Guidelines

The investment manager, in collaboration with the governing body of the vehicle, should define an appropriate ESG reporting framework. This framework should be clear, balanced, and fairly represent the ESG performance of the vehicle, in line with regulatory requirements, investor expectations, and its ongoing business needs. The framework should be clearly defined in the constitutional documents of the vehicle.

The investment manager, together with the governing body of the vehicle, has an obligation to ensure that all forms of reporting, including ESG reporting, are appropriate to the circumstances and include applicable regulatory and legal components. In pursuing this responsibility, the best interests of investors should always be considered. See also G31 of the inrev-guidelines">Governance module.

The investment manager should disclose relevant ESG information periodically (at a minimum on an annual basis) in a clear and concise manner. In accordance with INREV’s reporting guidelines, the investment manager should clearly define in the constitutional documents of the vehicle the content, frequency, and timing of its annual and interim ESG reporting (see also G37 of the Governance module. These should be determined in line with investor expectations and the ongoing business needs of the vehicle.

The organisation and reporting format of the vehicle’s ESG status, actions and performance may be reflected in a dedicated ESG section in annual/interim reports, integrated into relevant generic sections of those reports, or presented as a standalone sustainability report (see Reporting module).

When developing its ESG reporting framework, a broad range of ESG KPIs should be considered by the investment manager as relevant to the ESG strategy and business needs of the vehicle - see INREV ESG KPIs in Table 1 of RG73 and Appendix 1 of the INREV sustainability reporting guidelines.

In addition to respecting the regulatory and contractual reporting obligations of the vehicle, the investment manager may consider other widely recognised ESG reporting standards and frameworks. The investment manager should disclose to investors which industry frameworks were considered and adopted for ESG reporting and climate-related risk assessments (eg TCFD, WGBC ANZ, GRI, SASB, CDP, UN PRI, UN SDG (see Appendix 4)).

The investment manager should state whether the vehicle participates in ESG assessments and/or receives ESG scores (eg GRESB). Information regarding participation, outcomes/scores and future ambitions should be communicated to investors.

ESG reporting should include details on how the vehicle embeds the ESG strategy into its overall governance approach to achieve targets and the performance achieved against those targets. It should include a description of how its governance structure integrates ESG considerations into decision-making processes.

Certain legacy vehicles or funds which opt not to have a coherent ESG reporting framework should nonetheless disclose this status and provide any relevant explanations.