Nataliia Syrotenko
Odesa National Economic University, Ukraine
E-mail: nsirotenko@ukr.net
Nataliia Pravdiuk
Vinnytsia National Agrarian University, Ukraine
E-mail: npravduyk@gmail.com
Yulia Slobodyanik
Kyiv National Economic University named after Vadym
Hetman, Ukraine
E-mail: yslobodyanik@gmail.com
Svitlana Holovatska
Lviv University of Economic and Trade, Ukraine
E-mail: petrokutsyk55@gmail.com
Tetyana Skrypko
Ivan Franko National University of Lviv, Ukraine
E-mail: tanskr.lviv@gmail.com
Submission: 12/28/2020
Revision:1/30/2021
Accept: 3/4/2021
ABSTRACT
The study examines the features of environmental disclosures in the
management reports of medium and large enterprises of Ukraine for 2018-2019, as
well as non-financial reports of leading global companies, highlights the
positive aspects and problematic issues in terms of information content,
provides recommendations to improve approaches to environmental disclosures and
enhancement the quality and public confidence in the reports. The methodological basis of the study is Ukrainian regulatory
framework and recommendations of non-governmental world organizations on
environmental disclosures, comparative analysis, theoretical studies, and best practices. In the course of the research were collected and processed empirical data of 78 medium and large enterprises of 7 leading sectors of Ukraine's economy and data from some of the world's largest
energy, mining, agricultural, transport, pharmaceutical, food, and construction companies.
The conducted research confirms that the lack of mandatory indicators regarding disclosing environmental information and sanctions for non-provision and improper disclosure of data does not ensure transparency and comparability of reports. In order to monitor the environmental situation in Ukraine, it is recommended to disclose environmental information to all enterprises, regardless of their size; creation at the level of the regulator of a model report with the inclusion of a list of mandatory indicators of public importance and additional industry indicators; strengthening responsibility for improper information and incomplete disclosure and concealment of significant financial and non-financial environmental information; introduction of the statutory audit of management reports.
Keywords: Environmental disclosures; Management report; Transparency; Responsibility; Communication; Accounting
1.
INTRODUCTION
Ukraine continues its
purposeful movement towards harmonization with European legislation in the
field of accounting and auditing. Amendments to the Law of Ukraine “On
Accounting and Financial Reporting in Ukraine” adopted in 2017 updated the
classification of enterprises with their division into micro, small, medium and
large enterprises, introduced the concept of the “public-interest entity”,
expanded the scope of a statutory audit, fixed the need for individual entities
to prepare a management report.
The law stipulates that
the management report contains financial and non-financial information that
characterizes the enterprise's state and prospects
and reveals the principal risks and
uncertainties of its activities. In general, this characteristic of the
management report meets the requirements of Directive 2013/34/EU and Directive
2014/95/EU of the European Parliament and the Council, according to which it
should contain a balanced and comprehensive analysis of the development and
operation of the enterprise, including financial and non-financial data, in
particular on environmental and employee matters.
However, the Guidelines for the
Management Report approved by the Ministry of Finance of Ukraine (2018) set
requirements for the structure and content of the report, which provide for the
disclosure of information such as organizational structure and description of
the enterprise, results of operations, liquidity and liabilities, environmental
aspects, social aspects and personnel policy, risks, research and innovation, financial
investments, development prospects.
Besides, for large
enterprises with an average number of employees exceeding 500, it is
recommended to include in the management report non-financial indicators on the
impact of the enterprise on the environment, social protection, and respect for
human rights, anti-corruption, and bribery.
Thus,
it became apparent to expand the management report's content and include in it
the issues contained in international practice in the reports on sustainable
development, corporate social responsibility, strategic reports, integrated
reports, etc.
It should be noted that
the idea of disseminating non-financial reports in the world is not only to
meet the demands of many stakeholders and form a positive image but also to maintain
confidence in it, which is the key to efficiency and longevity on the market.
It is essential to have a conscious attitude of
business entities to prepare such reports, which, above all, requires
compliance with generally accepted standards and high quality. In other cases,
non-financial statements will be just a pro forma.
The
management report's effectiveness depends on management's awareness of its
importance, the expectations of stakeholders, and the appropriateness of
disclosing certain information. At the
same time, according to experts, a significant percentage of Ukrainian
enterprises conduct shadow business. Therefore, the
company's management's reluctance to disclose complete and reliable information
regarding environmental issues is expected. In this light, foreign companies' experience that prepare and publish
non-financial reports for more than a decade should be useful.
2.
LITERATURE REVIEW
The development of
approaches to the formation of non-financial reports in response to the diverse
and ever-increasing demands of external stakeholders has been studied for a
long time. For example, in the late 1990s, under the aegis of the European
Commission, research was conducted to assess the feasibility and cost-benefit
ratios of environmental disclosers in corporate annual and financial reports
(Jones, 2001). The study analyzed the content and location of environmental
information in the companies’ annual and financial reports in different
countries.
Jones (2001) emphasized
that the mere presence of environmental disclosure in different reports does
not indicate the type, quality, or comparability of the disclosed data. In
addition, the environmental disclosures in an annual or financial report
“…should present a “true and fair” view not only in words but also in
quantitative data where possible” (Jones, 2001).
The author noted that
to increase the usefulness of environmental information in an annual or
financial report, environmental disclosure should be presented in context to
make it easier to interpret. Given that different companies disclose
environmental information differently, it is difficult or sometimes even
impossible to compare. Moreover, to increase the reliability of environmental
information, it was recommended to conduct a statutory audit. However, the ability to professionally assess
environmental information will be an additional challenge for auditors who will
need special training.
The importance of
communicating environmental information to stakeholders is enhanced by climatic
changes and their consequences, which have exacerbated recent decades.
Therefore, the standardization of approaches to the disclosure of such
information is now supported by many initiatives, including the Global
Reporting Initiative (GRI), the UN Global Compact International, the
Sustainability Accounting Standards Board (SASB), the International Integrated
Reporting Council (IIRC) and many others.
However, even 20 years
later, studies conducted in different countries show that the problem with
environmental disclosure has not been resolved. Thus, Baalouch, Ayadi and
Hussainey (2019) analyzed the quality of non-financial information using a
sample of French listed companies for the period 2009-2014, which determined
that the quality of disclosure information remains relatively low.
In addition, their
findings indicate that the company's strategy, vision, and environmental
performance play an important role in explaining changes in the quality of
environmental performance. The authors note that the independence of the board
of directors and the company's environmental performance have a positive impact
on the quality of environmental disclosure.
According to the study,
the authors recommend that those who set standards and develop policies to
increase transparency and accountability think about implementing a generally
accepted framework of non-financial reporting. The study also emphasizes that
the external confirmation of environmental information is positively related to
the quality of environmental disclosures.
The authors explain
this conclusion by the provisions of neo-institutional theory, confirmed by
case studies that firms, as a rule, comply with regulatory pressure from
regulators to ensure transparency and reliability of disclosed information. Thus,
according to Baalouch, Ayadi, and Hussainey (2019), an external audit of
environmental information will help improve the quality of environmental
information and strengthen stakeholder trust.
Artene and co-authors
(2020) also pay attention to the problem of incomparability of non-financial
information. The researchers analyzed the frequency of terms in the
non-financial statements of Romanian and Greek companies and found that
countries using the relevant EU Directive still have very different approaches
to presenting information, making cross-country comparisons impossible. That is
why the need to strengthen the requirements for the structure of information in
non-financial statements is currently being considered.
Even the development of
modern standards aimed at standardizing certain information in the reports of
enterprises (GRI, SABS, IR, etc.) does not solve the problem of information
incomparability. Thus, Aluchna, Hussain and Roszkowska-Menkes (2019) emphasize
that communicating sustainable development efforts to stakeholders remains a
challenge for managers. The authors' observations point to the shortcomings of applying
IR standards, which are related to the lack of clearly defined recommendations
for their application. Additionally, companies transitioning to IR should do so
gradually, which also requires voluntary management efforts.
According to the
legitimacy theory, the essence of which is thoroughly described in the
scientific publication Kuruppu, Milne and Tilt (2019), voluntary increase in
disclosure of environmental accounting in practice occurs when the company
needs to maintain or restore its legitimacy in society, often after adverse
incidents (for example, leakage of pollutants).
Similar results are
presented in the study of Ding, Qu and Shahzad (2019), who, on the example of
Chinese companies, proved that entities that have received environmental fines
increase the volume of disclosure of "positive" environmental
information. At the same time, environmental sanctions force the punished
entity to reduce the amount of environmental information required for
disclosure, avoiding the disclosure of sensitive environmental information (for
example, on pollution).
The authors emphasize
that to prevent this situation, it is necessary to determine the mandatory
component of environmental information and maintain control over the
responsibility for its provision. Researchers also emphasize the need to
maintain qualitative characteristics of environmental information, such as
relevance, reliability, clarity, comparability, balance, and integrity.
Moreover, Wahl,
Charifzadeh and Diefenbach (2020) conclude that the positive effects of
integrated reporting are more relevant in environments where IR is mandatory.
Their study shows that there is no significant relationship between voluntary
disclosure of the integrated report and improved transparency of information.
Portella and Borba
(2020), based on a comparative analysis of the environmental disclosures by
companies in the United States and Brazil, received conflicting data that do
not support the legitimacy theory. The authors argue that more efficient
companies have higher rates of environmental disclosure. The differences
identified by researchers in the environmental disclosures require additional
cross-country comparisons.
Interesting are the
results of a study by Ma, Zhang, Yin and Bingcheng (2019), who, based on the
analysis of disclosures by Chinese companies, provide evidence that the
education and age of top managers influence the companies’ environmental
decisions. Thus, the education of a Master of Business Administration (MBA) and
the average age of top managers positively affect the environmental
disclosures, while the impact of legal education is negative.
Research reveals a direct
link between the disclosure of information about certain aspects of the
enterprises’ activities, a corresponding improvement in reputation, an increase
in the trust of business partners and the community, and the ease in obtaining
licenses, permits, certificates, which provide for the mandatory coordination
of future activities or implementation of projects with a particular category
of stakeholders (for example, when obtaining a construction permit).
At the same time, there
is a tendency to manipulate the company's information disclosed in external
reports to improve the image and create a positive image for stakeholders about
its activities. That is why today, more and more attention is paid to the
balanced disclosure of not only positive facts about the company's activities
but also negative, as well as a description of management measures to correct
negative consequences and avoid them in the future.
The conclusions of
scientists conducting research in this area are essential, in particular, through
empirical analysis of mass surveys of companies and their stakeholders on the
perception of non-financial statements, problems with their preparation and
expected quality. In our opinion, the study results by Helfaya, Whittington and
Alawattage (2018) on the inability of researchers to assess the report quality
without a detailed understanding of user needs are noteworthy.
Based on a detailed
survey of companies preparing sustainable development reports and users of
these reports, the researchers described a new understanding of the report
quality, taking into account the critical judgments of both parties. Research
has shown that the amount of information is not perceived as the essential
element in determining quality.
In addition to the
number, respondents also perceive the types of information, the activities
used, the topics covered, the guidelines for reporting, including the
validation of reports, and the use of visualization tools. Moreover, the
authors emphasize that the validity and reliability of reports are achieved
through the adoption of external reporting standards and confirmation of
reports by an independent third party (external auditor, expert).
However, Siddique and
Sciulli (2020), surveying investors who are members of a large Australian
investment company, indicate that investors expect high-quality environmental
disclosures from large firms rather than small ones, especially those operating
in environmentally sensitive sectors.
Noteworthy are the
results of a study by Yin, Li, Ma and Zhang (2019), which analyzed the
relationship between the type of environmental disclosure and firm
profitability. The authors demonstrated the difference between substantive and
symbolic styles of disclosures. Thus, firms that disclose their environmental
information in a substantive style focus on quantitative data related to
investments in environmental management and environmental achievements (clean
production, pollution control, development of green products).
Instead, the symbolic
style of disclosure focuses on many textual descriptions and non-quantitative
information (descriptions of behavior, corporate visions, etc.). Simultaneously,
researchers have proven that a symbolic style can help a company create an
environmentally responsible image in the market, maintain social legitimacy,
and lobby stakeholders in the capital market.
In our opinion, we
should take into account the study of Jeffwitz and Gregor (2017), who analyzes
the requirements for the management responsibility for the preparation and
disclosure of non-financial information in the UK, Germany, France, and Italy.
The consequences of non-compliance vary in different jurisdictions, from
administrative fines (in Italy) to imprisonment (in Germany).
In Italy, the
consequences apply to external auditors and persons who audit the report on
non-financial information. It is a criminal offense for directors not to
prepare and publish non-financial information as required in the United Kingdom
and Germany. Management must comply with the “comply or explain” rule,
according to which in the event of non-compliance of disclosed information with
the requirements in the absence of sound explanations, management is liable.
Thus, despite efforts
to unify the disclosure requirements for non-financial information, in
particular environmental information, different countries continue to use
various approaches that complicate cross-country comparisons and do not support the dissemination of
relevant standards.
3.
RESEARCH PROBLEM
In Ukraine, the need to
disclose environmental information in the enterprises’ reports of has long been
considered. At the same time, Ukrainian companies have no experience preparing
non-financial reports (except for large corporations and companies with foreign
capital). They are accustomed to the mandatory of implemented financial, tax,
and statistical reports, which has always been accompanied by strict
requirements for specific indicators and structure.
Approved Guidelines for
the Preparation of a Management Report are indicative and limited to a
description of general areas and a list of individual indicators, emphasizing enterprises'
right to submit information at their discretion. On the one hand, the
regulatory document opens ample opportunities for flexible presentation of
information by enterprises, does not put them in a rigid framework, and focuses
on interaction with stakeholders.
On the other hand, the
lack of precise quality requirements for the management report, for which it is
only stated that the report contains reliable financial and non-financial
information, entails subjectivity in the disclosure of information, which in
the absence of experience in preparing such reports completely undermines the
relevance of this document.
At the same time,
international experience and modern scientific research confirm the importance
of ensuring the quality of environmental disclosures, which is manifested in
its accessibility, transparency, and reliability, as well as in the
responsibility for improper presentation.
Thus, the purpose of this study is to
evaluate the management reports prepared by Ukrainian companies in terms of
environmental disclosure, compare them with best practices and find ways to
improve approaches to the presentation of such information, taking into account
the balance of interests of stakeholders.
4.
DATA AND METHODOLOGY
For the purposes of the article, the
authors conducted a desktop study of standards governing the environmental
disclosures, content analysis of management reports, and
other reports of Ukrainian and foreign companies that contain non-financial
information.
The study analyzed the data of 78
Ukrainian companies required by law to publish a management report. The
companies selected for analysis belong to the most environmentally sensitive
sectors – energy, mining, agriculture, transport, construction,
pharmaceuticals, and food. After that, a comparative analysis of approaches to
the environmental disclosures in Ukrainian companies and world leaders in
relevant fields – companies in the United States, Germany, Saudi Arabia, Great
Britain, Brazil, Australia, and Switzerland.
5.
RESULTS AND DISCUSSIONS
It should be recognized that the
preparation of reports with non-financial indicators is the subject of extended
discussion among scientists and practitioners in Ukraine (Nesterenko, 2018;
Potryvaieva et al., 2019; Tsaruk, 2020). The main contradictions are contained
in the organizational and methodological plane and relate to informativeness,
consistency with other forms of reporting, and responsibility.
There is no consensus among
Ukrainian researchers on the purpose of the management report. Thus, according
to Karpushenko and Shakhverdyan (2019), the national management report,
together with the financial statements, is part of the integrated reporting. At
the same time, Ozeran (2017) believes that the legislators made a
terminological inaccuracy in translating the term “management report” into
Ukrainian. The author also argued that this report was similar to the MD&A
(Management Discussion and Analysis) reports distributed in Canada and the
United States and the OFR (Operational and Financial Review), which comprise
British companies. According to the researcher, the management report should be
part of the financial statements and contain financial and non-financial
information about the enterprise's state, results, and prospects. It was
emphasized that the management report serves as a clarification and addition to
the financial statements and should not replace other reports addressed to a
broader range of users.
The generalization of the existing
approaches in world practice to the formation of a similar report suggests that
the needs of interested users should be based, in particular, on information
about environmental activities and consequences. At the same time, we can state
the passivity and information indifference of Ukrainian citizens and their
focus (in the vast majority) on today's social and domestic interests – aspects
of work or the feasibility of the existence of specific enterprises that cause
significant damage to the environment.
Thus, currently in Ukraine,
environmental information must be disclosed in the management report, which is
included in the annual report and must be fully published on the company's
official website. Simultaneously, enterprises have the right to determine the
content of the section on environmental information independently. In general,
we positively assess the implementation of approaches to increase the
transparency of Ukrainian enterprises, including environmental activities. At
the same time, we highlight several problematic aspects:
·
The
regulator does not prescribe clear criteria for the amount of information and
the calculated indicators. The planned combination of textual information and
infographic (diagrams, drawings, photographs) provokes a certain subjectivity
of their presentation by the enterprises’ management.
·
The content of environmental disclosures is not
limited to purely economic information, and therefore in order to cover technical
data, case law and social measures requires the involvement of competent
external specialists, including technical, legal, and other services of the
company, external focus groups (the impact of the enterprise on the
environment, the measures taken to eliminate the negative consequences of such
impact, etc.).
·
There is no liability for failure to provide
improper provision and non-publication on the company's official website of the
management report and, consequently, environmental information. In this regard,
it is essential to consider the lack of
voluntary disclosure practices, which, in particular, was influenced by the
peculiarities of capital formation in Ukraine, a significant percentage of
which is currently “in the shadows”, attempts to evade transparent data.
Ukrainian business entities are accustomed to the directive influence of the
state, and therefore any weakening of control and independence will provoke the
expected consequences – a formal attitude to the disclosure of information with
a minimum of effort.
We
believe that under such conditions, the information value of the Ukrainian
management report will be meager. Given the gradual development of
experience in creating a management report by domestic enterprises, it is
useful to analyze specific reports to identify positive and negative aspects.
Unfortunately, not all companies that compile a management report currently
publish it in open sources, which indicates a lack of understanding of the
purpose of this report. Therefore, we conducted a content analysis of the
management reports published on the websites of medium and large enterprises
(Table 1).
The
results of the analysis of 78 management reports of medium and large
enterprises of key economic sectors in Ukraine that have the most significant impact on
the environment allow us to state the
following:
·
Management reports of Ukrainian companies
are prepared according to the basic indicators of the Guidelines for the
Management Report (2018) and do not disclose the specifics of activities that
do not contribute to the transparency of sectoral reporting. The most
profitable industries that affect the environment and are provided with the
necessary staff, as shown by the actual analysis, are not yet interested in
disclosing industry features. We believe that at the initial stage line
ministries should be involved in the development of sectoral guidelines and
include key indicators in the management report that reflect
trends in the sectoral environmental impact on sustainable development.
Table
1: Environmental disclosures in the management reports of enterprises in
various sectors of the Ukrainian economy
Informativeness of the management report in
accordance with the requirements of the Guidelines for the Preparation of the
Management Report |
Energy |
Mining industry |
Agriculture |
Transport |
Pharmaceutical
industry |
Food industry |
Construction |
Regarding environmental activities: |
|
|
|
|
|
|
|
- impact on the
environment; |
+ |
+/–* |
+ |
+ |
+/– |
+/– |
+ |
- environmental
protection measures; |
+ |
+/– |
+ |
+/– |
+ |
+ |
– |
- reducing the
impact on the environment |
+ |
– |
+ |
+/– |
+/– |
+/– |
– |
independently determined by the enterprise: -
- environmental policy; -
- raising the environmental awareness of employees; -
- eco-projects. |
– |
+ + |
+ + |
– |
+ + |
+ + |
– |
Environmental indicators: |
|
|
|
|
|
|
|
- rational use of
water; |
+/– |
+ |
+ |
– |
+/– |
+/– |
– |
- waste
management; |
+/– |
+ |
+ |
+/– |
+/– |
+ |
– |
- greenhouse gas
emissions; |
+/– |
+ |
+ |
+/– |
– |
+/– |
– |
- energy
consumption; |
– |
+/– |
+ |
+/– |
+/– |
+ |
– |
independently determined by the enterprise: - costs of
environmental protection measures; - biodiversity; - investments in
energy efficiency; - Environmental
Compliance; - Supplier
Environmental Assessment |
+ + |
+ + |
+ + |
+/– |
– |
+ |
– |
* +/-
information is not disclosed by all enterprises in this industry
Source: compiled by the authors according to management reports of
enterprises
Management
reports of the farmers are the most meaningful. The logical explanation for
this phenomenon is the influence of foreign investors familiar with the
practice of preparation and disclosure of such information in the global space.
·
The regulator's recommendations can be
considered partially disclosed only at the level of environmental protection
measures.
·
On their own initiative, enterprises of
the extractive industry, agriculture, pharmaceutical, and food industries
disclose environmental policy. This should be considered a strength, as
businesses have a strategic vision of their place in the ecological
environment. For example, the lead enterprises of the Ukrainian economy do not
provide such information.
·
Management reports of construction
companies are not transparent, even considering the minimum set of indicators
included by the regulator, although the impact of their activities on land,
water, and air resources is significant. In our opinion, each company should
independently determine the report's scope, based on an understanding of the
stakeholders’ expectations. Although, for example, the International Standard
on Integrated Reporting requires a "report brevity", which should
also ensure the complete disclosure.
·
Mining and agricultural enterprises
disclose information about eco-projects, which indicates an understanding and
efforts to overcome the social problems of vulnerable groups of the population.
·
Management reports of enterprises within
the industry, as well as intersectoral, are not comparable in the set of
indicators. As an example, the management reports of medical institutions and
commercial enterprises (not presented in the table, given their lower impact on
the environment) additionally disclose such environmental indicators as
environmental taxes; use of vehicles; fines and penalties for non-compliance
with environmental legislation; heat recovery system and others. We can
conclude that top management education has a significant impact on the
formation of the mission and vision of enterprises, hence the disclosure of
environmental performance.
·
No information about the management
reports has appeared on many websites of large and medium enterprises for two
years. The absence of penalties leads to irresponsibility on the part of
enterprises that constitute a significant part of the Ukrainian economy. Based
on this, it is advisable to take coercive measures.
·
Management reports do not disclose the
proposals of stakeholders (investors, communities, states).
·
Enterprises do not disclose information
about environmental risks and penalties for violations of the law.
Table
2 presents the results of a comparison with the best world practices. When
choosing companies, we gave preference to the largest companies from different
countries to compare existing environmental disclosure requirements.
Table 2: Comparative analysis of reports with
the environmental disclosure of lead enterprises in Ukraine and the world
Industry / enterprise |
General characteristics |
Internal informativeness |
|||||||||
Name of the report* |
Access to the website** |
Declared standards*** |
Data disclosure style**** |
Information on environmental
policy |
Pollution information |
Information on environmental
protection |
Environmental taxes |
Liability for violations of the
law |
Environmental risks |
Proposals of stakeholders
(state, investors, community) |
|
Energy: E.ON (Essen, Germany) |
SR |
е |
GRI |
sub |
– |
+ |
+ |
– |
+ |
– |
– |
NNEGC Energoatom (Ukraine) |
MR |
h |
GRI |
sym |
– |
– |
+ |
– |
– |
– |
– |
Mining industry: Aramco (Saudi
Arabia) |
AR |
е |
n |
sym |
– |
+ |
+ |
– |
– |
– |
– |
Naftogaz (Ukraine) |
MR |
е |
n |
sym |
+ |
– |
+ |
– |
– |
– |
– |
Agriculture: Kidman & Co Ltd (Australia) |
– |
h |
– |
– |
– |
– |
+ |
– |
– |
– |
– |
KERNEL (Ukraine) |
AR |
е |
GRI |
sub |
+ |
+ |
+ |
– |
– |
+ |
+ |
Transport: MetrôRio (Brazil) |
AR |
е |
GRI |
sub |
– |
+ |
+ |
– |
+ |
– |
– |
KP "Kyiv Metro"
(Ukraine) |
MR |
е |
n |
sym |
– |
– |
+ |
– |
– |
– |
– |
Pharmaceutical industry:
Pfizer
Inc. (USA)
|
FR |
е |
– |
– |
– |
– |
– |
– |
– |
– |
– |
JSC "Farmak" (Ukraine)
|
NFRSD |
е |
n |
sym |
– |
– |
+ |
– |
– |
– |
– |
Food industry: Nestle (Switzerland) |
CGR |
е |
– |
– |
– |
– |
– |
– |
– |
– |
– |
Confectionery
Corporation ROSHEN (Ukraine) |
SОСR |
е |
GRI |
sym |
– |
– |
+ |
– |
– |
– |
– |
Construction: Laing
O’Rourke (Britain) |
AR |
е |
– |
– |
– |
– |
– |
– |
– |
– |
– |
PJSC
"HC" Kyivmiskbud (Ukraine) |
MR |
е |
n |
sym |
– |
– |
+ |
– |
– |
– |
– |
* MR – management report, SR – sustainability report, AR – annual report,
NFRSD – non-financial report on sustainable development; SОСR – social report,
CGR – corporate governance report, FR – financial report;
** h – hard, e – easy to find;
*** n - national legislation, GRI – Global Reporting Initiative;
**** sub - substantive, sym - symbolic
Source: compiled by the authors according to
enterprises’ reports
To
summarize the conducted comparative analysis of reports with the environmental
disclosure, we note the following.
Companies
disclose information about environmental activities in various reports – a
management report, a sustainability report, an annual report, a non-financial
report on sustainable development, a social report, a corporate governance
report, a financial report, etc. The lack of a single form of information
presentation makes it challenging to
find relevant information for different stakeholders and make international
comparisons. This determines the feasibility of developing international
standards in this area, such as IFRS, ISA, and others (Semenyshena, et al.
2020). We
consider it appropriate to develop such standards under the aegis of IFAC.
It
should be noted that according to our observation, the most meaningful are the
reports of energy and transport companies, which declare the preparation of
reports according to GRI. Such companies structure indicators with coverage of
materials, energy, water and wastewater, biodiversity, emissions, waste,
provide information on compliance with environmental requirements, the use of
transport, and more.
The
least transparent from the point of view of the studied indicators are the
enterprises’ reports of the mining, construction, food, pharmaceutical
industries. Almost undisclosed at the level of lead companies are the
following: environmental taxes; liability for violations of the law;
environmental risks; offers of stakeholders.
6.
CONCLUSIONS AND RECOMMENDATIONS
Taking
into account the results of the research, we recommend the following:
1) Establish
requirements for the environmental disclosures by all enterprises, regardless
of their size. Simultaneously, the management
report with financial and non-financial indicators in full form for large
enterprises and abbreviated form – for medium, small, and micro-enterprises. By
the way, Denmark and Sweden conduct integrated reporting for companies with
more than 250 employees (i.e., for medium-sized enterprises), in contrast to
the requirements of the EU Directive (more than 500 employees) (Jeffwitz &
Gregor, 2017).
2) To ensure the
balance of public interests and freedom of enterprise, we consider it
appropriate to combine a flexible approach to the environmental disclosures in
the management report. The regulator must fix a specific part of the indicators as mandatory. At the same
time, it is necessary to enable companies to provide information at their own
discretion, based on the current needs of stakeholders. To this end, it is
necessary to develop a model report, which should consist of mandatory and
additional indicators that will highlight the specifics of enterprises’ economic
activity (industry, construction, agriculture, transport, etc.) with the
appropriate level of individual detail. Mandatory indicators should be
developed at the level of the Ministry of Finance of Ukraine and the State
Statistics Service of Ukraine, and additional – at the level of line ministries
and public professional organizations. For example, the environmental impacts
of coal, transport, and agricultural enterprises will differ significantly but
will be of particular interest to stakeholders.
3) We
consider it expedient to single out the qualitative characteristics of
environmental information disclosed in the management report, according to the
following blocks: a) in terms of content: reliability and completeness;
objectivity and impartiality; materiality of the disclosed information;
relevance and clarity; argumentation and persuasiveness of conclusions;
specificity and realism; comparability of financial data; b) on the form of
presentation of information: clarity and accuracy of presentation; logical
presentation; informativeness; data visualization (graphics, tables, images,
photos, etc.); a balance of directions.
4)
It is necessary to define by law the responsibility for improper information
and incomplete disclosure and / or concealment of significant financial and
non-financial information, which essentially determines the quality of the
management report and environmental information disclosed in it. According to
researchers, the use of environmental responsibility principles is
a strategic priority for every company and the basis of sustainable development
(Andrushkiv, et al. 2020; Tsaruk, 2020).
5) To ensure the credibility of the
environmental information published in the management report, it is necessary
to introduce its statutory audit. Confirmed truthfulness and objectivity of
environmental information will also increase management's responsibility for
its disclosure.
Summing
up, we note that Ukrainian companies are only at the initial stage of
"forced" preparation of a management report, which includes
environmental information. Business is not yet aware of all the benefits of a
well-prepared report that in developed countries with significant experience in
disclosing relevant information becomes the basis for investment decisions,
forming a positive image of the company in society, which determines its
efficiency and prospects for further development.
It
is clear that the preparation of a management report requires significant
efforts on the part of management staff, particularly
additional time, the involvement of qualified specialists to ensure quality
coverage of information, including the enterprise's environmental
activities. At the same time, the regulator should
form a positive attitude in society to disclose certain information in the
management report, which will help the state and society take timely measures
to create a more sustainable environment, ensure business accountability, and
achieve Sustainable Development Goals.
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