Thursday, October 27, 2022

Five Examples of Beauty in Reporting

At a time when everyone is focusing on standards, data and metrics, there’s another side to reporting that often gets overlooked: the graphic design of the report. While the content is the key, the design turns the key to make the content sing🎵. Inspired design makes content more accessible and appealing for those who actually want to read reports, rather than just mine the data. Beautiful reports are inspiring for employees as well attractive for all stakeholders. 

It's clear that some report designs are constrained by in-house branding guidelines that prescribe fonts, colors, shapes and even layouts, so most report designs don't start with a blank page. Even so, there may be some design touches that help liven up the content. The key elements of great report design (in PDF), in my view, include: 
  • Pages that are pleasant to look at – not too empty, not too crowded, with a clear focus for the eye as it rests on the page. The thing that stands out should be the thing that’s most important, not just some random callout factoid. 
  • Consistent design language – I like the design to have its own language throughout the report, creating a familiarity and sense of expectation as you read through it. Disjointed, disconnected imagery and random font sizes and colors drive me a bit crazy. 
  • Clear tables and charts - legible and consistent across the report. Clear headings. NOT ALL CAPITALS. Block capital print is hard to read. 
  • Fonts – rightsized fonts, not too many either. Three different font sizes at most. They should be legible at 100% on my screen. 
  • Format – horizontal PDFs seem to work best for me. The wider sizes offer more room to play with on the page. 
  • Original photos – not image banks with plastic people and Amazon views. Real photos of a real business make the report more credible.  
  • Interesting design elements - little splashes of color or illustrations or (careful) icons, that complement and provide a pleasant eye-tonic alongside the text. 
  • Navigation navigation navigation. I want to sail through the PDF, back and forth, section to section, with single clicks. The navigation needs to be accessible, easy to follow, intuitive, interactive. Navigation tools are useful too. Love a home button that takes you to the contents page. 
  • Ice cream: The more images of ice cream, the better.
Things I hate in report design: 
  • Text that is not horizontal. I have ruined two computer screens when they fell off my desk as I tilted them to read vertical text. Haha.
  • An abundance of meaningless icons 
  • Massive fonts 
  • Photos of palms holding globes 
  • Images representing diversity that are clearly misrepresentative of the organization 
Not all reports that I consider beautiful adopt these design preferences. But they are all beautiful in one way or another because of the colors, visuals, tasteful imagery or other design creatives that bring the narrative to life in an attractive and inspiring way. To me, this shows a level of care and thought in the way the report is presented that helps me believe the intentions of the reporting company. I realize this may not always be a logical correlation, but, in their own way, beautiful reports are inspiring. Here are a few to feast your eyes on (while you are feasting the rest of you on your favorite ice cream):

Roma Group 2021/2022 ESG Report 

Roma Group is a privately-owned small-business valuation and technical advisory services firm in Hong Kong, employing around 60 people. This is the Group’s fifth ESG Report, it’s In Accordance with GRI Core Option and complies with the Hong Kong Stock Exchange ESG reporting rules. At 49 pages, it’s compact, focused and a delight to view. In fact, all Roma Group reports are beautifully designed – take a look at them all.

Roma Group reports have a few signature design approaches for all reports that I like very much. First, the design links to the annual report theme - for example, this year's theme is "The Pursuit of Sustainability". The report creative uses a camping trip to illustrate this theme. This demonstrates that the designer is not just laying out any old content on a page, but thinking creatively about how to reinforce the report messaging. 

A second design approach is a creative top menu bar. Although not interactive (a Home button linking back to the contents page would make navigation easier), each report chapter has a unique top menu illustration. A menu is not just a menu - it's an opportunity for creativity. 

A third element is the design of headings. A heading is also an opportunity for creativity. In the examples below, you can see how the paragraph subheadings are embellished with design elements that provide visual interest, especially on text-heavy pages. 

Finally, all tables are clearly presented, using a light touch of color to help differentiate different topics. Roma Group includes a GRI Content Index as well as a Hong Kong Exchange ESG Reporting Index.

I award Roma Group my highest Ice Cream Accolade. Five cones. 🍦🍦🍦🍦🍦.

S Hotels & Resorts Sustainable Development Report 2021

S Hotels & Resorts is a Thailand-based operator with 38 properties in some of the most beautiful locations in the world. No surprise then that the imagery in this report reflects the beauty of the views that visitors can enjoy while consuming their Thai ice creams.

Aside from the spectacular images, the design of this report includes thoughtful ocean-related illustrations on every page and small icon-type illustrations for callouts and highlights. The style complements the narrative and turns each page into a work of art, rather than simply words and paragraphs. Data tables are neatly drawn. Here are a few pages:

Definitely a four-cone design. 🍦🍦🍦🍦

Gucci Equilibrium Impact Report 2021

Gucci is part of the global luxury group Kering that develops and markets fashion, leather goods, jewellery and watches. This second annual Gucci Equilibrium Impact Report references the company's Environmental Profit and Loss accounting, a practice pioneered by Kering several years ago. The Gucci EP&L is not detailed in this report, but Kering's group EP&L is referenced.

The Gucci report combines vivid colors with light-touch design elements throughout the report. Using thread-like elements on each page to liven up images and creative icons for bullets, the report is super attractive in an understated sort of way. A compact navigation top menu on each page helps you get around this 42-page report. In fact, the report is a horizontal wide-page design that fills the screen from end-to-end, where each page actually holds the content of two regular pages, like double spreads. This adds a nice flow to the content and enables continuity on certain pages, such as the timeline page. Oh, and if you are looking for page numbers, don't bother. There are none in this report. Can't decide if that's a good thing or not - certainly one less thing to crowd the page, but perhaps less functional. Don't forget to stock up on luxury ice cream to view this sample of pages from the Gucci report. 

Four cones to Gucci 🍦🍦🍦🍦.

Genesys 2021 Sustainability Report

California-headquartered cloud-based software and artificial intelligence (AI) technology company Genesys has created a beautiful report out of a lot of white space and a focused color palette.  

Using bold colors, brush-stroke design elements and a handwritten-style callout font, it all hangs together in a truly appealing way. Bold images for the section landing pages are captivating, and little touches such as the illustrations on the inclusion timeline chart add visual interest. A full navigation top menu makes navigation super easy. This report is quite masterful in projecting a clean, uncluttered design approach while incorporating a range of content, images, tables, charts and graphs. 

The more I look at the Genesys report, the more I appreciate it's simple appeal. Genesys gets four cones from me, proving that less is more 🍦🍦🍦🍦.

Metaxa Hospitality Group Sustainability Report 2021

The Metaxa Group is a Greek-based group operating on the beautiful islands of Crete and Santorini. The Metaxa report projects a Mediterranean calm, inviting you to relax by the deep blue waters of the a hotel pool (don't forget the ice cream) as you peruse its pages.

The beauty in this report is in the flowing lines of the pages, the awe-inspiring imagery of the local landscapes, the colors that remind you of a sandy beach and the careful page composition that, on several pages, includes photos, callouts, data and text. Although sometimes it's quite a lot, it's tastefully put together and maintains a peaceful, calm design feel throughout.  Some images are used as page backgrounds, but care is taken not to render any text illegible. The top menu is not interactive, which is a pity, but it helps you know where you are in the report. 

Four cones also to Metaxa 🍦🍦🍦🍦.


That completes today's roundup of beautiful reports. There are many other fabulous report designs out there - so many different styles and formats - many more that are very impressive. And of course, no matter how beautiful the report, it's the content that we are all looking for.  But, at least, just in case you were wondering, now you know that there is also beauty in reporting. 

elaine cohen, GCB.DESG Competent Boards Certified (2021)Sustainability Strategy and Disclosure Specialist, former HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltdan inspired Sustainability Strategy and Reporting firm having supported >160 client reports to date; author of three books and several chapters on Sustainability Reporting and the Human Resources connection to CSR; frequent chair and speaker at sustainability events and judge in several sustainability awards programs each year. Contact me via Twitter , LinkedIn or via Beyond Business

Thursday, October 13, 2022

GRI Reporting: The Case of the Invisible Employees

In the middle of all the raging debates, exposure drafts, ESG wars and explosion in the number of ways you can say materiality, serious reporting companies are gearing up for their next reporting cycle. For those who report GRI, this includes getting ready for the introduction of the new GRI Universal Standards for reports published in 2023. 
You may have noticed that there are some early adopters of the new Universal Standards applied in reports published in 2022. It’s good to see companies showing leadership in transparency and paving the way for use of the Universal Standards. We can learn much from how they do things. Thank you to all the companies I mention below. 
The Universal Standards represent somewhat of a stretch for companies who have reported GRI Core Option in the past. Less so for Comprehensive Option reporters but still some adaptation is required. It’s not quite enough to continue to report as you were doing and just add new labels. 
Disclosure 2-8 is a case in point. This disclosure is an upgrade to previous GRI 102-8-d (2016) which required reporting of “Whether a significant portion of the organization’s activities are performed by workers who are not employees. If applicable, a description of the nature and scale of work performed by workers who are not employees.” A sub-clause of 102-8, this disclosure was largely overlooked and reported only occasionally by companies. Disclosure 2-8 now requires a detailed disclosure:

Let’s start by trying to understand who the workers are who are not employees. This is a tricky one and not as clear-cut as you might think at first glance. My initial assumption was that this refers to agency employees or contingent workers – people who work for an employment agency who replace employees on leave, or supplement employees at peak times etc. 
But, hey, wait, it’s not that simple. 
Reading the GRI guidance in the Standards, you realize it’s all about who controls the work. If the company controls the work of the worker who is not an employee, that worker is in scope for Disclosure 2-8. The guidance says: workers who are not employees are those who perform work for the organization and whose work is controlled by the organization but are not in an employment relationship with the organization. Control of work implies that the organization directs the work performed or has control over the means or methods for performing the work. 
But, hey, wait, it’s not that simple. 
How do you define “control of work”? Control can be interpreted in different ways. Does control mean setting wage scales? Supervising the work? Prescribing the work methods? Monitoring attendance? Defining materials to be used? Scheduling hours of work and rest? All of the above? GRI guidance talks about workers of one of the organization’s suppliers, where the organization instructs the supplier to use particular materials or work methods to manufacture the products or deliver the services
The “extent” of control plays a role here. If it’s control to a high extent, it’s control. If it’s control to a limited extent, it’s not control. Aaaaaaaaaaaargh. In order to solve this conundrum, I went straight to the source and would like to thank GRI's Bastian Buck, Chief of Standards, and Sharon Hagen, Senior Coordinator of Sustainability Reporting Standards, for their insights and guidance. Nothing like getting to folks who created the problem to sort it out for you 🤣. Ultimately, companies will have to define and declare the scope of control they apply in when using Disclosure 2-8. That’s comparability out of the window as reporters will inevitably report in different ways. But heck, comparability is a myth anyway. 

So now we know. Disclosure 2-8 is sort of a DIY disclosure. Make it up as you go along. 

Applying the insights above, here are examples of workers who are not employees, and how Disclosure 2-8 applies to them or not. 
INCLUDE Employees of high-control outsourced operations: An example is people employed by a contract manufacturer that provides a dedicated manufacturing operation (but not necessarily in a dedicated facility), employing a team of trained people to deliver defined products in accordance with a company’s specification. The company prescribes the work in quite some detail, defines the materials to be used, the nature of the work and even some or all of the work processes. Let’s call this high control.
EXCLUDE Employees of low-control outsourced operations: There are several examples – outsourced warehousing, outsourced logistics, outsourced call-centers etc. In these cases, although a company might prescribe an overall approach to the work, for example, safety standards, a Code of Conduct, ISO certification, or certain processes, generally it is the outsourced operation (supplier) that controls the practice of work on a day-to-day basis to meet contractual requirements. The outsourcing provider sets wages, manages employee terms and conditions, hours of work, shift patterns, training, discipline etc. In this case, the company has low control over the work itself. 
INCLUDE or EXCLUDE Employees of hard-to-define control outsourced operations: In some cases, operations may be outsourced with a high level of prescription about the work to be done and the processes to be used without detailing day-to-day specifics. It really depends on how much freedom the supplier of the service has to choose the way it instructs its workers to perform he work. Less freedom = more control. More freedom = less control. The rule of thumb here is: if in doubt, make a decision and explain it, and then apply it consistently. 
INCLUDE Employees of on-site service providers: Employees of contracted services usually performed onsite such as cleaning, catering and security services are usually required to perform their work under a high level of control by the company. Hours of work, place of work, type of work – generally it’s the buyer that decides. 
INCLUDE Agency or third-party contingent workers: These are individuals who are supplied by external employment agencies to do specific jobs in the organization, in place of or in addition to the permanent workforce. For example, cover for maternity leave or sick leave, additional resource on packing lines or in laboratories etc. They join the team and do the work required, directed by the Team Manager or Supervisor. Clearly high control is at work here. Haha. A pun. 
INCLUDE Contractors: Contractors manage and/or deliver construction or engineering-type projects. Often a General Contractor will bring in its own team and specialist sub-contractor companies and their employees to complete a project. They work on the company site or help build new sites, under the guidance and responsibility of the General Contractor who meets the contractual obligations of the contracting company who agrees the work plans and prescribes aspects of the work. 
INCLUDE Independent workers: This may include what GRI refers to as self-employed workers or home workers. They are generally considered an extension of the internal workforce, doing work an employee might do. For example, an independent laboratory worker who joins the team for a specific period of time to do work directed by the Lab Manager, or a homeworker who provides call-center services on contract to the company directed by the inhouse Call-Center Manager. 
INCLUDE Interns/Apprentices: These are included in GRI’s definition or workers who are not employees, even though, in many instances, interns and apprentices are not performing full work roles, but provide supplemental project work as they learn in the organization. For good orders’ sake, these we count these as in scope for 2-8 as control is with the company. 
INCLUDE Volunteers: If the reporting organization is a nonprofit or non-commercial entity, volunteers may be the primary providers of work in the organization, and may be managers, staff or occasional volunteers. Their work is determined by the organization. 
EXCLUDE Employees of general suppliers: Suppliers employ people to make and deliver goods and services. The people employed in the broader supply chain (excluding outsourcing examples above) are managed by their own organizations with no control of the procuring company. They would not be considered part of a company’s extended workforce unless they are specifically dedicated to providing custom work as noted in the examples above.  
EXCLUDE Employees of providers of professional service providers: Employees in legal and accounting firms, auditors, compliance organizations, manpower agencies, design firms etc. While these individuals provide a dedicated, custom service, their work is not controlled by the company.
EXCLUDE Independent consultants: An external consultant who works on contract to supply a service against a Statement of Work or other contract. Similar to providers of professional services.
EXCLUDE Robots: A robot performs work but is not an employee. But a robot is not a person. Well, not really.
EXCLUDE Non-Human Animals: If you use animals to perform work, for example, horses to pull carts, cats to catch mice, dogs to guard the yard, these would also be outside the scope of Disclosure 2-8. But you can report about them anyway. We love non-human animals. 

Complicated, isn’t it? 

But you get the picture. In order to understand a company’s full employment impacts, the categories to include above, in addition to the direct workforce, represent the overall number of people involved in a company’s activities. This number could be significantly larger than the direct workforce, especially in the case of organizations that outsource many operations. Take a company like Inditex. All garment sourcing is outsourced. Inditex employees 165,000 people directly. But has more than 1.3 million people employed in its supplier factories around the world. Although not yet using GRI Universal Standards 2021, Inditex reports extensively on workers in its outsourced factories and even publishes a special report: Workers at the Centre. 

Given the close control Inditex exerts over its garment suppliers, and the detailed strategies and due diligence deployed to drive responsible employment practices in the supply chain, with my new understanding of GRI’s guidance, I would expect these workers who are not employees to be in scope for Disclosure 2-8 when Inditex reports using the Universal Standards next year. 

Workers who are not employees – the invisibles 

Whichever category of “workers who are not employees” companies adopt, it seems that in any case, a lot of them are invisible in the disclosures of companies using the new Universal Standards. I have looked at reports from early adopters (selected randomly) and, in my analysis, in 16 reports: 
One company disclosed in compliance with the requirements of Disclosure 2-8 
Six companies provided some kind of information but not all required details or clarity 
Two companies omit Disclosure 2.8 from the GRI Content Index 
Two companies hide the disclosure 
Three companies advise that the information is not available 
One company provides the wrong information 
One company just doesn’t report
So, a one-in-sixteen (7%) hit rate for complete disclosure on workers who are not employees. 93% are more or less invisible. 

Let’s take a look: 

One company disclosed in compliance with the requirements of Disclosure 2-8 

Hong Kong power company CLP Holdings Ltd does a great job. CLP is no stranger to strong sustainability reporting and always delivers highly transparent, well considered reports. In this latest report using GRI Universal Standards 2021, CLP clearly identifies direct employees and different categories of non-employees where labour supply refers to people provided by manpower companies. See CLP’s GRI Content Index

Six companies provided some kind of information but not all required details or clarity 

Singapore-based City Developments Limited (CDL) is a global real estate company and another leading-light reporter and multiple times winner of the Asia Sustainability Reporting Awards over the years. No surprises that CDL is an early adopter of the GRI Universal Standards. CDL references construction workers in the 2021 Integrated Sustainability Report as workers who are not employees. No mention is made of other categories of workers, such as those involved in site services such as cleaning or security, nor whether this is a typical year or if there is significant fluctuation from year to year.  
Diageo discloses against 2-8 in the GRI Content Index of its 2022 ESG Report. This disclosure describes different categories of workers who are not employees, but makes no reference to workers in outsourced production operations. If any of Diageo’s outsourced plants operate under “high control”, they would need to be included. Also, no reference to year-on-year fluctuation. 

As with many global garment manufacturers, transparency of the supply chain is more common, whether or not the reporter uses GRI. H&M is however a GRI Reporter and Universal Standards early adopter and provides an overview of workers who are not employees in the supply chain in its 2021 Group Sustainability Disclosure. H&M also discloses much detail about the conditions of employment through their supply chain including wages paid to workers in supply factories in different countries. But as far as Disclosure 2-8 is concerned, there appears to be no mention of other agency or contractor workers at H&M’s own sites. 

Korean tire maker Hankook Tire & Technology’s ESG Report 2021/22 includes a brief response to GRI 2.8 in the GRI Content Index.  Short and to the point. Not clear whether subcontractors includes all types of services or only production-related work at the plants. But it’s something. 

Levi Strauss & Co’s 2021 Sustainability Report (with reference to GRI Standards, does not claim to be In Accordance but includes a GRI Content Index) includes a response to GRI 2.8 that is similar to the approach of H&M, referencing workers at supply chain factories but not other categories of workers.

Houston-based chemical company Westlake’s 2021 ESG Report’s GRI and SASB Appendix includes a GRI 2.8 disclosure that explains the company’s approach but provides no data. Better than no response at all. What’s an insignificant portion of the workforce? Less than 100? Less than 1,000? Westlake employees 14,000 people.

So far, all the companies mentioned have made some attempt at responding to GRI 2.8, even if all but one failed to provide a complete disclosure. The following companies did not provide any information or data, or provided the wrong information: 

Two companies omit Disclosure 2.8 from the GRI Content Index

U.S. based specialty food ingredients company Darling Ingredients2022 ESG Report GRI Content Index has a neat way of dealing with GRI 2.8. Just omit it from the Content Index.

Galaxy is a digital asset and blockchain leader providing institutions, startups, and qualified individuals access to the crypto economy. Hmmmm. There’s a business I don’t know much about. In any event, Galaxy had the same idea as Darling Ingredients. Just skip it. Galaxy’s Annual Sustainability Report 2021 includes a GRI Content Index. 

In fairness, both Darling Ingredients and Galaxy reference GRI Standards and do not claim to be In Accordance. 

Two companies hide the disclosure

These companies claim their reports are “In Accordance” and include a page reference for Disclosure 2.8 in the GRI Content Index. But, the disclosures are actually nowhere to be found is nowhere to be found in the reports. Hide and seek, anyone? 

Three companies advise that the information is not available

AT&T’s fiscal 2021 ESG Report GRI Content Index notes: 
AT&T is not able to provide this data, as it is proprietary and confidential. 
Hmm. I wonder what’s so proprietary and confidential about that?

Ford Motor Company's 2021 ESG Data Book notes: 
Information unavailable – this data is not readily available and is not tracked today. 

THREDUP’s 2021 Impact Report notes: 
This data is currently unavailable. We are working to expand how we report out these metrics in future reports. 

One company provides the wrong information 

Under Armour’s “In Accordance” 2021 Sustainability Impact Report responds to Disclose 2.8 by referencing the Human Capital section of the company’s Annual Report which provides data on employees who are employees and not workers who are not employees. 

One company just doesn’t report 

PepsiCo simply advises in the 2021 GRI Content Index
Not reported. 
But PepsiCo does not claim to report "In Accordance". Otherwise a reason for omission would be required.

Clearly, then, the Universal Standards may require a little extra consideration and in some cases, this is not so simple. Disclosure 2-8 in particular is a headache for most companies, as it requires securing data from sometimes complex supply chains. Not surprising then that in this first year of use of the Universal Standards, there are some inconsistencies and some gaps. It's all part of the learning curve and thank you again to all the sixteen companies who have already entered the GRI Brave New World and allowed me to see how it's going down and hopefully allow others to learn. 

Clearly, if GRI offered a free supply of ice cream for reporters for full and accurate reporting  against Disclosure 2-8,  I would have had nothing to write about. 

And if you are a worker who is not an employee. Don't despair. I am pretty sure you will become visible in future reporting cycles.

laine cohen, GCB.DESG Competent Boards Certified (2021)Sustainability Strategy and Disclosure Specialist, former HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltdan inspired Sustainability Strategy and Reporting firm having supported >160 client reports to date; author of three books and several chapters on Sustainability Reporting and the Human Resources connection to CSR; frequent chair and speaker at sustainability events and judge in several sustainability awards programs each year. Contact me via Twitter , LinkedIn or via Beyond Business

Friday, June 17, 2022

Perspectives from Mr. Impact: GRI CEO Eelco van der Enden

The new CEO of GRI, Eelco van der Enden is popping up everywhere these days. Webinars, round tables, conferences, colloquiums. And now he is popping up on the CSR Reporting Blog. Of course he is. The CSR Reporting Blog loves GRI (and loves to challenge GRI as well 😁). Eelco obviously has a lot to say on the topic of corporate sustainability disclosure, but then, these days, who doesn’t?! 

The current discourse is polarized into two camps: the let’s-live-better camp and the let’s-make-more-money camp. Of course, players in each camp acknowledge the relevance and importance of the other camp (as long as they don’t get too close to the campfire). Some talk about building blocks, some reference interoperability. Some say let’s live better comes before let’s make more money. Some say let’s make more money is necessary to achieve let’s live better. Some say these are equal grounds on the same camp site. Some say they will never be equal. Mervyn King, the South African governance guru, talks about moving from the “current clutter and confusion to a comprehensive global reporting system”. Frankly, the only clutter and confusion at the moment is the weird discourse that’s going on about how to change reporting. 

A new, better, fantastic, wonderful reporting system 
Everyone seems to think a new era has been ushered in with the development of modern standards, and observers are thrilled with the fact there is momentum, with more exposure drafts to review in these few months than there has been in years. But the reality is that the debate is now about the differences in the new standards and the relative merits of each, rather than about the overall value of better transparency and how it will help safeguard our future. So much so that ERM and Persefone invested time and effort in the production of a report that analyzes the differences between the ISSB, EFRAG and SEC proposals. I mean, where are we? Rather than deploying existing frameworks and standards, the new voices in sustainability reporting are creating new volumes of disclosure and metrics proposals that may have similar cores, but are sufficiently different to require separate reporting considerations, meaning that everyone is now engaged in comparing, contrasting and concluding, rather than in actually improving disclosure. There might be a reasonable endpoint after all of this, but the continued messiness of it all is quite exasperating. Has no-one ever heard of copy/paste? 

The let’s-make-more-money camp’s claim to fame is the premise that they know what investors want. Yes, you got it. Make more money. This seems to me to be a fundamental flaw. There are many types of investors, several of whom are looking to make a positive return on investment while aligning with the values of the let’s-live-better camp. I do not believe that a set of standards based solely on financial value creation, that may be influenced by estimated and extrapolated environmental and social factors, is enough to lead investors to decision making that will either deliver better returns or sustainable corporations. Eelco van der Enden often talks about the fact that there are two pillars of corporate reporting – the financial pillar and the impact pillar – and this is a winning concept. He says that each is widely used along fairly consistent lines by the largest companies around the world, and many of the not-so-largest. Eelco asks why we would reinvent the wheel when we have proof of concept? Financial reporting works; sustainability reporting works; taken together, and with ongoing improvements to the existing standards, all the information needed to assess corporate performance and risk is in place, he says. Maybe all we need to do is get better at that, rather than invent new stuff. Eelco told me:

“Thinking you can introduce a new comprehensive reporting system from nothing, I think, is fantasy. We have some very well proven concepts used by basically everyone, so it becomes about convergence and alignment, whether it’s mandatory or not or whether assurance is mandatory or not. But saying what we have all been doing to date is rubbish and now we need to change it all, is not going to lead us to a very good place. I represent a purpose, not a legal entity. This purpose is about reporting facts, not perceptions, for multiple stakeholders, not just investors. In the recent Amazon vote, more than 20% of independent shareholders, including some of the largest investors, voted in favor of greater tax transparency using the voluntary GRI Tax Standard. Other frameworks are using GRI – the WEF Stakeholder Capitalism Metrics use GRI for 17 out of 22 of their metrics. EFRAG is making use of GRI standards with some tweaks, to allow for local regulations, but they are keeping the baseline principles intact. I do not see a need to start all over again. On the other hand, there are proposals for mandatory assurance to put sustainability reporting on an equal footing with financial reporting. I say this is a good thing. If we are serious about the stakeholder-centric model, we must ensure that reported data is robust.” 

Christmas Parties with the ISSB 
Despite this, GRI has joined hands with ISSB with a Memorandum of Understanding. The ISSB proposals completely bypass anything GRI, other than giving a token nod to the fact that “impact” reporting is somewhere out there on the landscape in the let’s-live-better camp, and may be of interest to someone somewhere. The MOU is hyped as an agreement to create an interconnected approach for sustainability disclosures. What does this really mean? Eelco explains: 

“ISSB has an investor lens. But there is not one type of investor, not all of them are only looking at enterprise value creation. IFRS and ISSB appreciate there is a gap on their flank that needs to be covered. With this MOU, they endorse the role GRI has for the other stakeholders which are not in their target group. The symbolic significance of this is important; for the first time, capital markets are expressing themselves in a way that addresses broader needs, and this should be taken note of by investors. It’s definitely a polarizing discussion. Some of the comments we have been hearing include, say, on the one hand, that GRI has sold its soul to capitalism, while on the other hand, the IFRS foundation has taken a sharp turn to the left. The agreement with ISSB is not about the technical aspects – we have a very well-equipped standards division and 25 years’ experience, we will help ISSB if they need help. So, it really comes down to governance. If you believe in the two pillars approach, people will want to see how the balance between the two is being managed, so there will need to be an overarching, aligned governance mechanism that will enable regulators to have sufficient faith in the robustness of this structure and the roles of the players involved. At GRI, we have an extremely robust due process. I personally was on the Technical Committee for the new GRI 207 Tax Standard and I can tell you it was very hard work indeed. We need to get better at the fine art of compromise. Moving ahead, we will see how this convergence works. Focusing on governance rather than technicalities is what will make the difference for regulators.” 

My reading of this is that GRI and ISSB will continue to go their different ways, with different objectives, different audiences and different standards. However, rather than being public adversaries, it will be a sort of hands-off co-existence and an occasional joint Christmas Party. Which brings reporters back to where we have always been; a system for financial reporting (including financial-related sustainability topics) and a system for sustainability reporting. Plus ça change… But, in Eelco’s view, that’s not such a bad thing. 

GRI – is a 25 year legacy enough? 
GRI’s new Universal Standards kick in from January. The reporting burden will be more significant for companies who want to comply in full with GRI Standards. There are more extensive disclosures on governance, human rights, topic disclosures on material topics, and an entire restructure of the General (Universal) Standards, meaning that GRI reporters will have a LOT to do to reshape their disclosures for the next cycle if they want to remain compliant. Given that ISSB and ESRS drafts are now public, coupled with U.S. SEC requirements, reporters have a good idea of the direction of travel. Several companies already bypass GRI and report using SASB and TCFD only. The question will be whether companies will even bother to invest the extra effort to stay with the new GRI Standards, or whether they will simply pick’n’mix, choosing very selectively the individual GRI standards relevant to them, and bypassing the Universal Standards entirely? I wondered what Eelco thought about that. He shared as follows: 

“That’s a very good question. It’s more than just about whether the new Universal Standards are more complex or challenging for reporters. It relates to our vision about what the future reporting landscape should look like from an impact as well as a financial standpoint. Yes, it needs effort, the same as every new standard, it will add a burden for organizations because it is different. But the key point is that the Universal Standards are fit for purpose and fit for the future. Five years on from when GRI transitioned from providing guidelines to setting standards, it was time to modernize and renew these disclosure requirements. We have not heard from companies so far that they do not intend to continue to report fully using GRI Standards. But now, of course, there are new options, including the introduction of the ISSB and EFRAG standards. I can only answer fairly if we think about these other initiatives out there. And that’s why we are proposing two pillars. ISSB is based on IFRS international accounting standards. GRI is based on multistakeholder dialogue. Combine these two and you have a system that has been around for more than 20 years. Nearly 11,000 companies use GRI and also report against mandatory financial frameworks. The platform exists. It works. The mandate of the SEC in the U.S. will always be investors, that won’t change. Nothing new from that end. We might see more incorporation of SASB standards into these requirements but the focus will not change.” 

That’s an optimistic view. From my perspective, while it tends to make sense, the danger is that new standards may drive companies down to the lowest common denominator i.e., what regulation requires (assuming EU and ISSB standards become law in different jurisdictions around the world). In the absence of regulation, as has mainly been the case so far, voluntary disclosure not only flourished, but it also became a competitive advantage. If your peers use GRI, then you use GRI. In a brave new world where sustainability reporting (of sorts) is mandated, and required to be externally assured, and will carry the same regulatory and legal weight as financial reporting, companies may look to minimize the reporting burden to that which is unavoidable. I think a role of GRI through whatever this transition is will be to truly land the use of GRI Standards as the only way and the right way to provide impact transparency for all stakeholders, both as impact reporting in its own right and as a precursor for additional finance-related disclosures. If only a fraction of everything we have said about the value of sustainability reporting over the past 20 years is true, then ditching GRI for the let’s-make-more-money camp would be tragic. I predict there will be some fallout, and some lack of uptake, but I doubt most companies will do a full U-turn. I think GRI will continue to be the framework of choice for impact disclosure and the basis for effective sustainability disclosure as it affects the financials. 

Materiality – mind the gap 
So, let’s come back to materiality. Everything comes back to materiality. You all know by now that GRI’s version of impact materiality takes account of the organization’s most significant impacts on the economy, environment, and people, including impacts on their human rights. Impact materiality is central to GRI’s right to exist. Yet even the widespread use of GRI standards has not led to a consistent, clear, due-process-driven, transparent and verifiable methodology for determining material topics. The number of companies delivering a clear disclosure on how they actually determined material impacts, beyond asking selected (friendly) stakeholders for their multiple choice ticks, is probably less than the number of ice creams you can cram into a petri dish. Trying to work out how a company selected material topics is more often than not like staring down a black hole. There is some attempt to correct future practice in the new Universal Standards, in which the definition of materiality has been updated and there is more extensive guidance on process. But, as this is just guidance, I suspect that’s how companies will continue to treat it. (It’s guidance, let’s ignore it). I put this to Eelco: Why does GRI not bite the bullet and create a standard – not guidance or approach – for the process of developing a list of impact materiality topics? Given its central position in sustainability reporting, I find it baffling that GRI has never been willing to address this. Does it serve GRI’s purpose to deliberately leave this vague and open-ended? And his reply:

“Yes, I will go back to the Standards Team with this question. I do believe a systems audit approach is needed, but I am not sure that it’s within GRI’s remit to come up with a standard like this. We have never been prescriptive about defining materiality, and there are many possible ways to address this. We do get questions about whether GRI is planning to develop a standard for preparing a materiality assessment. Perhaps this is something we could influence in partnership with other groups who might be better positioned to develop such a standard. This is something for consideration.” 

I won’t hold my breath. The entire sustainability reporting proposition rests on how companies define materiality, and our trust in their process requires them to disclose it. I believe GRI is absolutely the best placed organization to develop a process standard such as this. Having companies everywhere using GRI standards without a consistent, auditable methodology for determining materiality is like inviting people to a Scrabble game where each player randomly decides the number of points for each letter. You can add up the scores but they actually mean nothing. 

When 5 months is like 50 years 
I asked Eelco how he would summarize his first five months at GRI and he replied: “Like 50 years”. That’s understandable. More has happened in the past five months in sustainability reporting than has happened since Adam ate the apple. 

I asked Eelco what legacy he wants to leave at GRI.

“I’d like to leave a resilient, financially independent organization that, in the two pillar structure, is the globally accepted pillar for impact reporting.” 

 And some of the challenges GRI is facing? 

“Externally, it’s getting GRI back in the front seat. We were not vocal enough about who we are and what we are all about. It’s very simple. We enable society to have a discussion based on facts, not perceptions, providing free standards as a public good. Internally, we need to increase our efforts to raise funds to help us deliver our purpose and create a stronger financial backbone. There is a lot to do. We need to double the size of the standards division, and generate revenues based on more services we provide. We must continue to recruit quality people who are or can become specialists in standard-setting. Our purpose appeals to people, it’s a fun workplace where everyone can make a difference. We must become more efficient, for example, we are now installing a new ERP which will enable us to get rid of a lot of manual work”. 

What is Eelco saying to reporters? 

“There are criticisms of sustainability reporting and questions relating to how serious companies are about their environmental, social and governance commitments. I think that’s dangerous. Cynicism kills everything. Business leaders and investors should be very serious about this topic, it’s about helping make the world better for everyone. Short-termism is a problem. We must keep the flame alive and also look at how regulators are dealing with this and how large intragovernmental organizations are getting on board. To achieve public accountability based on comparable data, you need to make an investment. You can’t manage with volunteers. It must be managed professionally. It’s too important. Organizations complaining about the burden of compliance are those who are not transparent. It’s exactly that which builds mistrust. At GRI, we advocate for two pillars of reporting, and we are expert in the impact reporting pillar. We encourage all companies to report their impacts on the economy, society and the environment with the necessary degree of investment and leadership attention to help continue to build trust, build inclusive economies and protect our shared future.” 


And a little note from me at the CSR Reporting Blog: I’d like to thank Eelco for generously spending time with me talking through these issues. We had a fun conversation and Eelco was not thrown by my direct and sometimes provocative questions. I believe the approach is clear. Do better what you do best and keep communication lines open. GRI’s focus is impact reporting, with a proven legacy of doing that best (although still not perfectly😏). All the peripheral noise around what investors need, want and how much data they can usefully integrate into their algorithms is exactly that: noise. I advocate for GRI-based impact reporting as the essential fundamental basis for corporate sustainability disclosure; starting with broad based GRI facilitates disclosure against every other standard and framework, as well as responses to mile-long investor analyst questionnaires. 

As usual, this post was written by me independently. No-one in GRI has influenced or requested to influence how I presented this conversation with Eelco. Of course, had they offered me a month’s free supply of ice cream, I might have used a few more superlatives 😁.

elaine cohen, GCB.DESG Competent Boards Certified (2021)Sustainability Strategy and Disclosure Specialist, former HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltdan inspired Sustainability Strategy and Reporting firm having supported >140 client reports to date; author of three books and several chapters on Sustainability Reporting and the Human Resources connection to CSR; frequent chair and speaker at sustainability events and judge in several sustainability awards programs each year. Contact me via Twitter , LinkedIn or via Beyond Business

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