以ESG信息披露为例：中美欧ESG政策探究

Global ESG Disclosure Frameworks - 96% of exchanges reference the Global Reporting Initiative (GRI) standards when compiling ESG disclosure guidelines[8] - 78% of Fortune 250 companies use GRI standards for ESG disclosures[10] - Approximately 3/4 of Fortune 250 companies in the U.S. use SASB standards[11] - 4,900 organizations from 103 regions have adopted TCFD's framework for climate-related disclosures[12] - Companies representing about 2/3 of global market capitalization disclose climate change, forest, and water security data through CDP[13] EU ESG Policy - The EU's Corporate Sustainability Reporting Directive (CSRD) expands the scope of mandatory disclosure from 11,700 to approximately 50,000 companies[15] - CSRD introduces 12 sets of European Sustainability Reporting Standards (ESRS) covering general requirements, environment, social, and governance[15] U.S. ESG Policy - California's SB 253 and SB 261 laws will affect approximately 5,300 and 10,000 companies, respectively, with penalties up to $500,000 and$50,000 for non-compliance[19] - Only 40% of U.S. companies disclose Scope 1+2 greenhouse gas emissions, compared to 70% of non-U.S. companies[21] China ESG Policy Development - China's ESG policy development can be divided into three stages: initial (2002-2016), exploratory (2016-2020), and deepening (2020-present)[23] - The 2024 Sustainability Report Guidelines require 457 companies to disclose ESG information, with full implementation by 2026[28] - China's ESG policies currently focus more on environmental (E) disclosures, with social (S) and governance (G) aspects needing further development[29]