An Ode to Reporters in CoronaWorld

As the world is in lockdown and the meaning of sustainability has truly hit home, thousands of reporting professionals around the world are battling against all odds to complete and publish their current Sustainability Reports. First and foremost, the CSR Reporting Blog wishes everyone good health! We hope you are all staying safe, staying home and staying optimistic. And if you are challenged to deliver your Sustainability Report at this time, here's a little Ode to Reporters in CoronaWorld everywhere:

Oh dear, oh my, I don’t know what to do
It’s the height of reporting season and ours is now due
We’re creating a CSR report designed to inspire us
But now, it seems, our report has the virus

So what should we do when we all are in lockdown?
Not publishing now would be such a letdown
I’ve tried to energize the team to engage
But we can’t even get past the title page

Our data collection has gone up the spout
To stakeholders, there’s simply no reaching out
The CEO is not interested, she’s in bed with corona
Even the printer has run out of toner

Reporting is hard when we’re social distancing
Our case studies suddenly don’t seem so interesting
No-one is really quite up to the task
Reporting’s not easy when you’re wearing a mask

Corona they say mitigates climate change
Even though it’s not great for the stock exchange
When it’s over, the planet may have been saved
But if we’re still solvent, I’ll be quite amazed

So what should I do with our sustainability report?
Go ahead anyway or decide to abort?
If only working virtually were not such a pain
It seems that everyone has locked down their brain

I called GRI, SASB and CDP
But whether to report none can agree
Which is hardly surprising as you all know
When defining materiality, consensus is no-go

I thought I’d get help from TCFD
As corona is saving the planet you see
With no flights, no travel and consumption is capped
Maybe their guidelines can now be scrapped

So stressful, so trying, this virus is awful
Even visiting my mom is now not lawful
As always a solution to stress is ice cream
Preferably injected into your bloodstream

Our company is closed, our offices shut
At least I can get by without a haircut
But even if we don’t manage to hit the deadline
"Delayed by corona" will be good as our tagline

So come on reporters, keep your spirits high
It’s time to prepare the copy and verify
With everyone working from home in their room
You can publish your ESG report on ZOOM

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: SASB: The Sector Specificity Question

So, since my last post broke the sound barrier with hundreds of reactions which mainly expressed support for the notion that collaboration rather than confrontation wouldn't be such a bad thing, I will delve a little deeper into one aspect of The Great GRI-SASB Showdown which didn't receive that much airtime in the multiple debates about mandatory or voluntary ESG disclosure. It's the question of specificity. Dr Madelyn Antoncic, SASB Chief Executive, made this point:

"SASB’s unique approach is well aligned with growing consensus among market participants that in order to integrate ESG matters into governance, strategy, risk management and performance monitoring, consistent with the TCFD recommendations, sustainability must be viewed on an industry specific level........ Indeed in order for any approach for corporate sustainability to be useful, it must address idiosyncratic, not systemic, risks. In other words, it must address not just climate change but climate change industry specific manifestations."

Now, I agree with this up to a point. I agree that business is done in industries and sectors, and each has their own specific material impacts. Having said that, business is done primarily by companies, and each company is unique in structure, geography, size, strategy, leadership etc., which means that its material impacts are also unique. So using pre-fab materiality à la SASB may well serve as a safety net to ensure relevant topics by industry are not overlooked, but it may not serve as a comprehensive basis for disclosure for every company in that industry. It also could lead to cutting corners where pre-fab materiality is blindly accepted without due process.

Nonetheless, SASB has done what GRI failed to do. Sector-based disclosures never reached the top of GRI's to-do list. In fact, I wrote about this back in 2013, in a post entitled "Will SASB make G4 redundant?" where I looked at the implications of the new SASB Standards on a specific sector basis. My closing line in that post is actually no less relevant today than it was then: ".....we perhaps ought to remind ourselves what Sustainability Reporting was designed to do in the first place. Account for company impacts on all stakeholders. Both GRI and SASB have an important contribution, I feel. The shame is that both appear to live on different planets, while the companies that are reporting are all on the same planet, and, more importantly, we are too!" Plus ça change.....

While SASB has developed standards for 77 industries in 11 sectors, GRI has 10 sector disclosures. There are differences in the approach to both - in fact, what GRI calls a sector, SASB mainly calls an industry. Oh dear, and I thought this was going to be easy....

I decided to see if I could substantiate the intuitive remarks I made in my last post: "Instead of debating which one is less perfect, whether they should be mandated or not and which definition of materiality should apply, GRI and SASB should roll up their sleeves and get down to some serious work with companies and with each other to help drive better implementation of sustainable development practices and disclosure. If we do nothing more than ensure existing standards are fully adopted by all companies, consistently, auditably and comprehensively, perhaps with a few tweaks here and there, we will have done a lot." In other words, let's work together with what we have and make it work. At some point, you just gotta stop checking if the oven works and make a start on the cooking. 

There is a small number of companies who use SASB Standards. Not quite enough yet to consider whether this enables sector comparability or even use of similar standards, but enough for me to handpick a few reports that cover both. I decided to check a few things out:

(1) Are SASB Standards really a useful tool? To what extent is there more information than that required by a GRI report which is well prepared? In checking the delta when reporting both SASB and GRI, what value does sector-specific SASB add over and above what is already in GRI standards?
(2) What does sector specificity actually add? Is there a meaningful level of specificity that makes it easy for companies to recognize themselves in the sector?
(3) Who needs to budge to turn this into one Standard that's useful for all? Haha. No-one wants to budge. But maybe they should.

I'll start with Bloomberg. With Bloomberg putting all their weight behind the development of the SASB Standards, it's clear that they would use them, even if as a privately held company, Bloomberg is not required to go the full Monty.

Bloomberg's 2018 Impact Report was prepared in accordance with (1) GRI Standards Comprehensive Option (including the Media Sector Disclosures) (2) SASB Standards (3) FSB Task Force on Climate-related Financial Disclosures (TCFD) guidelines and (4) "select content from CDP". That's four reporting frameworks. Convergence, anyone?

Supplementing this report, Bloomberg publishes a GRI Content Index (including the Media Sector Disclosures) and a SASB Disclosure. The SASB disclosure includes metrics from three separate SASB Standards:

• Internet and Media Services
• Media  and Entertainment 
• Professional and Commercial Services

Now, this is where the difference in approach start to show up. GRI's Media Sector Disclosures are integrated throughout the existing GRI Standard with some additional Sector-Specific Disclosures. In various sections throughout the GRI Standards, additional sector-relevant elements are integrated (noted by a little green + sign) or new elements are added (noted in green).  (NB: This still relates to G4, and has not been updated to reflect the changes in GRI Standards, but the approach is the same).

SASB Standards are all standalone. So, when Bloomberg decides to report against three SASB Standards, it is actually duplicating several pieces of information. For example, you can find data on workforce diversity included three times in the same Bloomberg SASB disclosure document - one for each of the three SASB Standards that Bloomberg identified as relevant to their business.

And the funny thing is, that all this data is reported as well already in Bloomberg's GRI Content Index:

I worked through every single Bloomberg SASB disclosure against all three SASB Standards to try to establish the delta. I found that there is extremely little in the SASB disclosures that is not already reported in the GRI Content Index, or would have been reported if the GRI Content Index were applied in full. Environmental data... it's in both; data privacy - it's in both; data security - it's in both - although there are a few metrics that SASB includes that are not in GRI. On the topic of employment, SASB asks for employee engagement measures (that GRI does not specifically cover). All in all, it would take very little to combine these GRI and SASB Standards to achieve sector-specificity with no duplication and enable relevance for all stakeholders including investors.

Here's another report. Apache Corporation 2018 Sustainability Report

Apache's report follows (1) GRI Standards, Core Option (2) Oil and Gas Industry Guidance on Voluntary Sustainability Reporting (2015) developed by IPIECA (3) SASB’s Oil and Gas Exploration and Production Standard and (4) the Disclosing the Facts framework which is an annual investor scorecard ranking of the 30 largest oil and gas companies engaged in hydraulic fracturing.

Again, I analyzed the SASB disclosure to assess if it includes more than is delivered by a regular GRI-based Sustainability Report. Note that, in this case, Apache does not use the GRI Oil and Gas Sector Disclosure, which, as with the media sector, integrates disclosures throughout the Standard and adds sector-specific additional topics.

So, what about the delta? For several metrics, such as GHG emissions, biodiversity impacts, community relations, and health and safety etc., there is no meaningful difference between the Standards. In others, there are differences. For example, on the topic of indigenous peoples: GRI focuses on violations of indigenous rights in the main GRI Standard, and on disputes in the additional sector disclosure:

SASB focuses on operations in proximity to indigenous lands and engagement processes.

Apache does not report these indicators, neither GRI nor SASB. Interestingly, APACHE does report against an IPIECA indicator relating to indigenous peoples, with a Statement on Indigenous Peoples representing Apache's approach.

So, while Apache has made significant efforts to deliver high-quality transparency, it is clear that the multiple standards and frameworks cause duplication and fragmentation of reporting requirements. However, Apache reports neither Standard in full, disclosing against 13 of the 27 metrics in the SASB Oil and Gas Standard, and 17 of the 33 Topic Specific Standards of GRI and none of the sector-specific topics. The SASB Standard offers some fine-tuning of disclosures for this industry, but nothing that is monumentally significant versus a fully reported GRI Standards-based disclosure.

One more? Let's try a different sector. Food. I LOVE food (especially ice cream).

Kellogg's 2018-2019 Corporate Responsibility Report also uses multiple sustainability disclosure frameworks:

• GRI Standards including the Food Processing Sector Disclosures (downloadable Content Index)
• SASB Food Processing Standard (downloadable index)
• CDP Climate and Water Disclosures
• Cross-references in the GRI Index to SDGs and the UN Global Compact Principles

Should we count that as six frameworks?

Here again, this company has worked hard to address the multiple reporting demands of different frameworks and organize disclosures in the least confusing way for stakeholders. Not an easy task to avoid the duplication and fragmentation that we have already seen in the two reports above.

Again, my focus here is on the delta between SASB Standards requirements and GRI. In this sector, there are some significant differences. For example:

Food safety: This is material for Kellogg's, and also highlighted in the GRI Food Sector Disclosures, SASB includes two indicators that link to external audit by the Global Food Safety Initiative (GFSI) GRI on the other hand references external standards certified by an independent third party according to internationally recognized food safety management system standards, leaving companies to choose which certifications.
Food waste: This is noted as material for Kellogg's but appears neither in the GRI Standards nor in the SASB Standard.
Climate change: This is not included in SASB Standards for this sector. Energy management is included, but not climate change impacts. As Kellogg's has noted climate change as material, then GRI Standards requires disclosure on climate change impacts. I find it hard to understand how investors assessing a company such as Kellogg's would not be interested in climate change data.
Diversity and inclusion: This is stated as material for Kellogg's but is not included in the SASB Food Processing Sector Standard. It is part of GRI Standards.
Packaging lifecycle management: This is included in the SASB Standard and is a relevant addition for this sector.  It is not included in GRI Standards (beyond regular disclosures about waste) although Kellogg's CR Report contains information about the sustainability of its packaging and lifecycle impacts.
Animal Welfare: The GRI Food Processing Sector disclosure is the only standard that points this out specifically. The SASB standard does not address this and Kellogg's maintain it is not material to their business.

Across both the SASB and the GRI Food Processing Sector Standards, and Kellogg's own list of material topics, there is a significant degree of overlap, but also some areas of difference. Does the SASB Standard add much? In this sector, the metrics are a little more industry-focused though it strikes me as odd that there are no SASB metrics relating to people, labor or human rights.

Kellogg's own material topics, SASB's Food Processing Standard topics and GRI Food Processing Sector Disclosures (additional to and incorporated in the general GRI Standards)

Back to my three questions:
(1) Are SASB Standards really a useful tool? 
(2) What does sector specificity actually add? 
(3) Who needs to budge to turn this into one Standard that's useful for all?

And my three answers:

(1) I cannot speak for the investor community, for whom SASB standards were devised. If the idea was that all the topics in the SASB Standards are "financially" material, then it's rather odd that very few of the SASB metrics I have seen actually correlate to any sort of financial measure. My observation is that where a company reports GRI in full, including any available sector disclosures, the additional disclosures required by SASB may not add a lot. For a company not using GRI, and using SASB for sustainability disclosures in its annual report, then it may not be enough. Having said that, the overview of what's most important by industry is a useful reference for any company conducting a materiality assessment.

(2) Sector specificity is a worthy pursuit, especially when companies are not rigorous in their materiality assessments. Kellogg's, for example, presents what I feel is a balanced and representative set of material topics, covering both the operational and purpose-driven aspects of its business. Apache's material topics are more generic, so the SASB Standard could be a useful safety net. However, in this case, as is the case in several other sectors, there is another reporting framework developed by the industry itself, IPIECA which tends to address the sector-specific requirements.

(3) I think both GRI and SASB need to budge. As can be seen from just 3 examples, reporting is fragmented, duplicated and yes, confusing. Just working out who reports what against which Standards was a nightmare. All three companies made valiant efforts to navigate these frameworks and deliver robust disclosures. We should not let the question of financial materiality divert us from the real questions of who should report what. There is room to develop a set of jointly-owned GRI-SASB Standards that would include (1) a core of disclosures and metrics on universally critical sustainability topics that every company should report, material or otherwise (2) a menu of core sector specific disclosures that all companies in a particular industry should report (3) a menu of optional metrics and indicators that companies can disclose in addition, if they or their stakeholders define them as material. What's important here is not only what to report but how to report, that is, by prescribing the methodologies required for each metric reported. That would enable the rigor and comparability that SASB maintains is so lacking. And in each industry, the industry associations, such as IPIECA, have an important role to play as well.

Ultimately, I think we have everything we need - except a spirit of collaboration. Combining the best of GRI, SASB and industry-specific experts can be an exercise in cooperation, not reinvention. By working together, we can totally simplify the landscape and make it much easier for reporters to report and users to use the information. Why is this such a big deal? Why is it so contentious?

But that's only the first step. The second step is doing more to encourage companies to fully implement these simplified reporting Standards in a consistent and auditable way. I don't mean through external assurance but through internal rigor and accountability. Both GRI and SASB are far too eager to hype up the numbers of how many companies are using their Standards. Neither is prepared to really buckle down and assess the way the Standards are being implemented or call out companies that are doing a pick'n'mix job of reporting what's easy or available or irrelevant.

The GRI-SASB Game of Thrones Showdown I witnessed at the Asia Sustainability Reporting Summit earlier this month did not offer much hope of collaboration. Apparently, the comfort zone is exactly where they are. Unfortunately, it's a very uncomfort zone for everyone having to deal with the fallout.


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 100 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     

SASB: Hot air. GRI: Cold shower.

The stage at the Asia Sustainability Reporting Summit was sizzling last week, despite Arctic temperatures in the conference room, as SASB and GRI battled it out in a fight entitled: My Standards are Bigger and Better than Yours. 

In contrast to the restrained, optimistic rhetoric we have been used to over the past few years, SASB burst forth with a whoosh of self-aggrandizement, leaving GRI doing a jelly-wobble in disbelief. Of course, we shouldn't be all that surprised. SASB received a setback earlier this year when U.S. SEC Chairman Jay Clayton rejected ongoing and heightening pressure to make listing contingent upon (SASB-based) ESG disclosure:

"In a blow to several investor groups, SEC Chairman Jay Clayton recently said that he does not believe public companies should be required to disclose information concerning environmental, social, and governance (ESG) matters in a standardized format. Clayton was especially opposed to requiring publicly-listed companies to use ESG standards developed by organizations like the Sustainability Accounting Standards Board (SASB) and the Global Reporting Initiative (GRI), which some companies voluntarily use."

Denied SASB the dream, it was perhaps predicable that SASB, having based its entire strategy on becoming THE ESG disclosure tool for U.S. based companies, would not accept this without a fight. 

At the Summit, which ran under the theme of "Is mandatory better?", both GRI and SASB came out forcefully in opposite corners of the two pivotal questions: Should ESG disclosure be mandatory? and Should ESG disclosure be based on the concept of financial materiality (rather than sustainability materiality)? 

The showdown started as Tim Mohin, GRI's Chief Exec, took center stage, presenting GRI's position. He made the case for increasing mandatory instruments around the world, with 544 instruments tracking some form of mandated ESG disclosure in 85 countries and quoted a McKinsey study that showed 82% of investors and 66% of corporate executives surveyed preferred companies to be required to disclose by law. He explained that voluntary mechanisms are seen to work too slowly and don't cover enough of the market. Tim also quoted a study that indicated that mandatory disclosure has led to more efficient boards, less corruption and improved corporate credibility.

This was all going so well until he reverted to something that sounds like wishful thinking: "There is a belief in the marketplace is that there is confusion (around ESG disclosure standards). In fact, there is a lot of convergence....." Tim explained convergence by referencing the widespread use of GRI standards. But this is not convergence. It's a sort of Hobson's Choice: there is actually no other general standard for broad-based sustainability disclosures, and in any case, the quality of implementation varies so widely that it's hard to assess just how effectively GRI Standards are being used. At the same time, companies using or sort-of using GRI are also deploying other forms of disclosure, including CDP, TCFD, SASB, UNGC, sector-based standards and even SDG, to mention just a few. So let me be clear. THERE IS NO CONVERGENCE. It's time to stop saying that.

Tim went on to explain his testimony to the U.S. House of Representatives Committee on Financial Services earlier this year where he said that (1) ESG information is essential for the operation of capital markets and free trade; (2) This disclosure must be mandated and must be based on international, independent multi-stakeholder standards and (3) The concept of financial materiality does not work for ESG disclosure.

He said "I don’t think I need to convince anyone in this room that ESG disclosure is essential. We know that investors are demanding this information as it becomes more critical to investors and free trade. The last point is most important. We cannot rely solely on the test of financial materiality. If ESG issues were financially material, we would not have ESG issues. In fact, these issues are very hard to monetize. When we do monetize these issues, they often do not make the test of financial materiality." He has a point.

Tim Mohin even went into print this week (post-summit) to reinforce how increasingly worried he is that SASB has upped the ante:

"The movement to limit corporate disclosure on environmental, social and governance (ESG) issues to financially material topics (already legally required for public companies), has gained some momentum. If it catches on, it could roll back decades of progress. Even more troubling is that the advocates of this position brand themselves as working for environmental and social causes. Could this be a clever Trojan Horse to put the brakes on corporate responsibility?"  Ta-da!

Following the GRI keynote, the Summit delegates then turned their attention to hear a very different story from Dr Madelyn Antoncic, SASB's new Chief Exec. SASB's proposition is about financial risk, market forces that incentivize corporations to make the choices that will cause investors to allocate capital to them. SASB believes that it is not regulation that will cause companies to improve and disclose ESG performance, but market forces and the promise of investor attention.  

Madelyn said: "At first flush, it may be easy to jump to the conclusion that companies won't do the right thing when it comes to sustainability, especially when it will have short term negative impact on their bottom line. As an economist, however, I challenge that view. As I know that on occasion, economic agents, people, whether acting as individuals or on behalf of on behalf of organizations, or institutions, are motivated by incentives."

According to SASB, current sustainability disclosure does not cut it. (That's not a new assertion by SASB.)

Madelyn added: "Yet while sustainability reporting has become near ubiquitous in recent years, the practice has widely been criticized for lacking the rigor of traditional financial reporting. A recent PWC report shows that 100% of corporations polled felt confident in the quality of their ESG information reporting while only 29% of investors polled were confident in the quality of that same information that they were receiving. More than 60% of corporations but only 8% of investors polled by Bank of America and Merrill Lynch during a recent congress thought that the ESG disclosure allowed for comparison among companies and peers."

My summary of SASB's view of the world is:

(1) Investors need corporations to provide reliable, consistent, auditable ESG information that is financially material by sector and by industry

(2) If they get this, they will act to allocate capital most effectively, rewarding good corporate citizens who show they are managing ESG risks

(3) The carrot of earning investor favor will keep corporations focused on good ESG performance and disclosure while the stick of higher risk and loss of reputation will do the same

(4) When all this happens, everybody wins.

Madelyn summarizes: "When we transform markets, we transform the world. .... What’s needed are incentives. Corporations need to be incentivized, to do the right thing because to do the alternative will negatively hit their bottom line. And only with consistent disclosure of financially material information, can investors be effectively the policing mechanism which will drive positive outcomes for the environment and society at large."

Ultimately, my reading of this is: Place your trust in investors. Let the money-makers and the money-takers decide what's best. Let money be the deciding factor in assessing corporate citizenship. If investors incorporate selected ESG factors in their decisions, so they can minimize financial risk, it will be good for everyone.

Well, sorry, but in my work in sustainability, I missed the bit where money was THE motivator for doing the right thing. I missed the bit where corporate transparency was ONLY about helping people make more money. I missed the bit where sustainability reporting has only ONE stakeholder group. When SASB was first formed, as an organization designed to deliver standards for financially material ESG disclosure in corporate annual reports, I could understand it. It was about helping investors understand and evaluate risk more holistically (even if they still don't quite know how to do it). It seems I am now hearing that voluntarily giving investors better ESG information is the key to delivering sustainable development and solving social and environmental issues. That's rather a lot of responsibility on the shoulders of those who are (only) managing financial assets.

The debate continued in the opening panel discussion which mainly focused on the chasm between GRI and SASB  (sidelining the others present on stage). It went something like this:

He said: 

"Let’s face it, this movement started from a very different place – of activism, of trying to do the right thing, we call it corporate responsibility and now, because it has become quite clear that these non-financial matters have financial implications, we have the interest of the financial markets, But as I said, the fact is that externalities are not properly valued, and when they are, a lot of times they are still not financially material. There is a subset of ESG issues that are financially material, and frankly, in every jurisdiction I am aware of, financially material ESG issues ALREADY have to be disclosed, it's the law. Ethics, gender diversity, Scope 2 and Scope 3 carbon, water... many of these things just don’t ring the bell of financial materiality, but we know that they are absolutely critical"

She said:

"I would challenge that because at the end of the day, ethics, if you aren’t an ethical company, you go out of business, gender diversity, sooner or later, you go out of business, so that’s why they are called non-financial risks, I think it’s a ridiculous statement, non-financial becomes financial. The reason we look at financial materiality is the comparability – so many reports are now coming out in the ESG space, where investors say we can't make heads or tails out of this, and I can't compare one company versus the other, because they are not tied to some financial metric, that one company can be compared and therefore the capital can allocate to the different companies that are being good corporate citizens."

He said:

"The judgement of what is material can't be made by somebody else, it can't be made in the rear view mirror, it has to be made with a multi stakeholder approach, up front, that’s looking at a horizon that is typically much further than companies look at, not next quarter or next year, that’s not what ESG issues are about. We would never have looked at things like gender diversity – how do you value such things? We don’t have gender diversity in the SASB standards. Scope 2, Scope 3 carbon are not financially material. These are things that if we don’t get a handle on, our society will be so much worse."

She said:

"I think there is a misunderstanding. Financial materiality, the way we look at it, it’s not next quarter, that’s the whole point and that’s what I mentioned, it’s about the long term. I think that any one of these issues that you mentioned .. of course.. sooner or later they are financially material.. and you mentioned that something is not in the SASB standards. Well, the SASB standards were only issued last November and now we are going through to look where we can improve.. as you know, these things evolve. I commend what your organization has been doing all these years and that’s great, but I think the world moves on. That doesn’t mean what we are doing today is wrong, it means we have built on the shoulders of what's been done, but we have to look at it now in a different way. Financial materiality and industry specificity makes it comparable .. and that’s why you see all these data providers coming up with their own interpretation and that’s why you see more and more of these so called standard setters -  because no one can come up with a way that investors can make use of the information. It’s about how you come to the use of that information so we can mobilize all that capital."

He said:

"It’s just not true that this information isn’t getting to corporate boards and CEOs. I have done it personally. If you think Tim Cook doesn’t know about the supply chain issues at Apple, I can tell you I have personally briefed him many times. It is difficult and many companies aren’t in a position to understand this, it’s like trying to teach a fish to ride a bicycle. One of the things we're doing is forgetting about a key player in the marketplace and that’s analysts. Most of the analyst work is done on the back of GRI Standards, and it's used to compare companies."

She said:

"I didn’t say that Boards are not aware that they have supply chain issues. I am saying that the reports are not being done under the same standards as financial reports which means they are not signed off.  As far as analysts are concerned, yes, there are lots of these data analysts, that’s the point, they are popping up all day, why? Because there are not robust reports that investors can use.. that’s why there is Sustainalytics, and RobecoSam and MSCI… and the list goes on. The reason is that the information is not consistent, it is not comparable, therefore these data providers are making inferences about what companies are doing and using analysts and coming up with the wrong answers. What we say is: use SASB standards, comparable, auditable. If the solution was what we currently have, without naming names, we wouldn’t have all these other things popping up."

He said:

"There is a lot of misleading information about the lack of comparability among analysts. In fact, in fact, it’s not meant to be comparable .. you can't just add up ethics, climate change and supply chain and come up with a number .. a lot of analysts cut it one way or another and they come up with different information because they are looking at different things. By design."

And by this time, the hundreds of delegates in the audience are starting to squirm a little at the way GRI and SASB are openly taking shots at each other (especially as the whole public rhetoric to date has been coochy-moochy harmonization and common purpose - remember the joint op-ed by Tim Mohin and the former SASB CEO, Jean Rogers?) In this dialogue of the deaf, both GRI and SASB are hyping themselves to their own downfall and missing the point. We do not need better standards. WE NEED BETTER IMPLEMENTATION. 

GRI Standards could provide a good degree of comparability IF companies applied the standards in a quality way. The problem has always been that  GRI has avoided any form of intervention in the way the standards are actually used and there is no consistent watchdog covering reporting accuracy or quality.

SASB Standards, which have not yet reached critical mass (any mass?) yet in terms of the number of companies fully using them, will only enable investors to get what they want IF the standards are IMPLEMENTED in a quality way. It's a little early for SASB to sing its own praises. 

And if GRI and SASB and the other parties in the rather useless Better Alignment Project of the totally superfluous Corporate Reporting Dialogue pooled their resources to help companies apply GRI and/or SASB Standards in a complete and proper way, we would all get much further, much faster. 

And as for mandatory, I think both GRI and SASB are wrong. They see the world too simply. One says YES to mandating ESG disclosure, the other says NO. I believe the answer is in the middle. Some things absolutely have to be mandated or they will never happen consistently across companies, industries and sectors. Others can be left to market forces, peer pressure, competitive appetite, stakeholder demands, investor self-interest. The real question here is not whether mandatory is better, but how much mandatory and which elements of mandatory would be truly effective. But GRI and SASB cannot see past their own ego and beyond their current legacy. GRI's overly positive hype about the status quo won't help us move forward. SASB's dismissal of everything that's not SASB is arrogant and misplaced. 

I think it's time to refocus and reframe. We need to spend more time looking at the quality of what companies are reporting and less time in slanging matches about which standard is better. No current standard is perfect to meet the needs of a broader audience that uses ESG disclosure, not just investors. Instead of debating which one is less perfect, whether they should be mandated or not and which definition of materiality should apply, GRI and SASB should roll up their sleeves and get down to some serious work with companies and with each other to help drive better implementation of sustainable development practices and disclosure. If we do nothing more than ensure existing standards are fully adopted by all companies, consistently, auditably and comprehensively, perhaps with a few tweaks here and there, we will have done a lot. 

GRI, SASB.... gauntlet over to you.  

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 100 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      

Story of a Sustainability Superwoman

There are plenty of excellent reasons to attend the Asia Sustainability Reporting Summit on 2nd and 3rd October 2018. I won't list them all here.

Just take a look at the website and you'll be convinced. Instead, I'll tell you a story. 

Once upon a time, there was a little girl called Suyin. Suyin lived with her mother and father and seven younger siblings in a remote part of Asia, in a wooden hut, far from the hustle and bustle of the big cities and the stresses of daily living in modern times. Suyin and her family were a close-knit group, relying on each other for love, support and inspiration. They lived on the resources of the earth, fishing, hunting and farming, taking from the land only what they needed to survive without wasting any precious resources. It was a simple existence, but it was a good one. 

As Suyin advanced in age, she noticed with each passing year that life in their region was becoming tougher. Rainfall patterns were changing, water levels were dropping in nearby streams, the soil was not as fertile as it once was, local wildlife had ceased to thrive. Slowly, Suyin was perceiving that her land was refusing to provide for them. And when she was just 19, there was a major typhoon that shook their wooden hut to its foundations, barely leaving it standing.

Suyin was worried about the long-term survival of her family. She knew she had to do something. Amid tears of farewell, she left her family, promising to return. She travelled by foot without a cent to her name until she reached a major city and there, she begged for food and money. What she was given, she saved. And when she had saved enough money, she rented a small room, and took a job in a small store. She did well. She was intelligent, capable and thoughtful and soon enough, she had enough money to fund a place at university, as she knew that without education, she would not advance and be able to help her beloved family. 

After studying, she was fortunate to be offered a job in a large corporation, in the Sustainability Department. In that role, she campaigned to mitigate climate change and advance social programs that would help families living in remote areas. She became a true sustainability leader, speaking all around Asia on the need to save the land and prevent environmental degradation, as well as taking care of communities and their ability to survive and thrive. Many companies followed her lead and joined the sustainability movement to drive positive change for prosperity. During this time, Suyin returned frequently to visit her family, provide them with resources and help them overcome their challenges. For example, she purchased a small farmer irrigation kit from Netafim so that they could irrigate the couple of acres they farmed and gain greater yields of fruit and vegetables with less water. 

In 2018, a colleague nominated Suyin in the annual listing of exceptional female sustainability leaders in the region, Asia's Top Sustainability Superwomen, an initiative of CSR Works International. Suyin was overwhelmed. She had never received such recognition for doing only what she thought was right. But will Suyin's nomination be accepted? Will Suyin shine through? How many more Sustainability Superwomen have been nominated and who will gain recognition at the Asia Sustainability Reporting Summit?

You can discover if Suyin is included in this prestigious list of Sustainability Superwomen in October in Singapore, at the Asia Sustainability Reporting Summit. Even if you don't get to meet Suyin, you will be able to engage with a host of inspiring women sustainability leaders and experts who have driven the sustainability agenda in Asia with passion and overcome challenges to ensure their voice is heard and improve life for all of us.

Come to the summit and celebrate Sustainability Superwomen with all of us. Overall, there'll be more than 60 international speakers (not ALL of them are women, however!) who will cover every important aspect of sustainability reporting in depth. You will hear directly from top leaders from

• Agility
• AIG
• Bangchak Corporation
• Baoviet Holdings
• Bombay Stock Exchange
• CapitaLand
• CDP
• City Developments Limited (CDL)
• CLP Power
• CP Group
• DBS Bank
• EcoVadis
• Golden Agri-Resources
• GRI
• Hang Lung Properties
• Intel
• International Integrated Reporting Council (IIRC)
• John Swire & Sons
• JSW Group
• Kalbe Farma
• Maritime Ports Authority Singapore
• Microsoft
• MSCI
• RobecoSAM (DJSI)
• Schneider Electric
• Sime Darby
• Singtel
• SM Investments
• Suntory Food & Beverage
• Sustainability Accountability Standards Board (SASB)
• Tata Consultancy Services
• Union Bank of the Philippines
• Viego Eiris
• WWF
and the list goes on

And of course, I will be there, co-chairing the summit with the man behind it all, Rajesh Chhabara.

Exciting debates and insights that will help you move the needle include:

Looking forward to a fun couple of days of learning, sharing, challenging and celebrating. Hope to see you there!




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 co-chairing  the  second annual Asia Sustainability Reporting Summit 2018 in Singapore on 2/3 OCtober. Join me there!

A new CSR standard in Safeguarding

Using the Datamaran Research Tool, I looked for how many companies are talking about safeguarding in their sustainability reports. It seems, that safeguarding can be applied to just about everything.

• Export Development Canada's 2016 Sustainability Report talks about safeguarding people and the environment 
• Piraeus Bank talks about open communication with employees and safeguarding their ongoing development and elearning for safeguarding of Human Rights and Equal Opportunities in the workplace 
• Wilmar International's 2016 Sustainability Report talks about safeguarding water quality
• Statoil's 2016 Sustainability Report refers to safeguarding people, communities and assets
• Stericycle's 2016 Sustainability Report refers to safeguarding sensitive information and helping protect against identity theft
• Motorola Solutions 2016 Corporate Responsibility Report includes disclosures related to machine safeguarding
• RSA Insurance Group refers to safeguarding customers' data and assets
• American Water Works Co Inc. talks about safeguarding the nation’s long-term water supply as water demand grows
• TDC goes for safeguarding trust and safety
• Macquarie Infrastructure Corporation includes references to safeguarding of storm drains, overfill controls, and extensive use of LED lighting
• SunArt Retail Group Limited includes safeguarding biodiversity
• L'Occitane International SA goes for another type of safeguarding -safeguarding the future of bees while helping to build communities.

In fact, safeguarding has become so popular that I am thinking of safeguarding my personal ice cream supply for the next five years. As you can see, safeguarding can apply to just about anything and the use of the term safeguarding is bandied around quite freely in CSR and sustainability worlds with no real accountability for what safeguarding anything actually means and how to measure it. Maybe this is a shame, because there is one use of the term safeguarding that is arguably the most important use of all: safeguarding vulnerable children, youth and adults. I happen to know a bit about this, as my niece, Sarah Carlick, (Yay! Proud Auntie) is a leading expert on safeguarding in the UK, and runs The Athena Programme, one of the best known and most active consulting and training firms dedicated solely to safeguarding in the important sense of the word. Sarah has just completed her doctoral thesis on safeguarding, so we shall be calling her Dr. Sarah in the very near future! (Yay! Extremely Proud Auntie). Read Sarah's insights into safeguarding in a corporate context later in this post.  

Some companies stand out in their approach to safeguarding vulnerable children and adults. Pearson's Sustainability Report for 2016 includes a commitment to safeguarding adults and children. 

As a company engaged in education and supporting learners all over the world in schools, training and learning centers and other teaching facilities, and even virtual classrooms, human rights risks and challenges are very real for Pearson and it seems quite obvious that safeguarding would be directly relevant to this company's business.

Another company that has a safeguarding focus, and also rather obviously so, is LEGO. With a business designed to engage children, LEGO partners with UNICEF to implement and globally promote the Children’s Rights and Business Principles developed by UNICEF, the UN Global Compact and Save the Children, and to promote the importance of play for early childhood development. LEGO's 2016 Corporate Responsibility Report also discloses what LEGO is doing to safeguard children.

LEGO's Digital Child Safety Policy was developed as an industry leading practice to ensure the welfare of children interacting with digital channels. The policy is implemented through mandatory training for employees who work directly or indirectly with children online and also applies to partners who deliver LEGO® branded experiences.

Online safety is relevant not only for companies in the education and toy development sectors. It comes up regularly as a key material topic for companies that provide internet or media content. For example, Liberty Global (whose reporting I have supported for the past several years) has invested millions in protection of children while online and watching TV (one of the company's most material impacts) through collaboration on the development of an entire set of resources for children at different stages of development and exposure, parents, teachers and schools. In 2015, Liberty Global joined the ICT Coalition for Children Online, which aims to help young people in Europe make the most of their digital life and be better equipped to handle the challenges and risks it may bring. 

There are more positive examples of safeguarding out there, enough to convince you that safeguarding is an essential element of corporate responsibility. (For those who want a fascinating and sobering read on this subject, see also Joel Bakan's Childhood Under Siege: How Big Business Targets Children). Many companies, especially food companies, have responsible marketing policies where the aim is not to market directly to children under age 12 - though in practice, exposure of children to marketing in all its forms today is impossible to monitor, I believe. Most companies today explicitly prohibit child labor in their supply chains. That's an obvious one in modern times, I guess, even though there is still much work to do to achieve safe supply chains. But there are endless, not so obvious other ways that children are exposed to and are potentially at risk from the practices of corporations. This may be unintentional but it should not be unknown. Corporations have a duty of care to understand the impacts of their activities on children. I believe, however, that this topic in the broader sense of safeguarding vulnerable children and adults has flown largely under the radar and is not explicitly included in sustainability frameworks and standards such as GRI or SASB, beyond responsible marketing and avoidance of child labor. I think this could be a new area for a potential performance and reporting standard.

I want you to hear from the expert herself, Sarah Carlick, Founder and Managing Director of The Athena Programme.

Why did you choose safeguarding as your area of specialist expertise?
"Safeguarding was my background as a social worker and probation officer which I was drawn to because of my passion for helping and protecting vulnerable people. Through my work and experience of safeguarding at both a national and international level, I am now able to incorporate all areas of this important and complex topic under one umbrella which I think is the most effective way of achieving results to benefit those that are vulnerable or at risk of harm."

In a business context, what are the connections to safeguarding? What are the key safeguarding risks for companies? 
"Governance, compliance, reputation, recruitment, social media communications, customer relations and interactions are all areas where safeguarding is a relevant potential risk that must be proactively managed. For companies or organizations that have services that are used or may be used by children, families or vulnerable adults, there may well be legal compliance issues (in different countries) as well a range of potential risk areas that are not currently legislated. While businesses often look outside for the impacts of safeguarding (for example, with services used by children), there is also an internal aspect. How do companies support their own employees who may be victims of domestic abuse, for example? I think there are many connections between the practices of business and corporate responsibility to protect vulnerable children and adults, and some may not be so obvious."

Does every company need a safeguarding policy? Can you give some examples of where such a policy might be needed?
"Not every company needs a policy, but some are required to have a policy and set of procedures, for example, those that are regulated or inspected, those that apply for external funding, or those that have residential services, schools, a charitable arm, or where they employ apprentices, teachers, mentors, nurses, dentists or manage learning environments, to mention just a few cases."

In what context is it important to train company employees in safeguarding?
"It is important as safeguarding is two-fold - both protecting and supporting your staff and as well as protecting and supporting those that use your services. There are many areas that come under safeguarding, for example, modern slavery, child sexual exploitation, on-line grooming and emerging risks such as prevention from radicalization."

What can you and The Athena Programme do to help companies practice effective safeguarding? 
"Whatever your needs, Athena can help any company with everything to do with safeguarding children and/or adults at risk. If it’s about safeguarding – we’re the experts. A first step we can help with for many companies will be to map the nature, scale and impact of their activities and identify the safeguarding hotspots - immediate and/or significant risks that need to be managed. From there, we can help companies develop tailored policies and procedures, formulate communications packages, deliver training for all staff and put in place monitoring and reporting tools. For companies who are not sure, we can or simply come and speak to your management, or deliver a lecture on what to watch for. We are always happy to listen to the challenges companies face, or help them decide what the challenges are and minimize potential risks. We have strong credentials from our work over the past 10 years, so we are confident that we can help companies do better in this area."

If you are interested in exploring more, contact Sarah here. Either way, I think we are going to hear a lot more about safeguarding, and not just safeguarding anything, but safeguarding those who matter most, our children and our youth and our friends and families and communities who may not be able to protect themselves. If that's not CSR, what is?




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