Environment, Social and Governance (ESG)

Reporting Guide for Listed Companies

Based on Capital Markets Authority laws and regulations No. 136/2022

Published on: May 23, 2023

 Boursa Kuwait – ESG Reporting Guide

Contact us

Boursa Kuwait
Mubarak Al Kabeer Street, AlSharq, Kuwait
P.O. Box 22235 Safat, 13083 Kuwait
T: +965 22992000 F: +965 22440476

ESG & Sustainability

If you are seeking more information, please contact

Boursa Kuwait’s ESG & Sustainability Department at
[email protected]

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Table of Contents

About This Guide 4

Unified Direction for a Sustainable Future 4

United Nations Sustainable Development Goals 5

Growth of Corporate Sustainability 6

ESG Progress Throughout the Years 7

Why Should Your Company Report on ESG Issues? 8

Key Points to Address When Reporting on ESG 9

ESG Reporting Formats 10

Reporting Standards 11

GRI Standards 12

Recommended Sustainability Metrics 13

Environmental 13

Social 14

Governance 15

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 Boursa Kuwait – ESG Reporting Guide

About This Guide

Boursa Kuwait has developed this Environment, Social and Governance (ESG) reporting guide with the aim of
supporting Kuwaiti listed companies disclose on Environmental, Social, and Governance (ESG) issues and their
corporate sustainability practices, in order to meet the growing needs of various stakeholders, including investors,
customers, suppliers, and regulators for transparent and regular information. Boursa Kuwait has amended this
guide to fulfill the requirements of Article No. (1-17-3) of Module Twelve (Listing Rules) of the Executive Regulations
of the Capital Markets Authority (CMA), in compliance with Article (42) of Law number 7 of 2010 regarding the
establishment of the Capital Markets Authority and Regulating Securities Activities and its amendments, which
states that Boursa Kuwait shall prepare a comprehensive guide for Listed Companies to refer to when preparing
their Sustainability reports, and this guide shall be approved by the CMA.

This guide proposes an initial set of corporate sustainability indicators that are in line with the State of
Kuwait’s sustainable development ambitions as set out by the Kuwait Vision and the “New Kuwait 2035”
National Development Plan1 and Kuwait’s commitment to reach carbon neutrality by 2060. This guide is also
aligned with the Sustainable Stock Exchange Initiative (SSE)2 and the World Federation of Exchanges’ (WFE)3
recommendations, and is intended for all issuers listed on Boursa Kuwait, whereby applying all stipulated terms is
optional.

Boursa Kuwait recognizes that adopting performance and disclosure best practices with regards to corporate
sustainability will be unique to each company based on its own business model and sector. Listed issuers may
choose to look beyond this guide and explore comprehensive reporting frameworks or guidelines, such as the
Global Reporting Initiative (GRI)4 or the Integrated Reporting (IR)5 framework.

Unified Direction for a Sustainable Future

On January 30, 2017, the Government of Kuwait unveiled the country’s National Development Plan, branded as “New
Kuwait”6. Derived from the late Emir of Kuwait Sheikh Sabah Al-Ahmad Al-Jaber Al Sabah’s vision statement, the
Kuwait National Development Plan mobilizes development efforts across seven pillars with the aim of transforming
Kuwait into a financial, cultural, and institutional leader in the region by 2035. The seven pillars are also in line with
the United Nations Sustainable Development Goals (SDGs).

1 Kuwait Vision 2035 "New Kuwait" - Ministry of Foreign Affair (mofa.gov.kw)

2 Sustainable Stock Exchanges | (sseinitiative.org)
3 Welcome to the future of markets | The World Federation of Exchanges (world-exchanges.org)
4 GRI Standards English Language (globalreporting.org)
5 International <IR> Framework | Integrated Reporting
6 New Kuwait (newkuwait.gov.kw)

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United Nations Sustainable Development Goals

The Sustainable Development Goals (SDGs)7, also known as the Global Goals, were adopted by all United Nations
member states in 2015 as a universal call to action to end poverty, protect the planet and ensure that all people
enjoy peace and prosperity by 2030.

The 17 SDGs are integrated — that is, they recognize that action in one area will affect outcomes in others, and that
development must balance social, economic and environmental sustainability.

Through the pledge to “Leave No One Behind”, countries and companies have committed to fast-track progress
for those furthest behind first. The sustainable development goals cover a wide range of social and economic
development issues (poverty - hunger - health - education - climate change - gender equality - water - sanitation -
energy - environment - social justice.

Everyone is needed to reach these ambitious targets. The creativity, knowhow, technology and financial resources
from all of society is necessary to achieve the SDGs in every context sustainability will be unique to each company
based on its own business model and sector. Listed issuers may choose to look beyond this guide and explore
comprehensive reporting frameworks or guidelines, such as the Global Reporting Initiative (GRI) or the Integrated
Reporting (IR) framework.

7 THE 17 GOALS | Sustainable Development (un.org)

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Growth of Corporate Sustainability

The concept of corporate sustainability has been often associated with meeting the needs of the present without
compromising the ability of future generations to meet their own needs. In today’s environment, corporate
sustainability has become a strategic priority for companies in an effort to capture new opportunities, reduce costs
and maintain competitive advantage. The term ESG (Environmental, Social and Governance) is particularly used
by the investment community to describe the sustainability or environmental, social and governance issues and
the related risks and opportunities that investors take into account when looking to make an informed investment
decision.

Environmental issues look at how a company mitigates the environmental impact of its business operations. Social
issues look at how a company manages relationships with its employees, customers, suppliers, and the communities
in which it operates. Governance deals with a company’s leadership, audits and internal controls, shareholder rights
and executive remuneration.

Globally, ESG is becoming mainstream, as investors have widely adopted the evidence-driven view that companies
adopting corporate sustainability practices financially outperform their peers. There is growing indication that
suggests that ESG factors, when integrated into investment analysis, may offer investors potential long-term
performance advantages. Companies that embrace corporate sustainability are considered to be better managed,
more competitive, and highly equipped to anticipate and mitigate risks8.

Boursa Kuwait recognizes that it can play a crucial role in encouraging and advancing corporate sustainability
practices in capital markets, and effectively contribute to achieving the overall objectives of the Kuwait National
Development Plan, by creating a climate that is capable of attracting funds and encouraging sustainable investments.

Model Guidance on Reporting ESG Information to Investors: A Voluntary Tool For Stock
8
Exchanges to Guide Issuers | Sustainable Stock Exchanges (sseinitiative.org)

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ESG Progress throughout the Years

2012 In 2012, member states called on governments and stakeholders with the support of
the UN to develop models for best practices and facilitate action for the integration of
sustainability reporting

2013 In 2013, the UN’s Report of the High-Level Panel of Eminent Persons on the Post-2015
Development suggested that by 2030, all large business should be reporting on their
ESG impact.

2014 In 2014, the United Nations Conference on Trade and Development recommended
that all exchanges should provide guidance on reporting on sustainability factors to
companies listed on their exchange.

2015 In 2015, all UN member states adopted the United Nations 2030 Agenda for
Sustainable Development, launching the 17 Sustainable Development Goals. Also known
as the Global Goals, designed to be a “shared blueprint for peace and prosperity for
people and the planet, now and into the future”.

2016 In 2016, a legally binding international treaty on climate change, known as the
Paris Agreement, was adopted by 196 parties. It covers climate change mitigation,
adaptation, and finance. The agreement, the agreement aims to significantly reduce
global greenhouse gas emissions and limit the global temperature increase in this
century to 2 degrees Celsius while seeking to limit the increase to 1.5 degrees.

2017 In 2017, France enforces a mandatory requirement on institutional investors to report

on how ESG factors are taken into account when investing.

2018 In 2018, the One Planet Sovereign Wealth Fund is created to accelerate the integration
of climate change issues into the management of large, long-term and diversified asset
pools.

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Why Should Your Company

Report on ESG Issues?
Investor interest in ESG Investing

• Enhance your company’s ability to attract longer term investors, including major foreign institutional investors
such as pension funds. A large and growing proportion of assets managed globally are incorporating ESG
practices in their investment decision process. An example of global incorporation of ESG investing would be
the One Planet Sovereign Wealth Fund, which aims to increase the efficiency in global capital allocation towards
a sustainable, low carbon economy9.
• Effective analysis of relevant ESG factors has become a fundamental part of assessing the value of an investment
for many investors.

Profitability and Competitiveness

• Generate financial value for your company by identifying opportunities for cost savings, revenue generation,
and risk mitigation.
• Create a deeper understanding of your stakeholders’ needs, which could drive innovation and enhance market
differentiation and competitiveness.
• Evidence suggests that strong corporate performance on ESG factors correlates positively with improved cost
of capital and financial performance. and increase access to new capital for companies.

Risk Management

• Address reporting requirements for financially material factors and mitigate compliance risks related to
financial disclosure regulations.
• Enable management and board scrutiny of ESG opportunities and risks and promote company - wide alignment
with long-term shareholders’ goals.

Enhanced Reputation

• Demonstrate your company’s commitment to responsibly managing environmental, social, and economic
impacts.
• Enhance your company’s reputation by improving stakeholders’ perception of your company through reporting
related stakeholder engagements.
• Improve employee perception of your company, which will help to attract, retain, and motivate new and existing
employees.

Market Efficiency

• Ensure that your company’s key stakeholders have the relevant information needed to make informed decisions
about your company’s ability to create value in the

9 One Planet Sovereign Wealth Funds (oneplanetswfs.org)

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Key Points to Address

When Reporting on ESG
Understand and identify your audience

Different investors can have different information needs. Understanding the company’s top investors, understanding
what kind of investors the company would like to have and utilizing the feedback received from past engagements
with investors can be useful for recognizing investor’s information needs.

Understand and identify your materiality matrix

A company may have a number of reporting objectives, but what is important is the materiality and relevance of
the reporting. Identifying relevant issues can lead the company to understanding ESG material factors that have a
direct effect on it. It is also important to note that immaterial ESG issues can also be reported on, as they may be
relevant to the company’s operational or reputational performance.

Adopting Relevant Performance Indicators

Once a company has identified their ESG themes and materiality matrix, it can start disclosing specific performance
indicators to reflect progress. The indicators can be generic or industry-specific/company-specific. However, it is
recommended to use indicators that are widely accepted internationally. The Global Reporting Initiative (GRI), for
example, produces a set of indicators for corporate sustainability reporting that is adopted internationally.

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ESG Reporting Formats

Annual Report

Companies may integrate ESG issues into their annual reports, aiming to combine ESG disclosures along with
broader information about the company.

Sustainability Report

A standalone sustainability report, which is favored by most companies, the sustainability report provides a
company’s consolidated ESG content at a single location and addresses the relevant information needs of investors
and other stakeholders.

Integrated Report

An integrated report aims to provide insight about the resources and relationships used and affected by an
organization. The primary purpose of an integrated report is to explain to providers of financial capital how an
organization creates value over time. An integrated report may be prepared in response to existing compliance
requirements and may be a standalone report or be included as a distinguishable part of another report. It is a
concise communication about how an organization’s strategy, governance, performance and prospects lead to the
creation of value over the short, medium and long term.

If the company chooses to prepare and publish one of the reporting formats referred to, it shall publish the
report on the company’s website in accordance with Article 1-17-1 of Module Twelve “Listing Rules” of the Executive
Regulations of the Capital Markets Authority. The article states that the Listed Company may issue an annual
Sustainability report and publish it through its website. The report shall determine the impact of the company’s
activities on the environment, society, and the economy, as well as the company’s opportunities and risks associated
with those areas and how it manages them. The Authority shall be notified of the report, and it shall be published
on the website of the Exchange.

10 Global Reporting Initiative

11 The Sustainability Accounting Standards Board

12 About the CDP

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Reporting Standards
The complexity of ESG reporting is due to the lack of a standardized ESG disclosure framework, which makes it
complicated to compare and evaluate between disclosed ESG practices. However, different organizations have
begun setting the standard in different sections of the ESG universe.

Prominent Global ESG Reporting Frameworks:

The Global Reporting Initiative (GRI) The Global Reporting Initiative (GRI)10 is an international independent standard
organization that helps businesses, governments and other organizations
understand and communicate their impacts on issues such as climate
change, human rights and corruption. GRI standards are the most widely used
standards for reporting on ESG impacts globally and have been developed over
many years through multi-stakeholder contributions.
The Sustainability Accounting The Sustainability Accounting Standards Board (SASB)11 is a non-profit
Standards Board (SASB) organization founded in 2011 to develop sustainability accounting standards.
Investors, lenders, insurance underwriters, and other providers of financial
capital are increasingly attuned to the impact of environmental, social,
and governance (ESG) factors on the financial performance of companies,
driving the need for the standardized reporting of ESG data. SASB provides
industry-based sustainability disclosures about risks and opportunities that
affect enterprise value for 77 industries. These standards are part of the Value
Reporting Foundation (VRF) which merged with the International Financial
Reporting Standards (IFRS) Foundation in 2022.
Task Force on Climate-related The Financial Stability Board created the Task Force on Climate-related
Financial Disclosures (TCFD) Financial Disclosures (TCFD) to improve and increase reporting of climate-
related financial information. The TCFD provides an industry-driven, voluntary
framework to encourage consistent financial disclosures on
material climate related risks and opportunities, for use by investors,
lenders, insurers, and other stakeholders. In developing this framework, the
TCFD considered the material physical and transition risks, as well as the
opportunities associated with climate change and what constitutes effective
financial disclosures across eight key sectors.
The United Nations Global Compact The United Nations Global Compact is a non-binding United Nations pact to
encourage businesses and firms worldwide to adopt sustainable and socially
(UNCG)
responsible policies, and to report on their implementation. The Global
Compact requires companies to commit to a set of ten universal principles
concerning human rights, labor, environment and anti-corruption.
Carbon Disclosure Project (CDP) The CDP (formerly the Carbon Disclosure Project)12 is an international non-
profit organization based in the United Kingdom, Germany and the United
States of America that helps companies and cities disclose their environmental
impact. It aims to make environmental reporting and risk management a
business norm, driving disclosure, insight, and action towards a sustainable
economy.
The International Integrated The International Integrated Reporting Framework is used to accelerate the
Reporting adoption of integrated reporting across the world. An integrated report
is a concise communication about an organization’s strategy, governance,
performance and prospects. Presenting each topic in the context of the
organization’s external environment. Further developing the Integrated
Reporting Framework, the International Accounting Standards Board (IASB)
and the ISSB assumed responsibility for when the Value Reporting Foundation
merged with the IFRS Foundation in August 2022.
Based on Article 1-17-2 of Module Twelve of the Executive Bylaws of the Capital Markets Authority in compliance with Article (42) of Law number 7 of 2010 regarding the
establishment of the Capital Markets Authority and Regulating Securities Activities and its amendments, the information available in the Sustainability report must be clear and
accurate, and the report must cover the most important issues of environmental, social, and economic impact in a way that enables stakeholders to evaluate the company’s
Sustainability level during the report’s period. The following points shall be taken into consideration when preparing the report:

• The report shall be prepared according to one or more of the international Sustainability reporting standards.
• Describe the scope of the report and the basis for its determination.
• Determine the company’s most important topics of environmental, social, and economic impact, and engage stakeholders in the materiality assessment process of those
topics and describe the method followed in the assessment process.
• Describe the method and procedures followed in dealing with each of the Sustainability topics that were determined in the materiality assessment process mentioned in
item (3). The company may seek external assurance to enhance the report’s credibility, provided that the assurance report shall be included in the Sustainability report.

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GRI Standards
GRI (Global Reporting Initiative) is an independent, international organization that helps businesses and other
organizations take responsibility for their impacts, by providing them with the global common language
to communicate those impacts. The GRI Standards the world’s most widely used standards for sustainability
reporting.

The GRI Standards are a modular system of interconnected standards. They allow organizations to publicly
report the impacts of their activities in a structured way that is transparent to stakeholders and other interested
parties.

There are three series of Standards: the GRI Universal Standards, the GRI Sector Standards, and the GRI Topic
Standards. Each Standard begins with a detailed explanation of how to use it.

GRI Universal Standards

The GRI Universal Standards apply to all organizations, and consist of the following:
GRI 1: Foundation 2021 (GRI 1) outlines the purpose of the GRI Standards, clarifies critical concepts, and explains
how to use the Standards. It lists the requirements that an organization must comply with to report in accordance
with the GRI Standards. It also specifies the principles – such as accuracy, balance, and verifiability – fundamental
to good-quality reporting.

GRI 2: General Disclosures 2021 (GRI 2) contains disclosures relating to details about an organization’s structure
and reporting practices; activities and workers; governance; strategy; policies; practices; and stakeholder
engagement. These give insight into the organization’s profile and scale and help in providing a context for
understanding an organization’s impacts.

GRI 3: Material Topics 2021 (GRI 3) explains the steps by which an organization can determine the topics most
relevant to its impacts, its material topics, and describes how the Sector Standards are used in this process.
It also contains disclosures for reporting its list of material topics; the process by which the organization has
determined its material topics; and how it manages each topic.

GRI Sector Standards

The GRI Sector Standards intend to increase the quality, completeness, and consistency of reporting by
organizations. Standards will be developed for 40 sectors, starting with those with the highest impact.
The Standards list topics that are likely to be material for most organizations in a given sector and indicate
relevant disclosures to report on these topics. If an applicable Sector Standard is available, an organization is
obliged (‘required’) to use it when reporting with the GRI Standards.

GRI Topic Standards

The GRI Topic Standards contain disclosures for providing information on topics. Examples include Standards
on waste, occupational health and safety, and tax. Each Standard incorporates an overview of the topic and
disclosures specific to the topic and how an organization manages its associated impacts. An organization selects
those Topic Standards that correspond to the material topics it has determined and uses them for reporting.

We recommend checking the updates on GRI standards frequently.

https://www.globalreporting.org/standards

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Recommended Sustainability Metrics

This ESG disclosure guide recommends an initial set of 30 sustainability indicators. These indicators are based
on KPIs from the World Federation of Exchanges (WFE)13 and the Sustainable Stock Exchanges Initiative (SSE).
These KPIs are designed to be relevant for all sectors and are aligned with the seven pillars of Kuwait’s National
Development Plan18. These indicators are voluntary, and their purpose is to support the listed companies in the
disclosure journey.

Environmental
Corresponding Kuwait
Metric Calculation Corresponding SDGs Corresponding GRI
2035Vision Pillars

E1.1) Total amount, in CO2 equivalents, for

Scope 1 (if applicable)
E1.2) Total amount, in CO2 equivalents, for
GHG Emissions GRI 305: Emissions
Scope 2 (if applicable)
E1.3) Total amount, in CO2 equivalents, for 2016
Scope 3 (if applicable)

E2.1) Total GHG emissions per output

scaling factor
Emissions Intensity GRI 305: Emissions
E2.2) Total non-GHG emissions per output
2016
scaling factor

E3.1) Total amount of energy directly

consumed
Energy Usage E3.2) Total amount of energy indirectly GRI 302: Energy 2016
consumed

Total direct energy usage per output

Energy Intensity GRI 302: Energy 2016
scaling factor

Percentage: Energy usage by generation

Energy Mix GRI 302: Energy 2016
type

E6.1) Total amount of water consumed GRI 303: Water and

Water Usage
E6.2) Total amount of water reclaimed Effluents 2018

E7.1) Does your company follow a formal

Environmental Policy? Yes, No
E7.2) Does your company follow specific
Environmental waste, water, energy, and/or recycling
Operations polices? Yes/No
GRI 305: Waste 2020
E7.3) Does your company use a
recognized energy management system?
Yes/No

Does your Board/Management Team GRI 102: General

Environmental
oversee and/or manage climate-related
Oversight Disclosures 2016
risks? Yes/No

Does your Board/Management Team

Environmental
oversee and/or manage other
Oversight
sustainability issues? Yes/No

Total amount invested, annually, in

Climate Risk Mitigation climate-related infrastructure, resilience,
and product development?

13 WFE ESG Revised Metrics June 2018 | The World Federation of Exchanges (world- exchanges.org)

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Social
Corresponding Kuwait
Metric Calculation Corresponding SDGs Corresponding GRI
2035 Vision Pillars

GRI 405: Diversity and

Ratio: Median male compensation to median female
Gender Pay Ratio Equal Opportunity
compensation
2016

S2.1) Percentage: Year-over-year change for full-time

employees
S2.2) Percentage: Year-over-year change for part-time GRI 401:
Employee Turnover employees
S2.3) Percentage: Year-over-year change for Employment 2016
contractors and/or consultants

GRI 102: General

S3.1) Percentage: Total enterprise headcount held by Disclosures 2016 GRI
men and women 405: Diversity and
S3.2) Percentage: Entry- and mid-level positions held by Equal Opportunity
Gender Diversity
men and women 2016
S3.3) Percentage: Senior- and executive-level positions GRI 405:
held by men and women Diversity and Equal
Opportunity 2016

S4.1) Percentage: Total enterprise headcount held by GRI 102: General

part-time employees
Disclosures 2016
Temporary Worker S4.2) Percentage: Total enterprise headcount held by
contractors and/or consultants GRI 401-Employment
2016

Does your company follow a sexual harassment and/or GRI 406: Non-
Non-Discrimination non-discrimination policy? Yes/No Discrimination 2016

GRI 403:
Percentage: Frequency of injury events relative to Occupational
Injury Rate
total workforce time Health and Safety
2018

GRI 103:
Global Health & Does your company follow an occupational health
Management
Safety and/ or global health & safety policy? Yes/No
Approach 2016*

S8.1) Does your company follow a child and/or

forced labor policy? Yes/No GRI 408: Child Labor
Child & Forced Labor
S8.2) If yes, does your child and/or forced labor 2016
policy also cover suppliers and vendors? Yes/No

S9.1) Does your company follow a human rights GRI 412: Human
policy? Yes/No Rights Assessment
Human Rights S9.2) If yes, does your human rights policy also cover 2016
suppliers and vendors? Yes/No

S10.1) Percentage of national employees S10.2) Direct GRI 202: Market

Nationalization
and indirect local job creation Presence 2016

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Governance
Corresponding Corresponding
Metric Calculation Corresponding GRI Kuwait 2035 Vision
SDGs Pillars

G1.1) Percentage: Total board seats occupied

by men and women GRI 405: Diversity and
Board Diversity
G1.2) Percentage: Committee chairs occupied Equal Opportunity 2016
by men and women

G2.1) Does your company prohibit its CEO from

serving as board chair? Yes/No
G2.2) Percentage: Total board seats occupied by GRI 102: General
Board Independence
Disclosures 2016
independents

Are executives formally incentivized to GRI 102: General

Incentivized Pay
perform on sustainability? Yes/No Disclosures 2016

GRI 102: General

Disclosures 2016
Collective Percentage: Total enterprise headcount covered
Bargaining by collective bargaining agreement(s) GRI 407: Freedom of
Association-and-Collective
Bargaining 2016

G5.1) Are your vendors or suppliers required to GRI 102: General

follow a Code of Conduct? Yes/ No
Disclosures 2016
Supplier Code of G5.2) If yes, what percentage of your suppliers
have formally certified their compliance with GRI-414-Supplier Social
Conduct
the code? Assessment 2016

G6.1) Does your company follow an Ethics and/ GRI 102:

or Anti-Corruption policy? Yes/No General Disclosures 2016
Ethics & G6.2) If yes, what percentage of your workforce
Anti-Corruption has formally certified its compliance with the GRI 205: Anti-Corruption
policy? 2016

G7.1) Does your company follow a Data Privacy

policy? Yes/No GRI 103: Management
Data Privacy G7.2) Has your company taken steps to comply Approach 2016
GRI 418-Customer Privacy
with GDPR rules? Yes/No 2016

G8.1) Does your company publish a

Sustainability sustainability report? Yes/No
Reporting G8.2) Is sustainability data included in your
regulatory filings? Yes/No

G9.1) Does your company provide sustainability

data to sustainability reporting frameworks?
Yes/No
Disclosure Practices G9.2) Does your company focus on specific UN
Sustainable Development Goals (SDGs)? Yes/
No G9.3) Does your company set targets and
report progress on the UN SDGs? Yes/No

GRI 102: General

Disclosures 2016
GRI 103: Management
External Assurance Are your sustainability disclosures assured or
Approach 2016 is to be
(Recommended) validated by a third party? Yes/No
used in combination
with the topic specific
standards

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