Jens Riis, Thomas Trier Hansen
January 2, 2024
CSRD: Double Materiality is essentially about strategy & risk management
With the introduction of the Corporate Sustainability Reporting Directive (CSRD) stock listed enterprises and other large companies are required to provide transparency on their sustainability impacts, risks and opportunities to financial markets and affected stakeholders. If the reporting is used wisely, it can feed in to business strategies and help companies prioritise their resources in the most effective manner.
Hence enabling financial markets to make informed investment and lending decisions, taking due account of sustainability matters. Companies should do this by streamlining reporting with the requirements of the European Sustainability Reporting Standards (ESRS).
The foundation of the ESRS is to conduct a double materiality assessment that informs which ESG data should be reported across a range of sustainability themes, and development of action plans to mitigate impacts and seize opportunities. Should you desire additional information about the contents of the CSRD and the reporting requirements of the ESRS etc. then please do consult our capability statement.
In essence, double materiality assessment is an analytical process that identifies the impacts of companies on the environment and people and the sustainability risks and opportunities to which companies are exposed to or can leverage in strategy-making. The relation is depicted below.
Throughout the double materiality process, companies must identify the sustainability impacts they have on people and the environment (similar to the due diligence process detailed in the OECD Guidelines and UN Guiding Principles on Business and Human Rights) as well as the financial risks and opportunities for companies have related to sustainability matters.
The end-product of the assessments can be split into two main outputs, namely a sustainable impact matrix (negative/positive) as well as a financial risk/opportunity matrix (financial materiality). View a hypothetical example below which build on underlying ESRS guidance on the mapping of sub-topics and sub-sub topics.
Impact materiality assessment is a known tool to use as a basis for risk management and strategy creation specifically within sustainability. The basis of materiality is to identify potential or actual impacts that the company has on people and the environment, which enables the management of those impacts or the development of new products/services which has a positive impact, and evaluate those based on severity.
If used properly, the double materiality assessment can be used in the strategy and process and can allow companies to prioritise resources in an effective manner to mitigate the harm on people and the environment. Simultaneously, the process can be used to create an overview of what companies can actively do to be a force for good and create true positive impacts on society at large.
The analytical process undertaken to inform the financial risks and opportunities stemming from sustainability matters is similar to that of a classic risk management process, namely the evaluation of financial risk and how likely they are to materialise among a core set of stakeholders. This is supported by cost models, climate risk and vulnerability assessments, historic litigation costs etc. In this fashion, it is possible for companies to assess the financial value of e.g. having access to raw materials, CO2e taxes, workforce harassment or similar.
On the opportunity side, a similar process is undertaken. However, instead of insurance premiums and cost models to support the assessment, strategy reports, market trends and customer/consumer insights are used to evaluate the financial opportunity from developing new products, engaging in supply chain initiatives or expanding the business with new service offerings. In essence, information which is used to inform the strategic direction of the company.
Therefore, companies have an immediate challenge of updating their enterprise risk management and strategy processes, so they encompass sustainability risks and opportunities. This will allow companies to use processes, thresholds, and evaluation methods to apply human and capital resources in a value-driven manner.
By integrating sustainability into the enterprise risk management and strategy processes, companies can prioritise sustainability impacts, risks and classic business risk themes like talent management, exchange rate risks, consumer trends etc. using the same business processes. In essence, providing a new dimension for executive management to steer the business. An illustration of how this could look like is shown below.
Integration of double materiality into the classic enterprise risk management process, and the reporting that follows from the double materiality assessment, raises the question of where it should be anchored in the organisation.
Given the deep intersection between group functions required to produce the assessment, e.g. finance, accounting, controlling, sustainability, strategy, risk management and investor relations, there is a need to delegate responsibility to people (possibly a new function) that are able to bridge knowledge, requirements and perspectives across the company. This could be a sustainable finance team, which likely will be anchored within the Chief Finance Officer’s realm in a traditional executive management setup.
Going forward, as organisations understand the power of double materiality, it could become a key responsibility for the Chief Sustainability Officer.
Going forward, the insights from the DMA process are an important tool for executive management to steer the company towards strategic objectives by harnessing sustainability and financial factors simultaneously.
To reap the benefits of this, a few lessons learned are good to be mindful of:
- Ensure close collaboration between relevant group functions, e.g. strategy, risk management, finance, procurement and sustainability to conduct the double materiality analysis.
- Harness existing strategy, risk, sustainability and reporting processes to update and use double materiality results to create business value.
- Increasingly build the double materiality analysis on data to drive true business impact
- Have clear priorities for which impacts to mitigate and which opportunities to target based on business relevance.
Want to know more?
Jens Riis
Associated Manager
+45 51 61 26 98
Thomas Trier Hansen
Chief Advisor
+45 51 61 23 59