13 March 2012

EC（欧州委員会）が発表した企業の社会的な責任に関する2011-14年のEU（欧州連合）の戦略についての報告書に対するFEE（欧州会計士連盟）のコメント

FEE supports the Commission in its important role to facilitate and encourage a holistic approach and commends the advancements in this area. FEE sees this Communication as a positive initiative in further progressing with Corporate Social Responsibility (CSR) on the European agenda. As the voice of the accountancy profession in Europe, FEE is committed to contributing to a more efficient, transparent and sustainable European economy.

The agenda for action 2011 – 2014 put forward in the Communication is an important milestone reflecting the need for better integration of CSR into core business strategy and to contribute to the long-term success of enterprises.

The accountancy profession has an important role to play in areas identified as being of key relevance such as contributing to enhancing trust, the reliability of reported information as well as education, training and research. Given its expertise, the accountancy profession is well equipped to inform CSR policy initiatives on these areas and help translating principles into measures that enhance corporate accountability in the public interest.

Improving and tracking levels of trust in business has been identified as an important area to which the accountancy profession could contribute. In tackling this element of the agenda it would be important to consider the relevance of social, environmental and governance issues in the loss of trust as well as their role to help regaining it.

Improving company disclosure of social and environmental information is an important objective to which the accountancy profession makes an instrumental contribution. FEE is particularly committed to this objective. There is a close connection between “Improving and tracking levels of trust in business” and “Improving company disclosure of social and environmental information”.

Transparency through appropriate disclosures influences behaviour. The value that such disclosures have for stakeholders largely depends on their credibility, accuracy and reliability. In this respect, assurance provided by independent professionals is essential to enhance trust. Where and on what independent professional assurance will add value needs to be carefully considered.

FEE has long been working to enhance Environmental, Social and Governance (ESG) disclosures. It contributed to the international debate and the Commission past workshops leading to this part of the Communication. In the FEE Position on ESG Disclosure issued in 2010, FEE presented a series of recommendations including the following:

• encouraging exploring the case for a combined approach to corporate reporting as one of the leverages to embed sustainability in corporate strategy and management practices;
• supporting a debate over the advantages and disadvantages of moving towards more mandatory regulatory approach to ESG reporting at the European level for large and listed companies;
• considering that there is no ESG reporting framework presently fully meeting the needs of capital markets players (namely companies and investors);
• acknowledging the fact that the time has come to unite the efforts of the scattered European initiatives on ESG disclosure and reporting, taking into account a global context; and
• urging the Commission to contribute to the global debate and initiatives in this area and ensure that any European requirements or guidance are compatible with these international developments.

FEE commends the Commission for the progress already made and encourages its further efforts in this direction.

The Commission highlights that integrating financial and non-financial reporting represents an important goal for the medium and long-term and that it will present a legislative proposal on the transparency of the social and environmental information provided by companies in all sectors. FEE supports the Commission in its ongoing efforts to engage with all stakeholders and looks forward to the impact assessment of possible options for this proposal that it is currently undergoing. As all impact assessments, it should be robust, comprehensive and independent.

FEE also welcomes the Commission’s commitment to follow with interest the work of the International Integrated Reporting Council (IIRC). In the Communication, it is also noted that there are a number of international frameworks for the disclosure of social and environmental information, including the Global Reporting Initiative (GRI). FEE is closely monitoring and contributing to the current development process of the GRI G4 Sustainability Reporting Guidelines.

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