Liberty Global: Discovering New Possibilities

It's always a pleasure to tell CSR Reporting blog readers about reports that I have been involved with. Last year, I posted about Liberty Global's inaugural Corporate Responsibility Report  and now, I am delighted to bring you an update in the form of the second global report, called Discovering New Possibilities, which was published last week.

 

This report represents a step up in transparency for Liberty Global with a GRI G3.1 report at Application Level B, more extensive than the first C Level report, and covers operations in including UPC (Netherlands, Poland, Romania, Slovakia, Austria, Czech Republic and Hungary), Unitymedia Kabel BW (Germany), Telenet (Belgium), VTR (Chile) and Liberty Cablevision Puerto Rico.

 

A lot can change in a single year, which is reflected in this new report from Liberty Global. The company is now the largest international cable company in the world, following the acquisition of Virgin Media in June 2013, and expansion of presence in different markets, generating a whole lot of economic and social value with revenues of over $17 billion and employing over 36,000 employees. With 24 million customers and over 48 million subscribers to video, internet and voice services, Liberty Global maintains an operation which is transforming access to the digital world - a transformation which is relevant to the quality of life of millions of people in the markets in which the company operates. Liberty Global's approach to delivering this transformation is routed in a compelling vision of the role that Liberty Global can play in society. It's much more than selling modems or set-top-boxes. It's about changing the way people live their lives. It's not enough to connect. It's about knowing what to do with that connection. In the language of Liberty Global, this means Discovering New Possibilities.

 

 

Possibilities for New Digital Skills

The Digital Agenda for Europe (DAE) recognizes that access to next-generation broadband with speeds exceeding 100 Mbps (megabytes per second) by 2020 is vital for long-term economic development and competitiveness. The goals of the DAE range from fast broadband for all to increased online commerce to 60% of disadvantaged people using the internet regularly. This is because digital technologies have "enormous potential" to benefit our everyday lives and support the economic wellbeing of Europe, as well as contribute to environmental resource efficiency. Liberty Global, as a seriously large player, recognizes that continually improving technology is not going to do the job. The technology needs to go where it's needed and people need to understand how to use it for their own benefit and for that of others. For example, in Belgium, Liberty Global's company, Telenet, installed 450 multimedia monitors in patient rooms at a hospital, providing video conference capabilities for patients and secure access to patients’ medical information for use by hospital staff, helping to increase the efficiency of staff while providing patients with opportunities to engage with their families and friends. Also in Belgium, Telenet Foundation developed an award-winning program called Recup PC, which helps people to get online, understand how to use the technology and develop digital literacy.

 

Possibilities of Buttons

Another great example of helping people not only to be aware of new technology but also to increase their capabilities is Liberty Global's innovative web tool called Internet Buttons. This enables people who have some experience in using the internet to create easy-to-use customized starter page for family members and friends who are new to the internet or find it confusing. Large, brightly colored ‘buttons’ act as shortcuts to websites such as email, search engines, Skype, eHealth or other services tailored to the user. These can be saved to a personal homepage, easily accessible at the click of a button and a whole lot less confusing than a bunch of unrecognizable icons and symbols that only experienced users can navigate around. New digital skills – button-wise – is a way to bring the internet to those who otherwise would probably never be able to figure it out on their own. Like most things, it's easy when you know how. But if no-one helps you, you never know how.

 

 

 

Possibilities of Engaging Children in Innovation

In Romania, Liberty Global company UPC has developed a platform to get kids interested in technology involved by submitting ideas with the possibility of winning a trip to attend a NASA educational summer camp. Over 230,000 visits to the Tech School website and 570 ideas later, the winning ideas included a super bionic hand, a mobile-phone-charging-T-shirt and a mobile astronomy observatory, showing that, when you provide the tools, kids get engaged and discover new possibilities. The overall winner of Tech School 2012 developed a prototype of a bionic hand with enhanced control and strength, which has wide-ranging implications for surgery, telemedicine and other remote interventions. A UPC Tech School grant will help develop an advanced version of this prototype.

 

 

Possibilities of Keeping Kids Safe Online 

Another area in which this report demonstrates the impact and potential positive impact of a company as large and influential as Liberty Global is the ways in which it advances technology, awareness and education to protect kids online. As a mom who has had personal experience of my own child getting into a potentially very dangerous online situation, which I managed to catch in the nick of time, and with kids who are mesmerized by the big, medium and small screens, I am only too aware of the need to protect our children. Liberty Global's report discusses this in detail and provides examples of how the company is supporting media literacy for parents in the Netherlands, campaigning to keep passwords safe in Chile and working in partnership in Europe to create safe internet experiences. The focus of protecting children is on education and empowerment.

 

 

Corporate Responsibility Performance

The nice thing about Liberty Global's report is that stories such as these show how positive impact is created through Liberty Global's core business. This is not a report about switching off lights at the end of the day and retrofitting offices with low-flow toilets (although there is some of that too). The main content of Liberty Global's report is about the role that the Company plays in society, which includes significant discussion about public policy and the complexities of creating internationally aligned protocols for data privacy and more. Liberty Global is active in helping define and shape the future of our digital world, which makes this report quite relevant for almost everyone.

 

Liberty Global's report also covers areas of responsible performance in environmental impacts, people management, supply chain monitoring and management and other relevant issues which affect the sector such as conflict minerals and an important discussion about e-waste, one of the sector's most significant impact areas. Liberty Global achieves a 36% retrieval and recycling rate of set-top boxes and modems, which adds up to over 5,000 tons of e-waste which avoids landfill. That’s equivalent in weight to offering 10,000 people an annual supply of ice cream every year for over 25 years. Unless you are me, in which case an annual supply would last about two days.

 

Take a Look – Give Feedback – Think Future G4

The transition from first reporter to experienced reporter is not easy. Liberty Global has delivered an equally relevant and more transparent report this year, which places the Company on the right road for a G4 report next time around. With this in mind, I encourage you to take a look, and give feedback!

 

 

elaine cohen, CSR consultant, winning (CRRA'12) Sustainability Reporter, HR Professional, Ice Cream Addict. Author of Understanding G4: the Concise guide to Next Generation Sustainability Reporting  AND  Sustainability Reporting for SMEs: Competitive Advantage Through Transparency AND CSR for HR: A necessary partnership for advancing responsible business practices Contact me via www.twitter.com/elainecohen   or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm)

 

The A+ Myth of Sustainability Reporting: Stop the Hype

I have just noticed the sparkling new Corporate Responsibility Report for 2011 published by ATOS, an international IT Services company, their third report. The first thing that struck me, even before I started to scan the report, was the delight and pride at Atos's achievement, for the second time, of the A+ Application Level of the GRI Framework. The Press Release is entitled: Atos Received Highest GRI Rating for its Corporate Responsibility Report. The Chairman's remarks start with: I am pleased to report that Atos has been awarded an A+ rating in accordance with the GRI standards for the second time in a row and the first in a list of 2011 key highlights is "Global Reporting Standards Recognition", which refers to the prior report's A+ rating and notes that this is: "recognizing Atos’ leadership position in the field of sustainability." Further on, in the Business Profile Section, Atos mentions its number of employees (74,000), its annual revenues ($8.5 billion) and yes, you guessed it : "Awarded an A+ by the GRI for its sustainability reporting." The "rated A+ by the GRA" statement appears again on yet another page mentioning 2011 Achievements.

The GRI Framework, as you know, offers three levels of reporting transparency - C (some disclosures and 10 performance indicators), B (all disclosures and 20 performance indicators) and A (all disclosures and all core indicators). The "+" refers to an external assurance statement. The decision at which level of transparency to report is a voluntary company decision. The GRI offers an Application Level Check which assesses whether the declared transparency level of the report actually conforms to the GRI Framework, and if so, issues a certificate to the reporting company to this effect. The wording of the GRI Statement is very clear:

Part of the GRI Statement from the ATOS report

The GRI Application Level Check is a quality assurance process, confirming whether a company has applied the guidelines in the intended and prescribed way. It is actually a very useful process. I have submitted two reports just this last month or so for a GRI for Application Level Checks on behalf of clients, and, I find that this is very helpful in ensuring rigor in preparing the report (you know from the outset that the disclosures and indicator responses will be scrutinized in detail) and in picking up issues which may have been overlooked, such as an incorrect page number in the Index, or a missing piece of data against one of the indicators. For new or inexperienced reporters, I am sure the GRI Application Level check also picks up some very significant omissions. I have spoken often about the quality of reporting - which is critical if reporting really is to become mainstream - and adhering to a selected Framework in the correct way is one part of delivering a quality report. The issue with the GRI Application Level Check is of course that it is only evaluates a small number of indicators and disclosures and is therefore not a comprehensive quality check. However, it is a worthwhile process.

Back to ATOS and the deliriously happy way in which they present the achievement of the A+ level as "recognition for sustainability leadership". Is the achievement of an A+ reporting level "sustainability leadership"?

In the GRI Reports Database for 2011, there are currently 2,802 reports, of which 68% declare an Application Level and 17% of the total number of reports declare an A+ Application Level (472 reports). Of these 472 reports, 248 (52%) are checked by the GRI and have received the GRI Application Level Statement.  Does this mean that 248 companies in 2011 are "Sustainability Leaders"?  Is conformance to the GRI Framework a reasonable measure of this leadership?

I am reminded of a whitepaper published earlier this year by BrownFlynn and CSRHub , entitled: "GRI Application Levels: Why Strive for an A". The PR about the study says: "The study demonstrates why companies with a higher Application Level are better able to manage their sustainability impacts, and provides evidence of a correlation between a company’s GRI Application Level and its reputation for sustainability performance. The study also clarifies the confusion around differences between Application Levels." Excuse me (or not) for being critical, but this contention requires a massive leap of faith, and this whitepaper, in my personal view, may encourage the type of thinking that puts more emphasis on the reporting level than on the report substance.

This is the conclusion of the whitepaper: ".. we conclude that a GRI Application Level can serve as a proxy for sustainability performance management and that a company looking to improve its sustainability performance should strive to achieve an Application Level B or higher."  While I fully agree that transparency is a catalyst for performance improvement, I am not convinced by the correlation put forward by this whitepaper. The conclusion is based on two main assertions:

First: that the GRI Framework has "implicit quality controls" : This is what the whitepaper says: "GRI subtly influences report quality through the specificity of the required disclosures. Although the Application Level is not downgraded when a company gives less information than the protocol requires, GRI is certainly not silent on the issue of report quality. GRI writes specific questions, encourages the use of third-party assurance, and then leaves it to the stakeholders to review the quality of the company’s disclosure." Well, errrrrrrrr, the GRI IS silent on the issue of report quality. There are no "implicit quality controls". The GRI provides guidance on how to respond to the performance indicators. That's it. A large cross-section of reports, I regret to say, do not apply these guidelines correctly at the declared levels, and even those checked by the GRI are only partially checked. The GRI offers a bonus "+" for third party assurance, which, in many cases, is hopelessly inadequate and does little to contribute to the quality of disclosure.

Second: that disclosure at Level A or B is evidence of "stronger sustainability performance". The whitepaper states: "A-Level and B-Level reporters disclose their policies, procedures, management approach, training strategy, goals and internal controls, whereas C-Level reporters do not. The conceptual differences .... predict that a company with well-defined sustainability training, goals, policies and controls in place is likely to have higher-quality data and risk management structures and, thus, demonstrate stronger performance. The CSRHub scores support this claim." I find this unconvincing. The GRI Framework is about consistent transparency of sustainability practices and results, not specifically about the quality of performance. The fact that a company discloses that is has a system in place for managing sustainability does not necessarily mean that it is performing any better than another company that does not disclose this information. The correlation of reporting levels to CSRHub scores is also a bit of a black hole for me. The whitepaper says that the CSRHub score, which is an aggregate of several external rankings, is higher for A Level reporters than for, say, C level Reporters, the difference being 57.4 versus 54.9 on the CSRHub scale. I have no idea what this means. How many A, B or C level reports were analysed is not disclosed and what a difference of 2.5 points actually means in terms of the quality of sustainability performance is opaque.   

Clearly, there has to be a correlation between transparency and sustainability maturity and performance quality. Clearly, a company performing well in sustainability has more extensive material that is relevant for inclusion in a Sustainability Report. Clearly, such a company may choose to report at the higher level of transparency. Even, and yes, I agree, companies use the GRI Framework as a form of benchmark to help them determine the sort of sustainability program they want to put in place. In this sense, the more extensively they adopt the Framework, the more their sustainability performance will mature and their ability to be transparent on a wider range of issues will be more significant. In our Global Transparency Index methodology, which measures the Website Transparency of the largest 25 companies in different countries,  more weight is given to A Level Reporting than B or C level Reporting. Transparency is a reflection of performance at some level.

However, this is a far cry from maintaining that disclosure at Level A or B is proof of "stronger sustainability performance".  You can be transparent and have rubbish carbon emission levels. You can be transparent and have 1% of women in management. You can declare GRI A Level and report on hardly any of the meaningful, material indicators by selectively navigating the GRI Framework. You can get a GRI A Level certification through good fortune that the inadequate indicators have not been picked up in the GRI Check. You can perform fabulously in terms of sustainability and choose not to report in line with the GRI Framework, or declare an Application Level.

Let's keep a sense of proportion, folks. The GRI Framework is a critically useful tool and has undoubtedly helped many companies develop their performance and their transparency in a consistent way. I am a  GRI supporter and recommend its use in all reports I write for my clients around the world. But let's be clear: an Application Level is not an "award", it is not "recognition" and it is not evidence of "sustainability performance leadership". Let's not advance this kind of thinking.

Instead, what will be more helpful, with the upcoming introduction of the GRI G4 guidelines, will be  the abandonment of a transparency "rating" for sustainability reports and the adoption of a more objective descriptor of  report transparency. For example: if there are core indicators, sector indicators and optional indicators, a report could be classified in terms of the percentage of disclosures and indicators it responds to in full.

In the case of the ATOS report, with whom we started out in this post, this is the situation:

• The report is written in accordance with the G3 framework (not 3.1)
• All Profile Disclosures are disclosed in full  with one exception.
• Management Approach Disclosures are all partial, except for Product Responsibility.
• The report does not disclose in full against 59 of the 79 performance indicators (75%).
• The report does not disclose in full against 36 of the 52 CORE indicators (70%).
• There are zero full disclosures in the Social (SO) category of indicators.
• One indicator (PR9) is not disclosed because it is "proprietary information.
• 27 indicators are not disclosed because the information is "not available".
• 18 indicators are not disclosed because they are "not material".
• EN29 and EN30 are not even included in the GRI Index - which is a clear error.
• ATOS adds 13 indicators under the heading AO. This is not explained - and I assume it is Atos own-generated indicators ? - it doesn't match the GRI Airport Operators Sector Supplement which has  AO prefixed indicators.
• The GRI Index in the report does not contain page numbers, only section headings, making it difficult to locate responses to indicators.

As you can see, it is possible to get this highest A+ "accolade" without actually disclosing much of the information required in the GRI Framework, and without necessarily making a stretching step-change in performance. 

So let's stop this "strive for an A" hype and concentrate on advancing sustainable business and a fair, balanced, material and transparent reflection of performance.

Apologies to ATOS for picking on this report to make my point, as, in other respects, the report appears to have been prepared with a high level of rigor and evidence of good process. Also, this post should not be construed as a criticism of the CSRHub data aggregation - just that in this specific case, I was not convinced of the conclusions drawn in relation to Reporting Levels as a predictor of sustainability performance or leadership.

 

elaine cohen, CSR consultant, winning (CRRA'12) Sustainability Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices  Contact me via www.twitter.com/elainecohen   on Twitter or via my business website www.b-yond.biz  (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm)

Sustainability Reporting with Integrity

I have been involved in the writing of many Sustainability Reports. In fact, it's one of the main services I provide to clients and something I spend a whole lot of my time doing. Several of the reports I have worked on have gone through the GRI Application Check (including the report of my own company, Beyond Business Ltd). This week, I received the results of the GRI check of the fourth report I have submitted this year, 2011, one being our own and the other three for clients (reports not yet published).

Now, here's my conclusion.

It's always worth submitting a draft report for the GRI Application Check.

Despite the fact that the GRI check is limited and does not cover EVERYTHING that's reported, what is does cover is very thorough. As experienced as I think I am in working strictly to the letter of the GRI framework, which I think I know very well indeed, there is occasionally something, no matter how minor, that I overlook. The GRI check really does help me in ensuring that I support my clients in delivering a report with integrity i.e. if it says it meets Application Level A, B or C, it does. Even reports which are externally assured are often not rigorously checked for adherence to the declared Application Level.

Using the GRI Reporting Framework is a choice. It is perfectly acceptable (though, arguably, not leading edge) for any company to write a Sustainability Report without adhering to the GRI or any other guidelines that may exist. It is perfectly acceptable to go with your own sustainability reporting flow and just do it your own way. However, if a company chooses to report using the GRI guidelines, then my expectation is that they will adhere to the guidelines right down to the fine detail of the indicator and the indicator protocols. For me, the credibility of a reporting company really drops when the company declares adherence to a GRI Application Level, and after even the most briefest of checks, it is apparent that the company has not met the requirements.

I see this as a question of professionalism, thoroughness and yes, integrity.

In order to earn the prestige / reputation / goodwill benefits associated with GRI Reporting,  many companies rush to self-declare adherence to the GRI at some level or other but don't follow through with the rigor and discipline required. As we say in Manchester, ignorantia juris non excusat. This means that you cannot claim not to understand the guidelines - everything is perfectly clear and if it is not, my experience of the GRI is that any question gets a response within 24 hours. So not adhering correctly to the GRI guidelines (after making a declaration to the contrary)  is either a question of genuine misunderstanding, minor oversight, generally sloppy work or intent to deceive. Harsh ? Maybe. But that's exactly why the GRI check is available.

What does the GRI actually check?

The GRI Content Index is checked for completeness, correctness and usability. This means that the GRI checks whether the completed GRI Content Index in the draft report answers the required number and set of standard disclosures for the self-declared Application Level (completeness); that the way in which the reporting (or not reporting) has been addressed is in-line with the self-declared Application Level and accepted standards (correctness); and that the Index serves as a functioning navigation tool (usability) including whether page reference numbers are correct.

GRI checks a sample of the standard disclosures. GRI takes a sample of the standard disclosures and determines whether the reporting claims made in the Index can be substantiated. For this purpose, the GRI checks the text to see if a quantitative standard disclosure has been answered with a pertinent quantitative response and a qualitative standard disclosure has been answered with a pertinent qualitative response. You cannot know upfront which of the disclosures the GRI will actually check, so as a reporter, you must make sure that all the disclosures required for your declared Application Level are reported correctly.

The Content Index Check List is a very good tool for reporters, breaking down the reporting requirements by indicator into precise reporting requirements and the type of response required (quantitative, qualitative).

Reporting inconsistencies from my own experience

Some of the things I get pulled up for are quite minor. I had to laugh when I wrote in my own A level Sustainability Report that one person out of a team of four left the business during the reporting year. The indicator, LA2, requires a percentage as well as a number. I had to correct that disclosure to "one person (25%) of our workforce left the business".  In a micro-enterprise like mine, the percentage is rather insignificant. But take a company of several hundreds or thousands of people which you want to benchmark for turnover against peer companies. The percentage of employee turnover, not the number,  is what makes the data comparable. In another report, I wrote that the reporting company sources all electricity from the National Grid (Indicator EN4). Not enough. I had to add the details of the primary sources of energy for electricity production used by the National Grid. Another example relates to the scale of the reporting company. I had not included market capitalization. (Indicator 2.8). Tougher examples might include detailed disclosure of stakeholder engagement practices. This is tougher because, while companies want to report, they may not have documented effectively all of their internal and external processes relating to stakeholder engagement. (Indicators 4.14-4.17), especially if this is a first time report. Sometimes, an oversight may just be a matter of not indicating the correct page number for the relevant content in the body of the report.

Adding punch for consultants

I also find that, as a consultant writing reports for companies and advising them on content, the GRI check helps bring certain issues to a head. Companies often anguish over what to disclose and what not to disclose, or whether it's worth making the effort to supply certain content. I would rather not count the amount of times I have successfully used the line: "This is required for GRI Application Level B" or " If you don't provide this data, we will not be able to pass the GRI Application Level check". For companies for whom the GRI check is important, either because it helps create internal legitimacy or external standing, it works every time, thereby helping to increase the real transparency (and not only the declared transparency) of any report.

And finally....

The GRI Application Level check is not assurance and it not exhaustive. But knowing that an external body is going to check your adherence to the guidelines does make for a heightened degree of discipline. When writing a Sustainability Report, there is always a lot to think about and it's always a rush to get it all done at the end of the process. It's easy to miss minor details. It's easy to forget that you needed to go back and check that last point. It's easy to overlook that the pagination changed when you added a few extra sentences.

Reporting with Integrity is not just about reflecting your sustainability performance in an accurate and balanced way. Reporting with Integrity is also about being true to your word. If your word is that you have adhered to the GRI Framework at Application Level B, then I expect to see that you have done that.

PS:

I would add at this point that I believe there is room for a revision of the GRI checking system. I think the GRI should offer a check which includes the entire content of the GRI Index, and not a sample check. Assuming that the A, B, C or some other type of transparency differentiator will be adopted in the new G4  guidelines, I believe the GRI should also offer a solution to ensure that declared adherence is correct in a more comprehensive way.  This will enhance the credibility of the reporting companies and also in the guidelines themselves. Who cares if that will make my life so much more difficult :)

PPS:

The GRI did not ask me to write this post! I am a GRI Organizational Stakeholder but otherwise have no connection to report-checking other than professional interest in a more robust reporting system.

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices   Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

The GRI Year in Review 09/10

Nope, it's not a Sustainability Report (that's due later in 2011), but it is a comprehensive summary of what the GRI has been getting up to between July 2009 and June 2010. It's the GRI Year In Review Report for 2009/2010, released today.

The 09/10 year for the GRI was quite a memorable one which included the outstanding third GRI conference in Amsterdam in May 2010 (1,209 attendees, dubbed "the largest multi-stakeholder conference focusing on the role organizational transparency plays in achieving a sustainable global economy") at which the GRI declared its visionary goals including:

By 2015, all large and medium-size companies in OECD countries and large emerging economies should be required to report on their Environmental, Social and Governance (ESG) performance and, if they do not do so, to explain why; and by 2020, there should be a generally accepted and applied international standard which would effectively integrate financial and ESG reporting by all organizations.

Despite the fact that the achievement of these goals still seems light years away, and, let's face it, 2015 is right in front of our noses, the GRI has made considerable progress as the only global comprehensive sustainability reporting framework available, translated into 25 languages and increasing in uptake year on year.    The GRI says that the data shows that more companies are having their sustainability reports assured, resulting in more accurate and trustworthy data and that statistics for 2010 reflect a global upwards trend in sustainability reporting, suggesting an increase in the use and awareness of GRI Guidelines. In 2010, 1,818 reports were recorded as using the GRI Framework (up 22% from 2009). The GRI recognizes that this does not include all sustainability reports which are estimated by CorporateRegister.com to reach close to 6,000 in 2010, but the GRI says that the GRI database and their Reports List which is freely downloadable is indicative of overall reporting trends.

The Year in Review opens up with an introduction by Elaine Cohen :-) (go on, take a look), and follows with an overview of updates to the GRI Framework undertaken in 2009/2010 leading up to the GRI 3.1 update and a review of sector supplements. Also in 2009/2010 the GRI made (welcome) strides to achieve greater partnership and alliance with a range of other organizations which promote sustainability and in some cases, reporting: the UNGC, the OECD, CDP, Earth Charter, IFC and ISO (for the ISO 26000 development). These alliances are important on the journey towards standards harmonization which the G4 framework overhaul will (hopefully) address over the coming year.

The Year in Review outlines the strides made in sustainability reporting and how reporting has been a catalyst for performance improvement in  many companies, as well as the developing technology focus to support more efficient reporting processes. The GRI has also advanced a successful partnership program for SME's in supply chains,  a project which should be scaled up with many more MNE's, in my view. The globalization of the GRI with the increase in Focal Points and partnership projects around the world, including the 179 times GRI staff were asked to speak at external events, and the engagement of 564 Organizational Stakeholders (members, in lay-language),  completes the picture of the penetration of the GRI Framework in many countries. The GRI's position on informing government policy change is also covered, and though tangible results are still a somewhat lightweight, the GRI is working hard to engage policy makers to put sustainability on their agenda.

Finally, what's next?  The GRI highlights expansion of its network in new geographies, translation of more publications, the G4 upgrade, collaboration with the IIRC, and the Next Big Conference in 2012. So far, so good, but personally, I believe this falls short of a concrete plan, with milestones, to deliver the visionary goals mentioned above. The GRI has less than 4 years to have companies required to report on ESG in OECD and emerging economy countries in order to to achieve their first goal. I would like to see more specific plans as to how this might be achieved because, aside from a few pioneers (Denmark, South Africa etc), I don't yet see significant strides towards this worthy goal.

Additional data on reporting status and trends from the GRI reports database shows an increase in GRI based reports every year since 1999 (see table on left). A GRI based report must contain a GRI content index. There are many reports published which use the GRI Framework as a guideline but do not include a content index and these reports are excluded from this data.

Europe leads the pack in GRI-based reporting at 45% of all reports published globally in 2010 (Spain is the largest reporting country in Europe). Asia follows at 20% and the USA and LATAM tie in third place with 14 % of reports published in 2010.

Looking at data by country, the USA, Spain and Brazil top the list for absolute numbers of GRI-based reports published in 2010, but Sweden, Spain, The Netherlands and Japan top the list for numbers of GRI-based reports per country GDP which is a much more relevant measure.

In terms of  sectors, the Financial Sector leads the field in 2010, followed by Energy, Energy Utilities, Food and Beverage and Mining. The GRI database shows that 12% of reports published in 2010 were Integrated Reports, and 33% of reports are sent to GRI for the Application Level check.  29% of reports published in 2010 reports achieved an Application Level A.
A whopping 47% of GRI based reports receive external assurance, though we all know that assurance remains somewhat of a Wild West. Another interesting piece of data shows that reporting by SME's has been increasing year on which is a welcome development and one which I expect to fully continue.

The Year in Review 09/10 is a nice summary of where the GRI is up to and is worth a look. GRI is staying very much on the radar on Sustainability Reporting and no conversation on reporting can take place today without reference to the GRI Framework. That's quite some achievement for what is still a relatively young organization, even though there is still so much more to do. The future agenda should include not only an increase in the quantity of reports, but also greatly improved quality of disclosures and accountability for impacts (not only actions). While we must value the drive towards greater transparency of business, and the GRI Framework is an essential stepping stone to transparency, we must all retain  focus on the fact that what the world needs is sustainability and not only sustainability reporting. Having said that, by now you all know that I am a strong supporter of the GRI and perhaps you might also know that I was born eternal optimist (that comes just after the fact that I was born an ice-cream addict), so with more hard work, clear direction and the vitality of the GRI team, there's a chance that it's all gonna work out.  

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

Is Marks and Spencer's ladder standing against the right wall?

I am often approached by students to provide assistance with their studies on sustainability. This time, an MSc student from the UK challenged me with several questions about the Marks and Spencer 2010 report. Whilst I don't manage to response to everyone in such great technicolor detail, I used this student's questions as a great opportunity to study the M&S report and blog about the iconic Plan A, all the while assisting with the study of sustainability.

Here are the questions in red with my answers in boring old black:

What is the GRI Application Level sought by the last report by M&S 2010? I have read that it is C, but looking at the GRI index at the end, it is not clear. How do I get this information?

Yes, it's true, some reports don't clearly state the Application Level of their report in a very visible and accessible way. The M&S Report notes on page 40: "To provide a common point of reference, the Global Reporting Initiatives’s (GRI) third generation G3 framework has been used as a checklist. As the Report is mainly based around our Plan A commitments it has been prepared in accordance with the level C". I interpret this to mean that they have not rigorously applied the C framework but have more or less, in a roundabout way, generally speaking, rather, somewhat, glanced at the GRI C framework. In actual fact, after a quick review I can see that one of the mandatory disclosures, 4.15 (basis for identification and selection of stakeholders with whom to engage) is not reported. You can look at the GRI Application Levels table on the GRI website to know what indicators need to be reported at each level.

M&S doesn't explain how they selected their core of stakeholders (4.15). However, although there is lot of literature on M&S, I never found a stakeholder unhappy to be left out. Most of the NGOs and Think Tanks commentators are positive about M&S's report (and therefore M&S's way of selecting stakeholders). Here is the contradiction: apparently they haven't reported properly (4.15) but nobody is complaining as if they have done well practically. Is this correct?

Actually, the  Stakeholder Dialog section in the M&S report (pages 42 and 43) is quite impressive and certainly has more breadth and depth than most of the reports I read. Stakeholder dialog is one of the most important parts of a sustainability report and most don't do it well, mainly because they don't have a structured approach to stakeholder engagement and therefore revert to reporting about general conversations with customer and suppliers and mentioning a few industry associations they are affiliated with. True stakeholder dialog is the fundamental basis for legitimacy any organization can seek, and representing it well in the Sustainability Report one of the strongest pillars of credibility. M&S report on how they engaged an external party, Ernst and Young to gather "impartial feedback" from a range of organizations, which the report lists. All of these organizations are NGO's which focus on different aspects of sustainability. The broad stakeholder responses gained from this exercise are listed and are quite enlightening being not simply complimentary but offering good suggestions for M&S's sustainability direction. M&S's responses to the responses are also listed. In addition, M&S reports the channels for stakeholder interaction with other stakeholder groups. 

This is a good overall representation of stakeholder engagement. We might of course ask how the stakeholder groups were selected, how many stakeholders from each NGO consulted provided feedback, and why they elected to use an external party to facilitate dialog rather than create a direct route for discussion involving M&S people. We might ask for more information about the true nature of stakeholder dialog with employees, suppliers, customers and regulators, some of which is only briefly referred to in the body of the report. We also might wonder how much stakeholder feedback and input influenced the selection of Plan A commitments (and we may need to go back to January 2007, when Plan A was launched, to find out) or the new 80 commitments launched in March 2010. In response to the point about no-one complaining because M&S did not disclose against 4.15, I would say that, first of all, we don't know who complained and if so, because M&S does not disclose this. In general, however, M&S does do well with a strongly branded and well-communicated Plan A, and a very detailed report against the commitments they have made, so I doubt there will be a stakeholder lobby about a gap against profile disclosure 4.15.

They said that they reported on 4.17 (what the stakeholders have to say). However, they reported only what the stakeholders said on the issues that M&S selected. So, we don't know whether the stakeholders presented other issues as material or not. Again, I never read practical criticisms of materiality on regard of M&S report 2010. I only read your comments to the report of 2008, on regard of the lack of transparency of what happened when employees were made redundant. So, am I right that 2010 report still lacks of transparency on materiality but that, at the same time, the public seems happy with it?

This is a good point. M&S have not published a materiality matrix. We are left to assume that the 100+ commitments reflect the most material issues. We don't know from the way M&S reports anything about the relative intensity of the feedback the company has received from different stakeholders, nor do we know how these issues tie into M&S's core business strategy, aside from some obvious assumptions relating to growth and cost savings. The plan A commitments range from aiming to make all  UK and Republic of Ireland operations (stores, offices, warehouses, business travel and logistics) carbon neutral by 2012  (no. 1), to maintaining a non GM food policy (no. 53), to introducing a range of recycling services for customers including a project for used clothing (no. 44) to providing improved health and lifestyle information to employees (no. 100) and a whole lot more in between.  Which of these are material?  Which are more material ? Which are most material? And why? M&S did not meet commitment no. 49, to triple sales of organic food by 2010. In fact, 2009/10 sales were below 2005/6 levels. Is this of any material significance? Will the general health of consumers be seriously affected by avoidance of organic foods? Will M&S's share price take a hit because of this? Will fertilizer and pesticide volumes used in M&S products be increased as they sell less organic food? 

M&S have a checklist of performance indicators, their own kind of GRI, and they work through this. The difference between Plan A and the GRI framework is that the GRI framework, imperfect though it may be, is a multi-stakeholder consensus driven platform which is now widely accepted as leading practice. The M&S Plan A is a unilaterally developed performance program. It's a bit like the ladder against the wall analogy. M&S are outstanding ladder-climbers, but is the ladder standing against the right wall? And how do we know?

In response to the point as to whether the public are happy with it, it seems they are. M&S enjoys much participation from consumers and gains much kudos from thought leaders in this space. The company deserves great credit. They are doing far more, and doing it far better, than many. Perhaps that is the limit of their stakeholder aspirations (and perhaps they know that).  

  

I have the feeling (from many readings, but I can't point to any specific one) that the supply chain issue is better covered by other competitors, such as Sainsbury. However, M&S is famous for being very demanding with its supply chain, being mostly the only big retailer that is sending auditors everywhere. So, could M&S be weak on reporting on supply chain, but strong in practice? Why would it be so?

I think part of the response to this is the format M&S uses for its reporting. Rather than describe policies, goals, objectives, case studies, and provide a platform for stakeholder voices in the report, the Sustainability Report is a list of commitments and status statements against Plan A. This makes for a very disjointed view of the M&S performance. We only know about anything insofar as it is encompassed in one of M&S's commitments. Reporters who weave goals and objectives into a body of narrative which flows logically may well give an impression of more comprehensive reporting when in fact they may be doing less than M&S.

Marks and Spencer report is a C Level but why is it self-declared and C only (not C+) given that it was externally certified by Ernst and Young ?

The assurance statement by Ernst and Young could qualify for the GRI "+". However, as mentioned earlier, M&S are very hedgy about their claim to Application Level C. They have not really declared and Application Level but merely assessed their level of disclosure to be in adherence with Level C guidelines. They could have said C+ guidelines just as easily. However, the assurance statement did not assess the M&S report against the GRI guidelines requirements, which I would expect it to do if assuring a true GRI report. Perhaps it was just easier all round to leave this point rather fuzzy.  

So, that was, for me, an interesting review of the Marks and Spencer report, based on an even more interesting set of questions from our London student. I think that definitely deserves a Chunky Monkey next time I am in London, don't you ?

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

Interesting times for Sustainability Reporting

The next few years are looking interesting, we might even say exciting, on the sustainability reporting front. Two significant step-changes in reporting that we know we can expect are (1) the GRI G4 guidelines and (2) the Integrated Reporting framework. Last week, I attended the GRI webinar for Organizational Stakeholders where Nelmara Arbex, the Deputy Chief Executive of the GRI, took us through the paces on the way GRI is approaching both of these major developments.

The G4 - next generation of GRI guidelines

G4 is the new improved ! GRI framework which is scheduled for launch by 2013 for use in reporting probably during 2015. The process of developing the G4 will be the GRI's familiar multi-stakeholder process whereby broad consultation over a prolonged period will lead to the development of a final G4 draft by the end of 2012. G4 has ambitious objectives, designed to meet several needs as GRI expects to ramp up the number of companies reporting over the next few years. Whilst reporting has made massive headway, particularly amongst the larger public companies, the fact remains that upwards of 80,000 public companies have not chosen to disclose sustainability information. 

The G4 identifies two broad goals: improve the G3, and prepare for scale-up. This is how Nelmara Arbex presented the objectives:

Improving G3: 

• Provide better guidance on how to report on governance issues
• More robust definitions to better support assurance processes
• Updated sustainability scope
• Guidance related to current stages of normative frameworks such as UNGC and OECD reporting guidelines
• Revision of the current Application level definitions

Prepare for scale up:

• Offer a variety of flexible reporting elements for use by reporters dealing with different requests
• Develop a user friendly format
• Link to the International Integrated Reporting Committee framework
• Link to broader ESG reporting requests and ESG information users 

Much of this might look like sudoku to you at this point, so let me try to fill in a few blanks from my own perspective.

G4 is the right direction

I will start by saying that I agree the G4 is the right way to go, and that there are many ways the current framework can be upgraded and modernized. As the GRI gains ground and becomes the de facto single reporting standard in the world, the name of the game will be not only to report on sustainability but also to do so in line with the GRI framework. As reporting "scales up" to achieve the aspirational mainstream, it makes absolute sense to reposition the common denominator and provide a platform which enables what we all want - a fair and balanced reflection of a company's sustainability performance and material impacts on all stakeholders in a way which is auditable, comparable and aligned with the business results. Additionally, disclosures should be accessible and presented in a way which makes it easier for stakeholders to use the data in a range of decision making tools.

Updated sustainability scope

The G3 is long and detailed but not long and detailed enough. The GRI's aspiration to "modernize" the G3 by including new sustainability issues which have emerged more visibly during the last five years since the G3 was developed in 2006 is absolutely relevant. Some issues have become more important such as the entire approach to water management whilst some represent new territory for the GRI such as the question of internet privacy and online exposure and intervention of corporations on social media, as well as a company's approach to managing employee presence on the world wide web. Other issues are not specifically covered in G3,  and I believe should be considered, such as the issue of road safety and how companies manage employees who spend a lot of time on the road for work purposes, a significant source of fatalities and other accidents which endanger not only employees but the general public. Many Sector Supplements  have been developed during the past 5 years and it may be that some indicators which have been identified via a single sector should be mainstreamed into the overall framework. My recent editorial for CSRwire.com refers to the mushrooming of sustainability fragments - specific industry associations that address single aspects of sustainability common to industry groupings - and it may be that these are also throwing up issues that G4 should address as basic opportunities for a common approach to disclosure. Updating the sustainability scope, providing the broadest possible scope for companies to report against the indicators which are material to them, is therefore a challenging but worthy objective for G4.

Improve the robustness of the GRI framework application

It is painfully obvious that many Sustainability Reports that have not applied the framework  lack rigor and balance. Regrettably, this can also be said of many who do use the framework, given a widespread lack of attention to detail when reporting on specific indicators. Far too often we find a GRI index at the back of a report which is neatly ticked off as fully disclosed only to find that, after detailed scrutiny, there is some fuzzy blurb which does not meet the requirements of the indicator. This is not helped by the hands-off approach by the GRI. The GRI Application Level Check, whilst very useful in providing an element of rigor in how the framework has been applied, only covers a small portion of the disclosures in any report and entirely skips over the quality of the assurance process.  Given that the GRI framework is not positioned as a "standard"  in the same way as ISO standards, for example, but as a helpful  tool for organizations, the GRI has distanced itself from any kind of "policing" or auditing of the use of the GRI framework, leaving the door wide open for all of the 1,500 users of the framework to "self-declare" pretty much anything they like. Sustainability is about impacts (outcomes) and not only inputs (actions), and as the GRI framework is the gold standard of how to report on sustainability (outcomes), I believe there has to be a greater connection between what companies are saying they are reporting and what we can actually find in the report. Therefore the GRI ambition with G4 to improve the framework to enable more rigorous assurance is a good objective of the G4 process.   

Provide a solution for harmonizing of reporting

As attention to sustainability has grown, so has the number of users of sustainability data, ranging from investor-targeted analysis and players in the financial markets, but also large companies who have understood that the sustainability of their business is linked to the sustainability of their broader supply chains. Companies such as Walmart and many others require sustainability data from their suppliers. Focused initiatives such as the Carbon Disclosure Project require data in a specific form. Local regulators are now requiring companies to include sustainability data in annual reporting. The UNGC and the OECD with whom the GRI has formed alliances, have their own reporting requirements as well. The plethora of requests to disclose that any company has to deal with is now becoming overly burdensome. The G4 aspiration is that reporters will be able to kill 43 birds with one stone and  cover off all bases with one set of guidelines. Harmonization should utopically make it possible to ensure all the data anyone might need is contained in one report. This is massively challenging but if achievable, is well worth the effort.

Revision of the current Application Level definitions

Aah, application levels. This is an interesting and controversial debate. At present, the Application Levels tend to be seen as an indication of the quality of the report, though as we know, the C, B or coveted A represents the measure of transparency, rather than quality. Arguably a more transparent report is of higher quality, but transparency still does not address the quality of the information provided. The gap between the levels is problematic - where a C report requires 10 indicators, a B report requires 20 and an A report requires all 79 plus a published Sector Supplement if relevant. The random selection of indicators, including some which are fairly lightweight and non-material to a particular business, can mean that a C reporter can actually produce a sustainability report without disclosing hardly anything about their true sustainability impacts, and a B reporter may not be much better. 

In my view, the Application Levels are unnecessary. What should be required is a summary table of indicators, in addition to the GRI detailed index which shows what has been reported and where to find it, which presents a quick n' easy overview of how many and which indicators have been reported in full. Profile and Management Approach disclosures should be required for all reports (currently C reports do not require Management Approach disclosures) as should, I believe, a minimum number of core indicators against which all companies should report. In other words, G4 is an opportunity to raise the threshold for all reports. Additionally, reporters should make it easier for us to see what else they have included. In this way, we would have a 45 report, or a 79 report, or a 15 report, or a 23 report, where the number refers to the number of indicators reported in full, in addition to the "pass" level of minimum disclosure. Partial disclosures are a bonus but, in order to achieve harmonization and a realistic assessment of sustainability performance, we need to look at full disclosures against indicators and not only work-in-progress or wannabe disclosures.

Alignment with the IIRC framework

For the uninitiated, the IIRC is the International Integrated Reporting Committee, established in 2010 by the GRI and the Accounting for Sustainability movement to create a globally accepted framework for integrated reporting.   The objective is that G4 should help companies to prepare for managing an integrated process in their companies and produce an integrated report in line with whatever framework the IIRC comes up with. The governance of the IIRC is as shown in the chart below, presented by Nelmara Arbex:

The members of the IIRC working group are predominantly accountants and investment experts, which tends to predict the nature of the output as predominantly geared towards the interests of financial markets, which is a double-edged sword and needs to be managed carefully. One of the objectives is to understand the link between sustainability impacts and financial results, if you like, a kind of platform for the financial ROI of sustainability as it is applies in a given company. This may yield some interesting outputs, but the integrated reporting framework is still a moving goalpost, and the preparatory alignment of G4 with the IIRC expected directional outcome makes sense, provided G4 does not become a pawn in the scheme of increasing the financial wealth of the already wealthy at the expense of other stakeholders.

G4 Technology

Another aspiration expressed for G4 is the use of new technology to make sustainability disclosures more accessible and allow for deeper analysis of data. New tools, ranging from XBRL to online reporting to  iphone applications and direct realtime data feeds to a range of applications could take reporting to another level and give stronger presence to sustainability performance for stakeholders. The GRi has also begun licensing software applications for GRI reporting, and once can understand an interest in these being more widely used. How technology can be used effectively for improved content development, greater accessibility and transparency of non-financial disclosures, as well as providing support for public consultation, is a challenge. Part of this is how the GRI presents the new G4 framework and what technical tools, in addition to a set of indicators, the GRI will provide. Thinking will have to transcend the basic excel tables and PDF's but not force reporting down a mechanical join-the-dots approach, exemplified by the "Let's Report" C level template.

Continue the debate

What's clear, is that the debate will continue, and if you have got this far in this obscenely long post, you might be interested in hearing more of Nelmara Arbex and other throught leaders in this space at a conference in London on 25th March, hosted by Justmeans, called Redefining Value, which I will  also attend. I love a good debate!

I could continue ... and I probably will at some stage ... but in the meantime, is there anyone who doesn't agree that the next few years will be an interesting time for Sustainability Reporting ?

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices  Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)

The Wild West of CSR report assurance

Sustainability reporting assurance. It's called assurance because its purpose is to assure you that the report is (1) accurate and (2) relevant. Accurate meaning you told no lies and made no mistakes in your data (that extra zero on the end of your annual cash donations number, or that missing digit in your carbon footprint calculation). Relevant meaning you reported on the most important things (materiality) and you didn’t leave out things that might influence the way stakeholders make decisions (our product was contaminated due to poor machine cleaning processes and 183 people were food-poisoned) .
For any of you who have ever written a CR report, you will know that deciding what to include and what to leave out is probably the toughest part of the process. The assurer of a report looks for what's in there, and what's not, and how accurate what's in there is. (An excellent assurer would look for how accurate what's not in there is, but he would probably charge more for this). The theory goes that if your report is assured, it has a better chance of being credible, and enhancing the trust of your stakeholders in your reporting and in your company.
CorporateRegister.com statistics show that around 25% of all reports are externally assured. And if you really want to know the nitty gritties, you can view the report by CorporateRegister.com issued in July 2008 called Assure View .You can read all about AccountAbility standards which set the framework for assurance at their website , and you can see what the GRI says about the criteria for good assurance.
Now that the formalities are over with, I guess the key point I would like to make in this post is that not many of the assurance statements I read actually assure me. Aside from all the fancy theory, what do I look for?

• the DETAILED EVIDENCE that sufficient practical work has been done to delve into the guts of the reporting process and content in order to assess accuracy and relevance.
• the NAME of the assurer or assuring team (not just a Company) who sign off on the statement
• the CREDIBILITY of the assuring team – their prior experience or qualifications in assuring CSR reports
• disclosure regarding the INDEPENDENCE of the assurer and the nature of the assurers relationship with the reporting company
• the GOOD NEWS and the BAD NEWS (recommendations for improvement) relating to the reporting process and content
• a CLEAR STATEMENT that the report has what I call integrity (a fair and balanced representation, in csr-speak).

I recently reviewed the State Street Bank report for CorporateRegister.com and highlighted the assurance statement as outstanding. It addresses all my points above comprehensively, succinctly and left me feeling that a thorough job had been done.
I took a look at some 2009 reports to see how their assurance statements shape up. ( I do not name assurance providers – you can check out the reports if you want to see who they are – my intention is to focus on the work and not the workers) :

Barrick Gold Corporation, 2008 report : reporting level A+
An interesting statement, assuring two things: this mining company's adherence to the Sustainability Principles of International Council on Mining & Metals (ICMM) and adherence to the GRI framework. There is a very detailed list of activities the assurers performed and a longer list of points for improvement. The conclusion says that Barrick has aligned its sustainability policies to ICMM’s 10 Sustainable Development Principles and in all material respects, reported in accordance with the GRI Sustainability Reporting Guidelines (2006) - level A requirements and the associated GRI Mining and Metals Sector Supplement Pilot Version 1.0 (2005) as presented in the GRI Content Index. That's clear enough for me. Credibility added value: dix points.
Wartsila Annual Report 2008. reporting level A+
Wartsila is a power company operating power plants and providing power solutions.The assurance statement in this report is a turn-off. One page short, it barely describes the assurance process activities, though the two (yes, just two) interviews conducted with senior managers and 2 site visits are mentioned (Wartsila operates in 160 locations). This is one of those assurance statements that ends up with "Based on our work described above, nothing has come to our attention that causes us to believe that the Sustainability Information,based on the abovementioned criteria, is not fairly stated in all material respects." That really oozes decisiveness and builds credibility, right? I wouldn’t pay someone to make a statement like that. Credibility added value: zero points.
Trelleborg AB, Sweden, 2008 CSR report: reporting level B+
Trelleborg is an engineering group which develops products based on polymer tecnology. The Assurance statement in this report  is based on a limited review of about 6 performance indicators. Activities for this limited review are included. Two site visits were made, and the rest was discussions and reviews. The conclusion is the multiple negative one – "nothing has come to our attention that …".
Credibility added value: zero points
Athens International Airport, 2008 report :reporting level B+
Published in the form of an eBook (what a painful way to read a report)  (I downloaded it – 31 MB). This is a short but nice statement. It lists a fairly long number of assurance activities. It contains both a positive statement and a multi-negative statement. Positive: "the range of topics reported provide a fair and balanced representation…." and negative , relating to KPI's "nothing has come to our attention that causes us to believe. …".
Credibility added value: sept points
OHL Group.2008 report : reporting level A+
This is a Spanish holding group with a range of interests mainly around construction and real estate. The assurance statement is a scanned copy of a one-page letter, designed to be almost illegible. The activities are listed, but they are super-general – review of .. checking that … analysis of …testing on a sample basis … It's hard to get a real feel for what was actually done. I was encouraged to know that the "review procedures did not disclose any matter that would lead us to believe that the information furnished on the degree of progress on the Corporate Responsibility targets for 2008 is materially misstated". To put it another way, we didn’t find any major blunders in reporting against targets.
Credibility added value: deux points
Telefonica 2008 report:  reporting level A+
This report has a great assurance statement – the detail included in the activity list includes ONE HUNDRED interviews with Telefonica people and states the purpose of these interviews - and much more. This gives me confidence that the assurance assignment was undertaken with seriousness and professionalism. It ends up with that double-negative again – "no significant matters that would lead us to believe that it wasn’t "etc. … but there is a crispness and comprehensiveness about this statement that gives you confidence.
Credibility added value: neuf points.

So, you know what?

I think assurance needs to get its act together. If the assurers aren’t prepared to put their neck out and say "we believe this report is credible" then why pay them? If they aren't prepared to do the leg work and list it in detail, why bother? If their credibility added value is below dix points, when why let them loose in your organization?
There is no accepted template for an assurance statement. There are general guidelines but no checklist that all assurers adhere to. And no qualitative assessment of assurance statements. And the GRI barely pays attention to this, checking only the existence of an assurance statement, and not its quality, in order to assign the coveted + to any reporting level. I think the time has come to establish a framework  for the verification of CSR reports that includes prescriptive format and content, much like the GRI framework. The GRI should consider adding performance criteria relating to the quality of the assurance statement. And allocation of the coveted + should be a little more rigorous.

If assurance is to move up from its current 25%, it has to add more value.
The Wild West of assurance needs to stop.  


elaine cohen is the joint CEO of BeyondBusiness, a leading reporting and social-environmental consulting firm . Visit our website at: www.b-yond.biz/en