Doug Hileman is a primary author of “Achieving Effective Internal Controls over Sustainability Reporting (ICSR)” – supplemental guidance released by COSO.  Douglas was the only non-CPA and the only ESG specialist among the six authors.  This document will help bridge the divide between those who know internal controls (CFO, Accounting, Internal Audit) and those who don’t (Environmental, HR, Operations, Procurement, Real Estate, Safety … and everyone else).  The download is available free here. 

I'm pleased to be leading this info-packed session provides background and trends on climate-related risks for Internal Audit, their sponsors and stakeholders.  Real-time attendees got CPE, but you can still (Watch Now)

The Federal Trade Commission’s Green Guides are intended to safeguard consumers from false or misleading claims in the products they buy.  The FTC revises the Guides every 10 years, soliciting public comments.  DHC advocates for more protection of consumers and ethical businesses alike.  Read more. 

Accountants are entering the fray for trustworthy ESG reporting and disclosures, says Financial Times. Much is driven by GHG emissions inventories, and the anticipated SEC rule for climate disclosures.  Will they stop there?  Should they?  What can other functions learn from accountants – and vice versa? , Read More.

Consumers are buying eco-friendly products and services.  Investors demand accurate sustainability reporting; what protection do consumers have?  With consumer spending at 70% of the economy, even a sliver of this market in ESG-aligned products is massive.  Consumer protection is left to FTC Green Guides – flimsy and rarely enforced.  Comment period now open.  For perspectives, read more.

Douglas Hileman Consulting LLC (“DHC”) is pleased to submit comments to the SEC on this matter. The proposal (amending existing rules) would require funds that consider ESG factors in their investment process to disclose additional information regarding their strategy. The amount of disclosure depends upon how “ESG-centric” the fund itself is. It would require information on the impacts they seek to achieve and key performance metrics. The proposal includes greenhouse gas (GHG) emissions as a separate topic for all ESG-focused funds.  (Read More)

Doug returns to Compliance Week’s signature event in Europe in Edinburgh, Scotland.  Much is written about the board and executives, yet the functional leaders – including Compliance professionals – do the heavy lifting.  “the devil is in the details.”  Doug shares ESG expertise with compliance professionals on compiling accurate data, benchmarking, aligning the details with organizational strategy, and a compelling case study. 

https://www.complianceweekeurope.com/

Doug will present at Loyola Marymount University’s prestigious “Business as a Force for Good” Annual Ethics Symposium on October 19, 2022.  Topic: “ESG Reporting:  Like Financial Reporting – and Not.”  Open for in-person attendance.  Business as a Force for Good Annual Ethics Symposium - Loyola Marymount University (lmu.edu)

Doug returns to the IIA Los Angeles Chapter’s fall conference October 18, 2022. 

Doug presents “Internal Audit’s Role in Assurance over Internal Controls over Sustainability Reporting (ICSR).”  Attendees will learn how to apply experience in ICFR to the world of ESG and sustainability reporting.  This is a warm-up to a COSO report linking sustainability and the Internal Controls Framework, due out early 2022.  Doug Hileman is on the core team.  More on the conference (Click Here)

The Uyghur Forced Labor Prevention Act (UFLPA) has been described as “the most interesting law in the world.”  “Interesting” covers a lot of ground.  The provisions of UFLPA are poised to disrupt trade, supply chains, product assembly and sales.  It may affect operations, compliance, financial and non-financial reporting, and strategies for companies in many sectors.  If your company makes or imports apparel or linens that include cotton, this applies to you.  If your company makes anything that includes silica (think chips), it applies to you.  This white paper highlights key provisions and offers takeaways from UFLPA, as well as context and tips.    

PREMISES

• UFLPA isn’t the first law regulating forced labor, including applicability in the supply chain. It is likely the most impactful.  And it may not be the last. 
• UFLPA and other laws, regulations and disclosures collectively are greater than the sum of their parts, in terms of relevance to operations, compliance, (financial and non-financial) reporting and organizational strategy.
• Few companies know what’s about to hit them. Or what already has.
• Companies can leverage the approaches, structures, resources and tools used for

Click here for full report

Douglas Hileman Consulting LLC (DHC) submitted comments on IFRS S1 - General Requirements of Sustainability-related Financial Information. Key points on: GRI; maintain focus on general investor; core content; defining short/ medium/ long-term; quantitative information; Internal Audit; materiality; and consolidated reporting.  Comment letter at:  ISSB S1 Exposure Draft - Sustainability Disclosures; Hileman Comments (ifrs.org)

DHC submitted comments on IFRS S2, Climate Related Disclosures.  Key points on: controls; Internal Audit; defining short/ medium/ long-term; climate resilience scenarios; and value chain risks.  Comment letter at: 

ISSB S1 Exposure Draft - ISSB Climate Disclosures; Hileman Comments (ifrs.org)

SEC Commissioners, Staff, and Stakeholders:

Douglas Hileman Consulting LLC (“DHC” pr “Commenter”) is pleased to provide comment on the SEC’s proposed rule on climate-related disclosures, released March 21, 2022. DHC submitted public input on June 7, 2021, responding to Commissioner Allison Herron Lee’s request for public input. DHC supported SEC actions on climate-related risk then, as we do now. 
(Click Here)

IIA Los Angeles Chapter (recorded)

This special webinar is a walk-through of the SEC Proposed Rule on Climate-Related Disclosures.  An investment of ~37 minutes will make you conversant in all the key subjects of the proposal.  Also with guest presenter Alexandre Rossin, President, Rossin International LLC.  Watch here. 

Presented to IIA Brazil, to over 1000 attendees!  ESG compliance looks different. ESG reporting is demanded; more calls for assurance. See Internal Audit calls to action.  Contact us for this document in Portuguese. Obrigado.” (Click Here)

Doug reflects on three years with the Volkswagen Monitor team.  Leveraging publicly available information, Doug connects dots and shares perspectives relevant for "second line" environmental, health and safety, and sustainability (or ESG) audit functions.  Learn how the experience can add value to your organization.  (Click Here)

DHC provides insights and suggestions on 15 questions posed by Commissioner Allison Herron Lee.  DHC agrees disclosures should be required.  DHC encourages keeping it simple, and minimizing burden to regulated community, and leveraging precedents (including the SEC Conflict Minerals Rule).  Our Clients are surprised we do not recommend assurance – see why.  (Click Here)

Trends in sustainability reporting, and how Internal Audit, Environmental Audit can mitigate risk and add value.  (Click Here)

From a humble start just 20 years ago, there are now many sustainability reporting standards and frameworks (“non-financial reporting”).  The coverage, profile, and importance has exploded – even during the COVID-19 pandemic.  The session included updates on four key frameworks, and suggestions on how to keep pace.  Contact us for presentation handouts.  (Click Here)

The session explores ESG as a business imperative.  Doug takes four timely ESG topics, highlighting impact, societal awareness, growth in regulatory actions.  And how smart companies have seized opportunities, and raised expectations of investors.  Management, Internal Audit, and EHS functions take special note. Contact us for presentation handouts. (Click Here)