Data-driven materiality for Strategic advisors

Workshop Purpose

We gathered a number of corporate reporters, together with assurance providers, institutional investors and data platforms, at UCL’s Centre for Sustainable Business in September 2026. This was the second industry workshop on a data-driven approach to financial materiality for sustainability matters. It followed an initial workshop in May at Brunel University and a series of proof-of-concepts completed over the summer with reporters, investors, assurers and other stakeholders.

The objective was to test whether the proposed methodology is understandable, robust, and useful across different use cases, and whether it could support a standard way of calculating financial materiality that is explainable, repeatable and objective. The workshop was conducted under Chatham House rules.

 

Key Insights and Learnings

  • There are 6 discrete use cases: corporate reporter, SME reporter, assurance provider, institutional investor, financial data provider, strategic advisory

  • Better explanation of the framework required

  • Link material topics to reportable IROs

  • Predictive analysis for investors, but also for reporters

  • Apply the approach to SMEs and private companies

Structure

 This note focuses on the ‘Strategic Advisor’ use case and is structured as follows:

  1. The three-body framework

  2. Proof-of-concept insights

  3. Advisor perspective

  4. Workshop outcomes

  5. Next steps

1. The three-body framework

  • The Earth: the company – the listed entity whose weekly share-price return is being examined.

  • The Moon: the peer group – the industry whose movement exerts a strong influence on the company.

  • The Sun: the index – the wider market benchmark against which company and industry effects are placed in context.

The analogy reflects the classical three-body problem. In the financial-materiality model, a company cannot be interpreted in isolation: a movement may be specific to the entity, common to its industry, or part of a wider market movement.

The model uses the SASB topic taxonomy to organize sustainability drivers. It compares weekly returns with external sentiment associated with those topics, then allocates relative importance across the company, peer group, index, and active sustainability drivers. Non-active drivers are reduced to zero, allowing attention to focus on the smaller set that contributes to the model for the period examined.

Source: Maxwell Data

What the model measures, and what it does not

  • It measures association – the analysis identifies sustainability sentiment that moves with weekly stock returns after industry and index effects have been considered.

  • It is relative – the allocations show which factors are more important than others within the model. They should not be read as an exact statement that a particular percentage of total return was caused by one topic.

  • It is retrospective – the proof-of-concepts assess historical alignment. They do not yet predict future returns.

  • It distinguishes activity from statistical significance – a driver may remain active in the allocation even when its conventional p-value does not pass a particular threshold. The two diagnostics answer different questions and should be displayed separately.

  • It is not the whole share-price model – earnings, pipeline, operations, capital allocation, innovation, macroeconomics, and many other factors also affect valuation. The current work isolates a sustainability-related component.

Source: Maxwell Data

External sentiment data

The analysis intentionally uses information available in the external market rather than content produced directly by the company. Company annual and sustainability reports are excluded from the sentiment input so that the result can provide an independent comparison with what the company says about itself.

  • Sources – news and financial media, specialist trade publications, blogs, forums and selected social-media sources. The strongest industry-specific signal was often found in specialist trade publications. Twitter was not used at the time because of data-quality concerns, and broadcast media was not captured directly.

  • Company material – company-owned webpages and reports are filtered out as inputs, although external discussion prompted by a company announcement is captured.

  • Authenticity – the team monitors short-lived accounts, bots, duplicated content, public-relations material, and other indications of manufactured conversation. Source selection remains an ongoing control rather than a solved problem.

  • Language and geography – local-language material is important because English-language discussion of a non-UK company can be global or less representative. At the time of the workshop, coverage centered on the UK, Europe, and the United States, with more limited coverage elsewhere and no complete Mandarin-language dataset.

  • Classification – machine reading uses a contextual library of approximately 77,000 keywords and phrases to assign relevant items to SASB topics and classify sentiment as positive, neutral, or negative. Thresholds are set conservatively to reduce false positives.

  • Persistence – sentiment is not treated as disappearing the day after publication. A decay factor recognizes that information can continue to influence market understanding over subsequent weeks.

Participants emphasized that this is sentiment about matters such as greenhouse-gas emissions, not a direct measurement of the emissions themselves. The model assumes that underlying reported facts are broadly accurate and analyses how the wider market responds to, interprets, or questions them.

2.Proof-of-concept portfolio insights

The presentation summarized analysis across a portfolio of 25 listed companies spanning the 11 SASB industries. The broader working database contains around 1,500 companies, principally in the UK, Europe, and the United States. The figures were presented as early evidence from a developing model rather than universal conclusions.

  • Company-specific movement remains material – on average, approximately 38% of weekly return variation in the initial portfolio was described as unique to the entity, although results varied substantially between companies.

  • The industry effect was often stronger – for 24 of the 25 companies examined, industry-wide sustainability sentiment explained more variation than the firm's own idiosyncratic sustainability signal.

  • Recurring firm-level topics – supply-chain management, physical impacts of climate change and customer privacy appeared repeatedly among company-specific drivers.

  • Recurring industry-level topics – ecological impacts, employee engagement, supply-chain management and labour practices appeared repeatedly at industry level

  • Divergence can be informative – negative company-specific sentiment can outweigh a rising industry or market. A widening difference between company and peer-group sentiment may therefore provide an early warning for reporters, investors, lenders, or insurers.

  • Directional hit rate is a diagnostic – the team compared the sign of the sentiment signal with the sign of weekly return. A 50% result would be equivalent to chance in a two-direction test; performance above that level is evidence of alignment, not a forecast.

Source: Maxwell Data

Peer-group construction

The choice of peer group emerged as one of the most important methodological decisions. Very small groups chosen by a company produced unstable or extreme results, while broad exchange-traded funds could be too smoothed to reveal useful industry dynamics. The proof-of-concepts suggested that a group of roughly 10 to 50 companies, with about 30 as a practical center point, created a more robust evidence base.

A further suggestion was to test whether peer groups could be derived from the similarity of active drivers rather than only from a pre-existing industry classification. This could reveal economically relevant relationships that do not map neatly onto conventional industry boundaries.

3. Advisor perspective

Advisors saw the output as separate from reporting. The central value was the ability to separate market-wide, sector-wide, and company-specific signals. This could show whether an apparent risk is common to the industry or represents a distinctive exposure, and whether the company is beginning to diverge from its peers.

  • Early-warning analysis – monitor changes in the distance between a company's signal and its sector, while recognizing that the model has not yet been validated as predictive.

  • Enterprise risk – risk teams could use dynamic, market-linked evidence to test whether sustainability-related issues should enter reputation, operational or strategic risk discussions.

  • Reputation – reputation-risk committees could compare what the organization believes matters with what external audiences are discussing and identify gaps.

  • Tendering and social value – one participant described social value as 20% of a tender score. Where it contributes materially to bid outcomes, strong performance can affect pipeline and future revenue, while external evidence may help demonstrate differentiation from competitors.

  • Marketing and communications – the signal can show which narratives exist in the market and where communication is disconnected from material issues. It should inform communication, not be used to manufacture, or manipulate sentiment.

  • Internal engagement – linking a topic to business performance may help overcome skepticism where the language of ESG or sustainability causes immediate resistance.

  • Product development – data platforms may be able to offer the factor outputs as part of a wider analytical product, provided the methodology and coverage can be standardized.

 

Accessibility for mid-market and smaller organizations

Participants working with mid-market firms stressed the need for simplicity. Larger listed businesses may have specialist reporting, risk, investor-relations, and assurance teams, while smaller organizations may view materiality assessments as costly exercises with little visible return. More bespoke analysis is not automatically more usable.

Any industry approach therefore needs a proportionate pathway: a clear baseline, plain-language outputs, transparent default peer groups and a simple method for deciding what further investigation is warranted. Where market coverage is insufficient, the result should say so rather than create false precision.


4. Workshop Outcomes

The workshop supported the direction of a data-driven approach to financial materiality, provided it remains transparent about what it measures and what it leaves out. The three-body framework offers a useful way to distinguish the company from its industry and the wider market, while external sentiment supplies an independent perspective on which sustainability matters are being reflected in market behaviour.

The strongest future proposition is not a single ESG score. It is an explainable, repeatable baseline that shows where company-specific and industry-wide signals differ, connects those signals to specific reporting and investment questions, and sits inside a broader understanding of enterprise value.

5. Next Steps

1.     Simplify the presentation and distinguish clearly between active drivers, statistical significance, relative allocation, and absolute explanatory power.

2.     Include 1, 3 and 5-year time horizons to speak to short-, medium- and long-term timeframes.

3.     Develop transparent rules for peer-group selection, including minimum viable group size and controls for dominant companies.

4.     Allow users to inspect the source stories, volume, language, and sentiment underlying each topic so that outputs can be challenged and assured.

5.     Validate the signal against analyst research, market-data platforms, ratings, and subsequent performance to test whether it is leading, coincident or lagging.

6.     Test proportionate approaches for small-cap and unlisted companies, including sector proxies or a two-body model where direct market data is insufficient.

7.     Show the sustainability-related component within a wider account of financial materiality, including residual and conventional business drivers.

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Data-driven materiality for data platforms