Hong Kong – SEHK Releases An Updated ESG Report Guideline To Encourage Disclosure Of Environmental Information.

Regarding non-compliant mandatory disclosure requirements and recommended disclosures, SEHK reminds listed companies not to resort to sweeping statements or use "boiler-plate" language. Instead, listed companies should:

(1) Set out the circumstances that are unique to the company to explain such departure; 

(2) Make clear and complete disclosures or provide reasons for any non-disclosures; and 

(3) Use cross-referencing links to minimize repeated disclosures.

SEHK proposes the following steps to prepare an ESG report: 

(1) Establish an ESG working group;

(2) Understand the ESG requirements and identify information gaps; 

(3) Determine the geographical or business boundaries for reporting purpose; 

(4) Assess stakeholder's engagement; 

(5) Conduct internal and external materiality assessments; and 

(6) Prepare the ESG report that includes the findings in the above steps.

Use the ESG toolkit to determine:

(1) Stakeholder's dependence and influence on the listed company;

(2) Stakeholder group's identity and profile; 

(3) Stakeholder engagement plan, action plan and contingency plan; 

(4) Post stakeholder engagement action plan and timeline; and 

(5) Materiality and relevance of the information for general disclosures and key performance indicators (KPI).