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Sustainability Reporting After the Paris Climate Accord

    Client Alerts
  • June 20, 2017

It’s fair to say that President Trump’s June 1 announcement that the U.S. will withdraw from the Paris climate accord has been widely reported. It’s also fair to say that the announcement triggered a host of passionate reactions, positive and negative, around the world. Within corporate America, a number of high-profile corporations (for example, Apple, Disney, Facebook, General Electric, Google, Salesforce, Tesla and Twitter) pledged to continue their efforts to cut greenhouse gas emissions and adhere to the spirit of the accord.

This leads one to wonder whether withdrawal from the Paris climate accord might, per the law of unintended consequences, actually increase investor emphasis on corporate social responsibility (CSR) and the number of companies that voluntarily report their sustainability initiatives. It’s an intriguing possibility.

Momentum for sustainability reporting has been building for years. In fact, the vast majority of S&P 500 companies now publish some type of sustainability or CSR report, and disclosures have begun to appear in SEC filings, particularly proxy statements. Mid-size and smaller companies, lacking the resources of their larger brethren, have been slower to do so, though some have begun and others are giving it serious consideration. Increased pressure from institutional investors, employees and other stakeholders, now coupled with widespread concern over withdrawal from the accord, could tip the reporting balance, especially for companies in sustainability-sensitive industries or companies that otherwise want to send a certain message.

One challenge for all companies is to make sense out of the CSR reporting landscape. First of all, the terminology itself—sustainability, CSR, environmental, social and governance (ESG), and triple bottom line, to name a few—is confusingly ambiguous and overlapping. Fundamentally, it all speaks to a company’s commitment to certain aspects of non-traditional, long-term value creation and to a broader range of stakeholders.

Such companies typically want to communicate that commitment, and so must decide what to say and how. Among larger companies, a stand-alone CSR or sustainability report has become the norm. Others combine those disclosures into a broader report that integrates business strategies and financial goals and performance. Still others begin by adding CSR narrative to their SEC filings, with an eye toward expanding it into other formats over time as their CSR efforts mature and resources become available. Though no single method of disclosure or form of content has yet emerged as the “right” way to do it, certain frameworks have gained popularity, including the Global Reporting InitiativeSustainability Accounting Standards Board and International Integrated Reporting Council.

As I’ve mentioned before, care must be taken to avoid misstatements or inaccuracies in these public statements. As with all disclosures, companies must analyze their CSR reporting in accordance with their established disclosure controls and procedures. (See this Doug’s Note for some tips to keep in mind.)

The U.S.’s withdrawal from the Paris climate accord presents investor and public relations opportunities to send a message, on either side of the issue, particularly in these days of enhanced stockholder engagement. Corporate America’s collective response over the next few months could significantly impact not only the quantity of U.S. greenhouse gas emissions, but also the future of CSR reporting and, ultimately, public perceptions. It may also re-affirm the mysterious law of unintended consequences.