Wednesday, July 3, 2024

GRI revises employment standards. Shoot me now.

Yes, we’re back at the CSR Reporting Blog. Apologies for too long an absence due to so much time working on reporting rather than writing about reporting. But this new GRI brainchild was too good to pass up.

GRI has published exposure drafts for the first phase of its employment and labor standards revision, introducing new and completely unique disclosures. Just when you thought ESRS was enough to mindblow even the most energetic of reporters, GRI has generated 13 original multipart disclosures and revised (expanded) 8 disclosures, all from 5 existing ones. It’s the GRI multi-stakeholder Mary Poppins at work again pulling more metrics out of the bottomless carpet bag.

We are truly in the age of mega mushrooming of metrics, where every new standard adds to the reporting burden in a way that I fail to believe is what's needed to advance sustainable development and protect people, society and the environment. There’s a point at which disclosure becomes dysfunctional rather than constructive. It makes you wonder when we will have a metric for how many times people use the bathroom – broken down by gender, region, employee category (including workers who are not employees) and time spent per visit. Let’s just hope that this disclosure requirement doesn’t include details of bathroom activities.

Despite reverberating declarations of cooperation, collaboration and undying love between the prominent standard setters (notably GRI, IFRS and EFRAG), here we go again: GRI proposes more unique disclosure requirements that do not appear in any other standards (as far as I can ascertain). But don’t worry, I am sure, once the new standards are finalized, GRI will publish an interoperability guide. That will make everything so easy. Not.

(The GRI-ESRS Interoperability Index will need quite some updating.)

What does this first phase revision cover?
This first phase covers topics relating to 
  • Employment practices and conditions 
  • Working life and career development 
  • Worker’s rights and protection 
that are part of GRI’s existing standards: 
  • GRI 202: Market Presence 2016 (Disclosure 202-1) 
  • GRI 401: Employment 2016 (Disclosures 401-1 and 401-02) 
  • GRI 402: Labor/management Relations 2016 (Disclosure 402-1) 
  • GRI 405: Diversity and Equal Opportunity 2016 (Disclosure 405-2) 
There is also a new draft, Standard Interpretation to GRI 2: Control of work, which aims to clarify the ‘control of work’ concept which is used to identify reporting requirements in some of the standards. 
All drafts and surveys are available here for public comment by October 4th. Sorry if that ruins your summer. 

General takeaways 
More policy please: In line with more recent GRI revisions, these new standards integrate topic-specific management disclosures in addition to the management disclosures required by GRI 3: Material Topics 2021. This means you can’t get away with a high level policy overview – each topic includes disclosures that are mandatory within that standard and, in some cases, require quite explicit responses. 
Gender expansion: Gender has expanded in the reporting world these days. Most of the proposed disclosure requirements ask for data breakdown by gender. In addition to female and male genders, there are now two more categories: Other (Gender as specified by the employees themselves) and Not Disclosed (Gender is not disclosed by the employees themselves.) 
Enter the age of the non-employee worker: GRI’s new disclosures relating to employee practices now expand to include information and metrics relating to both employees AND “workers who are not employees’. EFRAG (ESRS) calls these “non-employees” which rolls off the tongue a little more easily. Apparently, the interoperability spirit did not sync far enough to align on terminology. (I will continue here using the EFRAG term to reduce keystroke fatigue and lower my typing-time carbon footprint.) 
GRI’s new guidance on who is a non-employee aims to unblur the rather confusing guidance already published. “Workers who perform work for the organization and whose work is controlled by the organization but are not in an employment relationship with the organization. Control of work implies that the organization directs the work performed or controls the means or methods for performing the work. ….. [for example]….agency workers, apprentices, contractors, home workers, interns, self-employed persons, sub-contractors, and volunteers”. 
It’s still a bit blurry, I think (EFRAG actually does it better, see ESRS S1 AR61-65).           

The draft standard goes further than any previous standards regarding the reporting of many aspects of policies and practices relating to non-employees. For example, required reporting for BOTH employees AND non-employees incudes aspects of external and internal recruitment, performance management, performance reviews, data protection, termination, hours of work and rest, remuneration rates, social protection contributions and management of the effects of operational changes including redeployment or upskilling. These disclosures can be understood when accounting for impacts on own workforce, but the need to report so extensively on non-employees seems excessively burdensome to me. By comparison, ESRS S1 Disclosure Requirement S1-7 requires: The undertaking shall describe key characteristics of non-employees in its own workforce. This includes “disclosure of the total number of non-employees in the undertaking’s own workforce, i.e., either people with contracts with the undertaking to supply labour (“self-employed people”) or people provided by undertakings primarily engaged in “employment activities” (NACE Code N78).” All other details about non-employees in ESRS are optional disclosures (except in the case of health and safety, Disclosure Requirement S1-14, which makes sense). 

I believe that organizations should indeed be held accountable for work arrangements for non-employees (such as safety, privacy, working hours and conditions etc.) and in all cases should take measures to ensure non-employee rights are upheld though proactive monitoring/auditing of contracts with employment agencies or contractors or self-employed parties. I think there’s a case for separating these disclosures: one standard should apply to direct employees, and most companies would identify own workforce or subtopics thereof as material; a separate standard should cover the way organizations manage practices related to non-employees, which could be selected by companies that identify non-employee issues as material, perhaps those companies employing a very high rate of such workers. Jumbling up everything all together to me places an unnecessary burden on reporting companies and dilutes focus. 
NB: Let’s not confuse non-employee management with misclassification of workers as per the Uber ruling, where drivers were deemed to be workers and not self-employed. This form of “disguised employment” is addressed separately in the draft disclosures from a policy standpoint. 

In Accordance – too much? There was a time when declaring compliance to the full GRI Standards by being In Accordance was seen as a mark of leading practice among reporters. Many companies claim to report In Accordance to signal leading transparency (although there is quite some corner-cutting in most cases). Now, I am wondering if the burden of such extensive reporting will lead companies to pick’n’mix, preferring to “reference” GRI Disclosures rather than aim for In Accordance. I have always advocated for relevant transparency, not all-out transparency. I think these new draft standards proposals step over the line of reasonable and constructive disclosure. Read the drafts. Decide for yourself.

Key takeaways: Employment Draft Standard GRI 404-1 
Got a grievance? GRI’s got you covered: The strong influence of human rights thinking is clear in this revision, with almost all disclosures referencing grievance mechanisms, appeals processes, adherence to fundamental principles and rights at work or worker representative engagement on different issues. If your reporting has conveniently glossed over human rights issues, this revision means no more. 
Do you pay your interns? You probably should, because now you will be asked to give a full account of remuneration for interns and explain why they are not paid, if they are not. No need to disclose what they have for lunch. 
Surprise surprise, privacy matters: You will need to disclose policies regarding employee and non-employee personal data collected, processed and monitored as well as how you obtain informed consent. It will be interesting to see how many employers collect information about employee shoe sizes or ice cream flavor preferences. Regarding the latter, I’ll happily give my informed consent. Additionally, a quantitative disclosure requires reporting of the number and types of incidents related to personal data protection and privacy of employees and non-employees. Incident means legal action or complaint or internal discovery of noncompliance. Companies are just going to LOVE this one. All that dirty washing hanging out there. Can’t see that happening any time soon. 
Saying goodbye? Now say how: A new full disclosure devoted solely to termination practices, including a description of the valid reasons for termination. I doubt any company will publish a policy relating to involuntary termination for reasons other than poor performance, misconduct or layoffs or variations on those themes. GRI explains that “This new management disclosure aims to increase accountability on the termination of employment or work. The termination policy is related to job security.” I am not sure how explaining your policy on firing people is related to job security. I would have thought the opposite is true. 
More and more and more data: Currently, the data requirement for the GRI 401-1 new employee hires and turnover indicator includes “total number and rate of new hires during the reporting period, by age group, gender and region,” and the same for turnover. The proposed draft expands this to include reasons for voluntary turnover and termination AND internal recruitment rate for employees and non-employees AND length of tenure by region for four different employee categories AND the number and turnover rate for non-employees by region. Ugh. Might as well just include a link to your HRIS database and be done with it. Another example: Currently, GRI 404-3 requires reporting of the percentage of employees by gender and employee category that received a performance review. In the new draft standard, it is also required to report how many non-employees received a performance review, and for those employees and non-employees who did not receive a review, why not! Hmm. Good luck with that one too. 

Key takeaways: Labor and Management Relations Standard 
This set of three multipart disclosures expands the single disclosure in GRI 402 that requires reporting the minimum number of weeks’ notice provided to employees regarding significant operational changes that affect them. The exposure draft goes way further to encompass details of how such changes are managed for both employees and non-employees. 
Don’t forget to consult: A key feature of disclosures here are how a company consults with workers’ representatives. Everything from termination and appeals procedures, notice periods and severance payments, the number of weeks spent in consultation with workers’ representative ahead of implementing changes and more are part of the draft disclosure requirements. 
Don’t forget to mitigate: For employees and non-employees, reporting requirements include actions taken to mitigate the effects of significant changes including redeployment, training and reskilling or layoffs. 

Key takeaways: Remuneration and Working Time 
This set of disclosures has gone into overdrive with more information and data requirements than ever before with three management (policy) disclosures and four multipart remuneration disclosures. Prepare to get granular on rem. This section includes elements from existing GRI 202-1, 405-2 and 401-2 and more. 
From minimum wage to cost-of-living: In GRI 202-1, reporters were asked to describe employee remuneration policies relative to the local minimum wage rules, if available. In the draft disclosures on remuneration, companies are asked to define remuneration policy including how this accounts for cost-of-living estimates and provide, for significant locations of operation: median gross hourly basic pay by employee category AND the number of employees who are paid at the local minimum wage AND number of non-employees who are paid at the local minimum wage AND the cost-of-living estimate AND the number and percentage of employees whose basic pay is at or above cost-of-living estimate, including a breakdown of employee category and gender AND steps taken to address gaps between cost-of-living estimates and basic pay for employees and non-employees. GRI conveniently provides a suggested template (one of several template proposals in this revision) for presentation of the cost-of-living metrics. For companies with more than three “Significant locations of operation” and more than three “Employee categories”, this is going to stretch the spreadsheet limits. 

By comparison, the ESRS requirement on remuneration references “adequate wages” where adequate wage is defined as the legal minimum wage or, if not available, in line with other relevant benchmarks. The organization is required to report (ESRS S1 Disclosure Requirement S1-10) “whether or not its employees are paid an adequate wage, and if they are not all paid an adequate wage, the countries and percentage of employees concerned.” C’est tout. 
There is also the question of what data or benchmarks to use to define cost-of-living estimates in each country of operation. GRI recognizes that there is no universal formula for calculating cost-of-living, and this can vary extensively depending on what you include. GRI guidance explains: “Cost-of-living estimates are approximate calculations determining the necessary amount to cover an individual and their family's basic expenses like food, housing, and healthcare in a specific location. Different methodologies can be used to derive the cost-of-living estimates as there is no international agreement.”
I also wonder if the often-referenced living wage concept is different from the cost-of-living concept. Either way, any reporter counting this as material will need to set up a whole new database to meet the needs of this disclosure, and every reporting company is likely to interpret cost-of-living differently. I have to wonder how valuable this is going to be in the grand scheme of how we ensure that remuneration is fair and decent for everyone. 
Working time – all is revealed: New disclosures 2 and 7 are dedicated to working time and requires detail of policies defining working and rest hours by day, week and year and metrics demonstrating how these were applied, including a breakdown of employees by type as well as non-employees with details of the number of hours worked by each type across four working-hour bands, in addition to other disclosures relating to additional aspects of working hours. Specifying overtime hours worked is not a requirement but in case anyone wants to volunteer, GRI generously shares an example template for presenting information on the number of overtime hours worked by employees by gender at significant locations of operation, with a breakdown by three bands of overtime hours. Additionally, the proposed draft asks organizations to describe how the working time policy considers the specific needs of vulnerable groups, including young workers and pregnant and nursing workers. 
Gender pay gap - still on the table: This disclosure is similar to the current GRI 405-2 and asks for percentage difference in average gross basic hourly pay of men and women for each employee category. No momentous change here, except that very few companies actually report a gender pay gap except for in those countries where it is a legal requirement to report, such as in the UK and certain other countries.
Social protection coverage: This is another extensively expanded disclosure requirement building on existing GRI 401-2 Benefits provided to full-time employees that are not provided to temporary or part-time employees. Rather than requiring companies to specific which benefits they provide (as current), organizations will now need to specify whether they provide any of a set of 8 benefits categories, alongside other disclosures relating to who gets what and where and if it’s required by law or otherwise. Specifically, there is a requirement to report how a company monitors that social protection contributions are made to relevant authorities according to local regulations for non-employees.


In conclusion, with this first phase of changes, GRI has created a wish list of disclosures in a topic that is material to most reporters in some way. Disclosure should never be just for the heck of it. It should provide useful and meaningful information that helps us understand the impacts of a company on society and the risks it faces. If the second phase of the labor standards revisions take the same mushroomy approach, it’s hard to predict an enthusiastic adoption rate by most reporting companies. 
These disclosures differ drastically from what was hailed as "disclosure standards on steroids" with the introduction of ESRS. ESRS went further than any other sustainability disclosure standard. Despite all the wonderful collaboration going on, these proposals are not aligned with ESRS in a way that enables reporters to comply with both ESRS and GRI interchangeably for a single disclosure on these labor topics: reporting fully against ESRS would not meet the disclosure requirements of these GRI draft standards. I have to wonder who has lost the plot here. Oops. Maybe it’s me! Obviously, I need more ice cream.🍦🍦🍦🍦

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

Wednesday, January 4, 2023

15 First Time Reports from 2022

You may have heard me mention that I love first time reports. A first report is always an achievement, overcoming many new hurdles, organizationally and practically, to source and disclose sustainability information. First reports need a level of dedication, persistence, creativity and vision that enables everything to come together in the best way it can. Some first reports are very slick; they adopt the latest advanced reporting practice, the most widely used standards and bring a fresh design approach. Others are more basic and an obvious (painful) first effort at transparency. Either way, I have an extra helping of respect for first time reporters. So, as 2022 draws to a close, and we expect regulation and market forces to drive more companies to report in 2023 and beyond, this post is about how first timers are faring, and if they have learned from 30+ years of reporting practice.  

The post includes a list of 15 reports in alpha order, selected at random from reports I have come across from different sources. Ice cream cones denote my overall impression of clarity, credibility, transparency and appeal. More cones = more impressed. Maximum cones = 6.  No report got 6 cones πŸ˜‰

Before we start, a few overarching comments:

πŸ”ŽFew reports include a number for annual revenues or turnover in these standalone sustainability reports. I always look for this to get a sense of company size and impact (in addition to the number of employees). I recommend inclusion of this stat.

πŸ”ŽMany reports include tedious narrative about policy and approach and general descriptions of processes. In my last post, I referenced a Policy Bank - commuting this evergreen narrative to the web so that the annual sustainability report can focus on what was actually done in the reporting year. I recommend first time reporters consider this as part of their first reporting cycle.  

πŸ”Ž Many first-time reporters are new to disclosure but not new to sustainable practice. Sometimes this is reflected well in the first report, sometimes the first report is more basic, containing evergreen policy content rather than descriptions of actual progress. Some first reports barely cross the threshold of what I would actually call a report. BUT. It's important to appreciate the amount of effort that any first disclosure requires - even though the report itself may be lightweight in terms of progress and data. It's important to encourage first time reporters by providing practical feedback they can use in their second reports. 

πŸ”Ž The list of first reports published in 2022 that I wanted to share is way longer than these 15 that bubbled up to the surface from different sources. The selected reports are not necessarily representative of the full first timer landscape, but the variety presented below may provide insights for different companies at the early stages of their reporting experience. As a general rule, publishing a press release to announce the report publication helps it get on the radar. 

By the Numbers

  • 6 countries, with 7 reports from the USA (most press releases!)
  • 10 publicly traded companies, 5 privately owned
  • 6 reports reference GRI including 2 In Accordance (Core Option) and 1 referencing GRI 2021
  • 6 reports use SASB
  • 3 reports use the TCFD Framework at some level
  • 5 reports have some level of assurance
  • 12 pages is the shortest report (two reports actually) while 123 pages is the longest. 8 reports   are between 55-80 pages
  • 6 reports have ESG in the title
  • 8 reports have sustainability in the title 

Here is the summary of reports covered and their CSR Reporting Blog Cone Score: 

  1. Cedar Fair Entertainment Company 🍦 
  2. Cimpress plc 🍦🍦🍦🍦
  3. Corus Entertainment Inc.  πŸ¦πŸ¦
  4. EG Group πŸ¦πŸ¦πŸ¦
  5. Galaxy Digital Holdings πŸ¦πŸ¦πŸ¦πŸ¦πŸ¦
  6. MAG Silver πŸ¦πŸ¦πŸ¦
  7. Patrick Industries, Inc. πŸ¦πŸ¦
  8. Phibro Animal Health Corporation πŸ¦πŸ¦πŸ¦
  9. Primark Limited🍦🍦🍦🍦🍦
  10. Pyxus International, Inc. Fiscal Year πŸ¦πŸ¦πŸ¦ πŸ¦
  11. Ranger Oil Corporation πŸ¦πŸ¦
  12. Selina πŸ¦πŸ¦πŸ¦πŸ¦
  13. Vog Products πŸ¦πŸ¦πŸ¦πŸ¦
  14. Welch’s πŸ¦
  15. Zentiva  πŸ¦πŸ¦πŸ¦


Cedar Fair Entertainment Company 2022 ESG Strategy Report
Country: USA  
Entity: Publicly traded (NYSE: FUN) 
Sector: Amusement-resort operator
Report: 12 pages    

Cone-worthy 🍦  
# This is not an actual ESG report but the promise of a report. It's 12 pages of narrative about what the company plans to do, starting in 2023, and report on annually. But, it's something. And something is always better than nothing. Clearly considerable effort has gone into developing something.
# Presents a five pillar ESG strategy. Each pillar is apparently supported by aspirational goals, strategies to achieve those goals, and the tactics needed to implement the strategies, but none of this is shared at this time. The "report" describes the actions Cedar Fair is planning to take in each of these pillars.
Cone opportunities:
#Time will tell whether Cedar Fair delivers on its ambitious promises. I have made a note in my Google calendar to check back in 2023 for the publication of Cedar Fair's first actual ESG report to see how they are doing. Since Cedar Fair states its purpose as "Make people happy", it will make me very happy to see a report that contains at least a few core data points.

Country: Ireland 
Entity: Publicly traded (Nasdaq: CMPR) 
Sector: Customized print, signage, apparel, gifts, identity merchandise 
$ annual revenues: $2.9 billion 
Employees: 16,000
Report: 123 pages, no frameworks 

Cone-worthy 🍦🍦🍦🍦 
# Super slick professional report that presents a positive picture of a company that has been implementing sustainability practice for some time. 
# "Informed" by GRI and SASB, it does not apply these standards but discloses four years of data for most core metrics that these frameworks would demand, including full Scope 1, 2 and 3 GHG emissions. 
# Some targets for environmental impacts (including Net Zero by 2040).
# Fabulous design (only missing navigation tools) that presents data clearly and showcases local designers.
Cone opportunities:
# Material topics are listed as those "important to us and our stakeholders", whatever that means. Sounds like plug-and-play. I'd like to see a detailed materiality assessment process in future. 
# Highlight targets upfront - currently they are in-chapter. I like to see where a company is heading before I know where it's been. 

Country: Canada
Entity: Publicly traded (TSX: CJR.B) 
Sector: Media and content
Report: 55 pages, SASB, TCFD

Cone-worthy 🍦🍦🍦
#  Well-structured and clearly designed report that has a fun feel. Good navigation. Interesting section on journalistic standards - a relevant topic for a media company.
#  Honest responses to TCFD disclosure - for example, why the company has not set carbon targets.
#  Stakeholder voices - internal and external - throughout the report in quotes with images.
Cone opportunities:
#  Reference to having completed an "ESG Maturity Assessment" and a suite of goals seems great, but these are not disclosed in the report. I wonder why not? This report would be more credible if we knew what Corus is committing to. 
#  Would be good to see a broader set of data points in addition to DEI and carbon. 

Country: UK
Entity: Privately owned
Sector: Convenience retail
Employees: 58,493 
Report: 63 pages, SASB, TCFD, SDG (goal level), Assurance

Cone-worthy 🍦🍦🍦
#  Double materiality assessment with a definition of what this means for EG Group
# Full suite of ESG targets in three strategic pillars, plus a set of ESG Fundamentals that are not strategic but important in terms of maintaining responsible practice (without specific targets). 
# Nice focus on people with images short bios of Board members and employee testimonials.
# Good climate disclosure with detailed narrative and data across all three Scopes.
Cone opportunities:
# Data presented for one year (2021) though this is clearly not the first year of data-collection for EG Group. I recommend three years in future reports. 
# I am a little puzzled at the connection between ESG targets and materiality assessment. For example, community investment is positioned at the lowest level on the materiality matrix but EG has two public community targets. Items that are highest priority in terms of materiality (product packaging and plastics, diet and health and land and biodiversity impacts) do not have dedicated targets. Although materiality "informed" target setting, the correlation is not entirely obvious. Perhaps greater alignment here might be considered in future.

Country: USA
Entity: Publicly traded  (TSX: GLXY)
Sector: Financial services in digital asset, cryptocurrency, and blockchain technology sectors
Employees: 281 
Report: 73 pages, GRI 2021 (referenced), SASB, TCFD, SDGs (target level), GHG Assurance

Cone-worthy 🍦🍦🍦🍦
# This is a report with a unique kind of chic and makes a strong statement. With a mission "to engineer a new economic paradigm" through blockchain technologies and the crypto economy that most people (including me) still quite don't understand, it's a report that stands out from the crowd both in content and design.
# Overview of contribution to SDGs on a target-by-target basis with relevant supporting actions.
# Background and context articles to help us understand the crypto world and how ESG is relevant.
# Galaxy uses this report to showcase the work of photographer/artist Claudia Pawlak, with a special message about art and ESG.
Cone opportunities:
# Materiality is defined as "relevance" to internal stakeholders on the one hand, and to external stakeholders on the other. What does "relevance" actually mean? Impact on? Financial benefit? This needs to be clarified. 
# Great detail about Sustainability Program oversight but no goals or targets. Makes me wonder what the 10 ESG Steering Committee Members are actually overseeing.   

Country: Canada
Entity: Publicly traded (MAG: TSX / NYSE A)
Sector: Silver mining
Employees: 2,929  
Report: 72 pages, UNGC 10 Principles, SDG overview (goal level)

Cone-worthy 🍦🍦🍦
# A congenial first report, written in plain language that people can understand, no frills or fancy jargon.
# First internally developed materiality assessment covering "significance and relevance to MAG Silver’s business and potential ESG impacts" - the process is well described.
# Good suite of corporate ESG policies to supplement reporting.
Cone opportunities:
# It would be nice to see the adoption of a reporting framework such as GRI in future. 
# Design is double spaced - difficult to read
# A final proof always helpsπŸ˜‰ (See image below on Security) 

Country: USA
Entity: Publicly traded (NASDAQ: PATK) 
Sector: Component solutions provider for the leisure lifestyle and housing markets
Annual revenues: $5.1 billion
Employees: 11,000
Report: 41 pages, SASB

Cone-worthy 🍦🍦 
# A focus on people, more than half of this report is about company culture and people development and community contribution. A good start in demonstrating responsible people practices.
# The section on "where we're going" describes the broad next steps for this company, clearly at the initial stages of its structured sustainability plans
Cone opportunities:
# Tip of the iceberg transparency .. this report contains a limited amount of data, partially explained by the fact that the company has just started to put in place robust data collection processes. A world of opportunity awaits for achieving greater transparency in Patrick's second report.

Country: USA
Entity: Publicly traded (Nasdaq: PAHC)
Sector: Animal nutrition
$ annual revenues: 942 million
Employees: 1,800
Report: 56 pages, GRI referenced, SASB

Cone-worthy 🍦🍦 πŸ¦
# Phibro addresses a good range of ESG-related topics in this report, albeit most of the content is general narrative rather than specific reporting year content. The declaration that "Phibro is in the early stages of our ESG journey" is honest and credible and inspires confidence that Phibro will continue to evolve its approach and practice to include a defined strategy and targets in key areas.  
Cone opportunities:
# First materiality assessment reflects issues "perceived to be most important to our customers, employees and stakeholders and are most relevant to our business" That's a good start. But it still leaves me wondering what "most important" and "relevant" mean. Is it about opinion, impact or profitability? Perhaps this could be defined more precisely.
#Material topics are not disclosed. Alongside the description of the materiality assessment process, there is a list of "beliefs". It's not clear if these are material topics or a value system. 
# More pictures of animals would be nice. I love animals. 

Country: UK
Entity: Owned by Associated British Foods plc (ABF)
Sector: Fashion apparel
$ annual revenues: Approx. $9 billion
Employees: 72,000
Report: 57 pages, Assurance. Primark also contributes to ABF's annual sustainability reporting. 

Cone-worthy 🍦🍦🍦🍦🍦
# Primark is no stranger to reporting through its parent company Associated British Foods (ABF), but this is the first separate Primark report. It rests on the reporting foundation of ABF ABF's 2022 Responsibility Report here for reference), and is included in several sections of ABF's report, mostly narrative but some data. Certain statements in the Primark report are externally assured. As such a large business in its own right, it's a good move by Primark to add this solo venture into the world of transparency.  
# Great set of Primark Cares commitments, some of which are quite bold, for example, the product commitments: improving durability of clothes, all clothes to be recyclable by 2027, all clothes to be made of recycled or sustainable sources by 2030. I think these are quite transformative for a company that is part of an industry criticized for fast-fashion, throwaway quality and resource inefficiency.  
# Clear report structure in an easily navigable report that covers People, Planet and Product impacts in a coherent way, with case study examples. The narrative is easy to read, provides contextual background and avoids language that is overly gushy or superlative. It's actually a fascinating report with interesting content, reflective of a wide range of actions and impacts. 
Cone opportunities:
Beyond big credit for producing a standalone Primark report, recognizing that sustainability data is included in ABF reports, I believe there is a missed opportunity to include a selection of core data points that are specifically Primark. Carbon emissions are included but there is little other data. Human resources for example, with 72,000 colleagues, and a target to strengthen the position of women at Primark -  no data is presented on diversity and inclusion, women or other groups. 

Country: USA
Entity: Publicly traded (OTC Pink: PYYX)
Sector: Agricultural produce
$ annual revenues:
Employees: 2,943
Report: 78 pages, GRI Core, GHG Assurance

Cone-worthy 🍦🍦🍦🍦
# Symmetrically structured report with each core chapter presenting Our Ambition, Moving the Needle, How We Measure and Our Results, supplemented with case studies where relevant. I like symmetry in reporting, it gives me the impression that reporting is intentional not random. 
#A materiality matrix representing impact materiality, one of the few that do this in line with GRI requirements.
# A full suite of SMART ESG targets to 2030 including Net Zero value chain emissions by 2050. An impressive set of commitments in a first report. 
# Use of case studies to demonstrate environmental and social action in practice.
# Appealing, attractive but simple design, with appropriate use of images and supporting design elements and a useful bottom navigation bar. 

Cone opportunities:
# Pyxus disclosure could provide a more transparent picture of its activities in future reports. For example, the (material) section on Supply Chain Integrity describes important ethical supplier management practices, but discloses no information or data about what was actually done in the reporting year. The section on Motivated, Skilled and Engaged Employees contains no data at all about employees apart from two data points on women in leadership. Seems that Pyxus disclosure muscles need flexing a little.
# Pyxus presents a materiality matrix with 12 topics, 7 of which are top-right quadrant. Yet, despite declaring GRI In Accordance: Core Option, the GRI Content Index includes only three standards: 206 (Anti Competitive Behavior), 305 (Emissions) and 413 (Communities). Health and Safety is the most significant material topic on the matrix but GRI 403 (Occupational Health & Safety) does not appear in the Content Index. The report includes a section with a couple of data points on health and safety but this should be reflected in the Index.

Country: USA
Entity: Publicly traded (NASDAQ:ROCC)
Sector: Oil & Gas
Employees: 136
Report: 35 pages, SASB

Cone-worthy 🍦🍦   
This is an ESG report in the true sense of the word, created for investors, following SASB Standards. It provides a glimpse into the world of sustainability-related financial materiality disclosure that covers only those topics defined by an investor-focused ESG framework and providing single-year data as required by the selected SASB standard. Consistent with this approach, The Chair and CEO write a joint letter to "Shareholders and other Stakeholders". While I personally look to see an impact (or double) materiality disclosure, I acknowledge Ranger Oil for adopting this approach and running with it. 

Cone opportunities:
# I'd like to think that, at some point in the future, Ranger Oil's leadership would write a joint letter to "All Our Stakeholders", and include a materiality assessment of impacts on people and the environment, in addition to impacts on the business.  
# Most of this report is policy statements and descriptions of processes. There is little that reflects progress in this first reporting year. Hopefully the second report will offer more insights into how Ranger is delivering its policies and taking meaningful action.

Country: UK
Entity: Publicly traded (NASDAQ: SLNA)
Sector: Hospitality
Employees: 1,840
Report: 69 pages, references GRI (no Content Index)

Cone-worthy 🍦🍦🍦🍦
# This report is appealing for its familiar, straightforward back-to-basics style. It's about culture, connecting, caring and communities. As a young company, it's just ramping up its structured ESG approach, and the report explains its approach without the jargon-rich language of large company reporters. It has a simple authenticity that may resonate with its target millennial audience.  
# Selina gives an honest explanation of its environmental approach, with aspirations to align with Paris on emissions, measure emissions at all locations (currently 11%), eliminate single-use plastics by 2025, rolling out low-flow shower heads globally. Sounds like these initiatives are just ramping up but the direction is set.
# Describes ESG priority impact areas aligned to SDG goals.  
Cone opportunities:
# This report was published just before Selina became a publicly listed company traded on NASDAQ. It will be interesting to see Selina mature its ESG programs and disclosures to meet both regulatory and investor demands in its next report while retaining its focus on culture.
# A more detailed build-out of the ESG Strategy, defining the strategic goal in each strategy area and establishing targets and core metrics for each could help Selina advance its ESG performance and impact. 

Country: Italy
Entity: Privately-owned
Sector: Food products
Employees: 209
Report: 40 pages, GRI Core, covers two years, SDGs (goal level)

Cone-worthy 🍦🍦🍦🍦
# This report applies a GRI structure by dedicating a chapter to each material topic (fortunately there are only five 😁). Each chapter follows the same flow which includes a description of impacts, core activities, measures, objectives and stakeholder cooperation. This is an earnest approach to meeting the requirements of GRI while ensuring a full and balanced disclosure. The fact that objectives are included for each material topic is evidence of a considered and focused approach to disclosure.  
# The materiality assessment clearly explained: "How do our actions as a company have an effect, both positive and negative? This was the question at the heart of the impact analysis which the company carried out in autumn 2021. It focused on social, environmental, and economic aspects."
# Three-year data summary tables included at the end of the report.
# Most of the content of this report is focused on actions rather than evergreen policy. 
Cone opportunities:
# Change the title. "Sustainability is part of our DNA" is one of the most overused and meaningless phrases in the history of sustainability reporting. But maybe a first time reporter might not know that. 

Welch’s 2021 CSR Report
Country: USA 
Entity: Privately-owned by cooperative
Sector: Fruit-based food and beverage
Report: 12 pages

Cone-worthy 🍦 
# Welch's is a private organization owned by a cooperative of about 700 family farms across the U.S. This first report deserves credit for being a first report. 
# The report provides a high level overview of a strategic approach to corporate responsibility.
# Selected data points demonstrating progress are presented.
Cone opportunities:
# While any report is better than no report, Welch's has a great opportunity to enhance the transparency of its reporting to include meaningful data and more detailed practices and progress. As it stands, the report presents a summary of progress in each strategy area, but the selection of datapoints seems rather random, or possibly, the only positive data the organization has available or can present. For example, one data point is that 98% of growers are tracking and reporting their sustainable farming practices. If there is such a wealth of data available from almost 700 growers, Welch's has an opportunity to share a glimpse of the broader impact of the cooperative's activities and its wider impact on farming and environmental practices. The fact that growers report is less useful to know than what they report.  

Country: Czech Republic
Entity: Privately-owned
Sector: Pharmaceuticals
Employees: 4,700
Report: 35 pages, GRI referenced (no Content Index) GHG Assurance

Cone-worthy 🍦🍦🍦 
This is a credible report of a growing company clearly, in the early stages of its structured sustainability journey. As a privately owned company, it does a meaningful job of presenting its position across a range of sustainability topics with thought and consideration. Data is presented selectively, with the most transparency in environmental metrics over two years.
A strategic framework – People Partners Planet – creates a language and structure for this company’s sustainability plans, and a set of 30 material topics and 10 goals underpin its commitments, including carbon neutrality by 2030 and gender balance in leadership roles by 2026.
# This report is aesthetically designed. The layout is clean, tables and charts are clear and creative design elements make this report a pleasure to view.
Cone opportunities:
# As this company advances its plans and becomes more mature in its reporting, there is an opportunity for greater transparency in key areas such as human resources, safety and supply chain.  
# Beyond the direct ESG impacts of Zentiva’s business, it would be of value to understand its impact on healthcare; topics related to access and affordability, innovation, patient engagement etc. are core to Zentiva’s contribution to sustainable development. Greater discussion of these topics would help balance this disclosure and put its sustainability efforts in context.
# Stakeholders may be interested to understand more about the materiality analysis– stated as conducted using S&Ps ESG self-audit framework – for example, how the topics are defined for Zentiva and why they are material from an impact and/or financial materiality standpoint.



I am a fan of industry and trade association reports, as I believe they provide a helpful overview of sustainability issues that matter from an industry perspective and set standards that companies in the industry can learn from and align with. This first 40-page report from the World Coatings Council is well worth a look. 



That's all, folks. I expect there will be many many first time reports in 2023, so expect a much longer list this time next year. In the meantime, Happy 2023! and Happy Reporting!

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

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