Investing in a ‘Circular Economy’

A new report suggests investors should seek to better understand the concept of ‘resource intensity’ and pursue opportunities to reduce risks while improving global environmental outcomes.

Art by Parapaboom


In a new report from the Putnam Investments sustainable investing team, researchers discuss the concept of a “circular economy,” which is an economy consciously designed to maximize the efficient use of resources and minimize waste.

The report, “Toward a Circular Economy,” says the global economy, as it currently operates, demands more of the world’s resources than the Earth can sustain. As such, the concept of a circular economy has emerged as an important framework to inform business leaders and investors. A more circular economy, the report argues, offers the potential to improve planetary health and dramatically decrease the natural resource intensity of the global economy.

Never miss a story — sign up for PLANADVISER newsletters to keep up on the latest retirement plan adviser news.

Moving Away From ‘Take, Make, Waste’

The Earth’s capacity to provide and replenish natural resources in key areas has been diminished by human production and consumption, due in large part to linear “take, make, waste,” approaches to production, consumption and disposal, the report says. This approach has been linked to high levels of emissions and waste and other environmental challenges, increasing business risks and uncertainties.

In contrast, the report says, a circular economy focuses on effective design; extended product lifespans through reuse, repair and recycling; and more strategic decomposition. This approach has a direct link to new products, practices and business models, offering the possibility for enhanced growth, reduced risk and improved financial returns.

Putnam’s analysis suggests that, at the current rate of resource use, approximately 1.75 Earths would be required to maintain healthy ecosystem functions and regenerate needed resources, the report says. For context, more than 100 billion tons of raw resources enter the economy every year, including metals, minerals and fossil fuels and organic materials from plants and animals. Of this, just 8.6% gets recycled and used again.

Resource use has tripled since 1970 and could double again by 2050 if “business as usual” continues, the report says. Adapting business models to be less resource-intensive creates opportunity for tremendous environmental and economic benefit.

Around and Around

As the report explains, in a circular economy, products are specifically designed with the goals of efficient resource use, extended product life and improved ability to repair, recycle and reuse materials. Pollution and waste are minimized, products and materials are used longer and natural systems are more able to maintain health and regenerate.

Business innovations regarding circular economy principles are accelerating, Putnam says. This owes to the fact that businesses are feeling the finite supply of raw materials more directly and because the long-term costs of waste and toxicity have become much more apparent. Increasingly, business leaders are recognizing the systemic risks that impact their operations, such as potential inflation, materials scarcity, elevated operating costs and higher long-term liability.

As a result, the report finds companies are using less raw materials, designing better for repair and reuse and creating business models that allow them to benefit from extended product lives.

Specific Solutions

The report identifies three major types of production models, with each lending itself to a particular form of solution. Products derived from raw materials can benefit from recycling. More complicated products, involving high energy and materials intensity, can benefit from an extended product life. Products that are highly engineered and technical can benefit from a focus on modular design and repair and reuse.

From the investment perspective, business approaches that focus on circular economy principals have the opportunity to reduce risks, improve environmental outcomes, align with customer demand and enhance long-term prospects for growth and financial returns, the report concludes.

Today and in the future, investors should seek to understand the current resource intensity of products and processes coming out of the companies in which they invest. By recognizing potential solutions and analyzing individual company efforts to contribute to a circular economy, investors and business leaders can realign company goals with the needs of the world.

Facing Criticism for ESG Rules, SEC Unlikely to Back Down

Attorneys who track financial regulations say SEC Chair Gary Gensler has no qualms about pushing forward big, ambitious proposals, even if they are destined to be challenged in the courts.

Art by Parapaboom


Earlier in May, the Securities and Exchange Commission extended the comment period on its proposal to make key rule amendments that would require domestic or foreign registrants to include certain climate-related information in its registration statements and periodic reports, such as on the Form 10-K.

Examples of the information to be disclosed by securities issuers include climate-related risks and their actual or likely material impacts on the registrant’s business, strategy and outlook. Other information to be disclosed includes the registrant’s governance of climate-related risks and relevant risk management processes, as well as the registrant’s greenhouse gas emissions.

For more stories like this, sign up for the PLANADVISERdash daily newsletter.

The comment deadline extension came after the regulator received substantial criticism regarding the original 30-day window, with many financial services industry stakeholders requesting more time to digest the proposal and prepare their formal response. While the extension to June 17th will provide supporters and critics more time to prepare comments about the environmental, social and governance proposal, Amy Greer and Jennifer Klass, co-chairs of Baker McKenzie’s financial regulation and enforcement practice, already believe the SEC’s final rules are destined to be challenged in the courts.

Greer is the former chief trial counsel at the SEC’s Philadelphia regional office, while Klass formerly served as vice president and associate counsel at Goldman Sachs & Co. Based on their conversations in the marketplace, they say the most controversial aspects of the ESG-focused rulemaking—as proposed—relate to “Scope 3 emission disclosures” that some believe exceed the SEC’s authority. As commonly defined, Scope 3 emissions are those produced as a result of activities from assets not owned or controlled by the reporting organization, but that the organization impacts in its value chain and business operations.

Why Scope 3 Is Controversial to Some

Critics of this part of the proposal say mandating disclosures up and down the supply chain of stock issuers spills into environmental policy and seeks to drive specific behavior, the attorneys say. Therefore, they argue, this proposal is an overreach for a regulator like the SEC, which has not been specifically directed by Congress to develop and enforce environmental regulations.

Those who support the SEC’s actions, on the other hand, argue that the SEC is fully empowered to require many different types of disclosures from securities issuers, and that individual and institutional investors are demanding these types of disclosures in the normal course of their market participation. They also point out that those who think ESG topics are being over-valued in the current and future price of securities could just as easily use the mandated Scope 3 data to inform their own investment decisions.

“As you would imagine with this topic, many comments have been submitted already, and the comments are coming from across the board, speaking both to the procedural aspects of the rulemaking and to the substance of the proposal,” Klass says. “This is all coming during a busy time for the SEC. They have been very active, putting out a variety of new rules with short turnarounds in terms of the comment periods. For example, the private funds disclosure proposal has also generated a lot of attention and commentary.”

As Greer and Klass point out, the SEC leadership has clearly signaled its intention to work to improve ESG-related disclosures, and they can be expected to factor ESG themes into multiple rulemaking actions. Since its original proposal, the SEC has already followed up on the broad ESG disclosure package with two additional regulations, one aimed at mandating similar types of disclosures on the part of registered investment advisers and fund managers and the other restricting and regulating the use of the ESG label in fund names.

Greer says the substantial debate surrounding the SEC’s ESG proposal is no great surprise in the current political and legislative context. As the volume of comments demonstrates, whatever the venue, whether in Congress or within the walls of an executive branch regulator, the topic of ESG generates significant debate here in the United States—far more than in other regions of the world.

The SEC Will Fight for ESG Disclosures

“One thing I think we can say is that SEC Chair Gary Gensler is not afraid of the controversy generated by these proposals,” Greer adds. “We can also say he came to this position with a very heavy rulemaking agenda, prepared for him by the Biden administration. My impression is that he has really felt the need, I think, to not only ‘check the boxes’ on the task list he was given, but also to address issues as they arise. For example, we have seen this with the focus on cryptocurrencies and the emergency of tech-based retail investing platforms popularized during the COVID-19 pandemic.”

In this context, Klass and Greer say, the ESG proposal is almost guaranteed to face challenges in court, with plaintiffs raising all sorts of issues. At this early stage, the attorneys suggest, it is mere speculation to guess what the ultimate fate of the regulation may be. Even if it is ultimately blocked or curtailed by the federal courts, however, the fact that these proposals have been put forward will have a lasting impact, Klass and Greer say.

“I do think that the mere fact that the highly detailed and ambitious ESG proposals have come out will have an impact in terms of providing some guidance about how such disclosures can or should be done,” Klass says. “Many U.S. issuers have been looking for guidance about what is the right framework to adopt. If nothing else, the proposal reflects what the current SEC sees as appropriate. It gives issuers something to think about in terms of how they disclose ESG practices.”

As clients increasingly demand ESG-related information from stock issuers, competitive pressures will continue to play a key role, driving many issuers to put forward much of this information voluntarily. The attorneys also point out that, even without the proposed rules and client demands, failure to keep up with the marketplaces’ treatment of climate-change-related disclosures could create potential liability exposure under current SEC rules.

The idea is that, if a significant percentage of the investment community continues to take a position that certain climate-related information is material and that climate-related disclosures are important to an investment analysis, omitting such information could raise potential Rule 10b-5 concerns, for example. Part of the debate moving forward will focus on where to draw the line of materiality with regards to climate change disclosures. As it stands now, Klass and Greer say, the prescriptive nature of the SEC’s proposed rules takes a broad view as to what information concerning climate change may be material for investors.

«