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[Green Finance Special Review] The implementation of the "Sustainable Development Report" (Trial) guidelines of the three major exchanges will help promote the development of ESG ratings of listed companies

15 APR 2024

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On February 8, 2024, the Shanghai Stock Exchange, Shenzhen Stock Exchange and Beijing Stock Exchange (hereinafter referred to as the "Three Major Exchanges") simultaneously issued the "Self-discipline/Continuous Supervision Guidelines for Listed Companies - Sustainable Development Report (Trial) (Draft for Comments)" (hereinafter referred to as the "Guidelines"), which were officially released on April 12, more than two months later and will be implemented from May 1, 2024. The release of the Guidelines has made clear regulations on the disclosure of sustainable information such as environmental, social and governance (ESG) by listed companies in my country, filling the gap in the ESG information disclosure standards at the regulatory level of listed companies in my country. At the same time, the Guidelines have made mandatory requirements for the disclosure of sustainable development reports by sample companies of important market indices such as the SSE 180, Science and Technology Innovation 50, Shenzhen 100, and ChiNext Index, as well as companies listed at home and abroad. Through the demonstration effect, it will drive the standardized development of sustainable information disclosure by listed companies and even the entire market. The standardization, consistency, comparability and authenticity of the disclosure of listed companies are the basic guarantees of ESG ratings. The release of the Guidelines will greatly improve the quality of China's ESG ratings.

 

1. China Chengxin International has incorporated ESG factors into its credit rating index system in 2022

The global capital market pays close attention to the impact of ESG ratings or ESG performance on corporate credit. Since 2017, the three major international rating agencies have gradually begun to integrate ESG factors into credit ratings. With the popularization of ESG concepts in China, the gradual improvement of relevant policies and regulatory systems, more and more institutional investors have incorporated ESG factors into asset allocation and risk management, and the correlation between ESG factors and corporate operations and risk levels has gradually increased. The necessity of incorporating ESG factors into the credit rating framework has become increasingly prominent.

 

From the perspective of credit rating, the impact of ESG factors on corporate credit risk has the following three characteristics: First, different companies in the same industry often face similar ESG risk exposures, while companies in different industries face different ESG risks. Second, the impact mechanism of ESG factors on corporate credit risk is very complex and may have long-term or short-term impacts on companies. Finally, the potential impact of ESG factors on credit levels is mostly negative, and in rare cases may have an improving effect on credit levels.

Based on the above characteristics, China Chengxin International Credit Rating Co., Ltd. (hereinafter referred to as "China Chengxin International") has integrated and upgraded ESG factors with credit rating methodology in 2022 by absorbing and learning from international advanced experience and professional consensus, based on the overall situation of China's economic and social development, and combined with the characteristics of issuers in China's bond market. It has incorporated ESG factors directly or indirectly related to credit risk into the rating model, further improving the quality of credit ratings and the foresight and transparency of rating results.

Some domestic credit rating agencies still only consider "green factors" or "corporate governance and management" as partial substitutes for ESG factors in the credit rating model, while China Chengxin International selects comprehensive ESG factors related to the credit risk of the issuer, and uses ESG factors as credit rating adjustment items, focusing on the impact of environmental, social and governance factors related to credit risk on the company's risk resistance. In 2023, in order to further improve the accuracy of ESG factor considerations, China Chengxin International will incorporate the ESG rating results of CCXGF Technology (Beijing) Co., Ltd. (hereinafter referred to as "CCXGF") into the ESG factor consideration system used in credit ratings. For entities with ESG ratings below BBB (inclusive), the impact on credit ratings must be evaluated.

 

In April 2024, the People's Bank of China, the National Development and Reform Commission, the Ministry of Finance, the Financial Regulatory Bureau, the China Securities Regulatory Commission and other seven ministries and commissions issued the "Guiding Opinions on Further Strengthening Financial Support for Green and Low-Carbon Development", which pointed out that "credit rating agencies are encouraged to establish and improve a rating system for green financial products, and support credit rating agencies to incorporate environmental, social and governance (ESG) factors into credit rating methods and models". In the future, as relevant policies are gradually improved and ESG-related information disclosure in various industries becomes more comprehensive, the role and importance of ESG factors in credit rating methods and models will be further enhanced. China Chengxin International will further optimize the indicator system and evaluation methods of ESG factors in credit rating methods and models based on the risk characteristics of different industries, in order to more accurately reflect the impact of ESG factors on credit risk.

 

2. The release of the Guidelines will greatly improve the quality of ESG ratings of Chinese listed companies

Professional third-party ESG ratings are of great reference value to investors and other stakeholders in the capital market. However, due to the development stage of ESG management of Chinese companies and the irregular and incomplete information disclosure, ESG rating results are currently difficult to apply. The release of the "Guidelines" first constrains the disclosure standards and norms.

 

The Guidelines follow the principle of "dual importance" and are consistent with the essence of ESG ratings. The Guidelines clearly identify issues in two aspects: those that have a significant impact on corporate value (financial importance) and those that have a significant impact on the economy, society and environment (impact importance). "Dual importance" is also a reflection of the inherent nature of ESG ratings. On the one hand, ESG ratings focus on the evaluation of non-financial indicators, and through the grasp of corporate governance, strategy, operations and other aspects, determine the risk transmission mechanism, and effectively identify the inherent ESG risks that affect the sustainable development of enterprises for stakeholders; on the other hand, ESG ratings also focus on the short- and medium-term benefits and impacts of corporate operating behaviors on the outside, and incorporate the environmental, social and economic values of enterprises into ESG rating factors. The consistency of the inherent concepts of ESG information disclosure and ESG ratings will help meet the needs of investors and other stakeholders.

 

The selection of topics in the Guidelines is in line with international consensus and takes into account local characteristics, meeting the essential needs of building an ESG rating system for China's national conditions. The Guidelines carry out sustainable development information disclosure around the four aspects of "governance, strategy, impact, risk and opportunity management, indicators and targets", which is consistent with the IFRS framework content released by the International Standards Organization ISSB; in terms of topic selection, the Guidelines clearly define "responding to climate change", "resource utilization and circular economy", "pollution prevention and ecosystem protection", "commercial bribery and unfair competition ", "employees" and other global consensus issues, especially in the aspect of "responding to climate change", which is also a specific implementation under the background of China's "carbon peak and carbon neutrality" goals.

 

In addition, the "Guidelines" also fully consider the effective combination of international sustainable development goals with my country's actual situation, such as green development, support for small and micro enterprises, and achieving common prosperity. It has set up topics with Chinese characteristics such as "rural revitalization", "science and technology ethics", and "payment by small and medium-sized enterprises". On the basis of complying with the major international sustainable development goals, it carries out localized construction in specific content.

 

The CCXGF team has carefully studied the indicator system of the "Guidelines", which includes about 288 detailed indicators from the information disclosure perspective. Among them, those that are in line with the China Chengxin ESG rating indicators (Level 3) are shown in the following table for reference by market stakeholders.

 

First level indicator

Secondary indicators

Level 3 indicators

Combating climate change

Adaptability of strategies, business models, etc. to climate change

The impact of climate change on corporate strategy and business models

How corporate strategies and business models can address climate change

Significant uncertainties that companies consider when assessing their climate resilience

Ability to adjust strategy and business model

Transformation plans, measures and progress in addressing climate-related risks and opportunities

Business adjustments to address climate-related risks and opportunities

Mitigating climate change

Adapting to climate change

Transformation Plan

Implementing transformation plans

Greenhouse gas emissions

Scope 1 emissions

Scope 2 emissions

Scope 3 emissions

Carbon reduction

Carbon emission reduction related information

Carbon Emission Reduction

National Voluntary Greenhouse Gas Emission Reduction Program

Certified Emission Reductions (CCERs) (if any)

Participation in other emission reduction mechanisms (if any)

Carbon Emission Reduction Research and Development

R&D details

R&D investment amount

R&D Progress

Pollution prevention and ecosystem protection

Pollutants

Wastewater Information

Pollutant treatment

Pollutant prevention

Pollutant prevention and control results

Main pollutants

Waste

Waste emission targets

Specific measures taken to achieve waste management goals

Total amount of hazardous waste (in tons)

Hazardous waste density (e.g. per unit of revenue, per unit of production, per facility)

Total amount of non-hazardous waste (in tons)

Non-hazardous waste density (e.g. per unit of revenue, per unit of production, per facility)

Hazardous waste treatment methods

Disposal of hazardous waste

Ecosystems and biodiversity

Biological genetic resources

Species and their habitats

Impacts and dependencies of products throughout their life cycle on ecosystems and biodiversity

Environmental Events

Emergency Plan

Major environmental incidents

Major environmental incidents that have resulted in penalties from regulatory authorities or criminal prosecutions

Resource Utilization and Circular Economy

Circular Economy

Specific measures for circular economy

Specific progress and achievements of circular economy

Energy Use

Total direct energy consumption

Total indirect energy consumption

Total energy consumption

Energy consumption intensity

Renewable energy use

Clean energy use

Energy saving

Water Resources

Total water consumption

Total water consumption intensity

Water conservation

Rural Revitalization and Social Contribution

Rural Revitalization

Specific circumstances of integrating support for rural revitalization and consolidation and expansion of poverty alleviation achievements into the company's strategy

Specific measures to support rural revitalization

Achievements in supporting rural revitalization

Social welfare

Basic information on contributions to the public and society

Innovation drive, suppliers and customers

Innovation Driven

Strategies and goals for scientific and technological innovation

Specific situation of scientific and technological innovation

R&D progress and achievements

supply chain management

The Basics of Supply Chain Risk Management

Ensure the security and stability of the supply chain

Safety and quality management of products or services

Product or service quality management system

Quality management related certifications obtained by the company

Major safety and quality accidents related to products or services (if any)

After-sales service, product recall

Customer Complaints

Data Security and Customer Privacy

Data Security

Data security incidents (if any)

Customer Privacy

Customer privacy breach incidents (if any)

staff

Employee Recruitment and Treatment

Policies on employee recruitment and treatment

Implementation of policies on employee recruitment and treatment

Status of employment and informal employment of employees

Gender composition of current employees

Labor Disputes

Staff changes

Compliance, openness and transparency of recruitment and hiring procedures

Occupational Health and Safety

Establishment and implementation of occupational health and safety management system

Establishment and implementation of occupational health and safety management related training

Work Injury Insurance

Personnel coverage rate of production safety liability insurance

Detailed information of the safety responsibility accident (if any)

Employee career development and training

Company job system settings

Employee promotion mechanism, selection and career development mechanism

Types of employee training

Number of staff training sessions

Staff training progress

Annual training expenditure

Sustainability Framework

Governance Structure

The establishment of sustainable development management and supervision institutions

Institutional expertise and capabilities

Establish information reporting mechanism

Internal control system for goal setting and execution

Measures and methods to integrate sustainability impacts, risks and opportunities into strategic and major transaction decisions

strategy

Identified sustainability-related risks and opportunities

Significant impacts of the company's business activities on the economy, society and environment

Measures and actions taken to mitigate significant impacts

The impact of sustainability-related impacts, risks and opportunities on corporate strategy and decision-making

Impact, Risk and Opportunity Management

Methods for identifying sustainability-related impacts, risks and opportunities

Monitoring of sustainability-related impacts, risks and opportunities

Integrate sustainable development-related impacts, risks and opportunities into the company’s internal management processes

Indicators and targets

Sustainable Development Goals and Targets

Status and progress in achieving Sustainable Development Goals and targets

Preventing Commercial Bribery and Unfair Competition

Anti-commercial bribery and anti-corruption

Anti-commercial bribery and anti-corruption management system

Assessing commercial bribery and corruption risks

Anti-commercial bribery and anti-corruption training

Commercial bribery and corruption incidents

Anti-unfair competition

Unfair competition behavior leading to litigation or major administrative penalties

 

The release of the Guidelines will enhance the comprehensiveness and integrity of ESG information disclosure by listed companies, and will also have important guiding significance for the ESG management of listed companies. For ESG ratings, standardized and comprehensive indicators will more accurately reflect the ESG governance level of Chinese listed companies, and also provide an important basis for judging the scientificity, quantifiability and comparability of ESG rating indicators and weight settings. China Chengxin will uphold its objective, neutral and impartial third-party status, and continue to optimize and promote the ESG rating indicator system for Chinese listed companies in accordance with the contents of the Guidelines, and provide effective support for listed companies to improve their own ESG governance level and meet the requirements of stakeholders.