As the awareness of environmental, social, and governance (ESG) issues increases, many data vendors have emerged to meet society’s demand for ESG information. Among many roles that CDP plays, an important one is to serve as an information intermediary facilitating the communication between companies and their stakeholders. This study discusses the practices at CDP intended to enhance firm disclosure of ESG information by focusing on its disclosure request policy. It raises the concern that such practice might constitute selective disclosures of material information, thereby violating Regulation Fair Disclosure.

JEL Classifications: M14; M41; M48.

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