The Environmental Defenders Office (EDO) welcomes the opportunity to comment on Treasury’s Consultation Paper on a Sustainable Finance Strategy (Strategy).

As part of a national community legal centre specialising in public interest environmental law, the work of the EDO Safe Climate (Corporate and Commercial) lawyers includes examining greenwashing by companies. To avoid facilitating greenwashing, and to maintain domestic and international credibility, it is critical that science-based criteria are central to the development of a Strategy in particular to the design of the Sustainable Finance Taxonomy (Taxonomy) and sustainable investment labelling regime.

Without credible and science-based criteria, we are concerned that the Strategy will facilitate greenwashing by including in the Taxonomy activities that are not aligned with the Paris Agreement’s 1.5℃ temperature goal and by awarding sustainable labels to financial products invested in companies involved in activities that are similarly not aligned.

We set out below a summary of our key recommendations and detailed responses to select questions identified in the Consultation Paper.