GRI G4 Guidelines Public Comment Period Survey Report

Transcription

1 GRI G4 Guidelines Public Comment Period Survey Report BACKGROUND Q1) Please provide the following personal details: Name : Stephen Hine address : stephen.hine@eiris.org Country of residence : UNITED KINGDOM Q2) I intend to provide feedback that reflects: Personal interest Interest of an organization: EIRIS Q3) Please select a stakeholder group that best describes your organization: Rating Agency [Q4: only asked if Q3 = Business or Trade ] Q4) Which industry you represent : Q5) Which best describes your involvement with sustainability reporting? Please tick all that apply. Reporter (prepare a report for my own organization) Consultant (report preparer on behalf of a third party) Assurance provider Report reader (read reports for the purpose of evaluating or analyzing organizations) Q6) Please indicate how many years of experience you have with sustainability reporting: No Experience Less than 1 year 1 5 years More than 5 years DRIVERS Q7) In general, what do you personally, consider to be the primary reasons for sustainability reporting? We believe that reporting on ESG factors enables companies to better manage risk and exploit opportunities in the short, medium and long term. The introduction of integrated reporting by GRI and others points the way forward for more useable information for investor and other stakeholders. However, we believe that integrated reporting will not likely capture all aspects of a company s sustainability impact, since it focuses on key material factors. Therefore, there will remain a need to have broader sustainability reports either as standalone or contained elsewhere in a company s annual report or website. In turn, this implies that the GRI can remain a vehicle for the reporting of broader sustainability issues, in essence we should not expect to

2 see or wish to see total convergence between integrated reporting initiatives such as that of the IIRC, and GRI, but rather would wish to see them complement one another. As stated above, the availability of sustainability information helps provide a better picture of corporate risks and opportunities. A company can, in part, make a compelling business case to investors by showing that it has analysed all risks from so called externalities and has done so in a forward looking manner using ESG factors as part of long term business strategy and planning. If this disclosure is thorough and complete, it can save time in the long run, by proactively reporting on these issues and reducing the necessity of investors and others subsequently asking basic questions. The availability of sustainability information also acts as a check on corporate behaviour, and holds management accountable for certain statements given in the annual report or equivalent. Increased information leads to the more efficient working of capital markets. [Q8: only asked if Q5 = Reporter ] Q8) Please pick the most important reasons your organization produces its sustainability report. [Max. 5 answers] Demonstrate compliance with local regulations Demonstrate compliance with public norms Provide transparency on risks, opportunities, performance and impacts to a range of stakeholders Communicate risks, opportunities and performance to investors in particular Reduce the cost of capital Provide access to capital linked to responsible investment funds and indexes Engage with investors, employees and other stakeholders Establish trust with key stakeholders Manage reputation Identify strategic opportunities Improve risk management Improve collaboration across functions in the organization Improve organizational performance (inform resource allocation decisions and cost reduction strategies) : [Q9: only asked if Q5 = Reporter ] Q9) Which of the following sustainability reporting formats are most relevant to your organization today? Which do you expect to be the most relevant in three years? A decade from now? [Max. 3 answers per period] Today: In 3 years: In 10 years: Regulatory filing Sustainability report Integrated report Topic specific report Investor summary stakeholderspecific report Web based disclosures Regulatory filing Sustainability report Integrated report Topic specific report Investor summary stakeholderspecific report Web based disclosures Regulatory filing Sustainability report Integrated report Topic specific report Investor summary stakeholderspecific report Web based disclosures

3 MINIMUM CONTENT OF SUSTAINABILITY REPORT Q10) GRI s goal is to create a platform to mainstream sustainability reporting practices. In order to make sustainability reporting a common practice, it is important to understand what information should be provided, at a minimum. Please indicate the importance of the following elements for a sustainability report. Essential Useful Not Useful Don t know Overview of the operational structure and regional presence Overview of the organization s sustainability strategy Description of the organization s governance approach, including senior management s responsibilities for sustainability performance Description of groups or individuals either affected by the organization s activities or able to affect the organization s activities Description of the organization s stakeholder engagement approach Results of stakeholder engagement Identification of the entities (e.g., subsidiaries, joint ventures, subcontractors) covered by the report Description of the process taken to determine topics to be included in the report Description of the process taken to analyze the economic, environmental and social impacts of operational activities Description of material impacts Description of the organization s value chain, covering the life cycle of products/services and key inputs, outputs and participants Description of the process taken to analyze economic, environmental and social risks and opportunities resulting from operational activities Description of material risks and opportunities Indicators related to material topics Goals related to material topics Description of the organization s approach for managing material topics

4 MINIMUM CONTENT OF SUSTAINABILITY REPORT Q11) Is there other information that a sustainability report should include, at a minimum? As a minimum, a sustainability report should also include an explanation of any statements given in any accounts / directors report, as relevant according to applicable regulatory requirements. For example, if directors refer to ESG reasons as part of the material forward looking risks to a company in their directors statement, more detailed information about why this was seen as material and how this judgement was made, would be needed in a resource outside the annual report. Including this in a sustainability report would also provide investors with an ability to assess whether management s views of key risks are the same as those that they perceive as key risks. A gap / inconsistency between the two may be telling. CONTENT OF GUIDELINES, TOPICS GRI would like to know who you think should define the topics and indicators to be covered in a sustainability report. Q12) Topics are subject matters on which an organization may report, such as emissions, child labor, employment, etc Would you say topics to be covered in a sustainability report should be defined by: [Please pick one] The reporting organization, taking into account factors such as region, sector, impacts and stakeholder feedback An external body, such as GRI, based on international, multi stakeholder consultation The investment community, based on sector analysis and risk considerations Regulators [Q14C: only asked if Q12 = The investment community or Regulators ] Q14C) Could you indicate why? [Q13: only asked if Q12 = An external body, such as GRI, ] Q13) If an external body, such as GRI, based on international, multi stakeholder consultation, should define, a set of topics that cover the key economic, environmental and social performance and impacts of organizations, and require reporting on these topics, would you say these topics should be: A standard set of topics for all organizations A standard set of topics per sector : Mixture of both a standard set of topics for all organizations, and a standard set of topics per sector. From our experience with emerging markets and private equity, size and region may also be relevant. [Q13: only asked if Q13 = A standard set of topics or Other ] Q14A) Could you indicate why you think this should be?

5 We wonder whether it might be best to have a mixture of some topics per sector and some topics for all organisations, rather than just a standard set of topics for all organisations, or a standard set of topics per sector. From our experience with emerging markets and private equity, size and region may also be relevant. Companies also may have an idea (in some cases) of which topics are relevant for them. Furthermore, not all companies may fit straightforwardly into sector categories, particularly as new sectors evolve over time. Allowing room for companies own determination is important. [Q15: only asked if Q13 = A standard set of topics for all organizations ] Q15) Please identify which of the following topics should be covered in the standard set for all organizations: Economic related topics Economic Performance (e.g. value generated and distributed) Market Presence, including impact on local communities (e.g. local hiring, local suppliers) Indirect Economic Impacts Environmental related topics Materials Energy Water Biodiversity Emissions, Effluents, and Waste Products and Services (e.g. their impacts, product reclamation) Compliance Transport Overall (e.g. environmental expenditures) Labor related topics Employment Labor/Management Relations Occupational Health and Safety Training and Education Diversity and Equal Opportunity Equal remuneration for women and men Human Rights related topics Investment and Procurement Practices Non discrimination Freedom of Association and Collective Bargaining Child Labor Prevention of Forced and Compulsory Labor Security Practices Indigenous Rights Society related topics Local Communities (e.g. engagement, impacts and mitigation) Corruption Public Policy Anti Competitive Behavior

6 Compliance Product Responsibility related topics Customer Health and Safety Product and Service Labeling Marketing Communications Customer Privacy Compliance topics CONTENT OF GUIDELINES, INDICATORS Q16) Should an external body, such as GRI, based on international, multi stakeholder consultation, define a standard set of indicators that capture the key economic, environmental and social performance and impacts of organizations, and require reporting on these of indicators? Yes No [Q17: only asked if Q16 = Yes ] Q17) I would say these indicators should be: A standard set of indicators for all organizations A standard set of indicators per sector : Mixture of both a standard set of indicators for all organizations, and a standard set of topics per sector. From our experience with emerging markets and private equity, size and region may also be relevant. [Q18A: only asked if Q17 = A standard set of indicators or Other ] Q18A) Could you indicate why? To use a global platform to build consensus on metrics about particular indicators (in particular sector metrics for baseline analysis, such in health and safety, climate change) would be really very useful and a good guideline. Nonetheless, EIRIS is keen to ensure there is no dilution of available information. We wonder whether it might be best to have a mixture of some indicators per sector and some indicators for all organisations, rather than just a standard set of indicators for all organisations, or a standard set of indicators per sector. From our experience with emerging markets and private equity, size and region may also be relevant. Also, not all companies may fit straightforwardly into sector categories, particularly as new sectors evolve over time. Allowing room for companies own determination is important. [Q19: only asked if Q17 = A standard set of indicators for all organizations ] Q19) Please note which indicators should be covered in the standard set. Q20) Would you say GRI s Guidelines should offer guidance on how the sustainability reporting process or sustainability report content can be used to produce an Integrated Report.

7 Yes No [Q21: only asked if Q20 = No ] Q21) Could you indicate why? Q22) In May and June 2011, GRI invited the public to submit topics that it thought should be added to G4 and researched emerging trends in the sustainable development discussions. Below is a list of 12 topics that received broad support. Please pick the 5 topics that are most important to you. Feel free to add topics that are most important to you. Biodiversity. Revision to reflect recent international work in this field, including ecosystem services. Business Ethics. Implementation and promotion of ethical business practices. Chemicals of Concern. Identification and phase out out of chemicals of concern from product lines. Disabled Persons. Policies and practices related to facilities access, employment and communications. Eco innovation. Explores addressing investment in and revenue gained from offering products and services with sustainability considerations. Green Building Practices. Implementation of related certification, rating and labeling schemes. Greenhouse Gas Emissions. Alignment with other international emissions reporting frameworks. High Impact Event Management and Preparedness. Consideration of emergencies such as natural disasters and product recalls. Life Cycle Assessment (LCA). Implementation of LCA methodology into processes, products and services. Plastics, Packaging and Waste. Revision of existing materials, waste and product services topics with increased focus on plastics. Remuneration and performance based pay. Explores the link between compensation systems and sustainability objectives, difference between the organization s highest and lowest income levels. Water. Revision to include regional basin or reservoir considerations. [Q23: only asked if Q5 = Reporter ] Q23) Which of the following sustainability related standards, frameworks or initiatives does your organization uses either as a reporting or management tool?

8 Used for reporting Used for management Not Used CDSB Climate Change Reporting Framework Emissions trading system/scheme EU Eco Management and Audit Scheme (EMAS) ISO ISO ISO OECD Guidelines for Multinational Enterprises Product/Eco labels SA8000 Sector initiative (e.g. Responsible Care for chemical sector; ICMM for mining sector) UNCTAD Guidance on Corporate Responsibility Indicators in Annual Reports UN Global Compact Principles UN Millennium Development Goals UN Principles for Responsible Investment (UNPRI) Country specific reporting guidance Please list other sustainability related standards, frameworks or initiatives your organization uses either as a reporting or management tool: REPORTS [Q24: only asked if Q5 = Reporter ] Q24) Please list the top 5 material economic, environmental and social topics that your organization has identified for its sustainability report [Q25: only asked if Q5 = Reporter ] Q25) Please indicate the entities for which your organization prepares sustainability information. This may include any form of environmental, social, economic and governance information. National, regional or local regulatory programs National, regional or local registers Industry or Sector specific initiatives Supply Chain Initiatives (e.g. The Sustainability Consortium) Sustainability Index Providers (DJSI/SAM, FTSE4Good or other) Investor Initiatives (Carbon Disclosure Project, UN Principles for Responsible Investment or other) Individual investors (institutional investors, asset managers)

9 Research firms and intermediaries (Bloomberg, Thomson Reuters or other) FEEDBACK ON G3 AND G3.1 GUIDELINES The last questions aim to gather your feedback on the current GRI Guidelines (G3 and G3.1) Q26) Please indicate which of the following standard disclosures you think could be improved and which you suggest to delete. Improve Principles for Defining Report Content Stakeholder Inclusiveness Materiality Sustainability Context Completeness Principles for Ensuring Report Quality Comparability Accuracy Timeliness Clarity Strategy and analysis Organizational Profile Report Parameters Governance, Commitments and Engagement Disclosure on Management Approach Economic Environmental Labor Practices and Decent Work Human Rights Society Product Responsibility Performance Indictors and related Indicator Protocols Economic EC1 EC9 Environmental EN1 EN30 Labor Practices and Decent Work LA1 LA15 Human Rights HR1 HR11 Society SO1 SO10 Product Responsibility PR1 PR9 [Q27: only asked if 1 or more indicators in Q26 = Improved ] Q27) Could you explain for each of the disclosures you mentioned in the previous question what GRI should improve? Delete

10 It might be good to update the current definition of materiality with emerging trends in integrated reporting, as illustrated with the International Integrated Reporting Committee's work and that of EFFAS. For we think this could be improved by making it more targeted to ESG. For , we think this could be improved by making it more targeted to ESG. [Q27: only asked if 1 or more indicators in Q26 = Deleted ] Q28) Could you explain for each disclosure you mentioned in the previous question why it should be deleted? Q29) In response to stakeholder feedback, GRI s Guidelines could also include new guidance elements (e.g. principles, new concepts, definitions, ). Which guidance elements, if any, should be added to the current Guidelines? More guidance would be welcome on supply chains for all areas (labour, human rights, environment, auditing and reporting guidelines, and compliance). Q30) Please provide suggestions on improvements or possible alternatives to the current Application Level system. We would welcome a better system to code the information in reports. At present reference to a particular indicator is included in the GRI table of contents. That refers to a particular page, but the information is sometimes embedded and hidden inbetween irrelevant information. A way of coding the information on the relevant pages (and make that a standard requirements for levels C, B, A) would be very useful. Q31) If you have any further feedback to share with GRI, please note them here. In general any external body such as GRI, IIRC and GISR, will provide generic rules defining topics. Regulators and investors may also have a role in this. The Company may decide (in consultation with stakeholders) which ones are material to its operations and justify why. Alternatively the GRI or another guidelines provider can offer a number of alternatives for topics to be relevant to companies based on region/size, etc. We would suggest that any guidance from the GRI on integrated reporting should be guidance about how sustainability reports fits with an integrated annual report (or equivalent). We think that annual reports should mandatorily highlight key business risks and opportunities, including ESG risks. We would suggest that guidance is created to encourage annual reports to refer by link to a sustainability report, where more detailed sustainability performance information can be found and any background explanation for top level statements. We believe that reporting on ESG factors enables companies to better manage risk and exploit opportunities in the short, medium and long term. The introduction of integrated reporting by GRI and others points the way forward for more useable information for investor and other stakeholders. However, we believe that integrated reporting will not likely capture all aspects of a company s sustainability impact, since it focuses on key material factors. Therefore, a need will remain to have broader sustainability reports either as standalone or contained elsewhere in a company s annual report or website. This implies that the GRI can remain a vehicle for the reporting of broader sustainability issues, in essence we should not expect, or wish to, see total convergence between integrated reporting initiatives such as that of the IIRC, and GRI, but rather would wish to see them complement one another.