For those of us basking in the glory of meeting our 2021 ESG reporting deadlines, I regret to inform you that it’s almost time to gear up again. I know, I know…it feels like we just finished! But while you may understandably be reluctant to reopen that dusty desktop folder you had been living out of not too long ago (and which you were all too happy to finally close), it’s never too early to start planning.
So let’s make this a little bit easier and start with something achievable: an annual ESG gap analysis.
An ESG gap analysis is a valuable tool that can help you take a step back, understand how you’re doing, and identify where you should invest more time and resources. Used in conjunction with a materiality assessment, a gap analysis can help you quickly determine the topics and considerations relating to ESG that should rise to the top of your list, allowing you to craft a meaningful action plan.
And while it can be helpful to differentiate your ESG programming gaps (i.e. your activities) from your ESG reporting gaps, we believe that both of these concepts inherently inform one another, and should be considered as two sides of the same coin. ESG reporting and disclosure requirements can serve as a blueprint for your broader ESG program, helping you structure and refine your efforts and revealing what your focus areas should be.
Below, we’ll walk you through a step-by-step process to identify key ESG priorities and information gaps so that you can identify the proper set of actions to take as you look ahead to next year. This high-level framework can serve as a starting point for taking inventory of where your ESG program stands today – and where you should take it tomorrow.
Remember: there is no single right way to approach ESG; every organization is different. Let our suggestions be a guide and tailor them to your circumstances as needed. Let’s get into it!
Step 1: Rank ESG Topics for Disclosure by Order of Importance
As with many things, we recommended starting your ESG gap analysis at the highest level and working your way down.
To start, jot down all of the ESG topics relevant to your business that you may be required to report on, and rank them in order of importance.
Here’s an example of what that might look like:
Table 1: ESG Topics
|Order of Importance||Environmental||Social||Governance|
|1.||Energy Management||Supply Chain Management||Compensation Policy|
|2.||Energy Management Systems||Diversity Equity and Inclusions||ESG Reporting Standards|
|3.||Greenhouse Gas Emissions||Health & Safety||Board-level Oversight – ESG|
|4.||Climate Change, Opportunities and Risk||Stakeholder Engagement||Governance Policies|
|5.||Environmental Policies||Workforce Development||Risk Assessment|
The goal is to create a list you can quickly scan through to see which topics rank as top priorities and which don’t. It can also be helpful to make note of topics where you have already made significant progress, and ones which may require a bit more attention going forward. And remember: you can’t do everything at once, so if you start to get overwhelmed with competing priorities, refer back to your materiality assessment to ensure you stay laser-focused on the topics that matter most.
Step 2: Note the Gaps (and Overlaps) in Your Reporting/Disclosure Strategy
Before springing into action, we advise that you next take the time toconduct an ESG disclosure gap analysis. This will allow you to catalogue the specific outcomes and key performance metrics you may be required to disclose, whether for voluntary disclosures and frameworks or for mandatory compliance purposes. Remember: disclosures inform actions, and vice versa – especially in the ESG world. From here, you will be able to easily identify gaps and overlaps in the information needed to satisfy the requirements of various ESG disclosures and benchmarks.
In the example below, we’ve taken our top “E” topic from Step 1 (Energy Management) and provided examples of relevant disclosures and frameworks – and the key performance metrics that each encompasses:
Table 2: Energy Management Metrics
|CDP||DJSI||GRESB||GRI||ISS & ESS||SASB||TCFD|
|Energy consumption data coverage as a percentage of floor area, by property subsector.||X||X||X||X||X||X||X|
|Total energy consumed by portfolio area with data coverage, percent grid electricity, and percent renewable, each by property subsector.||X||X||X||X||X||X||X|
|Like-for-like change in energy consumption of portfolio area with data coverage, by property subsector.||X||X||X||X|
|Amount of reductions in energy consumption achieved as a direct result of conservation and efficiency initiatives.||X||X||X||X||X|
|Energy efficiency measures implemented in the last three years.||X||X||X||X||X|
You can do this for all relevant ESG topics and frameworks to figure out which frameworks you should disclose to – or perhaps you already have an idea of the frameworks you’d like to focus on (e.g. GRESB and CDP) and want to limit this exercise accordingly. Either way, by identifying the gaps and overlaps between the metrics required for various disclosures, you can begin to understand the level of effort that each disclosure will require – and where it’s possible to kill a few birds with one stone.
It can be helpful to think about the information you need to gather for ESG disclosures across the following categories (which broadly correspond with an increasing level of effort):
- Information you currently have
- Information you do not have, but can easily obtain
- Information you do not have and cannot easily obtain
In all, the goal is to take a step back, understand at-a-glance which ESG disclosures require which pieces of information, estimate the level of effort required to collect the information, and – with all that in mind – prioritize the right ESG disclosures for your organization.
Step 3: Rephrase Metrics as Goals or Actions
This is a small, simple tactic that might seem redundant. But we’ve found it to be enormously helpful when it comes to breaking down work into digestible actions – especially work in the ESG realm, which can often seem nebulous or confusing.
When you’ve finished populating the sample table above for your desired topics and frameworks, and have identified your top list of ESG disclosures, rephrase each performance metric as a high-level action by tacking an action verb onto the beginning and parsing out any specific steps you know you will have to take in order to complete the activity.
In our continuing Energy Management example, let’s assume that we now decide we want to focus on GRESB and CDP. Here’s what our list of action steps might look like:
Table 3: Energy Management – Actions
|Collect energy consumption and calculate data coverage as a percentage of floor area, by property subsector.|
|Calculate total portfolio energy consumption and coverage, differentiate grid versus renewable energy and calculate total percentages of renewable vs. grid energy consumption.|
|Isolate operational buildings with 24 months of data and calculate their like-for-like change in energy consumption and data coverage.|
|Identify energy efficiency conservation projects and calculate total reductions in energy (kwh) associated with these projects.|
|Identify all energy efficiency measures at each building in the portfolio implemented in the last three years.|
Voilà – we have a clear, actionable checklist that lays out exactly what we will need to do in which area to prepare for GRESB and CDP.
Step 4: Build Out Your ESG Action Plan
With all of this information in hand, return to your ESG priorities and gap analysis and work backwards, making informed decisions about which steps you can realistically take (and by when) to arrive at your desired outcomes (which could include anything from: successfully submitting to CDP for the first time, being ahead of the curve when it comes to GRESB next time around, or simply focusing on a specific performance metric to improve in 2022).
Questions to ask yourself when developing your plan and deciding how to prioritize various actions:
- Does this fall under a high priority ESG topic for my business? Refer to the first exercise in Step 1 and your materiality assessment.
- Do I have enough information to disclose on this topic? If not, can I get this information easily?
- Is this a common metric used in one or more reporting frameworks?
- What actors would need to participate to develop and implement these actions?
- What actors would need to participate to collect the relevant data needed for my ESG disclosures?
- Is there any technology that can help me implement, collect and report this information?
- What dates can I reasonably accomplish specific tasks for each goal/action by?
- What goals can I realistically accomplish this year and what can I begin to work towards for next year?
- What is my budget to complete these activities?
ESG as a business practice can frequently seem daunting and overly broad – but it doesn’t have to be. And ironically enough, ESG disclosures (labor-intensive though they may be in the moment) can actually help you reduce and simplify the amount of work required to build a forward-looking plan for your ESG program. While the framework we’ve shared above might require a little advance work, it should set you up for success in the long run. And whether you need to make the case to your executive management team for next year’s ESG initiatives, or just want to get a clearer picture of the areas you should be focusing on, we hope that this template can lend a hand and help illuminate the path forward for your organization.
ESG frameworks change annually, so we recommend repeating this process each year as a core playbook for your ESG program.
Looking for help to conduct a gap assessment and tie it back to your ESG strategy? Please email the author, Emily Christoff for more information.