The 2024 Financial Reporting Excellence (FiRe) Award
Sponsored by Jim McFie Chief Judge of the Fire Award and a Fellow of ICPAK

Winner of the 2024 Financial Reporting Excellence (FiRe) Award.
At a Gala Dinner at the Safari Park Hotel on Friday, December 6th, 2024, the contestants and their supporters gathered to find out if they would win the 2024 Financial Reporting Excellence (FiRe) Award.
2024’s competition was the 23rd annual race to see which entity has the best annual report. The original competition was started by ICPAK, but now there are five promoters: ICPAK, the Capital Markets Authority (CMA), the Nairobi Securities Exchange, the Public Sector Accounting Standards Board (PSASB), and the Retirement Benefits Authority (RBA). The dinner was the culmination of the judging process by a large group of members of ICPAK and experts in sustainability and governance reporting.
The 2024 competition was launched on Tuesday, 27th August 2024, by the ICPAK CEO, CPA Dr. Grace Kamau. She pointed out that the theme of the 2024 Award was: “Championing for effective sustainability reporting through technology and innovation to enhance transparency.” CPA Dr Grace went on to outline some of the Sustainability Reporting Challenges that see companies often miss the mark: in today’s world, corporate accountability and environmental consciousness are paramount: documenting a company’s sustainability efforts is no longer just a trend but a strategic necessity. In the 2024 competition, a new category, Environmental, Social, and Governance (ESG) Global Reporting Initiative (GRI) disclosure, was added to the 24 categories contested in previous years. Since November 2022, all the companies listed on the Nairobi Securities Exchange have to report publicly on their ESG performance at least annually: this must be done in their annual or integrated report; alternatively, they can choose to publish a separate ESG/sustainability report.
To help reduce uncertainties on which framework or standards to apply, the NSE recommends the adoption of the GRI Standards as the common framework for ESG reporting by listed companies in Kenya. According to a 2020 Global Survey on Sustainability Reporting conducted by KPMG, the GRI Standards are the most widely used framework for sustainability reporting. Furthermore, listed companies on the NSE that already report, prior to 2022, on ESG performance have chosen the GRI standards as their preferred framework for ESG Reporting.

Winner of the 2024 Financial Reporting Excellence (FiRe) Award.
112 private and 1,020 public sector entities participated in the 2024 competition. The private sector entities were judged on their International Financial Reporting Standards (IFRSs: there is a category for entities which use the IFRS for SMEs) and Companies Act (or relevant regulatory requirements) compliance; the clarity of the notes (especially on accounting policies); the clarity and breadth of the Board and Management reports; the presentation of performance data; the quality of the layout and visual appearance of the report; and the Corporate Governance and Sustainability reporting.
For the public sector entities, International Public Sector Accounting Standards (IPSASs) substitute IFRSs. A percentage is also given on the audit report – its compliance with International Standards on Auditing (ISAs) and the Companies Act or other relevant legislation for private sector entities or International Standards of Supreme Audit Institutions (ISSAIs) for public sector entities.
The overall winner was the NCBA Group PLC, which was also the best bank. However, NCBA did not have the highest score for IFRS compliance – that was taken by WPP-Scangroup PLC. CRDB Bank PLC from Tanzania was placed second in the banking category and was the best entry from Tanzania. In the new ESG GRI category, Absa Bank Kenya PLC was top, Bamburi Cement PLC was the first runner-up, and Equity Group Holdings PLC was the second runner up. For State Corporations and Semi-Autonomous Government Agencies (SAGAs) reporting using IFRSs the winner was Kenya Electricity Generating Company (KenGen) PLC; of those reporting using IPSASs Accrual Basis, the winner was the Kenya Tourism Board. The full list of winners is given below this article.
One major area of non-compliance was where entities claimed that their reports were Integrated Reports when that was not the case. The IFRS Foundation assumed responsibility for the Integrated Reporting Framework in August 2022 when the Value Reporting Foundation (VRF) was consolidated into the IFRS Foundation. The IASB and ISSB are jointly responsible for the Integrated Reporting Framework. The Framework and the requirements in IFRS S1, General Requirements for Disclosure of Sustainability-related Financial Information, and IFRS S2, Climate-related Disclosures, are complementary tools for investor-focused communications.
Together, the Integrated Reporting Framework and IFRS S1 and S2 provide a more complete picture of how value is created over time while meeting investor needs for comparable, consistent and reliable information. Integrated reporting means a process that: (i) brings together the material information about an organization’s strategy, governance, performance and prospects in such a way that reflects the commercial, social and environmental context within which it operates; (ii) provides a clear and concise representation of how an organization demonstrates stewardship and how it creates value, now and in the future; and (iii) combines the most material elements of information currently reported in separate reporting strands (financial, management guidelines, governance and remuneration, and sustainability) into a coherent whole.
Paragraph 6.1.5 of the Kenya CMA’s Code of corporate governance practices states: The Board (of Directors) shall continually work towards the introduction of integrated reporting, a process that brings together the material information about an organization’s strategy, governance, performance and prospects in such a way that reflects its commercial, social and environmental context within which it operates. The International Integrating Reporting Council’s (IIRC’s) long-term vision is a world in which integrated thinking is embedded within mainstream business practice in the public and private sectors, facilitated by Integrated Reporting (<IR>) as the corporate reporting norm. The IIRC defines an integrated report as a concise communication about how an organization’s strategy, governance, performance and prospects, in the context of its external environment, lead to the creation, preservation or erosion of value over the short, medium and long term. Unfortunately, this definition is not precise. What is clearer is the <IR> Framework, where the capitals that any entity uses are stated: the financial, manufactured, intellectual, human, social and relationship, and natural capitals.
Organizations may categorize the capitals differently: e.g. relationships with external stakeholders and the intangibles associated with brand and reputation (part of social and relationship capital), might be considered to be separate, a part of others or cutting across a number of individual capitals. Regardless of how an organization categorizes the capitals for its own purposes, the financial, manufactured, intellectual, human, social and relationship, and natural categories are to be used as a guideline to ensure the organization does not overlook a capital that it uses or affects. Any person preparing an integrated report must report on the different capitals required by the entity to function. An important point that was emphasized by CPA Anthony Murage, one of the Chief Judges, is that an integrated report should be concise: a number are excessively long.
Almost all the Audit Reports complied with ISA 700, Forming an Opinion and Reporting on Financial Statements. But auditors of companies must remember that the Companies Act also lays down requirements for audit reports. Section 727(3) states: The auditor shall clearly state in the auditor’s report whether, in the auditor´s opinion, the annual financial statements (a) give a true and fair view of (i) in the case of a balance sheet—of the financial position of the company as at the end of the relevant financial year; (ii) in the case of a profit and loss account—of the profit or loss of the company for the financial year. Some auditors state “in our opinion, the financial statements present fairly in all material respects the financial position.” Some judges will let that small point be correct but the strict judges (whose word is final) will deduct a mark.
Paragraph 78 of IAS 1 Presentation of Financial Statements states that: The disclosures vary for each line item, for example: (e) equity capital and reserves are disaggregated into various classes, such as paid-in capital, share premium and reserves. Section 3 of our Companies Act states: Undistributable reserves means those reserves of the company that comprise—(a) its share premium account; (b) its capital redemption reserve; (c) the amount by which its accumulated, unrealized profits exceed its accumulated, unrealized losses; and (d) any other reserve that the company is prohibited from distributing by its articles. These line items need to be stated clearly and with precision.
The nest paragraph of IAS 1, 79, states: An entity shall disclose, either in the statement of financial position or changes in equity, or in the notes: (a) for each class of share capital: (i) the number of shares authorised; (ii) the number issued and fully paid, and issued but not fully paid; (iii) the par value per share, or that the shares have no par value; (iv) a reconciliation of the number of shares outstanding at the beginning and at the end of the period; (v) the rights, preferences and restrictions attaching to that class including restrictions on the distribution of dividends and the repayment of capital; (vi) shares in the entity held by the entity or by its subsidiaries or associates; and (vii) shares reserved for issue under options and contracts for the sale of shares, including terms and amounts; and (b) a description of the nature and purpose of each reserve within equity. Some companies did not comply with this very basic requirement.
Paragraph 27 of IAS 1 states: An entity shall prepare its financial statements, except for cash flow information, using the accrual basis of accounting. Note that the entity does not need to disclose that it has done so.
Paragraph 25 of IAS 1 does have a disclosure requirement, but only in certain circumstances:it states that when preparing financial statements, management shall make an assessment of an entity’s ability to continue as a going concern. An entity shall prepare financial statements on a going concern basis unless management either intends to liquidate the entity or to cease trading or has no realistic alternative but to do so. When management is aware, in making its assessment, of material uncertainties related to events or conditions that may cast significant doubt upon the entity’s ability to continue as a going concern, the entity shall disclose those uncertainties. When an entity does not prepare financial statements on a going concern basis, it shall disclose that fact, together with the basis on which it prepared the financial statements and the reason why the entity is not regarded as a going concern. I stress the word disclose because one must distinguish between what one must do (as in paragraph 27) and what one must disclose (as in paragraph 25).
I cannot address comprehensively all the factors that enabled some entities to win and others to be left behind. But all preparers need to go over the basics with care and skill: the IFRSs, the IPSASs, and the regulations related to their type of entity. That will enable the entity to win the 2025 edition of the FiRe Award.