GRI: SASB: The Sector Specificity Question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Here's another report. Apache Corporation 2018 Sustainability Report

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

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

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

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

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

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

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

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

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

Should we count that as six frameworks?

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

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

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

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

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

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

And my three answers:

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

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

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

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

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

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


elaine cohen, CSR consultant, Sustainability Reporter, HR Professional, Ice Cream Addict. Owner/Manager of Beyond Business Ltd, an inspired Sustainability Strategy and Reporting firm having supported 100 client reports to date; author of three books and several chapters on Sustainability Reporting and the Human Resources connection to CSR; frequent chair and speaker at sustainability events and judge in several sustainability awards programs each year. Contact me via Twitter , LinkedIn or via Beyond Business     

10 Sustainability Insights from the Oil and Gas Industry

I have often said that business is done in sectors. A sector-based approach offers a platform for developing a shared appreciation of sustainability opportunities, risks, benefits and challenges while providing leverage for change and a support network for non-competitive knowledge sharing. Last month, I was delighted to engage with the Oil and Gas Industry for a day of working together all about sustainability reporting. I was able to share insights, recommendations and an external perspective while gaining a deeper understanding of the constraints and considerations that reporting specialists share in the large, complex, established companies in this industry, most of which have been reporting for years. For me, this was both an enriching experience and an opportunity to help. 

My reporting day was hosted as part of an annual meeting of members of IPIECA - the global oil and gas industry association for environmental and social issues. IPIECA was formed in 1974 following the launch of the United Nations Environment Programme (UNEP). IPIECA is the only global association involving both the upstream and downstream oil and gas industry on environmental and social issues. IPIECA’s membership covers over half of the world’s oil production. 

The core of IPIECA's mission and practical agenda is the development of the sector as a social and environmentally responsible player. IPIECA's most recent publication a couple of months ago was the Third Edition of Sustainability Reporting Guidance for the Oil and Gas Industry to help companies report across the industry's most common sustainability issues in a consistent way and in line with shared stakeholder expectations.

The 180 page volume of guidance draws on several years of reporting experience in the sector and external independent stakeholder input. It covers both the reporting process (and principles) and reporting guidance including what's material for Oil and Gas. The principles are simply stated: relevance, transparency, consistency, completeness and accuracy.

The IPIECA guidance also suggests a set of the most significant issues commonly associated with the oil and gas industry, broadly referring to types of sustainability aspects, including risks, impacts and benefits, related to the life cycle and value chain of a company’s activities.

The IPIECA reporting guidance suggests a list of 34 performance indicators that are likely to be relevant to companies reporting in this sector. Fairly straightforward - 11 greenie ones, 5 health and safety, and 18 across workplace and community.  

But then... the reporting guidance makes a distinction between three types of reporting elements: the common ones... that means, essentially, there's no point in producing a report unless you include these; the supplemental ones, that means, basically, a good selection of your peers probably already report so you should consider including if you want to be at the top of the game and finally, others. Others is what differentiates you.

And here is an example I prepared earlier:

So E1 - greenhouse gas emissions - actually becomes 10 separate indicators, some of which are very specifically tailored to the oil and gas industry. Ultimately, it's not so different from the GRI approach, where performance indicators are grouped into categories and aspects. IPIECA has selected 34 aspects for its member reporters - GRI G4 as you may recall has 46 aspects. Many companies in this sector choose to report GRI as well as being guided by IPIECA, and a cross-reference of the different performance indicators in each framework is provided.

The IPIECA approach makes for a simple and straightforward content index - see this one in Chevron's 2014 report - it is somewhat less cumbersome than a full GRI Content Index as the sub-indicators - the different reporting elements - are not identified in the index.

I think it's a great thing that a sector proactively provides guidance and comprehensive tools for the member companies. It's more than just guidance - it's a demonstration of accountability for driving the sector forward with a shared expectation around sustainability practice and transparency. The value of the debate in developing the framework, the value of the learning in applying the reporting guidance and the value of reviewing the challenges of reporting are immense. That's how it seemed to me in my working day with many companies from the Oil and Gas industry, including sustainability reporting representatives of BG Group, BP, Chevron, ConocoPhillips, ExxonMobil, Hess Corporation, Marathon Oil, Noble Energy, OMV, Repsol, Shell, Statoil, Total and Tullow Oil.

In our workshop day, we discussed three aspects of reporting that are always fascinating:

• planning the reporting process
• defining and reporting materiality
• reporting climate change

And while I am not able to disclose the details of the discussions that took place throughout the day, I did receive permission to share a small selection of the closing insights that the 25 or so people in the room shared at the end of the day. 

10: Prioritizing material issues: Care needs to be taken when prioritizing material issues - it's not always as straightforward as it might seem. Overly mechanical formulas or highly detailed positioning of issues on a matrix may not be as valuable as the time invested. Not every material issue is more or less important than other issues. Sometimes they are the same. There also needs to be a balance in reporting to ensure that issues that are not identified as most material are not completely omitted as some stakeholders may require these.

9: Additional resources: You don't have to cram everything into your report. In some cases, supplementary content can be added as an appendix or a web-page. Not everything needs to be upfront narrative.

8: Less is more:  (ha ha, no further comment)

7: Tighten the timeline: In the oil and gas industry, companies are very large and complex and global data collection takes the time that it takes. Often this, together with other reporting considerations, can drag out the reporting timeline across several months - in a survey of IPIECA member companies before the workshop, we discovered that the average reporting cycle was more than 8 months. If you are reporting annually, this doesn't leave too much time to go to the beach. I am pretty clear on this. Any report that takes more than 6 months to prepare from concept to publication is taking too long. And that's generous. While there are often practical considerations that delay the publication of the report, the more you can compact the timeline, the more time you have for making progress rather than making reporting.

6: Give up the search for the perfect formula: This is so true. In preparation for my work with the sector, I reviewed 15 Oil and Gas Sustainability Reports from 2014. Despite the fact that all these companies are in the same industry, the reports all have their individual character, style, tone and content focus. Each company is at a different stage of development along the sustainability journey. So, while I was able to share insights on the different ways of defining, prioritizing and presenting material issues, and participants took away new ideas, one size does not fit all and there is absolutely no perfect reporting formula for all organizations, only one for each organization.

5: Balance the broad and the narrow: It's important to find a middle ground between reporting at a broad level about complex issues versus increasing the resolution to report at a more granular level on specific issues. How do you represent that your overall carbon footprint reduction is made up of a thousand small actions and impacts, and which of those, if any, are worth highlighting? This is something worth thinking about as you plan your report process and content.

4: Get the design right: Everyone would agree that content precedes design. If you don't have relevant content, even the best of designers will fail to make your report credible. Yet, getting the design right for your corporate culture and sustainability content can make the report come alive in ways that words alone cannot. Careful use of infographics, any photography other than stock photography and controlled use of colors, fonts and styles will only improve the appeal and readability of your report.

3: Stakeholders were not all born equal: Don't let individual stakeholder groups dominate your content and do map and prioritize your stakeholders in advance and decide what you need from them and how you will represent their voices in your report. Giving stakeholders a voice - letting them tell your story - is often a proven route to credibility.

2: Link materiality to metrics: How many reports, especially with the fuller adoption of G4, now include a materiality matrix or list of material impacts. Yes, most or all. How many create a clear linkage (I call this the "materiality audit trail") between what's stated as material and all the rest of the report content - performance indicators, case studies, policy narrative etc? Oops. Rather few. So often, there is a gaping dissonance between what the report says it should be about and what it actually includes. But getting this alignment is not enough. The report user should be able to easily and quickly find the link between material impact and reporting content about that impact. I generally apply the "ten-minute rule" - if I can't find something after ten minutes of trying, for me, it doesn't exist. We have to make the link between materiality, content and metrics both available and quick to locate.

1: Have confidence: It's tempting to get derailed in reporting - there are so many frameworks, guidelines and complex rules and requirements that you can spend forever questioning yourself on the right way to go and the best way to pull it all together. But this can lead to a spiral of indecision that can delay the report process and dilute the content. Often the best way is simply to make your selection of how to frame and develop your report, and then have confidence in your approach and make it happen. No-one knows what you might have done. Everyone sees what you do. Best feel good about it and present it with pride. There are no bad Sustainability Reports. There are only Sustainability Reports that can help us improve our sustainability performance and disclosure. Each report is a learning platform, but it's also an achievement to be proud of.


And one more insight from me:

Even though we didn't have ice cream throughout this day-long meeting :-), it was one of the best sustainability days I have had in a while: a dialogue with like-minded professionals who are eager to do their honest best for their company, society and planet. I didn't even miss the ice cream!

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 first / next Sustainability Report? Contact elaine: info@b-yond.biz  

BP: Back in the Picture

In the world of sustainability, there are some names that evoke a range of strong emotions and reactions and I suspect that BP is one of them. BP has had some extremely interesting sustainability successes, and also, at least one devastating low point. You don't even have to mention the company name: just refer to Gulf of Mexico, Macondo, Deepwater Horizon, I want my life back - there are a million ways to say BP and most of them are not exactly positive. But if you stand back from the oil spill disaster of 2010, and accept that we are still and will continue to be reliant upon fossil fuels as our main source of energy for some time into the future, and take a look at what BP is doing today with a pair of fresh eyes, you may be encouragingly impressed. As I was.  

I was doing my homework in preparation for a conversation  with Louise Tyson, Head of Corporate Reporting at BP (that's both financial and sustainability reporting). Louise will be sharing her insights on "Giving your report complete clarity & readability" at the Smarter Sustainability Reporting Conference in London in February 2015 (still time to register :)). As usual, as the conference chair, I like to chat with speakers in the run-up to the conference. Ahead of our call, I navigated to BP's sustainability and reporting site after what I confess to several years of not paying close attention. I was pleasantly surprised. 

BP is an employer of 83,000 people, a strong contributor to the global economy and a long-standing sustainability reporter addressing serious issues in detail in its reporting suite. BP has various reports and formats to meet different stakeholder information needs. This year's suite includes:

A Sustainability Review for 2013 in PDF format
Several country reports for 2013 including Angola, Azerbaijan and more
Site reports from different local operations
A report archive with reports in different languages and reports dating back to 1998
An economic impact report for BP's operations in the U.S.
A super-snazzy Health, Safety and Environment charting tool that enables you to play around endlessly to review 25 years of data in different visual formats.

And my chat with Louise Tyson:

How did you get into the reporting role at BP? 

"Actually, my background is not in reporting. I was in magazine publishing for ten years and then worked in online communications. I was a consultant to BP one year, putting their sustainability report online. That was my introduction to sustainability, around seven or eight years ago. BP later hired me as the Sustainability Reporting Manager. My first report was published five days before the Gulf of Mexico incident."    

How did you move from sustainability reporting to corporate reporting? 

"I realized that our financial and sustainability reporting often cover the same issues - such as climate change and human rights – and that we should be talking about them in the same voice, even if the reporting focus and purpose is different. So, when I was promoted to the head of corporate reporting role, I knew there was an opportunity to encourage more accessible language and consistency across all of our reporting It's turned out to be a really interesting challenge. But if you had asked me if I had ever imagined that I would be doing what I am doing today, I'd probably never have guessed."  

How has BP's reporting changed over the years? 

"For many years, BP was recognized as a leader in sustainability reporting. We would win reporting awards and we were generally considered as innovative in our approach. After the Gulf of Mexico incident, things changed, of course. It became even more important that we report transparently, factually, credibly and in a balanced way – responding to the disappointment and anger of many of our stakeholders. It was very tough. We needed to provide a balanced view, clearly communicating what had happened and how we were responding. And, it was essential that our communication didn’t show up as green-washing. Over time, things have rebalanced somewhat and now most of our stakeholders are asking us much the same questions that they would ask of any large oil and gas player." 

Your reporting is so detailed and includes a wide range of local and site-specific reports. How do you manage your reporting cycle? 

"We launch our sustainability report in March, and we immediately begin on the next year’s report by getting feedback from external stakeholders on how they think we’ve covered the material issues. Over the summer, we work with representatives from our policy, risk, government and public affairs, and environmental and social teams, to pull together and prioritize a list of the most important topics. This is really powerful because it offers a broad perspective on the issues and where we are and what we should be doing. From September to December, we work on the report draft and present it to the board committee focused on sustainability issues. We then spend the first part of the year incorporating all feedback before publication."

What's the policy on country reports? 

"Country reports are developed locally by the local businesses. They decide whether they want to publish a local report. For some, it's extremely helpful as an engagement tool. We do not dictate a policy at corporate level, though we do provide a framework for local reporting, for those countries that adopt this practice. We provide positioning on group issues and other guidance. We also review the reports at corporate level before publication, to ensure there is alignment around common issues and approaches. Site reports can be very relevant to the detailed discussion at local level with local stakeholders. In general, countries and sites that report do so as a response to local demand and interest. In Azerbaijan and Angola, for example, we know this is helpful in maintaining positive relations with local institutions and government offices."

I am looking forward to hearing Louise sharing more insights at the Smarter Sustainability Reporting Conference next month. 

P.S.

I couldn't resist taking a look at BP's first Environmental and Social Report for 1998, at a time when there was no GRI, no other reporting frameworks and hardly any other companies that even acknowledged the value of transparency, let alone actually put a report together.

It's fascinating to see how advanced this BP report was for its time, and of course, compare it to the latest the 2013 review. They are both 52-53 pages in length, so that's one thing that hasn't changed. Surprisingly perhaps, given the dynamic evolution of reporting and the advances in reporting practice over the years, the pioneering 1998 report has many elements that are still very relevant today.  

The 1998 report contains:

• policies, approaches and commitments - good old DMAs in GRI lingo
• a range of environmental and social data dating back to 1990 in some cases , or later years when data collection commenced - demonstrating continuity and consistency
• a 20 year GHG emissions reduction target - 10% from 1990 to 2010
• several case studies covering different aspects of BP's operations in different parts of the world, supplemented with external commentaries developed through a process of interviews with local stakeholders by an independent consultancy - a precursor to what would today be called "stakeholder engagement"
• an "attestation statement" - external verification and a precursor to what has become known as "assurance"
• a questionnaire with a pre-paid postage form requesting feedback on the report. 

Looking at the BP 2013 Sustainability Review, you can see evidence of the transformation reporting has made over the years. The discussion is far more strategic and much greater context and depth is provided. The upstream-downstream business model demonstrates a higher level of value chain thinking, and the report is far more quantitative, focused and formal. The GRI, IPIECA and UNGC frameworks and principles help structure the disclosures and the metrics. New issues such as fracking and oil sands are explained and BP's approach is described (these issues were not around in the 1998 report). 

In the 1998 report, especially when compared to today's document, there is a sense of almost naive authenticity in a sort of clumsy but trust-building way. 2013's report is far more polished, and while it is direct and balanced, I wonder if recapturing something of the early-day spirit might be an interesting thought for BP and other companies to enhance credibility. To give you a sense of this, here are a few "gems" from the 1998 report:

"Our success depends on our making, and being seen to make, a distinctive contribution to every activity in which we are involved." 

"Ours is an evolving, rather than predetermined or overly bureaucratic, approach. We know that for high standards of ethical and social behaviour to thrive as part of our culture they must be felt and understood by our people. It is more important for it to be in the bloodstream than in a set of manuals."

"Diversity in internal teams (now the norm) is highly valued as it has been seen to result in more creative solutions."

"We wanted this year’s report to include more than just the ‘official’ views of the company."

"Questions of business ethics are often not clear-cut and cannot be resolved by rules alone. With this in mind, during 1998 we revised our Guidelines on Business Conduct, which provide guidance on ethical issues to anyone who has custodianship of the company’s assets or commercial relationships."

"To mark the 50th anniversary of the Universal Declaration of Human Rights we launched a human rights page on our internet site..."

"Our social impacts can range from positive ones, such as the creation of jobs and prosperity, to less welcome ones, such as fuelling unrealistic employment expectations, exacerbating existing or latent conflicts and disrupting settled ways of life."

Anyway, that nostalgic look at the early days of reporting has given me a new sense of respect for BP and its consistent, ongoing investment in transparency. This doesn't make BP perfect and it doesn't mean that BP should not continue to be held accountable for its far-reaching impacts on society and the environment in all that it does. But, especially after my conversation with Louise Tyson, I am more ready to believe that there is earnest intention behind the written words. 

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 next Sustainability Report ? Contact Elaine: info@b-yond.biz