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3 Steps For Completing An ESG Gap Assessment – Above the Law

Business
has
changed.
The
bar
is
getting
higher.
Regulators,
investors,
and
clients
demand
that
corporations
provide
transparent
environmental,
social,
and
governance
(ESG)
disclosures.
ESG
missteps
can
result
in
loss
of
business,
loss
of
investment
dollars,
greenwashing
allegations,
and
brand
damage.
And
the
stakes
are
getting
higher
as
new
regulations
come
into
effect.

In-house
legal
teams
are
increasingly
finding
themselves
in
the
crosshairs
of
ESG
challenges,
opportunities,
and
risks.
Often
they
are
told
something
like
“Put
an
ESG
plan
in
place.”

If
you
are
on
the
receiving
end
of
this
vague
direction,
it
will
be
hard
to
get
started.
What
does
that
even
mean?

I
take
a
practical
approach
to
ESG.
I
like
to
break
things
down
into
clear
and
actionable
steps.
It’s
a
big
part
of
why
I
was
able
to
roll
out
an
ESG
program
at
my
last
company
from
scratch.

Here
is
the
secret
to
getting
started.
You
must
assess
your
ESG
gap.
This
assessment
will
be
the
cornerstone
of
your
business
case
and
your
action
plan.

You
can
complete
an
ESG
gap
assessment
in
three
steps.


Step
1:
Create
A
Master
List
Of
ESG
Actions 

Your
company
is
probably
being
asked
to
do
a
lot
of
things
on
ESG.
You
need
to
identify
and
organize
those
asks.
Create
a
master
list
starting
with
these
sources:

  • Requests
    for
    ESG
    data
    that
    you
    have
    received
    from
    clients
  • Requests
    for
    ESG
    data
    that
    you
    have
    received
    from
    investors
  • Commitments
    you
    have
    made
    in
    contracts
  • Items
    that
    you
    need
    for
    third-party
    ESG
    assessments
    (like
    Ecovadis)
  • Requirements
    from
    any
    new
    or
    upcoming
    regulations

Check
your
list
against
the
items
in
this
article
on

8
Elements
Every
ESG
Program
Must
Have
.

As
you
create
this
list,
keep
track
of
where
the
requests
came
from
and
note
overlaps.
Use
this
information
to
prioritize
later.


Step
2:
Inventory
Your
Current
Practices
Using
The
Master
List

Once
you
have
your
master
list,
reach
out
to
the
relevant
departments
across
your
organization
to
collect
information
related
to
each
item.
For
example,
you
may
need
to:

  • Ask
    your
    human
    resources
    department
    for
    information
    related
    to
    labor
    and
    employment
    and
    health
    and
    safety
  • Check
    legal
    and
    compliance
    records
    to
    determine
    if
    your
    governance
    policies
    are
    complete
  • Look
    at
    how
    your
    operations
    team
    manages
    suppliers
  • Review
    (and
    verify)
    what
    is
    on
    your
    website

You
will
probably
discover
that
you
have
more
pieces
of
an
ESG
program
than
you
thought.
Often
ESG
efforts
are
siloed
and
not
well
known
across
the
company.
You
can
use
this
as
an
opportunity
to
assemble
the
relevant
information
to
respond
to
future
questionnaires.


Step
3:
Prioritize
Potential
ESG
Actions

At
this
stage,
you
will
know
your
gaps.
You
will
probably
have
a
lot
of
them.
Great.
So
what
do
you
do
with
that
information?

Organize
ESG
actions
into
four
categories:

  • Completed
    (Well
    done!!!)
  • Quick
    wins
  • Strategic
    considerations
  • Items
    for
    the
    future

Quick
wins
are
easy
items
you
can
complete
to
make
your
stakeholders
happy
and
items
that
you
must
complete
to
be
a
responsible
business.
These
could
include
things
like
filling
gaps
in
your
ethics
and
labor
policies
and
documenting
existing
responsibilities
for
ESG.

Strategic
considerations
are
items
that
depend
on
the
strategy
developed
by
your
executive
team.
For
example,
you
will
likely
need
an
executive
decision
on
your
approach
to
climate
and
DEI.

Items
for
the
future
are
things
you
are
being
asked
for
that
aren’t
relevant
to
your
business
today. 
If
your
current
business
does
not
touch
on
an
ESG
item,
put
it
on
a
watch
list
and
focus
on
what
you
can
impact
now.

Completing
an
ESG
gap
assessment
will
enable
you
to
shift
from
a
high-level
goal
(put
an
ESG
plan
in
place)
to
a
specific
list
of
actions
that
you
need
to
take
and
decisions
that
need
to
be
made.
It
will
also
help
you
say
“No”
to
external
requests
that
don’t
fit
in
with
the
broader
picture.

Curious
what
to
do
next?
Check
out
my

12-Month
ESG
Roadmap
For
In-House
Counsel
.
The
roadmap
provides
a
guide
you
can
use
to
go
from
ESG
assessment
to
reporting
in
a
year.




Christine
Uri
is
a
Top
100
Voice
in
Sustainability.
She
advises
general
counsel
on
the
development
and
implementation of
environmental,
social,
and
governance
(ESG)
programs.
As
a
former
Chief
Legal
Officer
and
Chief
Sustainability
Officer
for
a
global
sustainability
company,
Christine
knows
what
it
takes
to
move
ESG
to
the
top
of
the
corporate
agenda.
Christine
believes
that
improving
corporate
performance
on
ESG
measures
is
critical
to
building
a
more
sustainable
world.
She
is
passionate
about
inspiring
and
empowering
in-house
legal
teams
to
provide
ESG
leadership. You
can
follow
Christine
on 
LinkedIn.