ESG Reporting Guide

A voluntary support program for companies

In May 2019, we launched our new global environmental, social and governance (ESG) reporting guide for public and private companies. Initially introduced in 2017 as a voluntary support program for Nasdaq’s Nordic and Baltic markets, the new Guide includes the latest third-party reporting methodologies widely adopted by the industry and aims to help both private and public companies navigate the evolving standards on ESG data disclosure.

We are  committed to operating sustainable markets, and the intention of this guide is to reinforce our mission to provide fair, transparent, and efficient markets for all stakeholders. ESG practices can be as beneficial to individual companies as they are to investors, and a focus on ESG can lead to improvement and harmonization of management practices.

Nasdaq does not require the participation of its listed companies in this process. This is a completely voluntary initiative. It is not intended to compete with, supersede, or supplement any existing framework—but rather act as an informational reference for listed companies that strive to meet disclosure obligations. 

To support us with reaching better ESG reporting and better markets, we invite companies, investors and other stakeholders to give us feedback on ESG reporting and the guide.

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A Support Resource for Companies

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Questions and Answers

First and foremost, we want to support our listed companies. This Reporting Guide will help companies understand the complex (and sometimes conflicting) world of ESG-related reporting. It provides a business-centric rationale for focusing on certain essential data points, integrating these data points into management operations, and potentially reporting them to the public.

This is an important step in the process, but it is also the beginning of a conversation rather than a final pronouncement. You can help us to better understand how ESG reporting impacts your firm by commenting on the contents of this document. We want constructive feedback from companies, investors, regulators, and other stakeholders around the world.
While ESG factors are at times called non-financial, how a company manages them undoubtedly has financial consequences. The very term non-financial is a controversial point of reference, because many believe that ESG information is no less relevant or useful to an investor in assessing the financial prospects and operational performance of a company than information channeled through traditional accounting practices.

A range of studies have found correlation between companies with good ESG practices and a lower cost of capital, lower stock price volatility, and better valuation over the long term. Nasdaq itself is persuaded that a correlative exists, and it seems to exert positive influence for listed companies. For further information and links to the studies that we consulted in this process, please refer to the guide.
Yes, Nasdaq is both a leader and participant in a larger industry-wide effort. Nasdaq was one of the United Nations Sustainable Stock Exchanges (SSE) initiative’s founding partner exchanges in 2012. The SSE is a peer-to-peer learning platform for exploring how exchanges, in collaboration with investors, regulators, and companies, can enhance corporate transparency – and ultimately performance – on ESG (environmental, social and corporate governance) issues and encourage sustainable investment.

Half of the SSE member exchanges, including Nasdaq and its individual exchanges across the world, have now issued ESG guidance of some kind.
During the course of this revision, we have been guided by our work with the United Nations Sustainable Stock Exchanges (SSE) initiative and the Sustainability Working Group at the World Federation of Exchanges (WFE). Nasdaq was a founder and/or early participant in each project, and this Guide is directly correlated with current exchange industry trends and practices. We integrated perspectives from established sustainability reporting frameworks—chiefly the Global Reporting Initiative (GRI) Standards and the UN Global Compact (UNGC)—as well as emergent ESG disclosure efforts, such as the Sustainability Accounting Standards Board (SASB) and the Task Force on Climate-Related Financial Reporting (TCFD). Our Guide provides, wherever possible, a clear concordance with these and other initiatives. Last but not least, we tried to align our guidance with that included in the UN Sustainable Development Goals (SDGs).
Yes. The guide will be available to all companies listed on any of Nasdaq’s exchanges globally, including Nasdaq First North in the Nordic and Baltic markets, but also to any other company that hopes to make use of it.
Listed companies should not bear a disproportionate or unfair reporting burden, even if they elect to voluntarily disclose ESG data. Nasdaq is a public enterprise, responsible to its stakeholders and to the communities where we do business, so we embrace the reporting practices advocated in this guide. Our forthcoming 2018 Sustainability Report will cover many (if not all) of the recommended ESG metrics and we may elect to publish a supplement with more in the future.
No, this is a completely voluntary initiative. Because ESG is only a part of information that potential investors evaluate, Nasdaq does not require the participation of its listed companies in this process. The rewards for managing and disclosing ESG should not imply a benefit from Nasdaq for doing so, nor an implied punishment for not doing so.
The aim of this guide is not to add to the regulatory burdens of our listed companies. On the contrary, we frequently advocate for self-control and self-regulation in the markets. Companies must decide whether or not the benefits of ESG reporting outweigh any related costs.
Nasdaq’s goal is to assist listed companies wishing to incorporate ESG reporting into their existing reporting processes. This guide has been created to offer a framework to support companies that strive to meet ESG disclosure requirements. Thus, public and private companies alike could conceivably benefit.

The primary audience for company-reported ESG metrics is investors. Other stakeholders—including customers, employees, and community members—would likely benefit from the information, but we are currently focused on improving the information flow between exchanges, listed companies, and the investor community.
This guide will not compete with, supersede, or supplement any existing framework—but rather acts as an informational reference for any listed companies that seek support.

If a company currently reporting on ESG matters relies on a high quality, broadly recognized national, EU-based or international framework or several of them, it is welcome to continue doing so. It should be remembered that this guide is voluntary and meant for all Nasdaq markets for informational reference. We do not encourage taking up parallel reporting according to our guide.
No, this is a voluntary guide. We do not encourage parallel reporting. Companies currently reporting on ESG matters may want to study how our guide relates to their reporting. And companies that have not engaged themselves in ESG reporting, may want to take up some of the ideas of our guide or start following it.

But again, this guide is voluntary and meant for all Nasdaq markets for informational reference, and there is no obligation to agree with its principles or comply with its recommendations.
The 30 ESG metrics in this revision—reduced slightly from 33 in 2017, and somewhat altered in language and emphasis—are those that we find to be the most appropriate for most companies to track and disclose. It does not include sector-specific guidance, nor do we expect every company to report on these metrics, regardless of the material impact on its business. These metrics are, however, evenly balanced across environmental (10 metrics), social (10 metrics), and governance (10 metrics) categories, and are all given equal weight and consideration in this document. Our evaluation and ranking of these metrics is based on five key factors: precedent, prevalence, potential, perspective, and practicality. For more information on these factors, please refer to the Guide itself.
We believe in a voluntary, flexible and encouraging approach, where companies wishing to follow the guide can start reporting any or all of these data points at any time, presumably upon an annual basis thereafter. Companies can start by focusing on one or several data points that are most critical for their business and industry expectations.

We also encourage participating companies to use established reporting channels and schedules—rather than creating new ones—wherever possible. Current financial and non-financial reporting schedules are recommended.

Nasdaq Nordic listed companies are free to upload their ESG data in the ESG Data Portal, a centralized distribution point that offers investors access to standardised ESG data from Nordic listed companies, while listed companies are offered a platform to showcase their ESG data. Please contact Lise Mejlholm (lise.mejlholm@nasdaq.com) if you are interested in learning more about the ESG Data Portal.
While we are excited to expand this from a Nordic/Baltic to a global initiative, the launch of the new version of the ESG Reporting Guide is just another step of an ongoing effort, the beginning of a conversation rather than a final pronouncement. We invite our companies, investors and other stakeholders to give us their feedback on ESG reporting in general and this reporting guide in particular.

Although this guide is intended to support listed companies across all Nasdaq markets globally, we are aware of the fact that there may be local concerns. Thus we will consider publishing subsequent supplements to this document, each one focused on a specific market or country. These supplements may be needed in order to make the connection between sustainability practices and other local dynamics—new and existing regulations, corporate governance codes, social initiatives, political concerns, traditional business practices—more explicit.
You are welcome to contact us via email at sustainability@nasdaq.com or refer to this webpage.

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