Making Good on Promises – Measuring Non-financial Impacts


Oy Cheng Writes:

The Australian Government seeks to create impact investment funds to enable profitable capitalisation of natural assets and have released a discussion paper Discussion Paper Social Impact Investing (January 2017) on their view how to support the growth of this market.

The 2015 report on Impact Investing in Australia’s surveyed active social impact investments as of 30 June 2015 finding that the aggregate value of the 15 products surveyed was $1.2 billion. At this point, the market was dominated by green bonds ($900 million total).

By 2016, Impact Investing Australia has identified that the demand among local investors for social impact investing over the next five years as grown to at least $18 billion.

With such large demand to participate in impact investing there is a need to verify activities of the investment fund to confirm the activities of the investment.  Throughout the Government’s recent discussion paper, there is no discussion of the need to conduct third party verification or certification audits of either the investment fund itself or the activities of the investment (i.e. the impact).

For any financial instrument available on the market, APRA and ASIC has stringent regulatory requirements for financial reporting, data verification and audits, however, the same standards does not seem to apply to the independent verification of impact claims. All too often the claim of increased or successful impacts are justified by data provided by the teams involved in the development and management of the business and associated impacts, which have not been externally verified.

The increasing rise in demand for impact investments to be used as a mechanism to raise funds for social improvement project (such as the Murray-Darling Water Fund), and the nature of impact investors, makes it necessary to ensure robust systems are established to confirm the quality of impacts, and allay investors’ concerns relating to the efficiency and effectiveness of the fund. It’s a question of managing risk through robust systems.

Zoic Environmental is a specialised environmental and sustainability consultancy, experienced in due-diligence and compliance assessments of corporations and their supply chains. For more information, go to

EPA Auditor’s Meeting – 14 October 2016

Key points covered by NSW EPA at this meeting were:

  • Kate Herring identified that there are proposed changes to the CLM Act and CLM Regulation to promote better consistency and provide process for tracking Management Plans.
  • Anthea White provided an alert that Draft Auditor Guidelines released and identified notable proposed changes:
    • Requirement for Auditor to Notify EPA immediately of suspected false and misleading information, inaccurate waste classification, waste that has been taken to a facility that cannot lawfully receive the waste
    • Auditors are required to attach a Remediation Action Plan or Environmental Management Plan to the Site Audit Statement
    • Auditor’s are able to collect verification samples
  • Helen Prifti alerted all to new waste guidance for PFAS
  • Andrew Hawkins confirmed that Chemical Control Orders are currently being reviewed.  Patricia Fabiano foreshadowed some likely changes with respect to pesticides.


NSW EPA issues Waste Classification Guideline for PFAS – October 2016

The EPA has issued an Addendum to the Waste Classification Guidelines (2014) – Part 1: classifying waste in response to the classification of per- and poly- fluoroalkyl substances (PFAS) as emerging contaminants. The addendum contains interim test values developed by the EPA for specific contaminant concentration (SCC) and leachable concentration using the toxicity characteristics leaching procedure (TCLP) for the most common PFAS compounds. The addendum is available on the EPA’s website at:

NSW EPA releases PFAS Decision Tree – October 2016

The NSW EPA is implementing a state wide strategy to identify facilities in NSW where the past use of per- and poly-fluorinated alkyl substances (PFAS) may have resulted in site contamination.

This strategy includes an initial screening of sites, particularly focusing on whether the chemicals are present in soil or water. A decision tree has been developed to assist in the evaluation of the preliminary results for site prioritisation. This includes the use of trigger points to assist in the screening of data. Detailed investigations, if warranted, will be undertaken in accordance with appropriate contaminated land guidelines.

The decision tree will be reviewed following the release of national guidance on PFAS.

This document is now available on the EPA webpage and can be accessed here:

Draft Auditor Guidelines – October 2016

The NSW EPA has just released The Contaminated Land Management – Draft guidelines for the NSW Site Auditor Scheme (3rd edition) (the draft guidelines) for public consultation.

A copy of the draft guidelines and information on how comments can be submitted can be found at

Comments due 5pm 9 November 2016.