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Strategy: the first part to taking any step

Without strategic thinking, you can’t have effective disclosure

 Strategy refers to your organization’s plan to improve environmental, social and governance performance by developing clear objectives, adopting principles and understanding expectations for your sustainability disclosure. It also involves the creation of a governance structure designed to ensure your organization consistently and effectively discloses material information.

Sustainability disclosure objectives:
All sustainability disclosure activities should involve understanding what needs to be achieved and why. To gain a solid grasp of your organization’s broader sustainability and disclosure context, as well as your underlying disclosure objectives, ask:

  • Do you have clear sustainability disclosure objectives?
  • How do those objectives link to organizational strategy, risk appetite and sustainability goals?
  • Will the objectives meet voluntary as well as mandatory disclosure requirements?
  • Have you selected supporting disclosure or reporting standards (e.g., Global Reporting Initiative, Carbon Disclosure Project and AccountAbility)?

Sustainability disclosure principles:
It’s important to consistently apply quality disclosure principles, including relevance, completeness, consistency, transparency, accuracy, reliability, clarity, balance, context and timeliness. Key questions to consider include:

  • Do guiding disclosure principles or commitments exist?
  • How transparent will the disclosure process be?
  • What information can or cannot be disclosed?
  • Has a disclosure policy been developed? Does it reflect the latest requirements from financial regulators (e.g., CSA, SEC)?

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Materiality and stakeholder expectations:
Both internal and external stakeholder expectations must inform what and how much to report when determining financial and non-financial materiality. Key considerations include:

  • Have you identified all internal and external stakeholders?
  • Do you know which disclosure channels will best meet stakeholder needs?
  • Is there a framework and defined process for deeming which stakeholder issues are material and prioritizing them accordingly?
  • Have you defined materiality in a non-financial context?

Disclosure governance and alignment:
Subject matter related to sustainability disclosure can involve many functions and departments (e.g., Finance, Investor Relations, Human Resources, Environment, Health & Safety, etc.). Defining formalized roles, responsibilities, accountabilities and governance sustainability disclosure structures enables effective process management, as well as quality control over information. Communication sources, content and channels should be clear, and messages should be consistent across all channels. Key considerations include:

  • Do all levels of the organization have formalized sustainability disclosure responsibilities?
  • Are disclosure accountabilities clear and do they mirror requirements for other business disclosures?
  • How will you provide internal and external sustainability disclosure updates?
  • How will you standardize sustainability messaging and align it across different communication channels?
  •  Are sustainability disclosure objectives and principles consistent with broader organizational communication goals?

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Consumer business
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Technology, media & telecommunications