An International Study of Sustainability Reporting


In the last decade, a general surge in the financial sustainability reporting instruments has been experienced as economies and financial sectors experience paradigm shift from the traditional to the modern and dynamic financial management systems. Through a mixed methodology, the findings revealed that the number of reporting instruments has increased hundred folds from about 120 in 2012 to almost 400 in the year 2017 in the case study economies. Specifically, the growth in the reporting instruments has been steady in United State of America, United Kingdom, China, and parts of European countries. Specifically, most of the reporting instruments are part of government regulatory policies in the financial sectors. In all the case study countries, the findings revealed that mandatory financial reporting instruments were dominant with the voluntary instruments growing stronger in the last few years in the ratio of 1:3. Moreover, the results indicated that in every ten instruments, there is a reporting instrument that is angled on compliance. Interestingly, the financial market and stock exchange regulators in the case study regions accounted for a third of the sustainability instruments. Specifically, a third of all the financial reporting instruments applied to large publicly listed financial companies while the rest applied to other types of firms, such as those owned by the state. In particular, the findings also revealed that reporting instruments targeting specific sectors were dominant in the heavy industry and financial sectors. Across the period of review, the financial reporting instruments in the finance sector accounted for 40% of all instruments. Comparatively, there was a general rise in the instruments that are aimed at social information reporting from 50 in 2012 to almost 140 in 2017. The current regulations on disclosure of taxes have pressured companies to demonstrate fair payment of taxes in the economies they operate in.



This part of the research report discusses the research background, statement of the research problem, underlying question to be answered, objectives, and the hypothesis. This section examines the rationale, significance, and limitation of the research. In addition, the section puts into perspective the research background to relate the primary research theme to the objectives and question to be answered. This section concludes by highlighting the significance and potential limitations of the research into the perspectives of the expected findings. Specifically, the part of the study develops the foundation upon which the arguments and rationalization shall be established.

Research Background

Critical analysis and evaluation of sustainability reports of financial services have become an instrumental aspect of local and global accounting principles (European Commission 2014). Specifically, many organizations and economies across the global business arena have put in place policies and instruments to ensure that there is growth and rapid evaluation of different sustainability reporting instruments as part of their competitive advantage (Herbohn, Walker & Loo 2014). At present, different regions have unique and proactively tailored sustainability reporting instruments that are created to standardize their accounting principles in line with the global acceptable values (Eisenbeis, Frame & Wall 2007). Despite these developments, there are problems encountered in the development of financial services and the relationship with the global economy. In relation to this proposed research, the scope of establishing different sustainability reporting instruments will include the United State of America, United Kingdom, China, and parts of European countries.

Over the last decade, the number of sustainability reporting instruments has grown hundredfold. These instruments are engineered to encourage proactive reporting of financial information (Eisenbeis, Frame & Wall 2007). As a matter of fact, at present, most of the big economies have made the instruments a mandatory financial policy. As noted by Perez (2015), in the 2014 financial reporting instruments, the findings revealed that all the case study regions have active mandatory and voluntary policies, especially targeting the financial and taxation sectors. This is an apparent trend of an increase in the acceptance of these instruments in guaranteeing sustainability (Herbohn, Walker & Loo 2014). The upward surge in the adaptation of these instruments can be attributed to the complexity and modernization of the financial markets, which expect firms to continuously and consistently report information related to their non-financial and financial performance (Herbohn, Walker & Loo 2014). The primary drivers of the surging growth in assimilation of the reporting instruments in the case study economies include growth in regulatory policies, acceptance of the explain and compliance reporting modules, and increasing regulatory activities in the financial and stock exchange markets.

The aspect of sustainability disclosure has become a basic accounting principle for different economic blocs across the globe (Knights & Mccabe 1996). Specifically, a sustainability report of financial services defines the scope of instruments used in reporting, whether voluntary or mandatory in different regions across the globe (Black Sun Plc 2014). In the recent years, a lot of research has been carried out on the instrumentation of voluntary and involuntary reporting instruments in different regions in conformity with the twenty first accounting principles (Cheng, Loannou & Serafeim 2011). In the last five years, there has been a surge in the growth of sustainability reporting instruments in different economies. There were 400 reporting instruments identified in the year 2016 in 64 countries as opposed to 180 instruments in the year 2012 (Corporate Register 2016). This trend indicates that modernizing economies are becoming more complex and require businesses to proactively report financial and non-financial performance information (Dhaliwal et al. 2013). The drivers of the trend are attributed to growth in accounting regulatory principles in the United State of America, United Kingdom, China, and parts of European countries. For instance, explaining or comply reporting approaches adopted within Europe has ensured that many economies in this region are ahead in sustainability reporting instruments (Dhaliwal et al. 2013).

As indicated in the 2013 KPMG report, the regulations within the United State of America, United Kingdom, China, and parts of European countries have improved on sustainability reporting (KPMG 2013). Specifically, the voluntary and involuntary regulations have made the sustainability reporting instruments self-sustaining and effective in capturing the financial environment in these economies. At present, the regulations in the US and the EU regions have been very effective in promoting compliance and healthy financial practices in the firms and sectors operating within these locations. For instance, in the US, the government is very proactive through its regulatory bodies in rolling out different financial sustainability regulation instruments that operate at the micro and macro level of the economy (Cheng, Loannou & Serafeim 2011). The US-based regulatory model has ensured uniformity in financial and taxation sectors for healthy business activities (Herbohn, Walker & Loo 2014). Therefore, this research paper attempts to establish the sustainability reporting of financial services in different regions that have developed regulations on reporting instruments. Specifically, the research will attempt to carry out comparative analysis of the sustainability of the reporting instruments within the United State of America, United Kingdom, China, and parts of European countries. This will be necessary in identifying potential problems encountered in the development of financial services and the relationship with the global economy.

Research Problem Statement

Financial performance sustainability reporting has become a major instrument for measuring compliance and healthy financial practices in different sectors and economies across the globe. Over the last decade, the sustainability instruments have grown tenfold in the third world economies and hundredfold in the developed economies. Depending on the region of application, the sustainability regulatory policies are modelled around accuracy and predictability in financial reporting (Cheng, Loannou & Serafeim 2011). Despite the progress in the development and application of different sustainability instruments, it is healthy to establish the number of sustainability reporting instruments in the case study economies and their relevance in application. Moreover, as part of their applicability and relevance, there is need to establish the difference between voluntary and mandatory reputing instruments in terms of their magnitude. It is also important to examine the nature of organizations that issue the highest number of reporting instruments (Herbohn, Walker & Loo 2014). The organizations considered are stock exchange, industry regulators, financial regulators, government agencies, and others. Specifically, it is important to establish if the instruments cover specific or all organization types and if they require a specific format for reporting. Lastly, the research will establish if the reporting instruments are focused on specific social and environmental factors. Therefore, the proposed research study aims at carrying out a comprehensive comparative analysis around the above factors to identify the financial reporting sustainability instruments within the case study economies and their relevance in application. This is necessary to pinpoint specific and potential problems in the modelling of the global financial frameworks as related to the economies of the case study countries.

Research Aims and Objectives

The primary aim of the proposed research is to analyse and evaluate sustainability reports of financial services in different economic regions across the globe to establish a comparative performance as part of the global accounting systems. Specifically, the case study economies will include China, the U.K, the U.S and part of European countries reports. This means that the findings of the proposed research project would be instrumental in exploring the potential challenges that regulatory agencies and accounting policy creators face in creating financial services within the global business arena (Herbohn, Walker & Loo 2014). Moreover, the findings will display the impact of the voluntary and mandatory instruments in their application in the financial reporting. Specifically, the results will display how the impacts of different regulatory agencies create reporting instruments that are applicable in public and private firms. For instance, the findings may reveal the most predominant reporting instrument and how its application varies from one economy to another. From the primary objective, several sub-objectives were derived to facilitate a comprehensive coverage of the research aim as summarized below.

  1. To establish the sustainability, nature, and application of the reporting instruments applied in the case study economies and the relevant instruments in play.
  2. To establish similarities and dissimilarities in the sustainability reporting instruments formats for financial services across the case study economies.
  3. To quantify the reporting instruments and potential challenges in developing services based on different reporting regimes applied in the case study economies from social and environmental perspectives.

Research Questions

Based on the research objective and sub-objectives, the researcher generated research questions that can answer each sub-objective. The researcher was keen to cover all the sub-objectives to ensure that the results can match the aims of the study. From the above research aim and objectives, the following research questions were created to explore the research topic.

  1. What reporting instruments are applied in the case study economies?
  2. Are the reporting instruments applied in these economies voluntary or mandatory?
  3. How do the financial services banking sectors of these economies apply different sustainability approaches in financial reporting?
  4. Are the reporting instruments broad and similar or dissimilar across the different economies?
  5. Do the sustainability reporting instruments have similar or dissimilar formats for financial services?
  6. How many financial reporting instruments applicable in these economies focus on social and environmental factors?

Research Rationale

There are series of values and potential reasons for the proposed research in establishing potential challenges in financial services reporting and application at the global business arena. The proposed research will be critical in giving a lucid assessment of the sustainability reporting instruments that are applied in different regions in terms of their legislation, application, and challenges at local and global levels. The research will attempt to address the potential challenges in sustainability reporting instruments for financial services as they are key principle of proper accounting standards for present and future organizational performance. Thus, the proposed quant research study will reveal the effectiveness of different sustainability financial reporting instruments in terms of their legislation and application in creating a standard accounting system in different regions across the globe (Herbohn, Walker & Loo 2014). Specifically, the interest of the proposed research in reporting instruments in the United State of America, United Kingdom, China, and parts of European countries ensures that the findings capture the general practices in the American, Asian, and European continents. Besides, the is a need to enumerate the current challenges that policy developers have to deal with in creating competitive sustainable reporting instruments for different financial services to create standardized global accounting principles. Thus, through quantitative research approach, this research proposal will attempt to reveal significant trends in sustainability reports of financial services in the United State of America, United Kingdom, China, and parts of European countries.

Research Limitations and Delimitations

Several limitations will be faced in the course of the research study since it is very dynamic and complex. To begin with, the secondary data collection and research will consume time since little research has been carried out before on the same topic (Cooper 2014). Besides, access to any information would require placing special request and waiting for responses (Paul 2013). This means that actual data collection might take up to three weeks, especially considering the discrete nature of the China information policy. To address this limitation, the researcher will ensure that enough time is allocated for data collection besides prior planning for each and every day of information access (Mason 2015). Moreover, the researcher will consult online sources from reputable organizations such as Yahoo Finance and KPMG among others (Tullis 2014).

Limited compatibility between the researcher and the scope of the research might create a deceptive narrative, especially when personal biases are not minimized. For instance, the researcher might be influenced by prejudice on certain markets or economies to falsify information gathered or present incomplete data as the actual result (Miller et al. 2013). This will seriously jeopardize the seriousness of the actual findings. Since the success of the proposed research would depend on interpretation and the collected data, lack of data analysis skills or use of the wrong tool would compromise the integrity of the entire project. To address this limitation, the researcher will ensure that clear research ethics procedures are adhered to in sourcing for information (Monks & Minow 2014). Specifically, the researcher will attend training on confidentiality management when gathering data. Besides, the data gathered will be properly coded and stored in the right medium to avoid potential interference (Paul 2013). Moreover, the instruments are very many and the research will depend on assumptions that the categorization as voluntary and mandatory is adequate in answering the research question (Cooper 2014). In addition, since these instruments exist in different economies with different financial regulatory standards, the findings would not be as accurate if the research was concentrated on a single economy.


In summary, the first chapter of the study has presented a comprehensive research background, rationale, objectives, justification, and research question. These concepts were developed based on the dynamics within the financial reporting instruments within the case study economies. These concepts will be instrumental in guiding the literature review and methodology in establishing the relationship between different reporting instruments and their application within the case study economies.

Literature Review


This chapter reviews different concepts in sustainability reporting with reference to different instruments in place. Specifically, this section of the report examines the nature of each category of the reporting instruments, their application, implications, and relevance to the current financial health within the case study economies. The literature review comprises of the theoretical and empirical information existing on the topic of financial sustainability reporting instrumentation. At the end of this section, the researcher will carry out a comparative analysis between the information gathered and the findings to establish the current position of the research phenomenon.

Sustainability Reporting Background

Several definitions have been put forward to explain the meaning of sustainability reporting within the triple bottom line (Paul 2013). Generally, these definitions share similar content in terms of coverage of the economic, environmental, and social pillars of sustainability. According to Tullis (2014), sustainability reporting refers to the process of production of financial reports by organizations to cover their triple bottom activities surrounding the economic, environmental, and social performance as indicators for measuring success. On the other hand the Global Reporting Initiative (GRI) defines sustainability reporting as a bulletin published by an organization to capture the environmental, social, and economic impacts of its daily activities (GRI, 2016). This means that sustainability reports empower organizations to proactively present their governance and value models besides demonstrating the active link between its business strategies and underlying endeavours towards a sustainable economy. Across the globe, sustainability reporting has become a key pillar in the information gathering and presentation to the stakeholders on the financial and non-financial matters (Perez 2015). The information contained in such reports is channelled through an annual corporate bulletin and website.

According to Perez (2015), sustainability reporting has experienced a paradigm shift from a simple format to a complex and multifaceted system that shows the existing interrelationships between the three pillars of environmental, social, and economic factors. Through this correlation, accurate sustainability reporting has empowered organizations across the globe to effectively measure, communicate, and understand the impact of corporate governance on the performance of a firm through managing the set goals and general efficiency (GRI 2016). This means that the competency of a firm to report its sustainability processes and initiative is a primary building block towards improving the satisfaction and trust levels among the stakeholders for a proactive corporate reputation (Perez 2016).

At present, sustainability reporting remains a voluntary activity that is governed by policies designed by government and private regulatory agencies (Mason 2015). However, most global organizations have made it a duty to annually report their sustainability contributions and policies within the mandatory regulation frameworks. In the last ten years, Burlea & Popa (2013) note that there has been a surge in the number of organizations who voluntarily report on their sustainability initiatives. Interestingly, the study by KPMG in the year 2013 on the number of organizations carrying out voluntary reporting revealed that more than 250 organizations present annual reports on corporate responsibility (KPMG 2013). The report further noted that voluntary sustainability reporting has become very popular with “at least 62% of companies in every sector producing these reports” (KPMG 2013, p. 27).

Corporate financial reporting across the globe is controlled by specific accounting standards that tend to vary from one region to another, depending on the financial market regime in place. These standards are based on guidelines and rules created by the regulatory authority at government and organizational levels. For instance, in the US, the Generally Accepted Accounting Principle (GAAP) is the acceptable accounting standard that all public and private companies must adhere to when carrying out sustainability reporting (Mason 2015). Specifically, the Securities and Exchange Commission (SEC) is mandated with the duty of issuing the guidelines to companies in association with the Financial Accounting Standards Board (FASB), the American Society for Testing and Materials (ASTM), and the American Institute of Certified Public Accountants (AICPA) (Tullis 2014). Although different countries have different names for the regulatory authorities, their mandate and scope of operation is more or less the same.

Factors Propelling the Rise in Sustainability Reporting

Since most the sustainability reporting initiatives are voluntary, it is important to examine the value of such reports on organizational performance. Specifically, it is to review the motivation elements behind the surge. According to Perez (2015), the need to protect and maintain organizational reputation is an instrumental driver for sustainability reporting since it “not only highlights the perceptual nature of corporate reputation but also the relevance of information to the stakeholders and transparency that are central to the study of the relationship between CSR reporting and corporate reputation” (Perez 2015, p. 15). Another factor propelling the popularity of sustainability reporting is attributed to gain in the optimal benefits of engaging in healthy business practices, especially on the side of the stakeholders and shareholders (Mason 2015).

Previous studies on the impetus for sustainability reporting reveal very interesting findings. For instance, Perez (2015), Mason (2015), Cheng, Loannou, & Serafeim (2014), and Harrison & Wicks (2013) established that organizations attempt to illustrate proactive responsibility and construct an appropriate image to the stakeholders to improve on their understanding of the values driving change. Specifically, Harrison & Wicks (2013) noted that sustainability reporting is inspired by the desire to actively respond to direct public pressure on an organization. On the other hand, Mason (2015) established that the need to enhance the existing corporate legitimacy as a prerequisite for creating a niche inspires organizations to produce sustainability reports. According to Cheng, Loannou, & Serafeim (2014), the desire to develop a strong corporate credibility platform is responsible for most voluntary sustainability reports. Perez (2015) opined that stakeholder communication and direct engagement is responsible for the reports. Specifically, proactive communication about sustainability initiatives to the stakeholders will guarantee endorsement of the report (Perez 2015). The change in strategy is a complete shift from past practice when most annual reports were motivated by the desire to show profitability. At present, publishing of the annual sustainability report has become as important as profitability bulletin in maintaining the general corporate reputation (Herbohn, Walker & Loo 2014). Thus, effective communication through the CSR reporting module is laden with benefits such as increased financial performance, improved stakeholder confidence, and general acceptance of the business by customers.

Standards, Principles, and Guidelines for Sustainability Reporting

There are more than a thousand guidelines for sustainability reporting. The most common is the GRI besides climate change, product specific, and sector specific. Examples of the climate change, product specific, and sector specific guidelines are the Carbon Disclosure Project (CDP), Forest Stewardship Council (FSC), and CEA, respectively (Herbohn, Walker & Loo 2014). In addition, the International Organization for Standardization (ISO) has become very popular in the recent past due to the integrity and general acceptance of its certification process. For the case of this research study, the GRI benchmark will be applied since “it is the preferred international framework for reporting on the triple bottom line…of sustainable development, economic, social and environmental performance” (Tullis 2014, p. 5). Moreover, the GRI cuts across all sectors, unlike the other frameworks, which are specific to a single sector and does not report all the three pillars of economic, environmental, and social aspects of sustainability (Herbohn, Walker & Loo 2014). However, since the report covers sustainability practices that are specific to different sectors, the guidelines in the case study countries will be integrated into the GRI framework.

GRI Reporting Framework

All the case study countries use the GRI sustainability reporting framework besides more than a hundred other economies. It is currently the most popular reporting framework in the world. The GRI enables organizations, governments, and firms to understand and effectively communicate different sustainability issues (Burlea & Popa 2013). Moreover, the GRI is known to integrate other frameworks, such as the independent costing, multi-stakeholder input, and government references to accomplish the primary reporting objectives.

GRI Reporting and Effective Communication

Organizations within the case study countries have increasingly recognised the opportunities and risks linked to the direct corporate responsibility reports. Thus, most large firms have opted for substantial investment in their sustainability reporting systems as a prerequisite for positive corporate responsibility and behaviour image to the various stakeholder groups (Herbohn, Walker & Loo 2014). The entire framework is motivated by the desire to strategically and effectively pass information on organizational activities that can derive optimal benefits, irrespective of the business environment. The significance of efficient communication is explained by Harrison & Wicks (2013) that “even companies that seriously engage in CESR could be perceived cynically by stakeholders. After all, most stakeholders cannot directly witness a corporation’s CSR policies or initiatives and to a great extent must rely on the corporation’s reporting” (p. 661). Perez (2015) reaffirms this statement by noting that a reputation of a company is based on involvement and actions on sustainable initiatives in addition to effective communication. In a 2014 study conducted by the European Commission (2014), on the what makes sustainability reporting effective, the findings revealed that the performance of such reports depends on the leadership practices and effective communication initiatives. The report further explains that stakeholder perception and performance are important elements of sustainability strategies (European Commission 2014). Another research conducted by Knights & Mccabe (1996) established that transparent and effective communication framework is a primary ingredient for good CSR practices that can appeal to the external and internal stakeholders. In practice, the process is critical in coining the current and potential concerns that should be tackled to avoid an overspill in the business practices.

Imminent Challenges of Sustainability Reporting

Several challenges can be related to sustainability reporting, which explains why some corporations may be hesitant to adopt such framework. According to Stubbs, Higgins & Milne (2013), the primary shortcomings of sustainability reporting include minimal stakeholder participation, high cost implication, and conflicting reporting guidelines. Perez (2015) identified inconsistencies in the metric boundaries, expected conflict of interest, interference by third parties, and limited commitment to the ideals of sustainable reporting. Even organizations that produce annual sustainability reports experience a challenge of the most effective way of identification and analysis of the issues to be included in such bulletin (Herbohn, Walker & Loo 2014). The success of a sustainability report depends on the “management to establish an approach to identify what contextual priorities should be chosen in each reporting period and how to define and communicate its understanding of corporate sustainability” (Perez 2015, p. 18). This means that limited capacity in the operational communication strategy would lead to poor measurement and actual communication of the initiatives. To tackle this challenge, it is imperative for such organizations to backup their sustainability reporting with a well organized, systematic, and proactive accounting regulation system that can provide a comprehensive foundation for all initiatives. This is achieved through lateral and interdisciplinary team spirit to minimise ambiguity.

Theoretical Review

Many theoretical schools of thought have been put forward to provide a rationalization for the motivational drive associated with sustainability reporting. In relation to the case study, the researcher identified the stakeholder and legitimacy theories as legitimate and relevant in explaining the research phenomenon.

Legitimacy Theory

According to Burlea & Popa (2013), the concept of legitimacy is complex and refers to the assumption or perception that initiatives of an organization are proper, desirable, and necessary with the social and economic constructs in a norm system. The social system has values, definitions, beliefs, and norms. Reviewing this definition, the legitimacy theory is the organizational behaviour which can be related to the implementation and continuous development of voluntary environmental, economic, and social information disclosure as part of the general strategy of fulfilling a social contract (Burlea & Popa 2013). Irrespective of the size and area of operation, organizations across the globe are known to react positively to the societal interests, especially if such actions have positive results. As noted by Perez (2015), society-base intervention initiatives by organizations are reported in line with the community expectation. Reflectively, most communities are known to dissociate themselves from organizations that are perceived as selfish and non-conforming to their social and moral expectations. If such expectations are not proactively managed, they may have detrimental effects on such organizations, such as boycott of products or even complete demise (Herbohn, Walker & Loo 2014).

Despite strong opposing views by a myriad of scholars, the legitimacy theory offers a valid explanation surrounding factors influencing organizations to attempt to satisfy the societal perception and expectations (Cheng, Loannou & Serafeim 2014). Factually, this approach may promote accountability and transparency to the stakeholder groups (Perez 2015). In a quick rejoinder, Burlea & Popa (2013) opined that the legitimacy theory is actually a comprehensive “theoretical construct used for making viable predictions and thus, organizations must voluntarily disclose social and environmental information to consider their legitimacy as a resource” (p. 1579). Legitimacy theory emphasizes the notion that organizations desire to be viewed by the community as functioning within the moral and social business standards, to guarantee some level of acceptance as legitimate. Since these expectations are not standardised, the theory proposes that organizations should be proactive in responding to moral and ethical standards in their business environment (Cheng, Loannou, & Serafeim 2014). This is necessary to create an environment of self-regulation that supports the ‘social contract’ of the environment of operations. If an organization fails to meet the requirements in the ‘social contract’, the possibility of a societal revolt might hinder smooth operations and business sustainability in the long-term.

Legitimacy theory is a significant building block in the justification of the function of sustainability report in communicating the environmental, economic, and social information (Hahn & Kühnen 2013). This function is vital with the increasing concern in the social and environmental impacts of major sectors in their reporting of sustainable existence. At present, serious organizations must be in a position to explain their operations through legitimate social and economic actions that are supportive of the societies and the environment they operate in (Burlea & Popa 2013).

Stakeholder Theory

As previously established, the primary motivation behind sustainability reporting is to give the stakeholders a picture of the business environment besides showing accountability. The stakeholders have an important role. Thus, the stakeholder theory offers a valid explanation on why firms have to report their sustainability actions (Herbohn, Walker & Loo 2014). In relation to this research, the stakeholders are government, sector players, and regulatory agencies, who are interested to establish the level of business sustainability from one sector to another (Hahn & Kühnen 2013). Moreover, the stakeholder theory presents an interesting analogy of the current communication strategies in place across the case study economies. The concept of stakeholder theory was first explained by Freeman (1984) by defining stakeholders as a group who may directly impact or is impacted by the realization of organizational objectives.

The stakeholder theory explains strategies that organizations can employ to proactively address the interests of different stakeholders, irrespective of the economic sector. The theory is angled heavily on the Freeman’s Principle of Whom or What Counts (Burlea & Popa 2013). This principle defines the role of the stakeholders to an organization and determines the level of attention given to these roles by the management. According to Searcy & Buslovish (2014), stakeholder management “requires, as its key attribute, simultaneous attention to the legitimate interests of all appropriate stakeholders… in the establishment of organizational structures and general policies… in decision making” (p. 149). The theory conceives that the management of an organization has the duty of continually examining the significance of meeting the demands of the stakeholders to realise the underlying strategic management objectives in the short and long-term (Burlea & Popa 2013). This is because the stakeholders have veto powers to define and control decision making process during resource allocation. As a result, a firm must strategically and constantly manage the existing relationship with the stakeholders to guarantee survival (Herbohn, Walker & Loo, 2014). This theory reaffirms the significance of effective communication to ensure that decision making process is not compromised by stakeholders’ reservations (Bal et al. 2013). The stakeholder theory is relevant to this research study since it exposes the significance of the stakeholders’ confidence as a motivating factor behind voluntary and mandatory sustainability reporting (Searcy & Buslovish 2014).

Literature Contribution, Gaps, and Conclusion

The research within the field of sustainability reporting is experiencing paradigm shift and several concerns are being addressed by new studies each day. However, there is a need to draw attention the current efficiency and effectiveness in the reporting of sustainability initiatives as reported to the stakeholders. The researcher noted that most of the past and recent case studies have concentrated on the economic benefits of an organization releasing a sustainability bulletin. Therefore, this research study attempts to present new information to the current body of research knowledge on sustainability through filling this gap.



This section of the study examines the method used to collect and analyse data. The chapter commences with an introduction of the research design and discussion of the method of data collection. Specifically, the researcher opted for a quantitative approach involving data collection from secondary sources such as websites and previous reports.

Research Design

Since the research study is multifaceted, the researcher opted for a quantitative methodology using closed-ended data to present an analysis of the research phenomenon (Mason 2015). The rationale for this choice is informed by the comprehensive nature of quantitative approach. Since the analysis of the topic of sustainability reporting is complex, the adoption of the closed-ended data collection method was necessary to comprehend content and proactively synthesize different sustainability reporting bulletins gathered from the case study economies (Kothari 2013). The primary assumption in the use of this design is that the findings will conform to the conclusions of previous similar reports.

The aspect of quality in research is dependent on the reliability and validity of its content. Since this research is quantitative, the focus will be on the internal reliability and validity aspects of proactive data collection and interpretation (Mason 2015). Specifically, reviewing the trends in sustainability reporting instruments and their application in different economies will put the research findings into perspective (Kothari 2013). Thus, determination of the internal reliability and validity will involve a proactive comparison of the research study findings against previous literature on the same topic. This is necessary in fast tracking the match between the research study findings and the theoretical background or existing literature on the topic. In effect, the research quality will be ensured through adherence to the authenticity and trustworthiness in data collection, interpretation, and analysis.

Data Collection

The quantitative data were gathered from annual sustainability reports and company websites. To guarantee accuracy and consistency in comparative analysis of different sustainability issues, the researcher used the same criterion for website and report content classification (Kothari 2013). The research design was operationalized through proactive review of the annual sustainability reports. Specifically, the researcher concentrated on the sustainability communication tactics and medium the companies within the case study economies use to determine the content in each bulletin (Mason 2015). Inclusion of different websites of organizations across the case study economies was necessitated by the diversity in the communication strategies. A quick scan of these websites revealed that 70% of the organizations had comprehensive sustainability reports.

The integration of website for publishing sustainability initiatives was documented as an important medium for communicating responsible corporate behaviour to the stakeholders. According to Perez (2015), “the internet is the primary medium for firms operating in the international arena to communicate their practices” (p. 147). In relation to this, the relevant sustainability reporting initiatives found in the various organization websites were graded and assessed using the same approach to establish a trend and guarantee uniformity in the analysis. The researcher concentrated on the recent sustainability reports for different firms within the case study economies, which are published in the corporate websites (Mason 2015). In addition, the Global Reporting Initiative database and the UN Global Compact sites were reviewed. The performance of sustainability reporting was evaluated in the study through development of a standardised benchmarking instrument, which integrates the environmental, social, and economic pillars of sustainable operations. The researcher used the GRI guidelines and other relevant literature (Baxter 2015). The collected data were transcribed to identify the variables in place and put them into perspective of the research. Decoding data involved identification of trends in the disintegrated sets (Kothari 2013).

Generalisability and Vigour

The quantitative closed-ended design was representative clear, scientific, and verifiable criteria for analysing the trend established (Baxter 2015). The integration of several case study countries and different instruments are representative of the actual situation on the ground (Kothari 2013). In addition, the extensive sample space was ideal in comparative research in establishing the accuracy and degree of differential interval (Mason 2015). Based on these considerations, the study is predicted to be accurate and representational of the research questions and objectives.

Validity and Reliability

The aspects of reliability and validity determine the magnitude and accuracy in data collection or analysis (Baxter 2015). The researcher ensured that there is consistency in the research instruments applied to “reflect the unique understanding that personal experiences bring to the development of case study” (Mason 2015). The proposed quantitative research design will balance the practices and competencies that are relevant to the study.

Ethical Considerations

The entire study will embrace acceptable ethical principles of scientific research. The researcher is well trained to carry out ethical research, especially on how to apply distinctive data gathering and reporting strategies (Mason 2015). The dependability of the proposed research will be achieved through integration of a sequential design. Therefore, each research element will be congruently positioned to each research question to integrate the empirical and theoretical constructs (Kothari 2013). Lastly, the researcher will accurately transcribe the collected data to conform to the basic scientific standards of carrying out a case study (Mason 2015).

Summary of the Methodology

The researcher will apply quantitative method to subject the findings to a scientific interpretation. The methodology will be addressed through research survey of previous sustainability reports, articles, and other scientific publications.

Findings and Analysis


This chapter examines the findings and interpretation of the data to give a scientific interpretation. All the research questions are answered in this section. Lastly, the chapter presents a comprehensive discussion of the findings.

Findings and Analysis

As captured in table 1, the researcher reviewed more than one hundred companies from which the following 15 were selected for detailed review. The researcher ensured that there was a regional balance to capture the United State, Europe, and Asia (China).

Company SOE or Public Rank in Globally Origin
China National Petroleum SOE 4 China
PEMEX SOE 46 China
State Grid Public 2 China
Sinopec Group SOE 9 China
Volkswagen Public 6 Europe
Royal Dutch Shell Public 6 Europe
Reliance Industries SOE 347 Spain
HSBC Public 18 UK
Anheuser-Bushc Inbev Sa Public 33 Belgium
BP PLC SOE 49 United Kingdom
Berkshire Hathaway SOE 28 United States
ExxonMobil Public 22 United States
McKesson SOE 24 United States
Apple Public 17 United States
Wal-Mart Public 3 United States

From the review of different organizational websites, the researcher established an interesting trend in the instruments of sustainability reporting. As captured in table 2, the mandatory and voluntary instruments experienced a positive growth between the year 2006 and 2016.

Table 2. Trends in the instruments of sustainability reporting

Year 2006 2010 2013 2016
Reporting instruments Mandatory 35 58% 94 62% 130 72% 248 65%
Voluntary 25 42% 57 38% 50 28% 135 35%
Total 60 151 180 385
Economies and regions 19 32 44 71 (64 having instruments)

In responding to the first question, the research established that sustainability reporting instruments are in existence in all the case study economies. Specifically, over the last five years, the sustainability reporting instruments have grown significantly within the regions of study. All the 17 countries researched have a series of voluntary and involuntary reporting instruments. The findings established that there are 383 instruments, with the US and EU leading in the year 2016 as compared to only 180 instruments in the year 2013 as captured in table 1. There is an upward trend in the number of instruments with an average of 6.0 in each of the case study economies in 2016 as compared to only 4.1 in 2013. This is an indication that the modern and complex nature of the global market expects organizations to proactively report their financial and non-financial performance. From the secondary data collected, the primary drivers of the increased number of reporting instruments can be attributed to the establishment of government regulatory growth authorities, especially in the United State of America, United Kingdom, China, and parts of Europe, integration of the ‘comply and explain’ policy, and the advent of a series of direct market regulators.

The high number of reporting instruments in Europe can be attributed to the existence of many economies in this continent. By the end of the year 2016, there were 155 instruments in Europe as compared to 80 in 2013. The adoption of the EU Non-Financial Reporting Directive in 2015 instituted implementation measures in organizations such as disclosure on risks, outcomes, and policies related to social, economic, employee welfare, corruption, and diversity. In the year 2016, more EU reporting instruments were instituted to focus on mitigation of impacts of climate change, such as the Greenhouse Gas (GHG), energy efficiency trading, and human rights protection. On the other hand, the reporting instruments within the US grew substantially between the year 2013 and 2016. The number of instruments issued by governmental and non-governmental regulators doubled. The Asia Pacific region, especially China was not left behind. As captured in table 3, there was a reported growth of 75% between 2013 and 2016. Specifically, more than 31 out of 108 new instruments were introduced by the market regulators. At the end of 2016, financial and stock exchange regulators introduced more instruments than the respective government agencies.

Table 3. Growth in sustainability reporting instruments in the 100 companies in each case study economy

Region United States China UK and Europe
Year 2011 2013 2016 2011 2013 2016 2011 2013 2016
% 69 76 77 49 71 79 71 73 74

In answering the second question, the findings revealed that almost two thirds of all the reporting instruments are mandatory. During the period of the study, there were 115 new mandatory reporting instruments introduced in the case study economies. However, as captured in table 4 and 5, the proportion of the mandatory against voluntary instruments decreased to 65% in 2016 as compared to 72% in 2013. Across the case study economies, many organizations that adopted voluntary efforts have increasingly performed well within the mandatory information disclosure policies by governmental agencies. Specifically, the impact of mandatory policy was highest in Europe, especially the UK, where the 2015 UN sustainability initiative has created a stringent of laws, accounting policies, and direct intervention instruments to address the theme of environment, social, and economic concerns. For instance, the EU’s 2003 Modernization Directive has been replaced by the EU Non-Financial Reporting Direction of 2015.

Table 4. Voluntary Verses Mandatory instruments between 2013 and 2016

Year Voluntary Instruments Mandatory Instruments
2013 28% 72%
2016 35% 65%

Table 5. Voluntary vs. Mandatory instruments by region

Region United States UK and Europe China
Year 2013 2016 2013 2016 2013 2016
Voluntary 22% 20% 36% 38% 32% 38%
Mandatory 78% 80% 64% 62% 68% 62%

The findings further indicated that a ratio of 1:10 in the adoption of the ‘comply and explain’ approach in reporting instruments, whether mandatory or voluntary. The application of the ‘comply and explain’ is evenly spread in the US, Europe, and China. Interestingly, the financial and stock exchange markets were the leading implementers of the comply approach. Specifically, twenty one out of thirty eight ‘comply and explain’ instruments were introduced by the stock and financial market regulators in the year 2016. From the findings, it is apparent that the ‘comply and explain’ approach is instrumental in voluntary and mandatory reporting since it can motivate a firm to accurately report its sustainability initiatives as a result of peer pressure. For instance, in China, the major industry regulators and governmental agencies adhere to the regulatory policies of the central government, with the public companies being at the forefront. Eventually, the private entities have no alternative but to follow suit through compliance. The China Securities Regulatory Commission and the Assets Supervision and Administration Commission are mandated with the responsibility of monitoring the ‘comply and explain’ reporting approach.

In answering the third question, the findings revealed that government agencies issue the highest number of reporting instruments followed by financial and stock exchange regulators. As captured in table 6, the industry regulators issue the least instruments at 15.

Table 6. Number of reporting instruments issued per issuing body in the year 2016

Regulatory Body Governments Financial Sectors Stock Exchanges Industry Regulators Others
Number of Instruments 223 69 44 15 32

The government regulators contributed the highest number of regulatory instruments within the economies of study. The typical examples identified within the study regions include the Dutch National Action Plan on Business and Human Rights, the China Five Year Sustainable Development Plan, and the UK Action Plan on Corporate Social Responsibility 2015-2018 (Corporate Register 2016). The financial market and stock exchange regulators contributed almost a third of the instruments in the year 2016. This means that these groups were the most active besides any direct government intervention in sustainability reporting policy. For instance, the US Securities and Exchange Commission issued the Guidance Regarding Disclosure Related Climate Change instruments in the year 2010 and have made adjustments to conform to the current climate change concerns. More than half of all the stock exchange instruments were identified to be emerging from the Europe continent to conform to the Sustainable Stock Exchange (SSE) initiative introduced by the “UN Conference on Trade and Development (UNCTAD), THE un Global Impact, the UN Environment Programme Finance Initiative (UNEP FI), and the Principles of Responsible Investment (PRI)” (Perez 2015, p. 13).

In answering the fourth question, the findings revealed that 30% of the reporting instruments are engaged in large public listed companies across the case study economies. Within this percentage, the financial and stock market sectors applied 73% of the reporting instruments. The instruments that are applied in large firms proactively quantify ‘large’ on the metrics of equity (at least US $100 million), employees (500 and above in compliance with the EU Non-Financial Reporting Directive), and turnover (US$160 million in the US). Generally, the findings revealed that about 40% of the reporting instruments apply to all firms that were studied, irrespective of the listing, size, or sector of operation. The only exception was the state-owned firms. Factually, as captured in table 7, 84% of the instruments applied in all organizations originated from government agencies with the rest coming from other non-governmental regulators. In most of the economies studied, the focus of reporting instruments is on state-owned firms, large companies, and organizations operating in the stock markets and high-impact economic sectors. The focus on large companies is often rationalised by their human and financial resources, which should be tracked and reported. Moreover, as the large firms adopt the sustainability reporting, small organizations are believed to bow to this peer pressure and follow suit. In addition, in the court of public opinion, the large companies should be subjected to scrutiny to protect the social, environmental, and economic interests of a community.

Table 7. Firms covered by the reporting instruments in 2016

Organizations Voluntary Instruments Mandatory Instruments
Large Companies 111 52
State-Owned Firms 0 28
Public Sector Firms 0 23
SMEs 0 9
All Companies 0 155

The findings also revealed that one in every five instruments targeted specific sectors in the case study economies. Specifically, the heavy industry and financial sectors were most affected by the regulators and policy makers. For instance, the EU Accounting Directive impacted the logging and extractive industries in the UK. Also, the UK Stewardship Code has been instrumental in regulating the financial and stock market sectors. In Germany and Sweden, the Corporate Governance Code for Investors and the Swedish Mandatory ESG Disclosure for Pension Funds are significant instrumented for guaranteeing sustainable report to cover the interest of stakeholders and social pillars, respectively. On the other hand, the Consumer Protection Act and Dodd-Frank Wall Street Reform, and Regulation S-K in the US have become significant regulators for large companies (KPMG 2013). At present, in China, almost two thirds of the reporting instruments govern the financial service sector. Geographically, as established within the case study economies, almost 75% of the reporting instruments are implemented in the heavy industry, especially in China, the US, and the United Kingdom.

In answering the fifth question, the findings revealed that governments and other regulators have continuously encouraged firms to accurately disclose their sustainability reports in compliance with the set format standards. The instruments that need disclosure within the stand-alone format for sustainability reports have grown over the years. On the other hand, the instruments adopting the specific disclosure format have increased by almost 80% in the last six years. At present, about half of all the instruments observed in the year 2016 encourage firms to disclose any sustainability information in different formats, as long as the content is accurate. Among the acceptable formats include inclusion in stand-alone, integrated, and annual financial reports (Illia et al. 2013). Specifically, the reports could be formatted to include “stand-alone disclosure of data to government, such as greenhouse gas emissions, waste or employment figures, or the publication of policies or action plans on specific themes such as labour, social impact or biodiversity” (Herbohn, Walker, & Loo 2014, p. 438). The notable examples of the actual disclosures to governments include the US Toxics Release Inventory (TRI), China’s Environmental Protection Law, and the European Pollutant Release and Transfer Register (E-PRTR) as captured in table 8. In each of these cases, the government has published data electronically and furnished all the stakeholders with relevant information sites.

Table 8: Formats for reporting different instruments between the year 2013 and 2016

Format Sustainability Report (SR) AR and or SR Integrated Report Annual Reports (AR)
Year 2013 50 4 3 65
2016 76 2 4 127

In answering the sixth question, the findings revealed that more than sixty one percent of all the instruments identified in the year 2016 covered explicit report on social and environmental issues. The other two fifth encouraged sustainability reporting of the general non-financial information. There was a relatively significant rise in instruments that drive the reporting of any social information. The results indicated that social information is occupying more space in sustainability reporting than environmental factors. As indicated in Table 9, social information covered includes training, working conditions, health and safety, and human rights, especially in Europe and the US (Stubbs, Higgins & Milne, 2013). The rise in reporting social information may be attributed to the negative impacts of the previous global financial crisis motivating organization to develop interest in social issues. For instance, in Spain, the Strategy for Corporate Social Responsibility 2014-2020 has become an instrumental guideline to social sustainability reporting in compliance with the EU’s CSR and UN Guiding Principles on Business and Human Rights strategies (Marshall, McManus & Viele 2016). However, in China, the social sustainability reporting is influenced by the regional trends associated with public health and pollution concerns (Lozano 2013).

Table 9. Themes addressed by different sustainability instruments between 2013 and 2016

Theme General Sustainability Environmental Social
Year 2013 79 76 39
2016 147 133 74

The governments of the case study economies are expected to institutionalise National Action Plans (NAPs) in responses to the 2011 UNGP for sustainable human and business rights. Interestingly, the US, China, and the UK have developed NAPs due to stakeholder pressure. The NAPs framework as defined by the UN Working Group on Business and Human Rights recommends efforts by governments to encourage transparency and compliance. The notable instruments that have been put in place to address the social information reporting include “the Dodd-Frank Act (2010, conflict minerals) and the Business Supply Chain Transparency on Trafficking and Slavery Act (2015) in the US as well as Sustainability Reporting Guidelines for Apparel and Textile Enterprises (2008) in China” (GRI 2016. p. 14).

Over the period of study, the growth in environmental reporting has slowed. However, more instruments are focused on environmental reporting, though many organizations do not apply them. The decline in environmental reporting could have been as a result of the past trends in environment degradation concerns. For instance, as captured in table 10, the creation of the new GHG emission data has ensured that the US, Europe, and China are in the forefront in monitoring the implementation of the environmental reporting instruments. Following the global endorsement of the Paris Agreement during the UN Climate Conference (COP21) in Paris, there has been a significant rise in environmental sustainability reporting as governments implement stringent policy frameworks. Since 2015, the US Energy Transition Law has become an effective instrument for companies to accurately disclose risks associated with climate change in their annual and other sustainability reporting bulletins. In addition, the green bond market has become another significant effort in place to improve on environmental reporting. In the last ten years, the green bond value has doubled from US$1 billion in 2007 and US$41 billion in 2015.

Table 10. General versus environmental and social specific reporting instruments in 2016

Factor All Countries The US Europe/UK China
General Sustainability 147 4 59 42
Specific Environmental 106 13 36 35
Specific Environmental and Social 27 0 11 11
Specific Social 47 6 23 11
Other 55 2 25 11

In the US, 75% of the reporting instruments focus on specific social and environmental factors. Specifically, 15 reporting instruments focus on environmental reporting with only a single guideline tackling general sustainability. The noted focus of most the US reporting instruments on the environment can be related to the current movement on the need to embrace generic principles (Kimmel, Weygandt, & Kieso 2014, p. 44). For instance, the Business Supply Chain Transparency on Trafficking and Slavery Act of 2015 and the SEC Guidance on Disclosure Related to Climate Change of 2010 have integrated the views of the public on environmental factor (Goyal & Goyal 2014, p. 57). As the world moves in the direction of sustainable business practices, pressure has been increasing for companies to demonstrate their responsible tax strategies. For instance, the Dow Jones Sustainability Index has contributed to improved taxation policies that are sensitive to the environment and social concerns of the community (Horner 2013, p. 45). Moreover, the UK Finance Act has motivated organizations to practice accurate tax reporting to promote fair play. In the year 2015, the European Parliament passed a bill to increase the monitoring of the financial activities of multinational organizations. According to this law, “all companies and subsidiaries with annual turnovers of more than US$85 million would have to publish a county-by-country breakdown of profits, tax, employees, and net turnover, including activities in tax havens outside the EU” (Corporate Register 2016, p. 14).

Specifically, the European Union’s national measures on information disclosure to capture risks, policies, and outcomes associated with sustainability have propelled the current focus on non-financial sustainability reporting (Gordon 2013, p. 75). A similar trend was recorded in the US following review of sustainability reporting instrumentation by different financial regulatory agencies. For instance, the reporting instruments increased from 23 in the year 2012 to 39 in the year 2014 (European Commission 2014). The Asia Pacific region has not been left behind in the growth and expansion of the suitability reporting instruments. China has become a key player in promoting the growing trend in financial reporting instruments. In the last five years, the economy of China has recorded an average annual growth in financial reporting instrumentation of 20% (European Commission 2014). It is however important to note that most of these instruments are designed by government agencies in China due to the economy’s active market control.

Conclusion and Recommendations


This section reviews the fulfilment of the research objectives and how they are related to the questions of the study. This part offers recommendations based on the analysis in the previous chapter.


The research objectives were aimed at establishing sustainability, nature, and application of the reporting instruments across the globe to capture their similarities and dissimilarities. The findings confirmed existence of the reporting instruments with bias in the social and environmental perspectives. The findings of the first question provided an interesting insight into the existence and operationalization of different reporting instruments. Factually, it was established that the reporting instruments have grown tenfold in the last five years and all the case study economies have mandatory and voluntary reporting instruments. The second research question aimed at capturing the most common reporting instrument being applied within the case study economies. The findings confirmed that the mandatory instrument is the most popular at two thirds of all the instruments. In the last five years, voluntary instruments are slowly rising as more companies become conscious of the need for sustainable business. Interestingly, the study revealed that companies that use voluntary instruments perform very well in the non-financial matters. In ay either way, the mandatory and voluntary instruments are used via the ‘comply and explain’ format across the globe. The findings in answering the third research question paint a picture of dominating influence by government agencies in creating and regulating the application of different sustainability instruments. In the private sector, the stock exchange and the financial regulators have been effective in the creation and modification of sector-based instruments.

Almost all the large companies are active reporting their sustainability initiatives. The findings of the third question highlighted the impact of these large companies in influencing smaller organizations to comply. Organizations in the financial stock markets applied the highest number of instruments. This could be attributed to strict regulatory policies within this sector. The results painted a picture of a positive progress across the globe by major companies in promoting sustainable business practices, irrespective of their sector of operations, listing, and size. However, the state-owned firms indicated the highest level of compliance due to direct state involvement in sustainability policy creation and implementation. The second objective of the study was addressed by the results of the fifth question. The findings revealed that different regulatory agencies have remained proactive in encouraging organizations, whether private or publicly owned, to formalise accurate sustainability disclosure in the form of annual reports. These agencies have gone further to create standardised formats. Due to the growth of the instruments requiring the stand-alone format, most regulatory agencies concentrate on their modification to suit different sectors. The development of the specific disclosure format has not been left behind, especially to enable large companies operating in different economic zones to have a standardised reporting mechanism.

The third objective aimed at pinpointing social and environmental coverage in the sustainability reporting is addressed by the results of the sixth question. The findings indicated that majority of the sustainability reports in the year 2016 explicitly addressed the social and environmental issues. Specifically, more than 60% of the reports comprehensively highlighted the environmental and social issues as part and parcel of the daily operational strategies. The rest of the reports covered other non-financial information ranging from one sector to another. Generally, the drive for social and environmental information indicated a positive trend across the economies of study. At present, as revealed in the 2016 sustainability reports, the social or environmental information is currently at the forefront in practicing sustainable business activities. The social or environment information includes working conditions, training, human rights, and safety among others.


The research report has provided a comprehensive overview of the sustainability reporting in different regions that have regulations on reporting instruments. Specifically, the research has successfully carried out a comparative analysis of the sustainability of the reporting instruments within the United State of America, United Kingdom, China, and other parts of Europe. The researcher dwelt on the mandatory and voluntary nature of reporting instruments, issuers, targeted markets, their formats, and how they tackle specific social and environmental themes. The findings revealed that a variety and number of instruments are currently applied in different economies as a result of commendable efforts by regulators, governments, and other stakeholders. The research report has also established that there is a rapid and consistent growth in the reporting instruments over the years. Although the trend is positive, and likely to continue in the foreseeable future, there is a need for regulatory authorities to focus on harmonization and coordination of the instruments for effective and accurate reporting. To achieve this, there is a need for proactive levels of joint commitment and collaboration between the sustainability reporting regulators. In the end, the process of developing and implementing different instruments would be self-sustaining. Moreover, there is a need to improve on materiality and prioritization to satisfy the growing expectation by the public on the agenda of regulation and reporting.

As established in the report, concerns on human rights and tax practices have recently motivated the development of more the social and environmental reporting instruments. At present, the pressure is equally high on organizations to sustain transparency and accuracy in reporting sustainability initiatives. This means that the regulators and reporting firms should strike a balance between focus and perceived comprehensiveness in the sustainability information. The analysis began by summarising the quantitative overview of the reporting instruments. Since the research was open-ended, it was not possible to tackle issues surrounding context, impact, and instrumental drivers in sustainability reporting. Therefore, there is a need for further research to establish the effectiveness of the discussed instruments and their success in achieving the sustainability reporting objectives. The findings of this report have laid a stable ground for any future research on the development of regulation instruments to support sustainability reporting.

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