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SB 261 DISCLOSURE
This inaugural climate-related financial risk report is prepared by Gunderson Dettmer Stough Villeneuve Franklin & Hachigian, LLP in accordance with the Recommendations of the Task Force on Climate-related Financial Disclosures (TCFD, 2017) in response to the requirements under Section 38533 of the California Health and Safety Code, known as the “Climate-Related Financial Risk Act” or “California SB 261” (California State Legislature, 2023). A Climate Risk Assessment and Scenario Analysis were conducted to evaluate climate-related risks. The assessment addresses both physical and transition risks using reputable data sources, including FEMA, Climate Central, Climate Impact Lab, and the World Resources Institute. Physical risks are assessed across multiple timeframes and climate scenarios (RCP 4.5 and RCP 8.5), while transition risks are informed by SASB industry risk categories.
This Climate-Related Financial Risk Report is prepared in conformance with the Final Report of Recommendations of the Task Force on Climate-related Financial Disclosures (TCFD, June 2017), one of the approved frameworks under HSC § 38533. The TCFD framework was selected because it is globally recognized, directly referenced by CARB’s compliance checklist, and provides a clear structure aligned with the required disclosure pillars: Governance, Strategy, Risk Management, and Metrics & Targets.
Omissions: Gunderson has not yet reported a Firm-wide carbon footprint, which is not required in this initial CARB reporting period.
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Governance a. Describe the board’s oversight of climate-related risks and opportunities b. Describe management’s role in assessing and managing climate-related risks and opportunities |
Gunderson operates as a limited liability partnership, with its Management Committee serving as the equivalent of a Board of Directors and holding ultimate oversight of the Firm’s strategy, including climate-related risks and opportunities. The Managing Partner oversees firm management decisions, including environmental strategy and mitigation, while the full Committee meets regularly to review business strategy, risk management, and performance, including sustainability matters. The Management Committee also retains authority over equity partner compensation, which may eventually incorporate sustainability-linked metrics. The Risk Management Committee, a subcommittee of the Management Committee, identifies, assesses, and monitors risks, including climate-related risks, across operations, strategy, compliance, and client relationships. It reviews departmental information, recommends policies or corrective actions, escalates material risks, and engages external advisors as needed. Day-to-day climate-related management is led by the Assistant General Counsel, who collaborates with operational teams and reports findings to the Committee for approval, ensuring that sustainability considerations are embedded throughout firm operations. |
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Risk Management a. Describe the processes for identifying and assessing climate-related risks b. Describe the processes for managing climate-related risks c. Describe how processes for identifying, assessing, and managing, climate-related risks and integrated into the organization’s overall risk management |
Gunderson recognizes that climate change presents both risks and opportunities that can influence business operations, client delivery, and operational costs. Strategic planning considers a range of potential impacts, evaluating physical risks, such as extreme heat, wildfires, hurricanes, and drought, as well as transition risks linked to regulatory changes, client expectations, market shifts, and emerging technologies. The Firm leverages cross-functional partnerships to strengthen climate resilience and support sustainable operational practices. Gunderson integrates climate considerations into its enterprise risk management framework through a company-wide risk register and structured risk assessments. Initially focused on information security, the register now includes climate-related risks such as natural disasters and power outages, with updates informed by annual climate risk assessments conducted with external partners. Complementary measures, including emergency preparedness procedures, insurance reviews, and staff training, further enhance resilience and ensure that the Firm’s approach evolves with changing climate realities. These climate considerations are embedded alongside operational, financial, and compliance risks, rather than managed in isolation. This approach ensures that Gunderson addresses climate-related risks in the context of overall business continuity, operational resilience, and long-term strategic objectives, while also maintaining accountability to clients and other stakeholders. |
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Strategy a. Describe the climate-related risks and opportunities the company has identified over the short, medium and long-term b. Describe the impact of climate-related risks and opportunities on the company’s businesses, strategy, and financial planning c. Describe the resilience of the company’s strategy, taking into consideration different climate-related scenarios |
Gunderson engaged external consultants to evaluate the Firm’s climate-related risks and opportunities across three time horizons: present day, 2030, and 2050. Risk: Offices in areas with high physical climate-related risks Risk: Clients impacted by climate-related risks Risk: ESG reporting requirements Risk: Supply Chain impacted by climate-related risk These risks and opportunities are shaping the Firm’s strategy and financial planning. Compliance obligations are driving investments in emissions tracking and assurance, while customer procurement trends are influencing the evolution of a sustainable cloud communications portfolio. Gunderson’s approach positions climate resilience not only as a compliance issue, but also as a driver of long-term competitiveness and growth. |
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Metrics & Targets a. Describe the metrics used to assess climate-related risks and opportunities in line with strategy and risk management process b. Disclose Scope 1, 2, and if appropriate Scope 3 Greenhouse Gas (GHG) emissions and the related risks c. Describe the targets used by the Organization to manage climate-related risks and opportunities and performance against targets
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Gunderson monitors its office locations for exposure to upper quintile physical climate risk and integrates this analysis with financial performance metrics at each site. By linking climate vulnerability with personnel data, the reporting company is able to identify which offices may face the greatest potential financial impact from climate-related hazards such as extreme weather events, flooding, or prolonged heat stress. This approach enables Gunderson to prioritize resilience planning, allocate resources more effectively, and proactively manage risks to both operations and long-term financial stability. The Firm does not currently measure or disclose Scope 1, 2, or 3 GHG emissions but may evaluate tracking in the future. At present, Gunderson has not formally established climate-related targets. However, the Firm strives to ensure that any risks assessed as very high severity are mitigated through at least one targeted management strategy. This includes operational adaptations such as flexible working arrangements, supplier engagement, and compliance planning for emerging climate regulations. Over time, the Firm intends to reassess the value of setting explicit targets to enhance resilience, meet stakeholder expectations, and support long-term competitiveness. |
