Externalities and Sustainability Reporting
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Questions and Answers

Briefly explain the concept of 'externalities' in the context of economics.

Externalities are costs or benefits that affect a party who did not choose to incur that cost or benefit.

Name one framework commonly used for voluntary sustainability reporting.

Global Reporting Initiative (GRI)

What is the primary goal of targeted transparency regulation concerning negative externalities?

To ensure firms disclose information, so that decision makers internalize costs and benefits when making economic decision.

Compare and contrast the Nonfinancial Reporting Directive (NFRD) and the Corporate Sustainability Reporting Directive (CSRD) in terms of their scope and requirements.

<p>The CSRD broadens the scope of the NFRD to include more companies and introduces more detailed reporting requirements based on mandatory EU sustainability reporting standards.</p> Signup and view all the answers

Discuss the limitations of relying solely on mandatory sustainability reporting to drive corporate sustainability, suggesting alternative or complementary mechanisms that might be more effective. Insanely difficult.

<p>Mandatory reporting can lead to boilerplate disclosures and a 'tick-box' approach, lacking genuine commitment. More effective mechanisms include carbon taxes to appropriately price externalities, or perhaps even the establishment of an institution like a federal reserve for the environment.</p> Signup and view all the answers

According to the framework, what are the three broad categories of regulatory approaches to sustainability?

<p>Tax, Faire, and Ban.</p> Signup and view all the answers

Within the 'Faire' category, what specific private sector solution is highlighted as a mechanism for promoting sustainability?

<p>Sustainability reporting.</p> Signup and view all the answers

Briefly describe how stakeholder feedback is intended to function as a mechanism within sustainability reporting to influence firm behavior.

<p>Stakeholder feedback, informed by sustainability reports, is expected to pressure firms to improve their sustainability performance. This pressure can influence firm actions and outcomes.</p> Signup and view all the answers

According to the model, what is the immediate effect of a mandate that improves the quality and quantity of Corporate Social Responsibility (CSR) disclosures?

<p>Stakeholders update their beliefs about the firm.</p> Signup and view all the answers

Define what is meant by 'impact materiality' in the context of externalities.

<p>Impact materiality refers to the significance of the effects that a company's actions have on the environment and society.</p> Signup and view all the answers

Explain the core concept of 'targeted transparency regulation'.

<p>Targeted transparency regulation involves mandating the disclosure of specific information by companies to address particular societal or environmental concerns, aiming to influence behavior and promote accountability.</p> Signup and view all the answers

Name one way in which 'low-performing' firms might attempt to avoid the intended consequences of a mandate for improved CSR disclosures.

<p>Using boilerplate disclosures or omitting material information.</p> Signup and view all the answers

Briefly differentiate between the Non-Financial Reporting Directive (NFRD) and the Corporate Sustainability Reporting Directive (CSRD).

<p>The CSRD expands on the NFRD, requiring more detailed and standardized sustainability reporting, and it also broadens the scope of companies that must comply.</p> Signup and view all the answers

Explain the concept of 'greenwashing' as it relates to firms' responses to stakeholder pressure for sustainability.

<p>Greenwashing refers to firms responding to stakeholder pressure by making superficial or misleading claims about their sustainability efforts, without making genuine changes to their practices.</p> Signup and view all the answers

What is meant by the challenge that stakeholders might 'not care about sustainability' in the context of reporting's effectiveness?

<p>If stakeholders do not prioritize sustainability in their decisions or lack the capacity to act on sustainability information, then improved reporting will have limited impact on firm behavior.</p> Signup and view all the answers

Outline one key limitation of voluntary sustainability reporting.

<p>Voluntary reporting often suffers from a lack of standardization and comparability, making it difficult to assess the true sustainability performance of companies.</p> Signup and view all the answers

Critically evaluate: How might focusing solely on sustainability reporting as a solution be considered a 'red herring' in addressing broader sustainability challenges?

<p>Over-reliance on reporting might divert attention and resources from other potentially more effective interventions, such as direct regulations or economic incentives, that are necessary to achieve significant sustainability improvements.</p> Signup and view all the answers

What is the fundamental idea behind 'internalizing the externality', and how does it relate to sustainability reporting?

<p>Internalizing the externality means incorporating the external costs or benefits of an activity into the decision-making process of the economic agent undertaking the activity. Sustainability reporting can help by making these externalities visible and quantifiable, encouraging companies to consider them.</p> Signup and view all the answers

Critically assess: To what extent can mandatory sustainability reporting be considered a complete solution for addressing negative externalities caused by corporations? What other mechanisms might be necessary?

<p>While it can increase transparency and accountability, reporting alone is not a complete solution. Other mechanisms such as carbon pricing, stricter environmental regulations, and changes in consumer behavior are also crucial for fully addressing negative externalities.</p> Signup and view all the answers

Beyond stakeholder pressure, suggest one other way sustainability reporting could help internalize externalities, leading to more sustainable firm actions.

<p>Sustainability reporting can improve internal firm awareness and accountability regarding their environmental and social impacts, potentially prompting internal changes in strategy and operations, even without direct external stakeholder pressure.</p> Signup and view all the answers

Imagine a scenario where a company meticulously adheres to all requirements of mandatory sustainability reporting, yet its actual environmental impact continues to worsen. What fundamental problem does this highlight?

<p>This scenario highlights the problem that compliance with reporting standards does not necessarily equate to actual improvement in environmental performance. It indicates a potential focus on 'tick-box' compliance rather than genuine efforts to reduce environmental impact, a need for more stringent enforcement, or that the metrics being reported aren't capturing the key drivers of environmental damage.</p> Signup and view all the answers

According to Christensen et al. (2021), how can disclosure regulation support the pricing of negative externalities?

<p>Disclosure regulation can mitigate deadweight loss, which arises when negative externalities are not properly accounted for in market prices.</p> Signup and view all the answers

What is one reason why low-performing firms might not voluntarily provide information?

<p>Low-performing firms may not see net benefits in providing information voluntarily because disclosing their performance might negatively impact their reputation or attract unwanted scrutiny.</p> Signup and view all the answers

Explain how firm-level, private cost-benefit analyses might undervalue the benefits of voluntary reporting.

<p>Firm-level analyses may not account for the positive externalities; disclosures by one firm can provide information about other firms but this is not captured in a private cost-benefit analysis.</p> Signup and view all the answers

In what way does standardized reporting reduce market-wide cost savings?

<p>Standardized reporting reduces duplication in information production and acquisition, making comparisons less costly.</p> Signup and view all the answers

Why is enforcement important in mandatory sustainability reporting?

<p>Enforcement is vital to mitigate boilerplate and greenwashing disclosures.</p> Signup and view all the answers

Briefly describe the difference between the Non-Financial Reporting Directive (NFRD) and the Corporate Sustainability Reporting Directive (CSRD).

<p>CSRD expands upon NFRD, requiring more detailed and standardized reporting on a wider range of sustainability topics and applying to more companies.</p> Signup and view all the answers

What are the two benefits of mandatory reporting?

<p>Mandatory reporting mitigates deadweight loss and creates market-wide cost savings.</p> Signup and view all the answers

Define 'boilerplate' as it relates to sustainability disclosures, and explain why it is problematic.

<p>In the context of sustainability disclosures, 'boilerplate' refers to standardized, generic language that lacks specific, meaningful information about a company's actual environmental or social performance. It's problematic because it provides little insight and can obscure real issues.</p> Signup and view all the answers

Some argue that mandatory sustainability reporting can lead to 'ossification' of best practices. Explain this argument and provide a potential counterargument.

<p>The ossification argument suggests that mandatory standards can become rigid and stifle innovation in sustainability practices because companies focus on compliance rather than exceeding requirements. A counterargument is that mandatory reporting creates a baseline of acceptable performance, driving competition and innovation <em>above</em> that baseline as companies seek to differentiate themselves and attract investors.</p> Signup and view all the answers

Imagine a scenario where a country mandates sustainability reporting but lacks the resources to effectively enforce the regulations. Discuss the potential unintended consequences of this situation, considering both the reporting companies and the stakeholders relying on the reports.

<p>Without effective enforcement, companies may engage in superficial reporting or greenwashing to comply with the letter of the law without making genuine sustainability improvements. This erodes stakeholder trust, distorts capital allocation towards genuinely sustainable companies, and undermines the credibility of the entire reporting regime. It could also create a competitive disadvantage for companies that are making genuine efforts but are indistinguishable from greenwashers due to the lack of scrutiny.</p> Signup and view all the answers

Name the two distinct perspectives associated with 'financial materiality' and 'impact materiality'.

<p>Financial materiality is associated with an 'outside-in perspective', while impact materiality aligns with an 'inside-out perspective'.</p> Signup and view all the answers

Under the NFRD (2014/95/EU), what were the two primary criteria, related to size, that defined a 'Public Interest Entity' (PIE) subject to reporting requirements?

<p>A PIE was subject to NFRD reporting if it had at least 500 employees and met either of these conditions: total assets of EUR 20 million or more, or net sales of EUR 40 million or more.</p> Signup and view all the answers

List three categories of non-financial information that companies were required to include in their CSR reports under the NFRD.

<p>Companies had to report on environmental matters, social and employee factors, and human rights.</p> Signup and view all the answers

According to the public consultation on the NFRD, identify two key deficiencies users perceived in NFRD reports.

<p>Users found NFRD reports deficient in comparability and reliability.</p> Signup and view all the answers

What was the main reporting format used by Wirecard in their NFRD report, and what level of assurance did they obtain?

<p>Wirecard used a 'customized' format for their NFRD report and obtained limited assurance.</p> Signup and view all the answers

In what format will CSRD information be published to enhance digital accessibility and data processing?

<p>CSRD information will be published in digital format (XHTML) to enable digital tagging.</p> Signup and view all the answers

Explain the fundamental difference in the conclusion provided in a 'limited assurance' versus a 'reasonable assurance' engagement under CSRD.

<p>Limited assurance results in a negative conclusion ('nothing has come to our attention to indicate material misstatement'), whereas reasonable assurance aims for a positive conclusion ('sufficient evidence to conclude information is prepared according to standards').</p> Signup and view all the answers

For which category of companies does the CSRD reporting requirement become applicable starting from the financial year 2026?

<p>Listed SMEs (Small and Medium-sized Enterprises) are required to start CSRD reporting for financial years beginning on or after January 1, 2026.</p> Signup and view all the answers

Briefly describe the role of the 'EU Taxonomy' within the broader framework of CSRD and related EU regulations.

<p>The EU Taxonomy is a classification system that defines which economic activities qualify as environmentally sustainable, providing a basis for companies to report on their alignment with environmental objectives under CSRD and related regulations.</p> Signup and view all the answers

If CSRD were to refocus on 'single materiality', primarily 'financial materiality', how might this potentially impact the development and application of the ESRS (European Sustainability Reporting Standards)?

<p>A refocus on single (financial) materiality could lead to a revision of the ESRS to prioritize standards relevant to financial risks and opportunities, potentially downplaying or removing standards related to broader impact materiality perspectives.</p> Signup and view all the answers

Flashcards

Externalities

Actions of one agent affecting another outside the market.

Internalizing the Externality

Making the price reflect the full external costs/benefits.

Regulation

Rules forcing price to reflect external costs/benefits.

Targeted Transparency Regulation

Strategy to address externalities through transparency.

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Sustainability Reporting

Disclosing sustainability information.

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Nonfinancial Reporting Directive (NFRD)

EU directive on non-financial (including sustainability) reporting.

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Corporate Sustainability Reporting Directive (CSRD)

EU directive on corporate sustainability reporting.

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Tax Faire

A private sector approach to addressing externalities, relying on voluntary actions by firms rather than government intervention.

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Tax

A government-imposed solution involving direct taxation to discourage negative externalities.

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Quantity Regulation

A government-imposed restriction that sets a limit on the amount of a good or service that can be produced or consumed.

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Price Regulation

A government-imposed restriction setting the maximum or minimum price for a good or service.

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Target Transparency

The provision of accessible and understandable information about a company's environmental, social, and governance (ESG) performance.

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Change in Stakeholder Decision-Making

When improved transparency leads stakeholders to adjust their perceptions and actions towards a firm.

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Greenwashing

The potential for firms to exaggerate or falsely claim sustainable practices to improve their image without making significant changes.

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Red Herring

Disclosure of non-material information to distract stakeholders from more critical issues.

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What are externalities?

Costs or benefits that affect a third party who did not choose to incur that cost or benefit.

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What is targeted transparency regulation?

Regulations designed to enhance transparency regarding specific company activities or impacts.

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What is sustainability reporting?

The practice of companies publishing information about their environmental and social impact.

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What is the NFRD?

An EU directive that mandates companies to report on non-financial information, including sustainability.

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What is the CSRD?

Aims to make corporate sustainability reporting more common by creating a detailed reporting package.

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How does disclosure regulation mitigate deadweight loss?

Using disclosure rules to help reflect negative externalities in prices.

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What are positive externalities of disclosure?

When the societal value of information is greater than the private value to a firm.

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How does mandatory reporting reduce market-wide costs?

Standardizing reporting to reduce duplicated effort.

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What is Greenwashing?

False or misleading sustainability claims.

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What is mandatory reporting?

Rules require that firms supply this information.

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What is Boilerplate Disclosure?

Incomplete or inaccurate disclosures.

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What does the 'Green' represent on the map?

Countries requiring companies to disclose ESG information.

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What does 'yellow' represent on the map?

Countries not requiring companies to disclose ESG information.

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Why is enforcement important?

Important for sustainability reports, avoids greenwashing and boilerplate.

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Financial Materiality

Impact on the company from external factors

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Impact Materiality

Company's impact on the environment and society

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NFRD (2014/95/EU)

EU directive requiring certain large companies to disclose non-financial information.

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CSRD

An expanded replacement of NFRD that includes more companies and has more detailed reporting requirements.

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Deficiencies of NFRD Reports

Comparability, reliability and relevance of NFRD reports

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Public Support for CSRD

Common reporting standards, audit requirements, digitalisation, and expanded scope

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European Sustainability Reporting Standards (ESRS)

Mandatory standards for sustainability reporting under CSRD.

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Levels of Assurance

Limited provides negative assurance, reasonable (positive) assurance of info

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EU Taxonomy

Classification system to determine what activities contribute to environment objectives.

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Double Materiality Standard

A company must consider its impact financially and on the environment and community

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Study Notes

  • FEM11111 Lecture 4 addresses the question, "Does mandatory sustainability reporting work?"

Course Overview

  • The course addresses five questions, including, “Does mandatory sustainability reporting work?”
  • The course features a guest lecture from Vopak.

Learning Objectives of the Lecture

  • Introduction to sustainability reporting is covered in the first part.
  • The concept of targeted transparency regulation will be explained.
  • The limitations of voluntary reporting will be discussed.
  • The EU regulatory landscape, including the NFRD and CSRD will be reviewed.
  • The key question of the week, "Does mandatory sustainability reporting work?" will be the focus of group work and discussion.
  • Vopak case preparation will be done by working on the second set of questions.

Content for the Week

  • Focus on
    • Pricing of negative externalities
    • Targeted transparency regulation
    • Sustainability reporting
    • Voluntary reporting frameworks
    • Mandatory mandates like the NFRD and CSRD
    • Discussion of whether mandatory sustainability reporting is effective
    • A Vopak case tutorial, references, and an exit ticket

Recap: Remedies for Externalities

  • Externalities arise when one economic agent's actions directly impact another outside the market mechanism.
  • A key issue to consider is "impact materiality"
  • Internalizing the externality involves regulation so that prices reflect the external costs/benefits of transactions.

Reporting as a Solution

  • "Internalizing the externality" can be acheived through: Laissez Faire > Report > Tax > Ban
  • The model involves mandate improving CSR disclosure quality, stakeholders using disclosures, and firms responding to stakeholder pressure to become more suistainable
  • Challenges include boilerplate disclosures, stakeholder apathy, greenwashing, unintended consequences and red herrings

Reporting Solutions

  • Reporting helps internalize externalities
  • Preparing for a mandate increases awareness and learning, as an internal reporting system shows inefficiencies
  • Peer disclosures help benchmarking and disclosing GHG emissions.
  • Transparency reduces ex-ante adverse selection which leads to better capital allocation
  • Changes in societal preferences shifts focus in sustainability
  • Diversity of users, topics, measurement, horizon and materiality are reporting challenges.
  • Global sustainability reporting rates have increased significantly from 1993-2022.

Reporting Frameworks and Standards

  • Voluntary reporting reasons include: Lower costs, attracting investors or analysts, showing profitability, good reputation, insurance, and social license.

Major Frameworks Overview

  • GRI, CDP, IIRC, SASB, and TCFD are major reporting frameworks.

Scope and Adoption of Frameworks

  • EU REGULATORY LANDSCAPE: GRI, SASB, IIRC, ISSB, CDSB, UN Global Impact, NFRD, EU Mandatory, Corporate Sustainability directive

GRI: Global Reporting Initiative

  • Sector and topic standards exist
  • The GRI was founded in Boston in 1997.

GRI Standards

  • GRI 1 (Foundation) outlines the purpose, concepts and principles of GRI standards (accuracy, balance, verifiability)
  • GRI2 (General Disclosures) sets the guidelines for organization's structure, reporting, governance and policies
  • GRI3 (Material Topics) explains how firms determine most relevant topics

Mandates for Mandatory REporting

  • Justification for mandatory mandates includes:
    • Mitigating deadweight loss through disclosure regulation
    • Considering positive externalities and its affect on the public
    • Reduction in duplication so that comparison can be less costly
    • Enforcing boilerplates and greenwashing disclosures is key

Worldwide Regulatory Landscape

  • As of the material, 35 countries have ESG disclosure mandates. Includes both EU and non-EU countries
  • Carrots & Sticks provides regular surveys, categorization, and analysis of ESG regulation. It provides documents and a summary of documents related to sustainability.

EU Regulatory Landscape

  • Landscape includes GRI Standards, SASB Standards, IIRC Framework, ISSB IFRS Sustainability Disclosure Standards, CDSB Framework, UN Global Compact/SDG Disclosures, Non-Financial Reporting Directive, Voluntary Frameworks, Corporate Sustainability REporting Directive, EFRAG European Standards, Taxonomy for Sustainable Activities

NFRD: Nonfinancial Reporting Directive

  • CSR disclosure is Unprecedented act of supranational
  • The reports must be tied to the interest and economy of the EU
  • Specific reporting standards NOT required
  • CSR reports must include information on the environment, society, human rights, and corruption
  • Additional information for the policies and non-financial KPIs must be cited

From NFRD to CSRD

  • Public consultation from Feb to June 2020
  • Users believe that NFRD reports are deficient and 64% state that they receive additional request
  • 82% support common reporting standards and 67% want audit requirments

NFRD Continued

  • Formats are GRI limited
  • Aspects to be included are client, organization employee and GRI

Scope and Standards

  • Expansion to 49,000 firms from its previous 11,6000
  • Mandatory assurance is now a thing

Reporting of Standards

  • Now a corporate SUSTAINABILITY due directive
  • Must report EU taxonomy and SFDR

Does Mandatory Sustainability Reporting Work?

  • Next steps are exit ticket, references and exit tutorial

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Explore externalities in economics and sustainability reporting frameworks like the GRI. Targeted transparency aims to address negative externalities. The CSRD expands on the NFRD's scope, while mandatory reporting alone has limitations.

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