For those companies that are considering or revisiting their approach to voluntary ESG disclosure: In his latest "Audit Committee and Auditor Oversight Update" (see "Questions About ESG Disclosure? WBCSD’s Handbook Has Answers"), Society member and recently retired Baker McKenzie partner (also former SEC GC and former PCAOB founding member & Acting Chair), Dan Goelzer provides an informative overview of the new World Business Council for Sustainable Development (WBCSD) "ESG Disclosure Handbook."
The Handbook provides guidance to companies on these key questions:
- Why report ESG information?
- For whom should ESG information be reported?
- Where should ESG information be reported?
- What ESG information should be reported?
- How should ESG information be prepared and presented?
- How much ESG information should be reported?
In addition to the key questions, the proposed framework encompasses three process steps - evaluating options objectively and methodically, decision-making, and documentation - each of which is detailed in the Handbook, and, together with the key questions, conveniently outlined on page 28. The Handbook specifically addresses the desirability of subjecting ESG reporting judgment calls to a structured process that is supported by well-considered and informed evaluations and decision-making.
Dan comments: "For companies that are grappling with what information to disclose and how to justify those decisions, the Handbook lays out a process that may be useful and that could be cited as the basis for the company’s approach."
WBCSD is self-characterized as a global, CEO-led organization of over 200 leading businesses (see webpage bottom) working together to accelerate the transition to a sustainable world.
See also "Legal Risks and ESG Disclosures: What Corporate Secretaries Should Know" from the Society/Gibson Dunn & Crutcher, "ESG Roadmap: Observations and Practical Advice for Boards, Corporate Secretaries and Governance Professionals" from Society/BrownFlynn, and additional information & resources on our ESG page. This post first appeared in the weekly Society Alert!