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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Douglas Hileman guest speaker at Loyola Marymount University graduate Finance class.  Introduction to Sustainability reporting standards and frameworks.  Great launch pad for the newbie, or reminder for the pro.
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Doug presents at the 2025 West District conference of the Institute of Internal Auditors (www.theiia.org).  Some think the pendulum has swung back on Sustainability/ ESG.  If there’s no SEC Climate Disclosure Rule, does everything “climate” go away? Do privacy concerns evaporate?  Must customers be blocked from information they need for their decisions? Doug challenges Internal Auditors to apply core competencies:  objectivity; risk; opportunity to tailor efforts and add value to their organizations.   
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The cross-functional climate team at a mid-size company determined that commercially-available solutions were not suitable for their objectives.  Mr. Hileman presented a half-day workshop on processes, controls, and the design of calculation tools and techniques.  The session included mapping to the GHG Protocol, using estimates, leveraging COSO’s Internal Controls over Sustainability Reporting (ICSR), and designing controls to be “assurance-ready.” 

Douglas provided training for cross-functional team members from companies that were developing their program – and calculating their greenhouse gas (GHG) emissions inventory for the first time.  Mr. Hileman walked through the GHG Protocol Corporate Standard and the GHG Scope 2 Guidance in a “book club” approach.  He highlighted key sections, and encouraged discussions and questions.  He also shared how some companies have developed tools and techniques to demonstrate alignment with the standards and guidance.  The session enabled participants to design more effective, efficient controls, and to gain comfort on readiness for external assurance.

Sustainability reporting uses IT, yet the IT function often has limited role – until the last minute.  COSO’s ICSR framework points the way for all functions to recognize where IT should have prominent involvement.   More on Doug’s lively, informative session at ISACA Minnesota Chapter in July 2024
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Doug Hileman is a primary author of “Achieving Effective Internal Controls over Sustainability Reporting (ICSR)” – supplemental guidance released by COSO.  Douglas was the only non-CPA and the only ESG specialist among the six authors.  This document will help bridge the divide between those who know internal controls (CFO, Accounting, Internal Audit) and those who don’t (Environmental, HR, Operations, Procurement, Real Estate, Safety … and everyone else).  The download is available free here. 

I'm pleased to be leading this info-packed session provides background and trends on climate-related risks for Internal Audit, their sponsors and stakeholders.  Real-time attendees got CPE, but you can still (Watch Now)

The Federal Trade Commission’s Green Guides are intended to safeguard consumers from false or misleading claims in the products they buy.  The FTC revises the Guides every 10 years, soliciting public comments.  DHC advocates for more protection of consumers and ethical businesses alike.  Read more. 

Accountants are entering the fray for trustworthy ESG reporting and disclosures, says Financial Times. Much is driven by GHG emissions inventories, and the anticipated SEC rule for climate disclosures.  Will they stop there?  Should they?  What can other functions learn from accountants – and vice versa? , Read More.

Consumers are buying eco-friendly products and services.  Investors demand accurate sustainability reporting; what protection do consumers have?  With consumer spending at 70% of the economy, even a sliver of this market in ESG-aligned products is massive.  Consumer protection is left to FTC Green Guides – flimsy and rarely enforced.  Comment period now open.  For perspectives, read more.

Douglas Hileman Consulting LLC (“DHC”) is pleased to submit comments to the SEC on this matter. The proposal (amending existing rules) would require funds that consider ESG factors in their investment process to disclose additional information regarding their strategy. The amount of disclosure depends upon how “ESG-centric” the fund itself is. It would require information on the impacts they seek to achieve and key performance metrics. The proposal includes greenhouse gas (GHG) emissions as a separate topic for all ESG-focused funds.  (Read More)

Doug returns to Compliance Week’s signature event in Europe in Edinburgh, Scotland.  Much is written about the board and executives, yet the functional leaders – including Compliance professionals – do the heavy lifting.  “the devil is in the details.”  Doug shares ESG expertise with compliance professionals on compiling accurate data, benchmarking, aligning the details with organizational strategy, and a compelling case study. 

https://www.complianceweekeurope.com/

Doug will present at Loyola Marymount University’s prestigious “Business as a Force for Good” Annual Ethics Symposium on October 19, 2022.  Topic: “ESG Reporting:  Like Financial Reporting – and Not.”  Open for in-person attendance.  Business as a Force for Good Annual Ethics Symposium - Loyola Marymount University (lmu.edu)

Doug returns to the IIA Los Angeles Chapter’s fall conference October 18, 2022. 

Doug presents “Internal Audit’s Role in Assurance over Internal Controls over Sustainability Reporting (ICSR).”  Attendees will learn how to apply experience in ICFR to the world of ESG and sustainability reporting.  This is a warm-up to a COSO report linking sustainability and the Internal Controls Framework, due out early 2022.  Doug Hileman is on the core team.  More on the conference (Click Here)

The Uyghur Forced Labor Prevention Act (UFLPA) has been described as “the most interesting law in the world.”  “Interesting” covers a lot of ground.  The provisions of UFLPA are poised to disrupt trade, supply chains, product assembly and sales.  It may affect operations, compliance, financial and non-financial reporting, and strategies for companies in many sectors.  If your company makes or imports apparel or linens that include cotton, this applies to you.  If your company makes anything that includes silica (think chips), it applies to you.  This white paper highlights key provisions and offers takeaways from UFLPA, as well as context and tips.    

PREMISES

• UFLPA isn’t the first law regulating forced labor, including applicability in the supply chain. It is likely the most impactful.  And it may not be the last. 
• UFLPA and other laws, regulations and disclosures collectively are greater than the sum of their parts, in terms of relevance to operations, compliance, (financial and non-financial) reporting and organizational strategy.
• Few companies know what’s about to hit them. Or what already has.
• Companies can leverage the approaches, structures, resources and tools used for

Click here for full report

Douglas Hileman Consulting LLC (DHC) submitted comments on IFRS S1 - General Requirements of Sustainability-related Financial Information. Key points on: GRI; maintain focus on general investor; core content; defining short/ medium/ long-term; quantitative information; Internal Audit; materiality; and consolidated reporting.  Comment letter at:  ISSB S1 Exposure Draft - Sustainability Disclosures; Hileman Comments (ifrs.org)

DHC submitted comments on IFRS S2, Climate Related Disclosures.  Key points on: controls; Internal Audit; defining short/ medium/ long-term; climate resilience scenarios; and value chain risks.  Comment letter at: 

ISSB S1 Exposure Draft - ISSB Climate Disclosures; Hileman Comments (ifrs.org)

SEC Commissioners, Staff, and Stakeholders:

Douglas Hileman Consulting LLC (“DHC” pr “Commenter”) is pleased to provide comment on the SEC’s proposed rule on climate-related disclosures, released March 21, 2022. DHC submitted public input on June 7, 2021, responding to Commissioner Allison Herron Lee’s request for public input. DHC supported SEC actions on climate-related risk then, as we do now. 
(Click Here)

IIA Los Angeles Chapter (recorded)

This special webinar is a walk-through of the SEC Proposed Rule on Climate-Related Disclosures.  An investment of ~37 minutes will make you conversant in all the key subjects of the proposal.  Also with guest presenter Alexandre Rossin, President, Rossin International LLC.  Watch here.