Thailand's Securities and Exchange Commission's Consultation on Sustainability Related Information

We refer to the invitation from the Securities and Exchange Commission, Thailand (the SEC) to participate in the Public Consultation Aor Nor Ror. 37/2568 on the Regulatory Amendment pertaining to the Sustainability-Related Information Disclosure Requirements of Listed Companies towards the International Sustainability Standards Board Standards (ISSB Standards). We appreciate the opportunity to provide feedback as the SEC finalizes these requirements using a phased-in approach.

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 63.6 trillion at 30 June 2025, of which BHT67.7 billion was invested in the shares of 154 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 SEC’s consideration of an ‘adoption by reference’ mechanism to incorporate the English version of the ISSB Standards with full fidelity.

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