If you search the internet for ESG (Environment, Social, and Governance) and responsible and sustainable investing, you’ll find there is a vast amount of information about it. And with so much information it can be quite difficult to distil. When it comes to putting a project together around a broad-ranging and fast-moving subject such as this, it can be tricky.

From a project management perspective, let’s look at some of the challenges you may encounter at the early stages of the project:

• New and enhanced regulation is constantly emerging – in addition to the existing ESG regulation that has come into force, there is regulation that will become effective this year or next year, and some regulation still in the white paper stage. Understanding what is relevant and what you need to address now can be a minefield and will need your compliance team to work closely with the investment team to agree what is relevant for your business now (and needs addressing now) and what will need to be accounted for in the future
• Service providers are developing new ESG-related data modules – this is making available a plethora of factors, scores, indices, and benchmarks that you can use for internal and external ESG reporting. But determining which, if any, are most appropriate to the business needs is a complex matter and needs some dedicated focus with plenty of lead time
• Software developments bringing new and enhanced packages – new and existing system suppliers are introducing additional software functions and capability to monitor, model, and report ESG data. Similar to the point above, it is difficult to know exactly what is needed both internally and externally so perhaps don’t go for nirvana at the outset, rather start with the basics and build on that over time
• IT Architects need to ensure the solutions are sustainable – the proposed business strategy and processes for ESG must not be built on rocky foundations, i.e. the underlying systems will need to support future developments. You should consider the end-to-end process, and build any necessary time and budget into the plan to accommodate, for example, new data linkages and system enhancements
• Quantity and quality of data – there are many competing data providers in the market which can make selection difficult, particularly when you consider the cost and in-house ability to understand the data, understand how scores are determined, and ultimately what the data is telling you

What does this mean from a project perspective?

• Difficulty in defining and finalising requirements
• Difficulty in setting milestones
• Hard to contain the scope of the project, output, and deliverables
• There is a need for dedicated senior engagement & decision making
• The initiatives will suck up business stakeholder resource and project resources

How do you overcome some of the uncertainty?

My overriding approach would be to say ‘be brave’. By that I mean not to aim for all singing, all dancing solutions at the outset, but that you draw a line under what you know and have today and work from that. In due course, once you have formalised the approach and embedded the minimum standards, then you can start looking at future enhancements.

If you consider ESG from a programme perspective, it makes it easier to break initiatives down into manageable chunks. Develop individual workstreams and run things in sequence as far as possible. Don’t try and do everything at once; have a delivery roadmap. And don’t be surprised if you have 5 or 6 significant projects or workstreams within the programme.

Here are a few questions to consider with the project team to help structure the programme of works:

• What is it that the business needs to do as an absolute minimum to cover its activities e.g. from a TCFD or SFDS perspective?
• What are the strategic targets the business aims to achieve e.g. PRI membership or Stewardship Code membership? If the business is going down this route, then a gap analysis is a good place to start
• What are the internal policies, are they all written down and clearly defined e.g. for Voting and Engagements?
• Do you have any areas where you have limited existing material or current policies are not as extensive as they are required to be? A lot of material may naturally focus on an equity perspective, however, it is important to demonstrate, as much as is practical, that you take ESG into account for all asset classes
• What are the internal processes & practices, and are they all written down, clearly defined, and understood? Is everybody following them?
• Do you understand and monitor your third-party service providers ESG practices? If not, what steps do you need to take to ensure you are provided with the relevant information and reports?
• Are you able to demonstrate, through case studies and examples, how ESG principles have been put into practice?
• Have you got all the necessary evidence for the reporting periods required? Is this presentable? Or do you need to build new monitoring and reporting capability (for both internal and external consumption)?
• What is the business doing internally at an entity level, e.g. what actions are staff personally taking such as reducing their carbon footprints or using sustainable energy suppliers?

If you consider the challenges and have answers to these types of questions, that should allow you to start formulating a Terms of Reference from which the high-level plan can be defined.

One final message – There will undoubtedly be amendments as the project works through the finer detail (which should be through formal Change Control) and you should account for that in your planning.