Saturday, April 6, 2013

How to say Sustainability in a Poster

Having spent a lot of time on this blog talking about the new generation of the GRI Guidelines and the G4 Exposure Draft, and speculating about what it will look like when it is actually launched, it is now time for the talking to stop and the action to begin, as we enter the countdown phase for the G4 launch. It's time for everyone to start placing bets as the exact format for the G4 launch is being kept well under wraps. If you are not in Amsterdam on May 22-24, to hear the first exposure of the G4 draft, and engage with 1,500 or more sustainability professionals, consultants, commentators, academics, regulators, activists and optimists at the Innovation, Information, Integration GRI Conference, you will be missing out on THE sustainability event of the 2013 calendar. Download the conference agenda here. Plus, if you attend, you'll get to meet all our online friends at the TWEET-UP, which will be at 12:00 noon on Wednesday 22nd May, a unique opportunity to put all those Twitter handles to Twitter faces. 

One of the star attractions of the conference will, of course, be the first exposure of the G4 guidelines and the proposals for adopting them as the reporting journey moves forward. The G4 track runs through the conference, starting with the launch at the end of Day 1, running through Day 2 and finishing up on Day 3. If you attend all these sessions, you will become a true G4 expert and be able to advise your company on its reporting journey going forward.

Day One Wednesday 22nd May
17:30 G4 Launch "This plenary will showcase the G4 development process and present the views of different stakeholders on how G4 will help advance organizational reporting and transparency." Speakers are: Denise Esdon, Ernst & Young; Karin Ireton, Standard Bank Group; Mervyn King, IIRC; Roel Nieuwenkamp, Director Trade Policy at Dutch Ministry of Economic Affairs; Herman Mulder, Chairman GRI
Day Two Thursday 23rd May 
09:00: G4 Content Briefing: Jo Confino of the Guardian and Nelmara Arbex of the GRI will introduce the G4 guidelines
10:00: Defining Report Content: Material Aspects and Boundaries discussion will be moderated by Simon Longstaff, St. James Ethics Centre Disclosure 
11:30:  Disclosure on Management Approach (DMA) discussion will be moderated by Judy Kuszewski, SustainAbility
14:30: Governance and Remuneration discussion will be moderated by Christianna Wood, Chairman of the Board of Governors of the International Corporate Governance Network
16:00: Supply Chain discussion, moderated by Simon Longstaff, St. James Ethics Centre

Day Three Friday 24th May
09:00: Greenhouse Gas Emissions reporting discussion, moderated by Simon Longstaff... again.

In addition to the G4 track, there are "Trends in Reporting" sessions, Regional Overviews by Delegations from around the world, Policy and Regulation sessions and Learning Sessions, such as "First Time Reporting Made Easy" with Crystal Crawford, Corporate Responsibility Specialist of Liberty Global, whose report I featured on the CSR Reporting blog a while ago. (10:00 Thursday 23rd, Day Two)

In other words, plenty of interesting perspectives, updates, networking, discussion, insight, information, innovation and integration. I am looking forward to seeing absolutely loads of old, new, offline, online and bothline friends, colleagues and sustainability movers-and-shakers at the conference.  

In the meantime, before you get to Amsterdam, there is something else you can be doing.
As you may know, the voting period for GRI’s Next Generation Competition began on Wednesday 20th March, on GRI’s Facebook page. More than 60,000 Facebook users have been reached, and more than 3,000 votes (or "likes") for the different posters presented have already been received. The competition was designed to encourage young professionals up to age 30  to engage with the sustainability agenda and compete for the opportunity to be part of a landmark conference and turning point in Sustainability Reporting history. The challenge was to design a poster that promotes an inspiring concept or message to encourage people and/or companies to accelerate the transition towards a sustainable global economy, while relating to one or all of the key words that make-up the theme of the GRI Global Conference: Information, Integration, Innovation.
The Facebook album of the 25 posters submitted can be viewed on Facebook via this link:, and you are invited to "like" the posters you believe best reflect and inspire sustainability. Public voting closes on  10th April, which means your chance to vote for the top 10 is quickly approaching!

See the full selection of posters, and vote for your faves, on Facebook!
Once determined by public voting, the top 10 posters will be submitted to an international jury (which includes me, myself and I, as well as other sustainability pros) for a shortlist selection of the top three posters.  The authors of these top three posters will be invited to join GRI (and us) at the Global Conference in May and conference delegates will select the overall winner. This 1st Prize winner will be invited to give a speech at the closing plenary session of the conference, to explain her or his entry and inspire the international audience! Who knows, one of these poster-masters may well be a global corporate sustainability leader of the future...wouldn't you like to be able to say you had a hand in her or his professional development? Sure you would... so take a look, vote and see you at the GRI conference!

PS: I will be on the lookout for the best ice-cream in Amsterdam, so all suggestions welcome!

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

Wednesday, April 3, 2013

Is G4 reporting suicide?

Following my two recent posts, in which I partially analyzed two reports for their alignment with the new G4 Exposure Draft, I wanted to add some concluding thoughts. In developing these two (limited) analyses of Clorox and Henkel reporting, I realize that in practice, G4 is much much tougher than G3, moreso than I anticipated. Value chain, supply chain, material aspects, core and add indicators, profile disclosures, management disclosures... it's all makes the reporting task a much more serious affair. In essence, this is what we should want: a more connected sort of reporting, one which addresses real impacts and outcomes and not just a list of let's-play-nice activities. G4 requires much more in the way of planning and preparation. Mapping your value chain, consulting your stakeholders, identifying your material sustainability issues in that chain, prioritizing them and selecting how to report requires great rigor. And all of this is before you have started to send out excel files to your internal content providers for data collection and filled in your case study templates. In essence, it's the right way to go. In theory, it's the right way to report on sustainability. It bridges the gaping gap between the shopping-list sustainability report and the material role-in-society sustainability report.

However, the G4 framework as presented in the Exposure Draft does not bring out this reality in the most effective way. The new G4 guidelines are not sharp enough to prevent confusion about what is required to report and what is recommended (guidance), and the presentation is difficult, taking some time to understand and then, even only after several readings. Because of the way G4 is structured, aligning management approach categories and aspects to material issues and performance indicators is no easy exercise, and makes defining the reporting structure a job which is more stretching than writing the report itself.

At this point, I would go as far as to say that launching G4 (as presented in the Exposure Draft) for the GRI would be akin to reporting suicide.

I tend to agree with Ben Tuxworth of SalterBaxter in his article on the Guardian Sustainable Business site, in which he states: "Though nobody doubts the good intention behind the changes, the overall sense I have from a seminar we held with a dozen leading reporting businesses in December is that G4 could make GRI simply too complex and burdensome. As one reporter we spoke to put it: "if the expectations of G4 cannot be simplified, existing reporters may begin to step away from GRI, and new reporters may not be in a position to report against the guidelines at all".

Marjolein Baghuis of the GRI responded to this article with the following comments about what might be expected to launch in May:

1)  A new “in accordance” system with two tiers
2) Material focus: reporters will be required only to provide disclosures and indicators that are relevant to the business. It will be for the organization itself, in dialogue with its stakeholders, to determine what these are.
3) Separation between “What to report on” from “How to report” – greater clarity on what is requirement and what is explanation

So "In Accordance" may now become Application Level A and Application Level B? A two tier approach is not the solution. GRI needs to find a way to allow and reflect gradual and evolutionary implementation of the guidelines in a more comprehensive way without a qualitative beginners/advanced, high/low, better/worse black/white, A/B, impressive/not-impressive dichotomy. The approach needs to be fundamentally different. GRI has to be more creative here, and not simply reapply a bad system in a different way.  Creating two tiers simply adds to the complexity and creates another margin for error, or even false claims.
Without the competitive benefit of being able to claim "In Accordance", at whatever tier, many companies will use G4 to "inform" but not to "frame" their reporting, which would lead to a stark dilution of the application of the GRI framework in practice, possibly even less rigorous than today. While G4 has some good ideas and intent - value chain, materiality, some more detail on supply chain etc - the sum of the component parts is horrendously burdensome and, frankly, unnecessary.
I disagree with Ralph Thurm who claims that many of the objections to G4 are about the (increased) number of indicators that should be reported. I don't think that's it. I think the problem with G4 is the relevance of the indicators required and not the quantity. We may want transparency, but we must curb our appetite for information overload for the sake of information overload. We want to see the wood and the trees. But if we have too many trees, all we will see is a big blurry landscape with undefinable constituent parts. The 2494-page document published by the GRI including all the responses to the G4 Exposure Draft Public Comment Period makes for interesting reading (if you have a few months to spare) and largely supports the need to simplify, clarify and focus the new guidelines on what's truly important.
Who will monitor G4 compliance? Will GRI perform "In Accordance" checks on every report that wishes to claim this achievement? If not, who will? Stakeholders will not perform detailed checks on adherence to GRI, no matter how many times the GRI says that it is their responsibility to do so.

We all want businesses to perform better on sustainability, and be more transparent, and we recognize that there are many gaps in the current reporting landscape. G4, as is, may only serve to make those gaps wider and impossible to reconcile. Companies who are already experienced in reporting at the highest (GRI Application Level A) level, may be tempted to push the envelope, but, frankly, why should they strive to be "In Accordance"? Would it not be simpler for companies to publish a more general non-GRI based report, while responding to specific requests for information such as the Carbon Disclosure Project and the DJSI or other rating and ranking and analyst companies? Despite the objective of harmonisation, it is not clear how the GRI aligns with these frameworks (except for realignment of emission scopes reporting with the CDP), and when it comes to the crunch, companies may believe that they could gain more value from focused responses to information requests rather than publication of an overly complex Sustainability Report. In fact, this is a core inconsistency in the GRI approach. On the one hand, reporting is for stakeholders who should check whether companies are indeed transparently accountable. On the other hand, most stakeholders are not willing/able to do the detailed work to identify whether companies are actually living up to their promise in terms of report quality, accuracy and adherence to a reporting framework.
This is what GRI says "GRI is not in a position to police or control the quality of reports based on its Guidelines – this is outside of the remits of what GRI does. However, using GRI’s Framework means organizations should engage their stakeholders when developing their reports. GRI also encourages stakeholders to challenge reporting organizations on their sustainability goals and what they report."

The fact that almost nobody notices when companies mis-report, or mis-apply the GRI framework, may suggest that stakeholders are passive and perhaps, gullible. Or it may suggest that they are looking for the big picture, the material impacts, the difference a company's activities makes in their lives and in their communities, rather than the detail of how many suppliers of which type a company employs in Latin America and how many tons of ingredients it buys from each. It may suggest that stakeholders want enough data, but not too much, to assure themselves that executive remuneration is equitable, aligned with company performance and competently managed, rather than the entire disclosure of the "ratio of the annual total compensation percentage increase for the organization’s highest-paid individual in each country of significant operations to the median annual total compensation percentage increase for all employees in the same country (excluding the highest-paid individual)." Stakeholders want to know about supply chain risks, but may not need the full report  of "the percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts on society assessed on society-related performance, and actions taken".

In this sense, G4's focus on materiality is good. But this focus is buried in a mass of profile disclosures and a long list of performance indicators which go into unnecessary depth and which most stakeholders will not know how to use. Even the most skilled of financial analysts will be challenged to understand the financial impacts of such granular disclosures. Maybe G4 will have the effect of encouraging companies to leave detailed reporting of performance to those who specifically ask for it (and presumably know what to do with it) while publishing a more general review of their sustainability impacts for the bigger picture stakeholders. I think it would be a shame if this happened and could lead to disjointed reporting and potential for inconsistencies.
In the run-up to the May conference, I believe the GRI needs to do some soul searching, rethink several elements in G4 and turn it into something it was originally intended to be: a simpler, clearer, more relevant and more accessible framework that will deliver information that stakeholders need and know how to use. That doesn't mean just cutting out the extra bits. I think a real back-to-the-drawing-board approach is called for to get to what matters most in the most effective way.  I hope we will see a somewhat different G4 in Amsterdam in May. I suspect it's probably pretty much wrapped up by now, bar the waiting, so these comments may have missed the train. But it's not too late to make a change in the way G4 is launched......

....... I would recommend a soft launch for G4: an invitation to up to 100 reporters to produce their 2013/2014 report using G4,  log their experience, make recommendations, and help define whether G4 is really a workable, beneficial, new framework or something that looks great on the drawing board but overly challenging in the harsh reality of corporate practice.


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

Tuesday, April 2, 2013

HENKEL: G4: good-to-go?

Henkel is an early 2013 reporter, and with a GRI B (self-declared report), is now my next guinea pig in the G4 good-to-go test. As you will have seen from my first post in this series, covering the Clorox report, getting to G4 is more of a marathon than a short stroll (if G4, when launched, is fairly close to the current exposure draft).

In this analysis, I focus on just a few significant changes in G4, and these are just four Profile Disclosures and their corresponding Management Disclosures and Performance Indicators.

These are the new disclosures: (for more background see my Clorox post)
DI 12: Describe the organization's supply chain (number, type, location of suppliers, value of materials purchased etc)
DI 17: List the identified material Aspects (and other material topics).
DI 18: Describe the organization’s value chain.
DI 19: Place material Aspects (or other material topics) in the value chain.

Quick Overview of the Report
Henkel is headquartered in Dusseldorf, Germany, and employs 47,000 people and generates revenues of 16.5 billion Euros, manufacturing household care and personal care products. 

Henkel 2012 Sustainability Report GRI Application Level B - self-declared, 52 pages
The printed report is linked to the web-based report using reference codes, enabling you to find additional content by inputting a code - a nice touch. Henkel states a clear strategy for 2030 - a long-term goal to triple the value created by the company's footprint (i.e. become three times more efficient), supported by quantified five-year targets to 2015 in six focal areas - for example, reducing waste, water consumption and energy by 15% per production unit by 2015. Much of Henkel's report is focused on resource efficiency in product manufacturing and development. The company has developed a "Sustainability#Master" matrix approach which identifies the "hot spot" areas for improvement in value development and environmental efficiency for its products, and applies this system for evaluating and implementing improvements.

Sustainability#Master Matrix for adhesive product Loctite Max 2

Profile Disclosures
Henkel's supply chain disclosure includes a section related to suppliers, and there is reference to the supplier base in 125 countries and the fact that more than 70% of purchased volume comes from OECD countries. Supplier selection criteria include sustainability performance and adherence to responsible business practice principles, and Henkel has a risk assessment process which requires suppliers to complete a self-assessment on sustainability issues and participate in audits of their operations.

However, Henkel does not disclose the number of suppliers it works with, nor the number of results of audits conducted. Henkel does not make any reference to the types of suppliers as required by disclosure D12, for example, whether the supplier base includes ingredient suppliers or contract manufacturers (though later in the report we can read that around 10% of Henkel's volume of over  7 million tons of output is produced by contract manufacturers).

DI 12 also requires disclosure of the "total monetary value and/or volume of materials purchased from suppliers broken down by types of materials, types of suppliers and location of suppliers" (although I fail to see why this disclosure is an essential basic profile disclosure) and Henkel does not really provide information which meets this request. DI 12 Henkel G4 good-to-go? No.

I couldn't find a Value Chain description in Henkel's report, though there is evidence of value chain thinking in the Hot Spot analyses, as in the example provided above, as these take into account the upstream and downstream effects of product development, manufacture and use. However, these descriptors are individual for selected products, and are limited to the impacts of products and not the entire organization and the entities it impacts. Additionally, the detailed impacts in these analyses are not fully disclosed - only the areas in which product improvements are identified and the progress of these improvements are noted. Therefore, mapping the Value Chain disclosure - DI 18 Henkel G4 good-to-go? NO.

Henkel has a long list of material issues, which could expand this 56 page report into something much longer in G4. I believe this complies with the requirement for listing the material issues and aspects as required by G4. DI 17 Henkel G4 good-to-go? YES

These material issues translate into 19 material Aspects in the new G4 line-up, according to my calculations. I can't examine ALL of these, but let's take a couple.

Occupational Health and Safety is a material Aspect in the Social sub-category of labor practices and decent work. There are four performance indicators here: LA 6, 7, 8 and 9, of which 8 and 9 are core. LA7 refers to "rates of injury, occupational diseases, lost days, and absenteeism, and total number of work-related fatalities, by region and by gender" and LA8 refers to education and programs to assist with serious diseases. These are unchanged in G4 and Henkel includes these indicators as fully reported. However, Henkel's reporting against LA7 in this self-declared GRI B level report does not meet the indicator requirements. Rates of injury and total fatalities are disclosed but not lost days, absenteeism and this is not split by region and gender.

LA8 relates to serious diseases.  The Indicator Protocols define this as "Occupational or non-occupational related impairment of health with serious consequences for employees, their families, and communities, such as HIV/AIDS, diabetes, RSI, and stress." I could find no disclosure relating to such diseases in Henkel's reporting, although some of the health and safety training activities listed also include, for example, "back strengthening exercises and tips on nutrition". Therefore, in this material Aspect, not only does Henkel not meet the requirements for G4, it does not meet the requirements for G3. G4 good-to-go? NO  
Renewable raw materials is one of Henkel's stated material issues. This fits into the Materials Aspect in the Environment category. There are two core indicators here: EN1 (materials used by weight or volume, split by renewable and non-renewable) and EN2 (percentage of recycled input materials). Henkel indicates full reporting against both indicators. Regarding materials used, Henkel reports in general on the different types of raw materials in key product categories, and notes the approximate percentage of renewables. However, no data is provided on the weight or volume of key raw materials, including sustainable palm oil, which Henkel notes as a separate issue in its own right. Henkel confirms commitment to participation in the Roundtable on Sustainable Palm Oil and to purchasing of RSPO certified palm oil, but does not disclose how much palm oil the company actually uses. Henkel also mentions various initiatives to improve the sustainability of packaging, but apart from providing the total weight of packaging, does not identify how much is from recycled materials. Therefore, in these two indicators, Henkel does  show a good approach and several positive initiatives, but does not meet G4 requirements and not even G3. G4 good-to-go? NO
At this point, we know that Henkel's current reporting does not meet the G4 Exposure draft standards, based on, once again, a very limited analysis of just a small sample of G4 disclosure requirements. This is not surprising, as this report was not written with G4 in mind. It does however demonstrate the step change required to meet G4, as we saw with the previous Clorox example. In other words, Henkel has some significant changes to make before it can claim "In Accordance" with G4, if the company decides to become G4 compliant.
In my next post, I will share some further thoughts about the applicability, relevance, complexity, benefits and uptake likelihood of G4. Watch this space.

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

Monday, April 1, 2013

CLOROX: G4: good to go?

In the run-up to G4 (to be launched in May at the GRI conference), I decided to examine some recent reports (at random, but GRI-based and broadly same sector) to see if they would be good-to-go if the Exposure Draft is approved as published (albeit the likelihood of this appears low - the grapevine is indicating that significant stakeholder pushback is likely to dilute G4, though quite to what extent is not clear).

Below is a reminder of  what reports must include in order to qualify as "In Accordance" with the potential G4 Framework as we know it today from the Exposure Draft:

1. All of the Profile Disclosure Items. (There are 73 (!) Profile Disclosures)
2. Disclosures on Management Approach and Core Indicators related to all of the material Aspects identified by applying the Technical Protocol: Defining Report Content and Boundaries.
3. All disclosures identified in any applicable GRI Sector Supplement(s).
4. A GRI Content Index as specified in the GRI Guidelines.
5. A statement, signed by the highest governance body or Chief Executive Officer (CEO), that the report has been prepared in accordance with the GRI Guidelines and that it is a balanced and reasonable presentation of the organization’s economic, environmental and social impacts.

Regarding Profile disclosures, there are four substantive disclosures in G4 which make a difference to the entire reporting content. These are:
DI 12: Describe the organization's supply chain (number, type, location of suppliers, value of materials purchased etc)
DI 17: List the identified material Aspects (and other material topics).
DI 18: Describe the organization’s value chain.
DI 19: Place material Aspects (or other material topics) in the value chain.
Not reporting on these Profile Disclosures invalidates the "In Accordance" adherence. I will focus on these in my review of reports.

I ignore the 38 (!) Profile Disclosure items relating to governance and remuneration (up from 10 disclosure Items in G3), as, in my view, many of them are irrelevant, unnecessary and a waste of hours that the Working Group invested in devising every data point that they could possibly imagine. I expect this justified the cost of bringing the group to Amsterdam, but, in my view, it makes sustainability reporting look like's inventory of items shipped in the last five years.  I suspect that in almost every case, these 38 disclosures alone will disqualify all existing reports from claiming "In Accordance". However, let's not get bogged down in the negatives before we even started....
Regarding Disclosures on Management Approach, there are now three specific disclosures (replacing rather general guidance in G3) which require the company to report for each material issue (aspect), what the issue is and its key impacts, why it is material and what it's doing about it.      

First guinea pig:

The Clorox Company
GRI B+ GRI-checked online report with download (78 pages) Household Cleaning Products

Quick Overview of the Report
Clorox is a $5.5billion household products business with markets in over 100 countries and a workforce of 8,400 people. At Clorox, sustainability is paying off. Clorox people write in their annual report: "Sustainability investments in our Burt’s Bees®, Glad®, Brita® and Green Works® brands have accounted for about 40 percent of our sales growth in the last five years. Additionally, we’ve saved about $15 million annually by making sustainability improvements to our operations." A nice touch in this report is a description of some megatrends that are influencing Clorox's thinking. Clorox's Ingredients Inside is an interesting initiative, which lists all raw materials used in Clorox's cleaning products, with their chemical names and function. Of course, you would have to have a PhD in chemistry to make sense of all of that, but it's a good step for transparency.

The report receives a "+" from the GRI for being assured, although only GHG emissions from electricity consumption in U.S. facilities were verified. Frankly, you couldn't find a smaller sample of disclosure to assure, even if you tried really really  really hard. This report, to me, does not stand the test of assurance. I fail to see how the GRI can reasonably award a certificate for assurance here.

The well-respected Leon Kaye's concludes in his review of this report that "Clorox stands out as a corporate citizen that more companies within and outside of its space would be wise to emulate". Certainly the company demonstrates strong performance in waste reduction, GHG emissions, and water consumption. I note some positive employee practices including a new health and wellness program and also good community support.
However, I feel the Clorox report lacks some reporting depth and breadth, and is focused on activities rather than the change that Clorox is effecting in society as a result of its sustainable business focus. For example, 21% of products (since 2010) have been reformulated to reduce materials and waste, but Clorox does not disclose the extent of these improvements and the reduction in impact. There is a commitment to "responsible sourcing" but zero detail on what this actually means, beyond the existence of a Supplier Code of Conduct. More importantly, there is little about how Clorox is changing consumer behaviors with the exception of one or two small examples. With key business growth coming from "green"-ish products, I would have appreciated Clorox telling this story more fully.      
Profile Disclosures: 
Clorox lists four issues of material focus, based on insights gained from stakeholder engagement processes:
  • Sustainable Product Innovation to include solutions for public health and more natural or plant-based products.
  • Product responsibility  to improve human and environmental safety and ingredient transparency.
  • Environmental sustainability for reducing Clorox's eco footprint.
  • Public health in the area of disinfecting products.  

Looking at G4's matrix of Categories and Aspects, these appear to be just two aspects: Environment (emissions, effluent and waste aspect) and Product Responsibility (customer health and safety aspect). This is quite convenient for Clorox, as the performance indicator content of G4 is required only for Material Aspects. An opportunity to move from 78 pages to 20 :)

Clorox does not describe its Supply Chain, nor its Value Chain and does not place material aspects in the Value Chain. These are required G4 disclosures. G4 good-to-go? NO

As an aside, another interesting Clorox issue which invited the wrath of leading commentator Marc Gunther  and several others was their Greenworks campaign, which was too late for this report but may (or may not) be mentioned in the next report. Perhaps it's something for the Material Aspect: Marketing Communications! 

Disclosures on Management Approach
This is easy for Clorox as there are only two Aspects to report. I think this report meets the requirements for this section.G4 good-to-go? YES

Performance Indicators
There are 10 indicators which are in the Emissions, effluent and waste Aspect (EN16 - EN25), of which seven are core. Clorox currently reports on three of these seven core indicators in full, providing no data relating to, for example, water discharge (EN21) or significant spills (EN23), and avoiding non-core indicators such as hazardous waste (EN24) and biodiversity affected by water runoff (EN25). G4 good-to-go? NO

There are just two Performance Indicators in the Customer Health and Safety Aspect (PR1, PR2) and Clorox currently reports on one of them, providing a good description of safety assessments and procedures (PR1). Clorox does not report on incidents of non-compliance with regulations concerning the health and safety impacts of products during their life cycle (PR2), but this is non-core, so not required for "In Accordance". G4 good-to-go? YES

Despite producing a lengthy and generally comprehensive report using G3, and recording some good sustainability achievements, it looks like Clorox has quite some work to do in order to prepare future reports "In Accordance" with the G4 Exposure Draft. And this is based on an analysis which barely grazes the surface of the total new scope of G4. I believe this shows that G4 as proposed is not a small evolution for reporting, but a major overhaul, and will require significant reconsideration of what and how to report. The upside is that Clorox G4 will not be required to report on anything not defined as material. But is that really an upside? Are there not some disclosures which should be reported by all companies whether or not they are company-specifically-material? I suspect there are several.

At least Clorox will not be alone in having to make significant change if the company decides to adopt G4... watch this space for an example from Henkel's report in my next post.

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