A series of four blogs on the importance of assurance for sustainability reporting, the risk of adding to green or impact washing if we don't get this right and how
the UNDP SDG Impact Assurance Framework has been designed to address this risk.
First published on Pioneers Post
The secret to sustainability #1: why assurance means better decisions
Jeremy Nicholls 24th January 2023
First up, how assurance gives meaning to sustainability reporting.
If sustainability reporting is going to be good for anything, the people who use the reports will need assurance that they can make decisions based on the information provided. If there is no demand for independent assurance, it can only be because no one is using the information. These reports are only good for marketing or for propping the door open.
Civil society organisations as well as investment managers and politicians are now concerned about the level of green-, impact- or sustainability-washing going on. For those of us who have been banging the drum for assurance for years, this is a good thing. Assurance, done well, provides a real opportunity for increasing accountability to those whose lives are impacted by a business. Done in ways that follow the logic of financial auditing, it will end up questioning the very basis of capital markets. But there are significant risks as well: if assurance is not acting in the interest of the people whose lives are impacted, assurance will not increase accountability. Capitalism resists change, and forces of darkness are gathering to avoid more accountability. There is a way around this. But the devil will be in the detail.
In this four-part series – part of my wider series on financial accounting and auditing – I explore our opportunity to have assurance on the performance of businesses in contributing to sustainability and generating financial returns. This, the first, explores the idea of assurance in general. The second applies these ideas to financial audit and the third uses the same logic to think about assurance of sustainability disclosures for the same user as the financial report. The fourth considers assurance of these reports prepared for people experiencing the consequences of a business model, irrespective of any financial implications; it also covers some of the oddities and more fundamental problems with current approaches to both financial and sustainability assurance. All this means getting down into some of the weeds, nuts and bolts, plumbing or whatever metaphor helps think about the exciting and critical issues around assurance and auditing.
What is assurance? What is audit?
Assurance is implicit in any decision we make, whether personally or in an organisation. Without assurance we don’t make decisions. We want assurance that we are not about to make the wrong decision. And we know there is always going to be a risk, as decisions are choices between different futures. Which means we have some expectation that there is a purpose behind our decisions (and that purpose will come with a timescale) and a level of risk that we are willing to accept.
So, there are four elements to assurance: i) someone making a decision, ii) accepting a level of risk, with iii) a purpose behind the decision and iv) an opinion provided to someone making a decision.
In theory the bigger the decision, the more assurance we need because the consequences of getting it wrong will be higher (though think about how much time is spent on the decision to buy a new home compared with time spent choosing next year’s holiday). But if we don’t have whatever level of assurance we think we need, we won’t decide at all. And we’ll be biased towards the do-nothing option. In part because we tend to forget that not deciding is still a decision; in part because we don’t like change; and in part because if we are comparing what we are doing now with an alternative, we think sticking to doing what we are doing now is less risky. Human beings are not very good at risk assessment. And this is what assurance does: it provides a way of assessing and then reducing the risk that we make a make suboptimal or even a bad decision.
This means that we don’t only need assurance that information we are given is useful, we also need assurance that organisations are using that information effectively. The importance of assurance of effective use is often missed, as it is so embedded in our current economic system that we don’t notice it. Our economic system and creative destruction provide us with assurance that organisations are not choosing the do-nothing option too frequently. If we are, we are almost certainly not making the best decisions – where ‘best’ is defined by reference to the purpose that was behind our decisions. The second is assurance in the information we are using to inform our choice between uncertain futures. Either way, without these two levels we may not achieve our purpose, either at all or as fast as we could.
So we all need assurance in all our decision-making, personal as well as organisational. When it is a group of people making a decision, there will be some additional requirements: we will need to have a common understanding of the level of assurance the group needs, and a common process to achieve that level of assurance.
There are also some new risks. There may be conflicts of interest between those preparing information, assuring information and using information. This is why assurance is defined with reference to a three-party relationship. If the people producing the information also assure the information, then the people using the information will not have enough assurance. This is also the case if the people producing the information employ an agent to assure the information for them. An agent acts for their principal, not for the users. Assurance is a process which makes potentially useful information, actually useful.
Assurance or evaluation: not the same thing, but related
Assurance is a special type of an evaluation. In an evaluation the evaluator could be working to a scope that has been determined by a variety of people, and the report could be prepared in the interests of a wide variety of people, and the extent to which the evaluator can make findings public will also vary. The approaches used by an evaluator will depend on discussions between the evaluator and whoever has determined the scope. The competency requirements for the evaluator will also be set by whoever is paying and, while there are professional standards and qualifications, having these is not a legal requirement for those involved in an evaluation.
In assurance there is a predefined scope, set by reference to the interests of a group that has not prepared the information, and generally not paid for it and which follow international standards for preparation and disclosure. The work that will be done follows international standards for assurance. The organisations providing assurance must be approved and the staff must meet standards for their competence; there will be external review to ensure adherence to all these requirements.
Given social impact is mainly experienced by people with the least power, who generally cannot hold organisations to account, I cannot understand why anyone interested in social impact would argue against assurance of social impact reports – assurance that the information is useful and that the organisation is using it effectively.
The secret to sustainability #2: why financial assurance is a thing of beauty
Jeremy Nicholls 31st January 2023
What does financial audit means for sustainability assurance.
The second in this four-part series applies the description of assurance – explored in part one – to the existing economic system and financial audit.
Audits are not limited to financial reports. But this is how the financial world tends to use the word and what many people think about when they hear the word. Audit comes from the Latin, audire – to hear. Which brings us back to accounting and accountability. Accountability is a process by which one group of people, who are making decisions with a purpose, hold another group to account for their actions. An account is given, and could be verbal (which brings us to the word audit). And there will be consequences for the people providing an account if the actions do not meet expectations, where expectations are set against both a purpose and a timescale. The users will make decisions that the people providing the account may not like. This is why it is not possible to hold yourself accountable. Most people will not make decisions that are against their own interests.
Assurance that organisations are using information to make decisions to generate financial returns is provided by our economic system. This system provides assurance about the rate of decision-making. Maintaining profitability in a competitive market means making decisions. Or going out of business. Competition, in open markets, provides the first level of assurance. Users, that's all of us, won’t have this assurance for organisations that operate outside competition. Oligopolies are bad because they suppress competition and then organisations do not make decisions at the rate they would have to if there was competition. Creative destruction is a form of assurance that reduces risk. Foundations are an example of organisations where there is no competition, and so there is a risk that they do not make decisions at an appropriate rate. As there is no process of creative destruction, society has to find other approaches to get assurance and this is why, for example, the US requires private foundations to disburse 5% every year even if this is a poor measure of effectiveness.
Then we need assurance that the information can be used to make those decisions, accepting a level of risk, with a purpose behind the decision and an opinion provided to a defined group. The four elements. For financial returns, three of these are provided by the International Financial Reporting Standards Foundation (IFRS) in its Conceptual Framework for Financial Reporting (CFFR). The audience (i) are the primary users of financial reports, and these are current and future investors, providers of loan finance and suppliers. The decision (ii) is to provide or withdraw resources from an entity and the purpose (iii) is to assess future cashflows in the expectation of financial returns. All good and super clear – up to a point.
Four elements
The information, prepared by the company, includes information on the resources available to the company (the CFFR uses the term ‘entity’) and on management’s stewardship of those resources, or how well the management of the business used the resources to generate those financial returns. But there is something missing here, as users will also want to know about the future strategy and plans and the manager’s assessment of the implications of external factors. The CFFR focuses on the manager’s past decisions. And IFRS has been developing a management commentary so that users have all the information they need. But nonetheless for the audit of the financial statements, we do have the three-party relationship we need. The assurance provider is employed by the company but acts in the interests of those primary users. All this is enshrined in company law and is the exciting part of the AGM where the members, the people who have invested in the company, elect the auditors. This is a financial audit, the special type of assurance. But it applies the same elements as other forms of audit, and still has a three-party relationship to financial reports. In other words it covers the remaining element: iv) an opinion given to someone making a decision.
A defined group
While the audience for the assurance is the users, the assurance provider needs a defined group that could be all the users, but is often a subset. This is the group that can receive the assurance providers' opinion. Although the users are current and potential investors, providers of loans and suppliers, the audience for the assurance report is the existing members, where ‘members’ is the language used to refer to the existing investors, and who are only a subset of the users.
Risk
The interesting part of all this is the second element, the element of risk. What level of risk are these primary users willing to accept? Who asked them and how did they calculate it? How did they work out the risk that things were missed out, or included, to meet the level of risk that primary users will be willing to accept?? I confess that I think the way in which a combination of legislation, accounting standards and assurance standards deals with this challenge is a thing of beauty. In shock news, however, where human beings are involved it doesn’t always work. It is not and cannot be designed to always work. By definition, accepting risk means that sometimes it won’t.
The first step in sorting this out is to establish a level of certainty that is required for including what the CFFR describes as ‘economic phenomena’ but for shorthand, we’ll use ‘transactions’ (it is a little more complex than this). How certain do we need the information to be for a transaction to be included in the accounts? The CFFR recognises three types of uncertainty: existence, measurement and outcome. Does the transaction exist? Do we know the outcome? And can we measure it? (In accounting, measurement is in the common unit of physical money because that relates to the purpose of the information. If the purpose was not restricted to financial returns, the common unit could be something else). Of course, the absolute level of uncertainty and how one would measure this is not quantified and cannot be. But we still need it. The solution is that the common level of risk emerges from practice. This is part of the risk: the risk that something is missing that we did know about but where the level of uncertainty in measurement was incorrectly assessed. But there is also the risk that something is missing that we didn’t know about but would influence our decisions.
The assurance process needs to assess the risk that an account is misstated to the point that it would affect a decision being made. And there is a whole audit standard on the risk of material misstatement. And again, it doesn’t quantify the risk. It does though, in the end, leave all this up to the person doing the audit. And despite the fact that there may be many people involved, in the end, this is down to one person. One person will be held to account for providing an opinion on whether the accounts provide a true and fair view of the financial position of the entity. And that person has to prepare a work programme that will allow that opinion to be made within that acceptable level of risk. A work programme that therefore also has to recognise risk (it is like an onion!). And this is the acceptable audit risk. Again, this isn’t quantified or even quantifiable. How could you decide what work you should do to capture unknown things that would be included if you found them? And again, the solution is that it emerges in practice. Many organisations preparing information, many providing assurance, many using the results.
Complex, beautiful architecture
The implication of all this is that there is a cut-off point. A point at which a transaction does not get included in the accounts as, if it were missing, the decision wouldn’t change. It is not material. It does not matter. Of course, if lots of transactions were missing then cumulatively, they might matter. In calculating this cut-off point, assurance providers’ work is informed (but not led) by an assessment of a percentage of the profit and loss or the balance sheet.
When we go into a cathedral and gaze at the ceiling, the ornate carving, the amazing architecture, we don’t tend to worry that it is too complex and rush out (though perhaps we should be considering the foundations). I wish we could do the same with this structure and instead of rushing away from it, arguing it is too complex, too arcane – saying, ‘let’s do something simple’ – that we could recognise its beauty. It is a way of solving a problem to provide information that has allowed investors to invest in companies where they will never see or know the managers and still have enough confidence that returns will emerge (while recognising the risk that the value of your investments may fall). And just in case of any doubt: I do not think it is perfect or that it cannot be improved, and I would not say the same about the foundations, which are deeply flawed, and which will bring the whole edifice down unless changed.
So, in the next piece in this series, I’ll apply the same logic to sustainability disclosures designed to help these same investors make better decisions. Where ‘better’ is still the interest in financial returns, but now assessed by reference to some sustainability information that hasn’t made it into the financial statements.
The secret to sustainability #3: why uncertainty is key for sustainability assurance
Jeremy Nicholls 7th February 2023
Figuring out what to include in a sustainability report means accepting higher thresholds for uncertainty.
I previously set out a logic and structure on financial assurance and audit, which informs decisions made in expectation of financial return. In this third piece of the series, we use the same logic to explore assurance of sustainability reports.
Assurance on the rate of decisions is provided in the same way. Nothing needs to change. The purpose of this type of sustainability report is still to provide information to help that investor assess expected financial returns in the light of available resources. Following the same logic, sustainability information would cover i), how effectively the management have used those resources to contribute to sustainability; and ii), information on how sustainability topics affect the entity’s ability to generate cash flows. And our defined group of existing investors is the same as well.
But first we need to be more specific about these sustainability topics. Following the logic of the IFRS Conceptual Framework for Financial Reporting, which is based on economic phenomena, sustainability reports would include ‘social and environmental phenomena’. We used transactions as a shorthand for these in part two. This won’t work for sustainability, but this is where the term impact fits in. There will be impacts which can be thought of as the equivalent to a transaction (which does not mean they are the same!) because they occur at the level of a person (remembering that in law a business is a person).
The parallel starts to get even more interesting (no, really) when we think about the threshold at which these sustainable topics will be material to investors interested in financial returns. There still needs to be a cut-off point to decide whether sustainability information should be disclosed. But given this is information that is relevant to those financial returns it should be possible to estimate the effect on those returns and so use the same cut-off point that is used in the financial accounts. Otherwise, the contents will risk becoming an endless list of things that might or might not be material.
Higher uncertainty
But – and it is a big but – the information relating to sustainability topics must allow for a higher level of uncertainty than is used for deciding when to include information in financial reports. That’s because the effect on those financial returns is less certain, whether it is the effect of the management’s decisions on those returns or the effect of external sustainability trends.
This has two implications.
The first implication is that to assess relevance and consistency and have a chance of providing assurance, this higher level of uncertainty is going to need to be assessed. We also need to figure out an acceptable risk of material misstatement and an approach to audit risk. But all in the absence of all the levels of practice that made this possible in financial assurance. Hmmmm. Difficult. But even more important that we find some solutions. Solutions that actually do change investors’ decisions.
Given that the user, the decision and the purpose are all the same as for financial reporting, we need to think about risk in relation to disclosures relating to past management decisions, and what we can glean from the management commentary for disclosures in relation to strategy and external factors.
The second implication is that the different level of uncertainty creates a problem for a user. It means that there is information that is useful in International Sustainability Standards Board (ISSB) guidance that is too uncertain to be useful under International Accounting Standards Board (IASB) guidance, despite the information being used by the same people for the same purpose. In other words, there is information about assets and liabilities that isn’t useful and so not disclosed, but that would be disclosed if the same, higher level, of uncertainty was accepted as used in relation to sustainability topics that have financial implications. A user may well argue that they now want to know about all these too uncertain assets and liabilities – which would include some of what are currently described as intangible assets (they are not intangible, they are only too uncertain).
It is also possible that some of the information relating to sustainability topics would become assets or liabilities if there was more certainty, and so sustainability information includes both information on sustainability phenomena and too uncertain economic phenomena.
Confusing for the user. More difficult now for the auditor.
There will need to be some cold towels handed out in IASB to sort this out, unless we make some fundamental changes. Which I imagine was never the plan when ISSB was established.
The risk of material misstatement
I have argued previously that an assurance provider can only form an opinion on whether the sustainability disclosures are within the acceptable level of risk of material misstatement by seeing the assessment of all the consequences or impacts of the business that are material to the people that experience them, and by seeing the process by which these impacts are identified, regardless of whether they have a financial implication. The assurance provider then needs to assess whether the process for identifying those that do have a financial implication and how it has been applied is good enough.
Future management decisions and external trends
For IASB, the risk of material misstatement is in the context of past management decisions. For information on the influence on financial returns of external trends in sustainability topics, it will be even harder to assess completeness and accuracy. Simply for organising the information, it may be easier to have financial reports (relating to past management decisions), sustainability disclosures (relating to past management decisions) and a management commentary separating economic strategy from social and environmental strategies and influence of external trends. Quite how the assurance provider would assess the work required to reduce the risk that something has been missed out, or that the balance in a management commentary overemphasises one issue above another, is within the level of acceptable audit risk, I do not know. And if they can’t and the information isn’t assured, then it is of less use to the primary user. Perhaps these will be left mainly outside the scope of assurance, though something to stop pages of immaterial information being provided would seem to be necessary. Users will have to bring their own assessment to the information provided.
The debate about ‘inside-out’ information (consequences of the business) and ‘outside-in’ information (consequences for the business) would, though, feel a little irrelevant if it is only inside-out that can be assured and made useful. At least we need to be clear about which is which.
But the challenge doesn’t stop here. The timing of the impact of management decisions (or the timing of the external impact on the enterprise) will also matter. The further off in the future they are, the lower the certainty that they will happen. So an impact in 10 years that is 50% of balance sheet value with a 10% chance of occurring is as material as an impact in one year with 10% of balance sheet value with a 50% chance of occurring. Remember, we can’t really calculate those risk percentages, but the higher level of uncertainty will bring more of the future into play as potentially material.
The final part in this series looks at assurance for those of us who are interested in balancing financial returns with the impact or ‘consequences’ on people. The same logic of financial reporting and assurance can be applied – but assurance will need to have a different and a wider scope.
The secret to sustainability #4: how we can put stakeholders at the heart of assurance
Jeremy Nicholls 14th February 2023
Most companies’ sustainability reports still fail to capture what matters to the people who actually experience the impacts. Assurance can help us put them and their wellbeing high up on the agenda – and push us to keep improving.
The last in this four-part series considers assurance and audit more widely. If we are looking at sustainability disclosures from the perspective of people experiencing the impacts we will need a new user, a new decision, a new purpose and a new consideration of risk. We will also have to deal with the fact that many people who experience the impacts of a business are not in a position to make decisions. And we will have to spend more time on the question of future trends in drivers of impacts.
Assurance for the people who experience the impacts
This is assurance of sustainability disclosures for and on behalf of the people who experience the impacts. How then we address that first level of assurance: assurance that the rate of decisions is at a rate commensurate with the expectations of people experiencing those impacts. Their expectations are likely to be as much positive impact as quickly as possible. And because we take this level of assurance for granted in our current economic system, it doesn’t generally get discussed in sustainability. We have to imagine a world where businesses that are not contributing to sustainability at the rate we require would go out of business, which – if today’s business survival rates are anything to go by – would mean that 50% of startups would close by the end of their first year. Ironically, if there is a higher survival rate among purpose-led organisations, that may not be an indicator of success. Hold that thought.
The second level of assurance, that the information is complete and accurate to inform decisions, brings a raft of other issues.
The challenge here is that we need to identify a reasonably consistent purpose behind the decisions being made with this information.
Wellbeing
I would propose that the purpose is the expectation of increases in wellbeing – where wellbeing, as defined in the British Standard for understanding and enhancing social value (BS8950), ‘captures states of being where subjective and objective psychological or physical human needs are met in varying degrees, with increased wellbeing corresponding with better states of physical and psychological health’.
First, because there is increasing convergence around this idea – wellbeing is also integrated into OECD work on measuring wellbeing, UK Government Green Book for cost benefit appraisal, UNDP SDG Impact Standards, Capital Coalitions protocols, Social Value International standards, and most recently, British Standard PAS 808 on purpose-driven organisations – to name a few.
Second, because the purpose of all those financial returns is in the end also to increase wellbeing. Financial returns are a good proxy for wellbeing up to a point. But above a certain level of income, increases in wellbeing tail off rapidly.
Third, because any other purpose would mean making decisions which could reduce wellbeing, but where the information to know if it had would have been out of scope. Which is why we need this other type of sustainability report and why financial materiality inevitably ends up being half-hearted materiality (it only considers what is material to investors only interested in financial returns, and excludes anything else that is material to others, even to themselves). There could be many other types of report but if they are not for the people experiencing impacts, and involve making decisions in expectation of increasing wellbeing, they will all have the same problem. They may lead to decisions that reduce the wellbeing of some people without that being considered and recognised.
Fourth, because this allows us to have a purpose so that we can actually create information that meets the needs of the maximum number of users, just as financial reporting strives to meet the needs of the maximum number of users (although it then gets this wrong).
Finally, though this is a point about reporting rather than assurance, it will be important that the reports include information on management’s stewardship. Just as financial statements include a profit and loss as a means of assessing management’s decisions in generating financial returns for users, sustainability reports will need a statement that supports an assessment of management’s decisions in generating sustainability, in creating as much impact as quickly as possible. And this will have to include transparency of the trade-offs that have been made. This is the information that would, for example, be provided through use of the Capitals Coalition’s Natural, Social and Human Capital Protocols.
Decisions
The next challenge is around the decision. There are many, perhaps a majority of people who experience impacts but are not able to make decisions to increase their wellbeing and so risk not being seen as users. Sustainability disclosures that do not help decision-makers take these impacts into account are not worth the paper they are written on (or the energy used to store them digitally). The International Assurance and Auditing Standard Board (IAASB) has produced guidance on the assurance of extended external information, which covers both audit and this issue.
Paragraph 145 includes
...there may be circumstances when the stakeholders and intended users are not the same. When a stakeholder is not an intended user, their interests may be taken into account by other parties who are intended users…
This is a good start, but for this type of sustainability report, there is going to have to be the requirement that one of the users (in the sense of a user that can make decisions) must act in their interests.
And I think it would be possible to provide some guidance on which of the users should act in their interests.
For a business-to-consumer (B2C) business it would be the customer. They want the product but they also want a product that contributes to sustainability, not one that makes the world worse. At least enough of them do to argue this is still the maximum number of users. For an investment business it would be the investment manager. A simple shift in their fiduciary duty is all we need. After all, they are agents and their principals, the underlying investor (also a consumer), also want returns – but not if they make the world a worse place. For a charity, at least for example in the UK, it could be the Charity Commission, since they should already be acting in the interests of the people experiencing the consequences of the charity’s work, which cover both positive and negative consequences. For a business-to-business (B2B) relationship, the responsibility flows down the value chain from the consumer.
We now have users making decisions for a purpose and we have a defined group – perhaps not entirely representative of all those stakeholders, but a group now sharing the same purpose. And an assurance process where the provider is acting in the interests of that group. Not perfect, but without a similar disconnect that we identified earlier in financial audit. So all good.
Uncertainty
All that we need now is to address risk. A level of uncertainty for disclosure, a risk of material misstatement and a level of acceptable audit risk. The link between management decisions and impacts on others, in the absence of a bit of paper recording that transaction, is even more uncertain. But an increase in uncertainty is not a problem if the information is useful – if the user is happy making decisions despite the higher uncertainty in the information.
And again, we are addressing risk in the absence of thousands of organisations producing reports where their experience would help determine what that level of uncertainty might be. But there are things that we can use to make a start: for example, health and safety legislation. All risk-based. All downside risk. A useful and common approach to risk acceptance. But risk also relates to positive consequences, at least according to ISO 31000, the international standard for risk management. We could argue that people experiencing impacts, which are the things that are not in the accounts and therefore the things for which they have not been able to hold organisations to account, have a low tolerance and appetite for negative impacts and a higher tolerance and appetite for positive impacts. Our legal system does not generally accept the argument that ‘I didn’t know that would happen’ as an excuse. There is an idea of a reasonable expectation and so an idea of risk of missing material things, that could be explored. And purchases of lottery tickets could provide some insight into appetite for upside risk. Yes, there is work to do here but we could explore this if we wanted to. Exactly the kind of thing academic research could help with.
All fine then?
Not yet – we still haven’t solved for that first level of assurance, assurance that the rate of decisions is commensurate with expectations. We don’t know what this rate is. In financial markets it is too high, the relentless pursuit of higher returns creates customer needs that we didn’t know we had. But it needs to increase if we are going to shift any of the sustainability needles.
UNDP SDG Impact Standards and assurance
The SDG Impact Standards are effectively designed around the question – what would an organisation look like that was being held to account for both its contribution to the SDGs and the rate at which it was making decisions to increase that contribution, in line with stakeholders’ expectations? The Standards ask organisations to identify those expectations, set ambitious targets to meet them and then embed management practices to ensure decisions are being made at the rate required. If we limit assurance to reports on sustainability, we risk having assurance that the information is complete and accurate, but no assurance about whether the level of performance is as high as it could be and needs to be. We need assurance that sustainability is embedded in the organisation’s approach to its strategy, business model, operations and decision-making. SDG Impact is developing an assurance framework to meet this need.
A huge opportunity
The opportunity for assurance of sustainability reports that address an organisation’s performance in creating positive wellbeing or in making a positive contribution to sustainability is huge and fundamental. Dare I say, systemic, especially as the issues it raises would force changes to our existing approach to calculating profits, profits for some with unaccounted for costs for others. It may well mean that many organisations, as currently structured, with their existing strategies, approaches to value creation and business models, will not be able to provide disclosures that meet these requirements. If the organisation were serious and still made the report public, the report would be qualified by the assurance provider. It would mean that businesses whose sustainability performance was not driven to meet the expectations of users would struggle to attract resources. Some would close.
But the scale of transformation that our system needs if we are to avoid the precipice we face and instead create an inclusive world cannot be overstated.
There is also a significant risk that this opportunity will be lost, especially if those that seek to protect existing capital markets align with those who see accountability through accounting and audit only as something created by and for those capital markets. It can and needs to be the means of transferring power to those who experience the unaccounted-for costs that are destroying our world.
Anything less than the approach for audit of sustainability disclosures addressing these issues will just be another layer of green/impact/SDG-‘washing’, despite being carried out with the best of intentions. And what will that be good for?
I guess we should ask Edwin Starr, from the words of his famous track – War (What is it good for?).
Absolutely nothing.