To cite this paper: Muzammal Khan and Abeer Hassan. (2019).

“Environmental Reporting in
Pakistan’s Oil and Gas Industry”. International Research Journal of Business Studies, Vol.
12 | No. 1, pp. 15-29. https://search.crossref.org/?q=irjbs%2F&published=2019. Link to
this issue http://irjbs.com/index.php/jurnalirjbs/issue/view/43

Environmental reporting in Pakistan’s Oil and Gas industry

Muzammal Khan* and Abeer Hassan

Research Paper

Correspondence Author

Dr Muzammal Khan

Electronic copy available at: https://ssrn.com/abstract=3384843

Lecturer of Management

School of Business and Enterprise

University of the West of Scotland
Paisley Campus, PA1 2BE
Muzammal.Khan@uws.ac.uk

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Abstract

This paper investigates to what extent Oil and Gas (O&G) companies in Pakistan report on
environmental protection activities. Using a content analysis approach, environmental
reporting (ER) in 13 companies’ annual reports and websites are investigated over a five year
period (2010-2014) following the guidelines issued by Securities Exchange Commission of
Pakistan (SECP). Results reveal that the majority of the companies were found to have a low
level of ER. However, since the introduction of SECP’s voluntary guidelines, the level of ER
increased during the sample study period. Companies that issued a stand-alone report found
be having higher levels of disclosure on their environmental protection practices. This study
guides the management to engage with internal and external stakeholders with their
environmental management practices. The results may also be beneficial to the government
for providing reporting guidance and stock exchange regulations regarding obligatory
dissemination of environment-related information.

Key Words: Environmental reporting, Oil & Gas Industry of Pakistan, Content Analysis

Paper Type: Research Paper

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Introduction
Oil and Gas (O&G) are important resources and many developing countries are rich in these
natural resources (Alazzani & Wan-Hussin, 2013; Bowrin, 2013). However, several accidents
in the O&G industry have damaged the natural environment, wildlife and local human
populations. For instance, the Bhopal disaster in 1984 killed more than 15,000 people and
left thousands injured after deadly gases were released into the atmosphere as a result of an
explosion in a defective tank. In 2010, an explosion at a BP drilling rig in the Gulf of Mexico
killed eleven people, and leaving 17 injured, thus resulting in an extensive oil spill continuing
for 86 days. In 2003, an oil spill in Pakistan was found to be a major cause of illness amongst
thousands of people near the shores of Karachi, and this caused serious environmental
problems (Janjua, Kasi, & Nawaz, 2006). In addition, industries discharge poisonous waste
chemicals directly into the streams, endangering lives and biodiversity (Ullah, Malik, &
Qadir, 2009). As a result of such instances of environmental damage, inspections of O&G
companies activities have been initiated (Peck and Sinding, 2003), to ensure that the
environment is protected and natural resources are preserved. However, associated reporting
of environmental issues has also increased as a consequence of various influencing factors,
including pressure from stakeholders (R. Gray, Kouhy, & Lavers, 1995; Sarkis, Gonzalez-
Torre, & Adenso-Diaz, 2010). In the wake of such pressures, companies respond with
providing voluntary environmental related information, particularly O&G industry was found
to be giving more environmental information due to the high possibility of negative impact
on the environment by its operations (Kirat, 2015). There is now a trend to investigate the
disclosure practices of companies. Despite, the ER has been intensively investigated in
developing countries now (Belal, 2000; Chatterjee & Mir, 2008; Sumiani, Haslinda, &
Lehman, 2007; D. Villiers & Barnard, 2000), there is a limited evidence on the South Asian
region. Kemp and Vinke (2012) assert that in South Asia the evidence on corporate social
responsibility practices is limited as the majority of the previous studies targeted Bangladesh
and India while ignoring some geographically and economically important nation such as
Pakistan. Although, a small number of studies have investigated reporting practices in
Pakistan recently, (Kemp, L. J., and Vinke, 2012; Naeem & Welford, 2009; Nazir, 2010;
Sharif & Rashid, 2014) none have investigated the ER practices of Pakistani companies in
general and O&G companies in particular. On this note, our study explores the O&G industry
in the South Asia region, namely, Pakistan. This particular industry was selected because it

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has a greater impact on the environment as compared to any other industry. Additionally,
extractive industries might be embracing reporting practices to legitimise their practices since
it has more impact on the environment, which makes it an interesting case to be explored.
“The study contributes to the existing” (Smith, 2010, P. 13) literature in the following ways:
1) it brings a developing country study to the literature from a region (South Asia) where
there is limited evidence on ER and hence complements the current focus, which is mainly on
developed countries or some transitional economies such as Malaysia. 2) It extends the
literature on disclosure practices in Pakistan, particularly environmental disclosure in an
environmentally sensitive industry. 3) It captures the findings from various sources of ER that
companies use for disclosure. 4) It assesses the impact of voluntary regulation issues by
SECP (2013): whether or not this had an impact on companies’ environmental reporting
practice?
The paper is organised as follows, the next section explores the relevant literature on ER,
focusing on ER in developing countries. It will then outline research procedures, in relation to
the GRI-index, sample, unit of analysis and categorisation, used to analyse the content of
company reports and websites. It will then discuss the analysis of selected companies’ ER
practices, concluding that ER is still low and undergoing development in the O&G industry
of Pakistan, and suggesting that governmental and non-governmental organisations should
increase pressure on companies to be more transparent.

Theoretical Framework - Legitimacy theory

Legitimacy theory has been used extensively to discuss companies’ ER practices (Nik Nazli
Nik Ahmad & Haraf, 2013; Cho & Patten, 2007; Clarkson, Li, Richardson, & Vasvari, 2008;
Deegan, Rankin, & Tobin, 2002; Hughes, Anderson, & Golden, 2001; Iatridis, 2013;
Reimann, Ehrgott, Kaufmann, & Carter, 2012). Previous studies have discussed four
strategies of Lindblom (1993) that corporations can use to legitimize its existence by
voluntarily reporting environmental information. They are: 1) Educate and inform via
reporting – the company change and reports the actual facts. 2) Reporting to change the
perception of society – No changes in the organization but reporting on what it performs. 3)
Reporting to control perceptions of society – more emphasis on the positive news while
ignoring the negative news. 4) Reporting to change external perceptions - expectations are
regarded as being unfair. Lindblom’s strategies have been applied extensively to describe
companies reporting practices. For example, a study conducted by Cong and Freedman

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(2011) concludes that companies with a good governance aim to project an image of being a
good corporate citizen while their actual performance contradicts that image. In addition, they
argue, companies focus on projecting a good image on the high-profile issues in order to
obtain legitimacy. However, the image and the actions that companies use to influence
perceptions are unreliable (Patten, 1992). Similarly, a study conducted by Chu (2013) in
Chinese companies concludes that most of the reporting found to be neutral or good news,
this reflects that companies use their annual report disclosure as a tool to legitimate their
actions. In addition, this is achieved through manipulation technique which means changing
the attention of the public. Furthermore, for example, de Villiers and van Staden, 2006 and
Mahadeo, Oogarah-Hanuman and Soobaroyen (2011) found that legitimising objectives may
have been served by altering the type and volume of disclosure in order to avoid from
legitimacy crisis. Furthermore, Momin and Parker (2013) found that seeking internal
legitimacy appeared to be the main motivation for CSRR practice in MNCs subsidiaries in
Bangladesh. On the other hand, in regards to the reason behind non-disclosure of
environmental information Antonites and de Villiers (2003) argue that the sensitivity of
environmental information was considered as the most important reason in companies to not
to choose to report environmental related information. In addition, while choosing to report
or not to report, companies’ will do best effort to protect its image to obtain stakeholder
confidence because sensitive information can have a negative impact on the business and
therefore there is a reluctance.
In addition, Branco and Rodrigues (2008) argue that companies alter their reporting practices
when they confront environmental disasters such as oil spill which might bring them under
public scrutiny. Moreover, companies in a country such as Pakistan may be conscious of
negative publicity and in order to avoid such a crisis, they tend to give information about its
environmental performance. Nevertheless, over recent years ER has developed as an
important feature of corporate social responsibility. It is now customary for many companies,
including companies in extractive industries, to exhibit their commitment to sustainable
development (Peck and Sinding, 2003). The basic aim of ER was to display a corporation’s
commitment to the environment. However, the debate has been shifted and now the main
goal of ER has to be to demonstrate the company’s environmental performance. It is this
shift that needs to be tested in such a region (South Aisa, Pakistan) where environmental
problems are increasing rapidly.

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Literature Review
Excessive emissions and environmental carelessness create risks for the health of individuals
and the natural environment, also the negative corporate image created by these issues can
have a serious impact on companies’ profit (see, for example, Adams, Muir, & Hoque, 2014;
R. H. Gray, Owen, & Adams, 1996; Milne & Gray, 2012; Tilling & Tilt, 2010; Tilt, 2018).
This is not claimed only by academics, but also by some well-known firms such as Deloitte
(1993), ACCA (2013), KPMG (2015), who have issued reports that emphasise the growing
public demand for increased environmental disclosures. Many corporations have moved
business operations to South Asian countries to take advantage of less stringent laws and to
have the benefit of an abundance of natural resources (Schuster, Lund-Thomsen, & Kazmi,
2016). Naeem and Welford (2009) conducted a comparative study of corporate social
responsibility through an investigation of written policies of both local and multinational
corporations operating in Pakistan and Bangladesh. They concluded that both countries face
severe issues associated with the degradation of the environment and exploitation and abuse
of labour and human rights. Likewise, a study conducted by Bhutto, Bazmi and Zahedi
(2011) highlight that; Pakistan is suffering from deforestation due to land developments and
business expansion. In addition, spillage of oil in the sea and gas explosion is the most
prolific problem around the world, particularly in developing nations. As such major
incidents were witnessed in the United Arab Emirates, India, Kuwait, Libya, Mexico and
Pakistan. For instance, Meo et al., (2008) examined an incident of Greek oil tanker spillage
along the shores of Karachi, Pakistan, the study concludes that the event impacted the lungs
of the workers who were exposed to a crude oil spill. In addition, such events not only cause
deaths but also impact companies’ legitimacy.

Under such circumstances and pressure from a stakeholder for environmental performance,
companies have started to provide information regarding their environmental risks to avoid
any legitimacy crisis. For example, Cho and Patten (2007) argue that companies use
disclosure as a tool to minimize the exposure to social and political pressures, and companies
that show a bad environmental performance are likely to make more environmental
disclosures to gain legitimacy. In addition, the previous studies focusing on ER in developed
economies have suggested that the main reason behind such reporting is to obtain legitimacy
(Islam & Deegan, 2010; Mitchell & Quinn, 2005; Tilling & Tilt, 2010). In a similar vein, few
studies focusing on developing countries have also highlighted that the main reason behind
company disclosure is to gain legitimacy (see Chatterjee & Mir, 2008; Chu, 2013; Sahay,

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2004). However, Ahmad and Haraf, (2013) suggest that legitimacy theory has a limited
support in explaining the nature and reason for disclosure in the Malaysian context. Whether
or not this is true in the context of Pakistan still needs to be investigated, particularly in the
O&G industry.
A number of studies have found that the level of ER in developing countries are low and it’s
in early stage - evidence from few developing countries in Asia are as follows.

Table 1 - A summary of previous studies conducted in developing countries

Method Industry
Author(s)
Country & Conclusions
Year
Industry
Nazli Nik Malaysia Content Industrial The extent of environmental
Ahmad and Analysis products and disclosure is very low in selected
Sulaiman, construction industries.
(2004) companies
Dutta and Bangladesh Content Mixed listed The web-based ER is still in its
Bose (2008) Analysis companies early stage as the level of
environmental disclosure is very
low.
Othman and Malaysia Content Palm oil ER found to be a tick-boxing
Ameer, Analysis companies practice to hide the real pictures
(2010) from the stakeholders.
Azizul Islam Bangladesh Content Multinational Non-financial disclosures were
and Aminul Analysis O&Gs associated with the public
Islam (2011) pressures as a result of the
negative media coverage
regarding the blowouts.
Djajadikerta Indonesia Content Mixed listed ER is still in its infancy and
and Analysis companies companies have a lack of
Trireksani, understanding about such
(2012) disclosure. ER used as a tool to
obtain societal recognition.
Qi et al., China Content Mixed listed Low level of disclosure, except
(2012) Analysis companies larger companies that disclosed
significantly more about the
natural environment.
Eljayash et Arab oil Content Oil and Gas The quantity and quality of ER in
al., (2012) exporters Analysis Arab oil countries is still
considerably lower than in
developed countries.
Ahmad and Malaysia Content Property The quantity and quality of
Haraf, (2013) Analysis development environmental disclosure are
companies very low and inconsistent and
most the corporations give “soft
disclosure”.
Ullah et al., Bangladesh Content Textile Companies failed to address

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(2014) Analysis companiesenvironmental issues in reports,
and when they did, the level and
quality were very poor.
Fernando, Sri Lanka Content Mixed listed The company modified the
(2014) Analysis companies structure and format of reporting
time to time, nevertheless, the
CSR related expenditure seen as
diminishing gradually.
Chaudhry, Pakistan Interviews Petroleum The firms are more focused on
Mughal and Companies being seen as Green and they are
Zafar doing this to portray a positive
(2014) image.
Dissanayake, Sri Lanka Content Mixed listed The majority of companies focus
Tilt and Analysis companies on social aspects, despite poor
Xydias-Lobo environmental evidence in the
(2016) country.
Odera, Scott Nigeria Content Oil The quantity and quality of
and Gow Analysis companies CSRR are found to be low
(2016) despite concerns raised about
environmental degradation by the
companies.

The above table provides an overview of recent studies that investigated ER in various
developing countries. A general trend is observed that companies provided an inadequate
environmental information in their annual reports. The review of studies in the Bangladeshi
context indicates a poor state of ER. Over the time, both oldest (the year 2000) and recent
(the year 2016) studies concluded that the level of reporting is low. The studies in Malaysia
are relatively recently conducted and the state of ER is not different than any other
developing country as few studies found that the level of environmental disclosure in
Malaysian companies is low. However, interestingly, studies in the Malaysian context also
highlight the reasons behind the disclosure. For instance, companies use reporting as a tool to
be seen as sustainable businesses and practice reporting as a tick-boxing exercise. However,
Nazli Nik Ahmad and Sulaiman, (2004) argue that there is a limited support for legitimacy as
a reason to disclose on environmental issues. Nevertheless, the government’s intervention by
introducing mandatory reporting laws perceived to be a potential solution (Ahmad and Haraf,
2013). Overall, previous literature on ER indicates that the concept of non-financial
reporting is gaining importance in developing countries, even though it is still a voluntary
practice. In terms of literature on environmental reporting, Investigation of ER has been as
yet unexplored in Pakistan, with existing literature examining only corporate social
responsibility (CSR) reporting in general. Kemp and Vinke, (2012) found a variation in

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reporting practices across industries. For example. The level of reporting seen greater in
commercial banks than the Aviation industry. Chaudhry, Mughal and Zafar (2014)
investigated O&G companies of Pakistan and found that companies care about their
reputation; hence disclose to build their green image. Hence, there is a need for examining
other industries’ reporting practices. In addition, as extractive industries in developing
nations have had a negative impact on the natural environment and the lives of human beings;
stakeholders’ demand for information has increased, and there is a need to comprehend O&G
companies’ initiatives to protect the environment. The study of Kemp and Vinke (2012)
provides useful insights of a country to expand understanding on reporting practices of a
developing country. Using the same country sample, our study contributes to the literature by
focusing on the environmental aspects of corporate responsibility reporting in an
environmentally sensitive industry. In addition, the study investigates longitudinal (2010-
2014) rather than just relying on a single year. Therefore, the current study aims to
investigate the current state of ER in the Oil and Gas industry in Pakistan.

Method - Content Analysis

Many previous studies (see (Dutta and Bose, 2007; Gray et al., 2001; Hackston and Milne,
1996; Hassan et al., 2013) have used content analysis technique to investigate reporting
practices of companies. This study also employs a content analysis approach to examine the
extent of ER in annual reports and corporate website. Content analysis is “a research
technique for making replicable and valid inferences from data according to their context”
(Krippendorff, 2012). This involves classifying the object under investigation (ER) into
categories, on the basis of pre-defined criteria. This method has been used extensively to
examine the non-financial reporting in developing countries due to its nature, which assists to
observe the trend of companies reporting practices. Therefore, the content analysis as a
research method deemed suitable for investigating the ER of O&G companies.
This method requires a few important steps to implement its process; (1) the selection of
sources (2) the selection of a unit of analysis and (3) theme identification.
Sources of information: CR, stand-alone reports and company websites were selected as
sources of ER information. As a result, 60 CR reports, 9 stand-alone reports and 12 corporate
websites were investigated to determine O&G companies’ ER reporting practices. The
company reports were obtained from the company’s official website, usually in the public
relations and archive sections. Previous studies, when using the content analysis approach,

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relied on a single source (annual reports) of data collection; however, our sample includes
different sources of reporting: corporate reports (CR) and the website, and longitudinal period
in their current method. Wilmshurst and Frost, (2000) argue that companies use additional
mediums of reporting, such as CR, stand-alone report and websites. A longitudinal approach
was taken in order to analyse differences in reporting practices and the impact of pressures
from stakeholders on companies’ ER over a 5 year period between 2010 and 2014. This
period was interesting in Pakistan’s business context because SECP approved CSR Voluntary
Guidelines in 2009 and a comprehensively updated version was launched in 2013 that also
guides companies to report on environmental matters. Therefore, this period was selected to
assess the impact of voluntary guidelines on the volume of ER in O&G companies in
Pakistan.

Unit of Analysis: The study focuses on two types of measures: a) to measure what is
disclosed and b) to measure the level of ER based on the number of words disclosed on
environmental related information. Previous studies on CSR reporting have experimented
with different units, mainly, words, sentences and pages. There have been debates around
what works best to investigate such a complex phenomenon because companies not only
make narrative disclosures but also use images and infographics. The pages (devoted to ER in
an annual report) is used as a unit of analysis, based on work of (Campbell, 2004; Deegan &
Gordon, 1996; Gao, Heravi, & Xiao, 2005; Hassan & Kouhy, 2013) because a page provides
a significant amount of detailed description than number of words and sentences. In addition,
measurement based on number of sentences is incomplete because they do not consider
pictorial reporting and the majority of the companies’ reports do contain images of their
environmental responsibility. Nevertheless, for corporate websites, we counted the number
of words written on environmental issues to determine the companies reporting practices as
number web pages does not always consist of pages.

Themes and categories: To identify the themes from the sources (annual reports and the
website), this study followed the SECP’s guidelines that issued voluntary guidelines namely,
Companies (corporate social responsibility) General Order in 2009 and CSR Guidelines in
2013. The purpose of these guidelines was to encourage responsible business practices in
Pakistan. In this regards, Javaid Lone, Ali, & Khan, (2016, p. 786) state that “these guidelines
induce organizations to have a CSR policy endorsed by the board of directors that reflects
their understanding and commitment toward CSR reporting”. The guidelines outlines key

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environmental issues that companies need to focus in the Pakistani context such as energy
conservation, environmental protection, water management and health and safety. Such
issues have increasing prominence in Pakistan due to their negative impact on the
environment, species and human life. As such, it is important to assess the extent to which
Pakistani O&G companies actively engaged with these issues.

After an appropriate comprehension of the content analysis approach by exploring past

studies that utilised this method, we initiated the full content analysis process, which
prompted a scan of each report issued by the selected firms. This was undertaken with great
consideration in order to enable the cautious decision to be taken regarding whether a specific
item is relevant to any of the environmental categories outlined by SECP. Consequently, this
reduced the subjectivity in determining relevant items. In addition, the context of the text was
thoroughly read to confirm the relevance of information to environmental aspects. After
reading the text from the annual report the researcher assigned a label indicating the category
considered in the study and counted for content analysis. If an indicator was available in the
selected source, that item was considered as being ‘disclosed’ and given a value of 1. If no
information was available, the item was considered as being ‘non-disclosure’ and given a
value of 0. After analysing the content of a particular year was completed, the same
procedures were employed for the other years in the sample. This procedure was repeated for
every incidence of CSRR for each company – a thorough reading and then coding as per the
SECP indicators. Each indicator and source were investigated carefully to reduce instances of
error. In order to reduce instances of inconsistency and/or omission while undertaking
content analysis, the double review was performed in order to ensure the reliability of the
content analysis process (Krippendorff, 1980). Two researchers independently analysed the
reporting mediums to test the instrument and identify discrepancies. This then allowed for the
comparison of the results of two coders, the results of both coders were compared, and few
minor discrepancies were noted, such as slight variation in the theme identified, however, the
majority of the results were identical and this indicates that the results are replicable.
The sample includes only Pakistan O&G companies, listed on the Karachi Stock Exchange,
due to their high level of potential negative environmental impact. Three further criteria were
used to select the sample group, following Alazzani & Wan-Hussin’s (2013) study: 1)
companies within O&G sector of Pakistan (total 13 O&G companies operate in Pakistan). 2)
companies who have made a commitment to consider the environment (all companies are
encouraged to include environment information by the SECP). 3) availability of their reports

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(only one firm (Sui Southern Gas Co Ltd ) was excluded due the missing annual reports and
12 firms were included in the sample (see Table 2). As a result, out of 13 companies in
Pakistan’s O&G industry, 12 were selected for analysis (see table 2), with one being excluded
due to lack of availability of reports.
Table 2: Oil and Gas companies in Pakistan

# Name of Companies Assets Business Nature

(Rs, in Million)
1 Attock Refinery (ATR) 64,634 Crude oil refining
2 Burshane LPG (BPL) 792 Storing and marketing of LPG
3 Byco Petroleum (BYCO) 43,908 Oil refinery
4 Mari Petroleum (MARI) 34,192 Oil and Gas production
5 National Refinery (NR) 55,676 Oil refinery
6 Oil & Gas Development (OGD) 414,011 Drilling, refining and retailing
7 Pakistan Oilfields (PO) 53,638 Oil exploration
8 Pakistan Petroleum (PP) 212,901 Exploration onshore and offshore
9 Pakistan Refinery (PR) 27,412 Production and retailing
10 Pakistan State Oil (PSO) 281,308 Distribution of petroleum products
11 Shell Pakistan (SP) 40,596 Retailing oil products
12 Sui Northern Gas (SNG) 211,777 The gas production and serving

Findings
Oil and Gas (O&G) are important resources and many developing countries are rich in these
natural resources (Alazzani and Wan-Hussin, 2013). Table 2 provides descriptive statistics of
the volume of ER in each year. There has been a significant increase in the volume of ER in
the O&G sector of Pakistan since SECP announced (2009 and 2013) voluntary guidelines.

Table 2: Descriptive analysis of ER of all selected companies

Stats 2010 2011 2012 2013 2014 % Change

Total number pages disclosed 220 262 265 301 316 -
Average pages disclosed 17 20 20 23 24 44%
Max pages disclosed 76 94 88 100 103 36%
Min pages disclosed 1 1 1 2 2 200%

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Figure 1 – Number of companies disclosed and not disclosed environmental aspects
disclosure

Figure 1 indicates that almost all the companies in the Pakistani O&G sector disclosed
environmental and health and safety information. Similar results have been found by (Kilian
& Hennigs, 2013), who argue that “companies in controversial industries are more active in
CSR communication” (p 2). This is often attributed to a number of incidents in the O&G
sector, forcing companies to change their CSRR practices. This is supported by Tilling & Tilt
(2010) who found that after the incident the sample companies issued more environmental
information in their annual reports than before the incidents. Their findings are also in line
with (Islam & Islam, 2011) study. It can be argued that disclosing environmental information
gives them environmental legitimacy because disclosure is often used as a tool to build a
better corporate reputation (Branco & Rodrigues, 2007; Dragomir, 2010; Friedman & Miles,
2001; Kilian & Hennigs, 2013). Their study’s findings are in line with this study in their
assertion that large O&G companies disclosed more CSR information than their smaller
counterparts.

Quantity of Disclosure
Table 2 the findings show that the volume of general ER had increased during the period
2010-2014. All selected companies engaged in ER in various sources. The reporting trend
rises gradually each year, consistent with the finding of (Belal 2000; Imam 1999; Ullah et al,
2014). This trend may be as a result of increasing pressure from stakeholder on companies, as
ER becomes an important trend within developing countries. Similarly, the government
pressurising companies to be more transparent (Sari & Tjen, 2016). For example, the
introduction of the Companies (corporate social responsibility) general order in 2009 and
2013 by the Securities and Exchange Commission Pakistan (SECP) may have encouraged
companies to disclose information regarding “environmental protection” practices. This is

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also noted in Adefemi (2018) study that securities and exchange commission’s regulations
had an impact on increased disclosure practices of Nigerian firms. According to previous
studies, (Sari & Tjen, 2016)companies perform environmental disclosures as a legitimizing
tool and poor environmental performance leads to a higher level of reporting on
environmental aspects.
Table 2: Companies’ environmental reporting quantity
Oil and Gas Companies Number of pages in reports Website
2010 2011 2012 2013 2014 (Words)
Attock Petroleum 1.5 1.5 1.5 1.5 2 275
Attock Refinery 76 94 88 100 103 321
Byco Petroleum Pakistan Ltd 1 1 1 1.5 1.5 193
Mari Petroleum Company Limited 2 2 2 2.5 3.5 86
National Refinery 64 76 73 87 91 165
Oil and Gas Development Company 2.5 3 3 3 2.5 325
Pakistan Oilfields 4.5 5 5.5 6 6.5 242
Pakistan Petroleum 3 3 4 5 6 193
Pakistan State Oil 0.5 0.5 1.5 3 3.5 208
Sui Northern Gas Pipelines Limited 1.5 1.5 1.5 2 2 476
Sui Southern Gas Company 1 1 1.5 2 2 381
BHP Billiton (Pvt) Ltd. 30 34 37 46 48 103
Shell 32 39 45 41 44 847

However, despite an increase in the trend, ER is underdeveloped in Pakistan’s O&G industry

in comparison to developed countries. This is consistent with (Nik Nazli Nik Ahmad &
Haraf, 2013; Djajadikerta & Trireksani, 2012; Dutta & Bose, 2008; Othman & Ameer, 2010;
Qi et al., 2012; M. Ullah, Yakub, Hossain, Ullah, & Musharof, 2013), our result suggests that
the level of ER remains low.
It can be expected that companies tend to disclose on their websites with the intent to engage
with stakeholders. However, the level of reporting is at a low level, and lacking in detail. In
the majority of instances, ER related information found to be in a specified section on the
website - namely “Corporate social responsibility”, “Sustainability” and “Health and safety”.
Table 3 – Reporting guidelines and report type

Reporting Guidelines followed Number of Companies

Yes 4
No 9
Report type
Financial annual (combined reports) 10
Stand-alone report (separate report on ER) 3

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This indicates that using a guideline such as GRI as well as stand-alone reports can enhance
companies’ level of reporting. In addition, these guidelines can also show companies,
particularly in developing country, a way forward to make the better stakeholder engagement.
The volume of reporting was counted from two sources namely, annual financial reports and
stand-alone reports. When companies issue a stand-alone report, the volume of reporting
increases significantly. In the case of oil and gas companies, 4 companies were found to be
using reporting guidelines and issuing stand-alone reports as well. Studies suggest that oil and
gas companies have a greater impact on the environment and society and for companies in
the oil and gas sector maintaining legitimacy is essential (Alazzani & Wan-Hussin, 2013;
Berthelot, Coulmont, & Thibault, 2013; Eljayash et al., 2012; Kirat, 2015). It can be argued
that in order to gain stakeholder’s confidence, companies in this sector dedicate attention to
their reporting strategies (Sari & Tjen, 2016). One of those strategies is to issue a stand-alone
report to increase the volume of disclosure and other tactics involve using international
guidelines, such as GRI, to provide a detailed set of information on their CSR performance.
This is in line with findings of Alazzani and Wan-Hussin's (2013) study, which found that
companies made a reasonable effort to disclose in accordance with the GRI guidelines, as
these guidelines provide a robust and comprehensive tool for reporting. In addition, they
argue that the voluntary adoption of GRI by O&G firms enhances transparency, credibility
and comparability. The companies in this environmentally sensitive sector use proactive
strategies to gain organisational legitimacy because in the past a few environmental disasters
have been tied directly to the oil and gas sector, which makes it more vulnerable to threats to
its legitimacy. Hence, companies use various reporting practices to make a positive impact on
their stakeholders.

Discussion
The study accounts that despite not mandatory, most Pakistani O&G companies report some
environmental information. The state of ER in Pakistan’s O&G industry is not very different
than any other developing countries, as the majority of companies provided low ER in their
various sources of communication such as annual reports and websites. In addition, even
though, the most common medium that is being used to present environmental related
information found to be CR, the level of reporting is higher in the stand-alone report and
using guidelines significantly enhances companies’ disclosure. For example, NRL provided a
sustainability report for the first time in 2014. This may have been prompted by the company

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winning an annual award for the best report, organised by ACCA-WWF in Pakistan. Such
initiatives encourage companies to improve reporting practices, particularly winning such
competition provides the company with a recognition among various stakeholders among the
society (Sari & Tjen, 2016).
Even though, the SECP notification (2009) states that “obligations under the law- (1) Every
company shall provide descriptive as well as monetary disclosures of the Corporate Social
Responsibility activities undertaken by it during each financial year (p. 1)” however the
contents and statements about reported aspects of environmental activities tend to be general
and narrative, and particularly amongst local companies there was no evidence of monetary
disclosure about the environmental performance. In line with Cho, et al., (2007), the majority
of companies (10) included only descriptive information, explaining what they do in relation
to the adoption of policy, goals and objectives to protect environment, rather than providing
meaningful information about what, how and why such activities were performed and any
associated expenses. This supports previous studies (see Fernando, 2014; Imam, 1999; Kemp,
L. J., and Vinke, 2012) that found environmental disclosure to be general and descriptive in
nature.

Managerial implication
We argue that Pakistan’s O&G companies need to report on environmental performance
voluntarily to inform various stakeholders. Company management has a huge responsibility
to be able to engage a wider array of stakeholders and this study shows that ER is a powerful
tool for management to consider. Since, it is believed that ER not only provides stakeholders
with the ability to make the right decisions but also help companies to compare its
environmental performance. The results of this study have potential implications for
managers who may consider companies’ ER as being an indication of companies’
environmental performance. In addition, the results are useful as an evidence to convince
companies’ management to be transparent and engaged with stakeholders as it provides a
better reputation and gains stakeholder’s confidence. The results may also be used by the
management for focusing on reporting guidelines and stock exchange regulations to
disseminate environment-related information robustly. Du and Vieira (2012) suggest a
solution to this question: Despite a wide variety of CSR initiatives and prevalence of cross-
sector partnerships, oil companies need to abandon the ‘‘CSR as public relations’’ mentality,
and instead work proactively in minimizing the negative externalities of their business

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operations, and take a long-term approach to CSR by investing substantially in renewable
energies and going beyond simple financial donations in their cross-sector partnerships (p.
425).

Conclusion
This study investigated ER in O&G industry of a developing country where environmental
issues are increasing, namely, Pakistan. The findings of the current study suggest an
increasing trend in CSRR among O&G firms in Pakistan; however, the level of ER remains
low as is the case in many other developing countries. The main disclosure item observed
was “environmental protection” and “health and safety” and it can be argued that companies
in O&G sector are more active in disseminating ER related information and this can be
attributed to claim made by the legitimacy theory and a number of incidents in the O&G
sector, forcing companies to change their CSRR practices. The study has many limitations.
Focusing only on O&G companies, the results cannot be generalised to companies in other
industries. In addition, it is possible that errors or omissions of relevant information may
have occurred during scoring the disclosure, despite taking all measures to avoid this. Future
researchers may consider using a larger sample, including companies in other sectors, or
drawing comparisons with companies in developed and other developing countries.
Moreover, an in-depth study investigating the perceptions of managers dealing with
environmental activities and its reporting would be useful.

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