This article is for Requesters, and it covers the parent-subsidiary reporting policy in 2024.
Requesters have the option to request either the subsidiary for which they have a direct business relationship or the subsidiary’s parent company.
As in previous years, the preferred approach is for parent companies to respond on behalf of their subsidiary companies by submitting a consolidated response which includes all subsidiary data. This is in line with GHG Protocol, and the International Sustainability Standards Board’s IFRS S2. This approach ensures the parent company has complete control of all requests sitting at both subsidiary and parent level. It also has the added benefit of reducing CDP’s reporting burden, since it avoids parent and subsidiary both submitting a response.
Parent companies have the option to disclose a consolidated or independent response from their subsidiaries, and they can choose to respond for as many or as few of their direct subsidiaries as they wish. In 2024, requests from customers to a subsidiary will not automatically roll up to the parent, however, the parent will see their subsidiaries’ requests on their Portal and can grab these requests to include in their consolidated response from June 4. Parents can do this at the organization level, which grabs all requests of each selected subsidiary, as well as all requests from the subsidiary’s subsidiaries.
Until the parent actively grabs the request from the subsidiary, the subsidiary will be able to begin their response without having to reach out to CDP. Before a parent company grabs their subsidiary’s request, the parent will be informed that any progress the subsidiary has made on their response will be lost (but recoverable).
If a subsidiary is requested for a particular issue (e.g. Water) and the parent has chosen to respond for that subsidiary, then the parent will be expected to also respond for that issue. Subsidiaries will be able to see the parent’s response progress, but not their requests.
If both the parent and subsidiary organizations are responding, both organizations should provide a full dataset where possible. This helps CDP identify duplicated data and ensures that each response is accurate and follows the company’s reporting boundary.
In the case where a customer requests a subsidiary and the parent grabs the subsidiary’s request, the parent will become the disclosing organization. Requesters will see this reflected in their Request list and data products, where the Requested Organization remains the subsidiary and the Disclosing Organization becomes the parent. The parent will be able to, and should, disclose Requester relationship specific data in the Supply Chain specific questions throughout the questionnaire.
While CDP now has access to D&B company data including DUNS numbers, the CDP database continues to be the master parent-subsidiary database. This means that all past parent-subsidiary links from 2023 and before have been moved to 2024, and these continue to be used for the processes mentioned in this article. If a new organization is added and their parent from D&B is matched to an existing one in the CDP database, then the existing organization is marked as the newly created organization’s parent, automatically.
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