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

Item 05 – GRI Sector Standards
Project for Oil, Gas, and Coal –Input on GRI Topic Standards
For GSSB informationDate

20 January 2022

Meeting

10 February 2022

ProjectGRI Sector Standard Project for Coal

Description

This document summarizes the input relevant to GRI Topic Standards collectedduring the development of GRI 12: Coal Sector 2022. This document includes thepreliminary opinion of the Standards Division based on the outcomes of the Oil,Gas, and Coal Project to date. However, recommendations to the GSSB work
program will be made by the Standards Division on the basis of cumulative input
from multiple Sector Standards projects.

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. TheGSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2022

Contents
Background ..............................................................................................................................................3Input on Topic Standards .........................................................................................................................3Based on the Sector Standard .............................................................................................................3
Further feedback from the Working Group ..........................................................................................4
Input received during public exposure .................................................................................................4Preliminary opinion ..................................................................................................................................4Appendix 1. Public comments on Topic Standards collected during the exposure period for the CoalSector Standard .......................................................................................................................................5Page 2 of 8

1Background234Along with the developing GRI Sector Standards, as outlined in the Program Description, the GRISector Program is to support the enhancement and expansion of the GRI Standards by surfacingissues not previously covered in the GRI Standards.

567The Standards Division will make proposals to the Global Sustainability Standards Board (GSSB) todevelop new or revise existing Standards, which the GSSB will consider and prioritize during theregular reviews of the GSSB work program per the Due Process Protocol.

8910Feedback on GRI Topic Standards was collected throughout the GRI Sector Standards Project for Oil,Gas, and Coal. This document focuses on feedback relevant for coal, collected during research
activities, from project working group input and public comment submissions.

111213The document also includes the preliminary opinion of the Standards Division based on the project’soutcomes. The Standards Division will make recommendations to the GSSB work program on thebasis of cumulative input from numerous Sector Standards projects.

1415
1617

Some of the GRI Topic Standards feedback triggered by working group discussions has already beencommunicated to the GSSB when delivering the first Sector Standard, GRI 11: Oil and Gas Sector
2021. The feedback applicable to both sectors is referenced here with a hyperlink and not repeated infull.

18Input on Topic Standards

19

Based on the Sector Standard

20
21

Similar to GRI 11, the GRI 12: Coal Sector 2022 contains four topics for which no dedicated (orclosely related) Topic Standard exists, namely:

22
23
24
25

•
•
•
•

26
27

In addition, to achieve complete reporting for the sector, the working group identified disclosure gaps
for the following topics which necessitated additional sector reporting:

28
29
30
31
32
33
34
35
36
37
38
39

•
•
•
•
•
••
•
•
•
•
•

40
41
42
43
44
45

The topics without a dedicated GRI Standard and the disclosure gaps listed above were identified as
relevant for the oil and gas sector as well as for coal. The additional reporting included the topics ofanti-corruption, biodiversity, conflict and security, economic impacts, local communities, payments togovernments, rights of indigenous peoples, waste, and water and effluents, which are expected to behighly relevant for all extractives sectors. It is unclear if the additional reporting for the other topics will
be relevant for non-extractive sectors.

Asset integrity and critical incident management
Climate adaptation, resilience, and transition
Closure and rehabilitation
Land and resource rights

Air emissions
Anti-corruption
Biodiversity
Conflict and security
Economic impacts
GHG emissions
Local communities
Payments to governments
Public policy
Rights of Indigenous peoples
Waste
Water and effluents

Page 3 of 8

46

Further feedback from the Working Group47

Feedback from the working group focused on the following key areas:

4849

•

Enhanced reporting related to climate change and low-carbon transition, especially for sectors
involved with fossil fuel production;

5051•Inadequate scope of reporting on rights of Indigenous Peoples in GRI 411: Rights ofIndigenous Peoples 2016;

52•Insufficient scope of reporting on biodiversity in GRI 304: Biodiversity 2016;

53
54•Gaps in reporting payments and contractual arrangements between organizations andgovernments.

55

More details on these recommendations can be found in the GRI 11 Topic Standards input report.

56

Input received during public exposure

57
58

Some responses received during public exposure are directly relevant to Topic Standards. The
complete comments are listed in Appendix 1 and logged on the GRI website.

59

Key feedback received from respondents includes the following:

60•

Further guidance needed on how to assess indirect economic impacts.

61
62

•

Indicators on managing corruption risks in procurement processes to be incorporated in GRI
205: Anti-corruption.

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64

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Additional compliance indicators related to waste incidents or surpassing air pollutionregulations.

65•

Details of due diligence or impact assessments conducted on biodiversity.

66•

Further guidance needed to calculate/report Scope 3 emissions.

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68

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Disclosures to report on due diligence processes and impact assessments on rights ofindigenous peoples and expansion of the right to ‘free, prior, and informed consent’.

69Preliminary opinion

7071
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74
75

The four topics without a dedicated or closely related Topic Standard - asset integrity and criticalincident management; climate adaptation, resilience, and transition; closure and rehabilitation; andland and resource rights – all appear to have a high potential for being likely material for othersectors. Spills and leaks appear to be part of the topic of asset integrity and critical incident
management, which also includes reporting on tailings, a key element for organizations with miningactivities.

7677
78
7980

Consistent disclosure on climate change is increasingly critical, and a consensus is growing on how
this issue should be reported on. The GRI Standards were considered to lack a structure for reportingon all relevant aspects of managing and responding to risks and opportunities posed by climatechange, necessary for understanding an organization’s strategy and resilience in the face of thegrowing challenge.

8182
83
84
85

In addition, biodiversity, local communities, rights of indigenous people, and the Topic Standards
related to local economic impacts were considered insufficient or difficult to interpret. It is anticipatedthat this input will arise again in the future development of Standards for other sectors. Finally, issues
related to managing corruption risks and transparency over resource governance are likely to arise in
all extractive sectors projects.

Page 4 of 8

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

Appendix 1. Public comments on Topic Standards
collected during the exposure period for the Coal Sector
StandardNo.

Comments (extracted from more detailed responses received)

Topics with no corresponding Topic Standard or relevant disclosures
1Supplier management should be a stand-alone topic, especially looking at
the way a mining company is managed.
GRI 202: Market presence 2016
2Economic Impacts: Rather than disclosing senior management from the local
community, shouldn’t the Standard also ask for the proportion of local
workers as part of job creation?
GRI 203: Indirect economic impacts 2016
3
GRI 203: Indirect Economic Impacts 2016; Disclosure 203-1 Infrastructure
investments and services supported - More clarity is required on how toquantify, assess and report on this indicator.
GRI 205: Anti-corruption 2016
4Ideally, GRI 205 Anti-Corruption 2016 will eventually be updated to ensurethat it explicitly asks companies to report on how they avoid corruption inprocurement processes. For now, one option would be to add thisprocurement issue as a bullet under “The following additional disclosures

Name oforganization
or individualCountry

Stakeholder group

Submission type

PT IndoTambangraya
Megah Tbk

Indonesia

Businessenterprise

On behalf of anorganization, group,or institution

PT Life Cycle
Indonesia

Indonesia

Mediatinginstitution

On behalf of anorganization, group,or institution

TeckResources
LimitedCanadaBusinessenterprise

On behalf of anorganization, group,or institution

Engineers
WithoutBorders
CanadaCanadaCivil society
organization

On behalf of anorganization, group,or institution

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 isthe independent standard setting body of GRI. For more information visit www.globalreporting.org.

© GRI 2022

56

have also been identified as appropriate and should be reported on thistopic:” (page 53, line 1501). Draft language could be: “A description of theorganization’s procurement processes and how it ensures corruption andother problematic practices do not occur through the procurement of goodsand services”.
I suggest including this recommendation, ‘especially those countries whereactivities in the mining and energy sectors are contracted with thegovernment’ also in Disclosure 205-1 Operations assessed for risks related
to corruption.
Rather than ‘anti-corruption’ it should be scaled up to ‘business ethics’ as atopic. And corruption is only part of the bigger business ethics context.

GRI 207: Tax 2019
7It would be useful to add an explicit requirement to report on operated JointVentures.
89I suggest including this recommendation, ‘especially those countries whereactivities in the mining and energy sectors are contracted with thegovernment’ in Disclosure 207-4 Country-by-country reporting.
Disclosure 207-1 Approach to tax: commitment to comply with spirit andletter of the law, and avoid tax heavens.

GRI 303: Water and effluents 201810
Disclosure 303-4 Water discharge: Disclosure of quality and destination(both together, inclusively – not one or the other).
11

Disclosure 303-5 Water consumption: Disclosure of investment in water
recycling infrastructure/technology or optimization of existentinfrastructure/technology.
GRI 304: Biodiversity 201612
Details on due diligence/impact assessment conducted in areas neighboring
international (World Heritage Site, Ramsar site, Natura 2000) or national
protected sites.

Energía
Renovada
2050Chile

Mediatinginstitution

On behalf of anorganization, group,or institution

PT IndoTambangraya
Megah Tbk

Indonesia

Businessenterprise

On behalf of anorganization, group,or institution

ISS ESG

SwedenInvestment
institution

Energía
Renovada
2050
Energía
Renovada
2050

Chile

Mediatinginstitution

Chile

Mediatinginstitution

On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution

Energía
Renovada
2050
Energía
Renovada
2050

Chile

Mediatinginstitution

Chile

Mediatinginstitution

ISS ESG

SwedenInvestmentinstitution

Page 6 of 8

On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution

GRI 305: Emissions 201613
Number of incidents of non-compliance or infractions resulting in fines.

ISS ESG

SwedenInvestment
institution

14

Information on emissions reporting requirements submitted regularly toregulating authorities.

ISS ESG

SwedenInvestment
institution

15

Describe the number of incidents where the local (or international) standard
limit for NOx, Sox, and PM emissions has been surpassed (usually a daily or
hourly limit) and corrective actions taken.
Apart from the absolute value on sulfide, perhaps you could consider adding
sulfide emission per 10,000 production volume to measure productivity
rather than total volume.

Energía
Renovada
2050
Shaanxi Coaland ChemicalIndustry
Group Co. Ltd
Glencore

Chile

Mediatinginstitution

China

Businessenterprise

Australia

Businessenterprise

On behalf of anorganization, group,or institution

PT Life Cycle
Indonesia

Indonesia

Mediatinginstitution

On behalf of anorganization, group,or institution

Glencore

Australia

Businessenterprise

ISS ESG

SwedenInvestment
institutionEnergía
Renovada
2050

Chile

Mediatinginstitution

On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution

1617

GHG Emissions, b. Report breakdown of gross Scope 1 GHG emissions bytype of source (stationary combustion, process, fugitive). Suggested
improvement: instead of reporting by type of combustion process, align with
the GHG protocol and require reporting on the source of emissions (e.g.,diesel, venting, etc.).
18If we use life cycle assessment, the GHG emissions will be required down tothe end-users. It would be useful to provide guidance for companies to reportusing an estimation (along with the methodology) to report GHG Scope 3.
GRI 306: Waste 2020
19
Reporting regarding Waste could be simplified when this standard isreviewed, and this may have some flow on impacts on the additional sector
requirements for the reporting of waste.
20
Details on the alignment of the organization’s waste strategies withapplicable local legislation on waste management.
21

Report the number of ‘Incidents’ related to waste management (Differentfrom Disclosure 306-2 “impacts” and other than tailing spills).

Page 7 of 8

On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institution
On behalf of anorganization, group,or institutionWaste and effluents 201622
in addition to ‘Disclosure 306-3 Significant spills’: include a confidential oranonymous (grievance) mechanism for employees or community
stakeholders to report tailings incidents.
GRI 401: Employment 2016
23
Incorporation of an indicator in Employement Practices (p.43) or in Conflictand security (p. 37). SASB includes in Labor Practices “Number and durationof strikes and lockouts”. This would be an interesting piece of information toreport by companies in the field.
GRI 410: Security Practices 201624
We recommend adding in 2.12 Conflict and security (p37), in theManagement Approach: the provisions of the Responsible Mining
Foundation - Reporting Framework 2020: Point D.02 Security and ConflictAffected Areas “The company tracks, reviews, and acts to improve its
performance on preventing and remedying human rights abuses related toits security management, in line with the Voluntary Principles on Security andHuman Rights (Number and nature of incidents related to security
management, and remedies provided, across successive time periods,
throughout company’s operations).
GRI 413: Local communities 201625
Engaging with local communities: policy/commitment in place involving
informed consent/consultation (FPIC), with the community (not exclusively toIndigenous peoples), for instance, before the development of new projects orchanges in operations which may affect them.

Energía
Renovada
2050

Chile

Mediatinginstitution

On behalf of anorganization, group,or institutionAGSustentable

ArgentinaMediatinginstitution

On behalf of anorganization, group,or institution

AG
Sustentable

ArgentinaMediatinginstitution

On behalf of anorganization, group,or institution

Energía
Renovada
2050

Chile

Mediatinginstitution

On behalf of anorganization, group,or institution

Page 8 of 8