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

Item 02 – Public comments on topic
Boundary and sustainable
development dimensions in the
Universal Standards exposure draft
For GSSB discussionDate

4 December 2020

Meeting

10 December 2020

Project

GRI Universal Standards Project

Description

This document contains an extract of public comments related topic Boundary,and the dimensions of sustainable development, 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 9 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 10 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. Comments on topic Boundary ......................................................................................................... 3
2. Comments on human rights and climate change reporting ............................................................. 7
3. Comments on sustainable development dimensions .................................................................... 10
4. Comments on Disclosure RBC-2 Policy commitments ................................................................. 15

Page 2 of 16

2

Public comments3

1. Comments on topic Boundary

4

Please refer to lines 358-366 and 382-385 in the Explanatory memorandum.

5

Table 1. Comments on topic Boundary
Name oforganization orindividualCountry

Stakeholder
group

Submission
type(2) By a different perspective, the notion of topic boundaries could havestill helped the entity to understand the scope of its impacts. The lack ofthis concept should be compensated by a further stress and reliance on
stakeholders engagement activities especially during the first time
adoption of the standards.

Alessandro Mantini

Italy

Business

As an individual2

Deloitte supports the GRI103 disclosure simplifications and believes theremoval of the term “boundary” will be well received as we believe it hascaused much confusion over the years.

Deloitte

United States

Consultant

On behalf of anorganization,group orinstitution

3

I personally saw the value of the topic boundary concept and drew theattention of report users to its importance in the past. Understanding the
topic boundary application per company makes it easier to prorate to afull picture and make comparisons among industry peers. But i am surea lot of though went into this revision so i won’t contest it.

Eszter Vitorino

Netherlands

Investor

As an individual

4(3) Further clarity and guidance are required in order to determine
boundaries to an organisation’s responsibilities and the impacts it isaccountable for.

EuropeanAccounting
Association's

CanadaAcademic

On behalf of anorganization,

No.

Comment

1

Page 3 of 16

Stakeholder
Reporting Committeegroup orinstitution5(7) MT-2 Material topics and related impacts• 103-1-b has been revised: It now requires reporting, for each material
topic, whether the organization is involved with the negative impacts
through its own activities or because of its business relationships (seeMT-2-b-ii). In addition, the term 'topic Boundary' is no longer used. ERM
CVS recommends retaining ‘Topic boundary’ as, based on our
experience, a material topic such as water stress can be very significant
but within a very specific (organisational) boundary and this may beneeded for stakeholder understanding. Alternatively, adding a note on
identification of where the impact occurs or is significant within theorganization's operations would add further transparency.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

6

Removal of the term topic boundary and revision of concept brings moreclarity on reporting impacts for a material topic, by dividing into actualand potential, positive and negative.

Fuji Xerox (HongKong) Limited

Hong Kong

No response

No response

Step 2 of identifying material topics (Clause 2380) helps organization to
identify impacts in a more comprehensive way than current GRI 103,
clarifying that organization should consider actual and potential negative
impacts it causes or contributes to through its own activities, as well as
those directly linked to its operations, products, or services by its
business relationships. This aligns with “Balance”, the reporting
principles (Clause 476).
7Line 358,removal of topic boundary needs to be carefully studied again
as it is the essential concept for organizations' value chain.

International
Development Centerof JapanJapan

No response

No response

8

The DIHR is concerned that the Standards do not adequately reflect thatsome human rights issues are very context specific, whereas others are
wide-spread and that for a company’s due diligence to be effective andaligned with the UNGPs it needs to be implemented corporate wide inboth a horizontal and vertical understanding of that term, i.e. acrossfunctions and across regional and country level presences. Relatedly,

Danish Institute for
Human Rights

Denmark

National
human rights
institution

On behalf of anorganization,group orinstitution

Page 4 of 16when reporting material topics in accordance with MT-2, the Standards
should support organisations in including topics that may be of context
specific nature, but still considered material as well as topics that may beof relevance throughout a company. For instance, it is useful tounderstand whether a material topic is considered a group-wide issue oris a concern only in select countries of operation or in connection withselect products or business segments. Secondly, we are not convincedthat the Standards adequately capture the degree to which a reportingorganisation is involved with or exposed to the impacts of a given
material topic. MT-2-b does not currently guarantee that reportingorganisations provide readers with insight into these dimensions,although the guidance for MT-2-b-ii addresses the issue in part.
To ensure these important contextual pieces of information aredisclosed, DIHR recommends adding a new requirement iii to MT-2-b.
Suggested text: ‘MT-2-b-iii describe how and to which extent theorganisation is exposed to the material topic’. Associated guidanceshould encourage reporting organisations to disclose whether thematerial topic is considered material across the organisation or is
included due to its relevance to certain geographies, products, activities
or similar AND to provide context on the magnitude of the company’s
exposure to the risk (e.g. insight into how big a share of the company’s
suppliers or company subsidiaries are estimated to be exposed to thematerial topic.
9

Lines 541 – 543 (p. 21) Completeness (also cross-reference Lines 989
et seq a for Disclosure REP-2 of Organization’s entities included in its
sustainability reporting, p. 40). The Universal Standards should statethat organizations should state the scope for completeness purposes,
and, where some facilities are excluded (including only for someparameters), the organization should state so at the appropriate
location(s) in the report, and provide the basis for this. The Universal
Standards and guidance state or imply that the non-financial reporting
should be complete. This is impractical in many cases, or at least forsome parameters. It may be feasible to report on some topics that are
centrally managed, and apply across the entire organization - such as
human resources policies. Some material topics may apply at larger
facilities, but not at others – such as water usage and wastewater

Douglas Hileman

United States

Consultant

As an individual

Page 5 of 16

generation in a large organization with satellite offices or employees
working from home. “Materiality” can apply to some locations, andperhaps for some topics at those locations.
10

Identification of material topics and related impacts; Guidance to MT-I-aI and MT-I-a-ii. GRI should provide a mechanism for material topics tobe identified by the organization at the aggregated level, and that
additional material topics can be reported as appropriate for selectedorganizational units or high-profile topics with more limited financial andoperational footprint at the organization. The selection of material topics
is done at the aggregated level of an organization, consistent withconsolidated financial reporting. However, sustainability topics can bematerial at a dis-aggregated level from an environmental or people/
human rights perspective. A diversified global organization could haveone business unit that uses chocolate as a raw material, posting risk offorced labor or child labor in the supply chain. Another diversified
organization can have a small unit that uses electronics in a product,
posing risk of conflict minerals, use of banned or restricted substances,or products’ improper disposal. Although GRI emphasizes thatmateriality must consider topics through the eyes of others, the process
still favors aggregation, and eliminating many issues that pose
substantial risk.

Douglas Hileman

United States

Consultant

As an individual

11(5) In Identifying impact (2443-2451) the GRI listed a number of levels tocarry out the initial assessment, what is missing in the GRI Standards isthe consideration of facility-level data in the scoping of materiality topics,
particularly in industrial sectors. The lack of addressing this level in the
GRI Standards and the prominence of aggregates in the reports could
impact the principle of Clarity (489) and the contextualisation of the data
particularly for companies operating in different locations. This has adirect impact on materiality and material topics that vary acrossgeography and sector, and thus impact disclosures on performance.

Dr Aljaohra Altuwaijri

Saudi Arabia

Academic

As an individual

Page 6 of 16

6

2. Comments on human rights and climate change reporting

7

Table 2. Comments on human rights and climate change reporting
Name oforganization orindividualCountry

Stakeholder
group

Submission
type

Reporting on human rights has become fundamental and compulsory in
the proposed revision. Based on GRI Standards 2016, human rightsrelated topic disclosures are reportable only if it is one of the reporter'smaterial issues. This is a good implementation to push reporters toreport on its impact on human rights issues.

City Developments
LimitedSingapore

Business

On behalf of anorganization,group orinstitution(2) The revisions are welcomed. The focus on impacts is important - asis highlighting human rights.

ELEVATE

Hong Kong

No response

On behalf of anorganization,group orinstitution

ERM

United States

Consultant

On behalf of anorganization,group orinstitution

No.

Comment

1

2

Alignment with other guidance is a step in the right direction. The
language used in sustainability circles needs to be clearly defined withshared understanding of meaning.
3

There is a lot of emphasis on the importance of human rights impacts
throughout the standards in a way that could be seen as too humancentered and too focused on individual legal rights rather than on
broader sustainability impacts. This includes the statement: “The mostacute impacts an organization can have on people are those thatnegatively impact their human rights.” (GRI 101, Ln 135-136). This
statement seems to take a very broad view of human rights as the lensthrough which any impacts on people should be viewed; for example it
could be interpreted to mean that the most important element of aworkplace fatality is the infringement of a person’s right to live rather
than that they are dead. In general, the U.S. corporate community does
not view human rights on such broad terms and further clarity andeducation would be needed in order to ensure that many U.S.
companies continue using GRI.

Page 7 of 16

4(2) Adding further definition on human rights in this context would bepositive to help organizations define their impact in this area.
Acknowledgement of human rights impacts may be a challenge fororganizations in certain regions, such as North America. However, ERM
CVS believes it is a good addition to bring this conversation to the table.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

5

To be aligned with UNGP and the OECD Due Diligence Guidance for
Responsible Business Conduct impacts on human rights/ salient issues
should be emphasized.

Ethcial Trade
NorwayNorwayMSI

On behalf of anorganization,group orinstitution

6

We welcome the focus on human rights, due diligence, responsible
business conduct, governance and verifiability of data.

Institution of
Occupational Safety
and Health (IOSH)

UnitedKingdom

Charteredbody for
OSH
Professionals

On behalf of anorganization,group orinstitution

7(2) Human rights should not be a required general disclosure. Not allcompanies have (material) issues with human rights.

ISOS Group

United States

Consultant

On behalf of anorganization,group orinstitution

8

The integration of the human rights lens has enhanced the Universal
Standards.

KPMG

Australia

Consultant

On behalf of anorganization,group orinstitution

9(5) These proposed revisions will integrate reporting on human rights in
the GRI’s Universal Standards and apply to all companies reporting
according to the GRI. We consider this an important and positive
development that can contribute to more comprehensive corporate
human rights reporting. As we explain in our Expectations on Human
Rights, we believe that all companies have a responsibility to respecthuman rights in their own operations, as well as in supply chains andother business relationships.2 Respecting human rights is an inherent
part of good business practice and risk management. Companies should
integrate human rights considerations into their policies, corporate

Norges Bank
Investment
Management (NBIM)

NorwayInvestor

On behalf of anorganization,group orinstitution

Page 8 of 16

strategy, risk management and reporting.
We expect companies to disclose their human rights strategies, policies
and processes and to report on their implementation of relevantinternational standards. They should, for example, disclose information
about their human rights policy commitment, governance structures, due
diligence, including risk and impact assessments, taking a value chain
perspective. Information about stakeholder engagement and remediation
processes should also be disclosed where appropriate. Performance
reporting should include relevant metrics that enable year-on-yearcomparison.
10(2) Climate change is a material topic for all sectors and should be
mandatory.

Shelley Anderson

Australia

Consultant

As an individual

Page 9 of 16

8

3. Comments on sustainable development dimensions

9

These comments relate to the sustainable development dimensions covered in the definition of ‘material topic’: impacts on the economy, environment, and10people, including impacts on human rights.

11

Please refer to pages 8 and 103 in the Universal Standards exposure draft.

12

Table 3. Comments on sustainable development dimensions
Name oforganization orindividualCountry

Stakeholder
group

Submission
type(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 be brought back to impacts on people. As there are many
prepares (especially in developed countries) for which impacts onhuman rights are not material (due to the presence of a working andeffective regulatory framework), the introduction of this specific measurefacing a principle-based approach could be redundant.

Alessandro Mantini

Italy

Business

As an individual2(2) However, I suggest wording : impacts on people, planet,
communities and economies. I do not think it is necessary to specifically
call out human rights in this definition. Impacts on people andcommunities includes human rights. But people could be construed as
individuals, where in many cases, companies are central players in local
communities and economies, which specifically refers to groups ofpeople, so I think this should be more explicit.

Beyond Business Ltd

IsraelNo response

On behalf of anorganization,group orinstitution

3(2) However, the COVID19 pandemic has brought economic and social
turmoil and tragedy, bringing a new dimension to risk, impact andresponsibility regarding nature – the world must halt the loss of
biodiversity and put nature on a path to recovery by 2030. We would
therefore like to see a specific mention of nature (biodiversity andecosystems) in the new materiality definition, accompanying the addition

BirdLife International

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

No.

Comment

1

Page 10 of 16

of human rights: ‘topic that reflects the organization’s most significant
impacts on the economy, environment, and people, including impacts onhuman rights AND NATURE’.

4(2) Materiality
We recognize the need to uphold human rights and eradicate theirabuse, and support global efforts that support this goal. As such, we
support the inclusion of human rights within GRI’s proposed definition ofmateriality, as it is a non-diversifiable risk that affects all industries, andtherefore requires special attention. However, we also believe thatclimate change is a universal, non-diversifiable 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 alongside human rights
within GRI’s definition of materiality.

Deloitte

United States

Consultant

On behalf of anorganization,group orinstitution

5

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

Dr Aljaohra Altuwaijri

Saudi Arabia

Academic

As an individual

6(4) However, we note that that the definition of ‘material topic’ still favors
and prioritizes the financial & economic impact, at least in order of thelisted impacts. Therefore, we urge to revise the definition as follows:

EuropeanAccounting
Association's
Stakeholder
Reporting Committee

CanadaAcademic

On behalf of anorganization,group orinstitution

Institution of
Occupational Safety
and Health (IOSH)

UnitedKingdom

Charteredbody for
OSH
Professionals

On behalf of anorganization,group orinstitution‘topic that reflects the organization’s most significant impacts on theenvironment, the people (including impacts on human rights) and theeconomy’7(2) we would suggest that the latter reads "topic that reflects theorganization’s significant impacts on the economy, environment, andpeople, including impacts on their safety, health, wellbeing and humanPage 11 of 16

rights". We believe this would help emphasise important OSH issues asmaterial topics.
8

Explicitly including "impact on human rights" is unnecessary as "impact
on people" already comprises human rights. This line of thinking (whenincluding "human right") 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 an individual

9(1) The definition of sustainability set out in lines 31 – 43 underpins thestandards and we support the approach adopted to requireorganisations to consider both positive and negative impacts.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

Next Level
Sustainability

Australia

GRI Certified
Training
Partner inAustralia

On behalf of anorganization,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 start from, it is very vague and opens the door for impression
management. This means that it leaves room for companies to evadethe spirit of the GRI standards and present themselves in the best
possible light, whilst still meeting the standards. In the amendments thisroom is reduced due to the introduction of references to ‘human rights’.
However, it is not clear why the issue of human 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 – 17 dimensions 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 the text of the GRI
standards would be further aligned.
10

A GRI Technical Committee on Human Rights Disclosure is inevitably
going to want to emphasise human rights in the definition; but if there
was a TC on Climate Risk it might put a global heating augmentation
onto 'environment' and so on. Best to have a principle of weighted

Page 12 of 16

equality in the definition: economy, environment and people. Since thenew definition changes ‘society’ to ‘people’ that should be thecompromise with explanatory text on human rights included in the
Universal Standards and topic specific standards elsewhere.
Concern: The new definition of material topic skews the whole emphasisof the GRI Standards towards a human rights framework which isinconsistent with the triple bottom line intent. The emphasis on "impact
on human rights" is out of proportion to what might be material in a given
jurisdiction, and potentially marginalises environmental impacts such as
climate change (global heating) as a material issue. The new
qualification of ‘society’ defined as ‘people’ creates an immediate conflict
between environmental impacts and people impacts because humanrights 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 better emphasised 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, climatechange/global heating and occupation health and safety." [Note I've
replaced “anti-corruption” with “human rights” and “water and effluents”
with “climate change/global heating”].
11

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

Prysmian GroupItaly

No response

No response

12(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.

RHB Bank Berhad

Malaysia

Business

On behalf of anorganization,group orinstitution

Page 13 of 16

This would assist in ensuring alignment between material topic definition
and ESG rating requirements or expectations.

13(2) My concern is adding ‘including human rights’ as this seems toelevate this topic over other topics. Human rights is included as part ofthe considerations of the materiality determination process, therefore am
not clear as to the elevation. Is the intention that any negative humanrights impact will trump all other impacts? If so, suggest that highlight
this, as this is a significant emphasis of a particular topic.

SAICA

South Africa

Nongovernmentorganization

On behalf of anorganization,group orinstitution

14(2) MT: This revision creates more confusion as it refers to the TBL
People/Planet/Profit.

SchweryCade

Switzerland

Consultant

On behalf of anorganization,group orinstitution

15(3) The addition " including impacts on human rights" sounds very
strange assuming that we could understand the impact on thesociety/people excluding human right issues.

SchweryCade

Switzerland

Consultant

On behalf of anorganization,group orinstitution

16

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

SGS

China

No response

No response

17(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 of anorganization,group orinstitution

13

Page 14 of 16

14

4. Comments on Disclosure RBC-2 Policy commitments

15

These comments relate to the scope of Disclosure RBC-2 Policy commitments.

16

Please refer to page 60 in the Universal Standards exposure draft.

17

Table 4. Comments on Disclosure RBC-2 Policy commitments
Name oforganization orindividualCountry

Stakeholder
group

Submission
type

While we agree with the requirements on disclosures of policy
commitments, on human rights, we also believe GRI should go further
and explicitly reference climate policies, including commitments that are
made in line with the Paris agreement.
We are concerned that the omission of climate mitigation could sendreporters the wrong message about responsible business conduct. We
believe climate commitments and targets, including (potentially) sciencebased targets should be included in the scope of responsible business.
We also note that the reference in line 1655 to the UN declaration on
environment in connection with health and the environment does notinclude an explicit linkage to the Paris agreement.

Deloitte

United States

Consultant

On behalf of anorganization,group orinstitution

2

Anti-corruption should be one of the topics that is explicitly listed here as
one of the policy commitments that should be described. Corruption is
an issue of responsible business conduct that affects all others, and is arisk in literally every country in the world.

Engineers Without
Borders Canada

CanadaNo response

No response

3(1) Policy commitments – Requirement a. overlaps with that of theindividual topic disclosures for the material topics identified by theorganization. Requesting this two-fold, though in a slightly different
context seems unnecessary. This could be specifically about humanrights only.

ERM Certification
and Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

No.

Comment

1

Page 15 of 16

4(1) - Adding disclosure of policy commitments to internationallyrecognised instruments and to respect human rights is relevant.

Network for
Sustainable Financial
Markets CIC

UnitedKingdom

Nongovernmentorganization

On behalf of anorganization,group orinstitution

Page 16 of 16