On May 11, 2023, and within the framework of the Sustainability Strategy, the National Securities Commission (CNV for its Spanish acronym) published the Guidelines for Voluntary ESG Reports (the Guidelines).

The Guidelines highlight the benefits of voluntarily disclosing ESG (Environmental, Social, and Governance) information for companies. By considering ESG factors, companies can access new markets, attract investments, foster innovation, reduce costs, and differentiate themselves.

In that regard, the Guidelines emphasize the importance of understanding the target audience when determining the content of a voluntary ESG report. Different stakeholders may have different needs, such as climate-related risks or a comprehensive understanding of the company's management. The inclusion of an extensive range of stakeholders, such as investors, employees, consumers, governmental agencies, and communities is recommended.

Materiality plays a crucial role in shaping the content of ESG reports and can be reflected in two perspectives: financial materiality and impact materiality. Financial materiality focuses on ESG factors that significantly impact the company business model and contribute to making investment decisions. On the other hand, impact materiality relates to those aspects of the business that may affect the community and the environment. The concept of "double materiality" combining both financial and impact materiality has been adopted by the European Union and the Global Reporting Initiative (GRI).

The Guidelines include a list with the material topics that should be included in the ESG voluntary reports.

When evaluating these topics, companies are advised to use widely accepted indicators developed through recognized national and international institutions (i.e., GRI, SASB, CDP, ISSB, and TCFD). However, for certain relevant topics, industry-specific indicators may be necessary if there is no applicable international indicator.

Moreover, ESG voluntary reports should provide contextual information, approach strategies, business risks and opportunities, short and long-term objectives, compliance mechanisms, commitments and initiatives, actions taken, and data collection methodologies.

In summary, the Guidelines are aimed to fulfill the information requirements related to financial materiality. Although they acknowledge the importance of impact materiality and financial materiality, they encourage companies to adopt the double materiality perspective. Thus, by considering the target audience and using recognized indicators, companies can effectively disclose ESG information, meeting the expectations of stakeholders, particularly investors, and providing valuable insights into their ESG performance.