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What has the Charity Commission ever done for us?

If we apply Monty Python’s analysis of the Roman Empire to current challenges of reporting performance on ESG and corporate impact – we may find that charity reporting already has the answer.

First published by Pioneers Post

We are in the middle of a boom for sustainability-related information. Driven by the growing realisation of the risks arising from climate change and inequality, a realisation that has now permeated into capital markets.

Every day there is a new tool for ESG or SDG or sustainability reporting. Recent proposals for a European Corporate Sustainability Reporting Directive and for IFRS to establish an International Standards Board alongside the International Accounting Standards Board will make some form of non-financial reporting as commonplace as financial reporting.

Though there are some murmurs of disquiet – both from those who argue all this is an unnecessary burden, and from those who argue that current proposals do not go far enough. Olivier Boutellis, the CEO of Accountancy Europe, has recently co-founded North Star Transition, which argues:

ESG’s ascendancy is a strong signal that the finance community has begun to recognise the convergence of societal and commercial value. However, the current approach is not going to deliver in the way we need: it focuses on “doing less harm” rather than truly delivering transformative societal outcomes, and it exacerbates the multiple crises we now face including the climate emergency, biodiversity loss and social disenfranchisement.

Others have argued that the focus of ESG is on providing information to investors to help them assess the risk to expected financial returns and perhaps to understand how management is mitigating that risk. But not on understanding the consequences of a business’s operations and its contribution, or not, to sustainability. The UNDP SDG Impact Standards seek to address this by focusing on the practices that an organisation has in place to make decisions that make a positive contribution to sustainability and the SDGs. We need both.

But it is not impossible, as Jennifer Howard-Grenville argues in a recent article for the Harvard Business Review. It will also get easier the more the focus shifts to management decisions to address those impacts, which would permit a risk assessment of any impact information being used in decisions considering completeness as well as accuracy. There are others that also argue that measurement should focus on changes in wellbeing and decisions to improve that in line with global goals. The Impact Management Project’s impact dimensions, Social Value International’s standards and the Capital Coalition’s Protocols, to name a few, are all voluntary initiatives, working on standardisation, that support communities of practice that are exploring how to do this in practice.

Measurement of ESG tends to focus on inputs and outputs, the existence of policies and measures of activities – but not on the resulting changes to the wellbeing of people and the planet

Measurement of ESG issues also tends to focus on inputs and outputs, the existence of policies and measures of activities or on sustainability topics – but not on the resulting changes to the wellbeing of people and the planet. Increasingly, the shorthand for this is ‘impacts’ but given outcomes and impacts are still used in different ways it is safer to spell this out. Of course, ESG could be measured based on changes in wellbeing. The reason that it currently is not, is that measuring outcomes, let alone impacts is seen as too hard. And given it’s the people experiencing these impacts who would need to tell us what they were, it’s even harder.

But these are all voluntary initiatives. Are there any examples of regulatory or legislative requirements that expect organisations to understand and manage outcomes and impacts?

Yes, that was a rhetorical question – as the answer is yes.


Charity: higher expectations

In terms of assets or turnover, charities are generally somewhat smaller than investment funds and corporates and have fewer resources to do all this difficult stuff.

And yet…

In the UK the Charity Governance Code has a few things to say about this.

1.2 The board can demonstrate that the charity is effective in achieving its charitable purposes and agreed outcomes.

1.4.2 The board evaluates the charity’s impact by measuring and assessing results, outputs and outcomes.

1.5.3 The board recognises its broader responsibilities towards communities, stakeholders, wider society and the environment, and acts on them in a manner consistent with the charity’s purposes, values and available resources.

And there is more in the charities’ SORP (FRS102), the statement of recommended practice for charity reporting. This says it’s recommended but “all charities must use the SORP to prepare their accounts unless the trustees have opted to prepare receipts and payments accounts and their charity is a non-company charity which had an income of £250,000 or less in the reporting period”.

1.14 The SORP’s requirements that all charities must follow in their annual report are set out in the following headings:

  • objectives and activities;

  • achievements and performance;

  • financial review;

  • structure, governance and management;

  • reference and administrative details;

  • exemptions from disclosure; and

  • funds held as custodian trustee on behalf of others.

It’s easier to quote than summarise but I have highlighted the key parts.

1.41 In particular, the report must review:

  • the significant charitable activities undertaken;

  • the achievements against objectives set;

  • the performance of material fundraising activities against the fundraising objectives set;

  • investment performance against the investment objectives set where material financial investments are held; and

  • if material expenditure was incurred to raise income in the future, the report must explain the effect this expenditure has had, and is intended to have, on the net return from fundraising activities for both the reporting period and future periods.

1.42 The report should provide a balanced picture of a charity’s progress against its objectives. For example, it may explain progress by reference to the indicators, milestones and benchmarks the charity uses to assess the achievement of objectives.

1.43 In reviewing achievements and performance, charities may consider the difference they have made by reference to terms such as inputs, activities, outputs, outcomes and impacts, with impact viewed in terms of the long-term effect of a charity’s activities on both individual beneficiaries and at a societal level. Charities are encouraged to develop and use impact reporting (impact, arguably, being the ultimate expression of the performance of a charity), although it is acknowledged that there may be major measurement problems associated with this in many situations.

The last point is important.

Much of the above, in both the charities’ SORP and the Charity Governance Code, requires charities to report on the effect they are having on people’s lives, in line with objectives but recognising that there may be negative effects. The Governance Code has a higher expectation than the SORP since the SORP acknowledges that there may be major measurement problems.

There may be problems but, as I have argued previously in this series, measurement problems are not always a barrier to producing useful information, either in the context of making decisions to increase impact or in the context of financial reporting where existence, outcome and measurement uncertainty are all recognised and assessed in deciding on whether information can be disclosed.

If charities can find ways to do this surely business can too

And there are many examples of excellent charity reports. To take an example from just one of these, youth sports charity Street League, which includes performance information compared to both trend and targets (and also covers negative outcomes):

During the year ended 31 March 2019, Street League progressed 1,171 young people into work, education or training, this allows for only one progression per young person supported. This represents a 29% reduction compared to the previous financial year (1,171/1,656) and did not achieve our target for the year (1,387). The number of young people who had successfully sustained employment for six-months as of 31 March 2019 was 57% (390/679), a decrease on the previous year of 5% (62%:656/1, 050) against our target of 60%.

This report combines the financial with the social and environmental reporting in one report. In another example, the FRC Group, a Liverpool based social enterprise where I am a director, produces an annual report that goes further. The social and environmental information makes up most of the directors’ report in the accounts and audited against ISAE 3000 and AA1000AS. Two audit reports in one set of annual accounts!

I do not get it – if charities can find ways to do this surely business can too. Charities do because their purpose, and the eco-system around them, is to create changes in wellbeing. The only reason then that corporates and other businesses do not is because that is not their purpose and they are not required to. Putting a purpose back into business is the focus of the British Academy’s Future of the Corporation Programme.

Back to the question of audit. One particularly good part of the European Commission’s proposals for Corporate Sustainability Reporting is a requirement that reports should be audited. I suspect that businesses will not be keen and that charities would not be keen if the Charity Commission suggested the same. Though we should remember that an audit is not for the organisation itself. In financial reporting it is there to protect investors and for charity reporting it would be there to protect beneficiaries. For both, it will increase effectiveness. FRC Group’s report shows that it is possible.

Despite not requiring an audit, what (to paraphrase Monty Python’s analysis of the positive and negative impacts of the Roman Empire) ­did the Charity Commission ever do for us? Other than Governance Codes, and a SORP, and a focus on public benefit.

Given all the debates on mission-led, purpose-driven business, on broadening performance management to cover impact, on ESG and so on, I am left wondering whether it would not be a lot easier if we just made all businesses report using the same framework as charities.

Although charities do this because of their purpose, other businesses could because society demands it. The point is, being a relatively small organisation is not a barrier. This would move us a long way towards reporting performance on managing positive and negative impacts, against purpose and targets. Then all those voluntary initiatives I referenced above would become the basis for general company reporting and we could add making a significant contribution to corporate sustainability reporting to the list.

If you can think of any reasons why not, please let me know!


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