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Business and finance community respond to the proposed IFRS Sustainability Disclosure Standards

On this page:

  • Two statements, from Chief Financial Officers and institutional investors, respond to proposed IFRS Sustainability Disclosure Standards, created by the International Sustainability Standards Board (ISSB).
  • Both communities call for global alignment on sustainability reporting and for the ISSB to strengthen their proposed standards in a number of ways.
  • CFOs set out six areas for the ISSB to address to achieve effective sustainability reporting standards.
  • Investors call for decision-useful data that considers both environmental and social impacts on a company as well as the company’s impact on the environment and society.


The call for global alignment

86 global Chief Financial Officers from around the world and institutional investors representing more than £620 billion in assets under management, convened by A4S, have signed respective responses to the consultation for the proposed IFRS Sustainability Disclosure Standards. The statements welcome the role of the IFRS and the proposals, but also encourage them to revisit and further develop some of the proposed requirements for when the final standards are released.

Based on their experience in providing both financial reporting and sustainability-related disclosures, the CFO signatories have set out six areas for the ISSB to address to achieve effective sustainability reporting standards. This includes further alignment, to considering dynamic materiality, and to quickly move on to address a broader set of environmental, social and economic factors.

This group of CFOs represents organizations from Asia Pacific, Europe, North and South America, signalling a broad consensus for globally-aligned sustainability standards.

“Businesses and investors need transparency and consistency to be able to invest in a sustainable future. The adoption of a common set of sustainability standards is pivotal in meeting these needs and no one is better positioned than the ISSB to play this role globally. Time is running out and the business and finance community need to meet the moment. Let’s seize this opportunity to achieve global alignment through the proposed ISSB standards so that companies and investors can focus on action.” George Quinn, Group Chief Financial Officer, Zurich Insurance Group


Investors need decision-useful data

The disclosure of robust, comparable and decision-useful information is vital for investors, and others, to assess an entity’s performance and impact, supporting the allocation of capital needed to achieve a sustainable global economy. Institutional investors, including chairs of pension schemes, have therefore supported a high-level response to the proposed IFRS Sustainability Disclosure Standards. The response welcomes the role of the ISSB and the call for global alignment, but – as investors in the real economy – the group calls for the ISSB to strengthen their inclusion of factors beyond those narrowly impacting enterprise value.

As the International Sustainability Standards Board (ISSB) develops global standards on sustainability-related financial disclosures, we – as investors – have a significant and unique opportunity to signal to the global market what data needs we really have for investment decisions. Understanding the impact the entity’s activities has on wider society is just as important as understanding the risks and opportunities affecting the entity’s enterprise value. As users of sustainability data, we must ask the ISSB to enhance the proposed global standards and deliver a watershed moment on decision-useful, sustainability data.” Russell Picot, Chair, HSBC Bank (UK) Pension Trust and Co-Chair, A4S Asset Owners Network


Reporting is a means to an end

Sustainability factors can present both risks and opportunities to organizations, but without the right information neither businesses nor investors will be able to make fully informed decisions.

In determining what disclosures are required, the focus needs to remain on enabling action. Reporting is a means to an end, not an end in itself.

Companies that operate over different jurisdictions spend valuable resources reconciling reporting requirements across multiple standards. Resources that should be focused on action.

Reporting is not an end in itself. Global alignment on sustainability disclosure standards are needed so that organizations can focus on action, rather than reconciling the ‘alphabet soup’ of requirements across jurisdictions. This is why the ISSB and other standard setters need to listen to the call from CFOs and investors to establish a common set of global standards which will provide the information needed to deliver ambitious targets and action.” Jessica Fries, Executive Chair, A4S

* Please note that by signing these statements the individuals are not endorsing directly the A4S individual response to the ISSB.

Make your voice heard by adding your name to the list

To add your name to one of the statements, please email info@a4s.org

The Statements

The CFO Statement

Dear International Sustainability Standards Board,

As a group of Chief Financial Officers (CFOs) convened by Accounting for Sustainability, we welcome the ISSB’s consultation on the first two IFRS Sustainability Disclosure Standards. The disclosure of robust, comparable and decision-useful information is vital to address climate, and other environmental and social, risks and opportunities.

As CFOs from a wide range of sectors, we recognize that sustainability disclosures are most effective when they inform decision making – providing comparable, relevant information to investors and other stakeholders. We believe that the ISSB is well-suited to establish a comprehensive baseline which will enhance compatibility and interoperability and, ultimately, enable consistent and comparable information to assess an entity’s performance and value.

As the executives responsible for reporting at our organizations, we have been developing the systems and processes needed to prepare robust sustainability-related information in an efficient manner. Based on our experience in providing both financial reporting and sustainability-related disclosures, we believe sustainability reporting standards must:

  1. Align with relevant existing and emerging sustainability reporting standards to ensure harmonization and convergence, to the greatest extent possible. There is an urgent need for a global set of internationally recognized sustainability disclosure standards that should build upon the work of the existing bodies, enabling continued convergence and promoting widespread global adoption. The ISSB is in a good position to deliver on this, but it will need to accelerate work with other existing and emerging standard setters to align strongly the concepts, terminology, definitions and effective dates. Reporters need clear guidance and complimentary sets of standards to be able to provide decision-critical sustainability information efficiently and effectively.
  2. Consider the dynamic, industry-specific nature of materiality and provide clarity around the assessment of users’ expectations on what constitutes enterprise value, recognizing that investors may need disclosures on broader social and environmental impacts to assess risk and inform investment decisions. Clarity on the application of materiality will be particularly important in the context of the changing understanding of environmental and social risks and opportunities over time.
  3. Have clear definitions and guidelines that enable preparers to report in a transparent, consistent and comparable manner. This will help to underpin assurability and limit the need for extensive footnotes and supplemental disclosures.
  4. Recognize that reporting is a means to an end, not an end in itself. Unless the practical challenges around data accuracy and completeness are recognized and addressed within reporting and assurance standards, there is a risk that companies will avoid setting the ambitious targets needed to drive innovation and will divert effort into reporting instead of action. Providing the necessary time and provisions for companies to put in place appropriate processes, controls and technology is essential.
  5. Connect to financial reporting standards and promote integrated thinking as illustrated through frameworks such as the Integrated Reporting Framework.
  6. Address the broad set of environmental, social and economic issues that materially impact decision making. It is necessary to move quickly to other topics after climate to capture the interconnectedness of all sustainability topics.

Moving forward, it will be essential that the ISSB is agile. It must respond to real world feedback on the practical application of its standards, and incorporate evolving risks and opportunities associated with social and environmental factors.

We hope that sharing the above observations, based on our extensive experience with reporting and disclosure, will assist the ISSB in the development of the IFRS Sustainability Disclosure Standards. We commend your work to date and support your intention to develop a global, comprehensive baseline for sustainability disclosures. 

The Signatories

  • Lars Kramer, Vice Chairman and Chief Financial Officer, ABN AMRO
  • José Angel Tejero Santos, Chief Financial and Sustainability Officer, Acciona
  • Ray Young, Vice Chairman, ADM
  • Natalie Knight, Chief Financial Officer; Member Management Board and Executive Committee, Ahold Delhaize
  • Maarten De Vries, Chief Financial Officer, AkzoNobel
  • Paul Verhagen, Chief Financial Officer, ASM International
  • Roger Dassen, Chief Financial Officer, ASML
  • Debbie Clifford, Chief Financial Officer, Autodesk
  • Paul Donofrio, Vice Chair, Bank of America
  • Hetwig van Kerkhof, Senior Vice President Finance, BESI
  • Lars Machenil, Chief Financial Officer, BNP Paribas
  • Bhavesh Mistry, Chief Financial Officer, British Land
  • Julie Brown, Chief Operating and Financial Officer, Burberry
  • Andrew Lim, Group Chief Financial Officer, CapitaLand Investment Limited
  • Andrew Bonfield, Chief Financial Officer, Caterpillar
  • Maarika Paul, Chief Financial Officer, CDPQ
  • Philippe Blondiaux, Global Chief Financial Officer, Chanel
  • Scott Herren, Executive Vice President and Chief Financial Officer, Cisco
  • Heather Taylor, Chief Financial Officer and Treasurer, City of Toronto
  • Patrice Impey, Chief Financial Officer, City of Vancouver
  • Bettina Orlopp, Deputy Chairwoman, Chief Financial Officer, Commerzbank
  • Eddy Van Rhede, Chief Financial Officer, Corbion
  • Ben Almanzar, Chief Financial Officer, Coca-Cola HBC
  • Stephan Engels, Group Chief Financial Officer, Danske Bank
  • Chng Sok Hui, Chief Financial Officer, DBS Group
  • Neil Manser, Chief Financial Officer, Direct Line
  • Melanie Kreis, Chief Financial Officer, DP DHL
  • Keith Taylor, Chief Financial Officer, Equinix
  • Marc Rivers, Chief Financial Officer, Fonterra
  • Barbara Geelen, Chief Financial Officer, Fugro
  • Jose Filippo, Chief Financial Officer, Grupo Fleury
  • Iain Mackay, Chief Financial Officer, GSK
  • Javier Echave, Chief Financial Officer, Heathrow
  • Gavin Van Boekel, Chief Financial Officer, Heijmans
  • Steve Voskuil, Senior Vice President, Chief Financial Officer, Hershey
  • Ewen Stevenson, Group Chief Financial Officer, HSBC
  • David Zinsner, Chief Financial Officer, Intel
  • Tim Nicholls, Senior Vice President and Chief Financial Officer, International Paper
  • Kevin Monteiro, Executive Director and Chief Financial Officer, Japfa
  • Erik Swelheim, Chief Financial Officer, KLM
  • Chris Figee, Chief Financial Officer, KPN
  • Vanessa Simms, Chief Financial Officer, Landsec
  • Harmit Singh, Executive Vice President and Chief Financial Officer, Levi Strauss & Co
  • William Chalmers, Executive Director and Chief Financial Officer, Lloyds Banking Group
  • Philip Witherington, Chief Financial Officer, Manulife
  • Claus Aagaard, Chief Financial Officer, Mars
  • Chaye Cabal-Revilla, Executive Director, Chief Finance Officer, Chief Sustainability Officer and Chief Risk Officer, Metro Pacific
  • Mark Kaye, Chief Financial Officer, Moody's
  • Andy Agg, Chief Financial Officer, National Grid
  • Silvia Vilas Boas, LatAm Chief Financial Officer, Natura & Co
  • Katie Murray, Group Chief Financial Officer, NatWest
  • Renier Vree, Chief Financial Officer, Nouryon
  • Rishi Kalra, Executive Director and Group Chief Financial Officer, Olam Food Ingredients
  • Jonathan Simmons, Chief Financial and Strategy Officer, OMERS
  • Abhijit Bhattacharya, Chief Financial Officer, Philips
  • Pim Berendsen, Chief Financial Officer, PostNL
  • Martyn Roberts, Group Chief Financial Officer, Ramsay Health Care
  • Henry Schirmer, Chief Financial Officer, Randstad
  • Geraldine Matchett, Co-Chief Executive Officer and Chief Financial Officer, Royal DSM
  • Ewout Steenbergen, Executive Vice President and Chief Financial Officer, S&P Global
  • Kevin O'Byrne, Group Chief Financial Officer, Sainsbury's
  • Amy Weaver, President and Chief Financial Officer, Salesforce
  • Manfred Seah, Chief Financial Officer, SATS
  • Douglas Wood, Chief Financial Officer, SBM Offshore
  • Hilary Maxson, Executive Vice President and Group Chief Financial Officer, Schneider Electric
  • Maria Ferraro, Chief Financial Officer, Siemens Energy
  • Javier van Engelen, Chief Financial Officer, Signify
  • Ken Bowles, Group Chief Financial Officer, Smurfit Kappa
  • Birgit Conix, Chief Financial Officer, Sonova
  • Gregor Alexander, Finance Director, SSE
  • Seppo Parvi, Chief Financial Officer (CFO), Deputy Chief Executive Officer, Country Manager Finland, Stora Enso
  • Marcelo Bacci, Executive Director of Finance and IR, Suzano
  • Koushik Chatterjee, Executive Director and Chief Financial Officer, Tata Steel 
  • Dawn Allen, Chief Financial Officer, Tate & Lyle
  • Robert Allen, Chief Financial Officer, The Crown Estate
  • Elling de Lange, Chief Financial Officer, TKH Group
  • Taco Titulaer, Chief Financial Officer, TomTom
  • Stefano Porro, Chief Financial Officer, Unicredit
  • Graeme Pitkethly, Chief Financial Officer, Unilever
  • Matt Ellis, Executive Vice President and Chief Financial Officer, Verizon
  • Zane Rowe, Chief Financial Officer and Executive Vice President, VMWare
  • Michiel Gilsing, Chief Financial Officer, Vopak
  • Lindsay Pearson, Chief Financial Officer, Wittington Investments
  • Kevin Entricken, Chief Financial Officer, Wolters Kluwer
  • John Rogers, Chief Financial Officer, WPP
  • Chris Johns, Chief Financial Officer, Yorkshire Water
  • George Quinn, Group Chief Financial Officer, Zurich Insurance Group

The Investor Statement

As asset owners and investors, convened by A4S, we support the call for global alignment as the ISSB develops its standards. As investors in the real economy, we need decision-useful data that considers both environmental and social impacts on a company as well as the company’s impact on the environment and society. This double-materiality approach will give investors earlier insights into likely financial and business impacts, and provide the information we need to deliver on our own net zero and broader sustainability commitments. We call on the IFRS Foundation to strengthen their inclusion of factors beyond those narrowly impacting enterprise value.

The Signatories

  • Russell Picot, Chair, HSBC Bank (UK) Pension Scheme and co-chair of the A4S Asset Owners Network
  • Emma Howard Boyd, Chair, The Environment Agency and co-chair of the A4S Asset Owners Network
  • Hubert Danso, CEO and Chairman, Africa Investor (Ai) Group
  • Magnus Billing, Chief Executive Officer, Alecta
  • Dr Steve Waygood, Chief Responsible Investment Officer, Aviva Investors
  • Denise Le Gal, Chair, Brunel Pension Partnership Ltd
  • Morten Nilsson, Chief Executive Officer, BT Pension Scheme Management
  • Clive Mather, Chair, Church of England Pension Board
  • Robert Gould, Chair of Pensions Committee, Environment Agency Pension Fund
  • Caroline Mason, Chair of Investment Committee, Environment Agency Pension Fund
  • Arthur Stephen Power, Trustee delegated for Responsible Investment, Jesuits in Britain
  • Dominic Burke, Investment Director, Lankelly Chase Foundation
  • Ken Woodier, Chair of Pennon Pension Trustee, Pennon Group
  • Ruston Smith, Chairman, Tesco PLC Pension Scheme
  • John Timbrell, Pension Fund Trustee Director & Chair of the Investment & ALHC Committee, Transport for London (TFL) Pension Fund
  • Gale Rubenstein, Chair, Board of Trustees, University Pension Plan Ontario

Accounting for Sustainability is a Charitable Incorporated Organization, registered charity number 1195467. Accounting for Sustainability is part of the King Charles III Charitable Fund Group of Charities.
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