Capitalize on your carbon management solu4on investment

Transcription

1 Capitalize on your carbon management solu4on investment Best prac4ce guide for implemen4ng carbon management so9ware Carbon Disclosure Project +44 (0)

2 Content The case for carbon management solu2ons 3 Considera2ons, strategies and planning 4 The selec2on of a carbon management solu2on 4 Func%onality 5 The implementa2on process 7 Prepara%on is key 7 Ownership, stakeholder engagement and training 8 Requirements and Planning 9 Deployment 9 Tests and pilot systems 10 Go live and demonstra%ng success 10 Time requirements 12 Resourcing 12 What happens a@er the implementa2on? 13 Measuring success 13 Going forward 14 Conclusion 14 2

3 The case for carbon management solu4ons Corporate climate change repor4ng is becoming increasingly mainstream and public. Faced with scru4ny from stakeholders, including investors, regulators and consumers, companies need to ensure data quality and accuracy. Many companies s4ll rely on their manual data collec4on process, data management and analysis techniques. As carbon repor4ng matures, however, spreadsheets are growing increasingly complex and becoming cumbersome, prone to error and an increasing burden on resources. Capgemini, an implementa4on focused management consul4ng and informa4on technology services group, whose UK team managed a four gigabyte spreadsheet, explained that with over three million new data points being processed each year from 30 disparate sources, and numerous internal and external repor<ng requirements, colla<ng and managing the informa<on presented a considerable challenge. Making this process more rigorous and cost effec<ve while ensuring that the quality, accuracy and integrity of data was of a sufficient standard to support the ambi<ous sustainability goals they had adopted was thus a key reason from moving towards a carbon management solu4on. 1 Carbon management tools can transform data collec4on and analysis, helping organiza4ons to meet their sustainability goals faster and improve the accuracy of repor4ng to stakeholders. By achieving their sustainability goals, companies can enhance reputa4on while controlling costs through lower energy bills and automated informa4on management processes. Further savings are generated by libera4ng resources from labor intensive manual processing. It s a classic problem sustainability is a core part of a company s business strategy, but relevant teams seem to be spending most of their 4me and money producing a sustainability report rather than implemen4ng change. For example, O2, a mobile and broadband services provider, required a system that was cost effec<ve and would not strain their resources. 2 The evidence for the business case and ROI 3 soon stacks up. A well implemented carbon management solu4on vaguely resembles a financial accoun4ng system; it penetrates the en4re organiza4onal structure, and integrates with exis4ng processes and systems. A challenging task, and many organiza4ons struggle to achieve the enterprise grade solu4ons needed to transform their approach to sustainability. 1 Adapted from a case study provided by CA Technologies and Capgemini UK 2 Adapted from a case study provided by CRedit360 and O2 3 Return on investment 3

4 Considera4ons, strategies and planning Solu4on installa4ons will only be as effec4ve as the business processes and management structures that will underpin the so9ware. A clear climate change strategy and management structure need to therefore be in place, which in turn is then supported by the so9ware. In addi4on, exis4ng technology and data systems must be considered to ensure appropriate integra4on with the new solu4on. A clear understanding of exis4ng and future data is essen4al, in terms of type, volume, format, frequency, accessibility and portability. This data needs to be combined with easy access to relevant emissions factors that apply, for example per geography or facility. Without this base understanding, it becomes hard to set reduc4on targets and measure performance, no maver how sophis4cated the approach. Ideally the system integrates carbon with other sustainability indicators. During the implementa4on, consultants can add value to the process, but companies may prefer to use and build internal exper4se. In both cases, however, internal knowledge and involvement of those who will use the so9ware and those who will manage the processes it automates, remain essen4al if the organiza4on is to successfully embed the system in its processes. Finally, the general business case for a carbon management solu4on may be clear, but how can you jus4fy the expense for your organiza4on? Preparing a solid business case will help you in the budget approval process and will also help measure the success of your project in the end. A US based consumer goods manufacturer calculated that it saves 180,000 USD per year by implemen4ng a new carbon & environmental repor4ng solu4on that drama4cally reduces the 4me and resources spent on data collec4on, audi4ng and repor4ng. The manufacturer is collec4ng monthly data at its 11 worldwide manufacturing sites in order to keep track of about 150 carbon and environmental performance indicators. 4 The selec4on of a carbon management solu4on A solu4on must meet an organiza4on s requirements, but it is unlikely that one single so9ware package will meet all the needs a company might have. The range of solu4on providers for instance can be narrowed down by assessing which providers service the company's industry sector. Suppliers, distributors, even compe4tors may provide clues to suitable providers. Addi4onally, industry informa4on is available from third party analysts, for example, Verdan4x, Groom Energy, Gartner, or accredita4on schemes such as CDP 5 (accompanied by an independent so9ware evalua4on by the GHG Management Ins4tute) or GRI 6. 4 Adapted from a case study provided by PE INTERNATIONAL 5 Carbon Disclosure Project 6 Global Repor4ng Ini4a4ve 4

5 By establishing a clear set of criteria, graded from essen4al to nice to have, a company can objec4vely evaluate poten4al suppliers. Rather than evalua4ng all possible providers, companies should look to quickly narrow the field. A well planned RFI 7 or RFP 8 can help the selec4on process. An RFP based on specific requirements will quickly assess suitability of a product, and cultural compa4bility of a provider. Shortlisted providers will generally be able to offer demonstra4ons. References from, or even conversa4ons with exis4ng clients, can provide an independent view of the effec4veness of a solu4on. Func2onality From a func4onality perspec4ve, the solu4on must support the company s exis4ng and future sustainability strategy. The tool should offer the appropriate measurement, repor4ng, project planning and benchmarking capabili4es that may be required today and going forward. The tool must offer, for example, a hierarchal repor4ng structure that will accommodate the accoun4ng structure of the company be this organiza4onal structure, facility level or geographic. Companies should seek solu4ons that offer capability to drive reduc4on programs, and associated tracking criteria. A solu4on that offers addi4onal content sustainability content (databases) such as emissions factors, benchmarking informa4on and a best prac4ce database of sustainability projects, as well as the ability to create your own can enhance a company s sustainability performance management and internal and external repor4ng. When selec4ng a solu4on, companies also select a provider, and should assess not only the so9ware, but the provider s domain exper4se. Good providers will listen, and commit 4me to understanding a company s par4cular sustainability priori4es, before helping a company increase its own domain knowledge, specific to its industry. A suitable provider might have exis4ng clients in the relevant sector, which may help advance future supply and value chain engagement. Companies can further look at the quality of postimplementa4on support, the road map for the so9ware and the companies track record in delivering regular releases and updates an important considera4on in a rapidly evolving field. Generally speaking, the track record of the company and its key employees in sustainability is another useful review. While this guide primarily focuses on carbon and climate change data, a good system should also be able to incorporate many other metrics and applica4ons to cover the wide range of sustainability topics, including energy management, EHS 9, compliance, CSR 10 and community engagement. 7 Request for informa4on 8 Request for proposal 9 Environment, health and safety 10 Corporate social responsibility 5

6 For Singapore based Noble Group, a diversified commodi4es trading company,the reason to adopt a carbon management solu4on was not only to streamline the repor4ng process, but also to make it easier to iden4fy its opportuni4es for carbon emission reduc4ons and manage performance. With its first 4me CDP report Noble scored the second highest disclosure ra4ng in its region for Michael Rumberg from Noble Group commented Our solu<on provider s subject mafer exper<se and the performance management capabili<es in the sogware really helped us to be now recognized as one of the leaders in carbon performance. 11 The specific carbon management strategy and goals of a company will influence the features required in the solu4on: Strategic focus Key aims Feature Carbon and sustainability repor4ng Reduced cost and 4me for repor4ng; Higher confidence with financialgrade, verifiable informa4on; Improved posi4on in sustainability rankings; Enhanced company and brand preference from customers, employees, investors. Automated data feeds; Easy integra4on with enterprise resource planning, finance and exis4ng sustainability systems; Workflow support; Audit log for 3 rd party report verifica4on; Templates for GRI, CDP, Dow Jones Sustainability Indexes and others; Supply chain and Scope 3 repor4ng; Ability to manage quan4ta4ve and qualita4ve data. Carbon performance improvement and opera4onal efficiency: Find and close performance gaps in carbon emissions and efficiency; Discover opportuni4es and improvement projects to reduce carbon emissions, costs and risk; Efficient opera4ons; Efficient supply chains; Make the business case for sustainability ini4a4ves; Benchmarking with external data from peers, industry associa4ons, standards; Goal defini4on and target sepng; Intelligent best prac4ce library for example ROI and cost savings; Performance forecas4ng /scenario planning; Project porrolio planning and modeling; Supplier score cards and rankings. 11 Adapted from a case study provided by PE INTERNATIONAL and Noble Group 6

7 Addi4onal considera4ons will need to be taken into account if sustainability performance management in the wider sense (for instance health & safety and social performance generally) is to be enabled through the so9ware. Deutsche Post DHL, a German based logis4cs company, set targets to increase carbon and energy efficiency for its own opera4ons and its contractors. With its carbon management solu<on Deutsche Post DHL aggregates data from 600 sites and integrates it with its financial repor<ng system. The increased visibility of their contractors carbon performance and the collabora<ve iden<fica<on of savings in fuel and energy has helped DP DHL to increase scope 3 carbon efficiency by 12% over 3 years. In addi<on, DP DHL has developed a new offering: it reports the carbon footprint of its products and services for key account customers. 12 The implementa4on process There is no typical carbon management solu4on implementa4on project, but there are a number of golden rules and steps for a successful so9ware implementa4on project: 1. Prepara2on is key Planning is crucial. The introduc4on of a solu4on does not end with the installa4on of so9ware, but requires sponsor and management buy in, user training, target sepng and repor4ng to demonstrate success, and a future development path. It is important to define and align the processes and strategy that the solu4on must support, and to allocate appropriate 4me, energy and resource to allow the project to flourish. If an organiza4on does not have enough carbon management exper4se in house, should consultants be involved, or can the organiza4on rely on the provider s domain exper4se and support? Checklist: What is the company s carbon and sustainability strategy? What indicators and KPIs 1313 are being measured, and what are the targets? What are the expecta4ons from the solu4on? Streamlined and accurate repor4ng, streamlined external verifica4on, improved data quality, iden4fica4on of savings opportuni4es? What is the current process for sustainability data management? 12 Adapted from a case study delivered by PE INTERNATIONAL and Deutsche Post DHL 13 Key performance indicators 7

8 Who are the internal and external stakeholders? Who could be a driver and mo4vator? Who needs to be convinced? Which systems are currently in use and will they remain, for example spreadsheets? What type of reports does the company create? Do they comply with relevant repor4ng regimes, including regulatory schemes, CDP, GRI or Dow Jones Sustainability Indexes? What is the data collec4on and repor4ng frequency monthly, quarterly, or annually? How does repor4ng structure relate to organiza4on structure and hierarchy? Who will be the users? What will they do (data collec4on, data approval, plant level repor4ng, corporate repor4ng, or workflow control)? Will historic data be imported? For what period? Are there structural differences between the years? Is there a plan to have interface to an external database system? Or a live data upload? How important are these for the smooth opera4on of the system? How will the system fit with exis4ng systems, such as financial or building management systems, and with exis4ng system support processes? It is likely that you will need to consult with your IT department or service providers on these issues. 2. Ownership, stakeholder engagement and training A growing number of companies now appoint execu4ve posi4ons, such as a Chief Sustainability Officer (CSO), as well as energy, climate change, sustainability and environmental managers and teams. However, mul4ple business func4ons are s4ll involved in the execu4on of a company s sustainability goals, such as R&D, IT and facili4es, and therefore the selec4on and implementa4on of a new solu4on must involve all relevant stakeholders. Support from senior management whose influence sets the tone for the acceptance and use of any new enterprise system is helpful, from management of the system through to data collec4on. Where these teams have o9en worked in silos, it is vital to bring stakeholders together into a steering group. Through early involvement, the implementa4on process will benefit from the group s combined exper4se and help promote knowledge sharing across mul4ple disciplines. A steering group is just the beginning of the stakeholder engagement process. Organiza4ons must con4nue to cascade this mul4 disciplinary approach to the end users responsible for capturing and evalua4ng data at different sites and in different countries. Engagement, involvement and training of relevant stakeholders can help manage expecta4ons for each phase of an incremental deployment, reduce push back from users of the system and encourage effec4ve collabora4on. Solu4on providers will offer training to all users from data providers through to system administrators, however if a company wants to manage their own training process, most will also facilitate this through a 'train the trainer' principle. 8

9 Understanding data u4lity is just as important as providing for data accuracy and relevancy. Without clear data use plans, there is a risk that a company will focus too much on the solu4on, and not on corporate sustainability and carbon goals. 3. Requirements and Planning Mul4ple stakeholders means mul4ple requirements all of which need to be sufficiently defined before a carbon management solu4on can be selected and deployed. This is o9en best achieved collabora4vely in a workshop format. Workshops typically last 1 2 days and cover a number of points: review of the history of sustainability management at the organiza4on, the visions and goals for the future, and how the system is going to help achieve those goals. As well as defining the business processes that need suppor4ng (including capturing data from half hourly meters or u4lity billing), stakeholders should consider future scalability and flexibility. When is support for mul4ple currencies and languages required (for mul4na4onal corpora4ons, data providers, data managers, system administrators who might be based across different con4nents)? What volume and variety of data and assets might be relevant in 2 years 4me? Data systems can be built to facilitate a company s repor4ng obliga4ons (for example regulatory requirements, annual repor4ng, CDP) what repor4ng regimes are maturing in relevant jurisdic4ons? Agree the project scope and don t let it creep. Do not add game changing requirements once implementa4on has started, but agree the requirements and s4ck to them. Have a clear, formal process for dealing with any changes to scope, and ensure that changes are kept to a minimum. Once there is demonstrable success, sponsors will support an expanded scope. A signed off requirements document can help formalize this. 4. Deployment There are a number of approaches to so9ware deployment. By adop4ng an incremental approach, organiza4ons will be able to deliver and demonstrate quan4fiable results in a shorter 4meframe, gaining management buy in and ongoing sponsorship. Alterna4vely, larger organiza4ons may take a geographically phased approach. This enables loca4ons to benefit from lessons learned from the ini4al implementa4on stages, crea4ng a repeatable process that enables rapid and lower risk deployment. A third op4on might be the centralized colla4on of historical sustainability data along with new con4nually updated metrics for energy consump4on and carbon emissions. This enables a quick win in terms of improved data granularity, quality and 4meliness, which in turn will help iden4fy energy consump4on hotspots that need to be addressed. As with any project, project management basics should be applied, such as: Crea4ng a program and individual project schedules (which are relevant to the broader organiza4on s 4melines, budgets and sustainable business goals); Defining roles and responsibili4es both at an organiza4on and individual level and ensuring they are consistent with exis4ng sustainability management systems; Establishing a communica4ons plan; 9

10 Performing quality assurance and tes4ng; Enabling knowledge transfer; Iden4fying and managing risks to the project. 5. Tests and pilot systems A so9ware pilot is the first test implementa4on of the so9ware with a limited scope, for example for a selected number of sites and a limited amount of data. This tes4ng and ini4al user feedback are essen4al for a successful roll out of the final so9ware system, as they help to evaluate if the customized so9ware is already fit for the purposes of the company. The pilot can help refine requirements, adjust structures and sepngs, and the feedback from your pilot users can further enhance the so9ware. During the configura4on phase, there will be several milestones reached. As each milestone is achieved companies should verify that the work completed meets their requirements and provide feedback for further steps of implementa4on. 6. Go live and demonstra2ng success Once the configura4on and pilot have been completed the system is ready to go live. Training can and should s4ll be provided to data collectors and administrators of the system, explaining the technical basics but also the purpose and background of the system to those who had not previously been involved in the implementa4on process. Gepng broad buy in and support from these user groups will significantly impact the value the so9ware can add to the company. Companies can consider doing a post deployment ROI study to look at the savings that are being achieved and to help guide next steps. Savings may be in staff produc4vity, opera4onal costs, and new ideas or market opportuni4es that are discovered via the enhanced employee engagement of your carbon solu4on. Communica4ng the successes that have been accomplished throughout the implementa4on of the solu4on, but also the wider sustainability results will help drive ongoing support and investment. Key messages like reduced energy use and lower carbon emissions, but also other strategic goals, such as cost reduc4on, should be communicated to both internal and external stakeholders. It is recommended to schedule regular follow up mee4ngs with the provider s implementa4on team. This will help ensure the system is used to its full poten4al (e.g. repor4ng and benchmarking func4onali4es), and will in the longer run help users remain up to date with so9ware developments. 10

11 Case study Danske Bank 14 The Challenge With offices in 14 countries and almost 22,000 employees, Danske Bank, a large financial enterprise in Denmark, quickly iden4fied airline travel as a significant component of its carbon footprint. In addi4on to other carbonreducing ac4vi4es, Danske Bank invested in TelePresence studios in 16 key loca4ons to reduce the need for employees to fly for internal mee4ngs. Danske Bank selected CRedit360 to help capture the data necessary to build a solid business case to support the investment necessary to sustain this program. The Solu2on Danske Bank calculates its overall carbon footprint with a sustainability data management system, using this data in their annual sustainability report, as well as their annual submission to the CDP. To help track their progress against the goal of Carbon Neutrality and support their investment in TelePresence, a management system is used to: Convert each use of the TelePresence suite into the equivalent amount of CO 2 that would have been produced for each par4cipant that would have flown for an equivalent face to face mee4ng; Produce an easy to read chart that clearly demonstrates how CO 2 from flights is reduced as the use of TelePresence facili4es increases. An example output is included below. Key benefits delivered to The Danske Bank Group: Comprehensive data collec4on and analysis showed tangible return on investment and built a solid business case for further investments in TelePresence; Graphics added a sense of immediacy to help inspire employees to change their business travel behavior; A single system is used to meet mul4ple repor4ng requirements, from CDP and published sustainability reports, to engaging with internal stakeholders. 14 Adapted from a case study provided by CRedit360 and Danske Bank 11

12 Time requirements The project dura4on varies from company to company and is influenced by a number of factors: A clear and well ar4culated strategy will give immediate direc4on to a project and ensure the end solu4on is accepted and valued by the organiza4on; Well defined business processes will reduce the process re engineering needed in advance of solu4on design and deployment; Availability of quan4fiable goals, targets and KPIs; Breadth of scope and requirements will, for example, the solu4on only track carbon, or will it also integrate with financial data; Exis4ng data sets can help define the architecture of the solu4on, but can also hinder where sta4c data does not bed well with flexible features and func4ons; Resource availability consider the 4me required from internal staff, even if most of the work is being undertaken by external consultants. Time requirements from the so9ware supplier may be minimal, but implementa4on 4me may be extensive if informa4on or resources not available; The size, structure and hierarchy of the company. Considera4on must be given to repor4ng cycles so that the new system is implemented at a 4me when switch over from exis4ng methods of working is easiest. For instance, it may be appropriate to change immediately a9er the company s main annual sustainability repor4ng is complete. For smaller organiza4ons with simple organiza4onal hierarchies, a limited number of KPIs, or a limited number of system users, a full system implementa4on can be done in a number of days. Clearly 4me requirements will inherently be longer for mul4na4onal organiza4ons that will use the sustainability so9ware system for carbon management in addi4on to a variety of other sustainability KPIs. Generally speaking, however, implementa4ons can range from 10 to 300 days with an average of two months. Resourcing Carbon management systems can usually be managed with as many administrators, data approvers, and data providers as the company requires and solu4on providers will generally work with the client to iden4fy the most appropriate and efficient levels of users in the implementa4on phase. In the majority of cases, it is most efficient to have a single, primary administrator for the system and to be the primary point of contact to the supplier. However there can then be mul4ple 4ers of people with different access rights data collectors, data providers, reporters or analysts built within the system. 12

13 For the implementa4on process, the set up could look as follows: Project leader; Opera4onal project support; Future system administrator (if not project leader); 3 6 pilot users represen4ng the relevant departments and business units as well as geographical regions; IT department; Addi4onal stakeholders: execu4ves, marke4ng/ communica4on. What happens a9er the implementa4on? Measuring success Measuring the success of an implementa4on process and the tool is quite simple: buy in and regular use from all stakeholders of the tool. Companies can also review their original expected benefits from the so9ware implementa4on that they listed during prepara4on for example streamlined and valid repor4ng, faster external verifica4on, improved data quality, iden4fica4on of cost savings opportuni4es. Have these targets been achieved? ROI of the so9ware implementa4on can also be measured: Quan4fied reduc4on of 4me and resources spent on repor4ng; Quan4fied reduc4on of energy and resource costs; Other business benefits such as improved reputa4on or rankings. Capgemini UK was able to: Reduce the costs associated with collec4ng and managing data, and crea4ng reports by approximately 30 %; Ac4vely manage carbon emissions and waste through bever informed business decisions; Gather data to facilitate compliance with the legisla4ve requirements of the CRC Energy Efficiency Scheme Adapted from a case study provided by CA Technologies and Capgemini UK 13

14 Going forward Whilst, when the system is in place, it might be the end of the implementa4on process, it is very much the beginning of the ongoing fine tuning and con4nued development of the tool and its applica4on within the repor4ng company. Solu4on providers will assign dedicated account managers to ensure a company is able to maximize value from the solu4on on an ongoing basis. This may include: Introduc4on of new func4onality and features to improve carbon management as the domain matures; Controlled roll out of the solu4on across the wider business hierarchy to other business units, departments or subsidiaries. Updates to reflect changes in organiza4onal or changes of users; Iden4fying and mi4ga4ng challenges with performance and helping ar4culate value and success; Con4nuously integrate new best prac4ces and changes in company structures and processes. Conclusion In a world where informa4on is available at the click of a buvon, with live data on demand and global audiences, sophis4cated demand is growing around corporate climate change repor4ng. This may come from investors seeking investment grade data for their analysis, or customers that want to know what a company is doing about its climate and environmental impact. O2 s stakeholders get immediate and intui<ve access to verified and up to date sustainability informa<on via the O2 website. It s easy to navigate to the issues that mafer to you without leafing through a printed report which quickly becomes out of date. 16 Companies that have incorporated sustainability into their culture are not only addressing this drive for informa4on, but they are also achieving higher levels of efficiency, reducing costs in their opera4ons and driving their profitability. Data capture and tracking, however, is 4me intensive, complex and difficult in many cases. Carbon management solu4ons can streamline this process, allowing the company to drive efficiency and reduce costs. Enterprise level tools help companies achieve sustainability goals, and become a part of the future economy through the use of scenario planning, reduc4on ini4a4ves and performance monitoring. Sustainability repor4ng is becoming standard prac4ce and the future may well see it mandated. A well implemented carbon management solu4on will enable companies to make this transi4on seamlessly. 16 Adapted from a case study provided by CRedit360 and O2 14

15 About CDP The Carbon Disclosure Project (CDP) is an independent not for profit organiza4on providing a transforma4ve global system for companies and ci4es to measure, disclose, manage, and share climate change and water informa4on. Over 3,700 companies across the world s largest economies now measure and disclose their greenhouse gas emissions, water use and climate change risk and opportunity through CDP, in order that they can set reduc4on targets and make performance improvements. This data is gathered on behalf of 655 ins4tu4onal investors, holding US$78 trillion in assets. CDP now holds the largest collec4on globally of self reported climate change data. For more informa4on visit This guide was produced by CDP in collabora4on with members of its gold carbon calcula4on partnership program CA Technologies, CRedit360 and PE INTERNATIONAL. hvps:// US/OurNetwork/Pages/carbon calcula4on partners.aspx 15

16 Carbon Disclosure Project Marieke Beckmann Manager, Corporate Partnerships Dan Sokell Technical Partnerships and Innova4ons CDP Gold Carbon Calcula4on Partners CA Technologies Sonny Masero, VP Sustainability EMEA CRedit360 Efrain Quiros, Partnerships Manager PE INTERNATIONAL Dr. Robert Gabriel, Execu4ve Director, Corporate Sustainability & Strategy interna4onal.com Important No2ce The contents of this report may be used by anyone providing acknowledgement is given to Carbon Disclosure Project. This does not represent a license to repackage or resell any of the data reported to CDP or the analysis presented in this report and therefore if you intend to do this you need to obtain express permission from CDP before doing so. CDP prepared the content, data and analysis in this report based on informa4on submived by third par4es and in the annual CDP informa4on requests. CDP does not guarantee the accuracy or completeness of this informa4on. CDP makes no representa4on or warranty, express or implied, concerning the fairness, accuracy, or completeness of the informa4on and opinions contained herein. All opinions expressed herein are based CDP s judgment or judgment of the contribu4ng third par4es at the 4me of this report and are subject to change without no4ce due to economic, poli4cal, industry, firm specific or any other factors. Guest commentaries where included in this report reflect the views of their respec4ve authors Carbon Disclosure Project. Carbon Disclosure Project and CDP refers to Carbon Disclosure Project 16