gssbsecretariat@globalreporting.org

Item 03 – Overview of feedback
received on GRI Standards
For GSSB discussion
Date

3 October 2023

Meeting

17-18 October 2023

Description

This paper presents an overview of the feedback received on the GRI Standards
in 2023, until 3 October, and the Standards Division’s recommendations foraddressing the feedback. This paper is presented for GSSB feedback anddiscussion.

This document has been prepared by the GRI Standards Division and is made available toobservers 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 2023

Contents
Introduction.............................................................................................................................................. 3
Feedbacks ............................................................................................................................................... 3
Reporting gender breakdowns in Disclosure 2-7 ................................................................................ 3
Feedback received........................................................................................................................... 3
Standards Division’s recommendations........................................................................................... 4
Reporting age breakdowns in Disclosure 405-1.................................................................................. 5
Feedback received........................................................................................................................... 5Standards Division’s recommendations........................................................................................... 6
Reporting energy and emissions intensity ........................................................................................... 6
Feedback received........................................................................................................................... 6Standards Division’s recommendations........................................................................................... 6
Proposal to the Standards related to the Russian invasion to Ukraine ............................................... 7
Feedback received........................................................................................................................... 7
Standards Division’s recommendations........................................................................................... 9
GRI Standards architecture ............................................................................................................... 10
Feedback received......................................................................................................................... 10Standards Division’s recommendations......................................................................................... 10
Integration, benchmarking and industry professional feedback ........................................................ 11
Feedback received......................................................................................................................... 11Standards Division’s recommendations......................................................................................... 12Page 2 of 13

1

Introduction

2

Interested parties are invited to submit feedback on the GRI Standards to3

gssbsecretariat@globalreporting.org for the consideration of the GSSB.

4This paper presents an overview of the feedback received on the GRI Standards in 2023, until 3

5

October, and the Standards Division’s recommendations for addressing the feedback. This paper is6presented for GSSB feedback and discussion.

7

This paper does not include feedback received as part of the draft GSSB Work Program 2023-2025,

8

the draft Biodiversity Standard, or the draft Mining Standard, which were available for public

9

consultation earlier in 2023.

10

Feedback

11

Reporting gender breakdowns in Disclosure 2-7

12Feedback received

13

The following feedback was received from an anonymous respondent on 4 June 2023, through14

info@globalreporting.org.

15

Dear Global Reporting Initiative,

16

I am a novice communication specialist. I just started working at an agency specialized in giving

17

sustainability related services two months ago. One of the services we provide is the translation of18

GRI reports from Turkish into English.

19

I want to quickly summarize the event that urged me to email you. A superior of mine gave me

20

revisions about the gender terminology I used at the social sustainability part of the report. I chose to21

use the words “men” and “women” in reference to the gender of the personnel the company had

22

employed. My superior wanted me to change it to “male” and “female”. I defended my original

23

translation by saying that this part of the report is about social sustainability, and the word gender24

refers to the social counterpart, whereas male and female refer to the biological sex.

25

We then thought the best course of action would be to look at the templates on the official GRI

26

website. To my surprise, in your “Consolidated Set of the GRI Standards”, you used the words “male”

27

and “female” alongside with the “other” and “undisclosed” options.

28

First and foremost, as a queer person, I want to thank you for using the “other” option in your report, I

29

really appreciate it. It gives recognition to many marginalized communities.

30

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31

Unfortunately, however progressive these gender options you have given in your template may be, I

32

want you to be aware of the fact that on the reports prepared in developing countries like Turkey, the33possibility of adding the “other” section is almost impossible for various different political and cultural

34

reasons. And the copywriters handling these reports make partial use of your template and prepare

35

heteronormative and patriarchal reports which is the exact opposite of the point in writing a gender36

equality section!

37

The reason I am writing this email is not to blame you for the misuse of your template by other parties,

38

but it is to make you aware of this situation.

39

I believe regardless of this experience I had, the use of the terms “male” and “female” are incorrect40

while talking about gender equality.

41

But it becomes especially problematic in countries where the use of “other” is out of the question.

42

Even though it will always be problematic to use dichotomies while talking about such complex

43

notions, the words “women” and “men” seem to be the most suitable given the current norms.

44

I, therefore, feel the need to kindly ask you to revise your templates as a novice copywriter and a

45

queer person. I know the politically correct terminology changes over time, and as the Global

46

Reporting Initiative you want to create objective, valid, and long-lasting reports. I believe you can

47

come up with a better way to find a balance between providing representation and creating long-48

lasting reports.

49

Thank you for taking the time to read my concerns.

50

I know I am just one individual talking about their concerns, but I hope my email had the power to51urge you to make necessary changes.

52

Sincerely,

53

Standards Division’s recommendations

54

Disclosure 2-7 Employees in GRI 2: General Disclosures 2021 requires to break down employee data55

by gender. Disclosure 2-7 does not define the term 'gender' nor does it prescribe how to report the56gender breakdowns. Table 1 for Disclosure 2-7 lists examples of gender breakdowns such as

57‘female’, ‘male’, ‘other’ (as specified by the employees themselves), and ‘not disclosed’. Table 1

58

contains an example of how to present the information, and as such, the gender breakdowns listed in

59

Table 1 are not required to be used. Therefore, reporting organizations are free to use 'men' and60'women' instead of 'male' and 'female' to report in accordance with the GRI Standards.

61

The Standards Division recommends:

62

•

63
64

publishing an FAQ on the GRI website on how to report gender breakdowns based on the
explanation above;•

this feedback be considered as part of the GRI Topic Standard Project for Labor.

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65

At this stage, the Standards Division does not recommend amendments to Disclosure 2-7 Employees,

66

but amendments could be considered in the future subject to the outcome of the GRI Topic Standard

67

Project for Labor.

68

Reporting age breakdowns in Disclosure 405-1

69

Feedback received

70

The following feedback was received from Vera Shatunova on 29 August 2023, through71

info@globalreporting.org.

72

Dear all,73

i'm writting you about "Disclosure 405-1 Diversity of governance bodies and employees"

74

The reporting organization shall report the following information:

75

a. Percentage of individuals within the organization’s governance bodies in each of the following

76

diversity categories:

77

i. Gender;

78

ii. Age group: under 30 years old, 30-50 years old, over 50 years old;

79

iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

80

b. Percentage of employees per employee category in each of the following diversity categories:

81

i. Gender;

82

ii. Age group: under 30 years old, 30-50 years old, over 50 years old;

83

iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

84

The age limits of this social group are not clearly defined and may vary depending on the country,

85

organization, and purpose of the study. The lower age limit is usually set at the level of 14-16 years,

86

the upper - between 24 and 35 years. However, deviations are possible. For example, the UN directly

87

admits that “there is no universal concept” and proposes to consider people aged 15 to 24 as young

88

people, noting that other age limits can be used by a number of its own divisions, as well as in89

member states of the organization. The WHO uses a different classification , in which, from a medical

90

point of view, the age from 25 to 44 is considered young.

91

My suggestion is to change age groups like this: under 24 years old, 24-35 years old, 36-50 years old,92

over 50 years old.

93

Thanks a lot!

94

Vera Shatunova

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95Standards Division’s recommendations

96

GRI 405: Diversity and Equal Opportunity 2016 is being revised as part of the GRI Topic Standard

97

Project for Labor. The Standards Division recommends that this feedback be considered as part of98

this project.

99

Reporting energy and emissions intensity

100

Feedback received

101

The following feedback was received from an anonymous respondent on 18 July 2023, through102

info@globalreporting.org.

103

Dear team,104

It has been observed that companies with diverse product portfolios are adopting cumulative105

production as the denominator for calculating energy and emission intensity. By doing so, the106

denominator value of the ratio would increase, thus reducing the actual intensity values, which may

107

not be the case in actuality. This misrepresented information may lead to inappropriate conclusions

108

derived by the intended users of the sustainability report.

109

The justification provided by these companies is that the GRI disclosure recommendations provide for

110organizations to choose from a list of denominators, namely ‘unit of product’, which according to the111

companies is their cumulative production.

112

Considering the GRI reporting principles – Balance and Compatibility, companies with diverse product113

portfolios opting to report intensity values based on their top-line/revenue would be an adequate

114

representation.

115

Audited top-line or revenue figures of such companies is a financial proxy, inclusive of multiple

116

demand and market drivers, which are publically available for verifiability of KPIs.

117

Further, most rating agencies and other global frameworks are requesting intensity disclosures

118

primarily based on revenue.

119

Request you to kindly provide guidance for reporting in this regard to ensure harmonization of120

reporting on intensity disclosures.

121

Regards,

122

Standards Division’s recommendations

123

Disclosure 302-3 Energy intensity and Disclosure 305-4 GHG emissions intensity allow organizations

124

to choose the organization-specific metrics (denominators) to calculate the ratios. The guidance for125

these disclosures suggests the following metrics for the denominator:

126•

units of product;

127•

production volume (such as metric tons, liters, or MWh);

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128

•

size (such as m2 floor space);

129•

number of full-time employees;

130•

monetary units (such as revenue or sales).

131

The Standards Division recommends that this feedback be considered as part of the GRI Topic

132

Standard Project for Climate Change, as these disclosures are currently being revised as part of that133

project.

135

Proposal to the Standards related to the Russian
invasion of Ukraine

136

Feedback received

137

The following feedback was received from Yaroslav Bielov on 12 June 2023, through138

gssbsecretariat@globalreporting.org.

139

Dear colleagues

134

140

I am writing to you on behalf of a group of Ukrainian sustainable development and ESG experts.

141

By this letter we would like to address to you regarding the issue of ESG reporting of entities

142

that continue to operate in Russian Federation, the country that started a terrible war against Ukraine

143

in the centre of Europe.

144

Nowadays the world's largest companies report on sustainable development and ESG. This145

is, in fact, a response to requests of investors, consumers of products and society as a whole to have146

access to information about the impact of business on various spheres of life, as well as related

147

environmental, governance, social and other.

148

For companies compliance with ESG becomes a standard, which allows to demonstrate goals,

149

values, quality and competence of management as well as to attract investors. Investing in the150

securities of companies that meet ESG standards helps to avoid situations where companies are held151

accountable by government bodies, regulators and courts for unethical practices, resulting in a loss of152

capitalisation and investors’ confidence.

153

As you know, on February 24, 2022, Russia launched a large-scale war against Ukraine. As a154

result of the war thousands of people were killed, millions lost their homes and jobs, and became155

refugees. Russia destroys ecology, infrastructure, massively violates people's rights, kills and kidnaps

156

Ukrainian children.

157
158

Recently the russian forces destroyed the Kakhovka dam, triggering the largest ecological,
technogenic and humanitarian disaster in Europe in recent decades.

159

However foreign companies like Nestle, Procter&Gamble, PepsiCo, SLB, Metro AG, Unilever,160

Xiaomi, Philip Morris, OTP Bank and many others continue to operate in Russia strengthening its

161

economy and paying multimillion taxes. The total annual turnover of 1200+ international companies

162

operating in Russia is almost 290 billion dollars (20 percent of the GDP). They pay multibillion-dollar

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taxes to the russian budget, 30 percent of which is spent on defence, namely on killing, robbing and164

raping innocent people.

165
166

These companies continue releasing well-written reports on positive contribution to sustainable
development, and their work in a country that is itself a terrorist does not affect their ESG ratings.

167

Some of these companies even improved their ESG scores in 2022 when Russia was already168

killing Ukrainians. For example: SLB (Schlumberger) - world's largest oilfield firm received in 2021 and

169

2022 an AA rating from MSCI despite the fact that it has boosted its business in Russia by cherry-170

picking

171

left https://www.reuters.com/markets/commodities/slb-wins-russia-business-oilfield-rivals-exit-after-

172

ukraine-invasion-2023-01-19/

serviceandequipment

contractsfromrivalswho

173

In our opinion, the activities of companies in the territory of the Russian Federation have an

174

impact on their ESG assessment and must be displayed in their sustainability and ESG reports. By

175

paying taxes to the russian budget, helping russian propaganda, carrying out mobilization measures for176

their employees, companies support Russia in the war with Ukraine which contradicts the very idea of177

the United Nations Sustainable Development Goals and ESG principles. Thus, their activity leads to the178

following consequences and risks:

179- Companies sponsor the war that has catastrophic consequences for the environment. According to180

the estimates of the Ministry of Environmental Protection and Natural Resources, the environmental

181

damage caused by the Russian invasion amounted to more than 50 billion US dollars.

182- Companies pay taxes to the country that created a humanitarian disaster (life and health of millions of183

Ukrainians, refugees, displaced persons, human rights violations, destruction of social infrastructure,184etc.).

185- Pay funds to the russian budget, which are used in an illegal and corrupt manner to finance private

186

military companies, purchase ammunition, pay for propaganda, bribe politicians and voters, etc.

187

-

188

companies as war sponsors, etc. Ukrainian National Agency on Corruption Prevention added Procter

189& Gamble, OTP Bank, Metro AG and many other companies to the list of International sponsors of190

war https://sanctions.nazk.gov.ua/en/boycott/.

191- Face the possibility of losing control over the property, property rights and securities of companies

192

associated with unfriendly foreign countries in connection with the adoption of the Putin’s Decree No.

193

302, “On Temporary Management Over Certain Assets” dated April 25, 2023.

194- May be subject of sanctions imposed by countries or governmental organizations, accusations of

195

facilitating the evasion of sanctions, etc.

196

-

197

customers, society in connection with the recognition of Russia as a sponsor of terrorism, an aggressor,

198

etc. Since the start of the invasion, Russia has been placed under international sanctions and has been

199

accused of war crimes and massive violation of human rights. European Parliament and other national

200

parliaments declared Russia to be a state sponsor of terrorism. The UN GA Resolution A/77/L.65

201"Cooperation between the United Nations and the Council of Europe" refers to the "unprecedented

Risk to suffer reputational damage, mistrust of responsible investors and customers, recognition ofCompanies will definitely be a subject of pressure from government and regulatory bodies, investors,

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202

challenges" facing Europe "following the aggression of the Russian Federation against Ukraine and203

earlier against Georgia” calling Russia an aggressor.

204
205
206
207

We are confident that additional risks may be revealed in the process of a more in-depth
assessment of the impact of the companies' activities in Russia.
Having examined the Full set of GRI Standards we would like to highlight the following
statements:

208“In the GRI Standards, impact refers to the effect an organization has or could have on the209

economy, environment, and people, including effects on their human rights, as a result of the210

organization’s activities or business relationships. The impacts can be actual or potential, negative or211

positive, short-term or long-term, intended or unintended, and reversible or irreversible. These impacts

212

indicate the organization’s contribution, negative or positive, to sustainable development”.

213“The impacts of an organization’s activities and business relationships on the economy,214

environment, and people can have negative and positive consequences for the organization itself.

215

These consequences can be operational or reputational, and therefore in many cases financial”.

216

Taking into account the above we consider that we should bring into attention of investors the217

information related to any direct and indirect forms of cooperation with Russia and other countries with218

anti-democratic regimes that violate international law, human rights, Sustainable Development Goals

219

etc. We would also like to request you to consider the possibility of including this obligation into the GRI

220

Standards.

221

From our side, we are ready to join the work on this issue.

222

Thanking you in advance for cooperation and your prompt reply in this matter!

223

Best regards,

224

Yaroslav Bielov

225Standards Division’s recommendations

226

GRI 3: Material Topics 2021 provides guidance on determining the material topics and suggests

227

assessing an organization’s sustainability context in order to identify its impacts. This includes

228

assessing – at local, regional, and global levels – the economic, environmental, human rights, and229

other societal challenges related to the organization's sectors and the geographic location of its

230

activities and business relationships. These challenges, for example, include a lack of law

231

enforcement or political conflict. GRI 3 also provides organizations with a framework to report on their232

due diligence efforts to address any negative impact they have identified, in line with expectations set

233

out in intergovernmental instruments such as the UN Guiding Principles on Business and Human

234

Rights and the OECD Guidelines for Multinational Enterprises.

235

The topic of conflict is currently featured in GRI 11: Oil and Gas Sector 2021, GRI 12: Coal Sector

236

2022, and in the exposure draft of the Mining Sector Standard. These standards include reporting

237

recommendations such as listing the locations of operations in areas of conflict, their due diligence

238

process, and the approach to ensuring adherence to international humanitarian law.

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239

While there is no specific Topic Standard on the topic of conflict, the GRI Topic Standards cover many240

topics relevant for organizations operating in conflict-affected areas, such as tax, procurement241

practices, anti-corruption, water and effluents, and local communities. In its Work Program for 2023-

242

2025, the GSSB has identified the need for further research and the development of practical243

guidance on International Humanitarian Law. The Standards Division recommends that the scope of244

this practical guidance be expanded to report on situations of conflict more generally, including

245International Humanitarian Law.

246

GRI published in May 2023 a policy paper exploring the key role of reporting in conflict-affected areas,

247

which reporting organizations can refer to in the meantime for additional guidance.

248

GRI Standards architecture249

Feedback received

250

The following feedback was received from an anonymous respondent on 3 July 2023, through251

gssbsecretariat@globalreporting.org.

252

Dear colleagues,

253

In an age of proliferation of standards setters on sustainability reporting (now the EU with Eufrag and254

its redundant law on ESG add further con-fusion) I went to GRI to seek conceptual relaxation.

255

However, after a good impression of the logical framework and rigour of GRI 1,2, and 3, moving to256

Sectoral Standards I was quite confused. This I am wondering if these topics do not interfere with

257

Topic Standards, at least for the identification of the impact.

258

By the way, the meaning of Disclosure is not explained, while the logical explanation of Requirements

259

linked to Disclosures and Sustainability Reporting is not alway clear for reporting entities. It seems

260

that the GRI Standard would copy the EU Red Tape on the issue.

261

In addition, the evolution of economy threatens the rigid classification you are going to262

prepare expecting a regulative framework for 40 or 45 Sectors. Probably, next year you will realise

263

that sectors will be 55 or more.

264

In my view, sectors should be limited to the most important ones for the environment, while the impact

265

on society, governance, HR, is the same for the rest, falling in Others categories. This will facilitate266

the understanding of the GRI structure.

267

Best

268

Standards Division’s recommendations

269

The Sector Standards Program responds to the demand from stakeholders that organizations in the270same sector should report in a uniform way. The Standards Division considers that this demand271

persists even if the boundaries of sectors are not fixed but move with technological and regulatory

272

changes, as the respondent rightly suggests.

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273

No sector classification is perfect, and many organizations may not find a sector into which they can274

fit comfortably. Two important features of the sector program can help to alleviate this challenge:

275

1) The list of sectors is not closed but is subject to changes and additions.

2762) Organizations that do not find a GRI Standard for their sector can still report in accordance277

with the GRI Standards.

278

The Standards Division recommends maintaining the ambition to produce Sector Standards that will279

cover most economic activities and produce Sector Standards according to a schedule that prioritizes

280

the sectors with the most significant impacts on the economy, environment, and people.

281

With respect to the recommendation to focus the prioritization on environmental impacts only, the GRI

282

Standards consider the impacts of organizations on the economy, environment, and people, without a283

hierarchy between these categories. It has been observed in the first Sector Standards developed284

that there can be significant differences across sectors regarding impacts on people. Thus, likely

285

material topics vary by sector when it comes to impacts on people.

287

Integration, benchmarking and industry professional
feedback

288

Feedback received

289

The following feedback was received from an anonymous respondent on 11 July 2023, through290

gssbsecretariat@globalreporting.org in response to the Letter from the GSSB Chair issued on 11 July

291

2023.

292

Dear GSSB representatives,293

I react to the recent message and call for feedback on the GRI standards. I represent the real estate294

development company […], specializing in sustainable architecture. We have constructed the first

295

LEED Zero Carbon certified building in the region, pioneered green roofs on every project and last

296

year, after completing the GRI professional course, published our first sustainability report according297

to the GRI standards […]298

While the GRI standards are very clear and comprehensive, there are a number of areas where we299

could see improvement.

300

Firstly, integration should be deepened with the myriad of frameworks and standards which are

301

currently thrust upon SME’s. As a representative of a company with less than 200 employees, I can302

see that there are often requirements from EU Taxonomy, ESRS, etc. which are mandated directly or

303

via financial institutions, that create a massive bureaucratic overload which is difficult to guide through304

and integrate for smaller companies who are just starting their reporting. Mapping different

305

frameworks throughout GRI standards in a way that the data needs to be gathered in a unified way

306

and disclosed simultaneously would be a great help for companies.

286

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Secondly, benchmarking should be included. For larger companies with extensive portfolios that have308

decades of data it is much easier to set sustainability targets and already have a clearer path from309

year 1 of reporting. For smaller companies, there is often a complete lack of past data, since they are

310

often not forced or capable of gathering data required for many disclosures. Furthermore, as a

311

company long focused on sustainability but with a relatively short history, it is difficult to define future

312

targets since our portfolio is already on a high level of sustainability. We are then disadvantaged

313

against larger companies whose overall impacts are worse and their future targets can simply be to

314

start constructing real estate with the same level certification as our baseline. Including base level

315

benchmarks for carbon intensity of real estate for example would make it easier for us to compare

316

data from year 1 to a set industry baseline and also create more objective comparison between

317

companies, as they would measure against the same goals.

318

Thirdly, I would like to get informed on how development of new standards aimed at real estate or

319

integration with EU regulations will work in relation to industry professional feedback? Oftentimes,

320

standards for sustainable development are created on a political level without the inclusion of321

practitioners in the field, which creates big problems down the road. As a company with big focus on322

sustainability and ESG, as well as prior experience with reporting, we would certainly like to be

323

included in the process to ensure that GRI standards, or GRI influenced standards such as ESRS, are324

based on rational, achievable and evidence-based principles.

325

I will be glad to hear your feedback on this and/or our company report.

326

Kind regards,

327

Standards Division’s recommendations

328

Regarding the first point on integration with other standards, as set out in the GSSB Work Program329

2023-2025, cooperating with global, national, and other jurisdictional standard-setting bodies to330

ensure complementarity and interoperability between standards is a key commitment of the GSSB.

331

As announced on August 23, 2023, EFRAG and GRI are considering enhancing their technical332

cooperation. EFRAG and GRI will establish and make available for public reference the list of the333

ESRS disclosure requirements and data points that correspond to GRI disclosure requirements and334

data points and illustrate the high level of commonality achieved. This list will enable straightforward

335

reporting with reference to GRI standards. In particular, the two organizations intend to work on a336

digital taxonomy and a multi-tagging system for their respective standards to simplify reporting

337

processes. In addition, GRI also intends to publish a complete mapping document between the GRI

338

Standards and the ESRS to assist organizations in using both sets of standards in conjunction with339

additional educational support.

340

Regarding the second point on benchmarking, GRI 1: Foundation 2021 currently states that ‘It is

341

important to note that the GRI Standards do not set allocations, thresholds, goals, targets, or any

342

other benchmarks for good or bad performance.’ The information reported through the GRI Standards343

can be used by third parties to benchmark organizations. In keeping with the objectives of the GRI

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344Standards, the Standards Division does not recommend setting benchmarks through the GRI

345

Standards.

346

Regarding the third point, the Standards Division has responded with information on how practitioners

347

are involved in the development of the GRI Standards as well as how to get involved.

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