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ESG for suppliers: what large customers and banks will ask for

Pressure for ESG data reaches mid-sized companies through the value chain. Understanding where the questions come from helps answer them consistently, instead of building a report for each customer.

· 7 min read · Ideavus

A packaging manufacturer with 300 employees receives three sustainability questionnaires in the same half-year. One comes from a multinational customer, another from a retail chain, the third from the bank with which it is negotiating a credit line. The questions overlap but are not the same. Each uses its own terminology, asks for its own format, and has its own deadline. The quality team, which ended up with the topic because it "already handled certifications", spends weeks putting answers together.

This scene is becoming routine. Mid-sized companies rarely have a direct obligation to report on ESG, but their customers and lenders do. And those customers and lenders need data that only the supplier has.

Where the pressure comes from

Listed companies and CVM Resolution 193/2023. Brazil's securities regulator, the CVM, established sustainability-related financial disclosure based on the ISSB standards, IFRS S1 and IFRS S2. Adoption was voluntary from 2024 and became mandatory for listed companies for fiscal years beginning on or after January 1, 2026. IFRS S2 covers climate and requires disclosure of greenhouse gas emissions across scopes 1, 2, and 3. Scope 3 includes value chain emissions, that is, suppliers.

Global supply chains and double materiality. Customers operating in the European Union follow the European Sustainability Reporting Standards (ESRS), which adopt double materiality: the company assesses both how sustainability matters affect its finances and how its activities impact people and the environment. GRI 3, from 2021, guides the identification of material topics from the impact perspective. In practice, these customers ask suppliers for information on working conditions, human rights, and environmental impact, not just carbon.

Human rights in the chain. The UN Guiding Principles on Business and Human Rights, from 2011, set the expectation of human rights due diligence, which extends to business relationships. That is where supplier questionnaire questions about child labor, forced labor, working hours, and grievance channels come from.

Banks. Brazil's National Monetary Council Resolution CMN 4,945/2021 requires financial institutions to have a Social, Environmental and Climate Responsibility Policy and to consider these risks in their operations. That is why credit analysis now includes questions on environmental licenses, liabilities, waste management and, increasingly, exposure to climate risks.

What is usually requested

TopicTypical questionReference basis
EmissionsScope 1 and 2 inventory; estimate of relevant scope 3GHG Protocol
EnergyConsumption and share of renewable sourcesGHG Protocol, IFRS S2
Labor and human rightsPolicies, grievance channel, audits of own suppliersUNGP, GRI
Operational environmentValid licenses, waste, water, liabilitiesEnvironmental law, GRI
GovernanceCode of conduct, anti-corruption policy, person responsible for the topicGRI, compliance practices
TargetsReduction commitments with deadline and baselineIFRS S2

Start with the emissions inventory

If the company can do only one thing this year, it should be a greenhouse gas inventory following the GHG Protocol. It is the most frequent question, has a standardized methodology and, in Brazil, has the Brazilian GHG Protocol Program as an application reference. Scope 1 covers direct emissions (fuels, processes, own fleet). Scope 2, purchased electricity. Scope 3 is the most laborious, and the 2011 value chain standard organizes its categories.

A common mistake is trying to measure every scope 3 category in the first year. It is more useful to identify the two or three most relevant to the business, such as purchased goods and transportation, and improve accuracy over time.

Do materiality once and reuse it

Instead of answering each questionnaire from scratch, the company saves time with its own materiality assessment, done with double materiality logic. It defines which topics truly matter to the business and to affected stakeholders, and becomes the backbone of every answer. Data gets an owner, a frequency, and a source, and each new questionnaire becomes a mapping exercise, not a research project.

Checklist for the next questionnaire

  • Name a person responsible for the topic with access to operations, HR, and finance.
  • Complete the scope 1 and 2 emissions inventory for the last closed year.
  • Identify the most relevant scope 3 categories.
  • Consolidate existing policies (conduct, anti-corruption, human rights, environment) in a single repository.
  • Run a simple materiality assessment, listening to customers and employees.
  • Build a reusable answer base, with source and date for each data point.
  • Check environmental licenses and liability records before the next credit renewal.

A mid-sized company that organizes this data stops treating ESG as a cost of serving customers and starts using it in negotiations. In our experience, suppliers that arrive with a finished inventory and a clear policy get ahead in qualification processes and, often, in credit terms.

References

  1. COMISSÃO DE VALORES MOBILIÁRIOS (CVM). Resolução CVM nº 193, de 20 de outubro de 2023. Dispõe sobre a elaboração e divulgação do relatório de informações financeiras relacionadas à sustentabilidade, com base no padrão internacional emitido pelo ISSB.
  2. INTERNATIONAL SUSTAINABILITY STANDARDS BOARD (ISSB). IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information; IFRS S2: Climate-related Disclosures. Londres: IFRS Foundation, 2023.
  3. WORLD RESOURCES INSTITUTE; WORLD BUSINESS COUNCIL FOR SUSTAINABLE DEVELOPMENT. The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard. Ed. revisada. Washington/Genebra: WRI/WBCSD, 2004.
  4. WORLD RESOURCES INSTITUTE; WORLD BUSINESS COUNCIL FOR SUSTAINABLE DEVELOPMENT. Corporate Value Chain (Scope 3) Accounting and Reporting Standard. Washington/Genebra: WRI/WBCSD, 2011.
  5. GLOBAL REPORTING INITIATIVE. GRI 3: Material Topics 2021. Amsterdã: GRI, 2021.
  6. EFRAG. ESRS 1: General Requirements. European Sustainability Reporting Standards, Regulamento Delegado (UE) 2023/2772, 2023.
  7. NAÇÕES UNIDAS. Guiding Principles on Business and Human Rights: Implementing the United Nations "Protect, Respect and Remedy" Framework. Nova York e Genebra: ONU, 2011.
  8. CONSELHO MONETÁRIO NACIONAL. Resolução CMN nº 4.945, de 15 de setembro de 2021. Dispõe sobre a Política de Responsabilidade Social, Ambiental e Climática (PRSAC).
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