The current implementation of Environmental, Social and Governance programs mirrors the implementation of compliance programs in the late 1990s.  It’s a bit chaotic and things are moving quickly, particularly ESG regulation development and enforcement.  I believe the number one concern you should have is your leadership’s perspective on ESG.  Not only has SEC just announced its first ESG prosecution, more regulations are coming.  Perhaps the biggest concern I have seen is leaders who think that ESG could get out of control from a budgetary or political perspective because of “ESG extremism”.  But like compliance in the ‘90s or financial accounting in the early 20th century, ESG programs can be run strategically and cost effectively. Leaders need a simple ESG plan like what we have been working on at Osprey.

Assessing your existing ESG activities, opportunities and risks is a clear first step.  That should be followed by the implementation of an ESG framework, a reporting program and buy-in from key stakeholders and leadership.  At Osprey we call this our ESG QuickStart Program.  We help you with your Materiality Assessment, Framework Construction, Reporting and Key Results. Leadership tends to be more supportive when there is a clear understanding of where we are now and where we are going.  This is particularly important for ESG because, as I have mentioned, some leaders are concerned about ESG getting out of control.

The ESG QuickStart follows a proven methodology, with clear outcomes and actionable plans.  It delivers:

Key Outcomes

  • An executive ready ESG Program proposal and supporting material
  • An ESG materiality assessment and a functional framework for your organization
  • Plan for organizational & key stakeholder buy-in for your ESG program

ESG QuickStart activities include:

Landscape Assessment

  • Engaging your team in working sessions to define and review ESG topics, and their relevance to financial and impact materiality.
  • Reviewing industry-specific SASB materiality map and other standards to understand applicability to your business sustainability topics and corporate culture.
  • Understanding your key stakeholders and their concerns.

Framework Construction

  • Driving organizational buy-in on your proposed ESG program.
  • Leveraging standards and regulations to define disclosure metrics.
  • Identifying and documenting operational areas of responsibility, topic and metric owners, and data.


  • Reporting your ESG results to shareholders, investors, creditors and other key stakeholders
  • Planning where to disclose (Annual Report, 8-K, 10-K Filings, separate ESG focused report, web based)
  • Determining what to disclose (metrics, modifications, omissions, qualifiers)


As I have mentioned I wish I had known all this when I co-founded the Health Care Compliance Association and the Society of Corporate Compliance and Ethics.  Things would have been so much easier.  That is what experience is all about.  Implementing an ESG program is so much easier with Osprey’s ESG QuickStart.  If you have any questions feel free to contact me or Joe Robichaud @

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