S&P Global Inc. (SPGI) Earnings Call Transcript & Summary

Hello, everyone, and welcome to today's webinar. My name is Helen Wood-Gush, I'm a sustainability specialist at S&P Global Sustainable1. It is my pleasure today to moderate today's webinar, CSRD Essentials: Understanding Its Business Implications. Before I introduce my guests, a few housekeeping items. We recognize that the topic of today's webinar is of great interest to you. We want this to be an interactive session. At the bottom of your screen, you will see a row of widget icons. These icons will allow you to interact with us throughout the session. I'd like to point out that the Q&A widget, which can be used to submit questions to the panelists. I would also like to point out the survey widget. Please take the time to fill out our short survey after or during the webinar. We really value your insight. Additionally, you can find more content surrounding the topic in the resource widget. This webinar is being recorded, and an on-demand version will be available shortly after we conclude. [Operator Instructions]. Now it is my pleasure to introduce today's panel. David Henry Doyle, Head of Government Affairs & Public Policy for Europe, the Middle East and Africa; Michael Taschner, Global Head of Sustainability Solutions. So over to you, David. Thank you very much.

Thank you, Helen, and good to be with you all today. Maybe if we go to the next slide, I can just very briefly take you through three things that I'm going to do in the time that I have with you. First, I want to talk about the policy drivers behind CSRD and what they have been. Secondly, how those policy drivers are changing and the new ones that are driving momentum in CSRD right now. And thirdly, what that means for the future of CSRD and companies that are within scope. So on my first slide here, it's really important to situate CSRD and to understand its role in the context of the EU sustainable finance agenda, which has been happening over the last couple of years. The objective and its place in the overall EU regulatory strategy are really important for understanding how it works. So the CSRD is just one part of a series of regulatory disclosure frameworks designed by the EU to enhance the quality, the consistency and the comparability of sustainability information. You see the first two pieces of legislation that were agreed by the EU on the left-hand side here, the Sustainable Finance Disclosure Regulation and the EU Taxonomy. These are already aimed at improving transparency on sustainability for financial products and standardizing what investments qualify as sustainable. So the key objectives for these first two pieces of regulation were preventing greenwashing and helping to guide capital towards sustainable investments. CSRD was part of this architecture. It was intended to provide the underlying data, that sustainable data, the disclosure that financial market participants actually need to meet their SFDR requirements and their EU Taxonomy reporting obligations. But as you can see on the time line here at the bottom, the SFDR and EU Taxonomy preceded SFDR -- CSRD and came into force well before CSRD was actually finalized. So we have a gap between what market participants are required to report and what is reported by companies right now. And on this slide, you can see with the shaded area, there is overlap between all three of these pieces of regulation, in particular, the gray shaded area tells you where the CSRD and taxonomy directives and regulation overlap. Companies that are in scope of CSRD also need to fulfill the disclosure obligations under the taxonomy alignment criteria for CapEx and OpEx in Article 8 of that legislation. So with that baseline set of how CSRD sort of powers the sustainable finance regulation in the markets, maybe we turn to the next slide and cover some of the CSRD basics. So who is in scope of CSRD? And what are companies in scope required to do? Here it's really important to understand that CSRD is an enhancement of the EU's existing Non-Financial Reporting Directive, which was called NFRD. That came into force in 2014. Reporting for that happened in 2017. There was -- there's some differences between NFRD and CSRD, notably the number of companies that are captured and the granularity of the disclosures that the companies have to make. So as you see on the left-hand side here, there was about 11,000 companies captured by NFRD. CSRD is likely to capture, latest estimates are around 50,000 companies. So huge expansion of who has to report. There's also going to be a phased approach for CSRD, which really starts this year, but on financial year 2024 data and extended that to 2029. We'll come back to that time line a little bit later with the latest developments. And if we look at the CSRD reporting requirements, these are laid out across the bottom of this slide. We have, central to the regulatory framework, double materiality, which is a very unique European approach to financial disclosure and sustainability disclosure. It means that companies have to report not only how sustainability issues affect their financial performance, but also how the company's operations impact the environment and society. Secondly, on the ESRS, NFRD did introduce the concept of double materiality, but a lot of flexibility was given to companies on how they should report. By contrast, CSRD has a much more detailed and standardized reporting framework, and that is the European Sustainability Reporting Standards, the ESRS. And thirdly, companies under CSRD will have to disclose climate transition plans to outline their business model and how it aligns to 2050 targets that the EU has set. Strategies and targets are a key element of disclosures as well as reporting impacts across the supply and value chains of companies. Sustainability information has to be integrated into the management report of the company to provide a more holistic view of company performance. And finally, moving to the right-hand side of this slide, we have limited assurance as a requirement for those disclosures to enhance the reliability and new digital tagging in a machine-readable format for facilitating automated data analysis. So that's a snapshot of what CSRD looks like. If we move to the next slide, we can conceptualize it visually. This is essentially what the ESRS, European Sustainability Reporting Standards looks like. At the top of the slide, you see the cross-cutting ESRS 1 and ESRS 2, which apply quite broadly across sectors and types of companies. They're really intended to provide a foundational principles and disclosure requirements that are relevant for every organization regardless of the industry or the sustainability focus. So ESRS 1 sets out these general principles and conceptual guidelines for reporting, including how to approach double materiality. ESRS 2 sets out mandatory disclosure requirements across things like governance, strategy, impact, risk, opportunities and metrics and targets. So underneath that, we have the topical ESRS standards on the bottom of this slide, and they address specific sustainability issues such as climate change, biodiversity and workers' rights. If you go to the next slide, this is where it gets quite interesting. We are now in a sort of new part of the mechanics of European policymaking. And I'm sure you may have heard of the Omnibus review. Essentially in recent months, the European Commission has decided after having passed the CSRD and written all of the technical guidelines to make it implementable, it's decided to conduct an urgent review of CSRD and also the EU Taxonomy framework and the Corporate Sustainability Due Diligence Directive. And this was a very unexpected turn of events, given that the legislation has just been finalized. It has several political drivers, which we can go into in more detail in the Q&A, if that would be useful. But essentially, they're linked to the EU's perception that it's lagging in global competitiveness and perceptions that the EU regulatory burden on companies has become particularly excessive and noteworthy that smaller- and medium-sized enterprises are going to be caught up in CSRD for reporting requirements even if they're not captured in the initial waves because they are in the supply and value chains of larger companies. So this review of the sustainability regulation in the EU is happening next week. It is announced for the 26th of February. And it's been labeled an Omnibus proposal. Omnibus really just is a technical term in EU legislation that means you take a new proposal to amend several existing pieces of legislation. That's the Omnibus element. It means that there's many aspects to the amendment. The commission has been very secretive about what exactly it is planning to do with this review of CSRD. However, they have published some indications of what's planned in their 2025 work program. That's what you have on the screen right now in front of you. Some of this is taken almost verbatim from the European Commission's work program. And we have to read a little bit between the lines of what they could actually mean. So what do they talk about? They talk about, firstly, ensuring a better alignment of the requirements under CSRD, the disclosure requirements with the needs of investors. People have interpreted that as being maybe questioning the concept of double materiality and perhaps aligning more to international standards like the ISSB, which focus on the needs of investors and the financial materiality of disclosures. It's to be determined really what that will mean in practice. It may mean much less than that, and it may mean just a rationalization of the number of data points that are actually useful for investors and a further alignment to SFDR and the EU Taxonomy to avoid overreporting. Secondly, they talk about delivering a more proportionate time line for implementation. I think this really means delaying implementation for companies who are not yet in the process of reporting. So the smaller-, medium-sized companies, in particular, European companies that are feeling the pinch when it comes to the cost of regulation, maybe extending those deadlines out by a couple of years, but nothing has been confirmed on that. That would be the quickest thing to do is just to have a very quick-fixed amendment to delay all of the time lines for a couple of years. Thirdly, the financial metrics should not be discouraging investments in smaller companies that are in transition. And this is a criticism that we have heard of the EU sustainable finance agenda generally that it doesn't really cater for transition activities. The EU Taxonomy is very binary in that you are either green or not green. But the transition category is something that people want to have a conversation around it and have it included in the legislation so that there's more clarity as to what a transition actually looks like. But certainly not discouraging banks, investors cannot get the financial metrics or the sustainability metrics from smaller companies, not discouraging that from investing in them. I think that's a big part of what we'll see potentially next week. And fourthly and finally, a balance of obligations, which are in proportion to the scale of the activities of different companies. And again, two points here that they call out in the work program. One is to prevent excessive reporting requests to smaller companies that are in the supply chains of larger companies who are in scope of CSRD, maybe have to report earlier, but to limit the ability of them to have to bear the burden, maybe rationalizing or setting a limit to what they actually need to report in practice. And secondly, introducing a new definition of small mid-caps. This is really looking to add a new way of looking at companies in the accounting and transparency directives that the CSRD has built off to essentially provide more exemptions for middle-sized companies to tailor the requirements to the company size. So CSRD does make a difference between SMEs and larger companies, but we might see introduction of a new category that sort of feels that middle space provides more time and perhaps makes it less burdensome to report. So that's what the Omnibus review is expected. We will see next week, and tune in to the next episode of the series to perhaps discover exactly what it says. And if we move to the last slide, I can finish up with just the time line on where we have come from and where we are. So first, we see CSRD coming into force in January 2023, after 2 years of negotiation. It -- then the ESRS were drafted. So these very technical detailed reporting requirements were drafted. They came into force on the 1st on January 2024. And here we are in 2025, the reporting requirements have kicked in for the first scoped entities. So those NFRD scope entities that already have to report as of 2017, they are expected to report as of this year on financial year 2024. However, and this is where the stop sign comes in, we have this date in the calendar next week where the next phase of the agenda may be completely changed and completely disrupted. So caution on the 26th of February, this new Omnibus package will be published. It will suggest amendments. Those amendments will take a certain amount of time to work their way through the political process. There will be negotiations. And it is fair to say this is a very controversial and unexpected legislative proposal. There will be pushback on it. But what happens after that, particularly for the non-NFRD scope companies, there's 40,000 extra companies that were not reporting under NFRD. They have to report for financial year 2025 in the course of 2026. So a big question for anyone who's already undertaking exercises on CSRD there, will you have to report in 2026? It's an open question. If the legislation changes the time lines and it scopes out those companies for another couple of years, maybe not. And we see the second and second last dots here are the reporting requirements from 2027 for listed SMEs and for finally, certain third country entities in financial year 2028 from 2029. Those last three dates are the ones to watch. Companies are already reporting under CSRD. Companies are preparing to report. This Omnibus package will determine what the future time line looks like. So a very important week next week. And with that, I'll hand back to Helen.

Great. Thank you very much, David. So over to Michael now for a bit more in-depth discussion.

Perfect. Thank you very much, and a very warm welcome also from my end to everyone. Thanks for joining. And please don't hesitate to submit any questions you're having. We will refer and ideally answer most of them throughout the presentation. Those that we do not answer, we are happy to refer to them in the last 15 to 20 minutes of this session. So please jump to the next slide. So the purpose of the next chapters is pretty much a deep dive on how to operationalize the concept of double materiality assessment and how to literally approach it. We tried to simplify it but also try to focus a bit on the details. So the sequence that you are seeing here is really a very logical sequence for focusing on how to approach the double materiality assessment and subsequent reporting, beginning with understanding the context, identifying the IROs, assess the IROs and then reflect that in the reporting. So the understanding, I mean all of that, some could say, yes, makes sense, very much straightforward, which is the case, but still, the devil is in the detail. Therefore, let's kick it off with the first topic of understanding the context. The context, which is sensitive one in the double materiality assessment approach, is understanding the value chain. So how does the value chain from a customer but also from a supplier point of view looks like, which activities are considered, which business relationships are in place and which stakeholders are impacted either by the financial or by the impact assessment? The next level is the IRO. So IRO, the abbreviation stands for impact, risk and opportunities. From a conceptual perspective, this is something that is not entirely new. However, from a degree of prescription, this is something very CSRD specific as the CSRD is asking explicitly for identifying and assessing the IROs for all topics that are identified as material. And ultimately, it needs to be reported that some might say again, yes, of course, make sense. Important to mention here is that there is this critical consensus on the CSRD that it is just a burden of reporting. A lot of topics need to be reported, and whoever was reading the ESRS in details, this is just a lot of stuff. So -- and therefore, it is even more important to very precisely define what is in scope, what is not in scope. So the assessment of double materiality assessment within the CSRD identifies which topics and subtopics or sub-subtopics are material and only for those the reporting is supposed to happen. For the others not necessarily. So reporting only on those elements that are considered as material and not reporting on those that are not material. Please jump to the next slide. What you see here is pretty much the concept of the IRO assessment. So the separation between impact, risk and opportunities also is in line with the concept of the double materiality assessment. So the impact, this is where the double comes in because the risk and opportunity, this concept is already covered by the principle of the financial materiality, which referring to also what David said earlier, whether there is -- where there are, I think, where there are opinions that the CSRD should be aligned closer to the ISSB. We will see if this is -- if this -- to which extent this will happen in the Omnibus regulation. Long story short, ISSB is following financial materiality, whereas CSRD is also including the impact materiality. And the major difference there is the impact is supposed to assess how the company or its value chain impacts people or the environment, both positive or negative. Examples for that are, if the company causes any oil spill for example, company subcontractor leaks customer data accidentally. So there is data security and IT risks. Company's activities lead to workforce accident or company conducts reforestation, which would be a positive impact. So you see these are -- this is, of course, a non-exhaustive list of examples, but they should indicate that the assessment of the supply chain and the clear understanding of the potential risk of the supply chain is an important element in the IRO assessment. Both things together, they form a double materiality assessment from an inside-out and outside-in perspective. Please continue slides. So on this one, we see how the identification of an IRO, the logic of the IRO is supposed to happen. On the very left-hand side, you see the different ESRS topics, topics/reporting templates. So E1, E2, E3 up to G1. And the assessment will likely indicate and will likely impact which topic is in scope. So this is the first level, the identification of the relevant topic. And then the next level is the identification of the subtopics because every topic is split up into subtopic, and every subtopic is split up into sub-subtopics. It sounds very formalistic and prescriptive, which is the case. Even there, it's even more important and the advantage there is that whatever is prescriptive, you can just follow the logic. And that said, based on this logic and based on this logical connection, the identification of IROs, so the impact, risk and opportunities per -- on the lowest level on the sub-subtopic level is required. Let's take the example of climate change and climate change adaption. There, we see disruption of physical infrastructure due to extreme weather events, which might be a risk and deforestation making region more prone to flooding is an impact. The same is true for health and safety that can be exercised for all sub-subtopics, which needs to be done, which ultimately also needs to be reported and disclosed in the respective reporting templates. Please go on. Then there is -- the next is the assessment of the IROs. So after identifying the IRO, so let's do -- the recap is first is the identification of the topics. The second step is the subtopics and the sub-subtopics. And based on that, it is the identification of the IROs. The next step is the assessment of the impact of each IRO. So from a risk and opportunity point of view, but also from an impact point of view. And the quantification is as always kind of a challenge. In some elements, it's more straightforward. In other elements, it is a little bit less straightforward. Important there is, and there is no -- it would be easy if the regulator would give one applicable formula that covers everything. But the purpose of it is more, which is not the case. So the purpose of it is that everyone who is doing the assessment actively thinks about, okay, what does it mean for my company? What does it mean for my business model? And key element there is that any kind of assumption, any kind of methodology that is being applied is being documented and applied in a uniform way. So these examples that you see here, they could be used. It could also be equally different for any of those topics. So it is the consideration of the scale of the impact, the scope of the impact and the irremediability of the respective IRO. This needs to be multiplied with the likelihood of the impact and the outcome is a quantified measure if the -- which can be used to assess if this IRO is material or not. Let's please jump to the next slide, that indicates this slide shows what it could mean in real figures. These numbers are, I would say, random numbers, but you need to come up with those numbers individually, which will make sense for your business and where that senior leadership and the senior management that is responsible for risk and opportunity management is backing that up and is in line with these assumptions. Next step, please. The next one is the reporting and the reporting is also -- this slide should indicate what I mentioned earlier that only those IROs and only those topics that are being considered as material, they should be reported, whereas others should not be reported. This materially reduces the reporting and disclosure burden and helps the companies to really focus on only those elements in those contexts that is in scope and that needs to be disclosed and ultimately also processed further. We jump to the next slide, please. So the next two chapters, pretty much they cover two use cases. One use case is focusing on how a corporate -- classical corporate is or can assess that on a generic level. The second one is from the perspective of financial institutions as those two industry players, they, of course, approach it a little bit differently. Let's -- I will come through those quite quickly that we also have a chance to go into the Q&A. So please move to the next slide. This indicates the very high-level approach with the definition of topics and stakeholders, survey and prioritization of topics, analysis, viral ESRS gap assessment. So the definition of the topics and the stakeholders. This is supposed to be net all these different approaches, of course, but this approach indicates that the topics are pre-analyzed. So a pre-assessment of applicable topics based on the understanding of the supply chain, of the value chain and also of the risk and opportunities a company is exposed to can be done to initially minimize the entire scope of work. And then subsequently, the inclusion of stakeholders is a good practice that is seen in the market. Then there is surveying and prioritization of topics. It can either be surveyed by identifying and by collecting the input from major stakeholders or it can also be done internally to rely on the expertise and the intelligence that is available. And then the analysis of the IROs and ESRS gap assessment are next steps. We already talked about the analysis of the IROs. The topic of ESRS gap assessment, that is a logical consequence because it is no surprise that in particular, by doing it the first time or one of the first times, the outcome of the double materiality assessment that is indicating which reporting templates and topics are applicable, therefore, need to be reported, that the result will be okay. I now know that I need to report A, but I also know that I don't have A. So having this, coming to this conclusion is from a project point of view an important approach or an important step to consider it as all those gaps that are identified, they need to be put on the road map and the implementation of the gap closure activities should be managed and should start to properly ensure that all information are available at the point in time when the reporting needs to happen. Great. Let's jump to the next slide, please. I saw there is -- do we need to do some survey? No. If not, then let's do -- yes, let's do, let's focus on this slide on the -- which is -- let me only highlight the most important elements there. The most important or very important in this entire context is the consideration of the corporate setup. So the -- typically, a small- and mid-cap and of course, a large cap is exposed or has business exposure in more than one country, therefore, operating internationally. And considering the corporate setup by analyzing the corporate structure in terms of what -- how does the subsidiary setup look like, how does the consolidation logically look like and where might be some structures in place that I -- where I need to take a more detailed look on it. For example, companies might have subsidiaries or might have just -- yes, might have subsidiaries in any European Union country. However, those might also have subsidiaries in non-European countries. So the access and the regional scope might be different. However, that needs to be considered from a consolidation approach. That said, considering the corporate structure is important to understand what is my corporate scope of work. And secondly, and this is now where it operationally can get a little bit tricky, that the divisional and the operational setup needs to be reflected in the corporate limitation as well because many companies literally don't follow a corporate separation, rather they have a divisional setup which interferes with the corporate. That is not a big issue, but it is good to consider that at the earliest point in time to understand how to better and best set that up. So let's move on, please. Yes. Let's turn to the next slide. This has already been covered. That's also covered. Then let's go to the road map piece. Please, next slide. Next slide. Next slide, and then there we are. The road map is the important one, as I mentioned earlier, because the identified issues and gaps on the lowest level, they should be translated to a consolidated -- ideally a consolidated working plan. The working plan has to consider the different corporates and the different divisions. That's now where the nonregulatory work starts, which is more the transformation, the implementation work to make a proper decision on do I want to have a centralized or a decentralized setup? Do I want to cover it from a corporate or from a divisional setup? This question should be answered also at the earliest point in time. And also, as mentioned by David earlier, is that CSRD asks for limited assurance, therefore, involving and aligning with the assurance provider. Also at the very beginning or as of the earliest point in time, makes sense as everything that is aligned and everything where expectation can be managed properly at the earlier stage helps in managing a complex setup like that. If we can jump to the next chapter, please. Next one, please. The next one is focusing on the financial industry. So we took an example of how does the double materiality assessment looks like from an asset manager perspective, where the materiality or the double materiality of a portfolio can be analyzed in a very structured approach, assuming that our portfolio has a large number of constituents in there and focusing in this case on equity and fixed income and to -- and how to best approach that in a very structured and a very data-driven, analytical-driven approach. Please jump to the next one. So the level -- the approach there is to do a top-down, bottom-up, top-down approach. So that said, first, starting with the scoping on a fund level and apply a proper look-through approach and allocating all the different equities and actually constituents to the different GICS industries. So GICS is just a very common industry standard. Ideally, you can do that on the lowest level. So on the GICS level 3 sector allocation and break it down to the lowest level that is possible, and then aggregating it upwards again by -- in a step 4, identifying the applicable IROs and then lastly, add a qualitative layer to this assessment. Jumping on the next slide, you see it in a little bit more detail. There, we see how the GICS assessment can look like. The entire approach is supported by the S&P Global Industry Materiality assessment that we provide for all the companies that we have in scope, which are all listed companies following the double materiality assessment approach. And in this case, the portfolio is allocated to the different GICS sectors and weighted by the market value of the constituents. We selected a company that is allocated to the passenger airlines GICS sector as just an example to make it a little bit illustrative. Jumping to the next one, please. What this one indicates is that the different asset types. So one step back probably, it is -- every GICS sector, every industry, it reflects a certain degree of impact, risk and opportunity driven by the entire sector. What needs to happen now is it needs to individual adjustments based on the characteristics of the companies that are in the portfolio need to happen, to not either penalize or are underrepresented a certain risk element. That said, the adjustment from the industry average to the individual company shall happen. And this delivers a very portfolio-specific point of view of the entire materiality of this fact. Jumping to the next slide, please. Then in the next step, it needs to be aggregated. So whatever has been calculated for the different constituents would need to be weighted again based on the respective exposure of the assets in the portfolio that delivers a fund or a portfolio point of view of the different elements of materiality. Jumping to our next slide, please. And then the IRO assessment happens pretty much alongside the logic that we saw earlier. So every company in the industry relates to certain risk opportunities. The way of how we, in this case, did it is to leverage all the information that we have available from the entire universe of companies we are covering as we are collecting the information with regards to IROs for a long time already. And this is being used as a long list, and the long list needs to be applied to the different constituents, to the different... [Technical Difficulty]

Well, I think we've lost Michael there for a second. But thank you for that insightful run-through, Michael. I think we've got a lot of that.

I have a question for David, actually. David, let's just jump to some questions now. So regulatory intent versus market readiness. CSRD is raising the bar for corporate sustainability disclosure. How well do you think companies are adapting to the transition from voluntary to mandatory reporting? And do you foresee any regulatory interventions to ease compliance burdens while maintaining rigor? I'm kind of referring to the Omnibus conversation that we had at the top of your slides today.

Yes. It's a great question, Helen. And I spoke at the beginning of my intervention on the original regulatory and policy drivers for this and what they intended and what the current policy drivers are, which are completely different, let me say. So the question of regulatory intent is essential to understanding where we're coming from, what the intent was to where we're going and how the intent has changed. The original intent was to have a Big Bang disclosure revolution on double materiality with highly regimented disclosure standards that were adapted to the needs of financial market participants and their reporting obligations under SFDR, so that there was a high-quality flow of information from issuers, corporates, financial instruments into financial products to enable decisions to be made on the basis of really good, accurate, assured information and that capital would flow, that was the theory, towards more sustainable investments and the ability to greenwash would be reduced. That was something that was quite revolutionary at the time, something that was very much welcome in the context of the European Green Deal. It has met resistance as companies have woken up to the extent of the potential regulatory burden that, that would mean for their companies and the ambiguity that rolling out any piece of new regulation entails. And to their credit, the European Commission and the European -- and EFRAG, which is the body that designs and advises the European Commission on implementation of these standards, have issued guidance. They have tried incrementally to reduce sort of the risk of overreporting to clarify that not every ESRS disclosure point will be relevant for every company and that there is a materiality threshold and that the company has to decide whether to report certain things. And if not, why not? So there has been sort of a shift from, I think, financial markets expecting high-quality data on everything to the introduction of more realism around the materiality threshold to address that concern around companies having to report things that really aren't relevant for them and perhaps misleading investors that things are more relevant than they need to be to where we are today, where the intent is very much driven by a competitiveness agenda, which the Draghi report, the Letta report have fueled and a political change among member states who agreed to the CSRD not too long ago. I think once they heard back from companies who maybe were not anticipating the scale of the resources they would have to invest or the complexity of undertaking a double materiality assessment. So where we are today, which is a week or 2 or 3 away from the Omnibus proposal seeking to pause or to at least delay full implementation of this. I think larger companies have had more time to prepare for this. They have been scoped into NFRD, for example, since 2017 and reported some aspect of double materiality. They have the resources and the advisers to do this. I think that's why we're seeing a policy focus on the mid-cap and SME implementation phase right now. But to conclude, it is a very complex piece of regulation. It is a revolutionary approach to financial and sustainability disclosure. So the time lines have not been generous, but I think that is -- those are the reasons why we're seeing an about turn, at least in theory on the policies.

Thank you very much, David, and thank you very much, Michael, for today. That seems to be all the time we have for questions. Thank you all. It's very insightful. It's a very deep topic. This is one of a series of webinars on CSRD. We covered a lot today. So if you do have any follow-up questions, please use the widget, the Contact Us widget, and we'd be glad to assist. For those who want to review anything we've covered, this session is being recorded, and you will receive a copy shortly, so you can access this on-demand at your own convenience. In addition, when we close out the webinar, you will be routed to our webinar survey form. We would love to hear your feedback, so please do take some moments to complete this. Thank you very much for your time today.