Mercury accounting and accountability under the Minamata Convention
thesisposted on 28.03.2022, 12:13 by Md Hafij Ullah
This thesis explores how the quality of mercury reporting can be improved, with particular reference to the Minamata Convention. Mercury is one of the world's most toxic elements, with a diversified impact on human health and the environment. In a global approach to reducing mercury pollution, the Minamata Convention is currently being developed by the United Nations Environment Programme (UNEP). As with as other multilateral environmental agreements (MEAs), the Minamata Convention also includes reporting provisions as a mechanism of reducing mercury emissions. No study on mercury has previously been conducted from a social and environmental accounting (SEA) perspective, though studies in other disciplines focusing on mercury's toxicity and impact have mentioned quality issues in mercury reporting. To address this gap, this study examines the quality of mercury reporting from four perspectives: global mercury reporting under the Minamata Convention, country-level mercury reporting from the perspective of a developed country (Australia), country-level mercury reporting from the perspective of a developing country (Bangladesh), and corporate mercury disclosures. This thesis contributes to the understanding of current challenges posed by mercury reporting processes and identifies several means of overcoming those challenges. This is a thesis by publication consisting of four papers, which are briefly described below. Paper 1 evaluates whether the reporting provisions will improve countries' accountability for mercury emissions as parties to the Convention. This qualitative case study used accountability theory and the qualitative characteristics of accounting information as an analytical framework. Data comprised relevant literature along with UNEP technical reports for identifying the quality challenges to mercury information, the proceedings of all the seven Intergovernmental Negotiating Committee (INC) meetings, the first conference of the parties (COP1), and the reporting format, for justifying the level of accountability the Convention may currently achieve. This study also finds that the mercury reporting process and mercury disclosures are significantly lacking in quality which leads to a deficit in discharging reporting accountability of the parties to the Convention. Consequently, there is a significant risk in using the reported mercury information for decision making. This paper makes a novel contribution by identifying the weaknesses of the reporting framework (that is, lack of sanctions) and suggesting possible ways (positive sanctions/ felt accountability) for overcoming those limitation based on the background discussions in INC meetings, the reporting provisions of the Minamata Convention,and the reporting format in terms of qualitative characteristics, as well as exploring the reporting accountabilities of the parties to the Minamata Convention. Paper 2 evaluates whether Australian mercury accounting (primarily sourced from the National Pollutant Inventory) is of sufficient quality to meet Australia's reporting obligations under the Minamata Convention. This study used accountability theory (O'Dwyer and Boomsma, 2015) and qualitative characteristics of accounting information (FASB, 1980) to assess the quality of the existing reporting regime. Data comprises eight interviews with 11 interviewees including researchers,regulators, and corporate mercury reporters, as well as documentary analysis. The findings are that although Australian mercury accounting is expected to be sufficient to meet Australia's reporting obligations, there are some reporting deficiencies regarding timeliness, comparability, completeness, reliability and accuracy of mercury data, particularly in relation to governmental (as opposed to corporate) reporting responsibilities. Finally, a consistent theme is that of budgetary pressures undermining the quality of mercury reporting in terms of both scope and verification. This paper contributes to identifying the key challenges to high-quality mercury reporting in Australia and highlighting ways to overcome those obstacles by improving felt and imposed accountability. Paper 3 explores mercury reporting from a developing country's perspective. The reporting capabilities of one such developing country (Bangladesh) are examined with regard to how well it complies with the reporting provisions of the Minamata Convention and to what extent the constraints faced by developing countries are acknowledged in the Convention, since the literature has identified that compliance with these agreements by governments, especially of developing countries, is a serious concern. This paper is a qualitative analysis of the opinions collected through email interviews from seven interviewees representing a variety of relevant stakeholders, as well as of the sections of the Convention that specifically relate to developing countries. While Bangladesh has some capability for complyingwith the reporting provisions of theMinamata Convention, it needs more support from UNEP and developed countries. The Convention and the surrounding discussions acknowledge these challenges and the need for help, but whether the level of support provided will be sufficient remains unclear. Presently, while there are specific instances of raised awareness about mercury - such as among Bangladeshi dentists and dental colleges - there is limited awareness among government administrators, researchers, regulators and the general public. This study contributes by exploring the national reporting of an MEA in a developing country context. In addition, the study develops the element of capability within the theory of accountability, an element that is surprisingly absent from most previous discussions of accountability. Paper 4 evaluates the current voluntary mercury disclosure practices of the major emitting companies. A disclosure index is created which comprises best-practice mercury disclosure and is based on GRI305 : Emissions, the reporting format for mercury under the Minamata Convention, the relevant literature, and sample disclosures of the companies. The study evaluates the mercury reporting of 81companies (100 facilities) from five jurisdictions (Australia, Canada, the European Union, the United Kingdom, and the United States of America) which are identified as major mercury emitters from pollutant inventory data. Findings include the following: (a) only a handful of the mercury-emitting companies disclosed mercury information in an annual report, sustainability report, environmental performance report and/or on their website, despite them being major emitters; (b) the volume and dimensions of mercury disclosure were significantly different among the reporting companies, as there are no standards on mercury reporting; (c) companies from the USA and Australia understood the significance of mercury emissions as companies from these two jurisdictions disclosed more mercury information than their counterparts from other jurisdictions did. Further analysis revealed that 46% of mercury-disclosing companies, compared to 26% of non-disclosing companies, provided details of their materiality assessment process. These companies also had their environmental reports externally assured. This paper contributes to developing a best-practice mercury reporting framework and provides evidence that regulators need to both provide specific corporate mercury reporting standards and encourage (or ideally compel) adherence to those standards. Collectively, the four papers show that while there is a mandatory mercury reporting structure in some jurisdictions, the reporting process and the reported information suffer from significant quality challenges in terms of meeting user needs for eliminating the mercury emissions. To achieve the objective of the Convention, imposed and felt accountability of accurate reporting by the corporations, the countries, and the global structure as a whole need improvement. This thesis contributes to the limited previous literature on the quality challenges of mercury reporting and exploring the ways to overcome those hurdles. Specific suggestions include the introduction of a verification process for country reports to the UNEP Secretariat, incorporating all the areas of emissions in the remit of the Convention, imposing sanctions for non- or poor reporting, developing mercury accounting and reporting standards for corporations, and improving the level of felt and imposed accountability of the parties involved. As this thesis represents the first research study to focus on mercury reporting from an accounting perspective, there are a number of future research trajectories. Future research is needed to develop mercury reporting structures for corporations; to conduct reviews of national mercury accounting and reporting standards in countries other than Australia; and to further develop the reporting practices of parties to the Minamata Convention.