Saturday, September 15, 2012

A Sweet Year of Apples and Honey

This Sunday evening (16th September), Jewish New Year celebrations will be held around the world and in the best of tradition, everyone will consume quite a lot of apples and honey, the symbolic expression of a wish for a Sweet Year ahead. As global consumption of apples and honey will probably triple during the two days of the New Year festivities, I thought I would take a look at the sustainability of these two special foods.

Carl Sagan said: "If you want to make an apple pie from scratch, you must first create the universe." which is a very sustainability-ish type of comment. Of course, don't confuse apples with Apple, whose sustainability commitment is not so clear, as Fabian Pattberg, our sustainability conscience, explains, following the flamboyant iPhone5 launch. But in this post I want to refer to real apples - the kind that grow on supermarket shelves that you eat after scrubbing them with disinfectant to remove all the pesticides.

Sustainable apples may be TRU EARTH certified, such as those at the family-owned Ecker's Apple Farm, and others are the product of scientific agri-innovation such as that practiced by Bayer Crop Science. Actually, the science of apple growing is called pomology. There are 7,500 varieties of apple grown through the world, which makes for a lot of pomologists. Apples are fat, sodium and cholesterol free, which makes them ideal for a healthy (but not so much fun) diet, in fact, they say that an apple a day keeps the doctor away, which is a good thing, unless the doctor happens to be your wife, husband or best friend. You can find loads of amazing facts about apples here. I even found on the web what looks like a very interesting Spiced Apple Ice Cream recipe, which seems to be the perfect way to start the Jewish New Year.

Apples, of course, being a popular food, are often stars of Sustainability Reports. Using the PDF search facility at, I can find almost 2,000 Sustainability Reports that refer to apples (although some of them are the Apple kind of apple, some are components of pineapples, and one or two show up because they are mentioned in the word grapple (you'd be surprised how many times the word "grapple" comes up in Sustainability Reports. Wonder why that is?). However, this leaves the vast majority of reports with real apples, and while I won't mention the bad ones (bad apples, get it?), I will highlight just a few ways in which apples flavor Sustainability Reporting.

The Yummy Fruit Company in New Zealand supports the AppleQuest program by donating free apples to remote schools such as those in the Chatham and Pitt Islands - noted in the Giumarra Companies 2012 CSR Report.

The 2011 Annual Report of Club Mediteranee mentions a sustainable development partnership in Morocco which supports the professional development of fruit growers and the Village at Marrakech and made seasonal purchases of different varieties of apples and quinces.
Worcester College at Oxford University incorporated wildlife habitat into its garden design. They have an allotment and apple orchard (the apples are used to make apple juice that is sold at Waterperry Garden Centre in Oxfordshire). This is in the University of Oxford Environmental Sustainability Report for 2010/2011. So if you are ever incredibly thirsty and passing through Waterperry Gardens....

We even have a little blip about apples. Arla Foods 2011 Social Responsibility Report mentions that Rynkeby Foods added new details to the labelling on a blackcurrant fruit drink so that it states that the drink also contains apples. This change was made after a Danish newspaper drew public attention to the labelling error. The Power of the Press strikes again.
And General Mills Global Responsibility 2012 report recalls a little disappointment relating to apples: "In 2006, we launched Nature Valley Fruit Crisps. But the dried and baked slices of apple, with just 50 calories per pouch, didn’t meet consumers’ demanding taste requirements and were discontinued." Too bad. But maybe consumer taste has changed since 2006.

Enough about apples. Let's turn to honey.

Honey is a sweet food made by bees using nectar from flowers. Aha, but did you know that honey bees transform nectar into honey by a process of regurgitation, and store it as a primary food source in wax honeycombs inside the beehive. But don't let that put you off. The value of honey was recognized in ancient times when honey was known as a wonder-drug for curing almost everything and even embalming corpses. But don't let that put you off. Honey tastes great and there are several hundred unique honey varieties from all over the world. The good thing about honey is that,  in the honeybee world, females do all the work. That way, you know it's gotta be good.
Honey-bee raising can be a great activity to encourage Green Employees and help them become aware of their natural surroundings. This is the case with Novus International (disclosure: my client), who started a Honey Bee Project which remains very popular, as reported in their last Sustainability Report.  Another Sustainability Report (2011), this time from Greif Inc., talks about Greif’s Pollinator Habitat Improvement project. "Timberland offers the potential to provide clean forage for the bees that are vital to agricultural productivity and economic viability, while bees offer improved landscape health on timber holdings. Greif is working with Pollinator Partnership to learn how pollinators impact wildlife food availability on timber landscapes. We are also studying the added values of hosting honey bees and beekeepers on the landscape and the best management practice for ecosystem services on forest landscapes."
Burt's Bees, however, published a Sustainability Update in 2009 in which someone stole the bees, or at least that how it seemed, as they reported about everything but bees. Bees are one of the species affected by changing patterns of human behavior and consumption and climate change, linked to early pollination. Colony Collapse Disorder has become responsible for massive bee attrition, brought on by use of pesticides and other factors. The UK website HelpSaveBees makes an impassioned plea to do more to save the gradual extinction of our natural honeymakers. But the real reason we should all save bees is ... yes, you guessed it .... more icecream !!!!!!!! See what Haagen Dasz are doing to save bees. That Buy a Carton-Save a Bee campaign is totally compelling. Wonder how many bees I can manage to save in one day ? Enough said.
All that remains is for me to wish all the CSR Reporting Blog followers, all Twitter, Facebook and other Social Media friends, all current and future (!) clients of Beyond Business, and just about everyone that is celebrating the Jewish New Year (number 5773) :
elaine cohen, CSR consultant, winning (CRRA'12) Sustainability Reporter, HR Professional, Ice Cream Addict. Author of CSR for HR: A necessary partnership for advancing responsible business practices Contact me via   on Twitter or via my business website  (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm)

Friday, September 7, 2012

Don't Miss the CSR Twitter Explosion

Do you think Twitter could explode ? Could a rush of millions of tweets by hundreds of tweeps all over the world cause Twitter to shatter into millions of pieces all over cyberspace and create the world's first Twitter Big Bang? Can Twitter survive the shock? Next Thursday 13th September 2012 at 3pm ET, you will have the chance to find out and be part of an amazing experience. Even if Twitter survives, you will never get over the Buzz. Even if Twitter remains intact, you will never be the same again. Can you afford to miss out on one of the most energizing Twitter happenings of 2013? Could you ever forgive yourself for not experiencing the Twitter CSR explosion? Of course not. You have to be there. It's the #CSRChat, this time on the subject of "The ABCs of #CSR Reporting in the world of Social Media". With me as the Special Guest. Wow. What an honor!
 #CSRChat has been going strong now since early 2011 and has become the finger on the pulse of what's going on in CSR. #CSRChat is The Hashtag of The #CSR #Twitterscape. The leading light, initiator and brainwaver behind the #CSRChat movement is Susan McPherson, SVP, Senior Vice President and Director of Global Marketing at Fenton Communications, a serial connector, passionate cause marketer, writer, corporate responsibility expert and social media champion, and the most talented, genuine, generous and effervescent personality in  the CSR space today.  It's her great leadership of #CSRChat that has turned it into the not-to-miss tweet event on anyone's CSR calendar.
The last #CSRChat caused an explosion of fascinating tweets and was well worth an hour of fast-paced insights and generous sharing of experiences and insights from Sue Stephenson, the VP of Community footprints at Ritz Carlton, who talked about, among other things, the hotel's Give Back Getaways (#GiveBack), the first global #voluntourism program followed by #VolunTeaming for group guests. A fabulous core-business sustainability opportunity involving employees, customers and suppliers and turning Ritz Carlton into a true sustainability pioneer.

Previous #CSRChats have included special guests John Elkington, the all-time guru, or should I say Zeronaut, of sustainability,   Christina Bennett who manages global PR strategy and social media at Elizabeth Arden, Sarah Altshuller, a senior associate with the CSR practice at Foley Hoag, with a focuses on human rights, Margaret Coady, Director of Committee to Encourage Corporate Philanthropy (CECP), Dov Seidman, who has made a splash with How Metrics, Dave Stangis of Campbell's Soups and Susan Fallender of Intel on creating and running a CSR department,   and nine members of Microsoft's Citizenship Team who discussed Microsoft's commitment to sustainability. Other #CSRChats have covered  the role of video in corporate responsibility, CSR's role in disaster recovery, climate change and CSR, human rights and more.  The very first #CSRChat was on the subject of Employee Engagement.
If you have any questions about CSR Reporting and Social Media that you want covered in the #CSRChat, you can tweet them using the #CSRChat hashtag, or post them as a comment on this blog and we will make sure we cover them.
Please do mark your calendars for Thursday 13th September 3pm ET and get your tweet muscles in shape, log in and join in the discussion. I have even resigned myself to not eating ice-cream for a full hour as I don't want to get my keyboard covered in Chunky Monkey while I tweet fast and  furiously.
See you there! 

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

Tuesday, September 4, 2012

Condoms, Ice-Cream and Creating Shared Value

As a Person with a Passion for Reports, as you might have gathered, I have recently joined as a member of the newly launched service reserved for Sustainability Reporting companies only: the Full Membership Program!
Many of you will already be familiar with, the largest site for hosting all forms of CSR and Sustainability Reports dating back to the early 1990s. In fact, the oldest report I could find on the site is a digital recreation of Shell Canada’s first "Progress Toward Sustainable Development" report, issued in 1991, a time during those dark days when most companies hadn't even heard of sustainable development, let alone thought about reporting on it. This was a time when there was no Global Reporting Initiative, no United Nations Global compact, no AccountAbility Assurance Standards and no ISO 26000 and almost hardly any relevant global points of reference for Sustainability Reporting. Surprisingly, or perhaps not, this 1991 report is not vastly different from many of the reports we read today in terms of the topics covered and the language used. The difference, however, is that today, hosts 42,548 reports across 9,267 companies and 168 countries, many of which are impossible to find without laborious hours searching the Internet, and even then, 100% is not guaranteed.
In addition to helping you locate and view almost any (English Language) report that has been published since 1992 in the speed of light, the Full Membership brings a fabulous array of tools for anyone whose profession has something to do with Sustainability Reporting, or for anyone who just likes to be in the know. Here are some of my fave features:
Statistics: has the largest, most comprehensive, most fascinating set of statistics available anywhere on Sustainability Reporting. Want to know how many reports were published in 2011? That's easy. 6,311. Want to know how many of these were published in the Netherlands? Also easy: 195 reports, 3% of the global total, following increases every single year in report output in this country.

Want to know how many of 2011's first time reporters (my favorites) were 10 billion Euro companies? At the click of a click, you can find that close to 20% of all the first time reports published in 2011 were some of the largest companies around, while the major increase is in the 1 – 10 Billion Euro companies, indicating, perhaps that Sustainability Reporting is starting to reach the suppliers of the largest companies, and a range of other companies who have realized they are no longer immune to sustainability scrutiny.


Want to know if reporters in your region use the GRI Reporting Framework?


If you are in South America, you will tend to be the odd-one-out if you don't use GRI, but if you are in North America, you have the opportunity to make your mark.'s data includes detailed breakdowns of reports on a global basis by region, by country, by sector, and more as well as on a specific country basis by company size (revenue), by GRI adherence and by verification. You can even check how many Stock Exchange listed companies publish Sustainability Reports according to nine leading sustainability indices.


Want to know how many companies have published integrated reports? Or reporting companies participating in the UN Global Compact? A doddle. A couple of clicks and the data is at your fingertips.
As a Full Member, you also have access to very detailed sector statistics for your sector and a list of all the recent reports published.
Why is all this important? Sustainability Reporting is a dynamic field, constantly evolving, with new trends being established as we blog. Benchmarking the external reporting landscape is often an important factor in "selling in" reporting to senior management, or promoting your leadership in the reporting field externally. For example, if you are about to publish a Sustainability Report in Moldova, according to the database, you will be only the third company ever to have produced a Sustainability Report, and if you are in Liberia, Antigua or Cuba, you will be the first reporter!
More than the trends in numbers and types of reports and countries and companies, the Membership offers another fabulous feature which I just love.
PDF Search
This is the facility to search the contents of any Sustainability Report for any keyword over any period and any sector and any country. Suppose I am writing a Sustainability Report for a client in the electronics sector and I am interested to see who has reported on conflict minerals and how. Here we go with a PDF search for "conflict minerals" in reports published in the "technology hardware and equipment" sector during 2010 and 2011. Within seconds, I have a list of 57 reports which includes Lenovo's 2010-2011 Sustainability Report, Arm Holdings plc's 2011 Corporate Responsibility Report, Sun Microsystems Corporate Citizenship Report for 2010 (now Oracle) and a whole load more. A click on any of these report profiles immediately gives me some basic information about the report such as publication date, number of pages, adherence to GRI, AA standards and another click enables me to download the report PDF.
You can have a bit of fun with the PDF search too. I did a search for "condom" and got 1,147 results. What does that tell you? Well, two things. First, that in some companies, distribution of condoms to employees and their families is part of their Corporate Responsibility program, as reported for example by Rangold Resources in their 2010 Annual Report. When I download that report, the internal PDF search takes me right to that condom reference.

The second thing I discovered when I searched for condoms was that many of the 1,147 returned results are not only condoms, but condominiums! Haha. But that's an interesting subject as well!
Of course, I couldn’t not search for my most favourite words in the world – ice cream. Of all the reports published between 2000 and 2011, only 354 refer to ice cream. But wait, another 76 reports refer to ice-cream, the hyphenated version. And a further 23 reports refer to icecream, the one-word version. This doesn't affect the taste, however, so I am quite comforted that ice cream and ice-cream and icecream are so well represented in the world's Sustainability Reporting landscape.
Here's a little quiz – out of a selection of five classic Sustainability Report keywords, which appears in the most reports published in since 2000?
Environment - Employees - Community - Ethics - Carbon

And here are the answers:
• Environment: 26,057 reports
• Employees: 24,861 reports
• Community: 23,482 reports
• Carbon: 19,050 reports
• Ethics: 12,591 reports

Here's another interesting thing. Creating Shared Value. The new Sustainability Buzzword appeared in 46 reports in 2011 but only in 13 reports in 2010 and just 2 reports in 2007 (one of which was a Nestle report), following publication of the famous Michael Porter and Mark Kramer article in HBR exposing this concept.

Anyway, before I get carried away, the point is that this PDF search tool is an invaluable resource to know what's going on quickly in the reporting landscape and find out who's reporting what and how things are changing.

But if you are not a Full Member of, don't despair. You can still get free access to many of the reports by signing up for a personal account which enables you to view a range of reports (up to a certain limit), access Expert Report Reviews of a range of Sustainability Reports using the "3C" framework of Content, Communication and Credibility, offering sharp insights from reporting experts and commentators (including myself) and also view entrants and vote in CRRA, the largest global annual online report awards.

This post might sound like an advertisement for, and perhaps it is. It's unsolicited, however, though I did request permission to share the proprietary data and charts used in this post. The way I figure it, some things are worth sharing. My request also prompted a discount for The CSR Reporting Blog readers. If you send in your Application Form quoting the code CSRBLOG before end September 2012 you will receive a 5% off published early-bird prices, and if you apply between 1st October and 30th November 2012, quoting the same code, you will receive a 10% discount off published prices, from (No, I don't get a commission, just trying to be nice to my faithful blog followers). You can apply for Full Membership here.

Off I go now to read the 453 reports which contain ice-cream, icecream and ice cream.


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

Sunday, September 2, 2012

The G4 Anti-Corruption proposals - explained

Ready for more Thematics ? As promised in my last post on the Thematic Draft of the GHG Reporting Guidelines for the new G4 Framework, I will now discuss the Anti Corruption Thematic Draft. And don't worry, its only 24 pages. Surely there won't be too much to say about that! Think again.

(For clarity (and brevity!) (OK, forget brevity, that's not me), I will focus in this post only on the specific disclosures related to Anti-Corruption - not to changes made to the Ethics profile disclosures or the indicators relating to Public Policy and Political Contributions)

The proposed revisions include:
  • Disclosure on Management Approach: New disclosures and guidance (Anti-Corruption Aspect, Society Category)
  • Indicators
  • Specific edits to Indicators SO2, SO3, and SO4 (Anti-corruption Aspect, Society Category)
You can provide your feedback until 12 November 2012, using the G4 Consultation Platform.

Currently, G3 has three disclosures on anti-corruption (excluding public policy and lobbying):

CORE SO2: Percentage and total number of business units analyzed for risks related to corruption.
CORE SO3: Percentage of employees trained in organization's anti-corruption policies and procedures.
CORE SO4: Actions taken in response to incidents of corruption.
The new proposed Thematic has the same three, with slightly different wording and a lot more guidance on what to report against each one. The new indicators are: 

CORE SO2: Percentage and total number of operations assessed for risks related to corruption
CORE SO3: Information and training on anti-corruption policy and procedures
CORE SO5: Confirmed incidents of corruption and actions taken

Anti-Corruption may hide below the Radar
Remember, that in the new G4 draft, companies will not be required to report on anti-corruption if they have not selected this as a material issue. See my post on the G4 Exposure Draft for an explanation of this. So, unlike today, where every A-level reporter must respond to the Anti-Corruption indicators, in future, any company who does not consider this to be material will happily leave it out. In the Mother of Materiality Matrices Analysis by Fronesys, Bribery and Corruption was found to be only number 33 out of a total of 50 top issues identified as material by 31 leading companies. Given that the average number of material issues listed  per company is 27, Anti-Corruption may just conveniently drop off the radar! (This, I believe, is the single biggest weakness of the G4 proposal - there must be a threshold of basic indicators which all companies should report - and this should include at least some reference to anti-corruption practices.) 
Don't Forget the Juicy Bits
The Thematic Draft includes detailed explanations and specific details which should be reported against each disclosure, ensuring that reporting companies are not tempted to leave out the juicy bits. In fact, the level of detail required is quite daunting - for example, the disclosure on Management Approach for Anti-Corruption contains no less than 11 separate data elements, ranging from whether the organization has a publicly stated commitment to zero tolerance of corruption (that's an easy one, right? If the company doesn't have one, it sure will by the time  it publishes its report!), to processes to prevent, detect, investigate, respond to and remediate forms of corruption to whether and how the effectiveness of the anti-corruption training for governance body members, employees, and business partners is evaluated (errrr... we evaluate our anti-corruption program as effective if no-one has got caught). There is also another interesting disclosure which I haven't seen many companies refer to: "Report policy and procedures in place to ensure that charitable donations and sponsorships (financial and in-kind) that are made to other organizations are not used as a disguised form of bribery. "

Anyway, back to the juicy bits, let's face it, anti-corruption reporting is not the most fun part of any Sustainability Report. Along with reporting on Governance, the Anti-Corruption disclosures are pretty boring and unimaginative. It's not all that easy to make anti-corruption sound sexy and exciting. In G4, it's going to be much more not sexy and not exciting.

The State of Disclosure on Anti-Corruption in G3
This is a random selection of current disclosures  on anti-corruption:

State Street's reporting wouldn't measure up to G4. In fact the company reports partially against the current SO2 and SO4 indicators in this GRI Application Level B+ report.

State Street reports on the existence of an Ethics Office and a Standard of Conduct together with a specific email address for employees to send questions. State Street reports that the Ethics Office is currently updating ethics-related policies, especially Anti-Corruption and that risk requirements were implemented in the UK to respond to the new Bribery Act.

The report contains  a description of a Controls Testing Program in place to analyz risk, and the process for filing of a Suspicious Activity Report in the case of suspected incidents of unlawful activities. All employees must provide annual certification of their compliance with the Standard of Conduct, with 99.9% of employees did in 2011.

All in all, a light-weight disclosure on anti-corruption. State Street is going to have to work hard to be In Accordance with G4, if Anti-Corruption is selected as a material issue. It's could be a lot not more fun at State Street. Except that, Anti-Corruption is not listed as a key material issue for State Street, so it's possible they will not choose to go with the full disclosure anyway. That's a relief for their Sustainability Reporting team, I am sure.

This GRI Application Level A report, the company's 17th CSR Report, is 116 pages long. AMD confirms to reporting fully against the current SO indicators on Anti-Corruption
SO2: "AMD’s Internal Audit Department performs comprehensive risk analyses (including regarding corruption) of all AMD sites/departments." It is not clear if this is every year, and the description of internal audit procedures does not really address this. In G4, a much fuller response to this indicator will be required, including the criteria used for risk assessment for corruption, whether risks related to external stakeholders, and the operations identified as having high risk and what the risks are.

SO3: AMD's response is: "All employees worldwide receive copies of and training on AMD’s Worldwide Standards of Business Conduct, which includes strict anti-corruption provisions. Training typically takes about one hour per employee and must be completed during the employee’s first 90 days of service." In G4, this wouldn't cut it. The disclosure would have to include all forms of training and information on anti-corruption, including the number of business partners informed and the percentage of business or purchasing volume that these partners account for as well as the Board and Management members which are identified as high risk and the type of training they received, for example, web-based, in person or general or specialized training. I think the GRI Working Group forgot to add that the company should report whether lunch was served during the training and what brand of coffee was provided.

SO4: AMD has got this covered in G3: "The response is AMD is not aware of any incidents during or related to 2011." G4 contains several more points in this indicator, but of course, if there were no incidents, there's nothing more to say. It's probably worth avoiding corruption in your business just to avoid the endless details you would have to include in the Sustainability Report to be In Accordance with G4 on Anti-Corruption.

AMD reports only four material issues, and none of them are Anti-Corruption. Looks like this Thematic Revision may not be too useful, in that case.

This is Ford's 13th Annual Sustainability Report at Application Level A of the GRI Framework. The report is online with a downloadable summary, and Ford claims to respond to the SO Anti-Corruption indicators in full. The Disclosure on Management Approach is also noted as being reported in the Sustainability Governance section, though a search on this page reveals no mention of the word Anti-Corruption, as well as on the page on  Ethical Business Practices, which is noted as containing responses to SO2,3 and 4. This page also contains no specific reference to Anti-Corruption.

Reference is made to the Ford Code of Conduct Handbook, which is available in 14 languages and all employees must certify they conform every year. Ford assesses compliance with the Code of Conduct through internal audits. This level of disclosure barely meets the requirements for the current G3 framework, let alone G4. In fact, this report, which is self-declared at Application Level A, in the area of Anti-Corruption at least, would not make the grade. Ford will have more work to do on its 2014 report to be In Accordance with the new G4 guidelines on Anti-Corruption.

Ford's Materiality Analysis, which always has one of the longest list of material issues you can find in any Sustainability Report, also does not specifically include Anti-Corruption as a material issue. Sorry, Thematic Revision.

When is Anti-Corruption Material?
Actually, I found it hard to find a good example of where Anti-Corruption is stated as a top material issue.That's probably not so surprising. Identifying this as a top material issue could be interpreted as the company being plagued with corruption. Not the kind of impression most companies want to leave with their stakeholders. It's much easier to go with climate change and diversity.

Symantec's 2011 Sustainability Report includes Anti-Corruption so far down the bottom of the long list of material issues that it almost falls off the edge of the matrix and actually does fall off the edge of the report.

Wipro India's 2010 Sustainability Report, on the other hand, has two Materiality Matrices and one of them contains Anti-Corruption.

Wipro has a Code of Business Conduct and Ethics (COBCE) which is "is socialized at multiple points of an employee's lifecycle – it is first covered as part of the induction program of new hires and subsequently every employee has to take an online test annually to assert his familiarity with the tenets of the COBCE". Wipro states "We have a zero-tolerance policy for noncompliance with the COBCE,especially on non-negotiable factors – e.g., child labor, anti-corruption,etc." Wipro also discloses a case of financial embezzlement that was committed by a junior level employee during the period from November 2006 to December 2009. After investigation, it was decided that the amounts embezzled were not material, but changes such as enhancing segregation of duties and implementing stronger password controls to access financial systems were implemented. This particular case has an unfortunate consequence: "The employee directly involved died after the embezzlement was discovered."

Wipro also reports the number of complaints received through their Ombudsman process, and in 2010, 451 complaints were received of which 3% related to fraud or financial impropriety.

Would Wipro's reporting stand up to the rigor of G4? I could not locate a response to indicator SO2 - number of operations assessed for risk of corruption, and the disclosures on training would not pass the SO3 sub-clauses. SO4 is covered with the case of embezzlement, but the new cases arising in 2010 are not explained in detail. In other words, Wipro's reporting of this material issue is not significantly more extensive than companies who do not state Anti-Corruption to be material, and disclosures do not meet the requirements of the current G3, let alone G4.

One more point: the Difference between Ethics and Anti-Corruption
Generally speaking, if companies have a Code of Ethics, and this includes prohibition of corruption, and companies make sure that employees sign off on the Code of Ethics (after some training, perhaps), is this an adequate response to the question of corruption? Is ethics training enough to cover off anti-corruption? The answer is probably generally not.
The revised G4  Definition of Corruption is as follows:
"Corruption is ‘the abuse of entrusted power for private gain’ and can be instigated by individuals or organizations. In GRI’s Framework, corruption includes practices such as bribery, facilitation payments, fraud, extortion, collusion, and money laundering. It also includes an offer or receipt of any gift, loan, fee, reward, or other advantage to or from any person as an inducement to do  something that is dishonest, illegal, or a breach of trust in the conduct of the enterprise’s business. This  may include cash or in-kind benefits, such as free goods, gifts, and holidays, or special personal services provided for the purpose of an improper advantage or that may result in moral pressure to receive such an advantage."
There is a very good paper written on Corruption, published by FSG Social Impact Advisors - it's well worth reading.  Some highlights from this paper:

  • Corruption is estimated to cost $2.6 trillion annually, an amount equal to more than 5 percent of global GDP. Each year, over $1 trillion is paid in bribes; not only do these payments undermine fair competition and affect the profitability of businesses operating globally, but they also divert crucial public resources away from their legitimate uses, denying citizens essential public services such as education, clean water, and health care.
  • Emerging markets have higher corruption.
  • Almost two-thirds of executives have experienced some form of corruption.
  • Corporations today largely treat corruption as a legal and risk-management problem requiring a compliance-driven approach. Ethics and compliance officers typically do not view external anti-corruption efforts as part of their jobs, nor do CSR executives often seek to address this social problem.
  • Global or industry-wide anti-corruption initiatives are frequently toothless, inadequate in size, or nonexistent. Compared with other social issues that affect business, corruption has not received a proportionate level of attention.

In other words, a Code of Ethics has a very broad brief and contains many clauses ranging from privacy of information to equal opportunity to protection of company assets and more. Ethics training may not cover anti-corruption comprehensively enough. Ethics training is often broadscale and minimum (completion of an online module), and may not specifically go deep enough for those who are at highest risk of corruption. An example of training in the area of money-laundering, one of the defined forms of corruption,  can be found in the 2011 Sustainability Report of the Landesbank Baden Wurttemburg:

" ...all of our employees who conduct transactions or whose jobs involve initiating and establishing business relationships (such as opening bank accounts and securities accounts, assigning safety deposit boxes) are trained through an educational program at their workplace. In addition, compliance officers are assigned to the various divisions and sales departments to personally support our staff in their money laundering prevention activities directly on site."

A Thematic Conclusion
The GRI G4 proposed disclosures on Anti-Corruption are comprehensive and rigorous in detail - perhaps overly so. The Disclosure on Management Approach clauses and the detailed responses to SO2, SO3 and SO4 are probably more than most of us want to know and it's questionable whether they add to our assessment of an organization's true capabilities in managing corruption risk. If perfect is the enemy of good, then these Anti-Corruption disclosures might just be in enemy territory. 

The best way for most companies to handle this will be to establish a separate multi-year Anti-Corruption Policy, covering all the Management Approach Disclosures and part of SO2 on the way risk assessments are conducted, downloadable from the corporate website  This leaves the actual annual Sustainability Report to refer to this policy and report only those specific instances, percentages and numbers occuring in the reporting period. Assuming, of course, that Anti-Corruption is material for the organization. Who determines materiality? Well, that's another story. I have talked a little about this in my previous G4 post, but I will surely come back to it as a core determinant of effective sustainability reporting.

In the meantime, go and treat yourself to you an ice-cream. (I am glad the GRI doesn't issue guidelines about ice-cream consumption. My report would be 937 pages long!)

Yes, it was as delicious as it looks!

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