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

Item 04 – Public comments on theStatement of Use in the Universal
Standards exposure draft
For GSSB discussion
Date

06 November 2020

Meeting

19 November 2020

Project

GRI Universal Standards Project

Description This document contains an extract of public comments related to the Statementof Use received on the Universal Standards exposure draft, which was madeavailable for public comment between 11 June and 9 September 2020.
The document presents the comments received via the online survey and via
letters, for GSSB reference. It does not present an analysis of the feedback – theanalysis will be presented by the Standards Division directly at the meeting.
The GSSB is kindly asked to review the document ahead of the meeting and toshare any questions about the comments or highlight any comments fordiscussion, with the Standards Division by 17 November.
In support of the upcoming discussion, the GSSB is also invited to review theStandards Division’ earlier research on the Statement of Use, shared with the
GSSB on 9 April 2020.
Note to reading the comments:
Comments have been included verbatim. Where a respondent has raised several
distinct points in one comment, each point has been numbered and presented ina separate row. The point number is indicated in brackets before the verbatim
comment. In addition to this, comment numbers have been included in the firstcolumn to help facilitate the discussion during the meeting on 19 November.
This document has been prepared by the GRI Standards Division. It is provided as a convenience toobservers at meetings of the Global Sustainability Standards Board (GSSB), to assist them infollowing the Board’s discussion. It does not represent an official position of the GSSB. Board
positions are set out in the GRI Sustainability Reporting Standards. The GSSB is the independent
standard setting body of GRI. For more information visit www.globalreporting.org.
© GRI 2020

1

Contents
Public comments ......................................................................................................................................................... 3
Requiring the Statement of Use .......................................................................................................................... 3
Extending the Statement of Use to the quality and veracity of reported information ........................ 34

Page 2 of 52

2

Public comments

3

Requiring the Statement of Use

4
5

Survey question: Do you agree that the GRI Standards should require the highest governance body or most senior executive of the organization to
include a statement acknowledging their responsibility for preparing the reported information in accordance with, or with reference to, the GRI Standards?

6

Please refer to page 15 in the Universal Standards exposure draft.

7
No. Survey
Comment
response

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Yes, this acknowledgement in the Statement of Use should be required.
1

Yes

2

Yes

BECAUSE THE DIRECTORS AND THE SENIOR EXECUTIVES ARE
WHO ESTABLISH THE STRATEGIC PLAN OF THE ORGANIZATIONINCLUDING VISION, MISSION AND STRATEGIES. THEREFORE, THE
SUSTAINABILITY MUST BE INCLUDED IN THE STRATEGY OF THE
ORGANIZATION SO THAT THE TOP EXECUTIVES ARERESPONSIBLE OF THE ACCOMPLISHMENT OF THE SUSTAINABLE
ACTIONS THAT THE ORGANISATION MAKE.
Approach should be similar to what is used for financial reporting.

Luis Cordova

Peru

Academic

As anindividual

ISOS Group

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

Page 3 of 52

3

Yes

It demonstrates an organization's commitment to reporting and beingtransparent

TorontoPearson Airport

CanadaBusiness

4

Yes

No comment provided

Han Wei Ho

Malaysia

Consultant

5

Yes

and also cite all staff or mangers engaged in this reporting

RPMRG

Hungary

Consultant

6

Yes

No comment provided

Yes

It is essential for involve dicision makers to mobilise the wholeorganization, they should be aware and committed.

UnitedKingdom
China

Consultant

7

Alexandra
McKay
Hui Xu8Yes

It is important that the corporate governance is aware of the Standards
used to make the report.

Sustenia

Argentina

Nongovernmentorganization
Consultant

9Yes

It gives much more importance to the GRI Standards and legitimateseven more them as THE standard as such for sustainability reporting.

CrevalItaly

No response

On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution
As anindividual
As anindividual
On behalf ofanorganization,group orinstitution
No response

Page 4 of 52

10

Yes

I agree with this requirement, because one of the main goals withingovernance policies should ensure a robust and credible sustainability
report to the stakeholders. Achieving this goal would be achieved
through reporting in accordance with the GRI. Where, adherence to GRI
regulations is a common quality feature of sustainability reportingworldwide. (Hickman, 2020; Akisik and Gal, 2020) And as responsible
for setting these policies and then ensuring their implementation, thehighest governance body or senior executive should accordingly for
acknowledge this responsibility for their stakeholders, who will be moretrusting for the relevant disclosed information.

Noha
Abdelrahman

Egypt

Academic

As anindividual

Liberty Holdings
LimitedSouth
AfricaNo response

No response

References:
Akisik , O., & Gal, G. (2020). Integrated reports, external assurance andfinancial performance An empirical analysis on North American firms.
Sustainability Accounting, Management and Policy Journal, 11 (2), 317350.
Hickman, L. E. (2020). Information asymmetry in CSR reporting: publiclytraded versus privately-held firms. Sustainability Accounting, Management
and Policy Journal, 11 (1), 207-232.

11

Yes

Abdelrahman, N. (2018). Features Affecting the Quality of Sustainability
Reporting: an Empirical Study and Evaluation. International Journal ofManagement and Applied Science, 4(5), 36-47.
In my experience, if the most snr exec does not include a statement thenthe sustainability report is viewed as just another report but as soon as
they need to include a statement it elevates the priority of the reportand over time more interest is shown and value placed on the report sothat actual change happens.

Page 5 of 52

12

Yes

This is line with other frameworks. Would suggest that provide guidancefor organisations that cannot state such due to a legislative or regulatory
issue on how should they respond in these circumstances.

SAICA

South
AfricaNongovernmentorganization

13

Yes

This is a good way to motivate Board Directors or CEOs to elevatesustainability to a strategic decision making level. Since the Board
acknowledge their responsibility for information contained in the financial
report, we should demand the same level of accountability forsustainability reports if we believe it's as important as financial
performance.

Paia Consulting

SingaporeConsultant

EY S.p.A.

Italy

Consultant

14

Yes

Furthermore, in order for Board Directors or CEOs to approve thestatement of use, they need some level of expertise in GRI reporting and
ESG topics. This requirement will encourage more Board directors andCEOs to take GRI and ESG topics more seriously, and also understandthe differences between "in accordance with" and "with reference to"claims.
I’m agree, because the the highest governance body or most senior
executive of the organization not always are sufficiently involved in the
preparation of the Sustainability Report (expecially the highest
governance body, that usually read the document only at the end fo thereporting process). I think that the highest governance body and mostsenior executive of the organization sometimes have limited knowledgeof sustainability, therefore I hope that the requirement of a formal
statement will trigger an improvement of the sustaibaility culture of the
C-levels.

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 6 of 52

15

Yes

This exhibits that commitment to sustainability and transparency begins
at the executive-level and is spread throughout the organization. It showsthat accountability starts from the boardroom to the other functions of
the organization, which is crucial in achieving a truly sustainable businessperformance.

University ofAsia and thePacific - Center
for Social
Responsibility

Philippines

Assurance
providerOn behalf ofanorganization,group orinstitution

16

Yes

This would ensure the board and senior management’s endorsement of
the issuer’s process of sustainability reporting, and enhance thecredibility of the report.
This would be a proof that the highest governance body or most senior
executive have endorsed the report by formal review and approval, andthey would be held responsible for the information disclosed.

Fuji Xerox(Hong Kong)
LimitedHong kong

No response

No response

17

Yes

This acknowledgement by the highest governance body shall make thereporting process more useful being endorsed by the Board.

Corporate
SocialResponsibility
Centre Pakistan

Pakistan

Consultant

18

Yes

No comment provided

Yes

We believe it is necessary to enhance the significance of non-financial
information prepared in accordance with/reference to the GRI Standardsby positioning the content of non-financial disclosures as a matter for
approval by ‘the highest governance body or most senior executive of
the organization’.

UnitedStatesJapan

No response

19

University ofDenverGlobal Compact
Networking
Japan

On behalf ofanorganization,group orinstitution
No response- Study
Committee on
Corporate
ReportingGeneralincorporated
association

On behalf ofanorganization,group orinstitution

Page 7 of 52

20

Yes

We often find that this helps to link different activities in a company totop company level, to make sustainable development a top-down process

triple innova

Germany

Consultant

21

Yes

I agree that this should be a requirement and it should also include theprocess on how the Chief Executive is responsible.

Nazish Shekha

Pakistan

22

Yes

Deloitte believes this is an effective way of promoting accountability andeffective governance around the application of the Standards in thereporting process.

Deloitte

UnitedStatesNongovernmentorganization
Consultant

23

Yes

Yes, since the ESG aspects are becoming increasingly relevant to all
stakeholders' decisions and because non-financial information isincreasingly integrated into the Annual / Management Reports oforganizations, the accuracy and transparency of this information, as wellas the processes for compiling it, should be acknowledged by the highest
responsible body, regardless of whether the report is externallyreviewed or not.

PwC

UnitedKingdom

Assurance
providerICR Systems &Management
SRL

Bolivia

No response

On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

As mentioned in our response to #2, we recommend that the ‘statementof use’ is included in the actual ‘sustainability reporting’ rather than in the
GRI content index.
24

Yes

Governance should consciously understand the diference between both
appoaches and the effort for a change management and their implications
for the improvement. The statement is also very important, for thecredibility of the report and for take into account indicators and impacts
within the decision processes.

No response

Page 8 of 52

25

Yes

The acknowledgment statement of use is important to clarify theorganization about how to deal with the positive effects of its
empowerment, and the negative effects are important to challenge andhow to address it .. This contributes to the development, improvement
and sustainability of the organization

Sharjah City for
Humanitarian
Services

UnitedArab
Emirates

Non-profit
organization

26

Yes

IndustriALL Global Union agrees that the highest levels of anorganization must take responsibility for their reporting on GRI
Standards.

IndustriALL
Global Union

Switzerland

27

Yes

The sustainability team report directly from the highest governance bodyfor better tone from the top process.

Malaysia

28

Yes

Izzaty Khaleda
IsmailFanny Medalith
Mendoza
Gutiérrez

Labor
On behalf ofrepresentative anorganization,group orinstitution
Consumers
As anindividualBusiness
As anindividual

29

Yes

Angel Castillo

EcuadorConsultant

30

Yes

Australia

No response

31

Yes

University ofSouthern
Queensland
CDSB

UnitedKingdomStandard
setterthe organization would prove to be committed from the top
management.
Information that is reported should be endorsed by highest level in an
organisation.
Identifying the CEO/senior executive/Board committee responsible fornon-financial information provides valuable transparency over theaccountability for organisational oversight over disclosure. Any
acknowledgement should clarify how responsibility for environmental
information is delegated (if applicable). Providing this statement supports
comparability in governance and disclosure controls between nonfinancial and financial reporting.

Peru

On behalf ofanorganization,group orinstitution

As anindividual
No response
On behalf ofanorganization,group orinstitution

Page 9 of 52

32

Yes

33

Yes

34

Yes

35

Yes

36

Yes

37

Yes

Directly empowering the high management for these statements is agood choice.
To increase a sense of sustainability within the reporting organization.
Sustainability Strategy and Action should be checked and rechecked on
the ground level. A Great Power brings a Great Responsibility

SAI Global Italias.r.l.
ZENITH BANK
PLC

Italy

No response

No response

Nigeria

No response

No response

The companies I work with already review the report. The exchange thylist on (HKEX) now requires boards to identify and evaluate material
topics. This is another mechanism to ensure senior leadership are
involved in the reporting process and therefore aware of the company's
impacts.
A sustainability report is nowadays a political act and you need assustainability officer the support of the most senior executive. In somecountries, companies can be charged if the information in thesustainability report are wrong.
A company would never publish financial information that is not signed
off by the Board. If sustainability reporting in general – and GRI Standards
specifically – are to be taken seriously by the wider business community,
they need to align with sign-off expectations of financial information.

ELEVATE

Hong kong

No response

FOM Universityof Applied
Sciences

Germany

No response

On behalf ofanorganization,group orinstitution
No response

WBCSD

Switzerland

Nongovernmentorganization

This is highly encouraged, as it will guarantee that companies will
improve the quality and transparency of the reported qualitative andquantitative information. This is because for example some companies
will publish a GRI labelled and certified report; yet, on the cover page ofthe report you can find a legal statement (disclaimer) specifying that thecompany claim no responsibility for the accuracy of the reports. This ishighly problematic and reduces the user's ability to trust the disclosed
information in the report. However, companies that have included astatement from the highest governing body showed elevated levels of
consistency and quality in the reports.

Dr. Aljiohra
Altuwaijri

Saudi
ArabiaAcademic

On behalf ofanorganization,group orinstitution
As anindividual

Page 10 of 52

38

Yes

In this case we agree, however it is necessary for you to tell us how thisstatement of acknowledging, should be made, by means of a letter, in thepresentation of the Annual Report by the CEO, in the GRI index? Moredetail is necessary

Walmart deMéxico yCentroamérica

MexicoBusiness

39

Yes

GRI Standards or any form of standards/framework/regulations in any
particular organization are best presented with the top management
endorsement in a form of official statement to signify a dedicatedcommitment.

Universiti Malaya
Sustainability &Living Labs
Secretariat(UMSLLS)

Malaysia

No response

40

Yes

IOSH believes that this requirement will help ensure top levelcommitment, oversight and leadership for the organisation's reporting
process and the content and distribution of its reports.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

41

Yes

It reinforces the message that the GRI Standards are integrated in the

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Businessdecision-making process at the highest level.
42

Yes

If the highest governance body or most senior executive of theorganization will include in a statement acknowledging their responsibility
for preparing the reported information, then the highest governancebody or most senior executive will take the sustainability reporting more
responsible. It will increase the value of the report for the highest
governance body or most senior executive.

Da-Strategy

RussianFederation

Consultant

43

Yes

Governance of the reporting organization shall be fully operational toenhance the credibility of the report. The head of the highest governancebody, or the chairman, CEO, COO, etc. must endorse and acknowledge
the report contents.

International
Development
Center of JapanJapan

No response

On behalf ofanorganization,group orinstitution
No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

No response

Page 11 of 52

44

Yes

By having a commitment from the director of the organization,
sustainability management will permeate all people.

Ilunka, Estrategia
Sustentable

MexicoConsultant

45

Yes

No comment provided

Colombia

Consultant

46

Yes

Tone from the top for better sustainability initiatives in long run.

Ana María
Gonzáles Ruiz
DUOPHARMA
BIOTECH
BERHAD

Malaysia

Business

47

Yes

48

Yes

49

Yes

Requiring the highest governance body or most senior executive of theorganisation to include a statement acknowledging their responsibility for
preparing the reported information would hopefully get the higher levelsof the organisation aware of, engaged with and influenced by thesustainability issues.
While i think such a statement should be required, it still does notguarantee that they are fully aware of the importance of such astatement. The excplicit accountability for the accuracy, balance andtruthfulness of the disclosures would be highly desirable to build trust inreports.
The requirement is in line with demanding the "approval of material
topics by highest governance body" (line 2595). In other words,
demanding their approval without having a statement of responsibility
would be incomplete. From an organizational point of view, thisrequirement will also create an additional opportunity to involve thesenior leadership and educate them.

Enact Sustainable Sweden
Strategies

Consultant

Eszter Vitorino

Netherlands Investor

Datamaran

UnitedStatesDigitalplatform

On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

On behalf ofanorganization,group orinstitution

Page 12 of 52

50

Yes

GRI 101 3. Sustainability reporting using the GRI Standards

Corporate
Citizenship

UnitedKingdom

No response

No response

We note that the claim to be reporting ‘In accordance with GRI
standards’ will require the statement: “The Board of Directors
acknowledges responsibility for the following statement of use: The
information reported by ABC Limited for the year ending 31 December
2020 has been prepared in accordance with the GRI Standards.” In ourview, the previous arrangements have not worked effectively since GRI
G2. The fact of the matter is that some organisations will continue tocherry pick different GRI indicators and will not always use themproperly. That is part of the price of success of GRI over the years. We
do not think it can (or should be eradicated). We suggest that the
proposed Directors’ declaration be eliminated. That will then preservethe ‘In accordance’ statement as the gold standard
51
52

Yes
Yes

statement of highest is necessary for transparency of disclosing
This will show top management commitment, facilitate allocation ofrequired resources and delegation of responsibilities/authority.

SGS
VertAfrika
Limited

China
Nigeria

No response
No response

No response
No response

53

Yes

The acknowledgement in the ‘statement of use’ of the responsibility of
the highest governance body or most senior executive of theorganization for preparing the reported information in accordance with,or with reference to, the GRI Standards is found useful to driving
accountability and increased awareness around sustainability impacts
including human rights impacts at the top. It might further help drive
more accurate and evidence-based reporting, rather than an
inappropriate use of sustainability reporting for marketing andcommunication purposes. However the latter effect might be moreproactively pursued through the inclusion of direct language on thequality and accuracy of the report in the requirement (see response toq4)

Danish Institutefor Human
RightsDenmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

Page 13 of 52

54

Yes

Yes, it's a form of executive oversight acknowledging responsibility. If thisis relaxed, there won't be the same onus on the executive. GRI
Standards reporting needs to be analogous to Annual Financial Reportingin terms of accountability and responsibility and to anticipate what isrequired now in some stock exchanges, and ought to be the norm in all.

Next Level
Sustainability

Australia

GRI Certified
Training
Partner inAustralia

On behalf ofanorganization,group orinstitution

55

Yes

Absolutely agree. In my experience a lack of engagement by the side of
the governance bodies (as well as senior executives) is not unlikely,
especially when non-financial reporting practice is percieved as acompliance duty enforced by local regulations. The acknowledgment of a
specific responsibility in that sense could help in this case to create much
more consciousness and consensus on this practice.

Alessandro
Mantini

Italy

Business

As anindividual

56

Yes

this would help increase accountability

Yes

We consider sustainability impacts and opportunity to be directly linked
to the business model. Therefore, the highest governance body shouldtake responsibility.

UnitedKingdom
UnitedKingdomAcademic

57

Laurence
Vigneau
Network for
Sustainable
FinancialMarkets CIC

58

Yes

As a point of principle the responsibility should rest with the most senior
governance body or executive of the organisation.

Hong Kong
Institute of
CPAs

Hong kong

Professional
Accountancy
Body(including
regulator andstandard
setter)As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Nongovernmentorganization

Page 14 of 52

59

Yes

Yes, but the statement should be widened to include a statement thatthe governing body monitor and, where appropriate, act on theinformation reported.

UNDP - SDG
Impact Team

UnitedStatesUN body

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

60

Yes

Companies need to take greater responsibility and increase transparency
on these issues. A statement from the highest governance body or mostsenior executive will ensure this clarity and will also ensure theinformation is of the highest quality, via a more thorough review.

BirdLife
International

UnitedKingdom

Nongovernmentorganization

61

Yes

I believe strongly that the highest governance body is also the one dealing
with the most powerful stakeholders at this stage: shareholders. An
individual that speaks out loud a statement is committed to deliver it(commitment in psychology). To avoid schizophrenic discussions, or too
much distance and reaching real commitment, this is a must.

Virginie Poulin

FranceNo response

62

Yes

Prysmian GroupItaly

No response

No response

63

Yes

because it should be immediately clear for all the stakeholders whichkind of approach a company is using to realize its report, in order toexplain specific choices related to the content and the disclosures given.
Companies that have a major impacts though their activites on theenvironment, economy, people should give bigger and deeper disclosureson their business.
Its and excelent requirement. But, where should be located? Need moreclarification about that. Could be located in disclosure 102-14? With thecontent index? apart from the report?

AG Sustentable

Argentina

Consultant

64

Yes

But there needs to be some flexibility. For example, must it be the full
Board of Directors or can it be a sub board committee comprising justsome of the directors? This should be sufficient.

Joshua Rayan
Communications

Malaysia

Sustainability
ReportWriterOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 15 of 52

65

Yes

If there is more acknowledgement the will be more commitment togood, relevant, reliable information in the report.
It is important fir stakeholders to know that sustainability is top of mind
in executives mind as well as part of their business strategies.

BSD
CONSULTING
R&A Strategic
Communications

BrazilNo response

No response

66

Yes

South
AfricaNo response

No response

67

Yes

This would align with the requirements in financial reporting.

Trossa AB

SwedenConsultant

Yes

Greater accountability is needed when a statement is released to the
public. Public listed companies are already required by regulators toassign either their CEO or CFO to sign of financial statements andinternal control statements. As sustainability is becoming increasingly
important, it would be reasonable to get a C-Level or a board member
to make a statement and acknowledge their responsibility.

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

68

ICMM

UnitedKingdom

Trade orindustry
association

However, the qualification and competence of the person to making thatstatement should be specified. We do not want more accountants signing
off different statements. It needs to be the Chief Sustainability Officer
with pre-requisite qualifications.
This is to avoid accounting profession from dominating an area that isbest managed by the scientific community and economists.

69

Yes

It ensures involvement of management at the highest level and raises theimportance and credibility of sustainability information disclosed.

On behalf ofanorganization,group orinstitution

Page 16 of 52

70

Yes

It has a long-standing issue that, under current requirements, theorganisation and senior management do not explicitly take responsibility
for the contents of a sustainability report. That the organisation may
publish or otherwise make available its sustainability report is assumed bysome to imply that the organisation is responsible for the report, butthat assumption varies in strength and support from one jurisdiction toanother. We believe a stated acknowledgement of responsibility ispreferable for clarity and global comparability.

International
Trade Union
Confederation

BelgiumLabor
On behalf ofrepresentative anorganization,group orinstitution

71

Yes

This approach helps resolve an unnecessary distinction between
sustainability and financial reporting, which was privileging financial
reporting and placing responsibility for sustainability at a lower level. We
believe this acknowledgment should have been required previously but
are relieved is now.

CanadaAcademic

72

Yes

This proposal appears useful as it will likely stimulate (further)engagement from the highest governing body or most senior executive
on sustainable development.

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee
World
Benchmarking
Alliance73

Yes

Yes but override this with whatever answer Integrated Reporting decides
following its specific consultation on this issue.

Hong kong

No response

74

Yes

This will ensure a top down approach to good corporate reporting andbring the organisation together to achieve the same common goals.

Hong Kong
University of
Science andTechnology
Tang Lien

Malaysia

Consultant

75

Yes

Yes, we support the explicit acknowledgement that the highest
governance body/most senior executive of an organisation is responsible
for the contents of a sustainability report. This would provide clarity andglobal comparability between jurisdictions about who is responsible forthe report.

Netherlands Benchmarking
foundation

Australian
Australia
Council of Trade
UnionsOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response

As anindividual

Labor
On behalf ofrepresentative anorganization,group orinstitution

Page 17 of 52

76

Yes

Yes, sustainability and responsible business conduct cannot be separated
out from senior management decision-making processes.

Engineers
Without
Borders Canada

CanadaNo response

No response

77

Yes

Acountability is safety.

None

No response

No response

78

Yes

The CEO will always have the final say in a business and they will reportto thee board. If they do not take ownership for reporting, the reporting
will not have an impact (in the business or outside the business)

Positive Impact
EventsNo
response
UnitedKingdom

Nongovernmentorganization

79

Yes

Justina CallanganPhilippines

Business

80

Yes

The Chair and the President/CEO must acknowledge their responsibility
for its preparation.
Acountability is safety.

Anna McAbee

No response

81

Yes

Bank Audi sal

No response

No response

82

Yes

for us, it is routine, our CEO/Chairperson of the board has the opening
remarks of our annual CSR report published in accordance to the GRI
Standards and either way our report is always validated y our Executive
Committee.
No comment provided

No
response
LebanonOn behalf ofanorganization,group orinstitution
As anindividual
No response

Bipart,Italy

No response

No response

India

Academic

As anindividual

Cesvor83

Yes

This will be more value addition without waiting to any statements

Parlamentary
Antimafia
Commission
SUSHILPATTANAIK

Page 18 of 52

84

Yes

• Provide a statement of use (lines 353-358): It is correct that the highest
governance body or most senior executive of the organization needs toinclude a statement acknowledging their responsibility for preparing thereported information in accordance with, or with reference to, the GRI
Standards. This is because it serves to:
1. Embed human rights into company's systems management and"culture".
2. Affirm that ultimately this person/group are responsible for the
impacts that business operations, and/or purchasing has on the humanrights of people and communities.
3. Reporting can help identify where the company needs to invest moreresources and GRI reporting can be used as part of their internalmonitoring system that also instigates action where required.

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

For these reasons, FPP considers that the acknowledgement in thestatement of use should be extended to the quality and veracity of thereported information; however, we have not offered exact wording forconsideration.

85

Yes

Yes because the commitment to report using universal standards should
be a commitment from the highest leadership in the organisation.

Aldo Joson

Singapore

Business

As anindividual

86

Yes

No comment provided

SancroftInternational

UnitedKingdom

Consultant

On behalf ofanorganization,group orinstitution

Page 19 of 52

87

Yes

No comment provided

Transparency
International
Deutschland e.V.

Germany

Nongovernmentorganization

88

Yes

This is important for commitment.

Ethcial Trade
NorwayNorway

MSI

89

Yes

No comment provided

AlliedEnvironmental
Consultants

Hong kong

Consultant

90

Yes

it gives legitimacy and shows corporate mandate, to the report's content

Sulema Pioli

BrazilConsultant

91

Yes

Sustainable development requires commitment from the highest
governance body/most senior executive to ensure that management andmitigation actions are adequately resourced and implemented.

Shelley
AndersonAustralia

Consultant

92

Yes

No comment provided

Switzerland

Consultant

93

Yes

This way, sustainability professionals, wont make mistakes on the version
uploaded to the database and have the support of a legal represent of thecompany. Besides, the highest governance body will have to approve thefinal document (practice that is not yet generalized). BUT: Take on
account that the majority of sust. reports are not uploaded to the GRI
database so, the process of getting the highest body approval can becomplicated.

Manuela HuckWettsteinDaniela Winicki

Chile

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual
As anindividual
As anindividual
As anindividual

Page 20 of 52

94

Yes

95

Yes

For purposes of accountability and ownership, it is cardinal that the mostsenior executive provides a statement.
Aligns with the UNGC communication on progress approach

Fridah Mashandi

ZambiaNo response

Fraser Paterson

UnitedKingdom

No response

As anindividual
As anindividual

No, this acknowledgement in the Statement of Use should not be required.
96

No

97

No

98

No

GRI should acknowledge that the highest governance body or mostsenior executive may delegate this authority/responsibility to another(e.g., chief sustainability officer). Proper and effective governance shouldbe the objective with this requirement, not that the governance is led bya specific body/individual.
The exposure draft Universal Standards includes many roles,
responsibilities and tasks for the Highest Governing Body (HGB). As
outlined in several comments in part 5, GRI's expectations of the HGB
are not consistent with common practice. HGBs govern, whereas thetotality of Univ Stds' expectations create more of a Management role.
HGB should be informed and steer; they should approve some aspects of
non-financial reporting, but not nearly to the extent as outlined in the
exposure draft. GRI should include the Internal Audit activity as amechanism for reviewing internal controls (including risk identification,assessment, systems & controls for compiling and validating data andinformation, etc.) for non-financial reports. Internal Audit has been
performing these duties for financial reporting for many years.
Furthermore, Internal Audit is retained by - and reports to - the HGB.

Josiah McClellan

UnitedStatesBusiness

As anindividual

Douglas Hileman

UnitedStatesConsultant

As anindividual(2) Lines 409 – 419 (p. 16) “Highest Governance Body” (HGB) appears
here and many places throughout the exposure draft Universal
Standards. GRI should revise the approach to HGB here and throughout
the Universal Standards to reflect its role in governance, and not in therole of management. The HGB should have responsibilities for steering,

Douglas Hileman

UnitedStatesConsultant

As anindividual

Page 21 of 52

governing and supporting non-financial reporting – but they should not
manage, or get too far into the details of approvals that more
appropriately belong to Management. The draft assigns many
responsibilities to the HGB that are not consistent with general practicesof governance, or the usual functioning of the HGB. Many of the roles,
responsibilities and tasks assigned to the HGB are management activities.
It is the responsibility of the HGB to govern, not to manage. In theaggregate, the proposed roles, responsibilities and tasks are unfeasible
and will create problems. Furthermore, general governance practices are
well-suited to accomplish the same objectives. Organizations often havesupport functions that should have meaningful roles in this. For example,
the Internal Audit activity is authorized and overseen by the HGB. The
Internal Audit profession has existed for over 100 years, and is relied
upon by Boards, stakeholders, and regulators alike. Internal Audit
reviews and assures internal controls over financial reporting (ICFR).
Internal Audit considers risks across the enterprise, and performs bothassurance and advisory engagements. Although paid by Management andrelying on administrative and structural support from the organization,
Internal Audit is independent and serves at the pleasure of the HGB.
Internal Audit’s role is broadly described as a “third line of defense(3LOD)” in the “Three Lines of Defense in Effective Risk Management”
position paper, which is widely adopted worldwide. There are also
“second line of defense (2LOD)” audit functions for specific areas, suchas IT, environmental, health and safety, product quality, and supply chain.
Effort by 2LOD auditors can also contribute to effective and efficient
identification, evaluation of material topics, as well as reporting of
supportable data. Both 3LOD and 2LOD roles will be mentioned inother comments throughout.

Page 22 of 52

99

No

The start with, this statement unlikely helps to enhance the quality of
Marcus Chau
sustainability reports. Such requirement may even be an obstacle ofadoption of GRI Standards in China, because it can be a great deal for the
Board of Directors to endorse a statement, especially on a topic thatthey are not familiar with. The internal cost is pretty high that only if
non-compliance is a consequence, the organization could go for asking
the Board to endorse such a statement.

Hong kong

Consultant

As anindividual

BrazilStandard
setterAs anindividual

Currently, GRI provides services to acknowledge the adoption of certain
feature of compliant report, such as use of content index and correct
approach of materiality analysis. I think GRI can continue to be theorganization confirming whether a report is prepared 'in accordance
with' or 'with reference to' GRI Standards. Some third-party verifiers give
opinion that a report is prepared in accordance with 'core option' or'comprehensive option', yet GRI may want to regulate such verification
activities to make sure the verifiers are qualified enough to make suchstatement.
100

No

We should avoid that the Standards multiply efforts, publication
requirements and bureaucracy that is UNNECESSARY. So the highest
Governance body is already responsible for all institutional output it
produces and even for output that was not fully institutionally backed. So
publishing a report already constitutes responsibility. So there is no
reason to require things that are already taken care of. This will also
diminuish criticismo from stakeholders of aspect of pointlessness in the
GRI standards that could fuel bureaucracy arguments from third party oreven other standards.

Olaf Brugman

Page 23 of 52

101

No

102

No

103

No

104

No

105

No

106

No

I think the report has partly covered the committee structure that
prepares the report, which has senior executives included in thecommittee, so a statement isnt necessary. The start of the report would
usually state the standard that is being used throughout the report forreaders to know.
This statement reflects the company as a whole and should not be
attributed to a person or role. By definition and default, the person
accountable for governance acknowledges responsibility. An additional
statement is not necessary.
Agree - accountability at senior levels is important to mainstream
sustainability reporting, but acknowledge that this requirement may
present challenges, especially for large companies where the reportdevelopment process is removed from the highest governance body or
senior executive, other than final approval and sign-off.

wei shane low

Malaysia

Business

As anindividual

ABB

Switzerland

No response

No response

Think Impact Pty
LtdAustralia

Consultant

On behalf ofanorganization,group orinstitution

The board of directors signes the complete report, why is a seperatestatement necessary?
Actually, I think a statement like this should only be required in casethere is no external assurance on the reported information. In case of
external assurance the auditor takes responsibility for the reported
information and for the way of reporting(in accordance or withreference)
No comment provided

Bondt
Communicatie
Gazprom Neft
PJSC

Netherlands No response

No response

RussianFederation

No response

No response

SM Investments
Corporation

Philippines

Business

On behalf ofanorganization,group orinstitution

Page 24 of 52

107

No

While it is important to hold the leaders of reporters accountable forthe sustainability report, it is not reasonable to expect the board-levelcommittee or CEO/Chairman understand the practical applications of
GRI Standards as they are not the direct preparers of data anddisclosures of the report. The auditor, an independent party, plays thisrole in verifying alignment with GRI and rightfully, it should be an
independent party to make this claim for the statement to carry weight.

City
Developments
LimitedSingapore

Business

On behalf ofanorganization,group orinstitution

Bursa Malaysia

Malaysia

Stockexchange

On behalf ofanorganization,group orinstitution

Having the highest governance body/most senior executive claiming thatthe company is aligned with principles-based claims such as UNGC 10
Principles, would make sense.
We don’t see the highest governance body/most senior executive makethe same claim for financial reporting in annual reports as the
expectation is already built in.
108

No

The statement of alignment with GRI (102-54) should remain as it is.
In our context, there is already a requirement that companies areaccountable for the accuracy of content, and directors have a duty toensure that. It may add to the red tape and be a deterrent without
adding to credibility.
The governance body would be concerned about the standard/duty ofcare that needs to be met, before it is able to make this statement. Not
much guidance has been provided on that. In any case, compliance with
GRI standard is very technical, it isn't fair to require a governance bodywhich is supposed to focus on strategic and macro matters, and nottechnical details to take responsibility for the compliance. That should be
the role of management, and if further independent assurance isrequired, then external assurance can be procured.

Page 25 of 52

109

No

The question is the meaning of "in accordance", if it means every
requirement of the GRI is fulfilled, no highest governance body or mostsenior executive would state this without having an assurance done
before. If it means that the formal requirements are fulfilled than there isno surplus resulting from the statement. The approval from the highest
governance body or most senior executive of the report is the important
thing.

akzentekommunikation
und beratung
gmbh

Germany

Consultant

On behalf ofanorganization,group orinstitution

110

No

That is only a formality, doesn´t add to any trustworthiness in reality - as
the the reporting as such is never, but the actual business decisions andlong term strategy is, executed by those bodies or senior executives. It isbetter to require the highest governance body or most senior executive
to state and comment what is the overarching strategy and long term
ambition in terms of sustainability - at least to do that as well.

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

111

No

Does not make sense to tell the CEO what he as to write in the letter
otherwise the letters will be just written by the consultants. With theuniversal standards they decided to regulate less the letter from theCEO (in comparison to GRI G4). This is the right direction. This clausehas no legal implications - it is just a GRI checking exercise. The
statement should only distinguish between the options chosen. No needto have it in the CEO letter

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

112

No

Reporting organisations should have some flexibility to decide on theappropriate person to sign-off, although sufficient authority would need
to be demonstrated. For example, disclosures might fall under the remitof a Chief Sustainability Officer and this would be as impactful as sign-off
by the CEO.

GIB Asset
Management

UnitedKingdomBusiness

On behalf ofanorganization,group orinstitution

Page 26 of 52

113

No

Unsure whether this is right moment to insist on this as reporting is stilllargely voluntary and is not yet at the same legal level as financial/annual
reporting. Many CEOs would not know about GRI and potentially this
could lead to the financial auditor being asked to provide that
confirmation which is not in the wider interest of sustainability reportassurance. We would recommend a measure that moves responsibility
and accountability for the report to the C-suite. Therefore we suggestthat the GRI Standards should require the highest governance body ormost senior executive of the organization to include a statement
acknowledging their responsibility for the report and the reliability of theinformation in it. This could be an addition to the CEO Letter rather
than an 'in accordance' requirement. Further consultation before insistingon the suggested statement is needed, especially in parts of the world (egUSA) where there may be legal issues, especially for a voluntarystandard.

ERM
Certification andVerification
Services (ERM
CVS)

Netherlands Assurance
providerOn behalf ofanorganization,group orinstitution

Page 27 of 52

114

No

“Highest Governance Body” (HGB) appears here and many places
The Institute ofthroughout the exposure draft Universal Standards. The draft assigns
Internal
many responsibilities to the HGB that are not consistent with general
Auditors
practices of governance, or the usual functioning of the HGB. Many of
the roles, responsibilities and tasks assigned to the HGB are management
activities. It is the responsibility of the HGB to govern, not to manage.
In the aggregate, the proposed roles, responsibilities and tasks are
unfeasible and will create problems. Furthermore, general governancepractices are well-suited to accomplish the same objectives. The HGB
should have responsibilities for steering, governing, and supporting
nonfinancial reporting – but they should not manage, or get too far into
the details of approvals that more appropriately belong to management.
Organizations often have support functions that should have meaningfulroles in this. For example, the internal audit activity is authorized andoverseen by the HGB. The internal audit profession has existed for over
100 years, and is relied upon by governing bodies, stakeholders, andregulators alike. Internal audit reviews and assures internal controls overfinancial reporting. Internal audit also considers risks across theenterprise, and performs both assurance and advisory engagements.
Although compensated by management and relying on administrative andstructural support from the organization, internal audit is an independentand objective function that serves at the pleasure of the HGB. Internal
audit’s role is broadly described as a “third line role” in The IIA’s ThreeLines Model, which is widely adopted worldwide.

UnitedStatesStandard
setterOn behalf ofanorganization,group orinstitution

115

No

No
response

No response

No response

116

No

Yes, the audience should be informed of the highest governance body ormost senior executive who acknowledges their responsibility for thereported information.
It requires the to know what GRI is all about.

CanadaNo response

No response

Principles for
Responsible
Investment
Sustainability
Advantage

Page 28 of 52

117

118

No

No

See:
Government of Hong Kong. Comments on the Environmental, Social andGovernance Reporting Guide. September 18, 2015.
https://www.creativeinvest.com/HongKongESGReporting.pdf
While we recognize that this requirement would drive accountability andincrease credibility, it is unlikely that the highest governance body or
senior executive would know whether the report is "in accordance" ifthey have not been trained. They would not be equipped to make such astatement. Would GRI need to review/certify the statement of use?
From a practical standpoint, this requirement would create concerns forcorporate legal council and may result in companies moving away fromusing GRI. In addition, this change would effectively force compnaies togo through external assurance, regardless of the business case. Again,
this could lead to pushback from companies or many reporters moving
away from GRI altogether. (2) We suggest requiring that the highest
governance body or most senior executive acknowledge their review of
the report prior to publication, thereby demonstrating the importance ofsustainability to the company.

Creative
Investment
Research

UnitedStates

ImpactInvestingInnovator

ERM

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 29 of 52

119

No

Instead of “acknowledges responsibility” utilize something along the lines
of, “acknowledges that the information reported ….”

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
No response

To raise and provide feedback: There are a number of different
Standards, guidelines, principles or certification that companies mustcomply to and voluntary report on (disclosure) – e.g. Integrated Report<IR>, TCFD etc. GRI complements <IR> however, highest governancebody or most senior executive may be hesitant to sign-off on multiple
acknowledgements for corporate reporting purposes, and opt to choose
one reporting standard. Queries also may be raised on an independent
party or GRI itself to assure or provide confirmation that the Standards
have been used appropriately before any statement of use will beallowed.
120

No

I believe that it should be included, as already contemplated, that thereport has been prepared following the GRI criteria. Perhaps they could
include a sentence explaining that the CEO is informed, but not an
express statement.

UN Global
Compact
Network Spain

Spain

Nongovernmentorganization

121

No

This is entirely unnecessary. it is not the role of the Board or the CEO
to say the report is compliant with GRI Standards. They confirm thy
approve the content through other disclosures. The compliance with thestandards is not their thing. If this is retained, then at best, it should be astatement fro the Reproting Manager.... the individual in the company
responsible for actually delivering the report. Haha. If every reproting
manager has to put their name to the report and confirm application of
the GRI Standards in full, we would probably see a better overall job. If
this is left at the level of the Board of CEO, it will be lip service andreliance upon the advice of others including assurers who do not always
do a thorough job.

BeyondBusinessLtdNo
response

No response

Page 30 of 52

122

No

Middle-upper governance body should be enough for in-accordance-withor reference-to GRI Standards. Highest governance body could take partin providing acknowledgement or responsibility of the information
provided in the material topics sustainability report as a whole. In somecompanies, their highest gov bodies doesn't want to deal with too muchtechnicalities.

Trisakti
Sustainability
CenterIndonesia

Consultant

On behalf ofanorganization,group orinstitution

123

No

That's not their job. It will take years until they understand GRI-details.

ValoraSwitzerland

No response

No response

124

No

Marjolein
BaghuisNetherlands Consultant

As anindividual

125

No

Quite bureaucratic to have it from the highest governance body. Rather
than increasing visibility of the GRI standards with this group, it may
make them detach from the Standards.
Since non-financial disclosure is becoming mandatory in many countries,
what implies its validation by the board of directors, I don't envisage theneed of such statement. A brief description of the approuval process
could be mentioned instead

REPSOL

Spain

PrivateCompany126

No

To sign this statement, a CEO will have to rely on external assurance and CSRWorks
that will increase the cost of reporting, not a welcome outcome.
International

Singapore

No response

On behalf ofanorganization,group orinstitution
No response

127

No

Our governance responsibility is already established from the Board, to
Dow Inc
our executives, to responsible leaders throughout the organization. To
meet a requirement for sign-off by the Board or senior executive, wewould have to implement significant procedural restructuring. We don't
believe the additional statement would bring additional value or quality to
our reporting.

No
response

No response

No response

Page 31 of 52

128

No

Al least when the report is already subject to third party certification(e.g. according to ISAE 3000 principle), such an acknowledgment isabsolutely redundant. In fact, even if it is not a public document,
assurance companies require it to before delivering the assurance
statement. In this letter, signed by the CEO and/ or the Sustainability
report preparer, the accordance with GRI standards is clearly stated by
the reporting company, as well as the completeness, the reliability andthe veracity of the information provided. Moreover, accordance withGRI Standards is also stated by the assurance company itself in its
assurance statement which is normally published in the Sustainability
Report. In our opinion such request would require companies to deal
with another internal complex authorization process while not providing
added value to their stakeholders as this information is already includedin the third party certification statement.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

129

No

Eko
Sukoharsono

Indonesia

Academic

As anindividual

130

No

Simeon Cheng

Hong kongBusiness

131

No

DQS CFS

Germany

No response

As anindividual
No response

132

No

It is not necessary to be explicitly required their responsibility with astandard. It is automatically implicit the executives are responsible to thewhole report contents.
No need from the highest governance body, but it must be disclaimed in
the document.
I'm afraid that if it becomes to technical, executives will not bother tounderstand and just add a meaningless signature. We cannot expect the
top-Level executives to familiarize themselves with the Standards.
Rather, they should confirm the accuracy and representativeness of thedisclosed Information.
reason being - the highest executive may not be the subject specialist. assuch they will not likely know the content of the standard, whereas a
subject specialist would likely. if this becomes a requirement, it may
reduce the number of organisations using the standard over time, which
will be counter-productive to improved, more participatory sustainability
disclosure.

Sime Darby
Property Bhd

Malaysia

Business

On behalf ofanorganization,group orinstitution

Page 32 of 52

133

No

This is totally unnecessary. A publication which declares conformance to
GRI Standards, includes a CEO letter, and declares Board approval ofcontent does not need an additional statement of use. It's clutter.

Beyond BusinessLtdNo
response

No response

No response

134

No

BSI Group

Italy

No response

No response

135

No

No need from the highest governance body, but it must be disclaimed in
the document.
Current requirement is adequate as the sustainability report is preparedbased on local bourse's rules and regulations.

DRB-HICOMBerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

so, we are obliged to use the specific statement below in thesustainability report, without change any words. is it correct?

Prysmian GroupItaly

No response

No response(7) We would also recommend that the ‘statement of use’ is included inthe ‘sustainability reporting’ sections rather than in the GRI content
index. For the assurance provider, it is important that the criteria for thesustainability reporting is clearly identified within the sustainability
reporting itself. In fact, the GRI content index often falls outside thescope of the assured information. (reference 346-375; 400-430; 766767).
(5) 9. We suggest asking for more clarity in the reference statement on
the company’s approach to reporting. For example, where appropriate,
to add to the statement that the information has not been prepared inaccordance with all GRI standards.

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

Other comments
136
137

138

No
comment
providedNocomment
providedNocomment
provided

8

Page 33 of 52

10

Extending the Statement of Use to the quality and veracity of reported
information

11
12

Survey question: If your answer to the previous question is yes, should the acknowledgement in the Statement of Use be extended to the quality andveracity of the reported information?

13

Please refer to page 15 in the Universal Standards exposure draft.

9

14
No.

SurveyComment
response

Organization
nameCountry

Stakeholder
group

Submission
type

If your answer is yes, please provide suggestions on how to amend the statement.
1

Yes

Luis Cordova

Peru

Academic

As anindividual

Yes

BECAUSE BOTH, QUALITY AND VERACITY OF THE REPORTEDINFORMATION ARE CRITICAL TO MEASURE THE SUSTAINABILITYPERFORMANCE OF THE ORGANISATIONS.
No comment provided

2

Han Wei Ho

Malaysia

Consultant

3

Yes

Following industrial principles and standards, or or provide internal ones.

Hui Xu

China

4

Yes

Nazish Shekha

Pakistan

5Yes

The organization should reflect on its reporting procedures andprocesses in developing the report: ie hiring a consultant, KPIs reviewed
through internal audit, external audit and assurance.
[Title of the highest governance body or most senior executive of theorganization] acknowledges responsibility for the quality and accuracy of
information included in [name of organization]’s report and that it has
been prepared in accordance with the GRI Standards.

Deloitte

UnitedStatesNongovernmentorganization
Nongovernmentorganization
Consultant

As anindividual
As anindividual

6

Yes[Title of the organization’s highest governance body responsible for nonfinancial reporting] acknowledges responsibility for the following

PwC

UnitedKingdom

Assurance
providerAs anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanPage 34 of 52

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

7

Yes

8

Yes

9

Yes

10

Yes

Likewise, [Title of the organization’s highest governance body
responsible for non-financial reporting] assumes responsibility for the
published contents, the quality and veracity of the information, theadequacy of the information requirements identified in the different
disclosures of the content index, as well as the design, implementationand maintenance of the internal control related to non-financial
information.
‘This report has been prepared in accordance with the GRI Standards:
Core/Comprehensive option’ and comply with all requirements in
Section 2 of GRI 101: Foundation (‘Using the GRI Standards forsustainability reporting’).
Although our organization is not for profit, we take great care toembody the values of transparency and credibility
And assume responsibility .. We believe that the statement includes
these values that the organization adheres to in all its work
They are carried out in various fields and comply with standards
The importance of stakeholder participation... and this will benefit the organization and ensure the quality of its
work, its credibility with stakeholders and its sustainability in its work
environment at the local and global level.
As in any audit statement, senior management must acknowledge
responsibility for the statement - in accordance with the usual practiceof due diligence.
By mandatory assurance.

organization,group orinstitution

ICR Systems &Management
SRL

Bolivia

No response

No response

Sharjah City for
Humanitarian
Services

UnitedArab
Emirates

Non-profit
organization

On behalf ofanorganization,group orinstitution

IndustriALL
Global Union

Switzerland

Labor
representative

Izzaty Khaleda
IsmailMalaysia

Consumers

On behalf ofanorganization,group orinstitution
As anindividual

Page 35 of 52

11

Yes

No comment provided

12

Yes

13

Yes

14

Yes

15

Yes

16

Yes

17

Yes

The traceability of the positive impacts that an organization maximizes
and the negative or less favorable impacts that it manages must always
have a good quality of management within the organization.
Clearly state the level assurance of data presented - No Assurance,
Limited or Reasonable level. E.g. The information reported by [name oforganization] for the [reporting period] has been prepared inaccordance with the GRI Standards and data presented has has a[No/Limited/Resonable] Level of assurance applied prior to publication.
Considering the quality of the reported information in the statement of
use would help to provide users of the disclosure with further usefulcontext. Rather than requiring that the acknowledgement provides a
singular view of the quality or veracity of the overall disclosure, wewould suggest that it would be helpful to require organisations to
specifically identify any areas where information may be incomplete, or
has been prepared under conditions of uncertainty, together with an
explanation about the nature and degree ofomissions/errors/uncertainty. This would help to ensure that users of
the information are able to take this into consideration in their use of
the disclosure.
I acknowledge my full responsibility for quality and veracity of thisreport.
i attest that this rpeort has been prepared in accoradance with , or withrefrence to the GRI standards. I take full responsibilty, without
prejudice, for all informatation and data reported therin
I believe non-financial reporting is not treated with as much scrutiny asfinancial reporting. This will support oversight and verification of
information.

Fanny Medalith
Mendoza
Gutiérrez
Angel Castillo

Peru

Business

As anindividual

EcuadorConsultant

As anindividual

University ofSouthern
Queensland

Australia

No response

No response

CDSB

UnitedKingdomStandard
setterOn behalf ofanorganization,group orinstitution

SAI Global Italias.r.l.
ZENITH BANK
PLC

Italy

No response

No response

Nigeria

No response

No response

ELEVATE

Hong kong

No response

On behalf ofanorganization,group orinstitution

Page 36 of 52

18

Yes

I think that it would be important to show how the data have beencollected. A Infografic about the data collection (status and expertise of
the information providers, range of the data collection (only PR or also
HR-Controlling ...?) could be useful to indicate if it is credible that thesenior managers can verify the quality of the data collection.
If sustainability reporting in general – and GRI Standards specifically – areto be taken seriously by the wider business community, they need toalign with sign-off expectations of financial information. Sign off should be
required for reporting in accordance with GRI.
Suggested amendment:“The Board of Directors acknowledges responsibility for the following
statement of use:
The information reported by ABC Limited for the year ending 31
December 2020 has been prepared in accordance with the GRI
Standards ”.
As per the examples provided in (3.a).

19

Yes

20

Yes

21

Yes

In this case we agree, however it is necessary for you to tell us how thisstatement of acknowledging, should be made, by means of a letter, in thepresentation of the Annual Report by the CEO, in the GRI index? Moredetail is necessary

22

Yes

Information reported must reflect the statement by the top
management.

23

Yes

IOSH suggests that the statement of use could read as follows: "...hasbeen prepared in accordance with the GRI Standards. This organisation
can provide details of the quality and veracity processes it applied tosupport its data provision for this report."

FOM Universityof Applied
Sciences

Germany

No response

No response

WBCSD

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Dr. Aljiohra
Altuwaijri
Walmart deMéxico yCentroamérica

Saudi
ArabiaMexicoAcademic

Universiti
MalayaSustainability &Living Labs
Secretariat(UMSLLS)
Institution of
Occupational
Safety and
Health (IOSH)

Malaysia

No response

As anindividual
On behalf ofanorganization,group orinstitution
No response

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf ofanorganization,

Business

Page 37 of 52

24

Yes

It can be extended, however the wording “to the best of its knowledge”
should be included.

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

25

Yes

It can include the reaction of the organization to the international agendaof the reporting year and/or the year following the reporting year (whenthe report is being prepared), for example, COVID-19.

Da-Strategy

RussianFederation

Consultant

26

Yes

Lines 353-375 for A, lines 407-430 seem appropriate.

Japan

No response

27

Yes

ok

International
Development
Center of Japan
Ilunka,Estrategia
Sustentable

MexicoConsultant

28

Yes

No comment provided

Colombia

Consultant

29

Yes

Quality output for sustainability data is crucial and more mechanism
towards assurance should be there.

Ana María
Gonzáles Ruiz
DUOPHARMA
BIOTECH
BERHAD

Malaysia

Business

30

Yes

Requiring that the highest governance body or most senior executive of
the organisation assure the quality and veracity of the reported
information would in practice push reporting organisations toward theneed for a third-party assurance. Even though third-party assurance has
many benefits, it is still doubtful if GRI Standards should require all

Enact
Sustainable
Strategies

SwedenConsultant

group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response
On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 38 of 52

31

Yes

32

Yes

organisations wanting to use the GRI Standards to go through theresource intensive process of getting their report assured by a third
party.
One suggestion is to include a statement assuring the quality and veracity
as a distinguisher between Option A and B, where Option A would
require that the statement of use also include reference to the quality
and veracity of the reported information.
Being accountable for the accuracy (on best effort basis) and tying
variable remuneration to withstanding scrutiny of disclosed sustainability
information in the report. This may be out of reach in the coming coupleof years, but hopefully this is the direction of travel.
Same rationale as above

33

Yes

Seems a pretty feeble sort of statement if it does not cover this too!

34

Yes

35

Yes

36

Yes

statement shall indicate the independence with the outside consulting
company or assurance party.
The Board of Directors has approved the following statement for use:
418 The information reported by ABC Limited for the year ending 31
December 2020 has been
419 prepared with reference to the GRI Standards cited in this content
index with our knowledge and support.
The DIHR recommends including language that builds on UNGP
principles 21b to strengthen internal assurance of quality and veracity of
information included in connection to the statement of use or as aminimum that explicit reference to GRIs Reporting Principles are given.
Please see two alternative suggestions below:
Suggestion A: [Title of the highest governance body or most senior
executive of the organization] acknowledges responsibility for the

Eszter Vitorino

Netherlands

Investor

As anindividual

Datamaran

UnitedStatesDigitalplatform

Corporate
Citizenship
SGS

UnitedKingdomChina

No response

On behalf ofanorganization,group orinstitution
No response

No response

No response

VertAfrika
LimitedNigeria

No response

No response

Danish Institutefor Human
RightsDenmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

Page 39 of 52

37

Yes

38

Yes

39

Yes

following statement of use: The information reported by [name oforganization] for the [reporting period] has been prepared inaccordance with the GRI Standards and provides information that is
sufficient to evaluate the adequacy of [name of organization]’s
management of its material topics.
Suggestion B: [Title of the highest governance body or most senior
executive of the organization] acknowledges responsibility for thefollowing statement of use: The information reported by [name oforganization] for the [reporting period] has been prepared inaccordance with the GRI Standards including the GRI Reporting
principles on Accuracy, Balance, Clarity, Comparability, Completeness,
Sustainability Context, Timeliness and Verifiability.
The information reported by [name of organisation] for the [reporting
period] has been prepared by one or more GRI Certified Sustainability
Professionals [from the executive/highest governance body] to ensure
the quality and veracity of the reported information in accordance with
the GRI Standards.
the quality of the information provided in reports has been a longstanding issue in sustainability reporting. The inclusion of quality andveracity criteria in the statement could help address this issue. However,for this to work, we would need to have clearer guidelines on thereporting principles, including more precise methodological guidance.
The statement must include details of the method of assurance of theinformation provided in the report that has been adopted by thecompany and who has carried out the assurance (internal includingwhich division of the organisation; external including details of the nameand expertise of the organisation/s involved). This must include
assurance as to the quality and completeness of the information andreasons for any incomplete information (for example, the information
does not exist, is confidential, etc.)

Next Level
Sustainability

Australia

GRI Certified
Training
Partner inAustralia

Laurence
Vigneau

UnitedKingdomAcademic

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
As anindividual

On behalf ofanorganization,group orinstitution

The approach compliments the approach of the GRI standards toPage 40 of 52

40

Yes

41

Yes

42

disclose the names and details of the stakeholders involved in the
preparation of the report.
The Statement should acknowledge responsibility for reporting
information that is accurate and relevant but go so far as to suggest that
it is assured. External assurance, if engaged, will assure the responsibilityof the most senior governance body or executive of the organisation has
been met.

Hong Kong
Institute of
CPAs

Hong kong

Professional
Accountancy
Body(including
regulator andstandard
setter)UN body

The statement should be widened to include a statement that the
governing body monitor and, where appropriate, act on the information
reported.

UNDP - SDG
Impact Team

UnitedStatesYes

The survey should ensure any information provided can be appropriately
supported and require confirmation of addtional information, such as
information/data sources, dates, times and other references.

BirdLife
International

UnitedKingdom

Nongovernmentorganization

43

Yes

Virginie Poulin

FranceNo response

44

Yes

Yes if this is a collective assessment. To be true, the highest governancebody is legally responsible on the financial side, on the legal side, so why
not on the impact of their activities. Organizations, banks especially did atremendous job on setting up perfect organizations in termes ofcompliance and financial security, so why not with sustainabilit andimpact?
The whole Non-Financial Declaration has been prepared in accordancewith the “GRI Sustainability Reporting Standards” published in 2016 by
the“GRI - Global Reporting Initiative”. The document was prepared taking
into account the sustainability issues considered significant for the Groupand for the Group’s stakeholders, submitted as part of the materiality
matrix (see paragraph “Stakeholder engagement and materiality

Prysmian GroupItaly

No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

No response

Page 41 of 52

analysis”). As requiredby the reporting Standard, the “GRI Content Index” is reported at theend of this document, containing details of the accounted indicators.
This amend should be incluided to increase the porpuse of thestatement. If not, the previous statement could be not so relevant
It should be similar as financial reporting requirement in this kind ofstatements.

45

Yes

AG Sustentable

Argentina

Consultant

This is necessary to ensure a higher level of accountability. Not just at
Board level, bit across all levels of people involved in the thesustainability reporting process. It may also encourage stronger internalor external assurance.

Joshua Rayan
Communications

Malaysia

Sustainability
Report WriterThis report was verified internally (or by 3rd party) and contains reliable
and transparent information on this company.
This should be mentioned explicitly pointing to the external assurance
aspect.

BSD
CONSULTING
R&A Strategic
Communications
Trossa AB

BrazilNo response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response

46

Yes

47

Yes

48

Yes

South
AfricaNo response

No response

49

Yes

This would align with the requirements in financial reporting, andincrease the need for third party assurance, which is positive.

SwedenConsultant

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

50

Yes

51

Yes

This would impute legal responsibility and potential liability on the
person making the statement. The statutory auditor will be compelled toverify on the veracity of the statement. Collectively, this would
significantly increase the seriousness of the matter and efforts to ensurethat reporting is accurate.
We agree that there should be a statement of support in some form
from either a senior executive or the board of directors (whichever ismost appropriate to the reporting organization). It is acknowledged that
this responsibility may be delegated to senior management. Where

Page 42 of 52

52

Yes

53

Yes

independent assurance providers already express a public opinion on thequality and veracity of reported information (in accordance withspecified standards and within their agreed mandates), a reference tosuch engagement would be appropriate.
We consider that a stronger statement around quality and veracity
would give report users and stakeholders more certainty that they canrely on the contents of the sustainability report. While it is difficult for
an organisation or senior management to absolutely confirm the veracityof a report that has content on impacts outside of, or beyond, theorganisation, a statement that due diligence has been exercised inensuring the veracity of the report would be warranted.
We suggest the following amended statement:“The information reported by [name of organization] for the [reporting
period] is veracious, accurate, reliable and verifiable and has been
prepared in accordance with the GRI Standards”

54

Yes

55

Yes

Yes - but this is likely aspirational and may be challenging to provide(e.g., due to legal liability issues).
Could the statement of quality and veracity be included as arecommendation rather than a requirement? E.g., “The organisation
should include the following statement in its GRI content index: “Theinformation reported by [name of organisation] is to the best of myknowledge a true and fair representation of the material topics reportedon.”” or similar. This could encourage this as good practice by thoseorganisations with the means to do so but not penalise organisations not
yet able to.
Yes but follow Integrated Reporting’s decision based on its specificconsultation on the same topic.

group orinstitution
International
Trade Union
Confederation

Belgium

Labor
representative

On behalf ofanorganization,group orinstitution

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee
World
Benchmarking
Alliance

CanadaAcademic

On behalf ofanorganization,group orinstitution

Netherlands

Benchmarking
foundation

On behalf ofanorganization,group orinstitution

Hong Kong
University of
Science andTechnology

Hong kong

No response

No response

Page 43 of 52

56

Yes

Acknowledgement of the quality and veracity of the information isessential to ensure transparency and accountability.
Yes, a stronger statement re: the quality and veracity of the reported
information would give stakeholders more certainty about the reliabilityof the report. The statement could be amended to confirm that due
diligence has been exercised in ensuring the quality and veracity of thereported information.
Yes, we would expect this for financial information, and so there is no
reason it should be different for impacts on society.

Tang Lien

Malaysia

Consultant

AustralianCouncil ofTrade Unions

Australia

Labor
representative

Engineers
Without
Borders Canada
None

CanadaNo response

As anindividual
On behalf ofanorganization,group orinstitution
No response

57

Yes

58

Yes

59

Yes

No comment provided

No
response
UnitedKingdom

No response

No response

60

Yes

No comment provided

Positive Impact
EventsNongovernmentorganizationNo
response
LebanonItaly

No response

On behalf ofanorganization,group orinstitution
No response

61

Yes

No comment provided

Anna McAbee

62
63

Yes
Yes

No comment provided
No comment provided

64

Yes

65

Yes

As GRI is the highest body , any clarification or statements for any
change must be informed by its executives
No comment provided

Bank Audi sal
Bipart,CesvorParlamentary
Antimafia
Commission
SUSHILPATTANAIK
Forest Peoples
Programme

No response
No response

No response
No response

India

Academic

UnitedKingdom

Nongovernmentorganization

As anindividual
On behalf ofanorganization,group orinstitution

Page 44 of 52

66

Yes

Aldo Joson

Singapore

Business

Yes

Quality and veracity of the reported information can only be assured asof the time of writing/reporting.
No comment provided

67

SancroftInternational

UnitedKingdom

Consultant

68

Yes

No comment provided

Transparency
International
Deutschlande.V.

Germany

Nongovernmentorganization

69

Yes

same as 3.1, above

Sulema Pioli

BrazilConsultant

70

Yes

Shelley
AndersonAustralia

Consultant

71

Yes

Daniela Winicki

Chile

Consultant

72

Yes

Fridah Mashandi

ZambiaNo response

73

Yes

Fraser Paterson

Yes

UnitedKingdom
UnitedKingdom

No response74[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 and[name of organization]'s report and is complete and accurate.
In Chile, as an example, Financial info, is presented with an Annex, with
an image that shows the sign of each director.
The statement must include a component of how accurate theinformation should be reported including the recognized and acceptableassessment tools that an organisation would use when reporting
Participating organisations should have adequate guidelines as opposed
to a pre-set statement"The quality and veracity of reported information has been verified"

GIB Asset
Management

Business

As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual
As anindividual

As anindividual
As anindividual
As anindividual
On behalf ofanorganization,group orinstitution

Page 45 of 52

75

Yes

See 3b - important (but not in addition to 3) and moves the debate in
the right direction as it would ensure that CEOs/Boards see and review
the sustainability report.

76

Yes

77

Yes

The governing body should ensure the quality and veracity of thereported information by indicating the role of an internal audit functionin providing independent, objective assurance over the accuracy of theinformation being reported. Organizations can make broad claims andassertions that influence readers of nonfinancial reports. Internal auditing
plays an important role in ensuring the accuracy of claims and assertionsin qualitative content of nonfinancial reports.
Yes, there should be an audit trail of information to support thereported information.

ERM
Certification
and Verification
Services (ERMCVS)
The Institute ofInternal
Auditors

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

UnitedStatesStandard
setterPrinciples for
Responsible
Investment

No
response

No response

No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

If your answer is no, please provide an explanation.
78

No

A statement from senior management acknowledging their responsibility
already implies this.

ISOS Group

UnitedStatesConsultant

79

No

Difficult for an organization to self-assess thisTorontoPearson Airport

CanadaBusiness80Noi think it is better to have it in next levels , it can be used in draft orversion about how check e quality and veracity . providing level andchecking process should be differnt

RPMRG

Hungary

Consultant

Page 46 of 52

81

No

82

No

83

No

84

No

85

No

I think this could provide too much of a barrier for some organisations
and is to some degree implicit in the previous statement
It is assumed that the quality and veracity of the reported information isendorsed by the senior managers of the company at the time of the
publication of the report, so it is not considered necessary to say it
explicitly.

Alexandra
McKay
Sustenia

UnitedKingdom
Argentina

Consultant

It is probably a too strong assumption in our case: our auditor firm
(KPMG) requests already a signature of our CEO on a formal
documentation - in Italian "lettera_di attestazione revisione limitata" concerning the quality and veracity of the reported information.
*Acknowledging the Quality the sustainability report would be morecredible (especially in the eyes of the external stakeholders) if it isprovided by an External Assurance report for the sustainability report.
*Justification: External assurance provides an independent, professional
opinion on the quality of the information disclosed by the reportingorganization. Such unbiased opinion would objectively evaluate thesustainability impacts (if any) of the reporting firm and provides
suggestions for improvement from different perspective (other than thatof the reporting firm). In addition to being able to uncover "unreal"sustainability impacts. This excellent practices is considered to a crucial
one for external stakeholders, who would based their relevant decisions
on it. This would not be the same, if such quality acknowledgement isprovided by an internal stakeholder.
Reference:
Abd El-Rahman, N. (2020). The Assurance of Sustainability Reporting: An
Extra Fee or A Guarantee. Sustainable Development and Social
Responsibility. 1. Dubai, AUE: Springer.
https://link.springer.com/chapter/10.1007/978-3-030-32922-8_19.
It's difficult for the Snr Exec to know what the quality is. We need anassurance standard that will assess this reasonably i.e. not requiringexcess time, resources or funds to complete but actually providing value

CrevalItaly

No response

Noha
Abdelrahman

Egypt

Academic

As anindividual

Liberty Holdings
LimitedSouth
AfricaNo response

No response

Consultant

As anindividual
On behalf ofanorganization,group orinstitution
No response

Page 47 of 52

to the report as a whole (report wide assurance rather than selectedindicators only).
No as not sure. By selecting option A (even option B to a degree), thisthen implies that the organisation has applied the reporting principles
which infer ‘quality’ and ‘veracity’, and therefore the acknowledgement
implies that the governing body is responsible for these reporting
principles being applied. Does this question suggest that sections of theStandards are excluded? If so, which ones? Should then these not be
specified? And, what are the implications of these exclusions? As areader, I would welcome such an emphasis but as a director I would becautious as there is a potential of creating an expectation that might
carry an unintended liability or risk, i.e., readers may assume that all dataand information has been audited or assured by an independent party.
Report quality is subjective and should be judged externally. As forveracity, acknowledgment for the statement of use implies that thereport follows all reporting principles in GRI 101 section 4, including theprinciple of "verifiability". This level of implied acknowledgment issufficient.
The accordance with the GRI Standards already imply the quality andveracity of information provided, since the organization is required toapply the reporting principles (see lines 440-442 of Exposure draft)

86

No

87

No

88

No

89

No

The External Assurance statement gives more credibility in ensuring thequality and veracity of the reported information because it signifies that athird-party verified the data reported.

90

No

The highest governance body or most senior executive of theorganization may not have the ability and time to examine the veracityand quality of the information disclosed in the report. Similar to financial
reporting, to enhance the quality and credibility of the report, reporting

SAICA

South
AfricaNongovernmentorganization

On behalf ofanorganization,group orinstitution

Paia Consulting

SingaporeConsultant

EY S.p.A.

Italy

Consultant

University ofAsia and thePacific - Center
for Social
Responsibility
Fuji Xerox(Hong Kong)
LimitedPhilippines

Assurance
providerHong kong

No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response

Page 48 of 52

91

No

92

No

93

No

organizations may seek professional help from external assurance. Thismay cause duplication in section 5 (clause 625 to 688).
The quality and veracity is checked by third party reviewer and not by
the management.

This Statement of Use seems redundant with the most senior executive
statement that is typically at the beginning of most reports and does notgive the implication that the most senior executive is verifying or taking
responsibility for the content contained WITHIN the report. It is
doubtful that the most senior executive is a subject matter expert of the
GRI Standards and Reporting Principles (in the same way a sustainability
lead or consultant is) so why should they be signing a Statement of Usethat only has to do with adhering to the GRI Standards? It could beargued that this creates interest at their level regarding the report itself
and that I agree there should be a statement of use to hold someone
responsible. However, as an alternative (or in addition to the current
proposed statement), the statement should retain focus on the CEOtaking responsibility for the information and content within the reportand its validity. Following the nature of typical mandatory regulatorycompliance reporting, someone at the C-suite level should be held
responsible for misrepresentation or false data. If including such astatement, it should be with that context in mind. From a consumer's
standpoint, I likely won't stop buying a product because they missed one
or two points of the GRI Standards themselves but I will stop if I
discover that they were falsely reporting data that the companies
leadership did not verify or hold their own leadership responsible forvalidating.
To expand the scope to ‘the quality and veracity of the reported
information’ and to demand responsibility, it is necessary to have someclear rules on how to check the content. However, there are no unified

Corporate
SocialResponsibility
Centre Pakistan

Pakistan

Consultant

University ofDenverUnitedStatesNo response

On behalf ofanorganization,group orinstitution
No response

Global Compact
Networking
Japan

Japan

Generalincorporated
association

On behalf ofanorganization,

Page 49 of 52

94

No

95

No

96

No

97

No

98

No

rules in place at present.
In addition, the legal binding nature of disclosure of non-financial
information varies from country to country (e.g. Compulsory disclosure
is required in the EU by the Non-Financial Reporting Directive). We
believe it is unrealistic to require guarantees of the quality and veracityof the reported information as a uniform rule.
We believe this would just leverage external assurance, and notconvince top management to engage responsibly in material topics /sustainable development.
I would prefer this kind of acknowledgment was made by an external
auditor in charge of evaluating the quality of the reported information.
It is understood. One (of that position) does not sign such an important
document without reading it and making sure that the contents are true
and of quality. I wouldn't object though if required as it may serve as awarning to the signatory.
For the time beeing a formal acknowledgement of respoinsibility is
sufficient
My answer to Question 3 was NO. But the same rationale applies. To
the extent that anyone should provide statements regarding the quality
and veracity of reported information, that responsibility should fall toManagement. GRI could suggest that the sustainability/ non-financial
reports include language as to whether Internal Audit has been involvedin the review of the reported information, and if so, to what extent.
Another note on "reported information" - "information" includes data
[numbers, trends, etc.] as well as other information, including claims andassertions. The approach to ensuring quality and veracity of data andother types of information can be very different. When describing"information" included in sustainability reports, GRI should clarify that
this includes numerical data, and claims & assertions. This could be done
once in the Universal Standards, or via the glossary.

group orinstitution- Study
Committee on
Corporate
Reporting
triple innova

Germany

Consultant

Alessandro
Italy
Mantini
Justina Callangan Philippines

Business

Manuela HuckWettstein
DouglasHileman

Switzerland

Consultant

UnitedStatesConsultant

Business

On behalf ofanorganization,group orinstitution
As anindividual
As anindividual
As anindividual
As anindividual

Page 50 of 52

99

No

Again, the publication of the report implies the acknowledgement of that
person. Quality and veracity are included in the external assurance so a
published report would tick all the above mentioned boxes already.
How would quality be assessed? Need to provide more clarity on what
this means. Veracity may be ok, though isn't that the role of external
assurance?

ABB

Switzerland

No response

No response

100

No

Think Impact
Pty Ltd

Australia

Consultant

No

If external assurance is provided this is not necessary.

No

No response

No response

103

No

If the Company choses to comply with GRI Standards in its non-financial
reporting and states it clearly, it already agrees with the Principles fordefining report content.
It is normally part of our President's message. I think a specific statement
is not needed but it should be implied and incorporated in the
President's report or board message.

Netherlands
RussianFederation

No response

102

Bondt
Communicatie
Gazprom Neft
PJSC

On behalf ofanorganization,group orinstitution
No response101

SM Investments
Corporation

Philippines

Business

104

No

It should already be expected for reporters to provide accurate andquality disclosures, for a public document

City
Developments
LimitedSingapore

Business

105

No

The quality and veracity should be verified by external auditor, similar tofinancial reporting.

Bursa Malaysia

Malaysia

Stockexchange

106

No

this would mean the obligation of external assurance. As the highest
governance body or most senior executive could not assure this by itself

akzentekommunikation
und beratung
gmbh

Germany

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Page 51 of 52

group or
institution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

107

No

To strengthen the credibility for quality and veracity of the detailed
reporting it would have better effect to require for example at least
limited external assurance from external auditor, for the in accordance
option.

Bonava AB

SwedenBusiness

108

No

No comment provided

SchweryCade

Switzerland

Consultant

109

No

It is not necessary that the acknowledgement is stated as in the GRI
standard. All contents of the sustainability report are belonging to the
management and their responsibility.

Eko
Sukoharsono

Indonesia

Academic

Non-financial information is critical in the management information anddecision-making systems. It needs to be correct.

Sustainability
Advantage

CanadaNo response

No response

We believe new standards and technologies will be developed to help
deliver ESG data to interested parties.

Creative
Investment
Research

UnitedStates

ImpactInvestingInnovator

On behalf ofanorganization,group orinstitution

Other comments
117
118

No
comment
providedNocomment
provided

Page 52 of 52