Contents
1 Introduction ............................................................................................................................................. 3
1.1
About this Document .................................................................................................................... 3
1.2
Background ................................................................................................................................... 3
2 G4 Exposure Draft Consultation............................................................................................................... 6
2.1
In Accordance – G4 Exposure Draft .............................................................................................. 6
2.2
In Accordance – Focused Exposure Draft ..................................................................................... 8
2.3
Boundary ....................................................................................................................................... 9
2.4
Governance ................................................................................................................................. 11
2.5
Disclosures on Management Approach (DMA) .......................................................................... 13
2.6
Supply Chain................................................................................................................................ 15
3 Thematic Revisions Consultation ........................................................................................................... 17
3.1
Greenhouse Gas (GHG) Emissions .............................................................................................. 17
3.2
Anti-corruption ........................................................................................................................... 18
4 Other Feedback ...................................................................................................................................... 19
Annex I. Methodology for Analyzing Feedback .......................................................................................... 21
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1
INTRODUCTION
1.1
ABOUT THIS DOCUMENT
This Basis for Conclusions document has been prepared by GRI’s Secretariat and presents a high level
summary of the feedback collected during the second G4 Public Comment Period (PCP) on the G4
Exposure Draft and the Thematic Revisions on Anti-corruption and Greenhouse Gas (GHG) Emissions,
and indicates how GRI addressed the feedback received.
During the second G4 PCP, GRI collected over 2000 pages of written feedback from a total of 791
submissions received either through online or offline methods. The results of the qualitative analysis of
these submissions are presented in this Basis for Conclusions document, which complements the series
of Submissions documents available for download on the GRI website. The series of Submissions
documents presents a list of individuals and organizations that submitted feedback during the PCP, the
contents of all online and offline submissions received, the results of the quantitative analysis of the
submissions, and the notes taken during G4-related Workshops.
For the qualitative analysis, every textual submission received was reviewed by a number of Secretariat
staff members, to establish commonalities and to identify all individual feedback points. All textual
submissions were then categorized into themes. Please refer to Annex I for a detailed description of the
methodology followed.
This document presents an overview of the majority trends observed for each content area across the
submissions collected. The document is organized by content area and by themes. For each of the
content areas, a summary of the proposed changes, a description of the themes identified, and GRI’s
response to each of the themes are provided.
1.2
BACKGROUND
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’ perspectives –
to be included in the sustainability reports
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•
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
GRI’s Due Process1, 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 PCP for G4. GRI also asked individuals
and organizations to register their interest in taking part in the first G4 PCP. 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 GRI’s 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:
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
Application Levels
Boundary
Disclosure on Management Approach
Governance and Remuneration
Supply Chain Disclosure
Anti-corruption
Greenhouse Gas (GHG) Emissions
As defined in GRI’s Due Process, Working Groups are formed by the Secretariat, under the direction of
the Board of Directors and in consultation with the Technical Advisory Committee (TAC)2. Selection
criteria include expertise, stakeholder diversity, and availability. Proposed revisions to the text of the
Guidelines or Protocols are drafted by Working Groups as outlined under the overarching Due Process
principles. The TAC is responsible for reviewing proposals put forth by Working Groups.
1
GRI’s Due Process for the GRI Reporting Framework is available on GRI’s website www.globalreporting.org
The Technical Advisory Committee (TAC) provides GRI’s Board of Directors and network with high-level, expert advice on
reporting, and sustainability.
2
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On 25 June 2012, GRI launched the second G4 PCP, 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 proposed significant changes
to the Guidelines presented in the G4 Exposure Draft are summarized under ‘G4 Exposure Draft
Consultation’. 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.
In addition, 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 into standard disclosures and guidance, to
facilitate the identification of the reporting requirements by organizations and to offer guidance in a
user-friendly way.
The document was available for comment from 25 June to 25 September 2012.
On 14 August 2012, GRI launched an Additional PCP 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 and are
summarized under ‘Thematic Revisions Consultation’.
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 were launched in May 2013.
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2
G4 EXPOSURE DRAFT CONSULTATION
2.1
IN ACCORDANCE – G4 EXPOSURE DRAFT
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 to embark on a journey, in most cases on a
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. They were replaced in the G4 Exposure Draft by 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.
Theme 1: The ‘in accordance’ criteria proposal is seen as too onerous and difficult
Comments signaled that the minimum reporting requirements for the ‘in accordance’ model proposed in
the G4 Exposure Draft appeared to have increased significantly compared to the Application Levels. The
requirements on Profile, Strategy, Governance Disclosures and the Supply Chain Disclosures particularly
were noted as being too onerous and some of the proposed items were considered not feasible to report.
Some respondents flagged the possibility that the inability to comply with all of the requirements could
result in a disincentive to prepare a sustainability report.
Theme 2: Support to move away from the labels A, B, C
The proposal to discontinue the Application Level labels A, B, and C was widely supported by those who
offered inputs on this topic, as “this is misinterpreted as a grade”. There were also comments that would
like to see the A, B, C Application Level system retained, with levels renamed. A multi-level approach does
offer the advantage of encouraging commencement of reporting and progression through the different
levels. It is also seen as an advantage for experienced reporters who can also demonstrate a “higher
level”.
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Theme 3: Disadvantages are seen for SMEs and other organizations with limited resources
Some comments referred to the ‘in accordance’ requirements as a burden, and a disincentive to reporting
particularly for SMEs and organizations with limited resources, for example, organizations from developing
countries and public agencies.
Theme 4: Sector related reporting requirements in the ‘in accordance’ proposal
Comments suggested that the Guidelines should feature industry/sector-specific Core Aspects and
Additional Aspects. Comments also pointed out that, with the ‘in accordance’ model as presented, all
organizations subject to reporting with Sector Supplements would have to meet more requirements to
state their ‘in accordance’ status compared with other sectors, which creates inequality. It was suggested
that GRI should issue a timeline explaining when new Sector Supplements will be created for sectors
which are not currently covered (GRI has currently published 10 Sector Supplements). Other comments
considered that the Sector Supplement disclosure requirements in the ‘in accordance’ criteria should not
be included because some sectors are not represented in the existing Supplements and others are not
properly represented.
Theme 5: The required CEO statement in the ‘in accordance’ proposal is seen as too challenging
A number of comments considered such a sign-off as not feasible for legal reasons, others questioned
whether or not a lower level of sign-off is sufficient or why such a CEO statement is needed. The most
prominent reason for opposition concerned the requirement to include an explanation for omitting data.
This was seen as requesting too much detail, unnecessary or not feasible for a CEO statement. In general,
information on omissions was seen as useful, but not as part of the CEO statement.
THE OUTCOME :
In response to the comments received for each of the above themes and based on the feedback provided
by GRI’s Governance Bodies, the GRI Board of Directors proposed to replace the ‘in accordance’ model
presented in the G4 Exposure Draft with a new model which aimed to promote the essence of a
sustainability report, without representing a barrier to reporting to any organization, of any size or sector,
or to beginners or experienced reporters. The proposed draft revision was made available for additional
consultation in March 2013 to a selected group of stakeholders, including stakeholders who provided
feedback on the ‘in accordance’ proposal during the second G4 PCP and other stakeholders involved in the
development of G4. The outcome of this consultation is presented next.
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2.2
IN ACCORDANCE – FOCUSED EXPOSURE DRAFT
The revised model offered two alternatives available for an organization to claim that its report is ‘in
accordance’ with the G4 Guidelines: a ‘Core’ model (containing the essential elements of a sustainability
report) and a ‘Comprehensive’ (or ‘strategic’) model. Each alternative was a standalone model aimed at
answering the reporting needs of different reporters in ultimately meeting their stakeholders’
information needs. A benefit in having only two alternatives (i.e., no intermediary alternative) was that
it avoided the suggestion that there could be a ‘gradation’ in levels, a concern that was expressed by
different stakeholders with the existing Application Levels. There was also no expectation, intended or
otherwise, that organizations who report under the ‘Core’ model should transition to the
‘Comprehensive’ model over a period of time.
In light of the feedback received, the required statement signed by the highest governance body or
Chief Executive Officer (CEO) was deleted from the revised ‘in accordance’ model.
Theme 1: The ‘Core’ option does not contain the essential elements of a sustainability report
Comments received indicated that the proposed revised model for the ‘Core’ option did not contain the
essential elements of a sustainability report. Relevant elements missing included Strategy and Analysis
disclosures, the CEO Statement and a set of Indicators to report against, among others.
THE OUTCOME :
GRI addressed these comments by requiring one of the Strategy and Analysis disclosures for the ‘Core’
option, and by requiring ‘Core’ reporters to report at least one Indicator for each of the material Aspects
identified.
Theme 2: Naming conventions for the ‘in accordance’ options
Respondents were invited to suggest alternative names for the ‘Core’ and ‘Comprehensive’ options of the
‘in accordance’ model. About half of the respondents provided alternative names, the most commonly
mentioned being ‘Basic’ and ‘Advanced’.
THE OUTCOME :
Given that the number of comments received to change the name of the options was not significant – 50%
were not opposed to the proposed names – and that no majority trend for alternative names was
identified, GRI decided to maintain the proposed names ‘Core’ and ‘Comprehensive’.
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2.3
BOUNDARY
The process outlined in the 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 the 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 process
consisted of (1) a map of the organization’s value chain(s), (2) a list of material Aspects (and where the
impacts occur within the value chain(s)) and (3) related Standard Disclosures to be included in the
sustainability report. The Standard Disclosures included the core Indicators which were required to be
disclosed by the organization; if a core Indicator was not disclosed, the organization was required to
explain the reasons why it was not provided.
Theme 1: Difference between Aspect and topic not clear
Comments received indicated that the difference between the terms ‘Aspect’ and ‘topic’ was not clear in
the G4 Exposure Draft and the preference would be to adhere to one term only, whether that is ‘topic’,
‘Aspect’, or ‘issue’.
THE OUTCOME :
GRI addressed these comments by defining both terms in the Guidelines and reviewing the use of these
terms throughout the text.
Theme 2: Value chain reporting is not feasible
Comments were received as to the feasibility of reporting impacts along the value chain for both small and
large organizations. Although comments received showed support for a shift in the focus of the reporting
boundary to impacts rather than legal ownership, mapping the value chain as the first step for defining the
content of the report, and reporting on every core Indicator for every material Aspect across every value
chain element as required by the ‘in accordance’ criteria was considered to be too onerous and unrealistic
due to data availability and quality and the amount of resources that would need to be invested.
THE OUTCOME :
GRI addressed these comments by adjusting the sequence of the steps to define the content of the report,
in which the identification of relevant topics and where they occur (boundary) – whether in entities within
the organization (those entities included in the organization’s consolidated financial statements) or
outside of the organization (e.g., suppliers, consumers, distributors) – comes at the beginning of the
process, after which the material Aspects and their boundaries are selected and validated. When defining
the boundary of material Aspects outside of the organization, entities are grouped geographically or by a
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meaningful category (such as suppliers in country X). G4 also allows for reporting on limitations regarding
the boundary of material Aspects and advises organizations to report Indicators for material Aspects for
which impacts occur outside of the organization where data quality and availability allows. In addition, the
requirement to describe an organization’s value chain was removed.
Theme 3: Comparability with other reporting mechanisms
Comments received indicated that the absence of the notion of a minimum reporting boundary that aligns
with that of financial reporting could result in confusion and reduce comparability for reporting
organizations and report users. In addition, if boundaries can vary for each material Aspect, this approach
runs the risk of confusing the reader and reducing comparability. The idea of expanding the reporting
boundaries beyond an organization’s control and influence was viewed as a positive direction only if the
core of such reporting aligns with that of financial reporting and organizations are then invited and
encouraged to expand their reporting boundary to impacts beyond their influence and control.
THE OUTCOME :
GRI addressed these comments by emphasizing in G4 that the traditional financial reporting boundary of
an organization should serve as the starting point for sustainability reporting purposes. An organization
then moves onto identifying material Aspects and related impacts outside of the financial reporting
boundary. In addition, for each material Aspect identified, organizations are requested to list the entities
as included in their consolidated financial statements for which the Aspect is material.
Theme 4: Value chain terminology
Comments were received as to the confusion in the examples provided for the value chain elements in the
G4 Exposure Draft which combined elements of a traditional value chain (as most notably developed by
Michael Porter) and a stakeholder mapping exercise. In addition, comments were received as to the
confusion in the use of and difference between the terms ‘supply chain’ and ‘value chain’.
THE OUTCOME :
GRI addressed these comments by abandoning the use of the term ‘value chain’ in G4 and using instead
the distinction of ‘within’ and ‘outside of’ the organization.
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2.4
GOVERNANCE
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.
Theme 1: The governance and remuneration disclosures are too onerous
Comments received indicated that the governance and remuneration disclosures were onerous and
disproportionate when compared to the number of disclosures requested under other sections of the G4
Exposure Draft. The requirements would lead to lengthy reports and guidance would be needed as to the
level of detail expected for these disclosures. In addition, some comments indicated that many of the
requirements were not available at the global level for multinational corporations or would require
confidential information, especially for private and family-owned businesses.
THE OUTCOME :
GRI addressed these comments by combining disclosures in a meaningful way in order to avoid repetition
and to reduce the number of overall disclosures, and by providing a rationale as to the relevance to
sustainability for the governance and remuneration disclosures.
Theme 2: Alignment with other reporting mechanisms
Comments received indicated that some of the information requested by the governance disclosures was
already being reported in other publicly-available documents and that reporters should only be required
to report on governance and remuneration as per already existing national financial requirements.
THE OUTCOME :
GRI addressed these comments by clarifying in the G4 Guidelines that if some of the requirements are
already reported in other publicly-available documents, reporters may simply add a specific reference to
where the relevant information can be found in the public domain as a valid response to such
requirements.
Theme 3: Feasibility to report on remuneration disclosures and ratios
Comments were received as to the sensitive nature of the remuneration disclosures from the confidential
information standpoint and security concerns for some regions, and as to the dedicated resources that
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would be needed to compile and prepare the requested data. In addition, comments identified a lack of
sufficient definitions in order to provide comparable and meaningful disclosures between organizations.
Comments received also indicated that the remuneration disclosures should be kept separate from the
organization’s governance mechanism and the ratios should be included as Indicators under a new Aspect
and selected based on materiality considerations.
THE OUTCOME :
GRI addressed these comments by combining disclosures in a meaningful way in order to reduce the
number of overall disclosures, by re-purposing reporting requirements as guidance, and by deleting
disclosures based on an assessment of the cost and effort of collecting this information in relation to its
value.
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2.5
DISCLOSURES ON MANAGEMENT APPROACH (DMA)
The DMA 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 DMA should be provided at the Aspect level to reflect
management practices. However, when a topic is managed at a different level, the DMA should then 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).
Theme 1: Confusion between disclosure requirements and guidance
Comments received indicated that the difference between disclosure requirements and guidance for the
DMA was not clear, and that the DMA guidance was misinterpreted as a disclosure requirement to be met
in order to be ‘in accordance’. Comments suggested to improve the layout of the Guidelines in order to
make the difference between disclosure requirements and guidance clearer.
THE OUTCOME :
GRI addressed these comments by clearly separating the disclosure requirements from the guidance by
presenting these in two separate documents, the G4 Reporting Principles and Standard Disclosures and
the G4 Implementation Manual respectively.
Theme 2: DMA is overwhelming
Comments received suggested that the proposed DMA structure is too detailed and contains too much
guidance. Addressing every DMA guidance item for every material topic would result in lengthy and
repetitive reports.
THE OUTCOME :
GRI addressed these comments by clearly separating the disclosure requirements from the guidance by
presenting these in separate documents, the G4 Reporting Principles and Standard Disclosures and the G4
Implementation Manual respectively.
Theme 3: Reporting DMA at different levels
Comments received expressed concern with reporting the DMA for each Aspect as organizations often
have similar management approaches across several Aspects. The DMA would be unnecessarily lengthy
and repetitive in cases where organizations would repeat the same disclosures for different Aspects.
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THE OUTCOME :
GRI addressed these comments by clarifying in the introductory section for the DMA that the DMA should
be reported at the level at which the organization manages an Aspect and that if an organization’s
management approach or its components apply in general to more than one Aspect, such DMA can be
provided once in the report.
Theme 4: Aspect-specific DMA
Comments were received as to the feasibility of the Aspect-specific DMA requirements due to the level of
detail requested. In addition, Aspect-specific DMA requirements are inconsistent as they are not provided
for all Aspects in the G4 Exposure Draft.
THE OUTCOME :
GRI addressed these comments by re-purposing the required Aspect-specific DMA as guidance.
Organizations start by reporting the Generic DMA for the material Aspects and can then use the Aspectspecific DMA guidance to report their management approach for that Aspect in more detail, when
available.
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2.6
SUPPLY CHAIN
New and amended disclosures on the supply chain were included in the G4 Exposure Draft. These
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.
Theme 1: Feasibility of reporting on the supply chain requirements
Comments were received as to the feasibility of reporting on some of the disclosures, because some of the
information was deemed to be confidential due to its proprietary nature or because it did not necessarily
reflect an organization’s responsibilities or its approach to sustainability practices. In addition, some
questioned the need for the large number of disclosures, including the related level of detail, as they
believed it could be difficult to provide this information due to the cost and difficulty in collecting the data,
as well as the availability and reliability of such data.
THE OUTCOME :
GRI addressed these comments by re-purposing required Aspect-specific DMA, and some of the reporting
requirements and breakdowns of information in Indicators as guidance. Some Indicators were deleted
based on an assessment of the cost and effort of collecting this information in relation to its value, and the
scope of the other Indicators was reduced. In addition, definitions and terminology were adjusted for
greater clarity.
Theme 2: Placement of supply chain content
Comments were received as to the repetitiveness and placement of the supply chain disclosures. Some
considered that the supply chain disclosures should be placed together in one section of the Guidelines,
and that the 12 Indicators on screening, assessment and remediation cross cutting through different
Categories should be combined into a set of three Indicators to cover the entire range of potential supply
chain impacts so as to reduce complexity and make it easier to locate the supply chain disclosures in the
Guidelines. In case the proposed approach is maintained, a summary of the supply chain disclosures could
be offered in order to help users locate the different disclosures easily.
THE OUTCOME :
GRI addressed these comments by including a summary of the supply chain related disclosures under the
quick links section of the G4 Guidelines, making it easier for reporters to locate these. G4 includes supply
chain disclosures cutting through different Categories of the Guidelines as it is more intuitive and
pragmatic to consider supply chain impacts as one factor in a materiality assessment of an entire Category
and its Aspects.
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Theme 3: Prioritizing suppliers for reporting
Comments were received as to how to prioritize suppliers for reporting and as to the feasibility of
reporting on suppliers across different tiers. Comments suggested that organizations should only report
on a selected group of suppliers chosen based on either ‘material suppliers’ or suppliers with ‘significant
impacts’ (as per the Materiality Principle), large suppliers (e.g., by spending or by volume), or left to the
discretion of the organization.
THE OUTCOME :
GRI addressed these comments by sharpening the focus on significant impacts in the supply chain in the
G4 text – meaning that organizations need only report on significant economic, environmental and social
impacts in the supply chain. In addition, the emphasis on materiality has been woven into the different
elements of G4, such as the new ‘in accordance’ model or the Generic DMA.
Theme 4: Qualitative vs. quantitative data
Comments were received as to the level of prescriptiveness of the supply chain reporting requirements
and the large amount of quantitative performance data requested as opposed to more qualitative and
descriptive type of data on management practices.
THE OUTCOME :
GRI addressed these comments by assessing the right balance between narrative and quantified
information for supply chain reporting and by re-purposing many reporting requirements and breakdowns
of information in Indicators as guidance.
Theme 5: Alignment of definitions with other standards
Comments were received indicating the need for aligning the definitions of ‘supply chain’ and ‘supplier’
with that of other standards, such the standards developed by the International Organisation for
Standardisation (in particular ISO 26000 and ISO 9000), World Resources Institute and the World Business
Council for Sustainable Development’s GHG Protocol, and RobecoSAM’s Dow Jones Sustainability Index.
THE OUTCOME :
GRI addressed these comments by aligning the definition of ‘supply chain’ with that of ISO 26000 and the
definition of ‘supplier’ with that of ISO 9000. The definition of ‘supplier’ was slightly amended so as to
include entities along the supply chain.
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3
THEMATIC REVISIONS CONSULTATION
3.1
GREENHOUSE GAS (GHG) EMISSIONS
The GHG Emissions Thematic Revision proposed a number of changes mainly covering disclosures under
the Aspects of Energy and Emissions in the Environmental Category. Disclosures in other areas of the
Guidelines relevant to reporting GHG emissions were also included. The proposed revisions intended to
support reporting and alignment 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 and, in doing so, further alignment with
the CDP questionnaire was aimed for. Energy Indicators were modified to align with the GHG Emissions
Indicators for more streamlined reporting. Intensity Indicators were added for both energy and GHG
emissions.
Theme 1: GHG emissions-related disclosures are too onerous
Comments received indicated that the GHG emissions reporting requirements for methodology,
conversion factors, and the level of disaggregation suggested were considered to be too detailed. While
reporting requirements should strive for more clarity in a concise way, clarity should not be confused with
granularity of information requirements. Reporters should be given sufficient flexibility to report the
information in the way which makes most sense for the context of the reporting organization.
THE OUTCOME :
GRI addressed these comments by allowing for flexibility in reporting methodologies, conversion factors
and disaggregation levels, without requiring extensive detailed disclosures that already exist within other
frameworks.
Theme 2: Alignment with other reporting mechanisms and redundant reporting
Comments received suggested that the proposed GHG Emissions requirements closely resembled the
reporting requirements by the Carbon Disclosure Project, and, therefore, would be repetitive of already
existing reporting mechanisms.
THE OUTCOME :
GRI addressed these comments by clarifying in the G4 text that if some of the requirements are already
reported in other publicly-available documents, reporters may simply add a reference to where the
relevant information can be found in the public domain as a valid response to such requirements.
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3.2
ANTI-CORRUPTION
The Anti-corruption Thematic Revision 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.
Theme 1: The Anti-corruption and Ethics disclosures are too onerous
Comments were received as to the feasibility of reporting on some of the Anti-corruption and Ethics
disclosures, because the detail requested would impose a significant reporting burden on organizations
and because the benefits of this expected increased transparency to stakeholders would not outweigh the
costs of disclosing the requested information. While reporting requirements should strive for more clarity
in a concise way, clarity should not be confused with granularity of information requirements.
THE OUTCOME :
GRI addressed these comments by re-purposing required Aspect-specific DMA, and some of the reporting
requirements and breakdowns of information in the Indicators and Ethics disclosures as guidance. Some
requirements were deleted based on an assessment of the cost and effort of collecting this information in
relation to its value, and definitions and terminology were adjusted for greater clarity.
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4
OTHER FEEDBACK
The purpose of the second G4 PCP was to gather feedback on the content areas subject to revision
during the G4 development process. In addition, a number of questions were put forward to seek
comments on the structure and overall impressions of the G4 Exposure Draft. However, a number of
comments received did not relate to any of the revised content areas issued for public comment. These
comments urged GRI to update the Guidelines in different areas such as plastics, sustainability context,
occupational health and safety, indigenous peoples or disabled persons.
THE OUTCOME :
As outlined in GRI’s Due Process3, priorities for review and revision of the Guidelines are set by GRI’s
Governance Bodies based on input from different sources. Any proposed revisions to the text of the
Guidelines are drafted by global multi-stakeholder Working Groups and draft revisions are made
available for public comment. Suggestions to update or include new content in areas other than those
addressed by GRI’s Working Groups cannot be readily addressed for that Guidelines’ iteration – as such
revisions need to undergo GRI’s Due Process. These additional suggestions are recorded and monitored
by GRI’s Governance Bodies and considered as input when setting priorities for future revisions of the
Guidelines.
During the Preparatory Phase of the G4 development process, GRI gathered views on G4’s potential
structure and content. During a ‘Call for sustainability reporting topics’, which ran from May to July
2011, suggestions to update or include new content on many different topics were received.
During the first G4 Public Comment Period, which ran from 26 August to 24 November 2011, the 12
topics that received broad support during the ‘Call for topics’ were re-exposed to gauge levels of
support with a broader audience. Respondents could suggest additional topics for inclusion or revision.
Suggested topics were shortlisted according to the number of respondents that mentioned them; those
with more than ten mentions were selected. From a total of 17 topics analyzed that received broad
support, the Secretariat concluded that eight of them (eco-innovation, remuneration and performancebased pay, plastics, packaging and waste, high impact event management and preparedness, supply
chain sustainability management and performance, green building practices, community impacts and
development and animal rights and welfare) were either sector-specific, or would be covered by work
being done by already established G4 Working Groups (on Application Levels, Boundary, Disclosure on
Management Approach, Governance an Supply Chain Disclosure).
The international level of agreement around reporting metrics on the other nine topics (anti-corruption,
greenhouse gas emissions, biodiversity, occupational health and safety, life cycle analysis (LCA),
chemicals of concern, water, disabled persons’ rights and children’s rights) was investigated and, after
consultation with GRI’s TAC and Board of Directors, the Secretariat started recruiting experts for four
3
GRI’s Due Process for the GRI Reporting Framework is available on GRI’s website www.globalreporting.org
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Working Groups on Anti-corruption, Biodiversity, Occupational Health and Safety and Greenhouse Gas
(GHG) Emissions.
GRI was not able to recruit a balanced Working Group in terms of variety of stakeholders and regions for
the topics of Biodiversity and Occupational Health and Safety in time for their inclusion in G4. The
formation of these Working Groups was therefore postponed.
GRI has committed to prioritizing work on the following topics not covered by the G4 updates –
biodiversity, occupational health and safety, life cycle analysis (LCA), chemicals of concern, water,
disabled persons’ rights and children’s rights. Other topics suggested during the second G4 PCP will be
monitored by GRI’s Governance Bodies and considered as input when setting priorities for future
revisions of the Guidelines.
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ANNEX I. METHODOLOGY FOR ANALYZING FEEDBACK
During the second G4 PCP, GRI invited any interested party to provide feedback on the proposed
updates to the Guidelines.
GRI gathered feedback on the G4 Exposure Draft and Thematic Revisions through two formal channels:
1. The online GRI Consultation Platform, which included general and specific survey questions and
also featured a document review function for users to make comments on the presented
documents.
2. Letters and e-mails to the Secretariat
The workshops held worldwide by GRI were an additional means to publicize the PCPs, and gather
feedback.
GRI posed 27 questions regarding the G4 Exposure Draft; eight general questions on structural or overall
impressions of the G4 Exposure Draft, and 19 specific questions on the content areas of Application
Levels, Boundary, Disclosure on Management Approach, Governance and Remuneration, and Supply
Chain Disclosure. For the Thematic Revisions, GRI posed 7 specific questions on the proposals for Anticorruption and Greenhouse Gas (GHG) Emissions.
Three formats were used for the questions:
 Questions with the option of selecting ‘Yes’ and no further comments, or selecting ‘No’ and
providing 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
For the submissions to both PCPs, the Secretariat prepared two documents for use by the Working
Groups and TAC members when discussing the feedback. The first document contained a quantitative
and a qualitative analysis of the submissions (see steps 1 and 2 below), and the second presented,
verbatim, all the textual submissions4 (see step 3 below).
All answers to each of the questions posed online, and each line of all comments submitted online and
offline, was analyzed by the Secretariat.
4
Submission: an input of PCP feedback received by GRI through the Consultation Platform, letters or e-mails to the Secretariat.
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The analysis followed these steps:
1. Quantitative analysis
The quantitative analysis generated statistics about the submissions, in the form of total
numbers, percentages, and breakdowns by online and offline, constituency, region, personal,
and organizational submissions. Collective submissions5 were highlighted.
Detailed statistics were also generated for each of the 37 general and specific questions posed
online, in the form of total numbers, percentages, and breakdowns by constituency, region,
personal, and organizational submissions.
The results of the quantitative analysis can be found in the Submissions documents series.
2. Qualitative analysis
The submissions received through the GRI Consultation Platform, letters and e-mails were
analyzed.
a) Categorization
For the qualitative analysis, every textual online and offline submission was reviewed by at
least two staff members of the Secretariat, to establish commonalities and identify all
individual feedback points.
All textual submissions were then categorized into themes. Nvivo Qualitative Research
Software and Excel were used for this procedure.
Each categorization into a theme was double-checked by other Secretariat staff members,
to ensure that the categorization was correct.
Finally, in cases where the feedback received at G4 workshops, held worldwide by GRI, did
not support the themes identified from the online and offline submissions, the nature of the
discrepancy was noted for consideration by the Working Groups and the TAC.
b) Constituency and regional analysis of textual feedback
Constituency and regional breakdowns were generated for the themes identified in more
than 10 submissions.
Collective submissions were highlighted for each theme. The Labor constituency submitted
one coordinated global response to the second G4 PCP, and its feedback was highlighted.
5
Submission representing the view of more than one individual and/or organization, with a number of signatories.
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3. Verbatim submissions:
The Secretariat prepared a Verbatim Responses document, presenting all textual submissions
exactly as received and grouped by theme. This enabled the Working Groups and the TAC to
understand the categorization and the constituency/regional analysis, and form a view on the
underlying feedback. It also allowed for the discussion of submissions during meetings.
The verbatim submissions can be found in the Submissions documents series.
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