Mohit Saini
Consulting Firm
January 2024

Hi team,

Happy New Year!

behalf of Phenix Capital Group, we
would like to thank you for the opportunity to share our insights on the Draft 
Norms. Please feel free to reach us at for any clarifications.

Mohit Saini
December 2023

Good morning,

Please find below our comments on the various topics.

Do the Norms strike the right balance between uniformity and
standardization on one hand, and flexibility for preparer discretion and
customization on the other? What, if anything, would you change to improve that

  • Yes,
    the norms are a commendable blend of standardization and customization.

Does the suggested content and structure—in particular the list of
suggested topics in “3. Impact Performance”—include the right items with the
appropriate level of emphasis? Is there anything you would recommend adding,
removing, or changing?

  • Measuring unintentional impact seems challenging.
    Provide more guidance on the practices that can be applied to measure and
    report it, provide a clear definition and examples.
  • Consider adding explanations on methods of
    aggregation at a portfolio level to enhance the comparability (across
    asset classes, geography…). Encourage the reports preparers to report
    common types of metrics like reporting on the proportional impact (ex: for
    1 million USD invested, the number of … is …)
  • Provide additional guidance on how preparers
    should handle the reporting of expected impact vs. achieved impact. For
    instance, how do we treat investments that are not realized yet? Maybe we
    should encourage the reports preparers to put targets in their reports but
    not claim that is something that they achieved or will achieve.
  • In general, the norms should promote more
    alignment with already existing frameworks like HIPSO, ICMA, IRIS+, and
    provide more practical examples.
  • Have a direct recommendation of what should be
    publicly disclosed: The norms state that the reports should be privately
    shared with the report’s users (capital providers). However, they also
    state that the process will increase the ability of report preparers and
    users to benchmark impact performance against comparable peers, to the
    extent that reports are shared publicly.

Should a principle of conservatism be added? This would encourage report
preparers, when facing situations in which information is uncertain or may be
framed or presented in various ways, to favor possible understatement over
possible overstatement of positive impact (and vice versa for negative impact).

  • Yes

How can field-building organizations (including but not limited to
Impact Frontiers) best support collective action among report preparers and
users to transition to impact performance reporting in alignment with the

  • Report preparers and early adopters should
    receive active support during the transition period and through the pilot

Impact Frontiers can steward the Norms as long as is needed. In the
longer-term, however, incorporation into a larger body of standards may
increase adoption and reduce proliferation of standards. What kind of entity
would you see as the best long-term home of these norms?

  • It will depend on the target audience because
    Impact frontier is a non-profit association, it should maybe partner with
    an association that has a larger outreach, deep sector-specific expertise,
    and credibility to promote such norms.

Transition period

  • It can be beneficial to clarify specific
    milestones within the 3-year transition period to provide a more
    structured approach.

Pilot program

  • We think that it is a good idea, because it
    promotes a collaborative approach. However, clearly explain in the draft,
    the nuance between the transition period and the pilot program. At first,
    we did not understand the temporality between both, but after attending to
    the webinar, we understood that the emphasis is put on the way of working.
    Indeed, in the transition period, report preparers, users and reviewers
    will pilot individually, whereas, in the pilot program, they will
    pilot the norms as part of larger group.

Preparer statement

  • We don’t really see a value added to create a
    whole statement when reports preparers can simply merge it with the
    traditional disclaimers they already provide.
December 2023

Thanks for this important initiative. The proposals are a good start, but I suggest digging deeper into #1 (impact thesis), #3 (performance data), and #6 (data assurance). I don’t think #2 (investment process) is needed, as that is covered by the Operating Principles for Impact Management. Nor do we need case studies (#5). If governance means data governance, that could be combined into #6.

#1 – impact thesis. Here, I would ask for clear theories of change, as a basis for selecting the metrics that are reported on under #3.

#3 – I would require use of standard metrics where available from ISSB, GRI or IRIS+/HIPSO. This will provide the needed comparability. We should also distinguish between the impact performance of the firms that the fund/DFI has invested in, versus the impact performance of the fund/DFI – ie it should be clear which is being reported on. If the latter is being reported on, there should be transparent attribution rules, based on the theory of change (#1).

#6 – I would relabel this ‘data quality”. It should cover all the ways in which reporting entities can provide comfort to the user of the data that the data is reliable. This can be done in different ways, including audit/assurance of data, providing transparent disclosures on sources and methodologies used to compute performance data. Sometimes it will not be possible to provide accurate data, so #6 should also include some kind of statement of limitation, ie a health warning to the user on how accurate the data is. In addition, where the impact is on people, it should include an explanation of how affected people were consulted about the claimed impact.

On the question of who could house the performance reporting standards, it could be a useful adjunct to the Operating Principles for Impact Management. As such, it could be housed at the GIIN alongside the Principles. Fund managers/DFIs could choose to sign up to one or both standards, hopefully with investor pressure to do both. Over the longer term, the standards may be embedded in government regulation, so probably best to see its initial home as an interim solution – so use existing institutions rather than create new ones.

I look forward to seeing this initiative move into implementation.

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