Sustainability

CSRD – What do I need to Report?

Certitude Sustainability, Uncategorized ,

The reporting requirements of the EU Corporate Sustainability Reporting Directive (CSRD) are yet to be fully established through reporting standards. However, the draft proposals of the European Financial Reporting Advisory Group (EFRAG) will be the basis on which the standards are developed.

These proposals call for the following principles to be followed:

  • Quality of Information – to ensure sustainability reporting is of an equal standard to financial reporting it must be relevant, comparable, understandable and reliable/verifiable.
  • Retrospective and Forward Looking – reporting will need to cover policies, targets, action plans and goal alignment to enable transition trajectories to be assessed and help ensure that targets are linked to outcomes, set against a baseline year and time-bound, associated with relevant KPIs, where feasible science-based, and tested against stakeholders’ expectations.
  • Levels and boundaries of reporting – sustainability reporting must go beyond the scope of operations under the control of the reporting entity and into the value chain, products and services.
  • Double Materiality – that both financial and impact materiality are considered from the positive and negative perspectives.
  • Connectivity – to ensure the absence of gaps, overlaps and a lack of coherence, sustainability and financial reporting must be placed on an equal footing and timing.

Within 3 reporting areas:

  • Strategy
    • the sustainability aspects of the entity’s strategy and of its business model,
    • the materiality assessment process – how the entity determines what is material to be reported,
    • the specific governance, management responsibilities, processes and reporting procedures put in place to address and monitor sustainability matters.
  • Implementation
    • how the reporting entity translates its strategy into action through policies, targets, action plans and dedicated resources.
  • Performance measurement
    • how the reporting entity delivers against its policies and targets,
    • what is its transition trajectory,
    • including its past performance (retrospective information) and forward-looking perspectives.

And the 3 reporting subjects of ESG:

  • Environment – impacts to and from all environmental factors:
    • climate change mitigation and adaptation,
    • water & marine resources,
    • biodiversity & ecosystems,
    • circular economy,
    • pollution.
  • Social – impacts to and from all people factors over the scope of the entity’s whole ecosystem:
    • workforce,
    • value chain workers,
    • affected communities,
    • consumers/end users.
  • Governance+ – broader than traditionally considered under the concept of ‘governance.’
    • governance,
    • business & ethics,
    • management of the quality of relationships with stakeholders,
    • organisation,
    • innovation, reputation and brand management.

There is much to be done to prepare for CSRD and whilst the standards have yet to be finalised, preparations within your organisation should be commencing now.

If you need help in your preparations for CSRD, please don’t hesitate to contact us.  We have a wealth of experience with company reporting from a GHG, Sustainability and a CSR perspective as both consultants and independent assurers.  Let us help you build your reporting requirements into your core business processes and provide clarity for all your stakeholders.

PFAS – Forever Chemicals – What you need to know and how Future Policy will Impact your Business

Certitude Sustainability ,

What are PFAS?

Per- and polyfluorinated alkyl substances (PFAS) are approximately 10,000 different chemicals used in a wide range of products due to their water, oil and dirt repellent properties, their tolerance to high temperatures and pressures, and their non-stick qualities. These qualities are generated from a carbon-fluorine bond, which makes them very slow to break down in the environment.

They can be found in: textiles, cleaning agents, food packaging, pesticides, PPE, fire-fighting foam (FFF), cosmetics, pharmaceuticals, paints, sealants, varnishes, hydraulic fluids, surfactants, plastics, rubber, non-stick coatings. The list is endless.

Major manufacturers of PFAS products are moving away from their production and others, particularly in the US, are struggling with litigation costs due to the impacts affected on the environment and human health.

What is the Regulatory Position?

In the US restrictions are being imposed State by State with approximately 22 States currently banning PFAS for varying uses.

The EU have proposed a complete ban on all PFAS, with some use-specific, time-limited derogations but with a proposed entry into force of 2026-2027.

The UK’s Health and Safety Executive (HSE) have published their analysis of how to tackle PFAS in the UK, and they have stopped short of mirroring the EU’s complete ban. They have however recommended:

  • Research to potentially support one or more restrictions of PFAS under UK REACH for substances categorised as: carcinogenic, mutagenic or toxic to reproduction (CMRs); persistent and bioaccumulative (PBTs); very persistent very bioaccumulative (vPvBs); or substances of equivalent concern. 
  • Further evaluation and investigation of substances that have been highlighted to be of concern.
  • Continued collaboration across government and external stakeholders to bring together work on PFAS strategically, including a review of F-gas regulations to determine whether additional PFAS registered under UK REACH should be brought within scope. 
  • The development of statutory standards for PFAS in drinking water.

How will Your Business be Impacted and What can you Do?

Without doubt PFAS products that your business uses will be restricted by regulation sooner or later. Prior to this, availability of PFAS products will reduce as businesses see the writing on the wall and make decisions for their future.

All business will be impacted. Whether your business is in a key PFAS sector, e.g. chemicals or waterproofing or not, it will currently be buying and using products containing PFAS.

Start now to identify PFAS in your products, manufacture and supply chain and look to obtain alternatives prior to this risk impacting your day to day business operations.

EU Leading the way in Mandatory Corporate Sustainability Reporting

Certitude Sustainability, Uncategorized , ,

Last year the EU introduced of the Corporate Sustainability Reporting Directive (CSRD). This new framework will be rolled out from 2024, and will require companies to report on how sustainability issues impact their business and how their operations affect people and planet, together with governance elements, and must specifically include:                            

  • Environmental matters – including climate risk reporting. 
  • Social matters and treatment of employees.
  • Human rights.
  • Anti-corruption and bribery.
  • Diversity on company boards (age, gender, educational and professional background).

These reports must be independently assured to ensure they are accurate and complete.

Approximately 50,000 companies are expected to be obligated under CSRD, this includes:

  • Companies listed in the EU, and large companies (one that meets two out of three of the following criteria: more than 250 employees, a turnover of over €40 million and over €20m total assets).
  • Listed SMEs. 
  • Non-EU companies with a net turnover of €150 million in the EU, and with at least one subsidiary or branch in the EU.

CSRD requirements will be introduced in phases:

From 1/1/24Companies already reporting under the Non-Financial Reporting Directive (reports to be submitted in 2025 covering 2024 data)
From 1/1/25Large companies that are not currently subject to NFRD (reports to be submitted in 2026 covering 2025 data)
From 1/1/26Listed SMEs, small and non-complex credit institutions and captive insurance undertakings (reports to be submitted in 2027 covering 2026 data).
From 1/1/28Applicable non-EU companies. (report to be submitted in 2029 covering 2028 data).

If you need help in your preparations for CSRD, please don’t hesitate to contact us.  We have a wealth of experience with company reporting from a GHG, Sustainability and a CSR perspective as both consultants and independent assurers.  Let us help you build your reporting requirements into your core business processes and provide clarity for all your stakeholders.

EU MRV Regulation for Shipping – Time to Get Ready

Certitude Climate Change, EMS, Sustainability

On 1st July 2015 Regulation (EU) 2015/757 on the monitoring, reporting and verification of CO2 emissions from shipping came into force, the aim of which is to gather reliable information on such emissions from the sector within the EU.

The regulation applies to ships greater than 5,000 GT undertaking one or more commercial voyages into, out of, or between EU ports regardless of a ship’s flag. It requires per-voyage monitoring of emissions and annual disclosure of aggregated data on a ship basis.

Each Company must produce a monitoring plan by 31 August 2017. The monitoring plan must be reviewed and approved before the monitoring period commences on 1st January 2018.

Following the completion of each calendar year, each company must submit their emissions report for verification.

Companies therefore need to start considering the methodology that they will follow to fulfil their monitoring, reporting and verification obligations, and adapt their existing procedures to ensure they have a robust system for collecting and reporting their emissions.

Need help preparing your monitoring plan? Your monitoring and reporting procedures? Or preparations for verification? Contact us.

New York Climate Week – What happened?

Certitude Climate Change, New York Climate Week, Policy, Sustainability

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With Climate Week NY and the news of man and celebs taking to the streets now fading away, you might be wondering what – if anything- was achieved. Were any decisions or commitments made?

The answer is a resounding ‘yes’, and here they are summarised in eight key areas:

Food Security – the establishment of a Global Alliance for Climate Smart Agriculture, to improve people’s food and nutrition security.

Cities – Amongst other things, more than 200 cities committed to reducing emissions by 454 Megatonnes by 2020.

Energy – The launch of a public-private partnership to double the global rate of improvement in energy efficiency.

Finance – pledges of public and private financing for low carbon and climate resilient pathways.

Pricing Carbon – A call on companies to apply the Business Leadership Criteria on Carbon Pricing.

Forests – the NY declaration on Forests, pledging to end the loss of forests by 2030.

Oil & Gas – Commitments from industry and government to cut methane emissions.

Resilience – A variety of initiatives to support the worlds most vulnerable countries.

Transportation – The launch of four global alliances to scale up proven low-carbon transport tech.

Full details of all announcements can be found here. For what they ultimately will achieve – follow this blog 🙂