Top risks and controls for Environmental, Social and Governance
The Environmental, Social and Governance register lists 186 key risks and 135 best-practice controls across 12 units: Collaboration and Partnerships, Continuous Improvement, Environmental Stewardship, Governance and Ethics, Innovation and Research, Investor Relations, Reporting and Disclosure, Risk Management, Social Responsibility, Stakeholder Engagement, Strategy Development and Implementation, Training and Education. Use it to identify risks, benchmark your existing controls or start a risk and control self-assessment (RCSA).
In today's rapidly evolving global landscape, the financial sector has transcended its traditional role of profit generation to become a critical driver of sustainable development.
As society places increasing emphasis on ethical, environmental, and social considerations, banks are expected to adopt a comprehensive approach that goes beyond financial metrics.
This is where Environmental, Social, and Governance (ESG) factors come into play, reshaping the core principles of banking operations.
At the heart of this transformation lies the indispensable practice of risk assessment, a process that evaluates the potential threats and opportunities inherent in ESG dimensions.
By proactively identifying and managing risks across environmental, social, and governance domains, banks can fortify their resilience, enhance their reputation, and contribute to a more sustainable and equitable future.
Units covered
Collaboration and Partnerships: key risks and controls
Responsible for collaborating with external organizations, industry groups, and NGOs to share best practices and collectively address ESG challenges.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Cultural and Organizational Differences | Working with external organizations from different industries or regions might lead to challenges arising from differing organizational cultures and practices. | Controls for this risk are available in the full register. Ask us. |
| Data Privacy and Security | Sharing ESG-related data and information with external organizations could pose risks related to data privacy breaches or unauthorized sharing of sensitive information. | Controls for this risk are available in the full register. Ask us. |
| Dependency on Third Parties | Relying heavily on external organizations to address ESG challenges might lead to dependency issues, where your company's ability to implement initiatives is contingent on the actions of others. | Controls for this risk are available in the full register. Ask us. |
| Diluted Impact | Collaborating with a large number of external organizations could dilute the impact of ESG initiatives due to competing interests and priorities. | Controls for this risk are available in the full register. Ask us. |
| Financial Risks | Investing resources into collaborative ESG initiatives might not yield the desired financial returns, potentially affecting the company's financial performance. | Controls for this risk are available in the full register. Ask us. |
| Governance and Decision-making | Disagreements on governance structures and decision-making processes within collaborative efforts could hinder progress and lead to conflicts. | Controls for this risk are available in the full register. Ask us. |
| Greenwashing Accusations | If collaborative efforts are perceived as mere PR strategies without substantive impact, the company could face accusations of "greenwashing" exaggerating environmental or social efforts for positive image rather than actual change. | Controls for this risk are available in the full register. Ask us. |
| Inconsistent Communication | Miscommunication or lack of coordination among collaborating entities could lead to inconsistencies in messaging and efforts, potentially causing confusion among stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Intellectual Property Concerns | Sharing proprietary ESG strategies or practices with external organizations could potentially lead to intellectual property disputes or loss of competitive advantage. | Controls for this risk are available in the full register. Ask us. |
| Lack of Accountability | Collaborative efforts may suffer from a lack of clear accountability, making it challenging to measure the success of shared initiatives. | Controls for this risk are available in the full register. Ask us. |
| Legal and Regulatory Compliance | Engaging with external entities might expose your company to legal and regulatory compliance issues if they are not aligned with applicable laws and regulations. | Controls for this risk are available in the full register. Ask us. |
| Loss of Control | Collaborative efforts might require compromises and adjustments that could lead to a loss of control over the direction and outcomes of ESG initiatives. | Controls for this risk are available in the full register. Ask us. |
| Misaligned Values | Partnering with external entities that have differing ESG priorities or values could lead to conflicts and hinder effective collaboration. | Controls for this risk are available in the full register. Ask us. |
| Reputation Risk | Collaborating with organizations that are later involved in controversies or unethical practices could negatively impact your company's reputation by association. | Controls for this risk are available in the full register. Ask us. |
| Resource Allocation | Overcommitting resources to collaborative efforts might divert attention and resources away from other crucial ESG initiatives that could be more impactful. | Controls for this risk are available in the full register. Ask us. |
Continuous Improvement: key risks and controls
Responsible for monitoring and evaluating the effectiveness of ESG initiatives and adjusting strategies as needed and regularly reviewing and improving ESG-related policies and practices.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Greenwashing Accusations | Inaccurate or misleading claims about ESG initiatives could lead to accusations of greenwashing, damaging the company's reputation and credibility. | Controls for this risk are available in the full register. Ask us. |
| Inaccurate Data and Reporting | Reliance on inaccurate or incomplete ESG data could lead to flawed assessments of initiatives' effectiveness and misinformed decision-making. | Controls for this risk are available in the full register. Ask us. |
| Inconsistent Implementation | Discrepancies in the implementation of ESG initiatives across different departments or regions may result in uneven outcomes and diluted impact. | Controls for this risk are available in the full register. Ask us. |
| Insufficient Resources | Inadequate allocation of resources (financial, human, technological) could hinder the effective implementation and monitoring of ESG initiatives. | Controls for this risk are available in the full register. Ask us. |
| Lack of Alignment with Business Strategy | ESG initiatives that are not aligned with the overall business strategy may be seen as disconnected from the company's core mission and values. | Controls for this risk are available in the full register. Ask us. |
| Lack of Continuous Improvement | Failing to regularly review and improve ESG-related policies and practices could lead to stagnation and missed opportunities for innovation. | Controls for this risk are available in the full register. Ask us. |
| Lack of Stakeholder Engagement | Inadequate engagement with stakeholders (including investors, employees, communities, NGOs, etc.) might result in missing valuable insights and failing to address important concerns. | Controls for this risk are available in the full register. Ask us. |
| Regulatory and Compliance Changes | Evolving ESG regulations and compliance requirements may pose challenges in keeping policies up to date and avoiding legal or reputational issues. | Controls for this risk are available in the full register. Ask us. |
| Resistance to Change | Resistance from internal stakeholders who are not fully committed to ESG principles might impede the adoption of new policies and practices. | Controls for this risk are available in the full register. Ask us. |
| Short-Term Focus | Prioritizing short-term gains over long-term sustainability goals might lead to neglecting crucial ESG initiatives. | Controls for this risk are available in the full register. Ask us. |
Environmental Stewardship: key risks and controls
Responsible for monitoring and reducing the organization's environmental impact through energy efficiency, waste reduction, and resource conservation and implementing initiatives related to carbon emissions reduction, water conservation, and biodiversity preservation.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Competing Priorities | Other organizational goals and initiatives may take precedence, causing sustainability efforts to be deprioritized or inadequately funded. | Controls for this risk are available in the full register. Ask us. |
| Complexity of Initiatives | Large-scale initiatives related to carbon emissions reduction, water conservation, and biodiversity preservation may involve intricate planning and execution, leading to unforeseen challenges. | Controls for this risk are available in the full register. Ask us. |
| Data Accuracy and Reporting | Inaccurate data collection and reporting on energy usage, emissions, and resource consumption can undermine the effectiveness of sustainability initiatives and mislead stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Dependency on Key Personnel | If the individuals responsible for driving sustainability initiatives leave the organization, there might be a loss of expertise and momentum. | Controls for this risk are available in the full register. Ask us. |
| Employee Engagement | Employees may not fully understand or support sustainability initiatives, leading to resistance, lack of participation, or insufficient commitment. | Controls for this risk are available in the full register. Ask us. |
| Financial Constraints | Investing in sustainability initiatives may require upfront costs that strain the organization's financial resources, potentially impacting other strategic priorities. | Controls for this risk are available in the full register. Ask us. |
| Inadequate Training | Employees involved in executing sustainability measures may require training to ensure proper implementation and adherence to best practices. | Controls for this risk are available in the full register. Ask us. |
| Lack of Clear Metrics | Without well-defined metrics and goals, it's challenging to track progress and showcase the tangible benefits of sustainability efforts. | Controls for this risk are available in the full register. Ask us. |
| Measuring Impact | Accurately quantifying the impact of various initiatives on carbon emissions reduction, water conservation, and biodiversity preservation can be challenging and might result in unrealistic expectations. | Controls for this risk are available in the full register. Ask us. |
| Public Perception | A lack of visible progress or negative media attention on environmental efforts can damage the organization's reputation and affect customer loyalty. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Compliance | Changes in environmental regulations and policies could impact the organization's operations and initiatives. Non-compliance can lead to fines, legal actions, and reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Resistance to Change | Employees and management may resist changes required for environmental sustainability due to perceived disruptions or the need to adjust established routines. | Controls for this risk are available in the full register. Ask us. |
| Resource Availability and Cost | Fluctuations in energy, water, and raw material prices can impact the organization's ability to implement resource conservation initiatives effectively. | Controls for this risk are available in the full register. Ask us. |
| Stakeholder Engagement | Poor communication with internal and external stakeholders about sustainability efforts can lead to misunderstandings, resistance, and lack of support. | Controls for this risk are available in the full register. Ask us. |
| Supply Chain Complexity | Ensuring sustainability throughout the supply chain requires cooperation from suppliers and partners. Risks may arise if they do not share the same commitment to environmental goals. | Controls for this risk are available in the full register. Ask us. |
| Technology Obsolescence | Depending on the industry, new technologies and practices for environmental sustainability may emerge rapidly. Failing to stay updated could hinder progress and competitiveness. | Controls for this risk are available in the full register. Ask us. |
| Technology Risks | Adopting new technologies for energy efficiency or waste reduction can lead to technical glitches, operational disruptions, and data security concerns. | Controls for this risk are available in the full register. Ask us. |
| Unforeseen Environmental Events | Natural disasters or other environmental events beyond the organization's control could affect the implementation of sustainability initiatives. | Controls for this risk are available in the full register. Ask us. |
Governance and Ethics: key risks and controls
Responsible for ensuring strong corporate governance practices, including transparent decision-making and accountability, implementing and enforcing codes of conduct and ethical standards and managing risks related to legal, regulatory, and reputational issues.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Conflicts of Interest | Failure to identify and manage conflicts of interest among key decision-makers and employees can undermine decision-making transparency and lead to accusations of favoritism or bias. | Controls for this risk are available in the full register. Ask us. |
| Crisis Management Preparedness | Lack of preparation for potential crises, such as environmental disasters or scandals, can exacerbate their impact and damage the organization's reputation. | Controls for this risk are available in the full register. Ask us. |
| Cultural and Diversity Issues | Inadequate attention to promoting a diverse and inclusive corporate culture can lead to legal liabilities, reputational damage, and hindered innovation. | Controls for this risk are available in the full register. Ask us. |
| Cybersecurity and Data Privacy | Inadequate protection of sensitive data can lead to data breaches, legal actions, and reputational damage, undermining trust with customers and partners. | Controls for this risk are available in the full register. Ask us. |
| Employee Misconduct | Failure to address employee misconduct promptly and appropriately can harm morale, damage the company's reputation, and potentially result in legal actions. | Controls for this risk are available in the full register. Ask us. |
| Environmental and Social Responsibility | Neglecting environmental and social responsibilities can result in negative public perception and regulatory scrutiny. | Controls for this risk are available in the full register. Ask us. |
| Ethical Breaches | Failure to uphold codes of conduct and ethical standards can lead to loss of trust among stakeholders, damage to reputation, and potential legal consequences. | Controls for this risk are available in the full register. Ask us. |
| Failure to Address Stakeholder Concerns | Ignoring or dismissing stakeholder concerns, including those of shareholders, employees, and community members, can lead to reputational damage and loss of support. | Controls for this risk are available in the full register. Ask us. |
| Inadequate Board Oversight | Weak governance structures and insufficient board oversight can hinder effective decision-making, strategic planning, and risk management. | Controls for this risk are available in the full register. Ask us. |
| Inadequate Training and Communication | Insufficient training on ethical standards and governance practices, as well as poor communication of these expectations, can lead to unintentional breaches and misunderstandings. | Controls for this risk are available in the full register. Ask us. |
| Inconsistent Enforcement of Policies | Uneven implementation and enforcement of codes of conduct and policies can create perceptions of favoritism, erode trust, and lead to employee dissatisfaction. | Controls for this risk are available in the full register. Ask us. |
| Ineffective Decision-Making | Lack of transparency in decision-making processes can erode confidence in leadership, hinder effective decision-making, and create internal divisions. | Controls for this risk are available in the full register. Ask us. |
| Lack of Transparency | Insufficient disclosure of relevant information to stakeholders, including investors, can lead to suspicions of hidden agendas and hinder the company's ability to attract investment. | Controls for this risk are available in the full register. Ask us. |
| Leadership Succession Planning | Failing to plan for leadership transitions can disrupt operations, create uncertainty, and lead to a loss of direction. | Controls for this risk are available in the full register. Ask us. |
| Legal and Regulatory Changes | Failure to anticipate and adapt to changes in laws and regulations can result in non-compliance and legal liabilities. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Compliance Failure | Non-compliance with laws, regulations, and industry standards can lead to legal penalties, reputational damage, and operational disruptions. | Controls for this risk are available in the full register. Ask us. |
| Reputational Damage | Poor corporate governance or ethical lapses can result in negative publicity, loss of customer trust, and a decline in the company's market value. | Controls for this risk are available in the full register. Ask us. |
| Risk Management Oversight | Inadequate risk assessment and management can expose the organization to unexpected financial, operational, or reputational risks. | Controls for this risk are available in the full register. Ask us. |
| Supplier and Partner Relationships | Ignoring or downplaying risks associated with suppliers and business partners can result in reputational damage and disruptions in the supply chain. | Controls for this risk are available in the full register. Ask us. |
| Whistleblower Complaints | Inadequate mechanisms for employees or stakeholders to report unethical behavior or legal violations can lead to internal disputes, legal actions, and reputational harm. | Controls for this risk are available in the full register. Ask us. |
Innovation and Research: key risks and controls
Responsible for identifying new technologies and approaches that can improve the organization's ESG performance and conducting research to stay updated on emerging ESG trends and regulations.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Cybersecurity and Data Privacy Concerns | Exploring new technologies and approaches might involve handling sensitive ESG-related data, raising concerns about data breaches, cyberattacks, and privacy violations. | Controls for this risk are available in the full register. Ask us. |
| Greenwashing Accusations | If new technologies or approaches are not genuinely aligned with the organization's ESG goals, there's a risk of being accused of greenwashing, which can damage the organization's reputation. | Controls for this risk are available in the full register. Ask us. |
| Incomplete or Inaccurate Information | Relying on incomplete or inaccurate information about new technologies, trends, and regulations could lead to poor decision-making and ineffective implementation of ESG initiatives. | Controls for this risk are available in the full register. Ask us. |
| Intellectual Property and Patents | Adopting certain technologies might inadvertently infringe on intellectual property rights or patents, leading to legal issues. | Controls for this risk are available in the full register. Ask us. |
| Lack of Expertise | If the team lacks the necessary expertise in evaluating and adopting new technologies, there's a risk of making suboptimal choices. | Controls for this risk are available in the full register. Ask us. |
| Lack of Stakeholder Engagement | Failing to engage key stakeholders, both internal and external, in the evaluation and adoption of new technologies and approaches could lead to resistance and implementation challenges. | Controls for this risk are available in the full register. Ask us. |
| Long Implementation Timelines | Some new technologies and approaches might have long implementation timelines, which could delay the organization's ability to showcase improved ESG performance. | Controls for this risk are available in the full register. Ask us. |
| Market Volatility | Economic and market fluctuations could impact the feasibility and funding of new technologies and approaches, affecting their successful adoption. | Controls for this risk are available in the full register. Ask us. |
| Misalignment with Organizational Goals | Identifying technologies or trends that do not align with the organization's overall ESG goals and mission might result in wasted resources and efforts. | Controls for this risk are available in the full register. Ask us. |
| Rapidly Changing Landscape | The ESG landscape is constantly evolving, and trends and technologies can become outdated quickly. Failing to stay ahead of these changes might lead to missed opportunities. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Non-Compliance | Failing to keep up with evolving ESG regulations and compliance requirements could result in legal and reputational risks for the organization | Controls for this risk are available in the full register. Ask us. |
| Resistance to Change | Employees and stakeholders might resist adopting new technologies and approaches, leading to challenges in implementation and integration. | Controls for this risk are available in the full register. Ask us. |
| Resource Constraints | Pursuing new technologies and approaches might require substantial resources in terms of time, budget, and manpower. Inadequate resource allocation could hinder successful implementation. | Controls for this risk are available in the full register. Ask us. |
| Unproven or Ineffective Technologies | Adopting new technologies without proper testing or evidence of their effectiveness could lead to underwhelming results and resource wastage. | Controls for this risk are available in the full register. Ask us. |
| Vendor Reliability | Depending on external vendors for new technologies could expose the organization to risks related to the vendor's financial stability, support, and long-term viability. | Controls for this risk are available in the full register. Ask us. |
Investor Relations: key risks and controls
Responsible for engaging with investors and asset managers to communicate the organization's ESG initiatives and performance and responding to inquiries related to ESG practices and their potential impact on financial performance.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Communication Breakdown | Failure to effectively communicate the organization's ESG strategies, progress, and impact to investors and asset managers could lead to misunderstandings and reduced engagement. | Controls for this risk are available in the full register. Ask us. |
| Competitive Differentiation | If the organization's ESG initiatives are not sufficiently unique or competitive within its industry, it might struggle to attract socially responsible investors. | Controls for this risk are available in the full register. Ask us. |
| Complexity of ESG Metrics | ESG metrics are diverse and often complex, making it challenging to accurately interpret and communicate their impact on financial performance. Misinterpretation could lead to misinformed investment decisions. | Controls for this risk are available in the full register. Ask us. |
| Greenwashing and Credibility Risk | Misrepresenting or exaggerating ESG initiatives or performance could damage the organization's reputation and result in loss of credibility among investors, leading to potential legal and financial consequences. | Controls for this risk are available in the full register. Ask us. |
| Inaccurate Data Reporting | Providing incorrect or incomplete ESG data to investors can erode trust and harm the organization's reputation. Ensuring accurate data collection, reporting, and verification is crucial to maintaining transparency. | Controls for this risk are available in the full register. Ask us. |
| Investor Priorities Shift | Investor preferences and priorities around ESG issues can change rapidly. If the organization's ESG efforts are not adaptable, it might lose investor interest. | Controls for this risk are available in the full register. Ask us. |
| Lack of Alignment with Stakeholder Expectations | If the organization's ESG initiatives do not align with the expectations of investors, asset managers, and other stakeholders, it could lead to reduced investor interest and support. | Controls for this risk are available in the full register. Ask us. |
| Lack of Board and Executive Support | Without strong support from the board and executive leadership, ESG initiatives may not receive the necessary resources and attention to succeed. | Controls for this risk are available in the full register. Ask us. |
| Lack of Transparency | Failing to provide sufficient transparency regarding the organization's ESG practices may lead to suspicion and mistrust from investors and stakeholders, resulting in decreased investor confidence. | Controls for this risk are available in the full register. Ask us. |
| Market Volatility Impact | ESG-related concerns can impact market sentiment and lead to increased market volatility, potentially affecting the organization's stock price and investor sentiment. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Compliance Risk | Ignoring or misunderstanding ESG-related regulations and reporting requirements can result in legal penalties, regulatory investigations, and reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Reputation Risk | If the organization's ESG initiatives are not aligned with industry best practices or if negative incidents occur, its reputation could suffer, potentially leading to a decrease in investor interest and asset value. | Controls for this risk are available in the full register. Ask us. |
| Resource Allocation | Devoting significant resources to ESG initiatives might divert resources away from other critical areas of the organization, impacting overall performance. | Controls for this risk are available in the full register. Ask us. |
| Short-Term vs. Long-Term Focus | Balancing short-term financial performance with long-term ESG goals might be difficult, as ESG initiatives often yield benefits over a longer time frame. | Controls for this risk are available in the full register. Ask us. |
| Stakeholder Activism | Activist investors and stakeholder groups might scrutinize the organization's ESG practices and demand changes, which could create pressure to adapt and potentially disrupt operations. | Controls for this risk are available in the full register. Ask us. |
Reporting and Disclosure: key risks and controls
Responsible for compiling and disclosing relevant ESG information to stakeholders through various reporting frameworks (e.g., GRI, SASB, TCFD) and preparing sustainability reports and integrating ESG data into financial reporting.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Cultural Alignment | If ESG considerations are not ingrained in the company culture, it can lead to difficulties in data collection, reporting, and overall commitment to sustainability goals. | Controls for this risk are available in the full register. Ask us. |
| Data Accuracy and Reliability | Inaccurate or unreliable ESG data can lead to misinformed decisions, erode trust among stakeholders, and damage the company's reputation. | Controls for this risk are available in the full register. Ask us. |
| Data Security and Privacy | Handling ESG data requires safeguarding sensitive information to prevent data breaches, cyberattacks, and potential legal liabilities. | Controls for this risk are available in the full register. Ask us. |
| Emerging ESG Issues | Failing to identify and address emerging ESG risks can lead to negative surprises that affect stakeholder trust and business continuity. | Controls for this risk are available in the full register. Ask us. |
| Engagement with Stakeholders | Poor communication and engagement with stakeholders may lead to misunderstandings, lack of buy-in, and missed opportunities for feedback and improvement. | Controls for this risk are available in the full register. Ask us. |
| Greenwashing | Overstating or misrepresenting ESG efforts can result in reputational damage and legal liabilities if stakeholders perceive the company as insincere in its sustainability commitments. | Controls for this risk are available in the full register. Ask us. |
| Inconsistent Reporting Standards | The use of different reporting frameworks (GRI, SASB, TCFD) can result in inconsistencies and confusion in reporting, making it challenging for stakeholders to compare information across companies. | Controls for this risk are available in the full register. Ask us. |
| Integration with Financial Reporting | Poor integration of ESG data into financial reporting may lead to incomplete assessments of business performance, affecting investors' understanding of the company's value and long-term prospects. | Controls for this risk are available in the full register. Ask us. |
| Lack of Internal Coordination | Inadequate collaboration between departments responsible for ESG data collection, reporting, and financial analysis can result in incomplete or inconsistent information. | Controls for this risk are available in the full register. Ask us. |
| Market Perception and Investor Sentiment | Negative market perceptions related to a company's ESG performance can lead to lower stock prices, reduced access to capital, and increased cost of capital. | Controls for this risk are available in the full register. Ask us. |
| Materiality Assessment | Incorrectly identifying material ESG issues can lead to incomplete reporting, overlooking important risks, and potentially misallocating resources. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Compliance | Evolving ESG regulations and reporting requirements may lead to non-compliance risks, including financial penalties and reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Resource Allocation | Allocating insufficient resources to ESG reporting can result in incomplete or subpar reporting, negatively impacting stakeholder perceptions and compliance efforts. | Controls for this risk are available in the full register. Ask us. |
| Stakeholder Expectations | Failing to meet stakeholder expectations for transparency and responsible business practices can lead to reputational harm and strained relationships with investors, customers, employees, and other stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Supply Chain Risks | ESG risks can extend into the supply chain, impacting the company's reputation, operational stability, and relationships with suppliers. | Controls for this risk are available in the full register. Ask us. |
Risk Management: key risks and controls
Responsible for identifying and assessing ESG-related risks and opportunities that could impact the organization's long-term sustainability and developing strategies to mitigate and manage these risks.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Climate Change and Environmental | Physical risks from extreme weather events, such as floods, hurricanes, and wildfires, disrupting operations and supply chains. Transition risks associated with shifting to a low-carbon economy, including stranded assets and changes in market demand for certain products. | Controls for this risk are available in the full register. Ask us. |
| Community and Stakeholder Relations | Local community opposition to the organization's activities due to perceived negative social or environmental impacts. Inability to effectively engage with stakeholders and manage conflicting interests. | Controls for this risk are available in the full register. Ask us. |
| Crisis Preparedness and Response | Lack of preparedness for ESG-related crises, such as environmental accidents or social controversies. Ineffective response strategies leading to exacerbation of negative impacts. | Controls for this risk are available in the full register. Ask us. |
| Data Security and Privacy | Inadequate data protection measures leading to breaches of sensitive ESG-related information. Violation of privacy regulations impacting the organization's reputation and legal standing. | Controls for this risk are available in the full register. Ask us. |
| Financial | ESG-related financial risks, such as higher borrowing costs due to poor sustainability performance. Decreased shareholder value and investment due to poor ESG performance. | Controls for this risk are available in the full register. Ask us. |
| Lack of Integration and Accountability | Inadequate integration of ESG considerations into business decisions and strategies. Lack of clear accountability and oversight for ESG initiatives leading to ineffective risk management. | Controls for this risk are available in the full register. Ask us. |
| Long-Term Resilience | Failure to adapt to changing ESG trends and stakeholder expectations, leading to decreased long-term resilience and competitiveness. Inability to anticipate and address emerging ESG risks and opportunities. | Controls for this risk are available in the full register. Ask us. |
| Regulatory and Compliance | Changes in environmental regulations and laws that could impact the organization's operations and bottom line. Non-compliance with social and governance standards leading to legal actions, fines, or reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Reputation and Brand | Negative public perception due to perceived environmental or social irresponsibility, leading to customer boycotts and loss of market share. Exposure of unethical governance practices impacting trust and investor confidence. | Controls for this risk are available in the full register. Ask us. |
| Supply Chain and Vendor | ESG-related issues in the supply chain, such as child labor, poor working conditions, or environmental degradation, affecting the organization's reputation. Dependence on single or few suppliers vulnerable to ESG-related disruptions. | Controls for this risk are available in the full register. Ask us. |
| Talent Attraction and Retention | Failure to address social concerns like diversity and inclusion leading to difficulty in attracting and retaining skilled employees. Negative impact on workforce morale and productivity due to inadequate attention to employee well-being and development. | Controls for this risk are available in the full register. Ask us. |
| Technological and Innovation | Failure to adapt to emerging technologies and innovation that could improve ESG performance and efficiency. Being outpaced by competitors who integrate sustainable practices more effectively. | Controls for this risk are available in the full register. Ask us. |
Stakeholder Engagement: key risks and controls
Responsible for building relationships with stakeholders, including investors, customers, employees, communities, and regulatory bodies and responding to stakeholder concerns, inquiries, and feedback regarding ESG matters.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Changing Stakeholder Priorities | As stakeholder priorities evolve, there's a need to stay adaptive and responsive to their shifting expectations. | Controls for this risk are available in the full register. Ask us. |
| Community Backlash | If the organization's activities negatively impact local communities, there's a risk of public outcry, protests, or reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Competitive Landscape | Falling behind competitors in terms of ESG practices could result in market share loss and decreased competitiveness. | Controls for this risk are available in the full register. Ask us. |
| Complexity of ESG Issues | ESG matters can be complex and multifaceted, requiring a deep understanding of diverse issues and their interconnections. | Controls for this risk are available in the full register. Ask us. |
| Conflicting Stakeholder Priorities | Different stakeholders may have conflicting ESG priorities, making it challenging to address everyone's concerns simultaneously. | Controls for this risk are available in the full register. Ask us. |
| Crisis Preparedness | Organizations need to be prepared for potential ESG-related crises and have plans in place to manage them effectively. | Controls for this risk are available in the full register. Ask us. |
| Greenwashing Accusations | There's a risk of being accused of greenwashing – making false or exaggerated claims about ESG practices – if the organization's actions don't align with its stated commitments. | Controls for this risk are available in the full register. Ask us. |
| Inconsistent Reporting | Providing inaccurate or inconsistent ESG reporting can erode credibility and make stakeholders skeptical about the organization's commitment to sustainability. | Controls for this risk are available in the full register. Ask us. |
| Investor Discontent | Investors increasingly consider ESG performance when making decisions. Poor ESG performance could lead to divestment or decreased stock prices. | Controls for this risk are available in the full register. Ask us. |
| Lack of Employee Engagement | If employees perceive ESG efforts as insincere or ineffective, it can impact morale and overall productivity. | Controls for this risk are available in the full register. Ask us. |
| Lack of Transparency | Insufficient transparency in ESG efforts can lead to suspicion and distrust among stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Limited Metrics and Standards | Lack of universally accepted metrics and reporting standards can make it difficult to measure and compare ESG performance accurately. | Controls for this risk are available in the full register. Ask us. |
| Long-Term vs. Short-Term Trade-offs | Balancing short-term financial goals with long-term ESG objectives can be a challenge, potentially leading to tensions with investors. | Controls for this risk are available in the full register. Ask us. |
| Misalignment with Stakeholder Expectations | Failing to meet stakeholder expectations regarding ESG practices can lead to loss of trust and reputation damage. | Controls for this risk are available in the full register. Ask us. |
| Regulatory Non-Compliance | Not staying up-to-date with ESG regulations and failing to comply with them could result in legal and financial consequences. | Controls for this risk are available in the full register. Ask us. |
| Reputation Risk | Negative ESG incidents, such as environmental accidents or labor disputes, can harm the organization's reputation and brand value. | Controls for this risk are available in the full register. Ask us. |
| Resource Constraints | Adequate resources are required to implement effective ESG initiatives. Limited budget or support could hinder progress. | Controls for this risk are available in the full register. Ask us. |
| Supply Chain Risks | If the organization's suppliers and partners have poor ESG practices, it could reflect negatively on the organization itself. | Controls for this risk are available in the full register. Ask us. |
| Talent Attraction and Retention | Employees, especially millennials and Gen Z, increasingly prefer to work for companies with strong ESG values. Failing to meet these expectations could impact recruitment and retention. | Controls for this risk are available in the full register. Ask us. |
| Technological Disruption | Technological advancements can change the way businesses operate and impact their ESG strategies, requiring constant adaptation. | Controls for this risk are available in the full register. Ask us. |
Strategy Development and Implementation: key risks and controls
Responsible for developing and implementing ESG strategies aligned with the organization's mission and values and setting goals, targets, and key performance indicators (KPIs) for ESG initiatives.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Change Management Challenges | Implementing ESG initiatives may require significant organizational changes, and managing these changes effectively can be challenging, potentially leading to resistance and disruptions. |
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| Data Privacy and Security | Collecting and managing ESG-related data may expose the organization to data privacy and security risks, especially if proper safeguards are not in place. |
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| Employee Engagement and Culture | Lack of employee engagement or a misalignment of company culture with ESG values may result in resistance to change or a failure to integrate ESG practices into daily operations. |
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| Geopolitical and Economic Factors | Changes in geopolitical landscapes or economic conditions could influence the feasibility and impact of ESG strategies, potentially affecting resource availability and market demand. |
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| Inadequate Metrics and Data Quality | Poor data quality or inadequate metrics could lead to inaccurate reporting, hindering the organization's ability to measure progress towards ESG goals and effectively communicate results to stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Lack of Alignment with Business Strategy | ESG initiatives that are not aligned with the organization's overall business strategy may fail to create meaningful value and could be perceived as disconnected or irrelevant. |
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| Long-Term Financial Impact | While ESG initiatives are often seen as beneficial in the long term, there may be short-term financial costs associated with implementing changes that could impact the organization's financial performance. |
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| Market Perception and Investor Relations | Investors are increasingly considering ESG factors in their decisions. Poor ESG performance could lead to reduced investment interest or a negative impact on stock prices. |
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| Measurement and Reporting Complexity | Measuring and reporting on ESG performance can be complex due to the diversity of ESG metrics, frameworks, and standards. This complexity could result in inconsistencies or difficulties in comparing performance across different organizations. |
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| Regulatory and Compliance | Failure to comply with evolving ESG regulations and reporting requirements can result in legal and financial penalties, as well as reputational damage. | Controls for this risk are available in the full register. Ask us. |
| Reputation | The organization's reputation could be at risk if ESG initiatives are not effectively implemented or if there is a perception of "greenwashing" (misleading marketing of environmentally friendly practices). This could lead to a loss of trust from stakeholders. | Controls for this risk are available in the full register. Ask us. |
| Resource Allocation and Budgeting | Inadequate budget allocation and resource allocation could hamper the successful implementation of ESG initiatives, leading to underachievement of goals. |
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| Stakeholder Communication and Transparency | Insufficient transparency and communication about ESG initiatives could lead to misunderstandings, distrust, and negative stakeholder perceptions. |
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| Supply Chain and Vendor | ESG risks within the supply chain, such as issues related to labor practices, environmental impact, and social responsibility, could negatively impact the organization's overall ESG performance. |
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| Technological Challenges | Adopting new technologies to enhance ESG performance might face implementation challenges, integration issues, or resistance from employees. |
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Training and Education: key risks and controls
Responsible for providing training programs and educational materials to employees to raise awareness about ESG issues and the organization's commitment to sustainability.
| Risk | What can go wrong | Best-practice controls |
|---|---|---|
| Competing Priorities | Employees may perceive ESG training as an additional task on top of their existing responsibilities, leading to a lack of engagement or effort. |
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| Complexity of ESG Issues | ESG topics can be complex and interconnected, making it difficult to distill information into digestible training content that employees can easily understand. |
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| Difficulty in Behavioral Change | Raising awareness is only the first step; changing employee behavior to align with sustainable practices can be challenging and may require additional strategies beyond training. |
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| Employee Turnover | High employee turnover can result in a constant need for training and materials, requiring additional resources and efforts to maintain awareness across the workforce. |
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| Greenwashing Concerns | Overemphasis on positive aspects of sustainability without addressing actual organizational practices can lead to accusations of "greenwashing," damaging the organization's reputation. |
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| Inaccurate or Misleading Information | If training materials contain inaccurate or misleading information about ESG topics, employees might develop a skewed understanding of sustainability practices. |
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| Inadequate Content Quality | Poorly designed or outdated training materials could fail to effectively communicate the importance of ESG issues, resulting in reduced employee engagement and understanding. |
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| Insufficient Measurement and Evaluation | Without proper metrics to assess the impact of training programs, it becomes challenging to determine if employees' understanding and behavior regarding ESG issues have actually improved. |
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| Lack of Continuous Learning | Sustainability is an evolving field, and without ongoing updates to training content, employees might not stay up-to-date with the latest ESG trends and practices. |
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| Lack of Engagement | Employees might not actively participate or engage in the training programs, undermining the effectiveness of efforts to raise awareness about ESG issues. |
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| Lack of Senior Management Support | If senior management does not actively promote and support ESG initiatives, employees might not take the training seriously, considering it as a superficial effort. |
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| Language and Cultural Barriers | In global organizations, language barriers and cultural differences could hinder the effectiveness of training materials in conveying ESG concepts across diverse employee populations. |
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| Limited Accessibility | If training materials are not easily accessible or available to all employees, certain segments of the workforce might miss out on important information related to ESG issues. |
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| Misalignment with Company Strategy | Training programs and materials might not accurately reflect the organization's ESG goals and strategies, leading to confusion among employees about the company's sustainability objectives. |
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| Resistance to Change | Some employees might resist adopting sustainable practices due to a lack of understanding or personal beliefs, impeding the organization's progress toward sustainability goals. |
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This register is a starting point for risk identification and benchmarking against international practice. Adapt the risks and controls to your institution's size, products, jurisdiction and regulatory requirements.
Get the Environmental, Social and Governance register as an RCSA workbook
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Frequently asked questions
What are the key risks in Environmental, Social and Governance?
The main risk areas covered are Collaboration and Partnerships, Continuous Improvement, Environmental Stewardship, Governance and Ethics, Innovation and Research, Investor Relations, Reporting and Disclosure, Risk Management. Each unit lists its key risks with a short explanation and the best-practice controls that mitigate them.
How do I use this register for a risk and control self-assessment?
Select the risks that apply to your units, map the listed controls to the controls you actually operate, rate inherent risk and control effectiveness, then agree actions for gaps. The free RCSA workbook on this page has the columns ready.
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Social Responsibility: key risks and controls
Responsible for managing social impact by promoting diversity, equity, and inclusion within the workforce and across the supply chain, overseeing community engagement and philanthropic efforts and ensuring fair labor practices, human rights, and ethical sourcing in the supply chain.