Response in a personal capacity to the Consultation Paper on Sustainability Reporting by the IFRS Foundation by Timothy J. Mohin

I. Introduction

As the former Chief Executive of GRI from 2017 to 2020, I worked on establishing global ESG (Environmental, Social and Governance) disclosure standards in use by the majority of companies reporting sustainability information. Before joining GRI, I worked for more than 20 years on corporate sustainability issues for Intel, Apple and AMD, all of which reported on these matters. Prior to that, I worked for 10 years for the United States Federal Government on the creation of policies for environmental protection. I am currently the Executive Vice President and Chief Sustainability Officer for Persefoni AI – the intelligent carbon footprint management & reporting platform.

I will draw on these experiences to respond to this consultation.

II. The Past and Present of Sustainability Reporting

I worked on my first sustainability report in 1995 for Intel Corporation. The practice was in its infancy and very few companies voluntarily disclosed information on their environmental or social impact. Those companies that championed this effort early did so to establish a record of responsibility and stewardship. 25 years later, the corporate responsibility motive remains very powerful.

This driving force has contributed countless benefits to people and the planet, and continues to be the dominant motivator for environmental, social, and governance (ESG) disclosure. This history is important context as the IFRS Foundation considers establishing new disclosure standards for ESG matters.

More recently, many of the largest global institutional investors are demanding ESG disclosure from their portfolio companies. Some are motivated by responsibility, but as certain ESG issues have become material to corporate financial performance, companies are increasingly obligated to report on these topics to their investors.

The clearest sign of this shift is the rapid adoption of the carbon reporting framework issued by the Task Force on Climate-related Financial Disclosures, created by the G20 Financial Stability Board. Since the proposal was finalized in 2017, more than 1,500 organizations have supported the TCFD recommendations (a year over year increase of more than 85% compared with 2019). The latest status report states that “Nearly 60% of the world’s 100 largest public companies support the TCFD, report in-line with the TCFD recommendations, or both.”

The shift from solely responsibility motives to incorporate financial motives has inspired a range of activities designed to meet the ESG disclosure needs of investors. Specifically, there are two major trends addressing this shift in priorities: