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The Ultimate ESG Checklist for Malaysian Public Listed Companies

The Ultimate ESG Checklist for Malaysian Public Listed Companies

Reading Time: ~11 minutes
Key Takeaway: To stay ahead and compliant, Malaysian public listed companies must embed ESG into governance, reporting, risk management, strategy, and stakeholder engagement. Use this checklist as your practical guide.

Introduction (PAS Framework)

Problem:
Many Malaysian public listed companies know ESG (Environmental, Social, Governance) is important—but struggle with where to begin. The regulations, frameworks, stakeholder pressures, and reporting standards make ESG feel complex, overwhelming, and risky to get wrong.

Agitation:
If you skip or underreport something, you could face regulatory criticism, investor distrust, or reputational damage. Worse, your ESG efforts may look like greenwashing—claims without substance. You might miss opportunities to add real value or competitive edge through ESG.

Solution:
This post gives you “The Ultimate ESG Checklist for Malaysian Public Listed Companies.” It cuts through the noise. You’ll get a clear, stepwise checklist covering governance, environmental metrics, social actions, reporting, assurance, and stakeholder engagement. Follow it, and your ESG efforts become structured, credible, and business-relevant.

Summary Box

SectionKey Focus
Regulatory FoundationsUnderstand Bursa and Malaysian ESG rules
Governance & LeadershipBoard oversight, roles, policy
Materiality & RisksIdentify ESG risks/opportunities
Environmental MetricsEmissions, energy, water, waste
Social MetricsLabor, community, human rights
Governance MetricsEthics, compliance, board diversity
Reporting & DisclosuresSustainability statements, frameworks
Assurance & AuditThird-party checks, internal review
Stakeholder EngagementCommunicate and respond to stakeholders
Continuous ImprovementMonitor, review, update ESG efforts

The Ultimate ESG Checklist for Malaysian Public Listed Companies

Below is a straightforward checklist. Think of it as your ESG “to-do list” for compliance, credibility, and impact.

1. Regulatory & Framework Foundations

  • Confirm your obligations under Bursa Malaysia Listing Requirements: since 2015, listed issuers must include a sustainability statement in annual reports, describing how they manage material environmental, economic, and social (EES) risks and opportunities. SSE Initiative+2Tay & Partners - Under development+2

  • Refer to the Bursa Malaysia Sustainability Reporting Guide (3rd Edition) to guide disclosures. Bursa Malaysia+1

  • Stay updated on the new ESG reporting requirements: companies with market capitalisation > RM2 billion must start under IFRS S1/S2 disclosures in 2025; other Main Market firms in 2026; ACE Market in 2027. London Reporting Academy+2London Reporting Academy+2

  • Align with national policies such as the i-ESG Framework for industries, especially manufacturing, which supports capacity building and standardisation. Roedl

  • Understand existing environmental laws (e.g., Environmental Quality Act 1974) and social legislation (labour laws, occupational safety) relevant to your sector.

2. Governance & Leadership

  • Ensure ESG oversight at the board level—create or designate a Sustainability Committee.

  • Define roles and responsibilities: who leads ESG, who reports, who audits.

  • Approve an ESG or sustainability policy endorsed by top management.

  • Integrate ESG into risk management, strategy, and performance assessment.

  • Conduct training for directors and senior management on ESG topics, climate risk, and governance best practices.

3. Materiality & Risk Assessment

  • Carry out a materiality assessment to identify which ESG issues matter most to your business and stakeholders.

  • Classify issues by impact and likelihood (e.g. climate risk, water stress, labour practices, supply chain).

  • Document how you selected material issues and how you prioritize them.

  • Map risks and opportunities for each material topic (e.g. carbon pricing, regulatory changes, community relations).

  • Link ESG risks/opportunities to your business strategy and planning.

4. Environmental Metrics & Actions

  • Measure your Greenhouse Gas (GHG) emissions, ideally in scopes 1, 2, and gradually scope 3.

  • Track energy consumption (electricity, fuel), and set energy intensity targets.

  • Monitor water usage and water efficiency measures.

  • Track waste generation and recycling, hazardous waste handling, separated waste streams.

  • Monitor air emissions, pollutant discharges, and biodiversity where relevant.

  • Implement energy efficiency projects, renewable energy, water-saving systems, waste reduction programs.

  • Record environmental incidents, fines, violations, and corrective actions.

5. Social Metrics & Programs

  • Track labor and employment data: workforce demographics, turnover, training, safety incidents, lost time injury frequency rate (LTIFR).

  • Ensure occupational health & safety (OHS) policies, incident reporting, preventive programs.

  • Monitor human rights / supply chain: vendor code of conduct, audits, child/forced labour safeguards.

  • Engage with community & social investment: CSR programs, stakeholder outreach, local development.

  • Track diversity, equity & inclusion (DEI) metrics: gender, minority representation, inclusion programs.

  • Monitor employee satisfaction, grievance handling, whistleblowing mechanisms.

6. Governance Metrics & Controls

  • Maintain code of ethics / anti-corruption policy, with training and enforcement records.

  • Track compliance and litigation: regulatory penalties, legal actions, mitigations.

  • Ensure board diversity and independence metrics.

  • Monitor audit and internal controls: internal audit findings, corrective actions.

  • Report on executive compensation linked to ESG or sustainability performance where possible.

  • Document tax transparency and governance of tax strategy.

7. Reporting & Disclosure

  • Prepare a Sustainability Statement following Bursa’s guidelines. Tay & Partners - Under development+1

  • Use recognized frameworks (GRI, SASB, or align with IFRS S1/S2 later) to structure your disclosures. Elite Asia+1

  • Include 3 years of performance data (where possible) and targets for future. Tay & Partners - Under development+1

  • Use clear, balanced language—disclose both successes and challenges.

  • Provide assurance statement (internal or external) or at least indicate whether your data is reviewed/assured.

  • Publish ESG or sustainability report either standalone or integrated into the annual report.

  • Disclose climate-related risks and opportunities, aligned with global standards like TCFD or IFRS S2.

8. Assurance & Audit

  • Consider engaging third-party assurance or verification of key ESG data (especially emissions and climate metrics).

  • Implement internal auditing of ESG processes.

  • Document verification steps and audit trails.

  • Address nonconformities or gaps promptly and transparently.

9. Stakeholder Engagement & Communication

  • Map your stakeholders: investors, regulators, employees, suppliers, community, customers.

  • Conduct regular stakeholder consultations or surveys to gather input.

  • Disclose how stakeholder feedback influences your ESG strategy.

  • Maintain open communication channels (website, meetings, reports) with stakeholders.

  • Respond to ESG ratings agencies queries, investor ESG questionnaires, and market expectations.

  • Use ESG credentials for reputation, PR, and investor relations.

10. Monitoring, Review & Continuous Improvement

  • Monitor KPIs regularly—quarterly or annually.

  • Conduct management reviews of ESG performance, risk, and progress.

  • Reassess material issues periodically (every 2–3 years).

  • Update targets, strategies, and programs based on performance and changes.

  • Benchmark your ESG performance against peers and indices (e.g. FTSE4Good Bursa Malaysia) Bursa Malaysia+1

  • Document lessons learnt, improvement plans, and adjustments.

11. Common Challenges & Mitigation

  • Data gaps and measurement difficulties → start small, build systems, phase in more metrics.

  • Lack of internal capacity or ESG expertise → hire or train ESG officers, use consultants.

  • Stakeholder skepticism or greenwashing risk → be transparent, show evidence, acknowledge challenges.

  • Cost vs. benefit uncertainty → run pilot projects, use conservative estimates, leverage incentives.

  • Regulation changes → stay updated, build flexibility into your ESG structure.

Final Thoughts & Call to Action

This checklist, The Ultimate ESG Checklist for Malaysian Public Listed Companies, lays out the essential steps your organization should follow to build a credible, compliant, and effective ESG program. When ESG is done well, it’s not just reporting—it’s a driver of resilience, investor trust, stakeholder value, and competitive edge.

If you're ready to transform your ESG journey but need help structuring your report, selecting metrics, conducting materiality, or getting assurance—WhatsApp or call 013-300 6284 now. Let’s work together to make your ESG roadmap real, impactful, and future-proof.

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