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

Item 01 – Draft summary of the GSSB
meeting held on 3 December 2020
For GSSB approval
Date

7 January 2021

Meeting

21 January 2021

Description

This document presents the summary of the GSSB virtual meeting held on 3
December 2020.

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 2021

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ContentsParticipants.............................................................................................................................................. 3
List of abbreviations ................................................................................................................................ 3
Decisions and action items ..................................................................................................................... 4
Session 1: Welcome ............................................................................................................................... 4
Session 2: GRI Universal Standards Project update: Reporting model ................................................. 4
Session 3: Any other business and close of meeting ............................................................................. 7

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Participants

3

Present:456Name

Constituency

Judy Kuszewski

Chair

Robyn LeesonVice-Chair

Loredana CartaLaborPeter Colley

Labor

Evan Harvey

Investment institution

Kirsten Margrethe Hovi

Business enterprise

Vincent Kong

Business enterprise

Joseph Martin

Business enterpriseJennifer Princing

Business enterprise

Corli le RouxMediating institution

Gustavo SinnerMediating institution

Kenton Swift

Civil society organization

Michel Washer

Business enterprise

Apologies:
Name

Constituency

Rama Krishnan Venkateswaran

Investment institution

Tung-Li (Tony) Mo

Civil society organization

In attendance from GRI:
Name

Position

Bastian Buck

Chief of Standards

Mia d’Adhemar

Senior Manager Sector Program

Sharon Hagen

Senior Coordinator

Anna Krotova

Senior Manager

List of abbreviations
GSSB
RfOSDSME

Global Sustainability Standards Board
Reason for omission
Standards Division
Small- and medium-sized enterprise

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7Decisions and action items

8Decisions

9GSSB Decision 2020.24 The GSSB resolved to approve Item 01 – Draft summary of the GSSB

10meeting held on 5 November 2020.

11Action items
Standards Division
Session 2•SD to assess whether reasons for omission should bepermitted for selected disclosures in GRI 102 and GRI 103,and whether additional reasons for omission need to beincluded (besides the four current reasons for omission).

•SD to draft a requirement on comply or explain for instanceswhere a Sector Standard is in place, together with guidanceor a recommendation for reporting on commonly associatedtopics for a sector where no Sector Standard exists.

12

Session 1: Welcome

13

The GSSB was presented with Item 01 – Draft summary of the GSSB meeting held on 5 November

14

2020 for approval.

15

GSSB Chair Judy Kuszewski (henceforth the Chair) welcomed the GSSB and presented an overview

16of the meeting agenda.

17GSSB Decision 2020.24 The GSSB resolved to approve Item 01 – Draft summary of the GSSB

18

meeting held on 5 November 2020.

19

Session 2: GRI Universal Standards

20

Project update: Reporting model

21

The GSSB was presented with Item 02 – Public comments on the reporting model in the Universal

22Standards exposure draft and Item 03 – Public comments on the use of Sector Standards collected23

during the exposure periods for the Universal Standards and the Oil and Gas Sector Standard for24

discussion.

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In accordance requirements in the exposure draft

26

The Standards Division (SD) presented a recap of the reporting model proposed in the Universal

27Standards exposure draft, including a diagram showing the in-accordance requirements, to help

28

frame the discussion on material topics and appropriate disclosures.

29

As per the proposed reporting model, the organization is only required to report a reason for omission

30(RfO) if it does not report on a requirement within an appropriate disclosure; it is not required to report

31

a RfO if it deems a disclosure as not appropriate and it does not need to report on the ‘not32

appropriate’ disclosure. The Chair sought clarification on the scenario when an appropriate disclosure

33

could contain a requirement deemed as not appropriate, and the SD provided an example. A GSSB

34

member offered to provide further examples of this scenario if needed.

35

Another GSSB member noted that further guidance was needed on what constituted an appropriate

36

disclosure, and it would need to be examined whether RfOs were also needed in this instance. The

37

SD confirmed that discussion on this issue would be held at a future meeting.

38

Meeting in accordance level

39

The SD presented the percentage of Core and Comprehensive reports using the sample of reports

40

registered with GRI as of 18 November 2020. A GSSB member sought clarification as to whether the41

data presented on Core and Comprehensive reports was based on organizations’ self-declaration or42

was subject to external quality checks. The SD confirmed that the data was based on self-declaration.

43

The SD also highlighted that organizations tend to report more information than the requirements set

44

out in the Core option; however, not all reports that claimed to be Comprehensive actually met the45level of reporting required under the Comprehensive reporting option.

46

One GSSB member commented that resistance to raising the bar for reporting by introducing a single

47

in accordance option was to be expected, and expressed concern that the function of the Universal

48Standards would be weakened if RfOs were permitted for a substantial number of disclosures in GRI

49

102 and GRI 103. Another GSSB member expressed concern that reasons for omission compromise

50

the objective of raising the bar and are not a motivating factor to report fully.

51

A number of GSSB members expressed support for introducing a single in accordance option for

52

reporting, but also expressed reservations about setting the bar for reporting too high. One GSSB

53

member commented that unless certain flexibility is allowed, there is a risk that organizations will

54

report using alternative standards, and simply reference GRI Standards. Another GSSB member

55

pointed out that reporters currently reporting in accordance using the current Core or Comprehensive

56

options would see reporting with reference as a downgrade.

57

A number of GSSB members noted the frequent reference to governance disclosures in the feedback,58

and proposed reviewing RfOs in this respect. The limitations of what reporters are able to report59

regarding governance disclosures needs to be addressed. One GSSB member commented thatPage 5 of 7

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resistance to reporting on governance should be treated carefully, as it may simply be resistance to61

best practice.

62

The SD acknowledged the need to assess whether RfOs should be permitted for selected disclosures

63

in GRI 102, particularly those regarding governance, and also whether additional RfOs should be64

included (besides the four current RfOs). The SD suggested that, in addition to this, it should be

65

communicated even more clearly to reporters that if they are unable to report the required information

66

about an item specified in a disclosure because the item, e.g., a committee, policy, practice, or other67

process, does not exist, then reporting that fact is sufficient. The requirement is for transparency, not68

performance. GSSB members expressed agreement with these suggestions.

69

Material topics

70

The SD presented the GSSB with feedback on the following scenarios tested during the Oil and Gas

71

and Universal Standards public comment periods:

72•

Reporting being made mandatory for select likely material topics listed in Sector Standards;

73•Requiring an explanation, of why an organization deems topics listed in the relevant Sector

74
75Standard as not material; and•Requiring an explanation, in the absence of a relevant Sector Standard, of why an76organization deems topics commonly associated with the context/sector of the organization77

as not material.

78

One GSSB member commented that the situation, in terms of the selection of material topics and79

appropriate disclosures and reporting requirements, might differ for a homogenous sector (such as oil

80and gas) and a heterogenous sector (such as the chemical industry).

81

A GSSB member commented that GRI was currently some way from having the full suite of Sector

82Standards it aimed for. Though the ‘comply or explain’ approach for reporting on likely material topics

83‘commonly associated’ with the sector might be a subjective basis for a requirement, it is broad

84

enough to be used by those organizations for which no Sector Standard exists. To relinquish it

85

entirely would leave room for greater subjectivity and selectivity in identifying material topics;86

however, including it as a recommendation in guidance might be an alternative.

87

Another GSSB member commented that the requirement to explain why a topic commonly associated88with a sector is not material is a challenging reporting requirement, especially for small and medium

89

enterprises (SMEs).

90

The Chair commented that the topics commonly associated with a sector are to some extent

91

embedded in the concept of material topics, but the question was whether something more specific92

was needed to ensure levels of comparability and how to include this in a standard without creating

93

an unreasonable burden for reporters.

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The SD sought GSSB opinion on the option of a limited selection of topics being specified in a Sector

95Standard as material for all in the sector, and requiring reporting on these topics by all organizations

96

in the sector.

97

A number of GSSB members indicated that they did not support this option. One GSSB member

98

commented that the option could not apply to heterogenous sectors, and that Sector Standards

99

should not be a substitute for having a good materiality analysis. Another GSSB member commented

100

that there was no reason for removing the materiality principle from the Sector Standards. Even when101

reporting is done on a voluntary basis, organizations do not report only on what they are required to,102

but attempt to report as best they can, in their own wider interest.

103

One GSSB member commented that if a Sector Standard did not list likely material topics for

104

reporting, its purpose would be undermined, and it risked not being a standard but becoming merely105

guidance. The SD explained that there is a clear concern that the Sector Standards are currently too

106

optional and presented as guidance. The SD does believe that the Sector Standards offer information107

and explanations as to which topics are likely to be material and can establish a baseline for108

reporting. However, feedback highlighted if reporting on these topics is completely optional, this may

109

not achieve the aim of raising the bar for reporting. At the same time, other respondents suggested

110that if valid reasons for not reporting a topic exist, it should be acceptable to report that. The SD is111

seeking to balance the two views.

112

The GSSB agreed to the SD’s suggestion to draft a requirement on comply or explain for instances113

where a Sector Standard is in place, together with a recommendation for reporting on commonly

114

associated topics where no Sector Standard exists.

115

Actions

116•

SD to assess whether reasons for omission should be permitted for selected disclosures in117

GRI 102 and GRI 103, and whether additional reasons for omission need to be included118(besides the four current reasons for omission).

119•SD to draft a requirement on comply or explain for instances where a Sector Standard is in

120

place, together with guidance or a recommendation for reporting on commonly associated121

topics for a sector where no Sector Standard exists.

122

Session 3: Any other business and123

close of meeting

124

No other business was raised, and the Chair closed the meeting at 14.53 CET (Central European

125Time).

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