Consultation on Proposed Update of Qualitative Modules

What is this consultation about?

The Assessing low-Carbon Transition (ACT) initiative is proposing an update of four of the qualitative modules that form part of the ACT Performance score. These modules appear in the same form in many of the ACT Methodologies, though some have sector-specific elements. The modules proposed to be updated are:

  • Module 5: Management
  • Module 6: Supplier Engagement
  • Module 7: Client Engagement
  • Module 8: Policy Engagement

We are requesting specific feedback on these four qualitative modules. Your feedback is very important in informing our methodology development, and will be used only to inform the methodology update process.

You can leave feedback here (you will have to create a free ScribeHub account to do so – it takes less than a minute): ACT Consultation on Proposed Update of Qualitative Modules (

Why is now the time to update these ACT qualitative modules?

Recently the ACT team and a group of consultants have been carrying out road-tests of new ACT sector methodologies, including Agriculture & Agrifood, Aluminium, Cement, Chemicals, Iron & Steel, Glass, Pulp & Paper, Oil & Gas and Transport. Alongside this, CDP and the World Benchmarking Alliance (WBA) have undertaken several sector benchmarks, in which a large sample of companies from a specific sector is assessed using the ACT approach.

Feedback from the analysts and companies involved in the projects mentioned above have consistently pointed to two main issues with the four qualitative modules, namely:

  1. Not enough guidance was provided around data collection and scoring to aid analysts and companies; and
  2. Unclear or confusing maturity matrices made it difficult for analysts to assign maturity levels consistently.

In addition, the ACT team identified several areas in which thought leadership has progressed significantly since the modules were originally developed. For example, recent work by CDP and others (including TCFD) around transition plans meant it is appropriate to update the “Low-carbon transition plan” indicator to take the latest thinking into account. Similarly, it is proposed to add additional guidance to the “Company policy on engagement with trade associations” indicator in light of the publication of the 2022 Global Standard on Responsible Corporate Climate Lobbying. In general, each module has been updated where relevant to take the latest research into account, to ensure that they maintain a high level of relevance and ambition.

What is the aim of this consultation?

Receive feedback that will inform the updates to the four ACT qualitative modules, with the intention of incorporating these updates into new sector methodologies which are scheduled to be published in Summer 2022, (Aluminium, Chemicals, Glass and Pulp and Paper) and releasing updated versions of the already-published methodologies soon thereafter.

How to respond?

What is the timeline?

The consultation will be open for three weeks, from 16th May 2022 to 6th June 2022.


We welcome all input – you can provide feedback on as much or as little of the proposed changes as you wish, or provide general comments to the survey.

We thank you for your time and input.