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Ethico [https://www.ethico.com] facilitates a lively discussion with leaders committed to compliance and ethics. Compliance, HR, Hot Line, Investigators, Legal, and business leaders tune in weekly to learn, contribute, and build community. Douglas was invited to introduce Sustainability to this impressive community. Doug's slides helped facilitate the conversation.
Sustainability professionals should learn to talk the language of the Board and the C-Suite. Finance, Accounting, Internal Audit, and Controllers play an increasingly prominent role in reporting and disclosures to capital markets. They also have a role in engaging external resources.
I’ve read several publications in the EU’s Sustainability Reporting Standards, and key concepts required to achieve these disclosures. Some points have been useful, others – not so much. Or wrong. I offer some perspectives to help companies prepare for more extensive Sustainability reporting and disclosure requirements, particularly as imposed by the EU and/or capital markets. “Materiality” has always been difficult to explain, adding “double” makes it more than twice as hard. Let’s dive in.
DHC is pleased to provide comments in CARB's invitation. The attached file addresses each item. The most critical comments:
Specify GHG Protocol for all parameters where applicable; ISSB S-2 where GHG Protocol does not address the topic.
Use CDP as the disclosure portal, and NOT a separate submittal to CARB. Provide guidance annually on what fields of the CDP questionnaire fulfill the Calif. disclosure requirements.
Do not specify what type of firm should perform assurance. Allow technical firms to conduct assurance. The assurance providers should indicate what standards they used in their report.
Change the reporting deadline to reflect the reality of obtaining data, resource limitations at regulated and otherwise affected entities (e.g., business partners), and convention established by other laws (Dodd-Frank Conflict Minerals) and disclosure portals (CDP).
Respectfully submitted, Douglas Hileman, FSA, CRMA, CPEA
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