Prepare for 2024 – the New Era of Sustainability Reporting

 

Bracing for the annual sustainability report is always a formidable endeavour. However, the year 2023 marks a watershed moment, propelling companies into an intensified landscape of accountability. This pivotal year demands a thorough re-evaluation of sustainability reporting practices as we transition into what industry experts are terming ‘ESG 2.0’ — a new epoch characterised by strengthened regulatory frameworks.

Over the past decade, the regulatory environment has been transformed by the introduction of 1,255 new provisions since 2011 — a substantial increase from the 493 regulations recorded in the previous decade. While historically such regulations have been voluntary, largely adopted by pioneering enterprises or those of significant scale, we are now witnessing a paradigm shift.

75% of companies are unprepared

The investment in novel operational processes, strategic planning, and potentially new infrastructures for reporting is substantial. While procrastination may seem alluring, given that the inaugural deadlines for many directives are not imminent — and do not apply to all businesses — such a stance could be short-sighted. Notably, 75% of companies are currently unprepared for the emerging ESG data prerequisites. Nonetheless, the global trend is unmistakably towards obligatory reporting mandates, impacting every corporation, irrespective of size.

Deferring action could prove detrimental and financially onerous. The construction of a sustainability management framework that aligns with relevant legislation and directives is an extensive commitment, necessitating considerable time investment.

Forward looking companies

Leading companies are proactively adapting to these novel conditions within the current year, thereby conferring upon themselves a strategic advantage for future compliance. Hence, the landscape has altered — the implications are more profound. Standardised ESG reporting has transcended its previous domain of large-scale corporations and trailblazers; it is evolving into a universal standard. This year’s reporting cycle should be envisaged as a preliminary exercise for the impending regulatory environment. By conducting this year’s sustainability reporting with the diligence as if it were already under the purview of these new mandates, businesses will position themselves favourably for the forthcoming era of sustainability transparency.

What’s new for 2024?

In the swiftly evolving landscape of corporate responsibility, the recent surge in Environmental, Social, and Governance (ESG) regulations has substantially elevated the importance and complexity of sustainability reporting. The push for more rigorous reporting standards has dramatically heightened the stakes for corporate compliance.

The year 2023 marked a significant milestone with the International Sustainability Standards Board (ISSB) unveiling its inaugural global sustainability standard. Concurrently, the European Union introduced the European Sustainability Reporting Standards (ESRS), underscoring a worldwide trend towards harmonized sustainability disclosures.

Amidst this shift, there is an escalating call for businesses to provide transparency not only within their immediate operations but throughout their entire value chain. This includes comprehensive disclosures on Scope 3 emissions, which encompass all indirect emissions that occur in a company’s value chain, and detailed reporting on supplier labour practices. Such requirements are encapsulated in the EU’s Corporate Sustainability Due Diligence Directive, reflecting a broader expectation for companies to extend their reporting scope far beyond their direct activities.

Understanding the Landscape of Sustainability Regulations and Standards

The landscape of sustainability and corporate responsibility is rapidly evolving, with numerous directives and standards being established to guide businesses in their efforts towards more ethical and sustainable operations. As companies navigate this complex terrain, understanding and adhering to these regulations is not only about compliance but also about demonstrating leadership in corporate sustainability.

Corporate Sustainability Due Diligence Directive (CSDDD)

The CSDDD is a pivotal legal framework that mandates due diligence for EU and non-EU companies, ensuring they take accountability for human rights and environmental impacts across their value chains. It is projected to come into force in 2025, with the inaugural reporting deadline set for 2026. It is anticipated that over 17,000 enterprises, including approximately 13,000 within the EU and 4,000 beyond, will be encompassed by this directive.

EU Taxonomy

Implemented in 2020, the EU Taxonomy is a foundational classification system designed to help organisations categorise their economic activities as environmentally sustainable or otherwise. While it directly applies to large public-interest entities, listed small and medium-sized enterprises (SMEs), and financial market participants (FMPs), it’s a versatile tool that can be leveraged by businesses of all sizes to demonstrate their sustainability commitments to stakeholders.

Corporate Sustainability Reporting Directive (CSRD)

The CSRD aims to foster transparent and uniform Environmental, Social, and Governance (ESG) reporting. Starting from the 2024 fiscal year, with the first reports due in 2025, this directive is expected to encompass around 59,000 entities – 49,000 within the EU and an additional 10,000 located internationally.

Sustainable Financial Disclosure Regulation (SFDR)

Adopted in 2021, the SFDR is instrumental in promoting transparency in sustainability practices amongst investors and financial entities. It obligates asset managers and FMPs with over 500 staff members to disclose their sustainability strategies and product information, establishing mandatory disclosure requirements.

International Sustainability Standards Board (ISSB)

Formed by the International Financial Reporting Standards (IFRS) Foundation, the ISSB strives to create uniform standards for sustainability disclosures on a global scale. With its first two standards released in 2023, countries such as the UK, Australia, and Japan have begun implementing these guidelines, signifying a move towards global reporting consistency.

US Securities and Exchange Commission (SEC)

In 2022, the SEC introduced proposed rules for new climate disclosures, mandating all SEC-registered companies, including those outside the US, to disclose climate-related data, encompassing scope 1, 2, and 3 greenhouse gas emissions. These disclosure mandates are slated to take effect starting in 2024, marking a significant shift towards transparency in climate impact reporting.

10 tips to improve your sustainability reporting in 2024

As we enter 2024, the corporate world stands at a crossroads where the integration of robust sustainability reporting is no longer a choice but a necessity. Companies are facing mounting pressure from investors, shareholders, and consumers alike to disclose transparent, accurate, and comprehensive sustainability data. Failing to enhance sustainability reporting could lead to a significant erosion of investor confidence, potential divestment, and heightened scrutiny from consumer activists.

Moreover, directors and officers may find themselves increasingly vulnerable to litigation if they neglect the environmental, social, and governance (ESG) factors that materially affect their company’s performance and risk profile. In this climate, it is crucial for companies to not only meet but exceed current sustainability reporting standards. The following ten tips offer strategic guidance to bolster your reporting processes, ensuring they are both resilient and responsive to the dynamic expectations of a more environmentally and socially conscious market.

1. Utilise Learnings from Previous Reports

Reflect on your previous sustainability reports, assessing the strong points, the areas that need enhancement, and any gaps in your approach. Draw upon this analysis to refine your current reporting tactics and methodologies. By doing so, you can enhance the efficacy of your reporting process for the present year, ensuring that it is more aligned with organisational goals and stakeholder expectations.

2. Proactively Align with Standards

It is beneficial to voluntarily align your reporting with recognised sustainability frameworks and standards, even before they become a legal requirement. By being proactive and familiarising yourself with forthcoming regulations, your organisation can anticipate changes and adapt promptly. This not only demonstrates foresight but also ensures that your reporting addresses the aspects stakeholders are becoming increasingly interested in.

3. Clarify Reporting Intentions and Goals

Clearly articulate the purpose behind your sustainability reporting and pinpoint the specific objectives you aim to fulfil. Establishing clear goals will provide direction to your reporting efforts, allowing you to channel your resources and focus on the most critical elements that reflect your company’s sustainability mission.

4. Create Compelling Sustainability Narratives

Integrate both quantitative data and qualitative insights with real-world examples to illustrate the impact of your sustainability endeavours. By weaving in narratives that showcase actual outcomes, your reporting will not only be more engaging but will also provide a comprehensive view of your initiatives’ effectiveness. These stories can bridge the gap between statistics and the real-world implications of your sustainability practices.

5. Foster Independent Data Access and Strategies

Devise strategies that enable relevant personnel and departments to independently retrieve and contribute data. This decentralised approach to data collection can lead to enhanced accuracy and timeliness in your reporting. Establish clear roles, offer necessary training, and maintain open communication channels to support this process. This coordinated approach ensures everyone understands their responsibilities and how they contribute to the organisation’s sustainability narrative.

6. Engage Stakeholder Feedback

Actively involve various stakeholders in the reporting process, including employees, customers, suppliers, and community representatives. Gathering their perspectives and concerns can significantly enrich your report’s relevance and credibility. This engagement can be through surveys, interviews, or focus groups. Incorporating stakeholder feedback ensures that the report reflects the interests of those it impacts, leading to a more holistic and meaningful sustainability narrative.

7. Leverage Technology for Data Management

Employ advanced data management tools and software to streamline the collection, analysis, and presentation of sustainability data. This could include using AI for data analysis or blockchain for ensuring data integrity. By automating and digitising processes, you can enhance the accuracy and efficiency of your reporting, while also making it easier to track progress over time.

8. Incorporate Forward-looking Statements

Beyond documenting past and present sustainability practices, include future-oriented goals and strategies in your report. This involves setting clear, measurable targets for future sustainability efforts and outlining the steps your organisation plans to take to achieve these goals. Such forward-looking statements can demonstrate your organisation’s commitment to continuous improvement in sustainability.

9. Ensure Transparency and Accountability

Strive for the highest levels of transparency in your reporting. Clearly disclose your methodologies, data sources, and any challenges faced. This openness builds trust with your audience and holds your organisation accountable for its sustainability claims. Addressing shortcomings or areas for improvement can also be seen as a sign of maturity and commitment to genuine sustainability.

10. Regularly Update and Communicate Progress

Don’t limit your sustainability reporting to an annual event. Regularly update stakeholders on your progress throughout the year through various communication channels like social media, newsletters, or dedicated sections on your website. This ongoing communication keeps sustainability at the forefront of your organisation’s agenda and maintains stakeholder engagement and interest.

A 10 point guide to Writing a Quality ESG / Sustainability Report

In the realm of corporate sustainability, the Annual Sustainability or Environmental, Social, and Governance (ESG) report stands as the ledger of a company’s commitment to responsible business practices. It is a document watched closely by investors, regulators, and the discerning public eye. Yet, despite its importance, many corporations—small and large alike—fall prey to common pitfalls that undermine the very purpose of these reports.

1. The Veil of Opaque Language

One of the most significant errors companies make is the use of jargon-laden, complex language that obscures meaning. In an effort to appear knowledgeable or to cushion the impact of less favorable data, companies inadvertently create a barrier to understanding. The use of technical terms, acronyms, and corporate-speak may sound impressive but can make the content inaccessible to a broader audience. Sustainability reports should be transparent and easily comprehensible to stakeholders of all backgrounds, not just industry experts.

The consequence of opaque language is twofold. First, it alienates the lay reader, who may feel sustainability is beyond their grasp. Second, it creates suspicion among more savvy stakeholders, who may wonder what the convoluted language is masking. Clarity and simplicity are not just stylistic choices; they are central to the report’s integrity.

2. Hiding Behind the Real Answers

Another critical mistake is the avoidance of direct answers to pressing questions. Companies often provide general statements on their commitment to sustainability without offering concrete evidence or specifics. For example, a company might speak at length about its ‘commitment to reducing emissions’ without stating clear, quantifiable targets or timelines.

This lack of specificity can be particularly frustrating for stakeholders looking to understand a company’s actual performance and commitment. It can be perceived as an attempt to hide the full picture, leaving stakeholders to question the depth of the company’s commitment to sustainability.

3. The Illusion of Transparency

Transparency is the cornerstone of trust. However, the illusion of transparency is a common misstep. This occurs when a company releases a vast amount of data and information, but it is presented in a way that is difficult to decipher or compare. Information may be scattered throughout the report without a clear narrative or may lack the context necessary to understand its relevance or significance.

The result is a report that, while comprehensive in appearance, provides little insight. Stakeholders might feel overwhelmed by data but underwhelmed by the lack of clear, actionable information. This approach can also serve as a smokescreen to hide less favourable aspects of a company’s sustainability practices.

4. The Sin of Omission

Not all mistakes in sustainability reporting are about what is said—some are about what is not said. The sin of omission occurs when companies choose not to include full ESG disclosures, particularly around areas where they have not made progress or have experienced setbacks.

While it might be tempting to present only the most flattering picture, this selective reporting damages credibility. Stakeholders are well aware that sustainability is a journey fraught with challenges. They expect to see these challenges acknowledged and addressed. Omitting difficult aspects can raise doubts about the authenticity of the entire report.

5. The Static Report

Sustainability is inherently dynamic, with goals and benchmarks that evolve as circumstances change and new information comes to light. However, many companies produce static reports that fail to reflect this dynamism. They recycle content from year to year without significant updates, failing to account for new developments, changes in strategy, or progress towards goals.

A static report may give the impression that sustainability is a box-ticking exercise rather than a genuine, ongoing effort. It can also suggest a lack of engagement with the broader sustainability conversation, which is always moving forward.

6. Underestimating the Power of Narrative

Humans are hardwired to respond to stories, yet many companies underestimate the power of narrative in their sustainability reports. Instead of dryly presenting data, companies have the opportunity to tell a compelling story about their journey toward sustainability.

Narratives can help contextualize data, making it more relatable and memorable. They can also illustrate the company’s sustainability ethos in action, showing not just what the company is doing, but why it matters. A report without a narrative is a missed opportunity to connect with stakeholders on a more profound level.

7. Overlooking Materiality

Materiality is the principle that companies should focus on the issues that are most significant to their business and stakeholders. However, many reports seem to include everything but the kitchen sink, resulting in a document that is unfocused and difficult to navigate.

By attempting to cover every possible angle of sustainability, companies can dilute the impact of the truly material issues. Stakeholders are left to sift through a mountain of information to find the nuggets that are truly relevant to their interests.

8. The Trap of Self-Congratulation

While it is natural for companies to want to present themselves in a positive light, overemphasis on achievements can come across as self-congratulatory and may overshadow areas in need of improvement. Balance is key.

A report that reads like a list of triumphs is not only unrealistic but also unhelpful. Stakeholders are interested in a balanced account, one that acknowledges successes while also addressing areas for growth.

9. Ignoring the Global Context

ESG issues are global, yet many reports fail to place the company’s efforts within this broader context. A report that does not consider the global implications of local actions—or the local implications of global trends—may come across as myopic.

Companies operate in a web of interconnected systems and their sustainability efforts should be reported as such. The failure to do so can make even the most robust sustainability efforts seem insular and disconnected.

10. The Compliance Mindset

Finally, many companies approach sustainability reporting primarily as a compliance exercise, something to be done because it is required, rather than as an opportunity to engage and inform. This compliance mindset can lead to reports that are formulaic and uninspired.

Sustainability reporting should be seen as a chance to communicate with stakeholders about the company’s values, strategies, and goals in a way that is meaningful and compelling. Approaching the report as a checkbox exercise squanders this opportunity.

In conclusion, the process of crafting an Annual Sustainability or ESG report is fraught with potential missteps. By avoiding opaque language, striving for transparency, and presenting information in a clear, compelling narrative, companies can produce reports that truly reflect their commitment to sustainability. As stakeholders increasingly hold companies to account, the quality of these reports will become ever more critical. Those that succeed in avoiding these common mistakes will stand out for their clarity, sincerity, and commitment to a sustainable future.

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Humperdinck Jackman
Leads the daily operations at ESG PRO, he specialises in matters of corporate governance. Humperdinck hails from Bermuda, has twice sailed the Atlantic solo, and recently devoted a few years to fighting poachers in Kenya. Writing about business matters, he’s a published author, and his articles have been published in The Times, The Telegraph and various business journals.

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