Traceability and Transparency_TEST

Chapter 7

The role of public reporting and disclosure

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Publicly sharing data and policies

Public sharing of information through reporting and disclosure is a key aspect of transparency and often an objective of traceability systems. Private sector actors share information through voluntary disclosure to show progress against commitments; through third parties to demonstrate progress across actors or sectors; and to meet requirements be it at a national or company level. This chapter explores action across the transparency space and the potential impact on accountability and conditions on the ground.

Voluntary disclosure and reporting

Public reporting such as corporate social responsibility disclosure has been a common practice for decades. Originally it could have been seen as a way to showcase positive actions taken, often for reputational reasons, but disclosure processes have evolved. Corporate reporting on a wide range of issues and against company targets is now commonplace in annual sustainability reports, for example, with increasing expectations to show impact against commitments made.

Box 9 | Public reporting frameworks

There are many frameworks and standards for disclosing information publicly. The two leading standard-setting bodies for general sustainability are the Global Reporting Initiative and the Sustainability Accounting Standards Board, the latter of which was superseded in August 2022 by the International Sustainability Standards Board of the International Financial Reporting Standards organization.

In the context of forest loss and commodity supply chains, Carbon Disclosure Project (CDP) Forests is a leading platform that produces questionnaires as disclosure mechanisms with a rating. CDP Forests is aligned with the Accountability Framework initiative’s common reporting guidelines.

Financial institutions are increasingly looking at environmental, social, and governance (ESG) disclosures when assessing clients and portfolios, suggesting that for some sustainability concerns are becoming more integrated within decision-making processes. Governments are requiring companies to disclose ESG-related information, too, with the Task Force on Climate-related Financial Disclosures becoming mandatory in the UK, among other examples. This creates additional incentives for companies to demonstrate and disclose their ESG credentials, in terms of both the financial risk of investments but increasingly also the material and physical risks that climate change (including risks associated with forest loss) might have on companies. For example, BlackRock head Larry Fink’s 2022 letter to chief executive officers stated that a main factor in shaping BlackRock’s portfolio was the sustainability strategies of companies—for purely financial reasons (Fink 2022). In addition, reputational risk and consumer preference related to environmental impacts are also having a growing material effect on companies (Rijk et al. 2019; Forest 500 2022b; Wyers 2019).

Consistent application of reporting standards, definitions, and methodologies will help strengthen the uptake of their use by companies and other actors. Knowing that there is consistency across industry and potential competitors will reduce the risk of being perceived as acting alone, or sharing more information than competitors. The Accountability Framework initiative, with a consortium of expert and civil society organizations, has also developed a common methodology for assessing company progress on forest loss related to commodity supply chains based on company reporting (AFi et al. 2019). Common alignment on both reporting and assessment methodologies makes it easier for third parties to understand and compare the progress of individual companies and sectors, and mitigates the risk of different assessment agencies publishing contradictory company ratings. According to AFi’s 2020–2022 strategy and theory of change, the adoption of reporting frameworks and alignment on definitions lead to the emergence of a common language with which to talk about these sustainability issues (AFi 2020b). From this perspective, using the “right” language facilitates better behavior, leading to more effective policies, and positive impact.

Nevertheless, growing public scrutiny may represent a risk for some companies to report publicly, as good-quality, accessible reporting can open companies up to praise and/or criticism from civil society, consumers, and potentially investors. This is especially true where reporting/disclosure remains voluntary. Collaboration among organizations, including companies in commercial competition, civil society, and the public sector, as discussed in “Collaboration beyond individual supply chains,” can help reduce any such risks that may be posed by public reporting, ensuring that pressure from third parties facilitates continuous improvement.

Third-party disclosure mechanisms and role

Third-party disclosure and reporting on private and financial sector actions plays an important role in transparency and accountability, introducing into the public domain progress against stated commitments.

For some reporting and disclosure platforms, companies are invited to submit their own data, whereas others use publicly available information to assess, and often rate, company performance. There are also initiatives that merge a combination of publicly available data with self-reported information, either by companies or third parties, such as the Open Timber Portal (OTP). Examples of such initiatives include the following:

  • Global Canopy’s Forest 500, now in its 10th year, with nine reports completed to date, tracks publicly available policies and performances of the 350 most influential companies and 150 financial institutions linked to deforestation in their supply chains and investments.35
  • The OTP, developed by WRI and partners, aims to improve access to country-specific information about forest management and harvesting, and increase the effectiveness of regulations on illegal logging. The OTP compiles information from three sources: concession boundaries and the list of registered timber producers from the government; documents uploaded voluntarily by timber producers to demonstrate compliance; and observations by third-party forest monitors.36
  • SPOTT, a free, online platform developed by the Zoological Society of London (ZSL), undertakes annual assessments of companies involved in the production and trade of palm oil, timber, pulp and paper, and natural rubber. ZSL SPOTT assesses commodity producers, processors, and traders on their public disclosures regarding their organizations, policies, and practices related to ESG issues, aiming to support primarily the financial sector and supply chain stakeholders to manage ESG risks through increased and improved transparency, and incentivize the implementation of corporate best practices.37
  • WWF commodity scorecards provide global assessments including those on palm oil (Palm Oil Buyers Scorecard from 2009 to 2021)38 and, more recently, soy (first Soy Traders Scorecard in 2021) (WWF 2021), in addition to country-specific assessments, including on timber (e.g., UK Timber Scorecard from 2015 to 2019).39

In the forest sector, companies maintaining Forest Management or Controlled Wood Certification also must comply with a public reporting requirement for audit summaries.

Reporting specific to climate and forests includes the CDP questionnaires on climate, water, and forests; the Task Force on Climate-related Financial Disclosures including recommended reporting on Scope 3 emissions (i.e., those emissions that are not directly generated by a firm’s activities but that result from activities up and down its supply chain); and the early stages of the Taskforce on Nature-related Financial Disclosures. It should also be acknowledged that different reporting frameworks have been designed for different users and audiences, and this has led to a combination of definitions and metrics with overlaps and inconsistencies (GRI 2022). However, reporting and assessment frameworks such as CDP, Forest 500, and ZSL SPOTT have worked to align with the AFi standards on metrics, definitions, and reporting frameworks.

Public sector reporting

Governments and other public sector actors are also facing increasing pressure to report publicly on their own footprints (including on GHG emissions and land use due to their national consumption of commodities and products), as well as on progress achieved to date against their own targets and commitments.

For example, signatories to the Paris Agreement were expected to publish and then update their first nationally determined contributions (NDCs). According to Climate Watch, an online platform designed to empower policymakers, researchers, media, and other stakeholders with open climate data, visualizations, and resources, 170 parties (representing 169 countries and 91.1 percent of global emissions) to date have submitted new or updated NDCs.40

Furthermore, to participate in REDD+ (Reducing Emissions from Deforestation and forest Degradation), countries must develop a Forest Reference Emission Level and/or a Forest Reference Level as a benchmark for REDD+ activities.41

Countries importing agricultural commodities are increasingly concerned about their overseas land footprints. For instance, the French government has adopted a National Strategy to Combat Imported Deforestation (Stratégie Nationale contre la Déforestation Importée; SNDI). One element of this strategy is the development of a public information system to increase transparency for risk analysis and accountability. As part of this, the Ministry of Ecological Transition has worked with Trase, EFI, and Canopée to better understand France’s imported deforestation risk associated with imports of soy from Brazil and develop a new public information platform to support the implementation and monitoring of companies’ zero-deforestation commitments by increasing supply chain transparency (see also “Innovation and direction of travel of technological applications for traceability and transparency”).42 This was developed following the 2018 publication of France’s SNDI (MTOS 2018).

WWF has published two reports on the UK’s overseas land footprint—Risky Business in 2017 (WWF-UK and RSPB 2017) and Riskier Business in 2020 (WWF-UK and RSPB 2020)—highlighting the issues associated with the UK’s demand for agricultural and forest commodities, and related risks of forest (and other ecosystem) loss and degradation.43 The UK is developing a due diligence regulation on forest risk commodities (as per Schedule 17 of the 2021 UK Environment Act) recommended by the Global Resource Initiative taskforce in its 2020 Final Recommendations Report (GRI Taskforce 2020), which built on WWF Risky Business data. In addition, in the UK, the Joint Nature Conservation Committee, a public body, has developed an experimental methodology to calculate the UK overseas land footprint. (Data produced with this methodology are available on the CommodityFootprints.earth platform: https://commodityfootprints.earth; further information can be found in “Innovation and direction of travel of technological applications for traceability and transparency.”)

Public reporting: Company commitments and actions

Public reporting shows that commitments to act on forest loss have not yet reached the necessary critical mass to create a market shift in behavior.

According to the 2022 Forest 500 report (Forest 500 2022a) and a joint report by CDP and AFi (AFi and CDP 2022), an insufficient number of market actors have set commitments required to deliver the changes needed to halt and reverse forest loss. The data disclosed through CDP’s forests questionnaire in 2021 for companies44 that produce or source at least one of the seven commodities responsible for most commodity-driven forest loss (namely, palm oil, forest products, cattle products, soy, natural rubber, cocoa, and coffee) show that “only 36% of companies (245/675) have public company-wide no-deforestation or no-conversion policies and only 13% of companies have commitments to no-deforestation/no-conversion that are well-aligned with good practice” (AFi and CDP 2022).

Furthermore, “only 14% of companies (95) have a traceability target related to their no-deforestation/no-conversion commitments,” (AFi and CDP 2022) and while 76 percent of companies (512) report having a traceability system for at least one commodity, most companies have significant gaps in supply chain traceability:

  • Only 23 percent of reporting companies (157) can trace more than 90 percent of the volumes they produce or source back to the municipality level or equivalent for at least one commodity.
  • Thirty-eight percent of companies (257) report having no information about origins for at least half of their commodity volumes, and 28 percent (191) report having no traceability system for at least one commodity that they source.
  • Only 26 percent of reporting companies (177) have monitoring systems in place to assess compliance with rigorous no-deforestation/no-conversion policies or commitments (AFi and CDP 2022).

These findings show that companies often prioritize certain commodities, geographies, and/or sectors, likely following a risk-based approach to identify areas of highest risk to their businesses but recognizing that the complexity of commodity supply chains (see “Collaboration beyond individual supply chains”) has led to only partial progress being achieved.

Joining efforts with climate disclosures

A more coordinated approach between carbon disclosures on Scope 3 emissions and disclosures on the risk of forest loss within commodity supply chains could incentivize the uptake of transparency and public reporting and disclosure.

The recently launched Science Based Targets initiative (SBTi) Forest, Land and AGriculture (FLAG) sector pathway and criteria explicitly include land use change emissions and a deforestation policy requirement. This will require companies within the food, agriculture, and forest sectors to have a no-deforestation commitment, as well as enable them to set science-based targets that include land-related emissions and removals. These no-deforestation commitments also need to be aligned with the AFi, with a target date of no later than 2025 and a recommended cutoff date of 2020 (SBTi 2022c).

Additionally, all forms of land use change are included in the FLAG sector pathway model so that emissions from the conversion of other natural ecosystems and habitats (in addition to forests) must also be included and addressed as part of FLAG. Therefore, the SBTi and AFi have collaborated to ensure that the FLAG guidance builds on and is consistent with existing expectations for no deforestation and no conversion. In this way, climate and forest commitments are aligned and co-supported (SBTi 2022b).

The number of companies committing to set SBTs continues to grow (over 4,000 in December 2022), along with those that have approved SBTs (over 2,000 in December 2022).45 The SBTi has illustrated an increased rate of emission reductions among companies that are committed within the SBTi compared with those that are not, showing the potential influence this new FLAG sector pathway model could soon have (SBTi 2022a).46,47

Lessons

  • Transparency, both in terms of policies and progress, is growing across the private and public sectors. This is not only a trend in the context of forest loss, but also a broader global trend across diverse sectors, in particular climate change mitigation. There are several factors that can contribute to continued improvements in transparency and the emergence of a productive open data ecosystem.
  • A central enabling condition is the setting of reporting standards. Standard-setting and disclosure bodies, such as the AFi and CDP, have taken efforts to align their frameworks and are working to improve alignment with other bodies such as SBTi and the Sustainability Accounting Standards Board. This eases the process of disclosure by reducing the burden on private sector actors to meet different requirements and allows greater comparability across reports, enabling actors, such as financial institutions or civil society, to make better informed decisions about where to apply their pressure to improve the sustainability of supply chains. However, these standards are limited in their impact by the number of actors that are reporting.
  • Government-mandated disclosure is a powerful tool to increase levels of reporting. Learning from and being consistent with those used by the civil society, private, and financial sectors would support the standardization of approaches. The inclusion of Scope 3 emissions into mandatory climate disclosure obligations presents another opportunity with which to encourage data collection and reporting of actors on the impact of their value chains on forest loss.
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