Sustainability reporting in Malaysia: which framework to choose?

Bursa Malaysia has demonstrated a commitment to sustainability by asking listed companies to disclose a narrative statement of their material economic, environmental and social (EES) risks and opportunities in their annual reports.

Compliance with the initiative may sound easy to some companies, but it would in fact require a lot of thinking, internal alignment and possible organisational changes. The focus on materiality, governance and management - as suggested by Bursa Malaysia - encourages companies to bring investor relations and sustainability teams together and agree how sustainability supports the investment proposition. In my mind, this is the main advantage of the initiative.

To comply with the requirements, companies have to ask themselves the question: Which reporting framework allows them to best present the EES governance, strategy and performance? The answer to this question will impact the way you disclose information to investors and other stakeholders.


What does the Sustainability Reporting Guide say?

In its Guide to help companies report on sustainability, Bursa Malaysia suggests that companies “may also choose to move beyond the Guide and adopt a reporting approach in accordance with international sustainability reporting frameworks or guidelines…”.


What are the options?

We believe that companies have three options in terms of their sustainability reporting approach, each with their own advantages and disadvantages.

1.       Annual report with a narrative sustainability statement (no framework)

This is the most straightforward option. You can include a narrative sustainability statement (as a separate section) that would cover the required disclosures that depend on your market and capitalisation.  The advantage is that your sustainability information will get enough prominence and will be noticed by both internal and external users of the report.

Due to the stakeholder-focused definition of materiality in the Guide, some of your sustainability information (e.g. on community projects) may be important to wider stakeholders, but not necessarily investors.

2.       Annual report with a narrative sustainability statement (GRI Guidelines)

The proximity of the Guide and the GRI Guidelines in the definition of materiality drives us to a natural conclusion that Malaysian companies should adopt the latter as a reporting framework.

However, neither the GRI Guidelines, nor any other framework, can be applied to just to a statement in the report, which means The GRI Contents Index will have to refer to information elsewhere (other sections of the annual report, website, presentations, etc.). You may need to gather and publish additional information to be able to tick all the GRI boxes.

As an alternative, you can produce a standalone sustainability report in line with these guidelines and provide an extract of it in your annual report.

3.       Integrated report (<IR> Framework)

Integrating sustainability into the core elements of the annual report in line with the <IR> Framework will help you provide meaning information to investors in one document, as well as trigger integrated thinking within your organisation and demonstrate market leadership. To meet the needs of other stakeholders, you could publish additional information on your website. The disadvantage of this approach is that sustainability disclosures might not be visible enough in the annual report for unexperienced users.

To comply with Bursa Malaysia’s requirements, you can have a sustainability index referring to the provided disclosures in the integrated report and, if necessary, on the website.


How should you get ready?

Depending on the capitalisation, some companies have to comply with the requirements in 2017, while others in 2018 and 2019. Even if you have some time, you can run preparatory activities this year, such as:

  • Materiality analysis
  • Gap analysis in terms of policies, strategies and performance indicators to cover material EES risk and opportunities
  • Review of your governance structure

It is better to start earlier, as seeking internal agreement on sustainability will take time.  The sustainability reporting journey, if navigated correctly, can enhance your performance, build stakeholder trust and give you a competitive advantage.


Would you like to know more?

Contact Alex Annaev, Lead Sustainability Consultant, to hear more about how we can help you in your sustainability journey.


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My Say: Are you a good leader?

This article first appeared in Forum, The Edge Malaysia Weekly, on April 11 - April 17, 2016. Leadership obviously matters. Its importance varies with the context. But how do you determine effective leadership and identify leaders to emulate? The answer matters a great deal. There are many views and competing theories, much of which are grounded in dubious research.

Simplification is the ultimate sophistication, said Leonardo da Vinci. The massive leadership industry is anything but simple. Part of the complexity is due to the thinly disguised self-interest of those in the leadership business. Every self-proclaimed guru or author typically, with no significant leadership experience, seek to define effective leadership in a manner that plays to their particular solution or orientation. An effective leader undoubtedly has to be able to create impact. But what type of impact? One simple way is to look at the two domains in which most leaders operate — external and internal to the organisation.

External impact relates to financial results, market share, customer experience, share price performance and the like. The standard modus operandi is to study these externals and to attribute the outcome to the leader under question.

It is generally observed that when things go well, leaders are quick to take credit. The favourable tail winds are conveniently ignored but they matter greatly. This ignores the myriad macro reasons that influence performance, which often makes most of the difference. Correlation gets confused for causality. This process of identifying effective leaders is riddled with flaws.

The next near-death leap of faith is to retrofit reasons for a leader’s success, which are opaque at best. A rosecoloured walk down memory lane by the leader or researcher often completes the backstory where a narrative is created to explain the underlying factors for success.

In all this supposedly rigorous research, vital question go unasked. Were there other leaders who had the same attributes and were not successful? This is never addressed, which is a big flaw. Can the so-called lessons gleaned from so-called effective leaders be replicated? The promise is that they can. But it is a promise that is impossible to verify.

Internal impact rarely gets much attention but is a much better reflection of effective leadership. And the impact that matters most is on people. For all the talk about leadership, the other side of coin is followership, which is rarely discussed.

What exactly is followership? It is whether people in the organisation want to willingly work for a leader. Will they follow the leader to another organisation, all things being the same? Gauging followership is relatively simple since you can ask some direct questions and get unambiguous answers. One organisation I know uses followership as a critical determinant for promotions. This organisation has motivated employees with little internal politics and is a consistent leader in its field. Another organisation I am very familiar with is dominated by politics and upward management and an excessive reliance on external impact to place individuals in leadership roles.

Leaders have mastered the art of taking credit for tail winds. Employees suffocate under the hypocrisy and double talk. More than half the executive leadership would fail the test of followership miserably.

What creates followership? It is more than just being popular or likeable. It is more than having motivated or engaged employees, which often depends upon wider company factors rather than the leader alone. People in an organisation will want to follow you if you combine smarts with fairness, trust, genuine caring and helping individuals succeed professionally, to name a few.

If a leader plays politics, treats people disrespectfully, is self- centred, hypocritical and the like, most employees will not want to work for such a leader. It is remarkable how many individuals who are in leadership positions do not meet the test of followership.

Another issue that is replete with fairy tales is how one ascends to a leadership role. When interviewed or asked to share their experiences, many leaders either suffer from self-delusion or amnesia regarding what got them to the top. Rewriting history is a common pastime. Forgotten is the mentor on the board, luck, connections, skill at internal politics and the like.

Recently, a CEO I know was giving career guidance to his employees and emphasised the need to be modest, to focus on their jobs and to let their good work speak for itself. Remarkably, he seemed to have forgotten the selfpromotion he engaged in over a long period of time. Researchers, authors and leadership gurus never uncover these inconvenient facts since it interferes with the predetermined narrative. Since skill is generally a given, selection often depends upon superficial factors of perception. But if you asked followers, the real story would be easily revealed.

As a US politician once said, “Every politician wants you to believe he was born in a log cabin that he built himself.” It is simply not true. All leaders have blemishes and often skeletons in their closet, which is a reality and should not be a surprise.

The real issue is the attempt to portray leaders as personifications of perfection. Looking primarily through the lens of external impact to identify effective leaders can be perilous. A far better way to identify leaders to promote and emulate is to check their followership score. This simple measure is the ultimate sophistication.

Sanjeev Nanavati is a senior adviser to the Asian banking practice of a leading global management consulting firm and a Big 4 accounting firm as well as an adviser to the chairman of a public listed company. Until recently, he was the longest-serving CEO of Citibank in Malaysia. This article was first published in Singapore’s The Business Times.

Recent updates to the PDPA framework in Malaysia

The Personal Data Protection Commissioner has issued the Personal Data Protection Standard 2015 recently. Appended below are some of the recent PDPA updates for your reference.

1. Standards For Security, Retention and Data Integrity
Standards in relation to the Security, Retention and Data Integrity principles were issued by the Commissioner on 30 December 2015 and are binding on all data users with immediate effect. The Standards detail specific actions which need to be taken by data users in respect of the Security, Retention and Data Integrity principles and apply to both physical and electronic personal data.

Highlights extracted from the Standards include the following:-

• All staff involved in the processing of personal data need to be registered;
• The extent of authority of staff accessing personal data for purposes of collecting, processing and retaining personal data should be controlled and limited;
• The transfer of personal data through removable media devices (e.g. USB thumb drives) and cloud computing services is not allowed unless permitted in writing by officers authorised by the top management of the data user;
• Any transfer of personal data through removable media devices and cloud computing services will need to be recorded;
• Contracts must be executed between data users and parties appointed by the data user (data processors) to handle and carry out personal data processing activities;
• All transfers of personal data via conventional methods, for example by post, by hand, fax etc., must be recorded;
• Records of disposal of personal data must be maintained and produced upon request by the Commissioner;
• Personal data collection forms must be disposed within a period of 14 days, unless such forms have legal value (‘nilai perundangan’) to the commercial transaction;
• Data users are required to prepare a schedule for the disposal of personal data which have not been active for a period of 24 months;
• Data subjects may be informed about exercises to update personal data, via the data user’s portal or by way of notice displayed on the premises or any other appropriate means.

2. Data User Forums
Four Codes of Practice are in the final stages of gaining approval of the Commissioner, i.e. the Codes of Practice of the insurance, banking and finance, communications and energy sectors.

The Code of Practice of the insurance sector will likely be approved first, followed by that of the banking and finance as well as communication sectors. We have been informed that upon approval of the said Codes of Practice, the Commissioner will register the relevant Codes of Practice, with the date of formal registration being backdated to the end of December 2015.

Data users within the respective sectors will need to ensure that the Codes of Practice are fully operationalised and the necessary training is provided to their relevant personnel within the first quarter of 2016 (i.e. by the end of March 2016), with enforcement anticipated to commence from April 2016 onwards.

3. Compounding Regulations
The Compounding Regulations are a vital tool of the Commissioner as the said Regulations permit the Commissioner to issue compounds for offences under the PDPA instead of having to establish the data user’s breach of the PDPA in proceedings brought by the Commissioner against the data user.

We were informed by the Commissioner that the Compounding Regulations (which has been in the works for more than a year) are near finalisation and should be issued sooner rather than later. With the registration of the Codes of Practice in relation to specific sectors, and the issuance of the Compounding Regulations, data users can expect a very “active” 2016 from a personal data protection perspective.

4. On-line Registration
Effective 11th January 2016, the JPDP has made available an online portal for the registration of data users. The online portal may be accessed at

5. JPDP Registration Renewal
It is coming to close to two years since the first certificates of registration were issued by the Commissioner. As such, the JPDP has been issuing renewal notices to data users whose certificates of registration are several months away from expiry.

We wish to suggest that while data users are preparing to renew their certificates of registration, data users also conduct a review of their filings with the JPDP and update any information which has changed since the first registration (e.g. the personal data collected, the parties that personal data is disclosed to, the overseas jurisdictions that personal data is sent to). Do note that this is an obligation that needs to be fulfilled by data users.


SSM Offers Incentive of up to 80% for Compounds

SSM has announced a discount of up to 80% reduction on compounds in relation to offences for non-compliance with sections 143, 165 and 169 of the Companies Act 1965.

The reduction schedule is as follow :

Payment Period Reduction Rate*
9 to 30 September 2015 80%
1 to 31 October 2015 70%
1 to 30 November 2015 60%
1 to 31 December 2015 50%

* The reduced fee is based on the original compound amount and is subject to the terms and conditions.

Payments can be made at any SSM counters nationwide.


Malaysian Private Entities Reporting Standard with effect from 1 January 2016

The Malaysian Accounting Standards Board (“MASB”) had announced on 14 February 2014 that the current Private Entity Reporting Standards (“PERS”) would be replaced with the Malaysian Private Entities Reporting Standard (“MPERS’), for financial statements beginning on or after 1 January 2016. Early adoption recommended. Although MPERS is a replacement for PERS, a private entity may not necessarily adopt MPERS. In fact, private entities have the option to apply in its entirety either the MPERS or the Malaysian Financial Reporting Standards (“MFRS”).

With both options available, it is therefore necessary to evaluate and decide on the most appropriate framework, to best suit your company’s business before end of this year. Private entities are advised to evaluate the pros and cons of the respective accounting frameworks before making any decision.

Obligation to Lodge Your Company's Annual Returns Financial Statements with SSM

As stipulated in Section 165 of the Companies Act 1965, all companies are required to lodge their annual return within one (1) month of the Annual General Meeting (AGM).

Company directors are required to table the company's Financial Statements at the AGM within six (6) months from the financial year end.

For companies with financial year ending 31 December 2014, datelines for submission are as below :
a) 7 August 2015* (for states having public holidays on Saturday and Sunday) OR
b) 9 August 2015* (for states having public holidays on Friday and Saturday)
*Subject to the date of the company’s AGM

Failure to lodge Annual Return and Financial Statements is an offence and if convicted, the company and its directors can be fined under the Companies Act 1965.

Submission of Income Tax Return Forms (Form C and Form E)

The Inland Revenue Board of Malaysia (“IRB”) has made it compulsory for dormant companies and/or companies which have not commenced business in the year ended 2014 to submit the following Income Tax Return Forms (ITRF) within the stipulated dates as stated below:

1. Return form of Company for Year of Assessment 2014 (Form e-C)
a) Grace Period for Submission via e-Filing
- Within eight (8) months from the date following the close of the accounting period.

b) Failure to Submit within the Stipulated Date
- A penalty (equal to treble the amount of that tax) can be imposed under subsection 112(3) of ITA 1967 based on the due date for submission of ITRF.

2. Return form of Employer for Remuneration for Year 2014 (Form e-E)
a) Grace Period for Submission via e-Filing
- Not later than 30 April 2015.

b) Failure to Submit within the Stipulated Date
- A compound (not less than RM200 and not more than RM20,000 or imprisonment not exceeding 6 months or both) can be imposed under paragraph 120(1)(b) of ITA 1967.


SSM offers Incentive for Application to Strike Off Companies

Suruhanjaya Syarikat Malaysia (SSM) has announced an incentive for the application to strike off names of defunct companies which were incorporated between the year of 2010 to 2014, under section 308(1) of the Companies Act 1965 (CA 1965).

The incentive period is from 1 April 2015 to 20 September 2015.

During this period, companies (applicants) with outstanding penalties or compound issued prior to the incentive period will enjoy additional incentives and are only be required to pay :
a) A flat fee of RM100.00 for each offence committed by the company; and
b) A flat fee of RM100.00 for each offence committed by each director of the company

Applications can be made at any SSM counters nationwide. A full guide on the application and the application form as below.


GST Training Tax and Secretarial Fees - Income Tax Deduction

As companies are gearing up for the impending launch of the Goods and Services Tax in April this year, there will be inevitable additional training costs and secretarial and tax agent fees, to prepare for the implementation.

To ease the cost impact of these charges, kindly note the following Income Tax Rule 2014, for applicable deduction of the following :

1. Cost(s) relating to Training for Employees for the implementation of GST

> For Year of Assessment 2014 and Year of Assessment 2015

2. Expenses in relation to Secretarial Fee and Tax Filing Fee

> For Year of Assessment 2015 and Year of Assessment 2016

> Total amount of deduction allowed for Secretarial Fee shall not exceed RM5,000, for the year of assessment

> Total amount of deduction allowed for Tax Filing Fee shall not exceed RM10,000, for the year of assessment

Kindly refer to the attached circulars for details.


SSM gives 80% reduction in fines for limited period

In his recent announcement, Datuk Seri Hasan Bin Malek, Minister of Domestic Trade, Cooperatives and Consumerism, said that companies and directors issued with compound notices by the Companies Commission of Malaysia (SSM) will get 80 per cent discounts from November 1 to December 31, 2014.

The discounts are applicable for compound notices issued under the Companies Act 1965 for 2013 and earlier. Payments can be made at any SSM counters by presenting a copy of the notice of the compound, with no further questions asked. List of SSM counters can be found at :

Boardroom, a strong advocate of corporate compliance and healthy management culture, encourage you to seize this opportunity to verify if there is any offenses tagged to yourself or your company and make the necessary payments accordingly.


Guidelines on Incentives for Goods and Services Tax (GST) will be released soon

It was announced recently that the guidelines on incentives for companies that have registered for implementation of the Goods and Services Tax (GST) will be released soon.

Deputy Finance Minister Datuk Chua Tee Yong said the guidelines are needed as many companies or business associations, have yet to fully comprehend the incentive package being offered by the government.
“This could be due to the absence of the guidelines. I have as such had discussions with the Internal Revenue Board about the matter and it is now in the process of being prepared,” he added.

The guidelines, among others, covers secretarial fees, tax deductions which are allowable from the year of assessment 2015, the cost of purchase of equipment and ICT software that has been given an extension of the accelerated capital allowance until the year of assessment 2016.

It also includes expenditure for accounting training and ICT related to the GST for the years of assessment 2014 and 2015 that has been given an additional tax relief.

Chua said as of yesterday, 9,580 businesses had registered with the Royal Malaysian Customs Department to participate in the implementation of the GST as of April 1, 2015. He added that 119 companies with income of less than RM500,000 had also voluntarily registered.


An EFFECTIVE IR Program Is An Investment, Not A Cost. Here’s 4 Reasons Why.

Investor Relations (“IR”) programs – To be or not to be? I still get this response sometimes from Public Listed Companies (“PLC”), even after 13 years of being in the IR practice. But first, let’s ask ourselves, “Would we be confident with a purchase knowing that there’s no after sales services provided?” We surely wouldn’t!


More often than not, shareholders pay more for shares than the company’s products themselves. So it would follow therefore, that they would expect some sort of ‘after sales service’ from the company. Some PLCs are of the mind-set that they should solely focus on their company’s operations and deliver favourable results. While this is not wholly wrong, they should not limit their focus, simply because truly great companies produce great products alongside providing great customer service as well. 


Although it is not compulsory to have an IR program in place for your company, it certainly is a crucial element in the eyes of your investors. A good and engaging IR program not only brings about happy investors, it provides a great return on investments too:


1)      Investors are your customers – Smart and proactive companies use their investor database wisely to connect with investors electronically. They also connect with investors physically via investor sessions such as Annual General Meetings (“AGM”) as well as set up booths and offer special deals to their investors at investment related events. Marketers crave receiving this sort of undivided attention from their potential customers. Since you have already have the event venue reserved for your company for the day, why waste it? Utilise the space and the opportunity to communicate with your gathered investors to sell! If your investors believe in your company, there’s little doubt that they would believe in your products. The results may surprise you.


2)      Investors can act as your Ambassadors – If investors invest in your company, it is very likely that they like what you have been doing. With some of them investing their life savings in your company, you will be sure that they will help promote your company and would love your company to do well. Happy investors will not hesitate and are more than happy to share their experience with your company with a broader audience. That’s word of mouth promotion at no cost! Need I say more?


3)      It’s about supply and demandThe more investors you engage with, the easier it is to achieve fair valuation for your company and investors alike. It is important to maintain the engagement that you have with your existing investors, however, it is just as important to consider engaging with potential new investors throughout Malaysia, or better, international investors. There has been much recent talk of of practicing Digital IR as a breakthrough from the traditional IR culture, as this channel is able to reach a wider audience of potential investors who may be interested in your company. Regular content updates and live webcasting sessions for public viewership is an indispensable tool for reaching out to both retail and institutional investors effectively. Concurrently, this move is in line with current social media trends that involve the use of the Internet and social media.


4)      Business partnership opportunities – When you have ticked boxes for successfully meeting IR challenges and receive positive feedback in creating a different kind of investor experience, you gain brand recognition for your company and this will consequently open doors to various potential partnerships and even new business angles both locally and abroad. Many companies have successfully attracted strategic regional partners, which eventually helped to bring their company regional.


All those PLCs out there, still not equipped with an IR program, don’t miss out any further! Running a PLC without an Investor Relations campaign is akin to selling your product without offering any after sales service. So, the next time you’re about to nudge your salesperson for not providing better services to customers, think about whether you have done enough for your investors. It only takes a simple step to start by practicing the inclusion of a must-have IR agenda during every quarterly Board meeting. 


For PLCs that pride themselves on being leaders in their respective industries, it is time to take that leap forward, invest in your investors via an effective IR program, and lead the way in value creation for both your company and its stakeholders Good luck!

Article Contributed by:


Dr. Darren Wong
CEO, Director of Marketing & Founding Partner

Dr. Darren Wong is the CEO, Director of Marketing & Founding Partner of Esente Communications Sdn Bhd, a Malaysian integrated investor relations and public relations firm.

Dr. Darren Wong has grown the company from humble beginnings into becoming a leading IR & PR consultancy firm in Malaysia. Over an impressive decade which saw him and the company grow from strength to strength.

Dr. Darren has developed award-winning communication strategies for M&A, IPO and other capital market exercises over US$5 billion worth. He has provided invaluable counsel to captains of industry in the Oil & Gas, Banking, Property, REIT, Technology, FMCG and Hospitality business, assisting them to successfully navigate the investment landscape both locally and abroad. In addition to corporate counsel, Dr. Darren also advises Ministries and NGOs on complex policy communication and effective multi-stakeholder engagement using both new media and traditional media platforms.

Regulation too needs transparency

The SC is right to open up on its regulatory philosophy and activities

MANY regulators aren’t great at consistently communicating with the public, particularly when it comes to enforcement matters. When there are significant developments in their actions against wrongdoings, they seldom go beyond issuing press releases, and that too when there’s good news to report, such as them reaching milestones or notching up major triumphs.

When was the last time a Malaysian regulator announced that it had lost a fight it badly needed to win? Probably never.

And it’s not often that a regulator discusses what it wants and how it goes about getting what it wants. Usually, most of our knowledge on the subject is from the staid language of the laws and guidelines it enforces. Anything more has to be gleaned from speeches, reports and interviews.

The bottom line: it’s hard to get inside a regulator’s head if you’re not among those who deal regularly with it. This is important because if we don’t properly understand a regulator’s approach to its work, how do we assess its effectiveness? It’s easy to say a regulator is not doing its job because we believe a lot of people are getting away with offences, but is that fair? Is enforcement measured only by the number of bad guys caught?

The Securities Commission (SC) is something of an outlier among our regulators in the sense that it tries harder to communicate with stakeholders on how it carries out its regulatory functions.

In March last year, for example, the commission published a 30-page booklet that elaborates on its regulatory philosophy. The main purpose here is to explain its two pillars of regulation – proportionality and transparency – and the nine outcomes that the SC seeks from its regulation.

What’s equally pertinent is the regulator’s statements in the document’s conclusion.

“The decisions we make must take into account various factors, including the protection of investors, growth and confidence of the market and also impact of such decisions on the industry. With this in mind, stakeholder engagement will remain an important aspect of our regulation,” says the SC.

It adds: “To communicate our expectations to our stakeholders, we will continue to publish additional guidance on our regulatory approach, and may publish further details on our regulatory principles and outcomes.” We should hold the SC to that commitment.

Another way to get some insight into the SC’s thinking on regulation is to read its publication called The Reporter. Like the booklet on regulatory philosophy, The Reporter can be downloaded from the SC’s website.

Previously billed as the regulator’s “enforcement and supervision bulletin”, The Reporter was little more than a digest of highlights and updates of the SC’s enforcement actions. That doesn’t do a lot in terms of communicating new and meaningful information to the public.

After almost eight years – the first issue came out in January 2008 – The Reporter was revamped, with the first new-look issue available in November last year. It covers developments between January and August 2015. The next issue is also the latest, and it looks at the subsequent eight-month period that ended in March this year.

The overhaul of The Reporter is linked to the SC’s regulatory philosophy, in particular the transparency pillar.

“The Reporter will now function as one of the SC’s communication channels to share among others, observations from its thematic reviews, new regulatory initiatives and developments, emerging risks, including other issues that have direct implication on market participants and investors,” says the commission. “This publication will also highlight good practices and common areas of deficiencies in the industry to promote and reinforce good conduct.”

The two most recent issues of The Reporter are promising. They featured a wide range of topics such as the lodge-and-launch framework for wholesale products; the evaluation of Malaysia’s ability to combat money laundering and terrorism financing; equity crowdfunding; quality of the listed companies’ financial reporting; and clients’ asset protection.

Some of the articles are esoteric and are more relevant to market participants than to the man in the street. But there are nuggest of information that can be very helpful to others.

According to the report on financial reporting, the SC’s surveillance found several areas in which some listed companies have not complied with the accounting standards. Among these are the classification of loans between long-term liabilities and current liabilities; measurement of liabilities arising from financial guarantees; recognition of contingent assets; and presentation and disclosures.

But what captures the SC’s attention the most is some companies’ accounting treatment for the impairment of assets.

The regulator has observed that there’s poor understanding of what exactly is a cash-generating unit, which is key to a correct impairment assessment.

In addition, some companies use assumptions that are overly aggressive and unsupported when making cashflow projections. A related problem is the use of inappropriate discount rates in computing net present value of projected cashflows. Also, the projections aren’t adequately assessed.

The article ends with messages to listed companies and their directors, auditors and investors. That has value and utility.

It’s a step in the right direction when a regulator chooses to help its stakeholders understand and manage regulatory expectations. After all, no regulator is strong enough to do it all. It needs to work together with the public and market participants, and that can’t happen if information doesn’t flow well in both directions.

Executive editor Errol Oh likes the term ‘policy wonk’.