CCRcorp Sites  

The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

Our Sites


A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.


An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.


The “one stop” resource for information about responsible executive compensation practices & disclosure.

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.


Keeping you in-the-know on environmental, social and governance developments

Long-standing concerns over the general lack of company controls for ESG data are finally turning to action.  The Principles for Responsible Investment (PRI) included two separate items for ESG data assurance/audit in its newly released Strategic Plan 2021-2024.

In the Plan, PRI updates twenty-two initiatives under its three themes of (1) Responsible Investors, (2) Sustainable Markets and (3) A Prosperous World for All.  The increased expectations for ESG data validation are part of Initiatives 8 and 9 under the “Responsible Investor” theme. Initiative 8 has been expanded to require:

Internal verification of report/C-level sign-off of report/internal audit of some/all data / independent audit of some/all data

While Initiative 8 focuses on internal controls, Initiative 9 also adds external assurance as a requirement to “build confidence in the data reported.”

This is in parallel to an initiative launched in late 2020 by members of the UK RI Roundtable including USS, BTPS, Brunel Pension Partnership, the Church of England Pensions Board and RPMI Railpen to help users of PRI’s reporting framework. According to one article about this effort, 

… an asset owner reporting on all asset classes under the PRI survey could be required to provide over three hundred and fifty distinct items of information or data points… For example, USS’s draft PRI submission alone is almost 350 pages.

This group has published a reporting tool intended to map reporting requirements of the UK Stewardship Code, the PRI’s Reporting and Assessment requirements and the Pension Regulator’s Implementation Statement. 

All of this policy talk might seem far off and somewhat irrelevant to companies. But investors have been sending a strong signal that they want a robust, highly accurate ESG reporting and ratings ecosystem, and these updates show that they’re zeroing in on companies’ internal controls and external assurances as a way to get what they want. 

Back to all blogs

The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile