This blog is based on An Eight-Step Guide to the SASB Standards Disclosure Process that was recently published on the Value Reporting Foundation-Sustainability Accounting Standards Board website.
The guide was originally written by an executive at a leading European bank as an internal checklist. However, it is a useful reference for any company that wants to set up an internal process for ESG reporting.
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ESG reporting is still to pick up in a big way. But the signs are positive, with many jurisdictions across the world bringing in mandatory ESG disclosure and a number of reporting standards being available — including those by SASB.
The challenge companies face when it comes to ESG reporting is to decide how and where to focus their energies and resources to provide their stakeholders with the information they seek. The following eight steps offer some clues.
Step 1: Expectation management
The first step is to recognize your most important stakeholders and their expectations about your sustainability disclosures. This may include the frameworks and standards they want you to focus on as well as the frequency with which they evaluate ESG disclosures.
When it comes to institutional stakeholders, you will have to consider the issues they consider as “material” for your industry. You would also want to know how your stakeholders will use the ESG data and narrative you present to them.
Step 2: Applicable standards
The second step is to identify the metrics that apply to your industry in any given set of sustainability standards. For example, if it is the SASB Standards you wish to use, then you need to choose the list of metrics that pertain to your sector out of the 77 industry-specific standards on the SASB website.
Step 3: Assessment and Comparison
Your firm’s existing process of collecting and disclosing data needs to be analyzed and evaluated. This will enable you to assess the extent to which you are already adhering to the metrics articulated in your chosen sustainability standard. ESG as well as financial disclosures put out by your firm should be part of this analysis.
Internal discussions with your team can inform you better on the collection of the data needed to respond to the remaining metrics and whether they are being recorded currently. This can enable you to identify which disclosures can be enhanced and to what extent the information you are collecting aligns with the objective behind their inclusion in your chosen standard.
Identifying which disclosures may be viewed unfavorably by allied stakeholders and providing additional perspective around quantitative responses can go a long way in providing investors with a comprehensive view of things.
Step 4: Evolving Existing Systems
Another key area of focus should be to determine whether your business can make improvements in performance metrics as measured by your sustainability standard. Where they do not align with the expectations of investors and allied stakeholders, efforts should be made to work collaboratively so that expectations line up with outcomes.
It is also advisable to review and compare the disclosure practices of other companies to get an idea about how to plug your own gaps and revise processes if needed.
Step 5: The drafting process
The process of drafting your sustainability disclosures involves paying attention to the documentation or guide that comes with the standards you are using. The ideal way to go about the drafting process is to group your governance or sustainability officers with financial disclosure experts such as external reporting and investor relations personnel. It is advisable to pass on your draft disclosures to law firms and ESG-focused organizations for review.
Two points about your disclosures:
- It is useful to provide a narrative or commentary against the qualitative information you provide. This will help your stakeholders understand your business better.
- In case you are not willing or able to respond to any of the metrics that apply to your business segment, consider providing at least partial information (as far as possible) and explain why you are not able to make a complete disclosure. Not providing any information may raise concerns about the ‘cherry picking’ of the metrics.
Step 6: Senior management involvement
Your draft ESG disclosure should be internally evaluated and reviewed, especially if new information is being divulged. Senior management should be apprised of the disclosures and procedures that are still not up to speed.
Apart from discussing any additional changes that need to be made to your internal processes to comply with the standard, the remaining measures that need to be undertaken to make the disclosure publicly available should also be considered.
Step 7: Publicize your disclosures
After acquiring all the requisite approvals from the senior management and the Board, you may want to make the disclosure public by making it available on your company’s official website along with supporting ESG and corporate governance documents.
You may want to consider other modes of communication as well, including a proxy statement and press release. The right messaging can go a long way in delineating your vision behind the adoption of an ESG standard. Examining other best-in-class disclosures can give you ideas on how to go about your own announcement.
Step 8: Stakeholder engagement
Comments, feedback, and suggestions should always be encouraged in any subsequent stakeholder engagements after the publication of your disclosure. This gives you an opportunity to improve disclosure and associated practices.
Internal transparency should be maintained by reporting all the responses received to top management and the board so that everyone in the company is aligned with each other.
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One aspect of the ESG disclosure preparatory process that has not been mentioned above is digital reporting. For corporate disclosures to lend themselves to comparison and analysis, they need to be in a digital format.
eXtensible Business Reporting Language (XBRL) is the one digital reporting standard that regulators worldwide prefer, and most ESG reporting requirements are bound to mandate the use of XBRL.
For that purpose, most ESG standards setters are making available an XBRL taxonomy that includes all their sustainability concepts.
Companies will need assistance in the form of software and support in order to furnish ESG reports in the digital format — and that is where firms such as IRIS CARBON® step in.
Our SaaS XBRL report creation platform is used in 40 countries across the world. We support companies in their compliance with the mandates of over 30 regulators worldwide.
