A unique opportunity to become a responsible business role model

In our work we’re increasingly approached by representatives of companies – many of them in investor relations – asking about the next steps following last November’s narrow rejection of the Swiss Responsible Business Initiative (RBI). Regulation will indeed change, and Swiss companies will have the challenge of aligning with stricter, EU-inspired standards in terms of corporate disclosure and sectoral human rights due diligence. But what starts out as a discussion with clients about the pitfalls of the new law often ends up as a conversation about the potential, as they see the opportunities created by the transition to a more sustainable economy. In this blog post we explain how you can take the reins and become best in class – and why the current reporting cycle is a good time to start.

In the run-up to the vote on the Swiss Responsible Business Initiative (RBI) on 29 November last, it was interesting to note a view shared by many companies, and their stakeholders, with their finger on the pulse: Perceptive organisations regarded this vote as a manifestation of the growing expectations placed on business enterprises and their role in society.

Are you ready for higher expectations and peer comparison?

Since the RBI vote, this trend has not subsided. On 12 January 2021, Switzerland officially became a supporter of the international Task Force on Climate-related Financial Disclosures (TCFD). The TCFD has developed recommendations to enhance companies’ transparency on climate change. The Federal Council has called on Swiss companies in all sectors of the economy to implement these recommendations on a voluntary basis from now on. A bill will be drafted this year to make the recommendations binding. Likewise, in December 2020, the Ethos foundation, like a number of other proxy voters, revised its voting guidelines for 2021 shareholder meetings, introducing a new chapter dedicated to the approval of companies’ climate reports and climate strategy (‘say on climate’).

Even more importantly, companies are realising that investors, potential partners and stakeholders are factoring in transparency on environmental, social and governance matters (ESG) when they choose who to do business with. On the one hand there are formal reasons for this. The UN-sponsored Principles for Responsible Investment (PRI), for example, require that signatories (among them many institutional investors and asset managers) seek appropriate disclosure on ESG issues from the entities in which they invest. Similar requirements are at the heart of the first measures adopted under the EU’s Sustainable Finance Action Plan (the SFDR Sustainable Finance Disclosure Regulation and the taxonomy). For banks and asset managers to advise their clients on the ESG-compatibility of their investments, investee companies must disclose key metrics on the risks and opportunities of their activities. Financial firms are thus urging the real economy to comply with meaningful transparency requirements.

But the reasons aren’t just formal. It’s also important to realise the interplay between non-financial and financial reporting. Companies have to disclose non-financial information in accordance with the regulations. These non-financials inform the assessment of the financials that define whether a company meets investors’ ESG requirements. So stepping up your ESG reporting isn’t just about producing a compliant sustainability report. It’s actually an opportunity to steer your business to becoming more ESG-compliant – which in turn has a financial impact.

It’s also crucial to understand the underlying developments. The regulators’ ultimate aim is that investors and lenders have the information needed to price ESG-related (and in particular climate-related) risks and opportunities. This implies that appropriate controls govern the production and disclosure of this information, similar to those used for the preparation of mainstream annual financial filings. At some point, a company’s ESG performance will be compared with that of its peers based on standardised criteria. The market will reject those that fail to meet the expected ratings. For the winners, by contrast, there will be rich potential rewards, including satisfied investor expectations, better business outcomes, lower costs, and an easier ride to fulfilling their ambitions.

Responsible business conduct

Watch the recording of our past webinar on "Responsible business conduct: what challenges lie ahead?". Learn more about stricter due diligence duties, implications for socially responsible enterprises and best practice shared in our panel discussion.

Watch the recording

It’s important to realise the interplay between non-financial and financial reporting. Non-financials inform the assessment of the financials that define whether a company meets investors’ ESG requirements.

Momentum for sustainability-focused companies

There is now a window of opportunity to seize the upside of this situation. It’s a chance for businesses to ensure their ESG-profile is in line with their values so that when the spotlight comes, they’re ready for the scrutiny. For companies to achieve this, they have to capture the right set of quantitative and qualitative data to accurately evidence their commitment to sustainability and corporate responsibility.

This won’t happen overnight. A meaningful responsible conduct programme needs substance. To be transparent about the kinds of areas requiring disclosure under the RBI counterproposal, for example, your organisation needs to become aware of its processes and supply chain and work out ways of managing them efficiently. Getting a better insight into your processes means identifying your main stakeholders and starting a dialogue with them. This takes time, but doing it now allows you to identify and close any gaps with the performance of comparable actors in the market. The process of thinking about what you need to disclose and how you disclose it benefits your entire business. As soon as you have visibility on an issue, you can start to address it.

How does this work in practice? The RBI counterproposal as an example

The Responsible Business Initiative isn’t the only challenge companies face in terms of transparency and disclosure, but it is a pressing one for businesses in Switzerland at the moment. Let’s then take a brief look at how your approach to meeting the requirements of the counterproposal could look.

The law doesn’t list in detail the specific indicators or metrics that a company now needs to disclose. Carbon targets are the only specific topic mentioned. The other areas are referred to more broadly as environmental, social and employee-related matters, respect for human rights and anti-corruption. Ultimately your organisation is going to have to describe five things:

How the business model impacts the matters covered
What management approach is in place, and what kind of due diligence has been conducted
The form implementation takes (your action plan) and how it is monitored
The key risks: not just naming them, but describing what each risk is all about
The process in place for selecting the relevant KPIs

This obviously involves more than merely telling a story. You have to have a plan a structured approach. At PwC we’ve developed a model management process to help our clients through the process. It consists of four steps: assess, design, implement, and operate & review.

Assess
Design
Implement; operate & review

Assess

Define your ambitions (stick to the law or go beyond?)
Engage with stakeholders (who is our most relevant stakeholder, and how do we get their view?)
Identify material topics (what’s the scope of the assessment, and how do we identify relevant risks and opportunities?)

Design

Select reporting standard (do we adopt one and if so, which is the most appropriate?)
Define report content (do we focus on all topics, and how do we apply the ‘comply or explain’ approach?)
Update policies (what should the policies address; do we need to draft new policies for all material topics?)

Implement; operate & review

Define measures and KPIs (do we need metrics for all topics, and can we use qualitative KPIs?)
Develop a dashboard (how do we involve senior management, and how often should we assess the information internally?)
Allocate responsibility for quality and accessibility (how do we assure quality and timely reporting, what tools do we need to implement, and who signs off?)

As you can see, this framework allows you plenty of flexibility and room to decide just how you want to shape your reporting. It can also easily accommodate reporting in response to other regulatory developments besides the RBI.

To sum up: give yourself time to shape your ESG profile

Companies have a choice as to how they approach the challenges that the Swiss RBI sought to address and that will now be embedded in several other ESG-related initiatives: as an exercise in bare-bones compliance or as an opportunity to articulate a clear strategy and action plan to navigate economic transformations. The latter course will inspire confidence with stakeholders and allow companies to distinguish themselves. It promises rich rewards – but involves time and investment. To make it into the best-in class league in your 2021 reporting, a good time to start is now.

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A unique opportunity to become a responsible business role model

Responsible business conduct

Assess

Design

Implement; operate & review

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