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

Item 04 – GRI Universal Standards
Project – Draft GSSB basis forconclusions
For GSSB information
Date

10 May 2021

Meeting

10 June 2021

Project

GRI Universal Standards Project

Description

This document summarizes the significant issues from comments received on the
GRI Universal Standards exposure draft, during the public comment period from11 June 2020 to 9 September 2020, and the GSSB responses to the significant
issues raised.
The full set of public comments can be downloaded from the Review of the
Universal Standards project page on the GSSB website.
In line with the GSSB Due Process Protocol, the final version of this document is
to be published on the Review of the Universal Standards project page together
with the GRI Universal Standards 2021 after their approval.

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

© GRI 2021

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Contents2

About this document ............................................................................................................................ 33

Introduction ........................................................................................................................................... 3

4

Objectives for reviewing the Universal Standards ........................................................................... 3

5

Scope of the public comment .......................................................................................................... 3

6

Overview of submissions ................................................................................................................. 4

7

Methodology for analyzing comments ............................................................................................. 4

8

Significant issues and GSSB responses ............................................................................................ 5

9

Cross-cutting issues ............................................................................................................................ 5

10

GRI 101: Using the GRI Standards ..................................................................................................... 6

11

Section 2. Key concepts in the GRI Standards ............................................................................... 6

12

Section 3. Sustainability reporting using the GRI Standards ........................................................... 8

13

Section 4. Reporting principles ...................................................................................................... 13

14

GRI 102: About the Organization ...................................................................................................... 14

15

Section 2. Organizational details and reporting practices ............................................................. 14

16

Section 3. Organizational activities ................................................................................................ 14

17

Section 4. Governance .................................................................................................................. 15

18

Section 5. Responsible business conduct ..................................................................................... 16

19

Section 6. Stakeholder engagement .............................................................................................. 18

20

GRI 103: Material Topics ................................................................................................................... 18

21

Section 2. Identifying material topics ............................................................................................. 18

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Section 3. Reporting on material topics ......................................................................................... 19

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Appendix 1. Participation to regional workshops and webinars ................................................... 21

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Appendix 2. Public comment submissions by stakeholder constituency, organization size andregion ................................................................................................................................................... 22

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About this document

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This document presents the significant issues raised by respondents regarding the exposure draft of
the GRI Universal Standards during the public comment period from 11 June 2020 to 9 September
2020.

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The document summarizes feedback provided by respondents through the public comment survey
hosted on the Review of the Universal Standards project page and official feedback submitted byemail. Where relevant, it also references feedback received from respondents at regional workshops
held during the public comment period.

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All individual comments received, together with an analysis of the significant issues raised, wereconsidered by the GSSB in their review of the Universal Standards. This document provides asummary of how the GSSB has responded to the significant issues raised in the public comment
period.

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The full set of comments received can be downloaded from the Review of the Universal Standards
project page on the GSSB website.

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The GRI Universal Standards 2021 can be downloaded here [GSSB website].

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Introduction

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Objectives for reviewing the Universal Standards

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The project proposal for the review of the GRI Universal Standards was approved by the Global
Sustainability Standards Board (GSSB), GRI’s independent standard setting body, at its meeting on
26 March 2019.

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The project was initiated following the recommendations from the GRI Technical Committee on
Human Rights Disclosure. The project also drew on feedback received from the GSSB during thetransition from the G4 Guidelines to the GRI Standards, feedback received from reportingorganizations and other stakeholders, and information gathered from the review of sustainability
reports using the GRI Standards. Overall, the project aimed to:• provide greater clarity on key concepts, reporting principles, and disclosures in the Universal
Standards and ensure they are aligned with recent developments in responsible businessconduct;• integrate the expectations of due diligence into the GRI Standards;• assist reporting organizations in understanding the reporting requirements and how they
demonstrate compliance in a transparent way;
• drive consistent application of the GRI Standards;• encourage more relevant and comprehensive reporting for experienced reportingorganizations;• enable first-time reporters and SMEs to more easily apply the GRI Standards;• improve overall usability of the GRI Standards.

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The project followed the GSSB Due Process Protocol. A sub-committee of four GSSB members wasconvened to provide advice and direction for the project, and the proposed revisions were discussedwith all GSSB members over the course of 18 meetings between 2019 and 2021.

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Scope of the public comment

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The exposure draft of the Universal Standards was open for public comment, as required by the
GSSB Due Process Protocol, from 11 June 2020 to 9 September 2020. Respondents were invited tosubmit their feedback on the clarity, feasibility, and relevance of the significant proposals contained in
the exposure draft.

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Several outreach activities were carried out during the public comment period, including webinars,
regional workshops, and one-to-one consultations with stakeholders. Approximately 390 participants

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attended the regional workshops, online or in-person, in Africa, Hong Kong, Latin America, Greater
China, North America, South East Asia (Malaysia, Philippines, and Singapore) and Taiwan.
Approximately 2,340 individuals attended the webinars. Appendix 1 contains an overview of these
events.

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Overview of submissions

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Respondents were invited to submit their comments on the Universal Standards exposure draft using
an online survey. The link to the survey was made available on the project page on the GSSB website
for the full duration of the public comment period.

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Respondents could also submit an official letter or statement to universal@globalreporting.org.

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A total of 144 submissions from individuals and organizations were received on the exposure draft,
consisting of 141 completed surveys and three letters. The submissions contained approximately
1,300 comments. Feedback received during regional workshops is not included in the total number ofsubmissions but, where relevant, a summary of significant issues raised during these consultations
has been presented alongside the significant issues raised through the public comment survey.

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Appendix 2 contains a breakdown of public comment submissions by stakeholder constituency,organization size, and region.

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Methodology for analyzing comments

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All comments submitted by respondents were collated by the Standards Division.

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Each comment was categorized according to its relevance to a specific Standard, section, disclosure
or a group of disclosures in the Universal Standards exposure draft, or as a cross-cutting theme. Eachcomment was then sub-categorized by the respondent’s:

93•

support for proposed content, based on its clarity, feasibility, and relevance to reporting;

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opposition to the proposed content, based on its clarity, feasibility, and relevance toreporting;

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concern about the proposed content, based on its clarity, feasibility, and relevance toreporting;98•

proposals for new content.

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When a respondent had raised several different points in one comment, the points were separated
into distinct comments.

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Comments that could not be adequately summarized or interpreted have been presented, where
relevant, verbatim inside quotation marks in this summary.

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The qualifiers indicated in Table 1 have been used to indicate the percentage of respondents thatprovided feedback on a significant issue. Given that the survey mostly contained open questions toenable respondents to provide feedback on sections of interest, not all respondents provided
comments on all sections of the exposure draft. Consequently, certain sections or disclosures have arelatively low number of comments compared to the overall number of respondents.

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Table 1. Qualifiers to describe the proportion of respondents.
QualifierRespondents

Majority

> 50%

Many

30-50%

Some

10-30%

A few

< 10%

One

1

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Significant issues and GSSB
responses

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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents, outlines proposed changes to the Universal Standards exposure draft, and explains thereasons why significant changes recommended by respondents were, or were not, accepted by the
GSSB.

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The significant issues identified have been organized into the following sections:

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116

•

Cross-cutting issues:

117oHuman rights

118oUniversal Standards structure

119•

Issues regarding the exposure draft of GRI 101: Using the GRI Standards, including:120oKey concepts in the GRI Standards

121oSustainability reporting using the GRI Standards

122oReporting principles

123•

Issues regarding the exposure draft of GRI 102: About the Organization, including:124oOrganizational details and reporting practices

125oOrganizational activities

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oGovernance127oResponsible business conduct

128oStakeholder engagement

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Issues regarding the exposure draft of GRI 103: Material Topics, including:130oIdentifying material topics

131oReporting on material topics

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This section includes references to the Universal Standards exposure draft, the current Universal
Standards 2016, and the revised Universal Standards 2021. When referring to the content in the
exposure draft, the titles used in the exposure draft are used. When referring to the content in thecurrent and revised Universal Standards, the titles of the Universal Standards 2016 and Universal
Standards 2021 respectively are used.

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Cross-cutting issues

138a) Human rights

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A few respondents expressed opposition to the inclusion of human rights in the definition of ‘material
topic’. These respondents stated that:

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‘human rights impacts’ are already covered by ‘impacts on people’;
it is not clear why the issue of human rights was highlighted, while other issues such as
climate were not;the definition may imply that human rights are more important than other topics related topeople, such as health and safety;
for many reporters, particularly those in developed countries where effective regulatory
frameworks exist, human rights are not a material issue.

One respondent disagreed with requiring reporting on human rights, stating that not all companies
have (material) issues with human rights.

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GSSB response: The reference to 'human rights impacts' has been maintained in the definition of'material topic', as well as the human rights-related disclosures, as human rights are the mostfundamental level of protection provided to people in authoritative intergovernmental instruments.
Impacts on human rights are a cross-cutting issue that have always occurred, and will continue tooccur in the future, thus making them one of the most vital types of impacts for the GRI Standards toaddress.

156b) Universal Standards structure

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Many respondents expressed support for the revised structure and submitted that the proposedchanges:

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are coherent and provide clarity;
will facilitate more consistent and streamlined reporting;are an improvement.

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GSSB response: No further changes have been made.

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GRI 101: Using the GRI Standards

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Section 2. Key concepts in the GRI Standards

165a) Impact

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A few respondents requested clarification on the concept of ‘impact’, including:

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the difference between inward and outward impacts;
the relationship between ‘risk’ and ‘impact’.

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GSSB response:

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The terms inward and outward impacts have been removed, but the meaning of these concepts has
been clarified. See section 1.2 Users and Box 1. Sustainability reporting and financial and value
creation reporting in GRI 1: Foundation 2021.

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The relationship between ‘risk’ and ‘impact’ has been clarified. See Section 1 in GRI 3: Material
Topics 2021.

175b) Material topic

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Many respondents expressed support for the revised concept of ‘material topic’. These respondents
stated that they welcome:

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the focus on outward impacts;
the alignment of this concept with authoritative intergovernmental instruments on businessand human rights and responsible business conduct;
the simpler and clearer approach, which will help to avoid the misinterpretation of thedefinition to mean ‘impact on the company’.

A few respondents suggested adopting a double materiality approach. These respondents stated that:••••the materiality definition should also explicitly consider financial materiality and the impacts on
the company;a double materiality approach will enable a holistic analysis of a reporting organization;a double materiality approach will improve the connectedness between financial and nonfinancial reporting;a double materiality approach is aligned with integrated thinking and integrated reporting.

A few respondents expressed disagreement with the revised concept of ‘material topic’. These
respondents proposed retaining the Materiality principle as stated in the current Universal Standards
2016 and suggested that removing 'substantively influences the assessments and decisions ofstakeholders' from the definition could lead to less engagement with stakeholders. They raised

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concern that this could lead to identification of material topics more heavily focused on theorganization’s interests than the stakeholders’ interests.

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A few respondents commented on the use of the materiality matrix included in the current Universal
Standards 2016. Respondents were divided on the usefulness of the matrix. Those opposed statedthat the matrix tends to encourage overly simplistic issue identification and may undermine
accountability and appropriate management controls for a given topic. Those in favor stated that a
visual presentation of material topics is a useful tool for understanding the relative importance of anorganization’s material topics and makes materiality more transparent, understandable andapplicable.

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GSSB response:

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The definition of ‘material topic’ proposed in the Universal Standards exposure draft has been
maintained.
The importance and role of stakeholder engagement in identifying an organization’s mostsignificant impacts has been clarified more prominently. See section 2 in GRI 1: Foundation
2021.
The relationship between sustainability reporting and financial reporting has been clarified byexplaining how the information derived from sustainability reporting forms a key input for
financial risk assessment and for financial reporting. See Box 1. Sustainability reporting andfinancial and value creation reporting in GRI 1: Foundation 2021.
The materiality matrix has not been reinstated, as the revised concept of ‘material topic’ nolonger encompasses two dimensions. The GSSB will consider developing further guidance onmateriality for reporting organizations in a format such as a website FAQ, which could also
include suggestions for visuals. This may include options for visual representations of therevised GRI concept of materiality and its connection to double materiality.

218c) Due diligence

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Two respondents raised concerns about the feasibility of meeting the expectations of due diligence by
new reporters and suggested removing the concept from the GRI Standards.

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GSSB response: Due diligence has been retained as a key concept, in line with expectations in theauthoritative intergovernmental instruments with which the GRI Standards seek to align.

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d) Stakeholder

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Some respondents expressed support for the revised concept of ‘stakeholder’. These respondents:

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welcomed the alignment of the definition with the OECD;
welcomed the clarity of the proposed definition;
welcomed the consistency with the approach to materiality focused on outward impacts;
noted that the proposed definition addresses the shortcoming of the current definition, which
creates an incentive for organizations to pick and choose stakeholders that suit theorganizations’ own views.

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A few respondents expressed disagreement with the revised concept of ‘stakeholder’ and suggested
the definition should encompass those that ‘affect the organization’ as well as those that ‘are affectedby the organization’ (in line with the definition in the current Universal Standards 2016).

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Two respondents suggested clarifying the relationship between ‘stakeholders’ and ‘rightsholders’ andbetween ‘interests’ and ‘rights’.

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GSSB response: The definition of ‘stakeholder’ proposed in the Universal Standards exposure draft
has been maintained. The relationship between ‘stakeholders’ and ‘rightsholders’, and between‘interests’ and ‘rights’ has been clarified. See section 2.4 Stakeholder in GRI 1: Foundation 2021.

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Section 3. Sustainability reporting using the GRI Standards

241a) Revised approaches to using the GRI Standards for sustainability reporting

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Some respondents expressed support for the proposal to allow two approaches for using the GRI
Standards: reporting in accordance with the GRI Standards and reporting with reference to the GRI
Standards. These respondents stated that this proposal will:

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provide clarity and increase transparency about how the GRI Standards are used;make it easier to understand the level of adherence to the GRI Standards;
improve the quality and consistency of reporting;
set a higher standard for reporting, by driving reporting in accordance with the GRI Standards.

A few respondents raised concerns about the proposal to allow two approaches for using the GRI
Standards. These respondents stated that the two approaches can:••••create quality distinctions between reporting organizations, similar to the ‘Core’ and‘Comprehensive’ in accordance options;
make the ‘in accordance with’ approach unattainable and thereby drive organizations to report‘with reference to’ and discourage from considering sustainability reporting as a path ofprogressive improvement;
entice organizations to use the ‘with reference to’ approach to report on issues that are
favorable to an organization, but avoid reporting on challenges, risks and failures;
be misunderstood by stakeholders who are not familiar with the GRI Standards.

Some respondents expressed support for having one option to report in accordance with the GRI
Standards. These respondents stated that:••••the ‘Core’ and ‘Comprehensive’ options are not effectively used;the value of the ‘Comprehensive’ option is not clear, it is not widely used and did not evolve
as a differentiator from the ‘Core’ option;
this will remove the perception that organizations using the ‘Comprehensive’ option are‘better’ than organizations using the ‘Core’ option;
this will facilitate understanding of a reporter’s application of the GRI Standards – a reporter iseither in accordance with the GRI Standards or not.

Some respondents raised concerns about having one option to report in accordance with the GRI
Standards. These respondents stated that:
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many organizations use the ‘Core’ option, and reasons behind the application of the ‘Core’
option and the barriers to transition to the ‘Comprehensive’ option need to be better
understood;the ‘Core’ and ‘Comprehensive’ options enable organizations to evolve their reporting overtime;
it will be challenging to comply with all (additional) requirements, especially for ‘Core’reporters and SMEs;
it will be difficult to report all disclosures in GRI 102: About the Organization and GRI 103:
Material Topics if reasons for omission are not permitted, especially the governancedisclosures;
meeting the revised in accordance level is only possible with sufficient transition andimplementation time.

Some respondents raised individual points. These respondents did not clearly express support ordisagreement with the revisions, nor did they raise concerns. For example, these respondents stated
that:
•
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organizations that are less mature and start their reporting journey reporting with reference to
the GRI Standards should transition to reporting in accordance with the GRI Standards overtime;
it is important to make clear that reporting with reference to the GRI Standards has
significantly less requirements than reporting in accordance with the GRI Standards.

GSSB response: The two approaches to using the GRI Standards proposed in the Universal
Standards exposure draft have been maintained. An organization can report in accordance with thePage 8 of 23

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GRI Standards, or with reference to the GRI Standards. Reporting with reference to the GRI
Standards can be used when an organization wants to report information about specific topics for
specific purposes (e.g., to comply with a reporting regulation on climate change) or when an
organization is unable to comply with all requirements for reporting in accordance with the GRI
Standards.

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The focus of ‘Section 3. Sustainability reporting using the GRI Standards’ in the exposure draft has
been changed. This section now presents ‘in accordance’ as the recommended approach forreporting with the GRI Standards, by outlining the ‘in accordance’ requirements before therequirements for reporting with reference to the GRI Standards. In addition, the reference to Approach
A and Approach B has been removed, to emphasize ‘in accordance’ as the default approach toreporting with the GRI Standards. See section 3. Reporting in accordance with the GRI Standards in
GRI 1: Foundation 2021.

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A recommendation has been added that organizations that cannot comply with all the ‘in accordance’
requirements should transition to reporting in accordance with the GRI Standards over time. See‘Reporting with reference to the GRI Standards’ at the end of section 3 in GRI 1: Foundation 2021.

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The one option for reporting in accordance with the GRI Standards proposed in the exposure draft
has been maintained, but the mechanism to use reasons for omission has been revised. Reasons foromission are now permitted for all disclosures in GRI 2: General Disclosures 2021 and GRI 3:
Material Topics 2021 except for:

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Disclosure 2-1 Organizational details
Disclosure 2-2 Entities included in the organization’s sustainability reporting
Disclosure 2-3 Reporting period, frequency and contact point
Disclosure 2-4 Restatements of information
Disclosure 2-5 External assurance
Disclosure 3-1 Process to determine material topics
Disclosure 3-2 List of material topics

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These seven disclosures are considered critical for an organization’s sustainability reporting.

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See Requirement 6: Provide reasons for omission for disclosures and requirements that theorganization cannot comply with in GRI 1: Foundation 2021.

321b) Appropriate disclosures

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A few respondents commented on the revised requirement to report appropriate disclosures from the
GRI Topic Standards. These respondents raised concerns or requested clarification about themeaning of ‘appropriate disclosures’, and stated that:

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the explanation of ‘appropriate disclosures’ in the Universal Standards exposure draft was not
sufficient for organizations to properly understand the concept and how to use it;
the explanation creates an opportunity to ‘pick and choose’ what to report and to report less;an organization’s judgement of what is appropriate may be subjective or not sufficiently
transparent and will present a challenge for verification by assurance providers and other third
parties;
ultimately, it can lead to large variations in reported information, and compromise
comparability of information.

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GSSB response: The concept of ‘appropriate disclosures’ proposed in the exposure draft has beenrevised. In the exposure draft, appropriate disclosures were defined as ‘disclosures that adequately
capture the impacts related to the organization’s material topics’. In the revised Universal Standards,
the disclosures from the GRI Topic Standards required to be reported for each material topic are now
defined as ‘those disclosures that are relevant for reporting information about the organization’s
impacts in relation to a material topic’.

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A requirement has been added for the organization to explain why Topic Standards disclosures listed
for the organization’s material topics in applicable GRI Sector Standards, where they are available,
are not relevant to the organization’s impacts. Such an explanation helps confirm that the disclosures
are not relevant to the organization’s impacts, and why.

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It has been clarified that there is no requirement for a minimum number of disclosures to report fromthe Topic Standards, and that the number of disclosures to report is based on the organization’s
assessment of which disclosures are relevant to its impacts in relation to a material topic.

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See guidance to Requirement 5-a and see Requirement 5-b in GRI 1: Foundation 2021.

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c) Using Sector Standards to identify and explain if topics listed in a Sector Standard are notdeemed material by the organization

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The majority of respondents expressed support for the proposal to identify and explain if topics listed
in an applicable Sector Standard are not deemed material by the organization. These respondents
stated that such an explanation would:
•

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In addition, these respondents suggested that the reporting expectation about the format of the
explanation be clarified and submitted that:
•

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reporting burden must be considered when setting the expectation about the extent of
information to report and a brief explanation about why a topic is not deemed material should
be sufficient;
it is not clear whether an organization would need to provide an explanation for each topic
that is not deemed material, or to provide one explanation covering all topics that are notdeemed material;
the evaluation of what is deemed not material can be subjective;the explanation needs to be easily locatable in the report / reported information.

•••

Some respondents raised concerns about the proposal to identify and explain if topics listed in an
applicable Sector Standard are not deemed material by the organization. These respondents statedthat such reporting would:
•

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be reasonable, given that Sector Standards represent consensus on what is consideredmaterial for a sector and set an industry benchmark, developed through a rigorous standardsetting activity;
ensure credibility of the materiality assessment process, as well as strengthen the overall
reporting process and performance of the organization;
provide transparency and confidence to stakeholders that material topics and significant
impacts have not been avoided or overlooked and that all material topics have been
considered, even if not all have been addressed;
provide additional context for information users to better evaluate an organization’s
performance in relation to its impacts, compare the performance between companies, andengage in a subsequent dialogue.

•
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•

be unnecessary because material topics that a company reports on are the result of, and are
justified by, the materiality assessment process, and the exposure draft already includes arequirement to use the Sector Standards when identifying material topics;
add to the subjectivity of responses and compromise clarity of reported information;
add to the reporting burden and length of reports, especially for companies operating acrossseveral sectors;
divert focus, time, and resources from addressing material issues / contradict GRI’s
approach to focus on material topics;
risk substituting an organization’s materiality assessment process.

In addition, a few respondents responded “I don’t know” to the question about identifying andexplaining if topics listed in an applicable Sector Standard are not deemed material by theorganization. They submitted that:•••such reporting has the potential to strengthen the materiality assessment process but might
divert time and resources from managing the impacts;
such reporting has the potential to strengthen the materiality assessment process but
presents a risk of substituting a robust materiality assessment process;the feasibility of such reporting depends on the scope and rigor of Sector Standards and thenumber of topics that are deemed not material by the organization.

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GSSB response: Requirement 3-b in GRI 1: Foundation 2021 has been revised to require theorganization to determine whether each topic in the applicable GRI Sector Standards is a material
topic for the organization. It also requires the organization to list in the GRI content index any topics
from the applicable Sector Standards that the organization has determined as not material, and to
explain why they are not material.

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An example table and guidance about how to prepare the GRI content index have been added,
including how to indicate when a topic listed in a Sector Standard has been determined as notmaterial.

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403d) Identifying and explaining if topics commonly associated with sectors are not material
when Sector Standards do not exist

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Many respondents raised concerns about the proposal to identify and explain if topics commonly
associated with the organization’s sector are deemed not material in the absence of an applicable
Sector Standard. These respondents stated that such reporting:

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is subject to the materiality assessment;
increases the reporting burden and length of reporting;diverts attention from managing material topics.

Many respondents opposed this proposal while they supported the proposal to explain when a topic isdeemed not material when a Sector Standard is available, and submitted that:•the concept of a topic being ‘commonly associated’ is too subjective to form the basis for arequirement and lends itself to interpretation and conflicts of interest;
such reporting would compromise the purpose of the Sector Standards which are meant toserve as an industry benchmark.

•

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Many respondents expressed support for the proposal to identify and explain if topics commonly
associated with the organization’s sector are deemed not material in the absence of an applicable
Sector Standard. These respondents stated that such reporting will improve transparency,
comparability and clarity of information, and the credibility of the materiality assessment process.

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A few respondents supported this proposal as a good approach to risk management, while they
opposed the proposal to explain why a topic is deemed not material when the Sector Standard isavailable.

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A few respondents responded “I don’t know” to the proposal of identifying and explaining if topics
commonly associated with the organization’s sector are not deemed material in the absence of an
applicable Sector Standard. Seven respondents explained that if Sector Standards are meant to set
an industry benchmark, in their absence such reporting would be subjective.

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GSSB response: A recommendation has been added to the guidance for Disclosure 3-1 (Process todetermine material topics) in GRI 3: Material Topics 2021 clarifying that, in the absence of applicable
Sector Standards, the organization should explain how it has considered impacts commonly
associated with its sectors, and whether any of these impacts have been determined as not material,
together with an explanation of why this is the case.

432e) Statement of use

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A majority of respondents expressed support for requiring a statement of use acknowledging thehighest governance body’s or most senior executive’s responsibility for preparing the reported
information in accordance with, or with reference to, the GRI Standards. These respondents statedthat it will:

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439
440
441
442
443

•
•
•
•
•
•

provide transparency and promote accountability and effective governance of sustainability
reporting and the application of the GRI Standards;
raise awareness of sustainability at the top level and across the organization;
improve the credibility, quality, clarity, and comparability of reported information;
attract resources and support to the reporting process;align with the approach used in financial reporting;respond to regulatory expectations about sustainability reporting.

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444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474

A majority of the respondents further expressed support for the highest governance body toacknowledge the quality and veracity of reported information in the statement. These respondents
stated that this will:•••

increase accountability of the highest governance body for managing impacts and forsustainability reporting;
improve the quality of reporting;increase the need for external assurance.

Some respondents raised concerns about the proposal to provide a statement of use. These
respondents stated that providing such a statement:
•
•
•
•
•
•

would require a practitioner’s level understanding of the GRI Standards to make it, which is
not consistent with the highest governance body’s general oversight role;is not a guarantee for the credibility or quality of the reported information;is redundant as the highest governance body’s responsibility for, and sign-off on, thesustainability report is implied;
will add to the reporting burden and costs of reporting;will compromise the utility of the GRI Standards as a tool for the highest governance body tounderstand and address the organization’s impacts;
will drive reporters to report ‘with reference to’ the GRI Standards.

Some respondents raised further concerns about the highest governance body acknowledging thequality and veracity of reported information in the statement of use. These respondents stated thatproviding such a statement would:•••

create an obligation of external assurance which would increase the costs of reporting;
be redundant because reporting in accordance with the GRI Standards requires applying the
GRI reporting principles which cover report quality principles;
present a legal liability to the highest governance body.

A few respondents made suggestions about how to amend the formulation of the statement of use toacknowledge the quality and veracity of reported information. These suggestions included:•••

verbatim acknowledgement of the quality and veracity of reported information;verbatim acknowledgement of the opinion about the extent to which the information iscomplete and accurate;
verbatim acknowledgement that the GRI reporting principles have been followed.

475
476
477
478
479

GSSB response: Reference to the highest governance body and senior executives’ acknowledgementof responsibility for the level of application of the GRI Standards has been removed from thestatement of use. The statement of use is to be issued by the organization, and it is to specify whether
the reported information has been prepared in accordance with, or with reference to, the GRI
Standards.

480
481
482

Guidance has been added to clarify that to issue the statement of use, the organization must comply
with the corresponding requirements for reporting in accordance with the GRI Standards or withreference to the GRI Standards.

483
484
485
486
487
488

Disclosure 2-14 in GRI 2: General Disclosures 2021 (Role of the highest governance body insustainability reporting) has been revised to clarify the responsibility of the highest governance bodywith respect to reviewing and approving the reported information, including the organization’s material
topics. A new requirement has been added to Disclosure 2-14 for the organization to explain thereason for the highest governance body not being responsible for reviewing and approving thereported information, in situations where this is the case.

489
490
491
492

No further requirements have been added to acknowledge the quality and veracity of reported
information, as this would be redundant with Requirement 1 in GRI 1: Foundation 2021 to apply thereporting principles and with Disclosure 2-5 in GRI 2: General Disclosures 2021 on the organization’s
approach to external assurance.

493

See Requirement 8 in GRI 1: Foundation 2021.

Page 12 of 23

494

Section 4. Reporting principles

495a) General feedback

496

Some respondents commented on the reporting principles. These respondents:

497
498
499
500
501
502

•
•
•

acknowledged the lack of description of the relationship between the key concepts and thereporting principles and their roles in the system and function of reporting;suggested retaining the reporting principles for defining report content, instead of presenting‘material topic’ and ‘stakeholder’ as key concepts;
made one-off comments about the Accuracy, Comparability, Completeness, and Verifiability
reporting principles.

503
504
505

GSSB response: The introductions have been revised to clarify the function of the key concepts andof the reporting principles. Wording has been amended in reporting principles Accuracy,
Comparability, Completeness, and Verifiability based on public comment suggestions.

506

See section 2. Key concepts and section 4. Reporting principles in GRI 1: Foundation 2021.

507
508

b) Sustainability context principle

509
510

Five respondents commented on the Sustainability context principle, including one respondent who
submitted their comments on behalf of 19 individuals. These respondents:

511
512
513
514
515
516
517
518
519

•
•

expressed support for the retention of the Sustainability context principle;
suggested retaining the performance-based description of the principle and adding guidance
about how to apply the principle, based on considerations of:o integrating stakeholder perspectives;o impacts on natural, human, social, and constructed (or built) capital stocks;
o fair and proportionate allocations of carrying capacities of natural stocks or of sharedor exclusive burden to produce and/or maintain anthropogenic capitals to individualorganizations;o context-based metrics.

520
521
522
523
524
525

GSSB response: Wording in the guidance to the Sustainability context principle has been amended toclarify that an organization must assess its impacts in the wider context of sustainable development,
including in relation to consensus on the limits and demands placed on environmental resources,
sustainable development goals and conditions, societal expectations and expectations of responsible
business conduct set out in authoritative intergovernmental instruments, and in relation to appropriate
local contexts. See Sustainability context principle in GRI 1: Foundation 2021.

526
527

No further change has been made to the guidance of the Sustainability context principle, using thefollowing rationale:

528
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
544
545
546

•

•
•

•

Stakeholder perspectives and stakeholder engagement are foundational concepts andrequirements in the GRI Standards. See the key concepts of ‘impact’, ‘material topic’, and‘stakeholder’ in section 2 of GRI 1: Foundation 2021, Disclosures 2-29 and 2-30, andrequirements 2-12-b-i, 2-20-a-i, and 2-20-b in GRI 2: General Disclosures 2021, andrequirements 3-1-b and 3-3-f in GRI 3: Material Topics 2021 respectively.
Impacts on the economy, environment, and people, including impacts on their human rights,
is the foundational concept in the GRI Standards. See the key concepts of ‘impact’ and‘material topics’ in section 2 of GRI 1: Foundation 2021.
The GRI Standards do not set allocations, goals, targets, thresholds, or any otherbenchmarks for good or bad performance. The GRI Standards contain references to, anddisclosures based on, expectations for responsible business conduct set out in authoritativeintergovernmental instruments. The GRI Standards enable organizations to report informationthat can help information users make assessments about the organization’s impacts on theeconomy, environment, and people, and thus how the organization contributes to sustainable
development and meets the expectations set out in authoritative intergovernmental
instruments.
The GRI Standards include quantitative context-based metrics, where such metrics havebeen proposed by project working groups or technical committees based on expert
consensus on the feasibility of such metrics. Where quantitative context-based metrics do not

Page 13 of 23

547
548
549

exist, organizations are required to report on their impacts in the absolute to enable
information users to assess these impacts in relation to the organization’s size and global andlocal conditions of operations.

550

GRI 102: About the Organization

551

Section 2. Organizational details and reporting practices

552a) Clarifications requested, editorial changes and new content proposed

553
554
555

Some respondents provided feedback on the disclosures about organizational details and reporting
practices. These respondents requested clarifications, and suggested additional contents or editorialchanges, including to:

556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579

•
•
•
•
•
•

clarify the term ‘significant operations’ in REP-1;
clarify the term ‘consolidated groups’ in REP-2;
introduce a requirement to report the publication date of reported information;
retain the contact point for questions regarding the reported information (Disclosure 102-53 in
GRI 102: General Disclosures 2016);
introduce a requirement to report criteria for making restatements in REP-4;
clarify reporting expectations on external assurance in REP-5 (i.e., how to report what is notassured and the relationship with assurance providers).

GSSB response:
•
•
•
•
•

The term ‘significant’ has been removed in requirement 2-1-d (REP-1-d) and the reporting
expectation in the guidance has been clarified. See Disclosure 2-1 in GRI 2: General
Disclosures 2021.
The term ‘consolidated group’ has been deleted in requirement 2-2-c (REP-2-c) to avoid
confusion with its use in other financial instruments. See Disclosure 2-2 in GRI 2: General
Disclosures 2021.
A requirement has been added to specify the publication date of the report and therequirement to specify the contact point for questions regarding the reported information has
been retained. See Disclosure 2-3 in GRI 2: General Disclosures 2021.
A recommendation has been added in the guidance to Disclosure 2-4 (REP-4) to report thecriteria used by an organization to determine when to issue a restatement. See Disclosure 2-4
in GRI 2: General Disclosures 2021.
The reference to ‘what has not been assured’ has been removed from requirement 2-5-b-ii(REP-5-b-ii) and guidance has been added to clarify the meaning of the ‘relationship withassurance providers’. See Disclosure 2-5 in GRI 2: General Disclosures 2021.

580

Section 3. Organizational activities

581a) ACT-2 Employees and other workers

582
583

Five respondents raised concerns about the feasibility of reporting information on workers who are not
employees and stated that:

584
585
586
587
588
589

•
•
•
•

this information will be challenging to compile for large corporations operating in different
businesses and regions;
it will be challenging to measure fluctuations in the number of employees and the number ofworkers who are not employees;
the term ‘significant fluctuations’ needs to be clarified;
the term ‘workers’ needs to be clarified.

590
591

One respondent suggested adding a new disclosure on rightsholder mapping, identifying people andcommunities affected or potentially affected by company operations and supply chains.

592

GSSB response:

Page 14 of 23

593
594
595
596
597
598
599
600
601
602
603
604
605
606
607

•

•
•
•

The requirements for reporting in accordance with the GRI Standards have been revised topermit the use of reasons for omissions for disclosures which are subject to confidentiality
concerns, legal prohibitions, which do not apply to the organization, or where information isincomplete or unavailable. This includes Disclosure 2-8 in GRI 2: General Disclosures 2021
on workers who are not employees. See Requirement 6 in GRI 1: Foundation 2021.
Guidance has been added clarifying the reporting expectation for reporting significant
fluctuations, see guidance to the requirements 2-7-e and 2-8-c in GRI 2: General Disclosures
2021.
Guidance has been added to clarify the scope of workers who are not employees and whose
work is controlled by the organization. See guidance to requirement 2-8-a in GRI 2: General
Disclosures 2021.
A new disclosure on rightsholder mapping has not been added, as Disclosure 2-29 in GRI 2:
General Disclosures 2021 already requires a list of the categories of stakeholders theorganization engages with, which would include those whose human rights are affected or
potentially affected by the organization.

608

Section 4. Governance609a) Reporting feasibility and reporting burden

610
611

Some respondents raised concerns about reporting feasibility and reporting burden of the disclosures
on governance. These respondents submitted that:

612
613
614
615
616
617
618
619
620

•
•
•
•
•
•

region-specific legislation may prevent disclosure of certain elements or differ from practices
suggested in the GRI Standards;
required information might be sensitive or confidential;
reporting may be challenging for SMEs or put them at a competitive disadvantage whendisclosing that governance roles, practices and policies do not exist;
required information is repetitive of annual financial or other statutory reporting;some of the governance disclosures overlap;
the relevance of the disclosures to sustainable development is unclear.

GSSB response:

621
622
623
624
625
626
627
628
629
630
631
632
633
634

•

635

See section 3. Governance in GRI 2: General Disclosures 2021.

•••

The reporting model has been revised to permit the use of reasons for omissions fordisclosures which are subject to confidentiality concerns, legal prohibitions, which do not
apply to the organization, or where information is incomplete or unavailable. See Requirement
6 in GRI 1: Foundation 2021.
Disclosures have been consolidated where appropriate.
It has been clarified in the introduction to every Standard, and in the introduction to theGovernance section, that if the organization intends to publish a standalone sustainability
report, it does not need to repeat information that it has already reported publicly elsewhere,
such as on web pages or in its annual report. In such a case, the organization can report on arequired disclosure by providing a reference in the GRI content index as to where thisinformation can be found (e.g., by providing a link to the web page or citing the page in theannual report where the information has been published).
The purpose of reporting these disclosures has been clarified in the introduction to theGovernance section.

636b) Clarifications requested, editorial changes and new content proposed

637
638

Some respondents requested clarifications and suggested editorial changes or new content in thegovernance section, including to:

639
640
641
642
643
644

•
•
•

clarify the terms ‘under-represented groups’, ‘significant positions’, ‘stakeholder
representation’, ‘internal resources’, and ‘critical concerns’;
expand diversity criteria beyond ‘gender’ when reporting on the composition of the highest
governance body;require reporting the frequency of engagement between the highest governance body andstakeholders;

Page 15 of 23

645
646
647
648
649
650
651
652
653

•

revisit the methodology for calculating the annual total compensation ratio for a moremeaningful and feasible approach.

GSSB response:•••

The terms have been clarified as per the public comments.
A recommendation has been added to report on the frequency of stakeholder consultation
with the highest governance body. See guidance to requirement 2-12-b-i in GRI 2: General
Disclosures 2021.
The methodology to report the annual total compensation ratio has been revised. See
Disclosure 2-21 (Annual total compensation ratio) in GRI 2: General Disclosures 2021.

654

Section 5. Responsible business conduct655a) Reporting feasibility and reporting burden

656
657

A few respondents raised concerns about reporting feasibility and reporting burden. These
respondents submitted that:

658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
677
678
679

•
•

required information in Disclosures RBC-2, RBC-3 and RBC-4 could increase reporting
burden for companies that already describe their policies in other sources;
disclosing grievances in Disclosure RBC-4 is sensitive information.

GSSB response:
•
•

•

•

The requirement to report ‘the date of approval’ of the policy commitments has been moved to
the guidance section. See guidance to requirement 2-23-d in GRI 2: General Disclosures
2021.
All other requirements in Disclosures 2-23 (RBC-2), 2-24 (RBC-3), and 2-25 (RBC-4) in GRI
2: General Disclosures 2021 have been maintained, as the information requested is relevant
and in line with authoritative intergovernmental instruments that organizations are expected tocomply with, and it is often underreported.
No change has been made with respect to Disclosure 2-25 (RBC-4) in GRI 2: General
Disclosures 2021, as the disclosure does not require information on the number of grievances
received or the nature of the grievances, but to report the approach to identify and address
grievances.
It has been clarified in the introduction to every Standard that if the organization intends topublish a standalone sustainability report, it does not need to repeat information that it has
already reported publicly elsewhere, such as on web pages or in its annual report. In such acase, the organization can report on a required disclosure by providing a reference in the GRI
content index as to where this information can be found (e.g., by providing a link to the web
page or citing the page in the annual report where the information has been published). See‘Using this Standard’ in the introduction section of GRI 2: General Disclosures 2021.

680b) Clarifications requested and new content proposed

681
682

Some respondents proposed adding new requirements about responsible business conduct, including
requirements related to:

683
684
685
686
687
688
689
690
691
692
693
694
695

•
•
•
•
•
•
•
•

the policy commitments related to climate, including commitments made in line with the Paris
Agreement;
the policy commitments related to anti-corruption and political lobbyism;
the policy commitments that contribute to sustainable development in the areas closest to theorganization’s business activities;
how the organization considers and uses the precautionary principle and where there havebeen incidents or impacts from its incomplete or ineffective implementation;
the means through which the organization communicates the policy commitments, and how it
identifies and removes potential barriers to communication;
how external inputs are reflected in the policy commitments;
specific targets, milestones and contribution to the Sustainable Development Goals that relate
to the organization’s policy commitments;
procurement or investment policies and practices;

Page 16 of 23

696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723

•
•
•
•
•
•

how the organization ensures compliance with the policy commitments across functions andgeographies;
whether the staff that cover human rights have formal training in human rights;
how the organization has defined ‘caused’, ‘contributed’ and ‘directly linked’;“ethical communications side” to evaluate effectiveness of responsible business conduct
measures;how the board oversees the mechanisms covered in Disclosure RBC-5 and addresses theireffectiveness, and whether these mechanisms are audited by internal and/or external parties;
the nature of the concerns raised through the mechanisms covered in Disclosure RBC-5.

A few respondents suggested to clarify:•••

whether broader trends include social trends in the guidance to Disclosure RBC-1;
whether Disclosure RBC-4 covers negative impacts related to human rights or negative
impacts overall;
the difference between ‘grievance mechanisms’ and ‘other remediation processes’ inDisclosure RBC-4.

GSSB response:
•
•
•
•
•

Proposed additional requirements have not been added, based on public feedback concerns
about reporting feasibility or sensitivity, or due to overlap of proposed content withrequirements in other sections or existing Standards.
Some of the additional points have been included as suggestions in the respective guidance
sections.
The guidance to Disclosure 2-22 (RBC-1) in GRI 2: General Disclosures 2021 has beenclarified to indicate that broader trends include social trends.
The scope of Disclosure 2-25 (RBC-4) in GRI 2: General Disclosures 2021 has been clarified
in the guidance section, to make clear that it covers actual and negative impacts on
stakeholders, including impacts on their human rights.
Disclosure 2-25 (RBC-4) in GRI 2: General Disclosures 2021 has been revised to make clear
the difference between ‘grievance mechanisms’ and ‘other remediation processes’.

724c) RBC-6 Compliance with laws and regulations

725
726

A few respondents raised concerns, requested clarifications or proposed changes for Disclosure
RBC-6. These respondents stated that:

727
728
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746

•

•
•
•
•

‘significant fine’ is not a good proxy for impact because thresholds that define ‘significance’
vary and may be influenced by the size of the organization, and because monetarysignificance does not equal significant impact;
it is unclear whether to report all instances of non-compliance for which non-monetary
sanctions are incurred or ‘significant’ instances;
it is unclear whether ‘incurred’ refers to fines levied or paid and suggested to separate thedisclosure to differentiate between the two;
it is unclear how to report recurring fines which is an important matter for assurance;
reporting the nature of each instance of non-compliance may not be feasible for large
companies where many instances occur, and it may be subject to “legal privilege” in someterritories.

GSSB response:••••

The disclosure has been revised to focus on significant instances rather than significant fines
and a requirement has been added to report how significant instances were determined.
The requirements have been separated to distinguish between fines levied and fines paid.
The expectation for reporting whether the fines are recurring has been clarified in theguidance.
The expectation for reporting the nature of instances of non-compliance has been clarified in
the guidance.

See Disclosure 2-27 in GRI 2: General Disclosures 2021.

Page 17 of 23

747

Section 6. Stakeholder engagement

748a) SE-1 Approach to stakeholder engagement749

A few respondents requested clarifications or proposed new content for Disclosure SE-1, including to:

750
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
766

•
•
•
•
•
•

report the outcome of the engagement and what decisions were made or influenced as aresult;report the type and frequency of engagement with each category of stakeholder;
report whether the engagement resulted in identifying actual and potential negative impacts,
or in determining prevention and mitigation responses to potential negative impacts;
report on Free, Prior and Informed Consent (FPIC);
clarify the difference between engagement and consultation;
add ‘rightsholder’ terminology where appropriate.

GSSB response:•••

The relationship between ‘stakeholders’ and ‘rightsholders’, and between ‘interests’ and‘rights’ has been clarified, but the term ‘rightsholder’ has not been used elsewhere in theStandards as every person is a rightsholder. The GRI Standards use the term ‘stakeholder’
instead. See section 2.4 Stakeholder in GRI 1: Foundation 2021.
No additional requirements have been added due to concerns of reporting feasibility or due tothe fact that other GRI disclosures already require information on stakeholder engagement.
Adding requirements to report on Free, Prior and Informed Consent (FPIC) has been deferred
for consideration during revisions of the GRI Topic Standards.

767

GRI 103: Material Topics

768

Section 2. Identifying material topics

769a) General feedback

770

Some respondents expressed support for the guidance to identify material topics, and stated that it:

771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787

•
•
•
•

supports the move from stakeholder-led materiality assessments to using a broader, richer
evidence base;reflects current best practice, which combines stakeholder input with market and operational
context, national and international trends, expert views, etc., and removes the risk of skewing
the materiality assessment by choosing a narrow set of external stakeholders;highlights the important distinction between an ‘organization’s ongoing identification andassessment of impacts as part of its regular activities in order to manage its impacts’ and the‘identification of material topics for reporting’;aligns with the United Nations (UN) Guiding Principles on Business and Human Rights andthe Organisation for Economic Co-operation and Development (OECD) Due Diligence
Guidance for Responsible Business Conduct.

A few respondents, including those that expressed support for the guidance on identifying material
topics, raised concerns about feasibility and stated that:••while the changes are welcome and will enable better reporting of impact, they will create
challenge and confusion;
identifying impacts, especially negative ones, is challenging, and determining the significanceof impacts is a subjective exercise and can be hard to evaluate accurately.

788
789
790
791

A few respondents requested further guidance or clarification on identifying impacts, determining
which business entities and relationships to include in the assessment, assessing significance,
defining types of involvement with negative impacts (causing, contributing, directly linked), grouping
impacts into topics, and setting a threshold.

792
793

Two respondents disagreed with the approach to prioritizing human rights impacts based on severity,
stating that it makes the approach inconsistent and could risk including irrelevant information inPage 18 of 23

794
795
796

reporting. Yet another respondent stated that doing so is challenging. Two respondents suggested
that prioritizing impacts based on severity should also apply to the topics of climate change and healthand safety.

797

Respondents also submitted that:

798
799
800
801
802
803
804
805
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820

•
•

•
•

the proposal that only experts are consulted during Step 4 (Prioritize the most significant
impacts for reporting) is not adequate, as experts could be biased by the organization itself,
and the organization could manipulate the experts to get what it wants;
it is not acceptable that an organization is the sole decision-maker in identifying potential andactual impacts. The proposed approach is putting the responsibility on the reportingorganization to determine the materiality to the stakeholders. This bears the risk of greenwashing and that companies self-censor topics that are material to their stakeholders;the identification of relevant stakeholders should be a step of the process;the process should be required, rather than recommended.

GSSB response:•••

The importance and role of stakeholder engagement in the process to identify anorganization’s most significant impacts has been clarified in section 2 of GRI 1: Foundation
2021, and a new step has been included for organizations to identify relevant stakeholders in
section 1 of GRI 3: Material Topics 2021.
Additional guidance and clarification have been provided where possible, such as about thesources organizations can use to identify impacts and how to set a threshold for determining
which topics are material, in section 1 of GRI 3: Material Topics 2021. However, it should be
noted that the GRI Standards are not an impact identification and assessment methodology
and, thus, organizations need to refer to other existing methodologies for this purpose.
The approach to prioritizing human rights impacts based on severity has been maintained, inline with the United Nations (UN) Guiding Principles on Business and Human Rights. It has
been clarified in section 1 of GRI 3: Material Topics 2021 that an organization may alsochoose to prioritize other impacts, e.g., environmental impacts, based on severity alone.

821

Section 3. Reporting on material topics

822a) Topic Boundary

823
824

A few respondents commented on the revisions to the concept of ‘Topic Boundary’. These
respondents stated that:

825
826
827
828
829

•
•

the removal of the term ‘Topic Boundary’ and the revised concept is welcome, as it hascaused much confusion over the years;
the concept should be retained as an essential concept for an organization’s value chain,
which helps it understand the scope of its impacts. For example, a material topic like water
stress can be significant, but within a very specific (organizational) boundary.

830
831
832
833
834

Four other respondents did not comment on the concept of ‘Topic Boundary’ but suggested it isimportant for organizations to consider and distinguish in their reporting between topics that are of
relevance throughout a company, and topics that are context specific (e.g., whether a material topic is
considered a group-wide issue, or whether it is a concern only in select countries of operation or inconnection with select products or business segments).

835
836
837
838
839
840
841

GSSB response: Requirement MT-2-b-ii in the Universal Standards exposure draft (to report whether
the organization is involved with the negative impacts through its own activities or as a result of its
business relationships) has been expanded to require a description of the activities or business
relationships, and additional guidance has been developed. This will allow organizations to report
whether a material topic is considered a group-wide issue or is a focalized issue (e.g., in certain
countries, sites, business relationships). See requirement 3-3-b and corresponding guidance in GRI 3:
Material Topics 2021.

842b) Concerns raised, clarifications requested and new content proposed

843
844

Some respondents raised concerns or requested clarifications about Disclosures MT-1, MT-2, andMT-3, including to:Page 19 of 23

845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
864
865
866
867

•
•
•
•
•

clarify if the organization has to explain what significance means to the organization based on
severity and likelihood;clarify if the organization has to specify which type of impact it is (e.g., negative, positive,
actual, potential);
require reporting only the most relevant or significant impacts identified for each material
topic, as reporting all impacts can be extremely cumbersome for certain large organizations;limit the scope of reporting on the effectiveness of the actions taken, as the requirement iscurrently very demanding;revise Disclosure MT-3, as it seems to focus solely on negative impacts, and readers ofreports are also interested in positive impacts and how reporting organizations act to magnify
them.

These respondents have also proposed to add new requirements, including:
•
•
•
•
•
•
•
•
•

how stakeholders have been engaged in the process to determine material topics;
evidence and sources of data that have informed the process to determine material topics;
the time horizon (short, medium, long term) considered in the impact analysis;
the threshold and criteria used when determining material topics;
any changes to the selection of material topics after testing these priorities with external
parties;changes in the material topics occurring within the reporting period;
the time frames of the positive impacts and measures being taken to ensure that the positive
impacts continue on an ongoing basis;
how the organization uses root cause analysis;an analysis of crucial and huge impacts that occurred in the past.

868
869
870
871

Feedback from the regional consultations suggested separating requirement MT-2-a (to list material
topics) and requirement MT-2-b (to describe the impacts and involvement, for each material topic) into
different disclosures. Requirement MT-2-a has to do with materiality in general and MT-2-b requires
information about each specific material topic, which is the focus of Disclosure MT-3.

872

GSSB response:

873
874
875
876
877
878
879
880
881

•
•
•

Requirement MT-2-b in the Universal Standards exposure draft (to describe the impacts andinvolvement, for each material topic) has been moved into Disclosure MT-3. See requirement
3-3-b in GRI 3: Material Topics 2021.
A new requirement has been added for organizations to report actions to manage actual andpotential positive impacts, in order to make clear that these actions are also to be reported.
See requirement 3-3-d-iii in GRI 3: Material Topics 2021.
Most of the other points have been addressed in the guidance to the disclosures, assuggestions for what to report, but additional requirements have not been added to thedisclosures to keep reporting feasible.

Page 20 of 23

882

Appendix 1. Participation to regional883

workshops and webinars
Regional workshops

Date

Number of attendees

Regional workshop North America

27 July 202025

Regional workshop Africa

28 July 202043

Regional workshop Latin America

31 July 202024

Regional workshop South East Asia

17 August 2020

231

Regional workshop Taiwan

19 August 202018

Regional workshop Hong Kong

19 August 202032

Regional workshop Greater China

21 August 202023

Regional workshop Singapore

18, 20, 21 August 2020

21

Total

Webinar393

Date

Number of attendees

24 June 2020

380

GRI live webinar

24 June 2020

372

GRI live Q&A webinar

9 July 2020

72

GRI live Q&A webinar

9 July 2020

80

COVID-19: What COVID-19 means forrethinking stakeholder engagement &materiality assessment

14 July 2020

567

COVID-19: 2020 outlook – innovating
the sustainability report

21 July 2020

503

GRI Community webinar - Humanrights policy agenda

29 July 202043

GRI Community Universal Standards& Sector webinar

18 August 2020

80

GRI live webinar (Spanish)

21 August 2020

245

GRI live webinar

Total

2342

Page 21 of 23

884

Appendix 2. Public comment

885

submissions by stakeholder

886

constituency, organization size and887

regionPublic comment submissions by stakeholder
constituency

Investment
institution
7%

Labor
organization
3%

Civil society
organization
16%

Not specified
1%

Mediatinginstitution
51%

Businessenterprise
22%

Public comment submissions by organization size
Not specified
7%
Medium (50249)
15%
Large (250 +)42%

Small (1-49)
35%

Page 22 of 23

Public comment submissions by region
Africa5%

Oceania4%

Not specified
1%

Middle East
5%
Europe39%

Latin America
9%North America
13%

Asia
24%

Page 23 of 23