ESG REGULATION, OVERSIGHT AND DISCLOSURES

R&C: How would you characterise current stakeholder demand for information regarding companies’ environmental, social and governance (ESG) activities, risks and performance? What aspects of ESG do companies need to monitor and assess?

Bichet: In spite of the changing political landscape, we are seeing stakeholders such as investors, suppliers and employees continuing to request environmental, social and governance (ESG) information from companies. Often, companies are asked about their ESG policies and governance, ESG goals and targets, or more granular information on topics such as carbon emissions, pay equity or sourcing practices. This is sometimes driven by demands from investors or suppliers who need to meet their own ESG goals, and in other cases driven by legislation such as the European Union’s (EU’s) Sustainable Finance Disclosure Regulation (SFDR).

Stephen: Our expectation is that investor demand for accurate non-financial information relating to ESG will continue to grow. Not only is there an expectation that companies should accurately reflect the progress they have made toward their ESG commitments, but investors also want some assurance around reporting, including as regards sustainability information. ESG-related requirements are to be found in a wide range of sources and include disclosure obligations relating to the Task Force on Climate-related Financial Disclosures (TCFD) framework under the UK Listing Rules, emissions under the Companies Act 2006, modern slavery under the Modern Slavery Act 2015 and equality under the Equality Act 2010. Companies should identify requirements relevant to their business and continuously monitor and assess their compliance with these as business models evolve and the operating environment changes, as well as keeping an eye on new developments.

Jul-Sep 2025 Issue

Cooley LLP

Norton Rose Fulbright LLP