Executive Compensation and the Investor, Worker & Stakeholder: The New Corporate Disclosures on CEO Pay Ratios Are Now Part of the Public Dialogue

There are some interesting new angles to the perennial public dialogues that go on about issues related to executive compensation.  The new news is regarding the compensation packages for the Top Man (in the Fortune 500 universe, there are only 24 companies that have female CEOs) and the relationship of that sum to (1) the employees of the firm and (2) the shareholders, including key fiduciaries managing OPM (other peoples’ money).  The CEO Pay Ratio disclosures of 2018 are now becoming more of a public dialogue.

One thread of conversation that is gaining some momentum in the public square is about the ratio of the CEO’s pay to the median worker pay at various companies in specific sectors.  This disclosure was mandated in 2010 with passage of the Dodd-Frank reform legislation and it took until this year before the final rules were in effect for public company disclosure, and the disclosures began.  The analysis of what this all might mean to investors and stakeholders is now underway.

The CNBC commentator James Thorne, for example, explored the ratio issues in a post on May 13th.  He begins his commentary by noting that for decades, as publicly-traded companies disclosed their CEO’s pay, criticism could rise when investors thought the pay was not justified by the company’s performance.

Now that the CEO-to-Median employee disclosures are being made, Thorne’s initial conclusion was that companies with certain characteristics — closer CEO pay to workers in the ratio —  maygenerate a higher profit-per-worker than firms with a wider gap. He began his research with the question:  does the ratio say something about performance?  The CNBC analysis suggested that it did — with equal pay distribution generating higher profit per worker.

In examining corporate disclosure on the pay ratio to date, the “bunching up” seems to be in the 200-300-400 (200-to-one, etc.) range, with some firms having ratios as high as 800 to 1,000 CEO pay to the median.  The analysis was performed by Calcbench.

The CNBC commentary explains that ratios can vary, depending on factors like company size, geographic distribution and percentage of part-time or seasonal workers; companies also have latitude in deciding how the ratio is calculated (and then disclosed). The Willis Towers Watson firm noted that direct (company-to-company) comparisons can be difficult. The SEC cautioned that firm-to-firm comparisons were not the intent of the disclosure rule.

Touching on something relevant to the investment side is Ric Marshall, MSCI’s executive director of ESG research:  “The investors who will find the most value [in ratio disclosures] are those who have concerns about inequality.”  Here at G&A we are seeing a steady flow now of news and commentary on the ratio issue from investors and other stakeholders focused on inequality and related societal issues.

With fundamental changes in the structure and definition of “worker” the short- and longer-term effects of these changes are being examined by a host of social scientists and pundits. (The familiar “rank and file” has been replaced by part-timers, seasonal workers, contractors, consultants, outsourced workers, and more variations at many firms.  Researchers are closely examining the results).  One extension of this ongoing public discussion is the concept floated for a minimum payment to those displaced or unable to find work in the new normal of “employment.”

We suggest that you check out the flow of related commentary on the topic of “the workplace” from the McKinsey & Company’s Global Institute at: https://www.mckinsey.com/mgi/overview

The Top Story this week from CNBC explores the CEO pay ratio dialogue and provides highlights within industries for you (manufacturing, retail trade, etc.).

The overall public dialogue on “inequality” (steadily rising in tempo and fervor) includes the subset of executive compensation and the CEO pay ratio is becoming a part of the discussion.  The news, commentary and research results to come in the months ahead will be of interest to investors, employees and other stakeholders.

Top Stories

Companies with closer CEO pay ratios may generate higher profit per worker
(Monday – May 14, 2018) Source: CNBC – A CNBC analysis of CEO pay ratios suggests that companies with more equal pay distribution also tend to generate higher profit per worker.

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The “100 Best Corporate Citizens 2018” Roster -– Published by CR Magazine

by Hank Boerner – Chair, G&A Institute

Now in its 19th year, the well known CR Magazine “100 Best Corporate Citizens 2018” list was just unveiled; this effort recognizes the ESG performance of public companies in the United States. (The publication is now titled Corporate Responsibility Magazine, published by 3BL Media LLC.)

Top Companies:
Microsoft
(MSFT) earned top ranking (#1), followed by Accenture, Owens Corning, Intel, and Hasbro (at #5).

The next five ranked companies are (#6) Altria Group, Cisco Systems, Ecolab, Johnson & Johnson, and NVIDIA Corp (at #10).

The biggest gainers for the year were Becton, Dickenson; IBM; Owens Corning; and Biogen.  The complete list is available in our Top Story (below).

Assembling the list does not rely on responding to a survey, publisher Dave Armon explains.  Each year the rankings measure the success of the “Brands Taking Stands” movement by celebrating the most successful, most transparent companies that report on their responsible practices. “We congratulate the company on the 2018 list for their commitment to corporate responsibility,” he said in announcing the rankings.

Methodology:
The list examines 260 data points of performance measures and disclosure, harvested from publicly-available information for every company in the Russell 1000® Index, in seven categories (environmental, climate change, employee relations, human rights, corporate governance, financial, and philanthropy & community support).  The underlying research is conducted by ISS Corporate Solutions (Institutional Shareholder Services).

The inaugural list was published in 1999 by the former Business Ethics Magazine, which segued into CR Magazine.

Coming up soon, CR Magazine in collaboration with the 3BL Association (formerly the Corporate Responsibility Association), presents the well known annual COMMIT!Forum conference, now re-branded as the 2018 3BL Forum by its new owners.

This year’s event is at MGM National Harbor near Washington DC, October 23-25; the theme is “Brands Taking Stands – The Long View”.

3BL Media LLC is the global leader in disseminating CR and sustainability content. Its brands include Triple Pundit; CSR Wire; 3BL Wire; 3BL Report Alert; Justmeans, 3BL Studio, and others. Corporate clients utilize the platforms for their sustainability, CR and related content distribution, communications and campaigns.

G&A Institute has collaborated with the 3BL Media staff and Corporate Responsibility Magazine on a long-term basis.  3BL content is carried daily on G&A’s news and opinion web-based distribution platforms.

The details for the “100 Most are in the Top Story:

Top Stories

Corporate Responsibility Magazine Announces 2018 100 Best Corporate Citizens
(Wednesday – May 09, 2018) Associated Profiles : CSRwire Source: CSR Wire — Corporate Responsibility Magazine (CR Magazine) announced today its 19th annual 100 Best Corporate Citizens list, recognizing the standout environmental, social and governance (ESG) performance of…

Are We Making Progress? Considering Recent News About “Apparel Fashion and Sustainability” — and the Investor Initiative to Help Make East Asian Factory Workers Safer and Better Paid…

by Hank Boerner – Chair, G&A Institute

In monitoring the growing abundance of news stories and commentary about “supply chain,” “globalization” or “trade” topics and issues, our editors often see the focus is on apparel, clothing, textiles, fashionand related topics & issues.

Companies in the developed economies widely source apparel footwear and related items in the developing and under-developed nations – and what happens there can quickly make news that travels around the globe.

Example:  The focus five years ago about this time was on the East Asian nation of Bangladesh and the Rana Plaza vertical factory tragedy in the capital city of Dhaka (or Dacca) that killed more than 1,000 garment industry workers.  The labels of leading western nation marketers were scattered about the debris and ashes — and those familiar brand images as well as images of the collapsed building and details of the tragedy helped to focus attention on worker conditions in the East Asian region in both North America and Europe.

The Interfaith Center on Corporate Responsibility (ICCR) investor coalition is keeping the focus on worker safety as the “Bangladesh Accord on Fire and Safety” is renewed for another three years.

ICCR institutions and their investor allies organized as “The Bangladesh Investor Initiative” (with collective AUM of US$4.5 trillion) on the 5th anniversary are urging a stronger corporate response and demonstrated commitment to local worker safety and adequate wage levels.  The link to our blog commentary on recent developments and background information for companies and investors is below.

Some good news to share is that sustainability is catching on in the fashion industry.  The uber fashion magazine from publishers Conde Nast – Vogue, with more than one million readers — just published a story about the embrace of “eco-friendly” fashion, spotlighting “the best designers of a new generation are stitching sustainability into everything they do…”

“While sustainability has long been considered a “byword for hemp-heavy bohemia,” writer Olivia Singer explains, “a new generation of designers is building brands with a more conscious approach to fashion at their core.”

Fabrics are sourced through collectives in India empowering female weavers as just one example.  In the article designers explain why sustainability is important to their brands (Richard Malone, Le Kilt, Elliss, E.L.V. Denim, Alyx, Marine Serre, Richard Quinn are featured interviews).

A number of creative approaches being adopted by the designers is explained — just think about the contribution to global sustainability of turning recycled plastics and viscose into yarn and fringing, using organic cotton as well as recycled polyester for “new” fashions, creating ECONYL from fishnets to make swimwear, and using recycled cotton and plastics as part of the effort of making sustainability a “pillar of luxury”.

The encouraging details are in our Top Story this week – a cautionary note:  some of the fashion photos are edgy and might offend.

Top Stories

The Young Designers Pioneering A Sustainable Fashion Revolution
(Thursday – April 26, 2018) Source: Vogue – While eco-friendly fashion has never had particularly glamorous connotations, the best designers of a new generation are stitching sustainability into everything they do.

And of interest, our own related content on G&A’s Sustainability Update Blog:  The Bangladesh Garment Factory Workers Tragedy and Investor and Corporate Response Five Years On…

As the Global Demand for Palm Oil Rises, There is More Focus on the Growing Areas – and on Industry Behaviors Such as Deforestation

By Hank Boerner – Chair, G&A Institute

Palm Oil is one of the world’s most popular vegetable cooking oils and in western nations is widely used as prepared food ingredients. Food industry interests promote the benefits: lower cholesterol levels, less heart disease, more Vitamins A and E, and much more, derived from the rich beta-carotene from the pulp of oil palms.

Palm oil also shows up in our detergents, shampoo, cosmetics, pizza slices, cookies, margarine — and even in biofuels. Palm oil is especially used for cooking in Africa, Asia and parts of South America and is growing in favor in other regions such as in North America.

The palm oil plantations are located in such regions of the world as Southeast Asia – and there the industry is linked to the downside of the beneficial consumer product: deforestation, degrading of flora and fauna habitat, abuses of indigenous peoples, and negative impact on climate change as old growth land and tropical forest is cleared to make way for oil palm plantations.

Stakeholder reaction resulted in the creation of “reliable No Deforestation, No Peat, No Exploitation” policies – the “NDPE”.

These were developed for certification (to buyers) by the Roundtable on Sustainable Palm Oil (RSPO) and adopted in 2013 and 2014 by numerous Southeast Asian palm oil traders and refiners.

The policies (spelled out as best practices) are designed to prevent clearing of forests and peat lands for new palm oil plantations. There are 29 company groups, reports Chain Reaction Research, that have refining capabilities and have adopted NDPE policies. (Climate Reaction Research is a joint effort between Climate Advisers, Profundo and Aidenvironment.)

“Un-sustainable” palm oil practices are an issue for investors, customers (buying the oil), companies with sustainable practices, and countries in which palm oil is grown and harvested.

According to a new financial risk report from Chain Reaction Research, major markets with customers that accept “unsustainable palm oil” include India, China, Pakistan and Indonesia.

One of the major centers of production is the huge – more than 3,000-miles wide — Pacific Basin archipelago nation of Indonesia (once known as the Dutch East Indies). Almost half of the world’s palm oil refineries are in Indonesia and Malaysia.

The Indonesian government (the Ministry of Agriculture) reacted to the NDPE policies and proposed changes to its own certification program – known as the “Indonesian Sustainable Palm Oil Standard” (ISPO) – that would appear to be presenting companies with pressure to adopt one or the other of the certifications.  (The ISPO policy focus is on reducing Greenhouse Gas Emissions and addressing environmental issues.)

For Indonesia, palm oil is a strategic product that helps the government to meet job creation and export market goals. “Small holders” account for more than 40% of production in the country.

“Evidence suggests that the need for edible oil and energy will continue as populations grow, “Darmin Nasution, Coordinating Minister for Economic Affairs for Indonesia points out. “Land that can be utilized will decrease, so the question is how to meet those needs in the limited land area. Increasing productivity will be the key.”

Companies using the existing Indonesian ISPO certification were accused of human rights abuses and “land grabs” and so in January the government developed the new certification, which opponents claim weakens protection (the draft changes for the regulation removes independent monitoring and replaces “protection” with “management” for natural ecosystems).

Stranded Asset Risks

CDP estimates that global companies in the industry had almost US$1 trillion in annual revenues at risk from deforestation-related commodities. As the developed nation buyers looked carefully at their global supply chains and sources, “stranded assets” developed; that is, land on which palm oil cannot be developed because of buyers’ NPDE procurement policies. Indonesia and Malaysia have some of the world’s largest suppliers.

Western Corporate Reaction

Early in 2018 PepsiCo announced that it and its J/V partner Indofood suspended purchasing of palm oil from IndoAgri because PepsiCo — a very prominent global brand marketer — is concerned about allegations about deforestation and human rights were not being met.

Institutional Investors are busily identifying companies that source Crude Palm Oil (“CPO”) without paying attention to sustainability requirements, putting pressure on both sellers and buyers and perhaps pushing the smaller players to the sidelines. European buyers import CPO in large quantities to be used in biofuels.

The bold corporate names in western societies show up in rosters of company groups with refining capacity and NDPE policies, including Bunge, Cargill, Louis Dreyfus Company, Unilever, and Wilmar International. These are large peer companies in the producing countries (like IOI Group, Daabon, Golden Agri-Resources) are aiming for “zero deforestation” in their NDPE policies.

Other companies that source palm oil include Kellogg’s, Procter & Gamble, Mars, General Mills, Mondelez International, and other prominent brand name markets.

Your can check out the Chain Reaction Research group paper – “Unsustainable Palm Oil Faces Increasing Market Access Risks – NDPE Sourcing Policies Cover 74% of Southeast Asia’s Refining Capacity” at: http://chainreactionresearch.com/2017/11/01/report-unsustainable-palm-oil-faces-increasing-market-access-risks-ndpe-sourcing-policies

What About Exercise of National Sovereignty?

This situation raises interesting questions for developed nation brand marketers. If the government of Indonesia presses forward with the country’s own standards, should the purchaser in a developed country ignore or embrace the country standard? Instead of the Roundtable on Sustainable Palm Oil (RSPO) standard? What about “sovereign rights,” as in the ability for a sovereign nation to establish its own policies and standards governing the products developed within its borders?

As industry groups create their own standards and invite industry participants to embrace these (such as for product certification), corporations may find themselves bumping up against “nationalistic” guidelines designed to benefit the internal constituencies rather than “global norms” imposed from outside the country’s borders.

# # #

Responding to the streams of negative news coming out of Indonesia, Chain Reaction Research on April 26 reported that Citigroup has cancelled loans to Indofood Agri Resources and its subsidiaries. Citigroup will exit its overall relationship with Indofood other than specific financial relationships that are not related to the palm oil business, says the research organization.

The research firm said that labor and environmental violations by Indofood and other companies related to Anthoni Salim and his family have been documented. The web of companies: Salim and family own 44% of First Pacific, which owns 74% of Indofood.

In April a report commissioned by Rainforest Action Network Foundation Norway and SumofUS and prepared by Chain Reaction Research alleged deforestation of almost 10,000 hectares of peatland by PT Duta Rendra – which is majority owned, the report says, by Salim and PT Sawit Khatulistiwa Lestan, which is associated by Salim.

Notes:

As we prepared this commentary, the Danish Institute for Human Rights and The Forest Trust carried out a Labour Rights Assessment of Nestle’s and Golden Agri-Resources palm oil supply chain in Indonesia.  Nestle’s and GAR and going to share their own action plans in response to the findings and recommendations.

For The Roundtable on Sustainable Palm Oil information: https://www.rspo.org/

There is information from a recent conference in Jakarta for you at: https://www.scidev.net/asia-pacific/forestry/news/science-can-keep-palm-oil-industry-sustainable.html

The Indonesian Government ISPO information is at: http://www.ispo-org.or.id/index.php?lang=en

General Mills Statement on Responsible Palm Oil Sourcing is at: https://www.generalmills.com/en/News/Issues/palm-oil-statement

Rainforest Action Network information is at: https://www.ran.org/palm_oil?gclid=EAIaIQobChMIuJyBg97i2gIVE1mGCh3A-QMYEAAYASAAEgKZePD_BwE#

The Union of Concerned Scientists information is at: https://www.ucsusa.org/global-warming/stop-deforestation/drivers-of-deforestation-2016-palm-oil#.WudvOKjwbAw

A U.S. Corporate Leader Shares His Thoughts on Sustainability – EDF’s Fred Krupp Interviews Tom Linebarger of Diesel-Maker Cummins Inc.

By Hank Boerner – Chair, G&A Institute

Fred Krupp is head of the two-million-member Environmental Defense Fund (EDF), a leading global not-for-profit that creates “transformational solutions” to address environmental problems by linking economics, law, science and innovative private-sector partnerships.  Since the mid-1980s he has been a very vocal thought leader, activist, and champion for change on various climate change issues, striving to use the power of the marketplace to protect the global environment.

Krupp has worked with many business leaders over the years and today characterizes Tom Linebarger – the Chair and CEO of Cummins, Inc. (leaders in diesel engine manufacturing) – as one of the forward-thinkers on sustainability and environmental innovation.  Krupp interviewed the CEO for Forbes, our Top Story for this issue.

Cummins Inc. has publicly committed to set science-based targets for reducing GHG emission across the company’s supply chain, which would help to address stakeholder concerns and help contribute to the future well-being of communities in which the company operates.

Cummins’ innovation efforts will also help to make a difference in terms of the company’s products (such as vehicle and stationary engines), its facilities and the supply chain.  Diesel power is central to the progress of the economy, says Linebarger, moving vast amounts of products and supplying power just about everywhere — and is a factor in driving wealth creation.  While doing this, the Cummins’ products also impact the environment and so the intense focus on corporate sustainability for the company.

Here are some welcome words for us in the Trump/Pruitt era of tearing up environmental rules and regulations and denying the impacts of climate change:  “Regulations play an important role in protecting the environment, and we’ve worked to make sure we’re a positive contributor to the effort,” the CEO explains.

Cummins also pushes industry peers and its suppliers to support tough, clear, science-based, enforceable regulations that are good for the industry.

Also, welcome to other champions of corporate sustainability – this making the business case statement:

“There’s no question that our focus on environmental innovation and leadership has caused our company to grow, to become more profitable, and to increase our appeal with big companies that would like to partner with us because of our leading technologies.”

Cummins (NYSE: CMI) is headquartered in Columbus, Indiana; the company designs manufactures, sells and services diesel and natural gas power engines; and, alternative-fueled electrical generates sets, “emission solutions”, and components for electronics and fuel systems. The company has 58,600 employees and serves customers in 190 countries – sales are US$20 billion (2017).

Disclosure:  The G&A Institute team members were instrumental in 2000 in assisting diesel power and vehicle manufacturers in organizing the Diesel Technology Forum, a not-for-profit advocacy dedicated to raising awareness about the importance of clean diesel engines, fuels and technologies.  Cummins was instrumental in the concept of and the founding of DTF and over the years since has been active in advancing the mission. Our former colleague Allen R. Schaeffer is the organization’s Executive Director.

You’ll want to read and share our Top Story this week with very encouraging comments about sustainability from a respected U.S. corporate sector leader.

Top Stories

Cummins CEO Says Innovation, Sustainability, And Regulations Are Good For Business
(Thursday – April 19, 2018) Source: Forbes – As head of the largest independent maker of diesel engines and related products in the world, Tom has set lofty environmental goals for Cummins, including cutting energy intensity from company facilities by a third by 2020.

Global Trade – Good or Bad For Nations – For Individuals — a Factor in Encouraging Greater Sustainability for Society?

by Hank Boerner – Chair, G&A Institute

“Trade” can be viewed in the macro-environment or the micro, with personal advantages and disadvantages for men and women in both developed and developing nations.

With a new administration coming to Washington DC in January 2017, the heated rhetoric of the 2016 presidential primaries and during the general campaign quickly moved “trade” as a loose-lip and often-un-informed talking point at rallies in the direction of possibly enacted national public policy.

Tear up NAFTA  – punish China – make cozy deals with countries one-at-a-time instead of multi-lateral agreements.  That’s seemingly the direction of the Trump Administration policy-making in 2018 — if we believe the rhetoric.

So — the question hangs — is global trade good or bad for U.S. workers…for the economy…for workers in both developed and developing nations…as a positive or negative in the quest for greater global sustainability?

As in all policy making, we must search for truth and evidence to help answer the questions — and guide public governance.

We do have help if we want to tune in to the source:  The independent, not-for-profit National Bureau of Economic Research (NBER) weighed in in April with a Working Paper: “How Large Are the U.S. Economy’s Gains From Trade?”

FYI – NBER (founded in 1920) is based in Cambridge, Massachusetts, and has a huge cadre of economists and researchers that work to provide us with “objective, quantitative analysis of the American economy.”

The scholars issue a steady stream of Working Papers for public consumption (and study and discussion by policy makers looking for “truth, fact, objectivity, reliable findings”  — my characterizations).

The name may ring a bell — NBER is the non-governmental organization that declares the official start and end of a U.S. recession, for example.  Their declaration is often separate of what is going on in the capital markets so it stands out.

In the current paper, the researchers examined “estimates of the economic benefits of a globally-open economy.”  And the impact plus or minus on the American economy.

Most likely results: they see a gain for the U.S. domestic economy of from 2% to 8% through open global trade, depending on certain assumptions about consumer and producer behavior.

What if we actually slammed the door shut on trade beyond our borders?  Authors Arnaud Costinot and Andres Rodrigues-Clare explain there is [surprisingly] little direct quantitative evidence on how the economy would react if we did begin to close the doors on global trade. (Note to policymakers: That’s why we don’t make hasty or dumb decisions on trade!)

Looking at such factors as labor and capital embedded in goods purchased from around the world, they estimated the gains from trade by comparing the size of a “counter-factual” U.S. economy that would depend entirely on domestic sources compared with a nation (like the USA) that has ready access to foreign services and goods.

While the dollar value of U.S. imports is large, as a percentage of national spending it is actually really small.

There are varying impacts of open trade on individual industries – and the enterprises and their workers.

For garment and apparel companies the demand for cheap labor is “in-elastic” in economic lingo. Not much wiggle room or flexibility. That is why the companies go to East Asia for labor inputs.

For an American automaker, the import of German-made transmissions for installation in Detroit’s models is somewhat lesser of an impact (there are always alternatives).  US manufacturers used to be more “integrated” and made most of the components for their trucks and cars. Now the industry is defined as a global sourcer.

For U.S. farmers, the impact depends on where else in the world wheat is grown and the ready availability and pricing for that wheat. Trade is critical to the American farm belt.

Think of rare minerals used in manufacturing — if vital minerals are only available in certain areas of the globe, and are needed (say for making cell phones or other electronic products), the dependency is greater for U.S. manufacturers (again, in-elasticity reigns).

Tradeoffs in global trade exist everywhere: Lower consumer prices are enjoyed (as designer-label garments flow to U.S. retailers’ shelves from cheap East Asian labor sourcing) — but too many American workers may lose jobs and/or work for lower wages.  And in turn, local communities suffer.  The 2016 elections showed one of the results of that suffering as voters signalled their discontent with trade policies.

Global Trade ESG Issues

NBER researchers looked at a different topic in the trade bucket for their Working Paper: the effects of Fair Trade Certification.

The movement began led by a church-affiliated NGO in Holland and quickly spread throughout Europe and to the U.S.A. and various groups coalesced in the Fair Trade Labelling Organization (“FLO”) in 1997.

In this research effort, NBER authors Raluca Dragusanu and Nathan Nunn examined the impact of the Fair Trade movement on coffee producers in the Central American nation of Costa Rica, in the heart of the global coffee belt (typically countries near the Equator).

They looked at FLO impacts on incomes of coffee growers, their neighbors and communities.

Fair Trade policies, they assert, is a positive as it raises prices for local growers, to begin with, high enough to cover the cost of production. The higher prices are typically intended as well to raise the quality of life in the coffee-growing region.

Premium prices paid by buyers above the set minimums are used to build schools and establish scholarships, create local health care facilities, and various infrastructure, and to help improve growing practices.

Through fair trade practices, income rises in Fair Trade growing areas, for both certified growers and many of their non-growers neighbors.

Income levels were on average 3.5% higher for growers and as much as 7.5% for “skilled” coffee growers (when the “intensity of fair trade increases in an area).

The researchers found that price premiums for growers increased school enrollments (2%-to-5%) for children ages 13-to-17 — critical ages for young men and women preparing for their adult lives.

# # #

We found this and other NBER research interesting. We have “cold, hard facts” about the economy and trade and the “what-ifs” if present trade policies and practices are messed with, and the results are in the main “unknown”.

And we see that global trade is lifting people and their communities in a Central American country where coffee growing is an important agricultural pursuit.  And a benefit of open and fair trade.

Like climate change and many other public issues, there are plusses and minuses in trade affairs — and no easy answers!

Therefore, we can argue, let reason reign, common sense be applied — and science and facts and evidence-based research be the foundations of good public sector decision-making!

Thanks to NBER researchers for their efforts (in producing more than 1,000 Working Papers a year) to continue to produce research and surface evidence that can add to be leveraged to develop both public and private sector strategies.

You can learn more at:  www.nber.org

The Bangladesh Garment Factory Workers Tragedy — and Investor and Corporate Response Five Years On

By Hank Boerner – Chair, G&A Institute

We are five years on from the Rana Plaza “Savar” five-story factory building collapse and fire that killed more than 1,000 garment workers in Dhaka (Dacca), the crowded capital city of Bangladesh. (The accident was on April 24, 2013). In the ashes and debris there were the labels of prominent developed nations’ apparel marketers. Reputations were at stake — “Reforms” discussions were immediately underway in Europe and North America.

The Europeans moved on with the “Bangladesh Accord on Fire and Safety” while in North America brand marketers were moving on “The Alliance on Bangladesh Safety.”

Where are we today?

The Interfaith Center on Corporate Responsibility (ICCR) is keeping the accident and aftermath in the focus of the investment community and stakeholders. Yesterday ICCR (a coalition of 300-plus institutional members managing $400 billion AUM) and the group of allied investors issued a statement that helps to explain where we are.

About The Accord

Right after the building collapse, the Bangladesh Accord on Fire and Building Safety was created as a model for collective action by brand marketers and retailers that source in Bangladesh.

The Accord is now being extended (as the five-year deadline is reached in May) for another three years to complete the remediation of the 1,600 factories and companies that have not signed on (yet) are being invited by the investor coalition to become signatories and to implement the reforms spelled out in the Accord.

The Accord, the investors point out, is still serving as a model that can be adopted and applied to other at-risk countries and sectors.     

The Bangladesh Investor Initiative – led by ICCR – was a catalyst that brought together 250 institutional investors with US$4.5 trillion in AUM in May 2013 to urge a stronger corporate response to the Rana Plaza tragedy, including urging companies to sign on to the Accord.

The coalition invited companies to commit to strengthening local worker trade unions to ensure a “living wage” for all workers, and to engage with the Bangladesh government.

About the Accord:

  • Corporate signatories agree that global and local trade unions and NGOs could be invited to inspect the country’s apparel factories and implement reforms to protect workers.
  • Companies were asked for transparencies in publicly disclosing their suppliers – including those located in the nation of Bangladesh.
  • Worker grievance mechanisms and effective remedies (including compensation) should be put in place for all workers and their families.
  • The investor coalition argued that supply chain transparency is critical to safeguarding workers and employer responsibility – including information on sub-contractors.
  • Note that the Accord is legally-binding for signatories.

Making the Case

Lauren Compere, Managing Director of Boston Common Asset Management makes the case for companies: “Stakeholders, including investors, rely on transparency as a tool for evaluating corporate performance on a range of social, environmental and corporate governance issues. The Accord has been very transparent in requiring disclosure of each of the 1,600 companies it covers, which helps investors track progress. This is a ‘best practice’ that all companies need to implement, beginning with Tier One suppliers, then throughout their supply chain.”

Progress Report – 5 Years On

To date, 220 brands and retailers have signed on to the original Accord. Remediation plans have made 2.5 million workers in “Accord factories” have been made “meaningfully safer”. A steering committee made up of an equal number of brand and union representatives and a neutral chair from the International Labor Organization govern the Accord.

The Accord provided for in-depth health and safety training to personnel in 846 factories, reaching 1.9 million workers. A grievance process is in place; to date, there have been 183 worker complaints investigated and resolved.

Detailed information is required for each factory.

The Rana Plaza Donors Trust Fund has been established to compensate workers injured in the collapse and families of workers who were killed (note that Bangladesh has no national employment injury system). $30 million has been raised to date; companies sourcing garment/apparel work in the country were asked to contribute; 30 companies did so, along with several union funds and foundations. The ILO is the trustee and oversees distributions.

The investor coalition is pleased with the progress made to date – but stresses that there is much work still be done (therefore the 3-year extension is necessary). “The job of mediating all of the issue is far from done and we will continue to urge those companies that have not signed on to the 2018 Accord and its three-year extension to do so.”

The New Elements to the Accord

The 2018 Transition Accord has gathered140 signatory companies to date, with 1,332 factories covered. The new elements include:

  • Safety Committee & Safety Training at all covered factories;
  • Training and Complaints Protocol on Freedom of Association;
  • Severance payments for affected workers in factory closures and relocations.
  • Voluntary expansion of the scope to include home textiles; fabric and knit accessories;
  • Transition of Accord functions to a national regulatory body.

We’ll bring you updates as the Transition to the new Accord continues.

About the Nation of Bangladesh

Located in Southeast Asia, the People’s Republic of Bangladesh is the world’s 8th most populous country, according to Wikipedia (163 million estimated). It was once part of “British India” until East Bengal became part of the Dominion of Pakistan, was re-named East Pakistan and then became independent in the early -1970s. It is characterized as a “developing country,” one of the poorest, and trades with the USA, EU, China, Japan, India, and other nations. Per capita income was estimated at US$1,190 in 2014.

The largest industries are textiles and ready-made garments; leather-goods (footwear is the second largest in exports. Bangladesh is the second largest exporter of clothes in the world.

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Notes / Information:

There’s more information for you on the ICCR web site: www.iccr.org

Information about the Accord: http://bangladeshaccord.org/

The Accord Update for April is at: http://bangladeshaccord.org/wp-content/uploads/ACCORD_FACTSHEET_Apr2018.pdf

There’s information for you in G&A Institute’s “To the Point!” management briefing platform:

https://ga-institute.com/to-the-point/a-big-year-2018-for-developments-in-corporate-sustainability-sustainable-investing-the-two-halves-of-the-great-whole-of-the-new-norms-of-capitalism/

CNBC in commenting on the five year anniversary (on April 24) noted the factories still pose a life-threatening risk, with 3,000 of 7,000 factories endangering the lives of low-paid garment workers (according to a New York University Centre for Business and Human Rights Study).

The story is at: https://www.cnbc.com/2018/04/24/bangladesh-factories-still-pose-life-threatening-risks-five-years-on-from-rana-plaza-disaster.html

The NYU report authored by Paul M. Barrett, Dorothee Baumann-Pauly and April Gu is at: https://static1.squarespace.com/static/547df270e4b0ba184dfc490e/t/5ac9514eaa4a998f3f30ae13/1523143088805/NYU+Bangladesh+Rana+Plaza+Report.pdf

Human Rights Watch also weighed in with “Remember Rana Plaza: https://www.hrw.org/news/2018/04/24/remember-rana-plaza

It’s ESG Survey & Query Time — Public Companies Are In Response Mode

by Hank Boerner & Louis Coppola

Barrage… Avalanche… Tidal wave… Tsunami“Survey Fatigue…
These are terms we hear all year ‘round but especially in the spring of the year as corporate managers describe for us what they often feel as the inevitable flow of third party ESG / Sustainability surveys, forms and various types of questionnaires come pouring their offices. It’s spring – survey time!  Some large-cap companies may receive 200 or more such queries during a year.  What to do!

Effective Response and Engagements Will Be Key to Success
in Communicating Corporate Sustainability Strategies and
Demonstrating Leadership for Investors

The challenges posed to company managers are:

  1. First to decide which queries will matter most to the company and to investors and select those out of the large flow for response;
  2. decide what to do with the rest of the third party queries;
  3. decide what information to be disclosed is material, of relevance and of importance to the third party and beyond to that organization’s user base;
  4. internally source and organize the data and narrative needed in responding to put the best story forward to maximize the positive perceptions of the stakeholders using the data in some way;
  5. and as we hear, [typically] debate internally what can and should be disclosed and why — beyond the mandated financial and related disclosures.

These challenges grow in importance each year as many more asset owners and managers either directly pose the questions to companies — or do so through an army of third-party ESG analytics firms.

The stakes are high and getting higher; the most efficient and effective of the corporate responders could enjoy inclusion in the sustainable investing indexes and benchmarks, and investor products; win high rankings, scores, ratings and other honors bestowed by the third party organizations; and in turn, be recognized by still more third-party organizations for their high scores and rankings.

Questions Often Heard in the Corporate Office: 
How come we are not in the DJSI?
How come “competitor X” is ranked higher than we are?
What should we be doing to improve our scores?
Who are the most important providers to engage with and respond to?

THE MORE TRANSPARENT COMPANY – THE PUBLIC COMPANY ESG PROFILE
Beyond the challenges to responding to the many third party organizations that crank the response and other information into their models and into investor-facing products, there is an ever-widening transparency of the company profile that may be of importance say, to major customers or business partners: for example, the Bloomberg professional services ESG dashboard will put the company’s ESG data and profile in front of more than 300,000 subscribers.   Similarly, the Thomson Reuters’ Eikon dashboards reach 200,000 and more subscribers with the same kinds of information.

We can hear the call from the corporate offices this month — Help!  The spring round of queries is at hand. For example, RobecoSAM’s “Corporate Sustainability Assessment” (the CSA) opened for company response last week; companies have only until the end of May to respond.  (We recently conducted a workshop in NYC for first time reporters in collaboration with RobecoSAM’s Robert Dornau and Gretchen Norwood.)

The information provided by companies in responding to the CSA will be an important determinant in RobecoSAM deciding which companies will be in the Dow Jones Sustainability Indexes and featured in the prized Yearbook roster. The information is used in S&P Dow Jones Company’s various products as well.

HOW TO ADDRESS THE CHALLENGES IN RESPONDING
 The good news is that there are efficient, thorough, comprehensive and organized ways to meet the challenges described above that are faced by many managers at publicly-traded and even privately-owned enterprises.

Here at G&A Institute, we call this our matrix approach that results in a more comprehensive “mosaic” (multi-dimensional) corporate ESG profile with significant benefits for the issuer.

It is important to keep in mind: the public company already has a sustainability profile shaped by its own publicly-disclosed information, by the dissemination of information by third parties distributing ESG analysis and data sets and by such stakeholders as government agencies, media, NGOs, activists, competitors, and others.

This mosaic corporate profile may be incomplete, inaccurate, misleading, or otherwise have information that is detrimental to the company and its stakeholders that can be corrected with more timely and/or accurate information. The “wrong information” can lead to negative perceptions that can affect corporate reputation and valuation, and perhaps even societal freedom to operate.

THE G&A INSTITUTE APPROACH TO ESG DATA REVIEW
We usually start with an examination of the existing public ESG profile of the corporation.  This is the information typically provided to investors and key stakeholders by a ever-expanding universe of the ESG rankers and raters.  This phase of the work this helps us and the internal team in developing an understanding of how investors and stakeholders may be viewing the company, what issues are most material in their view — and from this analysis we can provide strategic guidance for how the company can work to better position itself to take advantage of any advances in corporate sustainability over the months and years ahead.

The comprehensive sweep of first-round examinations can be for a key set of the most important data providers (around 4-to-6) or more comprehensive and up to 15 or more of the ESG data providers, index managers, asset managers and public information platforms (such as the data on the Bloomberg and on Eikon).

The specific third party service providers to be examined may depend on peer group, geography of operations, the company’s sector and industry classifications (and keep in mind there are variations of these), the nature of products and services, and other factors.

IMPORTANCE OF THE GAP ANALYSIS
Once the key third party organizations are selected for close examination, an internal gap analysis against the information being made available to investors by the third party provider can be determined – and addressed by the internal team.

Key areas of strength, weakness and the peers’ standings will emerge for internal managers to address. Low hanging fruit such as correcting inaccurate data, or improving reporting by better organizing important ESG disclosure data, may make it easy for short-term improvement.  Longer term the results of this type of analysis and engagement will inform strategy setting, and resource allocations to most efficiently and effectively improve the ROI of the Sustainability program.

G&A’s Co-Founder Louis Coppola was recently interviewed at Skytop Strategies ESG4 Summit on the “Value Companies Can Obtain by Engaging with ESG Investor Data Providers.”  You can watch the interview here and email Lou at lcoppola@ga-institute.com if you have questions or would like to discuss the ESG review process.

KEEP IN MIND:
Improving the ratings, rankings, scores etc is a journey, not a sprint.

It’s important here to stress that whether or not a company chooses to answer queries, respond to data provider inquiries or attempts to correct some public information that service providers are sharing with investors, there is a public sustainability profile out there and it is making an impression on investors.

As the flow of this year’s queries reaches corporate managers, it is important to understand who some of the key third party ESG players are — and what their work is about – and how they can impact the corporation.  We provide some recent news updates about leading players below for your information.

FOR YOUR FURTHER INFORMATION: NEWS ABOUT KEY ESG / SUSTAINABILITY DATA PROVIDERS

The Universe of ESG Rankers Serving Institutional Investor Clients Expands…
Source:G&A Institute’s To the Point! Management Briefs (January 2018)
ISS’ Traditional Corporate Governance Focus Expanding to Encompass Environmental & Social QualityScores for Roughly 1,500 Public Companies Coming in January…And Expanding to 5,000 Issuers in Q2…

ISS Unveils New Corporate “E” and “S” QualityScores for 1,500 Companies
Source:G&A Institute’s To the Point! (February 2018)

Oekom Research to Join Institutional Shareholder Services
Source: oekom research news (March 2018)
oekom research, a leader in the provision of environmental, social, and governance (ESG) ratings and data, as well as sustainable investment research, today announced it will join Institutional Shareholder Services Inc. (“ISS”). Reflecting the strength of both brands, oekom research will be renamed ISS-oekom…

Sustainalytics’ New Research Report Offers Insight into ESG Risks Facing 10 Sectors
Source: Sustainalytics (February 15, 2018)
Sustainalytics, a leading global provider of ESG and corporate governance research, ratings and analytics, today released a new thematic research report – “10 for 2018: ESG Risks on the Horizon”.  The report examines critical ESG risks facing 10 sectors, which are classified under four broad themes, including: Water Management / Stakeholder Governance / Consumer Protection / Climate Change..

Morningstar & Sustainalytics Expand Sustainability Collaboration
Source: Sustainalytics (July 2017)
In a continuing and growing commitment to helping investors integrate sustainability considerations into portfolio decisions, Morningstar, Inc. (NASDAQ: MORN), a leading provider of independent investment research, and Sustainalytics, a leading global provider of environmental, social, and governance (ESG) research and ratings, today announced that Morningstar has acquired a 40 percent ownership stake in Sustainalytics. The direct investment represents an important milestone in Morningstar’s long-term sustainability strategy and intends to support Sustainalytics’ ability to deliver high-quality, innovative ESG products and services to the global investment community…

Bloomberg ESG Function for Sustainability Investors Adds RobecoSAM Data
Source: Bloomberg (September 2016)
Bloomberg recently expanded its offering of ESG (environmental, social, governance) data by incorporating information from RobecoSAM’s percentile rankings on the Bloomberg Professional service at ESG<GO> —  a Bloomberg Terminal function that provides sustainability investors with data about a company’s environmental, social and governance metrics…

RobecoSAM Publishes “The Sustainability Yearbook 2018”
Source: RobecoSAM (February 2018)
RobecoSAM, the investment specialist that has focused exclusively on Sustainability Investing (SI) for over 22 years, today announced the publication of “The Sustainability Yearbook 2018”.    The Yearbook showcases the sustainability performance of the world’s largest companies and includes the top 15% per industry, which are awarded Gold, Silver or Bronze Class medals. RobecoSAM has analyzed the corporate sustainability performance of the world’s largest listed companies every year since 1999…

Results Announced for 2017 DJSI Review
Source: RobecoSAM (September 7, 2017)
S&P Dow Jones Indices (S&P DJI), one of the world’s leading index providers, and RobecoSAM, an investment specialist focused exclusively on Sustainability Investing (SI), today announced the results of the annual Dow Jones Sustainability Indices (DJSI) review. The three largest additions and deletions…

MSCI:  2018 ESG Trends to Watch
Source: Commentary by Linda Eling-Lee, Global Head of ESG Research, MSCI  (January 2018)
Bigger, faster, more.  Whether due to policy, technological or climatic changes, companies face an onslaught of challenges that are happening sooner and more dramatically than many could have anticipated.  Investors, in turn, are looking for ways to position their portfolios to best navigate the uncertainty. In 2018, these are the major trends that we think will shape how investors approach the risks and opportunities on the horizon. In 2018, investors will…

Has ESG Affected Stock Performance?
Source: Commentary by Guido Giese – ED, Applied Equity Research, MSCI
Are ESG characteristics tied to stock performance? Many researchers have studied the relationship between companies with strong environmental, social and governance (ESG) characteristics and corporate financial performance. A major challenge has been to show that positive correlations — when produced — explain the behavior. As the classic phrase used by statisticians says, “correlation does not imply causation.”Instead of conducting a pure correlation-based analysis, we focused on understanding how ESG characteristics have led to financially significant effects…

CDP:  The Disruptors:  Paul Simpson, the Atypical Activist Who Awoke C-Suites to Climate Risk
Source: Ethical Corporation (November 2017)
The founder of CDP tells Oliver Balch how the organization he started 17 years ago has helped transform corporate and investor attitudes to climate change  The phrase “task force” is hardly one to get the heart racing. Expand it to the Task Force on Climate-related Financial Disclosures, and you’re into catatonic territory. So it’s little wonder that when the TCFD (as insiders call it) issued a suite of recommendations over the summer, it didn’t trouble the headline writers much. Not so Paul Simpson, who met the news with huge excitement…

Our Governments Have Committed to Keeping Global Temperature Rises to Well Below 2-Degrees – What Can Companies and Cities Do…
Source: CDP Campaigns
The Paris Agreement sends a clear signal that the shift to a low-carbon economy is inevitable, and everyone must play their part. To facilitate this transition, CDP and its partners have developed campaigns that seek to highlight and spur meaningful action on tackling climate change from the private sector and sub-national governments…campaign information…. committed to keeping global temperature rises to well…

Feeding 9 Billion People in 2050? Challenging!  – A Leading U.S. CEO in the Food & Agriculture Business Has Important Perspectives to Share

by Hank Boerner -Chair, G&A Institute

The CEO of one of the nation’s leading food and agriculture companies has important messages for us:  “To move the planet forward, farmers must lead the charge. But they cannot do it alone. Coordinated action on sustainability across the food supply chains is the only way to achieve lasting progress.”  He tells us how and why in his commentary in a Top Story in our Sustainability Highlights newsletter.

BackgroundThe Population Division of the Department of Economic and Social Affairs of the United Nations Secretariat in the 2017 revision of the World Population Prospects (the 25th version of this report) says: the current world population of 7.6 billion is expected to reach 8.6 billion in 2030, 9.8 billion in 2050 and 11.2 billion in 2100.

More than 80 million people are added to the world’s population each year. One of the 2030 Agenda for Sustainable Development Goals (the SDGs) is to end poverty and hunger – how do we achieve this will depend in large measure on the success of growers in the USA and many other lands.

Looking at global agriculture moving towards 2050, there are serious challenges posed; the UN’s Food and Agriculture Organization (FAO) in 2009 described some of these:  much more food and fiber must be produced; there will be a smaller rural labor force to help do this; there will be increased demand for more feedstocks for a potentially huge bioenergy market; adapting to climate is  necessary; and, ag producers must be more efficient and sustainable.

Demand for cereals, as example, could almost double from today’s production (for animal feed and human food). Almost all of the land expansion for ag could be in sub-Saharan Africa and Latin America.

The CEO of Land O’Lakes, Chris Policinski writing in Agri-Pulse explains that while the discussion about climate change and other challenges seems to be focused on developments being a generation away, American farmers are dealing right now with such things as harsh drought, severe weather and more pests…the challenges to the food supply are happening right now.

And it is time to start talking about sustainability differently…to include (for example) the reality of what farmers face, acre-by-acre/field-by-field. And then, “farm-to-fork” issues.

Bringing together big-picture, company-level sustainability commitments and acre-by-acre conservation efforts makes both more effective. The great example used by the CEO is Wal-Mart’s Project Gigaton, which aims to remove one billion metric tons of GhGs from the company’s supply chain by 2030.  (Land O’Lakes was one of the first supply partners to sign on.)

There’s much more for you in the Land O’Lakes CEO’s message in one of our Top Stories this week.  There are related items “up top” for you – this week we have ag and food in focus in the Highlights.

Note:  Land O’Lakes, Inc. is a member-owned cooperative agribusiness and food production company based in Minnesota, with $13.7 billion revenues in 2017. The cooperative is almost 100 years in operation and ranks #215 on the Fortune 500® roster.

Top Stories – Ag & Food In Focus

Opinion: To Move Our Planet Forward, Food and Agriculture Must Think about Sustainability Differently
(Friday – April 06, 2018) Source: Agri-Pulse – In many ways, the sustainability story of the American farmer mirrors that of every other American. Farmers genuinely care about doing their part to protect our planet, for all the same reasons as anyone else. They want to leave…

Smallholder farmers are key to making the palm oil industry sustainable
(Monday – April 02, 2018) Source: Eco-Business – Smallholder farmers play an increasingly prominent role in Indonesia’s growing palm oil industry and could be the vanguard of sustainability, say WRI researchers.

A few surprising industries affecting the concept of sustainability in a positive way
(Tuesday – April 03, 2018) Source: Augusta Free Press – In the last ten years, sustainability has become a very important element in the business processes in many industries. For instance, all-natural and organic have become trendy terms in the food industry. Companies which are part…

Opinion: To Move Our Planet Forward, Food and Agriculture Must Think about Sustainability Differently
(Friday – April 06, 2018) Source: Agri-Pulse – In many ways, the sustainability story of the American farmer mirrors that of every other American. Farmers genuinely care about doing their part to protect our planet, for all the same reasons as anyone else. They want to leave…

Don’t Believe In Global Warming? Just Ask A Tuscan Winemaker
(Wednesday – April 04, 2018) Source: Forbes – “Have you seen the effects of climate change and global warming in your region?”

Hershey is investing in more sustainable cocoa for its chocolate treats
(Wednesday – April 04, 2018) Source: LA Times

The DJSI Corporate Sustainability Assessment Will Soon Be “Open” for US Companies to Begin Their Response Effort – a Workshop for Corporate Staff is Scheduled for April 6th in New York City, Presented by G&A Institute in collaboration with RobecoSAM

The Dow Jones Sustainability Indexes are some of the most important and widely-used benchmarks for global investors – the suppliers of capital to the corporate sector.  The “DJSI” benchmarks include the well-known “World” and “North America” indexes.

The DJSI are managed by RobecoSAM which described them as a family of best-in-class indices (launched in 1999) that evaluate the sustainability performance of thousands of publicly-traded companies. The indices track the stock performance of the world’s leading companies across 60 industries in terms of economic, environmental and social criteria.

RobecoSAM is a strategic partner of the S&P Dow Jones Indices and the RobecoSAM “Smart ESG Methodology” is used to generate ESG factor scores to construct a family of indices; the methodology is used for example in constructing the S&P ESG Factor Weighted Index family.

RobecoSAM has been driving innovation of the fields of ESG investing…the indices are built on the strength of rigorous internal analytics and research.  An important input to the process is the annual Corporate Sustainability Assessment (the “CSA”) that RobecoSAM explains in this way:

“The quality of a company’s strategy and management and its performance in dealing with opportunities and risks deriving from economic, environmental and social development can be quantified and used to identify and select leading companies for investment purposes. For this reason, RobecoSAM developed the CSA to help identify those companies that are best equipped to recognize and respond to emerging opportunities and risks resulting from global sustainability trends.”

Very soon, the CSA questionnaire will be landing in the offices of leading US companies for internal managements to complete and return to RobecoSAM as the process for adjusting the family of funds is underway (the results will be known in early fall).  One day after the Skytop Strategies “ESG Summit 4” conference, G&A Institute in collaboration with RobecoSAM is presenting a workshop to help American corporate managements in the response process in New York City on April 6th.

Special Note
Lindsey Kauffman, Environmental Lead at Owens Corning will be at the workshop and will share her insight on leading the CSA/DJSI response for her company. Owens Corning is the Industry Leader in overall score/ranking as well as the Industry Leader in all three dimensions.

Skytop’s CEO Chris Skroupa interviewed RobecoSAM’s Robert Dornau and G&A’s Louis Coppola on the workshop and the importance of the DJSI CSA questionnaire to corporate managements.  There’s lots of important details for you in the Top Story this week from the Forbesinterviews.

If you’d like to learn more about G&A’s advisory services for responding to the RobecoSAM CSA please contact Louis Coppola at lcoppola@ga-institute.com.

Top Story

The Corporate Sustainability Assessment; Important ESG Events In Early April
(Thursday – March 29, 2018) Source: Forbes – interviews by Christopher P. Skroupa – The RobecoSAM Corporate  Sustainability Assessment is about to hit the desks in many publicly traded companies. Are executives aware and what are they doing to prepare?  The CSA is a “living document” – what were they key changes in 2018?