We recently featured Shari Littan on a joint PracticalESG.com/TheCorporateCounsel.net podcast on the new COSO guidance document on Internal Controls over Sustainability Reporting (ICSR). Shari was one of the primary authors of the document. Last week, she spent time on another podcast with Ropes & Gray’s Michael Littenberg (also a member of our Advisory Board) on ICSR, going into more detail along with another primary author Doug Hileman.
One point Shari made in her comments with Michael:
“… the SEC has started to issue comment letters on company filings where the Form 10-K or financial reports are not aligned with sustainability or ESG information in other non-SEC reporting. One good thing about a good control system, governance and oversight, is to make sure that information aligns, so that internal groups are speaking cohesively and working to make sure the company is not saying two or three different things in different places. The analysts also will pick up on that.”
Shari is spot on with that insight. We’ve blogged before on SEC’s latest round of climate and ESG-focused comment letters issued from July 1, 2021 to March 31, 2023. One of the nine topics identified by the SEC in its sample letter is internal controls over data and disclosures between the level of disclosure provided in corporate sustainability reports and in SEC filings.