Draft Esg Disclosure Narrative

---
name: draft-esg-disclosure-narrative
task_id: environmental-esg/draft-esg-disclosure-narrative
description: Guides drafting of an ESG disclosure narrative and companion legal risk memo by ensuring environmental performance claims are substantiated by underlying data, legal contingencies are properly characterized, and climate risk disclosures satisfy applicable framework requirements.
activates_for: [planner, solver, checker]
---

# Skill: Draft ESG Disclosure Narrative for Inaugural Sustainability Report

## 1. Subject-matter triage

- Treat the ESG narrative and the legal risk memo as separate deliverables with different audiences and standards.
- Draft the primary disclosure first, then the risk memo after the narrative exists and is internally consistent.
- If the source set contains multiple reporting periods, facilities, emissions scopes, scenarios, or enforcement matters, enumerate them before analysis and handle each on its own terms.
- If only one item is actually in scope, state that explicitly and do not imply a broader review.

## 2. Failure modes the skill is correcting

- Drafting aspirational environmental language without tracing each claim to source data, methodology, or assurance coverage.
- Collapsing emissions, targets, and climate-risk statements into generic sustainability rhetoric that is too vague for a public disclosure.
- Treating the legal risk memo as a summary instead of a distinct advisory analysis of disclosure exposure, enforcement exposure, and privilege boundaries.
- Making affirmative performance claims that are inconsistent with any regulatory, remediation, or enforcement history in the source set.
- Omitting the tension between what the company wants to say and what the documents actually support.
- Failing to distinguish verified metrics from management-prepared, partially assured, or unaudited information.
- Describing climate risk in broad terms without specifying governance, strategy, risk management, and metrics/targets implications.
- Writing conclusions without naming the legal or disclosure framework that supports them.

## 3. Legal frameworks / domain conventions that apply

- Emissions reporting should distinguish direct emissions, purchased-energy emissions, and value-chain emissions, with methodology, boundary, and data-quality assumptions stated consistently.
- Climate disclosure should address governance, strategy, risk management, and metrics/targets in a way that is usable in a formal reporting context.
- Material climate-related risks should be described with enough specificity to inform investors or other report users, even if a particular framework is voluntary or evolving.
- Physical risk analysis should cover acute and chronic exposures at the facility or operations level when the source data permits.
- Transition risk analysis should cover policy and legal, technology, market, and reputational risk where relevant.
- Any assurance statement must be read narrowly: claims outside the assurance boundary should not be presented as independently verified.
- Any active or recent enforcement matter, consent decree, remediation obligation, or similar constraint must be characterized accurately and consistently with the source documents.
- Scientific integrity matters: emissions metrics, targets, and progress statements must remain internally consistent across periods and sections.
- For legal analysis, rely on the applicable antifraud, periodic disclosure, and privilege principles that govern public-company disclosure risk; do not state a legal conclusion without naming the rule or doctrine that supports it.

## 4. Analytical scaffolds

- For each quantitative or qualitative performance claim, trace it to a specific source document, check the defined boundary, and confirm the terminology matches the data.
- For each emissions statement, verify category placement, period consistency, baseline references, and whether the claim is absolute, intensity-based, or target-based.
- For each target or progress claim, check the baseline year, measurement method, and whether progress is measured on a comparable basis.
- For each climate-risk statement, separate governance, scenario analysis, risk identification, and mitigation planning rather than blending them into one paragraph.
- For each facility-level vulnerability statement, cross-check the underlying asset or operations data before stating exposure or resilience conclusions.
- For each legal or regulatory reference, identify the governing authority by name and section, rule, or doctrine before drawing the implication.
- For each enforcement-related fact, test whether the narrative understates, overstates, or omits the operational or legal significance of the matter.
- For the legal risk memo, analyze affirmative misstatement risk, omission risk, challenge risk, and privilege treatment as distinct questions.
- For advisory conclusions, pair diagnosis with a concrete mitigation path so the reader can see what to do next.

## 5. Vertical / structural / temporal relationships

- Every disclosure claim should follow a data-to-narrative chain that can be reconstructed from the source set.
- Where assurance coverage is narrower than the disclosure scope, the narrative should draw a clear boundary rather than imply blanket verification.
- Where an enforcement or remediation matter overlaps with a performance claim, the legal and factual implications should be assessed together.
- Where prior-period disclosures exist, check for consistency in definitions, scope, and trend language before describing change over time.
- Where multiple facilities or operations are implicated, do not generalize from one site to the whole enterprise unless the source documents support that move.
- Where the source set contains timing information, preserve sequencing: identify the underlying event first, then the disclosure consequence, then the recommended response.

## 6. Output structure conventions

- Produce the ESG environmental narrative as a polished disclosure document with conventional reporting sections for emissions, climate governance, climate risk, metrics, targets, and performance narrative.
- Produce the legal risk memo as a separate advisory document organized by risk topic, with an explicit severity field for each issue and a short rationale for the severity assigned.
- Use clear headings, short analytical paragraphs, and language suitable for an inaugural sustainability report and an internal legal memorandum.
- When identifying issues, include the governing authority, the source fact pattern, and the practical consequence for the company or report.
- End the legal risk memo with a Recommended Actions section that gives concrete next steps, names the responsible role or function, and ties timing to the reporting cycle or another relevant milestone.
- Keep the narrative and the memo aligned, but do not duplicate text mechanically; the memo should explain risk, not restate the report.
- Confirm in the final drafting pass that both deliverables are complete, internally consistent, and written as operative content rather than placeholders or summaries.