gssbsecretariat@globalreporting.org

Item 04 – GSSB Work Program2023-2025 Public comment
feedback
Date
2023
For
GSSB14 March
information
Meeting

28-29 March 2023

Description

This document presents the comments received during the Public Comment
Period on the exposure draft of the GSSB Work Program 2023-2025. The
exposure draft was made available for public comment from 17 November 2022 to
17 February 2023.
The GSSB members are invited review the comments received on the draft GSSBWork Program 2023-2025 and
1) Provide observations on the comments received.
2) Provide Work Program prioritization(s) and recommendation(s) in casethese are not reflected in the draft GSSB Work Program 2023-2025

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 2023

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Comments received
AASB - Australian Accounting Standards Board
AMB - Anton Mifsud-Bonnici
Australian Red Cross/ICRC/RMIT
Deloitte
EIRIS
Fundación Once
Geneva Center for Security Sector Goverance – DCAFFBRH (presentation, petitions)Greenlam
LSE Ideas
Meat and Livestock Australia
NOREA
SAICA
SHoP Architects
TNFD
Trust Works

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Postal Address
PO Box 204
Collins Street West VIC 8007
Telephone: (03) 9617 7600

GSSB Secretariat
Global Sustainability Standards BoardP O Box 10039
1001 EA
Amsterdam
The Netherlands
17 February 2023
Dear Ms Kuszewski,
Draft GSSB Work Program 2023-2025
The Australian Accounting Standards Board (AASB) is pleased to have the opportunity toprovide comments on the GSSB’s Draft Work Program 2023-2025 consultation, issued in
November 2022.
Overall, the AASB is supportive of the proposals and prioritisation of projects as set out in the
Draft GSSB Work Program 2023-2025. However, given there is no specific guidance
addressing issues particular to the public sector, the AASB encourages the GSSB to progressa public sector GRI Sector Standard project from its research phase to a standard development
stage as soon as possible.
Additionally, given the industries’ importance to Australia, the AASB is supportive of the
GSSB advancing the development of Sector Standards for financial services, mining, metal
processing and forestry.
The Appendix to this letter includes the AASB’s comments to the questions asked in the
consultation document.
If you have any questions regarding this letter, please do not hesitate to contact me or Siobhan
Hammond, Acting Director, AASB Sustainability Reporting (shammond@aasb.gov.au).
Yours sincerely,

Dr Keith Kendall
Chair, Australian Accounting Standards Board

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Appendix
AASB responses to questions raised in the Draft GSSB Work Program 2023-2025

Question – Should the GSSB change the order of prioritization of the existing GRI
Topic Standards for review during the period covered by this work program?
The AASB supports the order of prioritisation of GRI Topic Standards for review in 20232025.
The AASB notes that the first three revision projects (Biodiversity, Labour and Climatechange) listed in Table 1 of the draft work program have already commenced and that theybroadly align with the anticipated direction of the International Sustainability Standards
Board. Therefore, the AASB supports the priority they have been given.

Question – Which topics should the GSSB prioritize for the development of new GRI
Topic Standards during the period covered by this work program?
The AASB is highly supportive of the development of a Topic Standard that addresses
digitisation, data protection, cybersecurity and privacy given there have recently been anumber of high-profile data breaches within Australia.1 Furthermore, in response to the
AASB’s Invitation to Comment (ITC) 46 AASB Agenda Consultation 2022-2026,
respondents commented that data privacy and management2 was an important topic that
could be addressed as part of sustainability reporting.

Are there any sectors currently listed in priority groups 2, 3, and 4 in the list ofprioritized sectors that should be prioritized for development during the period
covered by this work program?
The AASB is highly supportive of the prioritisation of a Sector Standard on financial
services due to the industry’s importance for all economies. The AASB is also supportiveof the prioritisation of Sector Standard projects on mining, forestry and metal processing,
not only because of their importance as industries in Australia, but also because of theirpotential to have a significant impact on the environment and sustainability in general.
Furthermore, because of the potential impact on human rights and the environment, the
AASB also supports the prioritisation of a Sector Standard on textile and apparel.
However, given there is no specific Sector Standard addressing public sector issues, the
AASB encourages this project be progressed from the research phase to the standard
development stage as a matter of priority. Recent AASB public consultations addressing
1

2

In 2022 there were two high profile data breaches in Australia – a telecommunications company (Optus) and a private healthinsurer (Medibank Private). In both cases, hackers released customer information on the dark web, and for some Medibank
Private customers this included private and sensitive medical data. For more information on these data breaches see:•https://www.abc.net.au/news/2022-10-03/optus-data-breach-cyber-attack-deloitte-review-audit/101496190•
https://www.abc.net.au/news/2022-10-20/medibank-cyber-attack-hack-stolen-data/101557122
https://www.aasb.gov.au/media/ylwp41rf/3-4_sr_feedbacksummary_itc46_m185_pp.pdf#page=7

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sustainability reporting3 reflected a high level of engagement from the public sector.
Feedback to these public consultations indicates there is support from Australian public
sector entities for sustainability reporting but that because IFRS Sustainability DisclosureStandards have an investor focus, they may not be entirely suitable for use by the public
sector. Therefore, the AASB is of the view that a Sector Standard that addresses topics
particular to the public sector would help facilitate sustainability reporting by the public
sector.
What activities or materials should the GSSB prioritize with regard to cooperation
with other standard-setting bodies and international organizations?
The AASB encourages the GSSB to continue its efforts to develop a digital taxonomy thatis compatible with other standard-setters. This will contribute to the alignment ofinternational sustainability standards and their interoperability.
The AASB commends the GSSB for the connections already made with leading standardsetting bodies and international organisations and encourages the GSSB to continue to form
connections as appropriate.
The AASB strongly urges the GSSB to utilise its connection with the International Public
Sector Accounting Standards Board (IPSASB) to identify public sector specific issues
related to sustainability reporting. This will not only aid the GSSB in developing a public
sector Sector Standard but could also help the IPSASB with furthering its own project on
Advancing Public Sector Sustainability Reporting.

3

The AASB consulted on sustainability reporting as a part of three public consultation documents:•
ITC 46 AASB Agenda consultation 2022-2026 – October 2021•
ITC 48 Extended External Reporting – November 2021•
ED 321 Request for Comment on ISSB [Draft] IFRS S1 General Requirements for Disclosure of Sustainability-related
Financial Information and [Draft] IFRS S2 Climate-related Disclosures

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OFFICIAL

6 February 2023
Attn: GSSB Secretariat
Global Sustainability Standards Board
By email: gssbsecretariat@globalreporting.org
Dear Global Sustainability Standards Board
Re:

Public Comment GSSB Work Program 2023-2025
The integration of international humanitarian law and armed conflict sensitivity into
GRI Standards

We welcome this opportunity to submit to the Global Sustainability Standards Board (GSSB) ourcomments on the draft GSSB Work Program 2023-2025, specifically Consultation Annex 2
regarding the development of new Topic Standards (pages 27-29). Australian Red Cross, RMIT
University and the International Committee of the Red Cross (ICRC) wholeheartedly welcome thereferences to international humanitarian law (IHL) and conflict sensitivity into the draft GSSBWork Program 2023-2025, and encourage their greater integration into the GSSB’s activities.
We encourage the GSSB to not only consider the importance and relevance of IHL and conflictsensitivity when revising existing standards, but to prioritise these topics when developing new
GRI standards. Indeed, we recommend the development of a stand-alone conflict sensitivity and
IHL standard.
The undersigned are well-placed to offer these comments and recommendations. Australian Red
Cross and RMIT University have engaged in a multi-year collaboration engaging the Australianand global corporate community on the relevance of IHL to business and developing guidanceand educational resources. The ICRC, considered ‘custodians of IHL’, draws on decades of
constructive dialogue with State and non-State actors, including companies, in armed conflictsituations.
It is our shared assessment that businesses with operations in, or connections to, conflictaffected areas are not sufficiently equipped with the knowledge and tools they need to respondto the specific risks that arise in conflict contexts, for instance the implementation of heightenedhuman rights due diligence. Further, we have found there is a lack of awareness among
businesses of the unique rights, protections and responsibilities that flow directly from IHL – thelegal framework that regulates armed conflict.

IHL and conflict sensitivity in reporting
An IHL/conflict sensitivity GRI standard would respond to a clear need within the responsible
business sector. How to engage in armed conflict situations is a major “sustainability/ESG”
question confronting many companies, and one which the war in Ukraine has certainly brought
to the fore. Many responsible companies are seeking frameworks and responses to manage their
engagement with conflict situations.
A GRI standard would not only provide a practical framework to report (and act) on IHL andconflict sensitivity, but would provide a powerful signal to investors and the entire ESG
community that this issue of armed conflict should be prioritised in their sustainability reportingand considerations. Doing so would also echo the United Nations Guiding Principles on Businessand Human Rights that call for a focus on conflict-affected areas, as it is there that the mostegregious human rights abuses occur. It would also build on existing legal obligations such as
those under the US Dodd-Frank and EU Conflict Minerals Regulation, which are intended tomitigate corporate harms in conflict zones. However, GRI standards could go beyond the limited
reporting requirements of these laws, for instance by applying to all sectors and range ofactivities that impact conflict-affected communities, not just those related to the extraction ofnatural resources.
Commendably, the GSSB and GRI have been willing to lead on providing industry human rights
reporting frameworks, and keep its standards up to date with various governance requirements
for industry, including GRI 412 on human rights assessment and ensuring alignment with the UN
Guiding Principles on Business and Human Rights and OECD Guidelines on Multinational
Enterprises.
The GRI has independent standards on child labour, security practices, indigenous peoples, andnon-discrimination. The addition of an IHL/conflict sensitivity standard would continue thispractice, and reinforce the GRI’s position as a leader in providing human rights reporting
frameworks and guidelines that are responsive to both business needs and emerging governancerequirements. In the interim, guidance for reporting entities on how and where IHL and conflictsensitivity could be incorporated into existing standards is recommended.
What are IHL and conflict sensitivity?
IHL – also known as the laws of war or the law of armed conflict – is the specialist body of law
that regulates situations of armed conflict. Its fundamental aim is to limit suffering in war byprotecting persons who are not taking part in the fighting (such as civilians, wounded soldiersand prisoners of war) and regulating the means and methods of warfare, including particular
types of weapons.
Importantly, IHL is not the same as human rights law. The two sets of international law arecomplementary and both strive to protect the lives and dignity of individuals, but they are also
distinct, contained in different treaties and have developed separately over time. In situationsof armed conflict, additional legal obligations arise under IHL – adding to, and in some2circumstances replacing, the rules and principles of human rights law – extending responsibilities
to anyone with a close connection to the conflict, including companies and their personnel.
Failure to comply with IHL may translate into criminal and civil liabilities. In the most serious
cases of IHL violations, companies and associated individuals may face war crimes charges andprosecutions. There have been, and continue to be, high profile prosecutions and investigationsof corporate involvement in war crimes in several jurisdictions, including France and the UnitedStates.
A conflict sensitive approach emphasises effectively preventing, managing and addressing
conflict, including by seeking to understand conflict dynamics and related risks. Companies
conduct a conflict sensitivity analysis to identify how they relate to these dynamics and how to
avoid causing, exacerbating or driving conflict.
The relevance of IHL and conflict sensitivity to business
It is globally recognised that businesses operating in conflict-affected areas – as well as thosewith supply chains, partners or customers in these environments – face heightened risks of
involvement in serious violations of human rights and humanitarian law. Additionally, businesses
may unintentionally contribute to the grievances and drivers of conflict. This includes uniquerisks under IHL, as distinct from more commonly understood human rights-related risks. For
example:

Committing or being complicit in pillage, that is, acquiring property or natural resources
without the freely given consent of the owner;
Criminal liability risks relating to military occupation, for example involvement,
participation or assistance in settling civilians in occupied territories, and maintaining ordeveloping settlements;
Committing or being complicit in the forced displacement of, or attacks on, civilians fora reason relating to armed conflict; andLosing the protected civilian status afforded to businesses by failing to carefully manage
their operations, personnel and connections to the ongoing armed conflict, thus
becoming a potential military objective (for instance, when company security providers
engage in hostilities).

Recommendations
Respect for IHL is a crucial facet of achieving responsible business conduct in conflict-affectedareas and in helping to safeguard the lives and dignity of the local communities affected. It is ourhope that continued commitment from the GSSB to consider and integrate IHL into GRI standard
setting will further global efforts to see the adoption of genuinely conflict-sensitive approaches
to business in conflict-affected areas, while also strengthening the quality offerings of the GRI.
With this in mind, we reiterate our initial recommendations:

3





IHL/conflict sensitive-specific standard: first, and foremost, the development of a topicspecific standard on IHL and armed conflict, with corresponding reporting guidance.
Gap analysis of existing GRI standards and guidance: an assessment of existing GRI
standards and guidance to identify potential areas for IHL and conflict sensitivity inclusion
in reporting; andEducation/training in IHL: support for the enhancement of education and training in IHL
and conflict sensitivity among businesses.

Conclusion
The ongoing conflict in Ukraine, and corporate responses to it, have highlighted the need for
greater corporate awareness of business risks and responsibilities, and the legal protections
afforded to business actors, under IHL. Beyond Ukraine, the impact of armed conflicts – from
Myanmar to Yemen, Mali, Afghanistan and many more – continues to be felt by individuals,
communities and the environment across the globe. It is clear that all societal actors have a roleto play in minimising human suffering in such situations. Indeed, there is a need and an
opportunity for the GSSB to take up this responsibility.
A ‘Human Rights Standard’ for responsible business reporting, which does not include mentionof IHL or conflict sensitivity is, in our opinion, incomplete. A GRI topic standard, and a navigation
document or some other form of reporting guidance on IHL, must be introduced in order tocomprehensively assess corporate impact and guide their behaviour in conflict contexts.
Australian Red Cross, RMIT University and the ICRC would welcome the opportunity to support
or assist in the development of such an initiative.
Yours sincerely,

Ms Fauve Kurnadi
Legal Adviser – Private Sector Engagement
International Humanitarian Law
Australian Red Cross
Email: fkurnadi@redcross.org.au

Dr Jonathan Kolieb
Senior Lecturer | Peace and Conflict Lead
Business and Human Rights Centre
RMIT University
Email: jonathan.kolieb@rmit.edu.au

Mr Claude Voillat
Economic Adviser
International Committee of the Red Cross
Email: cvoillat@icrc.org

4List of relevant resources (written or edited by the undersigned)Australian Red Cross and RMIT University, Doing Responsible Business in Armed Conflict:
Risks, Rights and Responsibilities (June 2020)
https://www.redcross.org.au/getmedia/7ef922ac-7360-4bd9-97f9fb9517547eba/Doing-Responsible-Business-in-Armed-Conflict-final-publicationWEB.pdf.aspx

Australian Red Cross and RMIT University, Seven Indicators of Corporate Best Practice inInternational Humanitarian Law (January 2021)
https://www.redcross.org.au/getmedia/7a742c8c-e184-4c0b-9146-ae4e2edef8bc/7indicators-of-corp-best-prac-FINAL-2021.pdf.aspx

Geneva Centre for Security Sector Governance, International Committee of the Red
Cross, and Geneva Center for Business and Human Rights, Addressing Security and
Human Rights Challenges in Complex Environments: A Practical Toolkit (2022)
https://securityhumanrightshub.org/toolkit/a-practical-toolkit.pdf

Jonathan Kolieb, ‘Don’t forget the Geneva Conventions: achieving responsible businessconduct in conflict-affected areas through adherence to international humanitarian
law,’ Australian Journal of Human Rights (2020) Vol. 26:1, 142-164.
https://doi.org/10.1080/1323238X.2020.1792137



Fauve Kurnadi and Jonathan Kolieb, ‘The importance of the laws of war to companies’,
The Laws of War Blog, Australian Red Cross (2021)
https://www.redcross.org.au/stories/ihl/the-importance-of-the-laws-of-war-tocompanies/Australian Red Cross and RMIT University, War, Law and Business: A Module on IHL for
Future Business Leaders (an interactive, online training module on IHL for business)(2021) https://ihl.redcross.org.au/

5Deloitte Touche Tohmatsu Limited
2 New Street Square
LondonEC4A 3BZ

16 February 2023

Phone: +44 (0)20 7936 3000
Fax: +44 (0)20 7583 1198
www.deloitte.com/about
Direct phone: 020 7007 0884
vepoole@deloitte.co.uk

Global Sustainability Standards Board
Barbara Strozzilaan 101
1083 HN Amsterdam
The Netherlands
Via email only: gssbsecretariat@globalreporting.org

Dear Ms Kuszewski
Comment on the Draft GSSB Work Program 2023-2025
Deloitte Touche Tohmatsu Limited is pleased to comment on the draft Global Sustainability Standards
Board (GSSB) Work Program 2023-2025 and the Project Schedule 2023.
We fully support the role the Global Reporting Initiative (GRI) plays in enhancing companies’ transparency
and accountability on their impacts on the economy, the environment, and people, through reporting tostakeholders. We consider this to be an integral part of a comprehensive global corporate reporting
system that encompasses reporting on sustainability matters relevant to capital markets participants, andon those matters relevant to stakeholders more broadly.
We make some high-level observations below in response to the questions in the consultation.
Should the GSSB change the order of prioritisation of the existing GRI Topic Standards for review during theperiod covered by this work programme?
We have no direct suggestions on the proposed order of prioritisation for reviewing the existing GRI Topic
Standards. However, we consider that, as an overall approach, revisions to the GRI Standards should seek
to enhance interoperability with those developed and issued by the International Sustainability Standards
Board (ISSB) and other significant sustainability standards-setters such as EFRAG. This is particularly
important when those standards are under development and there is therefore an opportunity to work
bilaterally to achieve greater alignment. We strongly encourage the GSSB to take into consideration thepriorities and workplans of the ISSB and other standards-setters when finalising its own workplan. We
consider that alignment, where possible, of terminology, structure, disclosures, and metrics is essential, tohelp to reduce the reporting burden for companies and enhance the consistency and comparability ofreported information.

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and theirrelated entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide
services to clients. Please see www.deloitte.com/about for a more detailed description of DTTL and its member firms.
Deloitte Touche Tohmatsu Limited is a private company limited by guarantee incorporated in England & Wales under company number 07271800, and its registeredoffice is 1 New Street Square, London, EC4A 3HQ, United Kingdom.
© 2023 . For information, contact Deloitte Touche Tohmatsu Limited.

Which topics should the GSSB prioritise for the development of new GRI Topic Standards during the period
covered by this work programme?
Of the priorities referenced in the document, we agree that expanding coverage of climate-related
matters is important, in particular, coverage of adaptation and resilience, transition planning, and justtransition.
Companies also highlight to us the increasing importance to them of reporting on social matters. We
would therefore support the GSSB giving further priority to social topics. We consider that expanding
existing content on the rights of indigenous peoples, economic inclusion and modern slavery areimportant both for public policy and business. We further note that the living wage was included in the‘expanded metrics’ identified by the World Economic Forum in its Stakeholder Capitalism Metrics project,
and therefore companies have identified its relevance as a business issue.
Furthermore, given the increasing prevalence of technology, and its impact on employees and society
more broadly, we agree that the GSSB should consider broadening its coverage on data privacy andrelated areas. We observe that there is an increasing connection between technology/digital services andsocial cohesion, and encourage the GSSB to consider whether it should prioritise coverage of the broader
impacts arising from digitalisation.
In the light of the agreement of the UN Convention on Biological Diversity at COP15, we conclude thatbusiness will be increasingly expected to identify, measure, manage and report on its impacts on natureand biodiversity. In that regard, we welcome the progress the GSSB has already made towards the revised
GRI Standard 304 on Biodiversity. We consider there may be a case for further content on companies’
impacts on natural ecosystems (either directly or through the value chain), to the extent this is notcomprehensively addressed in the revised standard.
As before, we urge the GSSB to liaise closely with the ISSB and other standards-setters with the view ofaligning the prioritisation of revised and new topical standards as far as possible, and so that eachstandards-setter may develop new standards that are interoperable with others, while still meeting theobjectives of their own standards. In that regard, we note that the ISSB has announced its intention toenhance climate-related disclosures with further coverage of natural ecosystems and the just transition. It
has also indicated it will consider a number of topics for future development, including biodiversity,
ecosystems and ecosystem services; human capital, with an initial focus on diversity, equity and inclusion;and human rights, with an initial focus on labour rights and communities’ rights in the value chain. We
encourage the ISSB and the GSSB to align their development programmes as far as possible.
We also emphasise the importance of continuing to work with EFRAG and the Taskforce on Nature-related
Financial Disclosures. In the case of transition planning, we think consideration should be given to
recommendations and frameworks being developed by various task forces and other bodies – forexample, in the UK by the Transition Plan Taskforce.
Are there any sectors currently listed in priority groups 2, 3, and 4 in the list of prioritized sectors thatshould be prioritized for development during the period covered by this work programme?
In our comments above on priorities for new topics to be considered for development as standards, weemphasised the increasing importance of social topics to business. While we support the need forstandards that address sectors that have the most significant environmental impacts, we encourage the2

GSSB further to consider whether sectors that may have low environmental impacts but high impacts onsociety and its prosperity more generally have been sufficiently prioritised.
We suggest that the GSSB should discuss and consider the plans of the ISSB for industry guidance and also
standards in sectors being addressed by EFRAG to maximise opportunities for alignment (for example,
agriculture and transportation).
Finally, we observe that the activities of SMEs may lead to high impact on the economy, the environment,
and people, including through their role in the value chain of the largest companies. As a result, suchcompanies are increasingly coming into scope of mandatory sustainability reporting. Proportionality may
therefore become a more important consideration for the GSSB when developing its standards.
What activities or materials should the GSSB prioritise with regard to co-operation with other standardsetting bodies and international organizations?
We welcome the GSSB co-operating with the ISSB and other global and jurisdictional standards-setting
bodies to advance complementarity and interoperability between standards. In that regard, we believethat the Workplan identifies the primary organisations that the GSSB should co-operate with, although we
believe the Taskforce for Nature-related Financial Disclosures should also be explicitly included, especiallyas the GRI and the GSSB already collaborate through their respective work on biodiversity and nature.
As we have written elsewhere in this response, we consider it important that the GSSB seeks to maximisealignment on establishing priorities for standards-setting and on the content of standards themselves, toachieve interoperability such that the same definitions, disclosure requirements and metrics are used
when they are consistent with the objectives of the standards-setter.
We consider it a priority overall that the GRI and the GSSB cooperate with the ISSB to the maximum
extent. We therefore welcome the collaboration agreement concluded by the two organisations as a basis
for pursuing that aim. In particular, we think it is important that the GRI and the GSSB advocate for andare active participants in developing a global comprehensive and interoperable system for corporate
reporting of sustainability information. This system should bring together the baseline of sustainability
information that drives enterprise value, which is essential to capital markets and their ability to direct
capital to long-term, resilient business; and reporting related to the information needs of broader
stakeholders primarily concerned with an entity’s impacts on the economy, the environment, and people.
The ISSB’s IFRS Sustainability Disclosure Standards and the GRI Standards should be viewed as the sets ofinterrelated and compatible standards that serve the two distinct perspectives making up this global
comprehensive corporate reporting system. At the level of development of standards, the cooperation
should aim to achieve commonality, connectivity and interoperability, when possible, between the two
sets of standards.
We also believe that the GSSB should continue to work closely with EFRAG, with the aim to support thedevelopment of European Sustainability Reporting Standards that take account of internationalsustainability standards to the greatest extent possible (including the GRI Standards) and therefore to help
achieve a global baseline of sustainability information for capital markets and greater consistency inreporting to other stakeholders.
The Workplan references cooperation with the International Audit and Assurance Standards Board (theIAASB). We observe that companies are increasingly seeking external assurance over their sustainability
disclosures to enhance confidence and trust in reported information. Some jurisdictions are introducing
3

mandatory assurance of sustainability disclosures. We therefore welcome GSSB’s collaboration with the
IAASB, and underline the importance that the GSSB continues to work to ensure the GRI Standards aredeveloped to enable them to be considered as suitable criteria for the purposes of assurance assignmentsin accordance with the characteristics of suitable criteria set out in the International Standard on
Assurance Engagements 3000 Revised (ISAE 3000) and as may be further developed by the IAASB in its
ISSA 5000 series.
Finally, we note an increasing interest in greater measurement of impacts, including the potential formonetisation of sustainability impacts. We work with a number of organisations around the world that aredeveloping impact measurement frameworks and methodologies. We suggest that the GSSB continues tomonitor developments in this space, and note that the GRI and the GSSB may be able to play a role in the
future to convene some of these organisations with the aim of encouraging alignment of thinking andoutputs and promote consistency with the GRI Standards.

Yours sincerely

Veronica Poole
Global IFRS and Corporate Reporting Leader
Deloitte Touche Tohmatsu Limited

4

NonProfit Center
89 South St, Boston
Massachusetts, 02111
reports@sudan.eiriscrn.org
eiriscrn.net
17 February 2023
Global Sustainability Standards Board
Barbara Strozzilaan 101
1083 HN Amsterdam
The Netherlands
Re: Public Comment GSSB Work Program 2023-2025 The integration of international humanitarian
law and armed conflict sensitivity into GRI Standards
Dear Global Sustainability Standards Board:
On behalf of The EIRIS Conflict Risk Network (CRN), we thank you for the opportunity to submit
comments on the draft GSSB Work Program 2023-2025, specifically Consultation Annex 2 regarding thedevelopment of new Topic Standards in pages 27-29. EIRIS CRN strongly supports the greater integrationof international humanitarian law (IHL) and conflict sensitivity into the GRI Standards and guidance.
As an organization that conducts research and assessment on the business activities of companies
operating in conflict affected areas, we have observed that majority of these corporations are
insufficiently equipped with the knowledge and tools needed to properly prepare and respond tosituations of conflict. We have researched companies active in Sudan for many years, supported an EIRISFoundation project on occupied territories taking Crimea and Palestine as examples and more recently
undertaken research on companies active in Burma/Myanmar. In our research on company reports andrecords, as well as our engagement with them, there is very little or no mention at all of heightenedhuman rights due diligence or IHL and companies seem unclear what information it would beappropriate to report publicly.
Emphasizing the importance of heightened human rights due diligence
Given the dire situation armed conflict places populations in, it is important to stress to companies thevalue of conducting and reporting on heightened human rights due diligence. Armed conflict can inmany ways exacerbate the human rights abuses happening within a region and make companies more
vulnerable to being complicit in these abuses due to strained or weak governance. Whether companies
are aware of it or not, they could inadvertently be financing or supplying an oppressive regime. By
conducting research on ways companies could be complicit in human rights abuses in armed conflict andproviding them with parallel research on the relevance of IHL and the effectiveness of heightenedhuman rights due diligence to reducing the vulnerability of their situation GRI would help companies
report convincingly on the risks they face and the action they have taken.
Providing companies with well founded research on the relevance of IHL and heightened human rights
due diligence, introducing educational material and training courses on the subject would also help
companies understand the difference between IHL and fundamental human rights, as well as the added
responsibilities expected of a company which operates in a conflict affected area. Additionally,
introducing practical guidance on IHL for reporting would send a strong signal to companies that armed
conflict should be prioritized in their ESG considerations and reporting. Having specific guidance on IHL

would not only help companies operating in conflict affected areas, but it would also help investors
facilitate their engagement with said companies and their investment decisions.
Aiding investment decisions
At the onset of the Russian invasion of Ukraine, investors rushed to respond adeptly to the situation andsanctions implemented by several countries, including the United States and the European Union.
Several questions arose during this period including what the most responsible course of action was totake, the appropriateness of divestment, and the process of responsible exit for companies. Hesitations
in decision making arose during this time due to concerns regarding a double standard in relation toother conflicts and a recognition that while every conflict is different and needs to be addressed incontext, there is also a need for some level of consistency in approach. If guidance and tools were to beprovided by the GRI on IHL for reporting, this could serve as a starting point for investors to engage
more specifically with companies on the subject and then perhaps form their own consistent standards
for addressing the issue of conflict from an investor standpoint.
Groups of investors have come together to make statements on Burma/Myanmar, Sudan & Russia (seebelow), which demonstrates the appetite amongst investors for this information. But corporate
disclosure is currently well short of the information investors would need to assess whether companies
are following the steps investors have called for.
Conclusion
The ongoing conflict in Ukraine and how companies have responded to it have highlighted the need for
greater corporate awareness of business risks and responsibilities, and the legal protections afforded tocompanies, under IHL. Until now the impact of conflict in other countries such as Myanmar and Sudan
continues to affect the lives of individuals. The continuing effects of these conflicts are a clear sign that
more can be done to help reduce their harmful impact. A GRI Standard reporting guidance andadditional training materials on IHL would go a long way in helping companies assess the impact of theirbusiness activities to conflict and guide their behavior moving forward.
Yours sincerely,Peter WebsterCEO
EIRIS Conflict Risk Network

Samantha Chua
Sr. Project Manager
EIRIS Conflict Risk Network

Investor statements• https://eiriscrn.net/wp-content/uploads/2021/12/sudan-with-signatures-for-web.pdf• https://media.businesshumanrights.org/media/documents/Investor_Statement_on_the_Crisis_in_Ukraine_16_May_2
022.pdf• https://investorsforhumanrights.org/sites/default/files/attachments/202107/Investor%20Statement%20on%20Human%20Rights%20in%20Myanmar%2016%20July%202
021.pdf

Public Comment GSSB Work Program 2023-2025
Persons with disabilities represent more than 1 billion people in the world,being a large group of population experimenting different forms of inequality,
exclusion, disadvantage and discrimination.
The 2030 Agenda and the Sustainable Development Goals (SDG) recognize
persons with disabilities as a vulnerable group of population and makes explicit
reference to them in different SDGs and targets. Relevant efforts are still needed
to improve their situation in many areas such as education, employment andaccessibility of goods and services, where business can play an important role.
A broad approach of the SDGs and the situation of persons with disabilities canbe found here.
The UN Convention on the Rights of Persons with Disabilities, ratified bymore than 180 countries, is a legally binding instrument setting minimum
standards for rights of people with disabilities, placing the matter of disability inthe very heart of Human Rights.
Global Reporting Initiative has had a longstanding alliance with Fundación
ONCE, based on the vision that disability is part of the sustainability agenda. As
a result, both organizations have been collaborating in different ways, including
the publication of the Guide “Disability in Sustainability reporting” first in 2015,
and updated in 2019. Both organizations are currently working together to update
again its content according to the new GRI Universal Standards.
Fundación ONCE welcomes the work undertaken by GRI and the GSSB to
update and amplify GRI Standards, as the reference worldwide universal
guidance for sustainability reporting. The Foundation also welcomes theopportunity for stakeholders to comment on the process ahead, reflected in the
Draft work program 2023-2026, highlighting the following ideas:-

There is an opportunity to better integrate disability matters in the revisionof the Labor standards, encouraging GRI and the GSSB to take stock of
the specific work developed in the past in this field, as well as to count withexpert advice and opinion of organizations representing and working withpersons with disabilities.

-

Disability matters are also relevant within other Topic standard revision
processes such as the ones regarding: economic impacts, customer
impact, procurement practices, digitalization and data privacy.

-We also encourage GRI to consider the development of a specificStandard on persons with disabilities, that could integrate all thedifferent aspects related to this vulnerable group of population.

We would like to highlight that persons with disabilities can be understood as animportant stakeholder group from a 360º perspective: they can be employees,
users/consumer/clients (where universal accessibility and design for all becomes
key for real inclusion), part of the supply chain and, of course members, of thelocal community.
Fundación ONCE remains at GRI and GSSB’s entire disposal to further
contribute to the revision and development of new topic standards.

*About Fundación ONCE
Fundación ONCE is a Spanish foundation dedicated to improve the social andlabor inclusion of persons with all types of disabilities, with a main focus on theareas of training, employment and accessibility of products, services andenvironments. Fundación ONCE is founded by the National Organization of theBlind in Spain (ONCE). Also, besides its founder, the different organizations
representing persons with disabilities are included in the Foundation’s Board ofTrusties.
Fundación ONCE collaborates with the business sector, public authorities,
education institutions and civil society in Spain, Europe and at international levelto generate inclusion opportunities and better integrate the disability dimension
into the sustainability agenda.
Fundación ONCE, its founder ONCE and the social business group ILUNION,
form all together the ONCE Social Group, which employs near 73,000 workers,
almost 60% persons with disabilities. The ONCE Social Group is the largest nonpublic employer in Spain and the largest employer of persons with disabilities
worldwide.

13 February 2023

Attn: GSSB Secretariat
Global Sustainability Standards Board
By email: gssbsecretariat@globalreporting.org

Re:

Public Comment GSSB Work Program 2023-2025

Dear Global Sustainability Standards Board,We, the Geneva Centre for Security Sector Governance (DCAF), welcome this opportunity to submit to the
Global Sustainability Standards Board (GSSB) our comments on the draft GSSB Work Program 2023-2025.
As a short background, DCAF is a Swiss-based international foundation dedicated to improving the securityof states and their people within a framework of democratic governance, the rule of law, respect for humanrights, and gender equality. Since 2012, DCAF has partnered with the International Committee of the Red
Cross (ICRC) to promote responsible business conduct and respect for the security, rights and dignity of
local communities as described here: https://securityhumanrightshub.org/.
Addressing security and human rights in GSSB’s planned work program (line 227)
Although security has typically been associated as a concern for extractives companies in the oil and gas
or mining industries, there is increasing acknowledgement that companies in a broad range of sectors must
increase scrutiny over their security arrangements, particularly in conflict-affected and high-risk areas.
Security arrangements, security providers, and interactions with security forces and actors create humanrights risks for all companies, whether it relates to their field operations, supply chains, or contractors.
Equally, if left unaddressed, any human rights issue has the potential to escalate into a security incident
with significant consequences for host communities. Security and human rights risks create a feedback
loop of potential problems. Security is therefore a cross-cutting and essential component of human rights
due diligence processes, as well as corporate reporting on environmental, social and governance issues.
In alignment with the letter submitted by DCAF and ICRC in October 2022 to the GSSB, DCAF welcomesthe fact that that the review of GRI: Security Practices is slated to begin in 2024. With regards to the GRISector Standards, we also welcome that the mining standard has been released for public comment on 7
February 2023. DCAF looks forward to providing feedback and reviewing the standard closely forsuggestions on incorporation of strengthened security and other important human rights perspectives.

Research and expert support on security and human rights (line 228)
DCAF encourages the GRI to assess the interlinked issues of security and business in conflict and theirtransversality across all the standards. To this end, we reiterate our interest in undertaking a mapping/gap
analysis of challenges and opportunities for the GRI Standards to incorporate these issues in a crosscutting way. Other practical reporting guidance tools could be included in the mapping, such as expanding
the GRI’s “Reporting in Practice” case studies to include security and human rights-related reporting(whether sector or topic-specific, or grouping together several sectors and topics).
Support for new topic standard on conflict sensitivity and international humanitarian law (line 233)
As many businesses have operations in conflict-affected or high-risk areas, DCAF puts forward two
recommendations:
1) DCAF recommends that the GSSB ensures that international humanitarian law (IHL) and conflictsensitivity is incorporated into existing standards that are being revised. A mapping of IHL and conflictsensitivity elements in the GRI standards could accompany a security mapping (as recommended above).
2) DCAF recommends that the GSSB develops a standalone topic-specific standard on IHL and heighteneddue diligence for companies operating in conflict-affected and high-risk areas. In such situations, the ruleof law may be weak and companies do not have the tools nor the practical know-how on addressing theirimpacts. The GRI meanwhile, does not have a dedicated and comprehensive standard for assessing
business in conflict. Additionally, the existing GRI standards (in particular the human rights standard) do
not clearly make the link between human rights, security and conflict situations. This leaves a significant
gap in accountability.
We look forward to supporting the GRI in strengthening security and human rights in its standards. We
thank you for consideration of our suggestions and remain at your disposal for any questions.

p.o.

Alan Bryden
Head, Business and Security Division
DCAF- Geneva Centre for Security Sector GovernanceYEARS

Why we believe it is essential the

GSSB prioritises
the GRI Education Services
Sector Standard
Empowering 235m Students*
for a Sustainable Future* UNESCO https://www.unesco.org/en/higher-education

Simon Pitsillides, MBA, FIEMA, FCIM, MIoJ, GRI & IEMA Trainer, GRI Certiﬁed Sustainability Professional

Our aim: Empowering 235 million university students to start understanding significant impacts
and take action in their future professions

Arguably, universities and other teaching institutions’
most important impact concerns teaching students the
skills they need to conduct their future professions
in a sustainable and responsible way.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

2

The enormity and diversity of the continuously
evolving sustainability challenges in our worldnecessitate that each future employee/ expert iscapable of identifying /addressing them eﬀectively
within their unique area of expertise.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

3

Our aim: Empowering 235 million university students to start understanding significant impacts
and take action in their future professions

The world is currently facing a crucial moment
where many leaders appear to lack the will and determination
to meet the sustainability goals deﬁned by experts.
The GSSB’s decision to prioritize the development of standards for themost harmful sectors is a wise one, as it targets the most important “ﬁres”(most pressing issues our world is facing) we need to address .

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

4Our aim: Empowering 235 million university students to start understanding significant impacts
and take action in their future professions

The question we ask is:what will it take for the GRI Education Services Sector Standard to be developed
ASAP and in parallel with the GSSB’s solid prioritisation programme’s thinking,to ensure that the future workforce of 235 million employees possesses thenecessary skills not only to prevent “ﬁres” from igniting,but also to eﬀectively extinguish them as future experts in their ﬁelds?

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

5With this approach we will be building aproactive and sustainable world, together

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

6Percentage of courses which include the identification of significant impacts

Percentage of courses which include
the identiﬁcation of signiﬁcant impacts
Once the GRI Education Services Sector Standard
proceedings are launched, FBRH will take action,
through the GRI’s robust, transparent and multistakeholder approach to include a speciﬁc indicator.
YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

7Percentage of courses which include the identification of significant impacts

An indicator that will require organisations to provide
the percentage of courses which include theidentiﬁcation of signiﬁcant impacts (economy,
environment and society) using a process such as the
GRI’s 4-step approach (materiality).

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

8

Why a GRI Education Sector Standard is a necessity

Why a GRI Education Sector Standard is a necessity
The power of the GRI Sector Standards lies in two very important aspects:
1. A list of a sector’s most signiﬁcant impacts is clearly deﬁned in the
public interest through a transparent, multi-stakeholder approach(academia, business, experts, governments etc.) which includes aperiod of public comment.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

9

Why a GRI Education Sector Standard is a necessity

2. Organisations are required to either show how they are taking action
related to these signiﬁcant impacts, or provide the reason why they
consider a signiﬁcant impact not applicable for them (depends on theirvalue chain position). This level of transparency is an extremely
powerful driver for change.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

10Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possible

Other reasons why is it important that GRI
and the GSSB prepare the Education Services
Sector Standard as soon as possible

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

11Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possible

1) GRI has a principled approach to sustainability.
Preparing sustainability standards in the public interest
using a transparent, multi-stakeholder approach is a very
credible way to conduct sustainability that does not only
focus on a speciﬁc stakeholder group’s needs (e.g. investors).

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

12Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possible

2) GRI’s robust methodology to identify signiﬁcant
impacts (double materiality). In our experience, as
GRI Certiﬁed Training Partners, this methodology(GRI-3, 4-step approach) can be taught
in half a day. It will therefore not impact in a big way
course programmes.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

13

Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possible3) Sustainability needs to be embedded into the DNA oforganisations. It will be a game changer with potentially 235m
students understanding how signiﬁcant impacts are identiﬁedusing a principled approach (double materiality).
a) All inter-company departments need to be responsible forassessing impacts and outpacing competitors in aligning with thegreen economy (gaining competitive advantage is the win-win forthe company and the world).
YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

14

Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possibleb) Future employees have the skill set to be able
to call out bad practices. This will beneﬁt boththe organisation and the world.

YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

15

Other reasons why is it important that GRI and the GSSB prepare the
Education Services Sector Standard as soon as possible

4) Increasing the uptake of the GRI Standards.
Providing the ﬁrst comprehensive sector standard for education
will make it natural for organisations in this sector to gravitate
towards it. If signiﬁcant impact identiﬁcation (in the
curriculum of every course) is part of the likely material topics,
students across the world might learn GRI’s principled approachto sustainability and use it in their future professions.
YEARS

We help business gain value by operating in much cleverer, sustainable ways

www.fbrh.co.uk

16

YEARS

thank you!

Simon Pitsillides, MBA, FIEMA, FCIM, GRI & IEMA Trainer

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Empowering 235m Students for a Sustainable Future:
Request from GSSB an Education Standard
203 have signed. Let’s get to 500!
At 500 signatures, this petition ismore likely to be featured inrecommendations!
Iris Charalambidou signed 1 hour ago
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Empowering 235m Students for a
Sustainable Future: Request from…
GSSB an Education Standard

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Building a proactive and sustainable world, together
Positive change does not come through wishful thinking. Our busy andcomplicated world will continually face many challenges on many fronts.
Beyond climate change, other main challenges we need to deal with include:
other aspects of planetary pollution and destruction (eg. waste, plastics),
Biodiversity loss (which also affects food security), human rights, inequality(digital and economic), mental health deterioration, and social cohesion
erosion.

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Our aim: Mobilising 235 million university students to startunderstanding significant impacts and take action in their future
professions
Arguably, universities and other teaching institutions’ most important impact
concerns teaching students the skills they need to conduct their future
professions in a sustainable and responsible way. Only after proper andprincipled significant impact identification (on economy, society, people), canthe other sustainability steps begin to be implemented (measure, manage
and change). Preparing students to take real action to continually addresssignificant impacts where these matter.

The goal of this petition
To achieve the above aim our goal is to convince the GRI Global
Sustainability Standards Board (GSSB) to work on the Education services
sector standard as a top priority in the work programme that has been
defined for the next three years.
The Global Sustainability Standards Board (GSSB) is currently seeking publiccomment on its 2023-2025 Work Program. GSSB is soliciting stakeholder
feedback on questions including: “Are there any sectors … that should beprioritized for development during the period covered by this work
program?”
The results of this petition - to prioritise development of an Education Sector
Standard - will be shared with GSSB on Feb 17, 2023 as a response to thesolicited feedback.

Why an Education Sector GRI Standard is a necessity
The power of the GRI Sector Standards lies in two very important aspects:
1. A list of a sector’s most significant impacts is clearly defined in
the public interest through a transparent, multi-stakeholder
approach (academia, business, experts, governments etc.)
which includes a period of public comment.
2. Organisations are required to either show how they are taking
action related to these significant impacts, or provide thereason why they consider (a significant impact) not applicablefor them (depends on their value chain position). This level oftransparency is an extremely powerful driver for change.
A GRI Education Sector Standard will therefore help organisations focus theirefforts on their significant impacts as these have been clearly defined
through this robust multi stakeholder and transparent GRI process.
Report a policy violation

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update you post will be sent as a separate email to signers ofyour petition.

100 supporters

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Simon Pitsillides started this petition

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Reasons for signing
I’m signing because…

Fiona Gillespie · 1 week ago

YES! Great idea which MUST be done ASAP, the future of our species IS in
their hands... Us elders need to show them the way, as we too arefighting for the future of us ALL!
3 ·Share ·

Tweet

Nancy Palmer · 7 days ago

I’m concerned about the fate of our environment and want to see achange1 ·Share ·

Tweet

William Cook · 1 week ago

It's the future for these students
1 ·Share ·

Tweet

Richard Boyle · 1 week ago

Sounds a smart idea
1 ·Share ·

Tweet

John Kavaliauskas · 1 week ago

For our future.
1 ·Share ·

Tweet

Vernon Taylor · 1 week ago

It is true today's students will eventually making the major decisions;making policy and governing the world - it is necessary they should leave
education with the most appropriate core skills for their future roles.
The first thing they should learn is nothing is sustainable … Read more
0 · Report

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thissummer.
Wecafesareetc.
on Ecclesall& Abbeydale
roadtalking
about scenariosthat arein andour nearsurrounding
areas.
thewelack
footfallwill
future. Scenarios
thatareofnotprepared
inevitably
force
job losseslake
andhasbusinessfor because
Windermere
alreadyclosuresof many independent
local
become eutrophic.
We now seeand
blue-green
business’
algal blooms in Windermere even in thedepths of winter. Blue-green algae can killyour dog and will hospitalise you if you
swallow it when swimming. This is not
Promoted by 24 supporters
speculation. A gentleman has come forward
after he contracted Campylobacter after

Save MidlothianSureswimming
in Windermere
and Start
accidentally
Family Learning
Centres water
swallowing
its water. Windermere'squality
is declining
with theimpacton
Please sign
this petition
to savefrontline
human
only becoming
worse.
If
serviceshealthin Midlothian.
Midlothiancouncila…

Beatrice. Today,
SignBeatrice
the petitionis on the road totheirsupply chains.
But even
when theirconfinedin cagesat factories,…
hens will still be used in many industries and
Him Hoo, DCEO and Director-General Anim…
up to 8 million hens will still be caged in the&Veterinary
Read more Service - Dr Chan Siow Foong,
UK every year. The only way to stop thisGroup Director Animal &Veterinary Service suffering is for the UK Governments to ban
Mr Joshua Teoh, Director Objective: To ban
this outdated
practice
once and for all. The
Dog AwarenessownersChained
from keeping
dogs as guard dogs
in14,524
UK is a Sg
nation of animal lovers and we’ve
factories, workshops and religious grounds
shown time and again that we want betterunless the below conditions are met: - theprotections for animals. The UK
Sign
dog must be
kepttheawaypetition
from a fireGovernments must ban cages for all laying
hazardous environment, free fromhens by 2026. Thank you for taking action
dangerous materials, free from constantfor animals. Mia Fernyhough, Animal Welfare
noise and air pollutions and exposure toSpecialist and hen rescuer with The Humane
weather elements. - If chaining or confining
League UK, the Conservative Animal Welfare
a dog is for safety reason, the adequate
Foundation and the RSPCA. Want to learn
shelter must meet the following
more about Beatrice? Follow her story!
requirements: A space with a radius of 10m

temperaturerisen
by 1.7°C in
70 years.
commitment has
holds
tremendous
promiseforThis
is just demanding
one invertebrate
my sisters
more species
for theirwhich
lives. isapivotalpart of Windermere's
But
a commitment
only countsfreshwaterif a© 2023, Change.org, PBC
ecosystem
andjustTheoneGlobal
of several
speciescommitment
is is
kept.
Partnership

Iran, we are going to need hundreds ofattacked by a white female student, her…
thousands more signatures. Join us tosisters
and mother right outside her school Read morepressure global powers to raise their voices
Thomas Knyvett college. No attempt wasfor these people, unfairly sentenced tomade by anyone to stop this vicious attack.
death: Mohammad Ghobadloo Saeed Shirazi
The principal
at thisImoniorocollege, casually strolls
Magdalene
124,231
Mohammad Broghni Abolfazl Mehri Hossein
into the scene and does nothing to break up
Hajiloo Manouchehr Mehmannavaz Ali
the fight. He allows the perpetrators of the
Rakhshani (15 years old) Mohammad
Signthepetition
crime to walk
away
after
inflicting bodily
Rakhshani (15 years old) Shoaib Mirbaloochharm on the young girl. Enough is enough!
Zehi Rigi Hassan Firouzi Mehdi Bahman
Black Lives Matter!
Javad Roohi Mehdi Mohammadi fard (18years old) Arshia Takdastan (18 years old)
Kambiz Khorvet (20 years old) Saleh Mir
Hashemi Majid Kazemi Saeed Yaghobi
Ebrahim Naroeei Mansor Dahmardewith an approved well designed shelter withseparate space for resting, feeding and its
toilet needs. The specs can be discuss later.
Proper animal husbandry include providing
Promotedby 378supporters
properfood, clean
shelterand protection

Promoted by 240 supporters

against diseases to be enforced. This should
include:makingsure the animal
is diseaseSupport
earthquake
victimsinfree
by takingannual vaccination. Full blood
Syrialift sanctions
check including 4Dx to check for heartworm
The earthquake that hit Syria and Turkey
and tick fever annually. Enclosure should beearlier last week means that thousands of…
clean daily to maintain hygiene. Dog should
peopleare dying. In Syria the situation is
Read more
be placed on heartworm and tick prevention
especially bad because global aid
on a monthly basis. An assigned staff or its
organizations are struggling to transfer
caregiver has to commit to walk the dog
money Zeinoor medicine
toZeino across the border due
33,606
twice a day. Each walk to be at least 30mins.
international sanctions on Syria. Syrians who
Dog must be licensed and comply with theare still living in Syria have suffered greatly
animal welfare guidelines or they will bein recent years.
SignPeople
the petition
are being deprived of
fined up to $5000. Unlicensed and/or
their basic needs. Food, drinking water,
unsterilised dogs discovered in theirenergy, safe accommodation, medical
premises will immediately fall under the
suppliesand many more to mention are
TNRM area and will be handled in the besteither not available or extremely expensive.
interest of the animal. That is: TNRM
This was initially a result of the conflict, but it(Trap.Neuter.Release.Management) or
has been much worse after more sanctions
rehome.
If you believe all dogs,
were imposed on the Syrian trade andboth strays and pedigree are of the same
manufacturing sectors. The pandemic madeworth, please sign this petition to change
the humanitarian crisis much worse and thethe fate of this group of suffering dogs. No
majority of the people in Syria are living
sentient being should be subjected to such
below the poverty line. Western countries
cruelty. PARTICIPATING ANIMAL WELFARE
should act now and provide aid and support
GROUPS:CHAINED
DOG
AWARENESS
Promotedby 18
supporters
to help
the Syrians
survive
this disaster. To
SINGAPORE, ACRES, ACTION FOR
do this they must lift the imposed sanctions
SINGAPORE DOGS, CAUSES FOR ANIMALS,
onthe economy,
especiallythe areas
Launcha FullPublicinInquiry
EXCLUSIVELY MONGRELS LIMITED, FORGETworse
impactedby theinto thedeath
inearthquake.
custody This
of…is
ME-NOT, OSCAS - OASIS SECOND CHANCE
not about politics,
it is Roberts
about survival. Lifting
Anthony‘Terry’On
21st April
2018.MUTTS
Anthony‘Terry’ SOSD,
Roberts a
ANIMALSHELTER,RESCUE,
sanctions - even in a limited way - is the only
54
year
old man was
remandedDOG
in custody …
SPCA
INITIATED
BY: CHAINED
hope for Syrians to this disaster and find a
Highdown
Read morePrison,
AWARENESSSG Surrey. He died theway to rebuild their country.
following day after a catalogue of failures on

No to 15% Council Tax hike.
Fund Croydon fairly
We the people of Croydon reject theimposition of a 15% council tax rise. We…
shouldnot be asked to pay more to get less.
Read more
Funding for Croydon Council from central
government has been cut dramatically overthe pastSteven
13 years,
and we receive far less
Downes
22,865funding per person than neighbouring

Lambeth. We note that the Conservative

Council that
Sign
left office
the inpetition
2014 handed overaround £1 billion in debt. This was increased
by 50% by the Labour group which ran the
council from 2014-22. Successive councils
and successive governments are to blame
for the current financial situation in Croydon
Council. The one group that is not to blame
is Croydon’s residents. We call on the
Croydon Mayor to withdraw plans for a 15%
hike in Council Tax in the middle of the worst
fall in living standards on record. And we callon the Government to give Croydon Council
the same funding level per person as
PromotedLambeth.
by 179 supporters
neighbouring

Help! Easing and expediting
family reunification due to th…
earthquake
disaster in Türkiye
Dear Prime Minister, I am writing this letteron behalf of UK citizens and Permanent…
Residents
who have family members living in
Read more
the earthquake zone in Turkiye. Thesethe part of prison staff to safeguard his
TerrySurvivinghealth. Sinéad
Mr Roberts
sufferedfrom COPD and
4,690
Partner & Child.
asthma and was left alone locked in his cellfamilies have been facing immensewith breathing difficulties after a COPD

help them. In light of these circumstances, I

delays in getting him to hospital andprogram that would allow the family

hampered the delivery of life saving

members of UK citizens and Permanent

procedures once at hospital which led to his

Residents in Turkiye to reunite with their

untimely demise. On the 23rd December

loved ones in UK. This would provide them2020, Surrey Coroner’s Court concluded thewith the necessary support and stability toinquest into his death with a narrative

cope with the aftermath of the earthquake.

verdict citing ‘missed opportunities’ only. We

Furthermore, I kindly request that the

Terry’s family were shocked andprocessing of family reunification

disappointed that the Coroner did not direct

applications be expedited for the primary

the court to investigate unlawful death orapplicants who live in the earthquake zone.

pursue an inquiry into the conduct of thoseThis would greatly aid in the timely

whose care Terry was in. The court had
Promotedby 691
supporters
heard
contradictoryevidencefrom thereunification of families and provide much-prison staff and that they had withheld

understand the importance of maintaining aimportantevidencefrom super-richthe court. Several
Prosecute
Putin's

rigorous
process, but in thisProtectimmigration
Police Dogs

Sign
attack. Prison
staffthethenpetition
caused a series of

witness
statements
were not committe…
completed andoligarchs
for crimes
never
in
the
investigated.
UK and Surrey
EU police were called
Press contact email:Victorious Petitions

The
Freshwater
Biological
Associationhas
girl andevery boyin the newUnited Nations
shown
that thelake's annual
average
Sustainable
Development
Goals.
This surface

thisatrocity. But if weto saveColle…
these
Headteacher
atwantKnyvett

fenced up area to be provided for the dog

to Epsom general hospital following Terry’s
sychev.massmedia@gmail.com…
death but these officers did not take any
nothing
is doneinspiring
water
nota
lookingtomake thissavings
as they
are willfacingEPIGRAPH
Read more
Read more(quotes from Putin's oligarchs
statements so could therefore not provide
beable to budget
be swumin,forwildlife
will ofnotbeprojected
gap
2023/24£14
who are the defendants in my UK lawsuit No.
these in court. Why would Surrey police notable
to live
inhaveit andhowever
3% of theUk's economy
million.
They
tripledfunding
CL-2016-000831 in the High Court of Justice)take statements when called to A&E deptwilldisappear
the tourist
industry inWeto theski
slopewhensetting
A moreIgor
complete,
BUT NOT EXHAUSTIVE,
Midlothian
Sureaside
Start£31 million.1,707
Sychev
45,325
after
my
loved
one
died. Why was No CCTVthe
National
Park
dries
up.
The
healthofourface multiple cuts: Cuts to our Family
list of 37 (!!!) such death threats, together
handed over when we requested this several
freshwater
impactswhich
everywould
singlelead
one toof us in
Learning Contract
with the decision of the Latvian Police totimes, the coroner said ‘ we don’t need this’thecountry.
We alldrink
water,towe
all need
Midlothian
Sign
Sure
Start
the
needing
petitionclose
one
Signproceedings
the petition
initiate criminalon the facts of
let
me
&
my
legal
team
be
the
judge of that.
water
to family
live, solearning
we all must
speak
upto
for ouror morecentres
Cuts
death threats, is here.
Why was the body worn cameras that werelakes
rivers.
Thewouldcausemeanof thethedeathofother andgrantswhichremovalImportant preamble On 5 January 2023 an
implemented in 2017 not handed overWindermereof theofthreelargest inputs
of funding forTwo
a rangecharities/services
article about my monstrous story waseither. Why was my loved one held in aofphosphorus
into Windermere
are coming
estimated
at impacting
15 000+ peopleNopublished by Orato World Media, titled "Manprison carpark on a blue light ambulance &fromUnited Utilities
wastewater
treatment
discretionary
places for
A Good time
to be 2battles Russian Oligarchs in court, survives
they the prison staff wouldn’t open the gate
assets(hereafter
wwtw)
and from forprimarily
affectingthe opportunity
assassination attempts”, which speaks forbut we’re allowing other vehicles to leave &approximately
1900 private
septicneeds
tanks.
children with Additional
supportitself. The article describes (1) repeatedenter what sort of carry on is this. Why was
Storm
overflowdischarges(sewage)
into theReductionin therapeutic
services(through
Victory!
Victory!
attempts to kill me; (2) constant death
my non violent loved one, low risk-riskcatchment
thousands
hours
it is
Home Link for
FamilySupportofand
Playand
Therapythreats against me and even my children
assessment double cuffed & chained, unable
notsampledthe usvolumesmeasured.
Base)
We asknor
youareto joinin saying
NO towith demands to drop the English lawsuit; (3)to stand, speak or walk & was wheeled to aTheof septictanks Centres
within thecuts number
to our Family
Learning
anda crazy criminal case fabricated in Russia
waiting blue light ambulance unable to leave
catchment
has grown in the last 20 years.
other services!!
against me, with the help of which they tried
as it was a life saving emergency. Why wasSome old homes that used to hold one toilet
to take me hostage and blackmailed me; (4)our complaint of homicide to Surrey police
have now been split into holiday lets thatmy flight to Europe, where I was granted
not ever investigated. Why was evidence re:have several toilets, all of which are going
asylum and international protection. And all
this altercation with this Epsom General A&E
through the same-size septic tank. Some
this is a "reward" to me from Putin's
nurse deliberately withheld & why was our 4
septic tanks are extremely outdated and dooligarchs for the fact that I once saved themweekinquest not stopped
immediately
&
Fund
12the
Years
ofthatEducationfor
Reuniteparents!
not retain
sewageruns throughfrom prisonAshya
and ruin.with
On 12 his
Februaryin theproperly investigated. We The family of Mr
Girls
Aroundthe Worldthem. Many
more issues
from septic tanks
Britishpress
an article
wasstage
publishedabout
Ashya isa youngboy withfour cancer.
Roberts
believetheoverwhelming
evidence
arelargely unknown
becausethere
Sometimes
people ask
me, why
is it is nomyfocusing
on Naghemeh
the attempts
tobeing
kill meHis story,
parents
Brett andareagainsttheprisonofficers,
prisonnursesx2
monitoringor girls
regulatingthem.
It isItheimportant for
to go toschool?
think
inRussiaandthe criminal
thefo…
held
underarrestin Spain activities
unable toofcarethat stood down the first code blue, police dr,
Environment
Agencies
remit tothe more importantquestiontosortask thisis, why…
oligarchs
in theUK.treatment.
I thank thejournalists
Ashyamoreor givehim
Theyhave nowReadagencyprisondr&agencynurses,
Epsom
issue
but
the
governmentis
notprovidingitshouldn’t
girls have the right to go to school?
for
their
interest
extremely
unusualbeen
deniedbail.inI my
have
known theKing
Read more
General hospital A&E Dr x3 as well as Epsom
withthenecessaryfundingandresourcesto
My courageous friend, sixteen year-old
story!
PETITION
The
family for over a year. I've seen
how much
A&E
Nurses&Twoparamedics
allbeliedbydoso. Ultimately
thisgoes
issue
is worsening
asin
Muzoonfrom Syria,
fromtent to1,098,584
tent
purposeof
thispetition
theonly
Britishandthey lovetheirson
AshyatoandwanttoMalalaYousafzai
Ethan
Dallas254,910the coroners ruling, and that Terry did notnewdevelopments
to be built
her refugee
camp incontinue
Jordan encouraging
Latvian- Iparents
demandare
to being
prosecutethe bestauthorities
for him. His
receivejustice.
They
all
had
a
Duty
of
withinEvidenceofgirls tothe
staycatchment.
in school. My
sister Amina
fromthesuper-rich
Putin'soligarchs
forthey
crimeswronglyaccusedof neglect
when
were
Care.Thismostcertainly
is
a
Human
RightsWindermere's
decline
In
1980
855
sea
trout
the North of Nigeria, where Boko Haram(extortion,
corruption
others)committed
only attempting
to getandbettertreatment
forAct
Article
2
The
Right
to
Life
which
Terry’
werecaught
on
the
River
Leven
(the
main
threatens girls for simply wanting to learn,intheson.
UK andMain
their
UntilEU.
they are released, his parents
was
not
given
&
Also
A
Human
Rights
Articleriver
flowingout ofgirls
Windermere)in 2021
mentors
younger
who continue
to want
theses:Putin's tooligarchs,
who are defendants
will be unable
get the treatment
they
3
Inhumane&
DegradingConly
O M 12
PAwereN Y caught. This is an example ofC O M M U N I T Y
S Treatment
U P P O R The
to go to school. There are over 60 million ofinmy lawsuitin theCourt his(caseCLdesireand AshyawillHighbe facingillness
horrificallyreceived.
We
arecallingfora Fullone
speciesaroundwhich isdying
due
to share a
our sisters
the
world
who
2016-000831),
repeatedly
alone. They arehave
not refusing
anythreatened
treatment,
About
Blog
HelpThis petition is
Public Inquiry into his death.
inadequate
water quality.
not thethirst for education,
yet doThis
not is
have
me
and
even
my
childrenwith murder,
just the poor options available
to them in the
supportedbyhis
SpouseSineadand youngsurprising
when
you
look
at
how
pollution
opportunity to go to school or who have todemandingthat
the lawsuit
be isdropped.
Southampton
Hospital.
Ashya
a poorly
ImpactPress
Guideschild. Thanks for all your support. God Bless.
andclimatefactors
impactfish
species.
drop out too soon. Together we can change
Later,
theseoligarchs,
under threats
child whowill
no doubtalso
be confusedand ofCareers
Zooplankton,
the staple
for awillwhole Community Guidelines
that. In September,worldfoodleaders
murder,demandedthat IPrivacy
assigndistressedat being separated
bythe
from hisvarietyspecies,
die whenwater iscommitof
tofish12 yearsof free,safe, thequality
Team
too
warm
forsecondary
them in thesummer formonths.
primary
andeducationevery

20- year- olds
Signandthethey petition
are severely tortured

hardships
due Akcadag
to the recent natural disaster
Zergul30,541and are in dire need of support. And UK can

Sign
petitionkindly request
thethecreationof a special visa

needed support in these trying times. I

case, a humanitarian approach is crucial to
In Scotland, hundreds of service animals
assist those in need. The creation of thiswork daily to keep us safe, whether sniffer…
special visa program and the expedited
dogs,
police dogs or horses, they all work
Read more
processing of applications would not onlywith the same dedication to duty as the menbring comfort to these families but also
and women in our Police force.
demonstrate UK's commitment to
Unfortunately, in Scotland, our laws don't
supporting those affected by naturalprotectLiam
themKerr
the same
MSP way and currently,
68,094
disasters. Thank you for your time andthe law views a Police animal as little moreconsideration. A copy has been emailed tothan property. This means that if an animal
the Prime Minister!
the petitionis assaultedSign
or attacked
in the line of duty,
the assailant is likely to receive a punishment
akin to breaking a window. It happens. Police
dog Finn was seriously injured while
protecting handler, PC Wardell as he tried toarrest a suspect. Finn saved PC Wardell's life
but was so seriously injured that he had toundergo four hours of emergency surgery.

Victory!
The suspect was charged with aggravatedbodily harm for the officer's injuries but only
criminal damage for the horrific injuries toFinn. They are campaigning hard in England& Wales for a change in the law:www.finnslaw.com ; @finnforchange This is
unacceptable and it is time we didsomething to ensure that anyone attacking a
police animal is punished appropriately andanimals be given protection that reflects

Restartsearchforlinethetheir statusthe
if assaulted
in theof duty.
missing
Cheekicrew…
This campaign
aims toRafiki
persuade
the Scottish
members.
Government
introduce
a newcriminal
Cheeki Rafiki,toa sailing
yacht
from
offenceof harmingor killing ahome
serviceSouthampton,
was returning
to the UKanimal.
Thisofwould
thosewith a crew
four, adequately
following a punish
successful…
whoharm
animals
like dogs
andrace inthe trained
Caribean.
On Thursday
SkipperReadmorehorsesserve
the police,
Andrewwho
Bridgereported
that fire
the service,boat wasmilitary
orwater.
otherpublicservices. Itcrew
could
also
taking on
Theexperienced
NicolaEvans
240,862
cover
assistance
guide
dogs.
believedthat theanimals
situationlike
wasstablebut

Introducing
a criminal
offenceamended theircourse tohead offorcausing
the group
injuryto police
animals
will ensurecriminals
of islands,
Azores.
On Friday
morningthewhopolicewithyachtattack
training
andanimals
charter are
firmdealt
Stormforce
effectively,
raise
ofthem.
the severity
Coaching lost
all awarenesscontact withThe USof

CONNECTthecrimeandhasdeter
further
attacks.
Coast
Guard
done
a fantastic
job
Ultimately
thisthegives
serviceanimalsthesearching forcrew,
but weare asking

Twitter

legal
protection
theydeserveand goesthat they
just givethem
a bit moretime. It is
some,
small
saying thankyou forreported
thatway,
twoto
consecutive
signals
wereFacebook
their
dedicated
service. beacons indicating
pickedup from personal

Instagramthat they
had made it to the life raft. They

plaintiff's
rightspersonswithparents. So
as a toparent,Mr associatedCameron pleasedeserve a chance to be found, please help by

themis, in theirown words,
tried
see it (thatyour heart
to arrange
sometheymercy
tosigning this petition to ask the US

tothetwolawsuit).
By
doing
this, they
be captureshown forwonderfulparents.
This
Cookies

Coastguard to please search again. I sailed

Policies

directlyme thatthey wouldbribe
mypetition warned
has nothingwhatsoever
to do
with

with Andy on Cheeki Rafiki last summer

Britishlawyerseven judges.
Asora result,
criticisingeitherand
Hampshire
Policeduring the Fastnet 2013 race. Andy is an

Putin'soligarchs
have reallybribedmySouthampton
GeneralHospitalin theamazing guy and showed such genuine care

Britishlawyersandhandlingof this(lawcasefirms- it isCandey
purely about

for me and all his crew mates, that we all

Signature
Litigation).
Theensuring
High CourtofreunitingthefamilyAshya
This site is protected by reCAPTCHA and the Google Privacy
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apply.
declining.
Data
thatmust
the Environmentfor Education(GPE)
lead the way in
Justice
ofthe
Englandand Wales(deputy judge
receives
treatmentof his parents

English (United Kingdom)

consider him a close friend and desperately
want him to be found. ***UPDATE*** WeName
Simon Pitsillides
Nicholas Hadjiyiannakou
Roz Green
Christopher Collins
Stavros Goulas
Mandy Caddick
Julian Sheppard
jc
Louise Pitsillides
Peter Taylor
Helen Parkinson
Stephen Walker
Carole Hunt
Natalie Smith
Phil Badiz
Gretta Slane
Vasileios Grigoriou
Ayesha Smith
Gerasimos Haritopoulos
Melina Kourri
Jennifer Sawyer
Craig Mitchell
Davina Briggs
Helen Davidson
SS
Rory MacMahon
Sheraz Khokhar
Iain Purves
Lisa Pearson
Waris Razvi
Richard DelaneyPeter Vacara
Sonia Shahingrid de doncker
John Myers
Maddalena Galloni
Rita Matias
Tracy Salter
Carol Wainwright
Vahid Hp
Darryl Taylor
Sarah green
antonio soares
Amer J.
Justina Messeiller
Saliha Khawaja
Ekaterina Fields
Simon SeebaluckPeter Finn
Naveen Bali

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EnglandEnglandEnglandEnglandDudley, West Midlands
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EnglandEnglandEnglandNicosia
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LondonLondonEdgwareBirmingham
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ME15
UK
07/02/2023
CH44
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ME16
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S10 4EH
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E17
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SW17
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EC2V
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HA8
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B28
UK
07/02/2023
GL5 3SBUK
07/02/2023
HA1
UK
07/02/2023
Ireland
07/02/2023
CM20
UK
07/02/2023
152 Italy
07/02/2023
2705-835
Portugal
07/02/2023
EC4N
UK
07/02/2023
DY10
UK
07/02/2023
EC2V
UK
07/02/2023
HP5
UK
07/02/2023
nr17 1tr
UK
07/02/2023
st3 6reUK
07/02/2023
UK
07/02/2023
Switzerland 07/02/2023
UB6
UK
07/02/2023
sw1x 0sn
UK
07/02/2023
6050 Australia 07/02/2023
SK4
UK
08/02/2023
110074 India
08/02/2023

GIORGOS KOUTROUPIS
Caroline Tully
Jan Magne Renstrøm
Rebekah Smith
Pauline Rudd
emmanuel kafubula
Muhammad Ahmad
fabrice byll
Trevor Powlesland
Daniel Paul
Helga Steinthorsdottir
Omar Hourani
Jessie Frahm
Maria Mensah
Asep Hermawan
David Curbelo
julie reid
MOhammed al mukhainy
Duaij alfarhan
David McCormack
Ali Merhej
Vishnu Kumar
Julia Bena
Burcu Basaran
Paul Broekhof
Haoua Milocko
Mike Eggleston
Fiona Gillespie
Chris Allan
Surinder Gill
Holly Moore
Nigel Paddon
Helen Davies
Donna Ellis
Athos Hadjimitsis
Judith Velody
David Webb
Onsmus Mazanzi
Hannah Deveney
angela darby
Emma Finch
Nikita Dara
Regina Arsjah
Paul Hostler
Chitrang Gupta
Sia Michaella Bandabla
Martine Dennis
Derek Mercer
Clive Margolis
Amanda Hall
Mel Morland

DublinStordCollingbourne Ducis
LusakaJeddahPlymouth
Knutsford

LondonEdmonton
Bandung
S/C de Tenerife
Bournemouth
MuscatMumbai
LondonIzmir

WISBECH
Tealing
Scunthorpe
Brighton
Reading
Manchester
Wells
Leicester
EastleighLondonLiverpool
BangorLondonPune
Jakarta Pusat
Llangurig

LondonWatford
Brighton
Birmingham
Corby

Cyprus08/02/2023
Ireland
08/02/2023
Norway08/02/2023
Cyprus08/02/2023
England SN8 3FA
UK
08/02/2023
Zambia08/02/2023
Saudi Arabia08/02/2023
Gabon
08/02/2023
England PL5 4LW
UK
08/02/2023
England WA16
UK
08/02/2023
Iceland
08/02/2023
Kuwait08/02/2023
England E5 8GZ
UK
08/02/2023
England N18
UK
08/02/2023
40266 Indonesia 08/02/2023
38004 Spain
08/02/2023
England bh11 8hn
UK
08/02/2023
Oman
08/02/2023
Kuwait08/02/2023
Ireland
08/02/2023
Iraq
08/02/2023
400070 India
08/02/2023
EC4R
UK
08/02/2023
Turkey08/02/2023
Netherlands08/02/2023
Gabon
08/02/2023
England PE14
UK
08/02/2023
UK
08/02/2023
Scotland DD4 0QZ
UK
08/02/2023
England DN15 7DB
UK
08/02/2023
BN3
UK
08/02/2023
RG7
UK
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England M21 7LY
UK
08/02/2023
England BA5 2HU
UK
08/02/2023
Greece08/02/2023
England LE5 5RG
UK
08/02/2023
England SO509BU
UK
08/02/2023
EC2V
UK
08/02/2023
England L21 7QB
UK
08/02/2023
Northern Ireland
bt203prUK
08/02/2023
England SW7 2EU
UK
08/02/2023
411001 India
08/02/2023
10310 Indonesia 08/02/2023
England SY18 6RZ
UK
08/02/2023
United Arab 08/02/2023
Emirates
Sierra Leone08/02/2023
SW2
UK
08/02/2023
England WD24
UK
08/02/2023
England BN3 1PT
UK
08/02/2023
England B45 8QE
UK
08/02/2023
England NN18 8DW UK
08/02/2023

Matthew Godwin
Pauline Boston
Zoe Fox-Smith
John Kavaliauskas
Coleen Thomas
Barry Swan
Sara Crane
Yusuf Hassan
Sal Hyder
Ian Mortimer
Gideon London
Bryony Abis
Stephanie Lewis
Natasha Kinley
Helen Canham
Christopher MacRae
Coleen Thomas
Audrey Brooker
Bhaskar Mukhopadhyay
Daniel Gurney
Yibel Gebre-egziabiher
Stuart Ryan
michael herd
Debora Jones
Allan Thompson
colin webster
Roland Smith
Rachel Adams
Robert Dack
Alan Taylor
Vatche Gulbekian
jackie lewthwaite
Jacqueline Kidd
Michael O'Callaghanstella shackle
Carol Read
Sue O'grady
Ieva Vilke
jill bird
katie allen
Brian Dallaway
Conor McKeown
Wendy Bowyer
Pippa White
Ian Robinson
Tracy Reay
Avril Burt
Richard Boyle
Susan Randall
LIZ GODBER
Mike Doherty

Middleton, Manchester
Newcastle Upon Tyne
BedfordLondonBermondseyPeterboroughCrawley
SydneyMountain Ash
Crawley
Aldershot
Brighton
Brighton
Ruislip
New Bradwell
Chelwood Gate
LondonFrampton Cotterell
LondonUxbridge
Stockport
bedfordLondonNorwichForfarWalsall
Sheffield
TottonBirkenhead
CroydonBarrow
Leigh
Reading
Blofield
LoughboroughForest Hill
bristol, UK
Saint Ives
Llangadog
Portadown
Shipley
Reading
Northampton
ElyWinchester
Eastbourne
Baldock
Llanelli
Northampton

EnglandEnglandEnglandEngland

M24 4BQ
UK
NE12
UK
MK41 6DW UK
SW3 2PQ
UK
SE1
UK
PE4
UK
England RH11 8FA
UK
2000 Australia
Wales; Cymru
CF45
UK
England RH10
UK
England GU12UK
England BN2 4EJ
UK
CA2
UK
HA4
UK
England MK13 0AJ
UKEngland RH177lY
UK
England N18 1XF
UKEngland BS36 2BU
UK
England SE6 2DY
UK
UB8
UK
Ethiopia
England Sk3 8hs
UKEngland mk40 2nb
UKEngland NW7 1QY
UK
England NR13
UK
Scotland dd8 1db
UK
WS2
UK
England S35
UK
England So40 9FF
UK
England CH63 9AD
UK
England CR0 5JS
UK
England LA13
UK
WN7
UK
RG6
UK
England NR13 4RQ
UK
England le111rl
UK
England Se233sz
UK
Lithuania
England bs2 9Yh
UK
England PE27
UK
Wales; Cymru
sa19 9ha
UK
Northern Ireland
BT62 1PLUK
England BD18 2BD
UK
England RG5 4NT
UK
England NN7 3JB
UK
CB6
UK
England SO213EUUK
England BN23 5AB
UK
England SG7 6SS
UK
Wales; Cymru
SA14
UK
NN5
UK

08/02/2023
08/02/2023
08/02/2023
08/02/2023
08/02/2023
08/02/2023
08/02/2023
08/02/2023
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09/02/2023
09/02/2023

Allison Rensch
William Cook
Rania Al-Baroudi
Slavina Dimitrova
Vernon Taylor
Sriram Surapaneni
David Jackson
Derek Stephen
jeff stephen
Olga García
david tyson
Felicity Dobson
Nancy Palmer
Paul Whieldon
Kathy Szeputi
Stormy Weathers
Tokunbo Ifaturoti
Armen Suvaryan
Patricia Jenkins
Cheryl Hopkins
Charlotte Horder
Maha Najjar
Ally Micklem
Sandra Ruiz de Azua
Sifiso Nyembe
Ingrid Garzon
ozgur ekim
Lise Alex Marthinsen
Colin Ayres
Emily Clarke
Jenny Pitsillides
Jenny Pitsillides
Iasonas Hadjiloizou
Iznaur Khatataev
Elena Bagdades
Grace Davenport
Maria Christina Achilleoude
Greg Stylianides
zain elmajed
Abeer Abugharbiya
Rosario Galván
Dina Mylordou
Paraskevi Zavou
Maria Hadjiyiannakou
Kypros Pitsillos
Veronica NottNicholas Hadjiyiannakou
Yuliya Fateyeva
Ioannis Kakouris
Iris Charalambidou

LondonPortadown
GeneveLondonGranthamLondon
LeicesterPortsmouth
HavantValencia
Corringham
Chinley
WarrenHastings
Warrington
IlfordLondonChelmsford
Pontypridd
BochumBuguggiate
Vitoria-Gasteiz
ManziniLondonIstanbul
CroydonCornwallLondonLondonLondon
Edinburgh
New HavenCamborne
LondonNottingham

Badajoz
NicosiaSouthampton
LondonLondonLondonAnchorage
Cirencester
Nicosia

England E8 1HH
Northern Ireland
BT63

UK
09/02/2023
UK
09/02/2023
1205 Switzerland 09/02/2023
W3
UK
09/02/2023
England NG31 6DB
UK
09/02/2023
England RM6 5DS
UK
09/02/2023
England LE4 9NE
UK
10/02/2023
England PO5 3HN
UK
10/02/2023
England po9 2ef
UK
10/02/2023
46008 Spain
10/02/2023
England SS17 7PU
UK
10/02/2023
England SK23
UK
10/02/2023
Rhode Island
2885 US
10/02/2023
England TN34
UK
10/02/2023
WA5
UK
10/02/2023
UK
10/02/2023
IG4
UK
11/02/2023
Se13
United Arab 11/02/2023
Emirates
CM1
UK
12/02/2023
Wales; Cymru
CF37 5NGUK
12/02/2023
44791 Germany 13/02/2023
Palestine 13/02/2023
21020 Italy
13/02/2023
1006 Spain
13/02/2023
Swaziland 13/02/2023
SE1
UK
14/02/2023
Turkey14/02/2023
Norway15/02/2023
CR0
UK
15/02/2023
England EX23
UK
15/02/2023
SE1
UK
15/02/2023
SE1
UK
15/02/2023
W2
UK
15/02/2023
Scotland EH8 8EH
UK
15/02/2023
Connecticut
6511 US
15/02/2023
England TR14UK
15/02/2023
England WC1B 3AD UK
15/02/2023
England NG1 1QP
UK
15/02/2023
Jordan16/02/2023
Cyprus
16/02/2023
6010 Spain
16/02/2023
Cyprus
16/02/2023
England SO14 7FB
UK
16/02/2023
Cyprus
16/02/2023
England E14
UK
16/02/2023
England SW6 5AXUK
16/02/2023
WC2R
UK
16/02/2023
Alaska99501 US
16/02/2023
England GL7 1ES
UK
16/02/2023
Cyprus17/02/2023

17 February 2023
Attn: GSSB Secretariat
Global Sustainability Standards Board
By email: gssbsecretariat@globalreporting.org

Dear Global Sustainability Standards Board,Re:

Public Comment GSSB Work Program 2023-2025
The integration of human security, enhanced due diligence and conflict sensitivity into
GRI Standards

We welcome this opportunity to submit to the Global Sustainability Standards Board (GSSB) ourcomments on the draft GSSB Work Program 2023-2025, specifically Consultation Annex 2
regarding the development of new Topic Standards (pages 27-29). LSE IDEAS welcomes thereferences to international humanitarian law (IHL) and conflict sensitivity into the draft GSSBWork Program 2023-2025, and encourage their greater integration into the GSSB’s activities.
We would like to offer our expertise during the revision and development of (new) standards
when considering the issues listed below. Furthermore, in response to question 4, we ask you to
consider the materials developed by LSE IDEAS in cooperation with the UN that have the ability
to identify clear alignment between the Standards and the SDGs in addition to national
development objectives.
We specifically would like to bring to your attention the following additional considerations for
integration into the GSSB Work Program 2023-2025:• Integrate the concept of human security into the GRI Standards: Human Security, which
encompasses human rights, emphasises interconnections, both between individual typesof rights and needs, and the connection between human rights and development. It pays
attention to the intersections of diverse forces in people’s lives and the nexus between
issues in different domains – between economy, conflict, environment, health (physicaland mental) and justice. Our research has shown that by integrating double materiality
into existing risk assessment and impact measurement frameworks, through the conceptof human security, companies are better aligned with local realities and the context inwhich they operate. This is expected to lead to a more complete measurement of socialand environmental impact, especially for high impact sectors. It is recommended that the
GRI Standards include a reference to the importance of applying human security as a basis
for revealing double materiality impacts in the social and environmental impact••dimensions This will address the challenges listed by working group members in thereporting on impact experienced by local communities.
Incorporate enhanced due diligence and conflict sensitivity: When companies operate infragile and high-risk settings, it is recommended to include the use of enhanced due
diligence and conflict sensitivity in the GRI Standards, following the UN Guiding Principles
on Business & Human Rights. This should not be limited to situations of armed conflictbut also apply to post-conflict situations, volatile environments and natural disasters.
Potentially harmful social or environmental impacts that trigger conflict and violence canbe addressed through the concept of double materiality, hence help to mitigate the risks
and enhance sustainability.
Clarify the meaning of ‘meaningful engagement’: The GRI Standards (under Chapter 5.
Stakeholder engagement) explain what is meant by meaningful engagement. In addition,
it is recommended to explain what a proper process is for trust building or what trust
building conditions entail and how to measure these. In general, trust is built provided
that three conditions are met: commitments made, accountability and transparency. Thisimplies that meaningful engagement should serve these conditions. Structured andsustained interaction with affected communities is an essential prerequisite for beingtransparent and accountable. It is recommended to make this more explicit in theStandards. LSE IDEAS has developed guidance for such sustained interaction which can beused to make the meaningful engagement more tangible and practical.

We encourage the GSSB to not only consider the importance and relevance of human security,
enhanced due diligence and conflict sensitivity when revising existing Topic and Sector standards,
but to prioritise these topics when developing new GRI standards. Also, instead of developing astand-alone standard on conflict sensitivity and IHL (as recommended in the draft GSSB Work
Program 2023-2025), we recommend the integration of these issues in all sector standards, as
their use is important for any sector operating in fragile and high-risk settings.
Yours sincerely,

Mary Martin, Director of the Business and Human Security Initiative, LSE IDEAS
List of relevant resources (written or edited by the undersigned)• LSE IDEAS (2022), Maximising business contributions to sustainable development andpositive peace: A human security approach. Supported by the United Nations Trust Fund for
Human Security (UNTFHS).
• LSE IDEAS (2021), Human Security Business Partnerships: A risk informed approach toachieve the SDGs. Supported by the United Nations Trust Fund for Human Security (UNTFHS).

2

•

•

Dorp, M. van and M. Smits (2020), The Social Impact of Business in Fragile and Conflictaffected Settings: Contributing to the SDGs and reducing local ESG risks by using Human
Security and Positive Peace. United Nations at LSE Policy Brief
Dorp, M. van and M. Smits (2020), New Approaches to Assessing the Social Impact ofBusiness in Fragile and Conflict-affected Settings. Discussion Paper for LSE IDEAS.

3

Meat & Livestock Australia (MLA)
submission to

Draft GSSB Work Program 2023-2025

Introduction:
Meat & Livestock Australia (MLA) welcomes the opportunity to present this submission to the Global Sustainability
Standards Board (GSSB) Draft Work Program 2023-2025. MLA plays a critical role in supporting Australia’s red meatand livestock sector through the provision of research, development, and marketing activities for the industry as thedeclared marketing and research body under the Australian Meat and Livestock Industry Act 1997.
This submission seeks to articulate industry’s sustainability commitments and current MLA investments and highlightthe importance of recognising the Australian red meat and livestock context and production system to ensure equity
and equivalency across countries in global sustainability methodology and reporting frameworks.
MLA as Secretariat of the Australian Beef Sustainability Framework (ABSF) and the Sheep Sustainability Framework(SSF) welcomes GSSB’s guidance. It supports the prioritisation of the biodiversity topic and also recommends theinclusion of the animal welfare and wellbeing; natural ecosystem conversion; and soil health topics into the Draft
GSSB Work Program for 2023-2025.
As ABSF and SSF Secretariat, MLA holds significant interest and relevant expertise and welcomes the opportunity toparticipate directly on a working group or indirectly through further consultation in the development of these topics,
to help demonstrate and support the Australian context.

About the Industry:
The Australian red meat and livestock industry represents about 1.5% of the global cattle herd and 5% of the global
sheep flock. Australia exports approximately 70% of its red meat production and is the fourth largest global beefexporter. Australia’s cattle herd as of June 2021 was 24.4 million head and the sheep flock was 68 million head. ¹
The livestock industry is Australia’s largest agricultural industry with annual turnover of over $67.7 billion. The
industry employs approximately 428,000 people, including 191,000 directly and an additional 239,000 people
indirectly in businesses servicing the red meat and livestock industry.
The livestock industry by its nature is exposed to climate change and extreme weather variability which directly
impacts on livestock productivity and performance, natural ecosystem health and business resilience. Livestock
producers are custodians to over half of Australia’s land mass and with less than 8% of Australia’s landmass suitablefor other forms of food production, they are a critical contributor to food production globally and to the
management of natural ecosystems.

Investment priorities:
MLA considers the environmental, social, and economic impacts of all investment decisions, priorities, and projects,
seeking to ensure investments support both productivity and sustainability improvements to its stakeholders, soenabling industry to proactively drive sustainability progress and practice change rather than having additional
regulation and compliance costs imposed upon it.

1.

State of the Industry Report, 2022, Meat & Livestock Australia - State of the Industry report2Australian Beef and Sheep Sustainability Frameworks
The Australian Beef Sustainability Framework (ABSF)² and Sheep Sustainability Framework (SSF)³, managed by MLA,
are industry-led but customer and investor focused frameworks. They track performance through independent
evidence against indicators relevant to critical sustainability issues as defined by the four themes of Best Animal
Care; Environmental Stewardship; Economic Resilience; and People & the Community.
The Frameworks are informed by regular material assessments, applying the principle of double materiality, inrecognising industry impacts and the influence customer and investor decision making and are informed by the GRI
sustainability reporting standard. This ensures that industry is supporting best practice in addressing its sustainability
impacts and supports equity and equivalency for the Australian context in global reporting.
The assessments have identified animal health, husbandry practices and welfare, greenhouse gas emissions,biodiversity, forest and woodland, soil health, water security and quality, chemicals and safety and biosecurity as themost highly material issues for the Australian red meat and livestock industry.
Carbon Neutral 2030 Roadmap
In 2017 the Australian red meat and livestock industry set an ambitious target to be Carbon Neutral by 2030, thisrequires industry to make no net release of greenhouse gas emissions (GHG) into the atmosphere as measured by
the National Greenhouse Gas Inventory (NGHGI) by 2030. CN30 has driven a significant investment commitment andcollaborative partnerships in GHG Emissions Avoidance; Carbon Storage; Integrated Management Systems; andIndustry Leadership.
Significant emissions reduction investments are targeting further scientific validation of feed additives (3-NOP &Asparagopsis), and technologies to enable their application to extensive rangeland situations; investigation of abreeding value for methane traits in livestock and high-quality pasture-legume mixes that inhibit methane emissions
from livestock. Carbon storage investments include technologies to support remote sensing to reduce the cost of soil
carbon baseline measurements and further investigation into time-controlled grazing and integration of trees onfarm in livestock production systems.
The Australian red meat and livestock industry, as at 2019 had achieved a 59.5% reduction in its emissions sincebaseline 2005 and halved its contribution to national GHG emissions. Significant further reductions in GHG emissions
will be determined by the outcomes of current emissions avoidance and carbon storage investments and theirapplication across the whole production system.
Environmental Credentials for Grassfed
MLA is leading the Environmental Credentials for Grassfed Beef project which aims to enable grassfed beef
producers to demonstrate their environmental performance through verifiable credentials specific to the fivethemes of biodiversity, tree cover, grass cover, carbon, and drought resilience. The project will utilise where possible
remote sensing tools and is developing a digital platform to enable producers to collect and control their data, totake advantage of market opportunities. The project is at present scientifically validating the defined credentials withproducer piloting of the digital platform to commence in the near future.

2.
3.

Australian Beef Sustainability Framework 2022 Update, Meat & Livestock Australia - ABSF Update 2022.pdf
Sheep Sustainability Framework 2022 Update, Meat & Livestock Australia - Sheep Sustainability Framework Annual Report July
2022.pdf

3

Lifetime Animal Wellbeing Index
MLA is currently investigating the development of a Lifetime Animal Wellbeing Index to demonstrate industry’s
commitment to best practice animal husbandry, welfare, and wellbeing. The assessment of livestock wellbeing overthe lifetime of an individual animal and a mechanism to deliver information to markets is complex and highly
challenging and the development of an index is in preliminary investigation stage.
Australian Beef and Sheep Sustainability Frameworks Goals and Reporting
The ABSF is currently investigating the development of industry targets beyond the CN30 target to demonstrateindustry’s commitment to sustainability.
Targets will provide a tangible pathway for industry to progress meaningful sustainability outcomes; help define
industry’s future sustainability priorities in terms of science and technology; practice change; disclosures andreporting to achieve targets; and will provide proof of Australian industry’s global leadership in sustainability.
The ABSF and SSF are currently undertaking an investigation into alignment of the Frameworks’ sustainability
material priorities, indicators, and metrics with the GRI reporting, specifically against the GRI Universal Standards
and GRI 13 Agriculture, Aquaculture, and Fishing Sector 2022 standard.
The investigation has demonstrated strong alignment between GRI 13 topics and ABSF & SSF’s highly material topics
including GHG, animal welfare and wellbeing, biodiversity and soil health and overall good alignment with ABSF and
SSF’s moderately material topics.
The investigation has also highlighted significant differences in how topic scopes are defined, as explained by GRI’s
focus on impacts and the Framework’s focus on both impacts and risks; and differences in the global language GRI
applies as compared to the Australian context and operating language as applied by the ABSF and SSF, reinforcing
the need to recognise country context.

Important considerations in the determination of the draft GSSBIn the determination of the Draft GSSB Work Program 2023-2025 and the prioritisation of specific sectors and topics
MLA puts forward the following considerations:
•

•

•
•

The Australian red meat and livestock industry strives to ensure that its sustainability commitments are led
and driven by industry rather than imposed upon it by government regulation. MLA in considering all its
investment decisions, strives to ensure investments deliver to its stakeholders, the tools necessary to makeboth productivity and sustainability improvements. Only by supporting our stakeholders to become moreproductive and profitable and their businesses more climate and risk resilient, can they pursue emerging
market opportunities. In this way we strive to ensure industry can collectively achieve enduring
sustainability.
The Australian red meat and livestock industry, in contrast to many other livestock industries around theglobe, is predominantly extensive production on vast areas of land. In the development of global
sustainability methodology and reporting frameworks it is critical that country-specific landscapes andproduction systems are considered and provided for. This will help to ensure that methodologies,
disclosures, and reporting is applicable, relevant, and fair across the globe and delivers the desired
sustainability information and outcomes.
It is vitally important that reporting frameworks are developed and based on peer reviewed science and thatmethodologies and credentials are scientifically validated prior to the development of sustainability
reporting requirements.
Australian livestock producers are custodians of over half Australia’s landmass and vital contributors to
global food production and natural ecosystems management. Their direct contribution to natural ecosystemmanagement requires recognition and consideration. This includes land stewardship, the management ofground cover, and control of invasive fauna and flora species, which are key to the preservation of
biodiversity.
4

•

•
•
•

MLA as Secretariat of the Australian Beef Sustainability Framework (ABSF) and the Sheep Sustainability
Framework (SSF) welcomes GSSB’s guidance, it supports the prioritisation of the biodiversity topic and also
recommends the prioritisation and inclusion of the animal welfare and wellbeing; natural ecosystem
conversion; and soil health topics in the Draft GSSB Work Program for 2023-2025.
As ABSF and SSF Secretariat, MLA holds significant interest and relevant expertise and welcomes theopportunity to participate directly on a working group or indirectly through further consultation in thedevelopment of these topics, to demonstrate and support the Australian context.
Severe limitations in data availability, accuracy and currency need to be acknowledged as presenting
significant challenges for reporting entities and increasing the risk of inaccurate and counterproductive
reporting.
The burden of reporting in terms of cost, time and manual effort needs also to be acknowledged andaccommodated, to ensure it does not unduly impact specific sectors or businesses to the point ofcompetitive disadvantage.

Thank you for the opportunity to comment as an important industry stakeholder. We welcome any further questions
or requests for information, and we look forward to ongoing consultation with GSSB.
Yours sincerely

Jason Strong
Managing Director
Meat & Livestock Australia

Jstrong@mla.com.au
28 February 2023

5

Global Sustainability Standards Board (GSSB)
By email: gssbsecretariat@globalreporting.org

Date: Thursday 16 February 2023

Reference : WO/JvS
Re: NOREA Response
Public Comment GSSB Work Program 2023-2025

Dear members of the GSSB,Introduction
NOREA welcomes the Global Sustainability Standards Board initiative for this consultation.
NOREA is the professional organization of IT-auditors in The Netherlands, established 30
years ago. NOREA is affiliated member of IFAC and standard setter for registered ITauditors in The Netherlands. We collaborate closely with NBA (the Royal Netherlands
Instute of Chartered Accountants) in the domain of assurance, data&analytics andinvolvement of IT specialists within the financial audit. We also collaborate with globalorganizations such as the Information System Audit and Control Association (ISACA) andthe Institute of Internal Auditors (IIA).
Although the domain of sustainability reporting standards is not primairily the focus of ourorganization, the broad domain of non-financial information, including IT risk
management, IT-security and data privacy are key domains for an IT-auditor.
Furthermore we see a growing demand on Non Financial Information-assurance and firststeps to include apsects of internal controls and IT-security and provided assurance
thereon within the annual reports of public and private entities.
In 2006 together with NBA we drafted a specific framework for data privacy which was thefoundation for the PrivacyProof program we have in the Netherlands. The framework has
been updated in 2018, due to European data privacy law which became effective.
Another key program for NOREA is DigiD-assessments, where IT-auditors provide
assurance on the information security of the connections where civilians of theNetherlands with their digital identity (DIgID) can interact with government and otherorganisations.

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In our comments on the activities and priorities set out in the draft GSSB Work Program2023-10 2025 and the accompanying Project Schedule 2023, we have taken into accountthe four questions as listed in the consultation document:
1. Should the GSSB change the order of prioritization of the existing GRI Topic Standards
for review during the period covered by this work program (see page 8)?
2. Which topics should the GSSB prioritize for the development of new GRI Topic
Standards during the period covered by this work program (see page 10)?
3. Are there any sectors currently listed in priority groups 2, 3, and 4 in the list ofprioritized sectors that should be prioritized for development during the period
covered by this work program?
4. What activities or materials should the GSSB prioritize with regard to cooperation withother standard-setting bodies and international organizations (see page 14)?
We are pleased to provide our responses to your consultation and share our views andinsights on the following items:
1. Our vision on reporting on the management of IT topics;
2. Based on the first item, we respond to your draft GSSB Work Program, especially on thedevelopment of a new topic standard for management of IT topics;
3. Finally we would like to raise attention for the quality of data used for GRI reporting in
general, a topic that is close to the hart of IT-auditors and where we feel competent to
respond.

1. Our vision on reporting on management of IT topics
We live in a global environment that is becoming increasingly digital and where digitized
information, products and services are having substantial impact on individual consumers,
public interest sectors, companies, governmental organizations and society as a whole.
While it is clear digitization is bringing substantial benefits it also introduces growing
dependencies on technical infrastructures, including vulnerabilities regarding misuse,(cyber)crime and infringements of human rights. Organizations, be it public or private, that
do not sufficiently address this in managing their topics related to digitalization, dataprotection, cybersecurity, and privacy pose a weakness, and increasingly a threat to theirusers (consumers, companies) and other partners in their ecosystems. In line with the coreprinicples of GRI, transparent reporting on their material topics regarding digitization, dataprotection, cybersecurity, and privacy will substantially contribute to awareness and drive
improvement of these topics.

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2. Development of new Topic Standards
In the draft work program (lines 246-247) a new potential topic standard for the groupingof topics in relation but not limited to digitalization, data protection, cybersecurity, andprivacy is included. The plan is to conduct the research in 2023 and to start in early 2024.
We most welcome such initiative and are more than pleased to share our gained insights
and results of the reporting initiative we have started 2 years ago and we have discussedwith GRI represenatives, most recently at January 24, 2023, where we were invited tocontribute to this consultation to make the GSSB aware of our efforts and offer
collaboration.
After a series of conversations with various regulators and representative organizations in
the Netherlands for the need and content of an IT management report we identified anincreasing need for transparency on the way organizations manage their digital (IT) topics,
addressing the expectations from stakeholders such as customers, suppliers, employees
and other workers, regulators, investors and society. The ambition is to makeorganizations more aware of the challenges they face and on the other hand by increasingtransparency towards their stakeholders. Therefore, we started a reporting initiative, tocontribute to:— strengthen the compliance, confidentiality, integrity and availability of IT of theorganization itself; and also

— the resilience of digital eco systems and protection of our economic system.
Inspired by the ideas and concepts of GRI we used the universal standards of GRI and thestructure of the GRI topic standard as a starting point for a draft reporting framework. Thisbecause such provides a robust structure for a reporting standard, which is flexible
enough for inclusion of specific topics and/or sector specific reporting requirements.
So far we developed a reporting standard for Management of IT comprising a number oflikely material topics. This list has been composed combining the insights obtained from aseries of conversations with potential stakeholders that we deem as important users ofsuch reporting, e.g. supervising board members, credit institutions, supervising authorities
and regulating authorities, with our professional views as body of IT-audit professionals.
The table below provides the overview of likely material topics we included in our draft
reporting initiaitive. Please note items 1 and 2 have an organization wide scope,
overarching the (sub-)topic scope of the items 3 to 8.

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#

Likely material topic

Description

1

Organization & Governance

IT wide description of how the digital capabilities areof ITorganized and its governance. This links to theorganization description as covered in GRI 2.

2

Risk Management of IT

IT wide description of how IT risks are indentified andmanaged.

3

Digital Innovation &Disclosures on how digitization is used to pursue theTransformation

organization’s strategic objectives, including how thedesign is managed (IT architecture) and how thetransformation is realized (change management).

4

Data Governance & Ethics

Disclosures on how data is used in reaching theobjectives of the organization, how awareness iscreated on the safe, compliant and ethical /responsible use of data and how algorithms aremanaged.

5Disclosures on the sourcing strategies used by the

Outsourcing

organization and how outsourcing is managed
thoughout its lifecycle.
6

Diclosures on the protection of digital / IT assets,

Cybersecurity

how cyberevents are detected, how the organization
responds to, and subsequently recoveres from cyber
events.
7

IT Continuity Management

Diclosures on the protection of digital / IT processes
and services from disruption (considering a wide
variety of scenarios), on continuity measures that arearranged, how they are operated when required andhow the organization subsequently reinstatesbusiness as usual.

8Disclosures on how the organization ensures ongoing

Privacycompliance with data privacy regulations as well as
its own policies in its processing of personal data.
Where applicable we include the impacts of digitalization on human rights, e.g., of
consumers (data privacy, data ethics), employees or other workers (outsourcing), and see
potential to include disclosures on the environmental impacts of IT as well.

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We will be pleased to share our draft reporting framework, that is currently being prepared
for the public onsultation phase, and provide you with our gained insights of the pilots
that have been conducted and are underway, and to work toghether with you to etablish towhat extend it could be useful input for the due process towards the topic standard GRI
envisages.

3. Other topic to be considered; quality of data for GRI reporting
Reliable reporting requires reliable information. Which starts with the initial recording offacts or transactions, the processing of such information including accumulations andinterpretation and finally reporting. Often for such a number of IT systems will be used.
We experience in practice that in most organizations the internal control framework forsustainability data is less mature than that for financial reporting. Although such notnecessarily means data processing is less reliable, we believe that besides the reporting
framework on what should be reported, there is also a need for safeguarding for example
the privacy of the customers. However recent publications in the Netherlands are
addressing this topic as well. In a sound system for collecting, processing data, reportingon such data becomes easier and it will be beneficial to obtain independent assurance oversuch data reported. This will benefit the prepares and the users of GRI-based reports.
NOREA will be pleased to participate in activities where this topic is being investigated.

Closing remarks
We trust to have you informed sufficiently and would like to collaborate with the GRI on the
new GRI topics regarding digitalization, data protection, cybersecurity, and privacy as we areconstantly working on these topics and can share our relevant experience on these.
If you have any questions, please do not hesitate to contact NOREA via Jeroen van Schajik(Jeroen.van.Schajik@bdo.nl).
Yours sincerely.
NOREA

Jeroen van Schajik
Board Member

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17 February 2023
Barbara Strozzilaan 101
1083 HN Amsterdam
The Netherlands
Email: gssbsecretariat@globalreporting.org
Dear Sir/Madam
SAICA SUBMISSION ON DRAFT GLOBAL SUSTAINABILITY STANDARDSBOARD (GSSB) WORK PROGRAM 2023 - 2025
In response to your request for comments on the Draft GSSB Work Program 2023 - 2025,
attached is the comment letter prepared by the South African Institute of Chartered Accountants(SAICA). SAICA is South Africa’s pre-eminent accountancy professional body and is widely
recognised as one of the world’s leading accounting institutes. The Institute provides a wide
range of support services to more than 50 000 members and associates who are charteredaccountants (CAs[SA]), as well as associate general accountants (AGAs[SA]) and accounting
technicians (ATs[SA]).
This comment letter results from the deliberations of SAICA’s Sustainability TechnicalCommittee (STC) with observers and participants from various sectors including audit firms,
public sector and corporates. The STC comprises experts on the subjects of accounting,sustainability, assurance, ESG (environmental, social, governance), ethics, et al.

We thank you for the opportunity to provide comments on this Exposure Draft.

Please do not hesitate to contact us should you wish to discuss any of our comments.

Yours sincerely
Yvette Lange
Chairperson: STC

Nomsa Nkomo
Project Director: Sustainability,
Integrated Reporting and Thinking

Cc: Bongeka Nodada – Executive Corporate ReportingGENERAL COMMENTS
We are generally in support of the activities and priorities outlined in the draft GSSB Work
Program 2023-2025 and the accompanying Project Schedule 2023.
We acknowledge that the revision of the Universal Standards was the focus of the Global
Reporting Initiative (GRI) in the past three years, which is foundations to the GRI’s suite ofstandards. We further support the intention to review the existing standards continually toensure these are responsive to emerging trends or developments.
Our responses to the specific question are set out below.

SPECIFIC COMMENTS
Question 1 — Order of prioritization of Topic Standards
Should the GSSB change the order of prioritization of the existing GRI Topic Standards forreview during the period covered by this work program?
Procurement Practices- Start 2025
Based on the Draft GSSB Work Program 2023-2025 for public consultation (“consultation
paper”), the planned revision for the topic standard on Procurement Practices is scheduled tocommence during 2025. We suggest that the revision to this Topic Standard be prioritised byshifting this to start earlier than 2025. Procurement practices, notably disclosures pertaining to
the impact of business relationships with suppliers (both downstream and upstream) is
becoming prominent within our local context as well as globally. For example, disclosuresrelating to upstream suppliers could be a focus area in revising this Topic Standard which willserve to assist in shaping purchasing positions.
Additionally, with procurement practices linked to strategies for decarbonisation pathways andsupplier social assessments to fulfil the net zero ambitions (especially within the Scope 3
dimension in which companies have footprints in various markets), a more urgent focus on
procurement practices becomes apparent. As in many developing countries, these practices
support the growth of small and medium sized enterprises (SMEs) within the supply chain,social and economic upliftment providing for the realisation of the Sustainable Development
Goals (SDGs).

Question 2 — Development of new GRI Topic Standards and prioritization
Which topics should the GSSB prioritize for the development of new GRI Topic Standards
during the period covered by this work program?
We appreciate that labour, customer impact, indigenous people and local communities form
part of the work program. Although we recognise the importance of such topics across otherparts of the globe, we would welcome that the GRI provides feedback regarding the processapplied and considerations made about addressing the related social elements, particularly thesocial rights of the indigenous communities. We further perceive the broader topic of social
impact as it relates to communities impacted by the company activities being a priority in the
African context, and therefore propose that the GRI consider developing new Topic Standards
covering elements of social impact to additionally include the created value add to thosecommunities.
Considering the upcoming agenda consultation of the International
Sustainability Standards Board (ISSB) and its anticipated prioritisation of human capital andhuman rights, our comment regarding the consideration of this broader topic aligns well with
global priorities of other global sustainability standard-setting forums.
Question 3 — Sector prioritization
Are there any sectors currently listed in priority groups 2, 3, and 4 in the list of prioritized
sectors that should be prioritized for development during the period covered by this work
program?
There was broad support for the sector prioritisation as it focuses on industries with highenvironmental impacts, for example, mining. Some participants advocated including industries
with low environmental impacts but higher societal impacts and advise a revisit to the Priority
Groupings in the future.
GRI Standards can be used by any organisation, whether private or public, and according to
the relevant sector and material topics for that specific organisation. It was noted that time has
been set aside in the work programme to initiate research with regard to Standard requirements
for the public sector. There was great support for the GRI’s work in this area as it is agreed that
there is a need for more specific and focused material on the public sector and its peculiar
issues.
Question 4 — Co-operation of partners
What activities or materials should the GSSB prioritize with regard to cooperation with otherstandard-setting bodies and international organizations?
The GRI is encouraged to continue to work and collaborate with the other international bodies
as outlined in the consultation paper. We note the plans to identify areas for possible
collaboration with the International Public Sector Standards Board (IPSASB), and in line with

our earlier comments on the need for exploration of needs within the public sector with regards
to sustainability reporting and disclosures, we support this part of the work programme. With
regards to the ISSB, we are pleased to see the continued prioritisation of this collaboration. We
do however feel that more information is needed regarding a clear roadmap on thiscollaboration, and how this will support interoperability of the standards, in order to provide
any meaningful commentary around this aspect and its relative prioritisation.
OTHER COMMENTS
Accountancy profession
We appreciate the direct link with other global standard-setters as outlined in the consultation
paper and recommend that this approach becomes elevated to allow for the accountancy
profession to contribute to the ongoing work program of the GRI. While current engagement
is set with underlying entities of the International Federation of Accountants (IFAC), it issuggested that engagement at the IFAC level be considered by the GRI in terms of creating abroader scope for collaboration with the accounting profession regarding the sustainability
pillars covered by the GRI Standards and how these are adopted and implemented.
Standards interpretation
With regard to “language” members urged the GSSB to continue issuing Standards which are
written in an easily understandable manner so as to avoid challenges arising with interpretation
and application of the Standards. This would also serve to manage any unnecessary applicationof GRI resources to produce FAQs and / or Standard interpretation guidance in response tothese challenges.

SHoP Architects
233 Broadway
11th Floor New
York NY 10279
p 212 889 9005
www.shoparc.com

Global Reporting Initiative
Barbara Strozzilaan 101
1083 HN
Amsterdam
The Netherlands
February 15, 2023

Dear Global Sustainability Standards Board,
On behalf of SHoP Architects, I would like to ask GSSB to prioritize the “Construction
Materials” and “Construction” sectors which are currently placed in Group 2 of the prioritized
sector groups for the GSSB Work Program 2023-2025. In addition, we recommend accelerating
the development of the topic standards on “Circularity and Material Resources” and“Procurement Practices” as well as the Sector Standards Projects for “Forestry” and “Metal
Processing,” all of which are currently planned to begin in 2025.
SHoP is a leading global architecture firm based in New York City. We partner with many
international and local engineering firms and suppliers, most of whom are currently not reporting
according to any international ESG standards. Following a careful examination of our projects
and research into more than 50 certification, reporting and risk analysis platforms, we have found
GRI standards to have the best potential in aiding our ESG initiative. Now more than ever it isimportant to establish a common set of metrics to facilitate the efforts of architecture andconstruction sectors in reaching relevant UN SDGs.
It is urgent to prioritize the Architecture, Engineering and Construction (AEC) services sector andrelated standards due to the significant environmental and social footprint of these sectors andpersisting lack of universal tools for addressing these footprints. The built environment generates
40% of annual global CO2 emissions (building operations: 27%; embodied carbon: 13%).1
Concrete, steel and aluminum, mostly used in the built environment, are responsible for 23% of
total global emissions.2 The construction ecosystem also accounts for more than 13% of the
global GDP and $12 trillion in spending worldwide.3 At the same time, the construction sector isconsidered “one of the most disaggregated and least modernized sectors.” 4 Recent instances ofhuman rights abuses during the FIFA World Cup Qatar 2022 constructions further demonstratethat the construction sector is the #1 industrial sector at risk of forced labor.5 The abovementioned impacts need to be carefully managed to ensure the sustainable development of oursector around the world.
In the process of developing topic and sector standards, the GSSB should prioritize workshops
and interviews with global architecture and engineering firms to gain more insight into creating
standards that will be compatible with different types of design workflows internationally. At
SHoP, we believe that decisions made at the early stages of design, construction andmanufacturing have the potential to generate a positive impact on the environment, society andeconomy. GRI standards can aid architecture and engineering companies to annually update our
ESG database in the form of a report which can inform design teams and clients in decisionmaking.
Thank you for your time and consideration.

Sincerely,

Christopher Sharples
Founding Principal
SHoP Architects

1 WHY THE BUILT ENVIRONMENT?
2 Ibid.

3 SECTOR DATA
4 Ibid.
5 Sport, Architecture And Worker Rights: The Dark Side Of FIFA World Cup Qatar 2022 Constructions

C/O Green Finance InstituteInternational House, 24 Holborn ViaductLondon, EC1A 2BN
UNITED KINGDOM

19 February 2023
Ms Judy Kuszewski
Chair, Global Sustainability Standards Board (GSSB)
Global Reporting Initiative (GRI)
gssbsecretariat@globalreporting.org

Public Comment GSSB Work Program 2023–2025
Dear Ms Kuszewski,
Thank you for this opportunity to offer feedback on the draft work program 2023–2025 for the
Global Sustainability Standards Board (GSSB).
As you know, the Taskforce on Nature-related Financial Disclosures (TNFD) is an international
market-led initiative supported by G7 and G20 political leaders to develop an integrated and global
risk management and disclosure framework for nature related issues. In undertaking its work, theTaskforce is covering nature-related dependencies, impacts, risks and opportunities across therealms of the natural world – land, freshwater, oceans and atmosphere (other than emissions
covered by TCFD).
This mission has been given additional momentum by the signing of the Kunming–Montreal Global
Biodiversity Framework (GBF) in December last year. Target 15 of the GBF calls for businesses toregularly monitor, assess and transparently disclose their risks, dependencies and impacts on
biodiversity. The TNFD will provide a set of recommendations that seeks to help businesses to meettheir own reporting aspirations and those of their investors aligned with the GBF. The TNFD is also
committed to putting forward a set of recommendations in September 2023 that usefully inform thestandards work of GRI, the International Sustainability Standards Board (ISSB), other standards
bodies and government regulators.
Even before the GBF, the TNFD had secured strong global interest from a broad-cross sector ofmarket participants, reflecting clear recognition that nature-related dependencies, impacts, risks andopportunities are material to companies and investors. There is also a clear desire among market
participants to ensure that emerging nature-related corporate reporting aligns with, and builds
upon, climate-related corporate reporting, in particular the recommendations of the TCFD.
The TNFD is grateful for the ongoing support and guidance provide by GRI as one of our 19
knowledge partners. This has helped us to ensure our work is embedded in science, reflects what ispractically possible for organisations, and is coherent to the extent possible with existing andevolving nature-related reporting standards, notably those already developed and underdevelopment by GRI. The TNFD looks forward to continuing collaborative efforts with GRI to informand align our respective efforts on nature and biodiversity topics.
As an international initiative, the comments provided in this letter represent the view of the TNFD
Secretariat and not those of the individual member institutions of the Taskforce or of the TNFD
Forum who will provide their own institutional views to the GSSB should they chose to do so.

Strong, ongoing alignment in design and development efforts
The TNFD Secretariat welcomes the continued prioritisation of an update of the biodiversity
standard for publication later this year. This standard will add value in a key area for many of theorganisations applying the TNFD framework, along with the global sustainability reporting baseline
being developed by the ISSB. The TNFD Secretariat stands ready to continue to work with the GRI
teams developing this text to ensure interoperability of the TNFD framework and this GRI standard.
To ensure interoperability of approach, the TNFD continues to build upon the earlier nature andbiodiversity work of leading science organisations and key standards bodies, including GRI, as well as
ISSB, CDP and others:
•

•

•

•

The TNFD's conceptual approach, like the GRI, covers impacts on nature and biodiversity andis highly aligned in the draft approach in this area of the framework, while going further tocover also dependencies, risks and opportunities;
Technical experts from the GRI and TNFD teams have maintained an open and collaborative
dialogue during our respective development efforts since the commencement of the TNFD’s
activities in October 2021;
v0.3 of the TNFD beta framework, released in November 2022, and earlier beta releases
have drawn on key elements of relevant GRI standards, particularly in the TNFD's illustrative
lists of metrics for impacts on nature; andAs a knowledge partner of the TNFD, GRI technical experts have participated actively inproviding input to TNFD in its framework development through written input to draft
materials and participation in consultation workshops, particularly on indicators and metric.

The TNFD Secretariat has also provided input to the GRI team on relevant aspects of the TNFD beta
framework for the GRI biodiversity standard update. The TNFD looks forward to ongoingcollaboration with GRI as a knowledge partner to the TNFD to ensure alignment and consistency ofapproach for market participants.
The proposed GSSB workplan: Topic standards
The TNFD Secretariat has reviewed the proposed workplan for GRI topic standards and has identified
three areas where it would like to offer feedback and the opportunity to collaborate further:
Engagement with Indigenous Peoples and Local Communities; circularity and material resources; andtraceability.
The TNFD Secretariat sees further opportunities for collaboration on the GRI standard for reportingon engagement with Indigenous Peoples and Local Communities. Based on consultations over the
past year with over 40 Indigenous Peoples and Local Communities (IPLCs) leaders from around theworld, the TNFD beta framework includes a draft disclosure on how organisations have engaged
with stakeholders, including rightsholders, in determining their approaches to managing naturerelated dependencies, impacts, risks and opportunities. The next release of the TNFD beta
framework will include draft guidance on what organisations should include in this disclosure, as
well as longer guidance on stakeholder engagement when applying the TNFD's LEAP approach fornature-related risk and opportunity assessment. The TNFD Secretariat is drawing on GRI's work inthis area and offers its support to GRI in identifying areas of focus for the reporting standard boththrough what the Secretariat has learnt in developing the guidance, and to facilitate effectivealignment.

2

The TNFD framework is being designed to reflect both negative and positive impacts on nature sothat incentives are appropriately in place to help companies and investors shift business models andcapital flows towards more nature positive outcomes, not just away from current practices that
contribute to nature loss. The shift to circular business processes and production models is key tothis transition. As such, given the potential for rapid innovation in circular economy innovation andits importance for responding to nature-related impacts, dependencies, risks and opportunities wewould encourage GRI to consider updating its 2016 standard on circularity before 2025 if internal
resourcing allows.
Third, the TNFD Secretariat sees the emphasis put on traceability in the recent agriculture sector
standard as very welcome and essential to organisations looking to understand their nature-related
dependencies, impacts, opportunities and risks. There may be scope to generalise this thinking
across sectors. Traceability is a challenge in many sectors, and increasing transparency about thedegree of traceability that exists, and the barriers organisations face to increasing it, could help todrive the changes in up- and downstream value chains needed to ensure nature and nature-relatedrisks are managed sustainably.
The proposed GSSB workplan: Sector standards
In line with GRI, the TNFD has also identified a sectoral approach as an essential complement tocross-cutting guidance. The TNFD has established new sectoral working groups, including for manyof the sectors identified as priorities in the GSSB proposed workplan. These working groups are
already highlighting the importance of nature-related dependencies, impacts, risks andopportunities for these sectors. The TNFD Secretariat would be happy to work with the GRI sectoral
teams to support alignment between the TNFD sectoral guidance and the GRI sectoral standards(and similar sector standards developed by other standards bodies), bringing in the expertise fromthe TNFD Taskforce members and wider knowledge partners who are supporting the developmentof the TNFD guidance.
Further cooperation
As highlighted throughout this feedback, the TNFD Secretariat stands ready to work closely with the
GRI team in order to ensure a high degree of interoperability between GRI standards, standards
being developed by others and the TNFD framework and recommendations which will be publishedin September 2023. This has the potential to be an important factor in securing widespread adoptionof sustainability reporting, including on nature-related impacts in GRI's area of focus. Nature andbiodiversity is a new area for many organisations, and the more straightforward and consistent theapproach can be made, the better it will drive the changes in practices required to achieve a moresustainable economy, reduce risks to business and providers of capital, and achieve the global goalof halting and reversing nature loss.
Yours sincerely,

Tony Goldner
Executive Director

314 February 2023

For the attention of: The Global Sustainability Standards Board (GSSB)

Subject: Prioritisation of conflict-sensitivity in GRI Programme of Work
Dear Representatives of the Global Sustainability Standards Board,As part of the public consultations on the GSSB draft work programme 2023-2025, it is with great
pleasure that we –– the Investor Alliance for Human Rights; Heartland Initiative; International Alert,
PeaceNexus Foundation and TrustWorks Global - write jointly to express our unanimous views on thedevelopment of new Topic Standards, and particularly in reference to International Humanitarian Law(IHL) and conflict-sensitivity as noted in Annex 2 of the draft programme.
Who we are
The signatories of this letter have extensive experience working with investors and companies on issues
relating to human rights, conflict and peacebuilding in Fragile and Conflict-affected Settings (FCS).
Summary points
We strongly believe that the issues of IHL and conflict-sensitivity must be prioritised as distinct but
equally important issues in any new and revised GRI Standards for two key reasons:
1. The failure on the part of companies to comply with IHL has disastrous consequences forcommunities and contexts affected by conflict and may translate into material risks forcompanies and investors as the result of criminal and civil liability, regulatory enforcement,
operational disruptions, and reputational damage.
2. The inclusion of conflict-sensitivity as a GRI standard represents a historical opportunity toencourage companies and investors to avoid predictable adverse impacts on conflict and tocontribute actively to peace and stability at a time when violent conflict is on the rise.
We therefore welcome this opportunity to provide our reflections on why both IHL and conflictsensitivity are more important than ever before to enable companies, at a minimum, to avoid driving
and sustaining conflict and, where possible, to contribute actively to peace and stability when they dobusiness in areas that are characterized as ‘high-risk’ or fragile and conflict-affected.
We have noted the proposal (outlined in Annex Two of the programme of work) put forward by ourcolleagues at the Australian Red Cross, ICRC and RMIT University to develop new Topic Standards
on IHL; we also note the reference to “strengthening of other relevant GRI Standards on conflictsensitivity.” We fully support that proposal and underscore the importance of including conflictsensitivity as a related but separate GRI Topic Standard as a matter of urgency. In what follows, we

1elaborate our rationale for both supporting the development of IHL GRI reporting standards, as well as
separate ones on conflict-sensitivity.
Conflict and violence on the rise
The Russian invasion of Ukraine has brought the realities of conflict and instability to the European
headlines. War in Europe should not obscure the fact that, elsewhere in the world, 1.9 billion people
live in FCS – representing 24 per cent of the global population; besides Ukraine, there are a total of 38
conflict-affected contexts in the world, and a further 37 experiencing high levels of violence, fragility
and/or instability.1 Conflict is becoming a defining feature of 21st century politics, with devasting
impacts on lives and livelihoods.
Indeed, conflicts are increasing in intensity, complexity and scope. The number of civil wars has almost
tripled over the course of the decade, with a six-fold increase in battle-related deaths since 2011.2
Geopolitical power configurations are in flux, contributing to a dramatic increase in proxy warfare by
global and regional powers. As a result, conflicts are progressively more internationalised andregionalised, making them bloodier, longer and more intractable. It is estimated that the number ofstates that have or are likely to experience an episode of wide-spread violence between 2020 and 2022
increased by 56% globally.3
According to the United Nations Secretary-General Antonio Guterres over 71 million people have been
forcibly displaced by war, violence and persecution,4 resulting in the world’s largest humanitarian crisis
since the end of World War Two. At the end of 2022, UNHCR reported that over 100 million werefleeing conflict, violence, human rights violations and persecution – an unprecedented ‘record’.5
The 2021 Economic Value of Peace report demonstrates that the global economic impact of violence
was estimated to be $14.4 trillion in 2019 in constant purchasing power parity terms6 - the equivalentof 10.5 per cent of the global gross domestic product or 1,895 dollar per person. These costs are set toincrease: global peacefulness has continued to decline for the fourth time in the last five years,7 withviolent conflicts becoming more protracted, and involving an increasingly diverse set of actors.
The climate crisis, energy transitions and the risk of conflict
The global imperative to mitigate climate change and adapt to its impacts has both positive andpotentially negative implications for conflict dynamics. In FCS, the transition away from fossil fuels
could disrupt well-knit and highly entrenched political economies. Moreover, many technologies at theheart of the transition are dependent on minerals – copper, iron, lead, molybdenum, nickel and zinc much of which are currently found in FCS, with potentially devastating socio-economic andenvironmental impacts given the strong history in FCS of the inter-linkages between mining, violence,and human rights abuses.
Moreover, the transition to ‘clean power’ in the form of hydro and wind, could require inroads into thenatural environment and the securing of land and natural resources, which may well be at the very centre
of conflict dynamics. The complexity, scale and unprecedented speed of the transition will inevitably
produce winners and losers. If poorly managed, the transition could exacerbate existing conflict
dynamics, and createe new sources of conflictt, such as large-scale migration or land use disputes.
Conversely, interventions that are informed by a deeper understanding of conflict dynamics have thepotential to contribute in meaningful ways to both preventing conflict and contributing to peace.
We therefore believe the climate crisis presents both an opportunity and imperative to make conflictsensitivity a corporate duty against which companies are both expected to report, but also actively
supported to make a reality.

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Policy environment for companies
The policy environment for companies has been evolving over the past twenty years but changes in
expectations, duties and responsibilities have yet to be reflected meaningfully in reporting standards,
despite their inclusion in several internationally recognised policy frameworks.
The ‘UN Guiding Principles on Business and Human Rights’ and the OECD’s ‘Guidelines for
Responsible Business Conduct’, for instance, both indicate that corporate due diligence should be
proportional to risk. In FCS, risk is elevated and the standards expected of companies must therefore
also be elevated. Indeed, companies are expected to go beyond ‘business as usual’ in those contexts toboth know and show that they are managing risks and impacts appropriately through conflict-sensitive
operations.
More recently the UN Working Group on Business and Human Rights issued their report on ‘Human
Rights and Conflict-Affected Regions: Towards Heightened Action,’8 which emphasizes the need forbusinesses to perform heightened due diligence in FCS in line with the fact that these are contexts where
there are increased risks for human rights abuses to occur. And, this year, UNDP published a guidancenote on Heightened Human Rights Due Diligence for Business in Conflict-Affected Contexts.9
In 2023, we expect the EU Proposal for a Directive on Corporate Sustainability Due Diligence to be
adopted by the European Commission,10 thereby establishing a duty for companies to conduct corporate
sustainability due diligence to address negative human rights and environmental impacts in theiroperations in Europe and beyond. While the proposal had significant omissions related to zones ofconflict, the EU is under increasing pressure to ensure that the need for heightened, conflict-sensitive
human rights due diligence is included in the Directive.11
Practical realities for companies in FCS
Despite the clarity and abundance of normative frameworks, guidelines, initiatives and mechanisms andthe clarity of the ‘demand’, meaningful action on the ground remains elusive.
Very few companies understand the implications of IHL and few have incorporated conflict-sensitivity
into their internal policies and procedures; even fewer practice it in any meaningful or consistent manneron the ground. The few companies that have undertaken to operate in a conflict-sensitive manner havetended to do so reactively i.e., when things have, for want of a better term, already “gone south” - atwhich point the company has already contributed in a significant manner to igniting or exacerbating
violent conflict. While commercial investors are becoming more attuned to this issue - especiallyfollowing the Russian invasion of Ukraine, the coup in Myanmar, the Taliban takeover in Afghanistan,and the crisis in Xinjiang Uyghur Autonomous Region, China - the road ahead remains extremely long.
This is highly problematic both for companies and for the people living in the areas in which they areoperating or sourcing. For companies, FCS are extremely complex contexts which can drive their
exposure to a range of risks, including reputational, legal, financial, security and human rights risks.
Small missteps can make a company a target of communities, advocacy groups, or shareholder actions.
They can also impose financial costs – demonstrations can halt operations, advocacy groups may
mobilize divestment campaigns, illegal armed groups may attempt to extort the company, and homestate legislatures or regulators may impose fines or penalties. As noted by the International FinanceCorporation, companies operating in FCS “face business risks that are much greater than those in otheremerging markets.” These include the destruction of physical capital, as well as deaths and injuries,
weak state control, lack of security, and supply-chain disruptions.12
For the people living in FCS, it is vital to recognise that the impacts of companies are never neutral withrespect to conflict. When companies and investors operate/invest in FCS, their presence and activities

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interact with the context to shape the impacts that a company has on its stakeholders and on theoperating context itself. While companies and investors may deliberately position themselves as neutral
actors with respect to conflicts and tensions, their impacts are never neutral with respect to conflict.
There is a high risk that conflict-insensitive companies inadvertently ignite, exacerbate or contribute toconflict dynamics; there are also vast opportunities for conflict-sensitive companies to contribute topeace and stability.
The relevance of conflict-sensitivity and IHL to businessAmongst practitioners, policy-makers and academics working on business and conflict, there is
widespread understanding that complexity of the operating environment, weak regulatory frameworks,
endemic human rights violations and widespread violence create heightened risks for companies. Theserisks are three-fold: risks to the business (commercial); risks to human rights (people); and risks to theconflict (context).
We agree with the submission by our colleagues at the Australian Red Cross, ICRC and RMIT
University that the risks include unique risks under IHL, as distinct from more commonly understoodhuman rights-related risks, such as:••••

Committing or being complicit in pillage, that is, acquiring property or natural resources
without the freely given consent of the owner;
Criminal liability risks relating to military occupation, for example involvement, participation
or assistance in settling civilians in occupied territories, and maintaining or developing
settlements;
Committing or being complicit in the forced displacement of, or attacks on, civilians for areason relating to armed conflict; andLosing the protected civilian status afforded to businesses by failing to carefully manage theiroperations, personnel and connections to the ongoing armed conflict, thus becoming a potential
military objective (for instance, when company security providers engage in hostilities).

Conflict-sensitivity and IHL reporting standards should be free-standing
We note with great interest the sector program inputs on existing topics, such as GRI Standards Projectfor oil and gas, for coal and for agriculture, aquaculture and fishing as well as the revisions of GRI 304:
biodiversity 2016, labour-related topic standards and climate change-related topic standards, and GRI
201 economic performance 2016, GRI 202: market presence 2016 and GRI 203 indirect economic
impacts, amongst others. We also note that the Sector Program will develop Standards for around 40
high-impact sectors, prioritized primarily on their sustainability impacts including: mining; textiles andapparel; food and beverage; banks; insurance; capital markets; utilities; renewable energy; forestry; andmetal processing.
It is important to recognise that IHL and conflict-sensitivity apply irrespective of the sector in question.
Any sector has the potential to contribute to conflict, just as any sector has the potential to contribute topeace and stability. We therefore believe there are vast opportunities for IHL and conflict-sensitivity to
become an over-arching topic for GRI, which applies based on the contexts in which operations or value
chains occur, mainstreamed across all sectors of work. We would strongly advocate against a sectorbased approach to IHL and conflict-sensitivity at the risk of such approaches doing more harm thangood.
Recommendations
Respect for IHL is a crucial facet of achieving responsible business conduct in conflict-affected areasand in helping to safeguard the lives and dignity of the local communities affected. It is our hope that
continued commitment from the GSSB to consider and integrate conflict-sensitivity and IHL into GRI

4standard setting will further global efforts to see the adoption of genuinely conflict-sensitive approaches
to business in conflict-affected areas, while also strengthening the quality offerings of the GRI. With
this in mind, our recommendations are as follows:•••

Develop a conflict-sensitivity standard, with strong reference to IHL: Develop a topic
specific-standard on conflict-sensitivity for companies operating in or sourcing from FCS - withstrong reference to IHL and armed conflict for conflict-affected settings - and withcorresponding reporting guidance.
Include a conflict-sensitivity provision in GRI 412: Ensure that conflict-sensitivity/HHRDD
is reflected in the GRI provisions on human rights assessments in FCS, in line with therecommendations UN Working Group on Business and Human Rights.
Awareness-raising on conflict-sensitivity and IHL: Support the enhancement of awarenessraising on conflict-sensitivity and IHL amongst businesses.

In closing, we hope that conflict-sensitivity and IHL will become a priority agenda for the Global
Sustainability Standards Board in its work programme 2023-2025; as experts on these matters, wewould be delighted to contribute to the elaboration of these standards.
We remain available for any requests for further information.
Signed,Josie Lianna Kaye PhD
CEO & Founder
TrustWorks Global

Sam Jones
President
Heartland Initiative

Rebecca DeWinter-Schmitt
Associate Director
Investor Alliance for Human Rights

Najib Bajali
Head of policy and practice – Peace Economies
International Alert

Johannes Schreuder
Business Engagement Lead
PeaceNexus Foundation

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End notes
1
See Annex one (above); The TrustWorks Global ranking draws upon two key indices: the Swiss-based Rule of Law in Armed Conflict(RULAC) Project, which identifies conflict contexts where international law around conflict contexts applies –highlighted in orange andorganised in terms of battle-related deaths over the last five years (using ACLED data); and, the OECD-DAC States of Fragility Index, whichassesses country contexts according to six dimensions: economic, environmental, political, security, human and society; these country contexts
are highlighted in yellow and ordered in terms of their ‘fragility’.
2
Von Einsiedel, Sebastian; with, Bosetti, Louise; Cockayne, James; Salih, Cale; Wan, Wilfred, ‘Civil war trends and the changing nature ofarmed conflict,’ United Nations University, Occasional Paper 10, March 2017.
3
Doran, Whitney, and Jonathan D. Moyer. ‘Which development targets are hardest hit by Covid-19,’ SDG Integration, 2022. (link)
42019 Report of the Secretary-General on the Work of the Organisation.
5
UN News. ‘2022 Year in Review: 100 million displaced, ‘a record that should never have been set,’ 2022 (link)
6
Institute for Economics and Peace. Economic Value of Peace 2021: Measuring the global economics impact of violence and conflict, Sydney,2021. (link)
7
Institute for Economics and Peace. Global Peace Index 2020: Measuring Peace in a Complex World, Sydney, 2020. (link)
8
United Nations Working Group on Business and Human Rights. Business, Human Rights, and Conflict-Affected Regions: Towards
Heightened Action (A/75/212). 2020 (link)
9
United Nations Development Programme. Heightened Human Rights Due Diligence for Business in Conflict-Affected Contexts; A Guide.
New York, United States of America. 2022. (link)
10
For more information see the European Commission website (link)11
See for example, the Joint Statement on Conflict and Due Diligence Legislation: (link)
12
International Finance Corporation, “Generating Private Investment in Fragile and Conflict-Affected Areas,” IFC Publishing, 2019, (link)(accessed February 15, 2023).

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