The State of Sustainable / ESG Investment in 2018: The State of Corporate Sustainability Reporting & How We Got Here

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

In this issue of our weekly newsletter we brought you two important Top Stories that capture the state of sustainable investing from varying points-of-view. 

We selected these research efforts for their value to both corporate managers and investment professionals.

  • Corporate staff can use the findings to “make the case” upward to C-suite and boardroom using both documents.
  • Investors not yet on board with Sustainable / ESG investing can gain valuable insights from both reports.

First is the report by Guido Giese and Zoltan Nagy at MSCI – “How Markets Price ESG” – addressing the question “have changes in ESG scores affected market prices?”

MSCI examines the changes in companies ESG scores, “ESG momentum” — either strong or negative for the companies being rated. Using the firm’s model, the research showed that markets reacted “most sensitively” to improvements in a public company’s characteristics rather than to declines in ESG performance, among many other takeaways in the full report.

The takeaway is that changes in ESG profiles of companies certainly affect company valuations.  The change in ESG characteristics showed the strongest move in equity pricing over a one-year horizon compared to shorter or longer time frames.  The report contains a well designed, thorough methodology which clearly demonstrates the importance of a public company’s ESG profile.

The MSCI score, the authors point out, is a proxy for the ESG-related information that the market is processing. (All MSCI ESG scores are updated at least once a year.)  There’s good information for both corporate managers and investment professionals in the 25-page report.

The second report is a snapshot of the “State of Integrated and Sustainability Reporting 2018” — issued by the Investor Responsibility Research Institute (IRRCI)Sol Kwon of the Sustainable Investments Institute (Si2) is the author and colleague Heidi Welsh is editor.  (IRRCI and Si2 regularly publish research reports together.)

The report charts the evolution of corporate sustainability reporting, which got off to a modest start in the 1980s – then on to the 1990s when corporate sustainability reports as we know them today as investors and companies adopted ESG or Triple Bottom Line approaches.

Key:  Another transition is underway, writes author Kwon, the “value creation” (a/k/a shared value) which should lead to more holistic reporting of inputs and outputs…and the emergence of the integrated report.

In 2013, IRRCI had Si2 look at the state of integrated reporting among the S&P 500® companies and examined practices again for this year’s report.  (The earlier work focused on what companies were reporting without regard to status as “mandated” or “voluntary” disclosure.)  Much progress has been made – for one thing, investor attention on ESG matters is much higher today…making corporate sustainability reporting ripe for the next phase.

The details are set out for you in the IRRCI report including trends and examples in use of reporting frameworks (GRI, SASB, IIRC), Quality, Alignment with SDGs, Inclusion of Sustainability in Financial Reports, Investor Engagement / Awareness, Board Oversight, Incentives, and many other important trends.

This an important comprehensive read for both corporate managers and investment professionals, with a sweep of developments presented in an easy-to-read format.

Example:  What drives ESG integration into investment strategy?  The drivers are identified and presented in a graphic for you.

Important note for you regarding IRRCI:  in 2019 the organization’s intellectual properties will be assumed by the Weinberg Center at the University of Delaware.  The center conducts research and holds conferences on corporate governance and related issues and is headed by Charles Elson, one of the most highly-regarded thought leaders on corporate governance in the U.S.

Important Study on ESG Momentum by MSCI: 
https://www.msci.com/www/research-paper/how-markets-price-esg-have/01159646451

State of Integrated and Sustainability Reporting 2018:
https://irrcinstitute.org/wp-content/uploads/2018/11/2018-SP-500-Integrated-Reporting-FINAL-November-2018.pdf

Changes Ahead for Corporate Sustainability Reporting

This is a guest post by our colleague-in-sustainability, Jane DeLorenzo.  She recently completed the on-line Certificate in Corporate Responsibility & Sustainability Strategies.  The platform is hosted by G&A Institute and developed in partnership with IntegTree LLC. This is a dual credentials course!  A certificate is issued by Swain Center for Executive & Professional Education at the University of North Carolina-Wilmington and a separate certification is issued by G&A Institute.  This commentary is prepared as part of the completion of the coursework.  We are sharing it today to broaden understanding of the state-of-sustainability reporting – present and future.  Find out more about the dual certificate program here.

By Jane DeLorenzo  October 27, 2017

Now is the time for businesses and other organizations to take a closer look at their sustainability reporting; key considerations are what they report, why, how and which standards to use.

New standards released by the Global Reporting Initiative (GRI) will take effect July 1, 2018 — so the clock is ticking.

As more global companies produce sustainability reports, the process has become more complex. Competing standards and frameworks, increasing pressures from investors and other stakeholders, and the costs and resources involved to develop such reports can be challenging – and baffling to leaders.

While GRI is positioning and advocating to be the de facto global reporting standard, companies can select other frameworks, such as those of the Sustainability Accounting Standards Board (SASB) or the International Integrated Reporting Council (IIRC).

There are important factors to consider. Organizations can opt for an integrated report that includes both financial and sustainability information, or they can issue a sustainability report that is separate from the annual financial report.

Producing no sustainability report is also an option, since all three of these standards are voluntary in the United States and most other countries. Companies should be aware, though, that stakeholders may cry foul if no report is produced.

What’s a company to do?

The Continued Evolution of Reporting

Sustainability reports tell the story of an organization’s impacts on economic, environmental and social issues. Many corporations began to examine their non-financial impacts following the environmental and social movements of the 1970s in Europe and the United States.[i]

Public outcry due to rising awareness of pollution and social inequities pushed companies to try to be more transparent. Shareowners were making the case that non-financial issues can and do impact a firm’s financial performance.

In the U.S., for example, emissions data reporting was spurred by Right-to-Know legislation and rules in 1986 that required accountability from companies that were releasing toxic chemicals into the environment.[ii]

Demand for environmental and social disclosures led to the formation of GRI in 1997 by the Coalition for Environmentally Responsible Economies (now known as CERES) and the nonprofit Tellus Institute, both based in Boston. GRI later partnered with the United Nations Environment Programme (UNEP), which had been promoting voluntary environmental reporting by companies and industry groups.

At a ceremony in 2002 announcing the move of the GRI headquarters from Boston to Amsterdam in the Netherlands, UNEP Executive Director Dr. Klaus Töpfer acknowledged GRI’s mission to develop a framework for voluntary sustainability reporting.

He commented: “An increasing number of stakeholders, including the investment community, share the goal of the GRI to raise the practice of corporate sustainability reporting to the level of rigour, credibility, comparability and verifiability of financial reporting.”[iii]

GRI launched its first sustainability reporting framework in the year 2000 and subsequently developed four versions of its guidelines (G1 through G4). Keeping current was a long-term challenge for companies reporting their corporate social responsibility (CSR) efforts. Over time it became clear that a simplified, easier-to-update standard was needed. The new GRI Standards are meant to streamline and simplify the process.

As GRI marks its 20th year, the organization is attempting to “tackle the confusion among companies about the proliferation of different reporting frameworks,” according to GRI Chief Executive Tim Mohin.[iv]

While some media reports claim GRI and SASB are competing frameworks, a 2017 article in GreenBiz, co-authored by Mohin and SASB Founder/CEO Jean Rogers, intended to dispel this perception.[v] The article states: “Rather than being in competition, GRI and SASB are designed to fulfill different purposes for different audiences. For companies, it’s about choosing the right tool for the job.”

Best Practices

Using the right tool, or standard, is the key to companies producing a successful report for their target audience.

While GRI is the widely-accepted framework for reporting sustainability initiatives to a broad audience, SASB focuses on reporting to the investor audience. This audience is interested in the link between sustainability and financial performance. Both GRI and SASB agree on a common goal: to improve corporate performance on sustainability issues.

Other organizations with similar goals include a list of initials and acronyms:  IIRC, CDP, ISO, OEDC, SDG and more. These are:

  1. IIRC (International Integrated Reporting Council) promotes integrated reporting to provide “investors with the information they need to make more effective capital allocation decisions,” according to its website.[vi]
  2. CDP (formerly known as Carbon Disclosure Project) partners with organizations to measure their carbon footprint. Many companies use CDP alongside other reporting frameworks.
  3. ISO, the International Organization for Standardization developed ISO 26000 to help organizations improve their social responsibility efforts.
  4. OECD is the Organization for Economic Cooperation and Development. Its industrial economy member countries negotiate guidelines surrounding social responsibility.
  5. SDG stands for the United Nations “Sustainable Development Goals.” UN member states adopted the 17 SDGs with 169 targets that seek to protect the planet, end poverty, fight inequality and address other social injustices.

While CSR reporting has been widely voluntary, mandatory reporting is taking effect in some countries. In the European Union, large companies (more than 500 employees and certain assets and revenues) now face mandatory disclosure of environmental and social impacts beginning with their 2018 annual reports.[vii]

The EU published its own guidelines in 2017, but it allows companies to choose among the various standards. Laws requiring CSR reporting are also in effect in South Africa, China and Malaysia. Meanwhile, a growing number of stock exchanges around the world are issuing sustainability reporting guidance and requirements.

Companies that are just beginning the process to report on their sustainability impacts should find the new GRI Standards relatively simple to use. The Standards are free to download from the GRI website (www.globalreporting.org) by registering a company name and email address. Organizations can use all or some of the Standards, but they must notify GRI of their intended use.

The new Standards are made up of three modules (or manuals): (1) the Foundation, which describes the basic reporting principles; (2) General Disclosures, which outline required contextual information about an organization and how it operates; and (3) Management Approach, which requires organizations to state how they approach their selected sustainability topics or issues.

While the content and requirements are basically unchanged from the currently-used GRI G4, the Management Approach now takes center stage. A reporting company must provide information on how it “identifies, analyzes and responds to its actual and potential impacts.”[viii]

Once a company determines its approach to a key topic, this management approach might stay the same from year to year. Also, one management approach may apply to several key topics, which should make reporting more concise. The Standards include three additional modules that are organized according to topic categories: economic, social and environment.

Focusing on material (or key) topics, rather than a long list of topics, should also make the reporting process more concise as well as more meaningful to stakeholders. In other words, less is more. The new Standards direct companies to identify their key topics and then report on at least one of the topic-specific GRI disclosures.

For example, Company XYZ determines from stakeholder feedback that the topic of waste will be included in its sustainability report. Both the new GRI standards and G4 guidelines include five disclosures on waste. The new Standards require reporting on one disclosure so Company XYZ can report more in depth on this key topic.

Previously, some companies felt compelled to report on a greater number of topics and disclosures in order to be ranked favorably by rating agencies like Bloomberg or Thomson Reuters. These ratings not only can affect a company’s stock price, but they also can influence a company’s CSR strategy.

According to a 2016 study on rating agencies, about 33 percent of companies said inquiries from sustainability analysts shaped their overall business strategy.[ix]

Implications and Conclusion

Regardless of which sustainability reporting guidelines an organization chooses, the number of companies producing voluntary or mandatory reports is growing.

The process itself can give companies a clearer picture of their impacts and progress meeting their CSR targets. These insights help companies develop strategies to identify risks and opportunities within their realm of sustainability.

Because the GRI framework has been widely accepted globally, its new Standards will likely have a strong impact on the future of reporting. But it’s also likely that the leadership of corporations will continue to take a closer look at the link between sustainability and financial performance. Consequently, other frameworks that focus on both financial and non-financial impacts could gain acceptance.

GRI, SASB, IIRC and other frameworks are all driving improvements in sustainability reporting. As GRI’s Mohin explained: “In order to be more impactful, reporting needs to be concise, consistent, comparable and current. Brevity and consistency are key to successfully managing and understanding the insights delivered by the reported data.”[x]

Reporting must consider the financial bottom line if a company is to be both profitable and sustainable. What matters is that organizations need to be mindful of their reasons for reporting and how sustainability reporting can make an impact internally and externally. Honest, balanced and transparent reporting will ultimately benefit companies, their stakeholders and society-at-large.

Author:  Jane DeLorenzo is Principal of Sustainable Options, specializing in sustainability report writing and editing, and compliance with GRI reporting.

 

 

 

 

 

 

 

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The on-line Certificate in Corporate Responsibility & Sustainability Strategies provides a broad overview of key corporate responsibility challenges and strategies that will enable organizations to succeed in the 21st Century Green Economy.  The Program Developer is Nitish Singh, Ph.D., Associate Professor of International Business at the Boeing Institute of International Business at Saint Louis University with Instructor Brendan M. Keating.

Information is here:  http://learning.ga-institute.com/courses/course-v1:GovernanceandAccountabilityInstitute+CCRSS+2016/about

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References:

[i] Brockett, A. and Rezaee, Z. (2015). Corporate Sustainability: Integrating Performance and Reporting. Retrieved from https://www.safaribooksonline.com/library/view/corporate-sustainability-integrating/9781118238066/chapter02.html

[ii] Environmental Protection Agency, United States. (n.d.) Timeline of Toxics Release Inventory Milestones. Retrieved from  https://www.epa.gov/toxics-release-inventory-tri-program/timeline-toxics-release-inventory-milestones

[iii] CSRwire (2002, April 22). Global Reporting Initiative Announces Move to Amsterdam. Retrieved from http://www.csrwire.com/press_releases/15359-Global-Reporting-Initiative-Announces-Move-to-Amsterdam

[iv] GRI (2017, October 4). Q&A with GRI Chief Executive Tim Mohin. Retrieved from https://www.globalreporting.org/information/news-and-press-center/Pages/QA-with-GRI-Chief-Executive-Tim-Mohin.aspx

[v] Mohin, T. and Rogers, J. (2017, March 16). How to approach corporate sustainability reporting in 2017. Retrieved from https://www.greenbiz.com/article/how-approach-corporate-sustainability-reporting-2017

[vi] International Integrated Reporting Council. (n.d.) Why? The need for change. Retrieved from https://integratedreporting.org/why-the-need-for-change/

[vii] European Commission, Belgium. (n.d.) Non-financial reporting. Retrieved from    https://ec.europa.eu/info/business-economy-euro/company-reporting-and-auditing/company-reporting/non-financial-reporting_en

[viii] GRI (n.d.) GRI 103: Management Approach. Retrieved from https://www.globalreporting.org/standards/gri-standards-download-center/gri-103-management-approach/

[ix] Sustainable Insight Capital Management (2016 February) Who are the ESG rating agencies? Retrieved from https://www.sicm.com/docs/who-rates.pdf

[x] GRI (2017, October 4). Q&A with GRI Chief Executive Tim Mohin. Retrieved from https://www.globalreporting.org/information/news-and-press-center/Pages/QA-with-GRI-Chief-Executive-Tim-Mohin.aspx

 

Will We See Mandated Corporate Reporting on ESG / Sustainability Issues in the USA?

by Hank Boerner – Chairman – G&A Institute

Maybe…U.S. Companies Will Be Required…or Strongly Advised… to Disclose ESG Data & Related Business Information

Big changes in mandated US corporate disclosure and reporting on ESG factors may be just over the horizon — perhaps later this year? Or perhaps not…

Sustainable & responsible investing advocates have long called for greater disclosure on environmental and social issues that affect corporate financial performance (near and long-term). Their sustained campaigning may soon result in dramatic changes in the information investors and stakeholders will have available from mandated corporate filings.

We are in countdown mode — in mid-April the Securities & Exchange Commission (SEC), the agency that regulates many parts of the capital market operations and especially corporate disclosure and reporting for investors issued a Concept Release with a call for public comments.

Among the issues In focus are potential adjustments, expansions and updating of mandated corporate financial reporting. One of these involves corporate ESG disclosure. The issue of “materiality” is weaved throughout the release.

Among the many considerations put forth by SEC: expanding corporate disclosure requirements for corporate financial and business information to include ESG factors, and to further define “materiality.” Especially the materiality of ESG factors.

The comment period is open for you to weigh in with your opinion on corporate ESG disclosure and reporting rules — or at least strong SEC guidance on the matter.

SEC has been conducting a “Disclosure Effectiveness Initiative,” which includes looking at corporate disclosure and reporting requirements, as well as the forms of presentation and methods of delivery of corporate information made available to investors. (Such as corporate web site content, which most feel needs to be updated as to SEC guidance.)

The umbrella regulatory framework — “Regulation S-K” — has been the dominant approach for corporate reporting since 1977 has been the principal repository (in SEC lingo) for filing corporate financial and business information (such as the familiar 10-K, 10-Q, 8-K, etc.).

Investors Want More Corporate ESG Information

For a number of years now, investment community players have urged SEC to look at mandating or offering strong guidance to public company managements to expand disclosure and reporting to substantially address what some opponents conveniently call “non-financial,” or “intangible” information. An expanding base of investors feel just the opposite — ESG information is quite tangible and has definite financial implications and results for the investor. The key question is but how to do this?

Reforming and Updating Reg S-K

In December 2013 when the JOBS Act (“Jumpstart Our Business Startups”) was passed by Congress, SEC was charged with issuing a report [to Congress] on the state of corporate disclosure rules. The goal of the initiative is to improve corporate disclosure and shareholders’ access to that information.

The Spring 2016 Concept Release is part of that effort. The SEC wants to “comprehensively review” and “facilitate” timely, material disclosure by registrants and improve distribution of that information to investors. Initially, the focus is on Reg S-K requirements. Future efforts will focus on disclosure related to disclosure of compensation and governance information in proxy statements.

Asset managers utilizing ESG analytics and portfolio management tools cheered the SEC move. In the very long Concept Release – Business and Financial Disclosure Required by Regulation S-K, at 341 pages — there is an important section devoted to “public policy and sustainability” topics. (Pages 204-215).

ESG / Sustainability in Focus For Review and Action

In the Concept Release  SEC states: In seeking public input on sustainability and public policy disclosures (such as related to climate change) we recognize that some registrants (public companies) have not considered this information material.

Some observers continue to share this view.

The Concept Release poses these questions as part of the consideration of balancing those views with those of proponents of greater disclosure including ESG information:

• Are there specific public policy issues important to informed voting and investment decisions?

• If the SEC adopted rules for sustainability and public policy disclosure, how could the rules result in meaningful disclosures (for investors)?

• Would line items about sustainability or public policy issues cause registrations to disclose information that is not material to investors?

• There is already sustainability and ESG information available outside of Commission (S-K) filings — why do some companies publish sustainability, citizenship, CSR reports…and is the information sufficient to address investor needs? What are the advantages and disadvantages of these types of reports (such as being available on corporate web sites)?

• What challenges would corporate reporters face if ESG / sustaianbility / public policy reporting were mandated — what would the additional costs be? (Federal rule making agencies must balance cost-benefit.)

• Third party organizations — such as GRI and SASB for U.S. company reporting — offer frameworks for this type of reporting. If ESG reporting is mandated, should existing standards or frameworks be considered? Which standards?

The Commission has received numerous comments about the inadequacy of current disclosure regarding climate change matters. And so the Concept Release asks: Are existing disclosure requirements adequate to elicit the information that would permit investors to evaluate material climate change risk? Why — or why not? What additional disclosure requirements– or SEC guidance — would be appropriate?

Influential Voices Added to the Debate

The subject of expanded disclosure of corporate ESG, sustainability, responsibility, citizenship, and related information has a number of voices weighing in. Among those organizations contributing information and commentary to the SEC are these: GRI; SASB; Ceres; IEHN; ICCR; PRI; CFA Institute; PWC; E&Y; ISS; IIRC; BlackRock Institute; Bloomberg; World Federation of Exchanges; US SIF.

The overwhelming view on record now with SEC is that investor consideration of ESG matters is important and that change is needed in the existing corporate reporting and disclosure requirements. You can add your voice to the debate.

For Your Action:

I urge your reading of the Concept Release, particularly the pages 204 through 215, to get a better understanding of what is being considered, especially as proposed by proponents; and, I encourage you to weigh in during the open public comment period with your views.

You can help to ensure the SEC commissioners, staff and related stakeholders understand the issues involved in expanding corporate disclosure on ESG matters and how to change the rules — or offer strong SEC guidance. Let the SEC know that ESG information is needed to help investors better understand the risks and opportunities inherent in the ESG profiles of companies they do or might invest in.

SEC rules or strong guidance on ESG disclosure would be a huge step forward in advancing sustainability and ESG consideration by mainstream capital market players.

Information sources:

The SEC release was on 13 April 2016; this means the comment period is open for 90 days, to mid-July.

Helpful Background For You

Back in 1975 as the public focus on environmental matters continued to increase (all kinds of federal “E” laws were being passed, such as the Clean Air Act and Clean Water Act), stakeholders asked SEC to address the disclosure aspects of corporate environmental matters.

The initial proposal was deemed to have exceeded the commission’s statutory authority.

In 1974 the ERISA legislation had been passed by Congress, and pension funds, foundations and other fiduciaries were dramatically changing the makeup of the investor community, dwarfing the influence of one once-dominant individual investor. After ERISA and the easing of “prudent man” guidelines for fiduciaries, institutional investors rapidly expanded their asset holdings to include many more corporate equities.

And the institutions were increasingly focused on the “E,” “S” and :”G” aspects of corporate operations — and the real or potential influence of ESG performance on the financials. Over time, asset owners began to view the company’s ESG factors as a proxy for (effective or not) management.

While the 1975 draft requirements for companies to expand “E” and “S” information was eventually shelved by SEC, over the years there was a steady series of advances in accounting rules that did address especially “E” and some “S” matters.

FAS 5 issued by FASB in March 1975 addressed the “Accounting for Contingency” costs of corporate environmental liability FASB Interpretation FIN 14 regarding FAS 5 a year later (September 1976) addressed interpretations of “reasonable estimations of losses.” SEC Staff Bulletins helped to move the needle in the direction of what sustainable & responsible investors were demanding. Passage of Sarbanes-Oxley statutes in July 2002 with emphasis on greater transparency moved the needle some more.

But there was always a lag in the regulatory structure that enables SEC to keep up with the changes in investment expectations that public companies would be more forthcoming with ESG data and other information. And there was of course organized corporate opposition.

(SEC must derive its authority from landmark 1933 and 1934 legislation, expansions and updates in 1940, 2002, 2010 legislation, and so on. Rules must reflect what is intended in the statutes passed by Congress and signed into law by the President. And opponents of proposals can leverage what is/is not in the laws to push back on SEC proposals.)

There is an informative CFO magazine article on the subject of corporate environmental disclosure, published September 9, 2004, after the Enron collapse, two years after Sarbanes-Oxley became the law of the land, and 15+ years after the SEC focused on environmental disclosure enhancements. Author Marie Leone set out to answer the question, “are companies being forthright about their environmental liabilities?” Check out “The Greening of GAAP” at: http://ww2.cfo.com/accounting-tax/2004/09/the-greening-of-gaap/

And we add this important aspect to corporate ESG disclosure: Beginning in 1990 and in the years that followed, the G1 through G4 frameworks provided to corporate reporters by the Global Reporting Initiative (GRI) helped to address the investor-side demand for more ESG information and the corporate side challenge of providing material information related to their ESG strategies, programs, actions and achievements.

The G&A Institute team sees the significant progress made by public companies in the volume of data and narratives related to corporate ESG performance and achievements in the 1,500 and more reports that we analyze each year as the exclusive data partner for The GRI in the United States, United Kingdom, and The Republic of Ireland.

We have come a very long way since the 1970s and the SEC Concept Release provides a very comprehensive foundation for dialogue and action — soon!

Please remember to take action and leave your comments here:
http://www.sec.gov/rules/concept.shtml