How to Manage Sustainability Data

HOW TO MANAGE SUSTAINABILITY DATA A Practical Guide to Effective Data Management

BETTER BEGINS NOW

As custodians of the built environment, we believe that we should never settle for the status quo, but constantly drive forward towards a more sustainable world, every day. We stand by our practical approach to go beyond the hype of future missions and goals, encouraging clients to take simple steps to make their asset, portfolio, or organisation more sustainable and better optimized to handle what tomorrow brings.

By taking action, we can ensure a better future begins now.

CLOSE DATA GAPS WHILE YOU STILL CAN

Real estate asset owners and occupiers are entering a perfect storm. For most, historical data management practices have not kept pace with changing market demands for more transparent and robust sustainability reporting. That’s putting organizations on a collision course with regulators and stakeholders. For one, the move from voluntary to mandatory reporting in multiple countries means applying the same rigor to sustainability reporting as financial disclosures. Increasingly, that requires having sustainability data – and the sources and collection methods – audited and assured. Regulators and lawmakers are also becoming bolder in calling out greenwashing and better at spotting problems with data accuracy and coverage. Alongside being audit-ready, this adds to the expectation that the data used to report on sustainability progress is accurate, complete, and prepared to a similar standard as financial accounts. The reality for many is that data isn’t being managed to these standards, and compliance deadlines aren’t moving. Without more effective data processes, operational oversight, quality control, and digital assistance, organizations risk paying a high price. For example, identifying data errors late in the reporting cycle is all too common, delaying disclosure, taking up executives’ time, and inviting unwanted market scrutiny. Avoiding these situations doesn’t have to be complex. This guide helps real estate owners, occupiers, and investors gather information, track, and report on their sustainability progress—all enabled by effective data management and governance. WHAT’S RAISING THE PRESSURE?

The shift from voluntary to mandatory reporting in many countries

Expectations of regulators, auditors, and stakeholders

A diverse range of sustainability disclosure standards

Short horizons for reporting and compliance readiness

Added complexity of reporting on Scope 3 being phased in

WHY, WHERE AND HOW SHOULD YOU REPORT?

Globally, there is a multi-speed shift towards mandatory sustainability reporting. This includes the work of the International Sustainability Standards Board (ISSB) in monitoring the progress of climate-related disclosures and pushing for uniform global standards. Built on the TCFD (Task Force on Climate Related Financial Disclosures) recommendations, the ISSB’s standards reflect a commitment to integrated financial and sustainability reporting. However, different frameworks are adopted in different countries, often with phased implementation. This raises important questions. At the outset, this includes ‘Why am I reporting?’, Is it to satisfy the regulator? For public disclosure? To demonstrate achievements? The answer carries varying considerations. That’s followed by ‘Where am I reporting?’, covering the countries and regulatory regimes you must account for – particularly for global asset portfolios where reporting may be required across multiple jurisdictions. Finally, ‘How am I reporting?’, the expectations for disclosing data that match your operating circumstances, including audit trails. These may seem basic, but these important questions can often be overlooked. The answers have longer-term implications for your data management practices and the data-driven insights that inform both sustainability and business decisions.

NORWAY

CANADA

UNITED KINGDOM

EUROPEAN UNION

SWITZERLAND

*UNITED STATES

JAPAN

*MANDATORY REPORTING FOR PUBLIC AND PRIVATE COMPANIES DOING BUSINESS IN STATE OF CALIFORNIA

CHINESE MAINLAND

TAIWAN, CHINA

MEXICO

INDIA

HONG KONG, CHINA

PHILIPPINES

COSTA RICA

SINGAPORE

PERU

BRAZIL

AUSTRALIA

SOUTH AFRICA

CHILE

NEW ZEALAND

MANDATORY REPORTING STATUS

LEGEND:

EXISTING

PROPOSED

HOW DO YOU GET IT RIGHT? THE DATA MANAGEMENT MATURITY-RISK CURVE

Addressing the why, where, and how foundational questions can reveal organizational gaps, ranging from grasping the application of specific regulatory directives to imperfect data collection, management and verification practices. This is where we move from conceptual to practical aspects of effective data management. To add perspective, it’s worth considering the real-world impacts of poor data management. Having complete and accurate sustainability data gives you the best chance of acting before issues become problems. For example, addressing the need for lower energy consumption at certain sites to meet annual targets. Failing to see your blind spots early can put you in an uncomfortable position, where previous disclosures must be walked back or explanations issued to senior management, investors, or your workforce. Regulators may also take a dim view of firms restating data given it can indicate poor governance and internal controls. Regulators may wonder what other data, such as financial disclosures, may be suspect. It’s a reminder that the risk isn’t theoretical. We consider best-practice data management to cover four core pillars, which together indicate maturity: process, people, governance, and technology. The general rule is that the above risks linked to sub-standard reporting reduce as you move up the maturity curve.

NASCENT Data is not complete and not accurate

MODERATE Data is partially complete and partially accurate • Process: Basic procedures for tracking scope boundaries and data inputs but lacking clear guidelines and assurance trail. • People: Some assigned roles and responsibilities, but data ownership remains unclear. • Governance: Limited quality checks and data validation. • Technology: Data stored in spreadsheets or siloed systems with some automation.

ADVANCED Data is on track to be complete and accurate • Process: Established procedures for regular updates to scope boundaries, utilities tracking, and supplier data management. • People: Clearly defined roles, responsibilities, and accountability across data owners. • Governance: Strong governance framework akin to financial processes with documented assurance processes. • Technology: Automated data feeds and a single platform for data retrieval and reporting.

• Process: No defined methods for tracking scope boundaries, utilities, or suppliers; no data management guidelines. • People: Unclear roles, responsibilities, and data ownership. • Governance: No verification, quality checks, or assurance measures. • Technology: Data stored in spreadsheets or scattered documents.

REPORTING RISK

DATA MATURITY

WHAT STEPS SHOULD YOU TAKE?

STEP 01

We have outlined four key steps and considerations to help put you on the right data management path. By adopting these attributes, you can confidently and more efficiently meet reporting obligations. Crucially, investing in data processes and maturity early can also reduce sustainability-related risks and your decarbonization costs over time.

STEP 02

STEP 03

STEP 04

SET UP BOUNDARIES AND SYSTEMS OF RECORD STEP 01: PROCESS

SET UP BOUNDARIES AND SYSTEMS OF RECORD STEP 01: PROCESS

Whether you have a sustainability team and data collection systems or not, it always comes back to understanding and refreshing the scope of your obligations. That means the first step is setting your organizational boundaries, and you can do this by considering some simple questions:

What is the ownership structure of the assets in my portfolio, which locations do I occupy, and who pays for energy bills?

What utilities do I have at each location, whether electricity, gas, diesel, or renewables-powered, and have I documented things like supplier account numbers? Which suppliers have I requested information from, and what is its status? What data is automatically provided or manually collected? Do I have contact details for everyone?

Do I know how many data sources should be listed in the information provided to me, for example, the number of meters and corresponding IDs?

What parts of my business or operations should be excluded from reporting, such as tenants or joint ventures? What justifies their exclusion, and does that align with your reporting framework?

WITH THIS BASELINE INFORMATION YOU CAN SET UP THREE SYSTEMS, EACH OF WHICH ARE KEPT UPDATED REGULARLY. THERE IS NO SUCH THING AS SET AND FORGET.

MASTER UTILITIES TRACKER

SUPPLIER DATA MATRIX

DATA MANAGEMENT GUIDELINES

A record of precisely what and who is behind your data, a checkpoint for completeness, and a reference point for an existing or future custodian.

A working list that can be updated as suppliers change, assets are bought or sold, or tenancies change.

Documented processes around what you do to collect and analyze data, how you do it, and how it aligns with regulatory frameworks.

These processes can help produce auditable reports and the accompanying explanation required if a decision is made to include or omit data. An auditor may request the ‘basis of preparation’ or conduct ‘spot checks’ in the same way they do for financial reporting, and having identifiable methods and processes will address red flags. They should also be updated or checked periodically to reflect ongoing changes in your business operations. Good processes require active management.

RETURN

STEP 02: PEOPLE MAKE ACCOUNTABILITY EVERYONE’S BUSINESS

Now that you’ve defined and recorded your boundaries and have processes to guide you, the next area of focus is ensuring a coordinated approach to day-to-day data collection and management. Remember, your Master Utilities Tracker and Supplier Data Matrix will help you understand what data to expect, where gaps exist, and in what format it is provided. What these tools won’t do is define roles, responsibilities, or the chain of accountability for your data owners. Unless everyone is clear about what’s expected of them, data consistency, accuracy, and efficient management can suffer. It’s also essential to consider all relevant internal and external data owners beyond utilities providers. This could include property or facilities managers or other internal contributors in areas like HR. Energy brokers can also be a valuable source of quality information, offering additional insights when collecting data directly from a site is challenging. Operations teams, contractors, and other third parties should also be considered. When aiming for complete and accurate data, prioritize completeness first. Once you have all the necessary details, explore opportunities to automate data collection. Automation is beneficial but requires ongoing attention and quality controls to ensure data integrity. MAKE ACCOUNTABILITY EVERYONE’S BUSINESS STEP 02: PEOPLE

Whether you’re an asset owner or occupier, the responsibilities for data provision and reporting can be embedded within leasing documents. This is a good way to set parameters upfront and manage ongoing collection and analysis. Did you know?

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STEP 03: GOVERNANCE VERIFY, VALIDATE AND LIFT QUALITY CONTROLS

VERIFY, VALIDATE AND LIFT QUALITY CONTROLS STEP 03: GOVERNANCE

Having strong data validation and governance controls is essential to good management. After all, even automated data can be incorrect, while other information can arrive in varying forms and languages from various sites, suppliers, and platforms. How can you – let alone an auditor – be reassured the data is accurate? It takes a high level of due diligence and care. Many challenges are addressed by sound data governance, and there are good reasons why robust checks and balances are important. For example, it’s not uncommon for gaps in data management, human error, or the use of spreadsheets over more reliable platforms to call reporting into question. When it happens, it takes time and effort from senior management to rectify. While not exhaustive, some of the measures below may help prevent that from occurring. When it comes to trend analysis, good governance will also ensure the veracity of insights.

• Errors or gaps in data feeds from meters and other sources • Details lost when information is translated from different languages • Estimated bills replaced by actual bills, leading to missing values • Incorrect data transferred between platforms or miscalculated estimates • Human error or lack of expertise in entering, validating, or reviewing data

• Regularly refresh organizational boundaries • Establish quality assurance processes, including specific actions if data is missing or late • Use processes to sample and test the integrity of data coming in • Assign a team to review the data and cross check against master lists • Regularly conduct peer reviews of the data • Verify data inputs through integrations with chosen platforms

COMMON

DATA QUALITY ISSUES

ACTIONS TO ENSURE HIGHER DATA QUALITY

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STEP 04: TECHNOLOGY LEVERAGE TECHNOLOGY, BUT LIMIT OVERRELIANCE

LEVERAGE TECHNOLOGY, BUT LIMIT OVERRELIANCE STEP 04: TECHNOLOGY

UNDERSTANDING THE ROLE OF DATA MANAGEMENT CONSULTANTS. Many organizations accept the challenge of maturing their data processes internally; however, if you don’t have the expertise or capacity, a data management consultant can be critical. They will guide you through establishing organizational boundaries, understanding the reporting frameworks, and managing the data collection and quality assurance processes. They can also help you understand the pros and cons of different technology solutions. A data management consultant is like a guide. If you know the way, you may not need them. But if this is your first time climbing the data management mountain, a guide will help you reach the top quickly and safely.

WHAT TO THINK ABOUT WHEN CHOOSING THE RIGHT SOLUTION

If you have the right processes, approach to people and governance, then you’ve reached a logical point to choose the technology tools and platforms that will help keep you on track. It’s helpful to think about the technology in two distinct categories. The first category is software or hardware tools that help you automate data collection, and the second category is platforms that store and manage your data and power reporting outputs. When it comes to platforms, it’s crucial to remember that having custom-built software doesn’t guarantee effective data management. In fact, it can create a false sense of security unless you have appropriate processes around the data flowing into the software. The old adage of “garbage in, garbage out” is true, but you may not even have “garbage” to begin with – in other words, don’t neglect to focus on how you obtain data in streamlined and repeatable ways. All it takes is for organizational boundaries to be slightly incorrect or outdated, or for an extra zero to creep into a data input, to create significant issues. Similarly, it’s crucial to document clear methodologies for auditors, such as the basis of greenhouse gas emissions calculations. While software can streamline the process, auditors need to understand how conclusions were reached, not just the final numbers. Ensuring all data and basis of-preparation documents are readily available will make the assurance process smoother and more efficient.

It may be tempting to leap straight into selecting software that looks like a ‘shiny race car’. However, it will be of little use if you don’t know which race you’re in or what “fuel” you need. Selecting the best platform relies on several considerations. The first is thinking upfront about the problems you’re trying to solve, the reporting frameworks you must navigate and your data sources. Then, ask if you are doing this to unlock operational improvements, report to regulators, or achieve goals. Having clear problem statements in mind can help you select the right software tools. You may also want to deep-dive into energy analytics and decarbonisation pathways or better manage energy to reduce OPEX alongside compliant reporting. These goals should influence your selection criteria. Another is thinking about your data owners and software users. If it’s a highly technical tool better suited to sustainability managers, it may not be the right fit for property or asset managers and vice versa.

COMPREHENSIVE DATA MANAGEMENT: ROLES AND RESPONSIBILITIES

YOUR TEAM

SOFTWARE

DATA MANAGEMENT CONSULTANTS

Guides data structuring, collection, and quality assurance processes.

Defines objectives, reporting needs, and problem statements.

Automates data collection and reporting.

PROCESS

Provides tools for different user needs (e.g., sustainability vs. property managers).

Manages data ownership and internal users.

Helps match software to user capabilities and organizational needs.

PEOPLE

Advises on frameworks, regulatory reporting, and assurance processes.

Ensures data accuracy, compliance, and audit readiness.

Stores data and flags inconsistencies but requires oversight.

GOVERNANCE

Selects and implements solutions aligned with business goals.

Powers data collection, storage, and visualization.

Evaluates technology options and ensures effective integration.

TECHNOLOGY

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DATA MANAGEMENT IN ACTION

INVESTOR ISSUES • Data completeness for water and electricity was less than 50% for 2023. CUSHMAN & WAKEFIELD ROLE • Assess data completeness of current platform and work with provider to improve it to be prepared for GRESB 2024. SOLUTION • Manage stakeholders, including client asset and property managers, retailers, and platform vendor. • Put in place regular touch points and evaluation of completeness. IMPACT • Improved data completeness of known accounts to close to 90% or higher before GRESB submission.

PORTFOLIO OWNER ISSUES • Needed to check, verify, and clean up energy data dating back to 2017. • Inconsistent data quality before moving into a platform. • Inaccurate billing in some locations. CUSHMAN & WAKEFIELD ROLE • Support a private company with 16,000 locations to report and adapt to new regulatory requirements. SOLUTION • Focused on ensuring quality data and establishing a single source of truth. • Created custom energy intensity data and filled data gaps. • Formed a multi-disciplinary team to develop processes, clean up past data, and move forward. IMPACT • Reduced emissions footprint by 20% through energy intensity factors. • Minimized errors and inaccuracies in data reporting and billing.

OCCUPIER ISSUES • Manage the collection of Scope 1 – 3 data sources (selected data sources for Scope 3). CUSHMAN & WAKEFIELD ROLE • Long-term client relationship through a broader Facilities Management contract. SOLUTION • Prepared, analyzed, and consolidated information into a data platform for single-source reporting. • Supported mandatory and voluntary reporting requirements, including NGERS, DJSI, CDP and the client’s own reporting. • Provided regular interim quarterly reporting for year-end preparation. • Established procedures and guidelines to ensure smooth operations and audit readiness. IMPACT • Ensured the client was ready for audits with minimal errors identified by auditors.

TAKE THE NEXT STEP

Irrespective of where you are today along the data management maturity curve, there is always room for improvement. Particularly as the phased nature of regulatory rollouts globally will encompass more organizations over time and include more complex requirements like Scope 3 reporting. If you are one of the many organizations that are in the earlier stages of building a reporting capability, there are simple steps you can take to lay strong foundations for the future and reduce your reporting and commercial risks as you go. For larger organizations where responsibility for these issues is spread across different stakeholders, working with a single data partner ensures a holistic approach. It can streamline decarbonization efforts and reduce reporting costs and errors.

NASCENT Data is not complete and not accurate

MODERATE Data is partially complete and partially accurate

ADVANCED Data is on track to be complete and accurate

DATA MANAGEMENT CONSULTANT FOR END-TO-END SUPPORT

DATA COLLECTION, MANAGEMENT AND GOVERNANCE

ALIGNMENT OF DATA COLLECTION WITH LOCAL REGULATORY FRAMEWORKS

VOLUNTARY REPORTING/ DISCLOSURES (GRESB, GRI, SASB, CDP)

MANDATORY REPORTING/DISCLOSURES (TCFD, ESRS, IFRS)

BUILDING CERTIFICATIONS (LEED, WELL, BREEAM, FITWEL, NABERS, GREENSTAR)

BENCHMARKING AND SCORE OPTIMIZATION

DATA PLATFORM SELECTION AND MANAGEMENT

SETTING PORTFOLIO PATHWAY TO NET ZERO EMISSIONS

MAXIMIZE AUTOMATION, VERIFICATION AND TRACKING

ROBUST DATA GOVERNANCE AND COMPLIANCE PROTOCOLS

ASSURANCE READY REPORTING

WE THINK & WE DO WE CAN CREATE YOUR STRATEGY AND IMPLEMENT IT TOO.

NET-ZERO CARBON

STRATEGY SUSTAINABILITY ADVISORY

EXECUTION SUSTAINABLE OPERATIONS

CLIMATE RISK & RESILIENCE

SUBSCRIBE TO OUR HOW TO GUIDES

COMPLIANCE, REPORTING & DISCLOSURE

SUSTAINABILITY ADVISORY We develop strategies to tackle challenges, meet stakeholders’

NET-ZERO CARBON

CLIMATE RISK & RESILIENCE We assess the climate-related impact on your assets and then help you manage, mitigate and disclose your risks and opportunities.

REPORTING & DISCLOSURES We help you navigate the complex compliance arena and demonstrate and communicate impact, through our reporting and disclosure solutions.

SUSTAINABLE OPERATIONS We help you manage your buildings responsibly. We benchmark, plan, monitor and then report progress.

We assess your baseline, create roadmaps and

expectations, and deliver on your corporate responsibilities.

optimize your path to net zero. Then we help you deliver .

HOW TO MANAGE SUSTAINABILITY DATA A Practical Guide to Effective Data Management

JESSICA FRANCISCO Chief Sustainability Officer jessica.francisco@cushwake.com

JAMES WOODHEAD Head of Sustainability Services, EMEA james.woodhead@cushwake.com

MATT CLIFFORD Head of Sustainability Services, APAC matt.clifford@cushwake.com

JACOB SCHENKER Sustainability Advisory jakob.schenker@cushwake.com

LUCY MATCHETT Sustainability Advisory lucy.matchett@cushwake.com

MIKA KANIA Sustainability Advisory mika.kania@cushwake.com

ABOUT CUSHMAN & WAKEFIELD Cushman & Wakefield (NYSE: CWK) is a leading global commercial real estate services firm for property owners and occupiers with approximately 52,000 employees in nearly 400 offices and 60 countries. In 2024, the firm reported revenue of $9.4 billion across its core service lines of Services, Leasing, Capital markets, and Valuation and other. Built around the belief that Better never settles, the firm receives numerous industry and business accolades for its award-winning culture. For additional information, visit www.cushmanwakefield.com.

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