UK/Africa/America ESG Regulation Round Up 2023-2024

1. INTRODUCTION

Corporations are faced with an abundance of new laws and growing hazards related to their ecological disclosures. Environmental, social, and governance (ESG) is a framework that enables stakeholders to become aware of how organisations manage their ESG risks and opportunities.¹ ESG principles and frameworks are becoming mandatory rather than voluntary. Therefore, organisations need to figure out how to ensure that the information they gather and disclose is accurate, reliable, and relevant. The global setters' desire for more oversight and consistency throughout multiple areas has resulted in an ongoing evolution of the ESG regulatory setting. With noteworthy advancements over the past several months, the UK stands ahead and will be worthwhile to follow in the upcoming year. Investors in the UK are anticipating the implementation of the first part of the nation's ESG product labelling regulations, which shall concentrate on greenwashing, in May 2024. The ESG and climate disclosure requirements in North America are being cautiously developed. The US SEC's climate disclosure regulation was approved in March 2024, marking the most recent instance. The ESG regulations for the US, UK, and Africa are below.

2. UK DEVELOPMENTS

The primary UK ESG priorities for 2024–2025 are outlined in the FCA Business Plan 2024–2025.² The FCA is helping the financial industry bring about helpful change, such as moving toward net zero and examining broader sustainability issues. Integrating the Sustainability Disclosure Requirements (SDR) and labelling investment throughout the market, along with the anti-greenwashing rules and guidelines, will be the ongoing activity in 2024/25. Transition finance aids an organisation in rapidly responding to climate-related risks and credibly decarbonising its activities.³ Furthermore, it refers to financial products and services that assist companies with higher emission activities to decarbonise in the long run.⁴ The Green Finance Strategy was announced in 2023. This strategy intends to conduct a market-led review to develop transition finance in the UK to support foreign and home-based companies accessing the capital needed to decarbonise and fulfil the net zero goal.⁵ A call for information⁶about the Transition Finance Market Review (TFMR) became public on March 14, 2023. Many parties, financial institutions included, must respond by April 25, 2024. Initiated in January 2024, the TFMR is scheduled to provide its findings to the UK government by the summer of 2024.

2.2 UK Commons Reports on Finance and UK's Net Zero Transition.

The UK government released its response⁷to the November 2023 report, "The financial sector & the UK's net zero transition," by the House of Commons Environmental Audit Committee (EAC) on February 23, 2024.⁸ The UK financial industry can contribute to attaining net zero emissions of greenhouse gases by 2050, according to a report by the EAC. In response, the UK government outlines its ongoing efforts along with further measures to reach net zero, such as:

• Launching the Transition Finance Market Review
• We are developing the UK's strategy for climate transition plans.
• A forthcoming FCA discussion on a strategic approach to ISSB standards and recommendations for disclosures in plans for the transition of listed businesses.
• The FCA's implementation of the SDR of the 2023 Green Financial Strategy.
• She is urging UK companies to follow the recommendations of the Committee on Nature-related Financial Disclosures (TNFD).
• Offering advice on high-integrity voluntary carbon markets, the UK carbon border adjustment system, and the green taxonomy.

The FCA stated on January 16, 2024, that it had formed a sector-led committee for financial advisors to assist the sector in guiding customers on goods making claims for environmental sustainability considering the proposed UK system for the SDR & investment brands. The group aims to enhance the credibility and openness of environmentally friendly investment solutions.⁹

2.3 Developments in the UK ESG Ratings

The finalised version of the optional policy of guidelines for ESG ratings and information product providers was released by the ESG Data and Ratings Code of Conduct Working Group (DRWG) on December 14, 2023.¹⁰ The Code comprises six tenets, each accompanied by measures that offer an operational framework for applying and interpreting the concept. The principles cover the following: Effective governance, which requires providers to establish proper governance protocols to allow them to advance and maintain the values and overall goals; Ensuring quality, which calls for procedures and standards intended to help guarantee the delivery of excellent products; Conflicts of interests, which requires rules and processes to assist in recognising, prevent, or adequately handle, minimise, and reveal disputes; Transparency, which requires providers to prioritise their products concerning enough general disclosure and openness; Confidentiality: Providers ought to have policies in place to safeguard any private information about their goods that is disclosed to them by any of their representatives or obtained from them; and Engagement: Suppliers ought to assess how well their collecting data procedures work with the entities that their products are intended for.

After a provider joins the code, there will be an implementation phase during which the provider must integrate the principles into its operations. For ESG ratings suppliers, the implementation term is six months, while for ESG data product providers, it is twelve months.¹¹

2.4 The UK Unveils the Disclosure Framework Taskforce Transition Plan

The UK Transition Plan Taskforce (TPT) released a consultation on November 2023 that offers guidelines for those who design and use privately owned climate transition strategies. The consultation covers seven sector-specific "deep dives." Property managers, property owners, financial institutions, and other non-financial services sectors are among the industries covered. The deadline for the consultation was December 29, 2023.¹² The TPT released its final disclosure framework¹³ on October 9, 2023, to create a "gold standard" for thorough, reliable, and comparable disclosures on transition plans. The framework is intended to work in conjunction with other guidelines and systems, such as the standards set forth by the ISSB. Published in August 2023, the FCA's Primary Market Bulletin 45 announced the FCA's intention to consult in 2024 on regulations and guidelines for listed businesses to make disclosures per the TPT guideline as a supplementary package and the UK-approved ISSB requirements.¹⁴

2.5 Introduction of the Market Review for Transition Finance

The Market Review for Transition Finance was introduced on December 18, 2023, by HM Treasury and the Department for Energy Security and Net Zero (DESNZ).¹⁵ Vanessa Harvard-Williams is conducting the review, which will look at what the UK technical and financial services ecology must do to become an important centre and supplier of transitional monetary services. According to the conditions of reference, the review will look at which economic tools will have the most significant effects and investigate the best ways to set up the framework for expanding transition-focused fundraising ethically and optimising the chance for UK-based financial services to design and implement trustworthy transition monetary services.¹⁶ Although there is a chance that the study will be expanded to nine months, it will initially last for six months and report back to the government by July 2024. Representatives from the financial services industry will make up the panel of advisors, while the Bank of England (BoE) and the Financial Conduct Authority (FCA) will observe. The review was first mentioned in the Green Finance Strategy for 2023.¹⁷

3.1 ESG in Africa

It is uncommon to hear the terms "Africa" and "sustainability" in the same sentence. However, a silent ESG revolution is taking place throughout the continent, and many investors may soon become interested in it because policymakers in Africa are beginning to realise that ESG is here for good and will continue to impact the economy for years ahead.¹⁸ Consequently, several African countries have started to include ESG as a central issue in their continuing growth. When the Official Monetary and Financial Institutions Forum (OMFIF) surveyed economic growth across the continent a year ago, positive trends in the adoption of ESG were observed. Five more nations than in 2021, or 17 of the 26 in its financial sector ranking, have implemented financial regulations with an ecological focus.¹⁹

This is manifesting in various ways. For example, nine African nations, including Tanzania and Morocco, have started to issue debt tied to sustainability and are using these criteria to guide their national economic growth. Other countries have also established settings to draw in younger, environmentally sensitive investors. ESG disclosure guidelines have recently been introduced in South Africa, Uganda, Namibia, and Egypt, which has motivated companies to raise their accountability standards. To put things in perspective, the US and the UK continue to work on these same regulatory fronts.

ESG will undoubtedly be necessary for macroeconomic growth in Africa, as it will be in many other significant economies. The African Development Bank's recent announcement of a pan-African strategy to promote the spread of green finance and aid in energy transition projects served as a reminder.²⁰ Worldwide, the markets are being disrupted by ESG.²¹ Africa now has the chance to practically "catch up" with more developed economies, and indications of this have been seen already. For instance, according to the UN PRI, South Africa is one of the emerging economies with the highest percentage of PRI signatories (2%). In the meantime, just 1% of managers who have joined the UN PRI are from China.²² However, there are still difficulties being faced by the continent of Africa, such as many poverty issues; of its 1.4 billion people, 490 million are thought to be living in severe poverty. This presents obvious obstacles to some more poor areas where economic growth is still in its early stages. Nevertheless, the continent offers immense potential for ESG and has received vital backing from policymakers. Energy, minerals, and mining are the three industries currently dominating Africa's economy.²³

3.2 Africa's ESG Opportunities and Challenges

The adoption of ESG principles is a significant problem for Africa, particularly when compared to more advanced nations such as Europe and the US. Africa's dependence on resource and fossil fuel revenues creates challenges even as these regions quickly adopt ESG standards. Africa, however, might be the leader in developing a customised ESG strategy by utilising its unique conditions. Africa may emphasise cultural and political criteria, recognising its present financial structure, given regional differences in objectives, such as openness against protecting the environment.²⁴ In addition, the ESG Conference scheduled for October 2024 in South Africa will serve as a game changer for the dynamics of ESG in Africa and is aimed at giving insights to organisations on how to integrate ESG considerations into the totality of their corporate strategies.²⁵

ESG integration requires comprehensive organisational change, much like previous digital transitions have. It calls for integrating ESG standards into every aspect of business operations, from planning to day-to-day procedures, going beyond discrete acts. Companies must foster an environment where choices are based on ESG considerations, and the leadership needs to lead this change. If thorough transformation is not accomplished, there is the danger of lost value, unhappy customers, and financial damage.

3.3 Expert Advice for the Implementation of ESG

Acknowledging the multifaceted nature of ESG, companies stepping foot in this area ought to consult experts, just like with digitisation projects. Experts can assess dangers and social effects on investment, create customised ESG tactics, instruct and train staff, and monitor current initiatives. By ensuring financial sustainability and efficient integration of ESG, this strategic method helps companies manage the transitional process with a sense of direction.²⁶

Multinational corporations (MNCs) have several exciting opportunities in the area of ESG roles due to Africa's swift rise as a centre for growth and investment. Significant possibilities include the growing awareness of environmental and social issues among African customers, driving their demand for sustainable solutions. Governments throughout the continent are also establishing more stringent laws, which creates a favourable environment for businesses that adhere to high standards of ESG. Advances in technology, especially in digital farming and energy efficiency, create additional potential for MNCs to contribute to growth and sustainability in Africa. Cooperation between MNCs, authorities, and communities at large provides a guarantee for improving common ESG goals and revealing shared creation of value. Finally, the increasing popularity of ESG-conscious investing offers channels for MNCs with strong ESG dedication to utilise assets and foster sustainable business practices.²⁷

MNCs need to take a proactive and calculated strategy to prosper in Africa's changing ESG environment. This entails incorporating ESG factors into fundamental business plans and going beyond simple compliance to incorporate ESG guidelines into operational frameworks and decision-making procedures. MNCs must create specific to-context strategies to tackle the various ESG issues common in their business areas. Establishing trust and forming partnerships requires transparent reporting procedures and active cooperation with neighbourhoods, governments, and with other stakeholders. By utilising innovative technology, MNCs can produce significant solutions that tackle social and environmental problems and encourage collaboration and joint ventures to expedite attaining environmentally-friendly objectives.

For Multinational corporations, developing ESG within Africa offers tremendous prospects and difficulties. MNCs may significantly impact creating a future for the continent and its residents that is more just, fair, and successful by adopting environmentally friendly procedures and handling obstacles with insight. MNCs can advance their business goals and provide long-term value for stakeholders in Africa while promoting environmental sustainability, economic expansion, and social stability through strategic expenditures, cooperative partnerships, and adherence to ESG standards.²⁸Top of Form

3.4 Renewable Energy Potential in North Africa

North Africa stands out as a leader in developing renewable energy, especially in Morocco and Egypt. With the largest concentrated solar energy facility worldwide, plus the ability to generate wind power from onshore solid winds, Morocco is already supplying a sizable amount of its electricity demands from renewable sources. Significant foreign investment is also drawn to Morocco due to its potential for producing green hydrogen, as demonstrated by accords such as the EU's Green Partnership pact and the Germany-Morocco Hydrogen pact. Egypt has shown leadership in developing renewable energy, as evidenced by its hosting of COP 27, and its banking industry is actively committed to lowering emissions and incorporating ESG risk assessments into lending decisions. These advancements highlight North Africa's advantageous location and promise as a future centre for green hydrogen and renewable energy generation.²⁹

Although there is an extremely high adoption of renewable energy in North Africa, other African countries are still a work in progress.³⁰ Using the River Nile as a resource, Ethiopia and Angola are building dams to generate hydroelectric electricity. The Great Ethiopian Revolution Dam is the largest hydroelectric project in Africa.³¹ A significant focus on green hydrogen is emerging throughout the continent, as seen by the formation of the African Green Hydrogen Alliance, which includes Kenya, Egypt, Mauritania, Namibia, Morroco, and South Africa, among other countries. With projects like the Tsau Khaeb initiative in Namibia and Mauritania's aggressive production of green hydrogen ambitions, signifying more significant attempts to boost renewable energy across Africa, this partnership seeks to encourage green hydrogen generation on the continent.³²

3.5 Opportunities for Expanding Renewable Energy and Green Hydrogen

There is much promise for Africa's renewable energy landscape with green hydrogen, and there are joint initiatives to increase its production and use. The continent's dedication to cutting emissions and adopting sustainable energy alternatives is demonstrated by initiatives like Namibia's Tsau Khaeb project and Mauritania's aggressive green hydrogen goals. Africa is positioned to unleash its immense capacity for renewable energy as the African Green Hydrogen Alliance grows with collaborations and investments, opening the door for a more robust and sustainable energy future for the whole continent.³³

Companies are realising how crucial it is to conform with ESG best practices, taxes, and disclosure requirements as ESG principles become increasingly integrated into business strategies globally. Africa is uniquely positioned to play a significant role in the global shift towards a more sustainable economy because it recognises the widespread influence of ecological and sustainability concerns on all economic sectors.³⁴

4. US DEVELOPMENTS

strong>4.1 US National Business Sustainability Action Plan

The Biden-Harris Administration unveiled the United States' next National Action Plan (NAP) on Ethical Conduct for Business, highlighting a comprehensive strategy to promote responsible commercial behaviour locally and abroad. Respecting human rights due diligence (HRDD) along the value chain and promoting respect for people's rights are critical components of the NAP, which aligns with international principles, including the principles set forth by the UN and the Guidelines of the OECD (Organization for Economic Cooperation and Development).³⁵ The NAP outlines four key areas where the government will concentrate its efforts to encourage ethical corporate practices and expedite adopting HRDD procedures. These are:

• I am creating a Federal Advisory Committee on Responsible Conduct in Business to oversee the development and execution of the NAP and provide feedback from a broad range of stakeholders to strengthen programs, guidelines, and initiatives.
• We are enhancing federal procurement procedures and policies' adherence to human rights.
• It offers firms resources, such as creating new guidelines to urge investors to do HRDD when considering investing in technological advances that could facilitate or worsen human rights violations.³⁶

Finalised Climate Reporting Regulations by the SEC

Rules to improve and harmonise climate-related disclosures by publicly traded corporations and initial public offerings were enacted by the US SEC on the 6^th of March, 2024. The requirements will still necessitate a significantly higher level of statutory and financial disclosures, but they are less onerous than the SEC planned in 2022. Among other things, the proposed obligation to report scope three emissions has been removed.³⁷

4.2 US ESG Regulations: A Comparative Analysis

• US Regulatory Environment: The United States has traditionally relied on market forces and voluntary ESG laws, but the UK has taken a more directive approach. Instead, a discernible shift has occurred over the past several months, as evidenced by the surge of initiatives from government agencies such as the SEC and other associations. This shift was sparked by an executive order signed by President Biden in February 2021, which required all economic sectors to examine, disclose, and minimise risks associated with climate change. Since then, the SEC and other regulators have increased their attention to sustainability and ESG concerns. To speed up the energy transition, they have suggested additional disclosure laws, established dedicated task groups, and offered tax relief.³⁸
• Federal Government and Industry Measures: Various federal agencies have increased efforts to control climate hazards and encourage ESG compliance and disclosure over the last two years. A commitment to coordinating regulatory procedures with global structures like the Working Group on Climate-Related Financial Disclosures (TCFD) is shown by projects like the Inflation Reduction Act and upgrades to the Climate Risk Disclosure Assessment conducted by the National Association of Insurance Commissioners. Furthermore, the federal government's role in forming the ESG regulatory landscape is further cemented by suggested regulations by the Federal Trade Commission and SEC, which seek to improve sustainable marketing practices and harmonise climate-related reports, respectively.
• Measures and Rules at the State Level: Although there has been much federal action, numerous states in the US are also working toward ESG-related objectives. Certain states have mandated diversity standards for business boards or utilised retirement savings systems to encourage sustainable investments. Regulating carbon offsets and net zero claims, in addition to requiring climate risk disclosures in line with TCFD structures, is one area where California has distinguished itself as a pioneer.
• The Standardization and Disclosure Rulemaking Initiatives of the SEC: The SEC is a critical player in developing ESG disclosure guidelines and continuously works to improve reporting uniformity and openness. Modifying the Investment Company Act (ICA) and proposed regulations about investor disclosures on climate change could establish new standards for ESG reporting. The approved cybersecurity disaster disclosure and control regulations further demonstrate the SEC's commitment to thoroughly addressing new ESG risks.³⁹
• Impacts and Future Directions: Considering the issues posed by climate change, the US expanding ESG regulatory framework indicates an increasing understanding of the necessity of adaptive risk control and uniform disclosure.⁴⁰
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4.3 Regulations for US ESG Disclosure

The US Securities and Exchange Commission (SEC) has released guidelines and rules outlining its expectations for disclosure and mandates that all publicly traded corporations publish any information that could be relevant to investors, including information on risks associated with ESG. The SEC finalised changes to the ICA in September 2023 to ensure resources with names that emphasise one or more ESG factors have invested more than 80% of their funds in compliance with such priority, and the SEC embraced new cybersecurity incident disclosures and oversight regulations in July 2023. It is anticipated that the rules governing ESG disclosure will substantially shift in the upcoming months. By the year's end, the SEC will likely implement proposed disclosure regulations related to climate change. The SEC is also expected to publish further proposed regulations regarding diversity on boards and human capital. Furthermore, many federal authorities have released guidelines and suggested rules on the disclosure and supervision of environmental and sustainability issues. These agencies include the Federal Trade Commission, the Federal Acquisition Regulatory Council, and federal bank regulatory agencies.⁴¹

4.4 Main Issues for ESG Advocates

ESG proponents are presently concentrating on several important topics. These include issues with managing human resources, particularly about equality, inclusion, and diversity, as well as the supervision, administration, and reduction of hazards associated with climate change and the switch to renewable energy. Furthermore, concerns about stakeholders' interests and corporate purpose are gaining significance due to supply chain durability, geopolitical threats, and ecological difficulties. Cyber security threats continue to be of utmost importance, and attempts towards uniformity are being driven by the disjointed character of the ESG disclosure landscape. Moreover, authorities and investors are becoming progressively concerned about greenwashing, particularly regarding carbon reduction and net-zero commitments.

4.5 Significant Developments in ESG

The ESG landscape will witness several noteworthy advancements in the coming year. These consist of the continuous worldwide development of the requirements for required disclosure and the unification and harmonisation of voluntary standards for reporting, especially under the International Sustainability Standards Board (ISSB) umbrella. Amid economic and geopolitical concerns, investors continue to be focused on energy transitions, but workforce mobility and advances in AI are drawing more attention to managing human resources. Worries about biodiversity and its impact on society and the economy are also anticipated to grow. Furthermore, legislative initiatives to enforce ESG disclosures and stop greenwashing, as well as criticism from anti-ESG stakeholders concerning conformity with the interests of shareholders, are anticipated to gain support in the upcoming year.⁴²

5. Reflections

The ESG landscape encountered several difficulties in 2023, such as market volatility, political criticism, and worries over greenwashing. No matter what term was used to describe it—corporate social duty, sustainability, or ESG—the fundamental idea of taking these elements into account prevailed in the face of these challenges. ESG has become a vital part of the financial industry, influencing boardroom and C-suite talks, forming business policies, and influencing the economy. Notwithstanding conflicting news, capital providers and businesses acknowledge ESG as a value driver, with stable securities providing many options for companies looking to shift to an environmentally friendly society.

Footnotes

1. CFI, "ESG (Environmental, Social and Governance)" https://corporatefinanceinstitute.com/resources/esg/esg-environmental-social-governance/ accessed June 18 2024.

2. Financial Conduct Authority, "Business Plan 2024/25" https://www.fca.org.uk/publications/business-plans/2024-25#lf-chapter-id-commitments-4-13--minimising-the-impact-of-operational-disruptions accessed June 7 2024.

3. The Global City, "Transition Finance Market Review" https://www.theglobalcity.uk/tfmr accessed June 19 2024.

4. GOV.UK, "Transition Finance Market Review" https://www.gov.uk/government/publications/transition-finance-market-review accessed June 19 2024.

5. Ibid note 5.

6. Transition Finance Market Review, "Call for Evidence" https://www.theglobalcity.uk/PositiveWebsite/media/research-downloads/TFMR-Call-for-Evidence-2024-03-14.pdf accessed June 7 2024.

7. House of Commons Environmental Audit Committee, "The Financial Sector and the UK's Net Zero Transition-Government's Response to the Committee's First Report- Third Special Report of Session 2023–24" https://committees.parliament.uk/publications/43462/documents/216112/default/ accessed June 8 2024.

8. UK Parliament, "The Financial Sector and the UK's Net Zero Transition; First Report of Session 2023–24" https://publications.parliament.uk/pa/cm5804/cmselect/cmenvaud/277/report.html accessed June 8 2024.

9. Hogan Lovells, "UK/EU ESG Regulation Round-Up – Q1 2024" https://www.engage.hoganlovells.com/knowledgeservices/news/ukeu-esg-regulation-round-up-q1-2024 accessed June 8 2024.

10. International Regulatory Strategy Group, "Publication of a Code of Conduct for ESG Ratings and Data Products Providers" https://www.irsg.co.uk/drsg/ accessed June 9 2024.

11. Hogan Lovells., "UK/EU ESG Regulation Q4 2023 Round-Up and Horizon Scanning for 2024" https://www.lexology.com/library/detail.aspx?g=61b6313d-b2e4-4535-b9ac-db28389d3699 accessed June 9 2024.

12. Transition Plan Taskforce, "Sector Guidance" https://transitiontaskforce.net/sector-guidance/ accessed June 9 2024.

13. Transition Plan Taskforce, "Disclosure Framework" https://transitiontaskforce.net/wp-content/uploads/2023/10/TPT_Disclosure-framework-2023.pdf accessed June 9 2024.

14. Financial Conduct Authority, "International Sustainability Standards Board: IFRS S1 and S2" https://www.fca.org.uk/publications/newsletters/primary-market-bulletin-45 accessed June 10 2024.

15. GOV.UK, "Transition Finance Market Review" https://www.gov.uk/government/publications/transition-finance-market-review accessed June 10 2024.

16. GOV.UK, "Transition Finance Market Review: Terms of Reference" https://www.gov.uk/government/publications/transition-finance-market-review/transition-finance-market-review-terms-of-reference accessed June 10 2024.

17. Ibid note 14.

18. Tatton, "ESG in Africa" https://tattoninvestments.com/esg-in-africa/ accessed June 10 2024.

19. Ibid.

20. Africa Development Bank Group, "Africa Development Bank Launches Model for Deploying Green Financing Across the Continent" https://www.afdb.org/en/news-and-events/african-development-bank-launches-model-deploying-green-financing-across-continent-56903 accessed June 20 2024.

21. Worldfavor, "Companies Affected by Mandatory ESG Reporting-Here's the List" https://blog.worldfavor.com/countries-affected-by-mandatory-esg-reporting-here-is-the-list accessed June 20 2024.

22. Ibid note 19.

23. Ibid note 19.

24. PWC, "An ESG for Africa?" https://afrique.pwc.com/fr/actualites/decryptages/esg-for-africa.html accessed June 11 2024.

25. AR Managing Editor, "ESG Africa Conference 2024:Shaping Africa's Sustainable Future Through Leadership" https://www.africanresearchers.org/esg-africa-conference-2024-shaping-africas-sustainable-future-through-leadership/ accessed June 20 2024.

26. Ibid.

27. Sebastian Ngida., "The Future of ESG in Africa: Opportunities and Challenges for Multi National Corporations [MNCs]" https://www.linkedin.com/pulse/future-esg-africa-opportunities-challenges-multi-national-ngida-vbqtf/ accessed June 11 2024.

28. Ibid.

29. Kristina Holzhäuser., "ESG in Emerging Markets: Africa" https://www.commerzbank.com/portal/en/cb/de/firmenkunden/insights/financing_green_transition.html accessed June 12 2024.

30. United Nations Economic Commission for Africa Office for Noth Africa, "The Renewable Energy Sector in North Africa" https://archive.uneca.org/sites/default/files/Publication Files/renewable_energy_sector_in_ north_africa_en _0.pdf accessed June 20 2024.

31. The Washington Post, "Africa's Largest Dam Powers Dreams of Prosperity in Ethiopia -and Fears of Hunger in Egypt " https://www.washingtonpost.com/world/interactive/2020/grand-ethiopian-renaissance-dam-egypt-nile/ accessed June 20 2024.

32. Green Hydrogen Organisation, "The Africa Green Hydrogen Alliance (AGHA)" https://gh2.org/agha#:~:text=Six%20leading%20African%20countries%2C%20Egypt,projects%20on%20the%20African%20continent.&text=for%20domestic%20use%20and%20export. accessed June 20 2024.

33. Ibid note 30.

34. James Brand., "The Growth of ESG as a Focus Area in Africa" https://www.ensafrica.com/news/detail/6053/the-growth-of-esg-as-a-focus-area-in-africa accessed June 12 2024.

35. Simmon Simmons., "ESG View April 2024" https://www.simmons-simmons.com/en/publications/clv50l99400notzegflng4zcp/esg-view-april-2024G accessed June 13 2024.

36. Ibid.

37. Ibid note 10.

38. D M Silk., W.X. Carmen., "Environmental, Social & Governance Law USA 2024" https://iclg.com/practice-areas/environmental-social-and-governance-law/usa#:~:text=1.2%20What%20are%20the%20main,setting%20forth%20its%20disclosure%20expectations. accessed June 14 2024.

39. Ibid note 39.

40. Ibid.

41. Ibid.

42 Ibid note 39.

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