ESG regulation is evolving rapidly, and many legal departments are navigating these complex challenges with limited resources or specialist expertise.
Within ever challenging economic, cultural and geopolitical winds, the complexity of managing ESG risks, responsibilities and opportunities continues to grow.
ESG Evolve was born out of RPC's candid conversations with General Counsel and other legal and sustainability leaders across the sector. Through those conversations we identified a common disconnect between ambition and reality – between many organisations' intended impacts and the ability for (and enabling of) those working "on the ground" to deliver in practice. We wanted to help to empower sector leaders to identify and close that gap so that they can make good on their ESG ambitions for the health of their businesses, the sector, people and planet.
This report is the start of that continuing conversation.
What we found
Level of importance businesses place on ESG
Roadblocks to ESG progress within the business
How much does ESG reporting affect ESG priorities
Awareness of ESG regulatory developments
How embedded ESG strategies are within the business
What we found
Level of importance businesses place on ESG
Roadblocks to ESG progress within the business
How much does ESG reporting affect ESG priorities
Awareness of ESG regulatory developments
How embedded ESG strategies are within the business
Executive summary
Consumer brands and retailers are entering a new phase of ESG responsibility. Commitments that once centred on purpose and values are now being assessed on delivery and impact. Regulators, investors and customers are looking more closely at how businesses act, and at the evidence that sits behind their promises. As one General Counsel (GC) reflected: “It used to be about values and what we stand for. Now it’s about what we can demonstrate.”
Our research highlights a sector in transition. ESG is still widely recognised as strategically important, but the level of priority differs from business to business. On average, participants placed it mid-way up their board agenda. For some, it is deeply embedded and treated as part of their licence to operate; for others, it competes for airtime with a wide range of pressures and receives less consistent strategic attention. Most organisations are working in the space between ambition and delivery, seeking meaningful ways to close the gap.
The complexity of ESG delivery came through strongly in our conversations. Responsibility for ESG often spans multiple functions, with ownership not always clearly defined. Legal teams are playing an increasingly central role, but are sometimes brought in too late, once key decisions have been made. Reporting obligations continue to grow and demand significant time, yet they do not always feed directly into strategy. Alongside this disconnect, budgetary pressures and limited specialist capacity are recurring challenges.
The next five years will see ESG becoming less of a 'nice-to-have' and more of a 'must-have' for companies"
General Counsel
For consumer-facing businesses, the multi-stakeholder visibility of ESG adds further pressure. Supply chains, packaging, product design, and marketing campaigns all carry sustainability commitments, and scrutiny is rising. Leaders are navigating new regulatory powers, including those under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), as well as the emerging risk of greenwashing challenges, social washing risk and high-stakes ESG-related litigation. Many are approaching external communication with care, ensuring what is shared is supported by verifiable evidence or deciding to manage the risk by not sharing at all. But "greenhushing" risks missed opportunities for organisations to push forward with their own sustainability initiatives and to encourage each other to be more ambitious in this space. In a world where people and planet are reliant on organisational collaboration and competition to drive impact and move the ESG dial, the decision to stay silent is of more than just commercial concern.
Amid these pressures, opportunities are also clear. Organisations that integrate ESG into operations report tangible benefits: stronger supply chains, more effective procurement, improved employee engagement and retention, and greater credibility with regulators and investors. In these cases, alongside its purposeful impact, ESG is becoming a source of commercial resilience and business value.
This first ESG Evolve report reflects the insights of senior legal and sustainability leaders across the consumer brands and retail sector. It highlights the challenges they face, the practices that are helping, and the choices that will shape the next stage of progress. Above all, it shows a sector committed to steady movement from ambition to accountability, keeping its collective eye on the horizon even as day-to-day expectations and risks continue to grow.
Disclaimer The information in this publication is for guidance purposes only and does not constitute legal advice. We attempt to ensure that the content is current as of the date of publication but we do not guarantee that it remains up to date. You should seek legal or other professional advice before acting or relying on any of the content.