In the hot seat at GRI with Tim Mohin

After nine months at the helm of GRI, Tim Mohin is still, yes, still, enjoying his job and making waves in sustainability circles. An eternal optimist endowed with just about enough realism and an unshakeable vision of a future of sustainable development powered by corporate accountability and transparency, Tim has a lot to say. GRI is also 20 years old young, and though Tim Mohin has been leading it for a much shorter time, his experience as a practitioner and sustainability leader gives him the long perspective. 

What prompted me to pound Tim with a barrage of tough questions was an interview with Bob Eccles published in Forbes a couple of months back.  Tim is quoted as saying: "There is a narrative that has been running for a while now that portrays sustainability reporting organizations as in conflict with each other. The reality is that nothing could be further from the truth. I believe there is an increasing amount of harmonization in this space, whether it be GRI, or the UN Global Compact, SASB or the IIRC. Not only do we have longstanding partnerships with those organizations and others, but we are in fact all just after the same thing, which is sustainable development." 

I beg to differ. I do not see harmonization between any of these organizations and there are new frameworks and reporting approaches popping up all the time, whether in relation to specific sectors, regulation, stock exchange listings or other independent initiatives. Investment analysts use their own proprietary methodologies that are not based wholly on one framework or another. Longstanding partnerships with organizations in this space may look nice on paper, but in practice, they have yielded very little in terms of simplifying the way companies report. I am sure it sounds nice to talk of harmonization and partnership, but the reality is that it is not yet yielding tangible benefits. The proliferation of Linkage Documents that enable some sort of correlation between GRI Standards and other frameworks further clutters the landscape. 

One case in point is GRI's close collaboration with the UN Global Compact. Both organizations have been in dialogue forever and have signed more MOUs than Nobel has given out prizes. And yet, signatories to the UN Global Compact are still required to prepare a Communication on Progress in line with UNGC requirements at Advanced, Active or Learner level. In fact, the UNGC is very proud of its flagship reporting framework - as noted on its website. 

There is a 31 page document making the connection between GRI G4 Guidelines and the UNCG COP(s). This states clearly that reporters using GRI must still include content relating to UNGC core elements, even if those have not been deemed material for the organization and therefore not required by GRI Standards. Frankly, just reading this linkage document made me crave for paracetamol-flavored ice cream. If there were a true spirit of harmonization, I would expect the UNGC to declare the demise of the COP and require all large company signatories to deliver GRI-based in accordance reports and all SMEs to deliver reports covering a subset of GRI indicators. The perpetuation of different frameworks compounded by the need to understand the link between them is about as useful as an iPhone at a mindfulness retreat. There are many examples where unnecessary duplication of requirements adds nothing to sustainable development. It adds only bureaucracy, budget and salaries for people charged with promoting different frameworks. 

I asked Tim to explain his thinking about the positive extent of harmonization. 

"I am coming from twenty years of practitioner experience. I can say that a fractured landscape has created confusion and burden for corporations and we have to pay attention to that. We have to look at how to dig a layer deeper and appreciate that there are different tools for different uses. It is not a reason for companies to become confused. There is real harmonization work going on. When I say harmonization, I am talking about when standard-setters are asking the same question in annoyingly different ways. Right now, we have an aspiration to work with SASB to align such questions. There are over two thousand different disclosure standards out there. Currently we are in Phase One, mapping the overlap and looking at where we can align and simplify. This is work we are trying to get funded. I am certainly seeing a change in collaborative spirit at SASB. When I first got this job, I went on a listening tour. When I got to SASB, it felt like we were competitors. I took the opportunity to appeal to a shared aspiration which is our end-goal to improve how information is used to advance sustainable development. That's the reason I took this job."

And the new thinking on the Sustainable Development Goals? 

"My view is that work in industry sectors and work on the Sustainable Development Goals can merge together. When you look at a sector and what's material for that sector, and then overlay the SDGs, you can see there is a good degree of correlation. I am very keen to merge those streams of work."   

What about the work GRI is undertaking to advance reporting by SMEs? 

"I took a trip through Asia this summer and one of the things I noted was the explosion in stock market listing requirements. Many of the listed companies in that region are SMEs, and they are starting to come to us for help. This is a major driver of the expansion of SME reporting. We have been working with one of our major funders in a program to drive sustainability reporting through the supply chain. When large companies use their buying power, you can bring a lot of SMEs into the fold, so it's a program to bring buyer and supplier together. First, they define the material issues they really want from the SME. A digital tool has been developed to help them use the GRI Standards so that it is more simple, straightforward and requires fewer resources. We are conducting training in developing countries (Colombia, Ghana, Indonesia, Peru, South Africa and Vietnam) where we have funding and there are more to come. The pilot program has a two-year time-frame before we can roll it out globally. We are excited about this and it clearly shows the difference that GRI brings - we are trying to affect the entire global economy by harnessing the forces of capitalism in the service of sustainable development." 

How would you summarize your thinking after nine months at GRI?

"I have never been happier. This is certainly one of the highlights of my career. It's a fantastic cause and a fantastic organization. My only frustration is that there are so many ideas and possibilities, more than we can act upon at any given time. I have had to prioritize and manage expectations and focus but it's working out quite well. Running a not-for-profit is like running a business - we now have nearly 100 people around the world." 

And the focus is? 

"We have four key areas that we are prioritizing at present and we have reorganized our structure to meet the needs. (1) improving the quality of sustainability reporting (2) providing preliminary reporting guidance on sustainability topics that are new to the corporate reporting field (3) increasing reporting among small and medium-sized enterprises (4) promoting harmonization in the corporate reporting landscape. We are actively working in all these areas."

Do think there is still an issue connecting reporting practice to actual sustainable development?

"There is more work to do in this area. We have gotten some funding recently to work with the investor community to define what is investor grade reporting and how GRI can make that happen. It's a big hill we have to climb."

And the next GRI Global Conference?

"Ah yes, we'll be making an announcement on that soon. Watch this space!"

So, lots of things bubbling at GRI, including the tarmac on the Road to Harmonization. Tim Mohin is very consistent and clear in his purpose and intentions - to advance sustainable development and improve the value of reporting as a tool to help us all do that. In the meantime, defragging and optimizing the reporting framework hard drives continues to be somewhat of an elusive goal.

And if all that is not enough for you, you can check out the recent GRI Podcast with Tim Mohin and hear him talk about GRI's 20th anniversary and other things reporting - including more on the subject of harmonization. 






elaine cohen, CSR Consultant, Sustainability Reporter, former HR Professional, Trust Across America 2017 Lifetime Achievement Award honoree, Ice Cream Addict, Author of three totally groundbreaking books on sustainability (see About Me page). 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 first / next Sustainability Report? Contact elaine: info@b-yond.biz 

Elaine will be chairing  the edie Conference on Smarter Sustainability Reporting  in London on 27th February 2018

The GRI STANDARDS Exposure Draft explained

It's official. G4 is now becoming a STANDARD. GRI is looking for input to the new Exposure Drafts for GRI Sustainability Reporting Standards (GRI Standards) in the Public Comment Period which is taking place NOW and will continue until 17th July. Of course, for all of you attending the 5th GRI Global Conference next week (come and say hi!) you will be hearing a LOT MORE about that, so you might want to hold off on your comments until after the event. In the meantime, I decided to translate the technobabble into a digestible version of the changes for those of you who want to know more about what it means, in addition to what it means, if you know what I mean.  

I also took the opportunity to have a chat with the two folks who are key to making this change happen - Chelsea Reinhardt, GRI's Deputy Director of the GRI Standards Division, and Bastian Buck, GRI's Director of the Standards Division - both of whom shared some fascinating insights. Chelsea has a strong background in standards, having led a full supply chain standards review for the Marine Stewardship Council in a previous role. She also has great taste in ice cream - cappuccino chocolate chip is her thing. Sounds good to me. Their insights are included through this post, which is LONG. So grab your Chunky Monkey and let's get started. 

A GRI Standard - how scary is that?

I suspect that for most of us, hearing the word STANDARD brings a sense of almost regulatory-like scary officialdom to sustainability reporting - after all, what we have had so far from GRI is a periodically-updated set of guidelines in the form of a framework - and that doesn't sound particularly threatening. It's a credit to GRI that the voluntary uptake of this framework has been so widespread by so many companies around the world - although the cynics (or realists) among us might suggest that because the application of the framework has been so pick'n'mix-ish, it's been easy for many reporters to claim adherence to the framework without actually investing the rigor that adherence requires and without actually adhering. Adherence without adherence has been a major blow to the credibility of Sustainability Reporting over the years. As the CSR Reporting Blog has often pointed out. 

Now, with G4 becoming a STANDARD, is all that going to change? Are we going to enter the era of ISO G4 that requires an administrative army, a battalion of auditors, a paper trail to Antarctica and a list of corrective actions as long as the Great Wall of China in order to report GRI? Is reporting going to become a headache, rather than the FUN we all have today? (What? Not fun? Then you are not doing it right!) Well, you know what, I am not going to say it's not a little scary as I think there is a little more to the transition to Standards than we might believe at first glance. It's positioned as G4 same but better... but when you read the small print.. it's actually G4 with many new twists. We'll still be in the same ball park but the ball will be a little different. Stay tuned.

Insight from Chelsea
"One of the main challenges in transitioning the standards has been the size of the task. Going through more than 300 pages of very dense content in the G4 guidelines, the Implementation Manual and the FAQ document. We have been sifting through line by line, under the oversight of the GSSB, tying to make decisions on which content rightfully belongs as a requirement in the new Standards and what should be rightfully positioned as guidance or recommendations. We are really trying to bring it all together in one place and this often involves considering the historical context in which the content was developed and going back to the output of the G4 working groups as well."

Insight from Bastian
"The discussion about adherence to the Standards and quality of reporting has come up frequently. One of the main struggles for GRI is that the Standards are voluntary and adherence in the current context is first and foremost a claim that a reporting organization makes. There are probably a range of mechanisms needed to introduce rigor. Certainly GRI should be more proactive about bringing the users of reported information into this discussion. But the priority right now is the Standards with a very clear signal from the Standards Board that credibility is something to look at and that is high on the agenda."

Materiality still center stage
The new Standards retain the principle of materiality as a core element to shape the entire disclosure, in the same way as in G4. We have seen in many G4 reports, however, that materiality can be whatever you want it to be - and the detail of how companies convert stakeholder input into a dot on the matrix is often non-existent. I had wondered if the transition to GRI Standards might not have taken the opportunity to add some requirements for more disclosure about how materiality is determined.

Insight from Chelsea
"The process for prioritization of material issues in the Standards has not changed fundamentally. The principle has not changed but we have strengthened the guidance to give more specificity about what we expect to see reported against the materiality principle. We are currently preparing a guidance document that will be released with the Standards about identifying and prioritizing material topics and applying the reporting principles. In some cases, we have seen that the materiality matrix has been misinterpreted and we are trying to improve the consistency of reporting materiality in the new Standards."

The skinny

Here is the short version of what's going to change. Instead of G4 being two documents - the Principles Manual and the Implementation Manual - there will now be to be a set of multiple modular Standards:

The first three - SRS 101, 201 and 301 - are what we today know as the Reporting Principles / In Accordance criteria, General Standard Disclosures and Disclosures on Management Approach (DMA). The remaining standards each cover an individual topic, based on the G4 Aspects, and include all the Performance Indicators we love so well. Sector Disclosures still exist, but in the new Standards they are referenced as guidance, not as a requirement.

The In Accordance options remain the same in this new setup - you need to report against SRS 101, 201 and 301 and one disclosure for each material topic for CORE and every disclosure for each material topic for COMPREHENSIVE, just as now in the G4 framework. 

Selection of standards from the 400, 500 and 600 series are determined by the selection of your material impacts - just as now. If you don't want to go the full monty, you can use one of the Standards - say SRS 505 for reporting emissions - and reference that in isolation - just as in the current setup, you can include "disclosures from G4" without claiming In Accordance with the entire sustainability reporting framework. Note that all the Standards now have their own numbering, so Disclosure 403-2 in the SRS 400 series is the new version of G4-EC8 in the Indirect Economic Impacts of the Economic category. There are several changes in the order of the different disclosures so in making the transition, some application will be required to work out what's moved and where it's moved to.

Insight from Chelsea

"There were many compelling arguments to take away the (Economic, Environmental, and Social) categories altogether, as so many issues are cross-cutting and have both social and environmental implications. But on the other hand, there’s a benefit in having categories to help users navigate and understand the new structure. Ultimately we took away the sub-categories – but this is subject to change with feedback we may receive."

Insight from Bastian

"With regard to the Sector Disclosures, what we have learned over time is that one of the big struggles is grouping – companies’ activities often cut across different industries and are not directly comparable. The other thing is we don’t want to establish several levels of the Standards going forward, the vision is to be global, comprehensive across the board of potential sustainability impacts of corporations. What we have on the horizon is guidance around issues that you might want to consider if you have a certain business activity… and that would work in the new structure going forward. Having been around in these discussions for so many years, I am still hopeful that we can build that out. It is a big stretch and requires more resources but our priority today is to get the Standards in place. Reporters can also of course make use of the sector guidance from other sources in conjunction with the GRI Standards - they have been written to allow this."

Insight from Chelsea
"The options of core and comprehensive are definitely a point of discussion and continued debate. The decision was made at this point in time to maintain both options as consistent as possible throughout the transition to Standards. There is already going to be some transition work for companies but it is one of the priorities for future review. We will be consulting on this, probably later this summer. There is no consensus here that these are perfect options but once we see how companies are using the Standards, we will be able to consider that what changes might be best for a review and redesign. These will be really exciting conversations for us to consider."

Insight from Bastian
"Looking at the GRI Standards, going forward, they will be more appropriate for use by policymakers. Take the EU Directive for instance. GRI Standards are aimed to attract a new audience not just retain the ones we have. There may be specific requirements in different jurisdictions for companies to report on ESG issues that can be fulfilled by individual GRI Standards or sections of GRI Standards not necessarily against the entire set of standard relating to specific core or comprehensive options."

What's in the box? 

The Exposure Drafts of these documents are here and the party pack includes: 

• The first part of each of the three universal standard proposals SRS 101, 201, 301
• One example topic-specific Standard in the Economic, Environmental, and Social categories
• A revised Glossary of Terms

There is also a 77-page background document which you can find here which provides a blow-by-blow account of all the changes. 

All in all, you have 207 pages of documentation and 77 pages of explanation. Time to order more Chunky Monkey.

Insight from Chelsea

"There were some definite debates among members of our Standards Board about the nature of the content and the outcome we are trying to get to with these specific disclosures. There is actually a public record of all these conversations and outcomes on our GSSB website. There were also some structural debates – members had different opinions about the structure of the content, for example, do we create a structure of one standalone standard or should that be five separate standards. In the end, we settled with one standard but that was not necessarily a unanimous vote. This might be revised further depending on stakeholder viewpoints."

Learn the new language

GRI is known for creating its own language and the lingo associated with G4's introduction was somewhat unwieldy to say the least. All of a sudden we had to get used to Specific Standard Disclosures, Aspects, Aspect Boundaries, In Accordance and a whole lot more. In the transition to the GRI Standards, we will have to adjust once again. First, each is standard is now an SRS. We can handle that. But just as we had got used to calling everything Aspects, the new proposal kicks that out and replaces that with the term, "topic", no longer making the distinction between a GRI prefab material impact (Aspect) and any old material impact (topic). In addition, the GRI Standards adopt the aceptable lingo for standard-setting practice - we now need to understand the nuance between what we shall report, what we should report and what we can report. If the disclosure says you shall disclose, then it's required in order to be In Accordance. If the disclosure says you should disclose, or you can disclose - then this is not required - it's a recommendation or guidance. The new Standards are full of shalls, shoulds and cans.. You too should, shall, can adapt to the new language of the GRI Standards when you prepare your reports in the future.  

When is an Aspect not an Aspect?

When it becomes a STANDARD of course. In the new era of SRSs, Aspects have no home. They have become topics. Just like any other topics. You all have this table of Aspects committed to memory.

 Now it looks like this: 

GRI has whittled down the total number of Aspects ..errr topics.... from 46 to 35 and, as you can see, things have moved around a little lot - anti-corruption and anti-competitive behavior are now in the category of economic topics rather than social topics, for example, and many Aspects which had been duplicated in G4 - such as three different supplier assessments for labor, human rights and society have been boxed into one Supplier Social Assessment topic. All the grievance mechanism Aspects that were introduced in G4 have not been continued as individual GRI Standards - they are now to be part of the DMA and only disclosed if material. Another big change here is that there are no sub-categories for social topics.  

In many ways, this change to the Aspect-topic table makes a lot of sense - it's almost as though GRI is correcting the mistakes of G4 by tidying up the set of predetermined topics we can choose from. Some of them were indeed rather awkward. On the other hand, this list of 35 is not extensive enough and we might have expected GRI to dig a little deeper at this stage and develop a more comprehensive list of topics that help align the language and performance reporting around similar issues. If this list were broader (and I understand it can never be exhaustive), companies would be more easily able to match issues that are material to their business to the list of available topics. This would encourage more consistent reporting around more issues. As it stands, social issues such as access to products and services, animal welfare, digital inclusion and many many more are left to the vagaries of SRS 403-2 (G4-EC8 in a former life) - significant indirect economic impacts -  a sort of catch-all disclosure where nothing quite fits exactly but it's used because it's the nearest thing when you want to align your materiality within the G4 framework and you have topics that do not fit anywhere else. SRS 403-2 has more guidance clauses than Liberace had sequins. Guidance, that means, can, not should or shall. 

In essence, this goes right to one of the core weaknesses of G4. The framework should be about reporting impacts, but in fact, many of the topics and performance indicators are about reporting actions. Almost every company that uses the framework has indirect impacts far far greater than all of its direct impacts added together. Yet, in G4, so little space is given to these type of impacts that it drags reporters back to "what we did" rather than "where we made a difference to people's lives". Significantly enhancing the table of topics and providing guidance for disclosing on these would make the GRI Standards more robust and relevant to more reporters and report-users than the current proposal. I understand that one of the great benefits of the new Standards structure is that new topics can be more easily added in the future, and that this will be a priority for GRI once the Standards are in place.

When is a Boundary not a Boundary?

When it becomes a STANDARD of course. In G4, one of the most difficult things we had to get our mind around was the requirement to state Aspect Boundaries. The Boundaries, we were told, were where impacts occur.

From G4 Framework Glossary

The G4 framework requires reporters to describe where an impact occurs, including the geographical location, whether this is either within your organization or outside your organization, and then define who it affects. For example, child labor may be a problem in certain geographies and the impact maybe outside your organization because the child labor occurs at your supplier locations and not in your own factories. So, the material issue is child labor, but the Aspect Boundary might be external in country X. You might be tempted to think that it's material for you, but that, because it's external, you are not accountable. 

In the new Standard it has been clarified that the Boundary relates to the entities which cause the impact, wherever the impact occurs. Child labor may be the issue, and even if the impact occurs at your supplier's factory, you are still the cause of that impact insofar as you hired the supplier to do the work. No question here about accountability. Your supplier, your problem. In the proposed GRI Standards you are required to disclose which of the entities inside or outside of your organization are causing the material impact - no geography required (SRS 301-1). However, the new Standards do give you a little room for maneuver with some guidance: "If the Boundary for the material topic is defined as outside the reporting organization, it can be difficult to report the topic-specific disclosures. This can happen if, for example, the Boundary for a topic includes part of the supply chain, and the organization does not have access to supplier information to report the topic disclosures. In these cases the organization is still required to report its management approach for the topic, in order to claim that the report is in accordance with the GRI Standards."

This is all rather tiresome, somewhat confusing and probably not even all that relevant. The entire concept of Boundaries is a little off-putting. In my view, the simpler version would be to require (shall) companies to disclose material impacts using their entire value chain from sourcing to market as a start-point and leave out Boundaries altogether.

Insight from Chelsea
"The Boundary change is one of the things we want to be communicating about during this consultation period. The clarification around the definition of Boundary is very consistent with the intent of the definition in G4 and with the outcomes of the original working group that developed that content. One of the main references are the UN Guiding Principles on Business and Human Rights and this together with the OECD Guidelines established this concept that companies should take responsibility for the impacts they link into not just their own direct impacts. We didn’t provide enough explanation in the G4 text to help companies interpret that consistently. We have had many reporters who asked for clarification. Fundamentally the STANDARD offers a clarification which is not in contradiction with G4, but we probably didn’t do a complete enough job in explaining it in the first place. The other misconception was the geographic interpretation of this, that’s not really a real issue for this particular disclosure."

And now to the fine print

The remaining changes in the transition to Standards are largely about terminology, improved consistency and clarity, and by and large, this works. More to follow on this as I scrutinize the fine print, but in general, the changes seem positive, for example a slightly clearer version of the "describe your supply chain" disclosure and more.

Insight from Chelsea

"There are a number of more subtle but important changes and our job is to call them out in a way which is clear and digestible. For example, the content index will be more outcome based and we no longer prescribe the use of a specific table format. The intent is that it will make it easier for reporting companies. I would say for companies that were previously working off the guidelines and not consulting the Implementation Manual, there is a lot of additional guidance and this is a good thing for them to dig into and understand. This may look new to some organizations who have not used the Implementation Manual thoroughly, but we think it will be very helpful."

More insight from Chelsea
"Comparability is of course harder across companies with the concept of materiality. I think you will see some improvement in the Standards that leads to greater comparability with improved clarity. In some parts of the Standards we have more specific information about what should be reported where in the past it was less clear. We believe that companies want to do the right thing and report fully and correctly. The Standards make a clear distinction between what is mandated to report and the guidance and coaching that can help you to get there."

GRI STANDARDS: Good, bad or indifferent?

The main challenge with the GRI Standards, targeted for implementation for reports published in 2018, is that it comes so close on the heels of the G4 introduction. Most reporters are just getting their minds wrapped around G4, and whoosh, in comes STANDARDS with SRSs, topics, shalls, shoulds and cans and a different look and feel. I doubt it will be a very easy transition. GRI says the Standards are more user-friendly - they weren't all that user-friendly in the first place - but there are some welcome changes and clarifications. The big advantage will be that GRI can play around with the individual standards without having to revamp the entire standards suite which will enable updates, revisions and the addition of new topics more quickly, efficiently and effectively. Of course, I still suspect that the main motivator for GRI was not to improve G4 but to convert it into the currency of the leaders. Self-respecting organizations in this space have to have a standard. But if that makes reporting clearer, easier and better, it's progress. Time will tell if GRI Standards will have such an effect - in the meantime, we can be cautiously optimistic. 

Insight from Chelsea
"Everybody in our Standards Division and our Board would agree that it is complicated. It is harder to transition content into a new structure than we perhaps originally anticipated. The positive is that it will be a better product – we have done a lot of clean-up work and editing along the way. For reporters, almost all of the fundamental concepts of G4 carry through – there are no major shifts in the reporting process or additional work needed to report in the standards. What will be required is some time invested to understand the nuances of the changes and which changes impact different companies. We will be developing some detailed mapping documents showing exactly what has changed as well as a new training module. A guidance document is in development and we are going to create an ecosystem of resources to help companies manage this change. But we believe the overall impact on the reporting process will be fairly minor."

And on that positive note.... see you in Amsterdam for lots of interesting standard-type debates!

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 first / next Sustainability Report? Contact elaine: info@b-yond.biz  

Take time to code

Today, when you talk about coding, the younger among us immediately click to coding: "the process of designing, writing, testing, debugging, troubleshooting and maintaining the source code of computer programs". But in the context of CSR and sustainability, we have a type of coding that is just a little different.

If you work for a large company, the chances are you have a Code of Conduct, a Code of Ethics, a Code of Commitment, a Code of Behavior or some sort of Code that frames the way the company behaves and expects its employees to align with. In addition, your company probably subscribes to one or more external codes or standards or frameworks that provide structure and even external validation of your company's activities in the field of corporate responsibility and sustainability. 

Did you ever stop to think just how many codes, standards and frameworks are actually out there? (Don't get me started, that's another conversation.) But yes, there are LOADS. And even more that. This was the case more than ten years ago and it's still the case at present. That's why, when Deborah Leipziger came along in 2003 and provided a comprehensive guide to the most relevant and useful codes, standards and frameworks in The Corporate Responsibility Code Book, it was an iconic piece of work that would be invaluable as companies started the process of navigating where to hang their hat as they develop a responsible business strategy, or understand what it is that makes one code or another more or less helpful or relevant. Recently the Corporate Responsibility Code Book celebrated the publication of its third edition.

Why does a competitor align with SA8000, for example, where another competitor prefers to use the ETI Base Code? What might we learn from the Extractives Industry Transparency Initiative, even if we are operating in a different sector? What are framework agreements and what role do they play in changing the way business gets done? Do the Guiding Principles on Business and Human Rights actually have any relevance for our company and why? Today, the third edition of The Corporate Responsibility Code Book is updated to include new initiatives such as the Guiding Principles on Business and Human Rights and the Gender Equality Principles and updates to the Global Reporting Initiative guidelines, the OECD Guidelines for MNEs, Social Accountability 8000 and many others. Similarly, some initiatives which that have been overtaken by new frameworks and are therefore no longer relevant have been removed.

While it's probably only geeks like me who actually like to read a book like The Corporate Responsibility Code Book, it's usefulness for anyone working in this space cannot be underestimated. And because, as a geek, I find this so fascinating, I couldn't resist talking to Deborah Leipziger, the code guru, to hear a little more from behind the code scenes.

Deborah Leipziger advises companies, governments and UN agencies on corporate responsibility and sustainability. She has advised leading multinational companies on strategic and supply chain issues, as well as a wide range of CR initiatives, including the UN's Global Compact, the Global Reporting Initiative, the UN Environment Programme, the Human Rights Impact Assessment, and Social Accountability International. Ms Leipziger is a Senior Fellow in Social Innovation at the Lewis Institute at Babson, and has taught at the Bard MBA in Sustainability, at the Simmons School of Management, and at Hult International Business School. She is a co-author several books and has served as a member of several boards including the Advisory Committee on Socially Responsible Investment for Aviva (UK), the Center for Ethics at Manhattanville College (USA) and the International Board of Ethos (Brazil). check out her website: here    

The Code Book is somewhat of an icon in sustainability and the general body of knowledge available. Who actually uses the Code Book and what's its value to them?

Deborah: The Code Book is used in many classrooms to teach about sustainability and CSR. I use it to teach my MBA students at Bard. I have heard from many professors that it makes for a very good syllabus and complete course materials. Many college libraries also purchase The Code Book. In addition, companies and law firms also purchase The Code Book for their libraries.

What makes for a good Code of Conduct? 

Deborah: The best standards and codes build upon the knowledge and value of normative and foundation standards, such as those developed by multilateral organizations like the International Labor Organization. A good code of conduct should be dynamic and flexible, while at the same time having staying power. Over the past 25 years, I have worked with many codes and standards. The best codes and guidelines are clear and concise and written with implementation in mind. Strong support from stakeholders is also essential.

In your introduction, you refer to a new emerging vocabulary as an essential part of fostering corporate responsibility. What are the key changes in vocabulary and why is it essential for us to adapt?

Deborah: A wonderful question! One of the most lasting contributions of codes and standards is their ability to create clear definitions in a complex field. Guidelines and codes have shaped a lexicon of terms around CSR and sustainability. For example, SA8000 lays out definitions of child labor and trafficking which are helpful for stakeholders and companies. These definitions provide companies with concrete parameters. The UN Guiding Principles on Business and Human Rights uses the terms “irremediable” to define human rights abuses for which there is no remedy, such as a lost childhood spent in hard labor. There are abuses for which there is a remedy, such as providing back pay for wages which were withheld. A few years ago, I was asked to advise Aviva plc on a project they were working on with Forum for the Future to create scenarios for what a sustainable economy might look like in 2050. My reaction was that we do not yet have the vocabulary to imagine and create a sustainable economy in the coming decades. I tackle this in a book I co-wrote with a team at Babson: Creating Social Value: A Guide for Leaders and Change Makers, which came out in 2013. One of the paradigm shifts that I see is companies working to promote social value creation, which includes solving social problems while also creating financial value. Companies need to think beyond being compliant with laws and standards, and towards creating social value through social innovation.

Your last chapter talks about pathways to convergence with ISEAL as an example which brings NGOs together under a broad framework of shared principles. However, what's the evidence that any sort of convergence in the private sector is actually happening? It seems that the world of codes, frameworks, and standards is only becoming more complex.

Deborah: The ISEAL Alliance has brought coherence to a wide range of social and environmental certification systems, creating common frameworks. This has helped to bring credibility and efficiency to certification and labeling standards from organics to fair trade. At the same time, there are many new systems emerging many of which are complex. I think complexity and convergence can coexist.

Did you consider the standard of standards, the emerging GISR? Do you expect GISR to influence the way Codes are used? 

Deborah: I have been following the progress of the Global Initiative for Sustainability Ratings (GISR) for many years. Allen White and I worked together when we were both in the Netherlands and he has been a speaker in my classes for many years, which has allowed me to follow the progress of the GISR first hand. I think the GISR will indeed have an impact on how codes and standards evolve. Perhaps it will be included in a future version of The Code Book.

What's your position on the frameworks used for inclusion in major stock exchange sustainability rankings for example DJSI?

Deborah: Many companies use DJSI as a framework to drive strategy and disclosure. I think the Dow Jones Sustainability Index is an excellent tool for companies. It helps drive performance and serves as a driver for companies to excel. I consider stock exchanges to be pivotal in driving change in the corporate sector. I hope to see more rankings like the DJSI emerge.

What was your personal biggest insight as you were preparing the third edition?

Deborah: I was struck by how much membership has grown for the guidelines and codes covered in Code Book III. When I first began tracking codes and standards, many of the initiatives had a dozen or so members. Now initiatives encompass broad networks of companies. I am also struck by how the field has evolved from aspirational initiatives to complex and brilliant initiatives like the UN Guiding Principles on Business and Human Rights. The Guiding Principles constitute a significant contribution to the field of corporate responsibility, defining the role of the state and of companies in addressing human rights and the need to provide access to remedy when human rights have been abused. The Guiding Principles provide a useful tool for companies working to complete due diligence and to assess where their operations, products, or services might have a potential adverse impact.

Will there be a Code Book IV? 

Deborah: It’s not in the works right now, but it is a possibility. There is a great deal of interest from emerging economies and Code Book III was launched in New Delhi.  

*******

Thanks to Deborah for these insights. Happy coding!


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 first / next Sustainability Report? Contact elaine: info@b-yond.biz  

Getting the most out of Sustainability Report Interviews

As a Sustainability Reporting Consultant, one of the regular, most fascinating features of our role is the gathering of information within a company about advances in sustainability performance. This often requires interviewing many individuals, mainly executives and managers. Sometimes this is challenging, as many people in many organizations don't quite understand why they have been selected for a "Sustainability Report Interview" or what their role has to do with sustainability. Often they are just doing their job, and the connection between their day-to-day and sustainability is not explicit. Others are ready for the conversation, which is often an annual event, and even look forward to it. Some even do a little preparation!

As we work with several companies working with different reporting cycles, I find that that I am part of such conversations almost all the time as a regular feature of my job. I find that it's also one of the most useful parts of our job, as far as the organization is concerned, although they might not realize it.

In an ideal world, where Sustainable Business Strategy is articulated, implemented, communicated and part of the way of life in any company, you would expect that everyone would know their connection to the sustainability agenda and why it's important. The reality is that, even in companies where sustainability is just about as embedded as you can get, people still have trouble seeing linking their their roles to the organization's overall positive impacts. The Sustainability Report Interview is one tool among several that can help reinforce and refresh sustainability thinking and drive action in the organization.

There are several reasons that these conversations are always important. The Sustainability Report Interview is an Art Form rather than just another plain ole conversation. It takes a certain knowledge and skill to perform a Sustainability Report Interview well and get the most out of a short conversation.

The Sustainability Report Interview has several objectives, and becomes a powerful (and fascinating) part of the reporting process. It can make a big contribution to advancing sustainability awareness, understanding and practice in any company, including smaller companies. We always try to interview as wide as possible a range of individuals in any company, in order to gather and cross-validate information and ensure we have a rounded understanding of performance, activities and issues. This is the nuts and bolts of sustainability reporting. It is often overlooked as a value-adding element in the sustainability reporting process.

The key things we try to do in Sustainability Report Interviews are:

Gather Insights and Information: This is the clear, stated objective of any Sustainability Report Interview. We aim to gather insights and information about sustainability performance in the course of the reporting year, within the scope of the interviewee's role and responsibilities. The idea is to distill the precise contribution to improving social and environmental impacts, or even activity which impacted less positively, from a range of information about the interviewee's role and performance. At this point we do not restrict ourselves to specific information that we think may be relevant to the sustainability Report, but aim to gain deep understanding of what was done and why and an appreciation of the context in which such activities were progressed. We look for performance, stories, case studies and future plans and targets.

Identify Sustainability Practice: The very process of the interview causes the interviewee to think about her or his role through a sustainability lens. If you ask most managers in most organizations outright what have they done to advance sustainability, they don't come up with very much. At best, they may start talking about some volunteer activity or other. By asking them about their business activities, a skilled sustainability report interviewer can identify those areas which are relevant from a sustainability standpoint. For example, a Logistics Manager might say that she restructured routing processes to improve delivery efficiency. She is happy to have saved costs while maintaining customer service. When we ask about the environmental impact, she may know the fuel savings which were needed to calculate the cost benefit, but she has probably not thought of the greenhouse gas emissions impact of logistics efficiency improvement. The minute we ask about this, and try to identify environmental metrics for this approach,  advising that  a saving of, say, 1,000 gallons of fuel is equivalent in GHG emission terms to planting and growing over 220 seedlings for ten years, a light-bulb (LED, of course) suddenly illuminates the imagination of the Logistics Manager. The next logistics efficiency project she undertakes will measure both cost and environmental benefit. Suddenly the Logistics Manager has become a Sustainability Manager as well.

Identify More Information Sources: Sometimes, it takes a while to get to the right person who can provide detailed information. Often, you start with more senior people and have them identify highlights or areas for further investigation. They will generate a list of people to talk to within the organization. In other cases, there may be clues about possible external stakeholders that may be able to make an important contribution to the report. A manager might say: "We led a great project last year. We hired an external consultant to help us." Or possibly: "We partnered with a trade association or non-profit organization to complete this." As the credibility of reporting is often enhanced with the inclusion of external stakeholder voices, the interview is a good source of potential additional experts who can provide content to enrich the report.

Increase Sustainability Awareness: A more subtle role of the Sustainability Report Interview is to help increase awareness of sustainability and its business value. In some cases, organizations may not have a declared sustainability strategy, and may not have communicated sustainability widely within the organization. Many managers may be performing sustainably without even realizing it and often, do not associate their positive activities with a higher purpose of sustainability. They may even think there is something wrong with claiming to be sustainable when all they really wanted to be was efficient. Often, people might say, apologetically: "We saved energy for cost reasons, not for sustainability reasons." This is a great opportunity for the interviewer to explain the link between operational efficiency and sustainable business, and reinforce to the interviewee that, whatever it's called, positive social and environmental impact may be the (additional) result of their actions. This connects interviewees to a higher purpose.

Empower the Sustainability Leader: In many organizations the CSO or Sustainability Leader or CSR Reporting Manager, or whatever she's called, participates in the interviews. This is a great opportunity for the interviewer to help the Sustainability Leader build understanding, awareness and relationships. Often, the Sustainability Report Interview might be the first time the Sustainability Leader has actually had a conversation with certain managers in the organization. Often, the Sustainability Leader comes away from such conversations having learned something new. This empowers the Sustainability Leader with new information and new contacts which help her drive the sustainability agenda. It also ensures that skills are developed within the organization and not condemned to oblivion in a file of an external consultant.

Reward Commitment and Action: A Sustainability Report Interview is an unofficial way to recognize those who are doing good work in sustainability. Although it is not the role of the external consultant to do this, in practice, reinforcement that a manager's work is meaningful and even report-worthy is a helpful bonus that the consultant can bring.  The fact that we show an interest, want to know more, ask about challenges, successes and outcomes, as well as the possibility that the manager's story might get published, is a massive motivating factor. In some cases, people want to tell their story so that it can help others. We give them a stage to do so. This is invaluable in helping create and embed a culture of sustainability.

Support Internal Communications: You'd be surprised, or maybe you wouldn't, especially in large organizations, how some managers don't know what the organization is doing or even what their colleagues are doing. Many managers don't read the company sustainability report (evidence of a shortfall in internal communications programs?) and many are surprised to hear for the first time that the company they work for actually does a whole lot more to advance social and environmental benefits than adding zeros to a profit statement. Knowing this engenders pride in the company and pride in themselves. The process of engaging in conversation with a wide range of managers in an organization makes sure they are getting the message. In the course of an interview, you don't just listen, you share, you update, you tell people why sustainability is important. After a good Sustainability Report Interview, both interviewer and interviewee know more about the organization and its sustainable practices. The process is an effective way to open up communication channels and get more people on the same page.

Having established herewith that Sustainability Report Interviews are a fabulous tool, not just for reporting, but to advance sustainability, organization development, communications,, engagement and motivation, not all of them are a piece of cake. In conducting interviews, the interviewer needs to be skilled in handling a wide range of reactions to the interview summons.

Let's discern TEN types:

The Let's-Get-This-Over-With Type: 
Characterized by: Politically-correct manager, maybe senior, not particularly interested in sharing, has a big team of people who can tell us what we want to know, has a hard stop in 15 minutes.
Making the most of it: Thank the manager, state up front it will only take 15 minutes. Cut to the chase, extract the headlines, and note the additional people s/he recommends talking to first. Then ask the manager where s/he feels the biggest business contribution was from her or his department in the last year. That will earn you at least another ten minutes and provide clues for sustainability activities.

The What-Am-I-Doing-Here Type: 

Characterized by: Totally disinterested manager, really doesn't understand how her or his role is connected to sustainability, doesn't understand what all the fuss is about, but was urged to cooperate by The Boss. 

Making the most of it: Thank the manager, say it won't take too much of her/his time. Ask first about business achievements in the past year. Look for sustainability themes in the business achievements, and probe further in those areas. If there's nothing, let it go and move on.

The Talk-To-Someone-Else Type:

Characterized by: Manager understands and supports the sustainability agenda, but is simply not the right person to talk to. Sustainability projects are more related to the work of other colleagues. 

Making the most of it: Thank the manager and ask, anyway, what the manager has achieved in the past year and what benefits this has brought to the company. Then continue as for the What-Am-I-doing-Here-Type above.

The New-Kid -On-The-Block Type:
Characterized by: New manager, recently joined, never participated in a Sustainability Report Interview before. Happy to provide data and information but is not familiar with sustainability and doesn’t know if s/he will be able to help. 

Making the most of it: Thank the manager and wish her or him good luck in his/her new role. Explain about the Sustainability Reporting process, why it's important and offer some highlights from the last report. Explain why the new manager's role is important for sustainability.

The We-Donated-$500-To-Charity Type:

Characterized by: Manager who still believes CSR is about charity, and is very very proud of the $500 donation s/he made last month with her or his department. 

Making the most of it: Thank the manager and confirm that a $500 is a fabulous donation. Then ask the manager to tell you what her/his biggest achievements at work have been during the past year.

The Glad-You're-Interested Type:

Characterized by: Interested manager, but not quite sure how her/his role fits with sustainability, s/he is just doing what s/he knows best in the interests of the business. Very glad that someone is taking an interest. 

Making the most of it: Thank the manager. Take an interest in specific projects mentioned. Explain how they are relevant to sustainability. Create the connection between sustainability and the manager's role.

The Ready-and-Waiting Type:
Characterized by: Manager happy to engage, hasn't prepared anything in particular, but knows the drill and is quite willing to have the conversation and be helpful. 

Making the most of it: Thank the manager,  ask about key objectives, goals, targets and achievements in the past year. Ask about what didn't work so well. Confirm the relevance of this manager's activities to the sustainability agenda.

The I've-Done-My-Homework Type:

Characterized by: Prepared manager, been there, done that, knows the drill, knows what you will ask, has done homework and prepared a list of activities and events in anticipation of the call. 

Making the most of it: Thank the manager. Lap it up.

The Help-Me-Focus Type

Characterized by: Manager who is excited to share but simply can't focus on what you are asking. Shares great detail about helping a local sports club build a new clubhouse but fails to address sustainability issues in the core business. 

Making the most of it: Thank the manager. Listen to the story. Compliment the manager. Then ask about her or his work activities. See the Ready and Waiting Interview.

The Enjoyed-Our-Talk Type:

Characterized by: Interested manager, does best to explain everything about progress made in sustainability projects and enjoys doing so. Confirms that s/he enjoyed the conversation. 

Making the most of it: Thank the manager. Lap it up.

If your reporting process does not include Sustainability Report Interviews, something's amiss. If you are not getting the MOST out of these interviews, you should reevaluate how you they are conducted. If at the end of the interview process, you have not enriched the organization while gaining relevant information (both good news and less good news), you need to think it through. It's a large investment in time and money, it should work.

Some of the most rewarding outcomes of Sustainability Report Interviews for me are when people say:

• I am glad you are interested in what I do
• I really enjoyed the conversation
• I learned something new
• That's given me an idea, I am going to follow up. 

When there are a lot of these reactions, I know we are going to be able to help deliver a great Sustainability Report!

So, here's to 2014, the Year of the Sustainability Report Interview!
Happy 2014!

PS: Maybe I should post next about what NOT to ask in a Sustainability Report Interview. I could probably write TWO posts about that. HAHA.

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)