This week I want to share and comment on the best practices for sustainability reporting according to NYSE.
NYSE proposes an 8 steps process for sustainability reporting (and the key ideas we identify under each step) are:
- Identifying the right approach for the company: “Before a company can begin to think about reporting on its ESG performance, it needs to determine which ESG issues are relevant to it and how these issues fit into its overall business strategy…Companies should be able to answer the question: how do the specific ESG issues that the company has chosen to focus on contribute to its short-term financial performance and/or long-term value creation?”
- Identifying stakeholders and evaluating engagement: “Once your stakeholders have been identified, the next step is to ensure the company has mechanisms in place for stakeholder engagement. One primary purpose of stakeholder engagement is to identify how stakeholders think about the company and its conduct as it relates to their interests. In addition, this engagement can help the company identify key ESG issues that are likely to impact your company’s performance directly or indirectly and to appropriately manage stakeholder expectations and concerns.”
- Assessing materiality: “In essence, materiality is a lens or filter that allows your company to determine the ESG issues on which your stakeholders focus.”
- Establishing governance: “Strong governance of ESG issues and ESG reporting is key to the efficacy of ESG programs and credibility of ESG reporting. More importantly, good governance of ESG requires that ESG statements have clearly-defined owners to provide accountability and allocate clear responsibility for various aspects of the strategy.”
- Integrating ESG into business strategy: “Below the board level, responsibility for design, implementation and monitoring of the company’s ESG strategy should be clearly allocated by senior management. Depending on the nature of the strategy and the identified ESG focus areas, responsibility may be spread across various divisions in the company.”
- Telling your story: “Companies that provide this disclosure are likely to be more convincing than those that produce a long list of ESG metrics that appear unconnected to the company and how it operates. In adopting a more focused approach, your company can demonstrate that it has a strong handle on the ESG issues and is committed to managing them effectively.”
- Reporting frameworks and standards: “Many companies choose to align their sustainability reporting with one or more ESG frameworks. The sheer number of ESG frameworks and standards can make ESG disclosure seem overwhelming. The best way for companies to navigate this landscape is to figure out what would yield the most meaningful and useful disclosure for the company and its key stakeholders.”
- ESG research and ratings: “…several ratings are administered by, or connected to, companies that construct indices for investment purposes. Therefore, consider which ESG indices are of highest interest to your company when determining which ratings to focus on.”
As a conclusion NYSE says: “Reporting should be an output, not an end in itself. It should reflect what your company is doing to manage your ESG risks and opportunities.”
Our view: we wholeheartedly agree on the view that materiality (defined by really engaging your stakeholders) should provide the roadmap for any company that wants to start sharing ESG data and strategies. We would stress that to really integrate these concepts into the business (step 5), it is fundamental to have clearly established key performance indicators. Otherwise, it all becomes too subjective. We would also note that when defining the narrative, it is undoubtedly important to use standards, but it is also important to use far reaching language to impact non-institutional stakeholders. Finally, ESG ratings are not a necessity for all companies. For us, it is very important that companies don’t focus on ratings as much, since that sometimes distorts purpose. Ratings should be a result of the effort, and not the guiding principle (and companies should understand methodologies to really comprehend why some ratings may not favor them, but this does not necessarily mean their strategy is wrong). In some stages however, ratings will be very useful for some companies to reach certain audiences.
I hope you found this interesting. As usual, if there is anything we can help you with, please reach out.
CEO, Miranda ESG
Contacts at Miranda Partners