Daniel Rossi

Spend-based emission inventories pass financial audits but offer no actionable insight to executive leadership. Emission factors are public and spend is audited, but the arithmetic works backward: purchasing a higher-cost low-carbon alternative increases reported emissions.

I directed the system restructuring across more than 50 legal entities. Carbon accounting software extracting on schedule from legacy ERP and accounts payable. A six-step data hierarchy ranking supplier-specific physical measurement above financial proxy. Consolidation mirroring the financial statements. Third-party pre-assurance on all three scopes. Built to the disclosure regime the group reports under — the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), with EU Taxonomy alignment on the same data.

The critical control enabling the entire system is the least visible. Physical activity data and capex/opex financial records double-count emissions unless spend tied to primary activity data is isolated and deducted under the direct accountability of a designated owner. This is an accounting control, not a reporting task.

A single dataset serving two audiences: traceable for auditors, actionable for business leaders.

An investment committee receiving separate assessments on climate, biodiversity, human rights, procurement, security, and ethics will invariably focus on whichever issue raises the highest media profile.

I coordinated the creation of the group’s twelve-criterion ESG investment screening framework. Every criterion is evaluated for risk, standard compliance, or opportunity, requiring documented evidence for each score. No composite score is produced, by design. The complete assessment sheet is a mandatory attachment for every investment proposal submitted to the committee.

Where the process sits matters more than its content. Screening triggers at initial project scoping when data is scarce and multiple red flags appear; these early warnings signal to project development teams which studies to commission. Confirmed risks translate directly into mitigation actions within project execution plans, avoiding parallel ESG documentation. Plans follow the asset throughout its lifecycle: development, construction, operations, and eventual decommissioning.

The core complexity lay not in defining criteria, but in synthesising Climate, Biodiversity, Human Rights, Procurement, Security, HR, and Ethics requirements onto a single operational page suitable for committee review.

The committee evaluates six distinct dimensions instead of approving a single score, enabling the business unit to maintain a defensible evaluation before lenders and regulators.

Decarbonisation involves change, and change affects people who did not choose it. Closing an asset deprives a region of its primary employer around which the community was built. Reducing office heating by two degrees requires staff to wear warmer clothes. Both encounter resistance for the same reason: the decision was made upstream.

Typically, the fundamental decision is already fixed, and stating this clearly is an essential part of the work. Plant closures result from board resolutions or national targets; local consultation does not reopen that choice. What remains open is implementation: timelines, compensation, retraining, alternative economic activities, and cost allocation. Presenting a fixed decision as open is quickly spotted by stakeholders, undermining all subsequent credibility. A rehabilitation peer review I ran found exactly this: stakeholders felt the operator had pre-selected its preferred option without genuinely evaluating alternatives.

For this reason, the level of participation is designed, disclosed, and evaluated. The group’s investment screening measures community engagement along a continuum from top-down planning to participatory consultation and co-design. The Just Transition dashboard subsequently developed applies this metric at the project level, featuring a dedicated indicator to identify actions required to elevate participation. Supporting both frameworks are a stakeholder engagement plan integrated into the project management baseline and a corresponding budgeting methodology.

Delivered in a highly complex setting: a plant with 750 employees at closure and severely strained community trust following a 45-day industrial fire. Written up afterwards as the group position paper and the case collection the corporate university taught from.

Key principle: pinpoint precisely which aspects of change are open for consultation before communicating, ensuring complete transparency regarding the distinction.

In a decarbonisation plan, Scope 3 depends on external decisions. With roughly 13,000 suppliers, the primary challenge lies in setting operational priorities.

Lacking supplier-specific emissions data, I structured prioritisation using procurement spend as a proxy across group commodity categories. This narrowed the focus to approximately 55 suppliers across eleven product categories, accounting for two-thirds of relevant spend and nearly one-third of purchased goods emissions.

Transport. The top ten logistics carriers account for ~80% of transport emissions. We adopted the ISO 14083 standard for data governance, defined a KPI in kg CO₂e per tonne-kilometre, and drafted contract clauses to be inserted during routine contract renewals, avoiding out-of-cycle contract reopenings. No carrier reopens a freight contract to add a carbon reporting clause; asking would jeopardise the contract terms. The data arrived anyway: carriers face the same regulatory demands as their clients, making data production low-cost and directly useful for their own reporting.

Information and Communications Technology (ICT). Accounts for ~8% of group emissions. Eight key suppliers assessed on a maturity matrix I populated through interviews with each of them. The analysis highlighted that AI components within cloud services lacked a standardised calculation methodology.

Procurement Governance. Established the group’s responsible procurement policy and developed a training programme for the entire procurement organisation, featuring individual coaching for category managers rather than classroom lectures.

Transport and ICT emissions data are captured without reopening existing contracts, and procurement teams possess the capability to formulate targeted, justifiable vendor requests.

A product line managed sustainability claims in isolation: a claim published on a platform without an underlying process or commercial justification for the investment. I developed the two missing components: a product sustainability claim validation process and a value-capture framework for ESG data.

Three distinct models based on generated value and negotiation dynamics:

Regulatory compliance alone provides purely defensive value. When customers deploy automated procurement systems (e.g., AI purchasing bots), these systems apply ESG criteria as hard filters, excluding non-compliant products before human review. Costs fall on the firm to gather vendor data, while vendors incur costs too. No margin is created to share.

Product differentiation creates direct competitive advantage rather than mere protection: superior ESG performance, funded by market share gains or premium pricing, generates value that can be shared between the company and its suppliers.

Preferential commercial channel access requires strong market presence. The distributor creates preferential shelf space while the supplier delivers qualifying products. Once established, suppliers actively seek entry.

Only the second and third models generate shareable economic value; deliberately selecting how to distribute that value determines whether the product line covers overhead for all parties. A favorable asymmetry applies: negotiating profit-sharing is far easier than allocating costs.

The company gains clear criteria for funding product ESG data and a claim validation process that withstands regulatory and customer scrutiny.

External validation incurs a recurring operational cost measured annually in reporting overhead. Selecting a framework based solely on brand reputation defers costs to the operational phase, where reporting competes with billable client work.

The objective was to identify external validation that was both globally credible and operationally sustainable with proportionate effort. Following an evaluation of options, the UN Global Compact was selected. Choosing a manageable tool over the most complex framework is a vital step often overlooked during planning.

I subsequently authored the annual Communication on Progress across four pillars—human rights, labour, environment, anti-corruption—integrating third-party verified carbon footprint data and biennial materiality assessments.

The firm keeps external validation it can still afford in year three, and a disclosure that stays signed.

Two applications of the same challenge, a decade apart.

At the consultancy, I defined and championed three strategic environmental goals—carbon negative, zero waste, and positive water balance—with firm deadlines published in a CEO-signed report, avoiding internal-only commitments where missed timelines carry no accountability. Carbon neutrality was achieved in 2020, verified by independent third parties.

At the industrial group, the situation was reversed: an inherited 2030 target was un-auditable, requiring cost-prohibitive retroactive re-baselining. I drafted the group decarbonisation plan and target framework. Baseline reset onto a current inventory. Reference ceilings to 2035 aligned to 1.5°C across all three scopes, published as comparative disclosure. Finally, counter to pressure for premature announcements, I formalised a recommendation for partial Scope 3 target omission, establishing a monitoring roadmap rather than an unviable commitment.

The board receives targets supported by an auditable baseline and, regarding Scope 3, a defensible stance rather than an untenable estimate requiring future retraction.

Centralised criteria risk being unworkable at operational units, revealing flaws only after capital is committed.

I originated carbon assets across five multilateral carbon funds structured by the World Bank, IFC, and KfW, totaling over €100M. Operations involved primary market purchases of Kyoto Protocol emission reductions, including forward contracts with delivery-contingent prepayments. With Middle Office I built the limit framework those portfolios were hedged against: the share of unverified future output committable today, discounted by how far the project producing it has got. They brought the risk methodology; I brought the project knowledge that made it applicable.

During the group’s €2.5B green bond issuance, I served on the technical sustainability criteria working group. My focus was operational verification: ensuring centralised criteria could be practically implemented across assets within my operational unit.

Business units receive actionable asset criteria, vetted prior to capital deployment rather than after.