INFINZ is pleased to submit its comments on the draft sections on Strategy, Metrics and Targets as part of the new NZ CS 1 standards.
We commend the XRB on its continued effort in developing these innovative standards in such a short time frame. We urge the XRB to reconsider some of the extensive flexibility given to CREs in deciding which parts of the standard to disclose, as anything they deem immaterial could be avoided. We also disagree with the use of only single materiality, as this makes the disclosures a lot less useful for many end-users and the choice to not be prescriptive in the higher temperature scenario and on industry specific metrics. We elaborate more on these in the responses to the specific questions below.
Finally, we recommend disclosure of the materiality threshold being applied – such as what is currently being used in the Independent Audit Opinions.