Ghana: ESG Reporting In The Ghanaian Ecosystem

Introduction

ESG has quickly become the new buzzword, particularly in corporate circles. In the last decade or so, the concept has grown rapidly and continues to grow especially across major financial markets.¹ A 2022 study on ESG's momentum showed that more than a quarter of global investors consider ESG as vital to their investment approach.² Beyond financial markets, businesses and organizations have moved from a place of pure business profitability to focusing on the impact of their operations on the community at large. This requires transparency with various stakeholders, prime amongst them being investors and financiers. As part of the drive towards transparency and disclosure, 'ESG reporting' also known as 'Sustainability reporting' is being championed by stakeholders across the globe. Various metrics and standards have been developed in different countries to serve as a guide for companies in ESG reporting. Ghana is not left out of this drive as ESG reporting in Ghana is on the rise. Before we explore what ESG reporting in Ghana involves, we will consider the genesis of this framework.

Defining ESG and Why it Matters

ESG is an acronym representing Environmental, Social and Governance. It is an umbrella term that describes the framework used by stakeholders to assess how environmental, social and governance factors affect the sustainability of the operations of companies and states.³ It was first mentioned in a 2004 report by financial institutions under the auspices of the United Nations titled "Who Cares Wins". This highlighted the need for the financial industry to better integrate practices that promote sustainability in environmental, social and governance issues in their operations.⁴

Environmental considerations refer to a company's environmental impact and risk management practices such as steps to preserve natural resources, promote energy efficiency, as well as curb pollution and climate change. The social pillar on the other hand covers the company or organisation's relationship with stakeholders and deals with issues such as employee engagement, human rights, health and safety, and diversity and inclusion. The governance pillar tackles the management of institutions and encompasses board structure and diversity, bribery and corruption, and conflict of interest, anti-money laundering, among others.

The concept of ESG is not meant to just be another headache business leaders must grapple with. On the contrary, it holds a lot of good for businesses. A commitment to ESG ensures efficiency and growth as businesses are able to maximize their use of resources. It also makes a business better placed for investment opportunities as investors are more critical of companies' ESG feats due to social pressure.⁵ Further, the paradigm shift from pure profit-making to sustainability creates a more people-oriented setup and helps retain talent.⁶ ESG has the long-term effect of improving the overall financial performance of a business. The requirement of compulsory disclosure on how institutions are incorporating ESG, has resulted in the development of ESG reporting standards.

What is ESG Reporting?

ESG reporting, also known as Sustainability reporting is a means of evaluating or measuring how organisations integrate ESG elements into their operations.⁷ They consist of strategies and operations which would create a palpable value beneficial to stakeholders and their respective companies. It helps companies communicate and allows stakeholders to track both the positive and negative impact of the company's actions in respect of the ESG elements and accordingly set priorities.⁸ It also serves as an opportunity for companies to be more transparent about the risks and opportunities they encounter in safeguarding the ESG factors.⁹ ESG reporting creates a culture of sustainability in companies which aids their growth more progressively than ever before.¹⁰

International ESG Reporting Standards

ESG reporting has gained prominence due to stakeholder and investor demands for more disclosure and transparency on ESG initiatives.¹¹ This has led to the development of plethora of internationally-recognised ESG reporting standards.

Such internationally-acclaimed ESG reporting frameworks serve as guiding principles for ESG reporting among corporate institutions while ESG reporting standards provide these institutions with the tools to follow through on the guiding principles. Some of these standards and frameworks are specific to one pillar of ESG while others are designed to report on all the ESG pillars.

Standards such as the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards S1 General Requirements for Disclosure of Sustainability-related Financial Information; ¹² and the European Financial Reporting Advisory Group (EFRAG) Standards¹³ focus solely on the disclosure of financial information.

The International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards S2 Climate-related Disclosure;¹⁴ Climate Disclosure Standards Board (CDSB) Framework; the Carbon Disclosure Project (CDP) and the Task Force on Climate-Related Financial Disclosures (TCFD) Framework report on climate and environmental-related risks and opportunities.

Standards such as the Global Reporting Initiative (GRI) Standards¹⁵ and the United Nations Global Compact¹⁶ are more holistic and cover sector-specific and topic-based sustainability reporting across all the ESG elements.

ESG Reporting in Ghana

Ghana's ESG ecosystem can be described as budding. Before the development of consolidated ESG-specific standards or frameworks, Ghana relied solely on ad hoc provisions in statutes that made references to ESG.¹⁷ Further, provisions within certain statutes, predominantly those of the oil and gas and mining sectors, mandate some manner of ESG reporting. These reports are however largely focused on the environmental pillar of ESG.¹⁸

There have also been several sectoral corporate governance codes for regulating governance in various sectors, such as the Securities and Exchange Commission (SEC) Code for Listed Companies (2020), the Bank of Ghana (BoG) Corporate Governance Directive of 2018, the BoG Corporate Governance Directive for Rural and Community Banks (2021), State Interests and Governance Authority (SIGA) Code (draft), and the Public Services Commission Code.

Efforts are also being made to create awareness about ESG and to encourage the integration of ESG standards into the framework of businesses. ESG in Ghana has received a major boost with the Integrated ESG (IESG) programme, which was launched by the International Finance Corporation (IFC) in partnership with the Swiss State Secretariat for Economic Affairs (SECO) to emphasise the need for financial institutions to develop a set of regulatory and market mechanisms that stress on the assimilation and implementation of better ESG standards.¹⁹

As part of such efforts, two major consolidated ESG reporting frameworks have been developed in the country. These are the Sustainable Banking Principles and Sector Guidelines (SBP) and the Ghana Stock Exchange Guidance Manual for Disclosures on ESG reporting for listed companies²⁰.

• The Ghana Sustainable Banking Principles and Sector Guidance Notes (SBP)

The SBP was launched by the Bank of Ghana together with the Ghana Association of Bankers in November 2019. The Principles are to aid banks to respond effectively to current global issues including human security, anti-money laundering, economic and social inequality, information communication, transparency and disclosure, corporate integrity, and environmental and climate change.²¹ The SBP consists of 7 General Principles and 5 Sector Specific Guidance Notes. The Principles serve as a framework to guide banks, financial institutions, and stakeholders to ensure that sustainability remains an integral part of their operations and dealings. The Sector Guidance Notes are to give banks and financial institutions a sense of the practical application of the SBP. The Principles are to be applied to five key sectors of the economy: Agriculture and Forestry; Construction and Real Estate; Manufacturing; Oil and Gas and Mining; and Power and Energy. They are:

• Principle 1 - Environmental and Social Risk Management (ESRM)
• Principle 2 - Internal Environment Social and Governance (ESG) in banks operations
• Principle 3 - Corporate Governance and Ethical Standard
• Principle 4 - Gender Equality
• Principle 5 - Financial Inclusion
• Principle 6 - Resource efficiency, Sustainable Production and Consumption
• Principle 7 - Reporting

For each of the seven (7) principles, the SBP stipulates the importance; provides direction on where and how the Principles apply; and lists key performance indicators (KPIs) to include within the financial institution's sustainability strategy as well as steps for the implementation of the Principles.

The Reporting Principle particularly requires banks and other financial institutions to report on the six (6) other Principles. The implementation of the Reporting Principle comprises 3 phases. For the first phase, banks and other financial institutions are expected to submit a qualitative description of plans and action for implementation of the other Principles to the Bank of Ghana for review.²² The Bank of Ghana will then organize all qualitative reporting received and provide feedback to each bank (privately) as an indication of the bank's progress. The second phase requires banks and other financial institutions to select KPIs and set targets against those KPIs.²³ The Bank of Ghana will collate all reports received and provide each bank (privately) with an indication of their progress relative to all other banks. For the third and final phase, banks are required to demonstrate continuous progress towards the KPIs set at Stage 2 and set new targets once the timelines for old targets have lapsed.²⁴

In its bid to encourage compliance with the SBP, the BoG recently organized an industry engagement that opened participants up to deeper conversations on the SBP with a focus on Principles 3-7.²⁵

Monitoring, Guidance & Reporting Template

Additionally, the BoG has issued a Monitoring, Guidance and Reporting Template to be completed by banks biannually to monitor the levels of implementation of the Principles and Guidance Notes.²⁶ The template serves as a checklist for banks for the SBP implementation strategies. The banks appear to be already on the compliance track. At the 26^th National Banking Conference, Mr. Osei Gyasi, Head of Banking Supervision at the BoG, representing the Governor of the BoG, disclosed that all 23 universal banks in the country have completed and submitted their template reports developed by the regulator in addition to its SBP.²⁷

• Ghana Stock Exchange Disclosures Guidance Manual

The Ghana Stock Exchange Guidance Manual ("GSE Manual" or "Manual") was developed by the GSE to guide listed companies and other companies interested in ESG reporting to garner, analyse and publicly disclose important ESG information via an internationally accepted sustainability reporting standard.²⁸ The GSE Manual like the SBP, also reflects ESG Principles. It further lists the key steps in ESG reporting, Mandatory ESG Disclosures in ESG Reporting, and ESG reporting requirements from other organizations. It is important to state that the GSE Manual does not make ESG reporting mandatory but only serves as a guide.

The Manual recommends the use of Global Reporting Initiative (GRI) Standards for ESG reporting by listed companies in Ghana. The GRI Standards recognize the relevance of aligning corporate sustainability reporting with the information needs of stakeholders like governments, stock exchanges, and market regulators, providing decision-useful data to direct capital towards sustainable business practices.²⁹

Listed companies in Ghana are required to include the following ESG topics in their ESG reports as a bare minimum:

Listed companies may however add on additional disclosure topics.³⁰ More so, the mandatory disclosure topics above must be referenced by listed companies in Ghana to regulatory instruments which include Securities and Exchange Commission - The Corporate Governance Code for Listed Companies, 2020; the GRI Standards for Sustainability Reporting; IFC Performance Standards on Environmental and Social Sustainability; the UN Guiding Principles on Business and Human Rights; the World Federation of Exchanges ESG Metrics; the Environmental Protection Act (Ghana); the Consumer Protection Act (Ghana); the Data Protection Act (Ghana); and the Sustainable Development Goals.³¹

The GSE Manual further spells out the reporting Principles and format observed under the GRI Standards and demonstrates how companies can report on the Sustainable Development Goals via ESG reporting.³²

Conclusion

ESG is not just a 'PR' move or a means for businesses to attract bigger gains. Beyond being the new big thing and meeting the "E", "S", and "G" components, ESG is the future, one we must embrace. In the words of Hendrith Vanlon Smith Jr., "To survive in this century, every company must be on a continual journey of transformation." As part of embracing this transformative future, Ghana, like the rest of the world, is taking strides to ensure ESG reporting is integrated into our corporate culture. The recently developed Ghana Sustainable Banking Principles and Guidance Notes; and Ghana Stock Exchange Disclosure Guidance Manual are only our initial steps taken in the development of comprehensive reporting frameworks and standards on this journey.

Footnotes

1. Boffo, R., and R. Patalano ESG Investing: Practices, Progress and Challenges, OECD Paris (2020), available at www.oecd.org/finance/ESG-Investing-Practices-Progress-and-Challenges.pdf (Last Accessed 17/07/2023).

2. Jessica Ground, Capital Group ESG Global Study 2022 Harvard Law School Forum on Corporate Governance, available at https://corpgov.law.harvard.edu/2022/06/17/esg-global-study-2022/ (Last accessed 24/07/2023).

3. Kyle Peterdy, Corporate Financial Institute, ESG (Environmental, Social, & Governance) (2022) available at https://corporatefinanceinstitute.com/resources/esg/esg-environmental-social-governance/ (Last Accessed 19/07/2023).

4. United Nations, The Global Compact (2004). Who Cares Wins: Connecting the Financial Markets to a Changing World? United Nations (2004) available at https://www.unglobalcompact.org/docs/issues_doc/Financial_markets/who_cares_who_win (Last Accessed 19/07/2023).

5. Quantitative, What is ESG and Why Does it Matter to Your Business available at https://quantive.com/resources/articles/what-is-esg (Last Accessed 19/07/2023).

6. The ESG Report, What is ESG Reporting? available at https://www.esgthereport.com/what-is-esg-reporting/#:~:text=ESG%20stands%20for%20Environment%2C%20Social,affect%20a%20company's%20financial%20health (Last Accessed 19/07/2023).

7. Ibid.

8. Ibid.

9. PwC Slovakia, ESG Reporting and Preparation of Sustainability Report available at https://www.pwc.com/sk/en/environmental-social-and-corporate-governance-esg/esg-reporting.html (Last Accessed 19/07/2023).

10. What is ESG Reporting?, Dean Emerick, available at https://www.esgthereport.com/what-is-esg-reporting/#:~:text=The%20term%20'ESG'%20stands%20for,these%20elements%20into%20their%20practices. (last Accessed19/07/ 2023)

11. Ibid.

12. International Financial Reporting Standards General Requirements for Disclosure of Sustainability-related Financial Information available at https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s1-general-requirements/ (Last Accessed 19/07/2023).

13. Dan Byrne, What's the Difference between ESG reporting standards and Frameworks?, available at https://www.thecorporategovernanceinstitute.com/insights/guides/whats-the-difference-between-esg-reporting-standards-and-frameworks/ (Last Accessed 19/07/2023)

14. The International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards S2 Climate-related Disclosure available at https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s2-climate-related-disclosures/ (Last Accessed 28.07.2023)

15. IBM, What are ESG Frameworks?, available at https://www.ibm.com/topics/esg-frameworks (Last Accessed 19/07/2023)

16. Lauren Gibbons Paul, 8 Top ESG Reporting Frameworks Explained and Compared, available at https://www.techtarget.com/sustainability/feature/Top-ESG-reporting-frameworks-explained-and-compared (Last Accessed 19/07/2023).

17. The 1992 Constitution of Ghana and Acts such as the Environmental Protection Agency Act, 1994 (Act 490); Minerals and Mining Act 2006 (Act 703); The Commission on Human Rights and Administrative Justice Act 1993 (Act 4 56); The Labour Act 2003 (Act 651) have ESG considerations.

18. Provisions of Statutes such as the Environmental Protection Agency Act, 1994 (Act 490), s.18; the Minerals and Mining Act 2006 (Act 703) s.63 and the Petroleum (Exploration and Production) Act 2016 s.54, mandate some form of ESG reporting.

19. Emmanuel Bruce, IFC to strengthen ESG practices in Ghana's Private Sector, Graphic Business 28/04/2023 available at https://www.graphic.com.gh/business/business-news/ifc-to-strengthen-esg-practices-in-ghanas-private-sector.html (Last Accessed 24/07/2023).

20. B&FT, Stock Exchange Unveils ESG Disclosures Guidance Manual, available at https://thebftonline.com/2022/11/04/stock-exchange-unveils-esg-disclosures-guidance-manual-pledges-to-lead-with-self-reporting/ (Last Accessed 19/07/2023).

21. Bank of Ghana, Sustainable Banking Principles and Sector Guidelines, November 2019 available at https://www.bog.gov.gh/wp-content/uploads/2019/12/Ghana-Sustainable-Banking-Principles-and-Guidelines-Book-1.pdf (Last Accessed 23/07/2023).

22. Ibid at page 52.

23. Ibid.

24. Ibid.

25. Joshua Worlasi Amlanu, Banking Sector Embraces ESG Principles, B&FT 20/07/2023 available at https://thebftonline.com/2023/07/20/banking-sector-embraces-esg-principles/#:~:text=The%20banking%20sector%20has%20taken,to%20promote%20sustainable%20banking%20practices (Last Accessed 24/07/2023).

26. PWC Ghana, Ghana Banking Survey Report 2022 available at https://www.pwc.com/gh/en/publications/banking-survey.html (Last Accessed 23/07/2023).

27. Ebenezer Chike Adjei, Banks Making Headway with ESG Compliance, B&FT Online on 10/11/2022 available at https://thebftonline.com/2022/11/10/banks-making-headway-with-esg-compliance-bog/ (Last Accessed 23/07/2023).

28. Ghana Stock Exchange, The Ghana Stock Exchange Guidance Manual page 11 available at https://gse.com.gh/wp-content/uploads/2022/11/GSE-ESG-DISCLOSURES-GUIDANCE-MANUAL-1-1.pdf (Last Accessed 24/07/2023).

29. Ibid at page 34.

30. Ibid.

31. Ibid.

32. Ibid at page 25.

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