This article is for Disclosers and provides new guidance for parent and subsidiary companies reporting via CDP. This article covers the new standard, detailing the instances where subsidiaries should respond and the instances where parents should respond on behalf of their subsidiaries, as well as how they are able to do so.
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The preferred approach is for parent companies to respond on behalf of their subsidiary companies by submitting a consolidated response to CDP, which includes all subsidiary data. This is in line with GHG Protocol, and the International Sustainability Standards Board’s IFRS S2. We recommend a consolidated responses to ensure the parent company has complete oversight of all requests at both the subsidiary and parent levels. It also has the added benefit of reducing the reporting burden since it avoids both the parent and subsidiary submitting a response.
While the above outlines the preferred approach, parent companies can disclose a consolidated or independent response from their subsidiaries and choose to respond for as many or as few of their direct subsidiaries as they wish.
When parent companies sign into the Portal, they will be able to see all of their direct requests from the Requested tab which appears under My Requests.
Please note, if a parent doesn’t have a request themselves, they won’t be able to view the subsidiary requests.
To accept subsidiary requests, parent companies should:
1. Click on the Optional tab
2. Navigate to the individual subsidiary in the list
3. Click the arrow to open the Requested organization details panel. This will show the environmental issues covered by the subsidiary’s requests as well as the number of requests that subsidiary has received. Click the red button that says Merge [your subsidiary’s request] to allow the parent to include those requests within its own reporting. This will prevent the subsidiary from being able to respond to those requests themselves.
Important: If the subsidiary has already started responding, their progress will be lost when the parent company takes the subsidiary’s requests. A warning message will appear notifying the parent company of this.
After merging a subsidiary’s requests with their own, a new ‘Delegated’ requests tab will appear on the parent’s dashboard.
This tab will show all the requests that have moved from that subsidiary to the parent. If that subsidiary had a subsidiary of its own, the latter subsidiary’s requests would also move up to the overall parent.
In this instance, multiple companies (both the subsidiary and the subsidiary’s subsidiary) will show on the parent’s ‘Delegated requests’ tab, as below.
All of a subsidiary’s requests will appear on the Requests page in the Portal by default. The subsidiary can respond to their requests, unless these requests are ‘merged’ by their parent, in which case the subsidiary can no longer respond separately.
The top of the subsidiary’s ‘My requests’ page explains that if a parent has taken over their response and this was unwanted, they can contact CDP for support. CDP can manually change the delegation of requests if needed.
When a parent takes a subsidiary’s request(s), this will be shown on the requesting company’s Request list, in the ‘Disclosing organization’ column.
For more information for Requesters, please see our article here.
Requesters can make changes to their Request list until July 19 Reach out to your Account Manager contact if you have questions.
The submission deadline for a scored response is September 18, and final submission deadline is October 2.
You may also find the following articles helpful:
-Understand your CDP request
-Timeline for responding
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