Dialogue on Sustainability Reporting for Virtus Assure

1) Do we need to engage an external consultant to do our company’s Sustainability Reports? Can we do it in-house?
It is not a requirement as big-cap companies such as City Development Limited, CapitalLand Limited and Wilmar International Limited are doing it in-house, using a dedicated department not only to produce the sustainability reports but to implement their group sustainability strategy.

For some smaller-cap listed companies, where resources and manpower are more limited, engaging external consultants has been found to be more cost and time effective.

2) As we have one year from our financial year-end to submit our company’s Sustainability Reports, can we not start preparation after our AGM (Annual General Meeting), where we have more time and resources?
Delaying the preparation of the Sustainability Reports may result in companies not being able to provide a comprehensive reporting of the relevant data gathering and monitoring of environmental, social and governance (ESG) factors.

Let us illustrate with an example:

While the SGX allows companies whose financial year-end is 31st December 2017, a one-year period ending 31st December 2018, to submit their first Sustainability Report, these companies would not be able to do the following if they only started preparing their Sustainability Report after their AGM in April 2018:

a) Gathering and Monitoring of ESG data
Commence gathering and monitoring the data for the chosen ESG factors for the full financial year ending 31st December 2017, that is from 1st January to 31st December 2017.

In 2018, you may not have some of the data required for your chosen ESG factors and most importantly, you would not have been able to take any corrective action against deviation.

b) Materiality of ESG factors
SGX does require the ESG factors you are monitoring/reporting to be material, which needs to be established through stakeholders engagement before you start your monitoring.

c) Board Statement
At each critical stage, SGX requires the Board statement/approval. Hence, before you embark on gathering and monitoring any ESG factors, your respective Board must have approved it; as it would be insurmountable to backdate such approval.

3) Under what circumstances will listed companies NOT have to submit their company Sustainability Reports
Not too many but we would imagine it has to be rather extreme like under receivership, judicial management, bankruptcy or major equity/loan restructuring.

4) We find Sustainability Reporting to be just an added cost and a burden. Is there any value in it?
Yes, in the beginning it seems like added cost and a burden. For companies that have been in this sustainability journey longer, they have found intangible values and the business case to keep them committed. Besides the longer-term intangibles such as better corporate image and branding, the “low lying fruits” include savings from better resource utilization and operational efficiency. Please see an article written by Professor John Lee published in the Business Times, titled “Sustainability Reporting: Going beyond compliance” for some insights into this area..

5) Do we need to do assurance?
It is not mandatory but it will be good to do it, say after a few years of having done sustainability reporting, just to cross-check your processes and explore improvements.