach to phase in disclosure requirements. We recommend that a proportionate approach is also applied to transition reliefs and that SEC considers shorter transition reliefs (5.5.2 to 5.5.5) for the larger companies included in the SET50 and SET100 indices.

We thank you for considering our perspective and are available to discuss these matters further.

Please find in the annex our responses to the questions for the Public Consultation.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer 

Jeanne Stampe
Lead Policy Advisor