G4 DEVELOPMENT Second G4 Public Period: Submissions Document 6 of 12 Qualitative Online Feedback: Disclosure on Management Approach February 2013
INTRODUCTION ABOUT THE SUBMISSIONS DOCUMENTS In 2010 GRI began the development of the fourth generation of its Sustainability Reporting Guidelines, G4. Following GRI s Due Process 1, this development includes the use of Public Periods (PCPs) to gather stakeholder feedback on proposed updates. The series of Submissions documents presents the submissions received during the second G4 Public Period on the G4 Exposure Draft, and the Additional Public Period for G4 Thematic Revisions. These PCPs were held for a period of 90 days each, between June and November 2012. The documents include a list of the individuals and organizations that submitted feedback, the verbatim contents of all online and offline feedback submissions, and notes and summaries of the G4-related Workshops. All submissions are reproduced in these documents exactly as received by GRI, with no alterations. To protect personal data, personal contact details (e.g., email addresses, telephone numbers) have been removed. Submissions received in languages other than English were professionally translated and analyzed in English. In these documents, these submissions are presented in their original language. There are 12 documents, each available for download as a standalone file on the GRI website. The table below gives an overview of the contents of each document. 1 Process based on principles according to which all GRI Guidelines documents must be developed Second G4 Public Period: Submissions Introduction Page 1 of 2491
Documents Contents Page Second G4 Public Period 1: List of Participants A list of the individuals and organizations that submitted feedback. 12 2: Statistics: Quantitative Online Feedback 3-8: Qualitative Online Feedback 9: Offline Feedback 10: Workshop Summaries 11: Anticorruption 12: Greenhouse Gas (GHG) Emissions Detailed statistics about the answers to survey questions posed on the online GRI Consultation Platform. These documents contain all the verbatim comments received 86 through the GRI Consultation Platform for each of the following areas of proposed updates: 3. General Questions 4. Application Levels 5. Boundary 6. Disclosure on Management Approach 7. Governance and Remuneration 8. Supply Chain Disclosure All the submissions received via email or letters, presented verbatim. 1613 Summaries of 49 G4 Workshops held worldwide by GRI. 1918 Additional Public Period for G4 Thematic Revisions This document contains: A list of the individuals and organizations that submitted feedback Detailed statistics about the submissions received through the GRI Consultation Platform All the online and offline submissions received for Anticorruption, presented verbatim This document contains: A list of individuals and organizations that submitted feedback Detailed statistics about the submissions received through the GRI Consultation Platform All the online and offline submissions received for GHG Emissions, presented verbatim The notes taken at two G4 Workshops on GHG Emissions, held in Brazil 33 2130 2275 Second G4 Public Period: Submissions Introduction Page 2 of 2491
G4 DEVELOPMENT AND G4 OBJECTIVES In September 2010, GRI s Board of Directors approved plans to start developing the next generation of its reporting Guidelines (G4), and set out the following objectives: to offer guidance in a user-friendly way, so that new reporters can easily understand and use the Guidelines to improve the technical quality of the Guidelines content in order to eliminate ambiguities and differing interpretations for the benefit of reporters and information users alike to harmonize as much as possible with other internationally accepted standards to improve guidance on identifying material issues from different stakeholders perspective to be included in the sustainability reports to offer guidance on how to link the sustainability reporting process to the preparation of an Integrated Report aligned with the guidance to be developed by the International Integrated Reporting Council (IIRC) In May 2011, GRI began informal external consultations, to understand what was considered to be needed in order to achieve the objectives stated above. The GRI Guidelines development must follow a Due Process, which ensures that all efforts are made to involve and consider the interests of all of GRI s stakeholders (including, but not limited to businesses, civil society organizations, financial markets, consultancy services, labor representatives and academics). GRI launched Primer Surveys for Organizational Stakeholders, reporters and other groups to gather views on G4 s potential structure and content. Alongside this, a public Call for sustainability reporting topics was held in May and June 2011 to collect input on which new issues should be covered in G4. Results of this consultation were included in the Survey of the first Public Period (PCP) for G4. GRI also asked individuals and organizations to register their interest in taking part in the first G4 Public Period. This step helped ensure that the views of a regionally balanced and diverse group of stakeholders were taken into account. The first G4 PCP, which ran from August to November 2011, was the start of the formal consultation process. It attracted around 2300 participants, 1832 of whom provided a submission via an online survey. The results of the first G4 PCP can be found on the GRI website. Based on the G4 objectives set by the Board of Directors, the results of this first consultation and previous informal consultations, the following Working Groups were created to develop revised content for the Guidelines: Application Levels Boundary Disclosure on Management Approach Governance and Remuneration Supply Chain Disclosure Anti-corruption Greenhouse Gas (GHG) Emissions Second G4 Public Period: Submissions Introduction Page 3 of 2491
As defined in the GRI Due Process, Working Groups are formed by the Secretariat, under the direction of the Board of Directors and consultation with the Technical Advisory Committee 2. Selection criteria include expertise, stakeholder diversity, and availability. Proposed revisions to the text of the Guidelines or Protocols are drafted by the Working Groups as outlined under overarching Due Process principles. The Technical Advisory Committee is responsible for reviewing proposals put forth by the Working Groups. On 25 June 2012, GRI launched the second G4 Public Period, which sought the public s feedback on an Exposure Draft of G4. The draft featured significant proposed changes to content for Application Levels, Boundary, Disclosure on Management Approach, Governance, and Supply Chain Disclosure. The document was available for comment from 25 June to 25 September 2012. On 14 August 2012, GRI launched an Additional Public Period for G4 Thematic Revisions. This Additional PCP was complementary to the second G4 PCP and invited the public to provide feedback on the proposed thematic revisions to the topics of Anti-corruption and Greenhouse Gas (GHG) Emissions. The documents were available for comment from 14 August to 12 November 2012. The proposed thematic revisions were built upon the content and structure featured in the G4 Exposure Draft. During these PCPs, any interested party could provide feedback on specific proposed revisions to the Guidelines. The results of the second G4 PCP and the Additional PCP for G4 Thematic Revisions informed the work of the GRI Working Groups and Governance Bodies to finalize the G4 Guidelines. The G4 Guidelines are planned to be launched in May 2013. 2 The Technical Advisory Committee (TAC) provides GRI s Board and network with high-level, expert advice on reporting, and sustainability. Second G4 Public Period: Submissions Introduction Page 4 of 2491
SECOND G4 PUBLIC COMMENT PERIOD The second G4 PCP invited the public to provide comments on the G4 Exposure Draft. The G4 Exposure Draft represents the combined efforts, under the direction of the Board of Directors (which consults the Stakeholder Council 3 ), of the Working Groups, the Secretariat and the Technical Advisory Committee. In addition, a Technical Editing Task Force was created to review the content of the Guidelines and make recommendations to improve their clarity and enhance the consistency of their application. The proposed significant changes to the Guidelines presented in the G4 Exposure Draft are summarized below. At the core of these changes was a focus on materiality in combination with other reporting principles in all stages of sustainability reporting, from the identification of the content and boundaries of the report, to the disclosures provided by the organization. APPLICATION LEVELS The Application Levels were introduced with the launch of the G3 Guidelines to assist organizations in communicating the degree of transparency of their sustainability reports against the Guidelines. This system has served organizations well in allowing them the start of a journey, in most cases on voluntary basis, in sustainability reporting. In recent years, however, concerns have been expressed by different stakeholders that the Application Levels are wrongly understood by some report users to be an opinion on the quality of the report, or even a reflection of the sustainability performance of the organization. To remedy these concerns and, more importantly, to align with other international disclosure standards, it was proposed that the Application Levels as they presently exist in the G3 and G3.1 Guidelines be discontinued. The proposal made in the G4 Exposure Draft was to replace Application Levels with criteria that must be met for an organization to claim that the report has been prepared in accordance with G4. In addition, in recognition of the time and effort required to prepare an initial sustainability report, transitional provisions were proposed to allow first time reporters, for two reporting periods, to incrementally apply G4 by disclosing in the report the required information that has been omitted, as well as stating their commitment for the report to be fully in accordance with G4 once the transition period is over. BOUNDARY The process in the existing Technical Protocol Applying the Report Content Principles was revised to direct organizations on how to define the content and boundaries of a sustainability report in one sequence of process steps, thus to answer the question of what to report. The process began with the mapping of a value chain(s) and the identification of relevant topics and boundaries, followed by the prioritization of relevant topics as material GRI Aspects, for validation. The outcomes of the 3 The Stakeholder Council is GRI s formal stakeholder policy forum. The Stakeholder Council debates and provides input on key strategic and policy issues. Second G4 Public Period: Submissions Introduction Page 5 of 2491
process consisted of (1) a map of the organization s value chain, (2) a list of material Aspects (and where the impact occurs within the value chain(s)) and (3) related Standard Disclosures to be included in the sustainability report. The Standard Disclosures include the Core Indicators which are required to be disclosed by the organization; if a Core Indicator is not disclosed, the organization is required to explain the reasons why it is not provided. DISCLOSURE ON MANAGEMENT APPROACH The Disclosures on Management Approach are intended to provide organizations with an opportunity to explain how they are managing material economic, environmental, and social impacts. The G4 Exposure Draft outlined a generic approach for all topics and proposed that the Disclosures on Management Approach should be provided at the Aspect level to reflect management practices. However, when a topic is managed at a different level, the Disclosures on Management Approach should be reported at that level. That level may be general (applicable to Categories), or more detailed (applicable to Aspects or an organization s self-defined topics), or specific (applicable to Indicators). GOVERNANCE AND REMUNERATION The G4 Exposure Draft proposed a number of changes to governance and remuneration disclosures to strengthen the link between governance and sustainability performance, taking into account the consistency within existing governance frameworks and developments in that field. The proposed changes included new disclosures in the Profile section of the report on the ratio of executive compensation to median compensation, the ratio of executive compensation to lowest compensation and the ratio of executive compensation increase to median compensation. SUPPLY CHAIN DISCLOSURE New and amended disclosures on the supply chain were included in the G4 Exposure Draft. They included a new definition of supply chain and of supplier, as well as new disclosures on the supply chain, including procurement practices, screening and assessment as well as remediation. In addition, guidance was included on how to apply the supply chain reporting requirements. STRUCTURE AND FORMAT OF THE G4 GUIDELINES Throughout the development of the G4 Exposure Draft, an editorial review was conducted to improve the clarity and technical quality of the text as well as to facilitate the implementation of the Guidelines. One of the changes was the split of the text in the Indicator Protocols into standard disclosures and guidance, to facilitate the identification of the reporting requirements by organizations and to offer guidance in a user-friendly way. GRI plans to offer the finally approved G4 content through a web-based platform which will present other user-friendly features. Second G4 Public Period: Submissions Introduction Page 6 of 2491
ADDITIONAL PUBLIC COMMENT PERIOD FOR G4 THEMATIC REVISIONS An Additional PCP for G4 Thematic Revisions ran from 14 August to 12 November 2012 and featured proposed changes to GRI s guidance for reporting Anti-corruption and Greenhouse Gas (GHG) Emissions. The proposed changes to the Guidelines presented in the Thematic Revisions are summarized below. ANTI-CORRUPTION The Anti-corruption Working Group proposed a number of changes to existing disclosures for anticorruption, and proposed to locate certain new and revised disclosures under a new Ethics section. Updated definitions and references, and changes to existing terminology, were included to make disclosures clearer and more focused; and to align G4 with best practice in anti-corruption disclosure. The proposed revisions included: Strategy, Profile and Governance New disclosures under a new section e. Ethics Disclosure on Management Approach Indicators New disclosures and guidance (Anti-corruption Aspect, Society Category) Specific edits to Indicators SO2, SO3, and SO4 (Anti-corruption Aspect, Society Category) Specific edits to Indicator SO6 (Public Policy Aspect, Society Category) GREENHOUSE GAS (GHG) EMISSIONS The GHG Emissions Working Group proposed a number of changes mainly covering disclosures under the Aspects of Energy and Emissions (formerly Emissions, Effluents, and Waste) in the Environmental Category. Disclosures in other areas of the Guidelines relevant to reporting GHG emissions are also included. The proposed revisions intended to support reporting and align with the GHG Protocol, jointly released by the World Resources Institute and the World Business Council for Sustainable Development, and the ISO 14064 standard produced by the International Organisation for Standardisation. The proposed GHG Emissions Indicators are fully aligned with the GHG Protocol s grouping of emissions into three subsets (Scopes 1, 2, and 3), as well as the ISO 14064 grouping. Energy Indicators have been modified to align with the GHG Emissions Indicators for more streamlined reporting. Intensity Indicators were added for both energy and GHG emissions. Compilation points for each Indicator have been made consistent across Indicators and other reporting frameworks, and allow for more detailed reporting to assist with the comparability of data. Second G4 Public Period: Submissions Introduction Page 7 of 2491
The proposed revisions included: Disclosure on Management Approach New disclosures and guidance for the Energy and Emissions Aspect (Environmental Category) Indicators Edits to Indicator EC2 (Economic Performance Aspect, Economic Category) Edits to Indicators EN3 EN7 and Indicators EN16 EN20 (Energy and Emissions Aspects, Environmental Category) New Indicators under the Energy and Emissions Aspects, Environmental Category METHODOLOGY FOR GATHERING FEEDBACK During the second G4 PCP and the Additional PCP for G4 Thematic Revisions, GRI invited any interested party to submit feedback on the proposed updates. GRI gathered feedback on the G4 Exposure Draft and Thematic Revisions through three means: The online GRI Consultation Platform, which included general and specific survey questions Letters and emails to GRI s Secretariat Workshops held worldwide by GRI The online GRI Consultation Platform offered the option of making comments on the presented documents using a document review function, and posed survey questions for each PCP: 27 questions for the G4 Exposure Draft, and seven questions for the Thematic Revisions. For the G4 Exposure Draft, both general and specific questions were posed. General questions were on structural or overall impressions of the Exposure Draft. Specific questions were on the proposals for each content area Application Levels, Boundary, Disclosure on Management Approach, Governance and Remuneration, and Supply Chain Disclosure. For the Thematic Revisions, GRI posed seven specific questions on the proposals for Anti-corruption and GHG Emissions. Three formats were used for the questions: Questions with the option of selecting Yes and no further comments, or selecting No and offering comments. Only a No response invited the option to provide comments. This means that a Yes response reflected complete acceptance, while a No response may have been accompanied by explanations of agreement or disagreement with the question Multiple choice questions, with no option to provide comments Open-ended questions, designed to invite unguided responses and broader feedback Second G4 Public Period: Submissions Introduction Page 8 of 2491
TERMINOLOGY The following terminology is used in the series of Submissions documents, and was used for GRI s statistical analysis of the submissions: Submission: an input of PCP feedback received by GRI through the Consultation Platform, letters or emails to GRI s Secretariat; Online submission: submission received through the Consultation Platform Offline submission: submission by letter and/or e-mail to the Secretariat Personal submission: submission representing the view of an individual Organizational submission: submission representing the view of an organization Collective submission: submission representing the views of more than one individual and/or organization, with a number of signatories Participant: each individual or organization providing PCP feedback with an online or offline submission. Collective submissions represent the views of a number of participants Quantitative online feedback: detailed statistics about the answers to survey questions posed on the online GRI Consultation Platform. Qualitative feedback: the verbatim contents of textual submissions METHODOLOGY FOR CLASSIFYING SUBMISSIONS Document 1 of these documents presents a list of the Second G4 PCP participants, grouped into online and offline submissions. In some cases, GRI received more than one submission from the same organization or individual. GRI s intention for both PCPs, however, was to permit only one submission from the same organization or individual; in the case of the Thematic Revisions, the intention was to permit one submission from the same organization or individual on Anti-corruption, and one on Greenhouse Gas (GHG) Emissions. When more than one submission from the same organization or individual was received, the following classification criteria were adopted: Complementary submissions: if the content of the multiple submissions was complementary, the submissions were combined as follows: If all complementary submissions were received through the Consultation Platform, the combined submission is presented only once in Document 1 (List of Participants), Document 2 (Statistics: Quantitative Online Feedback) and Documents 3-8 (Qualitative Online Feedback). If all complementary submissions were received offline, the combined submission is presented only once in the offline section of Document 1 (List of Participants) and Document 9 (Offline Feedback). If the complementary submissions were made through the Consultation Platform and offline through letters or emails, GRI combined both submissions and classified Second G4 Public Period: Submissions Introduction Page 9 of 2491
them as online or offline, based on the submission which had the most substantive content. Duplicate submissions: submissions with similar or identical content sent by the same organization or individual through both the Consultation Platform and offline through letters or emails were only considered once for analysis. Conflicting submissions: if the content of the multiple submissions was conflicting, GRI contacted the organization or individual to clarify which of the submissions was to be considered as either organizational or personal GRI received several collective submissions, representing the views of a number of participants. The signatories to these collective submissions can be found in Document 1 (List of Participants) under the heading Collective Responses. In several instances, participants did not provide their profile information, such as constituency group and/or reporting relationship. For data integrity purposes, GRI either contacted the participant for clarifications or completed the profile information when it was possible to identify the missing data, e.g., through the email domain, organization name, or website. GRI staff was not allowed to provide feedback during the PCPs. Feedback received from GRI staff members is not included in this summary report and was not considered for analysis. A document describing the methodology used by the Secretariat for analyzing the feedback received during the second G4 Public Period and the Additional Public Period for G4 Thematic Revisions is available on the GRI website. Second G4 Public Period: Submissions Introduction Page 10 of 2491
6 QUALITATIVE ONLINE FEEDBACK: DISCLOSURE ON MANAGEMENT APPROACH (DMA) 6.1 ABOUT THIS DOCUMENT This is number 6 in the series of 12 Submissions documents. All these documents are available for download as a standalone file on the GRI website. This document contains all the verbatim comments received through the GRI Consultation Platform regarding Disclosure on Management Approach. These comments are presented exactly as received by GRI, with no alterations. The comments are organized by question and document review. 6.2 OVERVIEW OF SUBMISSIONS BY QUESTION: DISCLOSURE ON MANAGEMENT APPROACH (DMA) Table 92 below provides an overview of the online submissions that provided a response to the Disclosure on Management Approach (DMA) Questions on the GRI Consultation Platform. Percentages in the first column are calculated based on the total 590 online submissions. Table 92. Overview of submissions by question: Disclosure on Management Approach (DMA) Questions for General % of total submissions answering this question % of submissions answering 'Yes and no further comments % of submissions offering comments DMA1 Do the requirements for Disclosures on Management Approach offer sufficient flexibility to enable organizations to provide answers that will add value without making the report unduly repetitive and lengthy? 50% 50% 50% DMA2 Do you consider the proposed Disclosures on Management Approach an improvement over the current approach? 49% 61% 39% DMA3 Do you consider the proposed disclosures related to Disclosures on Management Approach appropriate and/or complete? DMA4 Do you consider the proposed guidance provided to support the Disclosures on Management Approach appropriate and/or complete? 48% 51% 49% 48% 64% 36% DMA5 Do you have other general comments about the Management Approach Disclosures? 29% - - Second G4 Public Period: Submissions Page 826 of 2491
6.3 QUESTIONS FOR GENERAL COMMENT: DISCLOSURE ON MANAGEMENT APPROACH HOW TO NAVIGATE THIS SECTION The GRI Consultation Platform combined an online survey with a document review function, allowing users to respond to questions GRI posed and to comment on the proposals for new and revised contents. The following section contains the responses to the survey s questions, received via the GRI Consultation Platform for this particular content area. The comments are presented in tables and in alphabetical order. The tables can be read in the following manner: Constituency Region Reporting Text Other XX Second G4 Public Period: Submissions Page 827 of 2491
DISCLOSURE ON MANAGEMENT APPROACH Q1 Q1) Do the requirements for Disclosures on Management Approach offer sufficient flexibility to enable organizations to provide answers that will add value without making the report unduly repetitive and lengthy? Yes No, please clarify: % of total submissions answering this question 50 % of submissions answering 'Yes and no further comments % of submissions offering comments 50 50 ORGANIZATIONAL SUBMISSIONS Constituency Region Reporting ERM considers the Requirements for Disclosures on Management Approach (DMA) an improvement from that in G3 and G3.1. However, we suggest that this may be an area of the guidance document that can be edited to be more clear and concise. ERM suggests that GRI more clearly define the difference between commitments and goals in relation to a management approach. There can be significant overlap between these concepts and reporting organizations may struggle with understanding the difference. ERM also suggests that GRI build out the discussion on including multiple aspects in one DMA. This will encourage organizations to include more information in a concise manner. ERM also suggests that GRI build out the discussion on how material issues will evolve in the future and how the reporter will respond. We welcome that the G4 draft encourages reporters to disclose the Management Approach for material aspects only, whereas in G3 reporters at level A and B are required to disclose on all management aspects. However, this advantage is outweighed by a higher number of requirements in other areas. A lot of time and space will also be consumed by explaining why certain aspects are not material. Ideally, the required narrative information on Management Approach should not be limited in terms of number of pages/space. As explained in more detail below, there is variability in the presentation of the DMAs and Aspects, with areas of repetition and unnecessary reporting burden, whereas other areas provide insufficient explanation definition on Aspects. As with other changes, the proposed requirements for disclosure on management approaches would significantly increase the burden of preparing a GRI report and reflects the "more is more" approach taken in the draft G4. Additionally, the exclusive focus Business Business Industry Association Second G4 Public Period: Submissions Page 828 of 2491
Constituency Region Reporting on material issues will limit the flexibility of the organization to cover issues that may be of interest and/or relevant for a particular target audience but not material. 1: Disclosure on Management Approach requirements are lengthy and prescriptive The extents of disclosures related to management approach are too elaborate. It is not clear as to what depth a topic / aspect needs to be assessed and disclosed. Management disclosure has become complex and may lose essence of reporting; however there is scope to simplify the disclosures. Companies are encouraged to disclose the DMA for material aspects only, which is good. But once declared material, companies need to cover information for the respective aspect of the different categories, as recommended by G4. This will lead to redundancies since such information is very detailed and repeatedly requested for each category (environment, social etc.) i.e. for the aspects Screening and Assessment as well as Remediation. This will also have significant impacts on the reporting activity especially for larger and more complex organizations. This can lead to a repeated and lengthy disclosure of similar information (e.g. in case management approaches are bundled for different topics in one system). Business Asia Business Further comments on this are made on p.35 (DI 44ff), p. 43ff (Disclosure 3). Depends on how the requirements are meant to be: It's positive I am allowed to selectively collect/report information where it is relevant. But it needs a lot of resouces if full disclosure of materiality on a local level is required. In addition, a standard guidance would be helpful of what is expected to be reported on in a certain sector. Disclosure on Management Approach requirements are lengthy and prescriptive: - The extents of disclosures related to management approach are too elaborate. It is not clear as to what depth a topic / aspect needs to be assessed and disclosed. Management disclosure has become complex and may lose essence of reporting; however there is scope to simplify the disclosures. DMA guidance is very detailed and these requirements will likely make the report longer as opposed to being more concise due as I interpret the materiality requirement was attempting to achieve. Due to too many disclosure items, reports will be lengthy and also repetitive as part of the information is already required in the governance section. Emphasis should not be on flexibility but on process requirements. The outcome of suggested approach would add no value, add length and cost. Far too complex now to expect ALL companies to complete many of the suggested indicators are not material to many businesses, however as a profile disclosure GRI are implying that these are a minimum standard requirement. I feel disclosures on management approach should be limited to specific material issues only, and in part be a response to stakeholders demands/concerns on the issue in question Business Asia Certified Training Partner & on Sustainability Reporting Business Business Business Business Second G4 Public Period: Submissions Page 829 of 2491
Constituency Region Reporting If all disclosures are mandatory, flexibility is not an option. If applied across all indicators, it is too cumbersome. In general we think the new approach provides this flexibility and can lead to more concise reporting. However, alongside the DMA the G4 should consider the readers /stakeholders perspectives, especially what they want to know about an organization. In some cases a qualitative explanation is sufficient, while for some material topics would they expect quantitative information on impacts and performance. We are also concerned that after stating that the DMA be reported for material topics (also in the in accordance criteria ), the Introduction to the Guidelines asks for brief contextual management approach information for topics with less significant impacts. Either the DMA is for material topics, or not. Financial Markets & Information Users Asia Training Partner / Data Partner Although the guidance says that organizations are encouraged to combine the DMAs for groups of Aspects where there is common management approach, this is not very clear in the ED. If a company then includes a DMA for each material Aspect there is a risk that it will be very repetitive, with less useful information for all the DMA requirements, as often happens with the G3. On specific disclosures: Disclosure #1 and #2 could be transferred to other elements (e.g. where an organization explains its prioritization-materiality analysis) and not be part of a DMA. Disclosure #3 should be kept concise - Its long analysis does not help; instead it may create confusion (especially the item actions ) where organizations think they need to report on every action item. In principle, it is an excellent initiative that is welcome, as it makes real effort to link how companies are looking at what they are reporting and how they are managing those issues. However, there is uncertainty as to whether organisations will be able to do this, and if they are, it is uncertain how effective such effort will be. Furthermore, when looking sections and questions in detail, there is a certain amount of repetition. Business Accountancy body Second G4 Public Period: Submissions Page 830 of 2491
Constituency Region Reporting In theory it may seem appropriate to ask for DMAs at the Aspect level, but in practice it will be confusing to reporters and promotes repetition. DMAs will take on more weight and potentially supplant some quantitative non-core data, which may make it difficult for analysts who look for comparable data. Integrated, required sector supplements will make it challenging for software providers like us. You should consider discontinuing separate charges for sector supplements which effectively discourage companies from reporting because it can be too financially onerous to provide for 1-2 companies. It did but the whole approach has been undermined by stipulating requirements for an "in accordance" report which makes the "Technical Protocol", which the DMA WG had positioned as guidance, mandatory. Business reporting software provider Business Asia In short, the entire rationalization has been undermined. It is not clear enough. As it is stated now, for each material topic you have to report according to the guidance provided in point 2 (DMA) and also then add the information stated on each category under the DMA only if it is considered material? It is a little bit confusing, and as it is stated now it seems that there is going to be a lot more of information in sustainability reports in order to be in accordance. It is not clear what is being referred to here. The application of materiality to DMA disclosures is a good addition. However for a vertically integrated company most subjects are material, so this results in no significant change for such a company. it is unclear to me how the greater focus on materiality is to be balanced with the requirement to report on management approach for all aspects. Is there a report or explain requirement for each aspect or is it the other way around; that the materiality assessment defines which aspects that are deemed to be material (thus the others can be left out)? Business We suggest clarifying that Disclosures on Management Approach should primarily be described for topics defined as material. It may not be possible to disclose management approaches for all material issues unless the issue has reached a certain degree of maturity and we have had sufficient time to develop a formalised management approach. Often the topics that are identified as material are as a consequence of recent events or emerging issues to the business (within the last 12 months) and may be difficult to outline a management approach. In most instance we may be still working through the detail to arrive at an appropriate response. Often there would be an absence of policy, resources or actions assigned to any degree of formality. Business Oceania The requirements appear overly prescriptive in many aspects, and could result repetitive and lengthy reports that will discourage readers particularly if all of the content outlined on page 42-46 has to be completed for each and every material topic. The reporting organisations should have appropriate discretion in ensuring relevant information is included and that it is not excessively detailed. Management disclosure has become complex and may lose essence of reporting; however there is scope to simplify the disclosures. Business Asia n Business Need to be more principles based. It would be better siumply to insist that a company did report on its management approach was within the report. We would then find out what the company really did and thought. It would give insight. Second G4 Public Period: Submissions Page 831 of 2491
Constituency Region Reporting No comment No. See response to DMA: Question 2 and specific text edits in the Document Review section. Business No. See response to DMA: Question 2 and specific text edits in the Document Review section. Business Our management approaches are often similar for more than one specific topic, making our future disclosure repetitive, and of no Business added value to our stakeholders. Pages 43-46 guidance on Disclosure 3 While line 505 says may include, so not all elements need to be reported, the message Business does not come through strongly enough, given the lengthy guidance that follows. Partially - We appreciate the greater focus on materiality and the work towards a better, more relevant and shorter report. We agree with GRI that only material information to the company and the stakeholders with materiality being assessed by the company s management should be included in the Sustainability Report. Business - Nevertheless some of this advantage will be outweighed by a higher number of requirements in other sections and by reporting on the determination of material aspects or why certain aspects are not material. - We therefore recommend having a basic set of material topics to be reported; while materiality should only be explained for the additional topics. Partly We welcome that the G4 draft encourages reporters to disclose the Management Approach for material aspects only, whereas in G3 reporters at level A and B are required to disclose on all management aspects. However, this advantage is outweighed by a higher number of requirements in other areas. A lot of time and space will also be consumed by explaining why certain aspects are not material. Please clarify: As narrative information is required- this is not limited-at best by number of pages/space. Single points good but reporting should be more standardized with regard to key messages/key requirements. There should be a minimum standard/amount of material topics. Partly Deutsche Bank welcomes GRI s attempt to give reporters the opportunity to disclose the management approach for material aspects only. Business Financial Markets & Information Users Second G4 Public Period: Submissions Page 832 of 2491
Constituency Region Reporting It doesn t makes sense to explain lengthy why something is not relevant. Deutsche highly objects to that! Partly Business Evonik welcomes that the G4 draft encourages reporters to disclose the Management Approach for material aspects only,whereas in G3 reporters at level A and B were required to disclose on all management aspects.however, this advantage is outweighed by a higher number of requirements in other areas. A lot of time and space will also be consumed by explaining why certain aspects are not material. Ideally, the required narrative information on Management Approach should not be limited in terms of number of pages/space. Partly. Business econsense welcomes that the G4 draft encourages reporters to disclose the Management Approach for material aspects only, whereas in G3 reporters at level A and B were required to disclose on all management aspects. However, this advantage is outweighed by a higher number of requirements in other areas. A lot of time and space will also be consumed by explaining why certain aspects are not material. Ideally, the required narrative information on Management Approach should not be limited in terms of number of pages/space. Partly. Business We welcome that the G4 draft encourages reporters to disclose the Management Approach for material aspects only, whereas in G3 reporters at level A and B are required to disclose on all management aspects. However, this advantage is outweighed by a higher number of requirements in other areas. A lot of time and space will also be consumed by explaining why certain aspects are not material. Ideally, the required narrative information on Management Approach should not be limited in terms of number of pages/space Perhaps, but without a sample report to see what you're looking for, it's hard to figure out what you need to disclose. Please see response to DMA: Question 2 and specific text edits in the Document Review section. Business Reporting organizations should be invited to report on what they can explain, not only what they do. For the most of their sustainability data, companies cannot explain the evolution. Consequently a key point is: report and explain how you performed against YOUR KPIs & implementation of YOUR action plans Requiring disclosures on management approach at the indicator level, rather than by category (environment, economy, and society) as they were before, will contribute to making reports more lengthy and repetitive. Second G4 Public Period: Submissions Page 833 of 2491
Constituency Region Reporting Se convierte en un documento muy largo y va en contravia de lo que se busca de reportes más pequeños. Business Latin See response to DMA question 2. Business See response to DMA: Question 2 and specific text edits in the Document Review section. See response to DMA: Question 2 and specific text edits in the Document Review section. Business Oceania See response to DMA: Question 2 and specific text edits in the Document Review section. Business See response to DMA: Question 2 and specific text edits in the Document Review section. Business See response to DMA: Question 2 and specific text edits in the Document Review section. Business See response to DMA: Question 2 and specific text edits in the Document Review section. Business Asia See response to DMA: Question 2 and specific text edits in the Document Review section. Business Africa Gold Mining Company that reports in accordance with the GRI Guideline See response to DMA: Question 2 and specific text edits in the Document Review section. Business See response to DMA: Question 2 and specific text edits in the Document Review section. Business See response to DMA: Question 2 and specific text edits in the Document Review section. Business Oceania See response to DMA: Question 2 and specific text edits in the Document Review section. Business Africa Seems to us that some DMA could be address in the forewords or detailed messages from the executives. It's fine to make sure material topics have their DMA, but they can be on any part of the report. That was the intent of what the DMA Working Group was trying to achieve but it would appear that the intent has been lost in the current structure of G4. The current way that DMAs are addressed in the G4 draft makes it appear cumbersome and prescriptive rather than the intended approach of keeping DMAs meaningful, informative and relevant fo the reader. The comunication of the DMA requirements and guidance in G4 needs to be revisited. Latin The 3.1 was much more efficient in my opinion, very high risk with 4 for very very lenghty reports Business Oceania Second G4 Public Period: Submissions Page 834 of 2491
Constituency Region Reporting The Disclosures are far too extensive and detailed and repeating these per topic/aspect will lead to unduly repetitive and lengthy reports. It is unclear why these disclosures have to be so detailed, and why all this information should be disclosed on an annual basis. Also, several of the disclosures seem like indicators. The general guidance on Management Approach provides flexibility but it is unclear how companies should report additional disclosures e.g. on p.48-49 should these be reported only if material? This could be more clearly explained. The generic Disclosure on Management Approach requirements are useful as a guide however to include all the requirements will add considerable length to any report particularly where they are reported at an aspect level. Business Business Africa The additional disclosure items in the GRI categories then add to this length and have gone a little bit over the top in some instances, particularly those concerned with supplier disclosure. This would most likely be repetitive and uninteresting for the reader but adds length and to the requirements for a succinct integrated report. The guidance in section 2 is very useful and will improve reporting. Perhaps it is lingering confusion between topics, aspects, categories etc but it is not very clear to me how sections 2 and 4 relate, one seems to be topic and one aspect but from what I have read it seems that aspects seem to make up topics so I am a little confused. The guidance really appears to ask for answers to set questions. This might actually cause repetition of answers in the managment disclosure and the index answers. The instructions on generic content are very helpful and it should be clarified, that this is a general requirement for DMAs per aspect. However, the repetition of DMA guidance conveys the expression that these requirements are MANDATORY and a requirement for all aspects, which does not make any sense. It therefore creates more confusion than explanation. If the distinction between generic content and guidance is not made clear, reports will be unduly repetitive and lengthy. The problem with including the management approach is that there is no measurable boundary fo acceptance of the explanation, which means that at the end disclosure can be either too descriptive and useless for practitioners (as most people will jus skip it considering it repetitive. The proposed approach seems to be very resource intensive. The framework on defining the material issues of a report actually answers the basic elements here. The DMA s should fit into a framework of materiality matrix. Business Business Business Latin Business Especially disclosure step 3 and 4 will result in doubling information in the DMA s and specific indicators. The proposed changes in the management approach add more complexity to the existing information disclosure. It demands more information without describing its benefits. This disclosure will make the sustainability report repetitive and lengthy. The required structure of contents for each material aspect makes the report look repetitive in some parts Business Asia DRINKING WATER Second G4 Public Period: Submissions Page 835 of 2491
Constituency Region Reporting The requirements for Management Approach do appear to allow more flexibility, however this message is hidden among very specific guidance on how to report DMA. The guidance section gives an impression of a very prescriptive approach that would promote lengthier reporting. Clearly separating the requirements from additional guidance would help reporters see the flexibility of the current approach. The message about combining DMA for different aspects does not come through as a clear direction of G4. Providing examples of how to approach combining DMA for different aspects or selecting different DMA items (for example, only providing Challenges and Dilemmas section) could alleviate concerns about including repetitive information in sustainability reports. The requirements of DMA sould fit into a framework of materiality matrix. The revised requirements for Disclosures on Management Approach, focusing on material aspects, are an improvement. However, addressing screening, assessment and remediation for each aspect in some cases is simply not relevant or possible, particularly on social indicators (labor, human rights and society). The value chain mapping is as part of the GRI defined Aspects goes too far in creating a reporting burden. Financial Markets & Information Users Business Business SUPLYER AND WASTE WATER TREATMENTS The entire draf should be revised to remove overlapping and duplicate disclosure requirements. There are many aspects included in the Management Approach which will make the report rather lengthy and indeed repetitive. It will be difficult to translate all these aspects in a creative and interesting CSR report There are to much guidances to explain issues that are obvious, as Specific actions, responsibilities and goals There is a lot of repetition between "Identified Material Aspect" section (DI17 to DI30) and "Disclosure on Management Approach (DMA)" section (DMA1 and DMA2). In fact, reporting organisation have to explain their materiality process twice. There is too much of data points being asked in a very detailed manner. As a company, these details are part of the internal strategy, policy and procedures. The detailing on these data points can be part of the audit requirement rather than publishing it in the report. This DMA of the guidance would benefit from greater simplification and clarification of what is expected from reporters. BSR also suggests that the DMA portion of the guidelines indicate how companies incorporate reporting on management approach should complement the metrics and indicators associated with material issues. BSR suggests that the guidance here encourage companies to include answer the following questions related to material issues: 1) what is the policy around this issue, 2) how is oversight and accountability for this issue organized, 3) what are the key management procedures, 4) how does the company assess performance for this issue. The results of that assessment are typically performance indicators that are also reported. Business Latin Business Asia Civil Society Organization Second G4 Public Period: Submissions Page 836 of 2491
Constituency Region Reporting Vale reinforces the need that DMA disclosures take into account the materiality issue. For example, if an indicator is not material our suggestion is that DMA does not need to be addressed even in general manner. We are concerned that the expansion of disclosure requirements will lead to more lengthy and expensive reports without meeting the goal of increased transparency and comparability among reporters. We are concerned that, due to the proposed approach, i.e. to ask companies to choose material subjects from a list of external topics, especially drawing from an environmental and social viewpoint, these entities may find it challenging to select and disclose elements which are truly material to their own value creation and preservation. We believe that the disclosure on Management Approach as in GRI G3.1 was sufficient. Providing disclosures on each Aspect might be repetitive and lengthy - especially if an organization has got an integrated managment approach. Providing disclosures on each category (economy, environment and society) with respect to the aspects seems sufficient enough. We believe the response is a "yes, but..." however I am going to select "no, however..." until we learn otherwise. We are concerned that the new approach to integrate disclosures on management (DMA) will lead to many redundancies in most areas of disclosure. For example, HR and Procurement are often in the same department and thus managed in the same style and by the same people. Thus we believe that without further instructions, the management style statement would be repeated by most organizations throughout the report. We felt the additional G4 disclosures for DMAs in some cases to be too prescriptive rather than principle based. Furthermore, we recommend guidance is provided on the application of the GRI reporting principles to the DMAs disclosures. Additional information /enhanced clarity is needed regarding the relevance of these new disclosure items will be useful. We found these proposed changes in disclosure could possibly result in excessive disclosure which may not add value to the reader. GRI reporting should focus on communicating the material matters - it is not clear that adding a requirement of disclosure at such a granular level (aspect level) would be useful to readers. Based on the table on page 8 of the Guide, there are approximately 44 aspects that would require disclosure on management approach. Furthermore, preparers of this disclosure would likely have difficulty in keeping up with the increased disclosure which raises some questions about the practical application of this change. While the direction of the proposed changes to the DMAs is commendable, with its focus on the most material issues and the ability to provide a single disclosure for material issues managed in the same way and some elements are reasonable, the level of detail would be burdensome and would require very lengthy -- and frankly very dry -- reporting that would be of interest to only a few stakeholders. While the GRI G4 s shift to requiring Disclosures on Management Approach (DMAs) for material issues only is a welcome change, the current exposure draft does not go far enough to forestall unduly repetitive and lengthy narratives. Specifically, the proposed Guidelines fall short in keeping a focus on concise and non-duplicative reporting: Business Latin Business Business Business Asia Asia Asia for academic purposes Ideas generator and public commentator/r eporter Guidance & Support Second G4 Public Period: Submissions Page 837 of 2491