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

GRI Universal Standards: GRI 101, GRI
102, and GRI 103 – Exposure draft
11 June 2020

Comments to be received by 9 September 2020
This exposure draft of the Universal Standards: GRI 101, GRI 102, and GRI 103 has been published
for public comment by the Global Sustainability Standards Board (GSSB), the independent standard
setting body of GRI.
The exposure draft is structured as follows:••••

GRI 101: Using the GRI Standards (lines 1 – 830)
GRI 102: About the Organization (lines 831 – 2205)
GRI 103: Material Topics (lines 2206 – 2890)
Glossary (lines 2891 – 3184)

The exposure draft is accompanied by the following three documents:•

Explanatory memorandum sets out the objectives for the review of GRI’s Universal
Standards, the significant proposals contained in the exposure draft, and a summary of the
GSSB’s involvement and views on the development of the draft.

•

GRI Sector Program information sheet helps reviewers understand references to the GRISector Standards included in the exposure draft.

•

Mapping document provides an overview of the changes between the disclosures in GRI 102:
General Disclosures 2016 and GRI 103: Management Approach 2016 and the exposure draft of
the Universal Standards.

This draft is published for comment only and may change based on public feedback before its official
release.
Any interested party can submit comments on the draft by 9 September 2020 using
this survey.
For more information, please visit the GRI Standards website. If you have additional questions about
the project, the exposure draft, or the public comment period, please send an email touniversal@globalreporting.org.

Users can navigate to specific sections of the exposure draft using the bookmarks available in mostbrowsers and in Adobe Acrobat Reader.
Note that this document includes internal links and hyperlinks to other Standards. In most browsers,
using ‘ctrl’ + click will open external links in a new browser window. After clicking on a link, use ‘alt’+ left arrow to return to the previous view.
© GRI 2020

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GRI 101: Using the GRI Standards

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Contents
1.

Introduction ................................................................................................................................................... 4

4

1.1

Sustainability reporting and the GRI Standards ............................................................................ 4

5

1.2

How to use the GRI Standards ........................................................................................................ 4

6

1.3

Structure of the GRI Standards ........................................................................................................ 5

7

1.4

Requirements, guidance, and defined terms .................................................................................. 6

8

1.5

Overview of this Standard ................................................................................................................. 692.

Key concepts in the GRI Standards .......................................................................................................... 8

10

2.1

Impact ..................................................................................................................................................... 8

11

2.2

Material topic ........................................................................................................................................ 8

12

2.3

Due diligence ........................................................................................................................................ 9

13

2.4

Stakeholder ......................................................................................................................................... 10

14

3.

Sustainability reporting using the GRI Standards................................................................................. 11

15

3.1

Approach A: Reporting in accordance with the GRI Standards ............................................. 11

16

3.2

Approach B: Reporting with reference to the GRI Standards ................................................ 16

17

4.

Reporting principles ................................................................................................................................... 18

18

5.

Additional recommendations for sustainability reporting ................................................................. 24

19

5.1

Aligning sustainability reporting with other reporting .............................................................. 24

20

5.2

Enhancing the credibility of sustainability reporting .................................................................. 24

21

Appendix 1. GRI content index for reporting in accordance with the GRI Standards ....................... 26

22

Appendix 2. GRI content index for reporting with reference to the GRI Standards .......................... 30

23
24Note 1: Defined terms are underlined in the text of the GRI Standards and hyperlinked to theirdefinitions in the Glossary.

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28

Note 2: The disclosure codes used in the exposure draft of the Universal Standards (e.g., REP-1,
ACT-1, GOV-1, RBC-1, SE-1, MT-1) are not the final disclosure codes. They are intended for the
purpose of the public comment, to help users distinguish these disclosures from the existing
disclosures in GRI 102: General Disclosures 2016 and GRI 103: Management Approach 2016.

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1. Introduction

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1.1 Sustainability reporting and the GRI Standards

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‘Sustainable development is development that meets the needs of the present without compromising
the ability of future generations to meet their own needs’.1 Through their activities and business
relationships, organizations impact the economy, environment, and people, and in turn makenegative and positive contributions to sustainable development.

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The GRI Sustainability Reporting Standards (GRI Standards) enable an organization to publicly
disclose its most significant impacts and how it manages these impacts, in accordance with a globallyaccepted standard. This allows information users to make informed assessments and decisions about
the organization.

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43

The GRI Standards are designed to be used by any organization – large or small, private or public,
regardless of sector, location, and reporting experience. The Standards create a common language
for organizations to report on their impacts in a consistent and credible way. This enhances theglobal comparability and quality of this information and enables greater transparency andaccountability of organizations.

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1.2 How to use the GRI Standards

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The GRI Standards cover disclosures on a wide range of sustainable development topics. They havebeen developed to help an organization prepare and report information that focuses on its material
topics. Material topics are topics that reflect the organization’s most significant impacts on theeconomy, environment, and people, including impacts on human rights.

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The Standards provide a flexible framework for reporting. Organizations can either report on all
their material topics in accordance with the GRI Standards, or they can use selected GRI Standards,
or parts of their content, to report information with reference to the GRI Standards.

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Reporting in accordance with the GRI Standards

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Reporting in accordance with the GRI Standards provides a complete and balanced picture of anorganization’s material topics and related impacts and how it manages these topics. The
requirements for an organization reporting in accordance with the GRI Standards (Approach A) are
set out in Section 3.1 of this Standard.

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Reporting with reference to the GRI Standards

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An organization can use selected GRI Standards, or parts of their content, to report informationthat meets the needs of specific information users for specific purposes, such as complying withregulatory requirements. The requirements for an organization reporting with reference to the GRI
Standards (Approach B) are set out in Section 3.2 of this Standard.

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Format of reported information

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The information reported using the GRI Standards can be published or made accessible in a range offormats (e.g., electronic, paper-based) across one or more locations (e.g., standalone sustainability

1 World Commission on Environment and Development, Our Common Future, 1987.

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report, webpages, annual report). The term ‘reported information’ in the GRI Standards is used torefer to this information.

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The term ‘sustainability reporting’, as used in the GRI Standards, refers to the entire process ofreporting, from identifying material topics to reporting the disclosures.

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1.3 Structure of the GRI Standards

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The GRI Standards consist of three sets of Standards: Universal Standards, Sector Standards, andTopic Standards.

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Universal Standards

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GRI 101: Using the GRI Standards is the starting point for all organizations. It introduces thesystem of GRI Standards and explains how they are to be used. This Standard applies to allorganizations using the Standards, whether reporting in accordance with or with reference to theStandards.

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GRI 102: About the Organization contains disclosures for contextual information about theorganization. These include disclosures that provide details about the organization and its reporting
practices, activities, governance, responsible business conduct policies and practices, and stakeholder
engagement.

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GRI 103: Material Topics includes guidance for identifying material topics, and contains disclosuresabout the organization’s material topics and related impacts, how it identifies its material topics, andhow it manages each material topic.

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Sector Standards

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The Sector Standards provide information on the most likely material topics for organizations in agiven sector. The organization uses the applicable Sector Standard(s) to assist in identifying its
material topics and what to report for each material topic.

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Topic Standards

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The Topic Standards include disclosures that provide information on particular topics. The
organization selects and uses the Topic Standards that correspond to the material topics it has
identified.

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Figure 1. GRI Standards: Universal, Sector, and Topic Standards

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1.4 Requirements, guidance, and defined terms

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The following apply throughout the GRI Standards:

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Requirements are presented in bold font and indicated with the word 'shall'.

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Guidance sections include background information, explanations, and examples to helporganizations better understand the requirements.

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The guidance sections also include ‘should’ statements, which indicate recommendations, and ‘can’statements, which indicate a possibility or an option.

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The organization is not required to comply with guidance.

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Defined terms are underlined in the text of the GRI Standards and hyperlinked to their definitionsin the Glossary. The organization is required to apply the definitions in the Glossary.

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1.5 Overview of this Standard

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GRI 101: Using the GRI Standards is the starting point for an organization to understand and apply the
GRI Standards. The rest of this Standard is structured as follows:

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Section 2 explains key concepts that are used throughout the GRI Standards. These are
critical to understanding how to prepare and report information with the Standards.

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Section 3 sets out the two ways in which the GRI Standards can be used and presents the
specific statements of use that these require.

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•

Section 4 presents the reporting principles, which are fundamental to ensuring the quality of
the reported information.

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•

Section 5 includes recommendations on aligning sustainability reporting with other types ofreporting and on methods for enhancing the credibility of reporting.

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2. Key concepts in the GRI Standards

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This section explains concepts that lay the foundation for sustainability reporting. Understanding
how these concepts are used in the Standards is essential for reporting as well as interpreting theinformation reported using the GRI Standards.

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2.1 Impact

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In the GRI Standards, impact refers to the effect an organization has or could have on the economy,
environment, or people, including on human rights, as a result of its activities or business
relationships. These impacts can be actual or potential, negative or positive, short-term or longterm, intended or unintended, and reversible or irreversible. These impacts indicate theorganization’s contribution, negative or positive, to sustainable development.

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The organization’s impacts on the economy refer to the impacts on economic systems at local,
national, and global levels. An organization can impact the economy through, for example, its taxes
and payments to governments, its procurement practices, or its competition practices.

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The organization’s impacts on the environment refer to the impacts on living and non-living natural
systems, including land, air, water, and ecosystems. An organization can impact the environment
through, for example, its use of water, energy, land, and other natural resources.

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The organization’s impacts on people refer to the impacts on individuals and groups. Individuals orgroups that have interests that are, or could be, affected by the organization’s activities and decisions
are referred to as stakeholders (see Section 2.4 of this Standard). An organization can impact people
through, for example, its employment practices (such as the wages it pays to employees), its supply
chain (such as the working conditions of workers making the organization’s products), and its
products and services (such as their safety or affordability). The most acute impacts an organization
can have on people are those that negatively affect their human rights.

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2.2 Material topic

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An organization might identify many impacts on which to report. When using the GRI Standards, theorganization prioritizes reporting on those topics that reflect its most significant impacts on theeconomy, environment, and people, including impacts on human rights. In the GRI Standards, these
are the organization’s material topics.

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Examples of topics could be anti-corruption, water and effluents, or occupational health and safety.
A topic need not be limited to one dimension, i.e., only the economy, or the environment, or
people; it can cover impacts across all these three dimensions. For example, an organization might
identify ‘water and effluents’ as a material topic based on the impacts its water use has on natural
ecosystems as well as on local communities’ access to water. The GRI Standards group impacts
under topics, like ‘water and effluents’, to help organizations report in a more cohesive way on
multiple impacts that relate to the same topic.

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In order to prioritize its most significant impacts for reporting, the organization needs to assess thesignificance of the impacts. The significance of a negative impact is assessed based on its severity(scale, scope, and irremediable character) and likelihood. In the case of potential negative humanrights impacts, the severity of the impact takes precedence over its likelihood. The significance of apositive impact is assessed based on its scale, scope, and likelihood. See Section 2 of GRI 103:
Material Topics for more information on assessing the significance of impacts.

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Box 1. Reporting using different materiality perspectives

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The GRI Standards focus on an organization’s most significant impacts outward: on the economy,
environment, and people, including impacts on human rights. These impacts can have negative or
positive consequences for the organization itself (such as operationally or reputationally, andtherefore in many cases financially). For example, an organization’s high use of non-renewable energy
contributes to climate change and could at the same time result in increased operating costs due tolegislation that seeks to shift energy use toward renewable sources.

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The outward impacts of an organization are therefore also important for those interested in thefinancial performance and long-term success of the organization. Understanding an organization’s
impacts outward is necessary in order to identify financially material risks, opportunities, and impacts
for the organization.

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An organization may want to report on its impacts outward as well as the financially material risks,
opportunities, and impacts it faces as a result of these outward impacts, in an annual report or an
integrated report, for example. When doing so, it is important for the organization to report on all
its material topics identified using the GRI Standards, in order to report in accordance with the GRI
Standards. The material topics identified using the GRI Standards need to be prioritized in their own
right and cannot be deprioritized on the basis that they are not financially material.

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2.3 Due diligence

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Due diligence is the process through which an organization identifies, prevents, mitigates, andaccounts for how it addresses its actual and potential negative impacts on the economy,
environment, and people, including impacts on human rights. The organization should address
potential negative impacts through prevention or mitigation. It should address actual negative
impacts through remediation, in cases where it identifies it has caused or contributed to those
impacts.

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The way an organization is involved with negative impacts is important for determining how toaddress the impacts:

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The organization should avoid causing or contributing to negative impacts through its own
activities, and address such impacts when they occur by providing for or cooperating in theirremediation through legitimate processes.

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In the case of negative impacts that are directly linked to the organization’s operations,products, or services by its business relationships, the organization should seek to preventor mitigate these impacts even if it has not contributed to them. The organization does nothave a responsibility to provide for remediation of these impacts, but it can play a role indoing so.

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If it is not feasible to address all identified impacts at once, the organization should prioritize theorder in which it addresses negative impacts based on their severity and likelihood. In the case of
potential negative human rights impacts, the severity of the impact takes precedence over its
likelihood.

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Due diligence is elaborated by the United Nations (UN) Guiding Principles on Business and Human
Rights, the Organisation for Economic Co-operation and Development (OECD) OECD Guidelines forMultinational Enterprises, and the OECD Due Diligence Guidance for Responsibility Business Conduct.

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2.4 Stakeholder

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Stakeholders are individuals or groups that have interests that are, or could be, affected by anorganization’s activities and decisions.2 Common categories of stakeholders for organizations include
business partners, civil society organizations, consumers, customers, employees and other workers,
governments, local communities, non-governmental organizations, shareholders, suppliers, tradeunions, and vulnerable groups.

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In the GRI Standards, an interest (or ‘stake’) is something of value to an individual or group that canbe affected by the activities and decisions of an organization. Stakeholders can have more than one
interest. Not all interests are of equal importance and they do not need to be treated equally.

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Stakeholder interests can be negatively or positively affected by the organization’s activities anddecisions. Due diligence focuses on identifying individuals or groups whose interests, such as their
human rights, are or could be negatively affected by the organization’s activities and decisions.

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Stakeholders do not need to have a direct relationship with the organization; for example, theworkers in the organization’s supply chain can also be its stakeholders. The organization should also
identify the interests of those who are unable to articulate their views (e.g., future generations).
Moreover, stakeholders might themselves be unaware that they are stakeholders of a particularorganization, especially if they have not yet been affected by its activities and decisions.

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Not all of an organization’s stakeholders will be affected by all activities and decisions of theorganization. The organization needs to identify the stakeholders whose interests have to be taken
into account in connection with a specific activity or decision (i.e., the relevant stakeholders).

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The organization might not be able to engage with all relevant stakeholders directly. In these cases,
the organization can engage with credible stakeholder representatives or proxy organizations (e.g.,
non-governmental organizations, representative public bodies).

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In addition to engaging with stakeholders, the organization can also consult with experts on specificissues or contexts (e.g., non-governmental organizations, academics) for advice, such as for
identifying and managing its impacts.

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Sometimes it is necessary to distinguish between stakeholders whose interests have been affected(i.e., affected stakeholders), and those whose interests have not yet been affected but could
potentially be affected (i.e., potentially affected stakeholders). For example, if an organization’s
activity results in a safety hazard, workers who are injured because of the hazard are affectedstakeholders, and workers who have not yet been injured but who are exposed to the hazard andcould be injured are potentially affected stakeholders.

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These distinctions are important in due diligence. In the example of the safety hazard, identifying
workers who are injured is necessary to determine which workers should receive remedy.

2 Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence Guidance for

Responsible Business Conduct, 2018.

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3. Sustainability reporting using the GRI
Standards

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The organization can select between two approaches for using the GRI Standards:

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A. Reporting in accordance with the GRI Standards: The organization uses the set of
GRI Standards to report on its most significant impacts on the economy, environment, andpeople.

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B. Reporting with reference to the GRI Standards: The organization uses selected GRI
Standards, or parts of their content, to report information about specific topics.

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Each approach to reporting with the GRI Standards has a set of requirements and a corresponding
statement of use that the organization is to use once it meets these requirements. These
requirements and statements are set out in Sections 3.1 and 3.2.

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Table 1. Overview of requirements for Approaches A and B
Approach A: Reporting in accordance with
the GRI Standards

Approach B: Reporting with reference to the
GRI Standards

Requirement A-1: Apply the reporting principles

Requirement B-1: Publish a GRI content index

Requirement A-2: Report the disclosures in GRI 102

Requirement B-2: Provide a statement of use

Requirement A-3: Identify material topics

Requirement B-3: Notify GRI

Requirement A-4: Report the disclosures in GRI 103
Requirement A-5: Report appropriate disclosuresfor each identified material topic
Requirement A-6: Publish a GRI content index
Requirement A-7: Provide a statement of use
Requirement A-8: Notify GRI

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3.1 Approach A: Reporting in accordance with the GRI Standards

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Reporting in accordance with the GRI Standards provides a complete and balanced picture of anorganization’s material topics and related impacts and how it manages these topics. It also provides
information about the organization’s specific context, which assists in understanding theorganization’s approach towards its material topics.

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To report in accordance with the GRI Standards, the organization must comply with all therequirements in this section. These requirements ensure that the organization:

249•

applies the reporting principles;

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reports contextual information, including information on its reporting practices, activities,
governance, responsible business conduct policies and practices, and stakeholder
engagement;

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identifies its material topics;

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•

reports information on its impacts and how it manages these impacts for each of its material
topics.

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If the organization does not meet all these requirements, it cannot claim that it has prepared thereported information in accordance with the GRI Standards. In this case, the organization may beable to claim that it has prepared the reported information with reference to the GRI Standards(Approach B), provided it meets the requirements as set out in Section 3.2.

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Requirement A-1: Apply the reporting principles

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a. The organization shall apply all the reporting principles set out in Section 4 of GRI
101: Using the GRI Standards.

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Requirement A-2: Report the disclosures in GRI 102

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a. The organization shall report all disclosures in GRI 102: About the Organization.

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Requirement A-3: Identify material topics

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The organization shall:

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a. identify its material topics;

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b. use the GRI Sector Standard(s) that apply to its sector(s), where these areavailable, when identifying its material topics in A-3-a.

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Guidance

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Section 2 of GRI 103: Material Topics provides guidance on how to identify material topics. The
Sector Standards provide information on the most likely material topics for organizations in a given
sector. Using Sector Standards, however, is not a substitute for the organization’s own process for
identifying material topics.

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Requirement A-4: Report the disclosures in GRI 103

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The organization shall:

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a. report how it has identified its material topics using Disclosure MT-1 in GRI 103:
Material Topics;

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b. report its material topics and related impacts using Disclosure MT-2 in GRI 103:
Material Topics;

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c. for each material topic, whether covered by a GRI Topic Standard or not, report
how it manages the material topic and related impacts, using Disclosure MT-3 in
GRI 103: Material Topics.

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Requirement A-5: Report appropriate disclosures for each identified
material topic

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For each material topic, the organization shall:

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a. report appropriate disclosures from the GRI Topic Standards that correspond tothe material topic;

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b. if it cannot comply with a requirement within an appropriate disclosure from a GRI
Topic Standard identified in A-5-a:

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i.

specify the requirement that it has omitted;

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ii.

provide one of the following four reasons for omission and the required
explanation for that reason.

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Table 2. Reasons for omission
Reason for omission

Required explanation

Not appropriate

Describe why the requirement does not contribute toward
explaining the impacts related to the organization’s material topic.

Confidentiality constraints

Describe the specific confidentiality constraints.

Legal prohibitions

Describe the specific legal prohibitions.

Information incomplete orunavailable

Describe the steps being taken to obtain the missing informationand the expected time frame.
If the required information cannot be obtained, or it is not of
adequate quality to report (as might be the case when theinformation is collected from another organization, e.g., asupplier), explain this situation.

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Guidance

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Guidance to A-5-a

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Appropriate disclosures are those that adequately capture the impacts related to the organization’smaterial topics.

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If a material topic is covered by an existing GRI Topic Standard, the organization is required toreport appropriate disclosures from that Standard.

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The topic names used in the GRI Topic Standards are intentionally high-level, as each topic can covera number of related areas. For example, the Topic Standard GRI 303: Water and Effluents 2018
covers a range of specific areas related to water and effluents, such as water stress, water pollution,
and access to water.

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In some cases, the organization might identify a material topic that does not exactly match the topic
names used in the GRI Topic Standards. In these cases, if the material topic is similar or relates to
one of the topics covered in the GRI Topic Standards, the organization should use thecorresponding GRI Topic Standard to identify appropriate disclosures to report on its material topic.

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When Topic Standards include disclosures on a range of areas, the organization only needs to report
the appropriate disclosures that relate to the impacts identified by the organization.
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For example, suppose an organization identifies energy and GHG emissions as material topics. These
topics are covered by GRI 302: Energy 2016 and GRI 305: Emissions 2016. However, the only form ofenergy that the organization consumes is purchased electricity. Neither the organization nor any of
the sources that it owns or controls consume fuel. In this case, the disclosure related to fuelconsumption in GRI 305, i.e., Disclosure 305-1 Direct (Scope 1) GHG emissions, does notadequately capture the organization’s impacts for the topic of GHG emissions and the organization is
not required to report it. The organization is only required to report the appropriate disclosuresfrom GRI 302 and GRI 305 related to the specific impacts it has identified for the material topics ofenergy and GHG emissions.

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If the GRI Topic Standards do not provide appropriate disclosures for the organization’s impacts fora material topic, or if the organization’s material topic is not covered by the GRI Topic Standards,
the organization should report appropriate disclosures from other sources. For example, suppose anorganization identifies chemicals of concern as a material topic. As there is currently no GRI Topic
Standard that covers this topic, the organization should report appropriate disclosures using otherframeworks or develop its own disclosures to report on this topic.

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If the organization identifies a topic as material and that topic is included in the applicable GRI Sector
Standard, this Sector Standard can also assist the organization in determining appropriate disclosures
to report on that topic.

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Guidance to A-5-b

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When the organization cannot comply with a requirement within an appropriate disclosure from a
GRI Topic Standard it has identified in A-5-a, it is required to use one of the four reasons foromission. Reasons for omission are not permitted for the requirements in GRI 102: About theOrganization and GRI 103: Material Topics.

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Reasons for omission should only be used in exceptional cases when the organization is unable tocomply with a requirement. Using reasons for omission frequently or for critical requirements
reduces the credibility and usefulness of the reported information. Additionally, it does not alignwith reporting in accordance with the GRI Standards, which aims to provide a complete andbalanced picture of the organization’s most significant impacts.

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In the example above where the organization only consumes purchased electricity and does notconsume fuel, it can use the 'not appropriate’ reason for omission for the requirements in
Disclosure 302-1 Energy consumption within the organization in GRI 302: Energy 2016 which relate
to fuel, e.g., 302-1-a and 302-1-b.

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Note that the organization is not required to provide a reason for omission for disclosures from a
GRI Topic Standard that it has identified as not appropriate; the reasons for omission only apply
when the organization cannot comply with requirements within the appropriate disclosures.

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Requirement A-6: Publish a GRI content index

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a. The organization shall publish a GRI content index in one location that is publicly
and easily accessible, using the template set out in Appendix 1.

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Guidance

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The GRI content index is a navigation tool that provides information users with a quick overview ofthe organization’s reported information and facilitates easy access to this information. The content
index shows which GRI Standards and disclosures the organization has used.

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Requirement A-7: Provide a statement of use

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a. The organization shall include the following statement in its GRI content index:

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[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement of use:

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The information reported by [name of organization] for the [reporting period]has been prepared in accordance with the GRI Standards.

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Guidance

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The organization is required to insert the title of its highest governance body or most senior
executive, the name of the organization, and the reporting period in the statement. For example:

362“The Board of Directors acknowledges responsibility for the following statement of use:

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The information reported by ABC Limited for the year ending 31 December 2020 has been
prepared in accordance with the GRI Standards.”

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368

This statement applies to all information included in the GRI content index. The term ‘GRI
Standards’ includes all Standards (Universal Standards: GRI 101, GRI 102, GRI 103, Topic Standards,
and Sector Standards) that are effective at the date when the information is published, as well asStandards that are adopted by the organization earlier than their effective date.

369
370
371

When determining whether the highest governance body or the most senior executive provides thestatement of use, an organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which can be related to:372•

the country where the organization is incorporated or registered;373•

a stock exchange the organization trades its securities on;

374
375

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

376

Requirement A-8: Notify GRI

377
378

a. The organization shall register its reported information and statement of use
through the GRI Standards Report Registration System.

379

Guidance

380
381
382
383

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

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384

3.2 Approach B: Reporting with reference to the GRI Standards

385
386
387
388
389
390
391
392

This is the other approach of reporting using the GRI Standards. The organization can use selected
GRI Standards, or parts of their content, to report information to meet the needs of specificinformation users for specific purposes. For example, the organization can report with reference to
the GRI Standards to comply with a specific reporting regulation on climate change. The organization
can also report with reference to the GRI Standards if it is unable to meet all the requirements forreporting in accordance with the GRI Standards. However, this approach of using the GRI Standards
does not provide a complete and balanced picture of the organization’s most significant impacts on
the economy, environment, and people.

393
394

To report with reference to the GRI Standards, the organization must comply with all therequirements in this section.

395
396
397
398
399

In addition to the meeting these requirements, the organization should apply the reporting principles
from Section 4 of this Standard. These principles ensure high-quality sustainability reporting and areimportant for any information reported using the GRI Standards. The organization should also
report how it manages its impacts using Disclosure MT-3 in GRI 103: Material Topics for any topics
reported.

400

Requirement B-1: Publish a GRI content index

401
402

a. The organization shall publish a GRI content index in one location that is publicly
and easily accessible, using the template set out in Appendix 2.

403

Guidance

404
405
406

The GRI content index is a navigation tool that provides information users with a quick overview ofthe organization’s reported information and facilitates easy access to this information. The content
index shows which GRI Standards and disclosures the organization has used.

407

Requirement B-2: Provide a statement of use

408

a. The organization shall include the following statement in its GRI content index:

409
410

[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement of use:

411
412
413

The information reported by [name of organization] for the [reporting period]has been prepared with reference to the GRI Standards cited in this content
index.

414

Guidance

415
416

The organization is required to insert the title of its highest governance body or most senior
executive, the name of the organization, and the reporting period in the statement. For example:

417“The Board of Directors acknowledges responsibility for the following statement of use:

418
419

The information reported by ABC Limited for the year ending 31 December 2020 has been
prepared with reference to the GRI Standards cited in this content index.”

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420
421
422
423

This statement applies to all information included in the GRI content index. The term ‘GRI
Standards’ includes all Standards (Universal Standards: GRI 101, GRI 102, GRI 103, Topic Standards,
and Sector Standards) that are effective at the date when the information is published, as well asStandards that are adopted by the organization earlier than their effective date.

424
425
426

When determining whether the highest governance body or the most senior executive provides thestatement of use, the organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which can be related to:427•

the country where the organization is incorporated or registered;428•

a stock exchange the organization trades its securities on;

429
430

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

431

Requirement B-3: Notify GRI

432
433

a. The organization shall register its reported information and statement of use
through the GRI Standards Report Registration System.

434

Guidance

435
436
437
438

The GRI Standards Report Registration System can be accessed using the GRI website. The
registration system notifies GRI of the use of the GRI Standards and the corresponding statement of
use reported by the organization. There is no cost associated with notifying GRI of the use of theStandards.

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439

4. Reporting principles

440
441
442

The reporting principles are fundamental to achieving high-quality sustainability reporting. The
organization is required to apply the reporting principles to be able to claim that it has prepared
information in accordance with the GRI Standards (see Section 3.1 of this Standard).

443
444
445

The reporting principles guide organizations in ensuring the quality and proper presentation of thereported information. Quality information enables information users to make sound assessments of
the organization’s impacts and aids in decision-making.

446

Each reporting principle consists of a requirement and guidance on how to apply it.

447

Overview of principles

448•

Accuracy

449•

Balance

450•

Clarity451•

Comparability

452•

Completeness453•

Sustainability context

454•

Timeliness

455•

Verifiability

456

Accuracy

457

Requirement

458
459

a. The organization shall report information that is factually correct and sufficiently
detailed to enable the assessment of the organization’s impacts.

460

Guidance

461
462
463
464
465

The characteristics that define accuracy vary depending on the nature of the information (qualitativeor quantitative) and the intended use of the information. The accuracy of qualitative information candepend on its level of clarity and detail. The accuracy of quantitative information can depend on thespecific methods used to gather, compile, and analyze data. Certain information users require higher
levels of accuracy than others.

466

To apply the Accuracy principle, the organization should:

467
468

•

report qualitative information that is consistent with available evidence and other reported
information;469•

indicate which data has been measured;

470
471

•

adequately describe data measurements and bases for calculations, and ensure it is possible
to replicate measurements and calculations with similar results;

472
473

•

ensure that the margin of error for data measurements does not inappropriately influence
the conclusions or assessments of information users;

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474
475

•

476

Balance477

Requirement

478
479

a. The organization shall report information in an unbiased way and provide a fair
representation of the organization’s negative and positive impacts.

480

Guidance481

To apply the Balance principle, the organization should:

indicate which data has been estimated, the underlying assumptions and techniques used forthe estimation, and any limitations.

482•

not omit relevant information concerning its negative impacts;483•

not overemphasize positive news or impacts;

484
485

•

present information in a way that allows information users to see negative and positive
trends in impacts on a year-to-year basis;486•

distinguish clearly between facts and the organization’s interpretation of the facts;

487
488

•

avoid presenting information in a way that it is likely to inappropriately influence theconclusions or assessments of information users.

489

Clarity490

Requirement

491
492

a. The organization shall present information in a way that is accessible,
understandable, and usable.

493

Guidance494

To apply the Clarity principle, the organization should:

495
496

•

take into account specific accessibility needs of information users associated with abilities,
language, and technology;

497
498

•

present information in a way that users are able to find the information they want without
unreasonable effort, for example, through a table of contents, maps, or links;

499
500

•

present information in a way that it can be understood by users who have a reasonableknowledge of the organization and its activities;

501
502

•

avoid technical terms, acronyms, or other jargon likely to be unfamiliar to users, and include
relevant explanations in the appropriate sections or in a glossary;

503
504

•

report information in a concise way and aggregate information where useful, withoutomitting necessary details (i.e., provide the level of detail required by users);

505
506

•

use graphics and consolidated data tables to make information accessible andunderstandable.

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507

Comparability

508

Requirement

509
510
511

a. The organization shall select, compile, and report information in a consistentmanner, to enable the analysis of changes in the organization’s impacts over time
and the analysis of these impacts relative to other organizations.

512

Guidance513
514

Comparability is necessary for evaluating an organization’s current impacts against its past impacts
and its goals and targets, and against the impacts of other organizations.

515
516
517

Consistency allows for assessing progress and for benchmarking by the organization or external
parties as part of rating activities, investment decisions, and advocacy programs, among otheractivities.

518

To apply the Comparability principle, the organization should:

519
520

•

present information for the current reporting period and at least two previous periods, aswell as any goals and targets that have been set;

521
522

•

maintain consistency in the methods used to calculate data and the manner of presenting
information, and explain the methods and assumptions used to prepare the information;

523
524
525

•

use generally accepted international metrics (e.g., kilograms or liters), standard conversion
factors, and protocols, where applicable, for compiling and reporting information, anddescribe the bases for measurements and calculations where this is not apparent;

526
527
528

•

report total numbers or absolute data (e.g., metric tons of CO2 equivalent) as well as ratios
or normalized data (e.g., CO2 emissions per unit produced) to enable comparisons, andprovide explanatory notes when using ratios;

529
530
531

•

provide contextual information that helps information users understand the factors that
contribute to differences between the organization’s impacts and the impacts of otherorganizations, such as the organization’s size and geographic location;

532
533
534
535
536
537

•

if there are changes in the organization’s identified material topics, the length of thereporting period, or other elements of reporting, such as the definitions used, present thecurrent disclosures alongside restatements of historic data to enable comparisons. The
organization is required to explain any restatements of information from previous reporting
periods and their effect, and report the reasons for such restatements, under Disclosure
REP-4 in GRI 102: About the Organization;

538
539

•

when restatements of historic data are not provided, explain the changes to provide
contextual information for interpreting the current disclosures.

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540

Completeness

541

Requirement

542
543

a. The organization shall provide sufficient information to enable the assessment of
the organization’s impacts during the reporting period.

544

Guidance545

To apply the Completeness principle, the organization should:

546•

not omit information that is necessary for understanding the organization’s impacts;

547
548
549
550

•

present activities, events, and impacts for the reporting period in which they occur. This
includes reporting on activities that have a minimal short-term impact, but that have areasonably foreseeable cumulative impact that can become unavoidable or irreversible in thelong-term (such as activities that generate bio-accumulative or persistent pollutants).

551
552
553

If the organization consists of multiple entities that form a consolidated group (i.e., a parent entity
and its subordinate entities), the organization is required to explain the approach used forconsolidating the information. See REP-2-c in GRI 102: About the Organization.

554
555
556
557

If gaps are identified in collecting information (e.g., when information is not available for all relevant
activities or entities), the organization is required to identify and explain these gaps when reportingin accordance with the GRI Standards. See Requirement A-5-b in Section 3.1 of this Standard formore information on reasons for omission.

558

Sustainability context

559

Requirement

560
561

a. The organization shall report information on its impacts in the wider context ofsustainable development.

562

Guidance563

To apply the Sustainability context principle, the organization should:

564
565
566

•

draw on objective information and authoritative measures of sustainable development,
where available, when reporting on its impacts (e.g., scientific research or consensus on
ecological limits, societal expectations);

567
568
569
570

•

report information on its impacts with reference to broader sustainable development
conditions and goals, as reflected in recognized sector-specific, local, regional, or global
instruments (e.g., reporting total GHG emissions as well as reductions in GHG emissions
with reference to the Paris Agreement);

571
572
573
574

•

report information on its impacts with reference to expectations of responsible businessconduct set out in internationally recognized instruments with which it is expected tocomply (e.g., OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business andHuman Rights);

575
576
577

•

if operating in a diverse range of locations, report information in a way that communicates
its impacts in appropriate local contexts (e.g., reporting total water use as well as water use
relative to the sustainable thresholds and the social context of given catchments).

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578
579
580

Assessing the organization’s sustainability context provides the organization with critical information
for identifying and reporting on its material topics and related impacts (see GRI 103: Material Topics).
The GRI Sector Standards describe the sustainability context for organizations in a given sector.

581

Timeliness

582

Requirement

583
584

a. The organization shall report information on a regular schedule and make itavailable in time for information users to make decisions.

585

Guidance

586
587
588
589

The usefulness of information is closely tied to whether it is available in time for information users
to integrate it into their decision-making. The Timeliness principle refers to how regularly
information is reported, as well as how up to date the information is in relation to the reporting
period.

590

To apply the Timeliness principle, the organization should:

591•

make information available in a timely manner;

592
593

•

balance the need to make information available in a timely manner with the need to ensurethat the information is reliable;

594•

ensure consistency in the frequency of reporting and the length of reporting periods;

595
596

•

clearly indicate the time period covered by the reported information, for example, whenpresenting information for several periods;

597•

indicate when the reported information was last updated and when it will be updated next.

598
599

See Section 5.1 of this Standard for information on aligning the reporting periods and the publishingschedules of sustainability reporting with other types of reporting.

600

Verifiability

601

Requirement

602
603

a. The organization shall gather, record, compile, and analyze information in a waythat the information can be examined to establish its credibility.

604

Guidance605
606

It is important that the reported information can be examined to establish its credibility and to
determine the extent to which the reporting principles have been applied.

607

To apply the Verifiability principle, the organization should:

608
609

•

ensure that individuals other than those involved in preparing the reported information areable to review the supporting internal controls and documentation;

610
611
612

•

document the decision-making processes underlying the organization’s sustainability
reporting in a way that allows for the examination of the key decisions as well as theprocesses, such as the identification of material topics;

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613
614

•

if the organization designs information systems for its sustainability reporting, design thesesystems in a way that they can be examined as part of an external assurance process;

615
616

•

be able to identify the original sources of the reported information and provide reliable
evidence to support assumptions or complex calculations;

617
618

•

be able to provide representation from the original information sources, attesting to theaccuracy of the reported information within acceptable margins of error;

619
620

•

avoid including information that is not substantiated by evidence unless it is relevant forunderstanding the organization’s impacts;

621
622

•

provide unambiguous explanations of any uncertainties associated with the reported
information.

623
624

See Section 5.2 of this Standard for more information on enhancing the credibility of sustainability
reporting.

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626

5. Additional recommendations forsustainability reporting

627
628

This section includes additional recommendations on aligning sustainability reporting with othertypes of reporting and on methods for enhancing the credibility of reporting.

629

5.1 Aligning sustainability reporting with other reporting

630
631
632
633

The organization should align its sustainability reporting with other statutory and regulatory
reporting, in particular, its financial reporting. This includes reporting information for the same
reporting period and for the same group of entities, and to the extent possible, publishing
information at the same time.

634

5.2 Enhancing the credibility of sustainability reporting

635
636

The organization can use several methods to enhance the credibility of its sustainability reporting,including internal controls, external assurance, and stakeholder or expert panels.

637

Internal controls

638
639
640
641

The organization should put in place internal controls to strengthen the overall integrity andcredibility of its sustainability reporting. Internal controls are processes designed and implemented
by the organization, generally its management, to provide reasonable assurance regarding theachievement of its objectives.

642
643
644
645

Internal controls can be implemented at a day-to-day operational level through management andcompliance functions. Additionally, the organization can establish and maintain an internal audit
function that is also responsible for the processes for sustainability-related risk management and for
managing sustainability reporting.

646
647
648
649
650
651
652
653

In some jurisdictions, corporate governance codes require directors to inquire and, if satisfied, toconfirm the adequacy of an organization’s internal controls in the annual report. This confirmation
might only relate to the adequacy of the internal controls for financial reporting. It does notnecessarily provide information on whether the same internal controls are also adequate to assess
the credibility of the organization’s sustainability reporting. If the organization relies on internal
controls related to financial reporting, it should assess the relevance of these controls for its
sustainability reporting. In cases where these controls are inadequate, the organization should
identify and use additional internal controls to assess the credibility of its sustainability reporting.

654

External assurance

655
656
657
658
659

In addition to internal controls, the organization should seek external assurance for its sustainability
reporting, even though this is not required in order to prepare information in accordance with the
GRI Standards or with reference to the GRI Standards. Disclosure REP-5 in GRI 102: About theOrganization requires the organization to report information on its policy and practice with regard toseeking external assurance for its sustainability reporting.

660
661
662

External assurance refers to activities that assess the quality and credibility of the qualitative andquantitative information reported by the organization and/or the systems or processes for reporting
this information (e.g., the process for identifying material topics and related impacts). This is different

625

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663
664

from activities that assess or validate the quality or level of performance of an organization, such as
issuing performance certifications or compliance assessments.

665
666
667
668
669

External assurance results in published reports, conclusions, or opinions that can be used for various
purposes, such as to validate that the information has been prepared in accordance with reporting
standards, to increase trust in the reported information and reduce risk in data quality, and to enable
information users as well as the organization to use the reported information in their decisionmaking.

670
671

External assurance should be conducted by competent assurance providers with appropriate
experience and qualifications.

672

In general, an assurance provider meets the following criteria:

673
674

•

Independence from the organization to be able to reach and publish objective and impartial
conclusions about the organization’s reporting in a written report that is publicly available.

675•

Demonstrable competence in the subject matter and assurance practices.

676•

Competence in applying quality control procedures to the assurance engagement.

677
678
679

•

Ability to conduct the engagement in a manner that is systematic, documented, evidencebased, and characterized by defined procedures in line with professional standards forassurance.

680
681
682

•

Ability to assess whether the organization’s reporting provides a reasonable and balanced
presentation of impacts, by considering the accuracy of information reported as well as theoverall selection of content.

683
684

•

Ability to assess the extent to which the organization has applied the GRI Standards in thecourse of reaching its conclusions or opinions.

685

Stakeholder or expert panels

686
687
688

The organization can also convene a stakeholder or expert panel to seek an external review of its
overall approach to sustainability reporting or to seek advice on the content of its reported
information.

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690

Appendix 1. GRI content index for reporting inaccordance with the GRI Standards

691

GRI content index

689

Statement of use[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement ofuse:
The information reported by [name of organization] for the [reporting
period] has been prepared in accordance with the GRI Standards.

GRI Sector
Standard(s)[Title of the Sector Standard(s) used to identify the material topics]

GRI Standard

Disclosure(Number, title, and publication
year)(Disclosure code)

Location ofreported
information(including page
numbers, URLs)

Omission
Requirement
omittedReasonExplanation

Disclosures about the organization
GRI 102: About theOrganization

Organizational details and reporting practices
REP-1
REP-2
REP-3
REP-4
REP-5
Organizational activities
ACT-1
ACT-2
Governance
GOV-1
GOV-2
GOV-3
GOV-4
GOV-5
GOV-6
GOV-7
GOV-8
GOV-9

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GOV-10
GOV-11
GOV-12
GOV-13
GOV-14
GOV-15
Responsible business conduct
RBC-1
RBC-2
RBC-3
RBC-4
RBC-5
RBC-6
RBC-7
Stakeholder engagement
SE-1
SE-2
Material topics (list all material topics identified in MT-2-a)Disclosures about identification of material topics
GRI 103: Material
TopicsMT-1
MT-2-a[Material topic name]
GRI 103: Material
TopicsMT-2-b[Topic Standard /other source][Disclosure
code]

MT-3

[Material topic name]
GRI 103: Material
TopicsMT-2-b[Topic Standard /other source][Disclosure
code]

MT-3

Reasons for omission are not permitted for the requirements in GRI 102: About theOrganization and GRI 103: Material Topics

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692

Guidance693
694

An organization reporting in accordance with the GRI Standards is required to include the following
elements in the GRI content index:

695•

The statement of use

696•

The Sector Standard(s) it has used to identify its material topics

697•

The GRI Universal Standards and Topic Standards it has used

698•

The disclosures it has reported

699•

The location where the information for the disclosures can be found700•

The reasons for omission it has used

701•

The title ‘GRI content index’

702
703

The organization is also required to present the complete GRI content index in one location that is
publicly and easily accessible.

704
705

The organization can use another format for the GRI content index than the one provided as long as
it includes the required elements specified in this Appendix.

706

Statement of use

707
708
709

The organization is required to include the statement of use for reporting in accordance with the
GRI Standards in the GRI content index. See Requirement A-7 in Section 3.1 of this Standard formore information.

710

Sector Standard(s) used, including the title and publication year

711
712
713

The organization is required to list the GRI Sector Standard(s) it has used, where these are available,
to identify its material topics. The organization is required to include the title and publication year
for each Sector Standard used.

714
715

GRI Universal Standards and Topic Standards used, including their number, title, andpublication year

716
717

The organization is required to list the Universal Standards and Topic Standards it has used. These
include:718•

GRI 102: About the Organization;

719•

GRI 103: Material Topics; and

720
721
722

•

The GRI Topic Standards it has used for each material topic. The Topic Standards used areorganized by each material topic reported under Disclosure MT-2-a in GRI 103: Material
Topics.

723
724

The organization is required to include the number, title, and publication year for each Standard
used (e.g., GRI 305: Emissions 2016).

725
726
727

The publication year indicates which version of a GRI Standard the organization has used. The GRI
Standards are regularly updated, and a newer version of a GRI Standard might have different
disclosures than its previous version.

728
729

The publication year does not refer to the reporting period covered by the reported information or
to the year that the reported information is published.

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730

Disclosures

731

The organization is required to list all the disclosures it has reported in the GRI content index.

732
733

For each material topic the organization is required to list the appropriate disclosures reported. This
includes appropriate disclosures from the GRI Topic Standards and disclosures from other sources.

734
735
736
737

The organization is required to report the disclosure code. The disclosure code refers to the unique
identifier for each disclosure in the GRI Standards (e.g., ACT-1). Additionally, the organization
should include the title of each disclosure (e.g., ACT-1 Activities, value chain, and other business
relationships).

738
739
740

For disclosures from other sources, if there is no disclosure code or reference available, theorganization can list the title of the disclosure or any other information that helps identify thedisclosure.

741

Location of reported information

742
743
744
745
746
747
748

For each disclosure that it has reported, the organization is required to include the specific location(i.e., the specific page numbers and/or URLs) where the publicly available information can be found.
For example, the organization is required to specify whether the information is included in astandalone sustainability report, annual financial report, policy document, or on a website. If theinformation to be reported under a disclosure is spread across multiple pages or URLs, theorganization is required to list all relevant pages and URLs across which the information is
distributed.

749
750
751
752
753

If the organization is required to report information that it has previously reported, and theinformation has not changed during the reporting period (e.g., the organization is required to report
information on a policy or process that has not changed since the previous reporting period), theorganization can republish this information or provide a reference to the previously reported
information.

754

Omissions

755
756
757
758

The organization is required to include the reasons for omission it has used in the GRI content
index for all requirements it is unable to comply with. The organization is also required to specify
the requirement that it has omitted and to provide the required explanation for the reason foromission it has used. See Requirement A-5-b in Section 3.1 of this Standard for more information.

759

Including references to additional information in the GRI content index

760
761
762
763
764
765

The organization can include in the GRI content index references to additional information beyond
what is required by the GRI Standards. For example, the organization can show how the disclosures
it has reported using the GRI Standards are related to those required by other reporting standards
or frameworks. Such additions can be made as long as the references to additional information do
not compromise the readability of the content index. The organization should add columns or rowsthat are additional to the ones specified in this Appendix at the end of the content index.

766
767

The organization should not report the information required by disclosures in the GRI Standards
directly in the content index. This can compromise the purpose of the index as a navigation tool.

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769

Appendix 2. GRI content index for reportingwith reference to the GRI Standards

770

GRI content index

768

Statement of use[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the following statement ofuse:
The information reported by [name of organization] for the [reporting
period] has been prepared with reference to the GRI Standards cited inthis content index.

GRI Standard

Disclosure(Number, title, and publication year)(Disclosure code)

Location of reported
information(including page numbers, URLs)[GRI Standard][Disclosure code][GRI Standard][Disclosure code]

771

Guidance772
773

An organization reporting with reference to the GRI Standards is required to include the following
elements in the GRI content index:

774•

The statement of use

775•

The GRI Standards it has used

776•

The disclosures it has reported

777•

The location where the information for the disclosures can be found778•

The title ‘GRI content index’

779
780

The organization is also required to present the complete GRI content index in one location that is
publicly and easily accessible.

781
782
783

The organization can use another format for the GRI content index than the one provided as long as
it includes the required elements specified in this Appendix. It can also use the GRI content index
specified for reporting in accordance with the GRI Standards in Appendix 1, if suitable.

784

Statement of use

785
786
787

The organization is required to include the statement of use for reporting with reference to the GRI
Standards in the GRI content index. See Requirement B-2 in Section 3.2 of this Standard for more
information.

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788

GRI Standards used, including their number, title, and publication year

789
790
791

The organization is required to list all the GRI Standards it has used in the GRI content index alongwith their number, title, and publication year (e.g., GRI 305: Emissions 2016). This requirement
applies to GRI 102: About the Organization, GRI 103: Material Topics, and the Topic Standards.

792
793
794

The publication year indicates which version of a GRI Standard the organization has used. The GRI
Standards are regularly updated, and a newer version of a GRI Standard might have different
disclosures than its previous version.

795
796

The publication year does not refer to the reporting period covered by the reported information or
to the year that the reported information is published.

797
798

The organization can list the GRI Standards it has used for each topic on which it has reported
information.

799

Disclosures

800
801

The organization is required to list all the disclosures it has reported in the GRI content index. This
includes disclosures from the GRI Standards and disclosures from other sources.

802

The organization can list the disclosures it has reported per topic.

803
804
805

The organization is required to report the disclosure code. The disclosure code refers to the unique
identifier for each disclosure in the GRI Standards (e.g., 305-1). Additionally, the organization should
include the title of each disclosure (e.g., 305-1 Direct (Scope 1) GHG emissions).

806
807
808

For disclosures from other sources, if there is no disclosure code or reference available, theorganization can list the title of the disclosure or any other information that helps identify thedisclosure.

809

Location of reported information

810
811
812
813
814
815
816

For each disclosure that it has reported, the organization is required to include the specific location(i.e., the specific page numbers and/or URLs) where the publicly available information can be found.
For example, the organization is required to specify whether the information is included in astandalone sustainability report, annual financial report, policy document, or on a website. If theinformation to be reported under a disclosure is spread across multiple pages or URLs, theorganization is required to list all relevant pages and URLs across which the information is
distributed.

817
818
819
820
821

If the organization is required to report information that it has previously reported, and theinformation has not changed during the reporting period (e.g., the organization is required to report
information on a policy or process that has not changed since the previous reporting period), theorganization can republish this information or provide a reference to the previously reported
information.

822

Including references to additional information in the GRI content index

823
824
825
826
827
828

The organization can include in the GRI content index references to additional information beyond
what is required by the GRI Standards. For example, the organization can show how the disclosures
it has reported using the GRI Standards are related to those required by other reporting standards
or frameworks. Such additions can be made as long as the references to additional information do
not compromise the readability of the content index. The organization should add columns or rowsthat are additional to the ones specified in this Appendix at the end of the content index.

829
830

The organization should not report the information required by disclosures in the GRI Standards
directly in the content index. This can compromise the purpose of the index as a navigation tool.

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831

GRI 102: About the Organization

GRI 102: About the Organization

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832

833

Contents
1.

Introduction .......................................................................................................................................... 35

834

1.1

Overview of this Standard ........................................................................................................ 35

835

1.2

GRI Standards .............................................................................................................................. 35

836

1.3

Requirements, guidance, and defined terms ......................................................................... 37

837

2.

Organizational details and reporting practices ............................................................................. 39

838

Disclosure REP-1 Organizational details.............................................................................................. 39

839

Disclosure REP-2 Organization’s entities included in its sustainability reporting ...................... 40

840

Disclosure REP-3 Reporting period and frequency .......................................................................... 41

841

Disclosure REP-4 Restatements of information................................................................................. 41

842

Disclosure REP-5 External assurance ................................................................................................... 42

843

3.

Organizational activities...................................................................................................................... 44844

Disclosure ACT-1 Activities, value chain, and other business relationships .............................. 44845

Disclosure ACT-2 Employees and other workers ............................................................................ 46

846

4.

Governance ........................................................................................................................................... 51

847

Disclosure GOV-1 Governance structure and composition .......................................................... 51

848

Disclosure GOV-2 Nomination and selection of the highest governance body ........................ 51

849

Disclosure GOV-3 Responsibilities for sustainable development topics and delegation ......... 52

850

Disclosure GOV-4 Stakeholder consultation on sustainable development topics .................... 52851

Disclosure GOV-5 Chair of the highest governance body ............................................................. 53

852

Disclosure GOV-6 Conflicts of interest .............................................................................................. 53

853
854

Disclosure GOV-7 Role of the highest governance body in setting purpose, values,
and strategy ............................................................................................................. 54855

Disclosure GOV-8 Collective knowledge of the highest governance body................................ 54856

Disclosure GOV-9 Evaluation of the performance of the highest governance body ............... 54857

Disclosure GOV-10 Identification and management of impacts .................................................... 55

858

Disclosure GOV-11 Role of the highest governance body in sustainability reporting ............. 55

859

Disclosure GOV-12 Communication of critical concerns .............................................................. 56

860

Disclosure GOV-13 Remuneration policies ....................................................................................... 56

861

Disclosure GOV-14 Process for determining remuneration.......................................................... 57

862

Disclosure GOV-15 Annual total compensation ratio ..................................................................... 57

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863

5.

Responsible business conduct ........................................................................................................... 59864

Disclosure RBC-1 Statement on sustainable development strategy ............................................. 59865

Disclosure RBC-2 Policy commitments ............................................................................................... 60

866

Disclosure RBC-3 Embedding the policy commitments throughout the organization ............ 62867

Disclosure RBC-4 Grievance mechanisms and other remediation processes ........................... 64

868

Disclosure RBC-5 Mechanisms for seeking advice and raising concerns..................................... 67

869

Disclosure RBC-6 Compliance with laws and regulations .............................................................. 69

870

Disclosure RBC-7 Membership associations ...................................................................................... 70

871

6.

Stakeholder engagement .................................................................................................................... 71

872

Disclosure SE-1 Approach to stakeholder engagement................................................................... 71

873

Disclosure SE-2 Collective bargaining agreements ........................................................................... 72

874

References ....................................................................................................................................................... 75

875
876

Note 1: Defined terms are underlined in the text of the GRI Standards and hyperlinked to theirdefinitions in the Glossary.

877
878
879
880

Note 2: The disclosure codes used in this Standard (e.g., REP-1, ACT-1, GOV-1, RBC-1, SE-1)
are not the final disclosure codes. They are intended for the purpose of the public comment, tohelp users distinguish these disclosures from the existing disclosures in GRI 102: General
Disclosures 2016 and GRI 103: Management Approach 2016.

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881

1. Introduction

882
883
884
885
886
887

GRI 102: About the Organization contains disclosures for contextual information about theorganization. These include disclosures that provide details about the organization and its
reporting practices, activities, governance, responsible business conduct policies and practices,and stakeholder engagement. This contextual information helps information
users better understand the nature of the organization and its impacts on the economy,
environment, and people.

888
889

An organization reporting in accordance with the GRI Standards is required to report all
disclosures in this Standard, as set out in Section 3.1 of GRI 101: Using the GRI Standards.

890
891
892

Disclosure REP-2 in this Standard requires the organization to identify the entities included in its
sustainability reporting. These entities define the scope for reporting all other disclosures in thisStandard.

893

1.1 Overview of this Standard

894

This Standard is structured as follows:

895
896

•

Section 2 contains five disclosures, which provide an overview of the organization, itssustainability reporting practices, and the entities covered in its sustainability reporting.

897
898

•

Section 3 contains two disclosures, which cover the organization’s activities, and its
employees and other workers.

899
900

•

Section 4 contains fifteen disclosures, which provide an overview of the organization’s
governance structure, composition, roles, and remuneration.

901
902

•

Section 5 contains seven disclosures, which provide an overview of the organization’s
policies and practices for responsible business conduct.

903
904

•

Section 6 contains two disclosures, which cover the organization’s stakeholder
engagement practices, including how it engages in collective bargaining with employees.

905

1.2 GRI Standards

906
907
908
909
910

The GRI Standards help organizations increase their transparency and communicate theircontribution to sustainable development. The GRI Standards are designed to be used by anyorganization – large or small, private or public, regardless of sector, location, and reporting
experience. The Standards provide a consistent and credible way for organizations to report on
their impacts, which in turn enhances the global comparability and quality of this information.

911
912
913

The Standards provide a flexible framework for reporting. Organizations can either report on all
their material topics in accordance with the GRI Standards, or they can use selected GRI
Standards, or parts of their content, to report information with reference to the GRI Standards.

914

Structure of the GRI Standards

915
916

The GRI Standards consist of three sets of Standards: Universal Standards, Sector Standards, andTopic Standards.

GRI 102: About the Organization

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917

Universal Standards

918
919

The three Universal Standards apply to all organizations reporting in accordance with the GRI
Standards.

920
921

GRI 101: Using the GRI Standards is the starting point for all organizations. It introduces thesystem of GRI Standards and explains how they are to be used.

922
923

GRI 102: About the Organization contains disclosures for contextual information about theorganization.

924
925

GRI 103: Material Topics includes guidance for identifying material topics, and contains
disclosures about the organization’s material topics and how it identifies and manages them.

926

Sector Standards

927
928
929

The Sector Standards provide information on the most likely material topics for organizations ina given sector. The organization uses the applicable Sector Standard(s) to assist in identifying its
material topics and what to report for each material topic.

930

Topic Standards

931
932
933

The Topic Standards include disclosures that provide information on particular topics. The
organization selects and uses the Topic Standards that correspond to the material topics it has
identified.

GRI 102: About the Organization

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934

Figure 1. GRI Standards: Universal, Sector, and Topic Standards

935

1.3 Requirements, guidance, and defined terms

936

The following apply throughout the GRI Standards:

937

Requirements are presented in bold font and indicated with the word 'shall'.

938
939
940

As set out in Section 3.1 of GRI 101: Using the GRI Standards, information required by thedisclosures in GRI 102 cannot be omitted. All information required by the disclosures in GRI 102
is considered critical for information users to understand the organization and its context.

941
942
943
944
945

If the organization is unable to report the required information about an item specified in adisclosure because the item, e.g., a committee, policy, practice, or other process, does not exist,
it can meet the requirement by reporting this to be the case. In such cases, the disclosure does
not require the organization to implement the item, such as the process, but to report if it does
not exist.

946
947
948
949
950

For example, Disclosure GOV-4 requires the organization to describe its processes for
consultation between stakeholders and the highest governance body on sustainable development
topics. If the organization does not have such a process in place, then it is required to state this.
This ensures transparency for information users and enables the organization to meet therequirement.

951
952
953
954
955

If the organization is required to report information that it has previously reported, and theinformation has not changed during the reporting period (e.g., the organization is required toreport information on a policy or process that has not changed since the previous reporting
period), the organization can republish this information or provide a reference to the previously
reported information.

GRI 102: About the Organization

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956
957

Guidance sections include background information, explanations, and examples to helporganizations better understand the requirements.

958
959

The guidance sections also include ‘should’ statements, which indicate recommendations, and‘can’ statements, which indicate a possibility or an option.

960

The organization is not required to comply with guidance.

961
962

Defined terms are underlined in the text of the GRI Standards and hyperlinked to theirdefinitions in the Glossary. The organization is required to apply the definitions in the Glossary.

GRI 102: About the Organization

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964

2. Organizational details and reporting
practices

965
966

The disclosures in this section provide an overview of the organization, its sustainability reporting
practices, and the entities for which it provides sustainability information.

967

Disclosure REP-1 Organizational details

968

Requirements

969

The organization shall:

970

a. report its legal name;971

b. report its nature of ownership and legal form;

972

c. report its location of headquarters;

973

d. report the countries where it has significant operations.

974

Guidance

975

Guidance to REP-1-a

976
977

If the organization uses a commonly known trading name or business name that is different fromits legal name, it should report this in addition to its legal name.

978

Guidance to REP-1-b

979
980
981

The nature of ownership and the legal form of the organization refers to whether it is publicly or
privately owned, and whether it is an incorporated entity, a partnership, a sole proprietorship, or
another type of entity such as a nonprofit, an association, or charitable organization.

982

Guidance to REP-1-c

983
984

Headquarters are an organization’s global administrative center, from which it is controlled or
directed.

985

Guidance to REP-1-d

986
987
988

The organization can also report specific locations within countries where it has significant
operations, e.g., regions, states, or cities, where this provides contextual information tounderstand the organization’s impacts included in its sustainability reporting.

963

GRI 102: About the Organization

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990

Disclosure REP-2 Organization’s entities included in its
sustainability reporting

991

Requirements

992

The organization shall:

993

a. list its entities that are included in its sustainability reporting;

994
995
996
997

b. if the organization has audited consolidated financial statements or financial
information filed on public record, specify the differences between the list ofentities included in its financial reporting and the list included in its sustainability
reporting;

998
999

c. if the organization consists of multiple entities that form a consolidated group,
explain the approach used for consolidating the information, including:

989

1000
1001

i.

whether the approach involves adjustments to information for minority
interests in the case of entities that are not wholly owned;

1002
1003

ii.

how the approach takes into account mergers, acquisitions, and disposalof entities or parts of entities;

1004

iii.

whether and, if so, how the approach differs across material topics.

1005

Guidance

1006

Guidance to REP-2-a

1007
1008
1009
1010
1011

The entities reported under REP-2-a form the basis for reporting the remaining disclosures inthis Standard and for identifying the organization’s material topics and related impacts. The
organization should align the entities included in its sustainability reporting with the entities
included in its other statutory and regulatory reporting, in particular, its financial reporting. See
Section 5.1 of GRI 101: Using the GRI Standards for more information.

1012
1013
1014

When identifying its material topics and related impacts, the organization should consider the
impacts of additional entities with which it has business relationships, that are not included in thelist reported under REP-2-a. See Section 2 of GRI 103: Material Topics for more information.

1015

Guidance to REP-2-b

1016
1017
1018
1019

If all the entities in the organization’s financial reporting are also included in its sustainability
reporting, the organization can provide a reference or link to the list of these entities included in
its audited consolidated financial statements or financial information filed on public record. Any
additional entities included in the sustainability reporting can then be separately identified.

1020

Guidance to REP-2-c

1021
1022

A consolidated group is a group of entities consisting of a parent entity and its subordinate
entities, such as subsidiaries, joint ventures, and affiliates.

1023
1024

A minority interest is the ownership or interest of a subordinate entity, by a party other than theparent entity, in the consolidated group.

GRI 102: About the Organization

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1025Disclosure REP-3 Reporting period and frequency

1026

Requirements

1027

The organization shall:1028

a. specify the reporting period for its sustainability reporting;

1029
1030
1031
1032

b. if the organization has audited consolidated financial statements or financial
information filed on public record, specify the reporting period for its financial
reporting and provide an explanation if it does not align with the period for its
sustainability reporting;1033

c. report the frequency of its sustainability reporting.

1034

Guidance

1035

Guidance to REP-3-a and REP-3-b

1036
1037
1038
1039

The reporting period refers to the time period covered by the reported information, e.g., theyear ending 31 December 2021. The organization should align the reporting period for its
sustainability reporting with the reporting period for its other statutory and regulatory reporting,in particular, its financial reporting. See Section 5.1 of GRI 101: Using the GRI Standards.

1040

Guidance to REP-3-c

1041
1042

The frequency of reporting refers to how often the organization carries out reporting, e.g.,annually.

1043

Disclosure REP-4 Restatements of information

1044

Requirements

1045

The organization shall:

1046
1047

a. explain any restatements of information from previous reporting periods andtheir effect, and report the reasons for such restatements.

1048

Guidance1049

Background

1050
1051
1052
1053
1054
1055
1056
1057

If the organization restates information reported during previous reporting periods and includes
the restated information in its reporting for the current period, it is required to explain therevision or correction made under the restatement. Restatements of information from previous
reporting periods can be provided to correct an error, or account for a change in measurement
methodology or a change in the business context. Providing restatements of information enablesconsistency and comparability of information between reporting periods, and helps information
users in interpreting the reported information. This disclosure provides transparency on thereasons for such restatements and their effects on the reported information.

GRI 102: About the Organization

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1058

Guidance to REP-4-a

1059

Reasons for restatements of information can include:

1060

•

errors made in previous reporting periods;

1061

•

disposals, mergers, or acquisitions;

1062

•

change of base periods or reporting periods;

1063

•

change in the nature of the business;

1064

•

change in measurement methods.

1065
1066
1067

The effect of the restatement refers to the actual revision or correction made to previously
reported information. If the restatement relates to quantitative information, the organization
should specify the quantitative change in the restated information.

1068
1069
1070
1071
1072
1073
1074
1075

For example, suppose an organization experiences a significant reduction in its reported GHG
emissions due to the adoption of a new method for measuring emissions that is more accurate.
The organization restates its previously reported information on GHG emissions in its reported
information for the current period. In this case, the organization is required to explain that it has
restated its previously reported GHG emission levels due to the new measurement
methodology, and that this has resulted in lower GHG emissions than previously reported forthese periods. The organization should also report the quantitative change observed (e.g., GHG
emissions are 10% lower compared to the level of emissions previously reported).

1076

Disclosure REP-5 External assurance

1077

Requirements

1078

The organization shall:

1079
1080
1081

a. describe its policy and practice with regard to seeking external assurance,
including whether and how the highest governance body and senior executives
are involved;1082

b. if the organization’s sustainability reporting has been externally assured:

1083
1084

i.

provide a reference to the external assurance report(s), conclusions, or
opinions;

1085
1086
1087

ii.

describe what has and what has not been assured, the assurance standards
used, the level of assurance obtained, and the limitations of the assurance
process;

1088
1089

iii.

describe the relationship between the organization and the assurance
provider.

1090

Guidance

1091

Guidance to REP-5-b-ii

1092
1093
1094
1095

The description of what has and what has not been assured, the assurance standards used, thelevel of assurance obtained, and the limitations of the assurance process is sometimes included in
the assurance report(s), conclusions, or opinions. If this is the case, the organization can provide
a link to this information included in the external assurance report(s), conclusions, or opinions.
GRI 102: About the Organization

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1096
1097

If this is not the case, the organization is required to report a summary, in accessible language,reflecting the key elements covered in the external assurance report, including:

1098

•

scope of information and processes covered;

1099

•

assurance and reporting standards used;

1100

•

responsibilities of the organization relative to the assurance provider;

1101

•

level of assurance obtained;

1102

•

limitations of the assurance process;

1103

•

opinion or conclusions formally signed off by the assurance provider;

1104

•

summary of the work performed; and

1105

•

information on the experience and qualifications of the assurance providers.

1106

See Section 5.2 of GRI 101: Using the GRI Standards for more information on external assurance.

GRI 102: About the Organization

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1107

3. Organizational activities

1108
1109
1110
1111

The disclosures in this section provide an overview of the organization’s activities and its
employees and other workers. This contextual information helps information users better
understand the nature of the organization and its impacts on the economy, environment, andpeople.

1112
1113

Disclosure ACT-1 Activities, value chain, and other business
relationships

1114

Requirements

1115

The organization shall:

1116

a. report its sector;

1117

b. describe its value chain, including:

1118

i.

the organization’s main activities, products, services, and markets served;

1119
1120
1121

ii.

characteristics of the entities upstream from the organization and theiractivities related to the organization’s products and services, i.e., its
supply chain;

1122
1123

iii.

characteristics of the entities downstream from the organization andtheir activities related to the organization’s products and services;1124

c. report other relevant business relationships;

1125
1126

d. describe significant changes in ACT-1-a, ACT-1-b and ACT-1-c since theprevious reporting period.

1127

Guidance1128

Guidance to ACT-1-a

1129
1130
1131
1132

Sectors can be identified according to different groupings, such as the public or private sector, orindustry-specific categories, such as the education sector, or the financial sector. If theorganization is part of more than one sector, it can report those sectors that provide contextual
information to understand its impacts on the economy, environment, and people.

1133
1134
1135
1136

Depending on the organization’s activities, sectors can be identified using various classification
systems that define categories for economic activities. For example, the UN-based International
Standard Industrial Classification of All Economic Activities, or investment-based classification systems,
such as the Global Industry Classification Standard or the Industry Classification Benchmark.

1137
1138

The organization is required to use the GRI Sector Standard(s) that apply to its sector(s), wherethese are available for its sector(s).

1139

Guidance to ACT-1-b

1140
1141
1142
1143

The organization’s value chain includes the organization’s own activities, as well as activities
carried out by entities upstream and downstream from the organization in relation to theorganization’s products and services. Entities upstream from the organization are those that
supply products or services that contribute to the organization’s own products or services.

GRI 102: About the Organization

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1144
1145

Entities downstream from the organization receive products or services from the organization.
Entities in the value chain include entities beyond the first tier, both upstream and downstream.

1146
1147
1148
1149

The information required in ACT-1-b helps to understand the impacts that occur across theorganization’s value chain, including through the use of its products and services. Describing themarkets served provides further information on the groups of customers targeted by theorganization’s products and services.

1150

Guidance to ACT-1-b-i

1151
1152
1153
1154

When describing its main activities, the organization should report the total number ofoperations. The organization should also report the definition used for ‘operation’. For example,
whether ‘operation’ refers to a single location used by the organization for the production,
storage, and/or distribution of its goods and services or for administrative purposes.

1155

When describing its products and services, the organization should:

1156

•

report the quantity of products or services provided during the reporting period;

1157
1158
1159

•

describe if it sells products and services that are banned in certain markets or are thesubject of stakeholder concerns or public debate, and how the organization has
responded to these concerns.

1160

When describing the markets served, the organization can:

1161

•

report the markets it serves using geographic, demographic, or behavioral characteristics;

1162
1163

•

specify information on the size and relative importance of the markets served, forexample, by reporting net sales or net revenues.

1164

Guidance to ACT-1-b-ii

1165
1166
1167

When describing the characteristics of the entities upstream from the organization and theactivities they carry out in relation to the organization’s products and services (i.e., the supply
chain), the organization can:

1168

•

specify the types of suppliers (e.g., contractor, wholesalers, brokers);

1169
1170

•

report the estimated number of suppliers throughout its supply chain (i.e., in the firsttier, second tier, etc.);

1171
1172

•

report the types of activities of its suppliers (e.g., manufacturing of the organization’s
products, provision of services);

1173
1174

•

specify the nature of the business relationship it has with its suppliers (e.g., long-term or
short-term contract, project- or event-based relationship);

1175

•

specify the sector-specific characteristics of its supply chain (e.g., labor-intensive);

1176

•

report the estimated monetary value of payments made to its suppliers;

1177

•

specify the geographic locations of its suppliers.

1178

Guidance to ACT-1-b-iii

1179
1180
1181

When describing the characteristics of the entities downstream from the organization and theactivities they carry out in relation to the organization’s products and services, the organization
can:

1182
1183
1184

•

specify the types of customers and beneficiaries (e.g., end consumers, other businesses,
recipients of the products or services from a social enterprise or a nonprofit
organization);

GRI 102: About the Organization

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1185
1186

•

report the estimated number of downstream entities (i.e., in the first tier, second tier,etc.);

1187
1188

•

report the types of activities of these downstream entities (e.g., wholesaler,
manufacturer, retailer);

1189
1190

•

specify the nature of the business relationship it has with its downstream entities (e.g.,long-term or short-term contract, project- or event-based relationship);

1191

•

specify the geographic locations of downstream entities.

1192

Guidance to ACT-1-c

1193
1194
1195
1196

Other relevant business relationships include relationships with entities that are not described aspart of the organization’s value chain under ACT-1-b. These can consist of business partners(e.g., joint ventures) and other entities directly linked to the organization’s operations, products,
or services.

1197
1198

When describing other relevant business relationships, the organization can specify the types ofentities, the activities they perform, and their geographic location.

1199

Guidance to ACT-1-d

1200
1201
1202
1203
1204

The description of significant changes to the organization’s sector, value chain, and other business
relationships helps understand any variations in the reported information since the previous
reporting period. Examples of significant changes include changes in activities, such as, facility
openings, closings, and expansions; changes in the structure of the supply chain or in relationships
with suppliers; and changes in the location of suppliers.

1205

Disclosure ACT-2 Employees and other workers

1206

Requirements

1207

The organization shall:

1208

a. report the total number of employees, and provide a breakdown of this total by:

1209

i.

employment contract (permanent and temporary), by gender;

1210

ii.

employment contract (permanent and temporary), by region;

1211

iii.

employment type (full-time and part-time), by gender;

1212

iv.

employment type (full-time and part-time), by region;1213

b. provide contextual information to understand the data reported under ACT-2-a;

1214
1215

c. report the total number of workers who are not employees and whose work is
controlled by the organization, including:

1216
1217

i.

the most common types of worker and their contractual relationship withthe organization;

1218

ii.

the work they perform;

1219
1220

d. describe significant fluctuations in the number of employees and workers who
are not employees during the reporting period and between reporting periods;
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1221
1222
1223

e. describe the assumptions and methodologies used to compile the data, including
whether the number of employees and workers who are not employees arereported:

1224

i.

in head count, full-time equivalent (FTE), or using another methodology;

1225
1226

ii.

at the end of the reporting period, as an average across the reporting
period, or using another methodology.

1227

Guidance1228

Background

1229
1230
1231
1232

This disclosure provides information about the number of employees and other workers who
are not employees that perform work for the organization. To understand how many workers intotal perform work for the organization, it is important to know the number of workers who are
not employees as these are not represented in formal employment figures.

1233
1234
1235
1236
1237

The disclosure gives insight into the organization’s approach to employment, as well as the scopeand nature of impacts created by labor issues. It also provides contextual information tounderstand the information reported in other disclosures, and serves as the basis for calculationin several disclosures, such as the disclosure on the percentage of employees covered bycollective bargaining agreements.

1238
1239
1240

This disclosure covers all employees and all workers who are not employees who perform work
for any of the organization’s entities included in its sustainability reporting (reported under
Disclosure REP-2).

1241

See references 6, 7, 8, 16, 22, 25, and 27 in the References section.

1242

Guidance to ACT-2-a

1243
1244

An employee is an individual who is in an employment relationship with the organization,according to national law or its application.

1245
1246
1247
1248
1249
1250

To identify the employment contract and employment type of its employees, the organization
should use the definitions under the national laws of the countries where the employees are
based, as what constitutes an employment contract and employment type varies between
countries. For example, the national legislations vary in their definitions of a full-time contract. If
the organization has employees in more than one country, it should add up the country-level
data to calculate the total numbers, disregarding differences in national legal definitions.

1251
1252
1253

Providing data on employees by employment contract and employment type by gender enables
an understanding of gender representation and diversity across an organization. The organization
can report information for gender categories in addition to male and female.

1254
1255
1256

Providing data on employees by employment contract and employment type by region enables anunderstanding of regional representation and variations across regions. Region can refer to a‘country’ or ‘geographical area’.

1257
1258
1259

If the organization is unable to report exact figures, it can report estimates of the number of
employees to the nearest ten or, where the number of employees is greater than 1000, to thenearest 100.

1260

See Tables 1-4 for examples on how to present this data.

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1261

Guidance to ACT-2-b

1262
1263
1264
1265
1266
1267

Quantitative data, such as the number of temporary and part-time employees is unlikely toprovide sufficient information on its own. For example, a high number of temporary or part-time
employees could indicate a lack of security for employees, but it could equally signal flexibility
when offered as a voluntary choice. For this reason, quantitative data should be accompanied bycontextual information to help information users understand the data and formulate an
appropriate interpretation.

1268
1269
1270
1271

The organization can explain the reasons for temporary employment (e.g., to undertake work on
temporary or seasonal projects or events, or because it is standard practice to offer a temporary
contract to new employees). If differences in employment contracts exist between genders or
between regions, the organization can explain the reasons for these differences.

1272
1273
1274
1275
1276
1277

Similarly, the organization can explain the reasons for part-time employment (e.g., toaccommodate employees’ requests to work reduced hours, or because it is unable to provide
full-time employment to all employees). The organization can also explain how full-time
employment is defined and whether the same definition applies globally. If differences in
employment types exist between genders or between regions, the organization can explain thereasons for these differences.

1278

Guidance to ACT-2-c

1279
1280
1281
1282
1283

Workers who are not employees are those who perform work for the organization but are notin an employment relationship with the organization (e.g., agency workers, contractors, selfemployed persons, volunteers). ACT-2-c provides an understanding of how much theorganization relies on workers who are not employees to perform its work compared to
employees.

1284
1285
1286
1287

Control of work implies that the organization directs the work performed or has control overthe means or methods for performing the work. The organization might have sole control of thework or share control with one or more organizations (e.g., suppliers, customers, or otherbusiness partners, such as in joint ventures).

1288
1289
1290

If the organization is unable to report exact figures, it can report estimates of the number ofworkers who are not employees to the nearest ten or, where the number of workers who are
not employees is greater than 1000, to the nearest 100.

1291
1292
1293

If all the workers performing work for the organization are employees and the organization does
not engage any workers who are not employees, a brief statement of this fact is sufficient tomeet the requirement.

1294

Guidance to ACT-2-c-i and ACT-2-c-ii

1295
1296
1297
1298
1299
1300
1301
1302

ACT-2-c-i requires the organization to report the most common types of worker who are not
employees. The organization can use the following categories to report the types of worker:
agency workers, apprentices, contractors, home workers, interns, self-employed persons, subcontractors, volunteers. The organization is also required to report its contractual relationshipwith the most common types of worker, i.e., whether it engages them directly or indirectly
through a third party, and in the latter case, who this third party is (e.g., employment agency,
sub-contractor). ACT-2-c-ii requires the organization to describe the work performed by themost common types of worker.

1303
1304
1305

It is sufficient to provide a general description; the organization is not required to report thetype of worker, contractual relationship, and work performed for every worker that is not an
employee.

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1306

Guidance to ACT-2-d

1307
1308
1309
1310
1311
1312
1313

The organization is required to describe all fluctuations in the number of employees and workers
who are not employees that it deems significant. The description can include how the numbers
vary (e.g., whether the numbers have increased or decreased during the reporting period or incomparison to the previous reporting period), and the reasons for the fluctuations (e.g., anincrease in workers who are not employees due to a seasonal event taking place, or a decreasein the number of employees in comparison to the previous reporting period due to thecompletion of a temporary project).

1314
1315
1316

If there are no significant fluctuations in the number of employees and workers who are not
employees during the reporting period or between reporting periods, a brief statement of thisfact is sufficient to meet the requirement.

1317

Guidance to ACT-2-e

1318
1319
1320

The organization should report the number of employees by employment type (full-time andpart-time) in head count. The head count gives insight into the number of individual workers
performing work for the organization, whether on a full-time or part-time basis.

1321
1322
1323

The organization can report the number of employees by employment contract (permanent andtemporary) in head count or full-time equivalent (FTE). Reporting these numbers in FTE gives
insight into the hours worked.

1324
1325

The organization can also use another methodology for reporting these numbers if that is
appropriate.

1326
1327
1328
1329

Reporting the number of employees and workers who are not employees at the end of thereporting period provides information for that point in time, without capturing any fluctuations
during the reporting period. Reporting these numbers in averages across the reporting period
takes into account fluctuations during the reporting period.

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1330 Table 1 Example template for1331 presenting information for ACT-2-a-i

1334 Table 3 Example template for1335 presenting information for ACT-2-a-iii

Total number of employees by
employment contract, by gender

Total number of employees by
employment type, by gender

FemaleYear

FemaleYear

Permanent[Number]Full-time[Number]

Temporary[Number]Part-time[Number]

Total[Number]

Total[Number]

Male

Male

Permanent[Number]Full-time[Number]

Temporary[Number]Part-time[Number]

Total[Number]

Total[Number]

Other gender category (to be determinedby the organization as needed)

Other gender category (to be determinedby the organization as needed)

Permanent[Number]Full-time[Number]

Temporary[Number]Part-time[Number]

Total[Number]

Total[Number]

Grand total[Number]

Grand total[Number]

1332 Table 2 Example template for1333 presenting information for ACT-2-a-ii

1336 Table 4 Example template for1337 presenting information for ACT-2-a-iv

Total number of employees by
employment contract, by region

Total number of employees by
employment type, by region

Region A

Year

Region A

Year

Permanent[Number]Full-time[Number]

Temporary[Number]Part-time[Number]

Total[Number]

Total[Number]

Region B

Region B

Permanent[Number]Full-time[Number]

Temporary[Number]Part-time[Number]

Total[Number]

Total[Number]

Grand total[Number]

Grand total[Number]

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1338

4. Governance

1339
1340
1341

Transparency on the governance structure, composition, roles, and remuneration is important toensure the accountability of the relevant bodies and individuals with respect to the organization’scontribution to sustainable development.

1342
1343
1344

In the disclosures in this section the term ‘sustainable development topics’ refers to topics thatreflect the organization’s impacts on the economy, environment, and people, including impacts onhuman rights.

1345

Disclosure GOV-1 Governance structure and composition

1346

Requirements

1347

The organization shall:

1348
1349

a. describe its governance structure, including committees of the highest governance
body;

1350
1351

b. report the committees of the highest governance body responsible for decisionmaking on and overseeing the management of sustainable development topics;1352

c. describe the composition of the highest governance body and its committees by:

1353

i.

executive and non-executive members;

1354

ii.

independence;

1355

iii.

tenure of members on the governance body;

1356
1357

iv.

number of each member’s other significant positions and commitments, andthe nature of the commitments;

1358

v.

gender;1359

vi.

membership of under-represented social groups;

1360
1361

vii.

competencies relating to sustainable development topics that are relevant to
the organization and the sector in which it operates;

1362

viii.

stakeholder representation.

1364

Disclosure GOV-2 Nomination and selection of the highest
governance body

1365

Requirements

1366

The organization shall:

1367
1368

a. describe the nomination and selection processes for the highest governance bodyand its committees;

1363

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1369
1370

b. describe the criteria used for nominating and selecting highest governance bodymembers, including whether and how:

1371

i.

stakeholders (including shareholders) are involved;

1372

ii.

diversity is considered;

1373

iii.

independence is considered;

1374
1375

iv.

expertise and experience relating to sustainable development topics are
considered.

1377

Disclosure GOV-3 Responsibilities for sustainable development
topics and delegation

1378

Requirements

1379

The organization shall:

1380
1381

a. describe the role and responsibilities of the highest governance body with regard todecision-making for sustainable development topics;

1382
1383

b. report whether the organization has appointed any senior executives withresponsibility for sustainable development topics;

1384
1385

c. describe how management of sustainable development topics is delegated from thehighest governance body to senior executives and other employees;

1386
1387

d. describe the internal resources that the organization has for managing sustainable
development topics;

1388
1389

e. describe the process and specify the frequency for reporting to the highest
governance body on sustainable development topics.

1390
1391

Disclosure GOV-4 Stakeholder consultation on sustainable
development topics

1392

Requirements

1393

The organization shall:

1394
1395

a. describe the processes for consultation between stakeholders and the highest
governance body on sustainable development topics;

1396
1397
1398

b. if responsibility for stakeholder consultation is delegated, report to whom it isdelegated, and how the feedback received is provided to the highest governance
body.

1376

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1399

Disclosure GOV-5 Chair of the highest governance body

1400

Requirements

1401

The organization shall:

1402
1403

a. report whether the chair of the highest governance body is also a senior executive
in the organization;

1404
1405
1406

b. if the chair is also a senior executive, explain their function within theorganization’s management, the reasons for this arrangement, and how any
conflicts of interest are managed.

1407

Disclosure GOV-6 Conflicts of interest

1408

Requirements

1409

The organization shall:

1410
1411

a. describe the processes for the highest governance body to ensure that conflicts ofinterest are avoided and managed;

1412
1413

b. report whether conflicts of interest are disclosed to stakeholders, including, as aminimum, the following conflicts of interest:

1414

i.

Cross-board membership;

1415

ii.

Cross-shareholding with suppliers and other stakeholders;

1416

iii.

Existence of controlling shareholder;

1417

iv.

Related parties, their relationships, transactions, and outstanding balances.

1418

Guidance1419

Background1420

See reference 13 in the References section.

1421

Guidance to GOV-6-b-iii

1422
1423

The organization should use the definition of controlling shareholder applied in the organization’s
consolidated financial statements or equivalent documents.

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1425

Disclosure GOV-7 Role of the highest governance body in setting
purpose, values, and strategy

1426

Requirements

1427

The organization shall:

1428
1429
1430
1431

a. describe the role of the highest governance body and of senior executives in thedevelopment, approval, and updating of the organization’s purpose, value or
mission statements, strategies, policies, and goals related to sustainable
development topics.

1432
1433

Disclosure GOV-8 Collective knowledge of the highest governance
body

1434

Requirements

1435

The organization shall:

1436
1437

a. report measures taken to develop the collective knowledge, skills, and experienceof the highest governance body on sustainable development topics.

1438
1439

Disclosure GOV-9 Evaluation of the performance of the highest
governance body

1440

Requirements

1441

The organization shall:

1442
1443

a. describe processes for evaluating the performance of the highest governance bodywith respect to governance of sustainable development topics;

1444
1445

b. report whether the evaluation is independent or not, and the frequency of theevaluation;

1446
1447

c. describe actions taken in response to the evaluation, including, as a minimum,changes in membership and organizational practices.

1424

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1448

Disclosure GOV-10 Identification and management of impacts

1449

Requirements

1450

The organization shall:

1451
1452
1453

a. describe the role of the highest governance body in overseeing the organization’s
processes to identify and manage sustainable development topics and their related
impacts, including:

1454

i.

the role of the highest governance body in due diligence processes;

1455
1456

ii.

the role of any committees of the highest governance body with specificresponsibilities for these processes;

1457
1458

iii.

how the highest governance body considers and reviews the outcomes ofthese processes;

1459
1460

b. report whether stakeholder consultation is used to support the role of the highest
governance body as described in GOV-10-a;

1461
1462

c. specify the frequency of reporting to the highest governance body on theorganization’s processes as described in GOV-10-a;

1463
1464
1465

d. describe the role of the highest governance body in reviewing the effectiveness ofthe organization’s processes as described in GOV-10-a, and specify the frequency ofthis review.

1466

Guidance1467

Background1468

See references 13, 15, 17, and 18 in the References section.

1469
1470

Disclosure GOV-11 Role of the highest governance body insustainability reporting

1471

Requirements

1472

The organization shall:

1473
1474
1475

a. report the committee of the highest governance body or senior executive position
that formally reviews and approves the organization’s sustainability reporting andensures that the organization reports all identified material topics.

1476

Guidance

1477

Guidance to GOV-11

1478
1479
1480

The organization is also required to include in its sustainability reporting a statement by the highest
governance body or most senior executive position acknowledging their responsibility that thereported information has been prepared in accordance with the GRI Standards or with reference to

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1481
1482

the GRI Standards, depending on the case. See Sections 3.1 and 3.2 of GRI 101: Using the GRI
Standards.

1483

Disclosure GOV-12 Communication of critical concerns

1484

Requirements

1485

The organization shall:

1486
1487

a. describe the processes for communicating critical concerns with regard tosustainable development topics to the highest governance body;

1488
1489

b. report the total number and nature of critical concerns that were communicatedto the highest governance body during the reporting period;

1490

c. describe the mechanisms used to address and resolve critical concerns.

1491

Disclosure GOV-13 Remuneration policies

1492

Requirements

1493

The organization shall:

1494
1495

a. describe the remuneration policies for highest governance body members andsenior executives, including:

1496
1497

i.

fixed pay and variable pay, such as performance-based pay, equity-based pay,bonuses, and deferred and vested shares;

1498

ii.

sign-on bonuses or recruitment incentive payments;

1499

iii.

termination payments;

1500

iv.

clawbacks;

1501
1502
1503

v.

retirement benefits, such as the difference between benefit schemes andcontribution rates for the highest governance body members, senior
executives, and all other employees;

1504
1505
1506

b. describe how performance criteria in the remuneration policies for highest
governance body members and senior executives relate to their objectives forsustainable development topics.

1507

Guidance1508

Background

1509
1510
1511
1512

Remuneration policies are established to ensure that the remuneration arrangements support theorganization’s strategy and its contribution to sustainable development, align with the interests ofstakeholders, and enable the recruitment, motivation, and retention of highest governance bodymembers, senior executives, and employees.

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1513

Guidance to GOV-13

1514
1515

If the organization uses performance-related pay, it should describe how remuneration for senior
executives is designed to reward long-term performance.

1516

If the organization uses termination payments, it should explain whether:

1517
1518

•

notice periods for highest governance body members and senior executives are different
from those for other employees;

1519
1520

•

termination payments for highest governance body members and senior executives aredifferent from those for other employees;

1521
1522

•

any payments other than those related to the notice period are paid to departing highest
governance body members and senior executives;

1523

•

any mitigation clauses are included in the termination arrangements.

1524

Disclosure GOV-14 Process for determining remuneration

1525

Requirements

1526

The organization shall:

1527
1528

a. describe its process for determining remuneration, including its remuneration
policies;

1529
1530

b. report whether independent members of the highest governance body or an
independent remuneration committee oversee the remuneration process;

1531
1532

c. describe how the views of stakeholders (including shareholders) regarding
remuneration are sought and taken into account;1533

d. report the results of votes on remuneration policies and proposals, if applicable;

1534
1535
1536

e. report whether remuneration consultants are involved in determining
remuneration and, if so, report any relationships that the remuneration consultants
have with the organization, its highest governance body, or senior executives.

1537

Disclosure GOV-15 Annual total compensation ratio

1538

Requirements

1539

The organization shall:

1540
1541
1542
1543

a. report the ratio of the annual total compensation for the organization’s highestpaid individual in each country of significant operations to the median annual totalcompensation for all employees (excluding the highest-paid individual) in the same
country;

1544
1545
1546
1547

b. report the ratio of the percentage increase in annual total compensation for theorganization’s highest-paid individual in each country of significant operations to
the median percentage increase in annual total compensation for all employees(excluding the highest-paid individual) in the same country.

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1548

Guidance1549

Guidance to GOV-15

1550

When calculating the ratios, the organization should:

1551

•

for each country of significant operations:

1552

-

list types of compensation included;

1553

-

specify whether full-time and part-time employees are included;

1554

-

specify whether full-time equivalent pay rates are used for each part-time employee;

1555
1556

•

depending on the organization’s remuneration policies and availability of data, consider all of
the following components:

1557
1558

(i) the base salary, which is the sum of guaranteed, short-term, and non-variable cash
compensation;

1559
1560
1561

(ii) total cash compensation, which is the sum of (i) the base salary, together with cash
allowances, bonuses, commissions, cash profit-sharing, and other forms of variable cash
payments;

1562
1563
1564
1565

(iii) direct compensation, which is the sum of (ii) total cash compensation, together withtotal fair value of all annual long-term incentives, such as stock option awards, restricted
stock shares or units, performance stock shares or units, phantom stock shares, stock
appreciation rights, and long-term cash awards.

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1566

5. Responsible business conduct

1567
1568
1569
1570
1571
1572
1573
1574

The disclosures in this section provide an overview of the organization’s policies and practices forresponsible business conduct. The disclosures are based on expectations for businesses contained ininternationally recognized instruments, which include the International Labour Organization (ILO),
Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy; the Organisation
for Economic Co-operation and Development (OECD), OECD Guidelines for Multinational Enterprises
and OECD Due Diligence Guidance for Responsible Business Conduct; and the United Nations (UN),Guiding Principles on Business and Human Rights. These instruments in turn are based on international
legal instruments, such as the UN’s International Bill of Human Rights and the ILO conventions.

1575
1576
1577
1578
1579
1580

Expectations for responsible business conduct include complying with laws and regulations;
respecting all internationally recognized human rights, including the rights of workers; protecting theenvironment, public health and safety; combating bribery, bribe solicitation, extortion, and otherforms of corruption; adhering to good tax practices; as well as conducting due diligence in order to
identify, prevent, mitigate, and account for how an organization addresses its negative impacts on theeconomy, environment, and people.

1581

Disclosure RBC-1 Statement on sustainable development strategy

1582

Requirements

1583

The organization shall:

1584
1585
1586

a. provide a statement from the highest governance body or most senior executive of
the organization about the relevance of sustainable development to theorganization and its strategy for contributing to sustainable development.

1587

Guidance

1588

Guidance to RBC-1

1589

The statement should include:

1590
1591
1592

•

the vision and strategy for the short-term, medium-term, and long-term, with respect tomanaging the organization’s impacts on the economy, environment, and people, including
impacts on human rights, across its activities and business relationships;

1593
1594

•

short-term and medium-term strategic priorities for contributing to sustainable
development, including observance of internationally recognized standards and agreements;

1595
1596

•

broader trends (e.g., macroeconomic or political) affecting the organization’s strategy forcontributing to sustainable development;

1597

•

changes in the business model to address impacts to sustainable development;

1598
1599

•

key events, achievements, and failures with respect to the organization’s contributions tosustainable development during the reporting period;

1600
1601

•

overview of performance against goals and targets for the organization’s material topics forcontributing to sustainable development during the reporting period;

1602
1603

•

the organization’s main challenges and goals and targets for the next year and for the coming
three to five years with respect to its contribution to sustainable development.

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1604
1605
1606

When determining whether the highest governance body or most senior executive provides therequired statement, the organization should consider its legal and operating context. For someorganizations this will be influenced by applicable legislation or regulation, which can be related to:

1607

•

the country where the organization is incorporated or registered;

1608

•

a stock exchange the organization trades its securities on;

1609
1610

•

the nature and type of the organization (e.g., charity, incorporated company, mutualorganization).

1611

Disclosure RBC-2 Policy commitments

1612

Requirements

1613

The organization shall:

1614

a. describe its policy commitments for responsible business conduct, including:

1615

i.

the internationally recognized instruments that the commitments reference;

1616

ii.

whether the commitments stipulate conducting due diligence;

1617

iii.

whether the commitments stipulate applying the precautionary principle;

1618

iv.

whether the commitments stipulate respecting human rights;

1619

b. describe its specific policy commitment to respect human rights, including:

1620

i.

the internationally recognized human rights that the commitment covers;

1621
1622

ii.

the categories of stakeholders, including at-risk or vulnerable groups, thatthe organization gives particular attention to in the commitment;

1623
1624

c. provide links to the policy commitments if publicly available, or, if the policy
commitments are not publicly available, explain the reason for this;

1625
1626
1627

d. report the level at which each of the policy commitments was approved within theorganization, including whether this is the most senior level, and the date of
approval;

1628
1629
1630
1631

e. report whether the policy commitments apply solely to the organization’s own
activities or whether they also stipulate the organization’s expectations of thosewith which it has business relationships and, if so, describe what those expectations
are;

1632
1633

f.

1634
1635

g. if the organization does not have any of the policy commitments in RBC-2-a,
explain the reason for not having them or describe any plans to develop them.

1636

Guidance

1637

Background

1638
1639

This disclosure covers the organization’s policy commitments for responsible business conduct,
including the commitment to respect human rights. These commitments can be set out in a

describe how the policy commitments are communicated to workers, business
partners, and other relevant parties;

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1640
1641

standalone policy document or they can be included within one or more other policy documents,
such as codes of conduct.

1642
1643
1644

The OECD Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible
Business Conduct, and the UN Guiding Principles on Business and Human Rights set out expectations fororganizations in relation to these commitments.

1645

Guidance to RBC-2-a

1646
1647

The organization should report the expectations, values, principles, and norms of behavior set out inthe policy commitments.

1648
1649

The organization can also report how the policy commitments were developed, including theinternal and external expertise that informed the policy commitments.

1650

Guidance to RBC-2-a-i

1651
1652

The introduction to this section (i.e., Section 5 of this Standard) provides examples of internationallyrecognized instruments for responsible business conduct.

1653

The organization can also make a reference to other standards or initiatives that it participates in.

1654

Guidance to RBC-2-a-iii

1655
1656
1657
1658

The precautionary principle is set out in Principle 15 of the UN Rio Declaration on Environment andDevelopment. It states: ‘Where there are threats of serious or irreversible damage, lack of fullscientific certainty shall not be used as a reason for postponing cost-effective measures to prevent
environmental degradation.’

1659
1660
1661

Applying the precautionary principle means taking early action in situations where there is sufficientreason to expect serious or irreversible damage, in advance of complete scientific understanding orevidence, to prevent and mitigate potential negative impacts on people’s health and the environment.

1662
1663
1664

While the precautionary principle is most often associated with the protection of the environment,
it can be applied to other areas, such as health and safety. The organization can describe the areas
where it applies the precautionary principle.

1665

Guidance to RBC-2-b-i

1666
1667
1668
1669
1670
1671

If the policy commitment covers all internationally recognized human rights, a brief statement of thisfact is sufficient to meet the requirement. The organization can also state if the policy commitment
references certain rights that require particular attention. For example, it can state that its policy
commitment covers all internationally recognized human rights and also references the rights to
privacy and freedom of expression in particular because the organization has identified that its
activities have an impact on these rights.

1672
1673
1674

If the policy commitment only covers some internationally recognized human rights, the organizationis required to state the rights that are covered. In addition, it can explain why the policy
commitment is limited to these rights.

1675

Guidance to RBC-2-b-ii

1676
1677
1678
1679
1680
1681
1682

Categories of stakeholders that the organization gives particular attention to can include consumers,
customers, employees, local communities, and workers, among others. They can also include
individuals belonging to groups or populations that are considered to be vulnerable or at risk, suchas women; persons who might be discriminated against based on their sexual orientation, gender
identity, gender expression, or sex characteristics (e.g., lesbian, gay, bisexual, transgender, intersex);
indigenous peoples; national or ethnic, religious and linguistic minorities; children; persons withdisabilities; migrant workers and their families; and/or human rights defenders.

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1683
1684
1685

For example, a bank might give particular attention in its policy commitment to avoid discriminating
against specific categories of customers, or a mining company might give particular attention to avoid
infringing on the rights of indigenous peoples.

1686

Guidance to RBC-2-d

1687
1688
1689

The most senior level can differ between organizations. For example, the most senior level in an
organization can be the highest governance body (e.g., the board), or it can be the most senior
executive (e.g., Chief Executive Officer).

1690
1691

The organization can also report the dates of adoption of the policy commitments (if different fromthe date of their approval), and how frequently they are reviewed.

1692

Guidance to RBC-2-e

1693
1694

If the policy commitments apply to all of the organization’s own activities and business relationships
equally, a brief statement of this fact is sufficient to meet the requirement.

1695
1696
1697
1698

If the policy commitments apply to only some of the organization’s own activities (e.g., they apply
only to entities located in certain countries, or to certain subsidiaries), the organization can reportwhich of its activities the commitments apply to and explain why the commitments are limited tothese activities.

1699
1700
1701
1702

If the policy commitments stipulate expectations for only some of the organization’s business
relationships, the organization can specify the types of business relationships (e.g., distributors,
franchisees, joint ventures, suppliers), and explain why the expectations are limited to these business
relationships.

1703
1704
1705

When describing the organization’s expectations of those with which it has business relationships,
the organization can explain whether they are obligated to abide by the policy commitments or are
encouraged (but not obligated) to do so.

1706

Guidance to RBC-2-f

1707

The organization can report:

1708
1709

•

whether the policy commitments need to be read, agreed to, and signed regularly by all
workers, business partners, and other relevant parties, such as governance body members;

1710
1711

•

the means through which it communicates the policy commitments (e.g., newsletters, formal
or informal meetings, dedicated websites, contractual agreements);

1712
1713

•

how it identifies and removes potential barriers to the communication or dissemination of
the policy commitments (e.g., by making them accessible and available in relevant languages).

1715

Disclosure RBC-3 Embedding the policy commitments throughout
the organization

1716

Requirements

1717

The organization shall:

1718
1719
1720

a. describe how the organization embeds each of its policy commitments forresponsible business conduct throughout its activities and business relationships,
including:

1714

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1721
1722

i.

how the organization allocates responsibility for implementing thecommitments across different levels within the organization;

1723
1724

ii.

how the organization integrates the commitments into organizational
strategies and operational policies and procedures;

1725
1726

iii.

how the organization works with those with which it has business
relationships, to implement the commitments;

1727

iv.

training that the organization provides on implementing the commitments.

1728

Guidance

1729

Background

1730
1731
1732
1733

This disclosure gives insight into how the organization embeds its policy commitments forresponsible business conduct, including the commitment to respect human rights, throughout its
activities and business relationships in order to ensure that people at all levels act responsibly andwith awareness of and respect for human rights.

1734

Guidance to RBC-3-a-i

1735
1736

The different levels within an organization can include the highest governance body, senior
executives, and operational levels.

1737

The organization can report:

1738
1739

•

the most senior level with oversight of, or accountability for, the implementation of thecommitments;

1740
1741
1742
1743

•

the functions in the organization with day-to-day responsibility for implementing each of thecommitments (e.g., human resources with the responsibility for implementing thecommitment to respect the rights of workers), their reporting lines to senior decisionmaking levels, and the reason for allocating the responsibility to them;

1744
1745

•

whether responsible business conduct is formally discussed at meetings of the highest
governance body or senior executives and, if so, which topics are discussed;

1746
1747
1748

•

whether there are other formal or systematic means for discussions about responsible
business conduct between different levels or functions in the organization (e.g., a crossfunctional working group).

1749

Guidance to RBC-3-a-ii

1750

The organization can describe:

1751

•

how it aligns the commitments with its:

1752

-

broader risk management systems and management policies;

1753

-

environmental and social impact or risk assessments and other due diligence processes;

1754
1755

-

policies and procedures that set financial and other performance incentives for
management or workers;

1756
1757

•

how it applies the commitments when making decisions, such as about its sourcing andoperating locations;

1758
1759

•

the systems it uses for monitoring compliance with the commitments across its activities andbusiness relationships.

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1760

Guidance to RBC-3-a-iii

1761

The organization can describe:

1762
1763

•

its procurement or investment policies and practices, and its engagement with those withwhich it has business relationships, including:

1764
1765

-

whether and how it applies pre-qualification processes, bidding criteria, or screening
criteria consistent with the expectations stipulated in the commitments;

1766
1767

-

whether and how it considers the commitments in contracting or investment
agreements, or in specific policies or codes of conduct for suppliers;

1768
1769

-

whether and how it considers the commitments in the process of determining whether
to initiate, continue, or terminate a business relationship;

1770
1771

•

processes through which it enables or supports business partners and other parties toimplement the commitments (e.g., capacity building, peer sharing);

1772
1773

•

incentives that it offers to business partners and other parties to implement thecommitments (e.g., price premiums, increased orders, or long-term contracts).

1774

Guidance to RBC-3-a-iv

1775

The organization can report:

1776

•

the content of the training;

1777

•

to whom the training is provided, and whether it is mandatory;

1778

•

the form (e.g., in-person, online) and frequency of the training;

1779

•

examples of how the organization has determined that the training is effective.

1780
1781
1782

The organization can report whether the training covers how to implement the commitments ingeneral or in specific situations (e.g., ensuring the commitment toward privacy when handlingcustomers’ personal data, or ensuring the commitments are considered in procurement practices).

1783
1784
1785
1786
1787

The organization can specify if training is provided to those with day-to-day responsibility for andthose with oversight of, or accountability for, the implementation of the commitments, as well as tothose with which the organization has business relationships (e.g., distributors, franchisees, joint
ventures, suppliers). The organization can also report the number or percentage of individuals,
business partners, and other parties that have been trained during the reporting period.

1788
1789

Disclosure RBC-4 Grievance mechanisms and other remediation
processes

1790

Requirements

1791

The organization shall:

1792
1793

a. describe its commitments to provide for or cooperate in the remediation ofnegative impacts that the organization identifies it has caused or contributed to;1794

b. describe its approach to identify and address grievances, including:

1795
1796

i.

the grievance mechanisms that the organization has established or
participates in;

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1797
1798
1799

ii.

other processes by which the organization provides for or cooperates in theremediation of negative impacts that it identifies it has caused or contributed
to;

1800
1801
1802

c. describe how the stakeholders who are the intended users of the grievancemechanisms and other remediation processes are involved in the design, review,
operation, and improvement of these mechanisms and processes;

1803
1804
1805

d. describe how the organization tracks the effectiveness of the grievancemechanisms and other remediation processes and provide examples of theireffectiveness, including stakeholder feedback.

1806

Guidance

1807

Background

1808
1809
1810
1811

This disclosure covers grievance mechanisms and other remediation processes that the organization
has established or participates in. These mechanisms and processes enable stakeholders to raise
concerns about impacts (actual and potential) that the organization has on them, including impacts
on their human rights, and to seek remedy.

1812
1813
1814
1815

The UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational
Enterprises set out expectations for organizations to provide for or cooperate in the remediation,
through legitimate processes, of negative impacts that they identify they have caused or contributed
to, and to establish or participate in effective operational-level grievance mechanisms.

1816
1817
1818
1819

Grievance mechanisms are distinct from whistleblower mechanisms. Whistleblower mechanisms
enable individuals to raise concerns about wrongdoing or breaches of the law in the organization’s
operations or business relationships, regardless of whether the individuals themselves are harmed ornot. Whistleblower mechanisms are to be reported under Disclosure RBC-5.

1820

Guidance to RBC-4

1821
1822
1823
1824
1825
1826

This disclosure covers the operation of grievance mechanisms and other remediation processes thatthe organization has established or participates in. The disclosure does not cover environmental
remediation processes, such as processes to remove contaminants from soil, when these are notconnected to grievances raised by stakeholders. However, the remedy provided to stakeholders
through the mechanisms and processes covered by this disclosure can involve environmental
remediation.

1827
1828
1829
1830

Examples where the organization has provided for or cooperated in the remediation of specificnegative impacts through grievance mechanisms and other remediation processes, as well as
environmental remediation processes, are to be reported under MT-3-b-ii in GRI 103: Material
Topics.

1831

Guidance to RBC-4-b-i

1832
1833

Grievance mechanisms refer to any routinized, State-based or non-State-based, judicial or nonjudicial processes through which stakeholders can raise grievances and seek remedy.

1834
1835
1836
1837

Examples of State-based grievance mechanisms, both judicial and non-judicial, include courts (forboth criminal and civil actions), labor tribunals, national human rights institutions, National Contact
Points under the OECD Guidelines for Multinational Enterprises, ombudsperson offices, consumer
protection agencies, regulatory oversight bodies, and government-run complaints offices.

1838
1839
1840

Non-State-based grievance mechanisms include those administered by the organization either alone
or together with stakeholders, such as operational-level grievance mechanisms. It also includes
collective bargaining and the mechanisms established by collective bargaining, as well as mechanisms

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1841
1842

administered by industry associations, international organizations, civil society organizations, or
multi-stakeholder groups.

1843
1844
1845
1846
1847

Operational-level grievance mechanisms are administered by the organization either alone or incollaboration with other parties and are directly accessible by the organization’s stakeholders. They
allow for grievances to be identified and addressed early and directly, thereby preventing both harmand grievances from escalating, and can provide important feedback on the effectiveness of theorganization’s due diligence from those who are directly affected.

1848

The organization can describe:

1849
1850
1851
1852
1853
1854

•

the intended purpose and users of the mechanisms (i.e., whether they are intended for aparticular stakeholder category, topic, or region) and whether they enable users to raisehuman rights-related concerns. For example, the organization can explain that it hasestablished a mechanism for community members to raise complaints about resettlement
and a separate hotline for workers to raise concerns about issues affecting their rights, suchas health and safety conditions;

1855
1856

•

how the mechanisms operate and who administers them (the organization and/or anotherparty);

1857
1858
1859

•

for operational-level grievance mechanisms, whether they are administered at theorganizational level or at a lower level, such as at the site or project level, and in the latter
case, how data from these mechanisms is centralized;

1860
1861
1862

•

how the mechanisms have been designed and the principles and guidelines on which they arebased, including whether they are designed to meet the effectiveness criteria set out in UN
Guiding Principle 31;

1863

•

the process through which grievances are investigated;

1864

•

whether grievances are treated confidentially;

1865
1866

•

whether the mechanisms can be used by stakeholders anonymously through representation
by a third party;

1867
1868

•

whether the organization requires or provides incentives for the creation or improvementof operational-level grievance mechanisms in workplaces of suppliers;

1869
1870
1871

•

whether the organization provides a back-up process for workplaces of suppliers that do nothave operational-level grievance mechanisms or where the existing grievance mechanisms inthose workplaces result in unresolved issues.

1872

Guidance to RBC-4-b-ii

1873

RBC-4-b-ii covers remediation processes other than grievance mechanisms.

1874
1875
1876
1877

Examples include a customer service desk where customers can raise complaints about
discrimination or privacy issues and receive remedy, or instances where the organization takes
action to remediate an actual impact evidenced in an impact assessment or a report published by acivil society organization.

1878

See Guidance to RBC-4-b-i for more information on how to report on other remediation processes.

1879

Guidance to RBC-4-c

1880
1881
1882

The organization can describe, for example, how it engages with stakeholders who are the intended
users of the grievance mechanisms, to understand how they want to access the mechanisms to raise
concerns and their expectations about how the mechanisms will operate.

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1883

Guidance to RBC-4-d

1884
1885
1886
1887
1888
1889

According to UN Guiding Principle 31, effective grievance mechanisms are legitimate, accessible,
predictable, equitable, transparent, rights-compatible, and a source of continuous learning. In
addition to these criteria, effective operational-level grievance mechanisms are also based on
engagement and dialogue. It is acknowledged that it can be more difficult for the organization toassess the effectiveness of grievance mechanisms that it participates in compared to those it hasestablished itself.

1890

The organization can report:

1891
1892

•

whether and how the intended users are informed about the grievance mechanisms andremediation processes and trained on how to use them;

1893
1894

•

the accessibility of the mechanisms and processes, such as the total number of hours per day
or days per week that they are available and their availability in different languages;

1895
1896

•

how the organization seeks to ensure that users are treated with respect and protectedagainst reprisals (i.e., non-retaliation for raising complaints or concerns);

1897
1898

•

how satisfied users are with the mechanisms and processes or the resulting outcomes, andhow the organization assesses users’ satisfaction;

1899
1900
1901

•

the number and types of grievances filed during the reporting period, and the percentage ofgrievances that were addressed and resolved, including the percentage that were resolved
through remediation;

1902

•

the number of grievances filed during the reporting period that are repeated or recurring;

1903
1904

•

changes made to the mechanisms and processes in response to lessons learned about theireffectiveness.

1905
1906
1907
1908
1909

Quantitative information, such as the number of grievances, is unlikely to be sufficient on its own.
For example, a low number of grievances could indicate that few incidents have occurred, but it
could equally signal that the mechanisms are not trusted by their intended users. For this reason,contextual information should be provided to aid in understanding and interpreting the quantitative
information.

1910
1911

Disclosure RBC-5 Mechanisms for seeking advice and raisingconcerns

1912

Requirements

1913

The organization shall:

1914

a. describe the mechanisms for individuals to:

1915
1916

i.

seek advice on implementing the organization’s policies and practices forresponsible business conduct;

1917

ii.

raise concerns about the organization’s responsible business conduct.

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1918

Guidance

1919

Background

1920
1921
1922
1923
1924

This disclosure covers the organization’s mechanisms for individuals to seek advice and to raise
concerns about responsible business conduct in the operations of the organization and its business
relationships. Examples of these mechanisms include confidential interviews during site visits,
escalation processes (to raise issues through management levels), hotlines, mechanisms to reportnon-compliance with laws and regulations, and whistleblowing mechanisms.

1925
1926
1927
1928
1929
1930

These mechanisms enable individuals to raise concerns about wrongdoing or breaches of the law inthe organization’s operations or business relationships, regardless of whether the individuals
themselves are harmed or not. They are distinct from grievance mechanisms, which enable
stakeholders to raise concerns about impacts (actual and potential) that the organization has onthem, including impacts on their human rights, and to seek remedy. Grievance mechanisms are to bereported under Disclosure RBC-4.

1931

Guidance to RBC-5

1932
1933
1934
1935

If the organization’s grievance mechanisms and its mechanisms for seeking advice and raisingconcerns about responsible business conduct operate in a similar way, the organization can provide
a single description of how these mechanisms operate and clearly state which mechanisms thedescription covers.

1936

Guidance to RBC-5-a

1937

The organization can report:

1938

•

who the intended users of the mechanisms are;

1939
1940

•

how the mechanisms operate and which level or function in the organization is assigned
responsibility for them;

1941

•

whether the mechanisms operate independently of the organization (e.g., by a third party);

1942

•

the process through which concerns are investigated;

1943

•

whether requests for advice and concerns raised are treated confidentially;

1944

•

whether the mechanisms can be used anonymously.

1945

Additionally, the organization can report on the effectiveness of the mechanisms, including:

1946
1947

•

whether and how the intended users are informed of the mechanisms and trained on how to
use them;

1948
1949

•

the accessibility of the mechanisms, such as the total number of hours per day or days per
week that they are available and their availability in different languages;

1950
1951

•

how the organization seeks to ensure users are treated with respect and protected against
reprisals (i.e., non-retaliation for reporting concerns);

1952

•

how satisfied users are with the mechanisms or the resulting outcomes;

1953
1954

•

the number and types of requests for advice received during the reporting period, and thepercentage of requests that were answered;

1955
1956

•

the number and types of concerns raised during the reporting period, and the percentage ofconcerns that were addressed and resolved, or found to be unsubstantiated.

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1957

Disclosure RBC-6 Compliance with laws and regulations

1958

Requirements

1959

The organization shall:

1960
1961
1962

a. report instances of non-compliance with laws or regulations for which significant
fines or non-monetary sanctions were incurred during the reporting period,
including:

1963

i.

total monetary value of the significant fines incurred;

1964
1965

ii.

total number of significant fines and total number of non-monetary sanctions
incurred;

1966
1967

iii.

the nature of each instance of non-compliance for which a significant fine or
non-monetary sanction was incurred;

1968
1969
1970

b. report instances of non-compliance with laws or regulations raised through dispute
resolution mechanisms during the reporting period, including the nature of each
instance of non-compliance.

1971

Guidance

1972

Background

1973
1974
1975
1976

This disclosure addresses all laws and regulations related to economic, environmental, and social
matters that are applicable to the organization. These laws and regulations can be issued by a variety
of bodies including governments (local, regional, and national), regulatory authorities, and publicagencies.

1977

Laws and regulations include:

1978

•

international declarations, conventions, and treaties;

1979

•

national, subnational, regional, and local regulations;

1980
1981

•

binding voluntary agreements made with regulatory authorities and developed as a substitutefor implementing a new regulation;

1982
1983
1984

•

voluntary agreements (or covenants) if the organization directly joins the agreement, or if
public agencies make the agreement applicable to organizations in their territory throughlegislation or regulation.

1985
1986
1987

Laws and regulations relating to economic and social matters include topics such as accounting andtax fraud, corruption, bribery, competition, the provision of products and services, or labor issues,
such as workplace discrimination.

1988
1989

Laws and regulations relating to environmental matters include topics such as biodiversity, emissions,energy, material use, spills and leaks, waste, and water and effluents.

1990
1991
1992
1993
1994

Non-compliance with laws and regulations can give insight into the ability of management to ensurethat the organization conforms to certain performance parameters. In some circumstances, noncompliance can lead to remediation obligations or liabilities other than fines, such as clean-up
obligations in the case of environmental issues. The strength of an organization’s compliance record
can also influence its ability to gain permits and consequently to expand operations.

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1995

Guidance to RBC-6

1996
1997
1998

Non-monetary sanctions can include restrictions imposed by governments, regulatory authorities, or
public agencies, on the organization’s activities or operations, such as withdrawal of trading licenses
or licenses to operate in highly regulated industries.

1999
2000
2001
2002
2003

A fine or non-monetary sanction is significant if it could influence decision-making by information
users making use of the organization’s reported information. If the fine or non-monetary sanction isreported in the organization’s audited consolidated financial statements or in the financial
information filed on public record, it can be considered significant and is required to be reported
under this disclosure.

2004
2005
2006

If the organization has not incurred any significant fines or non-monetary sanctions for noncompliance with laws or regulations, a brief statement of this fact is sufficient to meet therequirement.

2007

Disclosure RBC-7 Membership associations

2008

Requirements

2009

The organization shall:

2010
2011

a. report industry and other membership associations and national and international
advocacy organizations in which it has a significant role.

2012

Guidance

2013

Guidance to RBC-7

2014
2015
2016
2017

The organization can have a significant role in an association or advocacy organization when it holds
a position in the governance body, participates in projects or committees, provides substantive
funding beyond routine membership dues, or views its membership as strategic to influencing themission or objective of the association that is critical to the organization’s own activities.

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2018

6. Stakeholder engagement

2019
2020

This section includes disclosures on the organization’s stakeholder engagement practices, including
how it engages in collective bargaining with employees.

2021

Disclosure SE-1 Approach to stakeholder engagement2022

Requirements

2023

The organization shall:

2024

a. describe its approach to engaging with stakeholders, including:

2025

i.

the categories of stakeholders it engages with, and how they are identified;

2026

ii.

the purpose of the stakeholder engagement;

2027
2028

iii.

how the organization seeks to ensure meaningful engagement withstakeholders.

2029

Guidance

2030

Guidance to SE-1

2031
2032
2033

Stakeholders are individuals or groups who have interests that are, or could be, affected by theorganization’s activities and decisions. For more information on stakeholders, see Section 2.4 of GRI
101: Using the GRI Standards.

2034
2035

This disclosure covers stakeholder engagement undertaken by the organization as part of its ongoing
activities rather than for the purpose of sustainability reporting.

2036

Guidance to SE-1-a-i

2037
2038
2039
2040

Common categories of stakeholders for organizations include business partners, civil society
organizations, consumers, customers, employees and other workers, governments, local
communities, non-governmental organizations, shareholders, suppliers, trade unions, and vulnerable
groups.

2041
2042

The organization can explain how it determines which categories of stakeholders to engage with andwhich categories not to engage with.

2043

Guidance to SE-1-a-ii

2044
2045
2046
2047
2048

The organization can report the types of activities and decisions for which it engages withstakeholders, for example, to identify actual and potential negative impacts, or to determine
prevention and mitigation responses to potential negative impacts. In some cases, stakeholder
engagement is a right in and of itself, for example, the right of workers to form or join trade unions
or their right to bargain collectively.

2049

The organization can additionally report:

2050
2051
2052

•

the type and frequency (e.g., annually, quarterly) of stakeholder engagement. For example,
whether the engagements are ongoing (e.g., in the case of systemic issues) or whether they
are specific engagements with particular groups or for particular operations or projects;

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2053
2054
2055

•

when the organization engages directly with stakeholders and when it engages with credible
stakeholder representatives or proxy organizations, or other credible independent expert
resources, and why;

2056
2057
2058

•

whether stakeholder engagement activities take place at the organizational level or at alower level, such as at the site or project level, and in the latter case, how data fromstakeholder engagement activities is centralized;

2059

•

the resources (e.g., financial or human resources) allocated to stakeholder engagement.

2060
2061
2062
2063

Further information on stakeholder engagement undertaken for specific activities, for example, forthe setup and operation of grievance mechanisms and other remediation processes, or for theidentification and management of material topics and related impacts, is reported under otherdisclosures (RBC-4-d in this Standard, and MT-1-a-iii and MT-3-d in GRI 103: Material Topics).

2064

Guidance to SE-1-a-iii

2065
2066
2067
2068

As stated in the OECD Due Diligence Guidance for Responsible Business Conduct, meaningful stakeholder
engagement is characterized by two-way communication and depends on the good faith ofparticipants on both sides. It is also responsive and ongoing, and includes engaging with relevant
stakeholders before decisions are made.

2069

The organization can report:

2070
2071

•

how it takes into account potential barriers to stakeholder engagement (e.g., language andcultural differences, gender and power imbalances, divisions within a community or group);

2072
2073

•

how it engages with at-risk or vulnerable groups, such as whether it takes specificapproaches and gives special attention to potential barriers;

2074
2075

•

how it provides stakeholders with information that is understandable and accessible throughappropriate communication channels;

2076
2077

•

how stakeholder feedback is recorded and integrated into decision-making, and how
stakeholders are informed about how their feedback has influenced decisions;

2078
2079

•

how it seeks to respect the human rights of all stakeholders engaged, such as their rights to
privacy, freedom of expression, and peaceful assembly and protest;

2080
2081
2082

•

how it works with business partners to engage with stakeholders in a meaningful way,
including expectations it places on business partners to respect the rights of stakeholders
during engagement.

2083

Disclosure SE-2 Collective bargaining agreements

2084

Requirements

2085

The organization shall:

2086
2087

a. report the percentage of total employees covered by collective bargaining
agreements;

2088
2089
2090
2091

b. for employees not covered by collective bargaining agreements, report whether it
determines their working conditions and terms of employment based on its
existing collective bargaining agreements that cover other employees or based oncollective bargaining agreements from other organizations.

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2092

Guidance2093

Background

2094
2095

The right to collective bargaining is a fundamental right at work that is covered in the ILO Right toOrganise and Collective Bargaining Convention.

2096
2097
2098
2099
2100
2101

Collective bargaining refers to negotiations that take place between one or more employers or
employers' organizations and one or more workers' organizations (trade unions). The objective of
these negotiations is to reach a collective agreement on working conditions and terms of
employment (e.g., wages and working time) or to regulate relations between employers andworkers.1 These negotiations are an important means through which organizations and trade unions
can improve working conditions and labor relations.

2102
2103
2104
2105

Collective agreements can be made at the level of the organization, at the level of a particular site,
and/or at the industry level or at the national level in countries where this is the practice. Collective
agreements can cover specific groups of workers, for example, those performing a specific activity or
working at a specific location.

2106

See references 1, 2, 3, 4, 5, 9, 10, 24, 26, and 27 in the References section.

2107

Guidance to SE-2-a

2108
2109
2110
2111

SE-2-a provides information on the proportion of the organization’s employees whose working
conditions and terms of employment (e.g., wages and working time) are regulated by one or morecollective bargaining agreements. This can give insight into whether the organization respects its
employees’ rights to collective bargaining and freedom of association.

2112
2113
2114
2115
2116
2117
2118
2119

This requirement does not ask for the percentage of employees belonging to trade unions, whichmight be a different number. The percentage of employees covered by collective bargaining
agreements can be higher than the percentage of unionized employees when an organization isrequired to apply the collective bargaining agreements to both union and non-union members.
Alternatively, the percentage of employees covered by collective bargaining agreements can belower than the percentage of unionized employees when there are no collective bargaining
agreements available or when the collective bargaining agreements do not cover all unionizedemployees.

2120
2121

The percentage of total employees covered by collective bargaining agreements is calculated using
the following formula:2122

Number of employees covered by collective bargaining agreements
× 100
Total number of employees reported under Disclosure ACT-2

2123
2124
2125

The employees covered by collective bargaining agreements are those employees to whom theorganization is obliged to apply the agreement. If an employee is covered by more than one
collective bargaining agreement, it only needs to be counted once.

2126
2127

Employees who are represented by a works council are not included under SE-2-a, unless the works
council engages in collective bargaining that results in a collective bargaining agreement.

2128
2129

If none of the organization’s employees are covered by collective bargaining agreements, a brief
statement of this fact is sufficient to meet the requirement.

2130
2131

The organization can additionally report the percentage of employees covered by collective
bargaining agreements per region or country, or provide comparisons with industry benchmarks.

1

International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

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2132

Guidance to SE-2-b

2133
2134
2135
2136
2137

SE-2-b only applies to organizations where some or all employees are not covered by collective
bargaining agreements. In these cases, the organization might determine the working conditions andterms of employment of these employees based on its existing collective bargaining agreements thatcover other employees (as reported under SE-2-a) or based on collective bargaining agreementsfrom other organizations. SE-2-b requires the organization to report if this is the case.

2138
2139

If all the organization’s employees are covered by collective bargaining agreements, the organization
does not need to report the information in SE-2-b.

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2140

References

2141
2142

The following documents informed the development of this Standard and can be helpful forunderstanding and applying it.

2143

Authoritative intergovernmental instruments:

2144

1. International Labour Organization (ILO), Collective Agreements Recommendation, 1951 (No. 91).

2145

2. International Labour Organization (ILO), Collective Bargaining Convention, 1981 (No. 154).

2146

3. International Labour Organization (ILO), Collective Bargaining Recommendation, 1981 (No. 163).

2147
2148

4. International Labour Organization (ILO), Declaration on Fundamental Principles and Rights at Work,
1998.

2149
2150

5. International Labour Organization (ILO), Freedom of Association and Protection of the Right toOrganise Convention, 1948 (No. 87).

2151

6. International Labour Organization (ILO), ILOSTAT, https://ilostat.ilo.org/, accessed on 6 May 2020.

2152
2153
2154

7. International Labour Organization (ILO), Key Indicators of the Labour Market (KILM),
http://www.ilo.org/global/statistics-and-databases/research-and-databases/kilm/lang--en/index.htm,
accessed on 6 May 2020.

2155
2156

8. International Labour Organization (ILO), Resolution concerning the International Classification of
Status in Employment (ICSE), 1993.

2157
2158

9. International Labour Organization (ILO), Right to Organise and Collective Bargaining Convention,
1949 (No. 98).

2159

10. International Labour Organization (ILO), Workers’ Representatives Convention, 1971 (No. 135).

2160
2161

11. Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018.

2162
2163

12. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011.

2164
2165

13. Organisation for Economic Co-operation and Development (OECD), OECD Principles ofCorporate Governance, 2004.

2166
2167

14. United Nations (UN), Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework, 2011.

2168

15. United Nations (UN), International Bill of Human Rights:

2169

15.1 United Nations (UN), Universal Declaration of Human Rights, 1948.

2170

15.2 United Nations (UN), International Covenant on Civil and Political Rights, 1966.

2171

15.3 United Nations (UN), International Covenant on Economic, Social, and Cultural Rights, 1966.

2172
2173

15.4 United Nations (UN), Optional Protocol to the International Covenant on Civil and Political
Rights, 1966.

2174
2175

15.5 United Nations (UN), Second Optional Protocol to the International Covenant on Civil andPolitical Rights, aiming at the abolition of the death penalty, 1989.

2176
2177

16. United Nations (UN), Methodology. Standard country or area codes for statistical use (M49),
http://unstats.un.org/unsd/methods/m49/m49regin.htm, accessed on 6 May 2020.

2178
2179

17. United Nations (UN), Protect, Respect and Remedy: a Framework for Business and Human Rights,
2008.

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2180
2181

18. United Nations (UN), Report of the Special Representative of the Secretary-General on the Issue of
Human Rights and Transnational Corporations and Other Business Enterprises, John Ruggie, 2011.

2182

19. United Nations (UN), Rio Declaration on Environment and Development, 1992.

2183
2184

20. United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive Guide,
2012.

2185

Other relevant references:

2186
2187
2188

21. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights, and United Nations Global Compact, Human Rights Translated 2.0: A Business
Reference Guide, 2017.

2189
2190

22. Committee on Workers’ Capital (CWC), Guidelines for the Evaluation of Workers’ Human Rights
and Labour Standards, 2017.

2191
2192

23. Corporate Human Rights Benchmark Ltd., Corporate Human Rights Benchmark methodology,
updated annually.

2193
2194
2195

24. International Labour Organization (ILO), 8.Freedom of Association and Collective Bargaining,https://www.ilo.org/global/topics/dw4sd/themes/freedom-of-association/lang--en/index.htm, accessed on
6 May 2020.

2196
2197

25. International Labour Organization (ILO), Non-standard employment around the world:
Understanding challenges, shaping prospects, 2016.

2198
2199
2200
2201

26. J. Visser, S. Hayter, and R. Gammarano, ‘Trends in collective bargaining coverage: stability,
erosion or decline?’, Issue Brief no. 1 – Labour Relations and Collective Bargaining, February 2017,https://www.ilo.org/wcmsp5/groups/public/---ed_protect/---protrav/--travail/documents/publication/wcms_409422.pdf, accessed on 6 May 2020.

2202

27. ShareAction, The Workforce Disclosure Initiative 2019 Survey Guidance Document, 2019.

2203

28. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

2204
2205

29. Shift, Oxfam, and Global Compact Network Netherlands, Doing Business with Respect for Human
Rights: A Guidance Tool for Companies, 2016.

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2206

GRI 103: Material Topics

GRI 103: Material Topics

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2207

2208

Contents
1.

Introduction ................................................................................................................................................. 79

2209

1.1

Overview of this Standard ............................................................................................................... 79

2210

1.2

GRI Standards ..................................................................................................................................... 79

2211

1.3

Requirements, guidance, and defined terms ................................................................................ 80

2212

2.

Identifying material topics ......................................................................................................................... 82

2213

Step 1. Assess the organization’s context .................................................................................................. 83

2214

Step 2. Identify actual and potential impacts .............................................................................................. 84

2215

Step 3. Assess the significance of identified impacts ................................................................................ 87

2216

Step 4. Prioritize the most significant impacts for reporting ................................................................. 88

2217

3.

Reporting on material topics .................................................................................................................... 90

2218

Disclosure MT-1 Identification of material topics and related impacts............................................... 90

2219

Disclosure MT-2 Material topics and related impacts ............................................................................. 922220

Disclosure MT-3 Management of material topics and related impacts ............................................... 94

2221

References .............................................................................................................................................................. 98

2222
2223

Note 1: Defined terms are underlined in the text of the GRI Standards and hyperlinked to theirdefinitions in the Glossary.

2224
2225
2226
2227

Note 2: The disclosure codes used in this Standard (e.g., MT-1) are not the final disclosure codes.
They are intended for the purpose of the public comment, to help users distinguish these disclosuresfrom the existing disclosures in GRI 102: General Disclosures 2016 and GRI 103: Management Approach2016.

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2228

1. Introduction

2229
2230
2231

GRI 103: Material Topics is to be used by the organization to identify and to report on its material
topics. Material topics are topics that reflect the organization’s most significant impacts on theeconomy, environment, and people, including impacts on human rights.

2232
2233
2234

An organization reporting in accordance with the GRI Standards is required to identify its material
topics and to report all disclosures in this Standard, as set out in Section 3.1 of GRI 101: Using the
GRI Standards.

2235
2236
2237
2238

The organization is also required to use the GRI Sector Standard(s) that apply to its sector(s), wherethese are available, to identify its material topics. The Sector Standards provide information on themost likely material topics for organizations in a given sector. Using Sector Standards, however, is
not a substitute for the organization’s own process for identifying material topics.

2239

1.1 Overview of this Standard

2240

This Standard is structured as follows:

2241

•

Section 2 includes guidance in four steps on how to identify material topics.

2242
2243

•

Section 3 contains three disclosures for the organization to report its material topics andrelated impacts, how it identifies its material topics, and how it manages each material topic.

2244

1.2 GRI Standards

2245
2246
2247
2248
2249

The GRI Standards help organizations increase their transparency and communicate theircontribution to sustainable development. The GRI Standards are designed to be used by anyorganization – large or small, private or public, regardless of sector, location, and reporting
experience. The Standards provide a consistent and credible way for organizations to report on
their impacts, which in turn enhances the global comparability and quality of this information.

2250
2251
2252

The Standards provide a flexible framework for reporting. Organizations can either report on all
their material topics in accordance with the GRI Standards, or they can use selected GRI Standards,
or parts of their content, to report information with reference to the GRI Standards.

2253

Structure of the GRI Standards

2254
2255

The GRI Standards consist of three sets of Standards: Universal Standards, Sector Standards, andTopic Standards.

2256

Universal Standards

2257
2258

The three Universal Standards apply to all organizations reporting in accordance with the GRI
Standards.

2259
2260

GRI 101: Using the GRI Standards is the starting point for all organizations. It introduces thesystem of GRI Standards and explains how they are to be used.

2261
2262

GRI 102: About the Organization contains disclosures for contextual information about theorganization.

2263
2264

GRI 103: Material Topics includes guidance for identifying material topics, and contains disclosuresabout the organization’s material topics and how it identifies and manages them.

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2265

Sector Standards

2266
2267
2268

The Sector Standards provide information on the most likely material topics for organizations in agiven sector. The organization uses the applicable Sector Standard(s) to assist in identifying its
material topics and what to report for each material topic.

2269

Topic Standards

2270
2271
2272

The Topic Standards include disclosures that provide information on particular topics. The
organization selects and uses the Topic Standards that correspond to the material topics it has
identified.

2273

Figure 1. GRI Standards: Universal, Sector, and Topic Standards

2274

1.3 Requirements, guidance, and defined terms

2275

The following apply throughout the GRI Standards:

2276

Requirements are presented in bold font and indicated with the word 'shall'.

2277
2278
2279

As set out in Section 3.1 of GRI 101: Using the GRI Standards, information required by the disclosuresin GRI 103 cannot be omitted. All information required by the disclosures in GRI 103 is considered
critical for information users to understand the organization’s approach to its material topics.

2280
2281
2282
2283

If the organization is unable to report the required information about an item specified in adisclosure because the item, e.g., a policy, practice, or other process, does not exist, it can meet therequirement by reporting this to be the case. In such cases, the disclosure does not require theorganization to implement the item, such as the process, but to report if it does not exist.

2284
2285

For example, Disclosure MT-3 requires the organization to report its goals and targets for eachmaterial topic, among other items. If the organization does not have goals and targets for a material

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2286
2287

topic, then it is required to state this. This ensures transparency for information users and enables
the organization to meet the requirement.

2288
2289
2290
2291
2292

If the organization is required to report information that it has previously reported, and theinformation has not changed during the reporting period (e.g., the organization is required to report
information on a policy or process that has not changed since the previous reporting period), theorganization can republish this information or provide a reference to the previously reported
information.

2293
2294

Guidance sections include background information, explanations, and examples to helporganizations better understand the requirements.

2295
2296

The guidance sections also include ‘should’ statements, which indicate recommendations, and ‘can’statements, which indicate a possibility or an option.

2297

The organization is not required to comply with guidance.

2298
2299

Defined terms are underlined in the text of the GRI Standards and hyperlinked to their definitionsin the Glossary. The organization is required to apply the definitions in the Glossary.

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2300

2. Identifying material topics

2301
2302

This section describes the steps that the organization should go through in order to identify its
material topics; following these steps is not a requirement.

2303
2304
2305

The first three of these steps relate to the organization’s ongoing identification and assessment of
impacts as part of its regular activities in order to manage its impacts. These three steps in turninform the last step, which is the identification of material topics for reporting.

2306
2307
2308
2309

In subsequent reporting periods, the organization should review the previously identified material
topics to account for changes in its activities and business relationships that lead to a change in its
impacts. This helps to ensure the material topics are still representative of the organization’s mostsignificant impacts in each reporting period.

2310

Figure 2. Steps for identifying material topics

2311
2312
2313
2314
2315

The approach applied for each step will vary according to the specific circumstances of theorganization, such as its business model; sector; geographic, cultural and legal operating context;
ownership structure; and the nature of its impacts. Given these specific circumstances, theorganization should use a systematic, replicable, and documented approach to identify its material
topics. In particular, the organization should:

2316
2317
2318

•

document the process for identifying its material topics, including the approach, assumptions,and decisions taken. Accurate records help the organization to fulfil relevant disclosures andto explain its chosen approach, and they facilitate analysis and assurance;

2319
2320

•

apply the steps to identify material topics consistently over time, and document any changes
to the approach along with their implications;

2321
2322

•

be transparent about any subjective judgments it has made in the process to identify material
topics.

2323
2324

In addition, the highest governance body should oversee the process and approve the identified
material topics.

2325

The next sections describe the four steps in more detail.

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2326

Step 1. Assess the organization’s context

2327
2328
2329

This step involves the organization assessing its activities and business relationships and the context
in which these take place. This provides the organization with critical information for identifying its
actual and potential impacts.

2330
2331
2332
2333
2334

Relevant departments and functions within the organization can assist with assessing its activities andbusiness relationship and their context, for example, communications, human resources, investor
relations, legal and compliance department or functions, marketing and sales, procurement, andproduct development. The GRI Sector Standards also provide useful contextual information for theorganization’s sector(s).

2335

Assessing activities

2336

The organization should assess the following for its own activities:

2337
2338

•

The types of activities it carries out (e.g., sales, marketing, manufacturing, distribution) andthe geographic locations of these activities.

2339
2340
2341

•

The types of products and services it offers, and the markets served (i.e., the types ofcustomers and beneficiaries targeted, and the geographic locations where products andservices are offered).

2342
2343

•

The sector(s) in which the organization is active and the characteristics of the sector(s) (e.g.,whether it involves informal work, or is labor or resource intensive).

2344
2345
2346

•

The number of employees, including their employment type (full-time or part-time),
employment contract (permanent or temporary), and demographic characteristics (e.g.,gender, age, geographic location).

2347
2348
2349
2350
2351

•

The number of workers who are not employees that perform work for the organization,
including the types of worker (e.g., agency workers, contractors, self-employed persons,volunteers), their contractual relationship with the organization (whether the organization
engages these workers directly or indirectly through a third party), and the nature of work
they perform.

2352

Assessing business relationships

2353
2354
2355
2356

The organization’s business relationships include relationships with business partners, entities in its
value chain (including entities beyond the first tier), and any other entities directly linked to its
operations, products, or services. The organization should assess the following for its business
relationships:

2357

•

The types of business relationships it has (e.g., joint ventures, suppliers, franchisees).

2358
2359

•

The types of activities undertaken by these business relationships (e.g., manufacturing theorganization’s products, providing security services to the organization).

2360
2361

•

The nature of the business relationships (e.g., whether they are based on a long-term or
short-term contract, or based on a specific project or event).

2362

•

The geographic location of the business relationships.

2363

Assessing context

2364
2365

The organization should assess the following in order to understand the context in which its
activities and business relationships take place:

2366
2367

•

Economic conditions, societal issues, and environmental challenges at local, regional, andglobal levels related to the organization’s sector(s) and the geographic locations of its

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2368
2369

activities and business relationships (e.g., poverty, political conflict, water security, climatechange, lack of law enforcement).

2370
2371
2372
2373
2374
2375

•

The organization’s responsibility in relation to the international standards and agreementswith which it is expected to comply; for example, the International Bill of Human Rights; theInternational Labour Organization (ILO), Tripartite Declaration of Principles concerning
Multinational Enterprises and Social Policy; the Organisation for Economic Co-operation andDevelopment (OECD), OECD Guidelines for Multinational Enterprises; or the United Nations(UN), Guiding Principles on Business and Human Rights.

2376
2377

•

The organization’s responsibility in relation to the laws and regulations with which it isexpected to comply.

2378
2379

•

The organization’s vision and mission, strategy, business model, and policy commitments forresponsible business conduct.

2380

Step 2. Identify actual and potential impacts

2381
2382
2383

This step involves the organization identifying its actual and potential, negative and positive impacts
on the economy, environment, and people, including impacts on human rights, across its own
activities and its business relationships.

2384
2385
2386

In order to identify its impacts accurately, the organization should seek to understand the concernsof stakeholders (see Box 1). The organization can also consult with internal experts as well as withexternal experts, such as civil society organizations or academics.

2387
2388
2389
2390
2391

Impacts may change over time as the organization’s activities and business relationships and theircontext evolve. For example, new activities or business relationships or major decisions or changes
in operations or the operating context (e.g., new market entry, product launch, policy change, or
wider changes to the organization) could lead to changes in the organization’s impacts. For thisreason, the organization should identify its impacts on an ongoing basis.

2392
2393

In situations where an organization has limited resources available for identifying its impacts, it
should start by identifying its negative impacts, before moving onto identifying positive impacts.

2394

Box 1. Engaging with relevant stakeholders and experts1

2395
2396
2397
2398
2399
2400
2401
2402

The organization should seek to understand the concerns of its stakeholders by consulting them
directly in a way that takes language and other potential barriers into account. Identifying andremoving potential barriers to stakeholder engagement (e.g., language and cultural differences,
gender and power imbalances, divisions within the community) is important to ensure thatstakeholder engagement is effective. Engagement with at-risk or vulnerable groups might call for
specific approaches and special attention, such as approaches that remove social barriers limiting theparticipation of women in public fora, or approaches that remove the physical barriers preventing
remotely located communities from attending a meeting.

2403
2404

The organization should respect the human rights of all stakeholders and other individuals it engages
with (e.g., their rights to privacy, freedom of expression, and peaceful assembly and protest).

2405
2406

In situations that involve many stakeholders or involve certain types of impact that result incollective harm, broad engagement with stakeholders might not be possible. For example, in the case

1 This guidance is based on the United Nations (UN), Guiding Principles on Business and Human Rights:

Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011 and the Organisation for
Economic Co-operation and Development (OECD), OECD Due Diligence Guidance for Responsible BusinessConduct, 2018.

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2407
2408
2409
2410
2411
2412
2413
2414
2415

of corruption, which collectively harms the populations of the jurisdiction in which it takes place, or
greenhouse gas (GHG) emissions, which contribute to collective, transboundary harm. In thesecases, the organization may engage with credible stakeholder representatives or proxy organizations(e.g., non-governmental organizations, representative public bodies). This is also relevant insituations where engaging with individuals could undermine certain rights or collective interests. For
example, when considering a decision to restructure or shut down a factory, it may be important forthe organization to engage with trade unions to mitigate the employment impacts of the decision.
This is because in this situation, engaging with individual workers could undermine the right ofworkers to form or join trade unions and to bargain collectively.

2416
2417

The degree of impact on stakeholders may inform the degree of engagement. The organization
should prioritize the most severely affected or potentially affected stakeholders for engagement.

2418
2419
2420

Where direct consultation is not possible, the organization should consider reasonable alternatives,
for example, consulting credible independent experts, such as national human rights institutions,human rights and environmental defenders, trade unions, and other members of civil society.

2421

Identifying negative impacts

2422
2423
2424

The guidance in this section on identifying negative impacts is based on the UN Guiding Principles on
Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the OECD Due
Diligence Guidance for Responsible Business Conduct.

2425
2426
2427
2428

Identifying the actual and potential negative impacts with which the organization is or could be
involved is the first step of due diligence. The organization should consider actual and potential
impacts it causes or contributes to through its own activities, as well as those that are directly linked
to its operations, products, or services by its business relationships (see Box 2).

2429
2430
2431
2432
2433
2434
2435

To identify its actual and potential negative impacts, the organization can use information fromdiverse sources. It can use its own or third-party environmental, socio-economic, and human rights
impact assessments, legal reviews, anti-corruption compliance management systems, financial audits,
occupational health and safety inspections, and any other relevant assessments of its business
relationships. It can use grievance mechanisms that it has established itself or that have been
established by other organizations. It can also use information from external sources, such as news
organizations and civil society organizations.

2436
2437
2438
2439
2440
2441
2442

In some cases, the organization might be unable to identify actual and potential negative impacts
across all its activities and business relationships, for example, because it has diverse or multiple
global operations or because its value chain comprises a large number of entities. In these cases, theorganization may carry out an initial assessment or scoping exercise to identify general areas acrossits activities and business relationships where negative impacts are most likely to be present andsignificant. The organization can then identify and assess specific actual and potential negative impacts
for these areas.

2443
2444
2445
2446
2447
2448
2449
2450
2451

As part of this initial assessment or scoping exercise, the organization can consider sector-specific,
product-specific, geographic-level, and enterprise-level impacts, as well as other impacts it has faced
or knows it is likely to face. The GRI Sector Standards identify impacts that are most likely to bepresent and significant for organizations in a given sector. The organization can also use the OECD
Due Diligence Guidance for Responsible Business Conduct and the OECD sector-specific due diligenceguidance for information on sector-specific, product-specific, geographic-level, and enterprise-level
impacts, as well as reports from governments, environmental agencies, international organizations,civil society organizations, workers’ representatives and trade unions, national human rights
institutions, media, or other experts.

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2452

Box 2. Causing, contributing or being directly linked to negative impacts2

2453
2454
2455

An organization ‘causes’ a negative impact if its activities on their own result in the impact. For
example, if the organization pays a bribe to a foreign public official, or if it withdraws water from awater-stressed aquifer without replenishing the water level.

2456
2457
2458
2459
2460
2461
2462

An organization ‘contributes to’ a negative impact if its activities cause, facilitate, or incentivize
another entity to cause the impact. An organization can also contribute to a negative impact if its
activities in combination with the activities of other entities cause the impact. For example, if theorganization sets a short lead time for a supplier to deliver a product, despite knowing from pastexperience that this production time is not feasible, this could contribute to excessive overtime forthe supplier’s workers. In this case, the organization could contribute to negative impacts on thehealth and safety of these workers.

2463
2464
2465

An organization can cause or contribute to a negative impact through its actions as well as its failure
to take action (e.g., failure to prevent or mitigate a negative impact that the organization could haveforeseen).

2466
2467
2468
2469
2470
2471
2472
2473

Even if an organization does not cause or contribute to a negative impact, its operations, products,
or services could be connected to a negative impact of a business relationship. In this case, theorganization’s operations, products, or services are ‘directly linked to’ a negative impact by its
business relationship. For example, if the organization sources and uses cobalt in its products that ismined using child labor, the negative impact (i.e., child labor) is directly linked to the organization’s
products through the tiers of business relationships in its supply chain (i.e., with the smelter,minerals trader, or mining enterprise that uses child labor), even though the organization has notcaused or contributed to the negative impact itself.

2474
2475
2476

The way an organization is involved with negative impacts is important for determining how theorganization should address an impact and whether it has a responsibility to provide for orcooperate in its remediation (see Section 2.3 of GRI 101: Using the GRI Standards).

2477

Identifying positive impacts

2478
2479
2480
2481

To identify its actual and potential positive impacts, the organization should assess the manner inwhich it contributes or could contribute to sustainable development through its own activities, forexample, through its products, services, investments, procurement practices, as an employer, or as ataxpayer.

2482
2483
2484

Examples of positive impacts could be an organization adopting measures that lower the cost of
renewable energy for customers, or choosing an area with high unemployment to open a new facility
so that it can hire and train unemployed members of the local community.

2485
2486
2487
2488
2489
2490

The organization should consider any negative impacts that could result from activities that aim for apositive contribution to sustainable development. Negative impacts cannot be offset by otherpositive impacts. For example, a renewable energy installation might reduce a region’s dependence
on fossil fuels and bring energy to underserved communities. But if it displaces local indigenous
communities from their historical and cultural lands without their consent, this negative impact
needs to be addressed and cannot be offset by the other positive impacts.

2 These concepts come from the United Nations (UN), Guiding Principles on Business and Human Rights:

Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011 and the Organisation for
Economic Co-operation and Development (OECD), OECD Due Diligence Guidance for Responsible BusinessConduct, 2018.

GRI 103: Material Topics

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2491

Step 3. Assess the significance of identified impacts

2492
2493
2494
2495
2496
2497
2498
2499

The organization might identify many actual and potential impacts. This step involves theorganization assessing the significance of its identified impacts to prioritize them for action and also
to prioritize them for reporting in Step 4. How significant an impact is will be specific to theorganization, and will be influenced by its sector(s), and business relationships, among other factors.
In some instances, this can necessitate a subjective decision. Therefore, the organization should
consult with relevant stakeholders (see Box 1) and business relationships on how to determine thesignificance of its identified impacts. The organization can also consult relevant internal or external
experts as needed.

2500

Assessing the significance of negative impacts

2501
2502
2503

The guidance in this section on assessing the significance of negative impacts is based on the UN
Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, andthe OECD Due Diligence Guidance for Responsible Business Conduct.

2504
2505

The significance of an actual negative impact is assessed by considering its severity. The significanceof a potential negative impact is assessed by considering its severity as well as its likelihood.

2506

Severity

2507

The severity of an actual or potential negative impact is determined by the following characteristics:

2508

•

Scale: how grave the impact is.

2509
2510

•

Scope: how widespread the impact is, for example, the number of individuals affected or theextent of environmental damage.

2511

•

Irremediable character: how hard it is to counteract or make good the resulting harm.

2512
2513
2514
2515
2516
2517

The scale of a negative impact (i.e., how grave the impact is) can depend on whether the impact
leads to non-compliance with the laws and regulations or with the international standards andagreements with which the organization is expected to comply. For example, if a negative impact
leads to a violation of human rights or fundamental rights at work, or non-compliance with the
reductions in GHG emissions to be achieved under the Paris Agreement, the scale of this impact canbe considered greater.

2518
2519
2520
2521
2522

The scale of a negative impact can also depend on the context in which the impact takes place. For
example, the scale of the impact of an organization’s water withdrawal can depend on the area from
where water is withdrawn. The scale will be greater if water is withdrawn from an area affected bywater stress, compared to an area that has abundant water resources to meet the demands of
ecosystems and other water users.

2523
2524
2525

Any of the three characteristics (scale, scope, and irremediable character) can make an impact
severe. Although it is often the case that these characteristics are interdependent: the greater the
scale or the scope of an impact, the less remediable it is.

2526
2527
2528
2529
2530
2531

The severity – and thereby the significance – of an impact are not absolute concepts; the severity ofan impact should be assessed relative to the other impacts the organization has identified. For
example, the organization should compare the severity of the impacts of its greenhouse gas (GHG)
emissions against the severity of its other identified impacts. The organization should not assess thesignificance of its GHG emissions relative to global GHG emission levels, as that comparison could
lead to the conclusion that the organization’s emissions are not significant.

2532

Likelihood

2533
2534

The likelihood of a potential negative impact refers to the chance of the impact happening. The
likelihood of an impact can be measured or determined qualitatively or quantitatively, and can be

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2535
2536

described using general terms (e.g., very likely, likely) or mathematically (using a probability, e.g., 10
in 100 or 10%, or a frequency over a given time period, e.g., once every three years).3

2537

Negative human rights impacts

2538
2539
2540
2541

In the case of potential negative human rights impacts, the severity of the impact takes precedence
over its likelihood. For example, a nuclear power facility may prioritize the potential impact related
to loss of life in cases of natural disasters, even though natural disasters are less likely to occur thanother incidents at the facility.

2542
2543
2544
2545

The severity of a negative human rights impact is not limited to physical harm. Any human right canbe subject to severe impacts. For example, interfering with, damaging, or destroying a sacred space
without consultation or agreement with the people who use the space can have a severe impact on
people’s cultural rights.

2546

Assessing the significance of positive impacts

2547
2548
2549

The significance of an actual positive impact is assessed by considering its scale and scope. The
significance of a potential positive impact is assessed by considering its scale and scope on the one
hand, and its likelihood on the other.

2550

Scale and scope

2551
2552
2553

In the case of positive impacts, the scale of an impact refers to how beneficial the impact is or would
be, and the scope refers to how widespread the impact is or would be, for example, the number ofindividuals or the extent of environmental resources that are or would be positively affected.

2554

Likelihood

2555
2556
2557
2558

The likelihood of a potential positive impact refers to the chance of the impact happening. The
likelihood of an impact can be measured or determined qualitatively or quantitatively, and can be
described using general terms (e.g., very likely, likely) or mathematically (using a probability, e.g., 10
in 100 or 10%, or a frequency over a given time period, e.g., once every three years).4

2559

Step 4. Prioritize the most significant impacts for reporting

2560
2561

This step involves the organization prioritizing its impacts based on their significance, to identify
material topics for reporting.

2562

Setting a threshold to determine which topics are material to report

2563
2564
2565
2566
2567

The significance of an impact is assessed relative to the other impacts the organization has identified.
The organization should arrange the identified impacts from most to least significant, and define acut-off point or threshold to determine which of the impacts it will focus its reporting on. The
organization should document the threshold and criteria used when identifying material topics. To
facilitate prioritization, the organization should group the identified impacts into topics (see Box 3).

2568
2569
2570
2571
2572
2573

The significance of an impact is the sole criterion for determining whether a topic is material toreport on. The organization cannot use difficulty in reporting on a topic or the fact that it does not
yet manage the topic as the basis for determining whether or not to report on that topic. In cases
where the organization does not manage a material topic and related impacts, the organization isrequired to report the reasons for not doing so or any plans to manage the topic under Disclosure
MT-3.

3 International Organization for Standardization (ISO), ISO 31000:2018 Risk management – Guidelines, 2018.
4 International Organization for Standardization (ISO), ISO 31000:2018 Risk management – Guidelines, 2018.

GRI 103: Material Topics

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2574
2575
2576

While some topics can cover both negative and positive impacts, the organization may prioritize
negative impacts separately from positive impacts, as negative impacts need to be discussed
independently and cannot be offset by positive impacts.

2577
2578
2579
2580

Even if the organization has not prioritized an actual and potential negative impact for reporting, theorganization still has a responsibility to understand how to address the impact in line with theapplicable laws, regulations, or internationally recognized instruments (see Section 2.3 of GRI 101:
Using the GRI Standards for more information).

2581

Box 3. Grouping impacts into topics

2582
2583
2584
2585
2586
2587
2588

The organization can group impacts into topics according to general categories of impacts that relate
to a business activity, a stakeholder category, a type of business relationship, or an economic or
environmental resource. For example, if an organization identifies water pollution as one potential
negative impact of its activities, and the reduced access of local communities to safe drinking water
as another potential negative impact, it can group these impacts under the topic of ‘water andeffluents’. The organization can refer to the topic names included in the GRI Topic Standards and the
GRI Sector Standard(s) that apply to its sector(s).

2589

Testing the material topics with information users and experts

2590
2591
2592
2593

The organization can test its selection of material topics with potential information users andexperts who understand the organization or its sector(s) and have insight into one or more of thematerial topics identified. Examples of experts the organization can consult include nongovernmental organizations, academics, consultants, lawyers, and investors.

2594

Approval of material topics by highest governance body2595

The organization’s highest governance body should approve the identified material topics.

2596

Determining what to report for each material topic

2597
2598
2599

Once the organization has identified its material topics, it needs to determine what to report foreach material topic. See Requirements A-4 and A-5 in Section 3.1 of GRI 101: Using the GRI Standards
for information on how to report on material topics.

GRI 103: Material Topics

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2600

3. Reporting on material topics

2601
2602
2603
2604
2605

The disclosures in this section provide information about how the organization has identified its
material topics, the material topics and related impacts identified, and how it manages each material
topic. Material topics are topics that reflect the organization’s most significant impacts on theeconomy, environment, and people, including impacts on human rights. Section 2 of this Standard
provides guidance on identifying material topics, which help understand these disclosures.

2606

Disclosure MT-1 Identification of material topics and related impacts

2607

Requirements

2608

The organization shall:

2609

a. report how it has identified its material topics, including:

2610
2611
2612

i.

how it has identified actual and potential, negative and positive impacts on
the economy, environment, and people, including impacts on human rights,
across its own activities and business relationships;

2613

ii.

how it has prioritized impacts for reporting based on their significance;

2614
2615

iii.

the stakeholders and experts whose views have informed the identification ofmaterial topics;

2616

b. report changes in the material topics compared to the previous reporting period.

2617

Guidance

2618

Guidance to MT-1

2619
2620
2621

This disclosure covers how the organization has identified its material topics and related impacts.
The material topics and related impacts that the organization has identified are reported under
Disclosure MT-2.

2622

Guidance to MT-1-a-i

2623
2624
2625

The organization should describe the methods it has used to identify its impacts, for example,
environmental, socio-economic, and human rights impact assessments, grievance mechanisms, orinformation from external sources, such as civil society organizations.

2626

Guidance to MT-1-a-ii

2627
2628
2629
2630
2631

The organization should describe how it has assessed the significance of the impacts identified. The
significance of a negative impact is assessed based on its severity (scale, scope, and irremediablecharacter) and likelihood. In the case of potential negative human rights impacts, the severity of the
impact takes precedence over its likelihood. The significance of a positive impact is assessed basedon its scale, scope, and likelihood. See Section 2 of this Standard for more guidance.

2632
2633
2634

The organization should also describe how it has defined the threshold to determine which topics
are material to report, and whether it has tested its selection of material topics with potential
information users and experts.

GRI 103: Material Topics

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2635

Guidance to MT-I-a-i and MT-1-a-ii

2636
2637
2638
2639
2640
2641
2642
2643

The organization should describe how it has considered sector-specific, product-specific, andgeographic-level impacts when identifying its material topics. The organization should also explain
whether and why it does not report on some of these impacts as part of its material topics; forexample, because the specific impact was assessed to be absent or because the impact was notamong the most significant to report on. Reporting this information indicates whether theorganization recognizes sector-specific, product-specific, and geographic-level impacts, and provides
information users with adequate contextual information to assess the organization’s selection ofmaterial topics.

2644
2645
2646
2647
2648
2649
2650
2651

For example, an oil and gas project often requires land for its operations, access routes,
and distribution. This can lead to impacts such as involuntary resettlement of local communities,
which can involve their physical displacement as well as economic displacement such as loss ofaccess to resources. An organization undertaking an oil and gas project would need to consider, inthe early stages of due diligence, whether the project could result in involuntary resettlement ofcommunities. If the project does not result in involuntary resettlement of communities, theorganization should still report why this topic, which is commonly associated with the oil and gas
sector, was not identified as material to report, to make clear that the topic was not overlooked.

2652
2653

See Section 2 of this Standard and the GRI Sector Standards for guidance on sector-specific,
product-specific, and geographic-level impacts.

2654

Guidance to MT-1-b

2655
2656

The organization should explain why a topic that was identified as material in the previous reporting
period is deemed to no longer be material or why a new topic has been identified as material.

GRI 103: Material Topics

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2657

Disclosure MT-2 Material topics and related impacts

2658

Requirements

2659

The organization shall:

2660

a. report the material topics it has identified;

2661

b. for each material topic:

2662
2663
2664

i.

describe the actual and potential, negative and/or positive impacts identified
on the economy, environment, and people, including impacts on humanrights;

2665
2666

ii.

report whether the organization is involved with the negative impacts
through its own activities or as a result of its business relationships.

2667

Guidance

2668

Guidance to MT-2

2669
2670

This disclosure covers the material topics and related impacts identified by the organization. How
the organization has identified its material topics is reported under Disclosure MT-1.

2671
2672
2673

An organization reporting in accordance with the GRI Standards is required to include the material
topics reported under this disclosure in the GRI content index (see Requirement A-6 in Section 3.1
of GRI 101: Using the GRI Standards).

2674

Guidance to MT-2-a

2675
2676
2677

The organization can group material topics by relevant categories if this helps communicate its
impacts better. Examples of categories include negative human rights impacts, impacts in the supply
chain, or impacts on the environment.

2678

Guidance to MT-2-b

2679
2680
2681
2682

MT-2-b provides contextual information to understand how the organization manages each material
topic and related impacts (reported under Disclosure MT-3). MT-2-b does not require a detailed
description of impacts or a detailed explanation of how the organization is involved with eachnegative impact; the organization can provide a high-level description of the impacts it has identified.

2683

Guidance to MT-2-b-i

2684
2685

MT-2-b-i covers impacts related to each material topic. It enables the organization to indicate if a
topic is material because of negative impacts, positive impacts, or both.

2686

Describing negative impacts

2687

The organization can describe:

2688
2689
2690

•

whether the impacts are systemic (e.g., child labor or forced labor in countries where theorganization operates or sources inputs from) or are related to individual incidents (e.g., an
oil spill);

2691
2692

•

the stakeholders (without identifying specific individuals) or environmental resources thatare affected or could potentially be affected, and their geographic location.

2693
2694

Reporting on negative impacts can help the organization demonstrate that it recognizes these
impacts and that it has taken action or intends to take action to address them. The organization

GRI 103: Material Topics

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2695
2696
2697
2698
2699
2700
2701

might have concerns about reporting on negative impacts even if these impacts are already publicly
known. In fact, where negative impacts are publicly known, failure to acknowledge these impacts andexplain how they are being addressed could have consequences for the organization (e.g.,
reputationally, financially, operationally). If the organization is unable to disclose specific information(e.g., because that could affect the right to privacy of stakeholders), it can provide the information inaggregated or anonymized form, or it can describe sector-specific, product-specific, or geographiclevel impacts.

2702

Describing positive impacts

2703

The organization can describe:

2704
2705

•

the activities that result in the positive impacts (e.g., products, services, investments,
procurement practices);

2706
2707

•

the stakeholders or environmental resources that are benefitted or could potentially bebenefitted, and their geographic location.

2708

Guidance to MT-2-b-ii

2709
2710
2711
2712

The way an organization is involved with negative impacts is important for determining theorganization’s responsibility toward addressing the impacts (see Section 2.3 of GRI 101: Using the GRI
Standards). MT-2-b-ii therefore provides contextual information for understanding the actions taken
to manage negative impacts (reported under Disclosure MT-3).

2713
2714
2715
2716
2717
2718

MT-2-b-ii requires the organization to report whether it is involved with the negative impacts
through its own activities or as a result of its business relationships. Where possible, theorganization should also report whether it is or could be causing or contributing to the negative
impacts through its own activities, or whether the impacts are or could be directly linked to its
operations, products, or services by its business relationships even if it has not contributed to them.
See Box 2 in Section 2 of this Standard for more information.

2719
2720
2721

The organization can also report the types of activities (e.g., manufacturing, retail) or types ofbusiness relationships (e.g., suppliers of raw materials, franchisees) involved with the identified
negative impacts, their position in the value chain, and their geographic location.

GRI 103: Material Topics

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2722

Disclosure MT-3 Management of material topics and related impacts

2723

Requirements

2724

For each material topic reported under Disclosure MT-2, the organization shall:

2725

a. describe its policies or commitments for the topic;

2726

b. describe actions taken to manage the topic and related impacts, in particular:

2727

i.

2728
2729

ii. actions taken to address actual negative impacts, including actions to provide
for or cooperate in their remediation;

2730

actions taken to prevent or mitigate potential negative impacts;

c. report the following information about the effectiveness of the actions taken:

2731

i.

processes used to track the effectiveness of the actions taken;

2732

ii. goals, targets, and indicators used to evaluate progress;

2733
2734

iii. evidence of the extent to which the actions taken have been effective,
including progress toward the goals and targets;

2735
2736

iv. lessons learned and how these have been incorporated into theorganization’s operational policies and procedures;

2737
2738

d. describe how engagement with stakeholders has informed the actions taken (MT-3b) and whether the actions taken have been effective (MT-3-c);

2739
2740

e. if the organization does not manage a material topic, explain the reason for not
managing the topic or describe any plans to manage it.

2741

Guidance2742

Guidance to MT-3

2743
2744

This disclosure enables the organization to explain how it manages each of its identified material
topics and related impacts.

2745
2746
2747

The requirements in this disclosure apply to every material topic. An organization preparing a reportin accordance with the GRI Standards is required to report this disclosure for each of its identified
material topics.

2748
2749
2750
2751
2752
2753

Besides this disclosure, the Topic Standards and Sector Standards can also contain disclosures andguidance for reporting how the organization manages a topic. For example, some Topic Standards
contain disclosures about specific actions or methods to manage impacts for a topic. The
organization does not need to repeat this information under Disclosure MT-3 if it is alreadyreported under another disclosure. The organization can report this information once and provide areference to this information to fulfill the corresponding MT-3 requirements.

2754
2755
2756
2757

If the organization’s approach to managing a material topic, such as its policies or actions taken,
applies to other material topics, the organization does not need to repeat this information for each
topic. The organization can report this information once, with a clear explanation of all the topics itcovers.

GRI 103: Material Topics

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2758

Guidance to MT-3-a

2759
2760
2761
2762

Disclosures RBC-2 and RBC-3 in GRI 102: About the Organization provide guidance on how to reporton policies. If the organization’s policies for a material topic have been described under Disclosures
RBC-2 and RBC-3, the organization can provide a reference to this information under MT-3-a anddoes not need to repeat the information.

2763
2764

When reporting on commitments, the organization should provide a statement of intent to manage
the topic and related impacts, or explain the following:

2765

•

The organization’s stance on the topic.

2766
2767

•

Whether the commitment to manage the topic is based on regulatory compliance or
extends beyond it.

2768

•

Compliance with international standards related to the topic.

2769

Guidance to MT-3-b

2770
2771
2772

MT-3-b provides information to understand how the organization responds to its identified impacts.
MT-3-b does not require a detailed description of actions taken in relation to each impact; theorganization can provide examples to show how it manages its impacts.

2773
2774

The organization should include information on how it integrates the findings from its identification
and assessment of impacts across relevant internal functions and processes, including:

2775
2776

•

the level and function within the organization that has been assigned responsibility for
managing the impacts;

2777
2778

•

the internal decision-making, budget allocation, and oversight processes to enable effective
actions to manage the impacts.

2779

Guidance to MT-3-b-i

2780

The organization should report:

2781
2782

•

examples of actions taken to prevent or mitigate potential negative impacts (e.g.,
adaptation/modification measures, facility upgrading, training, red-flag systems);

2783

•

approaches taken to prevent or mitigate systemic negative impacts;

2784

•

how the organization applies the precautionary principle, including:

2785
2786
2787

-

how the organization proactively informs the public about potential negative impacts of
its activities, products, and services, and how it deals with related questions andcomplaints;

2788
2789

-

the organization’s support or contribution to scientific research related to evaluating
potential negative impacts of its activities, products, and services;

2790
2791

-

the organization’s participation in collaborative efforts to share knowledge and toprevent negative impacts of its activities, products, and services;

2792
2793
2794
2795
2796

•

how the organization uses or increases its leverage to prompt its business relationships toprevent or mitigate potential negative impacts. For example, the organization can use or
increase its leverage by enforcing contractual requirements, implementing incentives (such as
future orders), providing training and support, or actively collaborating with other actors tomotivate its business relationships to prevent or mitigate potential negative impacts;

2797
2798
2799

•

whether the organization has terminated a business relationship because it lacks the leverage
to prevent or mitigate potential negative impacts, and whether it has assessed if terminating
the relationship could itself result in negative impacts.

GRI 103: Material Topics

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2800
2801

See Guidance to RBC-2-a-iii in GRI 102: About the Organization for more information on‘precautionary principle’.

2802

Guidance to MT-3-b-ii

2803

The organization should report:

2804
2805

•

examples of specific actions taken to remediate actual negative impacts, including examplesof specific remedies or types of remedy provided;

2806
2807
2808

•

how the grievance mechanisms or other remediation processes (reported under Disclosure
RBC-5 in GRI 102: About the Organization) have made it possible for actual negative impacts
to be remediated.

2809
2810

See Disclosure RBC-5 for more information on grievance mechanisms and other remediation
processes.

2811

Guidance to MT-3-c-i

2812
2813
2814

Tracking the effectiveness of actions taken is necessary for an organization to know if its policies andprocesses are being implemented optimally, to learn whether it has responded effectively to theimpacts identified, and to drive continuous improvement.

2815
2816
2817

The processes used to track the effectiveness of actions taken can include internal or external
auditing or verification, impact assessments, measurement systems, stakeholder feedback, grievancemechanisms, external performance ratings, and benchmarking.

2818

Guidance to MT-3-c-ii

2819

When reporting on goals and targets, the organization should report:

2820

•

how the goals and targets are set;

2821
2822
2823

•

whether and how the goals and targets take into account the context in which the impacts
take place and are informed by expectations in internationally recognized instruments and,
where relevant, by scientific consensus;

2824
2825

•

whether goals and targets are mandatory (based on legislation) or voluntary. If they aremandatory, the organization can list the relevant legislation;

2826

•

the organization’s activities or business relationships to which the goals and targets apply;

2827

•

the baseline for the goals and targets;

2828

•

the timeline for achieving the goals and targets.

2829
2830

Targets can be qualitative, e.g., the implementation of a management system by a certain date, or
quantitative, e.g., reducing GHG emissions by a certain percentage by a certain date.

2831
2832
2833
2834
2835

The indicators used to evaluate progress can also be qualitative or quantitative. Quantitative
indicators can bring precision and enable comparisons. Qualitative information is often needed toput quantitative information into context, enable its interpretation, and determine which
comparisons and conclusions are likely to be most valid. The Topic Standards include qualitative andquantitative indicators.

2836

Guidance to MT-3-c-iii

2837
2838
2839
2840
2841

The organization should report examples supported by evidence of the extent to which specificactions taken have been effective. The evidence provided should show that there is a credible link
between the specific action taken by the organization and the effective management of the impacts.
For example, to show the effectiveness of capacity building provided to certain suppliers on
improving working conditions, the organization can report survey feedback from the suppliers’

GRI 103: Material Topics

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2842
2843

workers showing that working conditions have improved, together with data showing a decrease in
the number of incidents identified through independent audits.

2844
2845
2846

Similarly, to show the effectiveness of its actions to improve the quality of water discharged, theorganization can report data showing a decrease in the concentration of total dissolved solids (mg/L)
in its water discharge.

2847
2848
2849

When reporting progress toward the goals and targets, the organization should report whether
progress is satisfactory or not. If a goal or target has not been achieved, the organization should
explain why.

2850

Guidance to MT-3-c-iv

2851
2852

Managing impacts is typically an ongoing challenge requiring continuous improvement based onlearning.

2853
2854

MT-3-c-iv does not require a detailed description of lessons learned in relation to each material
topic; the organization can provide examples to show how it incorporates lessons learned.

2855
2856
2857
2858

For instance, the organization can provide examples of lessons learned that have led to changes inpractices, or that have led to plans for such changes, to manage impacts more successfully in the
future. Such examples can include a change to a policy, specific training for workers, or additional
attention given to the performance of suppliers.

2859
2860

Lessons learned might be derived from the organization’s own activities, its business relationships, or
stakeholder or expert feedback.

2861

Guidance to MT-3-d

2862
2863
2864

The organization can explain, for example, whether and how affected stakeholders have been
involved in determining an appropriate remedy for a negative impact, or how stakeholder feedback isused to assess the effectiveness of the actions taken.

GRI 103: Material Topics

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2865

References

2866
2867

The following documents informed the development of this Standard and can be helpful forunderstanding and applying it.

2868

Authoritative intergovernmental instruments:

2869
2870

1. Organisation for Economic Co-operation and Development (OECD), OECD Due Diligence
Guidance for Responsible Business Conduct, 2018.

2871
2872

2. Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011.

2873
2874

3. United Nations (UN), Guiding Principles on Business and Human Rights: Implementing the United
Nations “Protect, Respect and Remedy” Framework, 2011.

2875
2876

4. United Nations (UN), Protect, Respect and Remedy: a Framework for Business and Human Rights,
2008.

2877
2878

5. United Nations (UN), Report of the Special Representative of the Secretary-General on the Issue of
Human Rights and Transnational Corporations and Other Business Enterprises, John Ruggie, 2011.

2879

6. United Nations (UN), Rio Declaration on Environment and Development, 1992.

2880
2881

7. United Nations (UN), The Corporate Responsibility to Respect Human Rights: An Interpretive Guide,
2012.

2882

Other relevant references:

2883
2884
2885

8. Castan Centre for Human Rights Law, Office of the United Nations High Commissioner for
Human Rights, and United Nations Global Compact, Human Rights Translated 2.0: A Business
Reference Guide, 2017.

2886
2887

9. Corporate Human Rights Benchmark Ltd., Corporate Human Rights Benchmark methodology,
updated annually.

2888

10. Shift and Mazars LLP, UN Guiding Principles Reporting Framework, 2015.

2889
2890

11. Shift, Oxfam, and Global Compact Network Netherlands, Doing Business with Respect for Human
Rights: A Guidance Tool for Companies, 2016.

GRI 103: Material Topics

Page 98 of 106

2891

Glossary

2892
2893
2894

This glossary includes definitions for terms used in the Universal Standards: GRI 101: Using the GRI
Standards, GRI 102: About the Organization, and GRI 103: Material Topics. The organization is required
to apply these definitions when using the Standards.

2895
2896
2897

The definitions included in this glossary may contain terms that are further defined in the complete
GRI Standards Glossary. All defined terms are underlined. If a term is not defined in this glossary or in
the complete GRI Standards Glossary, definitions that are commonly used and understood apply.

2898

annual total compensation [minor edits]

2899
2900
2901

compensation provided over the course of a year, including salary, bonus, stock awards, option
awards, non-equity incentive plan compensation, change in pension value, and nonqualified deferredcompensation earnings2902

business partner [new]

2903
2904

entity with which the organization has some form of direct and formal engagement for the purposeof meeting its business objectives

2905
2906
2907
2908

Note 1: Examples of business partners can include affiliates, business-to-business customers, clients,
first-tier suppliers (such as a supplier that manufactures the organization’s products), franchisees,
joint venture partners, and investee companies in which the organization has a shareholding position.
Business partners do not include subsidiaries and affiliates that the organization controls.

2909
2910

Note 2: This definition comes from Shift and Mazars LLP, UN Guiding Principles Reporting Framework,
2015.

2911

business relationships [new]

2912
2913
2914

relationships that the organization has with business partners, entities in its value chain including
those beyond the first tier, and any other entities directly linked to its operations, products, orservices

2915
2916
2917

Note 1: Other entities directly linked to the organization’s operations, products, or services can
include, for example, a non-governmental organization together with which the organization delivers
support to a local community or State security forces that protect the organization’s facilities.

2918
2919

Note 2: This definition is based on the United Nations (UN), Guiding Principles on Business andHuman Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011.

2920

causing a negative impact [new]2921

The organization ‘causes’ a negative impact if its activities on their own result in the impact.

2922
2923
2924

Note: This definition is based on the Organisation for Economic Co-operation and Development(OECD), OECD Due Diligence Guidance for Responsible Business Conduct, 2018. See Box 2 in GRI 103:
Material Topics for more information.

2925

child [unchanged]

2926
2927

person under the age of 15 years, or under the age of completion of compulsory schooling,whichever is higher

2928
2929

Note 1: Exceptions can occur in certain countries where economies and educational facilities are
insufficiently developed and a minimum age of 14 years applies. These countries of exception are

Glossary

Page 99 of 106

2930
2931

specified by the International Labour Organization (ILO) in response to a special application by thecountry concerned and in consultation with representative organizations of employers and workers.

2932
2933

Note 2: The ILO Minimum Age Convention, 1973 (No. 138), refers to both child labor and young
workers.

2934

clawback [revised]

2935
2936
2937

repayment of previously received compensation required to be made by a senior executive or
member of the highest governance body to their employer in the event certain conditions of
employment or goals are not met

2938

collective bargaining [revised]

2939
2940
2941

negotiations between one or more employers or employers' organizations and one or moreworkers' organizations (trade unions), to determine working conditions and terms of employment
or to regulate relations between employers and workers

2942
2943

Note: This definition is based on the International Labour Organization (ILO), Collective Bargaining
Convention, 1981 (No. 154).

2944

conflict of interest [revised]

2945
2946

situation where an individual is confronted with choosing between the requirements of theirfunction in the organization and their other personal or professional interests or responsibilities

2947

contributing to a negative impact [new]

2948
2949
2950

The organization ‘contributes to’ a negative impact if its activities, in combination with the activitiesof other entities, cause the impact, or if the activities of the organization cause, facilitate, or
incentivize another entity to cause the impact.

2951
2952
2953

Note: This definition comes from the Organisation for Economic Co-operation and Development(OECD), OECD Due Diligence Guidance for Responsible Business Conduct, 2018. See Box 2 in GRI 103:
Material Topics for more information.

2954

directly linked to a negative impact [new]

2955
2956
2957
2958

The organization’s operations, products, or services are ‘directly linked to’ a negative impact by its
business relationships when a business relationship causes an impact in connection with theorganization’s operations, products, or services, even if the organization has not contributed to theimpact.

2959
2960

Note 1: ‘Direct linkage’ is not defined by the link between the organization and the other entity,
and is therefore not limited to direct contractual relationships, for example ‘direct sourcing’.

2961
2962
2963

Note 2: This definition is based on the Organisation for Economic Co-operation and Development(OECD), OECD Due Diligence Guidance for Responsible Business Conduct, 2018. See Box 2 in GRI 103:
Material Topics for more information.

2964

due diligence [minor edits]

2965
2966

process to identify, prevent, mitigate, and account for how the organization addresses its actual andpotential negative impacts

2967
2968

Note: This definition is based on the United Nations (UN), Guiding Principles on Business and Human
Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011 and the

Glossary

Page 100 of 106

2969
2970

Organisation for Economic Co-operation and Development (OECD), OECD Guidelines forMultinational Enterprises, 2011. See ‘due diligence’ in Section 2 of GRI 101: Using the GRI Standards.

2971

employee [unchanged]

2972
2973

individual who is in an employment relationship with the organization, according to national law or
its application

2974

employment contract [minor edits]

2975
2976
2977

contract as recognized under national law or practice that can be written, verbal, or implicit (i.e.,
when all the characteristics of employment are present but without a written or witnessed verbal
contract)

2978
2979

Permanent or indefinite contract: Contract with an employee, for full-time or part-time work, for anindeterminate period.

2980
2981
2982

Temporary or fixed term contract: Contract with an employee for a limited duration, which ends when
the specific time period expires, or when the specific task or event that has an attached time
estimate is completed (e.g., the end of a project or return of replaced employees).

2983

employment type [minor edits]

2984
2985

Full-time: A ‘full-time employee’ is an employee whose working hours per week, month, or year are
defined according to national law or practice regarding working time.

2986
2987

Part-time: A ‘part-time employee’ is an employee whose working hours per week, month, or year areless than ‘full-time’.

2988

governance body [revised]

2989
2990
2991

formalized group of individuals responsible for the strategic guidance of the organization, theeffective monitoring of management, and the accountability of management to the broader
organization and its stakeholders

2992

grievance [new]

2993
2994
2995

perceived injustice that evokes an individual’s or group’s sense of entitlement, which may be basedon law, contract, explicit or implicit promises, customary practice, or general notions of fairness
among the aggrieved communities

2996
2997

Note: This definition comes from the United Nations (UN), Guiding Principles on Business and Human
Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011.

2998

grievance mechanism [revised]2999

routinized process through which grievances can be raised and remedy can be sought

3000
3001
3002
3003

Note 1: Grievance mechanisms include routinized, State-based or non-State-based, judicial or nonjudicial processes. They also include operational-level grievance mechanisms, which are administeredby the organization either alone or in collaboration with other parties, and which are directly
accessible by the organization’s stakeholders.

3004
3005
3006
3007

Note 2: According to UN Guiding Principle 31, effective grievance mechanisms are legitimate,accessible, predictable, equitable, transparent, rights-compatible, and a source of continuous learning.
In addition to these criteria, effective operational-level grievance mechanisms are also based on
engagement and dialogue.

Glossary

Page 101 of 106

3008
3009

Note 3: This definition is based on the United Nations (UN), Guiding Principles on Business andHuman Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011.

3010

highest governance body [revised]

3011

governance body with the highest authority in the organization

3012
3013
3014
3015

Note: In some jurisdictions, governance systems consist of two tiers, where supervision andmanagement are separated or where local law provides for a supervisory board drawn from nonexecutives to oversee an executive management board. In these cases, both tiers are included under
the definition of highest governance body.

3016

impact [revised]

3017
3018
3019

In the GRI Standards, unless otherwise stated, ‘impact’ refers to the effect the organization has on
the economy, environment, and/or people, including on human rights, which in turn can indicate theorganization’s contribution (negative or positive) to sustainable development.

3020

Note: In the GRI Standards, the term ‘impact’ can refer to:

3021
3022

•

actual impacts (those that have already occurred) or potential impacts (those that could
occur but have not yet occurred);

3023

•

negative impacts or positive impacts;

3024

•

short-term impacts or long-term impacts;

3025

•

intended impacts or unintended impacts;

3026

•

reversible impacts or irreversible impacts.

3027

See ‘impact’ in Section 2 of GRI 101: Using the GRI Standards.

3028

indigenous peoples [unchanged]3029

indigenous peoples are generally identified as:

3030
3031
3032
3033

•

tribal peoples in independent countries whose social, cultural and economic conditions
distinguish them from other sections of the national community, and whose status isregulated wholly or partially by their own customs or traditions or by special laws or
regulations;

3034
3035
3036
3037
3038

•

peoples in independent countries who are regarded as indigenous on account of theirdescent from the populations which inhabited the country, or a geographical region to which
the country belongs, at the time of conquest or colonization or the establishment of present
state boundaries and who, irrespective of their legal status, retain some or all of their own
social, economic, cultural, and political institutions.

3039
3040

Note: This definition comes from the International Labour Organization (ILO), Indigenous and Tribal
Peoples Convention, 1989 (No. 169).

3041

internationally recognized human rights [new]

3042
3043
3044
3045
3046
3047

These rights are understood, at a minimum, to include the rights set out in the International Bill of
Human Rights (consisting of the Universal Declaration of Human Rights and the main instruments
through which it has been codified: the International Covenant on Civil and Political Rights and theInternational Covenant on Economic, Social and Cultural Rights), coupled with the principles concerning
fundamental rights in the eight International Labour Organization (ILO) core conventions as set out
in the Declaration on Fundamental Principles and Rights at Work.

Glossary

Page 102 of 106

3048
3049
3050

Note 1: Human rights are rights inherent to all human beings, regardless of nationality, place ofresidence, sex, national or ethnic origin, color, religion, language, or any other status. These rights
are all interrelated, interdependent, and indivisible.

3051
3052
3053
3054
3055
3056
3057

Note 2: UN instruments elaborate further on the rights of indigenous peoples; women; national or
ethnic, religious and linguistic minorities; children; persons with disabilities; and migrant workers andtheir families. There are also standards of international humanitarian law that apply in situations ofarmed conflict, such as the Geneva Conventions of 1949. See the Office of the United Nations HighCommissioner for Human Rights’ non-exhaustive list of universal human rights instruments,
https://www.ohchr.org/EN/ProfessionalInterest/Pages/UniversalHumanRightsInstruments.aspx,
accessed on 6 May 2020.

3058
3059
3060
3061

Note 3: At the regional level, binding treaties as well as non-binding instruments provide regionspecific frameworks for human rights. See the Office of the United Nations High Commissioner for
Human Rights’ list of regional human rights treaties,
https://www.ohchr.org/en/issues/escr/pages/regionalhrtreaties.aspx, accessed on 6 May 2020.

3062
3063
3064
3065

Note 4: This definition is based on the United Nations (UN), Guiding Principles on Business andHuman Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011 and theUnited Nations Human Rights Office of the High Commissioner webpage, What are human rights?,
https://www.ohchr.org/en/issues/pages/whatarehumanrights.aspx, accessed on 6 May 2020.

3066

local community [revised]

3067
3068

individuals or groups of individuals living and/or working in areas that are, or could be, affected by
the organization’s activities and decisions

3069
3070

Note: The local community can range from individuals living adjacent to the organization’s
operations, to those living at a distance who are still likely to be affected by these operations.

3071

material topic [revised]

3072
3073

topic that reflects the organization’s most significant impacts on the economy, environment, andpeople, including impacts on human rights

3074
3075

Note: See Section 2 of GRI 101: Using the GRI Standards and Section 2 of GRI 103: Material Topics formore information.

3076

mitigation [new]3077

action(s) taken to reduce the extent of a negative impact

3078
3079
3080
3081

Note 1: The mitigation of an actual negative impact refers to actions taken to reduce the extent of
the negative impact that has occurred, with any residual impact needing remediation. The mitigationof a potential negative impact refers to actions taken to reduce the likelihood of the negative impact
occurring.

3082
3083

Note 2: This definition is based on the United Nations (UN), The Corporate Responsibility to Respect
Human Rights: An Interpretive Guide, 2012.

3084

product [unchanged]

3085

article or substance that is offered for sale or is part of a service delivered by the organization

Glossary

Page 103 of 106

3086

remediation [new]3087

provision of remedy

3088
3089

Note: This definition is based on the United Nations (UN), The Corporate Responsibility to Respect
Human Rights: An Interpretive Guide, 2012.

3090

remedy [new]3091

means to counteract or make good a negative impact

3092
3093
3094
3095

Note 1: Remedy can take a range of forms, such as apologies, restitution, restoration, rehabilitation,
financial or non-financial compensation, and punitive sanctions (whether criminal or administrative,
such as fines), as well as the prevention of harm through, for example, injunctions or guarantees of
non-repetition.

3096
3097

Note 2: This definition is based on the United Nations (UN), The Corporate Responsibility to Respect
Human Rights: An Interpretive Guide, 2012.

3098

reporting period [revised]3099

specific time period covered by the reported information

3100

Note 1: The reporting period can be, for example, the fiscal year or the calendar year.

3101

Note 2: Unless otherwise stated, the GRI Standards require information for the reporting period.

3102

sector [revised]

3103
3104

subdivision of an economy, society, or sphere of activity, defined on the basis of some common
characteristic such as similar or related products or services

3105
3106

Note: Sector types can include classifications such as the public or private sector, as well as
industry-specific categories such as the education, technology, or financial sectors.

3107

senior executive [revised]

3108
3109

high-ranking member of the management of the organization, such as the Chief Executive Officer(CEO) or an individual reporting directly to the CEO or the highest governance body

3110

service [unchanged]

3111

action of the organization to meet a demand or need

3112

severity [new]

3113
3114
3115

The severity of an actual or potential negative impact is determined by its scale (i.e., how grave theimpact is), scope (i.e., how widespread the impact is), and irremediable character (how hard it is tocounteract or make good the resulting harm).

3116
3117
3118

Note 1: Severity is not an absolute concept; the severity of an impact is assessed relative to theother impacts the organization has identified. See Section 2 of GRI 103: Material Topics for more
information.

3119
3120
3121

Note 2: This definition is based on the United Nations (UN), The Corporate Responsibility to Respect
Human Rights: An Interpretive Guide, 2012 and the Organisation for Economic Co-operation andDevelopment (OECD), OECD Due Diligence Guidance for Responsible Business Conduct, 2018.

Glossary

Page 104 of 106

3122

stakeholder [revised]

3123
3124

individual or group that has an interest that is, or could be, affected by the organization’s activities
and decisions

3125
3126
3127
3128

Note 1: Common categories of stakeholders for organizations include business partners, civilsociety organizations, consumers, customers, employees and other workers, governments, local
communities, non-governmental organizations, shareholders, suppliers, trade unions, and vulnerable
groups. See ‘stakeholder’ in Section 2 of GRI 101: Using the GRI Standards.

3129
3130

Note 2: This definition is based on the Organisation for Economic Co-operation and Development(OECD), OECD Due Diligence Guidance for Responsible Business Conduct, 2018.

3131

supplier [revised]

3132
3133

entity in the organization’s supply chain, which provides a product or service that contributes to theorganization’s own products or services

3134
3135
3136

Note 1: Examples of suppliers include brokers, consultants, contractors, distributors, franchisees,
home workers, independent contractors, licensees, manufacturers, primary producers, subcontractors, and wholesalers.

3137
3138

Note 2: A supplier can have a direct business relationship with the organization (often referred toas first-tier supplier) or an indirect business relationship.

3139

supply chain [revised]

3140
3141

range of activities carried out by entities upstream in the organization’s value chain, which provide
products or services that contribute to the organization’s own products or services

3142

sustainable development/sustainability [revised notes]

3143
3144

development that meets the needs of the present without compromising the ability of future
generations to meet their own needs

3145
3146

Note 1: Sustainable development encompasses broader economic, environmental, and societal
interests, rather than the individual interests of organizations.

3147
3148

Note 2: In the GRI Standards, the terms ‘sustainability’ and ‘sustainable development’ are usedinterchangeably.

3149
3150

Note 3: This definition comes from the World Commission on Environment and Development, Our
Common Future, 1987.

3151

termination payment [minor edits]

3152
3153

all payments and benefits given to a departing senior executive or member of the highest governancebody whose appointment is terminated

3154
3155
3156

Note: Termination payments extend beyond monetary payments to giving of property as well as
automatic or accelerated vesting of incentives given in connection with a person’s departure from a
position.

3157

under-represented social group [unchanged]

3158
3159

population that, relative to its numbers in a given society, has less opportunity to express its
economic, social, or political needs and views

3160
3161

Note: The specific groups included under this definition depend on the organization’s operating
context and are not uniform for every organization.

Glossary

Page 105 of 106

3162

value chain [revised]

3163
3164

range of activities carried out by the organization and other entities, which convert input into output
by adding value throughout the life cycle of a product or service from conception to end use

3165
3166
3167
3168
3169

Note: The value chain includes the organization’s own activities, as well as activities carried out byentities upstream and downstream from the organization in relation to the organization’s products
and services. The upstream entities (e.g., suppliers) provide products or services that contribute tothe organization’s own products or services. The downstream entities (e.g., distributors, customers)
receive products or services from the organization.

3170

vulnerable group [revised]

3171
3172
3173

group of individuals with some specific economic, physical, political, or social condition or
characteristic that could experience negative impacts as a result of the organization’s activities anddecisions more severely than others

3174
3175
3176

Note 1: Vulnerable groups can include children and youth, elderly persons, ethnic minorities, excombatants, HIV/AIDS-affected households, indigenous peoples, internally displaced persons, people
with disabilities, and refugees or returning refugees.

3177

Note 2: Vulnerabilities and impacts can differ by gender.

3178

worker [minor edits]3179

person that performs work

3180
3181
3182

Note 1: Workers include, but are not limited to, employees. Further examples of workers include
interns, apprentices, self-employed persons, and persons working for organizations other than thereporting organization, e.g., for suppliers.

3183
3184

Note 2: In the context of the GRI Standards, in some cases it is specified whether a particularsubset of workers is to be used.

Glossary

Page 106 of 106