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ESG reporting in Australia: The path forward.

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Environmental social governance (ESG or sustainability) reporting in Australia is a phenomenon driven by broad stakeholder demand rather than specific legislation.

Today, there is no specific legislative requirement for ESG reporting in Australia. However, many ASX-listed companies (57% of ASX 200 @ 2022), private companies and other entities have been preparing ESG reports of some description for years, using voluntary international reporting standards.

Regulator guidance encouraging aspects of ESG reporting includes:

  • In 2021, the Australian Securities and Investments Commission (ASIC) stated that disclosing and managing climate change risks (as one component of ESG) is a key director responsibility
  • ASIC had previously noted that climate change (amongst other risks) could have a material impact on the future financial position, performance or prospects of entities.  ASIC noted that directors may consider disclosing in the operating and financial review contained in the director’s report additional information that would be relevant under integrated reporting, sustainability reporting or the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).
  • For ASX-listed companies, the 4th Edition Corporate Governance Principles and Recommendation 7.4, published in 2019, states that “A listed entity should disclose whether it has any material exposure to environmental or social risks and, if it does, how it manages or intends to manage those risks.”

What has driven ESG reporting so far?

Entities have been producing ESG reports for years for a variety of reasons, including to:

  • Report progress on activities seeking to operate in an environmentally friendly and ethical manner with a positive social impact for its stakeholders, which may have previously been reported under ‘corporate social responsibility’, ‘triple bottom line’ (people, profit, planet), or ‘integrated reporting’.
  • Maintain access to capital, as institutional and retail investors worldwide have demanded more information regarding their investments, particularly with the rise of ethical investment funds, which represent 36% of the Australian investment market
  • Maintain and increase sales to customers who are increasingly more aware of ESG impacts and will prefer to buy from ethical and ‘green’ companies
  • Attract and retain talent, as prospective employees choose to work for entitles who, at a minimum, do not harm the environment and community
  • As part of managing relationships with institutional investors, companies increasingly need to satisfy ESG proxy advisors and other rating agencies, which assess, report on, and rank companies’ ESG credentials and ‘investability’, whether the companies choose to engage with them or not.

What does an ESG report contain?

The ‘pillars’ of ESG reporting may include the following:

Environment

  • Biodiversity impacts
  • Energy consumption and sources
  • Land and natural resource use
  • Pollution – greenhouse gas (Scope 1, 2, 3) and other emissions
  • Waste production and disposal, inc. hazardous substances consumed and discharged
  • Water use

Social

  • Diversity and inclusion
  • Employee training
  • Gender equality
  • Health and safety, injuries and fatalities
  • Indigenous engagement and reconciliation
  • Local community engagement and employment
  • Modern slavery and human rights in supply chains
  • Stakeholder engagement

Governance

  • Corporate disclosure practices (financial and other)
  • Governance structure and accountability, inc. Board and committees, polices
  • Key policy disclosures, inc:
    • Anti bribery anti corruption and money laundering
    • Bullying and harassment
    • Code of conduct / ethics / behaviour standards
    • Diversity and inclusion
    • Environment and sustainability
    • Modern slavery
    • Privacy and data protection
    • Whistle blower
  • Remuneration practices and disclosure
  • Risk management

Existing legislation relevant to ESG reporting for effected entities includes:

  • Australian corporations law and consumer law regarding false and misleading statements (including ‘greenwashing’) and misleading or deceptive conduct
  • Australian privacy principles
  • Gender equality reporting
  • Modern slavery reporting
  • National greenhouse and energy reporting
  • Whistleblower legislation

In Australia, mandatory climate reporting is anticipated to commence in the 2024-2025 financial year for the largest ‘Group 1’ companies, flowing down to ‘Group 3’ companies by the 2027-28 financial year.

Note:

  • Group 1 Companies, any two of >500 employees; consolidated gross assets ≥$1 B; consolidated revenue ≥ $500 M, from 1 July 2024
  • Group 2 Companies, any two of >250 employees; consolidated gross assets ≥$500 M; consolidated revenue ≥ $20 M, from 1 July 2026
  • Group 3 Companies, any two of >100 employees; consolidated gross assets ≥$25 M; consolidated revenue ≥ $50 M, from 1 July 2027

Where to start?

Ideally an entity commences its ESG journey with a genuine desire to actively measure and manage its environmental exposure and impact and ensure positive outcomes for its stakeholders.  Alternatively, some companies commence their ESG journey though peer pressure as their competitors embark on ESG reporting.

It is essential for an entity to be clear on the purpose or objective of its ESG reporting, as it drives the framework, content and disclosure, and needs to be sponsored by the Board to be effective.

ESG reporting frameworks currently used in Australia include:

Where next?

Acclime has helped several clients with voluntary ESG reporting and would be pleased to discuss your ESG reporting journey. Please contact Acclime Australia on +61 3 8689 9997 or via email: infoaustralia@acclime.com.

ESG reporting in Australia: The path forward

About Acclime.

Acclime helps established multinational companies and startups start and operate their business in Australia and the APAC region. By seamlessly navigating our clients through the complexities of Australian laws and bureaucracy, we allow them to reclaim valuable time and fully focus on growing and developing their business.