more than 140 healthcare facilities including over 80 hospitals spanning across
10 countries, including Malaysia, Singapore, Türkiye, and India, and is listed on both Bursa Malaysia and the Singapore Exchange. We speak to Yasemin Tecmen Stubbe, IHH Healthcare’s Group Chief Sustainability Officer, to learn more about the group’s sustainability journey.
She shared two key takeaways: (1) to ensure long-term progress, secure
buy-in across your organisation, not just from your board or sustainability
division, and (2) to identify your end goal and work backwards, one basecamp
at a time. Read more to find out how Yasemin embodies this at IHH Healthcare.
The author is a member of the ACSR Implementation Working Group. These articles are published to provide thought leadership and share experiences. All views expressed in this paper are solely those of the authors and do not necessarily reflect the position of the Securities Commission Malaysia (SC). Any errors are the responsibility of the authors alone.
IHH Healthcare aspires to be the world’s most trusted healthcare services network; but great visions come with great responsibility. Yasemin Tecmen Stubbe, Group Chief Sustainability Officer, describes the sustainability journey as “climbing Everest. You can’t reach the summit overnight. You need preparation, teamwork, adaptability, the right gear, and endurance to keep moving upwards despite the obstacles. Along the way, there are base camps: moments of progress where you pause, reflect, and prepare for the next push. There are storms to weather, detours to take, and sometimes, you have to descend a little to move forward safely.”
“But the higher you climb, the clearer the view of what's at stake, and of the impact each decision has. And when organisations work together, supporting each other like climbers roped to the same mission, the summit becomes not just possible, but a reality”, she added.
As the landscape of reporting requirements evolves, IHH Healthcare adapts: the group was reporting against Global Reporting Initiative (GRI) Standards until 2024, consistent with most entities in ASEAN. However, they will begin reporting against the ISSB Standards, starting with climate-related disclosures in accordance with the IFRS S1 and S2 , to ensure compliance with the National Sustainability Reporting Framework (NSRF). IHH Healthcare is a Group 1 listed entity and will be required to submit their climate-related disclosures for financial year ending 2025 and other (non-climate) sustainability-related disclosures for financial year ending 2027.
“For those of us responsible for preparing reports, it is no small task. The complexity of IFRS S1 and S2 is daunting with over 300 clauses and 90 pages,” Yasemin says. “But it is also a powerful catalyst. Meeting sustainability disclosure requirements is a non-negotiable in boardrooms and it forces the hands of companies to do the right thing.
Fostering Cultural Change for Group-Wide Sustainability
55% of Malaysian firms cited regulatory compliance and optimising costs as the primary driver for transitioning. Yasemin noted the importance of shifting mindsets from viewing reporting as a regulatory burden, to reporting as an opportunity for advancing businesses and driving systemic change.
Yasemin is a strong believer that a shared commitment to sustainability begins with a shared understanding, which is why education and continuous learning underpins IHH Healthcare’s approach to sustainability. “For us, it’s about bringing 70,000 employees along on this sustainability journey,” Yasemin explained. In 2023, more than 90% of IHH Healthcare’s employees participated in group-wide sustainability awareness training, reflecting a growing culture of collective ownership and engagement across the organisation.
“Come up with a narrative that matters to the industry you’re in”, she emphasised. “For example, we took the narrative of the Hippocratic Oath of “do no harm” and developed our Care for Good aspiration for the Patients, People, Public, and Planet (4Ps)”. In aligning with the ESG framework, the Planet pillar corresponds to Environment (E), while Patients, People, and Public correspond to Social (S), all underpinned with a strong Governance(G) structure. Building this group-wide culture of sustainability, coupled with strong endorsement from the Board and Senior Management, enables the tactical execution necessary to achieve their sustainability goals.
A Systematic Approach to Goal-Setting, Measurement, and Review
Over 80% of non-financial targets in the IHH Healthcare’s Balanced Scorecard are linked to sustainability. IHH Healthcare’s sustainability goals under their 4Ps framework are performance-linked, time-bound, measurable, and accountable. Every quarter, the group monitors, measures, and tracks their progress against the set goals.
IHH Healthcare’s commitment to sustainability is achieved through a systematic approach to goal-setting, measurement, review and remuneration. Yasemin described the Group’s RACI (Responsible, Accountable, Consulted, Informed) Framework, where each of the goals is aligned to the Framework so what each person needs to do is clear.
“We track and monitor our sustainability progress through dashboards and manual trackers”, Yasemin shared. This model ensures accountability, which further translates into the Group’s governance processes. At quarterly Sustainability Committee meetings, each goal is reviewed according to the material matter and metric, history, and progress status. Further discussions are held on any matter at risk to identify mitigation strategies.
Forward-Looking Approach to IFRS S1 and S2 Reporting
Yasemin acknowledged that it can be overwhelming to take stock of the various requirements. One approach they have taken is to identify what their reporting requirements are, identify gaps, and then work backwards to develop an action plan. For example, by 2027, IHH Healthcare will have to fully adopt IFRS S1 and IFRS S2, fully disclose Scope 3 emissions, and provide group-wide assurance for Scope 1 and Scope 2 greenhouse gas (GHG) emissions.
Cognisant that assurance is coming at a group level, they have adopted a methodical approach. In 2022 and 2023, they conducted Scope 1 and Scope 2 GHG emissions limited assurance for some of their hospitals based in Singapore and Malaysia respectively. This provides the Group with breathing room and iterative learning, while ensuring group-wide readiness by 2027.
Yasemin shared the following resources for companies to embark on IFRS S1 and IFRS S2 reporting:
Supply Chain Transformation: Scope 3 as the Lion’s Share of Healthcare Emissions
The healthcare industry is responsible for up to 5% of global emissions; of that, 71% of the Scope 3 emissions derived from its supply chain. To put this into perspective, the healthcare sector contributes more greenhouse gas emissions than both the entire aviation and shipping sectors combined. This creates a uniquely challenging position for the healthcare industry vis-à-vis emission reductions, whereby emissions must be largely managed across their supply chain.
Alluding to the climbing Everest analogy, Yasemin emphasised addressing one base camp at a time. In 2024, IHH Healthcare completed a foundational step of supply chain engagement by publishing its Global Responsible Sourcing Policy, which sets clear expectations for vendors to meet and adopt climate-conscious and social-conscious practices. Next, the Group will introduce sustainability-related scoring into the vendor selection process.
Looking ahead, the Group’s goal is to work more closely with vendors committed to sustainable practices which will also help reduce the risks associated with climate disruptions across their supply chain.
Looking Ahead
Yasemin recounted the wins that IHH Healthcare has made on their sustainability journey:, and IHH is already underway to set their 2030 sustainability goals, expanding their Scope 3 emissions reporting categories, set science-based targets, and preparing for IFRS S2 disclosures this year.
At the end of the day, Yasemin reminded us of her raison d'être, “I want to be able to look my daughters in the eye and tell them I did my best to leave them a better, healthier world”. She sees sustainability as a chance to take a step back, reflect, prioritise, and figure out the best way forward and make a meaningful difference, for both her company and society.
- NSRF - Additional transition reliefs commencing from the first annual reporting period of the respective applicable entities where Group 1 and Group 2 scoped-in entities are permissible to disclose information on only climate-related risks and opportunities (in accordance with IFRS S2), for 2 years.
- Bank Negara Malaysia. Green Gauge: Tracking Firms’ Strides Towards Environmental Sustainability. Published 2024. Accessed 29 April 2025. https://www.bnm.gov.my/documents/20124/15223059/qb24q2_en_box1.pdf
- Healthcare Without Harm and Arup. Health Care’s Climate Footprint Report. Published September 23, 2019. Accessed April 28, 2025. https://global.noharm.org/resources/health-care-climate-footprint-report.
- World Economic Forum. Here's how healthcare can reduce its carbon footprint. Published October 24, 2022. Accessed June 13, 2025. https://www.weforum.org/stories/2022/10/cop27-how-healthcare-can-reduce-carbon-footprint/
