Why the materiality matrix is useless

2015 is a new year - Happy New Year to everyone! And as we close out 2014, I thought it would be a good time to shake things up a little and get just a touch provocative. (Totally out of character, haha). See, I have begun to be really irritated by useless materiality matrices.  I am looking forward to a year in 2015 where materiality drives strategy and reporting in a profound way, and where we stop playing around with dots on a matrix just because that's what seems to be the de rigeur of sustainability reporting.

One of the things that is going to have to get a whole lot better if companies are really going to gain best value from a strategic sustainability approach is the way materiality is considered, analyzed, developed and communicated, as well as, more importantly, used as a basis to drive action. In many cases, it's near impossible to relate what are stated as material issues to the way the company approaches its sustainability activities. The more G4 reports I read, the more materiality matrices I look at,  the more I come to the conclusion that, by and large, many companies are just missing the point. 

This is probably not entirely intentional. Maybe many companies actually think they are doing a good job of defining materiality. Spending time plotting little dots on a matrix and moving them up or down a millimeter may actually be someone's idea of meaningful strategic planning. Maybe people think that's how it's supposed to be done. Maybe companies look at their materiality matrices and give themselves a big slap on the back. 

But actually, it's not being done well. It's not hitting the right spots. It's not generating the leverage that is needed. Materiality, so far, as a concept, is not proving itself. It's a nice buzz word, makes everyone feel good, sound intelligent and provides creative license to draw pleasant graphs, charts and multicolor, even interactive, visuals, but it's not doing what it intended to do. This is clear from the disconnect we are still finding in sustainability reports between what's supposedly material (because the matrix says so) and what companies are actually doing (based on what's reported). 

The basis for my comments is my personal review of many of the 500+ GRI G4-based sustainability reports that have been published to date. I am referring to G4, because G4 places material impacts squarely at the center of the reporting approach. Not because it's right for reporting. Because it's right for business. This is how GRI G4 defines materiality: 

In G4 reporting, companies are required to list material aspects and provide disclosures that show how  an organization "identifies, analyzes, and responds to its actual and potential material economic, environmental and social impacts". Performance indicators supporting  material aspects are designed to reflect how a company measures its performance in relation to those stated material impacts. While I know that the G4 framework is not always 100% logical, and there is, in many cases, a rather unfathomable connection between certain material Aspects in the framework and the Performance Indicators that are designed to reflect those Aspects, the underlying issue is whether companies are approaching materiality in a meaningful way. (Perhaps someone might even be able to explain to me why G4 chose the very odd word Aspects and did not use the very clear word Impacts when making materiality the G4 engine driver). The metrics, or indicators, can be adapted or developed to meet the need. The material impacts should first drive what a company does or should do, and therefore measures, and therefore reports. Creating a materiality matrix after you have done everything else is not exactly going about things in the right way.

Let's think about what materiality really means in a sustainability context. It means the material impacts IMPACTS IMPACTS on stakeholders. 

These are things that material impacts are NOT (or not only):

• what's going to help us make more profit
• what our stakeholders mention in passing
• how we perform
• what we think is politically correct
• what everybody else is saying
• what's easiest to report
• what shows us up best
• what's in fashion
• what the  lawyers tell us to say
• what we've always said
• what the assurers can count
• things we have data for
• an afterthought
• an easy option
• a buzz word
• a box to tick
• lip-service
• a way to appear as though we wrote a G4 Sustainability Report

Material impacts are: 

• the way our business activities affect the lives of our stakeholders and our long-term business viability
• the basis for creating a sustainable business strategy with relevant targets
• defined as the result of an analytical process that engages internal and external stakeholders about what affects them and how
• the basis for creating sustainability communications including reporting
• specific to a business, a sector, a geography, an issue
• a catalyst for planning and action
• connected to a business's core social mission

A few examples? Sure. Wizness recently published a free download benchmark of 50 materiality matrices across 5 industry sectors. Almost all of them have loads of little dots carefully plotted on creatively designed squares, blocks and circles. Some of them have so many dots you begin to wonder how on earth the company even recognizes the dots, let alone creates a strategy to manage them. Whoever is selling dots is making a killing. And the relativity between the dots is often just incomprehensible. Here are some examples from the ones presented by Wizness:

HK Exchanges and Clearing House 2013 Report

You may be able to see, just about, that this company has loads and loads of dots, with the top 16 prioritized as the most material issues/impacts, supported by a detailed stakeholder matrix of what affects whom. The top 9 issues all have the same degree of importance to stakeholders, yet they are all at different coordinates on the matrix. Compliance with laws and regulations is only mediumly important to the business and to stakeholders while compliance with laws concerning products and services hits the top right box in the matrix. I wonder how these nine issues were plotted. What makes anti-corruption so much more important than anti-competitive behavior? The report gives no clue to how these issues were placed in the matrix. Their placement suggests that they are not equally most material and that some are more most material than others. What does this differentiation actually mean? To me, it suggests that there is a focus on moving dots around a matrix and not on the underlying drivers of sustainability performance. Notwithstanding the fact that the very act of defining a set of material priorities is an important part of the process and should be encouraged.  

Here is another example:

Pan American Silver Sustainability Report 2013

Wow. The entire 46 G4 material Aspects and Sector Disclosure Aspects all carefully ticked or unticked and slotted into place on a matrix that it took me half an hour to work out what's where. I wonder how long the plotting exercise took and how the little letters on the matrix were locked into position. The color coding of the different categories makes it almost impossible to tell without detailed study what is actually most material for this company. It looks to me like the top three - turquoise "a" is "local communities" as the top issue,  purple "c" is "occupational health and safety" one of the two runners-up and blue "d" looks like child labor as the second runner up. Why are these issues more important, than, say, anti-corruption, which appears much lower on the list, or labor relations which is not material at all?

In Pan Silver's report, there is a large section devoted to the most material Aspect, local communities. It's about how Pan Silver, while doing its core business, is engaged with local community projects to support economic and social development. A really fine array of projects that I am sure are highly commendable and make a genuine difference to local quality of life. But why is engaging with local community development projects the most material impact of this company? What about the impacts generated through the company's core business? What about materials use and ecological limits? Pan Silver produced 26 million ounces of silver and 150 thousand ounces of gold in 2013. What about water use in the mining sector? Total water withdrawn for Pan Silver in 2013 was more than 42 million cubic meters, that's about 15,000 Olympic swimming pools. Not to mention water discharge with potential toxic chemicals. Pan Silver has addressed these issues in the report, but what makes them less important local community projects? Does the materiality matrix indicate priority in allocation of the company's resources required to address material impacts, suggesting that a higher priority received more attention, more resources, more commitment? What I would really like to know from Pan Silver is its most significant impacts on stakeholders. The top 5 or 10. I don't really care where they are on a matrix. I don't really care about the tenth of a millimeter of space between the little letters. Does anyone? I don't even believe it is possible to differentiate between the most important material impacts at this level of detail. I am sure the process of thinking about what is most important should have been beneficial. I suspect that the part where the dots on the matrix slotted into place is simply a total waste of time.  

And here is another example from The Hershey Company 2013 CSR Report.

Hershey's has defined the priority issues and they are all dealt with well in the company's CSR report. It's great that out of a total of 25 issues, Hershey has selected ten that represent the most important impacts. However, what makes food safety so much less important than ethical sourcing? Why is child labor so much more important than GHG emissions? Why is ethics more important than governance? And if philanthropy is so low on the matrix, both for stakeholders and for the company, then what's it even doing on the matrix? Isn't that just a waste of energy, deciding where to put the philanthropy dot? And if the currency is dots, is philanthropy the only dot that is loooooooow priority? I could think of a whole load of additional issues that might have come up in a materiality discussion that are not on this matrix. The point is, selection of the top ten prioirities is great. Using these materiality priorities to define strategy is fantastic, and structuring your reporting around these material priorities is brilliant. Hershey does this fairly well.

But taking that to the point of plotting dots on a useless matrix is what I don't understand. Especially if no-one explains why these dots are where they are.

The GRI G4 guidelines does not require the presentation of material Aspects in a matrix. The reporting disclosure is:

The G4 guidance for determining what is material makes reference to defining thresholds for materiality and defining and documenting how the thresholds have been defined. The guidance also offers a matrix for presentation of material issues. But this is guidance... it's not a G4 requirement. In general, the companies that present materiality matrices define why issues are material but they do not make reference to the relative material priority of each dot on the matrix. So why bother with a matrix. Why not simply do what is asked: give a list.

Materiality and its importance were recently addressed by think-tank advisory firm SustainAbility. 

SustainAbility published an excellent paper on transparency and its use as a driver for improved performance. SustainAbility says: "Most companies are not gaining the value commensurate with the resources spent on reporting." This is a proposition that I wholly agree with, for many reasons. (Haha - you can see that from my red text). SustainAbility's response to this is to use materiality to drive the rest. 

The SustainAbility paper provides two examples of materiality presented in reports: PG&E and Fibria. 

The PG&E Sustainability Report for 2013 presents a materiality matrix in a pretty familiar way - using dots. (SustainAbility helped PG&E create this matrix.) It has an element not usually found in materiality matrices: the addition of arrows showing the interrelation of issues. The online presentation of the matrix is interactive - when you click on an issue, it turns blue and a number of little orange dots show up connecting things to the blue dot, as in the version shown below. No connection between Public Safety and Employee Engagement, for example. Seems rather odd to me. However, SustainAbility writes in their report that highlighting interconnectivity between issues "provided insight into how PG&E might approach issues in a more integrated way." Intuitively, that sounds sensible to me. Although, if I were to be truly provocative, I would say that pretty much everything is connected to pretty much everything.   

In the PG&E matrix, however, we again we have a nicely arranged set of dots. It is not clear, based on the description of the process, what criteria were used to actually decide where each dot should be carefully placed. On what basis do you assess the scale of business impact? Is this an opinion based assessment or a fact-based analysis? Interestingly, PG&E states that: "PG&E’s materiality assessment identified 18 issues. Every issue is material to PG&E’s long-term sustainability, regardless of its placement on the matrix." Sounds to me that there is no need for a matrix. The real value of the process was the engagement benefit. See this quote from the Corporate Sustainability Director.

The Fibria 2013 Sustainability Report, on the other hand, uses the list method. Isn't this super-clear? Ten key issues, all equally important, all top priority. Businesses are complex things. It's OK to have more than one top priority. 

For those of you who like a little more detail and to know where things fit, Fibria provides an infographic: 

However, the plain, no-dots list of material issues, and its use in defining strategy and reporting is.... for me.. the way to go. I like the list. I don't like the meaningless matrix.

In addition to the list of top priorities, for completeness, companies may also select to indicate other topics that are on the radar, but not considered to be most material. This could be another (not too long) list. All attempts at creating flurries of dots is simply a waste of energy.

So here's to a great 2015 and clear, focused, material reporting.
Down with the matrix.
Up with the list. 

elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Author of Understanding G4: the Concise guide to Next Generation Sustainability Reporting  AND  Sustainability Reporting for SMEs: Competitive Advantage Through Transparency AND CSR for HR: A necessary partnership for advancing responsible business practices . Contact me via Twitter (@elainecohen)  or via my business website www.b-yond.biz   (Beyond Business Ltd, an inspired CSR consulting and Sustainability Reporting firm).  Need help writing YOUR Top Ten Report in 2015? Contact Elaine: info@b-yond.biz   

Hershey's real real CSR report

Christine Arena, CEO of SparkUp and great CSR author, blogger and #CSR Debate moderator, made me aware on Twitter of the "real" Hershey report. And that is well worth a blop (= blog post for those not used to my lingo. Yet).

Let's set the scene:

First, Hershey, with great fanfare, published their first ever CSR Report (GRI Level C). This is the real report. This report, as might be expected, presents Hershey's strong commitment to Corporate Social Responsibility in all aspects of its operations, including management of the Hersey supply chain and cocoa sourcing.

Second, a group of activists and campaigners for human rights including Global Exchange,  Green America, The International Labor Rights Forum and Oasis USA  published a mock CSR report attacking Hershey for human rights abuses in the production of cocoa. This is the real "real" report. In this report, the campaigners focus primarily on what they allege to be forced labor, child labor and trafficking  in the Hershey supply chain, greenwashing regarding charitable and community activities in West Africa which mask the underlying human rights problems and urge Hershey to increase transparency and adopt full sourcing of Fair Trade Certified (TM) Cocoa. 

So which is the real real real report ?

First a look at both reports and then some perspectives of my own.

The real report

The report published by Hershey confirms that the Company is no stranger to CSR, in fact the story goes that when Milton S. Hershey started the firm that would become The Hershey Company in 1984, he conducted his business according to the following principles:

**  make and sell a high-quality product at a fair price

**  provide meaningful work and fair wages to employees

**  give back to the communities where the company operated

**  be a good steward of the land and its resources

The Hershey report follows the Quadrant Model (marketplace, workplace, environment and community) and, despite no evidence of materiality thinking and proiritization, the key headlines are covered in greater or lesser detail. These include promoting responsible consumption of snacks and treats as part of a healthy lifestyle (really?), supplier diversity, nutrition labelling and nutrition research (how many phytonutrients in your daily diet, hmm?), promoting health and fitness, marketing with integrity, plus all the regular disclosures and case studies relating to environmental stewardship, repsonsible workplace and community contribution. There is a two page section on "Addressing the Challenges in Sourcing Cocoa" which reconfirms Hershey's commitment to  "embrace our responsibility to ensure that the cocoa  we buy is grown and harvested in a sustainable manner. That means encouraging a cocoa supply chain that provides adequate incomes to small cocoa farmers, advances efforts to promote responsible labor in cocoa-farming communities, promotes gender equity and protects and preserves the environment." All in all, Hershey says, through their efforts in West Africa, "Hershey and its industry peers have made a positive impact on an estimated 500,000 farmers and their families—about 2.5 million people altogether."  There is no doubt that this is a good news report, very skillfully copywritten, designed to paint a very rosy picture of the Hershey Company. Its transparency is limited to the direct impacts that are non-controversial in terms of disclosure and the report is not assured. Nonetheless, it  does demonstrate a certain level of CSR commitment and practice, which cannot be denied.

The real real report

This report represents the "dark side" of Hershey's chocolate production and focuses on four key issues, alleging that:

First: In sourcing much of its cocoa from West Africa, Hershey does not have a system in place to ensure human rights abuses are eliminated.
Second: Hershey does not disclose its cocoa suppliers in West Africa, therefore making it difficult to monitor human rights issues.
Third: Hershey engages in greenwashing by reporting on charitable programs whilst masking underlying supply chain abuses
Fourth: Hershey does not adopt the Fair Trade Certification for Cocoa, "the strongest certification system available" for all but one of its chocolate products.

The report refers to a shareholder resolution submitted in 2006 to Hershey, that was rejected, to push Hershey into reviewing and reporting on supply chain sourcing and addresses why Hershey is purchasing from "the three companies,Archer Daniels Midland, Cargill, and Nestlé, which are involved in the ongoing lawsuit in US courts on child labor claims". Similarly, the alternative report looks at leading practices in cocoa sourcing and commitments by other manufacturers and shows how Hershey is lagging behind. Additionally, the report makes recommendations to Hershey for resolution of this issue through to the year 2022.

The real real real issues

So what should we make of all this?  Here are some thoughts:

Whether you are transparent or you are not transparent, you are transparent.
No company can hide from transparency. It's either forced or it's voluntary. In the same way that Gap Inc and Nike and others realised that the only way to gain benefit from transparency is to embrace it and work with it, so Hersheys, sooner or later, will have no option but to go this route. Whilst a first CSR report is a step in the right direction, transparency on the most material and critical issues cannot be avoided.

Don't cherry-pick at stakeholder engagement 
Hershey lists the stakeholders they engage with in their CSR report, which includes interest groups, NGO's and the World Cocoa Foundation (established in 2000, Hershey is a founding partner), but they don't drill down into the details of their engagement. The coalition of human rights activist groups who wrote the alternative report don't appear to rate this foundation, which focuses on good work without the same activist edge. In deciding whom to engage with, a company should not cherry-pick around who to talk to. If you do not engage with your strongest critics, you are at risk of them engaging you in a way you may not have anticipated. On the other hand, engaging with such critics may well provide a platform for your business to create new commercial opportunities and longer term sustainability.

Communications should be balanced
Both the real report, which is good news, and the real real report, which is bad news, are guilty of imbalance in communications. Both tell one story only. The one which advances their agenda. And let's make no mistake. The profit agenda of a corporation and the non-profit agenda of NGO's are also driven by people with personal interests and much to gain, one way or another. This approach to one-dimentional reporting undermines the crediblity of both players in this sad scenario.

Convert words into action
There is no doubt in my mind that, even if Hershey people have an adequate defense to the allegations in the real real report, they must respond and disclose an action pan to address the issues raised. Whether or not everything is true, or not, there is surely something that Hershey can accept as a way forward. I don't believe that Hershey can maintain a credible  CSR positioning without doing this. The first response should be a public invitation to the real real report authors to meet with Hershey leadership and table all issues at a facilitated conversation in open and positive spirit. Wow. That' s a conversation I would be happy to facilitate!

This story reminds me of two other anecdotes:

The story of the Hershey Trust decision to sell the Hershey Foods Company to the highest bidder, which was recounted by Andy Savitz in his book, The Triple Bottom Line. The story is amazing and shows how Hershey blundered through a process that caused stakeholder uprisings and ultimately had to back down, "squandering valuable social capital". Hmm. A lesson not learned, it seems.

The story of Starbucks and the Ethopian coffee farmers, which was the subject of an Oxfam led  campaign, which went pretty viral with people from all over the world posting videos in support of Ethiopian farmers, eventaually forcing Starbucks to give in. Starbucks did, and went on to build stronger reciprocally positive relationships with Ethiopian coffee farmers. A lesson learned, apparently.

Seems like Hershey has a knack for doing things the hard way. At least, as I have a few (ok, a lot of) pounds to shed, I wont have to ponder the issue of whether to eat Hershey's chocolate or not, for the time being. I will be watching for Hershey's to respond, however. Hopefully they will do so before my diet turns once again, into the tomorrow diet. Haha.

(Oh, and in case you are wondering, I did write directly to Hershey with my queries about this issue. I hope they have something to say).

elaine cohen, CSR consultant, Sustainabilty Reporter, HR Professional, Ice Cream Addict, author of CSR for HR: A necessary partnership for advancing responsible business practices.  Contact me via www.twitter.com/elainecohen  on Twitter or via my business website www.b-yond.biz/en  (BeyondBusiness, an inspired CSR consulting and Sustainability Reporting firm)