The GRI G4 deadline is looming and in this issue of Directions, Salterbaxter MSLGROUP looks at the first movers, frame the problem and break the decision down into a series of next steps to ensure that the transition is seamless and timely.
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Cutting Through the Complexity of GRI G4
1. WINTER 2014
Cutting through the complexity
of GRI G4: A roadmap to the
December 2015 deadline.
INSIDE
The GRI G4 deadline is looming
and in this issue of Directions,
we look at the first movers, frame
the problem and break the decision
down into a series of next steps
to ensure that the transition is
seamless and timely.
Cutting
through the
complexity
of GRI G4
NOW DECEMBER 2015
A roadmap to the December 2015 deadline
2. hen the GRI G4 guidelines were first released, the
implementation deadline of the end of December
2015 seemed a long way off. Now that we are
heading towards the final year of reporting under
the GRI G3 and 3.1 guidelines, the decision to go
early or wait until the final countdown is vexing
quite a few reporters. In this issue of Directions,
we look at first movers, frame the problem and
SHOULD I STAY
OR SHOULD I GO?
break the decision down into a series of next steps to help ensure that
the transition is seamless and timely.
Looking globally at industries, brands and countries, we can clearly see
a move towards G4 adoption and the role that governments and exchanges
play in encouraging reporting transparency and disclosure.
For a few brave reporters who have already taken the plunge, it has been
a journey of discovery. My conversation with some of these early adopters
provides some first-hand insight and advice.
We know you might be wondering whether to go for GRI G4 or not. That’s
why we’ve created a decision tree, to answer some of the key questions you
may have, as well as case studies to help inform your own roadmap to the
December 2015 deadline.
1
Cutting through the complexity of GRI G4
FAY HOGG
Head of Reporting
CONTENTS
1 Introduction
2 First movers
3 Decision tree
4 Brands who have made the journey
6 Conclusions
7 About SALTERBAXTER MSLGROUP
INTRODUCTION
3. FIRST MOVERS
So far in 2014, more than 35% of GRI reporters have made the leap to G4. Depending on
government-, market- and sector-led initiatives, we can see how reporters in some
parts of the world have come further than others.
BY COUNTRY, THERE ARE A FEW SURPRISES
Countries such as the United States, Colombia, Brazil, South
Africa and the Netherlands are leading the way. The US has
market- and government-led initiatives to address corporate
disclosure requirements; they also have a lot of big companies.
Brazil and the Netherlands both have market- and government-led
reporting initiatives, respectively. But Colombia? Yes, that’s
a surprise. Back in the late 90s their government decided that
a Green Economy could give them a competitive advantage.
National policy followed that specifically promotes the
disclosure of information using the GRI guidelines. Colombia
is also one of the GRI’s Focal Points that were set up to actively
engage organisations in the development of sustainability
reporting. Those efforts appear to be paying off.
TOP 10 INDUSTRIES
(Based on total GRI reports)
In the sector table, industry
heavies who take on the
lion’s share of impacts and
regulatory requirements are
producing the highest number
of G4 reports. This is more
or less proportional to the
inter-industry take-up of
the GRI framework.
What about countries like France, South Africa and Denmark,
who also have extra financial reporting requirements for listed
or state-owned companies? Many reporters in these countries
are considering the additional value of developing their reporting
to meet international standards against simply being compliant
with local legislation.
The truth is: governments have a key role in setting the baseline
for companies to report on social and environmental issues.
Many work in collaboration with the GRI in drafting legislation.
Some stock exchanges actively promote the GRI framework for
guidance. The move towards rules-based reporting is gaining
ground, and alignment with the GRI framework puts
organisations in a good place should environmental and social
reporting legislation become mandatory.
Cutting through the complexity of GRI G4
Source: Reports listed on the GRI database
and published in 2014 and correct as of
21st October 2014
164
150
66 54
UK 30% (44)
51
39 30 33 16 13
62 55
34 34 25 20 17 14
14 9
CANADA 29% (65)
SPAIN 32% (75) SWITZERLAND 27% (67)
SOUTH AFRICA 42% (43)
UNITED STATES 35% (165)
BRAZIL 34% (97)
COLOMBIA 56% (43)
NETHERLANDS 33% (70)
GERMANY 17% (69)
TOP 10 GRI REPORTING
COUNTRIES
% of GRI reports that
are G4 (total GRI reports
in brackets)
2
G4 reports
G3 or G3.1 reports
ICT & TECHNOLOGY
RETAIL
MINING AND MATERIALS
TELECOMMUNICATIONS
CONSTRUCTION AND
ENGINEERING
CHEMICALS
HEALTHCARE AND
PHARMACEUTICALS
FOOD AND BEVERAGE
PRODUCTS
ENERGY AND UTILITIES
FINANCIAL SERVICES
4. DECISIONS, DECISIONS...
Have you decided?
Here’s the full journey.
IS YOUR SECTOR COVERED
BY ONE OF THE 10 SECTOR
DISCLOSURES?
These are: Airport operators, Food
processing, Construction and real
estate, Media, Electric utilities,
Mining and metals, Event organisers,
NGO, Financial services, Oil and gas.
DO YOU BASE
YOUR CURRENT
REPORTING ON
MATERIAL ISSUES?
Do the criteria for prioritising the
material issues identify those that:
• Reflect the organisation’s significant
economic, environmental and social
impacts; or
• Substantively influence the
assessments and decisions
of stakeholders
As ‘Core’ and all
indicators for each
material aspect
PREPARE
REPORT
IS YOUR REPORT
EXTERNALLY ASSURED?
Conduct a gap analysis against
the GRI criteria. This is helpful to
get ready for the December 2015
deadline.
YES
The Sector Disclosures have been
reorganised to fit this structure
but contain no new content.
NO
No further action required.
Direct Management
Approach and at least
one indicator for each
material aspect
Include a
statement
in report
YES
A reference to the external assurance
statement should be included in the
Content Index for each Standard
Disclosure Item.
NO
Consider the value of assurance
or other ways to validate the report,
e.g. independent expert panel review
or include stakeholder feedback.
Cutting through the complexity of GRI G4
3
YES
There are two ‘in accordance’ options
to choose from:
Core and Comprehensive.
The options reflect compliance with
guidelines rather than business
performance.
NO
Materiality is a pivotal principle of the
GRI G4 guidelines. See our publication
‘Beyond the Matrix’ for further insight
on tackling materiality.
G4 CORE
‘Core’ contains the essential
elements of a sustainability report: its
economic, environmental, social and
governance impacts. New elements
of G4 include disclosures on strategy,
governance, ethics and integrity.
G4 COMPREHENSIVE
Builds on ‘Core’ by requiring
additional disclosure on strategy,
governance, ethics and integrity.
You must report on the Disclosures
on Management Approach (DMA)
and all indicators for each identified
material aspect.
G4 NOT YET READY
You can include the following
statement in your report: ‘This report
contains Standard Disclosures from
the GRI Sustainability Reporting
Guidelines’, along with a list of the
disclosures and their location.
5. BRANDS WHO HAVE MADE
THE JOURNEY TO GRI G4
STORA ENSO, TERHI KOIPIJÄRVI,
HEAD OF GLOBAL RESPONSIBILITY, FINLAND
The Finnish wood pulp, paper and packaging producer
has been reporting using the GRI framework since 2003.
For their 2013 report, published in February of this year,
they took a practical approach to move to G4 reporting,
in accordance with the ‘comprehensive’ level.
Having reported for a decade using G3, Stora Enso took the
decision to go for G4 ahead of the deadline. The company’s
ambition is to be a frontrunner in sustainability, and in
reporting, and it acknowledges that the new G4 framework
brings with it interesting developments to move their
reporting forward.
Terhi Koipijärvi, Stora Enso’s Head of Global Responsibility,
explained that the company took a practical approach to
moving to G4. “We conducted a gap analysis to see what was
needed, and then systematically went through each of those
areas with content owners,” she explained. Materiality was,
of course, central to the process, along with incorporating
the results of an internal project around value-chain thinking.
Stora Enso conducts a thorough materiality review, using an
online advisory panel. In 2013, the company reached over 600
stakeholders in over 40 countries using this tool, with a
majority of those being external stakeholders. In addition,
the company analysed feedback from investors, customers
and the global and social media landscapes.
Terhi points to some clear benefits of moving early to G4. “Our
environmental reporting has been made more concise, while
we have given more attention to the social responsibility
aspects that were emphasised by our stakeholders.”
Stora Enso took a practical approach to the transition to G4.
Terhi’s advice? “Gain leadership commitment to the process,
conduct a gap analysis, and invest time in the materiality
analysis up front,” she says.
STANDARD BANK, KARIN IRETON,
HEAD OF SUSTAINABILITY MANAGEMENT, SOUTH AFRICA
Standard Bank is a leading African financial services
provider, based in South Africa. Market-led initiatives there,
have paved the way for the bank’s transition to G4 reporting
at a core level.
The King Code is South Africa’s definitive approach to good
corporate governance. Now on its third iteration, the journey
to King III has put listed companies in a strong position when
it comes to governance and stakeholder engagement
because they are required to produce an Integrated Report.
“This reporting context has definitely ‘helped’ their transition
to G4,” says Karin Ireton, Head of Sustainability Management
at Standard Bank.
Karin chaired the Stakeholder Council convened for the G4
consultation process, so she knows the content of the G4
well. Even still, with the country’s market-leading approach
and experience on both sides, she says “the process can be
daunting”.
With a team of two, step one was a complete gap analysis.
From this, Karin said, they could see what criteria they were
already meeting and which aspects were not material.
‘Taking it step-by-step made the whole index a lot less
frightening’. Some of the indicators are complex with multiple
parts: ‘the supply chain indicators, for example, are a little
scary’. For companies with complex supply chains, the
breakdown by type or product and service, by point of origin
and by quantum can assist the honing and decision on the
most material issues, Karin advises. By analysing the types
of suppliers and the amount of spend, it became clearer and
a little less scary, Karin explained.
Materiality is also one of the harder areas to crack. Not
because of the concept itself, which is familiar to them: it’s
applying the materiality lens in practice to filter what you
actually report on. Karin says: “you need confidence to
determine which parts are applicable to your business and to
decide when you have adequately met the requirements of a
particular indicator”.
Karin’s advice: “The direction you take depends on where
you’re starting from, and very few companies have a clean
slate to start with”.
4
Cutting through the complexity of GRI G4
6. BRANDS WHO HAVE MADE
THE JOURNEY TO GRI G4
CONTINUED
Todd Camp believes GRI G4 is a part of the journey towards
integrated reporting and welcomes GRI’s contribution
towards unified reporting standards.
For Hershey’s the main benefit was bringing reporting to a
higher global level, something their stakeholders expect from
them. It also helped break through the paradigm of
compliance and developed a platform that demonstrated
how to integrate sustainability into the core of Hershey’s
business strategy.
“The process is well worth the time and effort requirement,”
Todd argues. “It will require some internal communication
and change management, but ultimately it’s about
identifying critical risks and main opportunities – and
demonstrating how our company is addressing these items.”
INTEL, LINDA QIAN, CORPORATE SOCIAL RESPONSIBILITY
COMMUNICATIONS, US
Intel is one of the world’s best-known technology
brands. As a mature reporter, they’ve been using the GRI
framework for the past 10 years. Implementing the G4, in
accordance with the comprehensive level, was just the
next step on their reporting journey.
As a highly visible company in its sector, Intel fully
appreciates the principles of stakeholder engagement
and materiality. Linda Qian, CSR Communications at Intel,
explains: “Intel has had a robust CSR materiality process
for many years, and we know who our stakeholders are and
how to engage them in the materiality process. The focus
on reporting material issues also means that we can narrow
our reporting to key issues.”
The only sticking point with G4, Linda explains, is with newer
indicators, for example, with remuneration. It can be
challenging to get executive buy-in on indicators like these,
which are not as material from a CSR perspective, and are
not required from a regulatory standpoint in the US. Other
aspects are much easier to achieve: “we helped inform the
changes in the G4 guidelines on supply chain,” Linda reveals.
Linda’s advice: See the transition as an opportunity: “the G4
guidelines put as much emphasis on the process and
governance of CSR as they do on non-financial reporting and
increased disclosure. Think about how you can better
leverage the reporting process with key stakeholders
internally and externally to move your CSR practice forward.”
Cutting through the complexity of GRI G4
M&S, ROWLAND HILL, SUSTAINABILITY AND REPORTING
MANAGER, UK
The UK retailer’s adoption of GRI G4 did not aim to be in
accordance, rather it used the framework to cross-check
its own reporting strategy ‘Plan A’. The process generated
better indicators for carbon and energy and allowed M&S
to improve their Plan A 2020 vision.
For M&S, sustainability reporting has always been primarily
structured around Plan A. Having a strong reporting strategy
in place, the GRI G4 guidelines were used as a secondary
navigation tool.
“Moving to G4,” Rowland says, “didn’t pose a problem
because we’re not aiming to be ‘in accordance’ and it has
no impact on our judgements of materiality.”
The main benefits were using the GRI G4 indicator for carbon
and energy, together with the gap analysis that needed to be
done. The process also started a debate around materiality
that turned out to be very relevant and improved the work
on integrated reporting.
Rowland’s advice to first-timers? “Get an accurate
benchmark of what your competitors are doing and don’t
be afraid to experiment with GRI. There are lots of issues
and problems with both GRI and regular reporting. The key
is to follow a logical trajectory.”
THE HERSHEY COMPANY, TODD H. CAMP, SENIOR
DIRECTOR, CSR AND COMMUNITY RELATIONS,
THE HERSHEY’S COMPANY, US
The American chocolate giant Hershey’s adopted GRI G4 as
a step in the right direction to bring sustainability reporting
to a higher global common denominator. For Hershey’s this
was a ‘natural step’ in harmony with their brand values.
Having used GRI since their first CSR report and with a
commitment to increase disclosure and transparency, it was
an easy decision for Hershey’s to adopt the framework early.
Regular meetings with internal data owners and legal team
helped to develop a smooth process of collecting data.
Support from Hershey’s senior leaders made it an easy choice
without pressure from government or industry requirements.
5
7. CONCLUSIONS
A popular myth holds that if you ask the people of Maine for directions they will
likely say, “You can’t get there from here.” Well I’m with the Maine folks. The first
step in any journey is to fully appreciate your starting point and maybe move to
a more advantageous point of departure.
A main objective of the new G4 guidelines is to focus on the
most material issues to ensure the report is both relevant
and concise.
Materiality, as we have suggested in our decision tree, becomes
the starting point of the journey towards more meaningful
reporting. However, there is a subtle nuance in the description of
materiality in G4 compared with G3 and that is determining
whether issues are likely to substantively influence the
assessments and decisions of stakeholders.
This suggests a much more in-depth stakeholder engagement
process and this is an area where new technologies can be a
great help in reaching wider audiences. New requirements to
validate these findings with senior management will also help
strengthen the credibility of GRI reports.
MINUS THE PLUS
The GRI recommends external assurance but does not require it
to report ‘in accordance with’ G4. The omission of the + sign, that
in G3 denoted whether or not a report had been externally
assured, would seem, at first glance, to weaken the argument for,
and take-up of, external assurance. But this is not the case,
according to Katherine Lampen, Director of Sustainability
Services at Deloitte LLP, London. In fact, Deloitte are receiving
more requests for external assurance rather than fewer, from
G4 reporters. Katherine attributes this to the requirement to
clearly show in the content index whether each Standard
Disclosure Item has been externally assured and, if it has,
to include the page reference for the External Assurance
Statement in the report.
“This is actually a better way to show the scope of the assurance.
Before, you could include a + sign even if only a small part of the
report had been externally assured. Now the content index
shows explicitly the areas that have been assured and those that
have not. This is driving more, rather than less, assurance.”
For other reporters, GRI G4 is not the destination but the
compass. It is a useful navigation tool to ensure that they are on
track, but their goal is to communicate the value or impact of
their business beyond the confines of reporting protocol. The
ability to report against the guidelines but stopping short of full
‘in accordance with’ requirements will ensure that GRI guidelines
are also relevant for those that adopt this approach, such as
M&S with Plan A.
For new reporters and those in developing markets, a ready-made
framework that is actively promoted by governments
and exchanges around the world also extends the appeal
of these guidelines.
All these factors are likely to ensure that the GRI guidelines
remain the de facto global standard for sustainability reporting
for the foreseeable future.
Cutting through the complexity of GRI G4
GLOSSARY OF KEY TERMS
• Aspects: the list of specific subjects covered by the
G4 Guidelines in each of the Economic, Social and
Environmental categories
• Material Aspects: subjects that reflect the
organisation’s ‘significant economic, environmental
and social impacts’ or that substantively influence
stakeholder decisions and assessments
• Reporting Content Principles: stakeholder
inclusivity, materiality, sustainability context
and completeness
• Reporting Quality Principles: includes balance,
clarity and accuracy
• Disclosures on Management Approach (DMA):
explanation of how the organisation is managing
its material aspects – why it’s material and how
it’s managed
6
8. Cutting through the complexity of GRI G4
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Business Development Director
jsutton@salterbaxter.com
Fay Hogg
Head of Reporting
fhogg@salterbaxter.com
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Level 4 Whiteleys Centre
151 Queensway
London W2 4YN
Tel +44 (0)20 7229 5720
www.salterbaxter.com
@salterbaxterMSL
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