Compliance

ESG and investigations: how to conduct Due Diligence from open sources

11 June 2025

Risk management increasingly involves the ability to monitor ESG aspects, today considered fundamental for access to markets and capital.

In this scenario, therefore, the ESG Due Diligence has established itself as an essential tool for evaluating sustainability and reputational risks associated with customers, suppliers and business partners.

When an ESG Due Diligence activity is conducted detective firm, without direct access to the internal documents of the target company, the process is based exclusively on Open sources (OSint), but it can still produce solid, consistent output that complies with regulatory purposes.

According to the OECD Due Diligence Guidance for Responsible Business Conduct, businesses should take a proactive approach to identify, prevent and mitigate potential or real negative impacts along the entire value chain.

Even the Corporate Sustainability Due Diligence Directive (CSDDD) - formally approved in 2024 - imposes stringent obligations on large European companies and their suppliers with regard to respect for human rights, the environment and ethical governance.

In the absence of direct access to business documents, the Investigative ESG due diligence focuses on a careful analysis of public sources, professional databases and official records, as well as on reputational intelligence tools.

The phases of the process

The first phase consists of operational perimeter mapping of the target company: corporate structure, offices, ATECO codes, subsidiaries or investments, any foreign exposures. From here we move on to collecting ESG evidence for each of the three pillars:

  • Environmental (E)
  • Social (S)
  • Governance (G)

according to techniques and methodologies for searching for information and carried out by intelligence professionals.

The output

The final report must provide a clear picture of the ESG profile of the company, with:

  • one Executive Summary with risk indicators;
  • an ESG risk map;
  • one List of red flags detected;

and with an indication of the sources consulted.

This investigative mode allows you to integrate due diligence with a reputational and strategic vision, particularly useful for companies subject to supplier selection processes in sustainable supply chains or to controls pursuant to Legislative Decree 231/2001 regarding corruption and environmental crimes.

Ultimately, even operating with only public sources, Argo can contribute substantially to the prevention of ESG risks, offering the client robust decision-making and documentary tools, in line with the main international best practices.

Author:

Katia Trevisan

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