FTSE Russell Names 15 Source Documents. Your One Report Is One of Them.

With two weeks left before 30 September 2026, sustainability teams across the SET are doing the same thing: polishing the English edition of the 56-1 One Report. It is the right instinct, and it is an incomplete one.

Because FTSE Russell has published, in plain sight, the list of what it actually reads — and the annual report is one line on a list of fifteen. The other fourteen are where the unworked points are.

The list FTSE Russell publishes — and almost nobody works

The source is FTSE Russell’s own ESG Scores and Indices FAQ, version 1.5, December 2025 — the current edition. Section 1.23 asks “What sources of information do you assess?” and answers with a specific, enumerated list rather than a vague gesture at “public disclosure”:

Read that list again with a Thai issuer in mind. Five of the fifteen are standalone policy documents — the Code of Conduct, the Articles of Association, the Environment Policy Statement, the Human Rights Policy, the Supplier Code of Conduct or procurement policy. Two more are meeting papers: the AGM notice and the AGM results. None of those live inside the One Report. All of them are separate PDFs sitting in the investor-relations section of a corporate website.

The same FAQ is explicit that this is a one-way process. FTSE Russell does not send a questionnaire; it assesses what you have already published. There is no submission, no portal upload, no chance to hand over a document that was not public. If a policy is not on your website in a language the research process covers, it is not evidence.

One entry on that list carries a language rule of its own. CDP Climate Change is the fourteenth source, and FTSE Russell’s FAQ states that CDP data is material to a company’s ESG Score. CDP’s own 2026 scoring documentation is unambiguous about which responses it will mark: “In 2026, responses will be scored if they are submitted in English, Japanese, Chinese, Spanish and Portuguese” — followed by “Responses not submitted in these languages will not be eligible for scoring.” Thai is not on that list either. A Thai-language CDP response is not scored low; it is not scored at all, and the gap propagates into a source FTSE Russell reads.

Fifteen doors, and most Thai issuers open three

In our audit work across SET-listed disclosure, the pattern is consistent enough to be predictable. The report-class documents — the One Report, the sustainability report, the ESG data tables — usually do have an English edition at the SET50 tier, and thin out quickly below it. The policy-class documents are a different story: they are frequently Thai-only, even at companies with a polished English annual report.

That is not negligence. Nobody ever told those teams the Human Rights Policy was a scored document. It is filed as a compliance artefact, not an investor-facing one, so it never enters the translation budget.

Note what that table is and is not. It is what we observe engagement after engagement — it is ไม่ได้ a published statistic, because none exists. More on that below.

There is, however, one place where this has already been measured and published, and it is not us. The ASEAN Corporate Governance Scorecard scores whether a company’s AGM notice and circulars are fully translated into English and published on the same date as the local-language version. In the 2024 assessment, Thailand ranked first in ASEAN on mean score — and still saw its Disclosure and Transparency score fall from 23.40 to 21.72 out of 25, a decline the country report attributes in part to more companies not providing AGM minutes in English. The AGM papers on FTSE Russell’s list are the same documents. The points are already being counted somewhere.

Your Data Platform filing is not one of the fifteen

Here is the part that catches teams out. Many Thai companies have spent the last two cycles feeding the SET ESG Data Platform, reasonably assuming that is how the score gets built. It is not.

SET’s own published Q&A on the FTSE transition answers the question directly — and the question put to SET specifically listed the Data Platform as one of the candidate sources, alongside the 56-1, the SD Report and the website. SET’s answer names the annual report, the sustainability report, and information on the company’s website. The Data Platform does not appear in it. The Platform matters for SET’s own voluntary-application process — it is not a channel into the FTSE assessment.

And in the same document, SET answers the language question in its own voice:

The Thai verb is แนะนำ — recommends, not requires. That distinction matters, and we will hold to it: there is no rule anywhere in Thai law or SET regulation obliging a listed company to publish its sustainability disclosure in English. What there is, is the exchange telling its own listed companies what the assessment reads.

Why the policy documents punch above their weight

The reason a single untranslated policy matters more than it looks is that FTSE Russell scores at the indicator level, not the document level. The model runs three pillars and 14 themes, built from more than 300 indicators, of which roughly 125 apply to any given company depending on its exposure. Each indicator is assessed as evidenced or not evidenced from public disclosure.

A Human Rights Policy is not one indicator. It is the evidence base for a cluster of them. When that document exists only in Thai, the indicators it would have satisfied do not score badly — they simply find nothing, and a theme built largely on policy evidence can land near the floor while the underlying practice is genuinely strong. That gap between what you do and what is legible is the whole risk.

It matters more for the FTSE4Good Thailand Index, launched with SET in July 2026 and now running on ground rules revised to version 1.1 in September 2026. A company needs an ESG Score of 2.9 or above to be added; existing constituents need 2.4 or above to remain, and one at 2.3 or below is flagged at risk of deletion. As at 31 August 2026 the index carried 119 constituents drawn from the 250 in the FTSE SET All-Share — so fewer than half the eligible universe is inside, and the gap between 2.4 and 2.9 is the difference between defending a position and being unable to win one.

The honest limits of this argument

This argument gets overstated in the market, including by people selling translation. So here is where it stops.

There is no language rule in the binding documents. We read the FTSE4Good Index Series ground rules and the ESG data model methodology looking for one. Neither contains a language criterion. Index inclusion is a score threshold and nothing else. FTSE Russell never says it refuses to read Thai — FAQ §1.8 says provision is made for other languages, then lists six key ones: English, French, Spanish, German, Japanese and Chinese. Thai’s absence is meaningful, but it is an absence, not a prohibition.

And SET’s own published data cuts against the simple version of this story. In its FTSE FAQ, SET is asked directly whether Thailand’s weak environmental scores come from thin disclosure or from companies not delivering results. SET’s answer does not blame disclosure. It says that while the environmental pillar does score below the social and governance pillars, Thai environmental scores are higher than Malaysia and Taiwan and at the same level as companies in the FTSE Developed Index. If language were the dominant driver of Thai scores, that is not the pattern you would expect to see. Translation is a necessary condition for being read. It is not a sufficient condition for scoring well, and we would not sell it as one.

The academic literature does not support the strong claim either. We went looking for a peer-reviewed study linking disclosure language to ESG rating outcomes and could not find one. What the research does establish is adjacent: adopting English as an external reporting language is associated with increased foreign ownership, reduced information asymmetry and wider analyst following — but that work is European, and about financial annual reports rather than sustainability disclosure. The ESG rating-divergence literature attributes disagreement to measurement, scope and weighting, and does not identify language at all.

There is also no official count of how many SET-listed companies publish English sustainability disclosure, and none is derivable — the filing databases carry no language field. Anyone quoting you a market-wide percentage is estimating. We are not going to.

No public FTSE Russell ESG Score exists for any Thai company yet. The 2567 and 2568 rounds were a pilot, with results delivered privately. The first public release is targeted for December 2026. Nobody can show you a before-and-after score uplift from a translation project, ours included, because there is no public before. How the raters differ on all of this is worth knowing too.

What to publish before 30 September

The mechanics of the next ten weeks are fixed and worth planning against. Only disclosures published by 30 September can be considered for the December index review. Companies publishing between April and September can expect their review invitation by the first weekend of October, and that window is for correcting what was assessed — not for disclosing something new.

With two weeks left, a full translation programme is not the realistic move. Working the fifteen-document list is. Pull your investor-relations page, map it against §1.23, and find which of the five policy documents and two meeting papers have no English edition. Those are short documents — a code of conduct runs a handful of pages, not a hundred — and they are the highest-yield thing you can publish before the cut-off.

None of this replaces the work of having a real climate strategy and real numbers behind it. TGO-certified carbon data still has to exist before it can be disclosedและ the ISSB-aligned reporting obligation is arriving on its own timetable. But between now and the end of the month, the cheapest points on the table are sitting in documents you have already written, in a language the scoring process does not list.

Othello builds those English editions under an ISO 17100 Translate–Edit–Proofread workflow with ESG terminology locked across the document set, and clause-maps the English edition to the Thai original so the two say the same thing. That is the whole wedge: your Thai filing satisfies the SEC, and your English edition is what gets read.

Sources: FTSE Russell, ESG Scores and Indices FAQ v1.5 (December 2025), §§1.6, 1.8 and 1.23; FTSE4Good Index Series Ground Rules v6.1 (August 2026); FTSE4Good Thailand Index Series Ground Rules v1.1 (September 2026), §§6.3.2 and 6.3.6; FTSE4Good Thailand (F4GSET) factsheet, data as at 31 August 2026; The Stock Exchange of Thailand, Questions from Q&A sessions (questions 16 and 17) and the SET FTSE Russell ESG Scores FAQ 2569 (question 18) — Thai originals, translations ours; CDP, Full Corporate Scoring Introduction 2026 v1.2 (18 June 2026); ACMF/ADB, 2024 ACGS Country Reports and Assessments. Observations on the English availability of policy documents are Othello’s own from client engagements and are identified as such — no official count is published.