Auditors may be asked to complete assurance engagements on non-financial information, and this is increasingly likely to include the review of management reports on social, environmental and sustainability information. When management provides this type of information it is known as Extended External Reporting (EER), which is a requirement for listed and larger private companies in some jurisdictions. In addition, many companies wish to provide additional information on the environmental impact of their operations on the environment.
There are challenges in undertaking such engagements, and although this can be a highly specialist area, there are still steps that the assurance provider can take to mitigate these issues.
This article considers the main reasons why companies produce these reports and the various methods of measurement used. Auditors may be asked to review the information as part of their review of the annual report, or as a separate assurance engagement.
This is the first of two articles which considers why sustainability information is published and a brief coverage of the measurement issues. An assurance professional is most likely to review sustainability information as part of the strategic report, which is covered briefly here. Increasingly though, assurance professionals are being tasked in reviewing specific sustainability reports, this is covered in the second article on the topic.
Why is there a need for companies to produce these reports?
- National reporting requirements: Some regions require specific sized companies (larger, listed entities usually) or those in specific industries to report on their environmental, social and governance information. Examples include:
- Corporate Sustainability Reporting Directive (CSRD) is legislation in the European Union (EU) requiring all large companies to publish reports on their social and environmental impact activities 1
- UK premium listed companies must report their compliance with the Task Force on Climate-Related Financial Disclosures (TCFD) recommendations for periods commencing 1 January 2021. This is already effective in New Zealand and Japan 2
- Stakeholder needs: Increasingly shareholders, especially larger investors like pension funds, are demanding more information of the impact of a company on the environment and society.
- Voluntary disclosure: Companies may seek to gain a competitive advantage by declaring their ‘green credentials’. Such voluntary disclosure may be subject to management bias as the reporting requirements are not specified under legislation.
Companies can choose to include this type of information within their annual report or to produce stand-alone reports on social, environmental and sustainability matters. In the last decade, Integrated Reporting <IR> has become common, which aims to provide a holistic view of the company’s financial and non-financial performance and its potential for long term value creation.
Measuring and reporting on environmental, social and sustainability information
The measurement of specialised information can be problematic, because sustainability or environmental indicators may be reported in different ways even within the same industry and several differing reporting standards may be used, rather than a single, global reporting basis.
In 2022, the International Sustainability Standards Board (ISSB) commenced a consultation on two proposed sustainability standards, one regarding general sustainability related disclosures and one regarding climate related disclosures. There are a variety of different Key Performance Indicators (KPIs) and metrics in use, and comparison between companies and industries is challenging for the following reasons:
- Rapid change in EER requirements and disclosure principles
- Diversity of subject matter
- Lack of single reporting basis for non financial information
- Additional risk of management bias due to the subjective nature of measurement in many cases and selection of the criteria being presented
Examples of performance measures
The United Nations (UN) adopted a series of sustainable development goals (SDG) in 2015 and there are over 200 KPIs as published by the OECD in 2021. Therefore, there is a wide range of KPIs (‘sustainability indicators’) and targets which may be adopted by businesses, and these can vary by region, by industry and by individual company.
Assurance providers are faced with understanding what is being reported upon and why (legislative or commercial reasons), as well how the information is being obtained, collated and presented.
The reporting of these benchmarks may be presented in different ways, for example, one company may produce a table of financial information to report on subject matter, whereas another may choose to report using non-financial or narrative disclosures. Comparison between companies, even within the same industry, is problematic due to the lack of consistency in selecting which measures to disclose, how the information is presented and how metrics are quantified.
Examples of reporting benchmarks include:
- Greenhouse gas emissions (GHG)
- Waste minimisation and management
- Finite resource consumption (oil, gas, coal, minerals, forestry)
- Supply chain sustainability
- Water and pollution
- Employee welfare and equality
Example of a water consumption disclosure within the sustainability reporting section of the Annual Report 2020 for MMC Corporation: 3