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How we collaborate with Vodafone on Nossa Data’s Corporate ESG Disclosure Product

Nossa Data first started receiving product feedback from Vodafone in 2020 to build our Corporate ESG Disclosure Product. As one of our early clients, Vodafone has been key in helping us build a product that companies can love. Our team interviewed David Irish and Lena Mistry, both members of the Vodafone Investor Relations team. The pair share their experience on working with Nossa Data as well as what it is like working on ESG for a large publicly listed company, in our latest blog series. 

1. What is your role and what led you to work in ESG?

David: I'm a Senior Manager in the Investor Relations team, having joined the team two years ago. As a chartered accountant by background, I spent my full career until that point in traditional finance roles, so when the ESG opportunity came up in IR, it was really exciting, as I knew I'd learn new skills, work with new people and on topics that personally I find very interesting.

Lena: I also work in the Investor Relations Team as a Manager, and I have a background in finance. In my previous Vodafone roles, I worked closely with other areas of the business that feed into ESG, such as the Sustainability team, the HR team, Cosec team, etc. I also have a personal interest in ESG having studied some relevant modules at university, so it seemed like a natural path.

“[Nossa Data] has the same passion for ESG that we have within Vodafone and when you've got a like-minded partner, passionate people who are willing to learn and tackle new problems, and go out there and look for best practice, working together is easy.”

2. What interested you most about using Nossa Data?

David: Two years ago, Julianne reached out to Vodafone’s IR director, who is always open to hearing new ideas and new approaches, particularly when it comes to data-driven insights. He pointed Julianne in my direction and we immediately had a very productive conversation. In particular, we talked about my desire to understand what ESG frameworks or initiatives our shareholders supported. Only a month later, Julianne and the Nossa Data team had developed it as a feature in their platform! That became an instant attraction because I could see that the team was agile and able to adapt to what we needed in the moment.

Lena: For me, I got to know the Nossa Data team during the WDI submission process. It was so useful as it’s a great tool to input our submission in, it has everything we need. On top of that, it’s great to be able to use a platform that not only solves a problem for us, but also through which we can give feedback to help the development as well. 

“What are the questions companies should ask when deciding to respond to a new ESG Framework?
1. “Who’s asking for it? 
2. “How does it differ from what we are currently disclosing?” 
3. “Do we have the expertise to respond?”
4. “How relevant is it to my sector?” 
5. “Is it voluntary or mandatory?”

3. What has been the most surprising thing you’ve learned about working in ESG as a large listed corporate?

David: Anyone who works in the ESG space knows that it’s an all-encompassing acronym that touches lots of different parts of the business, not just Sustainability, IR, or External Affairs. What strikes me is how much passion there is across various teams for ESG initiatives. They may not know what the acronym means, but they’re still working towards our ESG strategy and leading the charge. That passion ultimately translates into action. Then the question is, ‘are you disclosing what you’re doing?'

Lena: Following on from what David said, it’s the amount of ESG work that we actually do that we don't publicly disclose. We therefore think very hard about what we disclose and are always assessing what’s new, what’s important and what could be disclosed.

4. That is an interesting point you raised, Lena, that a lot of work is not disclosed externally. How do you manage internal communication to get a topic into the public disclosure realm?

Lena: When we identify something that could be published, we work with our internal stakeholders to mutually agree whether it is important. From an IR perspective, it's often an educational process to showcase the value add of making certain information public. As a second piece, we also look at what other corporates are disclosing and how that information is presented. 

David: I completely agree. The other thing that is important is that we are acutely aware that our colleagues put a lot of hard work into our disclosures. Unfortunately, I think that for many teams, it can be hard because they don't necessarily receive feedback. They may think: “ I've worked really hard on that disclosure or ESG theme to get it published in our Annual Report, but I don't know who's reading it or what impact it has. As a result, Lena and I make a special effort to show colleagues that their work is valued. 

  1. If we receive ad hoc feedback from investors, such as ‘I particularly like this element in the disclosures or that was really good’, we will go back to the team and make sure they're aware, so they know their hard work is being seen. 
  2. We will also try to give them data points. i.e. how many times has the TCFD report been opened? How long is the TCFD report typically viewed or which sections are more popular? How many people were looking at the Annual Report? 
“What we like most about working with Nossa Data is the fact that they take the feedback on and implement it very, very quickly.” 

5. How does technology, like Nossa Data, help improve your ESG workflow processes?

David: A really good example is the shareholder register analysis that I mentioned earlier; a great example of when we worked with Nossa Data to produce insights that would only be possible if you spent a huge amount of time. Furthermore, it’s not just the insights, but also the speed and accuracy at which you provide value. Looking at Nossa Data today, we have the ability to see previous answers, best practice answers, our current answer and cross references to various standards. If I were to do without Nossa Data, I’d need about six or seven windows open on my screen. It would make it very difficult and maybe I wouldn’t even look at these resources. 

Nossa Data also helps with internal collaboration, we’re working with a lot of different people across the organisation, many of whom are not in traditional ESG or IR teams.

Lena: I would agree with that. For me it’s the different elements that we have when completing our answers, it’s so much faster and more efficient for us now. 

“Thinking back to two years ago when we first responded to the WDI, we used Excel and it was not ideal in terms of ease of use, being able to coordinate everyone’s answers and just keep track of it all. The Nossa Data platform is a night and day difference between what we had before.”

6. When deciding whether to report on a new framework, what are your key criteria?

David: First it's ‘who's asking for it?’. Is there demand for yet more disclosures against a potentially new reporting standard? Are your peers adopting that framework as well? If there's no demand and your peers aren’t adopting this, that suggests that there's no appetite there. 

Second is ‘how does it differ to what you're currently disclosing?'. All reporting standards look at different areas and they have slightly different methodologies, but there's quite often overlap. If you're already disclosing 80% of the questions of a new framework, you may only need to disclose an additional 20% to complete this new framework. Finally, the third question is ‘do we have the expertise to respond?’. There are going to be some questions or topics within reporting frameworks that maybe Vodafone doesn't yet have the expertise, nor people internally working on the particular topic because of the current state of the business operations or strategy.

Lena: I’d add to that, ‘how relevant is it?’ to the sector or to our company. Is it voluntary or mandatory? These questions drive whether it’s worth the extra 20%of effort or not. 

“On Nossa Data’s platform today, we have the ability to see previous answers, best practice answers, our current answer and cross references to various standards. If I were to do that outside the Nossa Data platform, I would need about six or seven different windows open on my screen.” 

7. In 2021 Vodafone published its first ESG Addendum, what led to that decision?

David: To clarify, the first time we actually published an ESG Addendum was in the year before FY20, but that was a very different look and feel as it was a short PDF report. The first time we published an ESG Addendum in Excel or spreadsheet form was in 2021. The reason we have a separate addendum is because Vodafone stopped publishing a standalone sustainability report in FY19, not because sustainability wasn't a core part of our strategy, but because we moved and integrated the content into the Annual Report. However, with that move we realised there was still space for an addendum with extra data points. Sticking to a PDF didn’t feel like the best solution for our stakeholders. 

8. Vodafone is typically seen as a top ESG responder. What is something you are particularly proud about improving?

Lena: The Annual Report is a team effort and as David mentioned, we don't have a separate sustainability report. We receive a lot of great feedback from our investors on our full disclosure suite, including the Annual Report. Our disclosures hopefully show how important ESG is to Vodafone and our strategy, including our purpose, and key factors within E, S, and G. It's a really proud moment when one of your investors says you've done a great job with your disclosures.

David: It's the breadth of disclosures that I'm most proud of. We try very hard to make sure we're not distracted by individual ratings, because those are the opinions of one organisation. We look more broadly across our disclosures and across a broad range of ESG rating agencies. Vodafone is scoring quite highly across the board, but they're all measuring slightly different things. To me that suggests that we're disclosing the right things and that what we disclose is useful for our stakeholders and investors. I'm not saying there are no more areas that we can improve, but it does suggest that we're taking the right approach and if we continue with this approach, we'll continue to provide information that our stakeholders need.

9. What most frustrates you about the way the ESG market is today for corporates?

Lena: One thing that is quite frustrating is the number of perceived controversies.  We are a large global company that operates and partners in a lot of countries, and as a result of that, we're more open to negative newsflow. This can be quite frustrating, especially if we're compared to the sector which includes companies that don’t operate in such a large number of countries. 

David: For me, it’s the tick box nature of some elements of ESG ratings or reporting standards. That leads to an assumption that if you don't disclose something, you don't do it. If we disclosed everything that we do or don’t do, our disclosure would quickly become unwieldy and less helpful.  A recent example is where one rating agency has marked Vodafone down for not having a commitment to regularly publish climate reporting. However, in the UK, TCFD reporting is now mandatory for Vodafone, so we are left thinking, why do we need a specific and public commitment? On top of that, Vodafone was reporting against the TCFD recommendation before it became mandatory, so we've obviously got the record. The other frustrating thing, which is also the most exciting part of ESG, is the pace of change. Yes, it's frustrating if you're a corporate because there's suddenly a new reporting standard and new expectations.  Still that also makes it exciting for people like us because we’re constantly trying to improve. You're not standing still and just repeating the same thing each year.

10. What has been your favourite thing about working with Nossa Data?

Lena: For me personally, it's the Nossa Data team’s open and friendly nature. It goes without saying that the tool is so helpful. You also take our feedback on and implement it very, very quickly. That's been extremely helpful for me.

David: On top of your agility, the fact that you are active listeners, and our suggestions get developed, it's your [Julianne’s] passion in particular. You have the same passion for ESG that we have within Vodafone. When you've got a like-minded, passionate partner, who wants to tackle new problems, and go out there and look for best practice, you really see added value.

11. What advice would you give to otherIR teams in regards to ESG?

David: I would suggest mapping out stakeholders’ expectations. It's not just about reporting, but the underlying action as well. Once you’ve mapped that out, identify your gaps and benchmark yourself against your peers. Your peer group is a really good place to look in terms of what people are talking about and what may be material in your sector. Most importantly, it's about bringing people with you. IR or any other team in the business cannot ‘do’ ESG on its own. Our responsibility is to speak to colleagues and explain the importance of these topics and issues from an investor perspective. Then, it’s about sharing the feedback and having an honest assessment in terms of how we can potentially improve our external perception and our underlying actions.

Lena: Don't try to do everything! See which standards and topics are important to you and your business and focus on those because it is ever changing. Do the ones that you want to do really well and then consider the next ones.

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