BDO Survey: Fourth-year ESG reporting performance survey shows the evolvement in overall ESG involvement of majority listed companies but which remain inadequate to meet the requirements of the Revised Guide

Listed companies should increase their awareness and take significant steps to enhance their ESG reporting framework to meet the new disclosure requirements and achieve long-term sustainability

HONG KONG SAR – Media OutReach – 12
January 2021 – During the
fourth year of environmental, social and governance (ESG) reporting survey,
improvements have emerged in ESG disclosure in some areas and these are
reflected in the fact that the boards of listed companies are increasingly
aware of the importance of ESG management. However, the survey results are still
far from satisfactory in terms of compliance and quality. In particular, the results
of certain areas, such as ESG risk management and materiality assessment, are
reduced. In this survey, 7 key findings and 12 recommendations are made which
can serve as reference for listed companies to intensify efforts in ESG
reporting and practices, as well as achieve long-term sustainability. 

(From Left to Right) Mr. Ricky Cheng, Director and Head of Risk Advisory of BDO, Mr. Clement Chan, Managing Director of Assurance of BDO and Mr. Johnson Kong, Managing Director of Non Assurance of BDO today announced the Fourth-year survey results of “The ESG Reporting Performance of Hong Kong Listed Companies”

Nowadays, ESG
continue to gain traction in corporate reporting regimes and in the financial
institutions sector from the standpoints of long-term sustainability and
responsible investment. Users and investors are demanding an increasingly high
quality of ESG information disclosures from listed companies so as to
facilitate decisions on investment, interests and values alignment, business
partnerships, and joint efforts to overcome global challenges. In particular,
with the continuing adverse effects of COVID-19 and the revised HKEx ESG
Reporting Guide (“the Revised Guide”) which came into effect on 1 July 2020,
priorities have changed and reinforced public commitment to ESG. The ESG
reporting regime has been evolving in fulfilling users’ increasing expectations
and it is more important to improve ESG disclosure and become aware of the
importance of ESG management, which will enable listed companies to prepare better
to address ESG issues and risks and meet the disclosure requirements
of the Revised Guide. As the world’s fifth largest accountancy network, BDO has always spared no efforts
to conduct comprehensive ESG studies to provide useful findings for use by
listed companies.

This year, BDO’s Survey entitled “The ESG Reporting Performance
of Hong Kong Listed Companies“ (the Survey) randomly sampled 400 of
the most-recent ESG reports published by both Main Board and GEM-listed
companies on or before 31 July 2020. Most of the surveyed companies come from the
Consumer Discretionary sector (20%), followed by Industrials (17%), Financials
(15%), Properties and Construction (11%), Materials (8%), Information
Technology (8%), Consumer Staples (5%), Healthcare (5%), Energy (4%), Utilities
(3%), Telecommunications (2%), Conglomerates (1%) and Others (1%).

Of the 400 companies surveyed:

• 60% were small size, 23% were medium size and large companies comprised
  17%
• The boards of listed
  companies were increasingly aware of the importance of ESG management, with 54%
  (2019: 34%) of the surveyed companies disclosing information about the board’s
  oversight over ESG issues and 74% of the Board’s review of companies’ ESG
  performance against ESG goals and targets

Below
is a summary of the key findings of the 2020 Survey compared to the 2019 Survey
results:

Survey Area	Key Data Points	2019 Survey	2020 Survey	Increase / Decrease / Maintained
ESG governance	Top level commitment and management	34%	54%	Increase
	ESG Committee or personnel	24%	32%	Increase
	ESG risk management	28%	26%	Decrease
	ESG strategy	36%	48%	Increase
Stakeholder engagement		72%	76%	Increase
Materiality assessment		66%	60%	Decrease
Report assurance by independent third party		3%	5%	Increase
Goals on ESG management		15%	13%	Decrease
Staff career development programme		61%	60%	Maintained
Occupational health and safety training		69%	64%	Decrease
Customer support and services		67%	63%	Decrease
Whistle-blowing system		67%	65%	Decrease
Independent committee on anti-corruption management		23%	16%	Decrease
Adoption of reporting standards/guidelines other than HKEx ESG Reporting Guide		9%	10%	Maintained
Anti-corruption training		37%	17%	Decrease

Table 1: Summary of
Key Findings of the Survey on “The Performance of ESG Reporting of Hong Kong
Listed Companies 2020”

Boards are increasingly involved in ESG governance

The Survey results showed that 54% (2019: 34%) of the companies
disclosed information about the board’s oversight of ESG issues. At the same
time, among all the surveyed companies, the boards had gained momentum in
disclosing their involvement in monitoring ESG performance and ESG risk
management approaches in their preparations to meet the mandatory disclosure
requirements of the Revised Guide. Meanwhile, the Survey also found that boards
of large companies (76%) tended to put the most effort into overseeing ESG
issues. On the disclosure of other ESG governance information in ESG reports,
the Survey showed that there was slight improvement in the allocation of dedicated
resources to manage ESG issues and formulate ESG strategy, such as disclosing a
vision, ESG framework and ESG policy.

Reporting quality does not allow for meaningful comparisons

The Survey found that the information disclosed according to the
four reporting principles of the Revised Guide, namely materiality,
quantitative, balance and consistency, was inadequate. On disclosure on the
quantitative, only 48% of surveyed companies disclosed standards,
methodologies, assumptions, calculation tools used, and conversion factors used
for reporting data on emissions or energy consumption. Less than 29% of the
companies cited any changes made to the calculation methods or key performance
indicators (KPIs) that they had used or any other factors that may affect the
comparison of information in the report. Furthermore, only 64% of the companies
disclosed their reporting boundaries in the report. Among companies that
disclosed their reporting boundaries, only 30% explained the method that they
used to determine them.

 

Quality of materiality assessment disclosure is reduced

The Survey results showed that 60% (2019: 66%) of the companies
disclosed that they had conducted a materiality assessment, while the rest or
the remaining 40% did not provide any information about materiality in their
ESG reports. Of the 40%, small listed companies were the most likely not to have
mentioned a materiality assessment. Among companies that conducted a
materiality assessment, disclosed information was often inadequate. Only just
over 50% of those companies provided comprehensive descriptions on how the ESG
issues had been prioritised and they presented the results through visual aids,
such as a materiality map. It is observed that when companies do not disclose
adequate information about their materiality assessments, investors may find it
difficult to ascertain whether the data being reported are relevant to their
investment decisions.

Disclosure of
issues related to climate change is limited

Climate change is a new addition to the Revised Guide. Listed
companies are now required to disclose their policies on identifying and
mitigating any significant climate-related issues that have impacted, or may
impact, and the action taken to manage them. The Survey showed that only 12% of
companies cited issues related to climate change. Among these companies, it is noted
that over half (54%) disclosed the climate-related risks and opportunities that
applied to them; and most (83%) reported on measures that they had adopted to
mitigate their climate-related risks. The Survey also found that larger
companies were more likely to consider climate risks and ways to mitigate them.
Among companies that reported on climate change, only 15% referred to The Task
Force on Climate-related Financial Disclosure (TCFD) when disclosing
information related to climate change. Most of these were large listed
companies from the healthcare, financial and telecommunications industries.

Target-setting for
environment KPIs is limited

Only 15% of companies set targets for environmental KPIs, and
these targets were mainly set by large listed companies. Among these companies,
the most common targets set for environmental KPIs were to reduce waste, energy
consumption and greenhouse gases (GHGs). The companies adopted a variety of
approaches to setting the targets for their environmental KPIs while the most
common ones were to align KPI targets either with the company’s visions and
goals (33%) or with national or regional laws and regulations (40%).

Recognition of UN SDGs on climate
action is stronger

According to the survey results, there is a growing trend of
listed companies recognising the United Nations’ Sustainable Development Goals
(UN SDGs). This year, more of the listed companies (2020: 8% vs 2019: 6%)
identified SDGs that were relevant to their business operations and strategic
goals.

Independent
assurance on ESG reporting remains steady

The Revised Guide recommends that listed companies may seek
independent assurance on their ESG reports. However, the Survey pointed out
that independent assurance was obtained for only 5% of the ESG reports
published by the companies. There were no significant changes in these results
when compared with the results in the previous two years. Among the companies
that sought independent assurance for their ESG reports, 56% obtained assurance
for the whole report.

BDO
recommendations:

Integrate ESG into the enterprise risk-management
framework

In the context of risk management, ESG risks should not be dealt
with separately but must be integrated into a company’s enterprise risk
management (ERM) framework by referring to widely recognised best practice. The
ERM framework should include robust mechanisms to identify and assess the
impact of ESG risks that may influence the company’s strategy and objectives.
At the same time, by considering the challenges and response, the company may
identify new opportunities from predicted trends.

Build capacity on climate change

Given that climate change may affect a company through physical
and transition risks, companies may need to understand the implications of
these risks on financial performance. Climate change is associated with
specialist knowledge and complex technical terms. Therefore, the company’s board or
management may need to rely on the insights, knowledge or external expertise of
sustainability professionals in order to assess the impact of climate risks
during the process of identifying, assessing, prioritising and mitigating
climate risks and other issues. Companies may set up a dedicated committee or
working group to steer climate-change management. A climate change committee aims
to secure board-level oversight of strategic climate-related risk and
opportunity management. A climate change working group can build the company’s
capability relating to climate risk and accelerate the integration of climate
considerations into the ERM framework.

Enhance reporting quality

To increase the reliability and accuracy of the content, any
changes should be explicitly explained in the ESG report. In addition to the
Revised Guide, companies may refer to the Global Reporting Initiative standards
for the relevant reporting principles to enhance the quality of their
reporting. It is also important for companies to have a consistent and well-defined
approach to considering the scope and including appropriate material operations
or entities in the ESG report. Companies with a more complex structure may
apply their own judgment criteria to define the reporting boundaries.

Consider
industry factors

Disclosing factors that are related to a particular industry
could show investors that these industry-specific ESG concerns have been
adequately considered and addressed by the company. Listed companies may refer to
some global reporting frameworks such as Global Reporting Initiative Standards
(GRI) and Sustainability Accounting Standards Board Standards (SASB). These
frameworks provide industry-specific guidelines on reporting a full range of
economic and ESG impacts of operation within a particular industry.

Linking
stakeholder engagement feedback with materiality assessment

It is recommended that companies’ response should be disclosed
alongside stakeholder engagement results so readers may know whether the
concerns raised by stakeholders are material to the company and whether strategies
or measures have been formulated to address them.

Elaborate
the impact of climate change on the business model

Companies are recommended to provide specific details on how
climate change may affect various business model components from a strategic
point of view, in order to enhance their development of a governance structure
to manage climate change risks and to make changes to their business model as
well as their strategic goals and objectives with a view to achieve long-term
sustainability.

Specify the
nature of climate risks that may impact the business

Listed companies should disclose, for example, the kinds of
extreme climate events that would be highly likely to impact the business and
what critical business processes or assets would be affected by these events. Listed
companies should also disclose whether stakeholders that they rely heavily on,
such as customers or suppliers, would also be affected by certain climate
risks.

Alignment
with the goals of the Paris Agreement

While the presence of environmental targets enables companies to
gauge their environmental performance and reduce their impact on operations at an
expected level, companies are recommended to align their strategic goals with
the goals of the Paris Agreement so they can achieve net-zero carbon emission.
Companies may refer to some international methodologies when setting targets
for their environmental KPIs such as Science Based Targets.

Enhancing
the quality of environmental impact disclosure

To give investors a comprehensive overview of the company’s
environmental footprint, companies should disclose more background information
about the environmental KPIs in their ESG report and how KPIs are related to
their business operations. Companies may consider disclosing information, such
as the sources of each environmental KPI, environmental policies and a roadmap to
reduce the impact and long-term and short-term reduction initiatives and action
plans to achieve the targets.

Expanding
disclosure to include Scope 3 emissions

The Revised Guide requires listed companies to disclose direct
and energy-indirect GHGs, for the purpose of transparency and completeness in
presenting the carbon footprint for investors’ understanding. It is recommended
that listed companies may also consider disclosing Scope 3 emissions. There are
up to 15 types of Scope 3 emissions listed in the Greenhouse Gas Protocol.
Listed companies may disclose information about the types of emissions that are
relevant to their individual situation.

Integrating
UN SDGs to create more positive outcomes

There
is a view that companies may benefit from integrating UN SDGs into their
business strategy and operations. Thus, when undertaking SDG reporting,
companies may consider strategies such as identifying and understanding the
impact of all the SDGs and targets on the business portfolio, aligning SDGs
with the strategic targets that may have a critical impact on business
operations and may require significant changes to be made and prioritising the
SDGs and targets.

Ensuring Report
Credibility by External Assurance

To
ensure the credibility and transparency of disclosed ESG data, listed companies
should start by obtaining independent assurance on certain key ESG information,
such as their environmental or social KPIs, instead of the content of the whole
ESG report. Companies may choose to have the whole ESG report assured when
comfortable and accumulating adequate experience in ESG reporting.

Clement
Chan, Managing Director of Assurance of BDO, said, “An ESG
report is a useful tool to communicate to its stakeholders on organisation’s
ESG performance and progress in addressing operating challenges including
climate change. Also, since the COVID-19 pandemic
has caused unprecedented disruption to economies and financial systems, we
believe that green finance is the key to rebuild the economy on a more
equitable foundation as recovery is urgently needed. In this report, we see that companies have made noticeable
improvements in involving ESG strategy. But still, our Survey has found that
there were limited information disclosed to the public which discourage
investors and users with concerns of late over companies’ sustainability
development. Listed companies should now intensify efforts to enhance the
disclosure of ESG information to meet stakeholders’ information and investment
needs, as well as to meet the requirements of the Revised Guide by HKEx.”

Johnson Kong, Managing
Director of Non Assurance of BDO, remarked, “There is no doubt that green finance is getting
more prominent amid the increasing awareness in the investment community, and ESG
are rising on the rise across the world, especially in the healthcare and
information technology realms since the outbreak of Covid-19. Thus, the transparency and accuracy of ESG report are
increasingly important to Investors and capital markets institutions while they
factor ESG performance into investment decisions as they often consider
ESG-related information to determine whether a company is adequately managing
risks, not only to derive reputational benefits. However, our Survey has showed that only a limited
number of companies has reported climate-related issues with restricted
information disclosed. For effective management of ESG issues, we are eager to
see a higher engagement from companies on ESG reporting by elaborating the
topics on the business model”.

Ricky Cheng, Director and Head
of Risk Advisory of BDO, said, “We are pleased to see that there was improvement in ESG
reporting for most listed companies. However, the results are still not satisfactory. Since the HKEx launched
the Revised Guide and effect on 1 July 2020, listed companies are required to
meet higher standards of ESG reporting to fulfil the integrated ESG component.
Users of ESG reports are focusing on relevant and material ESG issues affecting
the business operations of an organisation. They would also like to see the
board of an organisation play a vital role in driving its ESG strategy and in
ensuring the integration of ESG issues into the enterprise risk management
framework, as well as the functions across an organisation. We hope our
suggestions can provide more specific guidelines and directions for companies to improve their ESG
reporting, with the ultimate aim to boost their investment value and inspire
investor confidence”.