Sustainability Reporting under Corporate Sustainability Reporting Directive (CSRD)
概要
TLDRThe webinar on the Corporate Sustainability Reporting Directive (CSRD) covers important aspects of the directive that demands increased transparency and rigor in sustainability reporting. The session, presented by experts from Mazars, offers insights into the legislative requirements, how businesses should prepare, the scoping for various organizations, and the need for robust compliance frameworks. With a focus on double materiality, the CSRD emphasizes the importance of reporting both how companies impact the environment and how they are affected by sustainability issues. Discussion includes the necessary preparation steps, such as stakeholder engagement and data quality assurance, and identifies the transition from limited to reasonable assurance in auditing these reports. Special attention is given to aligning practices across sectors and understanding potential exemptions within the directive. Throughout the webinar, the evolving landscape of sustainability standards and the strategic necessity for businesses to adapt are highlighted.
収穫
- 📊 CSRD enhances sustainability reporting transparency.
- 📅 Phased reporting starts with large companies in 2025.
- 📝 Double materiality is key in reporting requirements.
- 🔍 Data quality and assurance are critical for compliance.
- 🛠️ Preparing for CSRD involves multiple departments.
- 🔒 Limited assurance requires a convincing audit trail.
- ♻️ Transition plans are crucial for alignment with CSRD.
- 🏛️ Finance often leads CSRD reporting in organizations.
- 🌐 Sector-specific standards will soon complement existing CSRD.
- ⚠️ Transparency can pressure companies towards sustainability.
- 🚀 The transition from ESG dominance in reporting to more financial involvement is occurring.
- 🤝 Stakeholder engagement is vital for preparing sustainable reports.
タイムライン
- 00:00:00 - 00:05:00
The webinar, led by Le McKenna from Mazars, focuses on the Corporate Sustainability Reporting Directive (CSRD) and includes speakers Laura Angelin and Emmanuel Ter who discuss the background, scope, and requirements. They highlight the importance of CSRD as a tool for transparency and its impact on clients and auditors. The session stresses the need for companies to align with sustainability objectives while ensuring transparency and readiness for auditing under CSRD.
- 00:05:00 - 00:10:00
CSRD emphasizes transparency over sustainability performance rather than mandating sustainable business practices. Emmanuel Ter highlights the importance of disclosing business objectives and transition plans. Businesses need to align plans with global standards like the Paris Agreement. Transparency under CSRD pressures companies to act sustainably to maintain customer trust and financial stability. Organizations must prepare internally to meet these requirements and ensure robust control and reporting systems.
- 00:10:00 - 00:15:00
Laura Angelin explains the timeline for CSRD implementation and the companies affected, like large listed companies and non-EU entities with significant EU interests. She notes the need for Irish legislation to align with EU-level directives. Changes in scope and thresholds are influenced by inflationary conditions, making it essential for organizations to stay updated on these evolving standards.
- 00:15:00 - 00:20:00
The European Sustainability Reporting Standards (ESRS) guide CSRD reporting, similar to IFRS for financial reporting. Twelve standards will cover a range of E, S, and G topics. Initial implementations focus on identifying material topics for organizations using a structured materiality assessment process. While not all ESRS points apply to every organization, the process helps filter relevant issues. This approach helps organizations gradually adopt their sustainability reporting obligations under CSRD.
- 00:20:00 - 00:25:00
The concept of double materiality, unique to CSRD, assesses both the impact on the environment and communities and the financial impacts of sustainability issues. Establishing this involves evaluating actual and potential impacts over different time frames. Companies must analyze sustainability matters comprehensively. The assessment results guide the material topics which organizations need to report on, ensuring a robust sustainability strategy aligned with CSRD objectives.
- 00:25:00 - 00:30:00
CSRD requires entities to analyze impacts across their entire value chain, particularly for greenhouse gas emissions. However, detailed value chain data is primarily qualitative except for emissions data. Companies should develop indicators, policies, and targets accordingly. Establishing effective impact measures and gathering reliable data is crucial for accurate reporting and strategic improvements.
- 00:30:00 - 00:35:00
Emmanuel Ter discusses the comprehensive nature of CSRD readiness, highlighting the need for cross-departmental cooperation spanning IT, finance, and other operational units. He emphasizes early leadership involvement and strategic planning to anchor sustainability within company operations, aligning transition plans with CSRD standards and establishing reliable internal controls. Emmanuel cautions that implementing these robust frameworks can take substantial time depending on an organization's maturity.
- 00:35:00 - 00:40:00
Developing a sustainability report under CSRD necessitates a thorough materiality assessment, requiring significant stakeholder engagement and benchmarking. Communicating effectively within the value chain and understanding stakeholder demands are vital. Organizations typically start with broad industry benchmarks and refine their list of material topics to achieve compliance. This process is crucial, as it forms the foundation for accurate, auditor-approved, sustainability reporting.
- 00:40:00 - 00:45:00
Quality ESG data is crucial yet challenging due to its unstructured nature. The CSRD requires both historical and forward-looking data, with an emphasis on strategic conformity with established standards like the GHG Protocol. Many organizations face difficulties in data acquisition and governance, impacting their ability to provide reliable and transparent sustainability reports. Clear data management and understanding are vital for maintaining credibility and achieving compliance under CSRD.
- 00:45:00 - 00:50:00
CSRD necessitates careful strategic communication regarding ESG disclosures to prevent reputational risks such as greenwashing accusations. The directive increases accountability and regulatory attention on corporate sustainability statements. Organizations should adopt a verified and compliant approach to ESG reporting, aligning with the New Market frameworks to safeguard against potential litigations and secure stakeholder confidence.
- 00:50:00 - 00:57:18
Laura Angelin highlights the assurance levels under CSRD, introducing limited assurance for initial phases transitioning to reasonable assurance. Organizations must maintain a clear audit trail and consult with assurance providers early on to meet expectations. The transition towards reasonable assurance necessitates meticulous preparation, aligning sustainability information with financial reporting standards and ensuring comprehensive documentation and compliance for accurate sustainability disclosures.
マインドマップ
よくある質問
What is CSRD?
CSRD stands for Corporate Sustainability Reporting Directive, which is a framework outlining sustainability reporting requirements for companies.
Who are the main speakers in this webinar?
The main speakers are Liam McKenna, Laura Angelin, and Emmanuel Ter from Mazars.
What is the purpose of the CSRD?
The CSRD aims to enhance transparency in sustainability reporting and drive companies towards more sustainable practices through detailed reporting requirements.
When will companies need to start reporting under CSRD?
This depends on their size and sector. Large companies will begin in 2025, with others phased in through 2029.
What is double materiality in CSRD?
Double materiality refers to the assessment of both the impact the organization has on the environment and society, and the financial implications of those factors on the organization.
What challenges do organizations face with CSRD compliance?
Challenges include collecting and ensuring quality data, conducting double materiality assessments, and implementing internal controls.
What role does the finance department play in CSRD?
The finance department often oversees the reporting process while the ESG department focuses on strategic sustainability initiatives.
How can companies prepare for CSRD?
Preparation involves conducting a double materiality assessment, assessing and gathering data, implementing internal controls, and ensuring stakeholder engagement.
What is limited assurance and how does it differ from reasonable assurance?
Limited assurance involves concluding based on evidence that nothing has come to the auditor's attention, whereas reasonable assurance involves providing a positive statement about the information's truthfulness.
Are there transitional provisions under CSRD?
Yes, companies have a phased timeline to implement changes, including a three-year allowance for value chain data gathering.
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- 00:00:00everybody and welcome to this webinar on
- 00:00:02the corporate sustainability reporting
- 00:00:04directive um thank you all for joining
- 00:00:06we have a large number today so we're
- 00:00:07delighted to have so many of our clients
- 00:00:10and other interested organizations
- 00:00:12joining us for this webinar um so my
- 00:00:15name is Le McKenna I'm a partner with
- 00:00:17the mazars Consulting team here in
- 00:00:19Dublin I have about 25 years of
- 00:00:21experience working in in financial
- 00:00:24services and and subsequently in
- 00:00:25Professional Services and I've been
- 00:00:28focused on the sustainability topic um
- 00:00:31and sustainability strategies a lot of
- 00:00:33climate related projects since 2019 and
- 00:00:36I suppose more recently in the last six
- 00:00:38months or a year involved in this
- 00:00:39Readiness for csrg which is becoming
- 00:00:42more and more an important topic for our
- 00:00:45clients and and for ourselves here as
- 00:00:47Auditors within mazars I'm joined today
- 00:00:50by Laura angelin who's a also an Irish
- 00:00:53partner in Dublin Laura works on our
- 00:00:55insurance audit and insurance team and
- 00:00:57she's leading the roll out of our CSO of
- 00:01:00preparation obviously we have the
- 00:01:02requirement to train 500 Auditors and
- 00:01:04how to provide Assurance over um csrd
- 00:01:07reporting and is a very large job for us
- 00:01:10we have um Lura participates in our
- 00:01:13Global Network in preparing for this and
- 00:01:15lur is also on some Irish working groups
- 00:01:18within the industry to um I suppose
- 00:01:21identify the St and standardize some of
- 00:01:23the approaches to csrd and the
- 00:01:25documentation required to provide
- 00:01:27assurance and we're also joined today by
- 00:01:29Emanuel ter who's a partner in our
- 00:01:31French firm Emanuel is leading our
- 00:01:33Global csrd projects and teams um and
- 00:01:37he's also the lead partner on a number
- 00:01:39of our multinational clients that are
- 00:01:41engaging us on csrd and so you know he's
- 00:01:44he's probably got a breath of experience
- 00:01:46across quite a large number of
- 00:01:48organizations of different scale and
- 00:01:50complexity So within the um webinar
- 00:01:54today we're going to cover off a number
- 00:01:55of items first off just a little bit of
- 00:01:57the background around csrd and the
- 00:01:59drivers for C s SRD um then get into the
- 00:02:03scoping I think we get a lot of
- 00:02:04questions as to you know who is in scope
- 00:02:07and when are they in scope and you know
- 00:02:09particularly I suppose organizations are
- 00:02:11thinking about that from their own
- 00:02:12context um what are the esrs and the
- 00:02:15these are the standards which are
- 00:02:16driving a lot of what we call the
- 00:02:18materiality assessment and the
- 00:02:20considerations of what you need to
- 00:02:21report on uh preparing then so you know
- 00:02:24how do we actually get from an
- 00:02:26organization which is not currently
- 00:02:28reporting on csrg even nrd with
- 00:02:31precursor um and get them to a point
- 00:02:33where they're going to be delivering a
- 00:02:35robust csrd sustainability report and um
- 00:02:39Laura will then cover off a little bit
- 00:02:41just around assurance and what the
- 00:02:43Auditors would expect and I suppose the
- 00:02:45distinction between what's going to be
- 00:02:47required for initially for csrd versus
- 00:02:50what is required for financial reporting
- 00:02:52because there is a lower level of
- 00:02:53assurance required which will be covered
- 00:02:56off so just as suppose to introduce it
- 00:02:59you know the EU green deal has been
- 00:03:01around for a few years now everybody is
- 00:03:03probably familiar with it to some extent
- 00:03:05and they can see that it's driving a lot
- 00:03:07of change you know here in Ireland um we
- 00:03:09have the climate action plan from the
- 00:03:11government which is is coming from the
- 00:03:12green deal um and and a lot of policy
- 00:03:15and a lot of business investment is
- 00:03:17linked to the requirement to make very
- 00:03:20significant changes to how we operate
- 00:03:23and how how sustainable we are as
- 00:03:25individuals as as families and and as
- 00:03:28organizations in order to get to the
- 00:03:31type of world we want to be in in a
- 00:03:34couple of decades
- 00:03:35time and so the csor is about bringing
- 00:03:39um I suppose transparency to that
- 00:03:41process if we look at the difference
- 00:03:44between the non-financial reporting
- 00:03:46directive and actually even the naming
- 00:03:49of that is interesting we used to talk
- 00:03:51about sustainability be as being not
- 00:03:53something else it's not Financial but
- 00:03:56now it's clearly sustainability is
- 00:03:57something positive in its own right that
- 00:03:59that we need to talk about and address
- 00:04:01and the NFR was been in place since 2014
- 00:04:04it suffered from a number of um I
- 00:04:06suppose issues which are now addressed
- 00:04:08in the csod the first is it was quite
- 00:04:10narrow it was very large organizations
- 00:04:12only that had to report on the uh NF is
- 00:04:15there was no mandatory uh prescriptive
- 00:04:18reporting requirements it was quite
- 00:04:20vague and it allowed for organizations
- 00:04:23to um I suppose report what they wanted
- 00:04:26to report maybe ignore other things not
- 00:04:28apply the level of rigor and discipline
- 00:04:30necessarily required to be able to
- 00:04:32compare
- 00:04:34organizations um and to use the the man
- 00:04:37the mandatory use of limited insurance
- 00:04:38so actually to have some Auditors come
- 00:04:40in and validate it h one thing to point
- 00:04:43out about the csrd is that it's not it's
- 00:04:47you don't need to be a sustainable
- 00:04:49organization to be compliant with the
- 00:04:51csrd what you need to do is identify
- 00:04:54your material aspects and be clear on
- 00:04:57where you stand on those and what you're
- 00:04:59plan are around those if you turn out to
- 00:05:01be a an not unsustainable organization
- 00:05:05in the context of this type of language
- 00:05:07you're still fully compliant if you
- 00:05:08report the I suppose the driver or the
- 00:05:11sense is is that you will suffer from
- 00:05:14you a lack of you know clients and
- 00:05:15customers not wanting to deal with you
- 00:05:18uh access to debt and capital will
- 00:05:19become much more Troublesome um and
- 00:05:22staff may not want to work for you so
- 00:05:24really H and the csrd is not in itself
- 00:05:28going to result in more sustainable
- 00:05:29organizations but the transparency of it
- 00:05:32may do so hopefully I think actually
- 00:05:34Emanuel we we sometimes add a fifth item
- 00:05:36to this do you want to maybe comment on
- 00:05:38this slide that that's that's very
- 00:05:41that's very right what you just said so
- 00:05:43we we're talking mostly about
- 00:05:45transparency with csrd so you have to
- 00:05:48say what you're doing that's a key thing
- 00:05:51but the other thing is also there is one
- 00:05:53fifth item that we sometimes add to that
- 00:05:55list of differences to the NFR which is
- 00:05:58the fact that you need to disclose as
- 00:06:00well what which are your objectives what
- 00:06:02are your transition plans what are your
- 00:06:04adaptation plans and that is not to tell
- 00:06:07you what you should be doing but you
- 00:06:10need to be clear about what you want to
- 00:06:12do and that's quite important because
- 00:06:14also from a communication point of view
- 00:06:17you are making a statement as a company
- 00:06:19and for instance you need to State
- 00:06:22whether or not your transition plan is
- 00:06:25aligned with the Paris agreement of 2015
- 00:06:29and the 1.5
- 00:06:31degree and obviously making a statement
- 00:06:33that your transition plan is far from
- 00:06:36being align with the Paris agreement in
- 00:06:39itself is creating a sense of obligation
- 00:06:42so again there is no formal obligation
- 00:06:45it's all about transparency but through
- 00:06:47transparency comes also some kind of
- 00:06:49pressure because you have to State what
- 00:06:51are your objectives and whether or not
- 00:06:53you are aligned with the Paris agreement
- 00:06:55of
- 00:06:572015 same as with the taxonomy reporting
- 00:07:00you need to say if you are aligned with
- 00:07:03the EU uh sustainability development
- 00:07:06goals so typically your percentage of
- 00:07:08alignment is something that is revealing
- 00:07:11as well about the values and the
- 00:07:14strategy of the company so again
- 00:07:17transparency but giving you a little bit
- 00:07:19of a direction and making sure that uh
- 00:07:23you uh State whether or not your align
- 00:07:26with the objectives of the EU thank you
- 00:07:30so you know and I suppose that what
- 00:07:32organizations need to be clear on is
- 00:07:34getting to a csrd operating environment
- 00:07:38is is a complex and we'll get into it in
- 00:07:41a bit more detail later on but it's a
- 00:07:42very challenging um transition to make
- 00:07:45especially for organizations that
- 00:07:47haven't been reporting on nordd so maybe
- 00:07:49are starting from a a quite immature
- 00:07:51level so it's about you know you need to
- 00:07:53have the data you need to monitor the
- 00:07:55quality of the data you need to have an
- 00:07:57internal control system to to provide
- 00:07:59Assurance over um how much confidence
- 00:08:02you can have in that data and that's to
- 00:08:04report produce the report and then you
- 00:08:06need to get into the the process of
- 00:08:10actually delivering the Assurance
- 00:08:12bringing through the board processes
- 00:08:14reporting reporting it out and look
- 00:08:16ultimately you know maybe we might get a
- 00:08:19Manu to talk about it later but we're
- 00:08:21seeing a transition possibly from a
- 00:08:23sustainability ahead of sustainability
- 00:08:26owning these documents prior to csor to
- 00:08:29possibly others in more the financial
- 00:08:32reporting function getting ownership but
- 00:08:34I'm not going to jump into that now but
- 00:08:36maybe we we'll come back to it at the
- 00:08:37end um so that's I suppose a little bit
- 00:08:40of the background to it Laura now is
- 00:08:43just going to talk about the scoping and
- 00:08:45some more detail on the esrs
- 00:08:49materiality thanks Liam soose as as as
- 00:08:52we've we've heard this already uh in in
- 00:08:55Liam's uh section there the corporate
- 00:08:57sustainability reporting directive is a
- 00:08:59critical piece of legislation and and it
- 00:09:02can be seen as a GameChanger with regard
- 00:09:04to sustainability reporting as it
- 00:09:06basically extend the requirements across
- 00:09:09all sectors and to a larger volume of
- 00:09:12organizations the application of csrd is
- 00:09:15faced around four different group of
- 00:09:17organizations and so around four
- 00:09:20different timing periods for adoption
- 00:09:22and this is presented on the slide there
- 00:09:24the first group of entities in scope are
- 00:09:26the large listed companies with more
- 00:09:28than 500 employees so these are the
- 00:09:31organization that are already in scope
- 00:09:34for reporting certain sustainab
- 00:09:36information under nrd they'll be more
- 00:09:38mature um in their um um ESG and
- 00:09:42sustainability reporting and they are
- 00:09:44expected to report their first csrd
- 00:09:46report in
- 00:09:472025 reporting on 2024 data the second
- 00:09:52group then will include large EU
- 00:09:55companies being those listed and
- 00:09:58non-listed that meet two of the three
- 00:10:00criteria that we present here on the
- 00:10:02slides and their csrg report will have
- 00:10:05to be published in 2026 reporting on the
- 00:10:082025 data then from
- 00:10:122027 reporting on the 2026 data other
- 00:10:15listed entities will be added into the
- 00:10:17scope and again same principle uh
- 00:10:20entities that are meeting two of the
- 00:10:21three criteria presented on the green
- 00:10:23box this this time uh will be in
- 00:10:27scope finally um certain nonu entities
- 00:10:32or groups will also fall uh in scope for
- 00:10:34csrd at a later stage that will be from
- 00:10:372029 reporting on their 2028 data I
- 00:10:42won't go into too much detail today in
- 00:10:44terms of group considerations under csrd
- 00:10:47there's a number of element uh uh that
- 00:10:49that come into um into play um you will
- 00:10:52have a link in the slides that we
- 00:10:54distribute after the webinar to a
- 00:10:56publication on our website that actually
- 00:10:58has
- 00:10:59helpful decision trees and a number of
- 00:11:02case studies that cover a number of
- 00:11:04scenarios in terms of group structure
- 00:11:06that could be helpful uh if this is of
- 00:11:08interest to you but to be very brief um
- 00:11:11non EU entities or groups that are
- 00:11:15generating more than 150 million
- 00:11:17turnover in the EU will be in scope as
- 00:11:20well as groups uh which have at least
- 00:11:23one subsidiary that is considered as
- 00:11:25large or listed company in Europe will
- 00:11:28be in scope um similar then for
- 00:11:30financial reporting and consolidation
- 00:11:32purposes the csrd does allow for
- 00:11:35subsidiary exemption so if an entity
- 00:11:39um um so an entity can be exempt for uh
- 00:11:43presenting at individual level of
- 00:11:45sustainability report if they are
- 00:11:48Consolidated in a group which publish uh
- 00:11:51which publish at a Consolidated level a
- 00:11:54csrd compliant
- 00:11:56report and Laura just maybe a point I
- 00:11:58should made was just around the there is
- 00:12:01still some uncertainty in the sense that
- 00:12:03the Irish legislation has not yet been
- 00:12:05passed is that correct yes correct so
- 00:12:10the the
- 00:12:12csrd is at European level there's a
- 00:12:14requirement then as as for any directive
- 00:12:16to be transposed uh into Irish law the
- 00:12:19deadline for that is early July
- 00:12:222024 so this is in progress um so until
- 00:12:26it's done we can always expect some
- 00:12:28changes or are some elements that that
- 00:12:29may evolve and and maybe to um to add on
- 00:12:33that um the the threshold that you see
- 00:12:36here on the slides my if you have looked
- 00:12:38at that uh even a month ago they have
- 00:12:41changed very recently mid October uh
- 00:12:43there has been an amendments at EU level
- 00:12:45and the threshold have been increased by
- 00:12:4825% and this is to reflect uh for the
- 00:12:51current inflationary environment so
- 00:12:53things are evolving but but but this is
- 00:12:55where we are at the
- 00:12:57moment so we have have discussed now who
- 00:12:59will be in scope uh and in the next
- 00:13:01section I will cover what are the actual
- 00:13:04requirements um in terms of what needs
- 00:13:07to be disclosed so the European
- 00:13:10sustainability reporting standard the
- 00:13:12esrs um that's the reporting framework
- 00:13:16that's being implemented for
- 00:13:17sustainability reporting in the EU the
- 00:13:20same way that we have um the IFRS or the
- 00:13:24Irish Gap FS 102 for financial reporting
- 00:13:27a set of standards a framework has been
- 00:13:30adopted officially now since July 2023
- 00:13:33by the European commission and that's
- 00:13:35dedicated to uh reporting on the
- 00:13:39csrd when uh the csrd directive will be
- 00:13:42transposed into Irish law then the esrs
- 00:13:45will then also be officially enforced in
- 00:13:47Ireland so we commonly refer uh to this
- 00:13:51uh these standards as the set one of
- 00:13:54Standards the set two uh will be made um
- 00:13:59of a number of sector specific standards
- 00:14:02and will complement the complement the
- 00:14:04existing requirements under the set one
- 00:14:07at the moment I think it's about 40
- 00:14:08sectors that have been identified by the
- 00:14:10EU um that are under review and and the
- 00:14:13draft of those sector specific standards
- 00:14:16uh uh is ongoing so there's a bit of
- 00:14:19time uh before these new standards um
- 00:14:21will be effectively added into the scope
- 00:14:24um and also to note that very recently
- 00:14:26the European commission has revised
- 00:14:28their expected timeline pushing the
- 00:14:30deadline by two years so it it's an
- 00:14:33evolving uh um environment um but at the
- 00:14:36moment definitely the focus is on this
- 00:14:38uh uh set one of of standard so ad is um
- 00:14:44as it currently stands the isrs are made
- 00:14:47of 12 standards if we can see on the
- 00:14:51previous slide yeah please um there's
- 00:14:53two general standards and 10 topical
- 00:14:55ones um that are covering elements
- 00:14:57related to your your e environment your
- 00:15:00s social and your G
- 00:15:02governance so when you look uh at this
- 00:15:05list of standard there's a broad range
- 00:15:07of sustainability related topics um and
- 00:15:09disappear very clearly here um in terms
- 00:15:12of structure and to bring a little bit
- 00:15:14of of the language that um are using the
- 00:15:16standards the esrs are composed of what
- 00:15:19we call disclosures requirements 82 in
- 00:15:23total across the 12 standards um and
- 00:15:26each disclosure requirement is then
- 00:15:27broken down into data point which are
- 00:15:30really at a very granular level what is
- 00:15:33actually required to be disclosed in
- 00:15:35relation to um uh sustainability matters
- 00:15:40we're talking about more than 1,000 data
- 00:15:42points across the the
- 00:15:45esrs um so reflecting on what we already
- 00:15:50uh we've already seen um disclos in
- 00:15:53organization in Ireland um and you know
- 00:15:58um sustainability disclosures that we
- 00:16:00already see in financial statements for
- 00:16:01example climate change related
- 00:16:03disclosures are often captured um to a
- 00:16:06certain to a good extent within the
- 00:16:08director's report um we see as well um
- 00:16:12we tend to see disclosures related to
- 00:16:14diversity and inclusion um and that
- 00:16:17seems to be captured to a certain extent
- 00:16:21we have the G the gender pay Gap
- 00:16:23requirement in Ireland and that's
- 00:16:24supporting this but really when you look
- 00:16:26at the other uh topics there
- 00:16:29um there there's a number sorry there's
- 00:16:31a number of new elements um that that
- 00:16:33are involved here and that needs to be
- 00:16:35considered and and and assessed sooner
- 00:16:38than later um it is an extensive scope
- 00:16:42um in terms of sustainability
- 00:16:43information that that are captured under
- 00:16:46csrd um and and you know we we we can't
- 00:16:49understate that but as part of the csrd
- 00:16:53journey when implementing csrd um it's
- 00:16:56expected that in the first place
- 00:16:58entities entities will be able to
- 00:17:00eliminate naturally a number of these
- 00:17:03requirements because they'll be just not
- 00:17:05applicable not relevant to the entity so
- 00:17:08when you will actually start the the
- 00:17:10work and the analysis uh in terms of
- 00:17:13what's relevant to your organization you
- 00:17:15will start from a preliminary list of
- 00:17:17relevant topics and that won't be the
- 00:17:19full uh um 1,000 plus data points that
- 00:17:23I've mentioned there then embedded into
- 00:17:26the SRS one standard is a very
- 00:17:29prescriptive um methodology to conduct a
- 00:17:32double materiality assessment on those
- 00:17:35relevant topics and that will ultimately
- 00:17:37give you a list of material topics so
- 00:17:40you start with everything that's there
- 00:17:42naturally you remove what what is not
- 00:17:45relevant not applicable after that you
- 00:17:47do your materiality assessment which
- 00:17:49will allow you to eliminate a number of
- 00:17:52other um aspects and you end up with a
- 00:17:54list of material topics and these are
- 00:17:57the one that we need to to be uh
- 00:17:59reported on so I'm I'm conscious I want
- 00:18:01to keep time for um question there um so
- 00:18:06I'll I'll just refer to um a document
- 00:18:11that we publication we have on our
- 00:18:13website on esrs that go into a bit more
- 00:18:15detail in terms of this double
- 00:18:17materiality assessment in terms of the
- 00:18:19content the structure and and a bit more
- 00:18:21in terms of the spirit and what we're
- 00:18:23trying to achieve across those those
- 00:18:24isrs um I'll take a couple of minutes uh
- 00:18:28just to focus on double materiality
- 00:18:29assessment It's A New Concept um
- 00:18:31completely New Concept brought in by um
- 00:18:34the the csrd and it will require
- 00:18:38companies to disclose information on
- 00:18:40sustain sustainability matters um under
- 00:18:44that double materiality uh uh principle
- 00:18:47so a sustainability matter will be
- 00:18:50material if it meets criteria of either
- 00:18:54being um material for imp impact
- 00:18:58materiality and financial materiality
- 00:19:01are both so this concept of double
- 00:19:03materiality is introducing the impact
- 00:19:05materiality and the financial
- 00:19:06materiality so when you conduct a double
- 00:19:09materiality assessment um you have to uh
- 00:19:12take into
- 00:19:14account um not only the impact that the
- 00:19:17entity have on their people the
- 00:19:20environment the communities but also how
- 00:19:22the entity itself is impacted by
- 00:19:25external
- 00:19:27factors this this assessment of of
- 00:19:30materiality
- 00:19:32um and focusing on the impact
- 00:19:35materiality
- 00:19:37um will include different elements so
- 00:19:40actual and potential impact will need to
- 00:19:43be consider positive and negative impact
- 00:19:47shortterm medium term longer term so
- 00:19:50it's as I was saying there's a very
- 00:19:51prescriptive uh methodology that that's
- 00:19:53set up there um and and a number of
- 00:19:56elements that needs to be consider
- 00:19:58considered when I when assessing the
- 00:19:59materiality and the impact one when it
- 00:20:01comes to the financial materiality um
- 00:20:04this is probably closer to what we're
- 00:20:06used to uh uh use on the financial
- 00:20:09reporting side uh s um to to to assess
- 00:20:13the effect of sustainability matters on
- 00:20:15the entity's cash flow development
- 00:20:18performance uh uh cost of Capital Access
- 00:20:22to
- 00:20:23finance if we can move on to the last
- 00:20:25slide Liam please um there there's a
- 00:20:29last point that I wanted to make um in
- 00:20:32in respect of the esrs and and really
- 00:20:34what's expected from the companies under
- 00:20:36the standard so csrd brings in the
- 00:20:40necessity to take into account the value
- 00:20:42chain of the entity when considering
- 00:20:45what are the material topics applicable
- 00:20:46to that entity and preparing the
- 00:20:48reporting so the idea behind that is
- 00:20:51that the environmental fprint of a
- 00:20:53specific organization is impacted by
- 00:20:56both the upstream and the stream Valu
- 00:20:58chain participant as well as the The
- 00:21:01Entity itself so as to the entity itself
- 00:21:05and that's what we're present there on
- 00:21:06on the slide the sustainability
- 00:21:08reporting should cover the iros iros is
- 00:21:11a concept uh included in in csrd it
- 00:21:15refers to your impact your risk your
- 00:21:17opportunity so when you have identified
- 00:21:19a sustainability matter relevant to you
- 00:21:22this sustainability matter may have
- 00:21:24impact may have risks may have
- 00:21:26opportunities you have to disclose
- 00:21:28policy Target actions Emanuel referred
- 00:21:31to that earlier um and also include a
- 00:21:33number of indicators and and Matrix um
- 00:21:36under the csrd we estimate that
- 00:21:39approximately a third of the data points
- 00:21:41are quantitative and twoth third are
- 00:21:45qualitative when it comes to the value
- 00:21:47chain the iros the policy the targets
- 00:21:50the actions will also need to be
- 00:21:51disclosed as far as they are relevant to
- 00:21:53the entity's activities but then in
- 00:21:56terms of quantitative disclosure it it
- 00:21:58will be mainly the ghg emission
- 00:22:00disclosures that will be expected so I
- 00:22:03don't want to take as suppose too much
- 00:22:04of a shortcut here but it's expected
- 00:22:07that sustainability disclosures in
- 00:22:09respect of the value chain will be
- 00:22:12mainly quanitative in nature the spir
- 00:22:15the spirit of CSR is to understand and
- 00:22:17present the the environmental footprint
- 00:22:20of the organization including its its
- 00:22:23ecosystem but in terms of quantification
- 00:22:26this is really targeted to the to the
- 00:22:27enti specific metrics um Emanuel can I
- 00:22:31invite you there if you want to share
- 00:22:33any or any insight or add anything to
- 00:22:35that oh definitely I think it's
- 00:22:37something to to really keep in mind that
- 00:22:39when we talk about precise data when we
- 00:22:42talk about indicators and kpis for the
- 00:22:45value chain this is limited more or less
- 00:22:48to the greenhouse gas emissions so
- 00:22:52basically the the biodiversity kpis or
- 00:22:55other kind of kpis or even social kpis
- 00:22:58uh may not be relevant or may not be
- 00:23:02required uh for you to publish and
- 00:23:06that's also taking into account the fact
- 00:23:08that basically it's pretty tough to get
- 00:23:10that information right so we' be talking
- 00:23:13about data later on but at the end of
- 00:23:16the day there is a a point of making
- 00:23:20your information more transparent more
- 00:23:22relevant and for that you need to make
- 00:23:24sure that the information is available
- 00:23:27obviously for ghg uh emissions this is
- 00:23:30something that is possible that because
- 00:23:32the carbon footprint now is a concept
- 00:23:34that is uh relatively widely used at
- 00:23:38least in Europe and second there are
- 00:23:40also some ways through proxies through
- 00:23:43estimates to calculate the carbon
- 00:23:45footprint of your value chain so that's
- 00:23:47basically the only area where there will
- 00:23:49be a strong requirement for data for the
- 00:23:52rest it's going to be more qualitative
- 00:23:54kind of information that would be that
- 00:23:56would be required
- 00:23:58thanks thanks Emanuel so we've clarified
- 00:24:01what is csrd who is in scope we've
- 00:24:04introduced the reporting framework so
- 00:24:06Emanuel if that's okay I'll hand over uh
- 00:24:08to you again to cover some practical
- 00:24:10steps as to how we can prepare for
- 00:24:13csrd thank you Laura so um I'm leading
- 00:24:19our CSR task force uh globally at Mazar
- 00:24:23so I have a chance to see how CSR
- 00:24:26projects are actually
- 00:24:28implemented uh from Ireland to Poland if
- 00:24:31we just look at the EU but in fact we
- 00:24:33are also doing csrd projects in the US
- 00:24:36or even in Asia for Asian clients
- 00:24:38typically with subsidiaries in uh in the
- 00:24:42EU what we observe we see two big phases
- 00:24:46basically the first phase is with
- 00:24:48analysis and planning and the second
- 00:24:50phase is about implementation at the end
- 00:24:52of the day you'll tell me and no big
- 00:24:54deal that's kind of standard ways of
- 00:24:57condu any transformation project and
- 00:25:00that's true however what we need to keep
- 00:25:02in mind is that this is a transformation
- 00:25:04project which is not only for reporting
- 00:25:06but that will also have some impacts in
- 00:25:08terms of operations in terms of strategy
- 00:25:11so one key message maybe from from that
- 00:25:13slide beyond the fact that you have
- 00:25:15those two phases that need to be clearly
- 00:25:18identified one key message is that a
- 00:25:21csrd Readiness project requires the
- 00:25:23involvement of many different
- 00:25:26departments and you need really Embark
- 00:25:28people from the beginning with the same
- 00:25:31vision with the same view on what are
- 00:25:33the objectives of the project and how to
- 00:25:35get there you'll need people from the IT
- 00:25:38department you'll need people from the
- 00:25:40finance department HR
- 00:25:43operations and the on and so forth
- 00:25:45internal audit plenty of people will be
- 00:25:47involved because this is really an all
- 00:25:49encompassing project because this is so
- 00:25:53large and wide uh wide reaching that's
- 00:25:57why you always need to start with uh
- 00:26:00making sure that you have unboarded your
- 00:26:03top leadership what we are doing right
- 00:26:05now we're are doing plenty of
- 00:26:07presentations to the board audit
- 00:26:09committee but also to the board of our
- 00:26:12clients and as well to the executive
- 00:26:14committee of our clients and that's very
- 00:26:16important because then they understand
- 00:26:18and they are uh clear about what are the
- 00:26:21objectives of the project but also they
- 00:26:24understand the implications of csrd
- 00:26:26implications with regards to their
- 00:26:28clients implications with regards to
- 00:26:30potential financing issues the banks
- 00:26:32will cut uh the flow of financing if
- 00:26:36there is no csrd report that is
- 00:26:38compliant and also at some point of time
- 00:26:40if it's not in the right direction let's
- 00:26:41be clear about that so really there are
- 00:26:43some strategic issues that the top
- 00:26:45management needs to be aware about and
- 00:26:47that's why you always need to make sure
- 00:26:49you have the sponsoring at the right
- 00:26:51level then as Laura was explaining you
- 00:26:55move into double materiality assessment
- 00:26:56to know what you're going to disclose
- 00:26:58about what is significant for you what
- 00:27:00is really something material that you
- 00:27:01need to to to talk about and you move on
- 00:27:05with the kind of the traditional way of
- 00:27:06conducting projects with a with a gap
- 00:27:08analysis uh checking also taxonomy which
- 00:27:11is always a specific thing and you need
- 00:27:14to have your compliance road map what we
- 00:27:16observe that this first phase will last
- 00:27:19between two and three months usually
- 00:27:22because you need a lot of back and force
- 00:27:23making sure you have the right
- 00:27:24consultations and so on and so forth but
- 00:27:26you need at three months to to put
- 00:27:29together your compliance role map and
- 00:27:31then you have your implementation phase
- 00:27:32and your implementation phase it depends
- 00:27:34on your maturity if you already have a
- 00:27:37strong NFR kind of reporting or ESG
- 00:27:41report then that a lot of things will be
- 00:27:44relatively easy because you have already
- 00:27:46people who know what they're talking
- 00:27:48about who know uh who have put in place
- 00:27:52this kind of reporting uh processes and
- 00:27:55you will not start from scratch if if
- 00:27:57you have nothing obviously uh you're not
- 00:28:00that mature in terms of ESU reporting
- 00:28:03and it's going to be a much longer
- 00:28:05process so you for phase two a mature
- 00:28:07organization will take about 12 months
- 00:28:10maybe to to get
- 00:28:12there operations a company that has not
- 00:28:15yet really started in terms of ESU
- 00:28:17reporting may may need 18 months you
- 00:28:20have several P just let me talk about
- 00:28:23two of them one is uh internal control
- 00:28:26environment OB that's a new requirement
- 00:28:29for from csrd to align the quality of
- 00:28:33the ESG reporting with the quality of
- 00:28:36the financial information that's a clear
- 00:28:38statement a clear objective of the EU to
- 00:28:40make sure that both information ESG and
- 00:28:44um financial information are with the
- 00:28:46same quality level that's why we we have
- 00:28:48audit right that is being introduced as
- 00:28:50a as a mandatory step for for csrd but
- 00:28:53for that and that's also specifically
- 00:28:55stated in the csrd
- 00:28:58you also need to make sure you have an
- 00:28:59internal control environment and by the
- 00:29:01way in
- 00:29:0320228 when the entire EU is moving
- 00:29:06towards uh reasonable Assurance well you
- 00:29:09need to have a reliable internal control
- 00:29:11environment for the auditor to be able
- 00:29:13to issue its opinion so just one one
- 00:29:16reminder make sure you have the internal
- 00:29:18control environment that will allow you
- 00:29:20to deliver qualitative data but also
- 00:29:23that will allow you to monitor your kpis
- 00:29:26because it's not only about reporting
- 00:29:28it's also about making improvements uh
- 00:29:30let's be very clear the first reporting
- 00:29:33you're going to discover a number of
- 00:29:35things and you'll have some questions
- 00:29:37from the top management why do we have
- 00:29:39this why do we have that and so on why
- 00:29:41are we so bad compared to the uh
- 00:29:43competition so there will be Improvement
- 00:29:45plans that will be launched and without
- 00:29:47internal control you won't be able to to
- 00:29:49follow up on that second point I want to
- 00:29:51to Second module if you want that I want
- 00:29:54to to point out is a transition plan you
- 00:29:57need to disclose a transition plan so
- 00:29:59there are some transitory
- 00:30:02uh Provisions in the csrd or in the esrs
- 00:30:06but you need to have a transition plan
- 00:30:08and most companies they won't be able to
- 00:30:11avoid having a transition plan on E1
- 00:30:14which is about climate change because
- 00:30:15somehow climate change that's something
- 00:30:17that's relevant for all companies right
- 00:30:20so you need to make sure you have a
- 00:30:21transition plan the transition plan is
- 00:30:23something that's quite technical you
- 00:30:25need to put it in place with uh being
- 00:30:26comp with sbti which is a standard to to
- 00:30:30put together the carb accounting if you
- 00:30:32want and those transition plans will
- 00:30:35require you to make sure you have either
- 00:30:38the internal experts uh working on it or
- 00:30:41that you have also the the right people
- 00:30:43assist you in putting them together from
- 00:30:46a technical point of view but also from
- 00:30:47a compliance point of view because the
- 00:30:49transition plans need to according to
- 00:30:51the csrd to comply with a number of
- 00:30:54specific steps so those are the the key
- 00:30:57uh messages I I wanted to to share with
- 00:30:59you is really making sure you have the
- 00:31:02right sponsoring making sure you are on
- 00:31:05boarding all the different departments
- 00:31:07uh which are relevant for this kind of
- 00:31:09project and focus your attention on uh
- 00:31:14key issues that need to be addressed
- 00:31:15early on if you are not a mature uh ESG
- 00:31:19reporting mature company like the
- 00:31:22transition
- 00:31:24plans thank you Emanuel so
- 00:31:27maybe one of the aspects of phase one
- 00:31:30that Emanuel highlighted and obviously
- 00:31:32Laura has also spoken about it which is
- 00:31:34relatively new to most organizations is
- 00:31:36the double materiality analysis and
- 00:31:39Laura pointed out about the impact on
- 00:31:41financial materiality and uh taking both
- 00:31:44lenses but we get a lot of questions
- 00:31:47around this and it's probably within
- 00:31:48phase one the aspect that takes the most
- 00:31:51amount of time uh in order to get it
- 00:31:53right because ultimately if you don't
- 00:31:55report on the material topic the correct
- 00:31:57material topics you're not going to be
- 00:32:00um provide your Auditors are going to
- 00:32:01have challenges around that when they
- 00:32:03come to provide you with limited
- 00:32:05Assurance so maybe the the first thing
- 00:32:07about this is it is it requires quite a
- 00:32:09lot of stakeholder engagement like as a
- 00:32:11at the start of the um materiality
- 00:32:14assessment you're going to draw a value
- 00:32:15chain which would have upstream and
- 00:32:17downstream organizations in your value
- 00:32:19chain and and also the stakeholders um
- 00:32:22and if your stakeholders are uh for
- 00:32:24example uh investment organization
- 00:32:27they're also going to have to report on
- 00:32:29the sfd or so you know they're going to
- 00:32:31be demanding certain things from you and
- 00:32:33require certain data so understanding
- 00:32:35who it is is your stakeholder who is
- 00:32:38going to use this report and for what
- 00:32:40purposes in the future um is key to
- 00:32:43making sure that you you know you engage
- 00:32:45the right organizations you engage the
- 00:32:47right stakeholder groups in order to
- 00:32:50assess your materiality and come to a
- 00:32:51conclusion on
- 00:32:53it um one of the I suppose the question
- 00:32:57then becomes how do you gather all of
- 00:32:58the data an organization an insurance
- 00:33:00Organization for example is going okay
- 00:33:02well you know if we want to assess our
- 00:33:04materiality first off we want to make
- 00:33:06sure we're not out of line with
- 00:33:07everybody else but also how do we gather
- 00:33:10all of the information about upstream
- 00:33:11and downstream and what our stakeholders
- 00:33:13believe um so there are a number of ways
- 00:33:16first off we need to do a benchmarking
- 00:33:18exercise whenever you're starting the
- 00:33:20materiality assessment and if you look
- 00:33:21actually you can look yourselves anybody
- 00:33:23at the sasb um database on benchmarking
- 00:33:26data it has I think it has about 80
- 00:33:29different Industries in there at the
- 00:33:30moment and it will highlight what the
- 00:33:32most material items are within each of
- 00:33:35those so for example in Professional
- 00:33:36Services um which obviously Miss ours is
- 00:33:39it has data security ethics diversity H
- 00:33:43an inclusion as as some of the core
- 00:33:45topics um as Emanuel has said everybody
- 00:33:48really has climate as a material item
- 00:33:51but it's what you build on top of that
- 00:33:53that
- 00:33:53matters um so there's a number of I
- 00:33:56suppose thirdparty organizations that
- 00:33:59can provide us with some sort of
- 00:34:00benchmarking material which is is
- 00:34:02relevant we also then need to go out and
- 00:34:04talk to stakeholder groups so that would
- 00:34:06be staff um shareholders investors um
- 00:34:11you know key suppliers and key clients
- 00:34:14and really a lot we generally start with
- 00:34:18staff groups who can represent these
- 00:34:21individuals and then we go out and have
- 00:34:22further conversations with the
- 00:34:24individuals there is an opportunity to
- 00:34:26use some survey type techniques we found
- 00:34:29limited ability to use what we get back
- 00:34:32in the surveys H in order to be able to
- 00:34:35provide the level of assurance that's
- 00:34:37needed in order to satisfy the Auditors
- 00:34:40so at the moment it you know we're doing
- 00:34:42more actual direct engagement Workshop
- 00:34:45documentation review and then using
- 00:34:47survey tools more as a um a validation
- 00:34:50exercise um as opposed to actually
- 00:34:53coming forward with everything another
- 00:34:55Point actually that's that Laura made
- 00:34:56made earlier on was that we're we're
- 00:34:58currently at the first set of the esrs
- 00:35:01which are the global set and we will get
- 00:35:03into industry specific esrs and we also
- 00:35:06ultimately you can get into company
- 00:35:07specific esrs and so while we're at the
- 00:35:10point uh right now where we don't have
- 00:35:12the industry specific ones and they may
- 00:35:14not be here for a little bit of time the
- 00:35:17esrs we don't take it that they are the
- 00:35:19total potential requirements right so
- 00:35:22there's 82 disclosures within the esrs
- 00:35:24but when we're doing the materiality
- 00:35:25assessment you know we step back and we
- 00:35:27go let's take this from the bottom up is
- 00:35:29there anything else that's very specific
- 00:35:31to our organization to our industry
- 00:35:33which isn't yet built into the E ORS um
- 00:35:36and and then you know take it up from
- 00:35:38that point and decide if it's material
- 00:35:40so with the materiality we find it's
- 00:35:43probably 50% of the effort that we apply
- 00:35:46in Phase One of of these projects right
- 00:35:48now and it involves all of that and
- 00:35:51takes a significant amount of time in
- 00:35:53order to get it right and in order to
- 00:35:54get the the um the reporting to a level
- 00:35:57or the analysis to a level that's going
- 00:35:59to satisfy Auditors like ourselves or
- 00:36:02other Auditors in the future um Emanuel
- 00:36:06just maybe with regard to some of the
- 00:36:08challenges do you want to say a few
- 00:36:09words on on
- 00:36:10data sure well I want to be very short
- 00:36:13because I want to leave time of course
- 00:36:16for for questions later on and
- 00:36:18interactions maybe with this those
- 00:36:21listening to us but one thing that needs
- 00:36:23to be U clear to everybody that there is
- 00:36:26a real challenge uh with the ESG data
- 00:36:29compared to what we know about the pure
- 00:36:32data for instance one it's a very much
- 00:36:34unstructured and unstandardized we're
- 00:36:37not talking always about euros and
- 00:36:39dollars for instance we're talking about
- 00:36:41uh liters of water and then kilowatts of
- 00:36:45of energy electricity and that's a
- 00:36:47little tricky the second thing which is
- 00:36:50quite important in terms of ESG data
- 00:36:53that we need to keep in mind is that uh
- 00:36:57with regards to csrd there is a
- 00:36:59historical reporting that needs to be
- 00:37:01done but there is also a very large
- 00:37:03portion that is about prospective
- 00:37:04information I've been talking about the
- 00:37:06transition plan there are other examples
- 00:37:08in the sris that require um prospective
- 00:37:12information and that's something that's
- 00:37:13a little tricky and that companies are
- 00:37:15not necessarily used to do uh all the
- 00:37:18time um there are plenty of those
- 00:37:20elements and that's why in our last CET
- 00:37:24barometer data quality uh was identified
- 00:37:27as one of the main challenges for ES
- 00:37:30reporting and Data Tracking tracking as
- 00:37:33well obviously and that's something that
- 00:37:34we are really uh in on helping our
- 00:37:38clients to make sure that they have
- 00:37:39control around that and that they know
- 00:37:41what they are talking about this last
- 00:37:43point is important that they know what
- 00:37:44they're talking about too often what we
- 00:37:47realize is that people really don't
- 00:37:49really understand and contr rationalize
- 00:37:53the information that they disclose in
- 00:37:54theg reporting too often we have seen
- 00:37:58clients uh reporting numbers with three
- 00:38:01zeros uh in terms of number of liters of
- 00:38:04water consumption for instance uh three
- 00:38:07zeros more than was the actuals and
- 00:38:10nobody noticed because people are not
- 00:38:13used to consider whether this is a
- 00:38:16million liter of water that is a water
- 00:38:18consumption or if it's 10 million liters
- 00:38:21you are used to know if the net result
- 00:38:24is 10 million EUR or 22 million EUR but
- 00:38:27you don't know exactly what is the water
- 00:38:29consumption and you you don't have the
- 00:38:31benchmarks you don't have the the
- 00:38:33referential so that's something that
- 00:38:35really is is critical to understand that
- 00:38:38the data is different and that it's
- 00:38:40really a challenge to extract and
- 00:38:42aggregate the data in a way that can be
- 00:38:45uh controlled by uh the central
- 00:38:47functions of the
- 00:38:49companies if we move to the next uh
- 00:38:52slide and that would be maybe the right
- 00:38:54way to to to finish that that
- 00:38:56presentation is also to remind people
- 00:38:59that with uh the csrd it's a very strong
- 00:39:04strategic exercise but that's also a
- 00:39:06communication exercise which is
- 00:39:08something that uh people subject or
- 00:39:11companies subject to nrd are used to
- 00:39:13because the NFR was really started as
- 00:39:16being a communication exercise in many
- 00:39:17ways but here that's really becoming a
- 00:39:20strategic communication issue because
- 00:39:23green washing is in in the mouth of uh
- 00:39:27everybody and there are plenty of risk
- 00:39:29that are coming with the csrd
- 00:39:31disclosures plenty of new
- 00:39:32responsibilities that will be uh coming
- 00:39:35also for the the audit committee for the
- 00:39:39board and also for the company itself
- 00:39:42there are more and more information that
- 00:39:44are out there about ESG and more and
- 00:39:47more cases of
- 00:39:49litigations uh on uh ESG green washing
- 00:39:54so that's really something that needs to
- 00:39:55be uh dealt with carefully because
- 00:39:59typically for lit companies as well esma
- 00:40:03which is the European Association of uh
- 00:40:05Market Regulators just published uh csrd
- 00:40:09and ESG reporting and one of the top
- 00:40:11priorities to make sure that it's uh
- 00:40:13that it's correct so I can only urge uh
- 00:40:17our clients to adopt a very cautious and
- 00:40:21compliance approach compliant approach
- 00:40:23to ESG reporting to make sure Al that uh
- 00:40:28the company is not taking uh too much
- 00:40:31risk by being overly optimistic maybe
- 00:40:33about its own ESG foodprint so that's
- 00:40:36really a balance that needs to be uh uh
- 00:40:39that needs to be found for each company
- 00:40:42to make sure that they are not taking
- 00:40:43additional risk through this uh ESG
- 00:40:48publication thank you Emanuel so I think
- 00:40:50Laura maybe will just finish off with a
- 00:40:53little bit on auditing and Assurance
- 00:40:55levels yeah thanks Liam so I was
- 00:40:58referring earlier to the csrd being a
- 00:41:01game changer with regard to
- 00:41:02sustainability reporting this is also
- 00:41:04very true with regard to the Assurance
- 00:41:06requirement that will now be in place so
- 00:41:09in Ireland until now there was no
- 00:41:11Assurance required for entities subject
- 00:41:14to mandatory sustainability reporting
- 00:41:16under NFR this is something completely
- 00:41:18new um that is brought in by the the
- 00:41:22csrd so the requirement during the
- 00:41:25implementation phase
- 00:41:26when I say implementation phase I'm
- 00:41:28referring to 2025 to 2029 for the four
- 00:41:31groups to come into scope um the
- 00:41:35entities will be uh required to obtain
- 00:41:37limited Assurance on their
- 00:41:39sustainability reporting it is then
- 00:41:42expected that the limited Assurance will
- 00:41:44be replaced by reasonable Assurance at
- 00:41:47some point indication at the moment are
- 00:41:50referring to reporting in 2030 so in
- 00:41:532029 data that's the initial timeline
- 00:41:56online but is yet to be confirmed uh um
- 00:41:59so we we'll see when that transition but
- 00:42:02the intention is there and this is
- 00:42:04important to know from the beginning
- 00:42:06because you know from day one in in the
- 00:42:08project knowing that it will move to a
- 00:42:10reasonable um assurance that allow us to
- 00:42:13get ready from the beginning and and
- 00:42:14don't have to do this kind of catch up
- 00:42:16or or or um amendments um at at a later
- 00:42:20date um briefly to touch on the
- 00:42:23difference between the two level of
- 00:42:24assurance um limit Assurance is when a
- 00:42:28practitioner will include in their
- 00:42:31conclusion um a negative sense so based
- 00:42:34on the procedures performed nothing came
- 00:42:37to our attention whereas under
- 00:42:39reasonable assurance and reasonable
- 00:42:41Assurance it was what we do uh on
- 00:42:44statutory audit it's a positive
- 00:42:46conclusion that it's provided so the
- 00:42:48financial statements give a true and
- 00:42:49Fair View of the financial position of
- 00:42:52the company so you can see that the
- 00:42:53extent of procedures required and the
- 00:42:55audit report um would be broader under
- 00:42:58reasonable Assurance versus limited
- 00:43:00Assurance in the first place um so a
- 00:43:04third party an auditor will have to be
- 00:43:06engaged by by organizations in order to
- 00:43:08review their sustainability report um
- 00:43:10and that can be the statutory auditor
- 00:43:13that is already engaged to do the
- 00:43:14financial statement um
- 00:43:17audit just to finish and then we'll move
- 00:43:20on to the Q&A um I just wanted and and
- 00:43:23I'm putting my Auditors cap on there I
- 00:43:25wanted to share two comments two
- 00:43:26recommendation um with you um on the
- 00:43:29Assurance topic the first one is the
- 00:43:32importance to consider from day one of
- 00:43:35the csrd Readiness project in your
- 00:43:38organization The Limited reasonable
- 00:43:40Assurance review that will be perform so
- 00:43:43this is to ensure that from the
- 00:43:44beginning you have a proper audit trail
- 00:43:46that is kept um that the work perform
- 00:43:49the analysis you run the various aspects
- 00:43:52that have been considered are all
- 00:43:54documented that the decisions the
- 00:43:56conclusion re reached are supported so
- 00:44:00if you think about the double
- 00:44:01materiality assessment that we've
- 00:44:02discussed previously the degree of of
- 00:44:05Judgment of interpretation is is high is
- 00:44:08a topic material if not what led me to
- 00:44:11that conclusion um should I consult with
- 00:44:14this type of stakeholders how have I
- 00:44:16decided that um all of that it's very
- 00:44:19it's very critical to have from the
- 00:44:21beginning uh a very clear audit Trail
- 00:44:24and supporting evence that can
- 00:44:26ultimately be provided to the Assurance
- 00:44:28provider so they can review and
- 00:44:30corroborate your conclusions and then
- 00:44:32ultimately your your green
- 00:44:34disclosures the the second Point um that
- 00:44:37it could be beneficial to engage early
- 00:44:40with your anticipated Assurance provider
- 00:44:43even if that's only going to uh you know
- 00:44:45be in 206 2026 or 2027 for you um we
- 00:44:50have to remember that uh csrd Assurance
- 00:44:54is new for everyone um and by having
- 00:44:56this early engagement you can ensure
- 00:44:58that you get the inputs and the views
- 00:45:00from the party will be ultimately
- 00:45:02assessing your disclosures so getting an
- 00:45:05understanding of their um their
- 00:45:07expectation in terms of assessment
- 00:45:10documentation governance all of that can
- 00:45:13prevent surprises at a later stage but
- 00:45:15most importantly can prevent um having
- 00:45:17to revisit certain aspects or to go back
- 00:45:20and document again things that you've
- 00:45:22done um in the past so I'll I'll stop
- 00:45:26here um these were kind of the the the
- 00:45:29the key points we we wanted to share
- 00:45:31with you uh thank you very much for for
- 00:45:34uh joining us today on that and Liam
- 00:45:36I'll end over to you and I think we we
- 00:45:38have received some interest some
- 00:45:39interesting questions yeah we have we
- 00:45:42have quite a number of questions so I
- 00:45:43might try and bundle them together I
- 00:45:45I'll maybe take one and then I'll I'll
- 00:45:47ask Emanuel the next one so we've had a
- 00:45:49couple of questions around timing and I
- 00:45:50think Emanuel said you know you're
- 00:45:52looking at probably 12 weeks is to do
- 00:45:55phase one and then you're looking at a
- 00:45:57year to 18 months or maybe longer
- 00:46:00technology implications you know to to
- 00:46:02deliver the project I think the key
- 00:46:04thing we're finding is that
- 00:46:07organizations are being asked questions
- 00:46:08they haven't seriously considered in the
- 00:46:11past and so um it's one thing to be able
- 00:46:14to get to the point that you can
- 00:46:15actually deliver a report which your
- 00:46:17Auditors will stand over it's another
- 00:46:20thing for you to be proud of what that
- 00:46:22report says and not to be racing at the
- 00:46:25last minute to try and control the I
- 00:46:27suppose The Narrative around negative
- 00:46:29reporting so I think what we're seeing
- 00:46:31is
- 00:46:33um most organizations well I would say
- 00:46:35the vast majority of organizations that
- 00:46:37are going to be reporting at the end of
- 00:46:392024 are already um well through their
- 00:46:42project um there are we are seeing
- 00:46:44strugglers at this point but um they are
- 00:46:47challenged in the sense that they're you
- 00:46:49know if they need to capture data from
- 00:46:51the start of 2024 they're not going to
- 00:46:52be able to do so if they're if they're
- 00:46:54not already delivering their project
- 00:46:56now we that's not to say we aren't still
- 00:46:58being asked to Tender for projects even
- 00:47:01now for 2024 year end but really we've
- 00:47:04probably seen since September
- 00:47:06organizations that are really in the
- 00:47:082025 year end start to engage um more
- 00:47:12effectively on this so I think we're
- 00:47:14probably looking at you know 18 months
- 00:47:18to two two and a half years really to
- 00:47:19get on top of all of
- 00:47:21this Emanuel a question for you which is
- 00:47:24is probably there's there's a couple of
- 00:47:25there's one question which is very
- 00:47:26specific around the role of Enterprise
- 00:47:28risk management in the entire process
- 00:47:31but maybe you can put it in the context
- 00:47:33of ownership and of the implementation
- 00:47:36and the delivery of csrd more generally
- 00:47:38if there's an Enterprise risk management
- 00:47:40link please put it
- 00:47:44in you're mute there sorry apologies um
- 00:47:49yes uh well that's quite important to
- 00:47:52include the ERM approach uh
- 00:47:56in the materiality assessment phase for
- 00:47:59instance because typically what many
- 00:48:02companies have been doing in the past
- 00:48:04they were uh reporting on risk mapping
- 00:48:09and uh including uh ESG kind of risk
- 00:48:13that they were disclosing about and
- 00:48:14that's very consistent with the approach
- 00:48:16that needs to be followed for the
- 00:48:18materiality assessment and typically
- 00:48:20those risk mapping could be in many
- 00:48:22cases the basis or the feeding the
- 00:48:26materiality assessment so Enterprise
- 00:48:28risk management uh is really part of the
- 00:48:32resources that are going to be uh
- 00:48:35included in the modality assessment uh
- 00:48:39process thank you and then more
- 00:48:41generally on ownership of sustainability
- 00:48:44the the the entire
- 00:48:45process so on on the ownership what we
- 00:48:48observe is that if we look at the NFR
- 00:48:51reports very often it was uh owned by
- 00:48:55the ESG Department of the company of
- 00:48:57large companies they all have ESG
- 00:48:59department and so on and so forth now we
- 00:49:03do a lot of uh calls presentations and
- 00:49:06projects on csrd Readiness for clients
- 00:49:11almost all of them uh in all of them
- 00:49:14sorry in all of them we have the finance
- 00:49:16department involved and in most of them
- 00:49:19we have the lead of the project that has
- 00:49:22moved from the ESG Department to the
- 00:49:25finance department and which is
- 00:49:27basically turning um things in the right
- 00:49:31order in my mind because that's really
- 00:49:33looking at csrd as being a transparency
- 00:49:36reporting exercise and the finance
- 00:49:40department is used to the tricks of
- 00:49:43reporting sometimes more than the ESG
- 00:49:45department and that is really putting
- 00:49:47back the ESG department at the core of
- 00:49:50what it should be which is basically
- 00:49:52working on the strategy and at making
- 00:49:55sure that the company is on the long run
- 00:49:58sustainable so we are seeing again a a
- 00:50:02realignment of the roles and
- 00:50:03responsibilities of the various
- 00:50:05departments within the the companies
- 00:50:07with Finance taking the the role for
- 00:50:09reporting and the ESG Department taking
- 00:50:12the lead for the for the operations and
- 00:50:16the ESG strategy thank you um Laura
- 00:50:20maybe if I bundle a couple of questions
- 00:50:22here together so one is around
- 00:50:24exemptions with regards the esrs and the
- 00:50:26transitional requirements but then
- 00:50:28there's a second question around um er
- 00:50:31frag announcement in October around the
- 00:50:33delayed release of the standards and
- 00:50:35does that have any any impact on what
- 00:50:39should be done now yeah yeah so I
- 00:50:41suppose to start maybe with the the
- 00:50:43exemptions um the the short answer is is
- 00:50:46yes embedded within the SRS um um are a
- 00:50:50number of transitional Provisions um so
- 00:50:54not to go into the the level of detail
- 00:50:55but three categories the first one which
- 00:50:57is very important um is the fact that
- 00:51:00there is no requirement for disclosures
- 00:51:02of comparative information in the first
- 00:51:04year so basically first report you
- 00:51:07provide the information for the current
- 00:51:09year and then coming to the second one
- 00:51:11you bringing the prior year in so
- 00:51:13there's no there's no exercise to do on
- 00:51:16comparative in the first year the second
- 00:51:18one is um a threeyear
- 00:51:22delay um for collecting information
- 00:51:25around the value chain that is uh that
- 00:51:27is a loow now this is on the principle
- 00:51:30of comply or explain so it's requirement
- 00:51:34is there to um comply with with the
- 00:51:37disclosures requirement but if it's not
- 00:51:40possible uh because of the complexity or
- 00:51:43the time uh uh needed to gather all the
- 00:51:46right information you have this
- 00:51:48threeyear period though for elements
- 00:51:50that are not complied with and not
- 00:51:52disclosed you will have to show uh um in
- 00:51:56your report why information is not
- 00:51:58available the plan for remediating and
- 00:52:01the timeline for the remediation so um
- 00:52:05it's not that you can leave aside
- 00:52:06certain elements you still have to have
- 00:52:08a plan in place um to know how to get
- 00:52:11there in terms of the disclosures and
- 00:52:13then the third group um um certain
- 00:52:16specific uh disclosures related to
- 00:52:18entities so entity specific disclosures
- 00:52:21um will be subject to exemptions and
- 00:52:23have a sort of a a faed in um um
- 00:52:29approach that uh certain elements we
- 00:52:31need to disclose from year one certain
- 00:52:33elements are tagged as being required
- 00:52:35only from from year two um and and then
- 00:52:38maybe a quick word on the on the second
- 00:52:40question so um the sector specific
- 00:52:44standards will
- 00:52:47bring a more structured framework in
- 00:52:51terms of what expected from each o of
- 00:52:53the sectors but but still as part of
- 00:52:56your assessment under the set one um
- 00:52:59standards and and this is coming from um
- 00:53:02the esrs 2 um you still have to consider
- 00:53:07the material sustainability matters for
- 00:53:09your entity so from that an element of
- 00:53:13sector specific um aspects relevant to
- 00:53:16you will be captured so what the sector
- 00:53:19specific uh um standards will bring up
- 00:53:22is a more structured align making sure
- 00:53:24that uh you know there's better
- 00:53:26comparability within the organization
- 00:53:28but still an element of sector specific
- 00:53:31information will be captured naturally
- 00:53:33as part of the assessment that you do
- 00:53:36thank you Laura um we have a number of
- 00:53:39very specific questions about scoping
- 00:53:41going from NOS to Charities to UK
- 00:53:44companies to International groups and I
- 00:53:46would say to individuals that maybe if
- 00:53:48they want to you everybody wants us to
- 00:53:51tell them the answer to their particular
- 00:53:52situation so if you want to email us we
- 00:53:55can do that afterwards individually as
- 00:53:56opposed to try and uh address your
- 00:53:59specific situation and then say well we
- 00:54:01don't really know if this applies to you
- 00:54:02because you haven't given us the detail
- 00:54:04so if you do want to know the answer to
- 00:54:06that you can email us afterwards um
- 00:54:08there's a couple of questions around I
- 00:54:10suppose systems um so you know how are
- 00:54:13we going to capture the data and gather
- 00:54:15the data and certainly yeah we think you
- 00:54:17know we certainly in mazars have a
- 00:54:19global system that we use for our csrd
- 00:54:22preparedness um which will have you know
- 00:54:25climate module a social module an
- 00:54:28ethical module so there is yeah you're
- 00:54:30going to need to start to consolidate
- 00:54:33this data in using spreadsheets to for
- 00:54:36example report your uh carbon emissions
- 00:54:39and being able to stand over that from
- 00:54:41an insurance perspective is very
- 00:54:43difficult so more and more we are seeing
- 00:54:45systems being put into place which
- 00:54:46obviously that draws out the time
- 00:54:49required to deliver these projects I
- 00:54:51don't know Emanuel were you did you want
- 00:54:52to jump in no to to your point actually
- 00:54:55we've done there are a number of new
- 00:54:58systems new editors who are putting out
- 00:55:02um ESG reporting system that claim to be
- 00:55:05align with csrd so that's a good thing
- 00:55:08it's not uh the right solution for
- 00:55:10everyone depending on the size and
- 00:55:12complexity of the information of the
- 00:55:14organization but what we've done at
- 00:55:16Mazar our Global team
- 00:55:18as csrd task force has already reviewed
- 00:55:22200 of the softwares he reporting
- 00:55:25softwares that are out there in Europe
- 00:55:28and has rated them them so we have done
- 00:55:31already this kind of work of reviewing
- 00:55:33200 of those systems and we've been able
- 00:55:36to rank them depending on what is the
- 00:55:38objectives and find a way as well for uh
- 00:55:42our clients to to match their
- 00:55:44requirements so we've been working quite
- 00:55:46a lot on this uh ESG uh reporting
- 00:55:49systems we are not recommending
- 00:55:51specifically one of those systems but uh
- 00:55:54we have a view on uh how those systems
- 00:55:58could fit with the specific requirements
- 00:56:01of each
- 00:56:03company thanks Emanuel um probably just
- 00:56:05one last question um just around
- 00:56:08greenhouse gas reporting and you know is
- 00:56:10there standards within it no you you
- 00:56:12would use the greenhouse gas protocol
- 00:56:14and you would apply the same sort of
- 00:56:16scope and boundaries as would apply in
- 00:56:18the greenhouse gas protocol to do that
- 00:56:21yeah this is this is actually the the
- 00:56:23recommendation Al the guidance
- 00:56:25uh that is being issued by in esrs eana
- 00:56:29is basically to look at the at the
- 00:56:31greenhouse gas protocol yes so
- 00:56:34unfortunately we've come to the end of
- 00:56:35our time and we have a large number of
- 00:56:38additional questions so I would say many
- 00:56:41of them are from Anonymous attendees
- 00:56:43where people have included their name we
- 00:56:45we'll go back to them we have your email
- 00:56:47address from the registration if you
- 00:56:48have the anonymous attendees if you want
- 00:56:50to submit your question to myself or or
- 00:56:53any of the other team members you could
- 00:56:55do so these slides will be circulated
- 00:56:57and I think our email addresses are um
- 00:57:00included here in the last page so again
- 00:57:03thanks so much for uh uh we have a very
- 00:57:06large crowd here today we're delighted
- 00:57:08to have so many people engaged and we
- 00:57:10appreciate you coming along and uh thank
- 00:57:12you very much and have a great day bye
- 00:57:15now byebye
- CSRD
- Corporate Sustainability
- Sustainability Reporting
- Double Materiality
- Assurance Levels
- ESG
- Compliance
- Sustainability Strategies
- EU Green Deal