Julia Rowan answers your management, leadership, and team development questions I manage a large team which is split into three functions, each with a Team Leader, but I end up doing a lot of the TLs’ work.  When there is an issue to be resolved, they will summarise it in an email and ask ‘what do you want me to do?’. I have spoken to them about this several times, but they keep doing it. There are words, and there are actions. And ‘actions speak louder than words.’ A lovely pattern has been established here: they ask you for guidance, you tell them they shouldn’t—but you give it anyway. And off we go again. The longer this has been going on, the longer it will take to change it. You may need to be patient while a new pattern is established. Email is a lovely place to avoid conversation, so the first step might be to reply to these messages with something like ‘Delighted to talk this through with you—when suits?’. Then have a few great questions ready: ‘what’s important in this situation?’, ‘what are your options here?’, ‘how can I support you with this?’. These questions encourage the TLs to think through the issue themselves, while you offer support. If this does not change the pattern, you could reflect on what might be sustaining their dependency on you and ask questions about that: ‘We’ve talked about this a few times, and I notice you are still coming to me for direction. I feel that your instincts are good and I’m wondering what’s preventing you from suggesting a way forward / tackling this yourself….?’. If you meet with your three TLs as a group—which I hope you do regularly—you could make this an agenda point, encouraging them to report in on successes and challenges, supporting them in advising each other, etc.  Remember, they need to create a new pattern with their team members too. Two members of my team have had a dispute and are refusing to talk to each other or work together. It arose out of a simple enough miscommunication with ‘fault’ on both sides. I have been acting as a go-between in the hope that the situation would resolve itself, but it hasn’t. Team meetings have become very difficult as nobody speaks. Often there is huge hurt behind conflict – so go tenderly in this space. You could begin by reflecting on ‘what is reasonable?’. Is it reasonable for two adults (in their roles, on their salaries) to refuse to engage with each other in a way that other people must pick up the pieces? I might also reflect—as you are—on whether I am colluding with them and keeping the dynamic going. You could talk to them about the impact their behaviour is having on you and the rest of the team. Have a reasonable ‘ask’ worked out in advance. Offer support, or to get support (e.g. from HR), but be led by the requirements of the role. Make sure to notice, and give feedback in response to, even small improvements. But, be prepared for one, or both, to move on. If you read one thing... Turn the Ship Around – A true story of turning followers into leaders  by  David Marquet. Marquet was made commander of a submarine he had not been trained to run and had to rely on his crew—a huge challenge in a ‘command and control’ culture. You can find him on YouTube—‘What is leadership with David Marquet’. I recommend the animated Mindspring version. Julia Rowan is Principal Consultant at Performance Matters, a leadership team and development consultancy. To send a question to Julia, email julia@performancematters.ie

The Pensions Authority expects all schemes to be fully compliant with IORP II requirements by 1 January 2023. We speak to three members about their experience with the changing pensions landscape Barry Prendiville Director Nolan & Partners We are currently setting up a Master Trust arrangement for all employees, including those who are not currently in an existing pension arrangement. We were prompted to accelerate this process due to IORP II and, to a lesser extent, auto-enrolment. It has been a slower process than we would have liked, but it offers a suitable long-term solution. At a high level, there are benefits to IORP II. However, I do believe that one-member arrangements should have been exempt from the requirement to comply with IORP II. Trustee responsibilities have become much more onerous. Where possible and practical, it makes sense to outsource this risk to suitably qualified pensioneer trustees. I am concerned that transferring pension benefits accrued by employees to a new Master Trust may be a tedious process. Given prevailing volatility in financial markets, any transfers need to be efficiently managed. Pensions remain a mystery to a large cohort of the population. The myriad of pension arrangements in place and the technical jargon used by most in the industry confounds and confuses people. Education is key, and I think that retirement planning should be taught at school and university level. While a positive step overall, I have some concerns that auto-enrolment, once introduced, may lull scheme members into a false sense of security. It is debatable if the proposed contribution level will be adequate to meet long-term income requirements in retirement. It will also put an additional cost burden on businesses in particular sectors that were most particularly exposed to COVID-19. Overall, auto-enrolment should be seen as a positive development, but it must be clearly communicated and explained in jargon-free language. Damian Cooper Head of Private Clients and Investments Acuvest The burden of increasing regulation is unlikely to reverse any time soon. For the last two years, my organisation has been helping clients understand, develop, and implement updates to their policies and procedures to ensure their pension and investment governance complies with the new regulatory requirements. It is important to remember that, while Master Trust solutions offered in the marketplace are being strongly promoted based on their ability to help companies and trustees overcome a short-term regulatory hurdle, they are a relatively new development in the Irish market and, as such, are largely unproven in many respects. While the Pensions Authority is pushing for Master Trusts to retain the ability to independently select its key service providers in the interests of its members, it remains to be seen how easy it will be for a Master Trust to decide that the interests of members are best served by retaining a key competitor to provide scheme investment or administrative services. I think that IORP II will likely lead to a higher level of governance across the pensions industry, which is definitely to be welcomed. The transitionary period into a new regulatory regime is always challenging, and participants, regulators, professional service providers and advisors will all need time to adapt and find a new status quo that works effectively and efficiently. I think it would have been preferable to see if the regulations could have been implemented in a phased manner, starting with the largest schemes and well-resourced entities such as Master Trusts, which would then have allowed industry providers to develop best-practice models that the Pensions Authority could have assessed and then implemented, potentially in a scale-adjusted manner across the rest of the industry. It is important for people not to get too distracted by the industry focus on regulation and vehicles, as these will get sorted over time. The key thing to remember is that making pension contributions early and often is a valuable, tax-efficient way for people to save for retirement. Employees should take maximum advantage of any contributions available from their employer, remember that tax relief on contributions cannot generally be backdated, and start saving as early as possible. Bernard Barron Pensions Audit Partner Mazars Due to the recent legal enactment of the IORP II Directive in Ireland, there are very substantial additional pension administration and governance obligations and costs being incurred by pension schemes. Based on these expected additional costs, several smaller defined contribution pension schemes have already decided to wind-up and transfer their pension scheme arrangements into a Master Trust. The Irish Pensions Authority has set out strict criteria for establishing Master Trusts in Ireland, which is to be welcomed. There will be relatively few Master Trusts set up, and organisations expect to gain the advantage of lower administration costs through the economies of scale that these large Master Trusts will have compared to the smaller pension schemes. In addition, the Pensions Authority has set out stricter requirements for pension scheme trustees, and Master Trusts will have the benefit of pension specialists acting as trustees, which is not necessarily the case at present. Due to the increased size and importance of pension scheme arrangements for employees and employers, the increased governance and accountability requirements under this Directive are welcome. However, the currently proposed Pensions Authority requirements is imposing very significant obligations and costs on smaller and one-member pension schemes, which are not being allowed to implement on a proportionate basis or with a viable alternative. The IORP II Directive has substantial additional pension administration, governance obligations and costs. This may cause organisations to re-consider the pension benefits that they incur or plan to incur. In the context of the growth in the ageing of the Irish population, the Government’s plans for implementing pension auto-enrolment in the short- to medium-term are welcome. However, much more clarity and detail are needed about how this is going to work, particularly in relation to cost and funding by employees and employers. At a national level, the future increased costs and funding of pensions for those pensioners who are reliant on state pensions and for the public sector is a continuing concern.

The use of malicious software to extort small businesses is on the rise in Ireland as global criminals seek out easier prey. Arlene Harris reports Ransomware. At a time of rising awareness of cyberthreats and the need for adequate safeguards across all business functions, including finance, ransomware is emerging as a growing threat for even the smallest operators. And, according to Dr Richard Browne, Director of the National Cyber Security Centre (NCSC), ransomware is “here to stay”. A form of extortion “as old as the hills”, ransomware is a type of malicious software designed to block access to a computer system until a sum of money is paid, explained Browne. What is new in the field is a concerning rise in the number of ransomware attacks recently aimed at small- and medium-enterprises (SMEs), a segment of Irish business so far largely unaffected by this particular cyberthreat. Indeed, a statement issued in August by the NCSC in conjunction with the Garda National Cyber Crime Bureau warned SMEs that, in a noticeable shift in ransomware tactics, hackers were turning their attention away from big business and government entities to focus instead on smaller businesses. “This trend has been observed globally and Ireland is no exception, with several businesses becoming victims of these groups in the past number of weeks,” said Browne. “A number of different business models are typically used, which involve encryption of a victims data by a threat actor, whether that is a criminal gang or a lone individual.” Greater threat in newer tactics Cybersecurity has, by and large, kept pace with criminal activity online until now and experts are quite adept at dealing with established ransomware practices—which typically involve a threat actor making contact with a victim, and requesting a key to unlock or decrypt the victim’s information. The threat landscape is evolving, however, leading to newer ransomware tactics that are more difficult to defend against. “Recently, human-operated ransomware has been developed, which means there is a person in the loop with more advanced techniques,” Browne explained. “They hack into a system—or across it, in many cases—steal data and seek to encrypt an entire IT system. The old-fashioned ransomware ‘drive-by’ (often caused by clicking on a link) is not a massive threat as it can usually be stopped by anti-virus software, but human-operated ransomware is categorically a risk for businesses of any kind.” Behind the rise of human-operated ransomware are often established, integrated and organised criminal enterprises that operate “at scale and at speed” globally, Browne said. “This is very much a global market, with the ‘bad guys’ targeting IP addresses anywhere in the world,” he said. “Over the years, many have been heavily compromised, but, while their organisations have been broken up, the individuals involved are still criminals and they are still capable of conducting cyberattacks, so they tend to simply reform and go after smaller targets.” Criminals target smaller players While large corporations are more likely to have the financial means, technology and expertise to handle a sophisticated ransomware attack, the same cannot be said for many of their smaller counterparts. “Because of changes in the ecosystem, smaller companies are getting hit more often than bigger entities, which can afford to be prepared, are more resilient and much more able to deal with incidents when they occur,” Browne said. “So, [the hackers] are going after SMEs and individual companies, which might only net them a smaller ransom, but they are much more likely to be paid. “It is also easier. They don’t have to spend as much time navigating systems and don’t have to be as careful as they would with high-end security systems, so they can target more small companies. “Solicitors’ offices, for example, will often have sensitive data on file—so it is in their interest to pay not to have it released. “The criminals may also gain access to customer money sitting in a firm’s account over a weekend (for lodgement the following week), which makes them a target for other activities, such as fraud. “Of course, there have been some very high-profile attacks too, such as the Colonial Pipeline attack in the US, which took out a piece of physical infrastructure without actually damaging or physically affecting it. JBS Meats is another one and the HSE is probably the most well-known here in Ireland.” These ransomware attacks are happening “all the time”, said Browne, both in Ireland and elsewhere. “Just today, I’ve had reports of about 15 new ransomware attacks in Europe over a few days. We, in Ireland, are relatively lucky as we are something of a small player, but we are at risk nonetheless.” While criminal gangs are set to continue making money by hacking into IT systems, harvesting data and selling it on, or blackmailing companies into paying a ransom, Browne advises that there are steps SMEs can take to protect themselves from ransomware attacks. Effective security measures “We appreciate that many business owners are understandably nervous about the threat ransomware poses, but some straightforward security measures can be put in place to ensure that an organisation’s data and systems remain secure,” he said. “Some SMEs won’t have an IT system as it will be outsourced, so the first thing they need to do is to ask their vendor how prepared they are for dealing with this kind of thing.” At the very least, businesses should have two-factor identification on all of their online accounts—whether it be Facebook, Gmail or a financial services package. “It sounds simple, but, if everyone did this, it would dramatically reduce the amount of damage done,” said Browne. “After that, I would encourage firms to ensure their vendor has proper offline back-up and, internally, to decide that—on a specific day of the week—someone will be tasked with taking the external hard-drive, making a copy of it, and putting it away. “This way, they will have a secure offline system so, if they need to restore it after an incident, it can be done without taking down the company. “Beyond that, they should have an up-to-date antivirus system and ensure any vulnerabilities are patched up.” Making these provisions is becoming more essential for SMEs because ransomware, as Browne puts it, “isn’t going away”. “People need to be vigilant and governments need to do more to deal with it and ensure these guys don’t get paid, so that, eventually, it will become less prevalent,” he said. “That’s not going to happen overnight. It is going to continue to be an issue for some time. We all need to be aware and take steps to keep our systems secure.” For more advice and information, visit ncsc.gov.ie or garda.ie/en/crime/cyber-crime

The Corporate Enforcement Authority Act 2021 overhauled the legislative framework for businesses in Ireland, impacting company directors, corporate restructuring, share premiums, and the distribution of profits. Dee Moran and Lilian Halpin dig into the details Although most of the provisions of the Companies (Corporate Enforcement Authority) Act 2021 (CEA Act) came into effect in July of this year, the focus thus far has centred primarily on the Corporate Enforcement Authority, the successor to the Office of the Director of Corporate Enforcement. There is far more to this Act, however, including a number of interesting updates the Companies Act 2014 (CA 2014). The introduction of the CA 2014, followed the wide-ranging overhaul, modernisation and streamlining of company law in Ireland. It was inevitable, however, that there would be some gaps and omissions in the new regime. The CEA Act introduces provisions aimed at remedying some of these anomalies. While further remediative legislation is expected in the future as the legislature continues to review and refine existing law, in this article, our focus will be the amendments included by the CEA Act impacting company directors, company re-organisation, share premiums, and the distribution of profits. Requirement for directors to provide PPSN details Section 35 of the CEA Act introduces the requirement for directors of Irish registered companies to provide details of their Personal Public Service Number (PPSN) to the Companies Registration Office (CRO) when completing certain documents. While this section of the CEA Act has not at time of writing commenced, it is intended to help protect against identity theft, specifically concerning the set-up of new companies that have used bogus director details and addresses or individual names without permission. The UK’s register of businesses and their directors is famously so weak on information verification that both “Donald Duck” and “Adolf Tooth Fairy Hitler” have been listed as directors of companies. Other difficulties faced prior to this amendment included obtaining a list of directorships for an individual from the CRO as individual director filings may use different versions of the person’s name, such as ‘Eddie’ and ‘Edward’, or the person may have changed address. The introduction of the requirement to file the PPSN as a unique identifier should, therefore, make this process easier. It is important to note that there will be an alternative procedure in place for those directors who do not have a PPSN. The CRO is currently reconfiguring its online portal to accommodate this new requirement and it is expected that Section 35 will commence in the first quarter of 2023. Its implementation will not be without challenge and the CRO has set up a working group to identify issues and try to resolve them to ensure a smoother transition. The CRO is also reviewing the technical challenges that arose after the commencement in 2019 of the Registry of Beneficial Ownership (RBO). The RBO is “the central repository of statutory information required to be held by relevant entities (corporate or legal entities incorporated in the State) in respect of the natural persons who are their beneficial owners/controllers, including details of the beneficial interests held by them.” It is hoped that the CRO will take the learnings from this review and incorporate them into the new system. It is important that potential technical challenges in relation to PPSNs are resolved before section 35 of the CEA Act commences. If they are not properly considered, there is the potential for delays in the filing of changes to directors or to the filing of annual returns, and the possibility of late filing fees or the loss of audit exemption. Therefore, companies and practitioners alike need to be aware of these changes and to begin to make plans to ensure that the appropriate information is understood and updated. Three party share-for-undertaking transactions The provision for three party share-for-undertaking transactions within corporate reorganisations was introduced in section 91 of CA 2014. This section recognised that it is not uncommon for companies to enter into a transaction where an undertaking, part of an undertaking, or a subsidiary, is transferred to a new company, which then issues shares as consideration to the shareholders, rather than to the transferring company. Subsection 91(4) of CA 2014 has, however, been interpreted by certain practitioners to mean that such a transaction could only be validated by either a summary approval procedure or a special resolution confirmed by court—even where the company has adequate distributable reserves to underpin the transaction. The CEA Act has added subsection 91(4)(c) to clarify that such a transaction can take place without the summary approval procedure, or court approval, in circumstances where the company has distributable reserves that are at least equal to the value of the undertaking transferred. The use of a company’s share premium account Under the Companies Act 1963, a company’s share premium account could be applied for several purposes, such as application by the company in writing off preliminary expenses, or in writing off the expenses of, or the commission paid or discount allowed on, any issue of the shares or debentures of the company. Equivalent provisions were not included in CA 2014 in what was assumed to be an unintended omission by the drafters. This reduced the flexibility of companies in relation to the use of share premiums, causing difficulties. A company wishing to effect a transaction which had been permissible under the Companies Act 1963 was now, for example, obliged to carry out a formal reduction of company capital by the summary approval procedure in CA 2014. This meant that the company might have incurred additional expense, such as obtaining a statutory auditors’ report, or that it might have had to make a court application in circumstances where such a move would not previously have been required. In addition, because the summary approval procedure is not available for the reduction of company capital in the case of public limited companies, such a company had to apply to the High Court in order to reduce its company capital so it could write off such costs and expenses. To remedy this, section 14 of the CEA Act inserts a new subsection 71(5A) into the CA 2014. This subsection restores the status quo that had existed prior to the introduction of the CA 2014, with the exception of permitting its use for the issue of shares at a discount. Restoration of exceptions to “distribution” definition In the since repealed Companies (Amendment) Act 1983, company legislation provided for two exceptions to the rule that a company should not make a distribution except out of profits available for this purpose. They were: a reduction of share capital by paying off paid up share capital; and extinguishing or reducing all or part of a member’s liability on shares that are not fully paid up. These exceptions were not included in CA 2014 and it is worth noting that these omissions were considered and not unintentional. Both exceptions were included in draft legislation but were subsequently removed before CA 2014 was enacted. The effect of the omission of the exceptions meant that a company had to find distributable profits to be able to lawfully reduce or extinguish the liability of members in respect of any unpaid shares, or to pay off paid-up capital. The explanatory memorandum to CA 2014 refers to the omission of the exceptions as providing consistency in the legislation. However, in 2017, the Company Law Review Group—a statutory advisory expert body that advises the Minister on the review and development of Irish company law—was of the opinion that the omission of the two exceptions in the CA 2014 did not take into account the new and detailed regime in that legislation for the reduction of share capital, i.e. requiring either a court order, or to be effected under the summary approval procedure with contingent director liability. It recommended that the two exceptions which had been omitted from CA 2014 be reinstated. Section 19 of the CEA Act has now amended section 123 of CA 2014 to reinstate these exceptions. Planning for the changes ahead It is encouraging that improvements and clarifications continue to be made to legislation, particularly in company law where omissions or inadvertent changes from older legislation have resulted in difficulties in practice. Chartered Accountants Ireland continues to work with its technical committees to identify areas where further clarity on aspects of company law would be beneficial and to make representations to the relevant department outlining those areas so that they might be considered for future legislation. Dee Moran is Professional Accountancy Lead at Chartered Accountants Ireland and Lilian Halpin is Technical Manager at Chartered Accountants Ireland

Investors are asking if it’s safe to invest again. Cormac Lucey explains why they might want to hold off for now “Is it safe?” That was the question asked of Dustin Hoffman in the movie “Marathon Man” as he was being interrogated while strapped into a dentist’s chair by Laurence Olivier (playing the role of an on-the-run Nazi war criminal), expertly reimagining our worst dentist nightmares. Much like Hoffman’s position, equity markets have become a nightmare. Investors keep asking themselves whether it is safe to invest again or whether this bear market has longer to run. Jeremy Grantham, the veteran investor, wrote an article on GMO.com in late August warning that the “current super-bubble features an unprecedentedly dangerous mix of cross-asset overvaluation (with bonds, housing, and stocks all critically overpriced and now rapidly losing momentum), commodity shock, and Fed hawkishness.” He concluded that we haven’t yet seen the bottom. Having pumped vast amounts of liquidity into the world economy to stave off the deflationary effects of the pandemic in 2020, central bankers were shocked by the firm inflationary response. They responded by tightening monetary policy – the usual precursor of recessions. It’s important to note that this move pre-dated the Russian invasion of Ukraine with its resultant economic disruption, and even more important to note that the conflict in Ukraine has fundamentally changed the rules of the economic game we had become used to. Zoltan Pozsar of Credit Suisse has written that, in recent decades, “the EU paid euros for cheap Russian gas, the US paid US dollars for cheap Chinese imports, and Russia and China dutifully recycled their earnings into G7 claims.” The problem is that global supply chains work only in peacetime, “but not when the world is at war,” Pozsar notes. While Russia is currently being forcibly disentangled from trade with the west, China may decide to voluntarily and slowly remove itself to avoid the shock of aggressive disentanglement should its cold war with Taiwan ever turn hot. Key monetary indicators remain recessionary. In the US, money supply is growing at a slower pace than inflation, meaning the real quantity of money in the economy is falling. The yield curve has just inverted, meaning short-term (two-year) rates of interest exceed long-term (10-year) rates. For several decades, this has been an unerringly accurate harbinger of recession. Unfortunately, central banks remain in tightening mode for those wanting equity markets to lift as inflationary pressures prove to be more than just “transitory.” They say, “Don’t fight the Fed” (the Federal Reserve) and with good reason. Caution is warranted. There are other challenges facing equities. On previous occasions over the last two decades, the depth of downturns has been eased by the fact that not all large economic blocs have been in recession at the same time. In the wake of the Global Financial Crisis, when the western world was in deep recession, strong growth in China helped ameliorate the global impact of the recession and accelerate its ending. Today, all major economic blocs are simultaneously threatened by recession, which risks making this recession deeper and longer. What might signal an equity market bottom? I’ll be looking for a combination of value, investor sentiment, and a change in central bank behaviour. Share prices would need to drop sufficiently to be reasonable value. In 2000 and 2007, this required price drops of the order of 50 percent or greater. Speculative sentiment among investors would need to be replaced by the cold fear that characterises true market bottoms and central banks would need to replace tightening with easing. A halting of central bank tightening would certainly trigger considerable euphoria. But, having been too slow to tighten, central bankers cannot risk their diminished credibility by taking their feet off the monetary brake before inflationary pressures have been well and truly suppressed. Remember: the Nasdaq crash kept deepening two decades ago, even after the Fed had started aggressively cutting interest rates. So, is it safe? I don’t think so. Cormac Lucey is an economic commentator and lecturer at Chartered Accountants Ireland

The absence of a global baseline for reporting sustainability-related information is a concern for many, as the number of signatories to a global call-to-action on the matter demonstrates, writes Fiona Gaskin In late August, 65 companies, investors, and professional accounting firms from around the world added their voices to the call for standard-setting efforts to more closely support a global baseline for reporting sustainability-related information. All were signatories to a statement issued jointly by the International Federation of Accountants, World Business Council for Sustainable Development, and Principles for Responsible Investment, seeking to establish greater compatibility between the concepts, terminologies, and metrics in use in current draft standards for sustainability reporting. The statement acknowledged the important work of the International Sustainability Standards Board, US Securities and Exchange Commission, and the European Commission, together with the European Financial Reporting Advisory Group, in their efforts to advance sustainability reporting. The number of organisations supporting the call for the convergence of standards demonstrates, however, that the absence of a global baseline for reporting sustainability-related information is a concern for many corporates, financial institutions, and professional services organisations. The problem is very real. When various jurisdictions and standard-setters issue concurrent, but differing, standards, the users of those standards are left with varying frameworks, which can be costly and inefficient to interpret and implement. These efforts, while well-intentioned, can create confusion by adding more noise as reporting multiplies, but with different standards and objectives. A fundamental question for those setting standards and regulations is the question of whether or not reporting should be focused on information useful to investors (i.e. the enterprise value), or information useful to a wider group of stakeholders (i.e. the impact value). Enterprise value primarily focuses on the impact of environmental, social and governance (ESG) issues on business—in other words, how does the world affect the organisation? Impact value focuses more on the impact the organisation has on the world around it. Both enterprise and impact value offer information that can help to hold companies accountable for their actions—whether that is to maintain or create value, or to minimise negative impacts on the planet and society. Indeed, it is possible to argue that there is really no practical difference between these two values, and that the exposure draft of the International Sustainability Standards Board’s general disclosure requirements standard already provides a few good examples. This is because it is reasonable to expect that a business operating in a way that has a negative impact on the planet and its people will—in the short-, medium- and long-term—have a negative impact on the business itself and, therefore, on its enterprise value. In the long run, which is where sustainability standards focus, enterprise value and impact align. We can see first-hand that the proposed range of emerging standards are already proving to be a challenge for corporates. To start, there is the difficulty in simply gaining clarity on the reporting landscape—what has to be reported on, and by when. Once this has been established, the need arises for an exercise in understanding the crossover between reporting obligations—in the area of metrics, for example. These requirements then need to be assessed against what the organisation is actually doing and reporting. This last step typically results in an action plan which requires time and resources to address the underlying actions. While the statement calling for stronger alignment of regulatory and standard-setting efforts around sustainability disclosure has wide-ranging support, those creating the regulations and standards will ultimately need to continue to collaborate and respond to the call to action. Given that we are at the infancy stage of sustainability reporting when compared to financial reporting, it would seem like such a wasted opportunity to create complexity when standardisation and transparency are what is needed. Fiona Gaskin is Environmental, Social and Governance Leader for Assurance and Reporting at PwC Ireland