<Tentative Translation>
Report on the Ways to Disclose Corporate ESG Information in Order toIncrease Sustainability of Society and Enhance Creation of Corporate
ValuesMarch 2022
CSR Committee, Business Policy Forum, Japan

Executive Summary

Introduction
Looking back on the condition of rules and regulations regarding corporate non-financial
information disclosure, many sets of rules and regulations have been set up and are provided forcommon use.

In only the past few years, new international undertakings have been initiated tointegrate and merge existing disclosure frameworks, or to reinforce legal regulations or soft laws forsustainability information disclosure by states or regions. The most noted action among them is theconsideration of disclosure standards by the International Sustainability Standard Board (ISSB).
Another major action is the establishment of the legal regulation of the Corporate Sustainability
Reporting Directive (CSRD) by the European Union.
At the same time, accompanying by-product problems of Green and ESG Washing have started to
draw concerns that some disclosures include disguised information pretending to be tacklingenvironmental, social or governance issues at this time of a growing trend of ESG investments.
Accordingly, rulemaking for Green and ESG Washing is being promoted in various regions, and gradedfinancial products for ESG issues have been increasing in the market.
Intensified requirements for non-financial information disclosure have led to the introduction ofrules with standards in the situation as stated above, which might cause corporations to follow the rulesof disclosure only to abide by the rules.

However, the essential objectives of information disclosure

are to increase sustainability of society and to enhance creation of corporate values. It is critical for
corporations to upgrade integrated information disclosure that contains sustainability issues, while
promoting and enhancing integrated management to synchronize business management andsustainability management.

iThis report aims to compile relevant suggestions for Japanese corporations and related
stakeholders in reaction to the reinforced disclosure requirements in the current tide of integration of
disclosure standards and introduction of legal regulations and other rules.

Chapter 1: Current Situation of Institutional Regulation for Disclosing ESG Information
1-1: ISSB (International Sustainability Standard Board)
ISSB was established in November of 2021, under the IFRS (International Financial ReportingStandards) Foundation side by side with IASB (International Accounting Standards Board). Existing
major standards and frameworks for sustainability information disclosure have now been united or
merged into the ISSB standards, which are widely acknowledged to be the de facto global baseline.
ISSB had made its drafts of S1:"General Requirements for Disclosure of Sustainability-related Financial
Information" and S2:"Climate-related Disclosures" public, and is proceeding with the consultation
processes to finalize the drafts by June of 2023, and to put them into effect in January of 2024.
1-2: GRI (Global Reporting Initiative)GRI Standards were established as comprehensive guidelines for sustainability information
disclosure, and consist of Universal Standards, Topic Standards and Sector Standards.

Anyorganization that makes reports in accordance with the GRI Standard is supposed to process the reportby selecting related topics from Topic Standards or Sector Standards based on prior identification ofcore material topics of the organization.
GRI agreed on mutual collaboration in July of 2021 with EFRAG, the organization that stipulates
disclosure standards of EU’s CSRD, and also entered into a collaboration agreement with ISSB1 in Marchof 2022, in order to coordinate their standards to ensure compatibility.
1-3: CSRD (Corporate Sustainability Reporting Directive) Promoted by EU
EU is now proceeding with CSRD standards as the basic framework for sustainability information
disclosure. CSRD is a directive of legal regulations that require corporations to follow due information
disclosure, and covers not only European corporations but also Japanese corporations that operate inEurope at a certain magnitude, that will be asked to handle corresponding procedures.

The EU’s

disclosure framework emphasizes the concept of Double Materiality, which values both the financial side
and environmental and social side of corporate operations.
The European Financial Reporting Advisory Group (EFRAG) is now developing standards for large
corporations in Europe, which are scheduled to be adopted as a formal delegated act by the end ofJune 2023, and will enter into force in a step-by-step manner from 2023 to 2025.

A concrete schedule

for establishing CSRD rules for non-member country corporations of certain conditions has not been1

https://www.ifrs.org/news-and-events/news/2022/03/ifrs-foundation-signs-agreement-with-gri/ii

made public, but further elaboration processes are planned to adopt a delegated act by around June of2024, to start applying all the new rules by 2028.
1-4: United States
The Securities and Exchange Commission (SEC) of the United States revised in August of 2020 its
Regulation SK which provided disclosure rules, except financial statements, among the annual reporting
documents forms (Form 10-K) which should be submitted to SEC. The revised Regulation SK requires
listed corporations to include information on human capital in the reporting. It also made a proposalof a regulation in March of 2022 that ask corporations to publicly disclose climate related information,and the final version will be released around April of 2023. After publication of the rules, they will beapplied to corporations in a step-by-step manner according to corporate classifications.
1-5: JapanThe Financial Services Agency of Japan released draft amendments to the “Cabinet Office Orderon Disclosure of Corporate Affairs” and other related rules. The new rules include a) the addition of asection describing policies and activities for sustainability in the form of financial statements, b)
requirement to provide information on governance and risk management, c) request for an explanationof strategies and indexes and targets according to the relevance of them, and d) request for additional
explanations on human capital and diversity. These drafts are scheduled to be applied for financial
statements of business years that end on and after March 31st of 2023.
Furthermore, after the ISSB standards are finalized, sustainability standards of Japan aresupposed to be established by the Sustainability Standards Board of Japan (SSBJ) organized under the
Financial Accounting Standard Foundation (FASF).

Chapter 2: Expectation for Sustainability Information Disclosure by Stakeholders including
Investors
2-1: Institutional Investors and Financial Institutions
Current ESG investments show continued increases around the world.

The number of signatoryorganizations for Principles of Responsible Investment (PRI), which is led by the United Nations, has
surpassed 4,900, and the total amount of their investments was over 121 trillion yen at the end of
March of 20222.
been raised.

In the tide of this expansion, practical concerns about “Green & ESG Washing” have

In this context, regulatory authorities and ESG evaluation organizations of various

countries and regions have taken action to cope with the situation to intensify the standards.
The leading trend of regulatory actions of those organizations is to establish a set of categories
for financial products depending on the levels of contribution to sustainability, and to ask institutional

2

https://www.unpri.org/annual-report-2022/signatoriesiii

investors or financial institutions to classify their financial products as well as to disclose their detailed
contents.

A typical case is the Sustainable Finance Disclosure Regulation (SFDR) by EU.

SFDR

requests institutional investors and asset management companies: (step 1) to set and disclose thesustainability policies and programs of the whole institution, and (step 2) to make the detailed contentsof each ESG fund public.
Institutional investors and asset management companies will, accordingly, ask non-financial
corporations they invested in for additional information in order to obey the rules and regulations.
2-2: Investors of Long-Term and Active Portfolio Management
Mr. Hiroki Sampei, Principal of Astonering Advisor LLC, was kind enough to provide the committeewith the following information.
⚫

Viewpoints of Investors➢

It is important to be reminded that the investors do not just accept corporate disclosure.
When investors engage with corporations to consider their next investment possibilities, theinvestors evaluate the consistency or probabilities of the corporate explanations in advance,with an optical device, or logical hypothesis constituted from independent information sources.

⚫

Disclosure of Integrated Report of ESG Information and Active Use of Them➢

Messages from top management are the most informative items. Especially, investors placesignificant value on the logic and consistency of them and expect corporations to provide
clear explanations of a consistent and rational story for questions from cautious investors.

➢

While many corporations make use of similar templates for explaining “Value Creation
Processes,” the important items are supplementary explanations.

For example, the figuresof gender-gaps in payroll, which are required to be disclosed in financial statements, need
the following supplementary explanations.

They are analyzed information of current

conditions on; 1) consistency with the intention and assumed outcome of human resource
strategy, 2) possibility of unintended bias caused by existing specific perception, and 3)
rational reason for the possible bias in the actual business environment, and in addition,
concrete countermeasures to solve the problems as the next step.

Chapter 3: Research on Japanese Corporations that have Challenged Disclosing of Integrated
Reports
The committee researched 16 Japanese corporations, including committee member corporations,that had challenged disclosing of integrated reports, and thereafter put together the following views
after sharing the results and discussing it in the committee.
3-1: Objectives and Backgrounds to Start Integrated Reporting
2 major courses were found in the research as the objectives and backgrounds for corporationsiv

to start integrated reporting.
The first course starts from the recognition that financial statements cannot communicate thecorporate principles, the ways to create value continuously, or the style of corporate management bythemselves. The second course arises from the will of management to set sustainability at the centerof corporate management issues through integrating financial reporting and non-financial reporting.
Cases of the latter course included the following two approaches;a) One approach is that a corporation initiates integrated reporting processes first, and then it
intends to upgrade the level of integrated business management with proper feedback given
to the management board of the outcome of integrated reporting.
b) Another approach is that a corporation enhances, in advance, the management style tosynchronize between business management and measures for sustainability, and after that,the corporation starts to integrate its reporting.
3-2: Synchronizing Business Management with Measures for Sustainability of Environment andSociety(1) Priority Level of Performing Sustainability on Environment and Society in Total Corporate
Business Management
When synchronizing business sustainability with sustainability of the environment and society, along-term timeframe is necessary in constructing and conducting business management. Most of theinterviewee corporations were found to hold long-term visions or strategies for 10 years, andsustainability issues of the environment and society were clearly incorporated into the documents.
(2) Cooperating with Board of Directors or Management Board and Constructing the In-House
Coordination System
Major interviewees responded that the critical element in building a wide consensus for integrated
thinking, establishing integrated strategies and promoting integrated reporting is the change inmotivation and the demonstration of leadership of the top management.

Some said that occasions to

discuss sustainability issues in the management board increased substantially over the past few years,
and the contents of the discussion had also deepened in concreteness. Some other corporations said
they introduced their own methods, which include associating board members’ payment with the levelof participation in related processes, or assigning a business group leader to a board member in chargeof a material topic at the same time.
3-3: Identifying and Dealing with “Material Topics”(1) Identifying “Material Topics”
It was found in the research that the ways corporations identify and deal with “material topics,”
or the issues that the corporation regard to be crucial, are varied among corporations.

Eachcorporation introduced its own “material topics” with a unique style in its “purpose,” long-term vision,or long-term strategy based on the individual understanding.
v

There were cases that a corporation revised the position of “material topics” in its business
management when setting up its own “purpose,” or long-term vision or strategy, while promoting theprocess of advancing integration of sustainability with management. Some other cases showed that a
corporation specified a new set of “material topics” among the existing row on a similar occasion.
(2) Processes to Select “Material Topics”
The most general case was to proceed with the following three steps in selecting “material topics.”
A) Screening:

Selecting with reference to international norms and standards like SDGs, GRI
or SASBB) Evaluation:

Mapping the topics on the chart of 2 axes of viewpoints of the company andviewpoint of stakeholders

C) Discussion and Approval of the Screened Topics:
Decision making by management through in-house sustainability committee orboard meetings.
(3) Management Methods for each “Material Topic”
As to the management of selected “material topics”, the following cases were heard regarding
specifying a project strategy: allocating each business section to a corresponding “material topic,”
establishing an individual mid-term plan for each business section with consideration of a related“material topic,” or setting up a roadmap by region for each “material topic” by establishing a matching
global task force team.
Examples of the methods to specify Key Performance Indicators (KPI) were to identify quantitative
indicators in the mid-term business plan, to try to identify numeric indicators where possible, or to
identify some figures in the viewpoint of impact effects.
3-4: Implementing the Processes of Integrated Reporting(1) Improving Communication through Selecting Communication Media by Target Readers
Integrated reporting of a corporation is the starting point of engagement with stakeholders.
Among interviewee corporations, target setting in reports was roughly divided into two types: i)shareholders and investors and ii) wide multi stakeholders.
When selecting suitable communication media, some corporations specified contact media for all
stakeholders, while others intended to use classified media depending on the kind of stakeholder with
the intention of clarifying the role of each channel.

One corporation of the former direction compiled

its integrated report for all the multi-stakeholders so that it clearly communicated its own story of value
creation. Other cases of the latter included a corporation that put together a document with a detailed
image of assumed readers like investors, and a corporation that expanded the contents of financial
statements in order to make them the main tool to communicate with investors.

vi(2) In-House System to Carry out Integrated Reporting
An in-house system of a corporation for integrated reporting needs to ensure that its operationteam members are sufficiently informed of the activities of each section where necessary, in order toprovide persuasive views of the corporation.

Most of the interviewee corporations organized theirproject teams for integrated reporting composed of members of the main sections in-charge (sections
for management planning, public relations, investor relations, or sustainability) together with wider
corporate sector members.
Several corporations replied that the span of time for arranging an integrated report was about 6
months on average. The reasons for that time period were, for example, that it took time to collectand check related information, or that considerable time was needed to discuss and constituteconsistent stories covering broad sections.
3-5: Effects of and Further Tasks of Integrated Reporting(1) Effects of Integrated Reporting and Responses from Stakeholders
Most of the corporations answered that integrated reporting had brought them improvement inquality of engagement with stakeholders, especially with investors. In addition, many commented thatcases in which engagement was carried out with investors who had scrutinized the report beforehand
were increasing. One corporation talked about a case where it had a very important discussion withinvestors on critical factors of value creation.
Some other corporations noted that a merit of integrated reporting is that in-house processes to
put together the report are a beneficial opportunity to enhance mutual understanding and cooperationin different projects among employees of related sections.
(2) Further Tasks in Promoting Integrated Reporting
A lot of interviewees said how to quantify and show the linkage between non-financial targets andfinancial figures was a considerably challenging issue. Some also proposed, when the linkage of thetwo could not be clearly shown, it was important to disclose alternative measures, e.g. to upgrade thelevel of credibility of facts and assumptions, to show probability of estimates with correlation coefficients,
or to suggest the likely time difference from actions for non-financial targets toward possible positive
outcomes in financial figures.
As the same time, several revealed they had concerns about the volume of additional office workwhen they assume further responsibility to disclose based on the new regulations, while undertaking agood deal of work already.
(3) Demands and Expectations to the Government and Business Associations
Japanese corporations expect and demand the Japanese government to perform the following; a)participate or take a leadership role in making international rules, b) coordinate various kinds of rules
and regulations, c) provide information to support reactions of Japanese businesses, and d) arrange
rules that take actual business practices and characters of industry sectors into consideration.
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Chapter 4: Attitude to Deal with Sustainability Information Disclosure
Creating continued value for a corporation is to acquire confidence and empathy among its
stakeholders through solving their problems or providing new values to them, which involves sufficientdialogues and/or engagement with them. Corporate disclosure with clear transparency as the starting
point of the communication would provide an opportunity to receive varied feedback from stakeholders.
Incorporating that feedback into corporate management would probably lead to improved corporate
management.
Based on this understanding, suggestions in this chapter were compiled in an attempt to clarify
the key elements to help promote corporate engagement with stakeholders by introducing the keywords“compulsory exercise” and “free exercise” for disclosure requirements, or by proposing strategies for
integrated disclosure.
➢

Glossary: “Compulsory Exercise” and “Free Exercise”

The phrase “compulsory exercise” in this report means to disclose required information based on
existing rules and regulations.

The important suggestion when performing this “compulsory exercise”

is to disclose intentionally additional information that leads to proper interpretation of the information
provided to receive appropriate evaluation from stakeholders.
This kind of disclosure of additional information should be enhanced through “free exercise,” ormaking corporate information public to show its own competitive advantages to create empathy among
stakeholders.
This “free exercise” disclosure process is the task that each corporation, big or small, should carryout to look for the measures that are most suitable to its own condition. Enriching the quality of
disclosure through “free exercise” would also constitute a good foundation to deal with “compulsory
exercise” requirements.
4-1: Actions as “Free Exercise”“Free exercise” disclosure is the action that aims to acquire understanding and empathy among
stakeholders through communicating material topics and corresponding stories for integrated value
creation.
(1) Major Traditional Approaches to Select Material Topics
Material topics in the traditional business strategies were selected from business or managementtasks with a clear viewpoint of searching for new business opportunities, while material topics in the
traditional context of sustainability were adopted as major topics regarding sustainability issues thatwere connected to the fundamental position of the whole corporation.

It is, therefore, of critical needfor integrated business management to unite both sides of material topics to find new business
opportunities as well as to seek both social sustainability and corporate values in the long run.
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[Chart](*) The committee composed this chart referring to a chart by OMRONCorporation.
(2) Integrated Management and Measures for Information Disclosure
When promoting integrated management and information disclosure, the following three steps
should be key factors: i) encouraging continuous upgrading of in-house awareness for integrated
management, ii) finding and identifying suitable material topics based on the actual stage of the
management integration and, iii) advancing information disclosure and stakeholder engagement toenhance the probability of linkage between integrated management and real value creation.
i) Encouraging Continuous Upgrading of In-house Awareness for Integrated Management
There are three important approaches to unite the sets of material topics which were separated
in the traditional plans.
A) Re-evaluating the existing material topics selected by the traditional viewpoints of sustainability,from other viewpoints of potential business opportunities. Putting together the new corporate
business strategy with business operation sections, not only with corporate management
sections.
B) Urging both the business operation sections and the employees to perform the actions that are
being standardized by the “compulsory exercise” rules, through disseminating awareness of the
impact of business activities on the environment and society among the whole corporation.

ixC) Identifying the essential material topics for integrated value creation on the basis of a long-termtime frame together with the trials of the A and B approaches.
ii) Finding and Identifying Suitable “Material Topics” Based on the Actual Stage of theManagement Integration
It is essential in information disclosure for a corporation to clarify the way it identified its material
topics. The following three steps are basic methods in processing disclosure, as well as the steps tomodify the arrangement according to the progress steps of integration.
A) Clarifying the kind of value to be created.
B) Paying sufficient attention to possible impacts on the environment and society during the processof identifying material topics.
C) Coordinating the relationship between material topics and the business management strategy of
the whole corporation.
iii) Advancing Information Disclosure and Stakeholder Engagement to Enhance Probability of
Linkage between Integrated Management and Real Value Creation
When identifying and disclosing material topics to achieve integrated value creation, it is important
to develop a common understanding between a corporation and its stakeholders on how the material
topics are incorporated into the business strategy for value creation. Focused attention is currently
being paid to the two points: “drawing the picture of the relationship of material topics and financial
figures” and “visualizing the impacts on the environment and society.” Regarding the areas whereaccurate outlooks cannot easily be obtained, a reasonable alternative option is to upgrade the level ofprobability of the linkage of material topics and value creation, through disclosing the contents ofinternal discussions to look for the linkages, together with frequent engagement with stakeholders.
4-2: Actions as “Compulsory Exercise”
In this paper, “Compulsory Exercise” denotes the corporate disclosure processes to comply withstipulated legal rules and established common rules.

”Compulsory Exercise” is essential in promoting

fair business competition by enabling stakeholders to compare corporations based on a certain standard.
Furthermore, global big businesses are expected to develop their processes in a strategic manner tocover wider rules including some soft laws of informal rules.
Likewise, small and medium-sized enterprises (SMEs) that have businesses activities within supply
chains of big corporations are likely to be requested to disclose their information, in which big
corporations need to comply with “Compulsory Exercise.” At the same time, spontaneous practices of
SMEs to develop their own “Compulsory Exercise” and “Free Exercise” may generate positive effects forthemselves including more favorable evaluation from ESG minded financial institutions, increased
motivation among their employees, lower employee turnover rate, or increased possibility of acquiring
excellent human resources.
x4-3: Basic Hints in Establishing Strategies of Disclosure
It is important for corporations to construct their disclosure strategies based both on the idea of“Compulsory Exercise” and “Free Exercise.” The following three elements; i) targets, ii) media and iii)
frequency of revising, should be taken into account during the process of designing a disclosure strategy.
(1) Communication Targets
Communication targets may be classified into a) shareholders and investors and b) multistakeholders. A disclosure strategy may better be established separately by the group of stakeholders
having similar interests after searching for the interests of each group.
(2) Communication MediaOne suggestion is to associate each type of communication media with its respective uniquefunction, or allocate different purposes to i) integrated reports or ii) financial statements. Integrated
reports work as a tool of “Free Exercise” to communicate the corporate stories of value creation, while
financial statements serve as the media of “Compulsory Exercise” to transmit fundamental information
for a wider range of investors.
Other documents, e.g., iii) sustainability reports or ESG reports, will function as classified
information disclosure media, to provide varied information for diverse requests, according to the typeof media or information.
(3) Frequency of Revisions
Regarding the frequency of revising each document, the following measures are suggested basedon the fact that the frequency of revisions of original data are varied. It is also suggested that positive
actions to promote engagement are expected.
i) Fundamental information that does not change in a short period;
To disclose, in a systematic style, in the most comprehensive and transparent formii) Annual data;
To annually disclose in an integrated reporting style that consists of strategies, related plans,performed activities and real effects in quality and quantities.
iii) Other information in individual engagement activities;
To disclose the contents of individual engagement occasions with sufficient reviews so that
relevant information will be obtainable in a fair manner by every stakeholder.

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Chapter 5: Expectation for Enhanced ESG information Disclosure to Develop Social
Sustainability and Long-term Corporate Value Creation
It is crucial that a corporation and its stakeholders share a common vision regarding corporate
purposes and hold constructive discussions, in order to accomplish Sustainability Transformation (SX),or to “synchronize” social sustainability and corporate sustainability. In promoting these processes,
integrated disclosure is the starting point of the engagement. Based on the procedures, corporations,stakeholders, especially investors, and governments are expected to perform their roles in the nextstep.
5-1: Expectations for Corporations(1) Constructing a Disclosure Strategy for Integrated Reporting with Clarified Objectives,
Communication Targets, Standards Referred, for all Communication Media
It is effective to construct a disclosure strategy based on the key points of communication targets,
communication media and frequency of revisions, with the attention of “Compulsory Exercise” and“Free Exercise” or of information needs of stakeholders.

Clarifying disclosure objectives, assumed

readers, standards referred is important for all communication media, e.g., integrated reports, tocomprehensively transmit the whole image of the business management policy and corporate values
with stories of value creation.
(2) Enhancing Individual Story of Value Creation with Clarified Reasoning of Material Topics
It is advised for a corporation to explain its business strategies with stories that create value
through clear linkage to its corporate purpose and the whole business management policy.

In

identifying the material topics, the critical point is to estimate if the topics will result in relevant financial
effects, considering the possible short and mid-term impacts on society and the environment.

In

addition, proper operation management of the identified material topics is recommended by setting
related key performance indicators or evaluating the outcomes, and by taking the initiative toincorporate them into business management.
(3) Initiatives of Top Management to Lead the Corporation to Enhance Integrated Corporate
Management
Top management of a corporation is asked i) to put together its strategies to synchronize social
sustainability and corporate value creation in the long range of the time axis in promoting integrated
management, ii) to identify the material topics for value creation and incorporate them into mid-termbusiness management plans and KPIs, and iii) to take on initiatives to disseminate them throughout
the entire corporation.
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Most investors highly value the top messages in the disclosed integrated reports.

Presenting aconsistent story of both the company’s own corporate management policy and the expectations ofstakeholders is appreciated.
Engagement with varied stakeholders on the front line by top management can generatesignificant momentum to initiate and develop those reforms.
5-2: Expectations for Investors, Governments, Business Associations or Related Stakeholders
including Expert Associations(1) Expectations for Investors
Investors are expected to engage in more constructive dialogues with invested corporations, inthe time when institutional investors themselves are asked to disclose information on the sustainabilityof their business activities in the background condition of anti-ESG and Green Washing regulations inseveral countries and regions. In these engagement opportunities, investors are expected to upgrade
their dialogue techniques, e.g. to express their own ideas and positions regarding social sustainability
and long-term corporate value creation, so that their engagement leads to enhanced integrated thinking,practices and actual disclosures of the invested corporations, and vice versa, or that each side of theactions cause further actions of the other through circulation effects.
(2) Expectations for ESG Evaluation Institutions
It is desirable for ESG evaluation institutions to review and improve their own business policies
and the measures to evaluate corporations, and, on top of that, the institutions will change their
methods to cause a decrease in office work volume of responding corporations and to improve thequality of evaluation with more standardized and harmonized rules.

This is even more expectedconsidering these new rules now require more intensified disclosure along with the worldwide trend,
which has become visible through the introduction of legal regulations and other de facto rules.
In addition, evaluation institutions are expected to accept “the Code of Conduct for ESG
Evaluation and Data Providers” released by the Financial Services Agency in December of 2022, and toundertake improvement in quality of ESG evaluation data they provide by undertaking the 6 principles
shown in the code.
(3) Expectation for Stakeholders who Play Major Roles in Rulemaking, including theGovernment
Stakeholders who play major roles in rulemaking, including the Government, business associations,expert groups, are asked to construct the circumstances where corporations disclose their integrated
information properly and will be evaluated in an appropriate manner. Harmonizing rules of several
standards of international organizations or states and regions is expected. Those stakeholders are
asked to participate in the international processes.
The time limit to disclose integrated reports is a major issue in rulemaking. The time period toxiii

disclose sustainability information will finally unite traditional time to make financial information publicin the medium and long term, or by the time business management and sustainability policies will befully synchronized.

Before the situation can materialize, the time period to disclose sustainability

information in a corporation should be predicted to require a significant amount of time.
The third party's guarantee rule is another important issue regarding sustainability disclosure.
The rule should consider suitable solutions which take into account the level to guarantee the qualityof information, as well as the need to rationalize the office work volume of corporations.
In addition, there should be further rulemaking or arrangements to support and promote small
and medium sized enterprises to enhance their actions to develop sustainability in society and theenvironment.

xivMember of CSR Committee of Business Policy Forum, Japan（the chair）
Tetsuyuki Kagaya

Professor, Graduate School of Business Administration,
Hitotsubashi University（the committee）
Yusuke Asano

Team Leader of Stakeholder Engagement Team, Corporate Sustainability & CSR
Department, Mitsubishi Corporation

Masahiro Ishino

General Manager, CSR Section, Sustainability Dept., Sony Group Corporation

Akihiro Inatsugi

Executive Director, Corporate Sustainability, Bridgestone Corporation

Kei KanaiManager, Sustainable Management Office, Sompo Holdings,Inc.

Yuuko Shiota

General Manager, Sustainability Department,
ESG Promotion Department, MARUI GROUP CO.,LTD.

Hiroki ShinnoManager, CSR Section, CSR & Citizenship office,Panasonic Holdings Corporation

Tomoko Hasegawa

Managing Director, Keidanern (Japan Business Federation)

Haruo Hatanaka

ESG Strategy Specialist, ESG Strategy, ESG Division,
Kao Corporation

Shigeki Matsui

General Manager, CSR Operations Dept., Toray Industries,Inc.

Chikako Miyata

Executive Vice President, Group CSO（Chief Sustainability Officer), Director of
Corporate Sustainability, ANA HOLDINGS INC.

Mariko Yamada

Head of Corporate Purpose and GDB Division, Sustainability Unit,
Fujitsu Limitedxv

（Observer）
Toyokazu Nagamune Director, Corporate Accounting, Disclosure and CSR Policy Office, Ministry of
Economy, Trade and Industry
Miki Nogami

Assistant Director, Corporate Accounting, Disclosure and CSR Policy Office, Ministryof Economy, Trade and Industry

Hidemi Tomita

Managing Director, LRQA Sustainability K.K.

（Secretariat）
Kenyu Adachi

Chairman of the boad of Directors, Business Policy Forum,Japan

Tetsu Fukuoka

Director general, Business Policy Forum,Japan

Akira Kitabatake

General manager, Planning & research div.,Business Policy Forum,Japan

Hiroaki Konishi

Senior researcher, Planning & research div.,Business Policy Forum,Japan

Takeshi Nozawa

Researcher, LRQA Sustainability K.K.／
Managing Director, EcoNetworks Co.

Minami Tateyama

Researcher, LRQA Sustainability K.K.／
Researcher, EcoNetworks Co.

Shiho Funahara

Researcher, LRQA Sustainability K.K.／
Researcher, EcoNetworks Co.

/END/

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