Consultation on proposed Framework for Sustainability Assurance

We refer to the consultation by the Advisory Committee on Sustainability Reporting (ACSR) on the proposed Framework for Sustainability Assurance (Framework) to enhance reliability of information disclosed under the National Sustainability Reporting Framework (NSRF). We welcome the opportunity to provide feedback on the Framework, having earlier contributed our perspective during the March 2024 consultation on the NSRF and the October 2024 consultation on Bursa Malaysia listing requirements on sustainability reporting requirements.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with 7,778 billion MYR at 31 December, of which 12.1 billion MYR was invested in the shares of 217 Malaysian listed companies.

As a long-term investor, we consider our returns over time to be dependent on sustainable economic, environmental and social development, as well as on well-functioning, legitimate and efficient markets. We are active investors in over 65 countries and require reliable, consistent and comparable sustainability-related financial information across global capital markets.

We strongly support the International Sustainability Standards Board (ISSB) as the global baseline of investor-focused standards for sustainability-related financial disclosures. The ISSB standards share the same conceptual foundations regarding, inter alia, materiality and relevance as the International Accounting Standards Board (IASB) financial reporting standards. Investors will be able to receive sustainability-related financial information that is concurrent, connected and complementary to financial statements. This is critical for us to formulate a holistic view of a company’s performance and prospects over different time horizons and inform our investment decisions, risk management processes and stewardship activities.

Corporate sustainability reporting should follow the same rigorous oversight standards that govern financial reporting, including final approval by the board of directors. To build investor confidence in sustainability-related financial information, this information must be maintained under governance and quality processes and standards equivalent to other market-facing corporate disclosures. An increasing number of companies are having their sustainability reports externally assured, with various jurisdictions implementing or exploring mandatory assurance requirements. We believe that external assurance is critical for enhancing the reliability of sustainability-related financial information to the same level as that of financial statements.

Please find in the annex our responses to the consultation questions. We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer

Jeanne Stampe
Lead Policy Advisor