SINGAPORE (July 6): Urgent action to deal with various business disruptions has characterised the first phase of corporate response to the COVID-19 pandemic. These include activating business continuity plans to comply with safe distancing measures, finding alternative supply chains amidst lockdowns globally, and navigating legal contracts and force majeure events.
SGX RegCo provided guidance to the market in our Regulator’s Column dated 22 April 2020 on disclosures during COVID-19. We highlighted the importance of providing sufficient information to investors on material changes as and when developments arise or where near-term earnings prospects change.
As we enter the next phase of COVID-19 with the gradual reopening of borders and the resumption of more economic activities, issuers need to reevaluate how they can operate safely in the new environment. This goes beyond just restarting businesses. Certain business models may no longer work, while opportunities may arise in new ways of doing things. Coping with the pandemic has been possible through the accelerated digital transformation of the nation. Technology will once again be the enabler as the corporate sector and the broad economy move into the next phase.
In this milieu, a responsible board of directors would need to conduct a fundamental review of the company’s business and its business strategy against the operating environment. It requires boards to look into the future and consider various scenarios that may play out. When will things return to normal? Will they ever? If not, what are the plausible scenarios that may occur, and what is the company’s response? None of these has clear-cut answers, but boards are uniquely placed to guide the company through the crisis and beyond.
In the next phase, investors and other stakeholders similarly need to be kept updated. Issuers have called for a shift to a risk-based quarterly reporting regime to give them more latitude to consider longer-term strategic matters. We recognise that boards need time to think through these challenges and to formulate a response. The annual reporting apparatus, in the form of business, financial, corporate governance and sustainability reports, is a convenient medium and an opportunity, for boards to demonstrate their considered analysis and lay out their plans and strategies to bring the company forward. If boards have already considered these aspects prior to the annual reporting period, they should update stakeholders accordingly in their quarterly updates or half-year financial reporting.
Reporting on social factors particular important during COVID-19
Of particular interest is the impact of COVID-19 on the people element of business. The outbreak has laid bare the importance of managing material social risks and opportunities among key stakeholder groups, such as employees, customers, suppliers and the community. The company’s response in relation to these matters should therefore be included in, and may even form the basis of, the social aspect of sustainability reporting.
Here are some examples of the social aspects that companies may want to consider and describe in their reports.
Employees: Response to governments’ call to institute safe distancing measures and embrace ‘work from home’ arrangements to the furthest extent possible.
Health and safety of employees, which hitherto have been perceived to be more of a concern for heavy industries, may have become a critical consideration for all types of businesses. Efforts here may include providing face masks and hand sanitisers to employees and facilitating telecommuting. The economic downturn brought on by the crisis has also threatened livelihoods, and job security is of key concern for many employees. The training and reskilling of staff to meet new challenges, leveraging on training grants, may also have been considered as an appropriate alternative to retrenchment. Businesses tread a fine balance between competing priorities, and need to lay out their plans when crystallised. They also need to keep everyone within their organisation connected virtually, in form, and more intangibly in spirit.
Customers: COVID-19 also impacts downstream customers, who may be unable to perform contractual obligations due to physical restrictions or financial difficulties. Issuers should describe any extension of assistance to customers where possible, from not insisting on strict legal rights to providing free or discounted goods or services. Our companies know well that when you support your customers through good times and bad, they will be there when things turn around.
Suppliers: Many businesses found out the hard way that maintaining visibility on associated risks in their supply chain is critical. With lockdowns in place in many countries, they have been forced to seek out alternative supplies. Issuers who have conducted a supplier assessment exercise as part of their sustainability reports would appreciate its importance to deal with both foreseen and unforeseen circumstances. They would do well to describe how they have considered their supply chain, and assess the impact of the potential of lockdowns.
Community: Many talk about not ‘wasting’ the crisis, calling on us to use it as a catalyst for change. Some businesses have sought to renew their social licence and enhance their legitimacy in the local communities by repurposing their facilities to produce scarce essential necessities such as face masks or hand sanitisers that are in short supply.
Others have organised their furloughed staff to help in national efforts to combat COVID-19, for example as safe distancing ambassadors or contact tracers. Issuers’ plans to show solidarity with the people will generate goodwill and other reputational benefits for the future.
Companies have taken and will need to continue to take myriad actions to deal with the COVID-19 crisis. The World Economic Forum (WEF) in its annual Global Risk Report has identified infectious diseases as a major global risk in terms of their debilitating impact. Yet the WEF did say: “Outbreaks of infectious disease may be inevitable, but the economic damage they cause is not.”1 Businesses can expect to be constantly challenged about how they intend to sustain themselves in the face of risks such as diseases. We would expect issuers to set out their plans and strategies to recover from COVID-19 in the annual reports or sustainability reports for the relevant period, with a special emphasis on the social aspects in their sustainability reports. Stakeholders can then benefit from a holistic understanding of the company’s responses.
Tan Boon Gin is the CEO of SGX RegCo, and Michael Tang is the Head of Listing Policy and Product Admission at SGX RegCo.