ESG and Climate Impact Reporting
Looking into what information goes into an Environmental, Social, and Governance (ESG) report, how companies elect to disclose such information, how rating organizations collect and weigh the relevant data, what companies disclose, and how they disclose it can feel a bit like falling down the proverbial rabbit hole. Today, there is no single, global standard or framework for reporting. While in the United States the Securities and Exchange Commission (SEC) has a Climate and ESG Task Force working on a framework for ESG and climate disclosures, this comes after former SEC Acting Chair Allison Lee acknowledged that “Investors are demanding more and better information on climate and ESG, and that demand is not being met by the current voluntary framework…”1 For a baseline understanding of the present state, here is a look at the key “Group of Five” sustainability data collection and reporting organizations responsible for the top industry-recognized standards and frameworks in use today.
- CDP (originally the Carbon Disclosure Project) is a global non-profit that provides environmental impact information, including a Greenhouse Gas (GHG) Emissions Dataset with information on 5,000+ companies as well as lists of CDP’s top-rated companies and cities in the areas of climate, forest, and water security. Its reporting framework is centered on companies voluntarily providing information in a questionnaire format. In 2020, CDP reported that more than 9,600 companies used its framework to disclose climate-/environment-related information. See https://www.cdp.net/en for more information.
- Climate Disclosure Standards Board (CDSB) is a global consortium of environmental non-governmental organizations (NGOs) and businesses that offers its own framework for companies to provide environmental/climate change information. According to its website, “The CDSB Framework supports companies in reaching the UN Sustainable Development Goals by helping them integrate sustainability information into their annual mainstream reporting cycle.”2 The organization also hosts the Task Force on Climate-related Financial Disclosures (TCFD) Knowledge Hub (see TCFD description below). See https://www.cdsb.net/what-we-do
- Global Reporting Initiative (GRI) is an independent organization whose standards for public reporting of ESG impacts, the GRI Standards, is the most widely used worldwide by governments, businesses, and other entities. See https://www.globalreporting.org/about-gri/
- International Integrated Reporting Council (IIRC) is another global coalition of investors, companies, NGOs, academia, regulators, and standards entities whose “International <IR> Framework and Integrated Thinking Principles have been developed and are used around the world, [in] 75 countries, to advance communication about value creation, preservation and erosion.”3 See https://www.integratedreporting.org
- Sustainability Accounting Standards Board (SASB) is an international non-profit whose 77 SASB Standards focus on the ESG issues identified as most related to financial performance in each of 77 industries, sorted by sector. In September 2021 it was reported that 1,300 companies, including 600+in the S&P 1200 Index, use the SASB Standards.4 See https://www.sasb.org/
Recognizing that the current landscape is difficult for companies and investors to navigate coherently, the organizations listed above are collaborating to develop a comprehensive sustainability reporting system. They released “Reporting on Enterprise Value Illustrated with a Prototype Climate-Related Financial Disclosure Standard” on the fifth anniversary of the Paris Agreement in December 2020. 5 To date, however, no final global comprehensive system has been developed or adopted.
A few other organizations and reporting frameworks of note:
- Principles for Responsible Investment (PRI), a not-for-profit organization supported by (though not part of) the United Nations and funded by annual membership fees from organizations that sign its Principles for Responsible Investment, promotes commitment to include ESG factors in investment ownership and decision making. See https://www.unpri.org/about-us/about-the-pri.
- Task Force on Climate-related Financial Disclosures (TCFD) was established by the Financial Stability Board at the behest of G20 Financial Ministers and Central Bank Governors. In July 2021, the G20 called for global implementation of the task force’s framework, endorsed by 2,600 organizations worldwide and mentioned by current SEC Chair Gary Gensler in discussions of future mandatory environment-/climate-related reporting by public companies.6 See https://www.fsb-tcfd.org/about
- Value Reporting Foundation is global non-profit formed by the merger of the IIRC and SASB. It oversees and offers both the IIRC tools described above and the SASB Standards. See https://www.valuereportingfoundation.org/about
The organizations, standards, and frameworks listed above by no means constitute an all-inclusive list; and as noted, information provided is largely self-reported, voluntary, and not consistent from one framework to another. The bottom line: Although investors and consumers are clamoring for consistent information, we will all need to stay tuned for further developments.
- Acting Chair Allison Herren Lee, U.S. Securities and Exchange Commission, “A Climate for Change: Meeting Investor Demand for Climate and ESG Information at the SEC,” Speech Delivered March 15, 2021. Accessed at https://www.sec.gov/news/speech/lee-climate-change
- Ben Ashwell, “More than Half of S&P Global 1200 Using SASB Framework,” IR Magazine, September 23, 2021. Accessed at https://www.irmagazine.com/reporting/more-half-sp-global-1200-using-sasb-framework
- “Global Sustainability and Integrated Reporting Organizations Launch Prototype Climate-Related Financial Disclosure Standard,” Joint Press Release by CDP, CDSB, GRI, IIRC, and SASB, 18 December 2020. Accessed at https://www.cdsb.net/news/corporate-reporting/1139/global-sustainability-and-integrated-reporting-organisations-launch
- Aaron Nicodemus, “TCFD Recommendations More than Building Block for SEC Climate Disclosure Rules?” Compliance Week, December 16, 2021. Accessed at https://www.complianceweek.com/risk-management/tcfd-recommendations-more-than-building-block-for-sec-climate-disclosure-rules/31175.article