Materiality Is Not a Popularity Contest: Why sustainability should be driven by evidence, value creation and disciplined decision-making

One of the greatest strengths of modern sustainability reporting has been its emphasis on understanding what really matters. Materiality enables organisations to focus resources where they can create the greatest value while addressing their most significant impacts, risks and opportunities.

Unfortunately, this principle is sometimes misunderstood.

In some organisations, materiality assessments appear to place excessive emphasis on the preferences of particular stakeholder groups without sufficient consideration of objective evidence, expert judgement or the organisation’s actual impacts across its value chain. The result can be well-intentioned but poorly prioritised sustainability strategies that consume resources without addressing the issues that matter most.

This is not a criticism of stakeholder engagement. On the contrary, meaningful stakeholder engagement remains one of the foundations of credible sustainability reporting. The challenge arises when stakeholder opinions become the primary determinant of materiality rather than one important input into a structured decision-making process.

Materiality requires judgement, not voting

Materiality has never been intended to operate as a popularity contest.

Leading international frameworks consistently recognise that organisations should identify and prioritise issues using structured assessment processes supported by evidence and professional judgement.

For impact materiality, this includes considering factors such as:

• Scale of impacts
• Scope of impacts
• Irremediability
• Likelihood where relevant
• Connections throughout the value chain

Financial materiality similarly requires consideration of the effects that sustainability matters may have on enterprise value over different time horizons.

These assessments require expertise, data and informed judgement. They cannot be determined solely by counting how many stakeholders support a particular issue.

The value chain changes the conversation

One of the most powerful developments in sustainability reporting has been the increasing emphasis on value chain thinking.

Every organisation affects and depends upon activities occurring both upstream and downstream. Many of the most significant sustainability impacts occur outside an organisation’s direct operations—in raw material extraction, supplier practices, product use or end-of-life management.

Viewing sustainability through the value chain helps senior decision-makers answer much more strategic questions:

• Where are our greatest impacts?
• Where are our greatest risks?
• Where are our greatest opportunities to create value?
• Which decisions will benefit both the organisation and society over the long term?

Rather than attempting to respond equally to every issue raised during stakeholder engagement, value chain analysis enables organisations to concentrate attention where intervention can make the greatest difference.

In other words, it helps organisations focus on what matters, where it matters.

Stakeholders remain essential, but they are one source of evidence

Stakeholders often possess valuable information that management may not have.

Employees understand workplace culture.

Communities understand local impacts.

Customers identify emerging expectations.

Investors highlight financial concerns.

Civil society organisations frequently bring important issues to management’s attention.

However, none of these perspectives should automatically determine materiality in isolation.

Instead, organisations should integrate stakeholder insights with:

• Scientific evidence
• Operational data
• Financial analysis
• Regulatory developments
• Sector knowledge
• Expert judgement
• Value chain analysis

Only then can management make balanced, defensible decisions.

Poor prioritisation weakens sustainability

When organisations devote disproportionate attention to issues with relatively limited impacts while overlooking more significant environmental, social or governance challenges, sustainability risks losing credibility.

Resources become diluted.

Management attention is diverted.

Reporting becomes less decision useful.

Most importantly, organisations may miss opportunities to create meaningful value for the business, stakeholders and the planet.

This concern extends beyond individual organisations. Public confidence in sustainability reporting depends upon transparent, objective and evidence-based prioritisation. Where materiality appears driven by ideology, fashion or pressure rather than disciplined analysis, confidence in sustainability reporting inevitably suffers.

Materiality should help leaders make better decisions

Senior decision-makers do not need longer lists of sustainability topics.

They need better information.

A robust materiality process should enable boards and executives to understand where significant impacts occur across the value chain, where financial effects may emerge and where strategic action can create lasting value.

That is precisely why materiality exists.

It is not designed to satisfy the loudest voices.

It is designed to improve decisions.

When organisations combine stakeholder engagement with value chain analysis, expert judgement and objective assessment criteria, sustainability becomes what it was always intended to be: a management discipline that helps organisations create lasting value for the business, stakeholders and the planet.

References

European Financial Reporting Advisory Group (EFRAG) (2023) European Sustainability Reporting Standard ESRS 1: General Requirements. Brussels: EFRAG.

European Union (2022) Directive (EU) 2022/2464 on Corporate Sustainability Reporting (CSRD). Official Journal of the European Union.

Global Reporting Initiative (GRI) (2021) GRI 3: Material Topics 2021. Amsterdam: Global Reporting Initiative.

International Financial Reporting Standards Foundation (IFRS Foundation) (2023) IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. London: IFRS Foundation.

Organisation for Economic Co-operation and Development (OECD) (2023) OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Paris: OECD Publishing.

Organisation for Economic Co-operation and Development (OECD) (2018) OECD Due Diligence Guidance for Responsible Business Conduct. Paris: OECD Publishing.

United Nations (2011) Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework. New York and Geneva: United Nations.

United Nations Office of the High Commissioner for Human Rights (OHCHR) (2012) The Corporate Responsibility to Respect Human Rights: An Interpretive Guide. Geneva: United Nations.