Douglas Hileman (FSA, CRMA, CPEA, P.E.) has over four decades of experience in Sustainability compliance, risk, reporting and audit. He is an author of COSO’s groundbreaking document “Achieving Effective Internal Controls over Sustainability Reporting (ICSR)”. He was the senior environmental management & auditing specialist on the Volkswagen Monitor Team and worked at a Big 4 firm for six years. He has led his boutique consultancy for 16 years, working on climate-related programs and GHG emissions reporting; Sustainability policies, reporting and audits; and other specialty needs. He has been active in the Institute of Internal Auditors for over a decade, contributing to supplemental guidance. He leads a Governance & Controls work group for the Institute of Management Accountants. Mr. Hileman submitted detailed comments to the SEC on the proposed climate disclosure rule; in the final rule (released March 6, 2024), there are 42 references to his comments. See www.douglashileman.com.