Significance and Use
4.1 Purpose—This guide provides an overview of frameworks used for environmental, social, and governance (ESG) disclosures applicable to a variety of organizations. This guide provides users with information on the history of ESG disclosure frameworks, the components that comprise ESG disclosures, the target audience of these disclosures, and the challenges associated with this topic.
4.2 How to Use Information—This guide is intended to provide a brief overview of ESG disclosure frameworks and considerations. The users of this guide are encouraged to review the sections of this guide and the supplemental information provided in the Appendices to this guide which include example templates and further discussion on key topics relevant to ESG disclosures.
4.3 Who Should Use Information—The intended users of this guide may include a diverse range of stakeholders such as industries and companies that use, make, or sell products; regulators at federal, state and local levels; consultants and vendors; consumers; investors; academic researchers and students; non-governmental organizations (NGOs); and community constituents. Over the past 35 years, this topic has been the subject of increasing corporate, regulatory, consumer, ratings agencies, and stakeholder interest.
4.4 Regulatory Context—This guide reviews regulatory developments regarding ESG disclosures in the U.S. and internationally. This guide provides a brief overview of regulatory developments and trends regarding ESG disclosures. Users of this guide should stay current on the regulatory requirements applicable to their operations, products, services, and supply and value chains.
4.5 Frameworks—This guide provides an overview of ESG disclosure frameworks in the U.S. and internationally. There are several voluntary frameworks that provide guidance for ESG disclosures, such as GRI, TCFD, the Value Reporting Foundation, and the Stakeholder Capital Metrics framework (developed by the World Economic Forum and the major accounting firms). In the U.S., the practice of voluntary, market-led disclosures using multiple guidelines is developing into a more standardized but flexible approach. This stands in contrast to the European Union where specific standardized directives have been adopted.
4.6 Professional Judgement—An organization’s ESG disclosures require professional judgement regarding approaches to the selected ESG elements, and their alignment with the organization’s actual practices, as considered alongside many other factors. Explanations should be clear, concise, and well documented regarding how ESG disclosures were made and evaluated using goals established under selected ESG frameworks. Policies and procedures that address ESG disclosures should be documented and part of the organization’s relevant practices. Compliance personnel should be knowledgeable about the organization’s specific ESG-related practices. Factors requiring professional judgement should include a clear, well documented rationale.
4.7 This guide is not intended to replace or supersede federal, state, local, or international regulatory requirements. Users of this guide should confirm the regulatory guidance and requirements for the jurisdiction in which they are working. This guide may be used to complement and support such requirements. This guide does not replace the need for engaging competent persons in ESG disclosure.
Scope
1.1 This guide provides an overview of frameworks used for environmental, social, and governance (ESG) disclosures applicable to a variety of organizations.
1.2 This guide discusses the history and purpose of ESG disclosure frameworks, as well as the challenges associated with the greater interest in and broader requirements for transparency and accountability in the information used in disclosures.
1.3 The focus of this guide is the array of ESG disclosure frameworks and the regulatory context for organizations making ESG disclosures including climate and community concerns.
1.4 The goal of this guide is to improve the users’ understanding of ESG disclosure frameworks and to outline but not to supersede federal, state, tribal, and local regulatory requirements, and guidelines for disclosures. This guide can be used in situations where there may not be a regulatory requirement or framework for disclosure, or where the user wishes to conduct voluntary disclosure initiatives. In addition, it can also be used to standardize efforts when several different disclosure requirements apply to an organization.
1.5 This guide is organized as follows:
| Section 1 | Scope |
| Section 2 | Referenced Documents |
| Section 3 | Terminology |
| Section 4 | Significance and Use |
| Section 5 | Overview of ESG Disclosure Requirements and Guidelines |
| Section 6 | Overview of ESG Disclosure Frameworks |
| Section 7 | Common Elements of ESG Disclosures |
| Section 8 | Data Sources and Metrics |
| Section 9 | Materiality Determinations |
| Section 10 | Communications Methods and Best Practices |
| Section 11 | Keywords |
| Appendix X1 | Resources for this Guide: Weblinks |
| Appendix X2 | Example State and Municipal Disclosure Requirements |
| Appendix X3 | Example Industry-Specific Disclosure Templates |
| Appendix X4 | Databases for Federal Environmental Criteria |
| Appendix X5 | Resources for Social and Governance Criteria |
| Appendix X6 | Resources for Consumer Focused ESG Disclosures |
| Appendix X7 | Resources for ESG Disclosures: Enterprise Software Platforms |
| Appendix X8 | Overview of ESG Ratings |
1.6 Before beginning the ESG disclosures process, organizations should document the information and data identified and evaluated, clarify the professional judgement factors considered during decision making and state how those factors influenced decisions or actions, and document the relevant technical policy decisions. The organization should verify that the data and information which are to be used in the ESG disclosures process, including historical data and current data, will be relevant to and of sufficient quantity and quality to answer the questions posed and the decisions made in the ESG disclosures process.
1.7 The ESG disclosures should be appropriate, relevant, and decision-useful disclosures suited to a particular request, purpose, or target audience.
1.8 The ESG disclosure frameworks discussed in this guide vary widely in ESG elements. For example, some ESG frameworks focus only on disclosure of a select set of environmental factors such as regulated emissions. The wider range of ESG elements that may be disclosed are summarized below.
1.8.1 The environmental component of the disclosures might focus on an organization’s impact on the environment—for example, its energy and water inputs and pollution outputs. It also might focus on the risks and opportunities associated with the impacts of climate change on or by the company, its supply chains and value chains, its industry, and the communities in which its facilities and operations reside. Key elements of the environmental component may include carbon footprint; resource consumption; resource depletion; energy efficiency; renewable energy; greenhouse gas emissions; waste reduction, recycle, reuse, and waste management; pollution prevention; and issues related to environmental justice.
1.8.2 The social component of the disclosures might focus on the organization’s relationship with people and society—for example, opportunities and risks for diversity and inclusion; human rights; the rights of Indigenous People; specific faith-based issues; health and safety of employees, customers, consumers, and communities, both locally and/or globally; company investment in its local community; and how such issues are addressed by the organization in its facilities and its value and supply chains. Key elements of the social component of disclosures may include employee relations; customers and consumer relations; supply and value chain management; workplace health and safety; human rights; and community relations.
1.8.3 The governance component of the disclosures might focus on as how the organization is run—for example, transparency and reporting; ethics; compliance; shareholder rights; and the composition and role of the board of directors and/or senior management team. Key elements of the governance component of disclosures may include organizational structure; diversity; compensation; business ethics; reporting; transparency; oversight; communications; regulatory compliance; tax strategy; political actions (such as lobbying and campaign contributions); investor relations; shareholder and stakeholder rights; and decision-making regarding opportunity and risk management strategy for the organization, and its value and supply chains.
1.9 This guide assists users in navigating the array of various ESG disclosure frameworks. It is not the intent of this guide to define the technical decisions or professional judgements appropriate for each user, but rather to provide information on the existing decision frameworks.
1.10 This guide recognizes the complexity and diversity of topics related to ESG disclosures and provides technical support for a range of ESG disclosure applications. ESG factors are an increasing focus of regulatory guidance, consumer demand, investor goals, academic research, and industry efforts to manage risk and maximize return.
1.11 This guide provides an overview of ESG disclosure requirements and frameworks and provides resources for organizations in making their disclosures. It is beyond the scope of this guide to evaluate potential impacts of climate change, or to review the outcomes of decisions taken by organizations, or to analyze the cost/benefit determinations made by organizations on the negative vs. positive impacts of technological advances that may or may not contribute to climate change.
1.12 The guide user’s legal counsel should be consulted regarding information and data designated for the disclosure process, which should be evaluated for compliance implications potentially associated with its public release (such as compliance with environmental laws; regulations; and terms or conditions of permits and consent agreements). Review of alignment of ESC policy with fiduciary duty should be included in this consultation.
1.13 This guide is intended to complement, not replace, existing regulatory requirements or guidance. ASTM International (ASTM) guides are not regulations; they are consensus-based standards that may be followed as deemed appropriate by guide users.
1.14 Units—The values stated in International System of Units (SI) units are to be regarded as the standard. Refer to: IEEE/ASTM SI 10 American National Standard for Use of the International System of Units (SI): The Modern Metric System.
1.15 This standard does not purport to address safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.
1.16 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
