The implementation of Environmental, Social, and Governance (ESG) in government-owned companies has posed certain challenges for auditors. The main challenge is the potential for fraud or misconduct by the company in implementing ESG. According to Cressey’s Fraud Triangle (1969), fraud can occur when there is an interaction between three components: pressure, opportunity, and rationalization. Some of the identified challenges include:
- Pressure to meet ESG expectations – Companies face pressure from stakeholders to demonstrate support for the implementation of ESG initiatives.
- Opportunity for greenwashing and data manipulation – Companies' public statements supporting ESG policies open the door for greenwashing. Greenwashing involves making baseless or false claims to deceive consumers into believing that the company’s products are environmentally friendly or have a greater positive environmental impact than they actually do (fraudulent advertising/ESG reporting). Additionally, in the face of pressure to demonstrate ESG achievements, the Board of Directors and Chief Executive Officer (CEO) may manipulate related data through opportunities where there is no third party qualified to verify the achievement.
- Rationalization (because ESG activities are easy to manipulate) – In situations where companies face pressure to improve their ESG commitments, management may feel the need to manipulate data.
Control Mechanisms for Fraud Risk by Company Management:
- Consider the approach and mechanisms of ESG in the company’s risk assessment.
- Establish an ESG Compliance Framework to detect red flags and strengthen internal controls related to ESG data reporting.
- Appoint experts to conduct due diligence on joint ventures.
- Continuously monitor and assess the ESG mechanisms to prevent greenwashing.
Auditors are required to audit government-owned companies more thoroughly, taking into account the rapid developments in the ESG agenda. The audit assessment of the risks associated with ESG implementation is one of the main challenges for auditors today. Extensive knowledge among auditors regarding ESG concepts and practices is essential for ensuring that audit opinions are fair and relevant. The main challenges identified are the potential for fraud or misconduct by companies in implementing ESG. The factors that trigger misconduct, such as pressure from government companies, the opportunity for data manipulation, and the rationalization of why a regulatory violation may occur, are among the key challenges identified.
This article has limitations. First, the challenges faced by auditors discussed in this article, which uses the Fraud Triangle comparison method, may differ if a focus group discussion method were used to explore how the implementation of ESG practices in companies affects audit reporting. Second, the issues raised in the subtopic “Problems” above focus on the auditor’s responsibility in assessing risks within an audit environment that practices ESG. Risk assessment in the audit environment is broad, and other aspects, such as risk assessment using IT support, must also be considered.





