The European CSRD (Corporate Sustainability Reporting Directive) mandates large companies to transparently report on their sustainability efforts. Although most aged care providers are not directly obligated to comply with CSRD, they will indirectly encounter accountability demands from stakeholders like health insurers and banks. Industry association ActiZ, in collaboration with Deloitte and PwC, has conducted important preliminary work to reduce the administrative burden on individual healthcare providers and their stakeholders.
Of the nearly 400 elderly care providers that are members of ActiZ, only 12 are required to comply with the CSRD due to their organizational structure or international affiliations. The remaining ActiZ members are not subject to this obligation. "Nevertheless, they do have to deal with the CSRD," says Wiebe-Jan Stuursma, director of Catharina, at home on Voorne and a member of the Housing and Care core group within ActiZ. "Their CSRD stakeholders—health insurers, banks, suppliers—will confront them with accountability requirements to ensure transparency about their sustainability goals. We wanted to prevent elderly care providers from being unprepared for this."
"That is why ActiZ, in collaboration with Deloitte and PwC, initiated a preparatory process to map out the material topics on which these providers can report." This process was valuable not only for ActiZ but also for us," says Wil-Jan van de Rijdt, Partner Audit & Assurance at Deloitte. "The CSRD is complex legislation. For example, what does the double materiality analysis specifically for elderly care entail, and how do you interpret the reporting standards?"
Accountants also have a role to play in organizations subject to the CSRD, Van de Rijdt believes. Deloitte had already gained knowledge from assignments with companies that had to comply with the CSRD earlier. The collaboration with PwC and coordination with the NBA subcommittee Coziek (consultation platform for accountants in healthcare) broadens the support for the results of the double materiality analysis.
"For this project, we worked with a group of frontrunners in elderly care who had already taken steps and a reference group. We analyzed the input from these groups and further refined it into two end products: a list of 15 material impacts, risks, and opportunities applicable to most healthcare organizations and 15 possible material impacts, risks, and opportunities that are context-dependent."
"In elderly care, many material topics are the same for all institutions," says Stuursma. "About 80 percent of what they need to submit in the context of the CSRD already comes from this preparation. This process is valuable for our members because it allows them to maintain control over what is material and to substantiate this well for their stakeholders.
"It is also possible for providers to use a 'light' version of the CSRD, Van de Rijdt adds. "Determine which areas you can make the most impact on. Focus your energy there and explain to your stakeholders why you are doing it. Then you stay in control."
The project work saves providers a lot of administrative burden. The KIK-V platform is important here. The KIK-V platform is a working agreement where all providers label and store data unambiguously. "There should be no proliferation of requests from stakeholders," says Van de Rijdt. "With KIK-V, the sector has clear agreements on where and how all information can be recorded, so stakeholders can easily access it. Organizations will need to set up their processes to effectively collect and make the data available, but this will be very beneficial."
The CSRD directive requires large companies to report on issues such as CO2 emissions and social capital, on their impact on biodiversity and on human rights violations in the supply chain.
The directive builds on the existing European directive on sustainability reporting: the Non-Financial Reporting Directive (NFRD). A company is great if it meets at least two of the three criteria below.
In terms of content, the CSRD includes the following: Based on the double materiality principle, reporting on:
The diversity of the sector was deliberately considered in the project, Van de Rijdt outlines. "Elderly care includes large providers as well as small ones with limited capacity to undertake such a process independently. We wanted to establish something beneficial for both groups."
We succeeded, Stuursma adds. "Without this process, it would have been nearly impossible for small providers to address the questions posed by stakeholders in the context of the CSRD. Our work assists all aged care providers in gaining a clearer picture of where they can make the most significant impact with their sustainability goals. Essentially, it reinforces their understanding while providing a clearer perspective from a European viewpoint, enabling more targeted steps within the Green Deal sustainable care."
The CSRD's purpose extends beyond accountability, Stuursma emphasizes. "It fosters sustainability awareness and helps reduce our environmental footprint. Mapping out the material topics helps our members focus on them."
Sustainability (accountability) is a pressing issue. "Wiebe-Jan already mentioned the Green Deal, which many elderly care providers have signed," says Juwi Liu, Director Audit & Assurance at Deloitte. "The relevant topics in this agreement align with the material topics identified in the CSRD. From this perspective, the work we've done to outline the material topics is beneficial for them."
Health insurers themselves had already compiled a list of what they consider to be material topics for healthcare. "There turned out to be little difference between their list and ours," notes Van de Rijdt. "The only topic they included that we hadn't was the impact of pharmaceutical residues on surface water. This topic is likely material for hospitals, whereas drug residues are on the list of potential material topics for elderly care."
Stuursma adds, "Conversely, the health insurers didn't include child labor on their list, which we did. Sharing these perspectives in dialogue with the health insurers is valuable for gaining a better understanding of the issues within the elderly sector. Elderly care often involves using products manufactured outside Europe, where conditions are not always transparent. This exchange enriches the substantive conversation."
It is foreseeable, says Van de Rijdt, that banks and health insurers will eventually include incentives in their contracts with providers to encourage steps that advance the CSRD's goals. These goals can be quite diverse. "The Green Deal strongly emphasizes environmental aspects," Liu adds, "while the CSRD also addresses social sustainability, providing a more balanced picture."
Stuursma agrees. "For me, the sustainable employment of staff is truly valuable. I believe I can achieve more through this than by reducing CO2 emissions from the building I lease. Similarly, I could encourage employees to install solar panels on their homes or offer lease e-bikes. This not only reduces CO2 emissions but also improves their health."
Liu: "Also consider equal opportunities for everyone or ensuring living wages for employees in lower positions. While this doesn't directly impact the environment, it positively affects sustainable staffing. It's no coincidence that living wages have been identified as a material subject." Van de Rijdt concurs: "Financial hardship plays an important role in sick leave."
An important first step has been taken by identifying the material subjects, concludes Van de Rijdt. "My advice is that healthcare providers should also collaboratively determine KPIs and required data. This will help prevent providers from getting bogged down in the process."
*This article was previously published on ICT&health in August 2024