中國企業可持續披露新篇章

中華人民共和國財政部在2024年5月27日發佈的《企業可持續披露準則 – 基本準則（徵求意見稿）》[1]，標誌著中國企業可持續披露邁入新篇章。該文件旨在提升中國企業在ESG方面的透明度和責任性，體現了中國政府對企業可持續發展的重視。

《基本準則》共六章33條，涵蓋了可持續信息披露的各個方面，包括制定目的、適用範圍、資訊品質要求、披露要素、其他披露要求等。《基本準則》借鑑了國際可持續被露准則中對財務信息被露的要求，與S1在信息披露要素和披露要求上總體保持銜接。而在披露內容方面《基本準則》第四章中亦列出，對於重要的可持續風險和機遇的信息，引入國際較為通用的治理、戰略、風險和機遇管理、指標和目標“四要素”框架，這將有助中國的可持續披露準則與國際準則實現趨同。

另一方面，《基本準則》亦帶有中國色彩，例如在ESG的議題設置中，除了關於環境生態等議題，在社會議題方面加入了「鄉村振興」﹑「社會貢獻」等更具中國特色的可持續議題內容。

《基本準則》的發佈，體現了中國政府對企業可持續發展的重視，也為中國企業可持續披露提供了框架性指引。未來，隨著具體準則和應用指南的逐步確立，中國企業可持續披露體系將更加完善，並與國際標準接軌，促進中國企業在可持續發展方面取得更大的進展。

財政部在起草說明中提到，總體目標是到2027年，中國企業可持續披露基本準則、氣候相關披露準則會相繼發佈。到2030 年，國家統一的可持續披露準則體系基本建成。由於準則體系建設週期較長，目前可由相關部門根據實際需求先行制定針對特定行業或領域的披露指引、監管制度等，未來逐步調整完善。因此，可以預計未來將陸續有針對行業或地區性的指引或申報要求，企業應拭目以待，加強內部管理，盡早做好準備。

[1] 中華人民共和國財政部https://kjs.mof.gov.cn/gongzuotongzhi/202405/t20240527_3935674.htm

Author: Ms. Apple Chan, Certified ESG Planner, ICSD

2024年7月17日 本會副主席代表ICSD 為證監會提供了一個「可持續投資」的講座

2024年7月17日 本會副主席代表ICSD 為證監會提供了一個「可持續投資」的講座

A Granular Look on E.S.G: A Content-and-Form Architecture

A synonym to “granular” is “detailed”. A granular learning on E.S.G refers to its “scale” or “extent”. The term “granularity” in business refers to the layers of details taken into account during decision-making process (EcommerceMasterclass, 2022). In term of content-and-form architecture, in its straightforward explanation, content is what to be performed, about the substance and material, form is the way in which the content is arranged and performed, about the technique and method. In the context of business management, E.S.G should be depicted in a content-and-form architecture, where environment and society are acted as content and governance as form. 

The Content: Environment and Society

The granularity of the environmental and social content is often opaque. Even though the EU trying to introduce the EU Taxonomy Regulation to “call for the creation of a common classification system for sustainable economic activities”  (EuropeanCommission, 2020), in its efforts to create clarification for all stakeholders with appropriate definitions of “being green”, its robustness and feasibility remain controversial. Intense discussions are ongoing that the ultimate result of this legislation is still open.

Apart from the legislative level, more and more investors reply on E.S.G ratings to evaluate corporation information, a group of third parties providing E.S.G rating reports emerges. However, criteria, elements, metrics are disagreed substantially. Chatterji et al. provides two terms “theorization” and “commensurability” as the reasons for causing the divergence in E.S.G ratings (Chatterji et al., 2016). Research done by Berg et al., investigating the divergence of E.S.G ratings based on data from six selected E.S.G raters, discovered a “rater effect” that different views on categories are taken in E.S.G evaluation, which often happens that two different rating methods produce different assessment results on a same firm. (Berg et al., 2022) Raters have own preference, and the rater effect suggests that divergence follows rater-specific and firm-specific patterns. These patterns further suggest the structural reasons for the existence of divergence.

Although consensus is difficult to build, it is not mission impossible. Until the legislation can work out a more widely recognized taxonomy, there are existing standardizations working for environmental and social management system for organization internal performance. The International Organization for Standardization (ISO) released ISO 14000 family for the environmental management standards, and ISO 26000 providing guidance for companies to implement corporate social responsibility. ISO 14001 Environmental management systems (EMS) is a framework to help organizations to identify, manage, monitor and control the environmental issues. Such system can be tailored to the needs of the industry using it with quantified standards. However, ISO 26000 is a set of voluntary standards to help companies implement corporate social responsibility. As nature of social responsibility is difficult to be quantified, ISO 26000 provides guidance rather than requirements, standards can only be set for all types of organizations, regardless of their activity, size, or location (Fernando, 2023), confusion is occurred when organizations in different sizes, or different business models to share with the same group of standards. Key stakeholders from around the world should contribute to setting the ISO 26000 standards to achieve an international level of consensus.

The Form: Corporate Governance

Corporate governance is the system by which powers are exercised and controlled over the companies. Shareholders of the company appoint the directors to exercise such powers to satisfy their appropriate value. The appointed directors take responsibility for the governance of their companies in order to accomplish the interests of the shareholders. It encompasses a wide range of issues. In the content-and-form architecture of E.S.G, governance is about how to arrange and perform the environmental and social elements into the management strategy and practices. The C-suite, when designing the governance structure or setting rules and processes and practices, should blend in environment and society. The effectiveness of governance should be functioning by penetrating E and S in all levels in the organization

In this content-and-form architecture, although they are discussed as separate entities, the relationship is closely tight and related. The form, corporate governance, in which the content of being environment- and society- focused is presented, can shape and influence the impact and interpretation. It is like the orchestra performing symphony. Symphony is set (environment and society issues). The conductor (the board) should be able to lead the orchestra effectively, setting the tempo, shaping the sound, while each musician (employees, stakeholders) has the technical ability to play their instruments at a high level. Different orchestra might convey different emotion and meaning of the same symphony to the audience. Ultimately a successful performance is one in which the conductors and musicians are able to deliver the beauty and power of the symphony to the audience.

A Look into the Future

The growth of ESG in recent years has been exponential. The more granular look at E.S.G, the more apt to the idea that E.S.G is old wine in new bottles. The concept of CSR (Corporate Social Responsibility) has existed for many decades and have been largely neglected until the beginning of this century. Great wine is always a matter of perfect terroir, that blend of altitude, climate, and soil producing the essential fruit for excellent wine. E.S.G offers the world such an ideal mix of elements amid the best of 3 pillars: environment, society, governance, re-blend them all together to create a new taste to please the palate of any wine lover. A great wine is a very personal choice that comes down to the taste of the drinkers, so as E.S.G.. There is no universal one-size-fit-for-all rule or methodology for all companies to implement E.S.G. It is the confusion, but also the charm for organizations who can understand the essence. Looking into the future, it is likely that E.S.G will continue to thrive, but importantly, it is about the human survival that no one can stay out or left behind. Collaboration and cooperation should be built among individuals, organizations, nations, and the globe. The sooner, the better.

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Câmara, P., & Morais, F. (2022). The Systemic Interaction Between Corporate Governance and ESG. In (pp. 3-40). Springer International Publishing AG. https://doi.org/10.1007/978-3-030-99468-6_1

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Author: Ms. Huang Xumin, Certified ESG Planner, 國際可持續發展協進會