The disclosure of nonfinancial information took on an increased importance when the European Union issued Directive 2014/95/EU (http://bit.ly/305nwzg) concerning reporting of sustainability information by large enterprises; affected companies began applying the reporting requirements in 2018. Most U.S. companies are not affected by EU directives, but some larger U.S. organizations operating in EU member states may fall under the nonfinancial disclosure standards. In addition, many large U.S. companies have been issuing some version of separate environmental, social, and governance reports, although standards are lacking.
The Alliance for Corporate Transparency (http://www.allianceforcorporatetransparency.org/) analyzed 105 EU companies in 2018 regarding their sustainability disclosures following the implementation of the EU directive. The Alliance found that while most (but not all) of the companies did present some nonfinancial information, more than half did not provide key principles information in a clear structure. Organizations that fall under the EU nonfinancial reporting directive, or would otherwise like to follow the disclosure recommendations, can benefit from many of the available resources below.
European Commission: Nonfinancial Reporting
The European Commission (EC) proposes and monitors European Union laws and policies, as well as manages the EU’s budget. Its website (https://ec.europa.eu/info/index_en) provides access to information about EC and EU activities, including economic, statistical, and company reporting and audit requirements. The Nonfinancial Reporting webpage presents a helpful overview, including companies that must comply, information to be disclosed, and how the environmental, social, and governance information should be reported (http://bit.ly/2JRC1lx).
The EC published non-mandatory guidelines in 2017 to increase consistency and comparability in nonfinancial reporting (http://bit.ly/2FHJuQU). The key principles covered in the guidance include the materiality of the information; the fair, balanced, and understandable characteristics of the information; and the comprehensive-but-concise nature of the disclosures. The content of the nonfinancial information should include a brief description of the organization’s business model, a description of policies and due diligence, and a discussion of principal risks and their management. Companies may rely on any broadly recognized framework for reporting nonfinancial disclosures; the 2017 guidance provides many examples and explanations in an easy-to-read format and is a must-see for anyone attempting to follow nonfinancial reporting standards.
Recently, the EC published “Guidelines on Reporting Climate-Related Information,” available as a 44-page guidebook (http://bit.ly/2Xi8U2w) and two-page summary (http://bit.ly/2KQ5TQk). The discussion follows the same points made in the more general nonfinancial reporting guidelines, but expands them to specifically address climate-related issues; for example, materiality is extended from simply financial materiality to environmental and social materiality. Appendix II provides a chart that maps climate disclosures onto the nonfinancial reporting elements, which might be a good place to begin reviewing this material. The guidebook contains many sample disclosures regarding the business model, policies, outcomes, principal risks, and key performance indicators.
The International Organization of Securities Commissions (https://www.iosco.org) serves as the global standards setter for the securities segment and regulates more than 95% of the securities markets around the world. The IOSCO board priorities for 2019 include cyber-security, financial benchmarks, financial reporting, audit standards and quality, and sustainable finance (http://bit.ly/2KRl63D). In January 2019, IOSCO issued Statement on Disclosure of ESG Matters by Issuers, addressing investor and issuer perspectives, the role of securities regulation, and considerations for issuers, as well as IOSCO’s role in establishing a sustainable finance network of securities regulators (http://bit.ly/2XFX7tX).
One of IOSCO’s more important 2019 sustainability-related reports, Sustainable Finance in Emerging Markets and the Role of Securities Regulators (June 2019, http://bit.ly/31YsW0F), is the result of a two-year study focusing on environmental, social, and governance risks and the need for transparency and disclosures on these issues. Chapter 3 includes an overview of sustainable financing regulation initiatives in Asia (including China and India), the Americas (outside of the United States and Canada), eastern and southern Europe, and Africa and the Middle East. Chapter 4 addresses market trends, and Chapter 5 is a discussion of IOSCO’s 10 recommendations. An appendix provides a nicely condensed summary of the recommendations.
ICAEW Sustainability Portal
The Institute of Chartered Accountants in England and Wales’s (ICAEW) sustainability hub presents a large selection of resources under 12 different topics (https://www.icaew.com/technical/sustainability). The topical content comprises a variety of articles, videos, external links, and other materials. The Tools to Get Started main page (http://bit.ly/2Xi6Xmx) offers subtopics like Just Good Business, Role of Accountants, Mandatory Carbon Reporting, Sustainability Assurance, and Environment and Sustainability.
Just Good Business has some short videos, case studies, and ICAEW guidebooks. “Building Sustainability” provides helpful points to follow in developing performance measurements (http://bit.ly/2Lv4Wwo). “Resources” has many materials, such as “Environmental Issues and Annual Financial Reporting,” an 89-page document from September 2009 that covers EU and UK reporting requirements, recommendations for reporting companies and users, and guidance for auditors. It includes several helpful appendices, such as a table of environmental issues and a large collection of standards comparisons, as well as example questions and procedures for auditors (http://bit.ly/2J1obfa).
The Role of Accountants webpage (http://bit.ly/2KRLVVq) presents the ICAEW’s publication, “Sustainability: The Role of Accountants,” last reprinted in May 2013. This is a lengthy document that illustrates UK, EU, and global initiatives, with a particular emphasis on opportunities for accountants. The chapters cover corporate policies, supply chain pressure, stakeholder engagement, voluntary codes, benchmarking, reporting, assurance, and several other topics.
The Sustainability Assurance web-page (http://bit.ly/2XNGEEs) connects to some of the ICAEW’s assurance guidance. “Sustainability Assurance: Your Choice” (May 2010) is a 16-page PDF that highlights key issues, such as who will use the sustainability report and why they would desire assurance on the information (http://bit.ly/31VNcQm).
ICAEW’s Environment and Sustainability Library is a portal to resources grouped under the topics of green business, natural capital, organizations, socially responsible investment, the Stern Review on the Economics of Climate Change, and environmental, social, and sustainability reporting (http://bit.ly/2XhwU5L). The latter provides access to online resources, articles, and other publications (http://bit.ly/2KSLJFl). Links to several organizations’ websites are listed, such as Accounting for Sustainability, the Global Reporting Initiative, and the Sustainability Accounting Standards Board, among others. Some library resources are restricted to ICAEW members, but public materials include several external reports, such as KPMG’s “Carrots & Sticks: Global Trends in Sustainability Reporting Regulation and Policy” from May 2016, which reviews trends in sustainability reporting standards across 64 countries (http://bit.ly/2J3yn75).
ICAS Sample Sustainability Reports
The Institute of Chartered Accounts of Scotland (ICAS) sponsors a sustainability panel to increase awareness of environmental and other sustainability measures as important business issues and identify and encourage best practices for reporting. ICAS has created a downloadable Corporate Social Responsibility Template Report (http://bit.ly/2Ytr0ek). The eight-page sample report provides an outline of information to be included, from an introduction to the company to management structure and specific areas such as health and safety performance. ICAS’s website also has an invaluable directory of 40 actual reports, organized by industry, including many from U.S.-based companies, such as Coca Cola, PepsiCo, McDonald’s, General Motors, Johnson & Johnson, and United Parcel Service (http://bit.ly/2LrKqMS).
More Sustainability Resources:
Corporate Register: http://www.corporateregister.com/
Global Reporting Initiative: EU NFR Directive: https://www.globalreporting.org/information/policy/Pages/EUpolicy.aspx
ICAEW: Sustainability-Related Organizations List: http://bit.ly/2XftFXx
IFAC Sustainability Gateway: http://www.ifac.org/global-knowledge-gateway/sustainability