Assess record for 'Disclosure of Non-Financial Information by Companies'

Transcription

1 Page 1 of 6 Assess record for 'Disclosure of Non-Financial Information by Companies' Meta Informations Creation date Last update date User name null Case Number Invitation Ref. Status Background Information For the purpose of analysis of this consultation you want to be identified as -single choice reply- N Other Other, please specify -open reply- NGO Name(s) (of respondent and of your organisation / company) -open reply- Cassandra Chessum, Head of Government Relations, Carbon Disclosure Project (CDP) Lois Guthrie, Executive Director, Carbon Disclosure Standards Board (CDSB) Country where your organisation / EU-wide organisation company is located -single choice reply- Please provide the name and location of parent company Carbon Disclosure Project (CDP) & Carbon Disclosure Standards Board (CDSB) 40 Bowling Green Lane London EC1R 0NE United Kingdom Your address Carbon Disclosure Project (CDP) & Carbon Disclosure Standards Board (CDSB) 40 Bowling Green Lane London EC1R 0NE United Kingdom Your address: -open reply- cassie.chessum@cdproject.net Short description of the general activity of your organisation / company: Carbon Disclosure Project (CDP) The Carbon Disclosure Project (CDP) is an independent not-for-profit organisation, which operates the only global reporting system through which corporations, suppliers and cities report their greenhouse gas (GHG) emissions, climate change governance, risks and opportunities. CDP holds the world s largest registry of primary corporate climate change information. In 2010, over 3000 organisations in some 60 countries around the world measured and disclosed their greenhouse gas emissions and climate change strategies through CDP. CDP now operates five major programmes: Investor CDP is the largest collaboration of investors in the world and generates essential climate change information that helps drive capital flows to a low carbon economy. Over 534 institutional investors with assets of US$64 trillion are signatories to Investor CDP, including Allianz, Axa and Goldman Sachs. On their behalf, CDP issues an annual information request on climate change and GHG emissions data to more than 4,700 of the world s largest companies. CDP Supply Chain helps global corporations to understand the impacts of climate change across the supply chain, harnessing their collective purchasing power to encourage suppliers to: measure and disclose climate change information, set reduction targets and make performance improvements. Over 50 corporations including Ford, Kellogg s, P&G, Unilever and Wal-Mart are using CDP Supply Chain to gain an understanding of their supply chain emissions, which often exceed those from an individual purchasing company s own operations. CDP Public Procurement provides a way for national and local governments to better understand the climate change related risk they face through the supply chain and work towards building a resilient, low carbon government supply chain. CDP Public Procurement works with over 12 UK government bodies, including the Department of Energy & Climate Change, Office of Government Commerce, Cabinet Office, HM Revenue & Customs and the Ministry of Defence. CDP Water Disclosure provides critical water-related data from the world s largest corporations to inform the global market place on investment risk and commercial opportunity. On behalf of over 137 institutional investors representing US$16 trillion in assets, CDP requests information on the risks and opportunities companies face in relation to water; on water usage and exposure to water stress in companies own operations and in their supply chains; and on companies water management plans and governance. Launched in 2010, over 150 of the most water-intensive companies in the world are already disclosing via CDP. CDP Cities also launched in 2010 and provides a global platform that allows city governments to publicly disclose their GHG emissions data, analysis of

2 Page 2 of 6 climate change risks / opportunities and adaptation plans. CDP Cities allows city governments to demonstrate their commitment to transparency and facilitate the sharing of emissions data, as well as providing valuable insights into the strategies deployed by cities in relation to climate change. For more infomation, visit Climate Disclosure Standards Board The Climate Disclosure Standards Board (CDSB) was formed at the 2007 annual meeting of the World Economic Forum. CDSB is an international organisation committed to the integration of climate change-related information into mainstream corporate reporting. CDSB works with leading professionals in accountancy, business, standard-setting and regulation to develop and advocate a generally-accepted global framework for use by corporations in disclosing climate change-related information in mainstream corporate reporting. In support of its objectives, CDSB has developed a Climate Change Reporting Framework (see attached) by drawing on the work of its Board members, on international developments in climate change regulation and on the work of the International Accounting Standards Board. Technical Working Group members include representatives of the major accounting firms, as well as national and international accounting bodies. By drawing on these sources, as well as on ten years of good practice in climate change-related disclosure to CDP by thousands of companies worldwide, CDSB s Framework prescribes reporting requirements that are as consistent as possible with the most common features of voluntary and mandatory climate change disclosure and with the established financial reporting model. CDSB s work programme is managed by CDP, which acts as Secretariat to CDSB. It is responsible for advancing the CDSB Framework in association with members of the CDSB Board, Advisory Committee and Technical Working Group. For more information see Is your organisation registered in the Interest Representative Register? No If your organisation is not registered, you have the opportunity to register here before you submit your contribution. Responses from organisations not registered will be published separately from the registered organisations. -single choice reply- Can the Commission contact you if further details on the information you submitted is required? -single choice reply- Yes Publication: Do you object to publication of the personal data on the grounds that such publication would harm your legitimate interests? -multiple choices reply- (optional) Questionnaire 1. How would you consider the current regime of disclosure of nonfinancial information applicable in your country? -single choice reply- Poor In replying to this question, please provide information on what way current reporting provides useful information, and to what extent it is sufficiently tailored to the circumstances of the company. Please also comment on whether you find non-financial information useful for the decision-making of a company. The Carbon Disclosure Project (CDP) and the Carbon Dislcosure Standards Board (CDSB) believes that the current regime of non-financial disclosure is poor and could be greatly improved. With the exception of climate change disclosure, other areas of sustainability disclosure (such as social issues) are not well developed. In the case of climate change disclosure a lot of work has been done in this area and it is significantly ahead of other types on non-financial disclosure. However, whilst voluntary initiatives on climate change disclosure, such as CDP, have had a significant impact in recent years; greater levels of reporting are needed across companies in Europe data from CDP shows that around half of UK FTSE 350 companies responding to CDP are reporting their GHG emissions publicly and that the number of FTSE 350 companies whose data is verified is just 27%. This means that around 50% of companies in the UK FTSE 350 are not reporting their carbon emissions publicly and 73% of FTSE 350 companies that disclose climate change data are not verifying it. Given that the UK FTSE 350 companies have the best response rate to CDP in Europe (69%), it is clear that more needs to be done. Looking to other European countries, there could also be significant improvements. CDP data shows that the response

3 Page 3 of 6 rate to CDP in 2010 in some EU Member States is as low as 30%. Examples include Portugal (30%) and Italy (35%), as well as companies in the Central & Eastern Europe index which has a 12% response rate. There is clearly room for improvement, especially if you compare this with the response rate from indexes in less developed economies, such as Brazil, which has a relatively high response rate (72%). In summary, CDP and CDSB consider that the current regime of disclosure of non-financial information is poor because even though climate change disclosure is further advanced than other areas of sustainability disclosure, carbon disclosure by companies is very low in some European countries. Plus even in Member States, such as the UK, where the response rate is relatively high, the information is not always publicly available and is very rarely independently verified. See for various CDP reports. CDP and CDSB believe that (in the first instance) all large listed European companies should be required to disclose non-financial information (which is material) and that there should be a transition plan to bring more organisations into the scope of the regulations over time (as part of a phased approach). It is also important to note that identifying the organisations that should be part of the transition plan depends on the policy objectives that the European Commission would like to achieve. CDP and CDSB also recommend a phased approach in terms of the type of information that is required to be disclosed by companies. We believe that the regulation of climate change disclosure should be a priority and adopted in the first instance; and that other types of sustainability disclosure, which are less well developed should be adopted over time as part of a transition plan (once adequate frameworks have been developed). This is because climate change disclosure is a lot more advanced than other types on non-financial disclosure, plus there are sophisticated framework s already in place on climate change, which have been developed over several years by professionals in the leading accountancy firms and business (such as CDSB s Climate Change Reporting Framework), whereas adequate frameworks for other types of sustainability disclosure are yet to be developed. As CDP and CDSB have worked on disclosure for over 10 years, we would be delighted to assist the European Commission in this area and offer our experience which has involved working with the largest investors, corporations and service providers in Europe. If you would like to discuss any aspect of CDP or CDSB s work, please contact us using the details provided in this consultation response. CDSB s framework can be downloaded at 2. Have you evaluated the effects, Yes and costs and benefits, of any current corporate disclosure of environmental and social information? -single choice reply- The Department for Environment, Food and Rural Affairs (DEFRA) in the UK commissioned PricewaterhouseCoopers (PwC) and CDP to conduct a research study on the costs and benefits of corporate greenhouse gas (GHG) emissions reporting; as well as assessing the impact of corporate emissions reporting in helping the UK to achieve emission reductions and the development of broader corporate climate change strategies. CDP provided advice to PwC, as well as contributing a chapter about climate change-related reporting issues. The key findings from the report include: Most large companies, which are measuring and reporting their GHG emissions, are experiencing net benefits, such as cost savings and energy efficiencies; Some respondents (around 14%) quantified energy cost savings of over 200,000, suggesting that the benefits could be substantial for some companies; Many businesses believe the benefits outweigh the costs of reporting and that the costs are not financially material to the business; The majority of businesses (65%) are spending up to 50,000 on reporting GHG emissions and over 50% are spending less than 50,000 on measurement; and 72% of companies surveyed said they now have a corporate climate change strategy designed to reduce GHG emissions, which is linked to their emissions measurement and reporting programme. This research will help inform the UK government s decision on whether to mandate reporting of GHG emissions. For further information, please visit: 3. If you think that the current regime of disclosure of non-financial information should be improved, how do you suggest that this should be done? CDP and CDSB strongly believe that the current regime of disclosure of non-financial information should be improved. We suggest that this will involve a range of mutually reinforcing measures, including: A clear statement about the purpose of non-financial disclosure, the policy objectives that the information is designed to support and the principal audience for the information; Coordination between regulators and other parties with an interest in non-financial information, which might include securities, company and finance regulators, as well as environment agencies and standard setters; A review of existing literature about compliance gaps in narrative reporting, such as the UK Accounting Standards Board s report Rising to the Challenge (which reviews the narrative reporting of 50 UK listed companies in 2008 and 2009), as well as reports prepared by the Federation of European Accountants; Analysis of work already in progress on non-financial disclosure by CDP, CDSB, the Global Reporting Initiative (GRI) and the International Integrated Reporting Committee (IIRC). CDSB is on the Steering Committee of IIRC; and Reliance on and adherence to relevant principles from established international standards and guidance including, for example, the International Accounting Standards Board s (IASB) guidance on management commentary. 4. In your opinion, should companies Other be required to disclose the following

4 Page 4 of 6 (check all relevant boxes): -multiple choices reply- (optional) Other, please specify: -open reply- CDP and CDSB believe that the EU should follow the approach set out by IIRC, which involves focussing on those issues (such as financial, environmental, regulatory, social and governance factors), which are material either singly and / or in combination on the immediate and / or long term resilience and performance of an organisation. CDP and CDSB believe that the EU should follow the approach set out by IIRC, which involves focussing on those issues (such as financial, environmental, regulatory, social and governance factors), which are material either singly and / or in combination on the immediate and / or long term resilience and performance of an organisation. 5. In your opinion, for a EU measure on reporting of non-financial information to achieve materiality and comparability it should be based upon (check all relevant boxes): - multiple choices reply- (optional) 5a) In case you consider that Key Performance Indicators (KPIs) would be useful, would you think that they should be (check all relevant boxes): - multiple choices reply- Principles Key Performance Indicators (KPIs) Other General for all economic sectors Sector specific 5b) Please indicate which indicators you would consider to be the most relevant for all economic sectors: Please see Answer to Question 6 Other, please specify: -open reply- Please see Answer to Question 6 6. In your opinion, what should be the process to identify relevant principles and/or indicators (whether general or sector-specific)? In replying to this question, please comment on whether the Commission should endorse or make reference to any existing international frameworks (or a part of them), such as Global Reporting Initiative (GRI), UN Global Compact, the OECD Guidelines, ISO 26000, or other frameworks; or whether companies should be required to select relevant indicators together with their investors and other stakeholders and to disclose information according to such indicators, depending on the use that different stakeholders would make of such information. CDP and CDSB believe that the reporting of non-financial information should be based on a combination of: Principles (about what companies need to disclose); KPIs (to ensure comparability); and Good quality narrative information (so investors understand the context and to ensure the richness of qualitative data). The Global Reporting Initiative s (GRI) Reporting Framework sets out a very useful and comprehensive list of indicators for sustainability reporting. CDP works closely with the GRI and has co-authored a publication with them showing where our work is aligned. For further information, please visit US/Respond/Documents/Linking-up-GRI-and-CDP.pdf. In terms of climate change issues, we work closely with key organisations on climate change disclosure and through public consulation, we are satisfied that Chapter 4 of CDSB s Framework represents a comprehensive list of the matters that companies should consider reporting about climate change risk, opportunity, strategy and performance. Good quality narrative information is important, as it ensures the richness of data and provides valuable context. However, CDSB s research on the quality and usefulness of environmental disclosures made under the securities/corporate laws of 6 jurisdictions shows that compliance with reporting requirements varies considerably, sometimes relying on standard wording with minimal or no analysis/discussion. For this reason, CDSB s Climate Change Reporting Framework relies on the International Accounting Standards Board s qualitative charateristics of decision-useful information to help management apply its judgement on the degree to which information is useful. These are referenced in Chapter 3 of the CDSB Climate Change Reporting Framework. We would suggest that the European Commission assesses IASB s work in this area, which provide useful definitions of materiality and comparability. Unless such characteristics are applied, disclosures can result in what the UK Financial Reporting Council has called immaterial clutter. We would also recommend that the European Commision includes some guidance on how to apply judgement so as to manage the volume of information on social and enviromental matters in order to maximise its usefulness. Again, materiality also depends upon the purpose that the information is designed to serve and the interests of the user of information. It is also important to note that the efficiacy of disclosing non-financial information depends upon the policy objectives that the disclosure is designed to support. We

5 Page 5 of 6 suggest that a clear statement by regulators about the purpose that non-financial disclosure is intended to serve will help to improve, in and of itself, the efficacy of reporting as companies will be able to tailor their disclosures accordingly. In summary, CDP and CDSB therefore believe that the following is needed: Principles about what companies need to disclose; KPIs for effective and comparable communication; Narrative information and qualitative data, so investors understand the context and to ensure the richness of data; and A clear policy objective and definition of the users interest. 7. In your opinion, should companies No opinion be required to disclose the steps they take to fulfill the corporate responsibility to respect human rights? -single choice reply- Human rights issues are not a key area of expertise for CDP or CDSB, as we focus on climate change issues. 8. In your opinion, should companies No opinion be required to disclose the risks they face and the policies they have in the field of corruption and bribery? -single choice reply- Corruption and bribery are not key areas of expertise for CDP or CDSB, as we focus on climate change issues. 9. In your opinion, what companies Large listed companies should be required to disclose nonfinancial information (check only one box)? -single choice reply- 10. In your opinion, should Yes institutional investors be subject to specific or additional disclosure requirements, for example to disclose whether and how they take into account environmental and social issues in their investment decisions? -single choice reply- In replying to this question, please provide information on which issues seem to be the most relevant and why; and which institutional investors should be subject to such an obligation. A report prepared for Defra by CDSB entitled Financial Institutions: Taking greenhouse gases into account by Haigh and Shapiro concludes that, although they have a robust interest in environmental information, none of the investors involved in the research used it for portfolio allocation. Therefore, CDP and CDSB would support the requirement for investors to disclose whether and how they take account of environmental and social issues in their investment decisions. However, further research may be needed to make this feasible. 11. In your opinion, should European policy promote the concept of "integrated reporting"? Yes Integrated reporting refers to a report that integrates the company's key financial and non-financial information to show the relationship between financial and non-financial performance (environmental, social, and governance). -single choice reply- In replying to this question, please indicate the advantages and disadvantages of an integrated report, as well as possible specific costs of integrated reporting. CDP and CDSB strongly believe that European policy should promote the concept of integrated reporting and, for the purposes of non-financial disclosure by companies, the EU should follow the approach set out by IIRC,

6 Page 6 of 6 which involves focussing on those issues (such as financial, environmental, regulatory, social, governance factors), which are material either singly and / or in combination on the immediate and / or long term resilience and performance of an organisation. As noted elsewhere within this consultation response, it is important to note that the policy objectives must be clear so that integrated reporting makes sense in terms of those objectives and the purpose that integrated reporting is designed to serve. CDP and CDSB believe that (in the first instance) all large listed European companies should be required to disclose non-financial information (which is material) and that there should be a transition plan to bring more organisations into the scope of the regulations over time (as part of a phased approach). CDP and CDSB also recommend a phased approach in terms of the type of information that is required to be disclosed by companies. We believe that the regulation of climate change disclosure should be a priority and adopted in the first instance; and that other types of sustainability disclosure, which are less well developed should be adopted over time as part of a transition plan (once adequate frameworks have been developed). This is because climate change disclosure is a lot more advanced than other types on non-financial disclosure, plus there are sophisticated framework s already in place on climate change, which have been developed over several years by professionals in the leading accountancy firms and business (such as CDSB s Climate Change Reporting Framework), whereas adequate frameworks for other types of sustainability disclosure are yet to be developed. As CDP and CDSB have worked on disclosure for over 10 years, we would be delighted to assist the European Commission in this area and offer our experience which has involved working with the largest investors, corporations and service providers in Europe. If you would like to discuss any aspect of CDP or CDSB s work, please contact us using the details provided in this consultation response. CDSB s framework can be downloaded at In your opinion, should disclosed Yes non-financial information be audited by external auditors? -single choice reply- In replying to this question please provide any evidence you may have regarding costs of auditing non-financial information, as well as your views on other possible forms of independent reviews besides external auditing. CDP and CDSB believes that it is very important that (where possible) non-financial information disclosed by European companies is audited by external auditors. It is certainly possible to independently verify Scope 1 and Scope 2 GHG emissions. However, CDP data shows that the number of UK FTSE 350 companies responding to CDP in 2010 that verified their data is just 27%. In terms of climate change data, it would be helpful if the European Commission issued guidance referring to examples of assurance standards that might be used, such as those listed in paragraph 1.14 of CDSB s Climate Change Reporting Framework. Please see: We would also like to bring to your attention that the International Auditing and Assurance Standards Board is working on a project to draft a new International Standard on Assurance Engagements for Carbon Assertions. We anticipate that the new standard will set a useful precedent for future assurance standards on sustainability engagements. The PwC / CDP report for the Department for Environment, Food and Rural Affairs (DEFRA) in the UK assessed the costs and benefits of corporate GHG emissions reporting. It included some information about the costs and benefits of assurance. However, as this was often grouped with other types of costs, it is hard to disaggregate them. For further information, please visit: If you have relevant documents you want to share with us, please attach them here. (optional) -multiple choices reply- (optional) PRINT EXPORT RECORD