CCO Insight: Effective Compliance for Sustainability/ESG

Integrating the role of Compliance

How are Chief Ethics and Compliance Officers (CCOs) integrating the role of Compliance in building and sustaining an effective compliance program for Sustainability/ESG (Environmental, Social, and Governance)? 

KPMG client CCOs share many key insights, including:

The CCO Role in Sustainability/ESG

  • Position Compliance as a coordinator/collaborator with senior leadership and the Board
  • Work with internal stakeholders to determine if new Sustainability/ESG controls need to be designed and integrated into an existing framework
  • Validate all content messaging, reporting elements, and stakeholder responses prior to issuance
  • Use Sustainability/ESG as a value driver for ethical business practices and ‘good corporate citizenship’

Sustainability/ESG Compliance Program

  • Determine if a separate Sustainability/ESG policy is appropriate and what it should entail
  • Expand third-party and supplier risk management including due diligence and monitoring & testing
  • Assess current regulatory change management processes and ensure that they fully capture diverging global, federal, and state Sustainability/ESG regulations

KPMG Perspective

Compliance must drive an effective compliance program for Sustainability/ESG in line with an overall sound framework. This means identifying and building controls to mitigate a new series of potential Sustainability/ESG-related legal, reputational, and compliance risks. 

Sustainability-ESG Compliance wheel


Some key sample questions to ask of your Compliance program include:



Regulatory and Commitment Change Management: Does our regulatory change management process fully capture relevant proposed and new Sustainability/ESG-related requirements at the global, federal, and state levels and identify divergent requirements posing compliance risks?




Risk Assessment: Have we assessed the inherent and residual risks to the ESG-related regulatory requirements/expectations and our company’s Sustainability/ESG-related commitments?




Policies and Procedures: Have we mapped our existing policies and procedures to the Sustainability/ESG-related risks?




Monitoring and Testing: Have we updated our monitoring and testing to the new Sustainability/ESG-related risks (e.g., advertising/marketing/disclosures, social audits, monitoring of third parties/suppliers)?




Issues Management and Investigations: Do our current legacy data access/processes need to be revamped/retooled for active and varied stakeholder Sustainability/ESG-related requests?

Contact us

Amy S. Matsuo

Amy S. Matsuo

Principal and National Leader, Regulatory Insights, KPMG US

+1 919-244-0266