GRI Standards: Governance Galore

This is the fourth post in the exclusive read-only-on-the-CSR-Reporting-Blog unraveling of the GRI Universal Standards Exposure Draft that is now open for public comment. At 106 pages, the draft may seriously turn lockdown into meltdown. That is, of course, unless you give the technobabble a miss and skip to the juicy nuggets. Thanks to Wes Gee for this tweet.

Check out the first posts here: The overview. The human rights spotlight. The materiality clarity.  Or dive straight into today's ton of juicy nuggets ... all about probably the part of sustainability reporting that most reporters find intensely boring...governance! How many really exciting and fun governance disclosures have you spotted in sustainability reports?

(One of the most colorful and human presentations of governance disclosures I have seen recently is in the Del Monte Pacific 2019 Sustainability Report - makes you think that governance might not be so boring after all!)

Anyhow, the thing you might unwittingly overlook if you have been a regular GRI Standards Core Level reporter, is that the new proposed In Accordance rule now includes ALL the general disclosures on governance. Currently, at Core level, all you need to do is report Disclosure 102-18 on covering governance structure and Board Committees, including those with responsibility for economic, environment and social topics. Generally, this information is reported anyway by public companies in their annual reports, so a brief reference in the sustainability report often did the trick. Not overly stretching, and not overly transparent either.

The new Universal Standards Exposure Draft changes all that. There are no less than 15 governance disclosures that organizations wishing to remain In Accordance must report, with no acceptable omissions.

• GOV-1 Governance structure and composition 
• GOV-2 Nomination and selection of the highest governance body
• GOV-3 Responsibilities for sustainable development topics and delegation
• GOV-4 Stakeholder consultation on sustainable development topics
• GOV-5 Chair of the highest governance body
• GOV-6 Conflicts of interest
• GOV-7 Role of the highest governance body in setting purpose, values, and strategy
• GOV-8 Collective knowledge of the highest governance body
• GOV-9 Evaluation of the performance of the highest governance body
• GOV-10 Identification and management of impacts
• GOV-11 Role of the highest governance body in sustainability reporting
• GOV-12 Communication of critical concerns
• GOV-13 Remuneration policies
• GOV-14 Process for determining remuneration
• GOV-15 Annual total compensation ratio 

All these disclosures require more than easy-to-draft one-liner responses – they almost all have several parts requiring comprehensive responses. (There is a little loophole here, that is, if you do not have something in place such as a policy or committee or process, then you can report that this does not exist, and that would meet the requirement for disclosure. The disclosure does not come with an obligation to implement new actions, but to report those that are in place. A bit of a double-edged sword, but it may provide some relief to those who do not have extensive governance structures in place, maybe suitable for smaller or privately-owned companies.) 

Now, although GRI is saying that this is a simplification from 22 separate disclosures in the current Standards to 15 disclosures, in practice, several have been combined, resulting in a governance section that is almost a report in itself. In my view, many of these disclosures are part of mandated corporate financial reporting, and rather superfluous to sustainability reporting.
For example, GOV-6 Conflicts of interest: The organization shall: 
a. describe the processes for the highest governance body to ensure that conflicts of interest are avoided and managed; 
b. report whether conflicts of interest are disclosed to stakeholders, including, as a minimum, the following conflicts of interest: i. Cross-board membership; ii. Cross-shareholding with suppliers and other stakeholders; iii. Existence of controlling shareholder; iv. Related parties, their relationships, transactions, and outstanding balances. 

For a sustainability-focused stakeholder who assumes that conflicts of interest are addressed and disclosed as part of fundamental corporate governance, this is just noise. I think it’s unnecessary to burden the sustainability reporting process with this additional content.

Or this one: GOV-7 Role of the highest governance body in setting purpose, values, and strategy: The organization shall: a. describe the role of the highest governance body and of senior executives in the development, approval, and updating of the organization’s purpose, value or mission statements, strategies, policies, and goals related to sustainable development topics.

Sorry, but, frankly, who cares? Do we really need a load of unnecessary verbiage saying the Exec Team had a discussion and then the Board had a discussion and then they all had a discussion and then they agreed on the purpose, values and strategy? Since Disclosure GOV-11 covers the role of the highest governance body in sustainability reporting in which the purpose, values and strategy are disclosed, what’s the point of another disclosure adding who said what and who agreed?

GOV 13 and GOV 14 require detailed descriptions of remuneration processes for the Board – all this is covered in other corporate governance reporting. I think it’s irrelevant here.

Similarly, what does it help us to know “the ratio of the annual total compensation for the organization’s highest-paid individual in each country of significant operations to the median annual total compensation for all employees (excluding the highest-paid individual) in the same country” (GOV-15). It’s all very nice for those who want to cap CEO compensation (and there is some merit in this thinking) but frankly, this is not about sustainability impacts and not even really about ethical conduct. It’s about capital market forces that enable or even encourage these types of compensation processes. I would leave this to other corporate reporting platforms and leave it out of the sustainable development dialogue at this level of detail.

Personally, I suggest slimming down the mandated governance content to three or four disclosures related to Board accountability for sustainability topics that are not typically reported anywhere else.

I covered this in my conversation with GRI experts, Bastian Buck, Chief of Standards and Laura Espinach, Head of Technical Development.

ME: Does this now significantly increase the reporting requirement for companies who reported Core to date? Is this a deliberate new focus on governance? Won’t this make reports longer  😟?
BASTIAN: “When we first introduced the governance disclosures, in G4, I think we were ahead of the curve. At the time virtually no company was disclosing this information. But today, many already disclose more than what’s required to be In Accordance at Core level. If you look at all the data providers that send ESG queries to companies and at the regulatory domain where governance disclosure has become a lot more comprehensive, you see a clear trend of investor interest and demand towards more structured governance disclosure in both the financial and ESG reporting domains. As this became a more commonplace expectation, so companies went beyond the minimum disclosure. The GRI Global Sustainability Standards Board (GSSB) often wrestled with the question of whether this is too much – but input we received confirmed that this is important from a governance best practice perspective and interestingly enough, none of the other standards in the ESG space features these disclosures. It still holds true that you can reference other reporting you already publish – as long as this adequately fulfills the requirement of the GRI governance disclosures.”

ME: As GRI Standards are supposed to apply for all organizations, including private companies, SMEs, nonprofits etc., is it reasonable to expect that all organizations will report on all these governance disclosures? Some of these disclosures will be extremely awkward for all but the largest corporations - is it GRI’s intention to reduce the number of companies that can report In Accordance?
BASTIAN: “Let’s be clear that the requirement to disclose does not mean you have to put in place mechanisms that do not currently exist. It’s perfectly acceptable to disclose the absence of certain governance aspects. It’s understandable that certain organizations may not have all these governance processes in place that are required for large companies.”

ME: Another point: I note that many continue to include governance as a material topic. But, as the materiality definition has changed to focus on impacts of the organization, does it follow that governance should not be included as an IMPACT but part of the organizational approach and due process? Would a company including governance as a material topic then not be In Accordance with the Standards? 
LAURA: “What is important is that in the GRI Standards as proposed, governance is relevant to all organizations and all will therefore have to report all governance disclosures. Governance cannot be subject to a materiality assessment. But there is nothing that prevents an organization identifying governance as material (in addition to reporting the disclosures in GRI 102) as long as they can identify the impacts of governance and can justify the impacts in the context of the GRI standards.”

Let’s do a little poll: please read the question below and select the response that most reflects your view:

Question: Do you think several of the governance disclosures in the Exposure Draft are unnecessarily detailed and nitpickingish and do little to enhance our understanding of an organization’s commitment or capability to manage its impacts?

Answers: 

• Yes 
• Affirmative 
• Definitely 
• Absolutely 

Good, glad we got that sorted. Prepare for governance galore in the next iteration of the GRI Standards. If you like this, or do not like it, have your say before it gets locked down in the publication of the new Universal Standards sometime in the near future. The Exposure Draft is open for comments until 9th September 2020.

Stay tuned for the next post in this series which is all about the rebirth of Sector Standards. YAY!

Stay safe, stay well, stay optimistic! And eat lots of ice cream 🍦🍧🍨🍦 

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltd, an inspired Sustainability Strategy and Reporting firm having supported 107 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

GRI Standards: Materiality: You’ve Been Doing It All Wrong

There you have it. The infamous materiality matrix has disappeared from the GRI Standards (in the new Exposure Draft of the Universal Standards). Haha. About time. I have always maintained that the matrix and the plotting of dots was nothing but a distraction. (Check out my post from 2014, “Why the materiality matrix is useless”, before GRI Standards became G4, and another from 2016, “The missing piece of the materiality puzzle”.) 

Is this a total U-turn by GRI or is it an attempt to realign reporters with what’s really important, that is, defining the material topics, rather than developing creative visualizations of arbitrarily prioritized dots? I am reminded of a quote by the late Stephen R. Covey, the Seven Habits creator, who said: “If the ladder is not leaning against the right wall, every step we take just gets us to the wrong place faster.” 

And so it has been with materiality matrices, where most companies have taken to plotting material topics on two axes – importance to stakeholders and importance to the business, and prioritizing the topics that scored high on both axes. This was never the intention of GRI and it’s rather odd actually that the practice developed in this way. The intention of GRI Standards was that (1) companies should list the priority material topics (2) topics are most material if they score high on EITHER axis, not necessarily on both of them and most importantly, (3) that the horizontal axis represents the significance of the impact OF the business, not ON the business. Such a lot of companies reporting for such a long time on topics that were all prioritized against the wrong wall. How weird is that? 

I asked the GRI experts, Bastian Buck, Chief of Standards and Laura Espinach, Head of Technical Development, about this. 

ME: What are companies going to do now with all their materiality matrices? Many have invested loads of time and money perfecting the dots. Has this all been a waste of time? 

LAURA: “Let’s be clear that the use of the matrix was never a requirement. It became the practice that companies were including the matrix. We have now removed it first and foremost because the definition of material topics has changed. This also helps us address issues of how the matrix was applied in practice, with companies prioritizing topics that ranked high on BOTH axes, even though GRI Standards say that topics are material if they score high on one dimension. Will companies continue to use the matrix? Well, we don’t know. They can still choose to display the selection of material topics visually. What’s important is that if they opt to use a matrix, they must include the topics as required in the new GRI 103 Standard.” 

ME: Is the expectation that companies will now redo all their materiality assessments in order to align with the new definition of materiality? 

LAURA: “The answer is no, if they have been following the materiality principle as intended, that is, based on significant impact. That’s still the case. What’s different is that we recommend the approach to prioritizing impacts based on severity and likelihood but this method is not specifically required and organizations can select their own method and explain it. This may not therefore result in many changes to the material topics. But, if the company did not use a method that is aligned with the intention of expressing impacts through the material topics, then the new definition may require some changes.” 

ME: But what about all this new guidance on assessing the scale, scope and likelihood of topics? Wouldn’t it be better if GRI had provided some more specific guidance here? It’s still rather vague.

BASTIAN: “It’s important to note that the identification and assessment of material topics is not done for reporting purposes. The report reflects the impacts and actions of the companies throughout their activities. We offer options to use different methodologies and dimensions to assess material topics, but actually, GRI is not the tool that determines this. GRI is the disclosure tool, and we require companies to report their approach and methodology. The Standards do not prescribe the methodology.” 

I am pleased to see the revised definition of materiality in the proposed Universal Standards and new guidance – minus matrix. Material topics are redefined as topics "that reflect the organization’s most significant impacts on the economy, environment, and people, including impacts on human rights."  This is clear enough. (See my post entitled GRI Standards: Human Rights: Quadrupled for a discussion on how human rights snuck into that definition). 

The proposed new standard GRI 103: Material Topics includes guidance for identifying material topics and related disclosures. There are three required disclosures in the new GRI 103 (all mandatory for reporters wishing to claim “In Accordance”): 

Disclosure 1: (MT-1 Identification of material topics and related impacts) Includes the way an organization has identified its material topics and prioritized them, as well requiring disclosure of the stakeholders whose views informed the identification of material topics. Also, organizations should point out changes in materiality from the prior reporting period.

Disclosure 2: (MT-2 Material topics and related impacts) Includes listing the material topics, describing the impacts related to each topic and whether the organization is involved in negative impacts directly through its activities or as a result of its business relationships. 

Disclosure 3: (MT-3 Management of material topics and related impacts) Replaces and extends the scope of the Management Approach Disclosures of the former GRI 103 Standard. It requires for each material topic a whole load of information: 

• Policies or commitments 
• Actions taken to manage the topic and its related impacts 
• Actions taken to prevent or mitigate potential negative impacts, or address actual negative impacts through remediation 
• Effectiveness of actions taken 
• Process for tracking the effectiveness of actions taken including goals and targets, evidence of effectiveness and lessons learned 
• Ways stakeholder engagement has informed the actions taken and if the actions have been effective
• Reason for not addressing a material topic if the organization does not do anything at present and plans to manage it in the future if there are any. 

There are a few things worth noting here. Most of these requirements were already part of GRI Standards, but some bits that stand out are:

First: Change materially. Do you find yourself scrambling around to see what companies said were material last time? Ever since the G4 Framework, a disclosure requirement was for companies to report significant changes in material topics from previous reporting periods. Although, honestly, I have noticed only a few companies actually including explicit information about what changed. So you had to do a bit of scrambling around. The new requirement in MT-1 requires organizations to report changes in the material topics compared to the previous reporting period. That is, all changes. I suspect this won’t be such a burden as most companies revise their material topics every few years, and even then, not much actually changes. But it's worth reminding organizations of this requirement, as no report is standalone, it's always part of a disclosure continuum and changes in materiality by definition are not incidental.  

Second: Get descriptive. In addition to the requirement to report how the organization has identified actual and potential, negative and positive material impacts and how it has prioritized them, the new requirement is to describe the impacts for each material topic. Currently the requirement is to report why the topic is material - which can be a bit repetitive as most companies are fairly generic about why child labor is not good or why diversity is fantastic. The move to describing impacts could lead to greater specificity in what material actually means in terms of how the organization affects our lives.

Third: Preventive precaution. The requirement to state how you uphold the precautionary principle (currently General Disclosure 102-11), which most reporters didn’t really understand anyway, has now been changed. The proposed Standard (RBC-2) asks companies to state whether the precautionary principle is applied as part of its policy commitments. The precautionary principle is seen as one form of prevention of negative impacts, which applies in specific situations (where there is sufficient reason to expect serious or irreversible damage even though there is no complete scientific understanding or evidence of that). So maybe it's time to revisit how you talk about this and update your policies to bring precaution into the frame.

Fourth: Get authentic. You can not report any of the above on any material topic as long as you explain why you are not doing so. Hah! I don't recall seeing many reports saying we have loads of material impacts but we are not doing anything about them. But, the “report or explain” principle has been fairly effective in some jurisdictions, e.g. Denmark, in catalyzing action, so it worth reminding organizations of this requirement, which was included in current and prior GRI iterations. It's a recognition that not every company has all the answers all the time, and that it is better to disclose that this is the case than simply omitting reference to what might be an important impact of the company. It's rather uncomfortable to do this, and I suspect it's easier to conveniently deprioritize an impact which you are not prepared to deal with. The optimistic view is that companies will realize there's value in telling it like it is and will use this as a way to either report more authentically or get a meaningful approach and an action plan in place before their report is published.

In general, while there is still a lack of more explicit methodology for defining materiality, I am confident the new materiality definition will help improve the quality and relevance of disclosure. If you agree, or disagree, have your say before it gets locked down in the publication of the new Universal Standards sometime in the near future. The Exposure Draft is open for comments until 9th September 2020. 

Stay tuned for the next post in this series which focuses on the changes in disclosures on governance. 

Stay safe, stay well, stay optimistic! 

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltd, an inspired Sustainability Strategy and Reporting firm having supported 107 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

GRI Standards: Human Rights - Quadrupled

It can’t help but strike you when you review GRI’s Exposure Draft of the new Universal Standards (See my first post on this topic: GRI Standards: Shape Up or Shape Out) that human rights is just everywhere. A quick PDF search shows that in the new proposed revised Standards 101, 102 and 103, the term human rights appears more than 90 times, whereas in the 2016 version of these standards, the term appears less than 25 times. That’s an almost quadrupled helping of human rights in these new Standards. Now, if anyone offers me quadruple ice cream, I say: Yes please! But a disclosure Standard that’s so totally human rights flavored, well, that might just give you a little bit of indigestion.

If you read the Explanatory Memorandum that GRI published to accompany the Exposure Draft, you will have noticed that it started out with the sentence: “The primary objective in reviewing the Universal Standards is to address the recommendations from the GRI Technical Committee on Human Rights Disclosure.” Human rights even snuck into the new definition of materiality: “a topic that reflects the organization’s most significant impacts on the economy, environment, and people, including impacts on human rights”.

A quick glance at the 2019 Corporate Human Rights Benchmark shows that “More than half of the 200 benchmarked companies score less than 20% and only 1 in 10 companies score more than 50%. These extremely low scores reveal poor levels of implementation of the UNGPs by the vast majority of companies assessed.” So there is clearly more work to be done.

I asked Bastian Buck, GRI Standards Guru-in-Chief and Laura Espinach, GRI Standards Technical Development Guru-ess-in-Chief, about the human rights changes in the Exposure Draft. 

ME: Why the need to explicitly add human rights in this definition? Does impacts on people not automatically assume human rights? 

BASTIAN: “Even ten years after the publication of the UN Guiding Principles on Business and Human Rights, we are seeing that is still deeply uncomfortable for companies to disclose in this area.” 

LAURA: “Impacts on people should automatically assume human rights, but this has often been underreported by organizations. One of the main challenges the Human Rights Technical Committee grappled with as they were making these revisions was how to drive more reporting on human rights. They discussed some of the reasons for lack of reporting, for example, many companies do not think of their activities as having human rights impacts either because they don’t know what a human rights impact is or because they only think of human rights impacts as gross violations or issues that are life threatening. There has also been a historic masking of human rights within the economic, environmental and social framing of disclosure, so human rights issues were often overlooked. In fact, this is the reason we have moved from referring to social impacts to referring to impacts on people.” 

ME: Does this all imply that human rights are more material than everything else? 

LAURA: “The normative expectation in the UN Guiding Principles is quite unique. Human rights is one of the few areas that has been elaborated in this high level of detail about companies’ expectations and responsibilities, so we thought it was important to highlight that in the definition of material topics. This doesn’t mean that human rights are more material than anything else. We are trying to signal, of the impacts companies can have on people, human rights are the most acute / important ones. While it should be automatically assumed that impacts on people include human rights, this is not generally understood. By signaling this we hope to drive more reporting against the normative expectation that exists.” 

The Glossary in the Exposure Draft includes a definition of internationally recognized human rights, which is an addition to the current glossary. “These rights are understood, at a minimum, to include the rights set out in the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights and the main instruments through which it has been codified: the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights), coupled with the principles concerning fundamental rights in the eight International Labour Organization (ILO) core conventions as set out in the Declaration on Fundamental Principles and Rights at Work.”

I think many companies have become familiar with reporting labor rights (based on the ILO core conventions), although not necessarily doing so under the banner of human rights. The same, I think, applies to supply chain standards – companies report practices on Supplier Codes of Conduct, or ethical procurement etc., without necessarily referencing human rights. There are some areas of human rights that I believe have not benefited from broad disclosure, such as impacts on indigenous peoples, land rights etc. And of course, the International Convention on the Human Right to Ice Cream has been virtually ignored.

But by making everything about human rights, there’s a danger that we focus on the rights and not on the people – a bit like saying, the operation succeeded but the patient died. There just might be cases where the rights were upheld but the people were not. For example, non-discrimination. Companies declare they are non-discriminatory and list all the ways in which they are upholding equal opportunity for all. Then you look at their Board of Directors and Executive Teams, and they are predominantly white, male and middle aged. Somewhere in the system, therefore, discrimination is present, even though it might be tough to admit. In promoting human rights disclosures, we must be careful not to forget the people - which means that disclosures need to be underpinned with relevant practice.

I shared this concern with the GRI Standards experts, and Laura responded as follows:
LAURA: "Human rights is all about outcomes for people. I think the issue in the example may have more to do with how these issues are dealt with in practice, than with how this is framed in the Exposure Draft. The overall framing in the Exposure Draft is ‘impacts on people’ which include human rights-related impacts. And the changes to the definition of stakeholder also aim to focus reporting on individuals or groups that are or could be affected."

(Note here that the revised definition of stakeholder is: "individual or group that has an interest that is, or could be, affected by the organization’s activities and decisions". This is different from the previous definition which reflected a dual interaction - referring to stakeholders as being both affected by the organization and affecting the organization. The new definition aligns more closely with the focus on impacts of the organization on stakeholders, people, environment and society.) 

Nonetheless, the intention of GRI is clear and it’s helpful. I believe it will drive greater awareness, action and reporting. Now is the time to start assessing your organization’s impacts on human rights and the people who have them, if you haven’t already done so. If you think this is a great new direction, or excessive in emphasis, have your say before it gets locked down in the publication of the new Universal Standards sometime in the near future. 

The Exposure Draft is open for comments until 9th September 2020. The next post in this series will cover the new definition of materiality and what that means for the infamous materiality matrix.

Stay safe, stay well, stay optimistic!

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltd, an inspired Sustainability Strategy and Reporting firm having supported 107 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

GRI Standards: Shape Up or Shape Out

The Exposure Draft of the new GRI Universal Standards looks quite innocuous at first glance. Seems to put things in order and chop out a bunch of irrelevant/irritating stuff. Puts them back together again in a fairly logical way. At first glance, it seems super-duper. Then you read the fine print and consider the changes that reporters will face and wonder if they are a help or a hindrance, and in some cases, why on earth they were even considered.

I was fortunate to be able to chat about the Universal Standards revision with long time architect of GRI Standards, and occasional sparring partner, Bastian Buck, Chief of Standards, probably the most knowledgeable person on the planet on the topic of sustainability reporting standards, and a most patient and attentive responder to all of my niggly questions and observations, and someone I always tremendously respect. Joining us was Laura Espinach, GRI’s Head of Technical Development, an experienced and accomplished GRI specialist who has been instrumental in standards revisions for over a decade and specifically in guiding the current proposed Universal Standards revision. Both took on the call of responding to 5 pages of questions and observations I had prepared for them on the new revisions. 

In a series of posts, I will be sharing their insights and my thoughts about the aspects of the revisions that seem to me to be the most meaningful. This is by no means an exhaustive review. I have been a little selective. As usual, my purpose is to help people (including myself) understand the GRI technobabble (which has become a little less techno over the years, even though there’s still a lot of babble), and also to encourage you to navigate the changes and provide your input to the Exposure Draft through the formal GRI survey. 

But first: the cheat sheet. What’s changed? 

Here’s a quick summary of the proposals: 

• New alignment of three Universal Standards: 101, 102 and 103 where: 
• 101: contains information about how to use the GRI Standards
• 102: contains disclosures about the reporting organization and
• 103: contains guidance and disclosures relating to material topics (and supplemented by Sector Standards and Topic Specific Standards, where applicable).  It’s sort of a revised, expanded Management Approach Disclosure standard.
• In Accordance options Core and Comprehensive have been shelved. Now it’s In Accordance only with an option to reference the Standards if you can’t go the Full Monty. 
• Human Rights have been elevated to become omnipresent in every part of the Standard, including in the definition of materiality. This is to compensate for the underreporting of human rights over the years, as companies have sidestepped key human rights disclosures for different reasons. 
• Materiality definition has been revised to re-emphasize the focus on impacts of the business on economies, environment and people – making it clearer that reporting is not about what’s affecting the business but rather what or whom the business affects. Oops! Get ready to revise that materiality matrix. Or even ditch it. 
• Governance disclosures have been revised and a full set of sustainability-related governance disclosures have become part of the mandatory requirements for compliance with the In Accordance option. For those companies who have not reported governance extensively, or who have referenced Annual Reports (often misleadingly, as the Annual Reports do not generally contain the specific aspects of governance important for sustainability reporting), this will require companies to buckle down and publish more relevant information on governance. 
• Sector Standards are now mandatory for In Accordance disclosures, even though none of them yet exist. But, as they are developed, companies in the relevant sectors will be required to use them for their reporting to be In Accordance. 

And some very specific changes you might miss if you speed-read the new proposals. 

• Alignment of reporting timelines is a new proposal (guidance, not required to be In Accordance), whereby companies are asked to align the sustainability reporting period with that of the annual report. Hmph. Nothing more useful than treating apples and oranges in exactly the same way. 
• CEO Statement of Use is a new requirement, asking the CEO (officially: the highest governance body or the most senior executive) to publicly confirm that the GRI Standards have been applied correctly. Seriously? I thought that’s what assurers were paid for. 
• Contact Point is now not contactable. The requirement to list a contact point for queries (currently General Disclosure 102-53) has been removed. Apparently, no one felt it was important. Clearly one of the main tools for stakeholder dialogue does not need to identify how to reach the people to dialogue with. 

And in addition there are some revisions to other existing disclosures and some tightening up of the reporting principles etc. 

All in all, quite a big job, meaning that when these new Universal Standards are approved and published, and enter into force (I guess that will be in 2022 - on average the transition period for GRI Standards revisions is 2 years), reporters will have a much reduced use for the copy-paste button. (Don’t you wish all keyboards had one of those? Specially for Sustainability Reports.)

But, before we delve into the changes in detail (in a series of subsequent posts), I wanted to share the views of the experts on the revision of the In Accordance rules. To remind you, in earlier GRI iterations, there was the A, B,C system, where A was more extensive disclosure and C covered the basics. A-level reporters puffed up their chests and issued glorious Press Releases while C-level reporters were relieved they were able to issue a Press Release at all. The misleading nature of this system led GRI to adopt the Core and Comprehensive differentiation with G4, which was actually very similar. The tiered system has not proven useful, as transparency for the sake of transparency was not adding value. Transparency must be relevant, which in GRI jargon is about the focus on material topics.

The new In Accordance framework requires the following:

• Applying the Reporting Principles (no need for proof of this – the report itself should be proof) 
• Reporting ALL the General Disclosures in Standard 102 (same as current but now there are more – specifically in the area of Governance)
• Identifying and listing material topics (using available Sector Standards) and reporting GRI 103 which is all about materiality (similar to the current Management Approach Disclosures)
• Reporting appropriate disclosures from the GRI Topic Standards that correspond to each the material topic – the operative word here being “appropriate”. Currently Core requires minimum of one indicator and Comprehensive requires all. With the new definition, companies must select the indicators that are relevant and report those. For example, no point in selecting the hazardous waste indicator if you do not generate any hazardous waste. Duh. But, if all the indicators are relevant for a particular material topic, then you cannot just select the easiest one to report as you might have done with the one-per-topic rule in the current Core option. As with the current system, if GRI does not have a ready-made indicator, you can make one yourself. Or draw on other existing standards and reporting guidelines 

I asked guru Bastian about the new In Accordance rules:

ME: With the removal of the Core and Comprehensive “In Accordance” options, how can companies signal that they have been “more transparent” than other companies? Is this not seen as important? 
BASTIAN: “I think there is a historical perspective to the decision to remove Core and Comprehensive. We have this history of trying to take everyone and everything with us as we move forward, and there was always a tiered system. But eventually we knew that we would have to consider having a clear threshold, and now is the right time to do that. First, this aligns with the approach of standards such as the IFRS and many others. Either you are or you are not. Reporters need to make a clear commitment to stakeholders on where they stand. Second, it was confusing. In many cases, companies published a Core report, but reported far beyond the minimum Core requirements - by declaring Core, they were not setting an accurate expectation for their report.”

ME: That sounds fine, but what about omissions. You can still be In Accordance while not reporting performance and simply stating omissions. How will that work?
BASTIAN: “We have revised the acceptable language for noting omissions and how to include them in the disclosure. Some degree of omission is always possible – it’s far better to say that you are not able to provide certain information and explain the challenges you face, and when you plan to report in the future, if relevant. This is why the feedback loop with stakeholders is so important. They should challenge companies on what they said they would report at a future date. In some cases, systems simply don’t exist to gather the relevant data, but if you commit to resolving this, then stakeholders should check that you follow through.”

ME: So where does In Accordance now sit? At Core or Comprehensive?
BASTIAN: “The fact is that In Accordance will always deliver a high level of transparency across a broad range of general disclosures and across material topics. Companies themselves define what is material and therefore what they report. But we have also retained the reference approach, so that companies can use certain disclosures from GRI Standards. This continues to be relevant for us as a global standard because of regulatory regimes across the global system – the reference approach continues to cater to regulators and reporters who require or recommend / disclose a narrower set of topics.”



I believe current Core reporters will find the new approach a little stretching. First, there are more general disclosures. Second, they will have to think more deeply about the topic-specific indicators they commit to reporting. But, that’s a good thing. Somewhere in GRI’s purpose is improving the quality of reporting, I think, and this means raising the bar and challenging companies as stakeholder expectations change.

So, that just about covers it for this post. And this is only the overview 😊. Brace yourself for more posts on the Universal Standards Exposure Draft if you are really keen to understand how these changes might affect your reporting. If you agree, disagree, or have any better ideas, take some time to provide your feedback in the GRI Survey between now and 9th September.

In the meantime, you had better stock up on ice cream.

Stay safe, stay well, stay optimistic!

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltd, an inspired Sustainability Strategy and Reporting firm having supported 107 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

Getting Human Rights Right

Unilever gets a lot of the spotlight these days on the sustainability horizon. This will help you understand why. I felt compelled to shine a light on the new report that Unilever has published on human rights. This is by far one of the best corporate accounts of position, practice, performance and intention on this subject that I have seen over the years, and again, Unilever raises the bar for advancing sustainability practice and disclosure. With this report, Unilever turns human rights from an onerous obligation that's reported by most companies with zero bells and whistles and a dollop of misplaced righteousness into a fun, colorfully-presented, superbly constructed and actually interesting 64 pages. This has to be mandatory reading for anyone thinking about their company's position on human rights - both for the insights about what's important and why and what can be done, and also for the way it's presented. Just look at the cover. Doesn't look like boring old human rights again, does it?  

Paul Polman's introduction is credible. This is because Paul Polman has become more of a sustainable brand than Unilever itself. Paul Polman's personal brand promise is about the no-nonsense practicalities of making sustainable values work. All may not be perfect at Unilever but Paul Polman cuts through the noise as a leading sustainability advocate with a trusted voice that speaks honestly and with integrity. When Paul Polman says in this report that Unilever is approaching human rights with a mixture of conviction and humility, I believe him. When he says the process of developing the Unilever's inaugural human rights report has been inspiring and humbling, I believe him. When he says this is a new beginning, and a long-term commitment, I believe him. And believing him, I am believing the report. Partly also because this report is not touted as a look-how-great-we-are report, but as a sharing of learnings and a stage in the journey. It's also a public declaration of intent to go beyond "respecting human rights" to "actively promoting human rights". There is a sense that this report is as much for Unilever itself as it is for the world.  

It starts with reiterating the social need to protect human rights and goes on to highlight milestones along the path that Unilever has taken over the years to bring human rights into the corporate consciousness.

Marcela Manubens, Global VP for Social Impact at Unilever, reinforces the approach, making a call to "rethink" business. "At Unilever, our vision is to build a company that represents the new capitalism, in which business exists to serve – not take from – society, and is a critical enabler of inclusive economic growth and job creation." 

There are many things we can learn from this report. I am tempted to quote so much of it, but that would make this post as long as the report itself. So I will limit myself to a few observations:

Unilever's approach is firmly rooted in policy, starting with external globally-accepted policy frameworks that most of us are familiar with, such as the Universal Declaration of Human Rights and ILO (International Labor Organization) policies. It is also the first report that is aligned with the UN Guiding Principles Reporting Framework that was launched in February 2014 following the work of John Ruggie. What's interesting here is the way Unilever has created a set of aligned policies (7 in all, including the original Unilever Code of Business Principles) and while there is some overlap, each targets a specific aspect of Human Rights and /or a specific audience (such as suppliers or business partners). This suite of policies forms the bedrock of Unilever's action across the range of human rights issues in the business. 

Unilever's governance of human rights issues is clearly laid out - from the creation of HR Ambassadors across the markets to external engagement with a range of stakeholders. Long-standing collaborations with NGOs Oxfam and Solidaridad, among others, have helped shape Unilever's perspectives and performance. 

The focus of Unilever's activities has been clearly articulated across 8 core human rights issues identified as "salient" for Unilever.  (Maybe "salient" is the new "material"?).  

Each issue is addressed in its own section, providing some context, Unilever's historical and current approach, and a few case studies. It's good reading. What's most appealing, and illuminating, is the discussion of the challenges a company like Unilever faces when reaching deep into the supply chain to uncover issues at the day-to-day level of diverse operations and Unilever's sharing of examples of problems that have arisen and actions taken to resolve. For example, a supplier was found conducting pat down searches to prevent workers from bringing their mobile devices to the production area, and at a salt pan operation in India, excessive working hours, poor health and safety practices, and lack of a proper process for the payment of wages were uncovered. An an independent assessment of Unilever's tea supply chain in Turkey revealed "significant and pressing" challenges. Equally, there is an open discussion of road safety risks with 48 road traffic-related fatalities involving Unilever employees on company business and members of the public, as well as more than 250 injuries and 5,000 accidents between 2007 and 2014. Land use is a fairly recent addition to the human rights agenda, and Unilever's work in this area is also at an early stage, but the intention to create a new Global Land Rights Policy and ongoing consultations with external experts and organizations will help Unilever establish leadership here too in coming years.

The next section of this report is dedicated to Unilever's framework: Prevent - Detect - Respond - both in Unilever's own operations and throughout the supply chain.  Due diligence, supplier audits, support and encouragement for suppliers as they try to improve, and detailed tracking analysis of compliance data are highlighted. There was a 60% decrease in conformance issues over the past couple of years, for suppliers who were re-audited, but, Unilever notes, "while these audits present us with a snapshot in time, they do not communicate the full story." Ongoing local engagement and constant vigilance are key to making sustainable change.

This inaugural Human Rights report ends with Unilever's directional objectives for the coming three years. These includes a intention to create a set of quantitative metrics, noting  "more attention needs to be given to measuring social profit and loss". Uh oh. I hope this doesn't mean that human rights impacts will be converted to $ or Euros or £ a la Kering EP&L - which could turn the focus from people and lives to endless number-crunching and bottom lines. But I certainly am in favor of a methodology that helps us understand the true measure of social impact - positive and negative - of corporations and it's possible that Unilever's dialogue-based approach may held create breakthrough in this area.

All in all, while this report, as a first report, demonstrates a maturity of approach, there are many areas where Unilever must reach even deeper and embed robust systematic sustainable change and find creative and meaningful ways to measure progress. In the meantime, hats off to Unilever for all that has been done so far and triple ice creams all round for everyone who worked on this report. It's a text book for advancing and promoting human rights and a fascinating read, presented in an optimistic way. As the report notes: "The work ahead is significant but not insurmountable."

Read this report. It's worth a half hour of your time.

elaine cohen, CSR consultant, 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 Twitter (@elainecohen)  or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm).  Need help writing your Sustainability Report? Contact elaine: info@b-yond.biz   

Santa's 2013 G4 Sustainability Report

This year, Santa has published a G4-based Sustainability Report, in accordance with G4 comprehensive level. This follows a long tradition of sustainability reporting by Santa. Check out Santa's prior reports:

Santa's First Integrated Financial and CSR Report 2012
Santa's 1,747th 2011 Annual CSR Report  
Santa's 1,746th 2010 Annual CSR Report   
Santa's 1,745th 2009 Annual CSR Report

As usual, Santa always sends me an early copy of her annual sustainability disclosure, as she knows that the #CSR Reporting Blog is the most widely read blog anywhere that focuses on sustainability reporting. Knowing that featuring on the #CSR Reporting Blog is a privilege reserved for few reports, Santa always makes it worth our while by collecting all the toys that were not distributed to the world's children and sending them along to us on Boxing Day as a gift. This coming Boxing day, the #CSR Reporting Blog has decided not to accept these toys, but to donate them to bloggers everywhere, in return for a small postage fee. If you are a blogger, and would like to receive your free toy on Boxing Day, please make a bank transfer NOW to the #CSR Reporting Blog in the amount of $4,995. As soon as we confirm this amount has reached our account, we will dispatch your free toy. 

This year, Santa remains at the forefront of Sustainability Reporting. Last year, Santa's forefront was an Integrated Report, the first one to come out of Lapland, and the only Laplandish Integrated Report to include an Environmental Profit and Loss Balance Sheet whose bottom line was positive, meaning that the environment actually owes Santa a whole lot of money. This positive balance was due to the fact that elves multiplied carbon emission reductions achieved in Lapland by 196, the number of countries in the world, because Santa mentions all these countries in the Integrated Report as target destinations for toys delivered to kids. This exponentially increased Santa's carbon emission reductions and is perfectly credible, using methodology similar to the way the number of sustainability disclosures in Angola is calculated. In the meantime, Santa is trying to figure out how to actually get this money back from the environment, and, if all else fails, may have to ask PUMA to cough up the cash as they owe the environment around EURO 145 million based on their 2010 results. Santa's first Integrated Report for 2012 was helpful to the wider business community as it proved that the phrase "integrated reporting" is actually an oxymoron. This should go down in history as a massive benefit for humanity. It sort of equates integrated reporting to discovering that there is life on Mars. 

As Santa likes to demonstrate leadership, advanced-thinking, clear focus, sharp analytical skills, strategic visionary orientation, exceptional interpretive powers and amazing persistence, tenacity and staying power, she decided that this year's report should be written in accordance with G4. The only problem was working out what to call it. Santa consulted SOAP's CSR Report Name Generator and came up with some relevant options:

However, Santa felt that these report titles have been over-used, and decided to generate her own report title. So here it is:

Santa's 2012 G4 Sustainability Report

Chairwoman, President, CEO, CFO, and General Counsel Opening Message

As 2013 draws to a close, our work begins. With a core mission of making kids happier, while increasing the long-term sustainability and short-term profits of toy manufacturers around the world, Santa Claus Inc. is getting ready to make this Christmas the most memorable ever. With the digital divide creating gaps between those who have and those who want to have, we are giving priority to those who are disempowered by the digital divide. All they need to do is drop Santa an email, or use Santa's new IOS7 App, and tell us how the digital divide is limiting their ability to connect with the world at large and VOD at home. We will email back with the Santa Guide to Bridging the Digital Divide. This is a short 300 page manual, in two parts, which is very easy to understand, providing good advice on how to hack hot spots and divert satellite dishes.

Business-wise in 2013, Santa Claus Inc. delivered record profit levels, mainly because we achieved a higher degree of vertical disintegration, outsourcing not only our toy manufacture but also our testing procedures. In previous years, toy testing has been a major drain on our resources and over 18,000 elves were engaged in playing with all the toys we distribute to the world's children, to ensure they are safe and function in the way intended. To do this, the elves had to play with the toys in prolonged intensive sessions in which they had great fun but which usually ended up with the toys breaking or parts dropping off, or in some cases, elves choking to death. This meant that our pass-rate for acceptable toys was extremely low. In order to reduce our expenses and increase our toy pass-rate, we have transferred responsibility for toy-testing to our outsourced toy manufacturers, who are obliged to confirm toy integrity before shipping. We believe this has been an extremely positive change as our toy pass rate is now more than 100%.

Material Issues 

In line with G4 guidelines, this year, for the first time ever, we conducted a materiality analysis. We followed a process of stakeholder engagement with internal and external stakeholders, including consultation with the global sustainability guru, John Elfington, an expert in sustainable elf matters, and Jo Elfino, editor of a sustainable business newspaper for elves in the UK. 

We identified our key stakeholders as:

1. Me, Santa Claus
2. Children
3. Parents
4. Employees (elves and reindeer)
5. The Government of Lapland
6. Our Bank Manager 
7. Environmental Activists
8. Elf Trade Unions
9. Toy Manufacturers
10. Toy Testers
11. Sleigh Manufacturers
12. Reindeer Feed Suppliers
13. Wrapping Paper Suppliers
14. Chimney Sweeps
15. Santa Defense Fund Management
16. Santa Retirement Fund Management
17. Santa Benefits Committee
18. Santa Protection Agency
19. Santa Well-being Organization
20. Santa Earn-More-Money Campaign.

Given such a long list of stakeholders we were not able to complete our stakeholder engagement program in time for our Sustainability Report and have therefore assumed we know what most people think. This assumption resulted in a comprehensive and balanced set of most material issues, which we prioritized to deliver a list of 6 main issues that our report focuses on. These are our most material issues:

1. Improving (Urgently) Santa Compensation and Well-being
2. Advancing Santa Recognition around the World
3. Busting the Santa Disbelievers Movement
4. Ensuring the Ongoing Viability of the Chimney Sweep Profession
5. Increasing the Longevity of Elves and Reindeer
6. Ensuring Children do not Express Dissatisfaction with Toys Received

Our new Santa Sustainability Strategy for 2050 will address these material issues and ensure we maintain our license to operate and deliver a positive net contribution for humanity including generations to come and tremendous shareholder return. 

We submitted our report to GRI for the Materiality Matters Application Level Check, but were told that the GRI team is so completely underwhelmed with the number of companies submitting their reports for the check that they are considering revising the check to a "Materiality Matters As Well" Check, reverting to confirming that reporters have simply ticked the right boxes. As we await their conclusions, we take comfort in the fact that we can now declare our report as meeting the "in accordance" requirements and no-one will tell us anything to the contrary.   

New Shared Value Services

This year, in addition to distributing toys for children around the world, we decided that Santa should become more inclusive and we therefore started marketing a Santa Adult Toy range. This includes adult toys not typically suitable for anyone under the age of 37, and no, I won't go into details. Suffice it to say that the elves toy testing team was very sorry when adult toy testing was outsourced. However, this has posed a bit of a problem. Some of the adults have the same names as their children, and in a few cases, shipments were delivered to the wrong recipient. We are currently facing litigation for damages relating to a 5 year old boy who went into shock after an inflatable life-size doll exploded in his face, and a 6 year old girl who locked herself in a pair of handcuffs and was prevented from joining Christmas dinner festivities with her family.

In 2013, in order to get closer to our stakeholders, we opened up our Santa Claus Visitor Center here in Lapland. We are now offering round-trip packages from wherever you are in the world, accompanied by travel emission offsets so that you can take your trip with a clear environmental conscience. We intended that income from offsets would support the development of renewable electricity from combustion of reindeer antlers. Unfortunately, de-antlering all our reindeer proved problematic, and we already ruined 43 chain-saws in the process. Therefore we moved to plan B, which involves cloning Rudolph the Red-Nosed Reindeer, so that we can use all those reindeer red noses to provide lighting for all our operations. As reindeer have not yet been cloned, we feel this is a fabulous example of pioneering shared value sustainability progress, and we look forward to welcoming you to our Santa Claus Visitor Lit-by-Reindeer-Noses Center sometime in 2014. Aside from knowing your visit is carbon-neutral, you will also be able to chart the history of Santa Claus using our new android app, examine reindeer droppings through the ages, see elf fashion through the centuries, taste nutritional low-salt home-made probiotic reindeer-flavor yogurt, and read all Santa's previous Sustainability Reports. While the Visitor Center targets a population with a mental age of below 15, we also welcome politicians, CEOs and government officials.   

Reindeer Rights

Last year we had three complaints from the Global Reindeer Rights Protection Association (GRRPA) claiming that we are not paying our reindeer a living wage. We responded that we pay them a wage and they are living, and therefore didn't understand the problem. In order to deflect further complaints, we entered into a collaborative relationship with the GRRPA as they address the issue of reindeer trafficking. Trafficking affects some thousands of young reindeer, who are enticed from their families at an early age with the promise of well-paying jobs delivering toys in Hollywood and Bollywood. Once in the clutches of the reindeer traffickers, they are starved, drugged, abused, stripped of all reindeer dignity and forced to give reindeer rides for toddlers in shopping malls located anywhere but Hollywood and Bollywood, after which they end up as reindeer soup in high-end restaurants. By comparison, our 23-hour work day during the 12 days of Christmas is an attractive proposition. Our collaboration with the GRRPA includes a full employee communications kit and a compilation of visually disturbing videos of dignitaries eating reindeer parts at ceremonious dinners. These communication kits are designed to help all reindeer in Santa's employ realize that they actually have an easy life and that additional requests for protection of their rights will be met with disdain. In 2013, this worked and zero complaints were submitted to the GPPRA.

Elf Empowerment

As part of our ongoing investment in elf personal and professional growth, we created a special Elf Leadership And Talent Exceptional Development (ELATED) program which includes a 360 degree assessment of elf talent, capabilities, competencies and professional and personal relationships. Over 14,000 elves have already taken the ELATED program, participating in 5 residential workshops, meetings, online support and personal coaching from a senior elf mentor. Of the 14,000 elves who took the program, 3 were found to have some leadership and talent, and as soon as they realized this, they left the company to find better-paying jobs. We have therefore decided to replace this program with a new one, called the Developing Exceptional Forward-thinking Leadership And Talented Elves (DEFLATE) which focuses on helping elves continue to do the things elves do badly. This will increase our elf retention rate and save costs, while ensuring that all kids around the world receive at least one gift at Christmas time, even if it is the wrong one and arrives in more pieces than intended. 

Ethical Supply Chain

I was very distraught this year by the fire in the Rana Plaza operation in Bangladesh. It was a major tragedy to see so many people lose their lives due to unsafe working conditions. As a result, I personally visited all our toy manufacturing facilities in Bangladesh and asked them to ensure that all workers wear safety goggles and white overalls. Safety procedures may not have improved but at least the workers look good. Further, we considered joining major apparel manufacturers in signing the new Accord on Fire and Building Safety on Bangladesh until we realized this entailed a payment of $500,000 per year. At this point, we decided that outsourced facility safety is not a material issue for Santa Claus Inc. and deleted it from our list. 

Bad News

Survey results published by CorporateRegister.com in 2013 demonstrated that report readers find reports more credible if they contain bad news. I have been wracking my brain to try to come up with some bad news for this report. Santa Claus Inc. makes such a positive impact on the world and we do everything so perfectly, that bad news is just not in our lexicon, and even if it were, why on earth would I risk tarnishing our reputation so that the four people who read our report each year will find it more credible? These four people are my parents and my two daughters, and they believe anything they read anyway. 

However, as we are leaders in our field, and leaders must be responsive to stakeholder needs, here is some bad news. In 2012, we had a minor injury in our logistics operations when a fork lift truck driver elf backed into a wall. The elf sprained his right wrist on impact. He did not lose working hours and carried on driving the truck without his right wrist. The wall did not collapse and the fork-lift truck continued to operate. Nevertheless, we treated this safety incident very seriously and ran a series of elf discussions to highlight the necessity of not placing walls on fork-lift truck routes. We mapped the location of all our walls, and decided to relocate 27 walls to other positions outside the building. The bad news is that after we removed the walls, the roof collapsed, killing 32 elves and injuring another 346.  

Vote for Santa 

Even though our last report was not shortlisted in the online CRRA '14 global reporting awards, I take great interest in these online awards which advance reporting and help us learn from reporting best practice around the world. It is important to ensure that reporting remains a value adding exercise and continues to support an entire industry of specialists, as well as providing material for the CSR Reporting Blog, which so generously gives exposure to Santa's annual Sustainability Report. However, I am fairly certain that the fact that the Santa Claus Inc. 2012 report was not shortlisted is an oversight. Therefore, I suggest you vote for Santa Claus Inc.'s report anyway. Just delete the name of one of the other reports and manually add in the Santa report. We have made it our objective to achieve number one place in all reporting categories, and you can help. Please make this reporting year an even more memorable one for Santa. Double gifts for your kids in 2014 if you vote. Voting is open through January. 

Thank you for taking an interest in the Santa Claus 2012 G4 Sustainability Report. To read the entire 734 page report, please make sure you have a 100mbs broadband connection, about fourteen hours to spare and a supply of sedatives, and download it from our website. We will be happy to receive your feedback, as long as it's positive. 

In the meantime....

We Wish You and Everyone in the World a Happy Holiday Season and a Happy New Year. 

  

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 at www.twitter.com/elainecohen   or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm)