Introduction In practice, Indonesia’s environmental, social and governance (ESG) regime is best treated as a layered compliance environment. The main pressure points tend to come from: • environmental licensing, impact assessment and sanctions under the national environmental framework • capital markets and financial-sector sustainability reporting and governance expectations led by the Financial Services Authority (OJK), and • a growing set of climate/carbon market mechanisms that are operational enough to create data-integrity and claims risks even where full sector coverage is still evolving Private litigation is also a material risk channel, especially in the environmental realm, because Indonesia has accessible procedural tools for group claims and specialised guidance for courts hearing environmental disputes. Disclosure and reporting The backbone for ESG reporting in Indonesia remains OJK Regulation POJK 51/POJK.03/2017 on Sustainable Finance, which requires financial services institutions, issuers and public companies to apply sustainable finance and to publish a sustainability report (with phased implementation set out in the regulation and its appendices). In governance terms, listed/public companies also sit under OJK’s corporate governance framework

Introduction In practice, Ireland’s environmental, social and governance (ESG) compliance picture centres on Irish implementation and enforcement of EU regulation. The EU ESG regime is comprised of a combination of intersecting disclosure, due diligence, product and consumer-protection instruments rather than a single ‘ESG law.’ In practice, execution risk is driven by: • mandatory corporate reporting, for entities that remain in scope following the Stop-the-clock and Omnibus I amendments, led by the Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS) • financial market transparency under the Sustainable Finance Disclosure Regulation (SFDR) and EU Taxonomy • value-chain controls under the narrowed, Omnibus-amended Corporate Sustainability Due Diligence Directive (CS3D), for very large in-scope companies, together with ‘trade-gate’ measures like deforestation and forced-labour prohibitions, and • claims or marketing scrutiny through consumer law and supervisory expectations around ESG labels and fund names The EU regime is implemented in Ireland through Irish company law, consumer protection and sectoral regulators, with enforcement split across corporate reporting, consumer/competition law, financial supervision and environmental regulation. The practical implementation risk is

Introduction In practice, Japan’s environmental, social and governance (ESG) regime has a disclosure and governance core (eg capital markets, stewardship and comply-or-explain governance codes) which sits alongside a deep environmental compliance rulebook for waste, chemicals and pollution controls and a fast-moving decarbonisation policy regime. The day-to-day execution risk for multinationals is about whether statements to investors and consumers can be evidenced and whether operational sites and products are compliant with detailed lifecycle rules (especially for waste and chemicals) that are actively enforced through administrative tools and inspections. A second practical consideration is that Japanese ESG expectations are increasingly shaped by domestic standards explicitly built to incorporate International Sustainability Standards Board (ISSB) standards, which push companies toward audit-style controls for sustainability data and narrative consistency. Disclosure and reporting When it comes to corporate and investor disclosure, Japan is in an International Sustainability Standards Board (ISSB)-localised build phase. The Sustainability Standards Board of Japan (SSBJ) has issued sustainability disclosure standards designed to incorporate ISSB requirements (IFRS S1 and IFRS S2) with jurisdiction-specific alternatives and the Financial

Introduction Malaysia’s environmental, social and governance (ESG) regime is best understood as being led by capital markets disclosure, with a high execution risk around environmental compliance, driven by permitting, pollution controls and structured sustainability reporting, accompanied by assurance requirements. There is also a second enforcement lane that sits in consumer and trade description law, targeting misleading marketing claims. For most multinationals, the practical centre of gravity lies in three areas: • sustainability reporting expectations set through the National Sustainability Reporting Framework (NSRF) and Bursa Malaysia (Bursa) listing rules • Bank Negara Malaysia (BNM) climate/taxonomy expectations for financial institutions and financed-emissions conversations, and • the Department of Environment (DOE) permitting, Environmental Impact Assessment (EIA) gating and scheduled-waste controls for operational assets Reporting and disclosure On disclosure, Malaysia has moved decisively to align with the International Sustainability Standards Board (ISSB) baseline. The NSRF (announced 24 September 2024) sets IFRS S1 and IFRS S2 as the baseline sustainability disclosure standards, with phased coverage across listed issuers and certain large non-listed companies. This is

Introduction Mexico’s formal environmental, social and governance (ESG) regime (understood as a mandatory framework for measuring and reporting ESG indicators and performance) had been a long time coming, before being officially rolled out by the Federal Government through: • the issuance of Mexico’s Sustainable Taxonomy (issued on March 16, 2023) • an amendment to the Securities Market Law (on December 28, 2023) setting forth that general provisions should be issued in the areas of sustainable and responsible development, as well as gender equity, and • the amendments to the General Provisions Applicable to Issuers of Securities and Other Participants of the Securities Market (CUE, issued on January 28, 2025), providing the obligation for securities issuers to submit a sustainability information report prepared in accordance with the International Sustainability Standards Board (ISSB)/International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards (IFRS S1 and S2) Furthermore, on 13 May 2024, the Mexican Council of Financial and Sustainability Information Standards (CINIF) published the Sustainability Information Standards (NIS), which govern the sustainability performance information that must be disclosed by

Introduction South Africa’s environmental, social and governance (ESG) regime is best understood as a constitutional, principles-driven framework with strong environmental and consumer-protection underpinnings, executed through various Acts of Parliament and supporting regulations. Environmental permitting and enforcement Operational environmental compliance is permit and enforcement-led, with meaningful stop-start risk in projects if environmental authorisations or water use, air emissions and waste management licences are incomplete, poorly scoped, or vulnerable to administrative challenge under the National Environmental Management Act 1998 (NEMA) architecture (as amended by various subsequent enactments), its Environmental Impact Assessment (EIA) regulations and the Specific Environmental Management Acts (SEMAs). Many core environmental rules are national, but implementation is shared across national departments, provincial competent authorities and municipalities (for certain licensing and local environmental health functions). That split has operational significance—timelines, information expectations and enforcement posture can vary by geography and by the permitting ‘gate’ (for example, EIA/environmental authorisation sequencing under the EIA Regulations and listed-activity notices, versus sector licences such as air emissions and water use). Disclosure and conduct risk Disclosure and

Introduction South Korea’s environmental, social and governance (ESG) regime is a practical multi-regime system. In practice, execution risk usually comes from six channels operating at the same time: • listed-company governance disclosure through the Korea Exchange (KRX) and Financial Services Commission (FSC) regimes • developing sustainability-reporting standards through the Korea Sustainability Standards Board (KSSB) standards • environmental and product rules administered mainly by the Ministry of Climate, Energy and Environment (MCEE, formerly Ministry of Environment) • labour and occupational safety and health regulations (including regulations on serious accidents) administered mainly by the Ministry of Employment and Labour • Commercial Code, including directors’ duty to protect shareholders’ interests, administered by the Ministry of Justice, and • consumer-facing claim control by the Korea Fair Trade Commission (KFTC) That means legal teams need tracks for capital markets, risk and crisis management,

Introduction The main pillar of Switzerland’s environmental, social and governance (ESG) regime is company law disclosure, supplemented by targeted supply-chain due diligence rules, rules for green claims, supervisory transparency and risk management obligations of financial institutions and investment funds, as well as self-regulation against greenwashing in the financial sector. These company law rules are complemented by cantonal (regional) permitting and operational enforcement rules under federal framework statutes. For many multinationals, the practical trigger is the interaction between the following: • board and shareholders-approved non-financial and climate reporting duties for larger listed or Financial Market Supervisory Authority (FINMA) supervised undertakings in the Swiss code of obligations • FINMA expectations for nature-related risk transparency at large financial institutions, and • Swiss unfair competition and advertising enforcement routes for public claims Corporate disclosures and transition plans Switzerland introduced mandatory reporting on non-financial matters (environmental matters including climate, social/employee matters, respect for human rights and anti-corruption) for larger listed or FINMA supervised undertakings, with the report approved/signed at the top body level and published

Introduction In practice, Türkiye’s environmental, social and governance (ESG) regime is best approached as three overlapping systems that pull multinationals into ESG outcomes even when the obligation is not labelled that way: • first, capital markets and corporate reporting is rapidly hardening—the Public Oversight, Accounting and Auditing Standards Authority (KGK) has made Türkiye Sustainability Reporting Standards (TSRS) mandatory for defined categories of enterprises, with a formal assurance track • second, operational environmental compliance is still the sharpest edge for most businesses—permitting, inspections and administrative enforcement under the Environmental Law and the Environmental Impact Assessment (EIA/ÇED) process remain the most immediate sources of plant-level disruption risk • third, green claims and consumer-facing ESG statements are now an evidence-driven enforcement topic—the Advertising Board (RK) and the Ministry of Trade’s consumer protection apparatus have published a dedicated guide on environmental claims, which sits on top of general consumer and advertising rules Sustainability and climate related disclosures The reporting regime is now anchored in TSRS 1 (general sustainability disclosures) and TSRS 2 (climate-related disclosures). TSRS applies for accounting

Introduction The European Union (EU) ESG regime is comprised of a combination of intersecting disclosure, due diligence, product and consumer-protection instruments rather than a single ‘ESG law’. In practice, execution risk is driven by: • mandatory corporate reporting led by the Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS) • financial market transparency under the Sustainable Finance Disclosure Regulation (SFDR) and EU Taxonomy • value-chain controls pursuant to the Corporate Sustainability Due Diligence Directive (CS3D) and ‘trade-gate’ measures like deforestation and forced-labour prohibitions, and • claims or marketing scrutiny through consumer law and supervisory expectations around ESG labels and fund names This ESG regime is structurally established at EU-level, but most enforcement falls on Member States, with EU bodies coordinating and standard-setting, or supervising in the context of specific sectors. Corporate reporting For reporting corporates, the CSRD pushes sustainability information into the management report and assurance workflows, with ESRS specifying the detail and structure. Practically, this new reporting reality will require ‘double materiality’ assessment (covering both impact and financial materiality) and improved audit trails. Supply

Introduction In practice, the environmental, social and governance (ESG) framework applicable in the Netherlands largely consists of EU rules applied in a market characterised by civil litigation and regulatory oversight. Supervisory authorities In addition, the Dutch authorities pursue two pragmatic enforcement tracks: • consumer and competition-law are supervised by the Netherlands Authority for Consumers and Markets (ACM). This includes oversight of sustainability claims, commercial practices and sustainability-related agreements. On greenwashing, the ACM has positioned its Sustainability Claims Guidelines as the baseline ‘language of proof’ for commercial practices (such as marketing, websites and labels) and it expects substantiation that is specific, current, and verifiable • the financial sector is supervised by the Dutch Authority for the Financial Markets (AFM) focused on, among other things, ESG information in financial products, prospectuses and reporting. In its 2025/6 strategy, AFM made sustainability claims a supervisory priority for financial market participants and has published sector-specific expectations and review findings Greenwashing These two Dutch authorities lead to a dual-track claims risk around

Introduction The UK environmental, social and governance (ESG) regime is best understood as a collection of interlocking legal and regulatory frameworks rather than a single unified statute, some of which include: • capital-markets listing and disclosure rules • company-law narrative reporting • consumer/advertising controls on green claims • operational environmental permitting and producer-responsibility regimes, and • corporate duties to prevent fraud and corruption Execution risk In practice, execution risk concentrates where a business is publicly marketing ESG characteristics (consumer or investor-facing) and where it operates regulated assets or sells regulated products (permits, chemicals, waste, packaging). The same underlying set of facts may give rise to action through multiple channels (Financial Conduct Authority (FCA), Competition and Markets Authority (CMA)/Advertising Standards Authority (ASA), environmental regulators and private claims), so organisations must ensure that evidence and governance are consistent across functions rather than focused on compliance with any single regime in isolation. Private litigation Private litigation meaningfully shapes ESG risk in England & Wales, even where regulatory enforcement appears to dominate headlines. Compared with some European Union and United States jurisdictions,