Ep. 225: Unraveling ESG: Understanding Environmental, Social, and Governance Factors in Business – Part 2

Get ready for part two of our insightful ESG (Environmental, Social, and Governance) discussion on the Count Me In podcast. Our expert panel, Douglas, Dan, and Catie, unpack the pressures and fraud risks inherent in ESG reporting, offering invaluable insights gleaned from real-world scenarios. But it's not just about identifying risks; they also provide practical guidance for those embarking on their ESG journey. Learn how to start with what you have, concentrate on materiality, and establish a robust, cross-functional ESG team. Tune in for an essential roadmap to navigate the complexities of ESG reporting in today's business landscape. This is one episode you won't want to miss!

Connect with our speakers:
Catie: https://www.linkedin.com/in/ctserex/
Dan: https://www.linkedin.com/in/dan-mosher-8552519/
Doug: https://www.linkedin.com/in/douglas-hileman-fsa-crma-cpea-p-e-6abbb71/

Download the reports mentioned into today's podcast:
Achieving Effective Internal Control Over Sustainability Reporting
Managing Fraud Risks in an Evolving ESG Environment

Full Episode Transcript:
Adam:            Welcome back to Count Me In. Today we have part two of Unraveling ESG. We're joined, again, by Catie Selex, Douglas Hileman, and Dan Mosher for the completion of their conversation. Now, if you didn't hear part one, I encourage you to pause right now and listen to that first. In today's episode, we explore the challenges and risks of ESG reporting, including the potential for fraud.

Our experts delve into the pressures companies face and discuss real-world examples of how well-intentioned sustainability efforts can sometimes lead to misreporting and potential fraud. But it's not all about the pitfalls, they also offer essential guidance to those new to ESG. Emphasizing the importance of starting with existing resources, focusing on materiality, and setting up the dedicated cross-functional ESG team.

Don't miss this invaluable conversation, so let's get started.

[00:00:55]       < Music >

Dan:                Doug, I mentioned the ACFE's Fraud Triangle earlier, and I'm eager to hear some of your perspectives on applying that Fraud Triangle to ESG. 

Doug:              Thank you, Dan, it can be done too. It's a familiar construct, and I was fortunate to be an in-house at a Big Four when Sarbanes-Oxley hit. And at the very beginning of designing internal controls and testing internal controls, we had to consider the possibility of fraud.

We had to design controls to prevent fraud, in audits we had to detect fraud. 

Being an environmental specialist, and then with the IIA coming out with changing their IPPF, their framework, to require testing for fraud. I've been testing for fraud and considering fraud for 20 years, in the environmental space since 2002.

It looks a little different for ESG, but not as different as you might think. There is pressure, pressure can be, "We've got to get this report out."

"The customer wants this answer."

"We have to say, for example, that our products didn't come from Bangladesh, so what the heck? How will they find out?" There's so much pressure. I see that people are involved in ESG, in this non-financial reporting, as an add-on to their jobs. It might be 20% of their job, and it's the 20% between 120 and 140% of what they're supposed to do. People are under, and companies, are under tremendous pressure to put the right answer out there. 

They have the opportunity to do so because the controls are not designed, and have not been implemented with the potential for fraud in mind. So where there are weak controls or no controls, the opportunities are there. I see this comes into play, also, when data and information comes from outside the organization. 

There's this tricky thing where so much of what we do, in ESG, is not only what the organization controls but what the organization can influence. There are some challenges there, how do you control what you don't control? 

So the opportunity is there because the controls can be weak or nonexistent. And the rationalization can be, "Well, everybody does it." 

Or "It's not about money, it's about prestige."

"It's not really this, we want the award." We've seen, for example, there's a magazine, an organization, that rates colleges, the 10 best colleges in each thing. And we've started to see, in recent years, where the colleges are even fudging the information to get the prestige of being in that award. That may have secondary effects for how many people go to that college or what they're willing to pay for tuition, but that's fraud. 

In my book, if you submit data and information that is incorrect, or inaccurate, or misleading, with the intent to deceive at the expense of others. Especially if that turns into actual or potential financial gain, I call that fraud. So that applies on all three sides of the triangle. It's just a matter of thinking about this ESG and non-financial world and how that can happen.

Dan:                Excellent, Doug. Yes, maybe, just to add a couple of extra points around those pressures and incentives. Today we are seeing that there is incentive compensation for certain executives that is linked to various ESG measures. If you think about that and the opportunity for management override of certain controls that are out there, that's a great incentive. 

If you're going to get paid a bigger bonus because of greater ESG metrics, and your ESG, for example, your emissions information is held in Excel spreadsheet, which in many cases that is the case. I saw a survey, not so long ago, of more than a thousand executives saying that, I think, it was 86% of them had their emissions data just sitting in a spreadsheet.

And if you could change that with a few keystrokes, at the executive level, to boost your bonus, someone might do that. Other things I think of are from an incentive or pressure standpoint. Things around ESG-linked bonds or credits where there are a key performance indicators and you're required to maintain those metrics, to maintain certain interest rates or payment on your bond. Those things are out there and they're going to influence some portion of those that are held to them. Catie, maybe, you have some other thoughts around this as well?

Catie:              Yes, Dan, so one of the things that we're seeing in ESG, especially because people are so compelled to make great strides on their data and to make progress towards their targets, in a very quick manner, is there's an emerging market of solutions that some are absolutely l...