Tag Archives: EU CSR Reporting Policy

Environmental, Social and Governance Disclosures in Europe

Excerpt from: Camilleri, M. (2015). Environmental, social and governance disclosures in Europe. Sustainability Accounting, Management and Policy Journal, 6(2). http://www.emeraldinsight.com/doi/abs/10.1108/SAMPJ-10-2014-0065

 

Last year, the European Union (EU) announced its new guidelines on non-financial reporting that will only apply to some large entities with more than 500 employees. This includes listed companies as well as some unlisted companies; such as banks, insurance companies and other companies that are so designated by member states; because of their activities, size or number of employees. There are approximately 6,000 large companies and groups within the EU bloc (EU, 2014).  The most prevalent reporting schemes in the EU were often drawn from; the G3 Guidelines of the Global Reporting Initiative (GRI) and the United Nations Global Compact (UNGC). In addition, several platforms and organisations that promote corporate sustainability reporting have developed partnerships with AccountAbility, OECD, UNEP, Carbon Disclosure Project and with many governments and sector organisations (Van Wensen et al., 2011; Kolk, Levy & Pinkse, 2008).

 

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When one explores the key topics that companies reported on, it transpired that carbon emission disclosures have become quite a common practice (Kolk et al., 2008). Moreover, recently there was an increased awareness on the subject of human rights and the conditions of employment (Lund-Thomsen & Lindgreen, 2013). Curiously, online reporting has offered an opportunity for accountability and transparency as information is easily disseminated to different stakeholders (Zadek, Evans & Pruzan, 2013). This has inevitably led to increased stakeholder engagement, integrated reporting and enhanced external verification systems. This subject has also been reported by Simnett and Huggins (2015), who have also presented a number of interesting research questions which could possibly be addressed through engagement research. At this point in time, stakeholders are considering reporting schemes as a valuable tool that can improve the quality of their reporting, particularly as it enables them to benchmark themselves with other companies (Adams, Muir & Hoque, 2014). The GRI is often regarded as ‘a good starting point’ for this purpose. Moreover, the provision of a UNGC communication on progress is a new global trend that has become quite popular among business and non-profit organisations. Some of the European organisations are gradually disclosing environmental information or certain other key performance indicators that are of a non-financial nature in their reporting (Zadek et al., 2013). Generally, public policies are often viewed as part of the regular framework for social and employment practices. Therefore, a considerable commitment is made by local governments who act as drivers for stakeholder engagement (Albareda, Lozano, Tencati, Middtun & Perrini, 2008).

 

One way to establish a CSR-supporting policy framework is to adopt relevant strategies and actions in this regard. Such frameworks may be relevant for those countries that may not have a long CSR tradition or whose institutions lack accountability and transparency credentials (Zadek et al., 2013). It may appear that EU countries are opting for a mix of voluntary and mandatory measures to improve their ESG disclosure. While all member states have implemented the EU Modernisation Directive, they have done so in different ways. While the Modernisation Directive ensured a minimum level of disclosure, it was in many cases accompanied by intelligent substantive legislation. National governments ought to give guidance or other instruments that support improvements in sustainability reporting. Lately, there was a trend towards the development of regulations that integrate existing international reporting frameworks such as the GRI or the UNGC Communication on Progress. These frameworks require the engagement of relevant stakeholders in order to foster a constructive environment that brings continuous improvements in ESG disclosures. Regular stakeholder engagement as well as strategic communications can bring more responsible organisational behaviours (Camilleri, 2015). Many corporate businesses use non-governmental organisations’ regulatory tools, processes and performance-oriented standards with a focus on issues such as labour standards, human rights, environmental protection, corporate governance and the like. Nowadays, stakeholders, particularly customers expect greater disclosures, accountability and transparency in corporate reports.

 

At the moment, we are witnessing regulatory pressures for mandatory changes in CSR reporting. Of course, firms may respond differently to reporting regulations as there are diverse contexts and realities. In a sense, this paper reiterates Adams et al.’s (2014) arguments as it indicated that ESG disclosures are a function of the level of congruence between the government departments’ regulatory environment and the use of voluntary performance measures. Somehow, EU regulatory pressures are responding to energy crises, human rights matters and are addressing the contentious issues such as resource deficiencies including water shortages. Notwithstanding, big entities are also tackling social and economic issues (e.g. anti-corruption and bribery) as they are implementing certain environmental initiatives (e.g. waste reduction, alternative energy generation, energy and water conservation, environmental protection, sustainable transport et cetera). In this light, there are implications for practitioners and assurance providers of integrated reports, standard setters and regulators (Simnett & Huggins, 2015). Future engagement research can possibly consider how report content and reporting formats, might impact on organisations’ decision making (Correa and Larrinaga, 2015). This paper indicated that practice and policy issues would benefit from additional empirical evidence which analyse how the European disclosure regulations may positively or adversely affect the corporations’ stakeholders.

http://www.emeraldinsight.com/doi/abs/10.1108/SAMPJ-10-2014-0065

 

References

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Europe’s Energy Efficiency Targets

euThe European Union’s (EU) Member States are required to draft National Energy Efficiency Plans (NEEAPs) that report on adopted measures (or planned to be adopted) to implement the main elements of the Energy Efficiency Directive (EED, 2012/27/EU). All EU countries are required to achieve a certain amount of final energy savings over the period (01 January 2014 – 31 December 2020) by using energy efficiency obligations schemes or other targeted policy measures to drive energy efficiency improvements in households, industries and transport sectors. The Energy Efficiency Directive (EED) entered into force on the 4th December 2012 in order to establish a common framework of measures for energy efficiency within the EU. EED laid down specific rules to remove barriers in the energy market and to overcome certain market failures that impede energy efficiency. It also provides for the establishment of indicative national energy efficiency targets for 2020. All the EU-28 countries are urged to use energy more efficiently at all stages of the energy chain – from the transformation of energy, through its distribution until its final consumption.

EED measures may also translate to significant energy savings for consumers. For instance, this directive proposed that consumers ought to access easy and free-of-charge data on their real-time (and historical) energy consumption to enable them to monitor their energy consumption patterns. Moreover, this directive also recommended that large enterprises should carry out an energy audit at least every four years, with the first energy assessment should be held before the 5th December 2015. It also suggested that SMEs could be incentivised to undergo energy audits to help them identify the potential for reduced energy consumption. As from the 1st January 2014, the directive advised the public sector to lead by example by renovating 3% of the buildings owned and occupied by the central governments and by including energy efficiency considerations in public procurement. EED has even set realistic deadlines for further improvements in energy efficiencies in energy generation, the monitoring of efficiency levels of new energy generation capacities, national assessments for co-generation and district heating potential and measures.

It goes without saying that the requirements laid down in the EED directive are minimum requirements that do not prevent any Member State from maintaining or introducing more stringent measures. As from 2013, every member state have to report on the progress achieved towards national energy efficiency targets in accordance with Part 1 of Annex XIV.

Links:

EU (2012) DIRECTIVE on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012L0027

 

 

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The EU’s directive on the disclosure of non-financial information

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On the 29th September 2014, the European Council has introduced amendments to Accounting Directive (2013/34/EU) that mandates corporate business to disclose their non-financial performance. The EU Commission proposed non-binding guidelines on the details of what non-financial information ought to be disclosed by big businesses operating from by EU countries. This legislation respects environmental, human rights, anti-corruption and bribery matters as expressed in the UN Guiding Principles on Business and Human Rights (the “Ruggie Principles”) and OECD’s Guidelines for Multinational Enterprises (ECCJ, 2014).

This recent EU directive has marked a step forward towards the hardening of human rights obligations for large “public interest entities” with more than 500 employees. At the moment there are approximately 6,000 large undertakings and groups across the EU. Public interest entities include all the undertakings that are listed on an EU stock exchange, as well as some credit institutions, insurance undertakings and other businesses so designated by Member States.

In a nutshell, these non-financial disclosures should shed light on the corporate businesses’ social and environmentally responsible policies and practices. They will feature a brief description of the undertaking’s business model, including their due diligence processes resulting from their impact of their operations. This EU directive encourages corporates to use relevant non-financial key performance indicators on environmental matters including; greenhouse gas emissions, water and air pollution, the use of (non) renewable energy and on health and safety.

With regards to social and employee related matters, the corporate firms ought to implement ILO conventions that promote fair working conditions for employees. The corporate disclosure of non-financial information can include topics such as; social dialogue with stakeholders, information and consultation rights, trade union rights, health and safety and gender equality among other issues. Businesses should also explain how they are preventing human rights abuses and/or fighting corruption and bribery.

Through this directive the EU commission emphasises materiality and transparency in non financial reporting. It also brought up the subject of diversity at the corporate board levels. It has outlined specific reference criteria that may foster wider diversity in the composition of boards (e.g. age, gender, educational and professional background). The EU Commission has even suggested that this transparency requirement complements the draft directive about women on boards.

This new directive still allows a certain degree of flexibility in the disclosures’ requirements. As a matter of fact, it does not require undertakings to have policies covering all CSR matters. Yet, businesses need to provide a clear and reasoned explanation for not complying with this directive. Therefore, non-financial disclosures do not necessarily require comprehensive reporting on CSR matters (although this is encouraged by the Commission), but only the disclosure of information on policies, outcomes and risks (ECCJ, 2014). Moreover, this directive gives undertakings the option to rely on international, European or national frameworks (eg. the UN Global Compact, ISO 26000) in the light of the undertaking’s characteristics and business environment.

It is envisaged that the first CSR reports will be published in financial year 2017 (ECCJ, 2014).

Links:

http://ec.europa.eu/finance/accounting/non-financial_reporting/index_en.htm

http://business-humanrights.org/sites/default/files/media/documents/eccj-assessment-eu-non-financial-reporting-may-2104.pdf

http://europa.eu/rapid/press-release_MEMO-14-301_en.htm?locale=en
 

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CSR: new disclosure and reporting obligations for listed organisations | EurActiv

Commission accuses companies of ‘group think’, demands social responsibility | EurActiv.

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Valuing regulatory instruments for sustainability reporting

Laudable corporate responsibility practices often involve the development of network relations, as both private and government actors are increasingly investing their discretionary resources in social capital. Societal governance is intrinsically based on a set of increasingly complex and interdependent relationships. Several governments are stepping in with their commitment for corporate governance as they are setting their social and environmental responsibility agenda through different policies and frameworks.

Many countries are following the guidelines of the International Labour Organisation (ILO) and the Organisation for Economic Cooperation and Development (OECD) as these organisations have provided highly recognised international benchmarks for transparent and accountable practices. However, there are other pertinent actors within the local levels of society, which may include civil organisations and industry practitioners. There may be different expectations and perceptions within each stakeholder relationship, which have to be addressed successfully to develop appropriate CSR policies. Essentially, such relational approaches are based on the idea that recent changes and patterns affecting the economic and political structure may transform the roles and capacities of various social agents.

The corporations’ political role has inevitably raised the need for further transparency and accountability of practices. Apparently, the so called ‘standards’ represent voluntary predefined norms and procedures for organisational behaviour with regards to social and environmental issues and are often valid on a global level. There are several well-known examples of such standards, which may contain considerable differences. These standards help corporations to be accountable to the consequences of their actions. Organisations are encouraged to assess and communicate their responsible activities (and impacts) on sustainable issues to their stakeholders.

Yet, it may seem that to date there is still no formal model which can be used as a yardstick to evaluate the standards’ strengths and weaknesses. The accountability standards reflect a shift towards a ‘quasi-regulation’ which is based on a substantive (outcome-based) and reflexive (process-based) law approaches. A ‘substantive’ law approach is regulated by prescribing predefined outcomes, whereas a ‘reflexive’ law approach is regulated by prescribing procedures to determine outcomes in a discursive way. Since most accountability standards are addressing corporations all over the world, their macro-level norms may appear to be quite generic and broad in their content.

According to the EU Commission Expert Group (2012), non-financial reporting enables investors to contribute to a more efficient allocation of capital, and to better achieve longer-term investment goals. It can also help to make enterprises more accountable and contribute to higher levels of citizen trust in business. Several experts have supported the idea of a principles-based approach, rather than a detailed, rules-based one. The EU Commission Expert Group suggested that their framework on non-financial reporting has given flexibility to the companies to decide the topics to report on. The European Union’s experts (hailing from the Directorate General of the Internal Market and Services) came up with an innovative approach, which incentivised the companies to report their non-financial information. Of course, materiality is considered a key concern by audit experts. The experts stressed that improving materiality of reports is useful to address the comparability issues. They advocated that the companies’ boards should have ownership on reporting, in order to make it relevant and effective.

Clearly, the experts did recognise that there were significant differences in national cultural contexts as well as in their respective reporting mechanisms. Some experts have indicated their concern about the consequences of adopting more detailed reporting requirements (including specific key performance indicators) into EU legislation. On the other hand, they did not reject the idea of proposing a list of topics which could be covered by any company when reporting its responsible practices. The current EU framework still does not provide a specific reference framework as to the expected quality of the disclosure of the non-financial reports.

For the time being, the instruments for sustainable reporting are not compulsory, although a wide array of CSR tools and standards have already been developed. The voluntary nature of private non-financial reporting can be a valid reason why governments and businesses did not take a hands-on approach in the development of CSR policy. The governments could possibly play a more pro-active role by setting the regulatory social and environmental standards. The introduction of standards, phase-in periods and use of innovative technologies can possibly bring operational efficiencies and cost savings to the businesses themselves. Such measures may improve the environment, and increase the organisations’ competitiveness. Adequate regulation can possibly contribute to the wider societal and environmental objectives.

Mark Camilleri recently completed his PhD (Management) degree at the University of Edinburgh

Valuing non financial performance and CSR reporting

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