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

Item 01 – Public comments on key
concepts in the Universal Standards
exposure draft
For GSSB discussionDate

27 October 2020

Meeting

5 November 2020

Project

GRI Universal Standards Project

Description This document contains an extract of public comments related to key concepts
received on the Universal Standards exposure draft, which was made available
for public comment between 11 June and 9 September 2020.
The document presents the comments received via the online survey and via
letters, for GSSB reference. It does not present an analysis of the feedback – theanalysis will be presented by the Standards Division directly at the meeting.
The GSSB is kindly asked to review the document ahead of the meeting and toshare any questions about the comments or highlight any comments fordiscussion, with the Standards Division by 3 November.
Note to reading the comments:
Comments have been included verbatim. Where a respondent has raised several
distinct points in one comment, each point has been numbered and presented ina separate row. The point number is indicated in brackets before the verbatim
comment. In addition to this, comment numbers have been included in the firstcolumn to help facilitate the discussion during the meeting on 5 November.

This document has been prepared by the GRI Standards Division. It is provided as a convenience toobservers at meetings of the Global Sustainability Standards Board (GSSB), to assist them infollowing the Board’s discussion. 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 2020

1

Contents
Public comments ............................................................................................ Error! Bookmark not defined.
General comments on key concepts ................................................................................................................. 3
Impact ........................................................................................................................................................................ 5
Material topic ........................................................................................................................................................... 8
Stakeholder ............................................................................................................................................................ 43
Due diligence ......................................................................................................................................................... 52

Page 2 of 55

2

Public comments

3

1.General comments on key concepts

4

Please refer to page 8 in the Universal Standards exposure draft.
No. Comment

Name oforganization
or individualCountry

Stakeholder Submission
group
type

1

(1) For the section of key concept could need more clarification and also with therelation with the glossary. The items in the key concepts section could be althought
incluided in the glossary.

AG
Sustentable

Argentina

Consultant

On behalf ofanorganization,group orinstitution

2

The original 10 Reporting Principles have now been regrouped into Key Concepts andReporting Principles.
1) Materiality is also a key reporting principle. In the new in accordance requirement,
companies are to report on topics that they deemed material and only apply thecorresponding GRI standards for the material topics. I can understand why materiality is
put under Key Concepts, but there needs to be a clear reference in the Reporting
Principles section on Materiality. I can only find one reference on line 612 under
Verifiability. I would suggest including a reference to Materiality under Balance andCompleteness.

Simeon Cheng

Hong Kong

Business

As anindividual

Page 3 of 55

3(2) GRI 101 4. Reporting Principles
The section opens: ‘The reporting principles are fundamental to achieving high-quality
sustainability reporting.’ We agree. However, reporting principles needs to cover morethan Accuracy, Balance, Clarity, Comparability, Completeness, Sustainability context,
Timeliness, and Verifiability. These are vital principles about the process of reporting.
They are not adequate to provide full and effective guidance for reporting in its entirety.
Stakeholder inclusiveness remains a concept worthy of inclusion. The assumption of the
proposals is that impact(s) alone are a suitable substitute for materiality. They are not.
Materiality in reporting has developed over the last 25 years in such a way as to include
the values and aspirations of the reporting entity. This cannot be wished away. It isperfectly feasible to include the concept of materiality within GRI while placing greater
emphasis on impact(s). We believe that the concepts of materiality and stakeholder
inclusiveness (suitably updated) should retain their place in the system.

Corporate
Citizenship

UnitedKingdom

No response

No response

4(2) For the reporting principles, compared to current GRI standards, materiality andstakeholder inclusiveness are omitted in this revision. Instead, they are included in Key
Concepts (Clause 114 to 229). With this revision, the original principle “reportingorganization shall identify its stakeholders and explain how it has responded to theirreasonable expectations and interests.” is missing. To a certain extent, the repeatedreporting organizations may already have the awareness to identify stakeholder, but not
for first reporter.

Fuji Xerox(Hong Kong)
LimitedHong Kong

No response

No response5(2) QUESTION 9 POINT 2: The division of GRI’s previous 10 Principles into (a) four
Key Concepts and (b) Principles plus the split of this material between GRI101 andGRI103 makes the standards longer and more difficult to understand. Please canconsideration be given to retaining the previous structure of having
a. Principles of Report Content which would include:
i. The new Due Diligence, Stakeholder and Materiality definitions replacing the existing
Materiality and Stakeholder Engagement principles.
ii. The new ‘Sustainability Context’ and ‘Completeness’ wording.
b. Principles of Report Quality which include, as at present Accuracy, Balance, Clarity,

Hong Kong
University of
Science andTechnology

Hong Kong

No response

No response

Page 4 of 55

Comparability, Completeness, Timeliness and Verifyability (This last previously called
Reliability)
6/"Line 193 & 194 The existing principles of Stakeholder Inclusiveness and Materiality are
no longer presented as standalone principles."Removal of these two reporting principles from existing "report content" is a drasticchange and may confuse users. As " stakeholder inclusiveness" as well as "materiality" arestill important elements of "report content". These 2 principles should still be remaining
in the proposed structure.

International
Development
Center of
Japan

Japan

No response

No response

7

We generally agree with the structural changes, but we think the key concepts could
potentially be placed with relevant sections in the standards (e.g., Impact, Material Topicand Due Diligence may make more sense in GRI 103: Material Topics, while Stakeholder
may belong in GRI 102: About the Organization / Stakeholder Engagement.)

ERM

United States

Consultant

On behalf ofanorganization,group orinstitution

5

2.Impact

6

Please refer to page 8 in the Universal Standards exposure draft.
No. Comment

Organization Country
nameStakeholder Submission
group
type

8

Olaf Brugman

Standard
setter

The guidance or the standard should specifcally define what are negative or adverse
impacts. Because this is not clear and understanding in diferente regions or by diferente
stakeholders may be diferente. For example, to those who see forest as not providing
value, and deforestation as a way to create that, they will see deforestation as something

BrazilAs anindividual

Page 5 of 55

brining positivie economic and development impacts. This may sound amazing, but whata negative impact is just is not clear in many parts of the world. Just provide a list ofsocial and environmental risks and adverse impacts.
9(1) Lines ~142 – 150 GRI should revisit the language around “impact” in light of generalpractice for enterprise risk management (ERM), such as outlined by the Committee ofSponsoring Organizations (www.coso.org) and/or in ISO 31000, and generally familiar tothe compliance, risk management and audit communities. “Impact” is described as anevaluation of severity and likelihood. Many topics do – or could – have impact. This is
RISK. The “impact” is the result of something (a spill causes pollution, a breach of ethics
causes enforcement, using forced labor results in violations of human rights and awfulliving conditions). The material topics (as described in the Universal Standards exposure
draft) is those that do – or could – have the most impact. There is a difference between
reducing existing impact (or the impact of the reporting period) and reducing or
preventing future impacts. Likelihood may be more relevant for positive impacts and forforward looking statements. A GRI report, like a financial report, is backward-looking
and for a defined reporting period. GRI is actually describing a risk assessment
methodology.

DouglasHileman

United States

Consultant

As anindividual

10(1) Within the definition of materiality, I would refer to both impacts and contributions
to sustainable development with some direct reference to the Sustainable Development
Goals. When explaining the concept of impact, both negative and positive impacts areincluded as such, but I believe that the concept of contribution is more extensive.

UN Global
Compact
Network Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

11

impact can also be technological advancement or educational.
The definition of impact does not include the community or host community of theorganisation

VertAfrika
LimitedNigeria

No response

No response

Page 6 of 55

12Another negative effect an organisation can have on people is on their health

VertAfrika
LimitedNigeria

No response

No response

13(1) Material topic - Impact (negative and positive) would be difficult to be brought out.

FridahMashandi

ZambiaNo response

As anindividual

Engagement with stakeholders requires more and it is unlikely that the impact of anorganisation could be derived from such collaboration.
14(2) Impact (negative or positive) would be difficult to be stipulated by organisations.

FridahMashandi

ZambiaNo response

As anindividual15

Box 1 (row 55) explains the importance of reporting on outward impact. I am
concerned that the impact on employees, workers and/or suppliers might not be taken
into account here since they might fall into the category of ‘inward’ impact.

Laurence
Vigneau

UnitedKingdomAcademic

As anindividual16(4) It will be useful to have explanation on what impact outward vs impact inward looks
likes so that users/readers are can understand the distinction and not misunderstand any
inward impact as outward (exposure draft 156-171).

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

17(5) Purpose and impact
We also encourage GRI to make a greater connection in the standards between purpose
and impact. Although the term ‘impact’ is emerging and has several meanings, it is clearthat reporting entities increasingly wish to enhance positive impacts and measure theirimpact more thoroughly. Furthermore, companies are increasingly required to report on
the impacts of their activities – for example, in Europe, through the Non-financial
Reporting Directive (NFRD). We therefore encourage GRI to increase its coverage on
the connection between purpose and a desired impact (i.e. a company’s desired positive
impacts on people, the economy and the planet). We believe this can help to enhance

Deloitte

United States

Consultant

On behalf ofanorganization,group orinstitution

Page 7 of 55

transparency around the objectives and targets set by companies in relation to theirimpacts, in particular by encouraging the use of relevant metrics and targets on those
impacts to underpin long-term purpose.
18(2) The interpretation of impacts is limited to only those that are actually occurring.
Thus, the standards do not address impacts that ought to be occurring, but which may
not be, or impacts that are occurring, but which should be occurring to greater or lesser
extents, or in altogether different ways

7

3.Material topic

8

Please refer to page 8 in the Universal Standards exposure draft.
No. Comment

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

Organization
nameCanadaAcademic

On behalf ofanorganization,group orinstitution

Country

Stakeholder
group

Submission
type

UnitedKingdom

Non-governmentorganization

On behalf ofanorganization,group orinstitution

General comments (supportive, opposed, or other)19(1) We welcome the focus on impact as part of the material topic definition.
The avoidance of a focus on stakeholders within the definition should also
remove the potential bias experienced to date by allowing companies to focus onmaterial impacts to a specific group of stakeholders, which may not be
representative of a collective outlook.

BirdLife International

Page 8 of 55

20(2) We are pleased with the focus on material impact, as this should improve theaccountability and transparency of GRI reporting.

BirdLife International

UnitedKingdom

Non-governmentorganization

On behalf ofanorganization,group orinstitution

21

As a reporter: We do not anticipate any major changes to our identified material
issues. There are clear dependencies between stakeholder expectations andissues that can impact economic conditions, environment and the society.
No major changes expected. The new GRI Standards adopts a stakeholderfocused approach on impact identification, consistent with the previous
standards.

Bursa Malaysia

Malaysia

Stock exchange

On behalf ofanorganization,group orinstitution

22(1) Materiality
Deloitte welcomes the updated definition of materiality. Whilst we recognize it
was always GRI’s intent to focus on reporting impacts of the business on society,the economy, and the environment rather than impact on the business, we thinkthe updated definition makes it explicitly clear to reporters. We also see that thisdefinition is consistent with the positive and negative impacts that companies canmake towards the United Nations’ Sustainable Development Goals.

Deloitte

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

DQS CFS

Germany

No response

No response

In applying materiality, we also believe that the stakeholder influence axis in themateriality matrix that has been applied to date had the potential to double
weight stakeholder feedback as stakeholder perceptions could be used as a proxy
to determine the significance of impact, rather than the scale of impacts of the
topics in their own right.
23

Enormous improvement! Many reporting organisations applied the concept ofmateriality in the wrong way. Focusing solely on Impact will make it easier tounderstand.

Page 9 of 55

24(1) ERM CVS agrees with the standard revision that focuses on impact-based
reporting, by giving importance to material topic identification vs focus on reportcontent, as this is beneficial for ensuring relevance throughout the report. We
agree that impact driven reporting is a good direction.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

25(1) Generally, we are supportive of these changes and the general shift to impactbased reporting.

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

CanadaAcademic

On behalf ofanorganization,group orinstitution

26(2) I appreciate the more focalization on impacts and the elimination of double
criteria (no more materiality matrix)

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution

27(1)Agree with the update.
Organizations' board should be responsible for determining topics that are
sufficiently important and with significant impacts.

Fuji Xerox (HongKong) Limited

Hong Kong

No response

No response'Influence on the assessments and decisions of stakeholders' should not bestandalone factor to determine whether a topic is material. This can ensure
stakeholders' feedback are considered, that organizations do not only prioritize
issues highlighted by stakeholders, but also taking importance to the company
into account.

Page 10 of 55

28(4) • Line 171: “The material topics identified using the GRI Standards need to beprioritized in their own right and cannot be deprioritized on the basis that they
are not financially material.” We fully support this principle that materiality is far
wider than financial, affecting sustainability, reputation, social license to operate
and ethical governance and that social issues must be properly prioritised.

Institution of
Occupational Safety
and Health (IOSH)

UnitedKingdom

Other (please
specify): Chartered bodyfor OSH
Professionals

On behalf ofanorganization,group orinstitution

29

It’s a welcome development from a multistakeholder perspective but it could
create the impression among investors that these disclosures are not material tothem. That said, the EU SFDR regulation also follows as this logic of relevant
disclosures (identified as principal adverse impacts) so the new approach could
resonate well with European ESG imvestors.

Eszter Vitorino

Netherlands

Investor

As anindividual30

The change of focus for material topic is absolutely key.

Not applicableFranceNo response

No response

If we consider sustainability as a global concern that requires collective efforts
and thinking, stepping out of the company's internal system view and leadingthem to see them as only part of a global system is fundamental. It also boradens
the scope of innovation for the companies themselves and should lead them tobetter decision in consideration of more elements than just thinking from theirown points of view.
31

Revisions make the definition of Material Topic more succinct, a greater focus on
impact will help to identify better the keys areas needed.

Tang Lien

Malaysia

Consultant

As anindividual32

I agree with the change for clarity. There were companies in the past that
construed it to mean "impact on the company".
The Phil. Code of Corporate Governance for PLCs is also based on the OECD
Governance Principles so this is okay with me.

Justina Callagan

Philippines

Business

As anindividual

Page 11 of 55

33(1) Materiality: Bringing impact earlier in the sentence emphasises why impact isimportant.

SAICA

South Africa

Non-governmentorganization

On behalf ofanorganization,group orinstitution34(1) We believe that the modification of the concepts of materiality andstakeholders is correct.

Sustenia

Argentina

Consultant

On behalf ofanorganization,group orinstitution

35(1) Really like the drive for impacts on the economy, environment and people will make it more challenging for companies that now take the opposite
perspective (impact on the company).

Marjolein Baghuis

Netherlands

Consultant

As anindividual36(1) I think it is a good evolution of the GRI Standards to focus on externalconsiderations of impact and is clearly responding to reporters who haveinterpreted the material principle as being about impacts on the organisation.

Think Impact Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

37(1) Based on the number of materiality definitions from a corporate reporting
standpoint, the key concept revisions identified above are relevant and needed.
It's vital that an organization maintain the focus of their report on material topics
which externally impact the economy, environment or people. It's common formaterial topics to be defined in relation to financial impacts and how
sustainability affects the organization itself but this revised definition makes it

University of DenverUnitedStatesNo response

No response

Page 12 of 55

pretty clear cut. "Does it affect the economy, environment or people?" Yes orNo.
38(2) WBA supports the focus on impact in materiality, as this shifts the focus
towards understanding business’ externalities; it will support a better
understanding of business’ impact on all aspects of sustainable development. It
also helps to bridge the gap between the concept of salience in human rights risk
assessments and materiality under GRI, bringing better alignment with the UN
Guiding Principles on Business and Human Rights. Shifting companies to better
understand, manage and report their external impacts will support WBA’s own
benchmarking efforts.

World
Benchmarking
Alliance

Netherlands

Other (please
specify): Benchmarking
foundation

On behalf ofanorganization,group orinstitution

39(1) I believe the new materiality definition focusing on impacts is positive.

Beyond Business Ltd

IsraelNo response

On behalf ofanorganization,group orinstitution

40

Support these changes and I think they make the process more useful toreporting companies and in line with best practices.

Alexandra McKay

UnitedKingdom

Consultant

As anindividual

41

Agreed.

Hui XuChina

Non-governmentorganization

As anindividual42

in agreement

Bank Audi sal

LebanonNo response

No response

43

ok

BSI Group

Italy

No response

No response

Page 13 of 55

44

The updated definitions of materiality and stakeholders are very helpful and bringmore clarity.

CSRWorks
International

Singapore

No response

No response

45(1) The Danish Institute for Human Rights (the DIHR) welcomes the proposal tochange the definition of materiality and stakeholder to allow for better alignmentof these concept with internationally agreed standards on business and humanrights and responsible business conduct. We positively note that the current
draft clarifies the connection between the term material topic and impact,
including adverse impact. We further find the clarification provided around how
material topics can include impacts across all three sustainability dimensions
helpful and are hopeful that this may promote more holistic reporting, e.g. ofhuman rights concerns associated with environmental impacts.

Danish Institute for
Human Rights

Denmark

Other (please
specify): national humanrights institution

On behalf ofanorganization,group orinstitution

46

Support these revisions and alignment with other frameworks.

Dow Inc

UnitedStatesBusiness

On behalf ofanorganization,group orinstitution

47

Agree

Gazprom Neft PJSC

RussianFederation

No response

No response48

I support these proposed revisions, as they connect actual behaviour and impactsof reporting companies to their actual impacts and consequences. And also
because they connect actual behaviour and impacts with widely accepted soft law
frameworks such as those from the OECD.

Olaf Brugman

BrazilStandard setter

As anindividual49

We agree with the definitions.

Hong Kong Instituteof CPAs

Hong Kong

Professional
Accountancy
Body (including

On behalf ofanorganization,
Page 14 of 55

United
Kingdom

regulator andstandard setter)group orinstitution

Other (please
specify): Chartered bodyfor OSH
Professionals

On behalf ofanorganization,group orinstitution50(1) While IOSH generally welcomes the changes to the definitions for'stakeholder' and 'material topic'

Institution of
Occupational Safety
and Health (IOSH)51

The revision of key concepts is generally welcomed by the ICMM since they
evolved from the current Standards and are now focused on outward impacts.
The new focus on impact is in line with international trends and supports theintention to generate positive, measurable social and environmental impact
alongside a financial return. Understanding how these concepts are used in theStandards is essential for reporting as well as interpreting the information
reported using the GRI Standards.

International Council Unitedon Mining and Metals Kingdom(ICMM)

Trade orindustry
association

On behalf ofanorganization,group orinstitution

52

In agreement with the revisions

R&A Strategic
Communications

South Africa

No response

No response

53

OK, no comments

SAI Global Italia s.r.l.

Italy

No response

No response

54

Good explanations.

Shelley Anderson

Australia

Consultant

As anindividual

55

This is clearer and more balanced

SM Investments
Corporation

Philippines

Business

On behalf ofanorganization,

Page 15 of 55

group or
institution
56

We welcome these revisions. We note the removal of the influence on
assessments and decisions of stakeholders as a standalone factor in determining
whether a topic is material. We feel the revised definition better aligns with anorganizational focus on its impact on achievement of the SDGs.

United Nations
Development
Programme (UNDP)- SDG Impact Team

UnitedStatesUN body

On behalf ofanorganization,group orinstitution

57

I agree with the above revisions.

Eko Sukoharsono

Indonesia

Academic

As anindividual58

All fine.

ValoraSwitzerland

No response

No response

59

I agree with the definitions proposed for 'Impact' and 'stakeholder' and hence thedefinition of 'material topic'.

Hong Kong
University of Scienceand Technology

Hong Kong

No response

No response

60(1) We welcome the GSSB’s proposed revisions to the GRI’s Universal
Standards, which include a clarification of the focus of the GRI standards, revised
definitions of key concepts such as ‘impact’, ‘material topic’ and ‘stakeholder’, and(2) a proposal that companies reporting in accordance with the standards will nolonger have a choice between ‘core’ and ‘comprehensive’ options. We believethese proposed revisions will contribute to more comparable and comprehensive
sustainability reporting by companies.

NBIM

NorwayNo response

No response61

As we understand your argument to prevent a bias we still see it critical to erase"influence on the assessmenents of decisisions of stakeholders" from thedefinition. The main reason for us is, that stakeholder inclusiveness would form

akzentekommunikation undberatung gmbh

Germany

Consultant

On behalf ofanorganization,

Page 16 of 55

part only of the guidance and with this is not longer an requirement and in anassurance scope.
62(1) Corporate Citizenship notes the intention to shift the emphasis in GRI
towards the Impact that reporting organisations have. We have two significant
criticisms of this.

group orinstitution
Corporate
Citizenship

UnitedKingdom

No response

No response

Dr. Aljaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

Firstly the means proposed to achieve this cut out any consideration of thevalues, tradition, history and aspirations of the reporting organisations. This is agrave and unnecessary error. In reality these will exercise significant influence
over how the reporting organisation decides in real-time what the most material
issues are.
63(1) The revisions on the definition of the material topics seem to eliminate thesignificant role of stakeholders in the identification of material topics. Although
GRI 103 elaborates on the role of stakeholders, the removal of the 'substantively
influences the assessments and decisions of stakeholders' signal that the process
is developed and largely determined by the organisation itself.
The revision on 'material topic' is one that has the potential to introduce
problematic practices and reduce the role of stakeholders in building thesustainability reports. Extent research in social and environmental accounting
already points to the limitation of the current definition of material topics andthe role of stakeholders.

64(1) We dont see a good reason to revise these 2 fundamental concepts.
The assessment from the stakeholders should be explicitly mentioned and theirpriorities too. Two-dimensional matrix preferable as it shows the assessment of
the stakeholders.

Page 17 of 55

65(1) The stakeholder process is already the weakest part of most reports. It isdone superficially and with limited resources. When omitting 102-44 of the 2016
standards and reshaping he materiality matrix (not showing the results of the
stakeholder consultation process) then the whole concept of SE will be
weakened.;

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

66

The influence on stakeholder decisions was never a standalone criteria formateriality but it showed the importance of consulting stakeholders besides
identifying impacts. I believe taking it out of the materiality definition could leadcompanies to engage less with stakeholders.

BSD CONSULTING

BrazilNo response

No response

As mentioned before, the lack of the criteria "influence on stakeholders
decisions" could lead companies to engage les with stakeholders. Also, theprinciple of Materiality and Stakeholder Inclusiveness are out - which makes it"less relevant" for the standards.
67(1) Reporting principles for materiality and stakeholder inclusiveness should be
retained as is. More clarity and guidance on how to engage stakeholders rather
than demoting their importance is a better approach.

ISOS Group

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

68(2) MT: This revision creates more confusion as it refers to the TBL
People/Planet/Profit.

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

Page 18 of 55

69

The new definition of "material topic" based on outward impacts positions the
GRI Standard as the standards specializing in the "environmental and social" sideof double materiality. In a way, this stance seems to imply that any company
wishing to adopt a full double materiality perspective will need to use GRI in
conjunction with another standard reflecting financial materiality (e.g. SASB).

Datamaran

UnitedStatesOther (please
specify): - digitalplatform

On behalf ofanorganization,group orinstitution70(2) "Materiality" under the context of GRI Guidelines and Standards has been
known to be concerning impact of a particular ESG topic. So we are notsurprised with this clarification. Yet, this clarification has further made GRI a
more 'social responsibility' reporting framework, while our sense is that nonfinancial risk based reporting (frameworks that emphasize ESG being risk factors)
are better accepted by Asian companies with more compliance or capitalmarket-driven mindsets. This revision is making GRI Standard more niche in Asia.

Marcus Chau

Hong Kong

Consultant

As anindividual

71(2) The concept of material topic can be included in a specific section of the firstStandard in order to stress the fact that reporting on material topic is an
essential step of using GRI Standards.

Alessandro Mantini

Italy

Business

As anindividual

72(1) For the revised definition of material topics, to include an explanation or
guidance as to how “governance” is included as well. Financial institutions,investors and ESG ratings adopt the term “ESG” frequently. This would assist in
ensuring alignment between material topic definition and ESG rating
requirements or expectations.

RHB Bank Berhad

Malaysia

Business

On behalf ofanorganization,group orinstitution73(3) Material topic: this definition could be linked with risk management or
analysis, as also with due diligence definition. The risk management should be
relevant to this kind of analysis. Leaving the stakeholders valorization on material
topics as a standalone factor could be ok, but should be clarifyed that still is in
the materiality analysis (the change is the way of exposure)

AG Sustentable

Argentina

Consultant

On behalf ofanorganization,group orinstitution

Page 19 of 55

74(9) ‘Real’ Materiality definition: (2568) “The significance of an impact is the solecriterion for determining whether a topic is material to report on.” Disclosed
materiality becomes a function of significance. There is a difference between
material impacts and disclosed material impacts.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Non-governmentorganization

On behalf ofanorganization,group orinstitution

75

Agree with expanding the definition of materiality to focus on impact to theorganization

Toronto Pearson
AirportCanadaBusiness

On behalf ofanorganization,group orinstitution

76

Minor changes observed. Insignificant impact to sustainability disclosure.

DRB-HICOMBerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

77

Updates to the concepts seem to us

Ilunka, Estrategia
Sustentable

MexicoConsultant

On behalf ofanorganization,group orinstitution

Suggested additions/revisions
78

Additional guidance will be needed to assist companies using more robustmateriality frameworks (SASB, TCFD) to transpose the results to the morenarrowly focused GRI materiality framework. While the GRI revisions provide
clarity in conducting a designed-for-GRI materiality assessment, the revision

Josiah McClellan

United States

Business

As anindividual

Page 20 of 55

create more confusion when transposing a different materiality framework. For
example: a company that is highly dependent on a nature based resource forgenerating revenue and is sustainably managing that resource; however, otheractors are using that resource irresponsibly - it is not clear how this would playin the GRI framework. It is also difficult to envision how scenario planning will bea useful activity in the new GRI definition of material topic, where it remains avaluable activity with SASB and TCFD. Additional guidance will be critical toensure that experienced reporters can continue to conduct robust materiality
assessments not necessarily designed specifically for GRI, while being able toreport in accordance with the standards.
79(1) In the “impact” and “material topic” definitions, I suggest putting “society”
instead of “people”, because I think the definition of “society” implicates cultural
aspects too. Although, in some circumstances, the term “people” may beunderstood as a synonymous of “society”, I think that the definitions also musttake into account the Triple Bottom Line approach that considers economic,
social and environmental aspects to evaluate the sustainability. So, to be aligned
to the TBL approach, I consider that the term “society” is better adjusted to the“social” aspect than the term “people”.
Hence, I propose the following definition for Impact:“The effect an organization has or could have on the economy, environment, or
society, including on human rights, as a result of its activities or business
relationships”.

No response

Peru

Academic

As anindividual80(2) In the “material topic” definition, I also suggest considering the term
“represents” instead of “reflects”, to make the definition easier to understand forthe entrepreneurs.

No response

Peru

Academic

As anindividual

For the above mentioned, I propose the next definition for Material Topic:

Page 21 of 55

“Topic that represents the organization’s most significant impacts on theeconomy, environment, and society, including impacts on human rights”.
81(1) /Line149-line154,not easy to comprehend, plain English is preferable.

International
Development
Center of JapanJapan

No response

No response82

In the definition of material topics I miss 'society' more in general.

Bondt
Communicatie

Netherlands

No response

No response

83(2) We note the efforts made in Box 1 (l155-171) to provide clarity around how
the GRI definition of material topics relates to other definitions of materiality
including financial materiality. We are however concerned that existing
connotations around materiality in the context of corporate reporting willcontinue to influence how organizations, initially, understand material topics andthe related requirements. We therefore recommend that box 1 more explicitly
provides detail on how material topics as defined in the new Standards relate toand differ from previous / alternative uses of materiality in the context ofreporting and considers referencing the concept of double materiality to makemore clear to the reader the change in perspective introduced with the definitionof material topic.

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

84(3) Lines 156 – 171 (p. 9) GRI should clarify the objective of Box 1, aligning
content with the objective. This commenter has offered three suggestions forBox 1 on three different topics: the concept of “materiality”; the lack ofenvironmental and people/ human rights examples of material impact, andnegative and positive impacts and how the examples apply to different reporting
periods.

Douglas Hileman

United States

Consultant

As anindividual

Page 22 of 55

85(3) Lines 156 – 171 (p. 9) Box 1 uses an example of actual impact for the current
reporting period (contribution of emissions to climate change) and a future(potential increase in operating costs), which applies to a future reporting period.
GRI should explain differences in reporting periods (where used in discussion),or consider other examples, or whether examples are appropriate.

Douglas Hileman

United States

Consultant

As anindividual

86(3) Lines 156 – 171 (p. 9) GRI should include examples of material risks relevantto the environment and people/ human rights in the discussion in Box 1. The
discussion in the exposure draft calls out “financially material risks”.

Douglas Hileman

United States

Consultant

As anindividual

87(4) However, we note that that the definition of ‘material topic’ still favors andprioritizes the financial & economic impact, at least in order of the listed impacts.
Therefore, we urge to revise the definition as follows:

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

CanadaAcademic

On behalf ofanorganization,group orinstitution‘topic that reflects the organization’s most significant impacts on theenvironment, the people (including impacts on human rights) and the economy’88(1) Line 139 - I recommend to underline the words "most significant"
impacts.(My two arguments: 1) Big companies tend to focus on impacts that are
not always the most significants regarding the sustainability development. 2) Small
companies - that use the GRI Standards for the first time - coud be discouraged,
if they don't understand that the reports should first of all focus on the significant
impacts.

FOM University ofApplied Sciences

Germany

No response

No response

89(2) Line 151. You use the word "scope". In my lectures, I think the differentiation
between direct and indirect emission sources (scope 1, 2 and 3) from the GHG
Protocol very useful. You could perhaps add an hyperlink to the same word to alater session (material topics) and point out to the current division in three
scopes.

FOM University ofApplied Sciences

Germany

No response

No response

Page 23 of 55

90(1) “Material topic” (lines 137 - 171) there should be a note to say that although
a company may identify a material topic in its own evaluations, it needs to beaware of the fact that other material topics may come to light during due
diligence that are raised by rights-holders themselves as well as by informed civilsociety organisations on the ground, nationally and internationally.
It is recommended that in line 153, the following sentence be added: "In assessing
the significance of its human rights impacts, the organization should give special
emphasis to the priorities raised by rightsholders themselves as well as byinformed civil society organisations on the ground, nationally and internationally.”

Forest Peoples
Programme

No response

No response

No response

91

DELETE: For example, an organization’s high use of non-renewable energy
contributes to climate change and could at the same time result in increased
operating costs due to legislation that seeks to shift energy use toward
renewable sources.

Hong Kong
University of Scienceand Technology

No response

No response

No response

92(2) IndustriALL remains concerned that the word "materiality" is universally
understood in the financial and business community in a very narrow sense;
which despite GRI's attempt to broaden it to reflect outward relevance, is likely
to create some level of confusion. Nevertheless, a genuine assessment of“impacts” will always identify employment and workforce issues as a material
topic, which includes employment in the organization’s value chain as well as
within the organization.

IndustriALL Global
Union

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution

93(2) The text around identifying material topics is broadly supported, although
IndustriALL remains concerned about potential confusion in using a word that isunderstood in a very different, and narrow, sense in the financial/management
community.

IndustriALL Global
Union

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution

Page 24 of 55

94(1) The definition of 'material topic' is better understood by users by adding'social'⇒‘topic that reflects the organization’s most significant economical,
environmental, social impacts as well as impacts on people, including impacts onhuman rights’.

International
Development
Center of JapanJapan

No response

No response95(2) /Line233-235,A. Reporting in accordance with the GRI Standards: The
organization uses the set of GRI Standards to report on its most significant
impacts on the economy, environment, and people, ⇒also preferable to addsocial, as many entities or organization including SMEs are keen on meeting their
ESG needs.

International
Development
Center of JapanJapan

No response

No response96(4) (2632) There is confusion here regarding the term material. ‘material toreport’ is referred to before as ‘prioritized to report’. This is a different
understanding of materiality. It is recommended to only use materiality following
one definition to avoid confusion.

Network for
Sustainable Financial
Markets CIC

No response

No response

No response

97

Materiality Perspectives: Still not absolutely clear, how GRI-approach toMateriality works together with "outward materiality" (e.g. necessary for NFDDirective)

triple innova

Germany

Consultant

On behalf ofanorganization,group orinstitution

98(2) Although I know it is outlined in GRI 103, I do strongly recommend a clearer
definition here in stating that the impacts include positive, negative, actual andpotential impacts outwardly because as as it stands, can be left open tointerpretation and superficial materiality assessments. It also creates a separationof identification of impacts from identification of stakeholder views.

University of DenverUnited States

No response

Page 25 of 55

99(2) Specifically, line 149 could cause confusion between actual and potential
impacts. Section 2 clearly makes a distinction between actual and potential
impacts. This distinction should also be clear also in section 2.2.

World BusinessCouncil for
Sustainable
Development

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

100(2) Impact: We understand that the impact is outward and inward. But GRI is
focussing in the generated impact and not to the received impact fromstakeholders. This concept should be clarified to understand that focus. We also
believe that the impact received should be also considered.

AG Sustentable

Argentina

Consultant

On behalf ofanorganization,group orinstitution

101(2) However, I suggest wording : impacts on people, planet, communities andeconomies. I do not think it is necessary to specifically call out human rights inthis definition. Impacts on people and communities includes human rights. But
people could be construed as individuals, where in many cases, companies arecentral players in local communities and economies, which specifically refers togroups of people, so I think this should be more explicit.

Beyond Business Ltd

IsraelNo response

On behalf ofanorganization,group orinstitution

102(2) However, the COVID19 pandemic has brought economic and social turmoil
and tragedy, bringing a new dimension to risk, impact and responsibility regarding
nature – the world must halt the loss of biodiversity and put nature on a path torecovery by 2030. We would therefore like to see a specific mention of nature(biodiversity and ecosystems) in the new materiality definition, accompanying theaddition of human rights: ‘topic that reflects the organization’s most significant
impacts on the economy, environment, and people, including impacts on humanrights AND NATURE’.

BirdLife International

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 26 of 55

103(1) Material Topic: an addition would be made to that definition to be as follows:"topic that reflects the organization's (measurable) impacts on the economy,
environment, and society.
*Justification: having a measurable impact facilitates the evaluation process forsustainability performance, allows benchmarking and so that measuring
improvement levels, facilitates the external assurance task, easily understandable
and more legitimate for the stakeholders, helps in uncovering disclosuremanipulations and thus demonstrates whether or not, the organization is moving
towards achieving Sustainable development goals.
*In a relevant vein, disclosing measurable (quantitative) information in thesustainability report is considered as one of the important criteria for a highquality Sustainability Report (Hammond and Miles, 2004). firms disclosesustainability information in format that fits the quality requirements of its
stakeholders (Ane, 2012). Stakeholders prefer that type of sustainability
information reported in a quantitative, measurable format, as being perceived bythem as easily understandable, verifiable and comparable. (Wijk and Persoon,2006).
References:
Abdelrahman, N. (2018). Features Affecting the Quality of Sustainability
Reporting: an Empirical Study and Evaluation. International Journal ofManagement and Applied Science, 4(5), 36-47.
Iatridis, G. E. (2013). Environmental disclosure quality: Evidence on
environmental performance, corporate governance and value relevance.
Emerging Markets Review, 55-75.
Ane , P. (2012). An Assessment of the Quality of Environmental Information
Disclosure of Corporation in China. Systems Engineering Procedia, 420-426.

Noha Abdelrahman

Egypt

Academic

As anindividual104

The proposed change in the definition of a material topic focuses principally on
impacts on the economy, environment or people, without parallel considerationof stakeholder perspectives. Stakeholder input is then proposed to be sought
after this initial identification of actual or potential material impacts. This reduces

CDSB

UnitedKingdomStandard
setterOn behalf ofanorganization,

Page 27 of 55

the ability to concurrently consider materiality from the perspective of impact on
the organisation’s own enterprise value creation, the typical basis for determining
materiality within financial accounting standards. We believe that this creates therisk of reducing connectedness between financial and non-financial reporting. The
previous definition employed under the GRI Standards, which explicitly
incorporated stakeholder views, provided a direct means by which investor
perspectives could be integrated into the determination of material sustainability
topics, alongside the views of wider stakeholders. Accordingly, this supported
organisations to also consider a financial materiality perspective in theirsustainability disclosures, supporting greater connection between financial andnon-financial reporting.

group orinstitution

CDSB therefore believes that to promote greater interconnectedness between
financial and non-financial reporting, the materiality definition should explicitly
consider financial materiality, i.e. impacts on an organisation’s own enterprisevalue creation, in addition to impacts on the economy, environment and people.
This would help to ensure that disclosures prepared using the GRI Standards canbe used to identify the sub-set of wider sustainability information that is material
for enterprise value creation and thus of relevance for disclosure to investors via
the mainstream report.
105(1) (Note all line numbers mentioned in the response refers to the exposure
draft unless otherwise stated)
Section 2.1/2.2 (line 93-95, 166-167)- GRI proposes that a materiality assessment for the purpose of the Sustainability
Report (SR) should focus on an organisation’s outward impacts, while thosesustainability issues that impact on the company itself should be reported in the
Integrated / Annual Report instead. We are of the view that this approach does
not support companies to develop a SR that conveys a more holistic
understanding of how sustainability is embedded into general business strategy. It
is considered best practice to integrate material ESG topics into risk management

CLP Holdings Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

Page 28 of 55

processes and/or business strategy (see COSO/WBCSD guidance). Therefore,
the issues that impact the company should be considered as priority whenassessing materiality and thereby managed and reported on accordingly. And it isthrough this process where operational performance is tracked and managed
better that consequently we expect this to influence how a company creates
positive impact outwards.
106(2) Materiality
We recognize the need to uphold human rights and eradicate their abuse, andsupport global efforts that support this goal. As such, we support the inclusion ofhuman rights within GRI’s proposed definition of materiality, as it is a nondiversifiable risk that affects all industries, and therefore requires special
attention. However, we also believe that climate change is a universal, nondiversifiable risk (as set out by TCFD) that not only affects nearly all industries,
but leads to multiple impacts within society, the economy and the environment.
As a result, we believe climate change should be specifically included alongsidehuman rights within GRI’s definition of materiality.

Deloitte

United States

Consultant

On behalf ofanorganization,group orinstitution

107(2) Lines 156 – 171 (p. 9) “Materiality” as defined by the US Supreme Court for
purposes of financial reporting and disclosures is if an (actual or prospective)
investor would reasonably want to know the information to incorporate intoher/ his decision-making process. GRI should consider adopting more of thisconvention, using the criteria of whether stakeholders reading the GRI report
would want to know the information in order to make decisions about theorganization. GRI’s use of “materiality” differs from its use in financial reportingand financial disclosures. The discussion also calls out “financially material risks,
making it even more essential to users of GRI and financial reports anddisclosures to be able to rely on a consistent concept. GRI’s general intent is to
move towards aligning the various reporting frameworks. Given that financial
reporting and financial disclosures drive the economy (and have a long head

Douglas Hileman

United States

Consultant

As anindividual

Page 29 of 55

start), DH suggests they should adopt these definitions and concepts where
possible; if they use them different ways, they should clearly say so.
108

The overall intention with the revision of the standards – to strengthen the focus
on outward impact – is laudable; sustainability reporting has played, and is playing,a key role in helping societies, companies, shareholders and other stakeholders
not only to understand the impact companies have on society, but also tofacilitate a systematic way of addressing this impact. In many ways thestrengthened focus on impact, and the suggested changes to the definitions ofmateriality and stakeholder as a consequence, is therefore logical.

Enact Sustainable
Strategies

SwedenConsultant

On behalf ofanorganization,group orinstitution

On the other hand, the suggested development in moving the GRI Standards
away from the idea of integrated thinking and integrated reporting. How thereporting organisation itself is affected by society and external interests is nolonger a vital part of the standards. Business risks, business opportunities andhow the business strategy is linked to sustainability is not an essential part ofwhat should be reported on. And yet, many of us believe that this is precisely
what we need to see more of. Where and how should this be shared with
relevant stakeholders?
We therefore question if this is the best route to take. By doing so, reportingorganisations will need to use or establish additional frameworks along with GRI
Standards in order to demonstrate the consequences of current and potential
inward impacts (e.g. climate change, water scarcity, corruption or lack of respectfor human rights).
The suggested change will most likely make the GRI Standards less interesting formany small as well as large companies, since their interest in sustainability is often
intricately linked to business opportunities and business risks. They need to show
both an internal and an external audience how they are able to meet increased
external attention with integration of sustainability, leading to increased businessvalue, and thereby present how they adapt to changes in their surrounding

Page 30 of 55

society (inward impact) and the steps they have taken to mitigate inward risks
affecting the business negatively.
A sad but direct consequence is that the GRI standards will no longer be thenatural framework to use when implementing the Integrated Reporting <IR>
framework; the Integrated Business Model thinking that <IR> is based onrequires an organisation to manage and report on inputs as well as outcomes –and the steps in between – whereas the suggested revisions will make a GRI
Standards report focus primarily on the outcomes and the impacts.
Instead, a GRI Standards report will be a kind of condensed, combined
environmental and human rights impact assessment report. It will be perfect as atool to demonstrate compliance to external parties (e.g. investors), but muchless valuable for managing and driving development based on sustainability related
business risks and opportunities and generate lasting change.
109(1) We have some concerns on the revised materiality process.
First of all, it seems that the proposed process would not be aligned with the"double materiality" definition envisaged by the European Directive on Non
Financial Reporting.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

110(2) For the definition of material topic, we generally agree with the direction, as
it is less subjective, but we ask that GRI explain the following components about
how companies should determine "impact": Does a topic need to be included in acompany's enterprise risk assessment to be considered as material? How does
impact to a company's financial performance get incorporated into theassessment, or is financial materiality not relevant for GRI? It seems that acompany's financial performance should be a key contributor to sustainable
development.

ERM

United States

Consultant

On behalf ofanorganization,group orinstitution

Page 31 of 55

111(3) but I think that there is some risky ambiguity and overlapping in the conceptsof “impact” and “topic”. In my opinion at lines 2565 and 2566 it is not sufficiently
clear how, when and even why it is requested to shift from “impacts” to “topics”.
I’m afraid that to suggest to aggregate impacts in topics may lead tomisunderstanding. An organization could have differents impacts with different
relevance levels related to the same topic. The most relevant ones should be
depeen in the Sustainability Report, the other ones not. Fusing the impacts in aunique topic could make this important differences lost and make theorganization think to have to report all the impacts related to a topic, even theless relevant. Therefore, my proposal is to eliminate the concept of topic and use
only the one of impact. “Material impacts” should be reported, not “material
topics”. Material impacts in my opinion should be defined as the organization’s
most significant effetcs on the economy, environment, and people, including
impacts on human rights’.

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution

112

The document has singled out human rights, yet it is not clear how the additionof the word will change organisational behaviour. It does not give justice to thedepth of sustainable development which includes many other aspects, including
human rights.

Dr Aljaohra
Altuwaijri

No response

Academic

As anindividual

113(2) we would suggest that the latter reads "topic that reflects the organization’s
significant impacts on the economy, environment, and people, including impacts
on their safety, health, wellbeing and human rights". We believe this would help
emphasise important OSH issues as material topics.

Institution of
Occupational Safety
and Health (IOSH)

UnitedKingdom

Other (please
specify): Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution

114(3) Impact should not only focus on an organization’s outward impact but should
also remain focused on the impact from stakeholders and society at large on theorganization itself. This ‘two-way street’ will enable companies to use the

ISOS Group

United States

Consultant

On behalf ofanorganization,

Page 32 of 55

standards as an important management tool that provides and creates value
beyond reporting compliance.

group orinstitution

115(2) For the same reason, as far as material topic definition is concerned I would
have avoided to add a specific stress on impact on human rights which can bebrought back to impacts on people. As there are many prepares (especially indeveloped countries) for which impacts on human rights are not material (due tothe presence of a working and effective regulatory framework), the introductionof this specific measure facing a principle-based approach could be redundant.

Alessandro Mantini

Italy

Business

As anindividual116

We agree to have a focus on “impacts” as it might also further helps companies
to report on how they contribute to the realization of one or more SDGs.
However, we believe that there is a need to clarify the “nature” of the impacts
on a long-term perspective (as defined in the OECD Guidelines) and maybe
explore possible ways to align this definition to recent developments related tofinancial stakeholders’ due diligence expectations (ESG factors). This might also
better guide companies in developing a methodology to identify positive and/or
adverse impacts (and their potential linkages) on economy, environment, people,
including human rights (in line with the OECD Guidelines and the UNGPs).

MSC Mediterranean
Shipping Company
S.A.

Switzerland

Business

On behalf ofanorganization,group orinstitution

117(1) The definition of sustainability set out in lines 31 – 43 underpins the standards
and we support the approach adopted to require organisations to consider both
positive and negative impacts.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

The underlying definition is based on the triple bottom line. Whilst profit, people,
planet – or economy, environment, and people (EEP) – is a good point to startfrom, it is very vague and opens the door for impression management. Thismeans that it leaves room for companies to evade the spirit of the GRI standards
and present themselves in the best possible light, whilst still meeting thestandards. In the amendments this room is reduced due to the introduction ofreferences to ‘human rights’. However, it is not clear why the issue of humanPage 33 of 55

rights was picked, whilst at the same time many other issues are being
overlooked.
It would be more suitable to refer companies to the Sustainable Development
Goals (SDGs) and ask to use the SDGs as a framework for reporting – 17dimensions plus profit / economy. Given the explanatory material and the clear
definitions throughout the indicators the room for impression management
would be reduced. This would mean that the spirit of the GRI standards and thetext of the GRI standards would be further aligned.
118(2) In regards to the aforementioned four directions: In the definition there
seems to be a focus on the negative and positive impact of companies onsustainable development. However, it is not mentioned in the definition or in theamendments that there is an impact of sustainability on the company. For
example, climate change will have an impact of a company, so will biodiversity
loss through increases in zoonotic pandemics – like Covid19. It is crucial toexpand the current one-dimensional relationship – company on sustainability
issues – to a two-dimensional relationship – company on sustainability issues andvice versa.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Furthermore, and especially in the light of the materiality discussion, it is essential
to consider the positive as well as negative directionality of this relationship. For
example, the impact of climate change issues on video conferencing service
providers will be positively material, whilst it will be negatively material for a
fossil fuel company. This would result in a four-directional analysis: positive &negative plus company on sustainability issues and vice versa.
In combination with an SDG approach to sustainability we recommend to ask
companies to reports on GRI using a four directional and 17dimensional framework. This will close loopholes and bring the spirit of theamendments even closer to the text of the amendments.

Page 34 of 55

Furthermore, there needs to be a clear definition of what materiality means interms of an GRI report, i.e. what underlying definition does an issue have tomeet to be disclosed in a report that is in alignment with the GRI standards. Inline 2568 the ‘real’ materiality definition seems to be presented: Materiality
evolves into disclosed materiality, which becomes a function of significance.
There is a difference between material impacts and disclosed material impacts.
119

A GRI Technical Committee on Human Rights Disclosure is inevitably going to
Next Level
want to emphasise human rights in the definition; but if there was a TC on
Sustainability
Climate Risk it might put a global heating augmentation onto 'environment' andso on. Best to have a principle of weighted equality in the definition: economy,
environment and people. Since the new definition changes ‘society’ to ‘people’that should be the compromise with explanatory text on human rights includedin the Universal Standards and topic specific standards elsewhere.
Concern: The new definition of material topic skews the whole emphasis of the
GRI Standards towards a human rights framework which is inconsistent with thetriple bottom line intent. The emphasis on "impact on human rights" is out of
proportion to what might be material in a given jurisdiction, and potentiallymarginalises environmental impacts such as climate change (global heating) as amaterial issue. The new qualification of ‘society’ defined as ‘people’ creates animmediate conflict between environmental impacts and people impacts because
human rights proponents could then use arguments to trump environmental
concerns within the definition. The ‘people' and ‘human’ rights impact now
outweighs the 'environment' impact by 6 to 1 in terms of word weighting(content analysis). Accordingly, the new definition is an unnecessary
augmentation to 'people' which does not require qualification in the definition,and signals an obvious demotion of ‘environment’. ‘Human rights’ is betteremphasised after the definition. My suggestion for lines 139-143 is as follows:"...topics that reflect its most significant impacts on the economy, environment,
and people. In the GRI Standards, these are the organization’s material topics.
Examples of topics include impacts on human rights, climate change/global heating

Australia

Other (please
specify): - GRI
CertifiedTraining
Partner inAustralia

On behalf ofanorganization,group orinstitution

Page 35 of 55

and occupation health and safety." [Note I've replaced “anti-corruption” with“human rights” and “water and effluents” with “climate change/global heating”].
120

regarding the definition of "material topic" I think you should delete the last part
Prysmian Groupof the sentence "including impacts on human rights", because it seems that humanrights are more important or relevant than other topics related to people, suchas health and safety, or you should include other examples, not just one.

Italy

No response

No response

121(2) My concern is adding ‘including human rights’ as this seems to elevate this
topic over other topics. Human rights is included as part of the considerationsof the materiality determination process, therefore am not clear as to theelevation. Is the intention that any negative human rights impact will trump allother impacts? If so, suggest that highlight this, as this is a significant emphasis ofa particular topic.

SAICA

South Africa

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

122(2) Lacking: We believe the approach outlined in the exposure draft lacks aconnection to the notion of risk for reporting organisations, and may therefore
undermine a holistic analysis of a reporting organisation. It may also discouragesenior management from viewing sustainability and non-financial mattersseriously, absent an obvious ‘business case’.

SancroftInternational

UnitedKingdom

Consultant

On behalf ofanorganization,group orinstitution

An example: Any reporting organisation, regardless of size, typically only employs
a fraction of the people in any given community. In the case of a large city, thisfraction would be minuscule. Therefore, the scale of the business’s impact onskills and education through its employee-focused learning and training initiatives
would be said to be low. However, community-level education and skills could
carry a significant risk to businesses that depend on a highly skilled workforce. It
would not be reasonable for a reporting organisation to neglect this topic in its
sustainability reporting, we would argue, because it would diminish the reader’soverall understanding of how the organisation interacts with significant
sustainability factors.

Page 36 of 55

We suggest giving consideration to adding organisational risk as an additional
consideration alongside the core criteria of ‘Severity/Scale and scope’ and‘Likelihood’ in the description of process to address the significance of identified
impacts. Alternatively (or additionally) it could be referenced as a considerationin setting a threshold to determine which topics are material to report.
It may be helpful to consider the organisational risk associated with identified
topics in relation to the reporting organisation’s dependency on environmental,social or economic conditions or hard and soft resources in carrying out its core
activities or pursuing its business strategy.
We recognise that any reference to risk, particularly organisational risk, must not
be seen to override the assessment of impact that forms the core of material
topic identification and prioritisation. It should also not serve to reduce thescope of the definition of material topics, but rather help improve the relevanceof the topics to a clear understanding of the reporting organisation and its
context.
123(3) The addition " including impacts on human rights" sounds very strange
assuming that we could understand the impact on the society/people excluding
human right issues.

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

124

suggest "impacts on human rights" should not be emphasized in concept of "material topic", as if do so some topics might be ignored or missed.

SGS

China

No response

No response

125

Issues that are material to stakeholders are material to a company that have a
purpose to maximize stakeholder wellbeing. If the environment and society-atlarge are treated as special-case stakeholders, all sustainability issues are material

Sustainability
Advantage

CanadaNo response

No response

Page 37 of 55

to the company because they impact the wellbeing of some or all of theirstakeholders. Therefore, we don't need sector-specific versions of GRI any more.
All companies should answer all GRI questions. Sectors can then PRIORITIZE
which they will focus on to improve, but all companies in all sectors must reporttheir impacts on all sustainability issues. Mother Nature and Future Generations
don't care if the corporation is a bank or a steel mill; it just cares if the company
is harming it.
126

Explicitly including "impact on human rights" is unnecessary as "impact on people"
already comprises human rights. This line of thinking (when including "humanright") would require to also explicitly include "impact on climate" for example. I
prefer a clear and consistent definition : "topic that reflects the organization’s
most significant impacts on the economy, environment, and people’.

Manuela HuckWettstein

Switzerland

Consultant

As anindividual127

GRI Materiality must be coordinated with other standards definition such as
SASB and IIRC. One of the most important drivers for sust. reporting in Latin
America was the investors need of info. Sustainability for these stakeholders canbe associated with main risks and opportunities the company should manage andin that case, could not be associated with IMPACTs of the company. (example:
Security of info, climate change that affects the wine industry or a water utilities
supplier but is not affected by the company). Conclusion: The previous GRI
definition of materiality ADDING both views IS MORE INCLUSIVE than the newone. Companies job to prepare a materiality list for SASB and GRI can be toocomplicated.

Daniela Winicki

Chile

Consultant

As anindividual

128(2) Don't think human rights needs to be specifically called out - it should be
captured as an impact on people.

Think Impact Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

Page 38 of 55

129

While we agree that materiality should focus on impact, it is also important toalign its definition with other reporting standards or frameworks as so not to
confuse the readers of the reports, particularly for companies that produce
hybrid reports.

University of Asiaand the Pacific Center for Social
Responsibility

Philippines

Assurance
providerOn behalf ofanorganization,group orinstitution

130(1) I agree with the inclusion of impact in the new definition of material topic.
However, I think companies should also consider topics that has significant
impact on the organisation. e.g. Adaptation and resilience of Climate Change.

Simeon Cheng

Hong Kong

Business

As anindividual

131(3) As much as possible the concept of materiality should directly align with theupdated concept of “double materiality” being proposed by the EU.
In practice, almost all sustainability / combined / integrated reports that WBCSD
reads still simplify company vs. stakeholder perspectives in their matrices andprocess descriptions. The updated text should be re-emphasized in external
communications by GRI.

World BusinessCouncil for
Sustainable
Development

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution132

it may be valuable to add a wording related to the timeframe 'in the short,medium and long term' as defined in IIRC's definition of Materiality. For example,
we are now coming at a crossroads where the future of work is seen to bechanging due to automation and there is also a contrasting need to create jobs
which can become important issues in the future.

Nazish Shekha

PakistanNongovernmentorganization

As anindividual

133(1) We suggest to better define the impacts in terms of inherent or residual risk(e.g. CDP asks to focus on inherent risks).

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Page 39 of 55

134(3) Furthermore, there needs to be a clear definition of what materiality meansin terms of an GRI report, i.e. what underlying definition does an issue have tomeet to be disclosed in a report that is in alignment with the GRI standards. Inline 2568 the ‘real’ materiality definition seems to be presented: Materiality
evolves into disclosed materiality, which becomes a function of significance.
There is a difference between material impacts and disclosed material impacts.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Materiality matrix
135(1) It is a welcome change to no longer require the presentation of material
topics in a matrix format. A matrix appears to convey an accurate prioritisationof material topics, however assessments are in fact based on qualitative
stakeholders’ views and influence.

CLP Holdings Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

136(1) I appreciate the more focalization on impacts and the elimination of double
criteria (no more materiality matrix)

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution

137(2) Agree with removing ‘influence on the assessments and decisions ofstakeholders’ is determining whether a topic is material and there is no longer aneed for a materiality matrix.

RHB Bank Berhad

Malaysia

Business

On behalf ofanorganization,group orinstitution

138(1) Sancroft's comments are with respect to the revised definition of material
topics.
Positive: We support the effort to improve the sophistication and usefulness of

SancroftInternational

UnitedKingdom

Consultant

On behalf ofanorganization,
Page 40 of 55

materiality analysis and facilitate reporting that reflects an organisation’s
significant impacts. We support the move away from the traditional ‘matrix’
approach to materiality definition, which has tended to encourage overly
simplistic issue identification, and may undermine accountability and appropriate
management controls in relation to a given topic.

group orinstitution

139(2) This change rectifies the bad habit of companies simply focusing on material
issues that affect external sources AND business sources and dismisses the useof the materiality matrix.

University of DenverUnited States

No response

No response

140(2) The presence of matrix still is considered as the element that makes
materiality more transparent.

Da-Strategy

RussianFederation

Consultant

On behalf ofanorganization,group orinstitution

141(4) Materiality
We are therefore concerned the removal of the materiality matrix may makeapplication of the revised standards difficult for some reporters and reducetransparency for users on how material topics have been evaluated. As a result,
we believe there is a need for greater guidance on applying the revised definitionof materiality. As one option, we suggest that GRI consider retaining the conceptof a matrix as a decision-making and communication tool within the context ofthe proposed revised definition of materiality. We think it could be useful for
GRI to leverage matrices and tools adopted within other frameworks orapproaches, and introduce a new form of materiality matrix or similar thatshould address the dimensions of the significance of an impact; and the likelihoodof its occurrence over time.

Deloitte

United States

Consultant

On behalf ofanorganization,group orinstitution

Page 41 of 55

142

Per page 11 of the current GRI101 many reporters provide a ‘materiality matrix’
showing Influence on stakeholder assessments & decisions plotted against
Significance of economic, environmental & social impacts (as assessed by thecompany). I’ve found this a useful tool for understanding the relative importanceof a company’s Material Topics including the reasons why each topic is material.
Please can this useful feature be included in the new GRI103.

Hong Kong
University of Scienceand Technology

Hong Kong

No response

No response

143(2) Additionally, it should be mentioned that voluntarily, companies can publish
materiality matrices but these should refer to the concept of materiality
identified in GRI 103 (a concept of materiality based on impact and not on theinfluence on the company and on relevance/influence of the stakeholders, as inprevious versions of the standard’s materiality matrices).

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

Think Impact Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

The axes of the materiality matrix (e.g. impact probability/severity) should bespecified in order to ensure the homogeneity of the information contained in thereports for those cases where a company reports the materiality matrix
considering the new concept of impact. We would be in favour of redefining theaxes but retaining the visual presentation of material topics. Many entities had
adopted this visual approach because of the insights it provides to users.
144(2) Reporting practice since G4 has evolved to focus on the application of themateriality matrix, and whilst I understand GRi's concerns with this approach, thereason it has been so widely adopted is because it is understandable andapplicable. Asking reporters to abandon the matrix without providing a clear
alternative will create many issues such as confusion, inconsistency andincomparability.

Page 42 of 55

94.Stakeholder

10

Please refer to page 10 in the Universal Standards exposure draft.
No. Comment

Organization
nameCountry

Stakeholder
group

Submission
type

General opinion (supportive, opposed, or other)145

We support the revision of the stakeholder definition.

Australian Councilof Trade Unions

Australia

Labor
representative

On behalf ofanorganization,group orinstitution

146(2) Stakeholder: an excellent definition that is simple and comprehensive at thesame time.

Noha Andelrahman

Egypt

Academic

As anindividual

147(2) Section 2.4 Stakeholder (lines 196-229)- The recommended changes are supported

CLP Holdings Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

148(3) For the definition of a stakeholder, we agree with the changes as aligningdefinitions is preferable. We appreciate GRI for recognizing that not all stakeholderinterests are equally important.

ERM

United States Consultant

On behalf ofanorganization,

Page 43 of 55

group or
institution
149(1) The modification of definition of stakeholder is welcomed. The alignment with
the OECD guidance is making things more clear.

Marcus Chau

Hong Kong

Consultant

As anindividual

150(2) Stakeholders definition aligned with OECD on the outward impact part isconsistent with approach on materiality topics which focuses outward impacts.

Fuji Xerox (HongKong) Limited

Hong Kong

No response

No response

151(1) The alignment or "stakeholder" with OECD definitions is positive, and we insist
that important stakeholders not be left out of any assessment.

IndustriALL Global
Union

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution

152

We strongly support the revision of the definition of "stakeholder" in line with theOECD Due Diligence Guidance for Responsible Conduct. We believe that thisdefinition addresses the previous gap which created an incentive for organisations
to pick and choose stakeholders that suited the organisations' own views

International Trade
Union
Confederation

Belgium

Labor
representative

On behalf ofanorganization,group orinstitution

153(1) I found the revised definition of stakeholder more suitable to the focus of GRI
reporting. The fact that the stakeholders actions "can reasonably be expected toaffect the ability of the organization to successfully implement its strategies andachieve its objectives" was implicit and redundant. Entities must focus on therecognition of their impacts that lead finally to the relevant stakeholders.

Alessandro Mantini

Italy

Business

As anindividual154

The definition itself is suffice and justify a generic understanding on the meaning ofstakeholder.

Universiti Malaya
Sustainability &Living Labs

Malaysia

No response

No response

Page 44 of 55

Secretariat(UMSLLS)
155(2) I agree with the alignment of the definition of "stakeholder" with OECD.

Simeon Cheng

Hong Kong

Business

As anindividual156

I believe this definition of stakeholder is apt

ZENITH BANK
PLC

Nigeria

No response

No response

157(3) Relating to the “Stakeholder” definition, I suggest considering the following
definition:

No response

Peru

Academic

As anindividual

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

Da-Strategy

RussianFederation

Consultant

On behalf ofanorganization,“Individual or group that has an interest that can, or could, affect or be affected by
the organization’s activities and decisions”.
158(1) The updated definition of stakeholder makes sense, as commented in line 121129 in the explanatory memorandum.
We are also wondering about the second part of the previous definition not to beelaborated at all? Those whose actions can be expected to affect the ability of theorganisation to implement strategies and objectives. In our opinion that is
important information to understand how likely the strategies and ambitions are toactually be followed through, or if they are conditioned actions or re-actions fromexternal parties.

159(2) As to the notion of stakeholder, if it is reduced to the stakeholder that is, or
could be, affected by the organization, it seems to be that only "weak" stakeholders
are in to focus. However, there are stakeholders that are "strong", they do notaffected by the organization, but they have influence on it. For example, regulatory

Page 45 of 55

authorities, supranational associations (UN etc.), standardizers, rating agencies they will become out of the reporting focus.

group orinstitution

160(2) We understand GRI's aim to focus more on impacts produced outward; still,forus, stakeholders are also those who can influence strategy and objectives of anorganization, not only those who are affected by organizations' business (e.g.
shareholders' resolutions on climate change). Therefore, we believe that new
definition of stakeholders should take that into proper consideration.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

161(6) Stakeholder engagement• The new definition of stakeholder only accounts for the organization’s impact onthem and not the impact that stakeholders have or can have on the organization.
ERM CVS would like GRI to consider retaining, in a limited way, the effect of
stakeholders on the organization: this is a bilateral impact.

ERM Certification
and Verification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

162

I think stakeholders should also include individuals, groups or entities that can
impact or influence an organisation. This has been left out.

Joshua Rayan
Communications

Malaysia

Other (please
specify): Sustainability
Report Writer

On behalf ofanorganization,group orinstitution

163(3) Stakeholders: I do understand the position to shift towards an outwardlooking focus, however, there are inward- looking impacts on an organisation basedon stakeholder actions or decisions. Suggest that some guidance on how to
consider stakeholders response to an organisation’s actions; and any further
resulting stakeholder reactions to subsequent organisation actions need to betaken into account for a more holistic and multi- dimensional approach to
stakeholder management and disclosure.

SAICA

South Africa

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 46 of 55

164(4) Stakeholder definition: This narrow definition is not mainstream and OECD
(representing 37 western countries) not the reference for stakeholder engagement.
The active and passive formulation "that affect and/or could be affected" preferable
as it includes both dimensions of influence and dependency. Reference toAA1000SES would be advisable. Definition of Standards 2016 are preferable standard two dimensional system on influence and urgency.

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

165(2) On the other hand, we recommend adding in the definition of stakeholder thatthey are "people or organizations that also generate an impact on the activity of theorganization itself".

Sustenia

Argentina

Consultant

On behalf ofanorganization,group orinstitution

166

the aforementioned definition of stakeholder suggest one way relation: "--affectedby the organization's activities and decisions." Shouldn't it be a two-way
relationship: affect and affected by? Therefore suggesting that stakeholders has
influence to the organization

Trisakti
Sustainability
CenterIndonesia

Consultant

On behalf ofanorganization,group orinstitution167

It´s very important to have a definition for the stakeholder, which takes inconsideration the potential damages. This will comit the organizations to reportnegative aspects and to manage potential negative impacts.

ICR Systems &Management SRL

Bolivia

No response

No response

168(2) Can you please elaborate on which page of OECD Due Diligence Guidance for
RBC has the definition of 'stakeholder'?

International
Development
Center of JapanJapan

No response

No response

Page 47 of 55

169(2) The determination of stakeholders whose interests have been affected andcould be affected -- If it could be done, is it obligatory?

Trisakti
Sustainability
CenterIndonesia

Consultant

On behalf ofanorganization,group orinstitution

170(2) There is a potential problem with inconsistency with other standards and theirdefinition of stakeholders. The new GRI definition is more restrictive than others
and may reduce perceptions of stakeholder saliency/agency, but this is balanced by
the increased prominence of material topic selection and changes in the universalityof the standards/shifts in reporting concepts.

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

CanadaAcademic

On behalf ofanorganization,group orinstitution

171

Consultation with stakeholders has benefits for the organization, however, theneeds that these interested parties pose may not always benefit the sustainability
and transparency of the business.

freelance

EcuadorConsultant

As anindividual172

i think for stakeholder definition, it is better use of any interest or in decision
making process need ....

RPMRG

Hungary

Consultant

On behalf ofanorganization,group orinstitution

173

i support the idea of differentiating between stakeholder and interested party.

Sime Darby
Property Bhd

Malaysia

Business

On behalf ofanorganization,group orinstitution

Page 48 of 55

Suggested addtions/revisions
174(3) On the other hand, I believe the definition of stakeholder is too broad: it could Beyond Businessmean anyone anywhere. And "has an interest" is vague. Suggest using plain language: Ltd"A stakeholder is an individual or group that is or is likely to be significantly affectedby an organization's activities."

IsraelNo response

On behalf ofanorganization,group orinstitution

175(3) We further note that the definition of stakeholders has been aligned with thatof the OECD due diligence guidance for RBC and appreciate the efforts in thedefinition of stakeholder included in the glossary to make clearer the connection
between interest and rights. We are however concerned that the connection
between interests and rights is not clearly defined and communicated. From ahuman rights perspective we find that there is a need to state more explicitly that
potentially affected individuals and groups (or rights holders) should automaticallybe considered as part of the organization’s stakeholders. Notably, rightsholders
have human rights, that it is the duty of the reporting organization to respect, evenwhen these rightsholder are not identifying these as “interests”. There is an
important distinction between rightsholders, whose human rights and maybe
interests, are at stake and other stakeholders such as businesses, local government
who have “interests”. Interest is a subjective notion whereas human rights
instruments define the content of these rights. We recommend deleting Note 1 in
the definition of stakeholder included in the glossary as it seems to suggest thatrights can be reduced to interests and also suggest line 196-229 is revised inaccordance with input shared above. We recommend that the short definition
included in e.g. key concepts section is revised to say ‘individual or group that has
an interest or right(s) that is/are, or could be, affected by the organization’s
activities and decisions’. We also recommend that an explicit connection is madein the definition of stakeholders to the concept of (potentially) affectedrightsholders and that the definition explicitly includes language on how interests

Denmark

Other (please
specify): national humanrightsinstitution

On behalf ofanorganization,group orinstitution

Danish Institute for
Human Rights

Page 49 of 55

and rights are distinct. We finally recommend that clarifications are consistently
included directly in the Key Concept section as well as in the Glossary.
176(2) At line 204, it is recommended that this is replaced with the following text:
Forest Peoples“While not all interests are of equal weight, all human rights should be treated as of Programme
equal importance, and organizations should bear in mind that human rights areinterrelated and interdependent.”

No response

No response

No response

177(5) Language use (lines 119-136 & 196- 229): a note here should be added to
explain that some “stakeholders” are also rights-holders. GRI should check the fulldocuments to ensure wherever “stakeholders” are mentioned this is coupled withrights-holders in appropriate places.

Forest Peoples
Programme

No response

No response

No response

178(3) The change to the definition of stakeholder is still broad and far reaching andfeasibility for organizations with limited resources would seem difficult in regards
to stakeholder engagement under the proposed definition. Suggestion to create aseparate term and definition that accompanies the original (i.e. "affected andpotentially affected stakeholder").

University ofDenverUnited States No response

No response

179(6) Further “local communities” should be changed to “indigenous peoples andlocal communities” in line 200 and throughout the full GRI standards document(GRI 101-103).

Forest Peoples
Programme

No response

No response

No response

180(4) Line 218 should add: “…this includes securing the consent of indigenous
peoples and local communities to discuss issues affecting them with their chosen
representatives.”

Forest Peoples
Programme

No response

No response

No response

181(3) Line 209 should also point out that the relationship between corporate conduct
and human rights impacts may be indirect and be several steps removed, e.g.,
indigenous peoples lands, waters, natural resources, livelihoods, cultural integrity,

Forest Peoples
Programme

No response

No response

No response

Page 50 of 55

health and security can be impacted indirectly by a company's operations or
supplier’s operations even if the company's activities are not located on their lands.
182(5) • Line 198: We suggest the common categories of stakeholders fororganizations should also include investors, both public and private.

Institution of
Occupational
Safety and Health(IOSH)

UnitedKingdom

Chartered bodyfor OSH
Professionals

On behalf ofanorganization,group orinstitution

183(3) What are the treatment of Note1 and Note1 and Note 2 of stakeholder
definition on page 28 of GRI 101:Foundation 2016? These Note 1 and Note 2should be inherited in new GRI 101?

International
Development
Center of JapanJapan

No response

No response

184

Stakeholders are defined as “entities that can affect, or is affected by, anorganization, strategy or project.” We need to classify the environment/Mother
Nature and society-at-large/Future Generations as stakeholders, and ensure thatthey are included in a corporations' multi-stakeholder purpose: maximize
stakeholder wellbeing.

Sustainability
Advantage

CanadaNo response

No response

185(3) In relation to the definition of stakeholders I would include those directly andindirectly affected. Companies often have major impacts on certain stakeholders
indirectly.

UN Global
Compact Network
Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

186

Stakeholder mentions shareholders - should build this out and discuss individual
and institutional shareholders in definitions. Institutional shareholders may havedifferent drivers versus individual shareholders. This is touched on in Conflicts ofinterest Lines 1407-1423.

University ofSouthern
Queensland

Australia

No response

No response

Page 51 of 55

187(4) The GRI should also consider explicitly mentioning the specific needs ofvulnerable stakeholder groups. Line 209 suggested amendment: “The organization
should also identify the interests of those who are unable to articulate their views(e.g., future generations) and those who might require specific approaches or
special attention (e.g. at risk or vulnerable groups).”11

5.Due diligence

12

Please refer to page 9 in the Universal Standards exposure draft.

World BusinessCouncil for
Sustainable
Development

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

No. Comment

Organization
nameCountry

Stakeholder
group

Submission
type

188

(5) For due diligence, more explanation and samples should be included as part of the
Sector Standards for better clarity. In the case of financial institutions, the distinction
between caused, contributed to and directly linked to may be have different
interpretation especially for contributed to and directly linked to.

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

189(2) However, the referral to Due Diligence should preferably be rephrased
stakeholder or sustainability due diligence, as the term due diligence is frequently usedwith a more subjective focus than intended in this definition.

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

Page 52 of 55

190

Due diligence is confusing and should not be in the standards as proposed. If GRI
wants due diligence as a part of the standards, then make it a reporting principle anddevote considerable energy to giving it clarity and providing examples.

ISOS Group

United States Consultant

On behalf ofanorganization,group orinstitution

191

IOSH welcomes the opportunity to comment on the exposure draft GRI 101 (Using
the GRI Standards), GRI 102 (About the Organisation) and GRI 103 (Material Topics)
and was pleased to respond to the online survey in June 2019.

Institution of
Occupational
Safety and
Health (IOSH)

No response

No response

No response

We welcome the focus on human rights, due diligence, responsible business conduct,
governance and verifiability of data.
IOSH would be very pleased to provide further OSH input on the development ofthese GRI standards as required. For further information about this submission, pleasecontact: Richard Jones at richard.jones@iosh.com.

192(4) In the exposure draft, the GSSB proposes, among others, to integrate theexpectation of due diligence in the GRI Universal Standards and to align the standards
with the United Nations Guiding Principles on Business and Human Rights and theOECD Guidelines for Multinational Enterprises. We welcome these proposals as we
believe that all companies should follow these international standards for responsible
business conduct and report on their policies, practices and outcomes.

NBIM

NorwayNo response

No response

193

WBA also supports the increased alignment with the expectation of due diligence.
This will make it easier to accept that a company has looked at human rights impacts
if it has a GRI-aligned materiality process.

World
Benchmarking
Alliance

Netherlands

Benchmarking
foundation

On behalf ofanorganization,

Page 53 of 55

group or
institution
194(6) There is a high expectation when it comes to due diligence which may bechallenging for developing or new-to-sustainability companies (exposure draft line
193-195).

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

195

It is crucial to take into account role of stakeholders in due diligence for betterverification. This will provide better transparency especially in supply chain for allindustries.

DUOPHARMA
BIOTECH
BERHAD

Malaysia

Business

On behalf ofanorganization,group orinstitution

196(2) Secondly the proposals need to be adjusted to bring negative and positive impacts
more into balance.

Corporate
Citizenship

UnitedKingdom

No response

No response

We have further detailed comments:
GRI 101 2.3 Due diligence
The proposed text reads: ‘Due diligence is the process through which an organization
identifies, prevents, mitigates, and accounts for how it addresses its actual andpotential negative impacts on the economy, environment, and people, including
impacts on human rights.’ This is an unnecessarily gloomy definition of due diligence.
Due diligence ought to identify impacts good and bad and provide the organisation
with the wherewithal to think through and manage its external impacts. We submitthat the text should be amended accordingly.

Page 54 of 55

197

Actual negative impacts should be remediated, AND their reoccurrence should be
prevented. Recommend adding this important aspect.

Danish Institutefor Human
RightsNo response

No response

No response

198

ADD: 'and positive after 'negative'

Hong Kong
University of
Science andTechnology

No response

No response

No response

Page 55 of 55