Developments at the United Nation’s 27th climate conference will have far-reaching implications for financial professionals and businesses worldwide. Susan Rossney digs into the details COP27, the international climate summit, concluded on 20 November after two weeks of negotiations. While last year’s COP saw the International Financial Reporting Standards (IFRS) Foundation announce an International Sustainability Standards Board (ISSB), this year had less reporting-specific news.  One headline was the commitment by CDP (formerly the Carbon Disclosure Project) to incorporate ISSB’s IFRS S2 Climate-related Disclosures Standard into its global environmental disclosure platform—another step towards greater comparability and coherence of global standards and reporting. On a macro level, though, COPs have a huge importance for businesses worldwide. ‘COPs’—Conferences of the Parties—are summits attended by the nearly 200 countries which have signed the United Nations Framework Convention on Climate Change (UNFCCC).  At COPs, these countries discuss their existing efforts and future plans to deal with climate change and its effects. Any new agreements made at COP tend to be named after the host city, e.g. the ‘Paris Agreement’ (2015), the ‘Glasgow Climate Pact’ (2021). This year we have the ‘Sharm el-Sheikh Implementation Plan’, named after the Egyptian city in which it took place. This plan set up a new loss and damage fund for vulnerable countries most severely impacted by the effects of unpreventable climate change (floods, drought, desertification, and land loss due to rising sea-levels). The inclusion was a landmark moment in global climate politics as it acknowledged that the world’s richer countries—and biggest carbon emitters—are responsible to the developing world for the harm caused by global warming. How to finance this loss and damage, specifically how finance would be channelled to the developing world, was a dominant and contentious topic at COP27. The scale of the finance required is truly enormous. At least $2 trillion a year will be needed by developing countries to enable them to transition from fossil fuels, invest in renewable energy and other low-carbon technology, and cope with the impacts of extreme weather. The final figure is likely to be multiples of that. Although COPs have been criticised as political talking shops, divorced from the lived experience of most citizens and businesses, they have a considerable impact. Close to 200 countries gathering to debate a global response to climate change keeps alive an issue that affects all citizens, albeit not equally.  It restates the importance of holding global warming to the levels agreed upon at the Paris Agreement—i.e. well below 2°C and preferably 1.5°C above pre-industrial levels (we are currently at 1.1–1.2°C). What is decided at COP filters down to organisations through legislation and policy, like Europe’s ‘Fit for 55’ package, Ireland’s Climate Action Plans and sectoral targets, and through investors’ continued demands for projects that are aligned to climate targets to meet their own portfolio requirements.  Ireland will come under continued pressure from the EU to act on measures such as developing our renewable energy and tackling our carbon emissions. Changes are required across all sectors, and all businesses, including SMEs, will have to make changes. Accountants, as their trusted advisers, will need the knowledge to help businesses adapt and thrive in this new reality.   Susan Rossney is Sustainability Officer at Chartered Accountants Ireland

Moves underway globally to reform the audit process should reduce the likelihood of corporate collapses and internal fraud, writes Paul Kilduff Whenever there is a sudden company collapse, a shocking fraud or a financial scandal, the details make the front pages of the newspapers and news sites, and the shareholders and the public rightly ask: ‘And where was audit?’ Work is presently underway to address this vital question. In the US, the Public Company Accounting Oversight Board (PCAOB) oversees the audits of public companies in order to protect investors. There are quality control standards in place covering personnel, ethics, engagement performance and client acceptance, but the chair of the PCAOB accepts that these are outdated and do not adequately promote audit quality.  The PCAOB’s plan is to close the gaps by updating the rules for how firms should police their audit work. It recently issued its 2022–2026 Strategic Plan for public comment, so these planned developments will take time. In the UK, the Financial Reporting Council (FRC) develops and maintains auditing and assurance standards. The most recent annual report from the FRC on the quality of audit in the UK found that 33 percent of all audits reviewed needed improvement. This was an unacceptably high number of audits, according to the accounting watchdog. Of the 147 audits inspected by the FRC, 41 required ‘further improvements’ and seven needed ‘significant changes’.  The Institute of Internal Auditors believes the FRC findings underline the need for urgent audit reform and robust measures designed to increase audit quality. One solution is to put the FRC audit regulator on a statutory footing with enough new legal powers to do its job effectively. Sadly, the problem of audit quality remains, and it has impacted the work of the auditor for years. High-profile scandals When Nick Leeson single-handedly destroyed Barings Bank, I was an internal audit manager with HSBC in London. My first reaction was one of relief that the calamitous events had not occurred at our bank. My second reaction was one of concern that the bank’s internal audit team and external auditors in Singapore had not discovered the £869 million trading loss hidden by Leeson. Leeson outfoxed audit. When internal audit arrived from the London head office, he met them on the chaotic trading floor of SIMEX, he told them he was very busy, and he avoided the office and all meetings with the auditors. When external audit from a Big 4 firm asked him for a confirmation for a large bogus option trade, Leeson manufactured the confirmation from a page of headed bank notepaper, using scissors, glue, and a photocopier. The audit team was none the wiser as to his deceit. Wirecard AG, a Munich-based electronic payments provider, once valued at €24 billion, went kaput in 2020. The accounts of this listed company included a bank deposit in Singapore of €1.9 billion, which simply did not exist. The Financial Times reported that, instead of obtaining confirmation of the deposit directly from the bank, the auditors relied on documents and screenshots provided by a third-party trustee and by Wirecard staff.  This audit failure happened not once, but at three successive year-ends from 2016 to 2018. I qualified as an ACA many years ago, but even then, obtaining independent confirmation of bank deposits was covered in day one of audit training. The head of the German financial watchdog BaFin was critical of the audit work performed and said the Wirecard scandal was ‘a complete disaster’, adding: ‘It starts with looking at a complete failure of senior management and it goes on to the scores of auditors who couldn’t dig up the truth.’ In the UK, there are recent examples of previously robust companies, which had been audited by leading UK accounting firms, suddenly failing. The demise of retail chain BHS, travel agency Thomas Cook and construction giant Carillion had a major impact on the UK economy, costing the taxpayer millions. The Institute of Internal Auditors believes that stronger governance and audit can help to prevent such collapses occurring in the future, protecting jobs, pensions, investors and incomes. Necessary reform The necessary improvements to audit must deliver on several fronts. The audit profession must ensure that it attracts capable individuals with strong product knowledge, an inquiring mindset, and a character strong enough to deal with any management obstruction.  The improved audit approach must be documented in revised policies and procedures, which must be ingrained in audit work. Quality Assurance functions must be set up or enhanced in firms to ensure standards are met. The cost of implementing these audit reforms must be reasonable to bear, whether the auditor is in an internal audit function, a Big 4 audit firm or a small audit firm with a more limited budget. There is an expectation that audit reform must use all available technology to improve the quality and scope of audit work. In the past, audit sampling may have been acceptable, but with advanced Computer Assisted Audit Techniques (CAATs), 100 percent auditing is the likely optimal solution. Global audit reform must also consider the changing nature of work, and the associated risks. Few auditors thought three years ago that so many employees would now be working on a hybrid basis, relying on remote systems access for client verification, payments processing and other critical tasks.  When reform does arrive, there should be international convergence, so that the audit quality rules in the US, UK and other jurisdictions are consistent and align with international standards, thereby avoiding unnecessary differences and costly duplication that could weaken audit effectiveness.  In the meantime, accountancy bodies are providing new guidance to members.  New guidance  In the UK, the Institute of Accountants in England and Wales recently reported on the significant resources devoted to fraud-related activities within audit firms. It also acknowledged the public perception that auditors can and should be doing much more to deter and detect fraud and to prevent the unexpected failure of large companies due to fraud. It was Lord Justice Lopes who famously summed up the auditor’s duty in the case of Kingston Cotton Mills Co., where the company directors had fraudulently overstated the value of stock, by proclaiming: ‘An auditor is not bound to be a detective. He is a watchdog, but not a bloodhound.’  Lopes opined that the auditor cannot be liable for any wrongdoings they had no reason to suspect were taking place, but that landmark legal judgement was handed down in 1896. The expectation placed on both internal and external auditors is significantly higher today.  The auditor is not specifically expected to search out any fraud or deception in their audit, but if there are warning signs that all is not well, the auditor must investigate these to reach a satisfactory conclusion regarding the audit opinion.  While writing my latest banking book, I researched the case of Joseph Jett, a former bond trader with Kidder Peabody in New York, who created $350 million of phantom trading profits on the bank’s computer systems.  The subsequent post-mortem report stated that the internal auditors learnt that Jett had booked billions of dollars of unusual transactions, but no auditor followed up on this anomaly. The auditor had to explain his work in court, as audit workpapers were produced with hand-written annotations without evidence of action. This is not a situation any auditor would wish to defend.  I also came across Sir Allen Stanford and his Stanford Financial Group, based in Antigua, which was later revealed to be a giant Ponzi scheme. His bank at the time had a value of $8 billion, but it was audited by a small Antiguan audit firm with just ten staff. This should never have been acceptable. When corporate disaster does strike, it is easy to point the finger at the auditor, but this is often unfair. Every auditor comes to work with the intention of doing a good job. The aim of audit reform is to assist and guide the auditor in their work, rather than to make their work more onerous. The global audit reform process is underway, and it must deliver improvements to reduce the likelihood of further high-profile corporate disasters, which damage the reputation of the auditor. In the meantime, the auditor at large would do well to maintain a healthy sense of scepticism.  Paul Kilduff B.Comm FCA is an author and banker, who has worked with HSBC, Bank of Ireland, Bank of America, Barclays and Citibank. His eighth book, Stupid Bankers: The World’s Worst Banking Disasters Revealed, is available exclusively on Amazon UK in paperback and Kindle format

Irish Government finances are in surplus and Ireland’s debt-to-GDP ratio has stabilised, so why are there calls for higher taxes? asks Dr Brian Keegan It’s hard to avoid concern fatigue setting in. What with the war in Ukraine, the cost-of-living crisis, the continued Northern political stalemate, multiple dire warnings amplified at COP27 over climate change and another possible COVID-19 surge—the list of concerns seems particularly endless at the moment.   Some time ago, the commentator Marc Coleman projected that population growth—and, by implication, skills growth—would drive prosperity in Ireland. Coleman’s ideas have been given additional credence by the current situation in the UK. Chancellor Jeremy Hunt’s November budget looks towards an extended period of economic stagnation. British productivity has not grown in line with government spending in recent years. In the moribund British economy, there is a record low level of people out of work while the number of job vacancies is at a record high.   There is a straightforward, one-to-one relationship between economic growth and the growth in tax yield, which permits more government spending without further borrowing. When the growth in gross domestic product (GDP) stalls, so too do the tax figures.   In his book The Best is Yet to Come, Coleman pointed out some of the links between more workers, growth and greater resources for public services and benefits. Though the timing was unfortunate (the book was published just months before the 2008 financial crisis), Ireland is now indeed in a better place, at least economically, than it has been for many years. Government finances are in surplus and the debt-to-GDP ratio, at around 50 percent, is back under control.   Unlike the British situation where a Budget bordering on the austere was required to meet existing public spending commitments, without an intolerably high borrowing requirement, the recent Irish Budget took a cost-of-living crisis in its stride, with grant aid against soaring energy bills for households and businesses alike being met through current tax receipts. Nevertheless, a narrative has emerged that the burden of taxation in Ireland will have to increase.   Why this should be the case is not always specified. There are unquestionably problems with housing, health, and education, but it does not automatically follow that these problems arise from underinvestment. At the time of writing, close to half a billion euros set aside in 2022 for local authority housing remains unspent. This points to management or capacity problems, not funding challenges.   The much-heralded report of the Commission on Taxation and Welfare has not had a huge impact on the political debate. This may be because it presents solutions in search of a problem. As research from the Irish Fiscal Advisory Council has pointed out, “its work was not framed around any specific shortfall in funding that needed to be filled. Instead, it was guided by a broad intention to generate additional revenue”.   Even government politicians, who are rarely scathing about the output of an expert group, which the government itself commissioned, were dismissive of the recommendations. Clearly, there are some areas of the economy where additional tax funding will be required, if not immediately, in the medium-term.   Unless there is an unforeseen level of immigration of people of working age, the ratio of workers to pensioners is going in the wrong direction. Climate change management, ironically being driven more by energy security concerns than global altruism, will come with a price tag. The sustained high corporation tax take may have peaked. In Britain, the urgent need for higher taxation has been unanswerable. In Ireland, there needs to be a clear business case for any form of new or additional taxation. We have enough to be concerned about without the prospect of unnecessary taxes. Dr Brian Keegan is Director of Advocacy and Voice at Chartered Accountants Ireland

Chartered Accountant Eamonn Hughes is playing a leading role in Bank of Ireland’s Responsible and Sustainable Business Strategy. Hughes tells Accountancy Ireland about the four-year plan and his goals as Chief Sustainability and Investor Relations Officer  Before joining Bank of Ireland Group in February as Chief Sustainability and Investor Relations Officer, Chartered Accountant Eamonn Hughes had a longstanding career as a sell-side market analyst with more than 25 years’ experience in capital markets and domestic banking.  Having worked most recently with Goodbody, the stockbroking firm, as Irish Banks and Insurance Sector Analyst and, before that, Head of Research, Hughes also had a clear view of the swift rise in environmental, social and governance (ESG) to the top of the financial agenda worldwide. “I could see that ESG was becoming hugely important in capital markets and the financial sector. The climate crisis, in particular, is a critical threat, but also a significant opportunity,” said Hughes. “For our planet, there is no Plan B, but the discussion about sustainability is not just about climate change. It is also about creating a more sustainable business model. Our vision at Bank of Ireland is to be the national champion in Ireland, to use our balance sheet and resources to drive positive change for a better, fairer society and improve the environment. “This gives me a very strong framework to think about my role, because, if we can deliver on our ESG strategy, we can ultimately deliver a more sustainable business model for all stakeholders and positive returns for investors. “The ESG agenda also involves regulators, so disclosure and risk management are very important—and there are reporting frameworks in place, but they are evolving very quickly. This is one of the challenges we face and is also why transparency and the availability of clear data is so important.  “With my background in capital markets, I can clearly see the mobilisation in capital, and I think the banking sector has a very obvious supporting role to play in society’s sustainability transition.” Investing in tomorrow Bank of Ireland published its Responsible and Sustainable Business Strategy in March 2021, a year before Hughes joined the group.  Bank of Ireland’s four-year Investing in Tomorrow strategy set out its own goals to support the green transition, alongside two additional pillars: enabling colleagues to thrive; and enhancing customers’ financial wellbeing. The Investing in Tomorrow green transition pillar included the setting of science-based targets aligning the bank’s lending portfolios with the Paris Agreement. The international treaty on climate change, adopted in 2015 at COP 21, set out a goal to limit global warming to 1.5 degrees Celsius, compared to pre-industrial levels. “Data is key across all three pillars, because reporting is essentially an output of what we are doing in support of climate change, colleagues, customers and the organisation as a whole,” said Hughes. “We need to focus on how we interact with our stakeholders internally and externally and, in my role, investors are obviously a key priority. As investors now have to produce more disclosures themselves, they will need to engage more with us in terms of what we are doing on our own ESG journey.” Clear reporting strategy How Bank of Ireland communicates with, and reports to, stakeholders on the progress of its ESG strategy is a priority for Hughes in his role as Chief Sustainability and Investor Relations Officer. “Ultimately, we need to explain how we are meeting the targets set out in our strategy, and it is incumbent upon us to develop the capacity and skill sets we need to support reporting and strategy delivery,” he said. “My role is to support in delivering across all three pillars, which involves a lot of data-gathering internally, particularly from a regulatory and reporting perspective.” Detailed progress reports on ESG will now be a core part of Bank of Ireland’s annual reporting cycle. “We need to be able to demonstrate clearly that we are creating a sustainable business strategy, enabling colleagues to thrive in the organisation and enhancing financial well-being among customers, in addition to supporting the sustainable transition,” said Hughes. “Transparency is hugely important. There are a lot of differentials in this space, so we need to standardise our reporting; to be able to explain clearly and cohesively what we are doing and why.” Commercialisation is becoming increasingly important as Bank of Ireland continues to implement Investing in Tomorrow, Hughes said. “Like many banks, we are in the commercialisation phase of our ESG strategy with the creation of sustainable finance solutions for, and increasing engagement with, customers. We are supporting and incentivising customers through competitive rates to buy or build an energy efficient home or to retrofit their home or business to make it more energy efficient.” Sustainable finance fund Bank of Ireland recently announced a €3 billion increase in its Sustainable Finance Fund, which will bring it to €5 billion by 2024. The fund covers green propositions, including mortgages, home improvement loans and business  loans.  Bank of Ireland’s inaugural standalone Responsible and Sustainable Business Report, published in June, tracked the progress of its ESG strategy in 2021. More than €1.8 billion in mortgages, home improvement loans and business loans had been drawn down from the Sustainable Finance Fund by the end of the year, the report stated. Thirty-five percent of all mortgages provided by the bank in 2021 were green, rising to 48 percent in the first half of 2022.  Bank of Ireland was also the largest provider of wholesale finance for electric vehicles in 2021, providing finance to 13 of the 15 car manufacturer franchises. The publication of the Responsible and Sustainable Business Report marked a significant “step-change in the tracking and transparency” of the bank’s ESG reporting, Hughes noted.  “Our stakeholders—including customers, shareholders, and regulators—are demanding far greater transparency as to how we are meeting our ESG commitments,” he said. “This report provides insight into our strategic approach, appraisal of our progress to achieve our purpose, and information on the key focus areas we plan to progress in the years ahead. Being clear on ESG, and showing how you are delivering what you sign up to, is now a commercial imperative for all lenders, including Bank of Ireland.” Science-based targets Bank of Ireland has also committed to setting science-based targets across portfolios and operations to align lending practice with the low carbon ambitions set out in the Paris Agreement. “We completed two successful green bond issuances in 2021, raising €1.25 billion with the capital used to finance green buildings, renewable energy projects and clean transportation,” said Hughes. “Thirty-five per cent of the mortgages we provided in 2021 were green and we have also launched a green mortgage product in the UK.” Bank of Ireland is providing finance for the development of at least 750 megawatts of renewable wind capacity across the island of Ireland. The bank is also in the process of decarbonising its own operations—reducing absolute emissions by 88 percent between 2011 and 2021. Social and governance Although supporting the green agenda is a major part of Investing in Tomorrow, the strategy also sets goals for investing in colleagues and enhancing customers’ financial wellbeing. “We recognise the supporting role we can play in Ireland’s response to the climate crisis, but the ‘S’ and ‘G’ are equally important when we consider ESG,” Hughes said. “We have a strategy to improve the financial wellbeing of our customers and to foster a financially inclusive society.” Bank of Ireland was, Hughes said, supporting customers to become more financially confident, while also working to simplify processes, so that the “financially marginalised have easier access to banking services.” Financial health and inclusion  Bank of Ireland is one of 28 banks around the world that have signed the Commitment to Financial Health and Inclusion published in December 2021 under the United Nations Principles for Responsible Banking (PRB). A first-of-its-kind initiative aimed at promoting universal financial inclusion and health in the banking sector, its launch closely followed the publication of the UN’s PRB Collective Progress Report. The report identified financial inclusion as the third most pressing sustainability challenge facing signatory banks, behind climate mitigation and adaptation. “This UN initiative is particularly important in an environment in which we have a cost-of-living crisis and customers are facing major challenges in the medium- to long-term. The question for us is, ‘how can we deliver this particular skill set and support our customers at a time when they really need it?’” said Hughes. Bank of Ireland is also helping customers to “live more sustainably” with the recent announcement of the roll out of bio-sourced debit and credit cards. Launched in October, the initiative will over time replace all plastic debit and credit cards issued by the bank, to help support the reduction of single-use plastic. “If we are to live in a more sustainable way, we need to do things differently, including through our everyday banking. The introduction of bio-sourced cards is a very practical way we can help our customers to reduce their environmental footprint,” Hughes said. “As a bank, we are working very closely with our customers on the sustainability transition. As they deliver, we deliver. It is a symbiotic relationship and an exciting place to be.”  

Martin Moloney, Secretary General of the International Organisation of Securities Commissions, outlines his priorities for the year ahead Irishman Martin Moloney is Secretary General of the International Organisation of Securities Commissions (IOSCO). Headquartered in Madrid, Spain, the international body brings together the world’s securities regulators and is recognised as the standard setter for the securities sector worldwide. IOSCO develops, implements, and promotes adherence to internationally recognised standards for securities regulation, working closely with the G20 and the Financial Stability Board (FSB) on global regulatory reform. Accountancy Ireland sat down with Moloney to discuss his goals, priorities, and concerns for the year ahead. Q: What are the biggest risks facing investors around the world right now and how is IOSCO working with securities regulatory agencies to address these risks? The risks that investors face never really change. There are some fundamentals. You can hire the wrong advisers, you can pay them too much, you can choose the wrong times to get in or out of markets, and you can invest in the wrong things. These risks are the core risks for investors, and they have been for as long as financial markets have existed. The difficulty is that financial markets are constantly changing. New asset classes like crypto are emerging, and there are new ways in which intermediaries work on your behalf, but also earn fees for themselves. This creates new risks for investors. Also, as we saw from recent events in the UK, markets can go into sudden periods of stress and crash. We do our best, working with others, to try to make markets as resilient as they can be, to ensure that these episodes are few and far between insofar as we can. These are the big issues facing us currently. Really, it all comes down to integrity—being able to trust the price you see when you invest in the markets and ensuring that you are not being fooled by people who are trying to cheat you out of your money. Q: You have described the rise of cryptocurrency as an area fraught with risk, requiring “a lot of work” on the part of regulators. Can you tell us more? There is no doubt in my mind that we have reached a turning point in relation to crypto. This is not because of the so-called ‘Crypto Winter’. The value of crypto might go up or down, but that is not really the issue. The point that we all have to observe and recognise is that crypto has survived and has continued to survive over a number of years. It is reasonable to assume that it is not going away and, therefore, it has to be regulated. I am delighted to say that, since I have joined IOSCO, the organisation has moved forward with its policy in this area and is now very quickly developing a set of guidelines for the market on how different jurisdictions should regulate crypto and the common standards they should aim to achieve in doing so. We are seeing a number of regions, notably the United States and Europe, now moving towards developing legal frameworks. I have no doubt that this is far from the end of the matter, however—it is just the beginning. Crypto is going to evolve and change as people get on top of the technology and new opportunities emerge. The most important thing we must all keep an eye on here is the outcome for the investor. In the first years of crypto, a huge number of people lost money through fraud. Other people, who may not even have been aware of it, lost money through market manipulation, insider trading and various other dubious activities we know well. Very often, this has been driven by conflicts of interest. If you dig down into the principles articulated by IOSCO for financial markets many years ago, you will find us warning against many of the phenomena we are now seeing in crypto markets. Theft does not change. It might happen in a different location, but theft is still theft. Bad management is still bad management, no matter where it happens. It is up to us to re-articulate these very simple, but really important, ideas and explain how they can apply in the crypto space. It is also important for the crypto sector itself to come up with good solutions and technologically enabled solutions, so that its work can be supervised and that it can reach the same standard of regulation as the rest of the financial sector. There are a number of individuals, I think, within the crypto sector who have come to understand that they need to move positively towards a strong regulatory framework in order to bottom out their businesses and remain stable. If we do not start to see self-regulation within the crypto sector, then I think we will see more jurisdictions banning crypto. It is just not sustainable over the medium term to try to avoid the regulatory frameworks that apply to everyone else. It is one thing to see yourself as a different asset class. It’s quite another to see yourself as an entirely different industry when you are effectively doing the same thing. Q: So, you do believe that cryptocurrency has a long-term future provided that there is robust regulation in place across the board? I think there is some potential for this asset class, but it is going to become more challenging. I don’t have a crystal ball, so I try not to predict the future. I see some very interesting new products developing in the decentralised finance space, and I wonder if this is ultimately where crypto is going to go. We are all used to a simple model in which you get quite non-functional assets like Bitcoin being traded and people making money primarily out of the bubbles in Bitcoin. The use cases for crypto continue to be worked on extensively, however. So, every time you have one of those bubbles, what is actually happening is that money is being raised to allow people to invest in new potential use cases. There are now so many use cases that have come and gone, and failed ideas that have been touted and promoted, you could be forgiven for thinking that there are no use cases left for crypto—but that is probably wrong. I think people will continue trying to figure out good use cases for crypto. I don’t think it’s going away any time soon. Q: You have spoken recently about the greenwashing risk facing securities regulators—what can be done to address this? We put out a couple of reports in 2021 where we looked at the greenwashing issue in great detail, listing the different ways in which this phenomenon occurs. We had to acknowledge, however, that it is not just about ‘evil intent’. Activity that might be described as greenwashing often happens, because the market structures needed to adequately support sustainable finance are not yet in place. Sometimes, you do get people who are frankly trying to fool investors by issuing misleading information, but, equally, the markets as they stand are just not built for sustainable financing. Having identified the problem and having asked the industry to work as hard as possible to reduce the amount of greenwashing that now exists, we have had to acknowledge that the system itself needs to change. Regulators have to do it, governments have to do it, standard-setters have to do it—to create a better system to achieve true sustainable finance. If, for example, I am proposing an investment that has a strong impact in terms of reducing carbon emissions, I should get a better price on the market and a better investment price for that security than someone who comes to market with a security for a carbon-emitting project. We want the market to be sensitive to the environmental impact of different proposals, companies and products. They must have access to information that is reliable; that has been independently audited; and that brokers can bring together to compare stocks from different parts of the world and determine differential pricing based on their impact on the environment. Getting all of this right would be an incredibly hard job, so we have broken the job down into a number of elements. We will be progressively working on putting these building blocks in place over the next couple of years, in order to make sure that the process can be regulated and that people who don’t do the right thing can be held to account on the basis that they could have done the right thing and chose not to. Q: As the move to establish standards for environmental, social and governance (ESG) reporting gathers pace, what is your take on the current efforts underway? We have a very close relationship with the International Sustainability Standards Board (ISSB). We effectively oversee its work and, if we like what it is doing, we will endorse its standards, and recommend those standards to individual regulatory securities agencies around the world, so that these jurisdictions can adopt the standards as they see fit. The fundamental issue we are all facing is that a sustainable financial marketplace has to be a global marketplace. If you have fragmentation and you don’t have the same information sets available in different parts of the world, you cannot have a true comparison between different securities, and capital cannot flow to the best projects. It is no good for anyone if Europe is pristine, while the rest of the world is working in a different way. What happens in the Amazonian rainforest matters to all of us. Capital, therefore, has to flow from those places where it is abundant, such as Europe and North America, to locations in which the opportunities exist to do the right thing. What IOSCO has said to the countries we work with around the world is, “do this any way you want, but use the ISSB standards as a baseline and build your own approach on that foundation”. Put simply, you can do all you want in the ESG space, but unless we have a common core, we cannot create a global financial market that will bring about any real change. Q: Can you tell us about the work you are doing with the Financial Stability Board in relation to investment funds? This is a very big project for us. Investment funds are a crucial mechanism all around the world for people to get access to markets on a collective basis, but they can have a concerning impact on markets in periods of crisis. We have been doing work in this area since 2016. We have done a lot already, but there is more to do. A major focus for us next year will be trying to make sure that the kind of funds both ordinary individual investors and the more risk-averse institutional investors choose are safe in a crisis. We are trying to ensure that, if you are investing in a product that is riskier, it will be clear to you that it is more difficult to get your money out of it; that these kinds of investment funds are not the equivalent of a bank account. This is a typical example of what we do, but there are lots of others. We do a lot of work on cyber-resilience, and we are also very interested in the change in the behaviour of retail investors and their vulnerability to scams. One of the problems we face at the moment is that, while technology has made it easy or cheap for people to invest in the markets, it has also made it easy or cheap for fraudsters to get at many thousands of people. We need to figure out better and better ways to stop these fraudsters and prevent them in their designs. About Martin Moloney Prior to joining IOSCO as Secretary General in September 2021, Martin Moloney was Director General of the Jersey Financial Services Commission and, before that, he worked as a Special Adviser on Risk and Regulation to the Central Bank of Ireland, where he served for 16 years, previously heading up the Markets Policy, Markets Supervision, and Legal and Finance Divisions. Moloney began his early career working in industry with Barclays Bank and Bank of Ireland in London, before returning to Ireland to work with the Department of Justice, Department of Finance, the Irish Competition Authority. Born in Dublin, he has a master’s degrees in Business Law and Economic Policy, both from Trinity College Dublin.

Elaine Coughlan, one of Ireland’s most successful venture capital investors, tells us how her experience in accountancy and audit led to a high-flying career in technology Since qualifying as a Chartered Accountant and cutting her teeth in audit in the 1990s, just as the first wave of tech entrepreneurs in Ireland were beginning to access US capital markets, Elaine Coughlan has carved out an illustrious career in venture capital. Dublin-born Coughlan is the co-founder and joint Managing Partner of Atlantic Bridge, the global growth technology fund with more than €1 billion in assets under management across nine funds. For Coughlan, her career is a testament to both her training in finance and the power of human connection in business the world over. “Atlantic Bridge has over 35 companies we have successfully sold or ‘IPOed’ and I am immensely proud of that,” she says. “The wins drive you on because you can see what’s possible and those Irish entrepreneurs become role models for the next generation. I’m proud of the assets we have under management, and that Atlantic Bridge now has people in Dublin, London, Paris, Munich and Palo Alto in Silicon Valley. That is a truly global footprint, and it really helps us to scale our companies.” Early connections Coughlan credits the professional connections she made at an early stage in her career at Ernst & Young with setting her on the path to professional success. “Some of the people I met back in the nineties, our clients at the time, were hugely influential on me,” she says. Among those clients was Smurfit (now Smurfit Kappa), already a long-established industry leader in paper packaging production. “I was seconded from Ernst & Young to work with Smurfit when it was probably the number one Irish company in terms of market capitalisation and really blazing a trail in Irish business,” she says. “It is still a phenomenal company today, but for me at that time, Smurfit was just so ambitious and far-reaching in its approach to mergers and acquisitions, and the capital markets. I worked on fundraising and acquisitions with them and had early exposure to some of their senior executives—people like Gerry Fagan, their then-CFO.” Coughlan forged other crucial connections at the time with Bill McCabe, founder of CBT, the e-learning group, and Iona Technologies’ Chris Horn. “Bill and Chris were the first entrepreneurs in Ireland to float tech companies on the Nasdaq and, if you look at what they had in common with Smurfit, it was really that they were all entrepreneurial,” she says now. Coughlan would leave Ernst & Young to join Iona ahead of the company’s Initial Public Offering. “I knew then that practice probably wasn’t for me. That’s not to say that you can’t be entrepreneurial in practice, but the cut and thrust of the tech business pulled me in,” she says. “I remember traveling over to the US with CBT back in 1993 and that was it for me. There was such a sense of possibility.” Coughlan went on to join Parthus, the semiconductor IP company co-founded by Brian Long, and the pair formed an abiding partnership, co-founding both Atlantic Bridge and GloNav, the GPS company acquired in 2007 for $110 million. “All these years later, I am still in business with the same people, and they were the people that had an impact on me starting out. They were the people I learned from and the people who were generous with their time and their knowledge, and willing to give me experience and opportunities,” she says. For young Chartered Accountants starting out in their career, Coughlan has this advice: “Above all else, nurture your connections. These young professionals will already be well-qualified and proven in their ability and resilience, because training to become a Chartered Accountant is challenging in itself,” she says. “The question they have to ask themselves is ‘what differentiates me beyond that?’ It comes down to being able to combine your knowledge with strong relationships in ways that bring about better outcomes.” As Coughlan sees it, building solid sustainable relationships in business isn’t simply a case of networking and ‘transactional interactions’. “It’s about finding people who share your values and ethics, whose accomplishments and abilities you admire, and who have the ability to lead and inspire. You always have to be thinking long-term, not just about your next connection on LinkedIn,” she says. Supporting start-ups Coughlan’s commitment to supporting start-ups and advancing Ireland as a leading hub for technology development was recognised at this year’s Irish Accountancy Awards, at which she won the prize for outstanding contribution to the profession. “When we started Atlantic Bridge in 2004, we wanted to help tech companies in Ireland to scale successfully. Ireland is a small island and a small economy, so there are two things tech companies here need to scale—they need to move beyond the island to reach customers and they need access to capital,” she says. “We wanted to cross the Atlantic to the US, because it is the largest market in the world in terms of customers and capital markets. At the time, Ireland had a VC market of less than €100 million. It’s 10 times that size now, but back then, it was really small.” The primary focus for Atlantic Bridge today continues to be “deep tech” innovators in the business-to-business (B2B) space. “We’re not after instant gratification or overnight success. These are businesses with defensible research-intensive technologies that are primed to scale when the time is right,” says Coughlan. “Our investors are patient. They are looking for strong long-term returns, and we are very proud to have reached the stage where we have raised nine funds, because that is not an easy thing to do in this industry.” Coughlan warns, however, that we are entering a “new investment cycle”, in which surging inflation, rising interest rates, and the risk of recession, are all making investors more risk averse. “The outlook for Atlantic Bridge in the short-term will be cautious and tactical, but beyond that, we are optimistic and deeply committed to the technology trends we are seeing today that will make a difference in the future,” she says. “A lot of the technologies we’re investing in now are in climate change action—low-power, low-carbon enablers—and in medical technology and the digitisation of health, where we can meet unmet needs. We’re focusing on technologies like Artificial Intelligence and semiconductors—the fundamental building blocks that will be built into new products over the next three to five years.” Research and development As the economy enters uncertain terrain, Coughlan is urging the Government to continue investing in research and development (R&D). “Ireland has to continue to invest in R&D. We need to hold our nerve in continuing to invest in the best and brightest people and start-ups, because they will drive the next generation of growth,” she says. “Today, we are investing about 1.25 percent of GDP in R&D. We need to get that up to between 2.5 percent and three percent. The future economy will be knowledge-intensive and that requires knowledge-intensive people.” Coughlan is equally committed to the advancement of her profession, and proud of her own achievements as a Chartered Accountant. “The ‘bean counter’ perception is one too many people have of accountants, but I would probably be the last person you’d ask to do a P&L statement,” she says. “I can tell you if it is right or wrong though, because I understand the numbers and what they mean. I can interrogate and interpret any set of numbers and that is because I am a Chartered Accountant. All business now is run on data and our profession gives us a really strong grounding in using data to make decisions—and that is the future. “There are doors that are opened to you when you train as an accountant. You learn about process, structure, deadlines, and relationships. All of these skills are incredibly important. “You come out of it battle-hardened and resilient, and with all these options: to stay in practice; to focus on technical work; to go into consultancy; financial services; or business and entrepreneurship. The opportunities are phenomenal.” Growing up in Beaumont in north Dublin in the recession-hit 1980s, however, Coughlan had envisaged a different career for herself. It was a chance encounter that set her on the path to accountancy and a high-flying career in venture capital. Early career path “I was good at numbers at school and I studied accountancy for the Leaving Cert, but I wouldn’t say I was destined to be an accountant. I fully recognise now that it was my accountancy and audit experience that led me into the technology industry, but my real interest growing up was people,” she says. “I wanted to work in a people-focused environment, so I applied to study marketing and languages at DCU and went for a summer job at a small accountancy firm to keep me going in the meantime.” Coughlan didn’t get the summer job, but she was contacted by her interviewer and urged instead to consider accountancy as a full-time career. “It was 1989, unemployment in Ireland was something like 15 percent and so many people were emigrating to find work in the UK and the US,” she says. “I didn’t know anything about becoming a Chartered Accountant, but I wrote to the Institute and was offered a training contract with Ernst & Young. Here was this opportunity to have my fees paid and earn a wage with guaranteed work in a really tough economy. It was a great deal. That’s why I always say to this day, ‘what’s meant for you won’t pass you by’.”