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A Study on the Role and Due Diligence Methods of Corporate Investigators in Verifying ESG-Washing Risks

  • Industry Promotion Research
  • Abbr : IPR
  • 2026, 11(3), pp.281~292
  • DOI : 10.21186/IPR.2026.11.3.281
  • Publisher : Industrial Promotion Institute
  • Research Area : Interdisciplinary Studies > Interdisciplinary Research
  • Received : July 1, 2026
  • Accepted : July 17, 2026
  • Published : July 31, 2026

Sohn Jong-Wook 1 Jeong Eun-Sun 2 Yeom Ji-Hye 3 Yeom Keon-Ryeong 3

1㈜바핀파트너스
2국제교류전략연구센터(주)
3가톨릭대학교

Accredited

ABSTRACT

As ESG (Environmental, Social, and Governance) solidifies its position as a core norm and a stringent regulation in the global business environment, ESG-washing - the act of falsely packaging or downplaying a company's non-financial performance - has emerged as a critical risk. However, the current third-party ESG verification system, primarily led by large accounting firms and consulting agencies, remains confined to desk audits and checklist evaluations heavily reliant on data provided by the audited entities. Consequently, this system exhibits structural limitations in uncovering substantive on-site truths, such as concealed environmental pollution or labor exploitation within subcontracting networks. To address these blind spots within the existing ESG verification ecosystem, this study aims to establish the necessity of introducing and utilizing a 'Corporate Investigator' system as a highly effective alternative. To this end, the study analyzes the current utilization of corporate investigators in advanced overseas jurisdictions - such as the United States (the SEC Whistleblower Program), Japan(Third-Party Committees), and Europe(Corporate Sustainability Due Diligence Directives) - alongside specific fieldwork techniques, including OSINT, HUMINT, and undercover investigations. Based on these findings, this study proposes a Korean ESG investigative outsourcing model tailored to domestic conditions. This model establishes 'Triangular Governance' - connecting the client company, law firms or ESG evaluation agencies, and corporate investigation firms - as its standard structure to strictly ensure the objectivity of the investigation and the legality of the information-gathering process.

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