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

Item 02 – Public comments on thereporting model in the Universal
Standards exposure draft
For GSSB discussion
Date

25 November 2020

Meeting

3 December 2020

Project

GRI Universal Standards Project

Description

This document contains an extract of public comments related to the reporting
model received on the Universal Standards exposure draft, which was madeavailable 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 1 December.
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 in a
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 3 December.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2020

1

Contents
Public comments ..................................................................................................................................... 3
1. General comments on the reporting model ..................................................................................... 3
2. Comments on appropriate disclosures .......................................................................................... 22
3. Comments on the reasons for omissions ...................................................................................... 28

Page 2 of 30

2

Public comments

3

1. General comments on the reporting model

4

Please refer to page 11 in the Universal Standards exposure draft.
Name oforganization orindividualCountry

Stakeholder
group

Submission
type(1) We think that could be confuse the uso of option A o B with the riskof again fall in some kind of qualifications. We are leaving the option
core and comprehensive and this option election is similar to theprevious. To simplify it should be one option, to report according to
GRI. Then, if there any company that can not apply to be accordance,
they can reference to GRI in their report (or when is used in otherreports o for SMEs). But shouldnt be presented as an option. Could still
be confuzing and needed to still clarifying.

AG Sustentable

Argentina

Consultant

On behalf of anorganization,group orinstitution

2(3) if we spect that the companies should report all 102 disclosures(specially all GOV), is should incluide a reason for omision "don't haveit" (of course something more elegant). We believe that all core reports
could apply for that reason or unavaiable in many of GOV disclosuresor requirements. If not we have the risk to loose GRI Reporters

AG Sustentable

Argentina

Consultant

On behalf of anorganization,group orinstitution

3

erasing the both options "Core" "Comprehensive" will terminate themissunderstanding that one Option was better, shows a higher level onsustainability efforts of the company.

akzentekommunikation undberatung gmbh

Germany

Consultant

On behalf of anorganization,group orinstitution

No.

Comment

1

The best in our opinion would be a categorisation in different levels of
ambition and which show a journey for the reporting organisation. As it
was in GRI 3 with the levels A, B, C

Page 3 of 30

4(1) Changes are welcome and have streamlined the use of GRI
Standards.

Aldo Joson

Singapore

Business

As anindividual5

The old core/comprehensive option led in my opinion to a sort ofdistinction between "Class A" and "Class B" reporting entities.
Moreover, a stricter application of the Standards requirement and the
reduction of reason for omissions will lead in the future to a morehomogeneous application of the Standards and a wider comparability
between reports of different entities.

Alessandro Mantini

Italy

Business

As anindividual

6

Removing the core/comprehensive split makes sense. Especially ascomprehensive reporting wasn't widely used due to the quantity andrelevance of the indicators required.

Alexandra McKay

UnitedKingdom

Consultant

As anindividual

7

It is important that the form of reporting with a GRI Standards approachis left open for selection, not all organizations have the operational
capacity and are just moving towards sustainability and the GRI
standards should be a support.

Angel Castillo

EcuadorConsultant

As anindividual8

We support the revision of a single standard for 'in accordance' claims.

Australian Council ofTrade Unions

Australia

Labor
representative

On behalf of anorganization,group orinstitution

9

in agreement

Bank Audi sal

LebanonNo response
provided

No response
provided10

I am in favor of the new A and B options. However, I believe some of
the mandatory disclosures on governance that are now required for In
Accordance A are uncecessarily burdensome - sustainability reporting
is about impacts, not about governance.

Beyond Business Ltd

IsraelNo response
provided

On behalf of anorganization,group orinstitution

11

I fully agree with this change: more in line with the concept ofmateriality.

Bondt Communicatie

Netherlands

No response
provided

No response
provided

Page 4 of 30

12

Perfect

BSI Group

Italy

No response
provided

No response
provided13

The idea of moving away from having a comprehensive option as theultimate target looks wise to me since it is achievable only for few
anyway.

Carlo Diener

No response
provided

No response
provided

As anindividual

14(1) Essentially, 'Reporting in accordance to GRI Standards' is an
upgraded Core option. The new wordings make it easier for readers tocomprehend the reporter’s alignment with GRI Standards. You areeither ‘in accordance’ or ‘not in accordance’. However, GRI should be
mindful that this will significantly raise the bar for reporters currently
reporting under ‘Core option’.

City Developments
LimitedSingapore

Business

On behalf of anorganization,group orinstitution

15(1) The two different approaches differentiate those issuers that haveassessed material issues and report on strategy accordingly from thosethat take a box-ticking approach to reporting standards via strict
adherence to the provisions of a GRI content index. We are of the viewthat a statement indicating the level of adherence to the GRI standards
does not necessarily predict a high-quality report.

CLP Holdings Ltd.

Hong Kong

Business

On behalf of anorganization,group orinstitution

16

They facilitate the choice between the Options, in comparison to thepast.

CrevalItaly

No response
provided

No response
provided17

The proposed revisions will indeed raise the quality of reporting andraise the bar.

CSRWorks
International

Singapore

No response
provided

No response
provided18(1) Stakeholders that are not familiar to GRI won't value the difference
between "in accordance" and "with reference". So, as a result of thisspecific changes, companies that cannot answer in accordance (taking
in account that Governance disclosure are ALL mandatory) are free to
use it as a reference and make less disclousre than they do know. So,
as a result of this change, companies will be lest transparent andstakeholders will have less info to make decisions.

Daniela Winicki

Chile

Consultant

As anindividual

Page 5 of 30

19(2) In Latin America, Governance issues are yet arising so therequirement to report ALL is to high.

Daniela Winicki

Chile

Consultant

As anindividual

20(1) DIHR welcomes the introduction of the two approaches by whichorganisations can report in accordance or by reference to GRIStandards with the hope that this distinction will help raise the bar forreporting, by driving reporting ‘in accordance with’.

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf of anorganization,group orinstitution

21(2) With respect to Requirement A-5, DIHR does however note that GRI
Topic Standards may not all be 1) fully reflective of internationallyagreed standards on business and human rights and responsible
business conduct, 2) holistic in their inclusion of impacts across thethree sustainability dimensions, incl. for example by reflecting humanrights impacts in economic or environmental standards and 3) withregards to the social standards (400 series) fully aligned substantively
with human rights. Re the latter point the DIHR notes that the 400
series currently includes a mix of human rights and ‘social’ standards, a
mix of substantive and process-oriented standards (e.g. human rights
assessments), some of which may now overlap with or be slightly misaligned with the requirements of the Universal standards. This series
would in general benefit from updating and streamlining including toensure that common material topics are all represented by relevant andupdated topic standards. We therefore have concern that tying
reporting by organisations to strictly to the topic standards might dilute
some of the progress gained with the update of the Universal
Standards. Based on these observations and concerns, we recommendthat the inclusion and use of GRI Topic Standards in Requirement A-5
is reconsidered.

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf of anorganization,group orinstitution

22(1) It is important for the different organization that have decided toprepare sustainability report with GRI SRS to have stage-by-stage
approach. There are the organization that are weaker in theirtransparency.

Da-Strategy

RussianFederation

Consultant

On behalf of anorganization,group orinstitution

23(1) Deloitte supports the removal of core and comprehensive “inaccordance” options. The motivation and related practice aroundreporting in “accordance comprehensive” has not emerged as a

Deloitte

UnitedStatesConsultant

On behalf of anorganization,

Page 6 of 30

differentiator from in “accordance core”, and therefore we support thesimplification and the introduction of the new options.

group orinstitution

24(2) This reflects reporting practice, whereby some companies embrace
adoption in accordance with the GRI Standards but others use them asa reference, or adopt the standards partially. We also note that thisaccommodates organizations who are on the journey to adopting
standards” in accordance with” GRI Standards. It also encourages
greater transparency on how the GRI Standards are being used byreporters, which is valuable to users.

Deloitte

UnitedStatesConsultant

On behalf of anorganization,group orinstitution

25(1) Lines 277 – 283 GRI should provide guidance on level of detail
expected when reporting narrative descriptions. There is no guidancefor Requirement A-4. Two of the three requirements are narratives.
Narratives are difficult to describe. Practices vary widely. They arealso subject to exaggeration, misleading statement or even fraud.
Guidance could include language such as “When reporting narrativedescriptions, the organization should provide some list or description of
key processes, systems and internal controls, such that informed
stakeholders would have reasonable context to evaluate theorganization. The organization may include descriptions of how andwhere independent perspectives (councils, advisors, audits) areincorporated into these processes.”

Douglas Hileman
Consulting LLC

UnitedStatesConsultant

As anindividual

26

Personally I never understood why there should be a distinction
between core and comprehensive. For me this was a compromiserather than a logical Approach. Great to see it is gone.

DQS CFS

Germany

No response
provided

No response
provided27(1) The elimination of options on the level of adoption is a positive
move. Reports should either comply or not with the GRI Standards forusers to better assess the quality and consistency of the reports. It
should be emphasised, however, that reporting referencing the GRI
Standards is not a GRI complied report, it opens up the possibility forcompanies to learn and experiment with the standards; thus the user
should be aware of this fundamental difference this entails.

Dr Aljaohra Altuwaijri

Saudi Arabia

Academic

As anindividual

Page 7 of 30

28(2) Throughout the years, the GRI has attempted to adjust theapplication levels of the reports, from the former A,B,C (+).. to thecurrent approach; however, it is advised that the GRI should pay more
attention to the quality and the consistency of the reports that arelabelled as GRI reports and are deposited to the GRI database.
Screening of the deposited reports, as well as enhancing the quality ofcertifications of the reports are amongst the suggestions that should beconsidered. Although the GRI has done a lot in the realm ofsustainability reporting, it did very little on aspects of enforcement andoverseeing those reports that hold its name.

Dr Aljaohra Altuwaijri

Saudi Arabia

Academic

As anindividual

29

Most of the companies will faced difficulties in reporting theirsustainability disclosure using "in accordance" approach due tostringent requirements.

DRB-HICOM Berhad

Malaysia

Business

On behalf of anorganization,group orinstitution

30

Better with just one standard for universal compliance method.

DUOPHARMA
BIOTECH BERHAD

Malaysia

Business

On behalf of anorganization,group orinstitution

31

This should ease reporting burden for some companies that used thecomprehensive option.

ELEVATE

Hong Kong

No response
provided

On behalf of anorganization,group orinstitution

32

In order to protect the credibility of GRI and the Standards, it is vital toclearly define what Option B entails. We understand that the suggestionis that both Option A and Option B will require the reportingorganisation to include a GRI content index. An un-trained eye might bydefault think that all reports that include a GRI content index are
prepared in accordance with the GRI Standards (Option A). Only if thereader reads the statement of use (A1 or B2) will they find out if thereport is prepared in accordance with or with reference to the GRI
Standards.

Enact Sustainable
Strategies

SwedenConsultant

On behalf of anorganization,group orinstitution

Page 8 of 30

33(1) A Core option can be useful for companies when preparing the Non
Financial Information (NFI) requested by the European Directive thatneeds to be concise, especially when it is included into the Annual
Report. On the other hand, a Comprehensive option might be useful forvoluntary reporting where companies have the chance to provide more
information. Furthermore, the proposed Approach A would be very
difficult to apply for the European NFIs as companies would berequested to provide too many details about governance andresponsible business conduct. Moreover, such details are often
included in other company publications with the risk of uselessly
duplicate information.
In order to mitigate this risk, it is true that companies could report
directly in the content index the location of such information alreadypublished in other documents. Still consider that the Italiantransposition of the European Directive allows the "incorporation byreference" technique only to documents that are mandatory by law,
therefore a partial duplication of information would be unavoidable
anyhow.

Eni SpA

Italy

Business

On behalf of anorganization,group orinstitution

34

While we appreciate the intention and potential clarity behind this draftchange to the standards, we are concerned that the addition of thegovernance disclosures for previous Core reporters may shiftcompanies away from using GRI. For new reporters, many componentsof what are currently part of the Comprehensive governancedisclosures would require a maturity that they may not yet possess as
they seek to improve their sustainability management. We ask that GRI
clarify how a company determines "relevant" disclosures and whether itwill be enabling an omission consideration for the universal standards.

ERM

UnitedStatesConsultant

On behalf of anorganization,group orinstitution

35(1) Requirement A-2 Report disclosures in GRI 102• ERM CVS supports the revised approach as it will increasetransparency regarding the way that the GRI Standards are used.
However, we question whether all organizations currently following the‘Core Option’ will be able to comply with all requirements in 102(namely Governance and RBC disclosure requirements) in order to be“In accordance” under the new in accordance criteria. Consider

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

Page 9 of 30

allowing ‘omissions’ (with explanations) for these disclosures at least
for the transition period.
36

Another bold, but wise step: bringing more clarity to the world ofreporting. I frequently read GRI reports of companies in my role:sometimes a report with reference to GRI means that the report is lessmature, on its way to becoming in accordance. And sometimes itmeans the reporter has ‘graduated from GRI’ - i.e. the reporter is somature that they are able to define specific disclosures that capture
their mterial impacts even more accurately than the GRI standards.

Eszter Vitorino

Netherlands

Investor

As anindividual37

We agree with these revised approaches as they remove some of theissues with the reporting practices of companies, including the selective
use of GRI Standards, which had created inconsistent reporting
practices that often purported to be GRI-compliant but only reported
against cherry picked parts.

EuropeanAccounting
Association's
Stakeholder
Reporting Committee

CanadaAcademic

On behalf of anorganization,group orinstitution

38

I understand and agree with the GRI's intention to raise the quality of
published reports, but I'm afraid that to have only these two approaches
to using the GRI Standards could discourage companies from conceive
the sustainability reporting as a path of progressive improvement.
Maybe you can consider to introduce at least one more option to allow
companies to set goal of improvement with reference to the level ofconformity to the GRI Standards. In this case I suggest to use a
different wording from previous one (not "referenced to", not "core, not"comprehensive") to avoid misunderstanding, as the requirements ticomply with are different from the past. Moreover the GRI should
clearly recommend to the organizations to pursue better level ofaccordance to the GRI Standard over the time.

EY S.p.A.

Italy

Consultant

On behalf of anorganization,group orinstitution

39(1) When disclosing which the company has used, it must be madevery clear that a company choosing to report via Option B has opted toreport "in reference to the GRI standards" - and that this is a far lesser
reporting requirement than Option A, which is to report "in accordancewith GRI standards".

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

Page 10 of 30

40(2) Further clarification is needed in this section on how the company is
expected under “reporting in accordance with the GRI Standards” topublicly report how it will respond to past, present or potential future
harmful impacts linked to its business, investments, operations andsupply chains (including in relation to indirect/third party suppliers). Thisappears to be described briefly in 103 under “disclosures” (lines 27262729) but does not come across strongly enough in this section. For
example, if a company finds information on community grievances,conflicts or risks of future potential harmful impacts on human rights in
its business operations or supply chains, what does it do and how
should it report on that? How can GRI rules make these entities moreaccountable?

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

41(3) Why has GRI decided to have two approaches to using the GRI
Standards for sustainability reporting and ultimate claims making? As
detailed above this is of deep concern.

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

Concern as detailed above: however, it brings up (again) the issue withhaving two possible ways for companies to report and whether theclaims ultimately made by companies are clear enough for those who
do not know the nuance of the GRI standards (e.g. for an uninformed
reader there will be little difference or alarm bells between reading thata company is reporting “in accordance with the GRI” or “in reference to
the GRI” yet in reality these are significantly different reporting
requirements).
42

Option B would only consider subjective ways of reporting if chosen by
an organisation especially that the reporting is only with reference to
the GRI Standards, i propose term be used to both combine obligations
and requirements in reporting.

Fridah Mashandi

ZambiaNo response
provided

As anindividual

43(1) Unlike the current version, there would be no Core orcomprehensive option. On one side this can enable readers to easily
understand sustainability disclosure and unified reporting content.

Fuji Xerox (HongKong) Limited

Hong Kong

No response
provided

No response
providedOn the other hand, however, transitions might be challenging fororganizations which have been taking the core option. Extensive efforts

Page 11 of 30

must be made to comply with the new "in accordance" option,
especially on GRI102 and GRI103.
44

We believe that it is important to enhance the quality and consistency ofreporting, and are supportive of these changes.

GIB Asset
Management

UnitedKingdomBusiness

On behalf of anorganization,group orinstitution

45(2) ■ When using the phrase "Approach A/Approach B," "Approach B"
may give an impression that it is more difficult to use. This may cause
misunderstanding. Why not use the current phrase of ‘in accordance
with/with reference to’ as they are?

Global Compact
Networking Japan- Study Committee
on Corporate
ReportingJapan

Generalincorporated
association

On behalf of anorganization,group orinstitution

46

The intentions of the change are fine in principle but there is not muchto explain why "Core" will no longer be allowed and what this will mean
to the large number of companies that use "Core" but under the
proposal will have to upgrade to "Comprehensive".

Hong Kong Instituteof CPAs

Hong Kong

Professional
Accountancy
Body(including
regulator andstandard
setter)On behalf of anorganization,group orinstitution

47

The option of a ‘Core’ and ‘Comprehensive’ 'in accordance with'disclosure should be retained. The great majority of existing reports
are done per 'Core' rather than comprehensive yet (a) there is no
discussion in the explanatory memorandum why most companies follow
Core or the difficulties they will face upgrading to 'Comprehensive. This
was also not mentioned in the webinar held on 17 Aug to explain thechanges. See my answer to 5(a) for an example.

Hong Kong
University of Scienceand Technology

Hong Kong

No response
provided

No response
provided48

Agreed.

Hui XuChina

Nongovernmentorganization

As anindividual

Page 12 of 30

49

We acknowledge that organizations will now have to report on all
disclosures in GRI 102: About the Organization (General Disclosures),which would have essentially been considered comprehensive in thecurrent Standards. It will be substantially more onerous to report inaccordance with the GRI Standards for our members that previously
reported in accordance with 'core' requirements only.

ICMM

UnitedKingdom

Trade orindustry
association

On behalf of anorganization,group orinstitution

For our members that have been reporting in accordance with the‘comprehensive’ option, the revision will have a less significant impact.
However, most ICMM members should be able to report in accordancewith the revised GRI Standards. The proposed changes to GRI 102
have merged a number of the disclosures which does not necessarily
reduce the reporting burden but allows for more concise presentation in
the GRI Index.
It is generally considered that the revised approach is achievable oncondition the GRI allows for sufficient implementation time to adjust to
the new standards, along similar timelines as with previous changes.
Therefore, as an overall comment, the ICMM recommends that theimplementation timeframe for the revised universal standards is no lessthan 2 years from issue date.
50

From our point of view the options do not determine the quality of thereports, since the GRI 101 quality principles must be integrated in both.

ICR Systems &Management SRL

Bolivia

No response
provided

No response
provided51

Option B.

Ilunka, Estrategia
Sustentable

MexicoConsultant

On behalf of anorganization,group orinstitution

52

A single standard of "in accordance" is an improvement, reflecting theneed to take an integrative view of the social, economic andenvironmental dimensions of sustainability.

IndustriALL Global
Union

Switzerland

Labor
representative

On behalf of anorganization,group orinstitution

Page 13 of 30

53

IOSH believes that removing the option of 'core' or 'comprehensive'
reporting may help achieve more consistent reporting and may help
those using GRI-based reports to more readily appreciate the approachtaken by the reporting organisation.

Institution of
Occupational Safety
and Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf of anorganization,group orinstitution

54(1) We support the streamlining and shift to a single standard for Option
B "reporting with reference to the GRI Standards".

International Trade
Union Confederation

Belgium

Labor
representative

On behalf of anorganization,group orinstitution

55

Reporting in accordance - The loss of the two levels of reporting inaccordance (core and comprehensive) is likely to encouragereferencing of the standards rather than in accordance reporting. The
proposed one level of in accordance does not allow a company togradually work up to a comprehensive level.

ISOS Group

UnitedStatesConsultant

On behalf of anorganization,group orinstitution

56

Fully agree. But there should stronger recommendations for companies
to use the "In accordance" option for more comprehensive sustainability
reporting.

Joshua Rayan
Communications

Malaysia

Sustainability
Report Writer

On behalf of anorganization,group orinstitution

57

The distinction provides the investor/reader a clear and definite idea on
how a particular disclosure is made (in accordance if following thestandard, otherwise, it may only be made with reference to the GRI
Standards.

Justina CallanganPhilippines

Business

As anindividual

58(2) However, it should be noted that organisations that are starting theirreporting journey with reference should strive to move to in accordanceas quickly as possible. (barring the org. that report for other purposes).

Liberty Holdings
LimitedSouth Africa

No response
provided

No response
provided

Luis Cordova

Peru

Academic

As anindividual

In other words if an organisation in a sector is using the reference
version but peer companies are using the in accordance version, there
is an issue there.
59

I AGREE

Page 14 of 30

60

I recommend to abandonning Option B - either comply or explain within
Option A

Manuela HuckWettstein

Switzerland

Consultant

As anindividual61

For those who understand that various non-financial report framework
points to similar principles should find this change no difference tothem. Being 'in accordance' or 'with reference' or not may not imply areport is of high quality or not. If the objectives is just to measure towhat extent GRI Standards is being adopted, this is fine. Yet, thischange may mean a lot to those who consider 'core option' and'comprehensive option' as a benchmark of sustainability reporting
among its peers.

Marcus Chau

Hong Kong

Consultant

As anindividual62

The move away from Core and Comprehensive will make it really hardfor small and medium sized companies to report in accordance with thestandards. There simply are too many additional requirements, which
can be perceived as box ticking and compliance rather than helping todrive change within the company and industry.

Marjolein Baghuis

Netherlands

Consultant

As anindividual

63(1) The Approach A might be useful for companies at the initial stage of
their reporting process as it provides guidance on which topics theyshould consider as material.
Approach B is more likely to be used by multinationals with complex
operations, activities and supply chains, having already existing internalreporting systems in line with business strategies/broader sustainability
strategies.

MSC Mediterranean
Shipping Company
S.A.

Switzerland

Business

On behalf of anorganization,group orinstitution

64

this is fine. How do readers of sustainability reports differentiate
between the two. As ESG investing is a growing area, perhaps GRI canspread light on the difference of level of disclosure in light of growing
ESG requirements.

Nazish Shekha

PakistanNongovernmentorganization

As anindividual

65(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 no longer have a choice

NBIM

No response
provided

No response
provided

On behalf of anorganization,group orinstitution

Page 15 of 30

between ‘core’ and ‘comprehensive’ options. We believe these
proposed revisions will contribute to more comparable andcomprehensive sustainability reporting by companies.
66

This approach is a welcomed and is likely to encourage somecompanies who are either unable or unwilling to report in accordancewith the standard to provide some of the details required of the GRI
standards by reporting with reference to the GRI standards. The risk isthat companies will use this approach to report on areas that arefavourable to the organization and avoid challenges, risks and failures.
This places a responsibility on GRI to educate those using the report ofthe difference of the approach, the completeness of information of
those reporting in accordance with the GRI standards and potential
gaps in information provided by those companies reporting withreference to the GRI standards.

Network for
Sustainable
Financial Markets
CIC

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

67

Agree: Best to drop Core and Comprehensive and adopt Option “A” or
Option “B”.
Option “B” will be a good option if organisations properly reference andnot merely 'cite' GRI.

Next Level
Sustainability

Australia

GRI Certified
Training
Partner inAustralia

On behalf of anorganization,group orinstitution

68*Including the two approaches is very good and provides clarification
regarding the level of adherence to GRI standards and indicators.
However; I suggest highlighting in just one paragraph the (Benefit ofreporting in accordance with the GRI standards).
*Justification: Based on research, it is demonstrated that, as the level ofadherence to the GRI standards increases, the quality sustainability
reporting increases. Such quality is measured by GRI quality scale, e.g.
A+, A, B, C degrees for G3 standards previously. These benefits
include reporting consistency and benchmarking and most importantly
reporting on issues required by stakeholders.

Noha Abdelrahman

Egypt

Academic

As anindividual

Reference:
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.

Page 16 of 30

69(1) Turning core and comprehensive into one and only option of inaccordance with, and then also with reference to clarifies the readingfor external readers. It is also a good way to avoid inasmuch as
possible green washing. Two clearcut options is much simpler.

Not applicableFranceNo response
provided

As anindividual

70

Make clear what the expected impact is of these changes. Improving
quality of disclosures in one thing, but the changes should also makethings easier to reconcilie reporting on OECD, national and regionalguidelines, CDP, greenhouse gas frameworks, business and humanrights. Professional reporters have built in their reportable into systems,
processes, Governance. Every small change in the Standards
potentially triggers a big change in terms of time and Money implied inhaving to change systems.

Olaf Brugman

BrazilStandard
setterAs anindividual

71(1) 1. We agree that the new approach set out in section ‘3.
Sustainability reporting using the GRI Standards’ is less confusing fororganisations than the previous ‘core’ vs. ‘comprehensive’ approach.
We consider that it would be helpful also to emphasise that therecommended approach for companies with sufficient maturity insustainability management would be Approach A, and that therecommended approach for companies that are less mature in suchreporting would generally use Approach B with an aim to transition toapproach Approach A over time.

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

72

In agreement with the revisions

R&A Strategic
Communications

South Africa

No response
provided

No response
provided73

Option B provides more flexibility in a context with increasing
requirements in disclosure, that can help to optimise efforts in thissense.

REPSOL

Spain

PrivateCompany

On behalf of anorganization,group orinstitution74(1) The level required to meet “In Accordance” option will bechallenging even to those who have been reporting, “In Accordance –Core Option”. This is mainly because no omission is allowed for GRI
102, 103. Despite it being acceptable to say why a company might not

RHB Bank Berhad

Malaysia

Business

On behalf of anorganization,group orinstitution

Page 17 of 30

have such practices (in progress or indefinitely), this may not be
deemed favorable to the highest governance body or most senior
executive – thus, impacting their decision on whether to acknowledge
responsibility for the report/GRI Standards.
75(2) Further guidance or explanation for material topics with no GRI
Topic Standard (exposure draft line 320 – 325) – e.g. Digitalisation,
innovation and data privacy/cybersecurity. Through illustration, users
can have better clarity and certainty.

RHB Bank Berhad

Malaysia

Business

On behalf of anorganization,group orinstitution76

it is better cite the different among the these standards

RPMRG

Hungary

Consultant

On behalf of anorganization,group orinstitution

77

Very good choice. The previous "core" and "comprehensive" options
were not effectively used by organizations.

SAI Global Italia s.r.l.

Italy

No response
provided

No response
provided78(1) Supportive of these amendments.
I do like the removal of the core vs comprehensive requirement andshifting towards material topics reporting in general, which is aligned toa number of other reporting frameworks.

SAICA

South Africa

Nongovernmentorganization

On behalf of anorganization,group orinstitution

79(2) Options A and B are fine and we support the idea to give up the
distinction between core and comprehensive. Fine for Option A and B.

SchweryCade

Switzerland

Consultant

On behalf of anorganization,group orinstitution

80

The two approaches are understood.

Shelley Anderson

Australia

Consultant

As anindividual81

I disagree with the removal of "in accordance - core" option. Manycompanies report to the "core" option and remain so. GRI should
investigate into why this is, and what are the barriers for companies
reporting to the core option to upgrade to comprehensive, and try to

Simeon Cheng

Hong Kong

Business

As anindividual

Page 18 of 30

facilitate and encourage the upgrade, rather than to remove the core
option.
82

Option A is good to adopt

Sushil Pattanaik

India

Academic

As anindividual

83

Issues that are material to stakeholders are material to a company thathave a purpose to maximize stakeholder wellbeing. If the environmentand society-at-large are treated as special-case stakeholders, allsustainability issues are material to the company because they impact
the wellbeing of some or all of their stakeholders. 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 report theirimpacts on all sustainability issues. Mother Nature and Future
Generations don't care if the corporation is a bank or a steel mill; it justcares if the company is harming it.

Sustainability
Advantage

CanadaNo response
provided

No response
provided84

We believe that the A, B and C levels, as they existed in the G4
version, or the Core or Comprehensive option. as they are currently in
the Standards. are good for reporting processes as they allow
companies to be in intermediate stages of accountability and evolve
through years.

Sustenia

Argentina

Consultant

On behalf of anorganization,group orinstitution

85

The revisions will make reporting easier, especially with option B,
reporting in reference to the GRI Standards. This will allow more
flexibility for reports which adopt numerous guidelines and frameworks
for their reporting.

Tang Lien

Malaysia

Consultant

As anindividual86

I understand and support the change in principle, but anticipate that thiswill present a challenge for 'Core' reporters to meet.

Think Impact Pty Ltd

Australia

Consultant

On behalf of anorganization,group orinstitution

87

Much more clear in terms of how an organization is using the standards

Toronto Pearson
AirportCanadaBusiness

On behalf of anorganization,

Page 19 of 30

group or
institution
88

Our recent study on sustainability reporting of major German
companies found that some sustainability reports use only a small
number of GRI´s topic-specific standards (down to 12) and of the topicspecific disclosures ( down to 17). This raises the question of what itmeans to claim to be in accordance with GRI Standards. We think GRI
should define a minimum number of standards and disclosures thatmust be addressed in a sustainability report in order for an organization
to claim accordance with GRI Standards. The organization should set
the threshold for material topics (lines 2562 ff.) in such a way that itmeets this requirement.

Transparency
International
Deutschland e.V.

Germany

Nongovernmentorganization

On behalf of anorganization,group orinstitution

89

We support this decision

triple innova

Germany

Consultant

On behalf of anorganization,group orinstitution

90

It might be difficult for SMEs to fullfill the requirements in Option A. On
the other hand, Option B doesn't provide a balanced and complete
picture of the sustainability practices. Is it possible to provide "Option A"
for SMEs?

Trossa AB

SwedenConsultant

On behalf of anorganization,group orinstitution

91

For this point only a reflection. Removing the levels and making the useof the GRI guidelines a little stricter may affect their use for small andmedium sized enterprises.

UN Global Compact
Network Spain

Spain

Nongovernmentorganization

On behalf of anorganization,group orinstitution

92(1) We are of the view that, given the maturity of sustainability reportingand increase in mandatory requirements around the globe, that it isappropriate to strengthen the requirement to report in accordance withGRI Standards.

UNDP - SDG Impact
Team

UnitedStatesUN body

On behalf of anorganization,group orinstitution

93

I agree with the changes. Retaining the option to use selective optionsof the GRI Standards is understandable and the decision to remove"Core" and "Comprehensive" options approach is more streamlined,

University of DenverUnitedStatesNo response
provided

No response
provided

Page 20 of 30

transparent and direct. More importantly, it forces each organization to
be straightforward with their stakeholders and audience while
simultaneously allowing the audience to understand the extent to which
the GRI Standards were adhered to or just used as a reference point/
guide. Although it could be argued that this will increase the burden on
organizations which were previously Core reporters, after reviewing a
number of reports, many organizations go beyond those requirementson report on Governance disclosures anyway, as they will now be
required to do.
94(1) In general: Fine. I like a strict in accordance or not differentiation.
Four remarks:

ValoraSwitzerland

No response
provided

No response
provided1) At the same time, I like the reference standard. I fear that many Core
reporters will downgrade to comply with "with reference" only.
Therefore it might make sense to require some general disclosures(102) for "with reference", too.
95(3) Thirdly, very few reports that reference the GRI include a "statementof use."

WBCSD

Switzerland

Nongovernmentorganization

On behalf of anorganization,group orinstitution

96

WBA supports the revision to the two approaches for using the GRI
Standards, in particular now having only one option to report inaccordance with the GRI Standards and reasons for omission now only
applying to requirements, because we expect this will improve thequality and consistency of reporting, thus supporting our benchmarking
efforts.

World Benchmarking
Alliance

Netherlands

Benchmarking
foundation

On behalf of anorganization,group orinstitution

Page 21 of 30

5

2. Comments on appropriate disclosures

6

Please refer to page 13 in the Universal Standards exposure draft.

Name oforganization orindividualCountry

Stakeholder
group

Submission
type(2) The use of "not appropiate" should need more clarification. Is therequirement (a-b-c) or the disclosure the one who is not appropiate?

AG Sustentable

Argentina

Consultant

On behalf of anorganization,group orinstitution

2(1) Option A and B are ok but I believe it will be a challenge for assurers
and 3rd parties to verify if the company is reporting the "apropriate"
disclosures. How many disclosures are enough for a company to report"apropriate" disclosures on each material topic? It is subjective. The
definition of at least one material disclosure from the Core option was abetter / clearer criteria.

BSD CONSULTING

BrazilNo response
provided

No response
provided3(2) Line 149-154 specifies organisations “report the appropriate
disclosures from a Topic Standards” and have the flexibility to exclude
those that do not capture the organisation’s impacts. Such complexity
could potentially make disclosure difficult to compare, compromising the“comparability” principle.

CLP Holdings Ltd.

Hong Kong

Business

On behalf of anorganization,group orinstitution

4(3) Notably, we have concern that the current ‘appropriate disclosures’approach will allow for large variations in reporting and for organisations
to pick and choose among disclosures without transparent reasoning. If
the concept of appropriate disclosures is maintained, we recommendthat the organisation is also required to report which disclosures it has
found to be ‘not appropriate’ and state on which grounds in a manner
similar to requirements A-5-b.

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf of anorganization,group orinstitution

No.

Comment

1

Page 22 of 30

5(4) We also recommend that a human rights related example is added tocomplement the existing environmental example (line 311-319) of anorganisation having the defined a material topic based on impacts not
appropriately captured by an existing Topic Standard. We suggest that
this example is used to demonstrate what is considered appropriate
disclosure and to highlight that organizations may not use this evaluationof ‘appropriateness’ as a way to pick disclosures that are moreconvenient or may portray the organisations in a more desirable manner.

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf of anorganization,group orinstitution

6(2) As to the new approach to the disclosures Topic Standards, if theorganization will have the opportunity to decide, what to report and how
much disclosures, with a high probability it will choose to report less.
There can be manipulations.

Da-Strategy

RussianFederation

Consultant

On behalf of anorganization,group orinstitution

7(2) The propose approach A regarding appropriate disclosure could leadto different interpretation.

Eni SpA

Italy

Business

On behalf of anorganization,group orinstitution

8(3) Finally, in a Core option properly revised, companies could be
required to report on a small, well defined set of KPIs envisaged in the
Sector Standards (for examples GHG Emissions GRI 305-1 should becompulsory for an Oil & Gas company while for the others disclosure
should be up to the company to define which are very material) in order
to disclose on material topics in accordance with GRI. This would allow agreater comparability of non financial performances, at least among
peers.

Eni SpA

Italy

Business

On behalf of anorganization,group orinstitution

9(2) Requirement A-5 Report appropriate disclosures for each material
topic• For stakeholders, understanding whether "appropriate" topic
disclosures were chosen by the organization will depend on the qualityof the explanations around impacts and material topics that theorganization provides, given the flexibility gained in the new reporting
structure on choosing topics to report on.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

Page 23 of 30

10(3) Requirement A-5 Report appropriate disclosures for each material
topic• Requirement A-5 does not clarify whether all metrics within a topic
standard should be reported or that organizations can choose ONE toreport in full as per the previous guidance for Core. It does say that if notreported this needs to be explained, so it hints at full reporting of all
disclosures under a topic but allowing omissions including ‘notappropriate’. However, line 309 the draft states: when topic standards
include disclosures on a range of areas, the organization can selectthose that best relate to their impacts. Lines 311 -325 provide good
examples to clarify this requirement, however adjusting the text
explanations to make sure that does not mislead the user may bebeneficial.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

11(5) Questions raised by the changes - for consideration

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

Requirement A-5 Report appropriate disclosures for each material topic:• "For each material topic the organization is required to list theappropriate disclosures reported." A) What is the definition of‘appropriate’ in this instance? B) Does the organization chose one topic
disclosure or all related to the material topic? C) Within the topic
disclosure, are all sections or only one section required?
12(2) Organizations only required to report the appropriate disclosuresfrom a Topic Standards can better rule out immaterial topics with nosignificant impact to the organization.

Fuji Xerox (HongKong) Limited

Hong Kong

No response
provided

No response
provided13(1) ■ Under the proposed amendment, ‘appropriate disclosures’ would
be selected for each identified material topic from the GRI Topic
Standards, but we would like the definition of ‘appropriate disclosures’ tobe supplemented.
The reason for the supplementary explanation is that the understanding
and integration of ESG disclosure with management is still limited inmany companies.
A supplemental explanation of ‘appropriate disclosures’ is desirable tofacilitate integration with management and to help investors andGlobal Compact
Networking Japan- Study Committee
on Corporate
ReportingJapan

Generalincorporated
association

On behalf of anorganization,group orinstitution

Page 24 of 30

managers understand each other's view of ‘appropriate disclosures’ intheir company during an engagement.
14

Requirement A-5 (Line 287-294, Universal Exposure Draft) requiresorganisation to “report appropriate disclosures from the GRI Topic
Standards that correspond to the material topic” or to provide the thereason for omission and explain “if it cannot comply with a requirement
within an appropriate disclosure from a GRI Topic Standard identified” –e.g., to state that the reason for omission is “not appropriate”.
At the same time, Guidance to A-5-a provides an example in Line 311319, Universal Exposure Draft where an organisation, whose only formof energy consumed is purchased electricity, is not required to report on
Disclosure 305-1 Direct (Scope I) GHG emissions.
It may not be clear if a reason for omission is required for Disclosure305-1; or would it be acceptable if the organisation does not mention
Disclosure 305-1 at all in its GRI Content Index?

Han Wei Ho

Malaysia

Consultant

As an individual

15(1) Just to confirm if a topic is material but not all indicators in the topic
are material then the org. must explain the omissions but can still be inaccordance with the standards…

Liberty Holdings
LimitedSouth Africa

No response
provided

No response
provided

16(4) 5. More objective guidance should be provided for how companies
determine that a disclosure is ‘appropriate’, beyond merely referring to‘those that capture the impact’ of a material topic. We believe entities willoften struggle to determine based on a high level principle, if they haveto report one or more disclosures for each topic. Providing a more robust
and objective framework will help to drive consistency and will also help
assurance providers consider whether the entity’s assessments areappropriate. For instance, industry topics will provide additional
information and will help to avoid this. If there is not a clear framework to
describe measures that would be considered appropriate, this might leadto impaired comparability of reports and also to reduced reporting
quality.

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

17(5) 6. There should be additional guidance on an entity’s responsibility
where an ‘appropriate disclosure’ identified in the GRI Topic Standard is
not made in the entity’s report. That is, in the current proposals, it does

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,

Page 25 of 30

not appear that an explanation of the judgements made in determining‘why’ the disclosures are not appropriate needs to be disclosed by theorganisation. Where such explanatory disclosures are not required, this
could lead to reduced comparability which is an important demand fromstakeholders. Further, there is a risk of reporting bias with organisations
not reporting appropriate disclosures for the wrong reasons (or where atleast some stakeholders would perceive these to be the wrong reasons).
With the implementation of GRI Standards following GRI G4, the loss of
the requirement of having at least one indicator in place by topic has led
to a reduced number of overall indicators. Unfortunately, the current
exposure draft perpetuates this risk. A potential solution could be to
expect at least one disclosure for topic specific standard. We believe it
would be very rare that at least one indicator would not be appropriate,
and in those rare cases the topic specific standard would probably not
be related to a material topic of the company. However, in such rare
circumstances the entity should be required to include an explanation of
why an indicator was omitted. We believe the standard shouldemphasise that the process of identifying that a disclosure is‘appropriate’ should be supported by robust models, analysis andevidence, so that an assurance provider can consider whether theappropriate disclosures have been properly identified. (reference 294345).

group orinstitution

18(6) 7. The definition of ‘appropriate disclosure’ (reference 297-298)
should be included in the glossary because it is an important andpervasive concept.

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

19(2) 2) I don't understand, if all disclosures from one applicable topic need
to be reported to be in accordance. E.g. if "301 - materials" are material,
do I need to state why I report 301-2 and 301-3, but not 301-1? Or do I
have to report all of them?
3) Many material topics are a mix of two standards: E.G. our circular
initiatives are covered by parts of materials (301) and parts of waste(306). Say I choose 3 disclosures from 301 and 306, do I need to explain
why I am not reporting on all the other disclosures? If so: I fear, moststandards (especially the ones that haven't been renewed in more than

ValoraSwitzerland

No response
provided

No response
provided

Page 26 of 30

10 years) have too many KPIs that make little sense. I would hate toreason why I dislike reporting on them in my report.

Page 27 of 30

7

3. Comments on the reasons for omissions

8

Please refer to page 13 in the Universal Standards exposure draft.
Name oforganization orindividualCountry

Stakeholder
group

Submission
type(2) However, if a reporter cannot comply with a requirement within an
appropriate disclosure from a GRI Topic Standard, agree that thereporter has to provide the reason for omission.

City Developments
LimitedSingapore

Business

On behalf of anorganization,group orinstitution

2(3) What happens when the company, does not have the practice, or for
confidential or security reason the company cannot publish theinformation; Example, in Colombia, sharing the remuneration ofmanagers, can be dangerous. Some strategic issues can also be
confidential such as new exploration projects for a mining company.
Reason for ommisions should be used in many cases, especially in
Disclosure GOV-13 Remuneration policies. In this case, for example, theanswer cannot be "NO" because there is no "NOT EXIST" reason. In thiscase, companies that do not calculate or cannot show this gaps, musthave a space to explain. (some of governance requeriment are not a"HAVE or NOT HAVE" question, but they ask for numbers.

Daniela Winicki

Chile

Consultant

As an individual

3(4) Requirement A-5 Report appropriate disclosures for each material
topic• Guidance A-5b: lines 334-338 pose a challenge for assurance/
assessment of ‘in accordance’, because the terms ‘frequent’ and ‘critical’are not defined. This leaves room for interpretation, leaving it to theassurance provider to determine what is acceptable. ERM CVS suggest
the terms are rephrased, or properly defined.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

4(9) Requirement A-6 Publish a GRI content index:• Table 2: Reasons for omission: ERM CVS wonder what if anorganization can report a similar indicator but in different units of

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,

No.

Comment

1

Page 28 of 30

measurement or measures of impact? (For example, % of suppliers
evaluated vs number of supplier evaluated)? Would this be considered
an omission, or noted under the "Not appropriate" option? Or would it not
be noteworthy in the content index at all and just an adaptation that ispermitted in the "in accordance" requirements?
5group orinstitution(3) Under the proposed amendment, the disclosure requirements of GRI
102 and GRI 103 cannot be omitted. However, because of the influenceof factors such as social background and geographical situation, there
may be cases in which disclosure requirements differ between regions.
In that case, we would like you to consider the alternative of ‘satisfying
the disclosure requirement by explaining these factors’
For example, if there are differences in the board's approach or thematurity of diversity initiatives in Japan, we believe it is important to
explain the background and facts of these differences when conducting
the engagement.
Line 2280-2283 of the exposure draft states that “If the organization isunable to report the required information about an item specified in adisclosure because the item, e.g., a policy, practice, or other process,does not exist, it can meet the requirement by reporting this to be thecase”. Hence, why not add to this content the cases described above,i.e., "when it is not possible to satisfy the disclosure requirements due tofactors such as social background or geographic situation"?

Global Compact
Networking Japan

Japan

Generalincorporated
association

On behalf of anorganization,group orinstitution

6(7) 8. We would recommend that you reconsider the wording ‘does notalign with reporting in accordance with’, as this might lead to confusion
on whether a report is prepared in accordance with the standards or not
when validly omitting information. For example consider changing thewording to ‘does not align with the purpose of reporting in accordancewith’ or ‘Inappropriately omitting information would not comply’.
(reference 336-338)

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

7(8) We recommend that the standard explains more explicitly the scopeof the exception where an entity is ‘unable to report’ certain informationand that this exception would not include solely ‘confidentiality’concerns. Entities should also be required to use their best efforts toobtain information for reporting before asserting that it is unavailable.

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution- Study Committee
on Corporate
Reporting

Page 29 of 30

The guidance should specify that for an entity to be ‘in accordance’ with
GRI, it should make all the material information available. Where suchinformation is inappropriately omitted the standard should emphasisethat this would be a departure from GRI standards. In suchcircumstances, an assurance provider would need to evaluate theimpact on its report and whether a modification/modified opinion isrequired to reflect the departure from GRI standards.
8(2) Agree with the amendments to the reasons for omissions as believethese will support the clarity of disclosure.

SAICA

South Africa

Nongovernmentorganization

On behalf of anorganization,group orinstitution

9(2) Secondly, in practice, most companies only list a reason for omission
without going into further detail to explain it. Again, if companies are tofurther explain reasons behind omission, then GRI should re-emphasize.

WBCSD

Switzerland

Nongovernmentorganization

On behalf of anorganization,group orinstitution

Page 30 of 30