I was wrong about CSR/sustainability reporting
I’ve been skeptical about the value of CSR/sustainability reporting. I now have to admit I was wrong. Partly.
For years, I viewed reporting as a necessary evil: necessary for transparency and meeting stakeholder expectations, but evil in terms of disproportionate effort and dysfunctional impacts on strategy.
I’m not opposed to reporting. Going back to the first corporate environmental reports in the 1980s, doing a report has been a great way to hold up a mirror for senior management, helping (or forcing) them to see how their company looks from the outside in. (Disclosure: ERM is one of the world’s leading providers of EHS/CSR/Sustainability reporting services.)
But I have been wary. In an early blog, one of my new year’s resolutions was:
4. Don’t confuse reporting with doing. Transparency is important, but results are more important.
Many readers agreed, saying “too much time spent chasing data to report has led to putting off long term strategizing,” or noting: “I liked #4 a lot as reporting can take an inordinate amount of time!” I’ve echoed those sentiments over the years. I’ve frequently urged clients: “Don’t let the reporting tail wag the performance dog.” I often quote a client who said: “I’m afraid my reporting is writing checks that my performance can’t cash.”
Now, though, I’m seeing companies use the reporting process as an incredible strategic tool, as a lever to raise the strategic discussion in their company. What’s changed?
Fundamentally, the reporting process (in some companies) has changed from peer competition and branding, to a truly strategic process admittedly with branding implications. Give credit to evolving GRI guidelines, growing analyst attention, and simply the maturing of the art form. Give some credit also to the great subversive work of the green whisperers.
In the past, the reporting process juggled several questions:
- What do we want to talk about?
- What good pictures, stories and data do we have that we can use?
- Who – if anyone – is listening?
- What do the loudest stakeholders want to hear about?
Increasingly, the process revolves around four very different questions:

1. What matters?
“Materiality” has finally gotten serious. It has become a true business risk process, asking “what matters to the business?” and “what matters to the stakeholders who matter to the business?”
2. What do we do about “what matters”?
This is the real strategic opportunity. You don’t have to just lunge from materiality to writing any more. This is a huge change. This step can drive deep questions of goals, priorities, and performance.
3. What do we say about what we do?
You have to talk about “what matters,” but more to the point you have to talk about what you’re doing about the issues that emerged from question #1.
4. What do we do with what we say?
In some companies the emphasis is shifting from “the report” to “communication and reporting.” It’s a process now, not an event. As one colleague pointed out, “We focus on who owns each chapter of the report going into the process. We don’t talk about who owns each section coming out of the report.” That’s the emerging challenge: integrating the annual document into an on-going process of communicating with (not just to or at) stakeholders, both inside and outside the company.
Is the process perfect now? No. Can it still take too much time and attention? Yes. Can the tail still wag the dog? Sure.
But the trend is going the right way. Some companies are using the reporting process to drive deep discussions of business risk, prioritize actions, and stimulate on-going dialog. In some cases, this is an evolution in the companies who were already leaders. In other cases, it’s a “leapfrog” opportunity for companies who are coming late to the game: they are starting out with a focus on strategy, rather than having to unlearn or dismantle a document-driven, communications-only process.
“Necessary” is increasingly trumping “evil.” I guess I was wrong.
[Scott Nadler is a Senior Partner at ERM. To share this post, see additional posts on Scott’s blog or subscribe please go to snadler.com. Opinions on this site are solely those of Scott Nadler and do not necessarily represent views of those quoted or cited, ERM, its partners or clients.]
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