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

Item 04 – Public comments on Sector
Standards collected during the exposure
period for the Oil and Gas Sector
Standard
For GSSB information
Date

10 March 2021

Meeting

23 March 2021

Project

GRI Sector Program

Description

This document contains comments related to the format and approach of the GRISector Standards, collected during the public comment period for the Oil and Gas
Sector Standard.
Along with testing the oil and gas content, it was the objective of this publiccomment period to seek feedback on the value, clarity, and feasibility of the
proposed concept for Sector Standards.
The document presents comments received via the online survey and letters.
These comments will not be presented to the Oil, Gas and Coal Working Groupand are presented to the GSSB in accordance with the GSSB Due Process
Protocol. Analysis of these comments will be presented to the GSSB as part of asession on the Sector Standards to be held on 23 March 2021.
Comments previously presented to the GSSB on if an organization should be
required to explain why topics included in a Sector Standard are deemed material
and whether reporting on topics included in a Sector Standard should be required
have not been included in this document.
Comments received on oil and gas content, will be presented to the GSSB at alater date.
Comments are presented across two tables – the first lists comments targeted ata specific section of the Sector Standard, the second groups comments by theme,
which are more overarching or cross-cutting.
Note to reading the comments:••

Only feedback directed at, or relevant to, the general format and approach of
the Sector Standards has been included.
The comments included were made in response to a variety of questions
asked in the public comment survey and have been grouped by the Standards
Division. In some cases, all comments have been made in response to one
question or the most relevant question is needed to understand theThis 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

••

responses, in these cases the question is included along with the relevant
sub-heading.
Comments have been included verbatim. Where only part of a response has
been relevant, only this part has been included and the break is marked with
an ellipsis (…).
The Oil and Gas Exposure Draft is available for reference here.

1

Page 2 of 45

2Contents
Public comments ..................................................................................................................................... 4
1. Comments grouped by sections of the Sector Standard ................................................................. 4
2. Comments grouped by theme ....................................................................................................... 19

Page 3 of 45

3

Public comments

4

1. Comments grouped by sections of the Sector Standard

5
No.

Comment

Name oforganization orindividualCountry

Institutional
Shareholder
Services (ISS)

UnitedStatesJeanne-Mey Sun

UnitedStatesStakeholder
group

Submission
type

Section 1.3: Organizations this Standard applies to1

Two questions remain unclear: 1) If a company is under the "Industrial
Conglomerate" industry but is engaged in exploration and productionof oil and gas through subsidiaries or joint ventures, would this sector
standard also apply to them? 2) Involvement through associates which
the company does not control but exert significant influence on is notaddressed under "Business Relationships".

2

The scope is clear.

Provider ofcorporate
governanceandresponsible
investment
solutions
Consultant

On behalf ofanorganization,group orinstitution

As anindividual

However, it would be very helpful to provide distinct reporting
templates / examples for each of the four sub-sectors within the oil andgas sector that reporting organizations could reference.
Section 2.2: Sector context
Relevant survey question: “Is the type of information described in the section 2.2 'Sector context' helpful for understanding and identifying anorganization's material topics and/or examining an organization's reporting? If not, please explain how this section could be more helpful.”3

Yes

Institutional
Shareholder
Services (ISS)

UnitedStatesProvider ofcorporate
governanceOn behalf ofanorganization,

Page 4 of 45

andresponsible
investment
solutionsgroup orinstitution

As anindividual

Jeanne-Mey Sun

UnitedStatesConsultant

Yes

Paul Davies

Australia

Consultant

6

Yes

CIRS Srl

Italy

Consultant

7

It is generally clear by providing background information of the industry
and how material topics associate with industry. It defines the nature ofcompanies that this sector standard applies.

Fuji Xerox (HongKong) Limited

Hong kongBusiness

8

Yes

Enric Nebot
Teixidó

Spain

Conformity
Assessment
body

9

Yes

Raymond Colvin

United ArabEmirates

Government

10

Yes, helpful

Prospect
Institute (PTArjuna Wijaya
Karya)

Indonesia

Consultant

11

Yes

Lundin Energy

Switzerland

Business

4

Yes

5

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

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

Page 5 of 45

12Section 2.2.Sector context is useful understanding and identifying
material topics and examining orgniazations reporting.

Junji BanJapan

Consultant

group orinstitution
As anindividual

It could be better if some notes are made in relation to coal which isimportant as well as oil and gas in terms of negative impact casued by
the use as energy sources. I think it maybe better presented to include
the reason why coal is excluded in this sector standard.
13

Yes, this is a good approach to outlining the important issues.

Engineers
Without Borders
CanadaCanadaNongovernmentorganization

14

Yes, it is

Empresa
Nacional Del
Petróleo (Enap,
National Oil
Company)

Chile

Consultant

15

Yes it is

Tiwalade Adeniyi

UnitedStatesInvestor

16

Yes

AECOM Asia
Company
LimitedHong kong

Consultant

17

Yes, it is helpful, however this section is very climate focused andshould be broadened to include other ESG topics.

International
Petroleum
Corporation

CanadaBusiness18

Yes it is

Pedro Caemiro
Magalhaes Jr

BrazilConsultant

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

Page 6 of 45

19

2.2 is clear expression

Dr Sushil Kumar
Pattanaik

India

Academic

As anindividual

20

Yes

Marisport
Calçado Lda

Portugal

Business

On behalf ofanorganization,group orinstitution

21

Yes

MicheleDASSISTI

Italy

Academic

22

Yes

Dr. Marius
GavrilaLuxembourg

Academic

As anindividual

23

Yes

AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

24

With a few readings, the context presented in the draft is useful in
identifying material topics. We believe that examples offered in a later
version of the draft would flesh out what others in a subindustry are
selecting as material. Such examples could help the all industry
standards migrate toward more consistent metrics and discussions forcomparability.

FactSet

UnitedStatesEconomic,
Financial,
Operating, andESG Data
AggregatorOn behalf ofanorganization,group orinstitution

25

Section 2.2. provides very helpful context to understand the approachof the Standard and help organizations identify topics that are material
for them. We fully support the general direction of this section, whichframed the Standard in the context of the needed decarbonization of
global energy systems to limit global warming to 1.5C.

Pembina
Institute

CanadaNongovernmentorganization

On behalf ofanorganization,group orinstitution

As anindividual

Page 7 of 45

26

Yes

AustralianCouncil of Trade
UnionsAustralia

Labor
representative

On behalf ofanorganization,group orinstitution

27

Many other organizations already reflect the concept of materiality in
guidance and papers. We would strongly recommend for GRI to avoid
duplicating guidance that is already existing.
The way GRI structures the guidance on materiality does – in our view
– create an inadequate reflection of materiality in the oil and gas
industry: e.g., (line 155-159) starting with the topic corruption, while
climate (line 167-173) is only addressed afterwards.

IOGP

Belgium

Business

28

Yes, see previous objection to the word "material".

Joint submisionfrom IndustriALL
Global Unionand International
Transport
Federation (ITF)

Switzerland

Global Union
Federations

On behalf ofanorganization,group orinstitution

29

Partially, however this section seems more geared to providing abroader overview of sustainable development in the industry. The
following section (3.1) is far more helpful in the development ofmaterial topics.

Plains All
AmericanPipeline

CanadaBusiness

On behalf ofanorganization,group orinstitution

30

Yes this information is helpful. Just transition is underlined (andincluded in glossary), which is also helpful to emphasise. The linkage
to the SDGs is balanced (Figure 3) but it is important to read to the text
boxes to understand significance and whether impact is positive or
negative. Perhaps lines 183, 184 and 185 should be on the same pageas the figure.

Shelley
AndersonAustralia

Consultant

As anindividual

On behalf ofanorganization,group orinstitution

Page 8 of 45

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

31

Helpful in general, however with a risk of introducing a prioritization ofissues - about half the text deals with climate change, which mightsuggest that other issues may be less important.

HitecVision

NorwayInvestor

32

The information is helpful, but it does not really link to the“understanding and identifying an organization's material topics and/or
examining an organization's reporting”. Matters related to context also
seem to be missing or incomplete

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

Whereas there could be more reference to the material from some of
the more ‘scientific’ NGOs (WWF, Transparency international, FOE,etc.), the description of the wider context of sustainable development
related to the oil and gas sector seems accurate.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

34

The write-up is not too helpful. The Sector and SDG image (figure 3) ismore helpful.

Shazia Naik

India

Investor

As anindividual

35

Drawing from the IPIECA-API-IOGP Guidance for Sustainability
Reporting [accessible at https://www.ipieca.org/our-work/sustainabilityreporting/sustainability-reporting-guidance/], GRI should mirror theprocess for prioritizing topics as outlined in Module 1: Reporting
Process section of the Guidance, and should mirror the core indicatorsfor reporting across Modules of the Guidance – these are the mosthelpful guides for companies in our industry for identifying andprioritizing topics for reporting.

AmericanPetroleum
Institute (API)UnitedStatesTrade orindustry
association

On behalf ofanorganization,group orinstitution

36

Yes

Grupo Ecopetrol

Colombia

Business

33

On behalf ofanorganization,group orinstitution

Page 9 of 45

37

Yes, it's very helpful

PTT PublicCompany
LimitedThailandBusiness

On behalf ofanorganization,group orinstitution

38

Yes, this is fine

ShareAction

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Section 3.2: Topic description and what to report
Relevant survey question: “Are the 'What to report' sections useful in helping to understand what is appropriate to report on a topic for an
organization in the sector? If not, please explain how they could be improved.”
39

40

41

Some topic need to be more specific and sharp to provide a valuable
information to society.
...

Pedro Caemiro
Magalhaes Jr

BrazilConsultant

As anindividual

Could it then be considered to answer in the reports only those
sectorial indicators for the most relevant activity in the company? Eg. If
a company operates exploration, production, transportation, storage,
refining and marketing, but currently its most important activity isrefining and marketing, could it only respond to the sectoral indicators
associated with Refining and Marketing)?

Empresa
Nacional Del
Petróleo (Enap,
National Oil
Company)

Chile

Consultant

On behalf ofanorganization,group orinstitution

Institutional
Shareholder
Services (ISS)

UnitedStatesThe definitions for the bullet points are not entirely clear andoccasionally too broad. For example, "Approach to public advocacy on
climate change" (row #470) is very general and opens up opportunities
for greenwashing. A list of well-defined qualitative or quantitative
metrics is crucial for information users.
Companies should also be encouraged to set goals (row #477) inaccordance with the Science-Based Targets initiative and improvecomparability.

Provider ofcorporate
governanceandresponsible
investment
solutions

On behalf ofanorganization,group orinstitution

Page 10 of 45

42

Page 8/87: The text in gray is helpful guidance, but it leaves far too
much latitude for what exactly companies should report.

Jeanne-Mey Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey Sun

UnitedStatesConsultant

As anindividual

It would be much more helpful to reporting organizations if there were
specific metrics proposed. Even better, benchmarks / thresholds for
those metrics should be provided where possible to indicate what
"good" performance looks like. For example, for labor transition
assistance, companies could quantify the number of weeks ofseverance pay, the duration of retraining programs, etc. Benchmarks
should also be provided where possible -- e.g. 1 week of severance
pay for every year of service, etc. Companies could still provide
additional detail on their own particular labor transition programs andassociated metrics, but at least there would be some guidance for themost common / minimum expected metrics to report (and benchmarks
where possible).
43

44

They are helpful to understand WHAT is appropriate to report, but far
too vague in terms of helping reporting organizations understand HOW
to report.
All of the listed disclosures are challenging to report in the absence ofmuch more specific guidance on HOW to report them. Specificsuggestions:
It would really be helpful to the reporting organization if they didn't
have to pull up other documents but could see the main points of all of
the standards referenced here (302-1, 302-3, 305-1, etc.).
In addition, it would be very helpful to indicate here the following
guidance for reporting on each topic: the desired metric(s) to bereported, its unit(s) of measure, the desired frequency of its reporting(e.g. annually), the desired granularity by which it should be captured(total, by geography, by product, by type of activity, etc.), and thedesired number of time periods for which it should be reported (e.g. x
years of historical actuals, y years of forecast).
Even better, it would be very helpful to provide an accompanying data
template or form that a reporting organization could fill out, along with afilled-out example.

Page 11 of 45

45

Yes

Paul Davies

Australia

Consultant

As anindividual

46

Good as starting point

CIRS Srl

Italy

Consultant

On behalf ofanorganization,group orinstitution

47

Yes, the 'What to report' sections are helpful.

Fuji Xerox (HongKong) Limited

Hong kongBusiness

On behalf ofanorganization,group orinstitution

Clear instructions are provided on the use of appropriate Universal
Standards as well as Topic Standards and relevant information useful
to topics are provided.
48

Yes

Enric Nebot
Teixidó

Spain

Conformity
Assessment
body

As an
individual

49

Positives are:Raymond Colvin

United ArabEmirates

Government

As anindividual

Prospect
Institute (PTArjuna Wijaya
Karya)

Indonesia

Consultant

On behalf ofanorganization,group orinstitution•

Mitigating or reversing – negative environmental, social andgovernance impacts.
• Improving reputation and brand loyalty.
• Enabling external stakeholders to understand theorganization's true value, and tangible and intangible assets.
Negatives:• Time consuming• reporting methodology is a little confusing
50

Yes, very usefulPage 12 of 45

51This felt to me rather confusing because the 'what to report' question 1
often highlights specific aspects that an organisation should report, e.g.
for climate change, biodiversity... But then question 2. in the 'what toreport' section highlights the GRI Topic Standards to disclose against.
It would be much more straightforward to first of all, identify the Topic
Standard that would be deemed appropriate, and then to add an
addendum to each disclosure (as is the case for example with 306-5).
It's confusing to have these elements separated.

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

52

More clarity and consistency is recommended, for example in terms ofunits to help standardize disclosures. In many cases units are notprovided, e.g. in 303-4 Water discharge - hydrocarbon volumes, orDrilling Waste (306-5).

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

Junji BanJapan

Consultant

Netherlands

Benchmarking
Foundation

CanadaNongovernmentorganization

It would also be useful to explain somewhere at the beginning of the
document, which material topics require ADDITIONAL elements ofdisclosure than in the topic standard. For example, Diversity and nondiscrimination does not highlight any additional disclosures beyond
what is requires in the relevant topic standards. A simple tablehighlighting these would be useful, up front.
53

Useful. It maybe clearer, if line 103 "Figure 2.Content overview of"What to report" section included in each sector topic" , it may be user
friendly if it states, "this is just an example, and same approach can beused for 201-207,303,304, 305,306,and 402-405,410,411,413,415".

54

The Topic descriptions and what to report sections are quite lengthy,
which adds to the completeness and accuracy yet reduces the clarityand practicality of these sections. Perhaps the topic descriptions could
be included as an Annex, and only the what to report included in the
body of Section 3.2, as these disclosures are likely what companies
are primarily looking for.

55

Yes, it is usefulWorld
Benchmarking
Alliance

Engineers
Without Borders
CanadaAs anindividual

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,

Page 13 of 45

group or
institution
56

A clearer breakdown of what is added as a requirement for theindicators listed.

Empresa
Nacional Del
Petróleo (Enap,
National Oil
Company)

Chile

Consultant

On behalf ofanorganization,group orinstitution

57

Yes

Tiwalade Adeniyi

UnitedStatesInvestor

As anindividual

58

Yes

AECOM Asia
Company
LimitedHong kong

Consultant

On behalf ofanorganization,group orinstitution

59

Yes, they are

Pedro Caemiro
Magalhaes Jr

BrazilConsultant

As anindividual

60

Yes

Troy Carter

Australia

Trade orindustry
association

As anindividual

61

Yes

Marisport
Calçado Lda

Portugal

Business

On behalf ofanorganization,group orinstitution

62

Yes

MicheleDASSISTI

Italy

Academic

As anindividual

63

Yes

Dr. Marius
GavrilaLuxembourg

Academic

As anindividual

Page 14 of 45

64[More detailed comments were submitted by this respondent inaddition to their survey responses]

IPIECA

UnitedKingdom

Trade orindustry
association

We do not believe that the current draft standard achieves the focus
that is requested by stakeholders but potentially leads to more
proliferation of definitions and KPIs, and rather confuses than sharpens
company profiles to enable better comparability.

On behalf ofanorganization,group orinstitution

In addition, regulatory requirement will increase in many countries andcompanies need to ensure compliance with those first. Also, we findthat this question is basically contradicting the purpose of the standard:
we believe that guidance for reporting will likely not be able to become“complete”, as companies must define their materiality not within the“boundaries” of such guidance.
65

Yes but they may be improved further. For instance organisations
should provide data in a uniform format e.g. in a standard tableshowing relevant data like types of wastes, states, units ofmeasurements, dates, sites, etc. when reporting wastes (lines 668,
669 and 670).

ShailandGunnooMauritius

Civil Society

As anindividual

66

...

ShailandGunnooMauritius

Civil Society

As anindividual

Numbering of subsections should be done e.g. 3.1.1, 3.1.2, 3.1.3, and
so on
67

Yes they provide a good outline of what to report

AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Nongovernmentorganization

68

This section is helpful as it helps to standardize reporting. However, it
will prove more helpful to all stakeholders if it’s made a requirement –see answer to next question.

Pembina
Institute

CanadaNongovernmentorganization

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

Page 15 of 45

69

Yes they provide a good outline of what to report.

AustralianCouncil of Trade
UnionsAustralia

Labor
representative

On behalf ofanorganization,group orinstitution

70[More detailed comments were submitted by this respondent inaddition to their survey responses]

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

We do not believe that the current draft standard achieves the focus
that is requested by stakeholders but potentially leads to more
proliferation of definitions and KPIs, and rather confuses than sharpens
company profiles to enable better comparability.
In addition, regulatory requirement will increase in many countries andcompanies need to ensure compliance with those first. Also, we findthat this question is basically contradicting the purpose of the standard:
we believe that guidance for reporting will likely not be able to become“complete”, as companies must define their materiality not within the“boundaries” of such guidance.
71

Yes

Joint submisionfrom IndustriALL
Global Unionand International
Transport
Federation (ITF)

Switzerland

Global Union
Federations

72

Yes, this is very helpful.

Plains All
AmericanPipeline

CanadaBusiness

73

No, we find that there is a significant lack of clarity about materiality.

EuropeanAccounting
Association
Stakeholder

Belgium

Academic

We find that there is a lot of scope for misinterpretations (i.e. the needto switch between different documents) – confusing logics and nested
conditionality. This section could be more prescriptive. For example,

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Page 16 of 45

the default assumption can (should) be that an item is deemed material
and impose a rationale and explanation as to why it is not material.
Overall, and in contrast to the draft on universal standards (although
we pointed this out), there seems to be a switch towards allowing nondisclosure and making all topics voluntary. We were certainly not clear
on what organisations had to disclose.

ReportingCommittee

group orinstitution74

HelpfulShazia Naik

India

Investor

As anindividual

75

Yes, they are helpful.

Union ofConcerned
Scientists

UnitedStatesNongovernmentorganization

On behalf ofanorganization,group orinstitution

76

Yes.

Publish What
You Pay

UnitedStatesNongovernmentorganization

On behalf ofanorganization,group orinstitution

77

It is appropriate to report on a topic for an organization in the sector.

PTT PublicCompany
LimitedThailandBusiness

On behalf ofanorganization,group orinstitution

78

It would really be helpful to the reporting organization if they didn't
have to pull up other documents but could see the main points of all of
the standards referenced here (302-1, 302-3, 305-1, etc.).

Jeanne-Mey Sun

UnitedStatesConsultant

As anindividual

In addition, it would be very helpful to indicate here the following
guidance for reporting on each topic: the desired metric(s) to bereported, its unit(s) of measure, the desired frequency of its reporting(e.g. annually), the desired granularity by which it should be captured(total, by geography, by product, by type of activity, etc.), and thePage 17 of 45

desired number of time periods for which it should be reported (e.g. x
years of historical actuals, y years of forecast).
Even better, it would be very helpful to provide an accompanying data
template or form that a reporting organization could fill out, along with afilled-out example.
Resources and references
79

We need a portal where these documents are updated as there are
multiple new guidelines etc published during the year.

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

80

It will be exceedingly useful to iterate on these resources – and initiallyon a cadence faster than once per year as the standards evolve
quickly – to provide further examples and, we believe, bring
respondents closer together in terms of what they arereviewing/disclosing. Such a reference, too, may be good for GRI in
the sense of being a ‘live’ resource and continuing to be a place to go
for up-to-date examples of what to discuss and how to discuss it.

FactSet

UnitedStatesEconomic,
Financial,
Operating, andESG Data
AggregatorOn behalf ofanorganization,group orinstitution

81

...

Waste Analytics
LLC

UnitedStates

ESG
Research/Data
ProviderOn behalf ofanorganization,group orinstitution

Karen Ziegler

CanadaConsultant

It may also be worth mentioning at the end of the resources section foreach topic that the bibliography section contains additional referencesthat can also be utilized as resources.
82... the 'additional resources' components in the subsequent sections
obfuscate the decision and mechanisms for reporting.

As anindividual

Page 18 of 45

6

2. Comments grouped by theme
No.

Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Raymond
ColvinUnited ArabEmirates

Government

As anindividual

Additional reporting burden associated with Sector Standards
1

Positives are:•

Mitigating or reversing – negative environmental, social andgovernance impacts.
• Improving reputation and brand loyalty.
• Enabling external stakeholders to understand theorganization's true value, and tangible and intangible assets.
Negatives:• Time consuming• Reporting methodology is a little confusing
2... We do believe though that the overall volume of suggested KPIs
is too much – see also our comments against other questions.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

3

GRI is not in a position to mandate any reporting items. We support
an ambition to agree a small set of indicators that may be generally
adopted (in principle, what WEF is currently working on). GRI should
acknowledge that governments are also issuing regulations andguidance and companies will greatly benefit from eliminating
duplication and striving for simplification.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Page 19 of 45

4[More detailed comments were submitted by this respondent inaddition to their survey responses]

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

We do not believe that the current draft standard achieves the focus
that is requested by stakeholders but potentially leads to more
proliferation of definitions and KPIs, and rather confuses than
sharpens company profiles to enable better comparability.
In addition, regulatory requirement will increase in many countries
and companies need to ensure compliance with those first. Also, wefind that this question is basically contradicting the purpose of thestandard: we believe that guidance for reporting will likely not beable to become “complete”, as companies must define theirmateriality not within the “boundaries” of such guidance.
5[More detailed comments were submitted by this respondent inaddition to their survey responses]
Please refer to the excel document included in this submission for
detailed feedback on specific sessions to the Oil and Gas Standard.
The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies tomake choices which ones to use, dependent on a number of factors,
amongst them their particular investors.
Overall, we are concerned that the current suggestion for the O&G
sector standard is not enough addressing this challenge. Also, we
do not see the industry adequately reflected with regards tobusiness expanding into low-carbon, renewable, digitalized products
and services.
IPIECA member companies are committed to transparency, and areillustrating this by their ongoing activities with regards to evolving the
IPIECA, API, IOGP Guidance for Sustainability Reporting.
We believe that the volume of information GRI suggests to request
for reporting in the current draft is too much, reaching into clearlynon-material reporting.

Page 20 of 45

We do not see enough effort to achieve greater alignment with the
IPIECA, API, IOGP Guidance, and other commonly usedframeworks (e.g. SASB). For example, certain metrics, such as
water consumption (GRI 303), could be better aligned to include
water recycled/reused as found in the SASB and IPIECA standards.
We would also suggest with regards to the “oil and gas sector andthe Sustainable Development Goals” that you review the IPIECASDG Atlas which you could also reference.
A potential consequence of lacking focus on material topics is that
non-financial reports become very long and articulated, especiallywhen the information is included in annual mainstream reporting
adding to the overall volume.
With a clearer description of application of the materiality concept,
and clear encouragement for companies to focus GRI would help
data preparers and users. Currently, we think that the standard
implies “more data is more transparency” and we would argue that
this is not an automatism.
One of companies´ priorities must be to comply with local regulation.
For Europe, e.g., the Non-financial Reporting Directive is currently
under review and it may define certain further details, regulation onsustainable finance in connecting with the Taxonomy regulation is
expected to be in force in the course of 2021 and it will request
reporting against defined KPIs.
We are concerned that using both the GRI universal and sector
standards may lead to “getting lost in detail” (e.g. various ratios,
percentages of sometimes only locally relevant performance data).
In this context we believe, that giving up on the
Core/Comprehensive principle, GRI is discarding an option to focus
data prepares and users on material topics. We also regard this as
not helpful for the decision making process. The IPIECA, API, IOGP
Guidance works with a 2-level approach and even the latest
suggestions by the World Economic Forum work with 2 tiers: coreand expanded. Potentially it could be an option to define a small

Page 21 of 45

“minimum” set of KPIs that could support the interest in comparing
company performance data.
6

The structure is very clear, but too many details are asked. Nonfinancial information for the Oil and Gas sector are as strategic forinvestors as the financial information. A disclosure full of details
especially for companies who integrate non-financial reporting in
financial reports, could become an issue both for companies and forreaders. For example, sometimes breakdowns are superfluous
information, that should be disclosed only when relevant.

Eni SpA

Italy

Business

7

The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies tomake choices on which ones to use, dependent on a number offactors, among which their particular investors.

Eni SpA

Italy

Business

Overall, we are concerned that the current suggestion for the O&G
sector standard is not enough addressing this challenge. Also, we
do not see the industry adequately reflected with regards tobusiness expanding into low-carbon, renewable, digitalized products
and services.

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

We believe that the volume of information GRI suggests to request
for reporting in the current draft is too much, reaching into clearlynon-material reporting.
We suggest to closely monitor the evolution of reporting regulation:
for Europe, e.g., the Non-financial Reporting Directive is currently
under review and it may define certain further details, regulation onsustainable finance in connecting with the Taxonomy regulation is
expected to be in force in the course of 2021 and it will request
reporting against defined KPIs.
We are concerned that using both the GRI universal and sector
standards may lead to “getting lost in detail” (e.g. various ratios,
percentages of sometimes only locally relevant performance data).
In this context we believe, that giving up on the
Core/Comprehensive principle, GRI is discarding an option thatenables preparers and users to focus on material topics. We also

Page 22 of 45

regard this as not helpful for the decision making process.
...
8

GRI is not in a position to mandate any reporting items. We support
an ambition to agree a small set of indicators that may be generally
adopted (in principle, what WEF is currently working on). GRI should
acknowledge that governments are also issuing regulations andguidance and companies will greatly benefit from eliminating
duplication and striving for simplification.

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

9

The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies tomake choices which ones to use, dependent on a number of factors,
amongst them their particular investors.

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

Overall, we are concerned that the current suggestion for the O&G
sector standard is not enough addressing this challenge. Also, we
do not see the industry adequately reflected with regards tobusiness expanding into low-carbon, renewable, digitalized products
and services.
IOGP member companies are committed to transparency, and areillustrating this by their ongoing activities with regards to evolving the
IPIECA, API, IOGP Guidance for Sustainability Reporting.
We believe that the volume of information GRI suggests to request
for reporting in the current draft is too much, reaching into clearlynon-material reporting.
We do not see enough effort to achieve greater alignment with othercommonly used frameworks e.g. SASB or with the IPIECA, API,IOGP Guidance. For example, certain metrics, such as water
consumption (GRI 303), could be better aligned to include water
recycled/reused as found in the SASB and IPIECA standards.
A potential consequence of lacking focus on material topics is that
non-financial reports become very long and articulated, especiallywhen the information is included in annual mainstream reporting
adding to the overall volume.

Page 23 of 45

With a clearer description of application of the materiality concept,
and clear encouragement for companies to focus GRI would help
data preparers and users. Currently, we think that the standard
implies “more data is more transparency” and we would argue that
this is not an automatism.
One of companies´ priorities must be to comply with local regulation.
For Europe, e.g., the Non-financial Reporting Directive is currently
under review and it may define certain further details, regulation onsustainable finance in connecting with the Taxonomy regulation is
expected to be in force in the course of 2021 and it will request
reporting against defined KPIs.
We are concerned that using both the GRI universal and sector
standards may lead to “getting lost in detail” (e.g. various ratios,
percentages of sometimes only locally relevant performance data).
In this context we believe, that giving up on the
Core/Comprehensive principle, GRI is discarding an option to focus
data prepares and users on material topics. We also regard this as
not helpful for the decision making process. The IPIECA, API, IOGP
Guidance works with a 2-level approach and even the latest
suggestions by the World Economic Forum work with 2 tiers: coreand expanded. Potentially it could be an option to define a small“minimum” set of KPIs that could support the interest in comparing
company performance data.
10

We believe that all should be disclosed if material. They all appear to
be reasonable and measurable. We would like to push back against‘challenging’ criteria – if the topic is relevant and relates to anegative external impact, then the company should be required todisclose it and be accountable for it. We understand that the GRI is
not based on a ‘minimum compliance’ philosophy, but on as fullaccountability as possible and containing provision for additional
disclosures if necessary – explaining these challenges, limits in theinformation provided and developing how things get reported.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

Page 24 of 45

11

The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies tomake choices about which ones to use, dependent on a number offactors, among them their particular investors.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,group orinstitution

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Chile

Consultant

On behalf ofanorganization,

Many natural gas and oil companies utilize the IPIECA, API, IOGP
Guidance for Sustainability Reporting [accessible athttps://www.ipieca.org/our-work/sustainabilityreporting/sustainability-reporting-guidance/], which was recently
updated in 2020 and covers a broad range of material topics. We do
not see enough effort to align with the IPIECA-API-IOGP Guidance.
GRI should, in particular, draw from the “core” level of indicators in
the IPIECA-API-IOGP Guidance: these are those topics that areusually relevant for many oil and natural gas companies across thesector.
We believe that the volume of information in this draft that GRI
suggests for companies to report is too much, reaching into topics
that are not relevant for reporting.
We also advocate for greater alignment to our industry’s contribution
to the SDGs, per our industry’s reference “Mapping the Oil and Gas
Industry to the Sustainable Development Goals: An Atlas"[accessible at https://www.ipieca.org/resources/awarenessbriefing/mapping-the-oil-and-gas-industry-to-the-sustainabledevelopment-goals-an-atlas/].
...
12

13

As the service sector provides products and services on operations
managed by our customers; clarification is needed on who reports
what regarding emissions, water, waste outside of our operational
control.

Emissions, water and energy consumption should be mandatory, but
the breakdowns of the current GRI indicators (to water by cource, forexample) are too complex still. Thos topis could be simplified.

Empresa
Nacional Del
Petróleo(Enap,

Page 25 of 45

National Oil
Company)
14

If the sector standards asks for much more information than requiredby other standards then companies may not be too eager to adopt
them owing to costs and time considerations. Having said that,
requirements/ metrics which are universally accepted as key
material information for a sector across various standards andexchange requirements can be made mandatory.

Shazia Naikgroup orinstitution
India

Investor

As anindividual

Alignment with other frameworks
15...
Alignment with the EU taxonomy would help investors better
understand the information and lessen the reporting burden of
corporates.

16

Some disclosures might be more accurately reported if a longer-term
perspective is used. For example, there is a lot of focus on current
GHG emission performance and less focus on efforts to reduce
emissions in the future.

Institutional
Shareholder
Services (ISS)

United States

World
Benchmarking
Alliance

Netherlands

Benchmarking Foundation

On behalf ofanorganization,group orinstitution

International
Petroleum
Corporation

CanadaBusiness

On behalf ofanorganization,

Provider ofcorporate
governanceandresponsible
investment
solutionsComparing the climate change section to the ACT Oil & Gas
methodology, which will be used to create WBA’s Oil & Gas
Benchmark and is an assessment with thresholds and scoring, andthis GRI Sector Standard which provides detailed sector backgroundand the disclosures for companies to report, we suggest it is helpful
to include reference to ACT, WBA, and the SBTi as complementaryresources to enhance companies’ understanding of the latest
thinking on assessments, scoring, thresholds, and targets in the
sector to enable the transition to a low-carbon economy.
17...
The title “climate change” could be renamed to “climate change
related risks” reflecting physical climate risks and climate resilience

On behalf ofanorganization,group orinstitution

Page 26 of 45

and transition. Guidance here should align with TCFD for strongeralignment between reporting standards.
Line 192 – GHG emissions should sit under air emissions (line 202)as they are an intrinsic part of emissions to air.
...
18

...

group orinstitution

United States

Nongovernmentorganization

Ceres

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Ceres

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

CDP has produced sector-specific guidance for estimating Scope 3
category 11 (use of sold products) emissions for the Oil & Gas andCoal sectors (https://b8f65cb373b1b7b15febc70d8ead6ced550b4d987d7c03fcdd1d.ssl.cf3.rackcdn.com/cms/gui
dance_docs/pdfs/000/000/469/original/CDP-Scope-3-Category11Guidance-Oil-Gas.pdf?1479754082), the new Guidance being
developed on setting Science Based Targets for Oil & Gas andIntegrated Energy Companies (https://sciencebasedtargets.org/oiland-gas/), and more generally the most recent work on the topic.
19

Aligning this standard with the Climate Action 100+ (CA100+)benchmark (https://www.ceres.org/news-center/pressreleases/climate-action-100-calls-net-zero-business-strategies-setsout-benchmark) would create more consistency for organizations
and investors. Ceres would welcome a dialogue with GRI on thematter.

On behalf ofanorganization,group orinstitution

Ceres

The CA100+ benchmark 8th indicator on climate governancecurrently states (still a moving document):...
20

Because of the networked ownership structure of the gas industry, it
is essential that companies report all emissions from oil and natural
gas production on both operated and non-operated joint ventures.
Ceres recommends to find inspiration in other frameworks and bestpractices, like the Oil & Gas Methane Partnership’s new methane
reporting framework, OGMP 2.0.
Current industry standards for methane measurement anddisclosure are inadequate as they are derived from desktop

Page 27 of 45

calculations, not real-world measurements. This methodology
underestimates methane emissions from oil and gas production by
60% on average. Ceres recommends to use the Oil & Gas Methane
Partnership’s new methane reporting framework, OGMP 2.0, to
credibly estimate methane emissions from the oil and gas industry.
Alignment and consistency between standards - when possible - arecritical. Ceres wanted to confirm that GRI is engaged and/or torecommend that GRI engages with the SBTi sector process.
Alignment and consistency between standards - when possible - arecritical. Ceres would welcome a dialogue with GRI around theCA100+ benchmarking initiative.
21

What to report section: This section could benefit from closeralignment with TCFD: Report the organisations' climate-related
governance, risk, strategy, and metrics (11 disclosure items in
TCFD. Difficult to follow the structure of proposed disclosures.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

22

This seems to mirror the requirements of the Voluntary Principles on
Security and Human Rights, so a lot of this seems to be redundant.
There is also a VPSHR implementation toolkit (120+) pages which
outlines comprehensively how a program should be implemented.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Overall the text is negative and heavy handed and emotive when
discussing our industry. Also we don’t need different standards –best to refer to the Voluntary Principles of Human Rights andSecurity – they are detailed and comprehensive and our compliancewith them should be something we are proud of.
Need definition of what constitutes an 'area of conflict'. Some are
obvious others are not i.e. Qatar
23[More detailed comments were submitted by this respondent inaddition to their survey responses]
From the spreadsheet you can see that we believe the suggested
details are too much and do not contribute to a greater focus but
more proliferation of reporting. Only increasing the level of details

Page 28 of 45

does not necessarily increase the level of transparency for data
users.
It is commonly acknowledged that the current proliferation offrameworks and definitions is not helpful for increased transparency.
24

Generally speaking, we fret that information requested in the listed
disclosures in the "what to report" section is still too much, with thepossible consequence of making non-financial reports too long andarticulated, especially when they are included in the Annual Reports,
as the revised European Directive might require for the NonFinancial Information. Considering that, we would suggest not todiscard completely the Core/Comprehensive option of the current
version of GRI Universal Standards: indeed a Core option, possibly
built on the small set of mandatory KPIs of the previous question,
might be useful for companies when preparing mandatory NonFinancial Information, whereas a Comprehensive option might be
adopted for other Non-Financial reporting documents.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

IOGP

Belgium

Business

On behalf ofanWith the aim to increase performance comparability among peers,
we believe that a small set of KPIs - to be accurately defined –might be strongly recommended for companies to report on (suchas GHG emissions, TRIR, etc.), while the rest just labeled asadditional information (like the IPIECA guidelines).
25[More detailed comments were submitted by this respondent inaddition to their survey responses]
From the spreadsheet you can see that we believe the suggested
details are too much and do not contribute to a greater focus but
more proliferation of reporting. Only increasing the level of details
does not necessarily increase the level of transparency for data
users.
It is commonly acknowledged that the current proliferation offrameworks and definitions is not helpful for increased transparency.

26

The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies toPage 29 of 45

make choices which ones to use, dependent on a number of factors,
amongst them their particular investors.
Overall, we are concerned that the current suggestion for the O&G
sector standard is not enough addressing this challenge. Also, we
do not see the industry adequately reflected with regards tobusiness expanding into low-carbon, renewable, digitalized products
and services.

organization,group orinstitution

IOGP member companies are committed to transparency, and areillustrating this by their ongoing activities with regards to evolving the
IPIECA, API, IOGP Guidance for Sustainability Reporting.
We believe that the volume of information GRI suggests to request
for reporting in the current draft is too much, reaching into clearlynon-material reporting.
We do not see enough effort to achieve greater alignment with othercommonly used frameworks e.g. SASB or with the IPIECA, API,IOGP Guidance. For example, certain metrics, such as water
consumption (GRI 303), could be better aligned to include water
recycled/reused as found in the SASB and IPIECA standards.
A potential consequence of lacking focus on material topics is that
non-financial reports become very long and articulated, especiallywhen the information is included in annual mainstream reporting
adding to the overall volume.
With a clearer description of application of the materiality concept,
and clear encouragement for companies to focus GRI would help
data preparers and users. Currently, we think that the standard
implies “more data is more transparency” and we would argue that
this is not an automatism.
One of companies´ priorities must be to comply with local regulation.
For Europe, e.g., the Non-financial Reporting Directive is currently
under review and it may define certain further details, regulation onsustainable finance in connecting with the Taxonomy regulation is
expected to be in force in the course of 2021 and it will request
reporting against defined KPIs.

Page 30 of 45

We are concerned that using both the GRI universal and sector
standards may lead to “getting lost in detail” (e.g. various ratios,
percentages of sometimes only locally relevant performance data).
In this context we believe, that giving up on the
Core/Comprehensive principle, GRI is discarding an option to focus
data prepares and users on material topics. We also regard this as
not helpful for the decision making process. The IPIECA, API, IOGP
Guidance works with a 2-level approach and even the latest
suggestions by the World Economic Forum work with 2 tiers: coreand expanded. Potentially it could be an option to define a small“minimum” set of KPIs that could support the interest in comparing
company performance data.
27

Many other organizations already reflect the concept of materiality in
guidance and papers. We would strongly recommend for GRI to
avoid duplicating guidance that is already existing. The way GRI
structures the guidance on materiality does – in our view – create an
inadequate reflection of materiality in the oil and gas industry: e.g.,(line 155-159) starting with the topic corruption, while climate (line167-173) is only addressed afterwards.

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

28

In Europe, the Directive on non-financial reporting sets the
expectations for companies, and the application into national laws
sets specific obligations for companies. GRI should acknowledge
that governments are also issuing regulations and guidance andcompanies will greatly benefit from eliminating duplication andstriving for simplification.. GRI should remain a voluntary framework.

TOTAL S.E.

FranceBusiness

On behalf ofanorganization,group orinstitution

29

If the sector standards asks for much more information than requiredby other standards then companies may not be too eager to adopt
them owing to costs and time considerations. Having said that,
requirements/ metrics which are universally accepted as key
material information for a sector across various standards andexchange requirements can be made mandatory.

Shazia Naik

India

Investor

As anindividual

Page 31 of 45

30

Companies’ use of GRI as a reporting framework is voluntary; GRI
can acknowledge those governments that issue regulations andguidance for sustainability reporting.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Again, GRI should reference the oil and natural gas industry’s own
guidance for sustainability reporting [accessible athttps://www.ipieca.org/our-work/sustainabilityreporting/sustainability-reporting-guidance/] for those topics that are
typically most relevant for reporting by companies in our sector.
31

We advocate greater alignment with the IPIECA-API-IOGP
Guidance [accessible at https://www.ipieca.org/ourwork/sustainability-reporting/sustainability-reporting-guidance/], andfor “what to report,” with its Module 1: Reporting Process section of
the Guidance.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,group orinstitution

32

The ESG reporting landscape is currently characterized by aproliferation of frameworks and standards forcing companies tomake choices about which ones to use, dependent on a number offactors, among them their particular investors.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Many natural gas and oil companies utilize the IPIECA, API, IOGP
Guidance for Sustainability Reporting [accessible athttps://www.ipieca.org/our-work/sustainabilityreporting/sustainability-reporting-guidance/], which was recently
updated in 2020 and covers a broad range of material topics. We do
not see enough effort to align with the IPIECA-API-IOGP Guidance.
GRI should, in particular, draw from the “core” level of indicators in
the IPIECA-API-IOGP Guidance: these are those topics that areusually relevant for many oil and natural gas companies across thesector.
We believe that the volume of information in this draft that GRI
suggests for companies to report is too much, reaching into topics
that are not relevant for reporting.
We also advocate for greater alignment to our industry’s contribution
to the SDGs, per our industry’s reference “Mapping the Oil and Gas
Industry to the Sustainable Development Goals: An Atlas"

Page 32 of 45

[accessible at https://www.ipieca.org/resources/awarenessbriefing/mapping-the-oil-and-gas-industry-to-the-sustainabledevelopment-goals-an-atlas/].
...
Clarity and useability of the Sector Standard
Relevant survey question: “Is it clear how a Sector Standard should be used within the GRI Standards system? If not, please explain what isunclear and how it could be improved.”
Institutional
Shareholder
Services (ISS)

United States

Jeanne-Mey
Sun

United States

Consultant

As anindividual

Yes

Paul Davies

Australia

Consultant

As anindividual

Yes

CIRS Srl

Italy

Consultant

On behalf ofanorganization,group orinstitution

33

Yes

34

It would be helpful to add graphics such as a decision tree and/or
process flow map to summarize the approach described in section
1.5 "Using this Standard". Currently, it's very text-heavy whichmakes it more difficult to follow than necessary. More fundamentally,
GRI should consider creating presentations / slide decks toaccompany (or even replace) text documents for increased user
friendliness and quicker understanding.

35

36

Provider ofcorporate
governanceandresponsible
investment
solutions

On behalf ofanorganization,group orinstitution

Page 33 of 45

37

Yes, it is clear. Hyperlink in blue can be provided for GRI 102
exposure draft when it is mentioned in "What To Report" to be moreuser friendly.

Fuji Xerox(Hong Kong)
LimitedHong kongBusiness

On behalf ofanorganization,group orinstitution

38

Yes

Enric Nebot
Teixidó

Spain

Conformity
Assessment
body

As an
individual

39

Yes

Raymond
ColvinUnited ArabEmirates

Government

As anindividual

40

Clear

Prospect
Institute (PTArjuna Wijaya
Karya)

Indonesia

Consultant

On behalf ofanorganization,group orinstitution

41

Yes

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

42

More clarity necessary for the following points. Improvement can bemade through adding more information.
...
3.Summary of reporting by sector topic Table-1 in the explanatory
memorundum shoud also be included in the expoure draft fro thesake of user freindliness.
...

Junji BanJapan

Consultant

43

The use of the Sector Standard is clear. The steps outlined in GRI
103 ‘Identifying material topics’ provide clear and elaborative
guidance on how to identify material topics. This helps to increase

World
Benchmarking
Alliance

Netherlands

Benchmarking Foundation

As anindividual

On behalf ofanorganization,

Page 34 of 45

the accuracy and completeness of GRI reporting, which cansubsequently support the use of this information by otherorganizations such as the World Benchmarking Alliance (WBA).
The WBA will assess Oil & Gas companies on their alignment with a
low-carbon transition using the ACT Oil & Gas methodology. Thismethodology assesses companies by measuring their impact andprogress based on indicators that have relative weighting, as well asa holistic ‘narrative’ assessment and a trend assessment (whether
the company’s assessment - if re-performed in the near term - would
improve, stay the same, or worsen. WBA will also assess Oil & Gas
companies on their contribution to a just transition and performanceon WBA’s core social indicators.

group orinstitution

44

Yes, very clear - the diagram with the blocks is a helpful visual aid.

Engineers
Without
Borders
CanadaCanadaNongovernmentorganization

On behalf ofanorganization,group orinstitution

45

It is not totally clear, since it is necessary to specify which are theparticular indicators that would be incorporated, since until now wehave handled the detail of the previous OIL&GAS indicators (forexample: OG1, OG2, OG 5, OG4,OG%, OG 10). May be I can notfound the new ndicators in details in your website.

Empresa
Nacional Del
Petróleo(Enap,
National Oil
Company)

Chile

Consultant

46This is clear

Tiwalade
Adeniyi

United States

Investor

As anindividual

47

Yes

AECOM Asia
Company
LimitedHong kong

Consultant

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 35 of 45

48

Yes, it is clear

International
Petroleum
Corporation

CanadaBusiness

On behalf ofanorganization,group orinstitution

49

Yes

Pedro
CaemiroMagalhaes Jr

BrazilConsultant

As anindividual

50

Pages 6&7 [Section 1.5 Using this Standard] are fine ...

Karen Ziegler

CanadaConsultant

As anindividual

51

Yes

Dr Sushil
Kumar
Pattanaik

India

Academic

As anindividual

52

Yes

Marisport
Calçado Lda

Portugal

Business

On behalf ofanorganization,group orinstitution

53

Yes

MicheleDASSISTI

Italy

Academic

As anindividual

54

Yes

Dr. Marius
GavrilaLuxembourg

Academic

As anindividual55

In principle, it is clear. However, the overlap between existingStandards and the new sector Standard could be illustrated clearer.
Simple tables of KPIs for download would provide a practical help.
We do believe though that the overall volume of suggested KPIs is
too much – see also our comments against other questions.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Page 36 of 45

56

Yes

AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

57

It is clear how a sector standard should be used within the GRI
Standards.

FactSet

United States

Economic,
Financial,
Operating,and ESG
Data
AggregatorOn behalf ofanorganization,group orinstitution

58

While our organization is not a user of the GRI Standards, I think I
understand how a Sector Standard complements existing GRI
Standards system.

Pembina
Institute

CanadaNongovernmentorganization

59

Yes

AustralianCouncil ofTrade Unions

Australia

Labor
representative

On behalf ofanorganization,group orinstitution

60

It is clear and for sure helpful. However, the overlap between
existing Standards and the new sector Standard could be illustrated
more clearly. Simple tables of KPIs for download would provide apractical help. We do believe though that the overall volume ofsuggested KPIs is too much – see also our comments against otherquestions.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

61

In principle, it is clear. However, the overlap between existingStandards and the new sector Standard could be illustrated clearer.
For example. simple tables of KPIs for download would provide apractical help.

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 37 of 45

On behalf ofanorganization,group orinstitution

62

Yes

Joint
submisionfromIndustriALL
Global Union
andInternational
Transport
Federation(ITF)

Switzerland

Global Union
Federations

63

Yes, it is clear how to use the standard.

Plains All
AmericanPipeline

CanadaBusiness

On behalf ofanorganization,group orinstitution

64

Yes, we believe it is clear. However, please note we are not areporting organization.

Waste
Analytics LLC

United States

ESG
Research/Data Provider

On behalf ofanorganization,group orinstitution

65

Yes, it is clear. Figure 1 captures this well. Perhaps the only addition
to the figure is some way of indicating that an organisation may need
to use more than one sector standard, depending on their activities.

Shelley
AndersonAustralia

Consultant

As anindividual

66

Yes

Vigeo SAS

UnitedKingdom

Ratingagency67

We find this description difficult to follow. While the legalistic
language gets in the way of comprehension, the figure does help.
However, we also get the feeling that organisations have muchlatitude and discretion as to what to report – particularly in the choice

EuropeanAccounting
Association
Stakeholder

Belgium

Academic

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Page 38 of 45

of topics – leading to subjectivity issues (which seems to go against
the spirit of the changes in the universal standards, although wepointed this out in our response to that specific draft).

ReportingCommittee

68

Clear

Shazia Naik

India

Investor

69

Yes

Union ofConcerned
Scientists

United States

Nongovernmentorganization70

It is unclear whether organizations reporting either in accordancewith or in reference to the GRI standards must both report on
disclosure requirements under GRI-102 and sector specificstandards. The substance of our comments below relates toconcerns that important disclosures on grievance redress
mechanisms (RBC-4) are not referenced in the sector standards.
Sector specific standards should provide a platform for more in
depth or nuanced reporting on accountability than what is presently
required of the universal standards.

AccountabilityCounselUnited States

Nongovernmentorganization

71

The linkage between existing Standards and the new sector
Standard could be made more clear.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

72

Yes

Publish What
You Pay

United States

Nongovernmentorganization

73

Yes

Grupo
Ecopetrol

Colombia

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

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

Page 39 of 45

74

Yes, it is clear

PTT PublicCompany
LimitedThailandBusiness

75

Yes, clear

ShareAction

UnitedKingdom

Nongovernmentorganization

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

The following comments also provide input on the clarity and useability of the Sector Standard but were made in repsonse to a variety ofsurvey questions.
76

To promote use by companies, this document should be selfcontained and therefore provide within it the necessary
guidance on materiality.

77

It would be helpful to add graphics such as a decision tree
and/or process flow map to summarize the approachdescribed here. Currently, it's very text-heavy which makes it
more difficult to follow than necessary. More fundamentally,
GRI should consider creating presentations / slide decks toaccompany (or even replace) text documents for increaseduser friendliness and quicker understanding.

78

It would be very helpful to provide example reporting
templates that different types of oil and gas companies could
reference, e.g. one for each of the different parts of the oil andgas value chain (upstream, midstream, downstream, oilfieldequipment and services).

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Page 40 of 45

Materiality and Sector Standards
Relevant survey question: “After reviewing the topics listed in this section, an organization still needs to conduct its own materiality assessment
process. Is it clear that the list of likely material topics is not a) exhaustive or b) applicable for every organization in the sector? If not, please
explain what could be improved.”
79

A disclaimer would be desirable, highlighting that the list is not
exhaustive and companies are encouraged to provide additional
information on topics they consider to be complementary.

Waste
Analytics LLC

United States

ESG
Research/
Data
ProviderOn behalf ofanorganization,group orinstitution

80

Yes

Shelley
AndersonAustralia

Consultant

81

Yes

Vigeo SAS

UnitedKingdom

RatingagencyOn behalf ofanorganization,group orinstitution

82

It is a good starting point.

Shazia Naik

India

Investor

As anindividual

83

Yes. It is clearly stated in Section 1.5 Using this Standard.

Union ofConcerned
Scientists

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

84

Yes

Publish What
You Pay

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

As anindividual

Page 41 of 45

85

If GRI provided a specific tool for each assessment, this would help
with continuity of the assessments.

PTT PublicCompany
LimitedThailandBusiness

On behalf ofanorganization,group orinstitution

86

Applicable

ShareAction

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

87

Yes, we believe this is clear.

Waste
Analytics LLC

United States

ESG
Research/Data Provider

On behalf ofanorganization,group orinstitution

88

I think it is clear but could still be applied prescriptively. Maybe lines 6871 could be inserted earlier in Section 1.5 to emphasise this guidanceis not a substitution for the organisation's own process. I think anorganisation should conduct its own materiality process first and thencompare with the topics listed in this section or it be stated that it is an
iterative process (that should also encourage regular review of material
topics).

Shelley
AndersonAustralia

Consultant

As anindividual

89

Yes

Vigeo SAS

UnitedKingdom

RatingagencyOn behalf ofanorganization,group orinstitution

90

It seems to be clear on thisShazia Naik

India

Investor

As anindividual

Page 42 of 45

91This is clear, but would benefit from some topics to be mandatory (exGHG emissions) as they are applicable across all sector activities. The
industry has historically skirted around the edges of disclosure
requirements and had a loose interpretation of “material”, which
mandatory disclosures would rectify.

Union ofConcerned
Scientists

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

92

Yes. This is clear.

Publish What
You Pay

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

However, for the oil and gas sector, materiality determinations by eachcompany should be explained, including if materiality of topics isreassessed each reporting year. Given the long timespan of theindustry (contracts of multiple decades), and multi-decade and evengenerational impacts of oil and gas production, it would be important forreporting organizations to describe the time horizon of materiality
assessments for given topics and if materiality shifts on topics includedin the standard. There has been historic efforts by companies in thisindustry simply to avoid disclosure of uncomfortable topics - such as
project payment disclosure - using the rationale of ‘materiality’. Given
this history, GRI should clarify that organizations should be transparent
with their materiality assessment procedure and how it is validated
each year - especially as it concerns topics for which annual
performance may have multi-year and generational impacts (eg climatechange, pollution). See more on this in Question 4.
93

Yes, we still needs to conduct our own materiality assessment process
because we have to engage with our stakeholders and concerned
about the internal and external impacts.

PTT PublicCompany
LimitedThailandBusiness

On behalf ofanorganization,group orinstitution

94

A line in the document to acknowledge the material topics is not
exhaustive or applicable for every organization in the sector should
suffice.

ShareAction

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 43 of 45

95

Drawing from the IPIECA-API-IOGP Guidance for Sustainability
Reporting [accessible at https://www.ipieca.org/our-work/sustainabilityreporting/sustainability-reporting-guidance/], GRI should mirror theprocess for prioritizing topics as outlined in Module 1: Reporting
Process section of the Guidance, and should mirror the core indicatorsfor reporting across Modules of the Guidance – these are the mosthelpful guides for companies in our industry for identifying andprioritizing topics for reporting.

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Jeanne-Mey
Sun

UnitedStatesConsultant

As anindividual

Other comments
96

Should define (quantitatively where possible) "most significant"both in the Glossary and more fundamentally. Otherwise,
different interpretations will be applied by companies.

97

Should define (quantitatively where possible) "material" both in
the Glossary and more fundamentally. Otherwise, different
interpretations will be applied by different reporting organizations.
In addition, while there are currently references to Section 2 of
GRI 101 and GRI 103 in the Glossary for "material topic", itwould be helpful to have this (or at least a succinct extract) within
the current document to improve user-friendliness and minimize
the need to look at other documents.

98

There is no definition of "topic" in the Glossary. Why not?

99

I think it will assist in the identification of RELEVANT topics, but
it's less clear how organizations will determine which of therelevant topics are MATERIAL.
GRI should define (quantitatively where possible) "material" bothin the Glossary and more fundamentally. Otherwise, different
interpretations will be applied by different reporting organizations.

Page 44 of 45

In addition, while there are currently references to Section 2 of
GRI 101 and GRI 103 in the Glossary for "material topic", itwould be helpful to have this (or at least a succinct extract) within
the current oil and gas standard document to improve userfriendliness and minimize the need to look at other documents.
100

Overall comment on sector standard:

5.0.Q21

Analysis of reporting practices and reporting quality of the oil andgas sector could be provided. It helps reporting organization tounderstand the reporting rate of each material topic and common
pitfalls committed by the sector when reporting.
101

Is needed to pass to conformity assessment bodies theverification. Is needed to work together with accreditations
bodies worldwide (iaf members)

Enric Nebot
Teixidó

Spain

Conformity
As anAssessment individualbody

7Page 45 of 45