Sustainability is an evolving practice as governments and institutions set goals and policies that can alleviate the impact of climate change and also drive positive change in socio-economic and political factors. Sustainability reporting is seen as a necessary tool in promoting and driving sustainability. Worldwide, sustainability reporting is becoming increasingly mandatory for publicly listed companies, promoting transparency and communication between a business and their stakeholders.
Sustainability reporting in Malaysia has been evolving since 2015 when the Bursa Malaysia issued amendments to listing requirements for the Main Market, which is Malaysia’s prime market for established companies that have met certain standards in quality, size and operations, and the ACE Market, a sponsor-driven market for companies with growth potential. The amendments required listed issuers to include sustainability statements in their annual reports. The statement, which includes details on the business’s strategies or management on economic, environmental, and social risks and opportunities, replaced the previous requirement of having to disclose CSR activities. This further evolved the sustainability landscape in Malaysia by taking into account other factors driving sustainability. These amendments took into effect in December 2016.
Recent progress has been made in improving sustainability reporting in Malaysia to keep up with current global reporting trends and standards. Bursa Malaysia announced in September 2022 the enhanced sustainability reporting requirements for publicly listed companies in both Main and ACE markets. The new requirements follow a phased approach, gradually increasing disclosure requirements by 2027.
Reporting requirements and the timeline for reporting in the phased approach differs depending on whether the issuer is listed in the Main Market or ACE Market, with certain requirements requiring other details if one falls under a specific market. Yet essentially, overall requirements remain the same in crafting the Sustainability Statement.
Bursa Malaysia released an updated sustainability reporting guide listed issuers and corporations can refer to as they develop their sustainability reports. Within the guide, Bursa Malaysia provides key questions or disclosure guidance that can steer conversations and progress when fulfilling a requirement. They also indicate the proficiency and experience needed in certain aspects of the guidelines to help companies better understand and grow in their sustainability reporting journey. To even further aid companies, case studies, toolkits, and additional resources are available in the guide. [1]
In the enhanced sustainability reporting requirements, the issuer is asked to disclose the following in their Sustainability Statement:
Sustainability governance requirements ask companies to report who is responsible for managing the company’s sustainability matters. Details include the oversight of sustainability matters, strategic management and its nature or scope. Key roles, functions, and individuals involved in sustainability governance are also disclosed. Aside from the oversight and overall strategic management, day-to-day implementation of sustainability matters are highlighted in this section.
Disclosing the scope of the Sustainability Statement and its basis is required. Here, companies describe the extent of the report, considering geographical and operational boundaries, and business segments and divisions covered in the report. If the company report does not cover all areas in its operations, they are asked to explain these inclusions and/or exclusions.
Material sustainability matters take up most of the report, highlighting the business’s sustainability performance. Bursa Malaysia defines a sustainability matter to be material if it reflects the company’s significant economic, environmental and social impacts or influences assessments and decisions of their stakeholders. To help companies determine materiality, the sustainability reporting guide includes a list of 9 common material sustainability matters that must be disclosed by all listed companies. These 9 consist of anti-corruption, community or society, diversity, energy management, health and safety, labor practices and standards, supply chain management, data privacy and security, and water.
In disclosing materiality, companies report each matter, how it was identified, and its relevance to their stakeholders. Bursa Malaysia even recommends reports to contain a Materiality Matrix that visualizes the importance and impact of these factors to the business model and to stakeholders. Materiality disclosures also detail how these are managed by the company, listing policies, certain actions or steps taken to address the sustainability matter, and indicators demonstrating the company’s performance. Set targets for each indicator are also disclosed if the company has established these. In reporting sustainability performance, listed issuers are to provide data from the last 3 financial years.
2022 marked changes in sustainability reporting in Malaysia. Listed issuers are now required to report climate-related disclosures aligned with the recommendations of the TCFD on a separate section in the Sustainability Statement. This would cover the four pillars indicated by the TCFD, consisting of governance, strategy, risk management, and metrics and targets. Additionally, for listed corporations in the ACE Market, if the business does not report the TCFD-aligned climate-related disclosures, they would have to disclose their transitioning plan. This indicates the company’s transition to a low-carbon economy detailing the role of the board of directors and senior management in oversight and execution, and the strategies the company will undertake to address climate-related risks and opportunities.
Sustainability reports in Malaysia require a Statement of Assurance informing readers that the report has been reviewed internally by the company’s internal auditors. The company can also state that the report has been independently assured through recognized standards instead. If taking this route, the subject matter and scope of the assurance and the conclusions made are also reported in the statement.
Lastly, to summarize the company’s performance, a performance data table is also required in the sustainability report. The table should include the reporting of a business’s new indicator and its respective minimum data disclosures. As mentioned previously, data provided should cover the performance from the last 3 financial years. However, companies may not be able to provide the data in their first year of reporting. Thus, in the upcoming financial year, they would report data from the current and previous year and continue the practice in their third year of reporting.
Bursa Malaysia encourages companies to align their reports to other internationally accepted frameworks and standards to strengthen their reports, listing standards such as the GRI, SASB, ISSB, TNFD.
To transition to the enhanced sustainability reporting requirements, a timeline for each market has been set. For the Main Market, by 2023, companies should disclose performance on the 9 common sustainability matters and indicators and also provide a Statement of Assurance. In 2024, waste and emissions management are added into the list of materiality disclosures. By 2025, companies in the Main Market should start reporting TCFD-aligned climate-related disclosures, with full disclosure achieved by the end of 2027.
ACE Markets, on the other hand, take a different path starting in 2024 with the disclosure of a narrative statement on the company’s sustainability governance, scope and basis of scope for the statement, materiality assessment, and the management of material sustainable matters.. By 2025, it is expected that companies are to disclose material information for the common sustainability matters and assurance. By 2026, waste and emissions reporting is added into the report, along with the transitioning plan to a low-carbon economy.
Sustainability reporting in Malaysia has evolved and improved over time as it incorporates and adapts to new standards and trends in global sustainability reporting. In May 2023, the Securities Commission Malaysia (SC) established the Advisory Committee on Sustainability Reporting, which aims to support implementation of ISSB Standards on a national level, further advancing the country’s initiatives in transparent sustainability.
Malaysia continues to progress in sustainability reporting. Companies are given support and time to prepare for their sustainability reports and help the country achieve its nationwide sustainability goals, creating a resilient Malaysia. Sustainability reporting is transforming into a necessary practice vital for the growth of a business and of a nation as a whole.
References:
[1] Bursa Malaysia. Sustainability Reporting Guide and Toolkits (3rd Edition), 2022.
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