Expanding Public Debates About the “What” & “How” of Corporate ESG Disclosure

by Hank Boerner – Chair & Chief Strategist – G&A Institute

March 2, 2021

Corporate sustainability / ESG reporting — What to disclose? How to frame the disclosures (context matters!)? What frameworks or standards to use?  Questions, questions, and more questions for corporate managers to consider as ESG disclosures steadily expand.

We are tuning in now to many more lively discussions going on about corporate ESG / sustainability et al public disclosures and structured reporting practices — and the growing complexity of all this disclosure effort, resulting often in disclosure fatigue for corporate practitioners!

Corporate managers ponder the important question:  which of the growing number of ESG frameworks or standards to use for disclosures? (The World Economic Forum (WEF) describes some 600 ESG guidelines, 600 reporting frameworks and 360 accounting standards that companies could use for reporting.  These do vary in scope, quantity, and quality of metrics.)

In deciding the what and how for their reporting, public companies consider then the specifics of relevant metrics and the all-important accompanying narrative to be shared to meet users’ rising information needs…in this era of emergent “stakeholder capitalism”.

Of course, there is the question for most companies of which or what existing or anticipated public sector reporting mandates will have to be met in various geographies, for various sectors and industries, for which stakeholders.

We here questions such as — how to get ahead of anticipated mandates in the United States if the Securities & Exchange Commission (SEC) does move ahead with adoption of new rules or at least strong guidance for corporate (and investor) sustainability reporting.

The European Union is today ahead in this area, but we can reasonably expect the USA to make important moves in the “Biden Climate Administration” era.  (The accounting standards boards are important players here as well as regulatory agencies in the sovereign states.)

Company boards, executive committees, professional staff, sustainability team managers wrestle with this complex environmental (for ESG disclosure) as their enterprises develop strategies, organize data flows, set in place data measurement protocols, and assemble the ESG-related content for public disclosure. (And, for expanded “private sharing” with ESG ratings agencies, credit risk agencies, benchmark/index managers, to meet customer ESG data requests, and more).

The list of issues and topics of “what” to disclose is constantly expanding, especially as institutional investors (asset owners and their managers) develop their “asks” of companies.

Climate change topics disclosure is at the top of most investor lists for 2021. Human Capital Management issues have been steadily rising in importance as the COVID-19 pandemic (and spread of variants) affects many business enterprises around the globe.

In the USA, SEC has new guidance for corporate HCM disclosures.  Political unrest is an issue for companies.  Anti-corruption measures are being closely examined.

Diversity & Inclusion (including in the board room and C-suite) is growing in importance to investors.

Also, physical risk to corporate assets in the era of superstorms and changing weather patterns – what are companies examining and then reporting on?  Exec compensation with metrics tied to performance in ESG issues is an area of growing interest.

We are monitoring and/or involved in multiple discussions and organized initiatives in the quest to develop more global, uniform, comparable, reliable, timely, complete, and assured corporate sustainability metrics, and accompanying narrative.  And, to provide the all-important context (of reported data) – what does the data mean?  It’s a complicated journey for all involved!

This week we devote the content of this week’s Highlights newsletter to various elements of the public discussions about the many aspects of the journey.

Here at G&A Institute, our team’s recommended best practice:  use multiple frameworks & standards that are relevant to the business and meet user needs; these are typically then disclosed in hybridized report where multiple standards are harmonized and customized for the relevant industries and sectors of the specific company’s operations and reflect the progress (or even lack of) of the enterprise toward leadership in sustainability matters.

This approach helps to reduce disclosure fatigue for internal corporate teams challenged to choose “which” framework or standard and the gathering of data and other content for this year’s and next year’s ESG disclosures.

We shared our thoughts in a special issue of NIRI IR Update, published by the National Investor Relations Institute, the important organization for corporate investor relations officers:


Here are our top selections in the content silos for this week that reflect the complexity of even the public debates about corporate ESG disclosure and where we are in early-2021.

TOP STORIES

The ever-evolving world of ESG investing from a few different points of view. What are the providers of capital examining today for their portfolio or investable product decision-making?  Here are some shared perspectives:

Game Changing News on Climate Crisis Actions – President Biden Announces “Whole of Government” Plans

By Hank Boerner – Chair and Chief Strategist – G&A Institute

What a time to be a sustainability advocate – January 2021 is it!  There was significant news in the USA on matters related to meeting climate change challenges. Start with the Biden-Harris Administration bold moves on addressing the climate crisis…

President Joseph R Biden, in his first days in office signed Executive Orders to commit the “whole of government” to addressing the climate crisis in the USA — and around the world.

The President of the United States of America has broad, sweeping powers as the elected head of the Executive Branch of government.  Presidential EO”s must be anchored in the existing laws of the land (such as the Clean Air Act), be within the powers of the presidency as set out by the Constitution of the United States, and serve as the “directives” and instructions (as well as memoranda and “findings” and more) from the head of the Executive Branch to the organs of the Federal government of the United States of America.

The American Historical Institute explains the EO serves to deliver direct orders, intrepretation of law, provide guidance for future regulatory actions, structure government institutions or processes, and make political statements (foundations of policy). This is an often-used approach creating policy.

American heads of state have used the EO process at least 20,000 times dating back to the days of President George Washington – these orders can be challenged by the other two branches of the U.S. government (Judicial and Legislative).

The Biden Executive Orders are assembled in “Tackling the Climate Crisis at Home and Abroad” – the EOs issued “take bold steps” to combat the climate crisis at home in the USA and throughout the world with many elements included (starting with rejoining the Paris Agreement). Consider:

  • The climate crisis will be “centered” now in U.S. foreign policy and in national security considerations.
  • There will be a climate leaders’ summit in the USA on Earth Day (in April 2021).
  • The Major Economies Forum will be re-convened.
  • A new Special Presidential Envoy is appointed (former Secretary of State John Kerry).
  • The USA’s process to address the “Nationally Determined Contribution” (NDC) called for in the Paris Accord is now underway.
  • The National Intelligence Estimate on security implications of climate change is to be prepared by the Director of National Intelligence for the White House.
  • The White House Office of Domestic Climate Policy is established (headed by former US EPA Administrator Gina McCarthy).
  • Important: the National Climate Task Force is created; this brings the top leaders of the Federal government across 21 agencies (all Cabinet officers) to implement the president’s climate agenda.
  • Clean energy job creation is an important objective – this to be part of the “Build Back Better” initiatives.
  • “Made in America” for manufacturing is a pillar; the Order directs all agencies to buy “carbon-pollution-free” electricity for all government facilities and clean, zero-emission vehicles to help create good paying, union jobs and stimulate clean energy industries.

There’s more – rebuilding infrastructure (focus on “green” here); advancing conservation; reforestation; revitalizing communities left behind as the transition to clean energy displaced workers in fossil fuel extraction and processing; developing approaches to secure “environmental justice” for communities; spurring economic growth; bringing science back into climate change discussions; creating a Presidential Council of Advisors on Science and Technology.

The White House is now reviewing more than 100 of the Executive Orders of the prior administration to reinstate protections for air, water, land and communities.

This is sweeping and presents abundant opportunities and risks for both the corporate community and the capital markets. (As the EOs were being announced, General Motors unveiled its plan to “go all electric” in vehicle manufacture by 2035!)

We have prepared a Resource Paper to explain and explore the many implications for the Biden-Harris Administration moves to address the climate crisis. You can download the paper here: https://www.ga-institute.com/research-reports/resource-papers/biden-harris-white-house-actions-a-ga-resource-paper.html

In the days ahead we will be preparing numerous commentaries for this blog on the many (!) developments aligned with, and supporting, the presidential moves of this week. Stay Tuned!

Picking Up Speed – Adoption of the FSB’s TCFD Recommendations…

January 21 2021

by Hank BoernerChair & Chief StrategistG&A Institute

Countries around the world are tuning in to the TCFD and exploring ways to guide the business sector to report on ever more important climate related disclosures.  Embracing of the Task Force recommendations is a key policy move by governments around the world.

After the 2008 global financial crisis, the major economies that are member-nations of the “G20” formed the Financial Stability Board (FSB) to serve a collective think tank and forum for the world’s leading developed countries to develop strong regulatory, supervisory, and other financial sector policies (guidance, legislation, regulations, rules).

Member-nations can adopt the policies or concepts for same developed collectively in the FSB setting back in their home nations to help to address financial sector issues with new legislative and/or adopted/adjusted rules, and issue guidance to key market players. The FSB collaborates with other bodies such as the International Monetary Fund (the IMF).

FSB operates “by moral suasion and peer pressure” to set internationally-agreed to policies and minimum standards that member nations then can implement at home. In the USA, members include the SEC, Treasury Department and Federal Reserve System.

In December 2015, as climate change issues moved to center stage and the Paris Agreement (at COP 21) was reached by 196 nations, the FSB created the Task Force on Climate-related Financial Disclosures, with Michael Bloomberg as chair.  The “TCFD” then set out to develop guidelines for corporate disclosure on climate change-related issues and topics.

These recommendations were released in 2017, and since then some 1,700 organizations endorsed the recommendations (as signatories); these included companies, governments, investors, NGOs, and others.

Individual countries are taking measures within their borders to encourage corporations to adopt disclosure and reporting recommendations. There are four pillars -– governance, strategy, risk management, and metrics & targets.

A growing number of publicly-traded companies have been adopting these recommendations in various ways and publishing standalone reports or including TCFD information and data in their Proxy Statements, 10-ks, and in sustainability reports.

The key challenge many companies face is the recommendations for rigorous scenario testing to gauge the resiliency of the enterprise (and ability to succeed!) in the 2C degree environment (and beyond, to 4C and even 6C),,,over the rest of the decades of this 21st Century.

Many eyes are on Europe where corporate sustainability reporting first became a “must do” for business enterprises, in the process setting the pace for other regions.  So – what is going on now in the region with the most experienced of corporate reporters are based?  Some recent news:

The Federal Council of Switzerland called on the country’s corporations to implement the TCFD recommendations on a voluntary basis to report on climate change issues.

Consider the leading corporations of that nation — Nestle, ABB, Novartis, Roche, LarfargeHolcim, Glencore — their sustainability reporting often sets the pace for peers and industry or sector categories worldwide.

Switzerland — noted the council — could strengthen the reputation of the nation as global leader in sustainable financial services. A bill is pending now to make the recommendations binding.

The Amsterdam-based Global Reporting Initiative (GRI) is backing an EU Commission proposal for the European Financial Reporting Advisory Group (EFRAG) to consider what would be needed to create non-financial reporting standards (the group now advises on financial standards only). The dual track efforts to help to standardize the disparate methods of non-financial reporting that exist today.

The move could help to create a Europe-wide standard. The GRI suggests that its Global Sustainability Standards Board (GSSB) could make important contributions to the European standard-setting initiative.

And, notes GRI, the GSSB could help to address the critical need for one global set of sustainability reporting standards.  To keep in mind:  the GRI standards today are the most widely-used worldwide for corporate sustainability reporting (the effort began with the first corporate reports being published following the “G1” guidelines back in 1999-2000).

The United Kingdom is the first country to make disclosures about the business impacts of climate change using TCFD mandatory by 2025.

The U.K. is now a “former member” of the European Union (upon the recent completion of “Brexit” process), but in many ways is considered to be a part of the European region. The UK move should be viewed in the context of more investors and sovereign nations demanding that corporations curb their GhG emissions and help society move toward the low-carbon economy.

In the U.K., the influential royal, Prince Charles — formally titled as the Prince of Wales — has also launched a new charter to promote sustainable practices within the private sector.  He has been a champion of addressing climate challenges for decades.

The “Terra Carta” charter sets out a 10-point action plan designed to reduce the carbon footprint of the business sector by year 2030.  This is part of the Sustainable Markets Initiative launched by the prince at the January 2020 meeting in Davos, Switzerland at the World Economic Forum gathering.

Prince Charles called on world leaders to support the charter “to bring prosperity into harmony with nature, people and planet”. This could be the basis of global value creation, he explains, with the power of nature combined with the transformative innovation and resources of the private sector.

We closely monitor developments in Europe and the U.K. to examine the trends in the region that shape corporate sustainability reporting — and that could gain momentum to become global standards.  Or, at least help to shape the disclosure and reporting activities of North American, Latin American, Asia-Pacific, and African companies.

It is expected that the policies that will come from the Biden-Harris Administration in the United States of America will more strenuously align North American public sector (and by influence, the corporate sector and financial markets) with what is going on in Europe and the United Kingdom.  Stay Tuned!

TOP STORIES FOR YOU FROM THE UK AND EUROPE

Items of interest — non-financial reporting development in Europe:

Looking to 2021- Michael Bloomberg Advises: What President Biden Should Do

December 31, 2020

by Hank Boerner – Chair & Chief Strategist – G&A Institute

This is my last post of 2020 – indeed, a chaotic, challenging and tumultuous year for corporate managers and investment professionals.  And the rest of us!

At this time last year we were looking forward to continued peace and economic growth. That new virus spreading infection inside China was a blip on the horizon for many people. 

Most of us did not foresee the rapid spread of this dangerous virus to all corners of the globe, and the resulting tragedy of the immensity of deaths, as many families lost loved ones,  We were not adequately prepared for the resulting economic upheaval posing serious challenges to leaders in the private sector, public sector and capital markets.  At year end we are still working our way through the mess. 

And so we come the start of a new calendar year — 2021! — with all of humanity wishing for better days! 

Many eyes are on the United States of America, the world’s largest economy, which will soon have new leadership in the White House and the important arms of the federal government, the cabinets. Those are State, Treasury, Defense, Interior, Energy, Labor, Commerce, and other departments as well as in key agencies such as the Securities & Exchange Commission, and the Environmental Protection Agency (US EPA).

The better days could start on January 20th when a new President and Vice President are sworn in and a new Congress will already be in office (the 117th Congress will convene on January 5th with 100 Senators and 435 Members of the House of Representatives). 

And there is much work for all of those leaders to do!  There are especially high expectations of soon-to-be President Joe Biden and Vice President Kamala Harris…and the men and women they will appoint or nominate (for U.S. Senate confirmation) to help in leading the USA forward, working in cabinet offices or federal agencies. .

President Biden has said that his will be the “climate change administration” and that meeting the challenges posed by climate change is a top priority.

What should / can be done as these leaders settle into the office?

Mayor Michael Bloomberg, head of the Bloomberg LP organization — he with the loudest megaphone to reach and influence capital markets players, government leaders, NGOs, climate activists, multilateral organizations leaders, and many more leaders and influentials — has some specific suggestions for the Biden-Harris team as they assume office.

Here are some of the highlights of Mayor Mike’s suggestions:

  • “Biden Needs to Lead on Climate Reporting” (the headline of the editorial with the suggestions – there’s a link below).
  • Biden’s pledge to rejoin the Paris Agreement should be carried out and this will send a strong signal to the world. But that will take us back four years (when Secretary of State John Kerry led the US delegation in joining the agreement).
  • To move forward President Biden on his first day in the Oval Office should begin the effort to bring together the leaders of the G-20 nations (the world’s leading economies*)  to endorse a mandatory standard for global businesses to measure and then report on risks all nations face from climate change.

There are mechanisms and players in place to help make rapid progress.

Remember that Michael Bloomberg heads the TCFD – the Task Force on Climate-related Financial Disclosures — which was formed by the Financial Stability Board (FSB) —  the board a creation of the G20 nations after the disaster of the 2008 financial crisis. 

The concept of the FSB is to serve as a sounding board and think tank for the leading economies of the world to address among critical issues risks to the financial system. 

This is the organization’s official description: “The Financial Stability Board (FSB) is an international body that monitors and makes recommendations about the global financial system.  The FSB promotes international financial stability; it does so by coordinating national financial authorities and international standard-setting bodies as they work toward developing strong regulatory, supervisory and other financial sector policies. FSB fosters a level playing field by encouraging coherent implementation of these policies across sectors and jurisdictions.”

This means that the FSB, working through its member organizations, seeks to strengthen financial systems and increase the stability of international financial markets. The policies developed in the pursuit of this agenda are then implemented by jurisdictions and national authorities.  

Members include the US Department of the Treasury, the Federal Reserve System, and the Securities & Exchange Commission.  

The TCFD is a creation of these and other members. 

The TCFD issued recommendations for companies to measure, manage and report on risks and opportunities related to climate change — which Mayor Bloomberg sees as key driver in directing capital to companies with smarter, more responsible leadership that protect and company and seize opportunities related to climate change.

The TCFD guidelines have been adopted or endorsed by 1,000-plus companies and organizations in 80 countries on six continents, Michael Bloomberg pointed out in his editorial.  Sovereign members of the G20 are among the endorsers — Japan, Canada, France, New Zealand, the United Kingdom. 

And so the United States of America — the world’s largest economy — could serve as the catalyst, the unifier, the key player in the drive for adoption of global standards under Biden-Harris leadership. 

This would serve to bring a coordinated effort to deal with the challenges posed by climate change on a global basis, help to develop the right regulations for the world’s family of nations to develop uniform, comparable regulations for climate change disclosure and reporting, and remove uncertainty for corporate leaders and their providers of capital. 

Michael Bloomberg, whose own company’s widely-used platform (“the Bloomberg”) carries volumes of ESG data, tapping his own knowledge of ESG data, advises us that such data must be useful, comparable, and not be confusing (as is frequently now the case). 

Even with the increasing flow of ESG data, the world’s financial markets, Michael Bloomberg points out, operate in the dark today in terms of climate change – which he sees as the biggest risk to the global economy.

Michael Bloomberg is urging the Biden-Harris team to take action “…to help to develop a single global disclosure framework for climate risks that helps drive a faster and more effective response to climate change”.

Or else we will continue “with competing frameworks that make it harder for investors and businesses to identify risks, leading to more economic harm and lower progress”.

Mayor Bloomberg’s summing up his views:  “Climate disclosure is not flashy but it’s one of the important tools we have to speed progress on prevent climate change and economic hardship…which could dwarf the effects of the financial crisis.  The faster we make [disclosure] standard practice globally, the safer and stronger the economy will be.  The US can help lead the way.”

There’s the complete editorial and more perspectives shared at bloomberg.com/opinion.

And so we end 2020 (farewell!) and begin a new year, filled for many people with great hope and promise for better days.  Stay Tuned!  And best wishes to you for the new year.  

#  #  #

P.S. Michael Bloomberg was also the Chair of the Sustainable Accounting Standards Board (SASB) Foundation, 2014-2018 and remains supportive of the organization.

You can follow Michael Bloomberg on his web site:  https://www.mikebloomberg.com/

*  The G20 nations are the USA, UK, Germany, France Italy, Japan, Canada (these are the G7); Argentina, Australia, Brazil, China, India, Indonesia, Mexico, Russia, Saudi Arabia, South Africa, South Korea, Turkey.  Plus “guests” – Spain; two African countries; the International Monetary Fund; World Bank; United Nations; the World Trade Organization; the Financial Stability Board (all attend G20 summits).  

To understand the influence of the Financial Stability Board, here are the members: https://www.fsb.org/about/organisation-and-governance/members-of-the-financial-stability-board/

The members of the Task Force (TCFD) and other information: https://www.fsb-tcfd.org/about/

Looking Back to Look Ahead – The Promise of Biden-Harris Administration to Return to the Hopes of Action on Climate Change Issues

November 9, 2020

By Hank Boerner – Chair & Chief Strategist – G&A Institute

For almost four l-o-n-g, long years we have been watching – and decrying! – the antics of the Trump Administration in the attempt to roll back vital federal environmental protections that have been put in place (and protected) by elected representatives of both parties over five decades.

It was President Richard M. Nixon – a Republican and conservative leader – who signed the National Environmental Policy Act of 1969 (NEPA) into the law of the land. NEPA was established by the 91st Congress and became law on January 1, 1970.

This also established the President’s Council on Environmental Quality. What flowed thereafter was important…

…the Environmental Protection Agency (US EPA) was created;
The Clean Air Act was enacted into law;
The Clean Water Act soon followed; and then
Toxic Substances Control Act (TSCA);  and 
…”Superfund” for clean up of contamination (actually, CERCLA-Comprehensive Environmental Response, Compensation and Liability Act);  and
Emergency Planning and Community Right-to-Know Act;  and 
Endangered Species Act;  and
Federal Insectiside, Fungicide, and Rodenticide Act; and 
Energy Policy Act; and
Chemical Safety Information, Site Security and Fuels Regulatory Relief Act;
…and much more!

Beginning almost immediately as the Trump Administration took charge of the EPA and other cabinet agencies, these historic legislative achievements were being undermined and protections whittled away.

There will be new environmental overseers coming to town in 2021 and the great hopes pinned on the Biden-Harris Administration include rebuilding the important rules, oversight mechanisms and enforcement of the laws/rules by EPA, Interior, Energy and other agencies.

The New York Times today outlined the first steps that could be taken – issuance of presidential Executive Orders (EOs) and President Memoranda that would undo the same mechanisms employed by President Trump and EPA political leaders to undermine environmental protection measures.

We read in — “Biden Will Roll Back Parts of the Trump Agenda With Strokes of a Pen” – that on Day One, we can expect action on climate change, writes Michael D. Shear and Lisa Friedman.

That starts with notice to the United Nations that the U.S.A. will rejoin the Paris Agreement.

The move to revoke Trump era EOs and re-issue Obama-Biden Administration orders can be immediate; or, President Joe Biden in 2021 can issue new orders along the same lines of prior EOs addressing climate change issues.

Important: The new Executive Orders would create important policies for the heads and rank and file members of the departments – Defense, EPA, Labor, Commerce, Interior, SEC, and many others that in some way directly or indirectly are affected by climate change.

Attitudes do matter – and Presidential Executive Orders to heads of agencies really matter!

2021 is looking like climate change matters will move to front-and-center on the public policy agenda. The Financial Times today pointed out that candidate Joe Biden set a policy of having a target to reach zero carbon

While Donald Trump led the effort to isolate the United States from world affairs, China moved to pledge net zero by 2060 and Japan and South Korea set net zero targets.

With the USA back on board, real progress can be made toward meeting Paris Agreement goals. Exciting to consider: The United States of America as once again a leader in the drive to make the world a safer, healthier place for billions of us!

For a reminder of the Trump moves in 2017 to reverse a half-century and more of environmental protection, here’s my March 2017 look at what was underway just two months into the new administration, with a new leader (Administrator Scott Pruitt) at the helm of the EPA.

Let’s go back to March 2017 – Just two months into the Trump Administration – with bad news on climate change all around!

http://ga-institute.com/Sustainability-Update/climate-change-nah-the-deniers-destroyers-are-work-white-house-attempts-to-roll-back-obama-legacy/