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Submission to Bursa Malaysia – Review of the Sustainability Reporting Requirements Under the Main Market and ACE Market Listing Requirement

On 6 June 2022, ACGA sent a letter to the Bursa Malaysia Securities Berhad in response to the Consultation Paper No. 1/2022, Review of the Sustainability Reporting Requirements Under the Main Market and ACE Market Listing Requirement issued on 23 March 2022. 

We view the proposed changes as a step towards enhancing sustainability disclosure requirements in preparation for the imminent release of a globally-accepted set of reporting standards from the International Sustainability Standards Board (ISSB). We note and appreciate the similarity of approaches, with a set of general requirements, as well as sector-specific reporting requirements, Scope 1 and 2 and some aspects of Scope 3 emissions data, and disclosures aligned with the Task Force on Climate-related Financial Disclosures Recommendations (TCFD). In addition to our broad support, we offer suggestions including:

• Requiring five years of data instead of three, as well as graphs and narrative explanation of trends
• Taking a “climate first” approach to phasing in disclosure, aiming for a FY2023 start rather than FY2024
• Adding disclosure indicators for corruption investigations and work-related injuries
• Refining energy, water and carbon emissions to include intensity figures
• Strengthening rules to require assurance on some figures, as well as disclosure of the standard and level of assurance