Governance in the ESG Context: Proposal of a Metric for Evaluating Information Disclosure in Integrated Reports

Jussara Machado Bubniak; Gabriela Trindade Pinheiro

DOI: 10.22167/2675-6528-202603086

Article derived from a Course Conclusion Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by Instituto Pecege for textual synthesis and organization.

Summary

The growing relevance of ESG practices in the corporate context has amplified the need for transparency and accountability in organizational disclosures, especially in governance, highlighting a gap in systematic and comparable evaluation instruments. In light of this, the study aimed to develop and propose an evaluation metric for the governance axis of ESG reports, focusing on information disclosure practices in telecommunications companies listed on the B3. The research, of an applied nature, adopted a qualitative, exploratory, and descriptive approach. Documentary and content analysis was performed on ESG reports from companies in the sector, prepared according to GRI, SASB, and IFRS Sustainability standards, based on previously defined indicators organized into analytical dimensions of governance. The results revealed different levels of informational maturity among the companies, with greater consolidation in indicators of ethics, integrity, and risk management, but fragilities in the disclosure of structural information, such as shareholding composition and conflicts of interest. A predominance of an intermediate level of maturity was observed, with asymmetries in the quality and consistency of the disclosed information. Based on these findings, the Accountability Disclosure Index (IDPC) was proposed. It was concluded that the sector has advanced in the institutionalization of ESG governance, but still lacks greater standardization and alignment with best transparency practices. The IDPC constitutes a systematized and replicable analytical instrument for evaluating the transparency, traceability, and comparability of socio-institutional information.

Keywords: Information Disclosure; ESG; governance; Evaluation Metric; Transparency.

1. Introduction

The 2030 Agenda of the United Nations (UN), signed in 2015 by 193 countries, including Brazil, establishes a global commitment aimed at eradicating poverty, protecting the environment, and promoting prosperity and peace by 2030. Composed of 17 Sustainable Development Goals (SDGs) and 169 targets, the Agenda proposes an integrated approach to development, recognizing the interdependence between the social, economic, and environmental dimensions. In this scenario, corporate action requires the structuring of sustainable models integrated into the core business, with greater emphasis on governance, transparency, and responsibility in information disclosure (Prates, 2024).

In Brazil, the adoption of ESG practices, besides contributing to environmental sustainability and social equity, also presents itself as an economically viable strategy for companies (Martini, 2024). In organizational environments where institutional, cultural, and regulatory factors exert significant influence, ESG criteria operate as social norms, capable of generating incentives and new opportunities for organizations that strategically incorporate them (Shin et al., 2023). Consistent and verifiable communication of the benefits associated with adopted practices to the market and stakeholders becomes a central element of corporate governance (Bertoncello; Chang Júnior, 2007).

Governance plays a structuring role by strengthening mechanisms of accountability and transparency, which are fundamental for monitoring organizational practices. The literature highlights that information disclosure reduces informational asymmetries, contributes to organizational efficiency, and reinforces companies’ credibility (Baraibar-Díez; Sotorrío, 2017; Malacrida; Yamamoto, 2006; Stange, 2024). According to the Brazilian Institute of Corporate Governance (IBGC, 2023), corporate governance comprises the set of principles, rules, and structures that guide the direction and monitoring of organizations, aiming for sustainable value generation and alignment with stakeholders.

However, limitations in disclosure practices are still identified, as not all information is amenable to measurement, standardization, or comparability, which impacts the quality and reliability of reports. Additionally, tensions are observed between institutional discourse and the actual practices of organizations. Franco and Batista (2024) highlight the dichotomy between so-called “green slogans” and “grey behaviors,” pointing out that although many companies adopt ESG-aligned narratives, their operational practices do not always reflect a genuine commitment to sustainability and good governance. From this perspective, the concept of greenwashing refers to the disclosure of misleading or selective information, compromising the credibility of ESG practices (Huang et al., 2022).

In this scenario, transparency demands coherence, verifiability, and responsiveness to stakeholder expectations. The analyzed studies indicate that transparency can be understood from different perspectives, relating to the comparability and standardization of disclosed information, as well as to the level of relationship and accountability (Hsiao et al., 2024). The absence of structured instruments that enable systematic and comparable evaluation of disclosure practices in the governance (G) axis is evident, especially regarding the transparency, traceability, and accountability of corporate information. Structural weaknesses associated with the absence of clear criteria for governance, traceability, and accountability in organizations can generate information asymmetries, reduce stakeholder confidence, and increase reputational risks for companies (Adams; Abhayawansa, 2022).

In this context, the analysis of highly regulated environments becomes especially relevant, as such sectors demand more robust structures of governance, transparency, and accountability mechanisms. Among them, the telecommunications sector stands out, where these demands intensify, contributing to the strengthening of practices aligned with ESG principles. The National Telecommunications Agency (Anatel, 2025) highlights the strategic role of the telecommunications sector in promoting the SDGs, especially in the context of digital transformation. This work adopts as an empirical scope the telecommunications companies listed on the B3, a sector characterized by high economic relevance, broad social capillarity, and significant socio-environmental impact. It is a strongly regulated segment exposed to stakeholder evaluation, where governance, transparency, and accountability are strategic for building institutional legitimacy (Thangam et al., 2024).

Thus, given the growing importance of governance in the ESG context and the gap in the systematic evaluation of the quality of disclosures, this study is justified by the need for an instrument that promotes greater transparency and reliability. The objective of this study is to develop and propose an evaluation metric applied to the governance (G) axis of integrated reports, focusing on corporate information disclosure practices, aiming to ensure transparency, traceability, reliability, and quality of the reported data, so as to contribute to strengthening organizational credibility and the effectiveness of ESG practices in the context of telecommunications companies.

2. Material and Methods

The present study was characterized as a research of an applied nature, with the purpose of developing an evaluation metric. This metric was designed to be applied to the governance (G) axis, focusing on corporate practices for disclosing information in integrated ESG reports.

Regarding the approach, a qualitative method was adopted, with systematic data processing. The research was based on documentary analysis and content analysis, allowing the identification, organization, and systematization of disclosure patterns based on previously defined criteria in the literature, in normative references, and in the publications of telecommunications companies.

From the perspective of objectives, the research has an exploratory and descriptive character. It was exploratory for seeking to understand and structure a field that is still little systematized, specifically regarding accountability and the traceability of corporate information. Additionally, it was descriptive for mapping and characterizing the disclosure practices adopted by the analyzed companies.

The methodological design adopted was documentary and multi-case analysis, based on the analysis of public documents of a secondary nature. These documents were made available by the organizations themselves and by regulatory and certifying entities, allowing for comparison between different companies in the sector and the identification of similarities, differences, and patterns in ESG disclosure practices.

The data sources comprised ESG reports prepared based on the Global Reporting Initiative (GRI) guidelines, SASB standards, and IFRS Sustainability Disclosure Standards (ISSB), including the IFRS S2 recommendations related to climate, as well as indicators of contribution to the United Nations Sustainable Development Goals (SDGs). Such frameworks also guided the definition of the indicators analyzed in this study (Adams; Abhayawansa, 2022; Boiral; Heras-Saizarbitoria, 2020).

The research sample was intentional and non-probabilistic, composed of companies in the telecommunications sector listed on the B3. Algar Telecom S/A, Brisanet Serviços de Telecomunicações S.A., Desktop S.A., Giga Mais Fibra Telecomunicações S.A., Oi S.A., Telefônica Brasil S.A. (Vivo), TIM Brasil Serviços e Participações S.A., Tim S.A. and Unifique Telecomunicações S.A. were considered.

To ensure greater transparency in data selection, objective criteria were defined for the inclusion of companies and analyzed documents. Initially, all companies in the telecommunications sector listed on the B3 were considered, due to their economic relevance, degree of regulation, and exposure to governance and ESG practices (Thangam et al., 2024).

The selection of documents was based on three criteria: (i) public availability of information; (ii) adherence to recognized reporting standards, such as GRI, SASB, and IFRS Sustainability; and (iii) presence of content related to the governance indicators analyzed in this study.

From the sample selected for analysis, limitations were identified due to the unavailability of documents. Corporate reports from some companies were not found in the public sources consulted, which is why they were excluded from the sample. The excluded companies were Brasil Tower Cessão de Infraestrutura S.A., Elea Digital Infraestrutura e Redes de Telecomunicações, and Telecomunicações Brasileiras S.A. (Telebras).

The data analysis was conducted using the content analysis technique, according to the method systematized by Bardin (2022). This technique was conceived as a set of replicable methodological procedures, aimed at inferring knowledge from communications, through explicitly and objectively defined categories.

This study adopted a positivist-oriented content analysis approach, with categories established a priori, based on the research objectives and references. Each indicator was analyzed for its presence, level of detail, and degree of verifiability, allowing for the standardized classification of disclosures.

Based on the systematization of the analyzed indicators, a metric for evaluating the governance (G) axis was constructed, structured in dimensions aligned with the principles of governance, transparency, and accountability in the context of ESG practices. This metric was developed to assess the level of informational maturity of companies and to support the improvement of reporting practices.

The metric is composed of eight indicators, grouped into three analytical dimensions, which reflect different aspects of governance related to accountability and information disclosure. The level of detail of the information disclosed in each indicator directly contributes to the evaluation of its achievement level.

The first dimension, Structural Transparency and Governance, assesses the degree of transparency of organizational structures that directly influence decision-making, supervision, and risk mitigation. This dimension included the indicators of Shareholding Composition, Corporate Governance Structure, and Conflict of Interest.

The second dimension, Integrity, Risks, and Stakeholder Protection, focused on the mechanisms that ensure the integrity of processes and the protection of stakeholders. Risk Management, Ethics and Integrity, and Customer Data Protection and Privacy indicators were considered.

Finally, the third dimension, Social Dimension and Sustainability Governance, assesses the integration of social and sustainability practices into the organizational strategy, focusing on continuity and long-term impact. This dimension encompassed the People and Sustainability Governance (Future) indicators.

To operationalize the proposed metric, each indicator was evaluated based on the documentary analysis of the ESG reports of the selected companies, considering the degree of detail, objectivity, and verifiability of the disclosed information. Each indicator was assessed for the presence or absence of information in the analyzed documents, assigning the value “Yes” for identified items and “No” for unevidenced items.

Considering the equivalence between the indicators, each item received a weight of 12.5% in the index composition, totaling 100% when all eight indicators are met. The Accountability Disclosure Index (IDPC) was then calculated from the sum of the indicators achieved by each company, allowing its expression on a percentage scale from 0 to 100.

For methodological purposes, equal weights were assigned to the three dimensions: Structural Transparency and Governance (37.50%), Integrity, Risks and Stakeholder Protection (37.50%), and Social Dimension and Sustainability Governance (25.00%), with indicators equally weighted within each dimension. The IDPC calculation followed the formula: IDPC = (Score obtained / Maximum possible score) × 100.

The index is expressed on a scale of 0 to 100, allowing for comparability between companies and the identification of different maturity levels. For analytical purposes, the results would be classified into three levels of transparency maturity: values between 0% and 49% as low level, between 50% and 79% as intermediate level, and equal to or greater than 80% as high level.

3. Results and Discussion

The results obtained highlight the structuring role of governance in the ESG context of the analyzed companies, guiding and supporting the environmental and social dimensions. This approach contributes significantly to the reduction of informational asymmetries and to the strengthening of stakeholder trust. The effectiveness of governance is intrinsically linked to the quality and reliability of the disclosed information, being crucial for mitigating risks, avoiding opportunistic practices, and ensuring coherence between discourse and organizational practice, as discussed by Baraibar-Díez and Sotorrío (2017), Boiral (2016), and Adams and Abhayawansa (2022).

Within the scope of the 2030 Agenda, several SDGs present a direct or transversal relationship with the axis of governance, especially regarding ethics, integrity, transparency, accountability, and institutional strengthening. Although SDG 16 is the most directly associated with governance, other SDGs complement this axis by addressing structural aspects of responsible organizational action, promoting an integrated vision of sustainability. The adoption of consistent governance structures allows organizations to contribute effectively to the achievement of the Sustainable Development Goals, while strengthening their credibility and long-term performance.

SDG 16, focused on Peace, Justice, and Effective Institutions, constitutes the main reference for the governance axis, by emphasizing the construction of transparent, responsible, and effective institutions. In the corporate context, this SDG relates to the adoption of integrity programs, compliance mechanisms, anti-corruption policies, whistleblowing channels, accountability, and transparent disclosure of information, central elements for organizational legitimacy and stakeholder trust. Such practices are fundamental to ensuring compliance and social responsibility.

SDG 8, which deals with Decent Work and Economic Growth, connects to governance by addressing integrity in labor relations, promoting ethical organizational environments, and adopting responsible people management practices. Corporate governance acts as an essential instrument to ensure equity, respect for rights, and legal compliance, contributing to sustainable economic growth. This dimension is crucial for the well-being of employees and for the company’s reputation.

SDG 9, concerning Industry, Innovation and Infrastructure, relates to the governance axis as innovation and digitalization require solid structures for control, risk management, and information protection. The governance of innovation, technology, and data becomes fundamental to ensure that the development of infrastructures and technological solutions occurs ethically, securely, and transparently. This is particularly relevant in the telecommunications sector, which deals with constant technological advancements.

SDG 12, on Responsible Consumption and Production, presents a link with governance by emphasizing responsibility in corporate decisions along the value chain. Robust governance practices are essential to ensure integrity, transparency, and traceability in relationships with suppliers, partners, and consumers, mitigating socio-environmental and reputational risks. Extended value chain responsibility is a pillar for business sustainability.

Finally, SDG 17, which addresses Partnerships and Means of Implementation, also articulates with the governance axis, as effective partnerships depend on trust, transparency, and shared ethical standards. Corporate governance contributes to building responsible institutional relationships, based on clear criteria, accountability, and strategic alignment among the parties involved. Collaboration between different actors is vital for the progress of sustainable development goals.

The analysis of the adherence of telecommunications sector companies’ reports to international ESG reporting standards, such as GRI, SASB, and IFRS Sustainability, revealed varied disclosure patterns. All companies in the sample — Algar Telecom S.A., Brisanet Serviços de Telecomunicações S.A., Desktop S.A., Giga Mais Fibra Telecomunicações S.A., Oi S.A., Telefônica Brasil S.A. (Vivo), TIM Brasil Serviços e Participações S.A., Tim S.A., and Unifique Telecomunicações S.A. — indicated adherence to GRI and SASB standards in their 2024 reports. However, adherence to IFRS Sustainability was less uniform.

Specifically, Algar Telecom S.A., Desktop S.A., TIM Brasil Serviços e Participações S.A., and Tim S.A. reported compliance with IFRS Sustainability. On the other hand, Brisanet Serviços de Telecomunicações S.A., Giga Mais Fibra Telecomunicações S.A., Oi S.A., Telefônica Brasil S.A. (Vivo), and Unifique Telecomunicações S.A. did not indicate this adherence in their 2024 reports. This difference suggests heterogeneity in the adoption of more recent sustainability disclosure frameworks, which may impact the comparability and depth of ESG-related financial information.

The characterization of corporate governance practices, based on essential ESG indicators, allowed for the identification of the presence or absence of crucial elements for transparency and accountability. This systematization of information is fundamental for evaluating the maturity level of companies regarding governance and transparency practices, in addition to highlighting convergences and gaps between the analyzed groups, providing subsidies for comparative analyses and for understanding the sector’s alignment with contemporary ESG demands.

Indicator 1: Shareholding composition

The analysis of the “Shareholding Structure” indicator reveals relevant differences in the degree of transparency of telecommunications sector companies regarding the disclosure of ownership structure. Companies such as Algar Telecom S.A., Giga Mais Fibra Telecomunicações S.A., Oi S.A., Telefônica Brasil S.A. (Vivo), TIM Brasil Serviços e Participações S.A., Tim S.A., and Unifique Telecomunicações S.A. presented explicit disclosure of their shareholding structure. In contrast, Brisanet Serviços de Telecomunicações S.A. and Desktop S.A. did not evidence this type of information in the analyzed documents.

From the perspective of corporate governance, the disclosure of shareholding composition is a central element for reducing informational asymmetry between managers, investors, and other stakeholders, as discussed by Baraibar-Díez and Sotorrío (2017). Transparency regarding the control structure allows for the assessment of potential power concentrations, agency conflicts, and risks associated with strategic decision-making. The absence of this information in part of the sample can be interpreted as a relevant limitation from an accountability standpoint, especially in a capital-intensive and heavily regulated sector.

Adams and Abhayawansa (2022) highlight that structural information, such as shareholding composition, forms the basis for interpreting other ESG disclosures, directly influencing governance, strategic direction, and the degree of commitment to sustainable practices. Thus, companies that systematically disclose their shareholding structure demonstrate greater alignment with international best reporting practices. Those that omit or do not detail this information tend to increase stakeholder uncertainties, compromising trust and credibility.

Indicator 2: Corporate governance structure

Regarding the corporate governance structure, most of the analyzed companies show positive results in the adoption of formal mechanisms. Algar Telecom S.A., Brisanet Serviços de Telecomunicações S.A., Desktop S.A., Oi S.A., Telefônica Brasil S.A. (Vivo), TIM Brasil Serviços e Participações S.A., Tim S.A., and Unifique Telecomunicações S.A. disclose information related to their governance structure. However, Giga Mais Fibra Telecomunicações S.A. does not present sufficient evidence for this indicator, pointing to a gap in its disclosure practices.

Formal governance structures, such as boards of directors, specialized committees, and oversight policies, are fundamental to the consolidation of ESG practices, especially on the “G” axis, as pointed out by Mezzomo et al. (2024) and Prates (2024). The wide presence of this indicator in the sample suggests a movement towards the institutionalization of governance in the sector, possibly driven by regulatory requirements, investor pressure, and increased public scrutiny. However, the mere existence of formal structures does not, in itself, guarantee effectiveness or legitimacy.

The lack of disclosure by Giga Mais Fibra Telecomunicações S.A. reinforces the maturity asymmetry between companies and highlights the need for metrics that allow evaluating not only the existence, but also the quality and operationalization of these mechanisms. Prates (2024) warns that mere formalization may not translate into effective practices, demanding a deeper analysis of the functionality and impact of these structures on decision-making and accountability. Transparency about operationalization is as important as its existence.

Indicator 3: Conflict of Interest

The analysis of the “Conflict of Interest” indicator reveals a relatively positive pattern, with most companies evidencing policies or guidelines related to the theme. Algar Telecom S.A., Brisanet Serviços de Telecomunicações S.A., Desktop S.A., Giga Mais Fibra Telecomunicações S.A., and Oi S.A. present disclosures on conflict of interest. In contrast, Telefônica Brasil S.A. (Vivo), TIM Brasil Serviços e Participações S.A., Tim S.A., and Unifique Telecomunicações S.A. do not explicitly evidence this aspect in their reports.

The existence of clear conflict of interest management policies is essential to mitigate risks of opportunism, corruption, and decisions misaligned with collective interests, as highlighted by Shin et al. (2023). The absence of disclosure of this indicator in large and highly visible companies, such as Vivo and TIM, is noteworthy, especially considering the expected maturity level of these organizations in the ESG context. Such an expectation is based on literature that associates larger companies and greater market exposure with higher levels of transparency and disclosure, due to increased stakeholder scrutiny (Baraibar-Díez; Sotorrío, 2017), as well as on the principles of governance established by IBGC (2023).

This finding dialogues with the critique by Franco and Batista (2024) on the existence of a dissociation between institutional discourse and effective practices, suggesting that the omission of sensitive information may represent a form of selective transparency management. The lack of clarity on how conflicts of interest are managed can erode investor and public trust, raising questions about the integrity of corporate decisions. Full and transparent disclosure is crucial for organizational legitimacy.

Indicator 4: People

The “People” indicator shows uniform behavior in the sample, as all analyzed companies demonstrate practices or policies related to people management. This result suggests that topics such as diversity, inclusion, occupational health and safety, and human development are already institutionalized in the telecommunications sector. The broad evidence of this indicator may be associated with its greater ease of communication and the growing social pressure for more equitable and inclusive practices in the workplace.

Nevertheless, the extensive evidence of this indicator may not fully reflect the organizational reality, as aspects related to workers’ mental health and psychosocial risk management, including those contemplated by NR-1, may not be fully captured by the methodology for analyzing disclosure reports. According to Martini (2024), the social dimension of ESG has been consolidated as one of the most visible and communicated by organizations, especially in contexts where the workforce represents a strategic asset. However, as Boiral (2016) and Adams and Abhayawansa (2022) warn, the extensive disclosure of this dimension may also be associated with its greater ease of communication, compared to more sensitive aspects of governance.

Indicator 5: Sustainability governance (future)

The indicator related to sustainability governance with a future focus presents the most critical performance in the sample. Only Telefônica Brasil S.A. (Vivo) evidences this aspect in its reports, while all other companies in the sample show a lack of information on this dimension. This result suggests a significant gap in long-term strategic planning and the integration of sustainability into the decision-making processes of telecommunications sector organizations, with the exception of Telefônica Brasil S.A. (Vivo).

This result reinforces the discussion by Machado and Checon (2023), according to whom the consolidation of ESG practices requires long-term vision, continuous learning, and strategic incorporation of sustainability into decision-making processes. In the telecommunications sector, this perspective is directly associated with the continuous need for innovation, technological modernization, and adaptation to rapid transformations in digital infrastructure and services, elements inherent to the segment’s dynamics. The low incidence of this indicator suggests that, although companies adopt punctual ESG practices, few demonstrate structured planning and future-oriented governance, which may limit the resilience and adaptability of these organizations.

Indicator 6: Risk Management

Risk management shows broad adherence in the sample, being present in all analyzed companies. This result points to risk management as one of the main drivers for ESG adoption, especially in regulated and infrastructure-intensive sectors, as observed by Shin et al. (2023). In the telecommunications sector, this management involves, among other aspects, environmental risks related to intensive energy consumption, waste disposal, and the impacts of infrastructure expansion, in addition to risks related to cybersecurity, data protection, regulatory compliance, and the continuity of essential services.

However, as discussed by Prates (2024), the predominance of this indicator may be associated with an instrumental approach to ESG, focused more on mitigating financial and regulatory risks than on the structural transformation of organizational practices. Although risk management is fundamental, its application can sometimes focus on minimum compliance rather than a deep integration of ESG principles into corporate strategy. The absence of a more comprehensive vision can limit the transformative potential of sustainability practices.

Indicator 7: Ethics and integrity

The “Ethics and Integrity” indicator is also present in all companies in the sample, evidencing the dissemination of codes of conduct, anti-corruption policies, and compliance programs. This finding aligns with the results of Mezzomo et al. (2024), which point to corporate ethics as one of the most consolidated pillars of ESG governance. The widespread adoption of these instruments reflects the growing concern with corporate reputation and regulatory compliance, as well as stakeholder pressure for greater accountability.

However, the formal existence of these instruments does not eliminate the risk of symbolic practices, reinforcing the importance of independent monitoring and verification mechanisms, as warned by Boiral and Heras-Saizarbitoria (2020). The mere presence of a code of conduct, for example, does not guarantee its effective application or the engagement of all levels of the organization. It is crucial that these mechanisms are accompanied by an organizational culture that genuinely promotes integrity, with effective audits and whistleblowing channels to ensure accountability and transparency.

Indicator 8: Customer data protection and privacy

The “Customer Data Protection and Privacy” indicator shows a high incidence, reflecting its centrality in the telecommunications sector, whose operation depends directly on the continuous processing of large volumes of personal and sensitive customer data. All companies in the sample demonstrate practices and policies related to this indicator. The widespread presence of this indicator can be explained by the strengthening of the Brazilian regulatory framework, especially after the entry into force of the General Data Protection Law (LGPD), which imposed new obligations and responsibilities on organizations.

Hsiao et al. (2024) highlight that transparency in sensitive issues, such as privacy and data, is directly related to stakeholder trust and the reduction of reputational uncertainties. Thus, compliance with data protection regulations is not just a legal requirement, but a critical factor for maintaining customer credibility and loyalty. The absence of disclosure of this indicator in a large company, if it existed, would reinforce the need for specific metrics that allow evaluating the consistency and verifiability of disclosures, ensuring that declared policies are effectively implemented and monitored.

Given the results obtained, different levels of maturity in governance and transparency practices are evident among the analyzed companies, as well as relevant gaps in the quality and depth of the disclosed information. In general, a greater consolidation of indicators related to ethics, integrity, and risk management is observed, while structural and prospective aspects of governance, especially those focused on long-term planning, still appear incipient. These findings reinforce the need for analytical instruments capable of systematically and comparably evaluating the quality of corporate disclosure, contributing to the strengthening of governance, accountability, and the credibility of ESG practices in the context of the analyzed sector.

Based on the results obtained and the evidence identified in the content analysis, the Disclosure Index of Accountability (IDPC) is proposed as a metric for evaluating the governance axis. The IDPC is structured based on the disclosure patterns observed in the analyzed companies and considers that stakeholder confidence depends not only on the existence but also on the organizations’ ability to demonstrate their governance practices clearly, verifiably, and comparably (Bardin, 2022; Adams & Abhayawansa, 2022; Prates, 2024). The metric is composed of eight indicators, grouped into three analytical dimensions, which reflect different aspects of governance related to accountability and information disclosure. The level of detail in the information disclosed for each indicator directly contributes to the evaluation of its achievement level.

The first dimension of the IDPC, named Structural Transparency and Governance, assesses the degree of transparency of organizational structures that directly influence decision-making, supervision, and risk mitigation. This dimension encompasses three indicators. Indicator 1, Shareholding Structure, examines the clear and up-to-date disclosure of ownership structure, allowing for the identification of potential concentrations of power and agency conflicts. Indicator 2, Corporate Governance Structure, analyzes the existence and disclosure of boards, committees, and formal oversight bodies, as well as the definition of responsibilities related to governance. Indicator 3, Conflict of Interest, verifies the presence of policies and mechanisms aimed at preventing, identifying, and addressing situations that may compromise decision-making integrity.

The second dimension, Integrity, Risks, and Stakeholder Protection, focuses on the mechanisms that ensure the integrity of processes and the protection of stakeholders. This dimension is composed of three indicators. Indicator 4, Risk Management, assesses the disclosure of practices related to the identification, monitoring, and mitigation of risks, including reputational and socio-environmental risks. Indicator 5, Ethics and Integrity, examines the existence and communication of codes of conduct, compliance programs, and anti-corruption policies. Indicator 6, Data Protection and Customer Privacy, analyzes the disclosure of policies and practices aimed at data protection, especially relevant in contexts involving the processing of personal information. The literature indicates that these mechanisms tend to present greater institutionalization, although they often assume an instrumental character, which reinforces the need for metrics that evaluate the quality of disclosure and not just its formal existence (Boiral, 2016; Boiral & Heras-Saizarbitoria, 2020).

Finally, the third dimension, Social Dimension and Sustainability Governance, assesses the integration of social and sustainability practices into the organizational strategy, focusing on continuity and long-term impact. This dimension includes two indicators. Indicator 7, People, examines the disclosure of policies and practices related to people management, diversity, inclusion, and human development. Indicator 8, Sustainability Governance – Future, verifies the existence of structures, goals, and guidelines aimed at long-term sustainability, as well as their integration into decision-making processes. The empirical findings indicate that, although the “People” dimension is widely disclosed, prospective sustainability governance still appears incipient, which may limit the consistency of accountability and the strategic integration of organizational practices over time (Machado & Checon, 2023; Martini, 2024).

To operationalize the proposed metric, each indicator was evaluated based on the documentary analysis of the ESG reports of the selected companies, considering the degree of detail, objectivity, and verifiability of the disclosed information. Each indicator was assessed for the presence or absence of information in the analyzed documents, assigning the value “Yes” for identified items and “No” for items not evidenced. Considering the equivalence between the indicators, each item received a weight of 12.5% in the composition of the index, totaling 100% when all eight indicators are met. The Accountability Disclosure Index (IDPC) was then calculated by summing the indicators achieved by each company, allowing its expression on a percentage scale from 0 to 100.

The distribution of weights by dimension and indicators in the IDPC was defined to reflect the balance between structural governance elements, integrity and protection mechanisms, and the organizations’ capacity to incorporate sustainability and social impact in the long term. The Structural Transparency and Governance dimension, which includes indicators 1, 2, and 3, received a weight of 37.50%, with each indicator contributing 12.50%. The Integrity, Risks, and Stakeholder Protection dimension, covering indicators 4, 5, and 6, also received 37.50% of the total weight, with 12.50% for each indicator. Finally, the Sustainability Governance and Social dimension, comprising indicators 7 and 8, had a weight of 25.00%, with 12.50% for each. The IDPC calculation follows the formula: IDPC = (Score obtained / Maximum possible score) × 100.

For analytical purposes, the results were classified into three levels of transparency maturity, adopting a conservative approach. Values between 0% and 49% were considered low level, between 50% and 79% as intermediate level, and equal to or greater than 80% as high level, considering the greater incremental requirement for achieving higher levels of maturity. The application of the metric to the analyzed companies revealed that Algar Telecom S.A., Oi S.A., and Telefônica Brasil S.A. (Vivo) achieved 7 indicators, resulting in 87.50% and classified as high level of maturity.

The other companies — Brisanet Serviços de Telecomunicações S.A., Desktop S.A., Giga Mais Fibra Telecomunicações S.A., TIM Brasil Serviços e Participações S.A., Tim S.A. and Unifique Telecomunicações S.A. — reached 6 indicators, resulting in 75.00% and classified as having an intermediate level of maturity. The number of indicators reached corresponds to the number of items identified as present in the analyzed documents. The analysis of the results indicates the existence of two distinct levels of informational maturity among the companies, with Algar, Oi S.A. and Telefônica Brasil S.A. presenting greater adherence to the structural governance indicators and the analyzed disclosure practices.

On the other hand, the other companies were classified at an intermediate level, evidencing the presence of relevant practices, but still with gaps in specific aspects of governance, especially in the dimension of sustainability with a prospective focus. These results indicate that, although the sector presents high institutionalization of formal practices, structural fragilities still persist that impact the informational maturity of organizations. The asymmetry in the quality and consistency of the disclosed information suggests that, despite advances, there is a way to go for the standardization and deepening of ESG disclosures.

The proposed metric presents three central contributions. Firstly, it offers a systematized and replicable instrument for evaluating corporate disclosures, reducing gaps identified in the literature given the fragility of measuring the information presented in integrated reports. Secondly, it enables intra- and inter-sectoral comparisons, supporting future empirical analyses and the improvement of organizational practices. Finally, the metric acts as an inducer of transparency, by encouraging companies to incorporate more robust and verifiable governance structures, strengthening stakeholder confidence and the sustainability of actions in the ESG context.

In summary, the study identified different maturity levels in ESG governance practices in the telecommunications sector, with greater consolidation in ethics, integrity, and risk management, but fragilities in shareholder composition, conflicts of interest, and prospective sustainability governance. The predominance of an intermediate level of informational maturity, with asymmetries in information quality, highlights the need for greater standardization and alignment with best transparency practices. The Accountability Disclosure Index (IDPC) emerges as a systematized and replicable analytical instrument, capable of evaluating the transparency, traceability, and comparability of socio-institutional information, directly responding to the objective of proposing an evaluation metric for the governance axis of ESG reports.

4. Conclusion

This study sought to develop and propose an evaluation metric for the governance axis of ESG reports, focusing on information disclosure practices in telecommunications companies listed on B3, aiming to ensure transparency, traceability, reliability, and reporting quality. It was found that the analyzed companies presented different levels of informational maturity, with greater consolidation in indicators of ethics, integrity, and risk management. However, weaknesses were identified in the disclosure of structural information, such as shareholding composition and conflicts of interest, and in sustainability governance with a forward-looking focus. An intermediate level of maturity was observed, with asymmetries in the quality and consistency of disclosed information, indicating that the sector has advanced in the institutionalization of ESG governance but still lacks greater standardization and alignment with best transparency practices. As the main contribution, the Disclosure Index of Accountability (IDPC) was proposed, a systematized and replicable analytical instrument to evaluate the transparency, traceability, and comparability of socio-institutional information, offering a model for the analysis of organizational practices.

As a research limitation, it should be noted that the analysis was restricted to publicly available corporate documents, which may not fully reflect the internal practices of organizations. Additionally, the exclusion of some companies from the sample due to data unavailability may have impacted the scope of the results. Such limitations pave the way for future research, which may include expanding the application of the metric to other economic sectors and conducting intersectoral comparative analyses in the dimension of governance, deepening the understanding of the maturity and effectiveness of ESG disclosures.

Bibliographic References

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Article originating from the Final Course Work of the Specialization in Compliance and ESG of the MBA USP/Esalq

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