Disclosure

Key Takeaways 

  • Material assessments lay the foundation of successful reporting. 
  • Care should be taken when choosing the right reporting framework depending on the purpose and audience. 
  • Investors prefer transparency.  

After targets have been determined by a materiality assessment and efforts are underway, the next step is measuring, communicating and publishing an organization’s sustainability performance and impacts, both positive and negative. This can be done through a document that can be readily analyzed and judged by internal and external stakeholders, particularly investors. The document is shaped by following as set of protocols, known variously as reporting standards, frameworks or guidelines, as well as mandatory regulations.   

Sustainability reporting, also referred to as non-financial, triple-bottom-line or CSR reporting – is an opportunity for a business to consider its environmental and social impacts, identify opportunities, improve decision-making, encourage transparency, increase investor value and facilitate the transition toward being a sustainable company.  

Unlike financial reporting, it’s not a collection of data per se. Instead, it takes often intangible aspects of business operations and makes them tangible.  

As mentioned in the Materiality section, the activity of assessment and making a report helps an organization define and configure its longer-term sustainability strategy. 

Initial Challenges  

Reporting may seem like a daunting task, especially when time and resources are limited. In reality, even at larger public companies that undertake substantial ESG efforts, the human resources allocation for ESG management can be modest, with tasks such as data gathering and compliance shared around the organization.  

Resources aside, according to Elaine Cohen, the founder and manager of Beyond Business, an environmental CSR consultancy, sustainability reporting is straightforward and presents no more of a challenge than measuring and reporting other aspects of a business. 

“There are clear metrics, and clear processes. You just have to put them in place. Some are things you might have never measured before so you have to develop a process, but that’s the same for pretty much anything. The biggest challenge is the decision to do it and to disclose,” Cohen told Lubes’n’Greases. 

There is as yet no universal standard akin to the International Accounting Standards Board’s International Financial Reporting Standards and Generally Accepted Accounting Principles, for example. But there are moves toward such. 

“The need for a universal system has arisen really in the past few years as investors have realized that what used to be called non-financial issues can carry significant financial impact,” Cohen said. “So there developed a movement to create investor-useful information, as the claim was that sustainability reporting was not robust enough.” 

The GRI standard is complementary with SASB, with the former looking at a company’s impact and the latter looking at the world’s impacts on the company, said GRI’s CEO Tim Mohin in an interview with Greenbiz in 2018. 

Frameworks

The organization of non-financial data into an easily digestible format can be done using a reporting framework. The number of frameworks, guidelines and standards has mushroomed over the past 10 years. According to a 2020 report from Carrots & Sticks, a report launched by the UN Environment Program and KPMG International that that assesses sustainability reporting instruments, there are more than 600 voluntary and mandatory provisions in 87 countries. 

Regulations on sustainability reporting have rapidly evolved, recognizing the central role of transparency in advancing responsible business conduct. The field of sustainability reporting has also expanded not only in quantity but also in the type of information required,” Reuten said. 

GRI is part of what is sometimes known as the “big five” frameworks, which also includes the Sustainability Accounting Standards Board, the Carbon Disclosure Project (now just CDP), the Taskforce on Climate-related Financial Disclosure and the Workplace Disclosures Initiative. 

The array of frameworks is wide, but making a selection can be simplified by first recognizing the audience for the non-financial data that a company wants to communicate with. 

“This is the key difference between frameworks – the audience. Is the audience policymakers or employers or customers or NGOs?” Ekaterina Hardin, research analyst and sector lead for extractives and mineral process at SASB, told Lubes’n’Greases.   

“You represent your industry, [so] you might want to reach certain audiences and talk about certain issues. A different industry or a different-sized company might have different goals. So, it’s really up to the company to develop a system out of the tools that are on the market … to identify the best possible strategy for them,” Hardin said. 

As mentioned in the previous section on materiality, SASB looks at the worlds impact on the company, whereas GRI looks at a company’s impact on the world outside. 

“SASB standards are complementary to any other framework that a company can choose to report to. And the key complement that’s SASB framework provides is it’s industry specific,” said Hardin. 

Different stakeholders have different needs. This may go some way to determining the choice. Regulators may require information about emissions compliance, so CDP would be relevant; investors want to see information that will inform their decision making, and so SASB would be appropriate; and nearby communities may want a big picture report, so GRI may be best suited. 

Limitations  

A survey of investment managers carried out by sustainability website Greenbiz revealed a gap between the realities of reporting and what they require to make investment decisions. Their chief concerns were for incomplete, poor or immaterial data and inconsistent metrics and evaluation. 

These complaints are supported by Corporate Knights, a Canadian media company that promotes responsible capitalism, in a report on disclosure. While it recognizes significant progress has been made in the number of companies that are disclosing their emissions and sustainability performance, this progress “is overshadowed by the wide gulf that exists between the concise, current, comparable and consistent sustainability information that investors demand and the paltry disclosure that companies offer.”  

“Consistent and comprehensive reporting, covering the full range of organizational impacts, is important because it means that all data users – such as investors, policymakers and others – can draw meaningful comparisons of a company’s sustainability performance,” Thijs Reuten, head of policy at Global Reporting Initiative, told Lubes’n’Greases. “That’s why having a global common language for disclosure is needed.”