Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands
gssbsecretariat@globalreporting.org

Item 04 – GRI Sector Standards
Project for Oil, Gas, and Coal - Draft
Basis for Conclusions for GRI 12:

Coal Sector 2022
For GSSB review
Date

20 January 2022

Meeting

10 February 2022

Project

Sector Standard Project for Coal

Description

This document summarizes the significant issues from comments received on the
exposure draft of the Coal Sector Standard, during the public comment period
from 19 May to 30 July 2021. It also outlines the draft GSSB responses to thesignificant issues based on Working Group discussions and recommendations.
As outlined in the Due Process Protocol, this document is not subject to GSSB
approval, it does not constitute part of the final Standard, and is non-authoritative.
The draft is circulated for review and feedback. This draft document will be
updated, as needed, following the GSSB approval of GRI 12: Coal Sector 2022.
The full set of comments can be downloaded from the project page on the GSSB
website.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2022

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Contents
About this document ................................................................................................................................4
Introduction ..............................................................................................................................................4
Objectives for the development of GRI 12: Coal Sector 2022 .............................................................4
Scope of the public comment ..............................................................................................................4
Overview of submissions......................................................................................................................5
Methodology for analyzing comments .................................................................................................5
Significant issues and GSSB responses .................................................................................................6
Cross-cutting issues .........................................................................................................................6
Issues related to likely material topics ..............................................................................................9
Appendix 1. Questionnaire questions ....................................................................................................18
Appendix 2. Public comment submissions by stakeholder constituency and region ............................19
Appendix 3. Participation in regional events and webinars ...................................................................20

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About this document
12This document summarizes the significant issues from comments received on the exposure draft of
the Coal Sector Standard during the public comment period (PCP) from 19 May 2021 to 31 July 2021.

3
4

Contents of this document comprise feedback received through the formal public comment form on
the GSSB website and, where relevant, comments made in stakeholder workshops during the PCP.

5
6
7

All significant comments, together with an analysis of the issues raised, were considered by membersof the Oil, Gas, and Coal Working Group. The recommendations of the working group were sharedwith the Global Sustainability Standards Board (GSSB) for review and approval.

89This document provides a summary of the GSSB responses to the significant issues raised during the
public comment period.

10

The full set of received comments can be downloaded from the project page.

11

GRI 12: Coal Sector 2022 can be downloaded [here].

12

Introduction

13

Objectives for the development of GRI 12: Coal Sector 2022

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15
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The GSSB initiated the GRI Sector Program in 2018 to develop standards that are specific to certain
sectors and focus sustainability reporting on the impacts that matter most. The project proposal for
Oil, Gas, and Coal, was approved in March 2020 by the Global Sustainability Standards Board(GSSB), GRI’s independent standard setting body.

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The working group for Oil, Gas, and Coal was formed in June 2019, in accordance with the GSSB
Due Process Protocol.

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The project’s primary objective was to develop a Sector Standard that identifies and describes the Oil,Gas, and Coal sectors’ significant impacts and stakeholder expectations from a sustainable
development perspective and provide evidence and authoritative references for these impacts. In
addition, disclosure gaps not sufficiently covered by existing GRI Standards were identified andadditional sector reporting that supplements GRI disclosures have been developed for information
essential to understanding the sector’s impacts.

26
27
28

The working group had the mandate to recommend changes to the project scope. Following
feedback, the working group recommended separating oil and gas from coal, which the GSSB
approved in April 2020. GRI 11: Oil and Gas 2021 was published in October 2021.

29

GRI 12: Coal Sector 2022 was developed in line with the GSSB Due Process Protocol.

30

GRI 12 was approved by the GSSB on [XXX] and released on [XXX].

31

Scope of the public comment

32
33

The public comment period for the GRI Coal Sector Standard exposure draft ran from 19 May to 30
July 2021.

34
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36

Respondents were asked to provide input on whether the draft Standard covered the most significant
impacts of the coal sector and if the proposed disclosures allowed for meaningful reporting on these
impacts.

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A range of outreach activities were carried out to raise awareness of the public consultation, including
campaigns, webinars, and one-on-one sessions, targeting key regions and constituencies. Three
webinars were aimed at global audiences, each catering to different time zones ranging from the
Pacific coast of North America to Europe, Africa, Asia, and Oceania. Targeted sessions were also

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focused on relevant regions to coal mining in China, India, Indonesia, Latin America, and South
Africa. The webinars attracted approximately 220 participants.

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45

Though not regarded as official submissions, comments collected during live consultations were also
considered in cases where they aided in understanding or further expanded on official submissions orraised a significant issue that did not emerge from the official submissions.

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Any comments outside the scope of development of GRI 12 will be compiled and directed to theappropriate team or project for consideration. The development of Sector Standards also feeds into
the enhancement and expansion of the GRI Standards by surfacing issues not previously covered.
Feedback on Topic Standards [link to be added] has been collated separately for consideration by the
GSSB.

51

Overview of submissions

52
53
54

Respondents were able to submit comments on the exposure draft using an online questionnaire,
which was available on the coal project page (see Appendix 1 for the full list of questions).
Respondents could also submit additional feedback via email to sector@globalreporting.org.

55

A total of 29 submissions were received from individuals and organizations on the exposure draft.

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Four additional submissions were received but not accompanied by permission to make them public
as required by the GSSB Due Process Protocol. These submissions were considered, along with the
feedback gathered during the stakeholder engagement activities.

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The submissions came from all five stakeholder constituencies represented by the GSSB: businessenterprises, civil society organizations, investment institutions, labor, and mediating institutions.

61

For more detail, see:62•

The full set of received comments, available to download from the coal project page.

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64

•

Appendix 2 for a breakdown of public comment submissions by representation, stakeholder
constituency, and region.

65

Methodology for analyzing comments

66

All comments submitted by respondents were collated and analyzed by the GRI Standards Division.

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Each comment was categorized according to its relevance to a likely material topic, section,
disclosure, or cross-cutting theme. When a respondent raised several different points in one
comment, the points were separated into distinct comments.

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The qualifiers in Table 1 indicate the percentage of respondents who provided feedback on
a significant issue. Because the survey asked mostly open questions to encourage respondents toprovide feedback on sections of interest to themselves, not all respondents provided comments on all
sections of the exposure draft. Consequently, most comments made to specific topics or disclosurespresented below as significant issues were made by a single respondent.

75

Table 1. Qualifiers indicating the percentage of respondents who provided feedback
QualifierRespondents

Majority> 50 %

Many

30-50%

Some

10-30%A few< 10 %

One

1

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Significant issues and GSSB
responses

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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents during the public comment period, outlines proposed changes to the Coal Sector
Standard exposure draft, and explains why changes suggested by respondents were or were notaccepted by the GSSB.

82

Notes for the reader:

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Only topics for which significant issues were identified have been included in this document. It
includes references to the exposure draft of the Coal Sector Standard and the final version of GRI 12:
Coal Sector 2021. When referring to the content in the exposure draft, the same names of thesections and topics are used.

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Feedback relating to the general concept or format of the Sector Standards, the GRI Topic Standards,
and the GRI Glossary is not included in this document unless necessary to understand othercomments or proposed changes. Nor does the document include minor editorial comments, whichwere considered and implemented directly by the Standards Division.

91

Cross-cutting issues

92a) List of likely material topics for the coal sector

93
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95

The majority of respondents confirmed that the exposure draft was representative of the coal sector’s
most significant impacts, and business organizations considered it useful for identifying topics likely to
be material for them.

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98
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100

No clear objections were raised to any topic included in the exposure draft as likely to be material forthe sector as a whole, but a few respondents indicated that some topics were not considered material
to organizations in their geographical context. Examples of such topics include child labor, forcedlabor, and modern slavery. In addition, a couple of Chinese coal organizations suggested that climatechange would not be material for them.

101

Individual respondents suggested including the following additional topics as likely to be material:

76

102
103
104
105
106

•
•
•
•
•

Corporate governanceLand or mine rehabilitation
Product stewardship
Supplier management
Technology and innovation

107

GSSB response:

108
109
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111
112
113
114
115
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117

GRI 12 includes topics likely to be material for most organizations in the coal sector based on the
sector’s impacts. Some topics, such as topic 12.1 GHG emissions and 12.2 Climate adaptation,
resilience, and transition, are considered relevant on the basis of the sector’s contribution to a global
issue of climate change, while others may be more contingent on the unique context of eachorganization. For example, child or forced labor is well regulated in many areas, and while there isevidence of such human rights violations taking place in the coal supply chain in several countries,
the materiality of the topic may be subject to the location of the organization’s operations. If a topic
included as likely material in a Sector Standard is not material for an organization, it does not need toreport on it. See Requirement 6 in GRI 1: Foundation 2021 for more information on reasons foromission.

118
119

The additional topics suggested were considered to be sufficiently covered by existing reporting or
were not likely to be material for most organizations in the coal sector.

120
121

Corporate governance related information is required to report GRI 2: General Disclosures 2021.
Land or mine rehabilitation’ is included in topic 12.3 Closure and rehabilitation.

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Information on technology and innovation and supplier management should be reported as part of any
material topic they are relevant to (for example, water efficiency innovations can be reported in thecontext of topic 12.7 Water and effluents).

125
126
127

Product stewardship efforts can be reported using GRI 416: Customer Health and Safety 2016, which
addresses ‘an organization’s systematic efforts to address health and safety across the life cycle of a
product or service’ if material to an individual company.

128
129

b) Reporting burden

130
131
132
133

A few respondents raised concerns over reporting burden posed by the number of likely material
topics, which might be a barrier, especially for small and medium-sized companies. It was suggested
that some topics be eliminated or prioritized based on location, regulatory requirements, type ofmining, size of company, or other key qualifiers.

134

GSSB response:

135
136
137
138
139
140
141

The GRI Sector Standard for coal is intended for organizations of all sizes undertaking activities listed
in the section “Sector activities and business relationships”. The likely material topics are likewise
intended to cover the sector’s significant impacts as a whole. While organizations might determine alllisted likely material topics as material for them or even report additional topics as needed, if smallorganizations’ significant impacts are fewer, they may report on fewer topics. Similarly, should theorganization determine a topic as material, but one or more of the listed disclosures are not relevantto the organization’s impacts, the organization is not required to report these.

142c) Positive/negative bias

143
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147
148
149

The majority of respondents agreed that the draft Standard provides a balanced view of thesustainable development challenges faced by the coal sector. There were two notable exceptions:
one representative from a mediating institution felt strongly that the draft Standard does not place
enough emphasis on the sector’s negative impacts, enabling greenwashing. On the opposite end, one
business representative voiced a view that the Standard portrays a strong negative bias towards thesector, focusing too much on climate change and failing to emphasize the value brought by thesector’s products.

150

GSSB response:

151
152
153
154
155
156
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158

A Sector Standard outlines the significant impacts of a given sector, which can be negative or
positive. GRI 12 aims to balance the context and information needs of stakeholders of coalorganizations in different contexts. For example, the coal phase-out may have different timelines indifferent parts of the world – with many developing countries continuing to use coal longer thandeveloped countries. For organizations in countries that are well underway in their transition, thereporting may focus on aspects such as closure and just transition. For other coal organizations incountries planning to achieve net zero later, reporting on the impacts of day-to-day operations might
be most relevant.

159
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165

In relation to the focus on climate change, the role of coal in causing climate change is wellunderstood and scientifically proven. Leading bodies such as the Intergovernmental Panel on Climate
Change (IPCC) and International Energy Agency (IEA) call for a rapid end to coal use to maintain anarrow possibility to halt global warming to 1.5°C.1 Furthermore, close to 200 countries havecommitted to phase-down coal use in power generation. 2 The focus on this aspect in the sustainability
context is thus considered reflective of the current environment and critical for the dialogue ofreporting organizations and information users.

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167

The comments on positive bias are related to a section mentioning the sector’s contribution to jobs,
growth, and energy independence, which are also relevant impacts for the sector. However, as the

1

Intergovernmental Panel on Climate Change (IPCC), Climate Change 2021: The Physical Science Basis, 2021; International
Energy Agency (IEA), Phasing out unabated coal, 2021.
2

United Nations Framework Convention on Climate Change (UNFCCC), Glasgow Climate Pact, 2021.

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coal phase-down continues, the ability of the coal sector to contribute to the Sustainable Development
Goals may become more limited, which is now reflected in the text.

170d) Scope of the Standard and business relationships

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Scope of the Standard received wide approval. While commentary about the coal sector’s similarities
with mining was received, coal’s unique role with respect to climate change was also acknowledged,
justifying a self-standing Standard.

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177

One business representative contested the inclusion of metallurgical coal in this Standard, suggesting
it was too focused on thermal coal. According to the respondent, the sustainability context andmaterial topics relevant to thermal coal production used primarily for power generation differ fromthose relevant to metallurgical coal production used for steel manufacturing.

178

One submission proposed adding coal washery and coal bed methane as part of sector activities.

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182

The majority of respondents agreed that the business relationships singled out in the exposure draft
were the most relevant ones for the sector to identify significant impacts. Some new proposals to
include in the section included local governments and financiers providing loans to coal-related
projects.

183

GSSB response:

184
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186
187
188
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190

Impacts associated with thermal and metallurgical coal are only distinct in the end-use of theseprojects. The use of metallurgical coal or coking coal, primarily for steel production, has been added
to the sector profile and topic 12.1 GHG emissions. The steel sector accounts for approximately 20%
of industrial energy use and almost 10% of total energy use, of which 75% comes from coal. The steel
sector is among the largest producers of carbon dioxide3 and is actively looking for technologies toreplace coal in their processes to decrease or eliminate emissions. Hence, reporting on emissions
and transition to a low-carbon economy is highly relevant for metallurgical coal miners.

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Washing coal is part of the processing phase, already included in the Standard (Crushing, cleaning,and processing coal from unwanted materials). On the other hand, coal bed methane recovery is an
unconventional gas extraction method mostly associated with organizations in the oil and gas sector
and thus out of scope for GRI 12.

195
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201

Using the GRI Standards, an organization should consider the impacts of its own activities as well as
those of its business relationships when identifying its impacts and determining its material topics toreport. While local governments or capital providers are important business relationships for the coalsector, they are not likely to link coal organizations to additional negative impacts. The approach toengagement with any business relationship that is of particular importance to an organization can be
described in the context of Disclosure 2-29 Approach to stakeholder engagement in GRI 2: General
Disclosures 2021.

202e) Sustainability context

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206

One respondent proposed to highlight common economic problems associated with resource wealth,also known as the resource curse, and call out practices such as corruption and mismanagement in
the sector. Other individuals suggested adding emphasis on air pollution and its impacts oncommunities, as well as discussing carbon tax and carbon trading.

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The majority of respondents confirmed that the mapping of likely material topics to the UN
Sustainable Development Goals (SDGs) helps contextualize the sector’s activities in light of the global
sustainability agenda. A few companies found it hard to relate to some of the goals, and one
respondent believed the essence of the coal sector is opposed to the SDGs. Specific feedback wasgiven to a number of SDG linkages, including SDG Goal 8: Decent Work and Economic Growth,
namely, that underground mining is not decent work.

3

International Energy Agency (IEA), Iron and Steel Technology Roadmap, 2020, accessed 20 December 2021; McKinsey &Company, Decarbonization challenge for steel, 2020, accessed 20 December 2021.

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213

GSSB response:

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Negative economic impacts associated with the ‘resource curse’ as well as mismanagement andcorruption are relevant contextual issues for the coal sector, and discussions about these havesubsequently been included in the section.

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Air pollution is a major impact related to coal combustion, separate from climate change but notunrelated. Thus, the section acknowledges that mitigation of GHG emissions associated with coal use
would simultaneously reduce air pollution. More discussion about air pollution and its impacts oncommunities has been included in the topic 12.4 Air emissions.

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222

Carbon pricing has been included as one of the policy tools to curb GHG emissions, alongside air
pollution regulation and restrictions on public financing and subsidies for coal.

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The following are changes made to the mapping of the Sustainable Development Goals to the likely
material topics in GRI 12:
•

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236

•

•
•

Wording added on managing the sector’s workplace hazards (especially in undergroundmining) being a prerequisite for positive contributions towards SDG 8: Decent Work andEconomic Growth
Link from topic 12.3 Climate adaptation, resilience, and transition removed to SDG 9:
Industry, Innovation and Infrastructure, as there is insufficient evidence of the sector’s
contributions to widespread innovation that would provide solutions that address thechallenge of climate change
Links from topics 12.3 Closure and rehabilitation and 12.4 Air emissions added to SDG 12:
Responsible Consumption and Production due to their links to sustainable management andefficient use of natural resources and management of wastes.
Link from topic 12.22 Public policy to SDG 13: Climate Action added based on the sector’s
influence of public policy on climate change mitigation.

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Just transition

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The concept ‘just transition’ was not well understood, warranting clarification. A few comments weremade about considering the differing socioeconomic impacts, challenges, and timelines of the lowcarbon transition between developing and developed countries.

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GSSB response:

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The term ‘just transition’ has a history spanning over 30 years, and different actors in differingcontexts use it. This includes trade organizations to safeguard industry jobs lost as a result ofenvironmental protection policies, as well as the environmental justice movement advocating for theeradication of polluting industries to provide safe work and living environments for communities. GRI
12 draws on the definition of the term as used in the Paris Agreement and by the International Labor
Organization, which aims to consider environmental, social, and economic angles holistically and tofind solutions that benefit all and leave no one behind, in collaboration with governments, employers,
employees, and communities. 4 The passage explaining just transition has been clarified accordingly,
and the concept has been integrated into relevant topics, such as those dealing with mine closure,employment practices and worker rights, economic impacts on communities, and contract
transparency.

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The section ‘The sector and sustainable development’ was updated to highlight the individual
dependencies and national circumstances related to the low-carbon transition, acknowledging that thetransition timeline will differ between developing and developed countries.

256

Issues related to likely material topics

257

f)

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Some respondents expressed concerns about coal organizations being asked to report other indirect(Scope 3) GHG emissions from the use of sold products, as these emissions are not considered to be

GHG emissions

4

United Nations Framework Convention on Climate Change (UNFCCC), Paris Agreement, 2015; International Labour
Organization (ILO), ILO Guidelines for a just transition towards environmentally sustainable economies and societies for all,2015.

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within the organization’s control. It was suggested that mitigating Scope 3 emissions should involve
efforts from organizations along the entire value chain or that they are solely the responsibility of thecustomers using coal, such as organizations in electricity generation or steel production. On the other
hand, many stakeholders engaged through events were pleased to see the inclusion of Scope 3
emissions reporting, and one respondent called for more emphasis on these emissions in the topic
description. Accuracy, availability, and inconsistency of data were raised as potential issues, with afew calls to provide more guidance and a methodology for Scope 3 accounting.

267

GSSB response:

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Scope 3 emissions from the coal sector represent the single largest source of global CO2 emissions,and the expectation to report on them is becoming increasingly mainstream. Data availability andaccuracy can be a challenge, which requires engagement with business partners to acquire reliable
information. Disclosure 305-3 Other indirect (Scope 3) GHG emissions contains guidance on
disclosing Scope 3 emissions and links to further resources, as do the resources listed in GRI 12.
Reporting on Scope 3 emissions has been retained.

274g) Climate adaptation and resilience 5

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Topic 12.2 Climate adaptation, resilience, and transition was the most commented topic. The majorityof business constituency respondents confirmed that the disclosure expectations corresponded totheir current or expected reporting on climate change. Respondents categorized as information users
were almost unanimous in agreeing that the reporting included in the exposure draft reflected
expectations of public disclosure by coal organizations on climate change related impacts.

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Many respondents gave feedback on the additional sector disclosures, such as concerns overconfidentiality and challenges to disaggregate CapEx investment data, or difficulties in accounting on
reserves and potential emissions. It was also suggested to add more disclosures, including
information on transition plans; whether organizations are committed to sustainable product portfolios
or if they plan to expand coal mining operations; and disclosure on divesting coal assets, which was
identified as an increasingly common practice among multinational mining companies. It was also
proposed to supplement the disclosure of potential emissions from reserves with information on theownership structure of those reserves.

288

GSSB response:

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295

The forward-looking metrics on CapEx and potential emissions from reserves have been maintained.
Despite possible challenges, this information is considered essential to understanding the resilienceof a coal organization’s business model to climate-change related risks. In cases where information is
subject to confidential constraints, an organization may provide a reason for omission. Requirement 6
in GRI 1: Foundation 2021 contains more information on reasons for omission. The Coal Sector
Standard includes references to guidance on calculating and reporting potential emissions fromreserves.

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302

Transition planning has emerged as an expectation for organizations in GHG emissions-intensive
sectors. The existing additional sector recommendations in topic 12.2 Climate adaptation, resilience,and transition cover the elements of a ‘transition plan’,6 and supplemental information and resourceswere added to explain the concept of transition planning. An additional sector recommendation was
also included to report on the existence of a transition plan and whether it is a scheduled resolution
item at Annual General Meetings. This disclosure aligns with the CDP 2021 questionnaire for coalproducers.

303
304

To respond to information needs about coal organizations’ commitments to sustainable productportfolios or whether they intend to continue coal mining, the reporting section to report CapEx

5

The name of the topic has been revised in GRI 12 to ‘Climate adaptation, resilience, and transition’.

6

As outlined in Task Force on Climate-Related Financial Disclosure (TCFD), Guidance on Climate-related Metrics, Targets,
and Transition Plans, 2021.

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investments was supplemented with an extra point to solicit information about investments channeledinto the expansion of current mines.7

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321

Organizations divesting their coal assets to reduce the GHG emissions intensity of their productportfolios is an important emerging issue. This can be detrimental to broader climate change
mitigation efforts: shifting coal mining operations to another entity does not decrease global
emissions. It can also compromise responsible closure and a just transition if the responsibility ofeventual closure is transferred to a less experienced operator. In addition, many diversified mining
organizations divesting from coal are historically large contributors to climate change and thus have asignificant responsibility to solve the problem.8 Discussion on potential impacts has been included in
the topic, accompanied by reporting recommendations. This additional reporting asks whether theorganization’s commitments to responsible business conduct were considered when making thedivestment and whether and how the organization ensures that eventual closure is conducted
responsibly and following existing plans, addressing negative impacts on workers and communities.
While the reporting organization does not cause negative impacts that arise from actions of the new
operator, the organization may be considered as contributing or being directly linked to those impacts
with the responsibility to take due diligence steps, including exercising leverage over the buyer toprevent or mitigate the impacts it is causing or contributing to.

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327
328
329
330
331
332
333

The GRI Coal Sector Standard exposure draft included a disclosure in reporting potential emissions
from the organization’s proven and probable reserves. After alignment with GRI 11, the disclosure
specifies that an organization should use the same definition of reserves as in the organization’s
consolidated financial statements or equivalent documents. However, the concern was that thisapproach might leave a gap in reporting, as reporting reserves through ownership structures
presented in financial reporting may be limited to where companies maintain financial control.
Reporting potential emissions is an emerging field with few established or normative methodologies,
and no fossil fuel organizations are currently reporting on this. Some specialist organizations use theequity share approach as the organizational boundary for calculating potential emissions fromreserves, reflecting an organization’s economic interest, which typically aligns with the company’s
percentage ownership of that operation.9 The equity share approach is also mostly aligned withfinancial reporting. Thus, disclosure included in the exposure draft remains unchanged.

334h) Closure and rehabilitation

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Topic 12.3 Closure and rehabilitation was among the most commented on topics. The worker aspectof closure was considered adequately covered by the disclosures in the exposure draft.

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339

Some respondents called for reinforced disclosures on impacts on and engagement with
communities, specifically related to longer-term impacts on post-mining communities and efforts
towards establishing a sustainable post-mining economy.

340
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342

The additional sector disclosure to report the organization’s financial provisions for closure andrehabilitation received broad support but was highlighted by a business respondent as a potential
point of contention with communities and other local stakeholders.

343
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345

Individual respondents requested to add reporting, including on commitments to the rehabilitation ofmining sites; details on plans, policies, and strategies for environmental rehabilitation; andcompensation for communities from health effects or environmental liabilities.

346

GSSB response:

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348

From a local community perspective, a successful closure and rehabilitation can be achieved throughearly communication and inclusive planning.10 As part of the disclosure requirements of Disclosure 37

Other data points under this recommendation include CapEx investments into prospection, exploration, acquisition, anddevelopment of new reserves; energy from renewable sources; technologies to remove CO 2 from the atmosphere and naturebased solutions to mitigate climate change; and research and development initiatives that can address the organization’s risks
related to climate change.
8

UN Human Rights, A Safe Climate, 2019.

9

World Resources Institute (WRI) and World Business Council for Sustainable Development (WBCSD), GHG Protocol
Corporate Accounting and Reporting Standard, Revised Edition, 2004.
10 United Nations Development Programme (UNDP), Extracting Good Practices, 2018.

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3 Management of material topics, organizations are required to report how stakeholder engagement
informed actions taken to manage the topic. However, due to the importance of the engagement
process in limiting the negative impacts of mine closure, it is appropriate to add a recommendation toelaborate on how local communities were engaged on closure and post-closure planning andimplementation, including post-mining land use.

354
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357

Additionally, as monitoring of the environmental, social, and human rights impacts is considered a key
element of responsible post-closure activities,11 the additional sector disclosure included in the
exposure draft was amended to encompass both environmental and socioeconomic aspects whenreporting the financial provisions for closure and rehabilitation.

358
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360
361
362
363

Finally, the post-closure viability of communities is an increasingly topical issue for coal mining. For
example, actions for coal organizations range from collaboration with affected communities and local
governments to develop post-closure socioeconomic financial assurance mechanisms to publicly
disclosing financial surety arrangements for socioeconomic impacts from closure. To highlight theissue, a new sector disclosure to report information on non-financial provisions to manage the local
community’s social and economic transition to a post-mining economy was included.

364
365

Commitments, policies, and plans for rehabilitation are covered by Disclosure 3-3, which requires
reporting policies or commitments and management actions taken.

366
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368
369
370

Concerns related to the public disclosure of financial provisions could potentially lead to unsolicitedquestions or conflict over disbursement or gaining access to the funds. However, transparency overfunds to cover costs of mine closure by coal mining organizations is seen as essential, ensuring
meaningful engagement with stakeholders. Therefore, the additional sector disclosure was retained in
the topic.

371

i)

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373
374

One respondent suggested adding a mention of the financial impact of air pollution on local andregional governments. Other feedback on the topic was mostly related to the value, clarity, andfeasibility of the proposed additional sector recommendations, including:Air emissions

•

375
376
377
378
379
380

•
•

A few mentioned challenges to report particulate matter (PM) emissions separately from coaldust, as they are fugitive emissions and often not regulated, and thus outside the definition of“significant air emissions” as per GRI 305 Emissions 2016;
One commented that carbon monoxide (CO) emissions are currently not collected and would
add to the reporting burden; andA few found reporting on product quality improvements unclear.

381
382
383

Individual respondents further requested to add reporting on emissions reporting requirements
submitted regularly to authorities and to report the number of incidents of non-compliance orinfractions resulting in fines

384

GSSB response:

385
386
387
388

Air pollution has wide-ranging global and local economic impacts, which stem from, for example,
premature mortality, illness, and healthcare costs, lost working days, and reduced crop yields. 12 To
reflect this, a mention of the financial dimension of air pollution was subsequently added to the topic
description.

389
390
391
392
393
394

Particulate matter (PM) coal dust emissions are typically fugitive emissions, occur mainly throughblasting and earth moving in surface mining, and can be significant unless mitigated by dust
suppression technologies. Other locally significant dust emissions can occur from coal transport andstorage, for which mitigation solutions exist. 13 As such, the disclosure listed in the exposure draft toreport the total amount of PM emissions from coal dust would likely not add value to reporting, as
fugitive emissions are usually estimated and can have more severe impacts depending on the11See, for example, ibid; International Council on Mining and Metals, Closure Maturity Framework, 2020.

12

The World Bank, The Cost of Air Pollution, 2016; Ogranisation for Economic Co-operation and Development (OECD), The
Economic Consequences of Outdoor Air Pollution, 2016.
13 International Energy Agency (IEA), World Energy Outlook Special Report: Energy and Air Pollution, 2016.

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395
396
397

proximity to the release. Instead, the disclosure was revised to trigger descriptive information on dust
suppression that can prevent or mitigate potential negative impacts on local communities andworkers. It is an additional recommendation when reporting on the management of the topic.

398
399
400
401
402
403
404
405
406
407
408
409

For CO emissions, the most significant impacts of this highly toxic gas occur when workers are
exposed to it in confined spaces (e.g., as a result of a fire in an underground mine), potentially leading
to serious consequences, including fatalities.14 Accordingly, reporting on CO is most relevant in
Topics 12.13 Asset integrity and critical incident management and 12.14 Occupational health andsafety. In topic 12.13, mine fires and poisonous gas leaks are listed as relevant hazards in the topic
description, and prevention of such incidents should be reported. Fires and explosions are likewise
mentioned in the topic description for 12.14, with the potential to cause high-consequence workrelated injuries. Reporting on the management of such worker hazards and their impacts falls under
several disclosures in GRI 403: Occupational Health and Safety 2018. In addition, in regions where
CO is a regulated substance, organizations are required to measure and report those emissions, as
per the requirements in Disclosure GRI 305-7.15 As such, the additional sector disclosure to reportcarbon monoxide emissions has been removed from the topic 12.4 Air emissions.

410
411
412
413
414
415
416
417
418

A disclosure on product quality improvements to reduce air emissions was included in the exposure
draft as an additional sector recommendation to GRI Disclosure 416-1 Assessment of the health andsafety impacts of product and service categories. This was done on the basis that coal washing canhave a mitigating impact on the pollutants that are emitted upon combustion. 16 However, it wasassessed that Disclosure 416-1 might not generate meaningful information, but the recommendation
remained important. Disclosure 416-1 was removed from topic 12.4. Instead, to clarify the link
between coal quality and emissions, the topic description was amended to note that coal washing is amethod to reduce air emissions in the use phase. The language was clarified and placed as anadditional sector recommendation to GRI 3-3 Management of material topics.

419
420
421

Incidents of non-compliance are covered by The GRI General Disclosure 2-27 Compliance with laws
and regulations, whereas information on emissions reporting to regulators can add unnecessary
reporting burden, especially to multinational business organizations.

422

j)

423
424
425

For biodiversity, a request was made to include impacts from ground subsidence and reporting onwhether coal mining is associated with gas extraction. For water and effluents, one respondent posed
a question on the relevance of acid mine drainage for coal mining.

426

GSSB response:

427
428
429

Ground subsidence was validated as a relevant source of impact for the sector, and mention of it has
been added to topics 12.3 Closure and rehabilitation, 12.5 Biodiversity, and 12.13 Asset integrity andcritical incident management. No new reporting was deemed necessary.

430
431
432
433

The request to add reporting on whether coal mining is associated with the extraction of gas deals
with assessing the risk of leakage and explosion of gas pipelines. Upon further research, it was
discovered that these impacts are most relevant to coal bed methane extraction, which is an
unconventional gas extraction method and thus out of the scope for the Sector Standard for coal.

434
435
436

The phenomenon of acid rock/mine drainage is relevant for coal mining.17 However, as acid minedrainage is regarded as a runoff, not a discharge, the additional sector recommendation is moreaccurate in the context of Disclosure 303-1 Interactions with water as a shared resource, as opposed

Other environmental topics

14

United States Environmental Protection Agency (EPA), Basic Information about Carbon Monoxide (CO) Outdoor Air
Pollution, accessed on 12 January 2021; Yuan, L., Smith, AC, CO and CO2 Emissions from Spontaneous Heating of Coal
Under Different Ventilation Rates, 2011.
15 Definition of ‘significant air emission’ in the GRI Standards is “air emission regulated under international conventions and/or
national laws or regulations” (GRI Standards Glossary 2021).
16 International Energy Agency (IEA), World Energy Outlook Special Report: Energy and Air Pollution, 2016.

Acharya, B. S., & Kharel, G. Acid mine drainage from coal mining in the United States – An overview, Journal of Hydrology,
588, 2020; Campaner, V. P., Luiz-Silva, W., & Machado, W., Geochemistry of acid mine drainage from a coal mining area andprocesses controlling metal attenuation in stream waters, southern Brazil, Anais da Academia Brasileira de Ciências, 86, 2014.
17

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437
438

to its position in the exposure draft where it was connected to Disclosure 303-2 Management of water
discharge-related impacts.

439k) Economic impacts

440
441
442
443
444
445

Topic 12.8 Economic impacts received most feedback out of local community related topics. One
respondent felt that the significant role of local procurement in creating economic impacts was not
sufficiently covered. Another respondent suggested that the concept of ‘project’ needed to be clarified
in the context of reporting on economic value generated and distributed, as this information might belegally restricted or commercially sensitive. It was also suggested to mention the economic impacts ofhealth problems derived from environmental pollution.

446

GSSB response:

447
448
449
450
451
452

Local procurement is a significant source of long-term economic development and benefits for local
communities, often outweighing the value provided by direct employment by organizations.18 Topic
12.8 Economic impacts has been revised to reflect the positive economic impacts that can result fromlocal procurement, but no new reporting has been added. The additional sector recommendation
included in the exposure draft addresses an organization’s approach to providing local employment,
procurement, and training to enhance positive economic impacts on communities.

453
454
455
456
457
458
459

The additional sector recommendation to Disclosure 201-1 Direct economic value generated anddistributed (EVG&D) guides organizations to report their EVG&D on a project basis. This level ofdisaggregation can help information users better assess the benefits from coal activities on acommunity or regional level. It is also aligned with the additional sector reporting in topic 12.21
Payments to governments,19 which partly deals with the same payments. While Disclosure 201-1
requires reporting on EVG&D separately at country, regional, or market levels where significant, forcoal, and other extractive sectors, project reporting is a more meaningful level of disaggregation.

460
461
462
463

For economic impacts from pollution, the GRI 203: Indirect Economic Impacts 2016 mentions thatsignificant indirect impacts can include impacts of pollution. However, the pathway between coalmining and potential increased health costs is unclear and insufficiently substantiated to be included
as an impact broadly applicable to the whole sector. No additions were made to the topic description.

464

l)

465
466
467

For topic 12.9 Local communities, which deals with societal impacts from coal activities, one
respondent suggested including reporting on policies or commitments involving free, prior, andinformed consent (FPIC) with all affected communities, not just indigenous peoples.

468

GSSB response:

469
470
471
472
473
474
475
476
477

Fee, prior, and informed consent (FPIC), as laid out in the United Nations Declaration on the Rights ofIndigenous Peoples, is currently only applicable to indigenous peoples under international law.
Seeking consent from affected non-indigenous peoples takes place on the basis of loss or restrictionof access to land or natural resources, resettlement, or an impact on a human right. While there areindications that FPIC may be extended to all affected communities as a best practice stakeholder
consultation,20 there does not seem to be sufficient evidence that those in the broader community who
are affected in a variety of significant but less acute ways are afforded the right to withhold consent.
As such, the reference to FPIC in the topic 12.10 Land and resource rights is appropriate. The
language in the topic 12.9 Local communities was revised to highlight meaningful local engagement

Local communities

See, for example, Natural Resource Governance Institute, Local Content – Strengthening the Local Economy and Workforce,
2015; The World Bank, Oil, Gas, and Mining – A Sourcebook for Understanding Extractive Industries, 2015.
18

19

Reporting recommendations in the topic 12.21 are based on the Extractive Industries Transparency Initiative EITI Standard
2019.
20

UN Human Rights Committee & UN Special Rapporteur on the Rights of Indigenous Peoples (UN-REDD Programme),
Guidelines on Free, Prior and Informed Consent, 2013; The Food and Agriculture Organization (FAO), Free Prior and Informed
Consent, 2016; Responsible Mining Foundation, Responsible Mining Index Framework 2020, 2020; Forest StewardshipCouncil (FSC), Implementing free, prior, and informed consent (FPIC) - A Forest Stewardship Council Discussion Paper, 2018.

Page 14 of 20

478
479
480

and inclusion of communities in decision-making. In instances where organizations are drawing on
FPIC for the broader community, they can report this as part of reporting on the management of the
topic.

481
482
483
484

An additional sector recommendation was added on an organization’s approach to engaging
vulnerable groups. The additional sector disclosure was revised to expand the reporting on grievancemechanisms and other remediation processes in addressing local community impacts. These
revisions bring reporting for this topic into line with GRI 11.

485m) Rights of indigenous peoples

486
487

One respondent proposed to add reporting on due diligence and impact assessments regarding
traditional livelihoods and sites/practices of cultural significance for indigenous communities.

488

GSSB response:

489
490
491
492
493
494
495
496
497

For the coal sector, disclosing this information specifically in the context of indigenous peoples islikely to be meaningful. GRI 3: Material topics 2021 and GRI 2: General Disclosures 2021 include
disclosures and guidance related to impact assessments and due diligence applied to all topics. For
example, Guidance to Disclosure 3-3 Management of material topics states that an organization
should describe methods used to identify impacts, including impact assessments. Further, Guidance
to Disclosure 2-24 Embedding policy commitments directs reporting organizations to describe how
they embed policy commitments for responsible business conduct, such as human rights impact
assessments and other due diligence processes. As it could be relevant for many sectors, thisfeedback will be considered when revising the GRI Standard 411: Rights of Indigenous Peoples 2016.

498
499

An additional sector reporting recommendation has been added to describe identified incidents
involving the rights of indigenous peoples, which also aligns with GRI 11.

500n) Conflict and security

501
502

A respondent suggested reporting on compliance with the Voluntary Principles on Security and
Human Rights would be appropriate in the context of topic 12.12 Conflict and security.

503

GSSB response:

504
505
506
507
508
509
510

To report on compliance with the Voluntary Principles on Security and Human Rights 21, therespondent referenced a Responsible Mining Index (RMI) indicator requiring companies to track,
review and act “to improve its performance on preventing and remedying human rights abuses related
to its security management”.22 This information is considered to be covered by the Disclosure 3-3
Management of material topics (actions taken to manage the topic and related impacts; tracking theeffectiveness of actions taken), and Disclosure 2-23 Policy commitments (describe [theorganization’s] specific policy commitment to respect human rights).

511
512

The topic was also supplemented with an additional sector recommendation requesting information
on how the organization works with security providers. This also aligns with GRI 11.

513o) Asset integrity and critical incident management

514
515
516
517
518
519
520
521

On topic 12.13 Asset integrity and critical incident management, a few labor respondents pointed outthat other catastrophic risks, especially in underground mining, should be included in the reporting.
The focus on tailings facility integrity in the topic was regarded as positive, including the alignment
with the Global Industry Standard on Tailings Management (GISTM), with suggestions to further
reinforce the alignment. One respondent suggested that further clarity on what is meant by ‘tailings’ isneeded, as it was not recognized as a sector-relevant term in one producer country. One respondentsuggested the inclusion of a disclosure on whether a confidential or anonymous (grievance)mechanism for stakeholders to report tailings incidents is in place.
21

Voluntary Principles on Security and Human Rights, The Voluntary Principles on Security and Human Rights, 2000.

22

Responsible Mining Foundation, Responsible Mining Index Framework 2020, 2020.

Page 15 of 20

522

GSSB response:

523
524
525
526
527
528

Topic 12.13 describes many risks beyond tailings facility failures that can result in critical incidents,
but the reporting section is missing a general incident metric. While many risks relevant to coal mining
involving workers are reported in topic 12.14 Occupational health and safety, other risks may exist
that can result in environmental damage or serious consequences on communities left unreported.
The topic has thus been supplemented with an additional sector disclosure to report the number ofcritical incidents and describe their impacts.

529
530
531
532
533

The term ‘tailings’ has been clarified in the topic description. To further reflect the transparency
expectations set out in the GISTM, the additional sector reporting on tailings in the exposure draft was
supplemented with recommendations to list the organization’s tailings facilities, including the name,location, and ownership status; and to report the dates of the most recent and next independent dam
safety reviews for each tailings facility. Terminology was also revised to correspond to GISTM.

534
535
536

Reporting on grievance mechanisms is done in Disclosure 2-25 Processes to remediate negative
impacts and Disclosure 2-26 Mechanisms for seeking advice and raising concern, and thus triggered
no new reporting in the topic 12.13.

537
538
539

The exposure draft also included a disclosure on emergency preparedness and response plans in the
topic 12.13 Asset integrity and critical incident management. This disclosure was removed as it
overlaps with reporting requirements in the Disclosure 3-3 Management of material topics.

540p) Worker topics

541
542
543

Some organizations stated that the topic 12.16 Child labor would not be material for their operating
context. Other individual comments included a call for reporting on strikes and lockouts andconsidering living wage disclosures.

544

GSSB response:

545
546
547
548
549
550
551

While many organizations operate in areas with strict regulation and monitoring of human rights
issues such as child and forced labor, they might have business relationships with organizations that
do not. As part of reporting its management of a topic, an organization is required to report whether it
is involved with negative impacts as a result of its business relationships. While not present in all coalmining regions, child labor occurs frequently enough in coal supply chains to be considered asignificant impact for the sector. When assessing potential negative human rights impacts, theseverity of the impact takes precedence over its likelihood.

552
553
554
555
556
557
558
559

The rationale to include reporting on strikes and lockouts was based on alignment with a similar
disclosure listed in the SASB Standard for Coal Operations. There is no globally recognized definition
for what constitutes a strike or a lockout, and such practices are also restricted in many countries.
Such a disclosure may have been used to assess the risk of unionization to the organization rather
than assessing the impacts on employees based on the organization’s practices. Data on labor
employee turnover and collective bargaining are considered better indicators of workforce
unhappiness, together with respect for collective action, included in GRI 401: Employment 2016 andDisclosure 2-30 Collective bargaining agreements.

560
561
562
563

While expectations to communicate commitments to living wage are beginning to emerge23, the issue
is more pressing to sectors such as agriculture and textiles rather than coal. Due to extensive
regulation and a high unionization rate, coal workers are not commonly underpaid. No new reportinghas been added.

564q) Anti-corruption

565
566
567
568

For topic 12.20 Anti-corruption, a respondent suggested adding details and reporting on corruption
risks arising from the procurement process. The interconnection between conflict and corruption was
also raised by a respondent, with a proposal to add reporting on the heightened corruption risk in
conflict-afflicted countries where organizations’ operations are contracted with the government.

23

See, for example, Bettercoal provision 6.22; ICMM Performance Expectation 3.5; and RMI Framework indicator E.05.

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569

GSSB response:

570
571
572
573
574
575

It is acknowledged that the procurement process is one of the highest areas of risk in thedevelopment phase in particular. 24 Topic 12.20 Anti-corruption was amended to highlight this issue,
with new examples of risks and schemes related to procurement added. An additional sector
recommendation was added to supplement information reported under GRI 3-3 Management ofmaterial topics to describe how organizations manage potential impacts or risks of corruption in theirprocurement practices and throughout the supply chain.

576
577
578

Conflict can exacerbate corruption, and corruption can trigger conflict. This interlinkage has been
added to the topic description. However, as the existing additional sector disclosure includes all
contracts and licenses regardless of country of operation, the reporting remains unchanged.

579

r)

580
581
582

One respondent requested an explicit requirement to report on operated joint ventures whendisclosing payments to governments. Another respondent called for a commitment from organizations
to comply with the spirit and letter of the law and avoid tax havens.

583

GSSB response:

584
585
586
587
588
589

When determining its material topics, an organization is expected to identify its actual and potential
impacts on the economy, environment, and people, including impacts on their human rights across its
own activities and those of its business relationships. A joint venture is a type of business relationshipand reporting on impacts caused by joint ventures is, as such, potentially relevant. Organizations in
the coal sector can be involved with those impacts, even if it was a non-operating partner. No newreporting has been added. For more details, see GRI 3: Material Topics 2021, Section 1.

590
591
592
593

The suggested additions are sufficiently covered by Disclosure 207-1 Approach to tax. Under thisdisclosure, an organization reports information about its tax strategy, including tax havens and anorganization’s approach to regulatory compliance, outlining the organization’s intention with respect to
tax laws.

594s) Public policy and lobbying25

595
596

Using the term ‘lobbying’ in topic 12.22 Public policy and lobbying was contested by one business
representative due to negative connotations in the respondent’s country context.

597

GSSB response:

598
599
600
601
602

As a result of the alignment of topic names across Sector Standards, topic 12.22 Public policy andlobbying was changed to ‘Public policy’, which is consistent with the name of the Topic Standard GRI
416 Public Policy 2016. However, the term ‘lobbying’ will be maintained in the topic description, as it
is widely recognized and used to refer to both positive influences as well as aims for undue influence,
unfair competition, and policy capture.

Payments to governments

24

Organization for Economic Co-operation and Development (OECD), Corruption in the Extractives Value Chain, 2016.

25

The topic name has been revised in GRI 12 to ‘Public policy’.

Page 17 of 20

Appendix 1. Questionnaire questions
Sector profile
Question 1: Are the business relationships described those that present the highest risk of significant
negative impacts for the coal sector, based on the impacts’ severity and likelihood of occurrence?
The sector and sustainable development
Question 2.1: Does the section accurately reflect the coal sector’s sustainability context and the
key societal expectations towards the sector as set out in international instruments and agreements?
Question 2.2: Does the mapping of likely material topics to SDGs help to contextualize the coalsector’s activities in light of the global sustainability agenda?
Material topics
Question 3.1: Are the topics listed the correct likely material topics for the coal sector?
Question 3.2: Are the most significant impacts of the sector described in the likely material topics?
Question 3.3: Are the topic descriptions - including how they are named - complete and accurate interms of capturing the sector’s most significant impacts?
Disclosures
Question 4.1: Are the additional disclosures or recommendations listed understandable and feasible
to report on?
Question 4.2: Are the listed disclosures critical and useful for sustainability report information users
to understand an organization’s impacts related to each topic?
Question 4.3: Are the disclosures formulated correctly to produce valuable and consistent
information?
Climate change
Question 5.1: Reporting organizations: Do the disclosures listed in GHG emissions and Climate
adaptation and resilience correspond to your organization’s current or anticipated reporting on climatechange related impacts?
Question 5.2: Information users: Do the reporting disclosures listed in the GHG emissions andClimate adaptation and resilience reflect the stakeholder expectations of public disclosure by coalorganizations on climate change related impacts?
Tailings
Question 6: Please respond if you are a reporting organization: Does your organization comply orplan on complying with the GISTM? Please explain why/why not.
Other
Question 7: Please respond if you are a reporting organization: Which reporting instruments is yourorganization currently using for sustainability reporting, and why?
Question 8: Are there any other comments, or feedback you would like to provide about the GRI
Coal Sector Standard exposure draft or the specific content presented within?

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605

Appendix 2. Public comment
submissions by stakeholder
constituency and region

606
607
608

A total of 29 formal submissions from individuals and organizations was received on the exposure
draft of Sector Standard: Coal. The names of these individuals and organizations are listed in the
public comment feedback table, tab ‘Full set of comments’.

609
610
611
612
613

The charts below show the breakdown of submissions by constituency group and region. Most
responses came from mediating institutions (10), closely followed by businesses (9). Labor was
represented with three (coordinated) submissions, and three responses came from civilsociety organizations. Investment institutions submitted one response. The remaining responses were
submitted by an individual and a government body.

614
615

The submissions also represent regional diversity, with submissions originating from 18 countries andbalanced global distribution.

603
604

Page 19 of 20

616

Appendix 3. Participation in regional

617

events and webinars
Event

Date

Number of attendees

GRI live webinar and Q&A

2 June (Midday CET)45

GRI live webinar and Q&A

2 June (Evening CET)35

3 June (Morning CET)

25

22 June7

5 July64

14 July~10

20 July~20

21 July~10

GRI live webinar and Q&A
Regional workshop Latin
America
Regional workshop Indonesia
Regional workshop Africa
Regional workshop India
Regional workshop China
Total participants~220

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