People

Regulatory Framework

  • “some level of assurance” could also be just 1 KPI
    • like C-level renumeration tied to CO2 emissions
  • sus. reports grew from ~30 to ~100 pages
  • handling of financial data is very mature (50+ years) and simple
    • providing assurance is comparably simple as well
  • ESG data handling is not mature yet
    • has not been around long enough to be mature
    • no double-accounting paradigm for ESG data
    • archiving is a difficult topic too
  • some companies do other stuff too apart from ESRS and CSRD
  • CSRD is a directive no obligation until transposed into national law
    • citizens and companies not affected until transposition is done
  • new CSRD give a lot more structure over ISAE 3000
  • IT tools for ESG are numerous
    • a lot will die out - there is a tool for everything
    • not yet 1 dominant tool or 1 industry standard
    • interesting stuff
      • just a file explorer/archiving solution or is much more data processing happening?
      • e.g. a carbon footprint processing tool
        • what are the inputs and the calculations/processes
  • reasonable assurance readiness assessment
    • do you have processes and systems in place to support reasonable assurance someday?
    • no guarantee that reasonable assurance will work out when the deadline hits
  • Assurance
  • Sustainability Reporting has the power to close companies
    • lying about sustainabiltiy to get further credit
    • having to repay financing after fraud becomes public
    • insolvency
  • when reasonable assurance fails a lot of government regulation will follow
    • if there should be a serious case of Greenwashing in ESG reporting the regulations would be revisited
  • site visits
    • where is data coming from - really understanding how the process works and what data is coming from where
    • depends on regional differences and on the people
      • can be friendly and open with some topics, but not with others
      • some just want to get it over with and don’t want to work with you at all
    • e.g. measure waste water values to proof the values of the client are correct
  • sustainability auditing requires a lot more travelling than financial audits

Politics

  • important for companies: should they prepare reports (a lot of costs are involved)
    • if it is not mandatory I might as well wait for a year
  • focus is currently on bigger issues: taxes and budgets
    • no wins/losses with doing something you would have to anyways
  • sustainability reporting is low on the priority list
    • possibility that nobody will talk about it and it will just be passed
      • minimum requirements - resources needed in other places
    • possibility that AT government waits for DE governments decision
      • DE will most likely have a different government too
      • possibility that new government(s) requests changes from EU

Auditors approach & conclusion

  • forming conclusion is very structured and formal
    • processed by lawyers and experts how to formulate every single detail
  • Risk Management
    • media research
      • googling “company + issue”
      • e.g. “Microsoft greenwashing”
      • if not included in report questions

Double Materiality Approach

Key challenges - practical examples

  • under ESRS no quantitative data may have omissions
    • check for completeness required

Q&A / Discussion

  • who are you talking to exactly in the companies?
    • C-suite (whoever is responsible for sustainability)
    • different managers - whoever has important information
      • e.g. won’t ask finance dept about biodiversity
      • mostly those people are spread across a lot of departments - there is normally not 1 sustainability department
    • HR does social matters mostly
  • The better you can read a persons mind the better of an auditor you are
  • for the change to reasonable assurance to happen one needs to proof that being sustainable has benefits - otherwise the companies will protest heavily because of extra incurred costs for no benefit
  • different ways to enforce reasonable assurance other than just requirements for everything
    • e.g. if CEO renumeration is linked to sustainability KPIs
    • e.g. if green bonds are listed on the stock market