Chief Information Officers: What CSRD Will Mean for Your Role



As a Chief Information Officer, you play a pivotal role in steering your organization toward a more responsible future: across technology, privacy, and even sustainability. 


The impending EU Corporate Sustainability Reporting Directive (CSRD) isn’t just another regulatory hurdle: it’s a seismic shift in how businesses should approach sustainability reporting, and has implications for teams responsible for data, information, and technology infrastructure. 


Worldly has undertaken an extensive review of the full CSRD — here’s how we recommend that leaders in your role prepare. 


You may need new processes for data management. 

CSRD will require companies to have data on their material impacts, their environmental risks and opportunities, their related targets and goals — and on the progress made on driving improvement towards achieving those goals across  their entire value chains. Value chain data collection in a structured, efficient way will be a critical input to this process. 


For instance, while you may already be publishing a list of suppliers on your company website, CSRD requires that you collect and disclose sustainability data for suppliers across the tiers of your supply chain that help produce your final products. CIOs are in a unique position to help gather and disclose this additional information. Partners like Open Supply Hub can help you clean up your supplier master data, determine which other buyers that source at the same facilities to support greater collaboration, and provide a unique supplier ID that you can use  to link supplier information across databases. 


Similarly, as CIOs already know, supplier sustainability information is spread across many internal and external silos. Internal design and procurement systems often specialize in different product types. In addition, many companies have joined various external multi-stakeholder Initiatives to help them provide fuller coverage of social and environmental data — which may or may not be compatible with one another. All of this puts CIOs in the position of needing to aggregate and reconcile multiple datasets. 


As a first step, we recommend that CIOs begin by creating an “as-is” systems diagram that identifies existing sustainability and compliance data management systems for discussion with executive leadership. Through these discussions, CIOs can take the lead on creating a future ESG systems vision. Your IT data architecture needs to support importing data from various internal and external sustainability sources for data consolidation, analysis, and reporting. 


Existing social assessments and frameworks can support you. 

CSRD covers environmental, social, and governance measures. Within the social space, there are a number of third-party frameworks that can support your compliance efforts.


The Social Labor Convergence Program (SLCP) is a widely adopted and verified supplier self-assessment tool that reduces supplier audit fatigue while improving primary supplier data collection. Every CIO should study the relevance of SLCP to your industry and work with your executive team to make plans to implement SLCP as an important foundational step towards CSRD compliances on the social and labor topical standards. 


It’s also important that your business invest in making these frameworks relevant and usable. For instance, by now, almost every company has a supplier code of conduct. But when was the last time that code of conduct was reviewed and updated to account for the rapid changes in laws, regulations, and stakeholder expectations? While these supplier codes of conduct are often published as a supplier handbook, IT needs to translate these words into a set of mapping rules so that collected data can be scanned electronically and mapped to your supplier code of conduct — thereby automatically flagging out of compliance situations and creating corrective action plans.


These data management approaches can also present opportunities for collaboration with one’s suppliers. For instance, work with your key suppliers to put a worker-grievance system in place and recommend that they share this data with you in a machine-readable format. Develop the means to assign serious worker-reported issues to suppliers and your own company management for investigation and resolution. In addition to CSRD compliance, properly analyzed worker grievance data is a real time measurement that can help fill in gaps in periodic supplier assessments.


Pay attention to this changing landscape.

Going forward, it’ll be essential to stay educated on the rapidly changing expectations about social and environmental reporting. Beside the EU CSRD, new reporting laws are coming in different states and countries. We expect that the SEC will issue new reporting guidelines soon. While these government and financial governance regulations define legal and investment community reporting requirements, it’s important to recognize that consumers, customers, and employees also want to know what social and environmental targets you have set, and your progress towards them. CIO’s should benchmark companies that have successfully published credible social and environmental information for all stakeholders, to help you design your own future reporting framework.


The landscape of ESG technology offerings are also ever-growing. Savvy CIOs should plan their strategy around ESG carefully — understanding both short-term and long-term requirements, and choose technology partners with a successful track record of meeting emerging requirements, and with the leadership and experience to succeed. 


Here at Worldly, we are proud to support some of the largest and most innovative brands in apparel, footwear, and textiles. In 2023, we acquired Fair Factory Clearinghouse, which has 20 years of experience providing social and labor compliance tools to the world’s leading consumer brands and multi-stakeholder compliance organizations. Together, we provide the widest offering of environmental, social, and labor solutions available to the industry. 


Taking next steps

It’s important to remember that the end goal is not just reporting, but creating sustainable improvements in working conditions and reducing environmental harm. For Sustainability and IT teams with limited resources and time, a trusted technology partner will be essential. 


With industry-leading supplier assessment tools, and knowledge of the most important elements for a to-be systems sustainability environment, Worldly is here to help support your CSRD efforts with confidence. 

Get in touch today and learn how Worldly can support your compliance efforts.


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