2.1. The Directive 95/2014
On 15 November 2014, the European Union, aware of the pivotal relevance of non-financial information disclosure, approved Directive 2014/95/EU regarding disclosure of non-financial and diversity information [
6,
11,
26]. It is expected to enhance the quality, credibility, consistency and comparability of non-financial information, improving the trust and confidence of investors and stakeholders [
6,
11].
The EUD addresses large undertakings considered entities of public interest that have more than 500 employees [
27]. It represents an essential regulatory step towards the harmonisation of non-financial information among the EU State members, requiring the disclosure of a minimum content of information regarding environmental, social and employee matters, respect for human rights, anti-corruption and bribery matters [
2,
10].
According to the EUD, for each of these topics the undertakings shall provide: “(a) a brief description of the undertaking’s business model; (b) a description of the policies pursued by the undertaking in relation to those matters, including due diligence processes implemented; (c) the outcome of those policies; (d) the principal risks related to those matters linked to the undertaking’s operations including, where relevant and proportionate, its business relationships, products or services which are likely to cause adverse impacts in those areas, and how the undertaking manages those risks; (e) non-financial key performance indicators relevant to the particular business” [
27] (p. 4–5).
The EUD does not impose a particular form of report to provide this information, leaving the possibility to choose among a separate non-financial statement or the inclusion of such information in the management report [
28]. Moreover, it is also flexible about the use of the reference framework, permitting the use of national, European or recognised international frameworks, provided that entities indicate which frameworks they have relied upon [
27].
Some scholars converge on the idea that IRF may represent one of the most suitable reference frameworks to disclose non-financial information under the EUD requirements [
2,
10]. In particular, the connections between policymakers and politicians involved both in the legislation and IR movement should foster the general adoption of IR as a tool to adhere with the EUD [
2,
10]. The similarity between the EUD requirements and the IRF have been explored by Manes-Rossi et al. [
11], who demonstrated that organisations can adopt the IR framework in order to respond to the EUD requirements.
The high expectations surrounding the emergence of the EUD led scholars to investigate the effects of the EUD on corporate reporting disclosure. To this extent, a broad range of contributions has been observed. On a national level, Sierra-Garcia et al. [
29] investigated the application of the EUD in the case of Spanish companies, and Tiron-Tudor et al. [
30] analysed the change brought by the EUD on non-financial information by Romanian listed companies, for the year previous and after the entry into force of the regulation. Moreover, Venturelli et al. [
6] analysed the readiness of large, Italian organisations’ reports for the upcoming EUD, while Doni et al. [
31] explored the quality of non-financial reports in relation to compliance toward the EUD, in the case of Italian companies foreseen by the entrance into force of the Directive. Furthermore, from a comparative perspective, Venturelli et al. [
32] compared the compliance levels toward the EUD provided by Italian and British companies. Similarly, Dumitru et al. [
33] investigated the quality of non-financial reports issued by Polish and Romanian listed companies before the entrance into force of the Directive. On an international level, Manes-Rossi et al. [
11] explored the compliance level of the 50 largest European organisations in relation to the European Guidelines, related to the EUD.
Despite the considerable awareness that has grown around the EUD on non-financial information, no studies have been found that specifically address the impact of EUD on IR disclosure provided by SOEs even though these organisations are also affected by the regulation shift.
2.2. Integrated Reporting
Integrated reporting represents the last development in the theme of corporate reporting, based on the idea of integration in a single document of financial and non-financial information [
15,
34].
It constitutes a structured reaction to the growing investors and stakeholders’ needs, where the former asks for more useful and relevant information about firms’ financial and economic domains, mainly linked to the corporate value, and the latter require more information about social and environmental matters [
13]. In this end, it is meant to overcome the drawbacks of previous stand-alone (e.g., sustainability reports) and traditional reports (financial reports), which discuss social, environmental and financial information as “unconnected silos” [
13] (p. 1191), also neglecting the importance of intangible assets and governance features [
34,
35,
36].
As such, IR is a single tool which provides a holistic representation of all the dimensions which influence the organisation’s ability to create value over time in a forward-looking perspective [
15,
34,
37,
38]. It is based on principles and content elements established in the framework released in 2013 by the International Integrated Reporting Council (IIRC), “a global coalition of regulators, investors, companies, standard setters, the accounting profession and NGOs” [
16] (p. 1). The guiding principles are “strategic focus and future orientation; connectivity of information; stakeholder relationships; materiality; conciseness; reliability and completeness; and consistency and comparability” [
16] (p. 16). To this extent, the principle-based concept on which the IRF is based, resulting from a mimicry process with other standards and frameworks [
39], sets the framework in the forefront for the inclusion and disclosure of the SDGs [
12], creating further necessity to understand how current accounting techniques are, or can be, used in support of the spreading of the SDGs [
40]. Notwithstanding the emergence of the SDGs and the flourishing adoption of the IRF, no contributions that empirically investigate the adoption of SDGs in the IR context have been found. However, contributions investigating the relationship between the adoption of the SDGs among GRI adopters are already available [
41,
42].
The content elements include organisational overview and external environment, governance, business model, risks and opportunities, strategy and resource allocation, performance, outlook, basis of preparation and presentation and general reporting guidance [
16] (p. 5).
Although IRF has been primarily designed for for-profit companies, it can also be adopted and possibly adapted in the public sector and not-for-profit context [
16]. Consequently, in recent years, the debate about IR application in the public sector context has been fervent [
18,
19,
21,
43,
44]. In this vein, the Charted Institute of Public Finance & Accounting (CIPFA) delivered a study on the IR potential for public sector organisations [
45]. According to scholars [
17,
20,
21], IR may represent a useful tool for SOEs to evidence all the interconnections between the factors involved in the value creation process.
Moreover, as argued by Tirado-Valencia et al. [
44] (p. 3), “[T]he conceptual framework of IR is well-adapted to the public sector, because state-owned enterprises usually operate under market conditions, and the primary purpose of IR is to explain to financial capital providers how an organisation creates value over time”. Further, considering the full range of stakeholders orbiting around SOEs, IR can serve as an instrument to obtain their legitimacy and improve their engagement [
17,
43].
Although IR is in its early stages, an increasing number of studies have investigated the various issues related to IR [
25,
38,
46,
47]. However, most of the studies focused on theoretical aspects regarding the role of IR with related challenges and weaknesses and the IRF and the perceptions of stakeholders and investors about IR adoption [
14,
37,
38,
47]. Conversely, a few studies are investigating the IR disclosure practices in terms of disclosure and compliance levels with IRF. The existing studies are concentrated on private sector [
14,
25,
38,
46,
47], while, the research in public sector is still limited [
19,
24,
43,
44,
48].
A first strand of IR disclosure studies has been conducted before the completion of the IRF in 2013 and was based on previous guidelines introduced by the Integrated Reporting Committee of South Africa (IRCSA) in Discussion Paper issued in 2011 [
49].
Among these, Marx and Mohammadali-Haji [
50] investigated IR practices of the top 40 companies on the Johannesburg Securities Exchange, South Africa (JSE), finding that that the IR quality of the selected companies varies from excellent to poor with only a partial level of compliance with IIRC 2011 guidelines. Setia et al. [
36] analysed the corporate reports of the top 25 companies listed on the JSE immediately before (2009–2010) and after (2011–2012) the regulation of IRs [
49] by focusing on the disclosure of four capitals (human capital, natural capital, social capital and intellectual capital). Their results pinpoint that companies report more non-financial information when the disclosures are under increased scrutiny via regulated disclosure requirements and that JSE-listed companies disclose significantly more information on social and relational capital in IRs (2011/2012) compared to annual reports (2009/2010).
Then, with the final development of the IR framework in 2013, other disclosure and compliance studies emerged.
Based on strategic and institutional legitimacy theoretical framework, Haji and Anifowose [
50], analysed a sample of 246 IRs of large South African companies, over a three-year period (2011–2013), to test the difference in disclosure practices pre and post IR “apply or explain” introduction. Results evidenced a significant increase in the level of disclosure following the adoption of IR practice, especially regarding human and intellectual capital. Moreover, they observed a trend towards the institutionalisation of IR disclosure across and within the different industry sectors.
Others, explored the level of IR disclosure provided by firms included in the IIRC’s pilot programme. Focusing on four <IR> framework areas (the guiding principles of connectivity and materiality, and two content elements, the business model and governance), Rivera-Arrubla et al. [
14] found medium levels of IR disclosure and some significant explanatory factors: environment of organisations (i.e., region and industry), assurance of the report and publication in the IIRC website. Investigating a sample of eight financial sector European companies for the year 2015. Sofian and Dumitru [
46] found, on average, a medium level of compliance and that each sampled company differs from the others with respect to at least one of the guiding principles or fundamental concepts of the <IR> framework. Using the case of Johannesburg Stock Exchange (JSE) listed companies, Zhou et al. [
25] examine the level of adherence with the <IR> framework and the influence on the analyst forecast error and the equity cost. They found that analyst forecast error as well as the cost of equity capital are significant and negatively associated with the firms’ level of compliance with the <IRF>.
In the case of six French companies drafting IRs, Albertini [
51] finds that social, relational and financial capitals were the most disclosed capitals, while natural capital was the least discussed. Moreover, she observed a prevalence of increases in capital or positive information rather than negative or decreases in capital information. Also using a small sample of five companies that are expected to be superior IR reporters, Liu et al. [
15] applied a normative benchmark, to examine the level of compliance with the <IRF>. The analysis revealed both a low level of compliance with the <IRF> and a lack of connections between the various strands of information (e.g., financial and non-financial capitals). Human and social and relational capital are the most disclosed capitals, while business model, organisational overview and external environment and governance were the most disclosed content elements.
Pistoni et al. [
47] conducted a comparative analysis for the years 2013 and 2014 on a sample of 58 companies included in the IIRC database. They assessed the level and quality of IR disclosure provided in accordance with the IRF requirements. Although they observed a general improvement in the quality of the content from 2013 to 2014, the overall IR quality was still inadequate with more attention paid to the form than to the content of the reports. Kilic and Kuzey [
38] focused on a sample of 64 Turkish listed firms by examining the compliance level of corporate reports (i.e., traditional annual reports and stand-alone sustainability reports) with the IRF required content for the year 2015. Results showed that reports discuss generic risk information rather than company-specific, provide more positive than negative information as well as more backwards-looking information rather than forward-looking information, present financial and non-financial initiatives separately and lack a strategic focus. On the other hand, in the public sector realm, Guthrie et al. [
24] investigated a sample of five Italian public sector organisations to assess whether adoption of the IR concretely contributes to the advancement of integrated thinking. Through semi-structured interviews, reports and website analysis, the authors suggest that the adoption of IR can lead to change in organisations in terms of integrated thinking adoption. Additionally, Montecalvo et al. [
48] conducted a case study on a SOE based on the analysis of 15 years of annual reports and IRs, supplemented by interviews, to examine how the IR had influenced its sustainability reporting practices. They observed that IR implementation positively affected the balance and content of sustainability disclosures. Manes Rossi [
19] conducted a case study on six PSOs to assess the extent to which the IR framework is followed and if the IR may represent an appropriate tool to improve stakeholders’ engagement in PSOs. Focusing on four main aspects, business model, materiality, conciseness and stakeholder engagement, the author concludes that the IR framework does not provide sufficient support for public sector entities to be considered as the best reference for accountability purposes. Farneti et al. [
43] conducted a longitudinal case study, from 2009 to 2017, based on content analysis and interviews with key managers of a New Zealand SOE, to examine if the adoption of the IR influences social disclosures. They observed that, during the period 2009–2012, when the GRI framework was used, there were more social disclosures than in the 2013–2017 period when disclosure was driven by the IRF. Moreover, in the managers’ opinions, IR adoption had fostered the engagement of both internal and external stakeholders. Finally, Tirado-Valencia et al. [
44] focused their attention on the integrated thinking dimension of the IR, investigating a sample of 17 SOEs for the period between 2013 and 2017, to examine the incorporation of integrated thinking in IR report preparation. Their analysis evidenced that SOEs are still far from the full incorporation of integrated thinking in IR disclosure and that in the external approach dimension, connections of the environment and the impact on society with value creation are relatively frequent, while connections related to commitment to stakeholder expectations are infrequent.
Thus, by considering previous studies, a gap emerges in the literature, because there is limited research assessing the level of IR disclosure in compliance with the IRF under the EUD regulatory pressure. The majority of studies have been conducted in the private sector with a lack of empirical evidence in the public sector realm.
In order to fill this gap, this research aims at extending empirical research on IRs in the public sector field, by investigating the role of Directive 95/2014 in stimulating IR disclosure in the SOEs context. More specifically, the present study proposes a two-year analysis (2016 and 2017) to analyse the level of IR disclosure provided in compliance with IRF pre and post EUD.
2.3. Theoretical Background
According to legitimacy theory, organisations’ existence and the probability of survival are strictly correlated to the perceptions of stakeholders as well as to the relationship between social expectations and organisational behaviours [
36,
52,
53]. In order to obtain legitimacy, each organisation should act demonstrating respect to norms, social values and expectations shared by the community of stakeholders in which it is rooted [
7,
36,
54]. If the stakeholders’ community perceives a lack of congruence between its system of values and norms and that of the organisation, a legitimacy gap emerges [
7,
50]. Legitimacy theory takes on particularly strong connotations in the SOEs context where a more comprehensive forum of stakeholders exerting political and social influences exists, demanding information about financial and non-financial matters [
8,
54].
In this vein, SOEs can be considered particularly interesting as such organisations “constitute an important sector in different countries, and their response to existing and future challenges can greatly influence the development (not only economic growth) of many regions in the planet” [
55] (p. 207). Moreover, SOEs can be seen as instruments used to correct market failures or promote economic development; thus, such organisations represent an example for society in the way they act [
56]. Accordingly, to legitimise their actions, SOEs may manage these pressures, increasing their transparency and accountability level about financial and non-financial information [
8,
54]. In this aim, the IR can represent a useful tool, permitting the two strands of information (financial and non-financial) to be integrated in a single document, in turn helping SOEs in improving transparency and gaining legitimacy [
17,
20,
21]. By using the IR, SOE managers, beyond proving the efficiency and effectiveness underpinning the use of public funds, can also demonstrate the sustainability of their activities and programs, enhancing the general level of trust and credibility [
44].
Scholars identified two complementary strands of legitimacy: strategic and institutional [
37,
50,
52,
57].
Strategic legitimacy is based on an internal and managerial perspective and focuses on the strategy used to acquire or repair the legitimacy [
37,
50]. In the first case, organisations adopt a proactive behaviour, analysing the organisational field and disclosing additional information, especially about social and environmental issues, to demonstrate that they share stakeholders’ norms, social values and expectations [
37,
50,
52]. In the second case, a legitimacy gap exists [
36]. As such, organisations adopt a reactive strategy, changing internal managerial behaviours and disclosing more information to highlight the efforts made to adhere to the socially accepted norms and values and possibly change the negative stakeholders’ view [
2,
36].
Institutional legitimacy takes an external and institutional perspective and is based on the assumption that each organisation operates within an external environment whose pressures in terms of norms, laws, rules, routines and belief systems influence its behaviours and structures [
17,
53]. These pressures stimulate isomorphism, which is uniformity of practices and behaviours aimed at conforming to norms and values to gain wide acceptance [
17,
50,
53].
Institutional isomorphism can be coercive, mimetic and normative [
48,
50,
53,
58]. Coercive isomorphism can be identified with the external pressures exerted by regulatory bodies such as the European Union, the state or local governments, which require compliance with rules, laws, decrees or regulations [
48,
50,
59]. The Directive 95/2014 may stimulate a form of coercive isomorphism among EU Member State entities of public interests, provided that the search for standardisation and comparability of the information does not outweigh the quality of disclosure [
6,
59]. It can also represent a stimulus to provide a high level of disclosure through the IR [
10]. Mimetic isomorphism occurs when organisations belonging to the same environment or industry sector share similar behaviours and mimic the best practice of the best organisations [
50,
53]. In this vein, organisations pertaining to the same industry sectors, although coming from different geographical areas, follow the routines and reporting patterns of the industry leader, to reduce uncertainty and gain more legitimacy from the environment [
17,
50]. Such practices, in turn, can foster a process of institutionalisation of reporting practices [
50], especially in those sectors, which being particularly environmentally sensitive, are more socially exposed [
8,
36].
In the end, normative isomorphism arises from professional networks or industry bodies in terms of values, beliefs and social norms that provide structures of legitimate behaviour [
17,
50]. In this kind of isomorphism, in order to gain legitimacy, organisations tend to both adopt structures, systems and processes and adhere with values and social norms laid down by relevant professional groups [
17,
59].
Under a similar perspective, it is possible to assume that given the complex network of resource providers SOEs are exposed to, such organisations may try to satisfy different interests of different stakeholders that may affect their activity [
60]. In this vein, stakeholder theory is grounded on the existence of social contracts between the organisation and its stakeholders [
61]. Such theory permits an analysis of the relationship existing between an organisation and its stakeholders [
62].