ESG Materiality Assessment

Our ESG materiality assessments help organizations identify important sustainability impacts, risks and opportunities, serving as a foundation for stakeholder engagement, transparency and long-term success by prioritizing ESG factors with the most impact on their business.
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For those businesses struggling to get started on their sustainability journey, confused by the complexity of what their environmental, social and governance (ESG) agenda should be or simply seeking to become more accountable, conducting a materiality assessment with Kroll is a good starting point.

Even companies that have established ESG programs and regularly disclose ESG information find materiality assessments useful for prioritizing, reaffirming or refreshing their ESG goals and reporting program.

No matter how mature a company is, what their goals are or how many resources they have at their disposal, organizations should consider a thoughtful materiality assessment as a critical component of their decision-making for long-term sustainability.

In fact, evolving regulation is rapidly moving in the direction of making reporting on material sustainability factors mandatory.

What is an ESG Materiality Assessment?

What is ESG Materiality Assessment

The materiality assessment is a formal process used by decision makers to identify the issues that affect an organization’s sustainability performance and/or that affect people and the planet. Materiality originated in legal and financial accounting and specifically refers to both financial and nonfinancial factors that must be disclosed under securities laws. It has expanded from its original usage to become a useful tool to identify and prioritize those ESG issues that matter most to your organization.

In addition to its impact on both internal and external stakeholders, a material risk or opportunity can have a significant impact on the financial, economic, reputational, and legal aspects of a company. An increasing number of companies are incorporating these issues into their future strategic planning and development.

Identifying which ESG issues are most salient, or “material,” is now considered a key step toward developing a successful strategy for the organization and determining which issues it should report on.

Benefits of Engaging Kroll to Conduct a Materiality Assessment as Part of a Broader ESG or Sustainability Program

Kroll’s materiality assessments offer numerous benefits to an organization. They help identify key sustainability-related impacts, risks and opportunities; foster stakeholder engagement; enhance transparency; and position the organization for long-term success in a world where ESG considerations are increasingly important to stakeholders and regulators.

Identifying Key ESG Matters
Our materiality assessment helps an organization identify and prioritize the most relevant and effective sustainability matters for its business. Identification allows an organization to define its purpose and scope along its ESG journey. This also ensures that resources are allocated to address opportunities that matter most to stakeholders and the organization's long-term sustainability.

Stakeholder Engagement
By involving stakeholders (including investors, customers, management, employees, regulators and affected communities) in the materiality-assessment process, organizations can foster better relationships and trust. This engagement can lead to improved communication, responsiveness to concerns and enhanced reputation. Stakeholder feedback on the material topics identified is critical to the process.

Risk Management
Identifying and addressing material ESG matters proactively can help organizations mitigate potential negative impacts and enhance their broader enterprise risk-management processes. This can include reducing financial and operational risks, avoiding regulatory fines and protecting against reputational damage.

Opportunity Identification
Materiality assessments often reveal sustainability-related opportunities that align with an organization’s core business strategy. These opportunities may include cost savings through greater efficiencies (e.g., energy-related efficiencies), access to new markets through sustainable products or enhanced brand differentiation.


Enhanced Reporting and Transparency
Organizations can use the insights from Kroll’s materiality assessment to improve their ESG reporting. This leads to more accurate, decision-useful and credible reporting which can attract investors and other stakeholders interested in the company’s ESG performance.

Regulatory Compliance
Understanding material ESG issues helps organizations stay ahead of evolving regulatory requirements related to sustainability and responsible business practices. This is particularly useful as regulators increasingly focus on material sustainability-related financial risks and impacts on people and the planet. This can minimize compliance risks and costs and make the organization that much more attractive to investors.

Employee Engagement and Talent Attraction
Materiality assessments also facilitate identification of the sustainability factors that most contribute to talent attraction and retention, especially among those individuals who prioritize working for socially responsible organizations. It can also boost employee morale and engagement, which leads to more committed employees who work together to instill the organization’s culture.

Conducting an Effective Materiality Assessment

Kroll’s ESG materiality assessments help identify and prioritize the right ESG factors with the most impact on your business and/or that are most important to stakeholders.

Identifying Potentially Relevant Sustainability Issues and Key Stakeholder Groups
Ranking and Prioritizing the Right Sustainability Factors
  • In-depth interviews and information gathering from leadership and key internal and external stakeholders
  • Document review (existing sustainability-related reports and policies, procedures, and processes)
  • Comprehensive research on:
    • Macrotrends, industry dynamics, and competitive benchmarks
    • Scale, scope and severity of actual and potential harms from products, services and operations
    • Voluntary frameworks (e.g., Sustainability Accounting Standards Board [SASB], Global Reporting Initiative [GRI], International Sustainability Standards Board [ISSB], Climate Disclosure Project [CDP], Task Force on Climate-Related Financial Disclosures [TCFD], UN Principles for Responsible Investment [UN PRI])
    • National and subnational regulation (e.g., EU Corporate Sustainability Reporting Directive [CSRD] and European Sustainability Reporting Standards [ESRS], US SEC proposed regulation S-K and S-X, California Climate Corporate Data Accountability Act [CCDAA] and Climate-Related Financial Risk Act [CRFRA])

  • Analytics from qualitative and quantitative surveys and questionnaires
  • Review and incorporation of results of targeted intel gathering from field research and subject matter experts
  • Incorporation of management and board-level input on financial and commercial trade-offs, thresholds and budgetary considerations
  • Determination of strategic priorities, broader reporting requirements and on-going monitoring needs
  • Communication of results through visual depictions


Double Materiality

Double Materiality

An increasingly important consideration when conducting materiality assessments is whether or not to identify and assess existing and anticipated sustainability harms or benefits on people and the planet from an organization’s products, services and operations—through a process known as a “double” materiality assessment.

Typically, traditional (or “financial”) materiality focuses exclusively on a company's internal operations and financial drivers and performance to determine how its activities may affect stakeholder decisions about it and, over time, erode or create business value. Double materiality, however, takes the concept of materiality in sustainability reporting one step further.

In double materiality, a company also looks outward beyond financial drivers and performance to assess how its operations and decisions affect the external environment. Double materiality poses two overarching questions:

  • Which sustainability-related risks and opportunities directly relate to a company’s ability to financially perform and grow its enterprise value (i.e., financial materiality)?
  • How do a company’s products, services or operations cause or contribute to existing or future harms or benefits on people and the planet in terms of severity and likelihood (i.e., impact materiality)?

Understanding and Navigating the Demands of Different Frameworks and Standards

Different voluntary frameworks and standards have adopted different approaches and expectations concerning materiality. A double-materiality approach is required by the GRI, for example, which considers a wider range of stakeholders and focuses on issues that contribute to overall sustainable development. Both the ISSB and the SASB, on the other hand, take a more principle-based traditional approach focused on sharing decision-useful information with providers of capital. While both the ISSB and SASB recognize the potential value of also assessing impact, they are primarily focused on providing a methodological framework for consistent, comparable and decision-useful information in the context of financial decision-making.

Materiality requirements vary across jurisdictions as well, with U.S. regulators taking a different approach than those in the EU. The Securities and Exchange Commission in the United States maintains an investor-centric approach to sustainability issues, for example, focusing on those risks and opportunities that materially affect enterprise value and ensuring that information reported does not mislead investors.

However, in the EU, the CSRD expressly requires double materiality, the specific details of which have been set out by the European Financial Reporting Advisory Group (EFRAG). Despite the importance of value creation and financial materiality in EFRAG's sustainability reporting standards, EFRAG also recognizes that impact materiality is a crucial component of an organization's assessment, and that organizations should consider and disclose existing and anticipated impacts beyond those that carry financial risks and opportunities exclusively for the organization.

Kroll’s Approach to Double Materiality

Kroll regularly aids organizations in determining whether traditional or double materiality is the right approach. We help organizations weigh the costs and benefits, including the following considerations:

Regulatory Requirements

We examine the regulatory environment in which your company operates. Some jurisdictions (e.g., the EU and Brazil) may require organizations to report on both traditional and impact (ESG) aspects, effectively mandating a double-materiality perspective.

Risk-Management Considerations

We consider the broader benefits to your enterprise risk-management processes and procedures. Double-materiality assessments can unearth a much wider range of existing and potential sustainability-related risks, including “unknown unknowns” that may currently be outside of management’s existing risk-detection systems. Identifying and engaging with a much larger set of stakeholders beyond those with direct financial relevance to the organization during the impact assessment can offer tangible benefits by surfacing emerging or hidden sustainability risks, enabling better management and treatment of risk in general.

Stakeholder Expectations

We assess the expectations and demands of key stakeholders, including investors, customers, employees, management, regulators, advocacy groups and affected communities. Many stakeholders, including investors, increasingly expect companies to provide comprehensive sustainability reporting that addresses both traditional and impact materiality whether or not required by regulators.

Industry Norms

We evaluate industry-specific reporting standards and best practices. Some industries have well-established norms for sustainability reporting that emphasize a double-materiality approach. Adhering to industry norms can enhance credibility and comparability within your sector.

Competitive Advantage

We assess whether double materiality might enhance an organization’s competitive positioning. Demonstrating a comprehensive understanding of how ESG and sustainability factors affect both your financial performance and your broader societal and environmental context will make your organization more attractive to socially conscious investors and customers.

Long-Term Strategy

If sustainability is a key component of your business strategy and you aim to remain competitive in a rapidly changing market where ESG factors are becoming increasingly important, a double-materiality perspective will help you make informed decisions and adapt more effectively.

Your Next Steps with a Materiality Assessment

No matter whether your organization has an established ESG or sustainability strategy, or if it is completing a materiality assessment for the first time, the process can be daunting and may pose challenges. As part of a structured, customized process, Kroll will work with you to set a clear plan, assessing materiality relevance through data-driven analysis and industry benchmarks, while engaging stakeholders throughout the organization and externally to ensure the right objectives are identified and the proper solutions achieved.

If you believe your organization may benefit from our expertise in materiality assessments and our ESG advisory solutions, please contact us.

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