Few sectors are more prone to ESG (Environmental, Social and Governance) issues than Consumer & Retail. C&R companies are closely linked to people and the environment, which is creating specific responsibilities and specific dependencies (i.e.: risks). The impact of climate and regulatory changes is far-reaching. How do you manage this and other non-financial risks for your business and do you know what is coming?
The ambition is clear. The United Nations' Sustainable Development Goals (SDGs) have set the global agenda to meet global challenges in the areas of poverty, health and the climate change amongst others. Specifically with regard to climate, the European Commission's Green Deal leaves little to the imagination: by 2050, the European Union must be climate neutral. This seems far away, but regulatory changes are brought into force today which requires immediate action. More and more shareholders, investors and customers are voicing that same opinion: do everything that is possible to make the company resilient for the impacts of climate change - there is no alternative. And this is no longer a nice to have; failure in addressing your non-financial issues can bring serious risks to business: not only risks to brand value (including related fraud risk factors), but also increasing risks from non-compliance with a growing body of legislation, carbon taxes, and physical risks in the supply chain.
Fraudsters are going 'green', brand value at risk
Last January the European Union launched the Green Consumption Pledge and the first companies are committing to concrete actions towards greater sustainability. The Pledge is intended to empower consumers to make green choices, for instance via green products claims such as the carbon footprint of their flagship products. Big and reputable brands can clearly contribute here but, as we also learned from financial fraud cases, with pressure being put on targets and results, this leads to an increase in risks of falsified outcomes. Evidence is increasingly surfacing of organizations that have been involved in the manipulation of their sustainability data. Reasons for this include pressure to comply with regulatory demands, to demonstrate green performance to shareholders, or simply to attract new investors or clients.
Regulatory pressure, a powerful catalyst for change
Legislation such as the Non-Financial Reporting Directive (NFRD) and the increasing number of international guidelines and standards, such as The European Green Deal and the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), are powerful catalysts for change. The NFRD will be updated in 2021 and expectedly this will mean that all companies with more than 250 employees will need to report on ESG. Currently this is only applicable for listed companies with more than 500 employees. Furthermore ESG assurance over this reporting will likely become mandatory. Companies will then have two more years or even shorter to prepare for ESG disclosures (including climate risk) which will have its impact on the underlying (finance) processes.
The European Green Deal has found a forceful tool in the EU Sustainable Finance Taxonomy to deliver on its environmental objectives. The taxonomy covers environmental issues relevant for the C&R sector, such as circularity, pollution, water and again climate change. Within a few years companies eligible under the NFRD will need to report revenues, OpEx and CapEx for activities covered under the EU taxonomy.
For example, for plastics, you would need to report annual operational expenses and investments done to reduce them. If you are in the furniture business, you could be required to report the amount of sales from circular products and again related investments to bring these to market.
Investor and lender scrutiny, securing access to capital
Due to expected regulatory changes and the interest of the financial industry to disclose high portions of EU Taxonomy-aligned investments in their portfolio, many more companies than just the ones eligible under the Non-Financial Reporting Directive (NFRD) will expectedly be requested to report their Revenues, CapEx and OpEx on the basis of the EU Taxonomy categories to secure access to appropriate financing.