I think we can all agree: compliance professionals are obsessed with culture. And for good reason. A strong culture sets the tone for ethical decision-making, fosters trust, and protects an organization from the risks that come with misconduct.
Every Earth Day, the weight of our shared responsibility comes into sharp focus. For organizations, it's a chance to use our power and resources to be leaders.
At Learning Pool, this conviction drove us to launch our ESG program back in 2020 and to proudly become a B Corp in 2023. This wasn't about ticking a box, meeting a requirement, or crafting a pretty image. It was about something far more fundamental.
We did it because we believe ESG is about doing the right thing—by our people, our communities, and the planet. And that belief is baked into our culture and compliance DNA.
ESG isn’t just for public companies
There’s a misconception in the business world that ESG reporting is only relevant if you’re publicly traded or based in a heavily regulated industry. But I’m here to tell you: ESG is a business imperative for every company—especially if you care about risk, resilience, and long-term value.
Private companies, startups, small and midsize enterprises—we’re all part of the same ecosystem. And increasingly, investors, customers, and employees are asking the same questions of us as they do of listed firms: What are you doing to reduce your impact? How are you showing up for your people and community? Can we trust your governance is strong?
Avoiding the trap of sustainability theater
It’s tempting to stop at symbolic gestures—like announcing a net zero goal without a plan, or relying solely on carbon offsets without changing how your business operates. But that’s not ESG—that’s sustainability theater. And if there’s one thing compliance professionals know well, it’s that shortcuts don’t last.
Why avoiding greenwashing matters
Unsubstantiated sustainability claims—commonly known as greenwashing—can erode trust, damage reputations, and carry real legal and financial consequences. Across industries, we’re seeing increasing scrutiny of ESG commitments, and the tolerance for performative or misleading claims is rapidly disappearing.
At Learning Pool, we committed to only reporting what we can back up with systems, processes, and controls. Our ESG work lives inside the business. It’s not a side project, and it’s definitely not a comms-driven initiative. We treat it the same way we treat our compliance program—with structure, accountability, and an eye on continuous improvement.
Getting started with ESG—without a big budget
If you’re thinking: “This all sounds great, but I don’t have a dedicated ESG team or a big budget,” I hear you. When we started, our ESG working group was a small team working outside of our day jobs. But we made real progress by focusing on a few key steps:
1. Start with your stakeholders
Ask: Who are the people impacted by your business? (Employees, customers, community, investors, suppliers.) Build your program with their perspectives in mind. We used a simple survey tool (Typeform) to gather input and conduct our ESG materiality assessment—no fancy consultants required.
2. Leverage what you already have
Chances are, you're already doing things that fall under ESG—you just haven’t labeled them that way yet. From DEI initiatives to energy-efficient operations to strong corporate governance policies—map what you’re already doing to an ESG framework (we used SASB for Software & IT Services).
3. Avoid ad hoc reporting
If you can’t audit it, don’t report it. Document your efforts. Build simple processes that support your goals—just like you would in a compliance program. We embedded ESG into our training, policies, onboarding, and even our travel calculators.
4. Set out your ESG goal
You don’t need to launch a 40-page glossy ESG report overnight. Ours started with one page of key metrics and commitments, backed by cross-functional input and real data. Build your ESG roadmap like a change management plan—work backwards from your goals, get buy-in, and break it into manageable steps.
5. Tell the truth
If your company hasn’t figured everything out yet, that’s OK. ESG is a journey. Be transparent about where you are and what you’re aiming for. Stakeholders value progress over perfection—and honesty over hype. This year, for example, we’re working to better define and publish our emissions reduction targets.
ESG and compliance: two sides of the same coin
If you're a compliance professional, you’re already uniquely equipped to drive ESG forward. You understand risk. You know how to influence without authority. You’ve built programs from scratch. ESG might feel like a new domain, but it’s built on the same foundations of ethics, integrity, and accountability.
On this Earth Day, I encourage you to take a fresh look at how your organization shows up in the world. ESG isn’t a burden—it’s a strategic advantage. And it starts with the simple act of doing the right thing, even when no one’s forcing you to.
And if you're thinking of starting your ESG journey and need a template, reach out—I’m always happy to share what's worked for us.
Harper Wells is a governance, risk, and compliance leader with over 20 years of experience developing enterprise-wide ethics and compliance programs. As Chief Compliance Officer at Learning Pool, she leverages data-driven insights and innovative training strategies to foster ethical, high-performing workplace cultures.


