#2 Where do you start with ESG reporting?

Introduction

Where to start with ESG reporting? There is no question that the ESG landscape is becoming more and more complex. In our previous article we touched upon the ESG framework and its pillars, however we didn’t really consider the complete landscape of global goals, regulations and stakeholder expectations that ESG reporting is a part of and is affected by.

Consider the broader landscape

Your ESG reporting efforts are a part of the broader landscape of sustainability issues. The goal of ESG reporting is to demonstrate how your company aligns with the various aspects of global sustainability issues. One way of conceiving of this landscape is layers stacked on top of each other. The top-level of sustainability issues are UN Sustainable Development Goals (SDGs) and the Paris Climate Agreement. These overarching goals in turn inform EU and local sustainability regulation, including reporting, which would be the layer beneath the previous one. It is important to note that the CSRD¹ is already under development and will be the EU's ESG reporting framework and is likely to be effective from 2023. Then beneath the layer of regulation we can consider the broad stakeholder expectations. In other words, what do investors and stakeholders expect of your company in terms of sustainability? An ESG report should ideally show how your company is aligned with their concerns as well. Finally, we can conceive of the various reporting frameworks as the bottom layer of the ESG reporting landscape. Of course, the layers described are not a strict hierarchy and each influence each other. It may well be argued that it is stakeholder expectations that drove acceptance of the Paris Agreement or that ESG reporting frameworks have shaped legislation because large parts of them are currently being adopted as part of the CSRD.

Think through all of the concerns that will be fed into your chosen framework

There are a myriad of ESG issues to report on and it is difficult to decide how to prioritise what to report on. The breadth and depth of ESG issues are significant. Narrowing down this breadth and depth to a manageable level is the purpose of selecting a framework and then conducting a materiality assessment in accordance with that framework. Remember from our previous article that there are 2 types of materiality: financial materiality and double materiality. Investor focused frameworks like SASB² use financial materiality (sustainability risks that affect company value) whereas frameworks like GRI³ that target a more broad audience tend to favour double materiality (where in addition to the financially materially issues, socially material issues are also considered). The economic sector level filtering of what issues to report on will be given either directly by your framework (SASB and soon in GRI as well) or by the materiality assessment. Whichever framework you choose, remember that there is no theoretical limit to the number of frameworks you can use and as your reporting process improves additional frameworks can be added to increase the breadth of your ESG reporting. The depth of your ESG reporting will depend on having a robust reporting process and good data quality on the one hand and having a comprehensive sustainability strategy (with targets and policies) on the other. Sustainability strategies are needed for depth because it is these strategies that set the context in which you move beyond simply reporting on the data and begin to report how you manage sustainability outcomes. We will explore the question of sustainability strategies at later date.

Check what your peers are doing

Check which frameworks your peers and industry leaders use for reporting but make your final decision based on your own reporting needs. A study by the Alliance for Corporate Transparency in 2020⁴ showed that based on their NFR⁵ disclosures most (70%) Central and Southern-Eastern European companies reference GRI as the framework they use to structure their report. The second most popular framework is reporting on the SDGs (34%). Strictly speaking, the SDGs are not a reporting framework in the same way that GRI or SASB is but they are referenced as such and do fulfil a similar function. Overall, when choosing your first framework, choose one that covers all ESG issues and helps you structure reporting according to your target audience’s needs.

Consider the target audience of your report

Your reporting requirements are in large part set by your target audience’s expectations, by the stakeholders you are looking to communicate with. As alluded to previously there are two typical cases for this. Focused reports that target investors and more general reports that aim to address the broader stakeholder groups. If this is your first report, unless you have a specific use case for an investor specific report, it is recommended that you choose a more flexible framework that is aimed at addressing a broader audience. Focused frameworks are tailored to the needs of particular audiences and require more strict adherence in order to be meaningful. Flexible frameworks give you leeway in choosing how and how many ESG issues you report on. Also, note that focused frameworks are data-driven and their successful completion hinges on good data collection processes already being in place.

Consider choosing GRI as your first reporting framework

It is a safe, future proof choice that can serve as a basis for building out your ESG reporting over time. When starting out your company will face a number of data collection challenges that you will have to overcome gradually. For this reason, it is most advisable to start with the GRI framework. As it offers the most flexibility it is common practice for companies just starting their ESG journey to start reporting with reference to GRI before developing their reports to where they are able to report in accordance with the standards.

GRI is also modular, so you don’t have to worry about revisions to the entire reporting framework. If the standards board decides to update a single module in the reporting framework then your company just has to update their approach to that one module.

GRI incorporates the following international standards:

• The UN guiding principles on businesses and human rights
• ILO conventions
• OECD Guidelines for Multination Enterprises

It is also compatible with the other standards:

• Sustainable Development Goals (SDGs)*
• Task Force on Climate-Related Financial Disclosures (TCFD)
• CDP questionnaires*
•  International Integrated Reporting Framework (IIRC)
• SASB industry standards*
• B-lab business impact assessment *

*linkage document is available on the GRI website.

Not to mention GRI is also likely to be compatible with the upcoming CSRD because:

• GRI considers double materiality which will be compulsory under CSRD
• It covers all three ESG pillars
• And is in line with human rights issues

Keep the end goal in sight

The goal is to demonstrate that your company is a good steward of all forms of capital. Not just financial but environmental and social as well. Don’t treat ESG reporting as just a compliance exercise, your task is not just about reporting on ESG issues. By collecting data, you are also taking the first steps towards managing ESG issues in the same manner as you would manage financial issues.