The European Union (EU) also seeks to roll out new legislation and directives for large companies, listed companies, and funds. Notable examples of legislation and directives include the EU Deforestation Regulation (EUDR), Sustainable Finance Disclosure Regulation (SFDR), and the Corporate Sustainability Reporting Directive (CSRD), among others. The EU is actively pursuing regulatory measures related to social sustainability in general, as well as due diligence and environmental protection. These developments could have implications for organisations involved in the agricultural commodity markets, including the CFC and the smallholder farmers we serve.
The EUDR covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, as well as products derived from these commodities. It requires companies trading in these commodities to conduct extensive diligence on the value chain to ensure that the goods do not result from recent deforestation or breaches of local environmental and social laws. The regulation applies to goods produced on or after June 29 2023, with some exceptions, and companies are advised to carefully check which products are covered. The EUDR is part of the EU's efforts to curb the EU market's impact on global deforestation.
The EUDR may have both positive and negative effects on smallholder farmers. The regulation's stringent requirements and complex traceability standards could pose challenges for smallholders, potentially excluding them from the EU market and increasing their compliance costs. Many smallholder farmers lack the resources, secure land access, and information to comply with the EUDR, which may hinder their market access and livelihood. However, the regulation also presents opportunities for smallholders to access environmentally conscious markets, double their income, and drive innovation and technological adoption in farming practices. Empowering smallholder farmers to meet the EUDR requirements through rigorous awareness campaigns and other enabling measures such as improved land titles and sustainable practices, are seen as a longterm positive impact of the regulation. Nevertheless, the challenges in demonstrating compliance with the EUDR requirements, especially for independent smallholders, remain a concern. Overall, while the EUDR may create barriers for smallholder farmers, it also holds the potential to incentivise sustainable practices and improve market access in the long run.
The SFDR has been in application since March 2021 and sets out how financial intermediaries, such as asset managers, must communicate sustainability information to investors. The SFDR has implications for asset managers and investment firms, who are required to overhaul their investment processes, product strategies and reporting operating models, to comply with the regulation. While the specific impact of the SFDR on the livelihoods of smallholder farmers remains unclear, the regulation's focus on sustainable finance and disclosures is part of the broader EU efforts to promote environmental and social sustainability in the financial sector. As such, the SFDR and similar regulations could indirectly influence the investment landscape for sustainable agricultural practices, which may have implications for smallholder farmers in the long run. The CFC does not have an obligation to report on the SFDR as an international organization. However, the direct impact of the SFDR on smallholder farmers will depend on how the regulation shapes investment decisions and capital flows in the agricultural sector. The CFC therefore will have to pay due attention to the requirements of SFDR in its work.
The EU's Corporate Sustainability Reporting Directive (CSRD) aims to hold companies more accountable for their environmental and social impacts and to accelerate the EU's transition to a sustainable and climate-neutral economy. The CSRD is a new mandatory sustainability reporting framework that requires companies to disclose their material environmental, social and governance (ESG) impacts and risks throughout their value chain, in a standardised digital format as part of their annual reports. The directive is designed to provide investors with a reliable and comprehensive dataset on which to evaluate companies' sustainability performance and climate impact. The directive's focus on corporate sustainability and environmental impact is part of broader EU efforts to promote sustainability and climate neutrality. The CSRD's implications for smallholder farmers would depend on how it shapes the reporting and sustainability practices of companies involved in agricultural production and value chains. The directive's potential indirect influence on the agricultural sector could have implications for smallholder farmers, particularly in terms of promoting sustainable and climate-resilient agricultural practices. However, understanding the direct impact of the CSRD on smallholder farmers would require a more detailed analysis of its implementation and its effects on the agricultural value chain.
These factors combined have contributed substantially to the breadth and depth of sustainability reporting among various stakeholders. International impact reporting standards are still very much in the formative stage, and the CFC is looking to adopt best practices which accurately reflect our impact while not creating an excessive burden for the target beneficiaries. The CFC is acutely conscious of the impact of commodities and their value chains on the lives and livelihoods of those who work so hard to produce them. We constantly seek to support smallholders to increase their incomes in a people and planet friendly way.
Impact measurement: an ongoing work
The CFC acknowledges that the impact investing sector lacks a well-established and robust system that enables all investors to manage and track their impact effectively. While the sector has risen to the task of assessing social and environmental impact, substantial advancements in new tools, frameworks and standards have emerged in recent years. Despite this progress, the development of comprehensive and dependable parameters that match those utilised for risk and return in the traditional financial markets is still a long way off.
The selection of proposals that receive support from the CFC is largely based on their potential development impact. For this reason, each investment proposal submitted through the Open Call for Proposals is expected to provide indicators of the intended impact. Since the 13th Call for Proposals in 2018, the CFC has required prospective investees to present the estimated impact of their projects using the SDG framework. Specifically, proponents must explain how their project will contribute to the advancement of the core SDGs and provide target impact indicators for each year of the project, as well as baseline values using the IRIS+ metrics. Projects that fail to provide this information are typically not recommended for further consideration during the screening stage.
At the due diligence stage, the CFC reviews the impact indicators and incorporates them into the project agreement between the CFC and the project proponent. The agreement ensures that the project strives to accomplish its intended outcomes and reports specific impact indicators, as agreed upon with the CFC. This data is submitted to the CFC annually along with financial reporting. The CFC’s Impact Strategy is characterised by regular and consistent impact reporting in addition to financial indicators.
In the past five years, the CFC primarily disclosed selfreported data in its annual reporting. Where data was missing, a proxy from previous years is used to estimate the CFC’s impact figures. However, reporting standards have since evolved significantly due to (a) the greater awareness of global challenges (such as climate change and the pandemic), (b) new mandatory reporting requirements enforced by governments, and (c) the increased willingness of corporations and investors to leverage sustainability reporting to their benefit.7
Our experience as an impact investor clearly shows that SMEs have significant difficulties in measuring their impactconsistently and in line with sustainability reporting standards, which are becoming increasingly more complex and costly to implement. Neither the SMEs, nor the CFC, can allocate resources for impact measurement in accordance with complicated standards due to the small size of projects. The environment in which SMEs operate is challenging enough without the added costs and administrative burden of impact reporting obligations. As a result, the quality and timeliness of self-reported data increasingly falls short of CFC requirements, but adding to the reporting burden of CFC investees could undermine our core mission to serve the poor. The CFC therefore faces the challenge of constructing a framework that uses specific project contexts and case-specific assumptions to derive project impact evaluation from the routine project performance indicators.
To address the situation requires us to refine our assumptions and estimation analysis. This is a common approach to achieving concrete results with incomplete information, to increase the practical value of impact reporting. It involves making estimations about certain variables, quantities or outcomes based on available information, experience and reasoning. Below is a breakdown of the typical steps involved in the process:
• Understanding the problem: First, thoroughly understand the project and indicator for which an estimate is needed. This involves clarifying the relevant factors, constraints and objectives.
• Identifying key variables: Next, identify the key variables or factors that influence the outcome or quantity being estimated. This may involve breaking down the problem into its constituent parts and understanding how each variable contributes to the overall result.
• Gathering information: Gather relevant data, information and context to inform the estimation process. This may involve researching historical trends, industry benchmarks or other sources of data that provide insights into the problem at hand.
• Making assumptions: In many cases, certain aspects of the problem may be uncertain or unknown. Strategy consultants often need to make assumptions to fill in these gaps. These assumptions should be reasonable and based on the available information.
• Using analogies and models: Drawing on past experiences, analogies or mathematical models can help in making educated guesses. Strategy consultants may leverage similar scenarios or patterns observed in the past to inform their estimates.
• Iterating and refining: The estimation process is often iterative, involving multiple rounds of analysis and refinement. As more information becomes available or as the problem is better understood, the estimate may be adjusted accordingly.
• Communicating the estimate: Help stakeholders understand the basis of the estimate and its reliability by communicating the estimated value along with the assumptions, uncertainties and limitations involved in the estimation process.
Box 1 provides an illustration of how we derived the impact number from the reporting numbers of an investee company. The investee, Coffee Planet, purchases and markets coffee beans from farmers in Ethiopia. The model shown in the box illustrates how impact can be derived from the reported financial indicators using a set of assumptions from public sources. The CFC continues the compilation of impact evaluation assumptions and relevant methodologies, based on the project documents and specific commodity and regional focus. Portfolio impact indicators are reviewed and updated with appropriate methodology accordingly.