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

Item 06 – GSSB Due Process
Adherence Report for the review ofGRI’s human rights–relatedStandards (Phase 1)
For GSSB [information]
Date

27 May 2021

Meeting

10 June 2021

StatusTo be submitted to the DPOC for review

Project

Review of GRI’s Human Rights-related Standards

Description

GRI Standards and related Interpretations are to be developed and issued in thepublic interest and according to due process as defined in the GSSB Due Process
Protocol.
The GSSB Due Process Adherence Report presents an explanation and, whereapplicable, evidence of how the Due Process Protocol has been followed in Phase
1 of the review of the GRI’s human rights–related Standards. Following the GSSB
decision to incorporate human rights and due diligence disclosures in the
Universal Standards, not all due process steps from the approval of the exposure
draft to the release of the final Standard are covered in this report but are covered
instead in the GSSB Due Process Adherence Report for the review of the GRI
Universal Standards.
The DPOC is requested to review the GSSB Due Process Adherence Report andto conclude whether or not due process has been followed in the review of theGRI’s human rights–related Standards.
Password protected resources
Resources to support the evidence of adherence that have not been published in
the public domain have been made available to you via links to an evidence
folder. The evidence folder contains sub-folders, whose titles reflect each DueThis 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 officialposition 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 2021

Process step sub-heading and are numbered in the order these appear in theDPAR.
Due to personal information contained in these resources, they have beenprotected with a password. The password to access these resouces will beprovided separately.
The following requirements are not applicable to this project:• Para 11 (see Formation of Project Working Groups)• Para 12 (see Multi-stakeholder composition)• Para 15 and 17-34, as these are covered by the Due Process Adherence
Report for the review of the GRI Universal Standards

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1Adherence with due process
Project

Description

Review of GRI’s
Human Rights–
related Standards

The objectives of the project were the following:
The main objective of this project was to bring the GRI human rights-related Standards in line with key authoritativeintergovernmental instruments in this area, namely the UN Guiding Principles on Business and Human Rights, as well asother instruments of the UN, the International Labour Organization (ILO), and the OECD. At the same time, the GSSB also
considered whether concepts contained in the UN Guiding Principles should also be adopted in other areas of theStandards.
The second objective consisted of revising the range of human rights-related topics covered in the GRI Standards,
prompted by the expert feedback that key human rights-topics may not yet have been covered.
And finally, the third objective consisted of reviewing the human rights-related topic-specific disclosures, based on theexpert feedback that existing disclosures may have limitations and may not reflect the best measurement of associatedimpacts.
Given the dependencies between these objectives, the GSSB carried out the project in two phases:• Phase 1: Conceptual review and alignment with the UN Guiding Principles;• Phase 2: Updating individual human rights topic-specific Standards.
An ad hoc Technical Committee was formed, as outlined in the GSSB’s Due Process Protocol, with the mandate to provide
recommendations about the development of human rights-related disclosures; whether and how concepts contained in theUN Guiding Principles can also be expanded to other areas of the Standards; which human rights topic Standards should
be reviewed and whether new ones should be created; and the approach for developing topic-specific disclosures. The
Technical Committee sought to develop content in alignment with key authoritative intergovernmental instruments and also
consider the content of other business and human rights reporting frameworks.
The drafting of new or revised text for the Standards covered by this project has been carried out by the GRI Standards
Division, with oversight and final approval of the Standard by the GSSB before its release.
The project proposal can be found here.

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Q4 2016

Project identificationand prioritization

Based on the stakeholder input received, andconsidering the international developments in thearea of human rights, the project to review GRI’s
human rights-related Standards was prioritized.

Para 6 (Basis ofidentification ofpotential new projects)‘Item 02 – Input for Discussion on GSSB Work
Program 2017-2019’ sets out feedback from thepublic comment process and GSSB members toinform the finalization of the GSSB Work Program for2017-2019. Item 02 was discussed during the GSSBOctober 2016 meeting.

For comments from the public, GRI
Stakeholder Council and the GSSB on
human rights, refer to lines 29-31, 70-72,108-113, 132-137, 203, 215-220, and 299 in
Item 02 – Input for Discussion on GSSBWork Program 2017-2019. Also, refer to lines
12-31 of the ‘Summary 27 October 2016
meeting’.

The United Nations (UN) Guiding Principles on
Business and Human Rights – released in 2011 –has become the authoritative global reference forpreventing and addressing adverse impacts onhuman rights arising from business-related activity.
Key elements of this instrument have been integrated
in global standards and initiatives relating to
responsible business conduct, such as theOrganisation for Economic Co-operation andDevelopment (OECD) Guidelines for Multinational
Enterprises (as well as emerging, related guidance
within the OECD system), ISO 26000, as well as
sector-specific initiatives by industry bodies. An
increasing number of States are also taking steps
towards enhancing and regulating human rights due
diligence.

A more detailed overview of international
developments relating to business andhuman rights can be found on pages 2-3 inthe ‘Review of GRI’s Human Rights-relatedStandards: Project Proposal’.

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Resources

Q3 2017

Projectcommencement

The GSSB agreed in its October 2016 meeting tostart engaging relevant stakeholders in preliminary
scoping discussions to address human rights issues
and consider this topic as the first priority of phase 2of its 2017-2019 Work Program.

Refer to lines 31-36 of the ‘Summary 27
October 2016 meeting’.

The Standards Division prepared an initial proposal
for the review of GRI’s human rights-relatedStandards. This was discussed during the March2017 meeting, where the GSSB agreed to expand
the scope of the project and solicit the Standards
Division to carry out a consultation with reportingorganizations to understand their reporting practices
in relation to human rights.

Refer to ‘Item 09 – Discussion paper on theReview of GRI’s Human Rights-relatedStandards’, lines 159-195 of the ‘Summary
21-22 March 2017 in-person meeting’, andlisten to minutes 1:42:46-1:45:35 of therecorded Livestream.

The revised draft project proposal was also circulated
to selected GRI Board and GRI Stakeholder Council
members for their comments. Input was received on
the project proposal.

Refer to lines 56-61 of the ‘Summary 24 May
2017 meeting’, line 171 of ‘Item 05 – Final
Project Proposal for the Review of GRI’s
Human Rights-related Standards’, and theEvidence folder (items 1 and 2).

The Standards Division incorporated feedback fromthe GRI Board and the Stakeholder Council andcirculated the final project proposal to the GSSB.

Refer to lines 18-29 of ‘Item 05 – Final
Project Proposal for the Review of GRI’s
Human Rights-related Standards’.

The GSSB approved ‘Item 05 – Final Project
Proposal for the Review of GRI’s Human Rightsrelated Standards’ during its May 2017 meeting withthe amendments noted in lines 18-29 of ‘Item 05 –Refer to lines 72-73 of the ‘Summary 24 May
2017 meeting’, and listen to minutes 1:35:141:35:33 of the recorded Livestream.

Para 8 (Developmentand approval of aproject proposal)

DPOC assessment
Y N Issue Note

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Final Project Proposal for the Review of GRI’s
Human Rights-related Standards’.
Q3 2017 toQ3 2021

Formation ofTechnicalCommittees

Para 9 (Appointmentof TechnicalCommittee)

Para 10 (Advice fromTechnical Committee)

Para 13 (Engagementwith the GSSB)

Appointment of ad hoc Technical Committee
An ad hoc Technical Committee (TC) was to beconvened to provide technical advice for the review
of GRI’s human rights-related Standards, as outlinedin the GSSB Due Process Protocol. This TC would
be appointed to provide recommendations on: thedevelopment of human-rights disclosures in line withthe UN Guiding Principles on Business and HumanRights; whether and how concepts contained in theUN Guiding Principles can also be expanded to otherareas of the Standards; which human rights-related
topic-specific Standards should be reviewed andwhether new ones should be created; and arecommended approach for developing topic-specificdisclosures.

Refer to lines 120-160 of ‘Item 05 – Final
Project Proposal for the Review of GRI’s
Human Rights-related Standards’.

The GSSB discussed and provided
recommendations related to the viewpoints to berepresented in the TC and the Standards Division
proceeded to consolidate these in order to provide a
proposed composition in time for the next GSSB
meeting.

Refer to lines 74-88 of the ‘Summary 24 May
2017 meeting’, and listen to minutes 1:35:411:45:45 of the recorded Livestream.

The GSSB approved the membership of the GRI
Technical Committee on Human Rights Disclosureand - to address the limited representation ofbusiness constituency - requested the Standards
Division to build a field test or expert roundtable tosocialize the Technical Committee’s

Refer to lines 236-245 of the ‘Summary 2021 September 2017 meeting’, and listen tominutes 32:55-36:46 of the recordedLivestream.

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recommendations before presenting their findings tothe GSSB.

As one civil society representative had withdrawn
their participation from the TC, the GSSB approved
the membership of an alternative candidate. As one
representative from the International Organisation ofEmployers (IOE) changed their role, a new
representative from the IOE was appointed to the TC
to ensure continuity in perspective and to increase
the representation of the business constituency.

Refer to lines 22-37 of the ‘Electronic Vote
11-14 December 2017 Record’.

As the two GSSB sponsors for the project endedtheir GSSB terms on December 2018, the GSSB
approved to appoint one of them to the TC to ensure
continuity of the project.

Refer to line 78-87 of the ‘Summary 7February 2019 meeting’, and listen tominutes 1:21:11-1:21:53 of the recorded
Livestream.

The Terms of Reference made it clear that the TC
members were expected act in an individual capacity,
exclusively in the public interest, and according todue process as defined in the GSSB Due Process
Protocol.

Refer to page 6 of the ‘Terms of Referencefor GRI Technical Committee on Human
Rights Disclosure’.

Refer to lines 39-45 of the ‘Summary 15
September 2020 meeting’, and listen tominutes 10:35 – 12:57 of the recorded
Livestream.

Technical Committee or PWG engagement withthe GSSBThe Standards Division provided updates on thereview of GRI’s human rights-related Standards
during the June 2018 and September 2018 GSSBmeetings.

Refer to lines 25-38 and 47-59 of the‘Summary 28 June 2018 meeting’, and lines
25-41 of the ‘Summary 25-26 September
2018 meeting’.

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Q3 2018

Due process step

Evidence of adherence

Resources

The Standards Division presented therecommendations of the TC on human rights
disclosure to the GSSB during its March 2019
meeting. This led to exploring a project to review theGRI Universal Standards.

Refer to lines 120-166 and 182-211 of the‘Summary 25-26 March 2019 meeting’.

The Standards Division presented a proposed option
for incorporating human rights and due diligence
disclosures in the Universal Standards, which wasdiscussed and agreed to by the GSSB during its
September 2019 meeting.

Refer to lines 119-149 of the ‘Summary 2425 September 2019 meeting’.

Formation of ProjectWorking Groups

Formation of Project Working Group

Para 11 (Appointmentof Project WorkingGroup)

Not applicable. A Project Working Group (PWG) was
not formed for the review of GRI’s human rights related Standards.

DPOC assessment
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Para 12 (Multistakeholdercomposition)

Para 13 (Engagementwith the GSSB)
Q3 2017 andQ4 2018

Development ofproposed Standards

Public form, roundtable, consultation paper, fieldtest

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Para 14 (Public forum,roundtable,consultation paper,field test)

As the GSSB had agreed that the Standards Division
carry out consultation with reporting organizations
about current reporting practices related to humanrights impacts during its March 2017 meeting, thefindings from this consultation were presented to theGSSB on its September 2017 meeting.

Resources

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Refer to lines 65-68 of the ‘Summary 20-21
September 2017 meeting’.

As requested by the GSSB during its September
2017 meeting, the Standards Division carried out
several informal stakeholder consultations tosocialize the TC’s recommendations before
presenting their findings to the GSSB. The findings
from these consultations were presented to the TC inNovember 2018 and considered by the TC in
finalizing its recommendations.

Regarding the GSSB request to theStandards Division, refer to lines 236-245 ofthe ‘Summary 20-21 September 2017
meeting’. Regarding the findings from thestakeholder consultation that were sharedwith the TC, refer to the Evidence folder (item3).

Para 15 (Voting on theapproval of anexposure draft)

The Standards Division presented the proposed
human rights and due diligence disclosures to theGSSB for approval as part of the Universal
Standards exposure draft during the May 2020
meeting.

Refer to the DPAR for the review of the GRI
Universal Standards.

Interaction with theGRI Board and theGRI StakeholderCouncil

Selected members of the GRI Board and GRI
Stakeholder Council were invited to comment on thedraft project proposal for the review of GRI’s humanrights–related Standards. Six individual comments
were received.

Refer to lines 56-61 of the ‘Summary 24 May
2017 meeting’, line 171 of ‘Item 05 – Final
Project Proposal for the Review of GRI’s
Human Rights-related Standards’, and theEvidence folder (items 1 and 2).

Further interaction with the GRI Board and GRI
Stakeholder Council was conducted as part of thereview of the GRI Universal Standards project.

Refer to the DPAR for the review of the GRI
Universal Standards.

Para 16 (Interactionwith the GRI Board
during thedevelopment andPage 9 of 13

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finalization of aStandard)Para 17 (Commentsought from the GRI
Board and the GRI SC
on proposals to start
new projects, andduring development
and finalization of aStandard)Para 18 and Para 19(Consideration ofcomments from theGRI Board and theGRI SC)

Q2 and Q3
2020

Public exposure

Not applicable. Refer to the DPAR for the review ofthe GRI Universal Standards.

Para 20 (Publicexposure andexplanatory
memorandum)

Para 21 (Exposureperiod)

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Para 22 (Commentson the exposure draft
are public)Q3 2020 toQ2 2021

Consideration of
respondents’comments on an
exposure draft

Not applicable. Refer to the DPAR for the review ofthe GRI Universal Standards.

Para 23 (Analysis ofcomments onexposure draft)

Para 24 (GSSB
consideration ofcomments on
exposure draft)

Q2 2021

Approval ofStandard andconsideration of theneed for re-exposure

Not applicable. Refer to the DPAR for the review ofthe GRI Universal Standards.

Para 25 (Revisedcontent of theexposed Standard)Para 26 (Advice of theHead of the Standards

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Division on dueprocess)Para 27 (Voting on theapproval of the final
revised content of anexposed Standard)Para 28 (Voting on theneed for re-exposure)

Para 29 (Explanatory
memorandum
accompanying the reexposure draft)

Para 30 (Effectivedate for theapplication of the finalStandard)Para 31 (GSSB basisfor conclusions)
Q2 2021

Withdrawal of aStandard

Not applicable. Refer to the DPAR for the review ofthe GRI Universal Standards.

Para 32 (Withdrawalof a standard)

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Q3 to Q4
2021

Release of the final
Standard

Not applicable. Refer to the DPAR for the review ofthe GRI Universal Standards.

Resources

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Para 33 (Reporting ondue process)Para 34 (Conclusion
DPOC on dueprocess)Page 13 of 13