The decision
We recommend agreeing a group-wide approach to ESG execution, with clear responsibilities in each region. The board should set priorities and expectations for oversight. Management can then determine which processes, data definitions and controls can be shared, and where local adaptation is needed.
Start with the obligations and business exposures that are material to the organisation. This gives teams a basis for setting priorities, without treating every jurisdiction or sustainability initiative as equally urgent.
Why it matters
When regions develop their responses independently, they can duplicate work and leave gaps between governance, finance, technology and procurement. A single global process brings its own risks if it assumes that legal requirements, data restrictions and supply-chain conditions are the same everywhere. Both approaches can weaken the evidence behind reports, financing discussions and public claims.
A shared framework should connect regulatory work with decisions about investment, business continuity and customers. It should help people understand their responsibilities, see where their work depends on others and adapt when local circumstances require it. Its value should be judged by the quality of those decisions and the performance of the controls supporting them.
Options and trade-offs
A centralised model makes it easier to maintain consistent definitions, shared systems and consolidated oversight. It also needs a reliable way to identify and manage local exceptions.
A regional model gives teams more room to respond to local conditions. The challenge is bringing their work together without incompatible data or duplicated controls.
A common core with documented local variations can offer a practical balance, provided the organisation has both central coordination and regional owners with clear accountability.
Whichever model you choose, apply it across five areas: governance and escalation, financial risk and investment, data and reporting, operations and supply chains, and stakeholder engagement.
Reliable source data and clear accountability should come before automated monitoring, predictive models or new verification technology. Each technology investment should address a demonstrated control problem, with its costs and limitations understood and recorded.
What to do next
- Map the decisions and obligations. Bring legal, finance and regional leads together to identify applicable requirements, material exposures, deadlines and existing controls. Record where local advice or further evidence is needed, and give each unresolved issue a named owner.
- Test the framework on one material business decision. Choose an investment, supplier relationship or reporting process. Follow the information from its source through to the decision, test how regional variations are handled and record any control gaps. Where asset valuation is involved, assess material climate risks using documented cash-flow and discount-rate assumptions appropriate to the asset. Use relevant carbon-price pathways and explicit sensitivity assumptions, rather than a universal price range or uplift.
- Agree the implementation and review plan. Set out the actions, resources, escalation routes and evidence needed to put the framework into practice. Include supplier engagement and stakeholder feedback where relevant. Assess legal and constructive obligations individually, and distinguish internal planning contingencies from provisions recognised under the applicable accounting framework.
Ownership and oversight
An executive sponsor should be accountable for the integrated plan. Finance should own valuation and accounting assumptions, while legal and compliance confirm how requirements are interpreted. Technology and data teams should maintain information controls, and procurement and operations should own supplier and continuity actions. Regional leaders should approve local variations and explain why they are needed.
The board or its designated committee needs a concise view of material gaps, overdue decisions, resource constraints and changing exposures. Set a review schedule that reflects those risks, with earlier escalation when a material assumption or requirement changes. Each scorecard measure should have a clear owner and dependable evidence.
Evidence and review
Keep the obligation map, decision records, scenario assumptions, data lineage, control results and action log together in a form that teams can use and review. Assess whether the framework is improving the quality and timeliness of decisions. Policy counts and technology deployments alone will tell you little about how well it works.
Record the source and date of each regulatory interpretation, and revisit it when the underlying requirements change.
Financial assumptions should reflect the relevant assets, obligations and operating conditions, rather than rely on fixed benchmarks without a supporting basis. Document the accounting guidance and scenario sources behind those assumptions so they can be reviewed as circumstances change.