DBS-23-04｢Impact and Value Measurement – A Way Forward｣
Philip Sugai, Graduate School of Business, Doshisha University
Wong Wai Khuen, Multimedia University, Malaysia
Dhiyan Arini, Value Research Center, Doshisha University

November,

2023

Abstract
As businesses, governments and researchers grapple with the need to measurestakeholder impacts beyond shareholders, each faces the unique challenge of matching
their intention to measure these truly with the complexities of doing so. This paper
outlines three key aspects of our current work including (1) the clarification of value
measurement, its elements and mindset required for effectively implementing such an
approach with inspiration from Japan, (2) an outline of the detailed quality assurance(QA) process that we have now completed, and (3) a case example of how the Value Modelcan be applied in order to assess the breadth and depth of any business’s sustainability
reporting initiatives based on their public disclosures.
Keywords:

Value, sustainability, purpose, wellbeing, sustainability reporting, ESGs

DBS Discussion Paper Series supported by the OMRON Foundation.DBS

Value Research Center
November 2023 White Paper
Impact and Value Measurement – A Way Forward
By Philip Sugai, Wong Wai Khuen, Dhiyan Arini

Executive Summary
As businesses, governments and researchers grapple with the need to measure stakeholder
impacts beyond shareholders, each faces the unique challenge of matching their intention tomeasure these truly with the complexities of doing so. In previous white papers from the Value
Research Center, we have outlined an underlying philosophy from Japan as well as an approach
built upon this philosophy to measure such impacts across seven key stakeholder groups,
including (1) the business itself, (2) its customers, (3) employees, (4) partners, (5) shareholders,(6) society and (7) the planet. This white paper, now outlines three key aspects of our current
work within the Value Research Center, including:A) The clarification of value measurement, its elements and mindset required for effectively
implementing such an approach with inspiration from Japan.
B) An outline of the detailed quality assurance (QA) process that we have now completed,
integrating more than 40 sustainability standards, frameworks and models that comprise
more than 1,200 individual impact measurements into a comprehensive Value Model formeasuring stakeholder impacts across a company’s operations.
C) A case example of how the Value Model can be applied not only to individual company
sustainability strategy efforts, but here we introduce the Value Model as a “healthcheck” system that can assess the breadth and depth of any business’s sustainability
reporting initiatives based on their public disclosures. While we have conducted anumber of these “health checks” for different companies in Japan and globally, here we
introduce one application to Natura & Co for illustration purposes.
While we have aimed to be as comprehensive and transparent as possible with our efforts, we
also understand that the work presented here has not covered all of the possible sustainability
reporting frameworks, nor the many different approaches to value measurement acrossstakeholders. However at the same time, we hope that the data and analyses that arepresented here can serve as a solid foundation upon which other researchers and organizations
can build even more effective and compelling models to help move marketing, sustainability
and business practices away from value washing and towards more transparent, objective, goalbased systems for measuring and managing impacts across all stakeholders. With such systems
in place, it is our sincere hope that new models and approaches for true value creation will
emerge, and by doing so, that many of the world’s great challenges that we face today can beclearly seen, measured and ultimately solved.
Keywords
Value, sustainability, purpose, wellbeing, sustainability reporting, ESG

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Section 1: On Value
This white paper outlines the latest advancements in the development and application of theValue Model. However, before explaining the Value Model and its application in detail, it isfundamental for us to first make sure that there is a shared understanding of what the “value”
that we are discussing in the following pages actually means. This first section is therefore
dedicated to making sure that we establish the philosophical foundation underlying the Value
Model and its use before moving on to the operationalization and measurement of this value
related to actual businesses.
As we have discussed in previous papers and presentations, value is infinite constantly evolving
and emerges in relationship over time between two or more actors.
To break this down further to see the mechanics of value in action, we begin our discussions byfocusing first on establishing the basic elements of value, which include:
1) Actors themselves are individuals, groups or entities,
2) Who form relationships
3) That form and evolve over time,
Within such a system,A) Each actor has the ability to1:
a. Impact another actor,
b. Experience the impacts of the other actor,
c. Have a response mechanism to judge these experienced impacts,
d. And finally, to respond or take further actions based on the impacts experienced.
B) This relationship was broken down into four unique points (Sugai & Mahajan, 2023), that
we can adjust here to be as shown in Figure 1 below:
a. A1R = the value received by Actor 1 from Actor 2,
b. A1C = the value created by Actor 1 for Actor 2,
c. A2R = the value received by Actor 2 from Actor 1, andd. A2C = the value created by Actor 2 for Actor 1
C) As shown in Figure 2 below, each actor can experience value as positive, neutral or
negative and varies over time as new experiences and interactions modify value
perceptions of each individual actor.2

1 It should be noted that these can be either conscious or natural processes that occur without thought. For

example, while two people in relationship may form these judgements and make informed decisions,humanity in relationship with nature also follows this same process, but nature responds through naturalprocesses based on our impacts.
2

We should note that for simplicity of our explanations in this white paper, we’ll specifically ignore the humanability to lie, value wash, or create a difference between the actual value received from impacts and those that are
expressed to others. For example, if Actor A actually achieves positive value from their relationship with Actor B,
but explains to Actor C that they have received negative value, they are either intentionally or unintentionally lying.

2D) We can scale this value from -100 which represents “ultimate value destroying” to +100
which represents “ultimate value creating”, with zero (0) serving as the neutral point
between these two extremes.
E) Value experienced typically falls in between these two extremes.
Figure 1: Two actors in relationship (adapted from Sugai & Mahajan, 2023)

Figure 2: The Measurement of Value

Finally, we can then chart the fluctuations of value over time by placing value expected at T1 andvalue received at T2 on the same scale as shown in Figure 2, we can also begin to understandrelationship justice between these two actors by calculating total relationship value over time asshown in Figure 3.
To do so, let’s look at two actors in relationship over time. Let’s say Sam is in the market for a
new smartphone, and we find him in an Apple Store on a Thursday afternoon in October (T1)
about to purchase a new iPhone. Putting this example in the context of our previous two
figures, let Actor 1 be “Sam” and Actor 2 be “Apple, Inc.” and as shown in Figure 3, on thatThursday, Sam expects that the value he will begin to receive from that new iPhone will beslightly positive over their current iPhone (they expect +15 points in positive value) in the near
future (T2), whereas Apple believes that they will achieve 30 points in value from this new
relationship with Sam in the near future (T2). The total expected relationship value here would
be 45 out of the 200 possible positive value points available in this relationship, so to keep theIn either case, for the rest of this paper we will assume that the value experienced is directly related to the value
expressed and actions that are taken because of this.

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same -100 to +100 point scale, we divide this by the number of actors (here we are just looking
at Sam and Apple, so there are 2), and as shown below, the total expected relationship value
between Sam and Apple is +22.5 points.
VT1 = (A1E + A2E) = (15+30) = 45 = 22.5n22
Figure 3: Calculating Total Relationship Value

Now, let’s fast forward to T2, let’s say a fine Saturday in November one month after Sam
purchased their new iPhone. And we find Sam much happier with their purchase than what
was originally expected. Because of this, Sam’s actual value score at this time is a 50. And while
Apple has received its expected profits from Sam as a customer, they also received positive
reviews and word of mouth from Sam in addition to this, and they haven’t experienced any
unexpected costs from customer service visits nor any other negatives. In light of this, theirvalue score also increased above their expectations to be 40 points. With this progression intime, the total relationship value between them has now grown to 45 (90/2) points from its
original expected level of 22.5, a doubling between expected value and experienced value.
VT2 = (50 + 40) = 45
2
Based on this experience, both Sam and Apple expect that the value from this relationship willcontinue at the same level as they are currently experiencing in T2, so their expectations at T3
remain at a total expected relationship value of 45. This dance between expected andexperienced value happens throughout the entire lifetime of this relationship and can be4measured in an infinite number of times, potentially across many different products (iPhone 16,
iPhone 18, etc.) and services.
The purpose of value creation activities: Jita Kyoei, Seiryoku Zenyo
Yoshie Sugai (2013), founder and head instructor of Chiseikan Dojo in Kyoto Japan introduced
the concept of “Seiryoku Zenyo Jita Kyoei” from Japanese martial arts philosophy for businessexecutives in her work. In her book, she introduces the martial arts concept of “Seiryoku
Zenyo,” which is written in Kanji characters as (精力善用) means to use all of our best energy
for good, and “Jita Kyoei”, which is written in Kanji characters as (自他共栄) means mutual
prosperity for executives to integrate into their leadership efforts.
Figure 4: Experienced Value

If two actors in relationship then apply these concepts, this means that optimal value from a
relationship (100 points for each actor, and therefore 100 average points from the relationship)
is what each actor is aiming to achieve. If each applies all of their energy for such an outcome,then this becomes their common goal. Sub-optimal or negative value outcomes are likely toarise over time when this philosophy of Seiryoku Zenyo Jita Kyoei (SZJK) is not applied inearnest. But if it is applied, even within relationships with negative outcomes for one of the
stakeholders (for example by businesses extracting resources from nature), with theimplementation of this philosophy, it is possible over time (T2, T3, etc.) to continuously lessen
the negative impacts incurred. On the other hand, without such a mindset, unfair or unjust

5relationships are likely to become increasingly antagonistic over time, with total potential value
decreasing instead.
Seven (7) Stakeholders
The number of stakeholders a business has across the entire universe of its activities isenormous if not uncountable. From the creation or extraction of raw materials at the very
beginning of a supply chain down through to the creation of a product or service through to the
distribution channels to the end user and the activities related to the end of life of that productor service, there are countless impacts and interactions that occur. For most businesses, thescale and scope of the value created and destroyed within these relationships is extremelycomplex and event with our current technical capabilities, it is currently unknowable.
Possibly someday in the future when blockchain, distributed ledger technology or a yet to be
developed technical system is used to monitor, measure and manage every value generating
aspect of such relationships, we will be able to capture the ebb and flow of value creation anddestruction in real time. However for now such capabilities to sense and understand theimpacts that businesses have across their entire ecosystem of stakeholder relationships remains
out of reach. Yet just because we can't see an account for this entire universe of impacts does
not mean we can't create workable proxies to measure and manage these today.
As a start, the Business Roundtable (2019) announced the new purpose of a company went
beyond the creation of stakeholder value just for shareholders but to encompass value creation
for a total of seven stakeholders including (1) the business itself, (2) its customers, (3) its
employees, (4) its partners, (5) its shareholders, (6) society and (7) the planet. At the same time
the World Economic Forum similarly announced in its Davos Manifesto 2020 (Schwab, 2019) theexact same set of stakeholders as fundamental to business success. Looking back to the historyof Japan this also matches closely with its cultural views on the role of business must play within
the context of society.
As outlined in our previous white papers, the ideas of Ishida Baigan, who argued for a
distinction between fair and unfair profits in the early 1700s, and the idea of “Sanpo Yoshi” or
the “three goods” of business operations that the Ohmi merchants from what is now Shiga
Prefecture put into action from this same time period, we can see that many of the ideas
expressed in the West today have had a long history of practice in Japan.
While it remains technically impossible today to implement as system that can perfectly
measure all impacts between a business and its many stakeholders, from this foundation we canbegin to develop a set of proxies for these that will help us to achieve this capability in the
future. To do so, we can begin to build an informed view of the value created or destroyed by abusiness in relationships to its stakeholders over time by focusing on these seven stakeholders
as an imperfect yet reasonable first step.
What is Value?

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As Vargo, Maglio, & Akaka (2008) point out, Aristotle and countless other philosophers scholars
and economists identified two different types of value. The first is “value in exchange” which isthe financial or economic worth of a product or service or any other thing when it is exchanged.
For example when you buy a new watch the price paid is a direct measurement of the exchange
value that one you attribute to the watch as well as two the watchmaker feels is fair
representation of the proper recuperation of all relative costs associated with the making andthe sale of the watch plus any additional brand related benefits they believe can or should bereceived.
But Aristotle argued that there was a second type of value called “value in use” which
represents feelings of satisfaction joy or pleasure an individual receives from that very samewatch. And this understanding has been at the heart of Japan’s leading business philosopherslike Ishida Baigan, the Ohmi merchants, Sontoku Ninomiya, Eiichi Shubusawa and many othersin their views of what “good” businesses are and do.
Reviewing these recent announcements from the World Economic Forum and Business
Roundtable, it is clear that the West is now catching up in terms of its thinking about the truerole of a business within the context of society at least in principal. In light of this cultural
history, it shouldn't come as any surprise that Japan accounts for 56% of the world's businesses
that are 200 years old or older. If a business is only focused on extracting as much value fromother stakeholders and funneling these to its owners or shareholders exclusively, it makes sensethat such companies won’t be sustainable over the long term. Their stakeholders simply won't
tolerate this as a difference between A1R and A2R is too wide to be sustainable. Take General
Electric (GE), Thomas Edison 's company as an example of what happens in the long-term bykeeping a laser-focus on optimizing shareholder value above all else. For a short time during
Jack Welch’s leadership, shareholder returns were phenomenal. Entire business school
programs were built around the short term leadership style of “Neutron Jack.” But fast forward
to 2023 and GE is a shell of its former self, far from its high flying days of only a few decadesago. Its focus on short term benefits for shareholders at the expense of all other stakeholders
was untenable over the long term.
This leaves us then with the following foundation:
•
•
•
•
•

Value is infinite and ever evolving.
It is derived from relationships between actors over time.
With a mindset of mutual prosperity (SZJK) shared by each actor, total value createdgrows closer and closer to its full potential.
The centuries-old philosophy of a good business from Japan shows evidence that suchthinking put into action results in long term sustainability, a topic now under hot debate
and interest in the West.
The Business Roundtable and World Economic Forum have clarified that the purpose ofa business goes beyond the optimization of shareholder value, and is in fact to create
value for multiple stakeholders including (1) the company itself, (2) its employees, (3) its
customers, (4) its partners, (5) its shareholders, (6) society and (7)the planet. With the7adoption of this thinking in the West, there is a growing alignment with the centuriesold philosophies from Japan.
In aggregate, these points serve as the foundation for the remaining discussions within thiswhite paper.
Moving Beyond Milton
Even as the realization that the purpose of the business is to create value for these sevenstakeholders, if a company chooses to say that it is pursuing this purpose but instead its
behaviors actually only focus on optimizing shareholder value by ignoring or misrepresenting its
actual impacts, it follows in the footsteps of what Milton Friedman (1970) explained in his
infamous New York Times magazine op-ed “The social responsibility of a business is to makeprofits.” In this article, Friedman explained that that our talk about social responsibility was“notable for its analytical looseness and lack of rigor” (Friedman, 1970, p. 32). He also explainedthat value washing (Sugai, 2021)i was perfectly in line with the optimization shareholder value.
As he stated, “It would be inconsistent of me to call on corporate executives to refrain from thishypocritical window dressing because it harms the foundations of a free society. That would be
to call on them to exercise “social responsibility”!” (Friedman, 1970, p. 124).
As outlined in our previous discussion papers, and re-stated here, any system that is created tohelp measure and manage the value experienced by these seven stakeholders in relationshipmust be free of value washing as well as the potential for it to be created. To do so a system thatmeasures and reports on impacts and the value derived from them must:
1. Be goal based: Clear measurable goals offer context for the impacts and value createdfrom them. Without this context, any report on impacts or improvements can beconsidered good, and comparison between businesses, industries or markets is
impossible.
2. Be objective: The ultimate goal of a value measurement system is that any objective
outside observer can report the same level of impact and value as another. For example
in Figure 5 below, while A1 experiences a value of 50, an objective outside observer (sayA2, A3 or A4) would report the same level of impacts and value creation as A1 did.
3. Have transparent third party feedback loops: Those objective observations must also
allow for transparent reporting of impacts and the value generated such that as Figure 5
shows A1, A2, A3 and A4’s observations of the impacts experienced and value received
can be confirmed independently of those actors in relationship.
Figure 5: Independent 3rd Party Feedback Loops to Avoid Value Washing8

4. Be a scale variable: Reporting on impacts must go beyond binary yes/no answers andmust have some degree of variability that can be measured and compared. For example,
rather than reporting only on whether or not a business creates plastic waste (yes orno), here the level or amount of this waste is required for a comparable understandingof these impacts to be created, as well as the appropriate measured needed to reducesuch impacts.
5. Avoid complexity: Because value is infinite and ever evolving, it is by definition acomplex topic. The greater the complexity of terms or information used about impacts
and value, the greater the likelihood that the difference between (a) impacts
experienced and (b) value received from these differs from (c) what can be said about
these. The simpler the terms used within an overall system created to measure andmanage impacts and value, the harder value washing becomes.
Developing the Value Model
While the subsequent sections outline our current achievements in our research, it is importantto first put these in context of the overall process we have followed to arrive here. This section
outlines the multiple waves of research projects that have been attempted in the creation of amodel for measuring value across multiple stakeholder relationships over time.
Wave 1: Failing in Academia (2016 – 2018)
As outlined in our first white paper, Valuing Value, development of the Value Model first began
in 2016 in a three year effort to create a system for measuring value across stakeholders thatwas free from value washing. The original idea at the time was that because there was a richbody of academic research across various disciplines and research fields, it would be possible toorganize and aggregate all of the precise mathematical formulas and related techniques for9measuring value for one or multiple stakeholder groups into one “meta-model” for value
measurement. Over the course of this three-year period and with the help of many competent
MBA students serving as research assistants, we pored through hundreds of academic articles
on value measurement to try to distill down to the key measurements of value creation anddestruction across the seven value actors outlined above. We narrowed these down to 156
papers that had clearly quantified measures for stakeholder value across these sevenstakeholders, but in the end, we failed to find a way to aggregate these into a comprehensive
meta-model. This was because each academic researcher, while building on his or her own
research field, did not align their work with the others within our 156-article data set. This led
to what can kindly be called a “mess” of measurement styles, data points, and calculation
methods that could not be combined into a clear nor consistent model. While this original
research effort did pre-date the announcements from the Business Roundtable and World
Economic Forum in the identification of 7 clear stakeholder groups supported within theacademic literature, it failed to produce the meta-model that was originally planned.
Wave 2: Failing into the sustainability world (2018-2019)
Different from the highly fragmented world of academic research on value, the sustainability
world includes a number of global, integrated value measurement frameworks and scoring
systems that appeared to already have the “meta-model” that we originally hoped to create in
Wave 1. Organizations such as MSCI, Bloomberg, FTSE, Sustainalytics and others generated awide array of research, insights and scoring of company impacts on their stakeholders.
However, after looking deeply at the methodologies used across these and other scoring andsustainability data systems, we hit a wall of proprietary information. While each of theorganizations we studied openly published the basic thinking behind the methodologies thatthey were using, when these were reviewed carefully, it was impossible to link a specificcompany action (for example a reduction of plastic pollution by 75% within a 3-year period)
with a resulting change in their sustainability score. These formulas remain confidential andproprietary in our experience even today, and therefore failed in both the (3) transparency and(5) simplicity requirements for a value measurement model free of value washing. Without theability to clearly see how scores are achieved, the ability for misuse proliferates and because ofthis, the “meta-model” for value measurement that we were hoping to find already in existence
could not be identified from within this category of sustainability-related organizations, agencies
or consultancies.
Wave 3 The Path to Value through Sustainability Reporting Frameworks (2019 – Present)
While the previous two waves amounted to 4 years of consistent failure, the combined
learnings from these efforts brought us to explore the publicly disclosed and openly available
sustainability reporting frameworks that companies operating in domestic and international
markets were tasked with reporting against. As outlined in our previous three white papers,
Valuing Value, A Value Model for Responsible Business and EFRAG and the Value Model,
through the end of 2022 we had gone through 3 consecutive rounds of research to collect,code, organize and ultimately combine the specific impact measurements from a wide range ofsustainability reporting standards and frameworks into a 7-stakeholder, 27-theme, 81-goalmodel for value measurement.
10Now within this white paper, our purpose is to:
1. Pick up where we left off in our last white paper, and
2. Explain the quality assurance (QA) process we’ve now completed of the entire value
model,
3. Outline the addition of a number of new standards and frameworks as well as the
updating of frameworks we had previously included (such as GRI, EFRAG and ISSB) that
had themselves been updated or modified between the publication of our last white
paper and today, and finally,
4. Apply this updated model to the public disclosures of an example company to show how
the Value Model can used as a scoring mechanism and strategy development tool for
future sustainability efforts.
Before explaining the details of this exercise however, it is important to note that while our QA
process for the Value Model led to the addition of hundreds of new impact measurements, andthe revision or modification of many pre-existing ones, the overall structure of the Value Modelremained intact. At the completion of this QA process, we were left with the pre-existing 7stakeholder, 27-theme, 81-goal model with one minor revision. Starting with the work that we
had done in our 2nd white paper, A Value Model for Responsible Business, the integration of ISSB
at that time had led us to expand the number of end goals within the Value Model to 80 with
their emphasis on reporting the use of palm oil. We had originally concluded that this singlingout of palm oil from other nut oils meant that ISSB was suggesting that “zero palm oil use” wasthe ultimate goal of their reporting mandate. However, upon careful re-evaluation of ISSB’s
guidance as well as a number of industry-specific reports and news articles, it was clear that we
had misinterpreted the ultimate end goal, and we therefore have now revised this palm-oil
related goal within our Biodiversity theme to be “100% sustainably sourced palm oil.”In addition to this, we have now created a set of 168 sub-goals that can help build a precise
measurement structure for any business, irrespective of its size or scope.
Quality Assurance for the Value Model
Phase 1: Valuing Value (2020 - 2021)3:
As explained above, during this initial research phase, and with funding from Doshisha
University’s special COVID-19-related research budget, our research team compiled a total of357 publicly reported impact measurement indicators which were drawn from 15 of the world’s
leading sustainability reporting frameworks including (1) the UN’s Sustainable Development
Goals (SDGs), (2) the Global Reporting Initiative (GRI), (3) Global Impact Investing’s GIIN-IRIS+,(4) the Sustainability Accounting Standards Board (SASB)[1], (5) B-Lab’s B Impact Assessment(BIA), (6) the International Living Future Institute’s JUST 2.0, The Capitals Coalition’s (7) Natural

3

Outlined in detail in our first white paper, Valuing Value A synthesis of global sustainability frameworks toestablish objective and transparent goals to measure value for a firm, its shareholders, customers, employees,
partners, society and the planet (2021), Sugai, Phattanaprayoonvong, Phetharn & Yamazaki

11Capital Protocol and (8) Social & Human Capital Protocol, Canada’s (9) Common Approach to
Impact Measurement, The UK’s (10) The National TOMs Framework, Michael Porter’s (11)
Measuring Shared Value, Richard Branson’s (12) The B-Team, RBL’s (13) Organizational
Guidance System, (14) McKinsey’s Five Fifty psychological safety framework, and McDonough &Braungart’s (15) Cradle to Cradle Certification.
Each indicator was carefully catalogued in a Microsoft Excel database, and to avoid any
ambiguities, and each was given a unique numerical ID. We then followed a standardized, 5step process to categorize and score each of these individual impact measurements into a 7stakeholder, 27-theme, 80-goal model for value measurement.
Phase 2: A Responsible Model for Value Measurement (2021 - 2022)4
Conducted between July 2021 and February 2022 this phase of the research effort integrated
an additional 346 impact measurements from six new ESG and sustainability
reporting frameworks including: (1) the International Sustainability Standards Board (ISSB)’s
Prototype Climate-related Disclosures, (2) the Stockholm Resilience Center’s Planetary
Boundaries, (3) The International Finance Corporation’s (IFC) Performance Standards, (4) the
UNDP’s SDG Impact Standards for Enterprises, (5) the Science Based Target’s climate
disclosures, and (6) the Task Force on Climate related Financial Disclosures (TCFD) guidance on
metrics, targets, and transition plans.
This second phase of research more than doubled the size of the original Value Model data set,
and in following the exact same 5-step process established in Phase 1 of our research, we foundthat the original 7-stakeholder, 27-theme, 80-goal model was valid, however with the additionof one goal within the Biodiversity theme focused on Paul Oil usage.
Phase 3: EFRAG and the Value Model (2022)
In April 2022, the European Financial Reporting Advisory Group (EFRAG) published its initial
drafts for sustainability reporting within the EU for public comment. In order to add ourperspective to this public comment period a research team at Doshisha University’s Value
Research Center downloaded all publicly available materials from the EFRAG website and again
followed our previous 5-step process to categorize, score and integrate the original 114 impact
measurements into the Value Model structure. Although this new framework significantly
increased the number of individual impact measurements included within the Value Model, no
new stakeholders, themes nor goals were derived from this process as all 114 impact
measurements aligned with pre-existing goals, themes and stakeholders.
Phase 4: Upgrading the underlying database system and QA of the Value Model itself (2022 2023)
As the size of our database grew across these three initial phases, working within Excel became
daunting, and throughout the latter half of 2022 and into 2023 we shifted our work which now
4Outlined in detail in our second white paper, A Value Model for Responsible Business (2022) Sugai, Koizumi,
Linnan, Phattanaprayoonvong, and Phetharn12included 832 individual impact measurements from Excel to the Notion platform. From late2022 through until July 2023, a research team of seven MBA student assistants were hired andseparated into two groups. The first group of five assistants were tasked with reviewing eachindividual framework and its component impact measurements to confirm that they had beenscored and categorized correctly within the Value Model. To ensure the accuracy of their work,
the second team of two senior research assistants who had worked on the previous EFRAG
analysis earlier that year were responsible for reviewing the work of each member from thefirst group. Finally, the entire updated data set was reviewed by a senior researcher at the
Value Research Center to confirm all results. This process followed the following seven step
approach:
1. Step 1: Downloaded the contents of the (now) original Notion database back into
Microsoft Excel for easier scoring and modification.
2. Step 2: Each research assistant within the first team was allocated a number ofsustainability reporting frameworks, which they then checked online for any changes or
updates published between the time that the framework was originally entered into the
Value Model and today.
3. Step 3: In the case updates had been made, the original 5-step process that was
followed to originally enter data into the Value Model was conducted to confirm thealignment of each new impact measurement with our existing stakeholders, themes,
goals as well as the anti-value washing score (please see the Valuing Value white paper
for a detailed discussion of this impact measurement scoring process).
4. Step 4: Impact measurements that had not changed from when they were originallyinput into the Value Model were also re-scored based on these four anti-value washing
metrics, which include whether or not they are: (a) goal-based, (b) objectively
measured, (c) transparently and independently checkable, and (d) are variable.
5. Step 5: Because each individual impact measurement in the Value Model database isuniquely identified, the reference to its online source was also updated as necessary.
6. Step 6: After research assistants from Team 1 had submitted their final work, one
representative from Team 2 then checked their work to confirm its accuracy.
7. Step 7: Post-verification, the updated data was transferred back into Notion, where it
was then checked by senior member of the Value Research Center team to confirm theprevious six steps had been conducted properly. It should be noted that during thisprocess a number of new fields were added to the Notion database regarding whether
each framework in the Value Model was a sustainability standard, framework, guideline,
or article.
In total, by the end of this process, our team had scored and integrated a total of 1,234
individual impact reporting requirements across 45 standards, frameworks, and models. Data
sources have gone through this 7-step process and comprise the underlying data within the
Value Model:
No.
1

Framework and Link
B Impact Assessment
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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
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21
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26
27
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39
40

B TeamCommon Approach to Impact
Cradle to Cradle Certified
GIIN IRIS+
GRI
IFC
ISSB
JUST 2.0
McKinsey
Measuring Shared Value
Natural Capital Coalition
Organization Guidance System
Planetary Boundaries
SASB
SBTi
SDG
Social and Human Capital Coalition
TCFD
The National TOMs
UNDP
International Labour Organization (ILO)US Office Disability Employment Policy
Zero Plastic Rivers
Alliance to End Plastic Waste
OECD
UN Treaty on Plastic Pollutant
Leaping Bunny
LEED
EFRAG
Plastic Soup Foundation
ISO 14020 - Truth in Labelling/Communications
ISO 14064 – GHG ReportingISO 14001 – Waste/Pollution, Biodiversity, &Water
ISO 37000
ISO 30414
ISO 14090
ISO 14064-1
ISO 14080
Business Responsibility & Sustainability
Reporting (BRSR)
14

41
42
43
44
45

OECD Due Diligence Guidance for Responsible
Business Conduct
Singapore Stock Exchange
SEC Climate disclosure
ISO 14001_2015
TNFD

Framework Considerations:
Within our review process two particular frameworks, B Impact Assessment (BIA) and EFRAG,
were found to have undergone significant changes since our previous research efforts had
reviewed them. First, in our review of our BIA categorization and scoring we found that becauseof the highly repetitive nature of BIA we had originally combined several individual impact
measurements with similar focus into one amalgamated impact measurement within the Value
Model during our initial Phase 1 research. However, in order to be more precise in our scoring
and categorization work in the QA process, we separated these impact measurements back into
their original form so that they could be directly matched against the questions andrequirements posed within the B Impact Assessment process. Second, in June 2023 theEuropean Financial Reporting Advisory Group (EFRAG) published its proposed revisions to its
first disclosure drafts that we had originally reviewed in 2022 and implemented them in July
2023. The number of individual impact measurements within the revised EFRAG reporting
requirements were significantly reduced from 114 in their initial draft versions to 70 in their
final version. While this reduction led to less EFRAG impact measurements within the overall
Value Model, this had no significant impact on the structure of the Value Model itself.
Value Model Coverage by Framework:
As outlined in Figures 1 and 2 below while no framework covers all seven stakeholders, many
cover a wide range of stakeholder groups.
Figure 6: Value Model Coverage by Framework (Part 1)

15

As shown in Figure 2 below, every framework aligned with at least one theme within the Value
Model, with some such as TCFD focused on relatively few themes (here only to Governance andWaste & Pollution), while others such as GRI, BIA and EFRAG focused on a much broader
number of Value Model themes. Details on the coverage of each goal within the Value Modelagainst each framework is attached in the Appendix.
Figure 2: Value Model Coverage by Theme

16

Of the 1,234 impact measurements that currently are included within the Value Model, themajority, 41.4% (n=512), were related to value for Nature. Following this, 20% (n=248) were17

focused on Employee value, 18.8% (n=232) were focused on Firm value, 10.6% (n=132) werefocused on value for Society, 5.4% (n=66) were focused on Partner value, and finally 2.7%(n=34) were focused on Customer value. As we have noted previously, no impact
measurement dealing specifically with Shareholder value were found, however this makes
sense as there is already a vast body of research and practice around shareholder value
measurement. As a proxy for this the Value Model continues to use Economic Value Added(EVA) as a tool to account for Shareholder value. Additionally, there were two impact
measurements that were directly linked to the process of developing and reporting on
company policy from GRI, including disclosures 2-23 and 2-24, that we use in our own guidance
to businesses on how their policies can and should be developed related to each of the 81
Value Model goals.
In the table below, we delineate the coverage of each framework with respect to thestakeholders, themes, and goals intrinsic to the Value Model. For an in-depth exploration ofwhich specific stakeholders, themes, and goals are encompassed by each framework, readers
are directed to the attached appendix.
Table 1: Individual Framework alignment with the Value Model

Framework
B Impact Assessment
B TeamCommon Approach to Impact
Cradle to Cradle Certified
GIIN IRIS+
GRI
IFC
ISSB
JUST 2.0
McKinsey
Measuring Shared Value
Natural Capital Coalition
Organization Guidance System
Planetary Boundaries
SASB
SBTi
SDG
Social and Human Capital
Coalition
TCFD
The National TOMs
UNDP
ILO

Stakeholders Themes
6
18
3
4
2
2
4
9
5
12
6
22
5
10
3
8
4
10
1
1
4
5
2
6
5
8
1
3
4
10
1
1
3
8
4
10
2
4
3
1

2
13
3
1

Goals
30
5
2
13
13
39
15
22
20
1
5
11
11
6
13
1
10
11
2
26
4
1

18

US Office Disability Employment
PolicyZero Plastic Rivers vzw
Alliance to End Plastic Waste
OECD
UN Treaty on Plastic Pollutant
Leaping Bunny
LEED
EFRAG
Plastic Soup Foundation
ISO 37000
ISO 30414
ISO 14090
ISO 14064
ISO 14080
Business Responsibility &Sustainability Reporting (BRSR)OECD Due Diligence Guidance for
Responsible Business Conduct
Singapore Stock Exchange
SEC Climate disclosure
ISO 14001_2015
TNFD

1

1

1

1
1
1
1
1
1
6
1
1
2
1
1
1
6

1
1
1
1
1
1
18
1
7
2
1
1
1
20

1
1
1
1
1
1
31
1
2
9
1
1
1
33

3

7

11

3
2
1
3

8
2
1
8

12
2
1
14

We have therefore concluded the QA process for the Value Model with a total of 45 standards,
frameworks, guidelines and articles, consisting of 1,234 individual impact measurements
separated into the Value Model’s 7-stakeholders, 27-themes, 81-Goals and 168 Sub-goals.
These were then uploaded back into a Notion database so that all could be relationally linked
together and more easily accessible to those outside the Value Research Center.
In the next section of this white paper, we outline the process we have followed to create aprecise scoring model that any business irrespective of its size, location or purpose can use to
see the overall scope of its sustainability efforts and use these to more effectively manage theirimpacts to creating greater levels of value for themselves and their stakeholders in aggregate.

19Section 2: Value creation assessment - Development and scoring criteria
This section highlights the cumulative effort undertaken by the VRC team, comprising MBA
student assistants from Doshisha University and a doctoral scholar from Multimedia Universityof Malaysia, between April 2023 and June 2023 to develop the Value Creation Assessment
Template (hereafter referred to as VCA-T). The QA process for the Value Model mentioned
earlier served as a crucial starting point for us in preparing a detailed assessment template forvalue creation analysis. The template's objective is to provide an organization with astandardized and consistent method to objectively measure and manage the impacts on value
across all its stakeholder groups. This is achieved by assigning scores in three key aspects:
policy commitment, disclosure quality, and value creation.
Policy Score
In our experience, an organization’s value creation journey begins with a policy and apurposeful decision to pursue the relevant goals. A clearly-defined sustainability policy
facilitates a consistent message and implementation across every business unit and investment
decision (Harrison et al., 2021). Following Sugai et al. (2020), organizations achieve policy
points for having a published a written policy that has been openly communicated and isavailable for other stakeholders to access. Here, we define policy score using a binary scale thatindicates whether an organization provides a policy statement related to a goal (=1) or not (=0).
Just as there are 81 goals under the Value Model guiding organizations to measure the value
they create for all stakeholders, there should be equally 81 policy elements to underpin thesegoals. As outlined in Table 2, the possible range for policy score data points are 0 – 81:
Stakeholders
Employee
NatureSociety
Firm
Customers
Partners
Shareholders
Total

Number of Practice Goals

Policy Score Data Points

23
22
12
8
6
9
1

0 - 230 - 220 - 12
0-8
0-6
0-9
0-1

81

0 - 81

Table 2: Policy Score under VCA-T

Disclosure Quality Score
Next, we introduced the disclosure quality score to measure the quality of the reported
information by an organization concerning the wide range of corporate social, environmental,
and governance topics. Based on earlier feedback, the VRC team noted there is a need toaddress the specificity of the 81 goals under the Value Model to reduce ambiguity, facilitate
measurement, enhance stakeholders’ understanding, and promote accountability. The initial
review of the Value Model, conducted from April – May 2023, allowed the VRC team to further
split the 81 practice goals into 168 unique sub-goals, each with measurable performanceindicators. The relationship between practice goals and sub-goals is hierarchical and20

interconnected. The practice goals represent the overarching outcomes in creating value for
specific stakeholders, whereas the sub-goals are the smaller, more specific objectives that
contribute to the accomplishment of the larger practice goal. In other words, each practice goal
will have its own set of sub-goals that would create a network of interconnected objectives.
For example, one of the practice goals for Value Model under the ‘Employee category is“No Discrimination by Gender. The gender balance of the workforce matches 100% with thesurrounding population both in terms of overall workforce and senior leadership team.” Here,
we identified two (2) sub-goals will greatly inform salient stakeholders whether an organization
is working towards the overarching goal of no gender discrimination, namely: 1) “The genderbalance of the workforce matches 100% with the surrounding population,” and 2) “The genderbalance of the senior leadership team matches 100% with the surrounding population.”
Following Papoutsi & Sodhi (2020), each of the 168 sub-goals will be evaluated using 0-3
scoring system based on publicly available documentation (i.e., financial report, sustainability
report, website), as shown in Table 3:
Disclosure Quality Score
01
2
3

Scoring Criteria
The item was not referred to in a report
The report only briefly mentioned something pertinent to theitem or provided only qualitative statements
The report provided detailed information with some numericalsupport.
The report provided extensive numerical support with data on
goals achieved or fully accomplished.

Table 3: Scoring Criteria for Disclosure Quality Score
Thus, the disclosure quality score data points under VCA-T can range from 0 to 591, asshown in Table 4:
Stakeholders

Number of Sub-Goals

Employee
NatureSociety
Firm
Customers
Partners
Shareholders

42
44
16
21
19
25
1
168

Total

Disclosure Quality
Score Data Points
0 – 126
0 – 132
0 – 48
0 – 630 – 57
0 – 75
0–3
0 – 504

Table 4: Disclosure Quality Score under VCA-T

21

Value Score
The value score enables stakeholders to assess the value impact or creation of acorporate organization based on a set of clearly defined end-goals. According to Sugai et al.
(2020), organizations earn points for their value score based on their actual performance inrelation to each practice goal. We can calculate the value score only if the organization achieves
a full disclosure quality score of 3, which acts as a benchmark for determining the scope of value
creation for a specific goal. The value scores are meant to be calculated for individual sub-goals(n=168), aggregated for each of the practice goals (n=81), and then aggregated again for each of
the stakeholders (n=7) to achieve a final overall score of 1,680.
Here, we introduced a 0-10 scoring system for each goal, with a full achievement of thatspecific goal earning a score of 10. This numerical scoring method provides a finer level of
granularity, allowing one to better understand which of the 168 sub-goal practices organizations
are adopting and the resulting value creation outcomes based on the extent of implementationof such practices. For example, an organization facing accusations of forced labor would receive
zero points if it has not yet achieved any meaningful outcome from their efforts to eliminate
forced labor, even if they have conducted an awareness campaign for 100% of their workforce.
Moreover, using a 10-point numerical scale allows decision-makers to precisely assess ratings
when establishing thresholds, setting performance targets, or identifying areas that require
improvement to maximize value creation for their stakeholders. For instance, if a company
reports actively reclaiming and recycling 50% of its plastic products, we can assign a value scoreof 5 (out of a full 10 points) to indicate that the company has reached the mid-point milestoneof zero plastic pollution, one of the practice goals under the Value Model. Table 5 provides an
overview of value score:
Stakeholders
Employee
NatureSociety
Firm
Customers
Partners
Shareholders
Total

Number of Sub-Goals
42
44
16
21
19
25
1
168

Value Score Data Points
0 – 420
0 – 440
0 – 160
0 – 210
0 – 190
0 – 250
0 – 100 – 1,680

Table 5: Value Score under VCA-T
Absolute and Relative Value Score
The introduction of relative and absolute value scores is an essential process to enable
us to better evaluate corporate organizations' value creation efforts. Both score measurements
share the same approach by evaluating an individual company’s value score against apredefined number of sub-goals. The key difference between absolute and relative value scoreslies in their calculation methodologies and the insights they offer, as illustrated below:

22

Absolute Value Score: The score provides an encompassing view of an organization's
performance by considering its achievements within the context of a fixed value score range.
Specifically, this score is calculated by summing the total value score achieved by a company
and dividing this sum by a maximum range of 1,680 points. The final score offers an absolutemeasure of an organization's value creation performance across the entirety of the Value Modeland serves as a robust benchmarking tool for comparisons across various industries, sectors,
and regions.
Relative Value Score: This score is computed by dividing the individual organization's total value
score points by the maximum value score points attainable within the specific sub-goals withassigned value scores (which in turn had achieved three points in terms of their disclosure
quality). This score provides a granular view of an organization's ability to create value within
individual sub-goals, with focus on the areas where the organization excels in achieving specificsub-goals, enabling a more comprehensive analysis of its value creation journey.
The Absolute Value Score offers an overarching perspective, making it suitable for comparisons
not only within industries but also on a regional scale. Conversely, the Relative Value Score
offers a micro-level perspective, highlighting a company's unique strengths in achieving specificsub-goals as outlined under the Value Model. This nuanced approach enriches ourcomprehension of value creation in corporate practices, empowering organizations andstakeholders to make more informed decisions in the pursuit of their objectives. The following
diagram illustrates the interconnected relationship between policy score, disclosure quality
score and value score:

27
THEMES

Representedby81

DeriveGOALS
POLICYSCORE

Consist of168

DeriveSUB-GOALS

DeriveDISCLOSUREQUALITY SCORE
ABSOLUTEVALUE SCORERELATIVE
VALUE SCORE
23

See APPENDIX for the complete list of themes, practice goals, and their respective sub-goals.
Normalizing VCA-T Score
Having established the definitions, interconnected concepts and scoring criteria, weconclude this segment with the scaling of all three scores to a 0-100 points system. The scaled
scores can be interpreted as percentages on a 100% points system, with minimum score
corresponding to 0%, and the maximum score corresponding to 100%. We introduced thescaled scores based on the following formula:
Scaled score = ( X / range )*100
where X = Total number of scores achieved by company; range = Scoring range according to
VCA-T. Table 5 presents the summary of the normalized score range of VCA-T:
Score Types
Policy Score
Disclosure Quality Score
Absolute Value Score
Relative Value Score

Data Points
0 - 81
0 – 504
0 – 1,680
0 – (Number of sub-goals with

Normalized Score Range
0 – 100
0 – 100
0 – 100
0 – 100

assigned value score)*10

Table 5: Normalized Score Range of VCA-T

24

Section 3: Case study for the application of VCA-T
Next, we proceed to review the practical application of VCA-T to evaluate real-world corporate
organization’s value measurement in corporate social, environmental, and governance pillars.
Here, we adapted the data collection and analysis approach by Di Vaio et al. (2022) in our
textual analysis for VCA-T scoring application for the selected organization: Natura & Co. First,
the VRC team collected and assessed all corporate financial and non-financial documents
officially published by this organizations for the reporting year of 2021. Next, we identified
specific keywords that were appropriate for defining disclosure items in this research paper. For
example, “diversity”, “workforce”, “gender”, “female” and “male” were selected as keywords
closely associated with the practice goal of gender diversity and equity-based policy. Lastly, weinvestigated all sentences containing these keywords and related concepts to identify which
specific sentence/paragraph to be extracted from these documents for scoring purposes.
Background information about Natura & Co
Natura & Co is a Brazilian multinational corporation engaged in the manufacturing, marketing,and sale of cosmetic, fragrances, and personal hygiene products. Natura & Co was founded in1969 by Antônio Luiz Seabra and it is currently headquartered in São Paulo, Brazil.
Natura & Co consists of several high-profile beauty brands including Natura, The Body Shop,
Avon, and Aesop. It holds a leading position in the cosmetics industry in Latin America and isrecognized globally for its commitment to sustainable business practices.
1. Natura: The original business, Natura is one of the most popular cosmetic brands in
Brazil. It is best known for products that use Brazilian biodiversity ingredients and for its
sustainable approach to packaging and waste.
2. The Body Shop: Acquired in 2017 from L’Oréal, The Body Shop is a British beauty andcosmetics brand. The brand is renowned for its ethically sourced, 100% vegetarian
products, and its commitment to environmental and social causes.
3. Avon: Natura &Co completed its acquisition of Avon in 2020, creating the world’s fourthlargest “pure-play” beauty company. Avon, originally an America company, is a globally
recognized beauty and cosmetics company with a direct-selling business model.
4. Aesop: This Australian luxury skincare brand was acquired in 2013 and is known for its
plant-based and laboratory-made ingredients.
Natura &Co's mission goes beyond simply selling cosmetics. The group prides itself on its
commitment to sustainable business practices and corporate social responsibility. It aims togenerate a positive economic, social, and environmental impact, with several initiatives toreduce its carbon footprint, promote fair trade, and maintain biodiversity.
Nature & Co recognized as a global leader in Sustainability
Natura has been recognized as a leader in sustainability reporting. According to their corporatewebsite (accessed on September 20, 2023), Natura was listed in:
1. The Dow Jones Sustainability Index Top 100 where they were listed for the eighthconsecutive year in the Emerging Markets portfolio,25

2. Corporate Knights, Global 100 plus ranked Natura &Co #42 out of 8,000 companies
they covered.
3. GlobeScan Sustainability Leaders 2021 placed Natura in 3rd place among theCompanies recognized as sustainability leaders.
According to their Integrated Report 2021, Natura & Co’s strategy is centered on several key
areas: sustainability and environmental conservation, social empowerment and community
integration, product innovation in harmony with nature, and robust financial growth. These
areas are discussed in detail, highlighting their approach, achievement, and futurecommitments.
Aligned with Sustainability Reporting Standards, Frameworks and Scoring Models
Natura & Co. aligns their sustainability reporting initiatives against a number of global
sustainability standards and frameworks including, the Global Reporting Initiative (GRI),
Sustainability Accounting Standards Board (SASB), World Economic Forum (WEF), Sustainable
Development Goals (SDGs), Task Force on Climate Related Financial Disclosure (TCFD), Global
Compact Principles, B Impact Assessment, and Health and Sustainable Living Research. Theirperformance has also been evaluated and assessed by a number of outside organizations, suchas Morgan Stanley Capital International (MSCI), Sustainalytics, Financial Times Stock Exchange(FTSE), and Dow Jones Sustainability Index (DJSI).
Supervised by Boards and Assured by Third Parties
Natura & Co’s integrated report was assured by an independent auditor, as determined by
Guidance CPC 09 from the Brazilian Accounting Pronouncements Committee (CPC) and
Resolution 14 from the Comissão de Valores Mobiliários (CVM). The integrated report is not justan internal effort; it also undergoes external assurance. In 2021, PwC was appointed as theoutside auditor to validate the accuracy and reliability of its sustainability report contents.
Natura & Co. and the Value Model Assessment
This segment outlines the analysis of Natura & Co’s sustainability efforts using only their
publicly disclosed data as the basis for this assessment. For this project, we have used thefollowing data sources:- Natura &Co Latin America Integrated Report 2021, accessed on August 2, 2023
- Annual Report 2021, accessed on August 2, 2023
- Natura Integrated Profit & Loss Accounting 2021, accessed on August 10, 2023
- Financial Statement, accessed on August 11, 2023
- Financial Statement Q4, 2022, accessed on August 10, 2023
- Bloomberg, accessed on October 6, 2023
The overall results of this 4-step assessment as applied to Natura and Co.’s 2021 sustainabilityrelated reports are as follows:26

Policy Score: Natura clearly demonstrates a strong commitment to sustainability, with 40 out of
the Value Model’s 81 total goals covered by corporate policies, giving them a score of 49% in thisfirst assessment category. Natura & Co.’s policies focus mostly on Employees, Nature, and theFirm stakeholders. While this is a respectable policy score, their growth potential in this category
is 51% and continuous improvement by Natura towards other stakeholders including Society,
Partners and Customers will not only increase its Policy Score, but also reinforce its commitment
to sustainability practices.
Disclosure Quality Score: Within the Value Model Assessment’s Disclosure Quality Score whichassessed disclosure quality against the 168 sub-goals within the Value Model, Natura & Co.
achieved a distribution of 39% (n= 60) 3-point disclosures which offered quantitative measuresthat directly matched the Value Model goals, 4% (n=7) 2-point disclosures that provided
quantitative measurements but were not directly aligned with the Value Model sub-goals, 2%(n=3) that only offered qualitative statements about the Value Model goals covered, and 58%(n=98) that were not mentioned within Natura & Co.’s public sustainability disclosures.
Key areas for improvement include the "Society" and "Customer" stakeholder categories, whichshow an improvement potential of 81% and 79%, respectively. Enhancing the disclosure quality
within these stakeholder categories can significantly boost disclosure quality and overall
transparency for outside investors.
Value Score: Those 60 goals that achieved 3-point Disclosure Quality status could then be
analyzed using the Value Model’s goals as benchmarks for performance. As stated above, Natura& Co. can potentially elevate their raw value score significantly (64%) by providing data acrossthe 108 Value Model sub-goals that have not yet achieved 3-points in terms of Disclosure Quality.
Of 168 Value Model sub-goals from Value Model, 108 did not generate any Value Score points,
leaving a growth potential of 1,080 points from scorable sub-goals. Because of this missing
disclosure data, the Overall Value Score achieved is 512 out of 1,680 potential points (30.5%) and
the Relative Value Score, for only those sub-goals to have achieved 3-point Disclosure Quality
scores was 512 out of 600 (85.3%). This suggests that while Natura & Co can significantly improvetheir overall value creation capabilities by focusing on the 108 missing subgoals within the Value
Model, of those that they do cover, they score very well.
Assurance: The last step of the Value Model assessment process is to confirm that the data
provided within the company’s sustainability reports have been assured by an independent,
outside auditor or organization. Natura & Co. has highlighted the fact that they have usedvalidation methods involving external third-party auditors to guarantee the authenticity of theirdata. According to our calculations, in accordance with Guidance CPC 09 from the Brazilian
Accounting Pronouncements Committee and Resolution 14 from the Comissão de Valores

27

Mobiliários, an independent auditor verified 42% of the Value Model’s data in their sustainability
reports. From a possible 168 points in this validation step, Natura & Co. secured 71 points.
For a deeper analysis of Natura & Co., please refer to the following pages in this report and ourcompanion Excel worksheet which includes all details and references for all of the information
discussed throughout this paper.
For a deeper analysis of Natura & Co., please refer to our complete assessment report and its
companion Excel worksheet, which includes all details and references for all the information
discussed throughout that paper. Below is a summary of our assessment of Natura & Co.

28

Section 4: Closing Thoughts
As outlined within this white paper, the Value Model continues to evolve as new standards,
frameworks and models are introduced, and we continue to work to refine this research basedon the application of the Value Model to different companies and businesses around the world.
The Value Research Center is now working to align the results of these Value Model “healthchecks” with different financial valuation methodologies, such as Impact Weighted Accounts
and the International Accounting Standard (IAS) 38, an international standard focused on theproper measurement and accounting of intangible assets. While it is too early for us to reporton these results, our intention is to continue to align our research efforts with best practices
related to value measurement as well as its qualification and quantification.
What has been presented in this White Paper is our best effort to publicly share the results ofour research efforts to date, and we hope to collaborate with other researchers, institutions
and organizations who are serious about moving beyond Value Washing, to a goal-based,
objective, transparent system of accounting for impacts across a business’s various
stakeholders and the value created or destroyed within these relationships over time.

29

Appendix 1: The 7 Stakeholders, 27 Themes, 81 Goals of the Value Model:[Dhiyan or Maciej, can you just copy/paste the Stakeholders, Themes and Goals from the Notion
Database here in a pretty way?]30

Appendix 2: Mapping of Standards, Frameworks and Models within the Value Model

31

32

33

References
Business Roundtable. (2019). Statement on the purpose of a corporation . Retrieved fromhttps://opportunity.businessroundtable.org/ourcommitment/
Di Vaio, A., Varriale, L., Lekakou, M., & Pozzoli, M. (2022). SDGs disclosure: evidence from cruise
corporations’ sustainability reporting. Corporate Governance, 23(4), 845–866.
https://doi.org/10.1108/CG-04-2022-0174
Friedman, M. (1970). Social responsibility of business, the new york times magazine. September,
13(33), 122-126.
Gelles, D. (2022). The man who broke capitalism: How jack welch gutted the heartland andcrushed the soul of corporate america—and how to undo his legacy Simon and Schuster.
Harrison, K. B., Meneer, E., & Zhu, B. (2021). ESG 2.0 - The Next Generation of Leadership.
Harvard Law School Forum on Corporate Governance.
https://corpgov.law.harvard.edu/2021/09/02/esg-2-0-the-next-generation-of-leadership/
Papoutsi, A., & Sodhi, M. M. S. (2020). Does disclosure in sustainability reports indicate actual
sustainability performance? Journal of Cleaner Production, 260, 121049.
https://doi.org/10.1016/j.jclepro.2020.121049
Schwab, K. (2019). Davos manifesto 2020: The universal purpose of a company in the fourthindustrial revolution. Retrieved from https://www.weforum.org/agenda/2019/12/davosmanifesto-2020-the-universal-purpose-of-a-company-in-the-fourth-industrial-revolution/
Sugai, P. (2021). The Definition, Identification and Eradication of Value Washing. Journal of
Creating Value, 7(2), 165-169.
Sugai P., Phattanaprayoonvong S., Phetharn J., & Yamazaki M. (2021) Valuing Value -A synthesisof global sustainability frameworks to establish objective and transparent goals to measurevalue for a firm, its shareholders, customers, employees, partners, society and theplanet [Discussion Paper, No: DBS-21-01]. Doshisha Business
School. https://bs.doshisha.ac.jp/studygroup/discussion_paper.html
Sugai, P., & Mahajan, G. (2023). Measuring Value Created for and by Stakeholders. Journal of
Macromarketing, 02761467231174426.
Sugai, Y. (2013). BizDo, the spirit of a business master (1st ed.). S. Carolina, USA:
Vargo, S. L., Maglio, P. P., & Akaka, M. A. (2008). On value and value co-creation: A service
systems and service logic perspective. European Management Journal, 26(3), 145-152.
doi:10.1016/j.emj.2008.04.003
34

35

Practice Goal E1-C
No discrimination by Gender. (KPI)
The gender balance of the workforce
matches 100% with the surrounding
population both in terms of overall
workforce and senior leadership
team.
Theme E1-D
Practice Goal E1-D
Broad Diversity
No discrimination by age, sexual
andorientation nor advantage levels.
Representativeness (KPI) Organization’s workforce andof employees
senior leadership team’s compositionin terms of age, sexual orientation
and advantage levels match 100%with the surrounding population.

Theme E1-C
Gender Diversity
and Equity-based
policyEMPLOYEE E1: DIVERSITY & EQUITY
Theme E1-A
Practice Goal E1-A
Full-time
Organization hires 85% or more of
Employment
total workforces as full-time
employees.
Theme E1-B
Practice Goal E1-B
Ethnic Diversity
No discrimination by Ethnicity. (KPI)
Organization’s workforce and seniorleadership team matches 100% withethnicity of surrounding population.

Sub-Goal E1-D#1
Organization’s workforce composition in terms of age match 100% with thesurrounding population.
Sub-Goal E1-D#2
Organization’s workforce composition in terms of sexual orientation match
100% with the surrounding population.
Sub-Goal E1-D#3
Organization’s workforce composition in terms of advantage levels match
100% with the surrounding population.
Sub-Goal E1-D#4
Organization’s senior leadership team’s composition in terms of age match
100% with the surrounding population.

Sub-Goal E1-B#1
Organization’s workforce matches 100% with ethnicity of surrounding
population.
Sub-Goal E1-B#2
Organization’s senior leadership team matches 100% with ethnicity ofsurrounding population.
Sub-Goal E1-C#1
The gender balance of the workforce matches 100% with the surrounding
population in terms of overall workforce.
Sub-Goal E1-C#2
The gender balance of the workforce matches 100% with the surrounding
population both in terms of senior leadership team.

Sub-Goal E1-A#1
Organization hires 85% or more of total workforces as full-time employees.

APPENDIX – COMPLETE LIST OF THEMES, PRACTICE GOALS, AND THEIR RESPECTIVE SUB-GOALSTheme E2-D
Broad Diversity
andTheme E2-B
Transparent
Reporting on
Wages
Theme E2-C
Living Wage

E2: FAIR WAGES
Theme E2-A
Transparent
Reporting on
Employees

Practice Goal E2-B
Organization reports 100% of thewages paid across worker categories
and locations.
Practice Goal E2-C
Employer pays 250% of theapplicable national minimum wage
for all employees.
Practice Goal E2-D
Organization has no one earning
more than 15 times the annual salary

Practice Goal E2-A
Organization reports on 100% of thepeople that it has employed within acalendar year which includes detailsof their employment status(permanent, full-time, part-time,
temporary, interns, new hires,
departed) as well as their age,gender, & ethnicity.

Sub-Goal E2-D#1
Organization has a maximum compensation scale ratio of 1:15.
Sub-Goal E2-D#2

Sub-Goal E2-C#1
Organization pays a living wage at least 250% of the applicable national
minimum wage.

Sub-Goal E2-A#1
Organization reports on 100% of the people that it has employed within acalendar year which includes details of their employment status(permanent, full-time, part-time, temporary, interns, new hires, departed).
Sub-Goal E2-A#2
Organization reports on 100% of the people that it has employed within acalendar year which includes details of their age.
Sub-Goal E2-A#3
Organization reports on 100% of the people that it has employed within acalendar year which includes details of their gender.
Sub-Goal E2-A#4
Organization reports on 100% of the people that it has employed within acalendar year which includes details of their ethnicity.
Sub-Goal E2-B#1
Organization reports 100% of the wages paid across worker categories andlocations.

Sub-Goal E1-D#5
Organization’s senior leadership team’s composition in terms of sexual
orientation match 100% with the surrounding population.
Sub-Goal E1-D#6
Organization’s senior leadership team’s composition in terms of advantage
levels match 100% with the surrounding population.

E3: HEALTH, WELFARE AND SAFETY
Theme E3-A
Practice Goal E3-A
Health, Welfare
100% of employees are covered
and Safety
under physical health policy.
Theme E3-B
Practice Goal E3-B
Retirement
Organization matches employee
Provision
retirement contributions as per thelaw of the land.
Theme E3-C
Practice Goal E3-C
Family/Medical
Organization provides up to 24 weeks
Leave
of full paid leave for family leave,
while offering flexitime.
Theme E3-D
Practice Goal E3-D
Employee
Organization is responsible for 100%
Healthcareof medical, dental and vision
insurance coverage and offers 100%
reimbursement for one annualcomprehensive medical test for all
employees.
Theme E3-E
Practice Goal E3-E
Occupational
Organization covers 100% of
safety and Health
Employees under the occupational
Coveragesafety and health plan and Zero (0)Work related injuries in this calendar
year.

Representativeness of the lowest paid worker, andof Employees
0% variance in pay between genders
or ethnic groups within each payscale class.

Sub-Goal E3-E#1
Cover 100% of employees under the occupational safety and health plan inthis calendar year.
Sub-Goal E3-E#2
Zero (0) work related injuries in this calendar year.

Sub-Goal E3-D#1
Organization is responsible for 100% of medical, dental and vision
insurance coverage for all employees.
Sub-Goal E3-D#2
Offer 100% reimbursement for one annual comprehensive medical test for
all employees.

Sub-Goal E3-C#1
Organization provides up to 24 weeks of full paid leave for family leave,
while offering flexitime.

Sub-Goal E3-B#1
Organization matches employee retirement contributions as per the law of
the land.

Sub-Goal E3-A#1
100% of employees are covered under physical health policy.

Organization has an equity pay-scale with a maximum variance in pay of 5%
between genders within each of the organization’s pay-scale classes.
Sub-Goal E2-D#3
Organization has an equity pay-scale with a maximum variance in pay of 5%
between ethnic groups within each of the organization’s pay-scale classes.

Practice Goal E4-A
Organization allocates the equivalentof 5% of annual salary per a full-time
employee per year, have a specificnumber of employees trained for a
specific number of hours to upgrade
employee skills

Sub-Goal E5-A#1
Provide turnover rate including:- Voluntary turnover rate = the number of employee-initiated voluntary
separations (such as resignations or retirement).
- Involuntary turnover rate = the total number of entity-initiatedseparations (such as dismissal, downsizing, redundancy, or non-renewal ofcontract).
Sub-Goal E5-A#2
Organization achieves an inclusion score (see JUST 2.0) of 8.0 or higher
within the last calendar year.

Sub-Goal E4-B#1
100% of employees receive performance feedback .

Sub-Goal E4-A#1
Allocate the equivalent of 5% of annual salary per a full-time employee per
year for training and continuing education purposes.
Sub-Goal E4-A#2
Organization provides detailed information on the number of full-time,
part-time, & temporary employees trained within the past calendar year.
Sub-Goal E4-A#3
Organization provides detailed information regarding the number oftraining hours "received" by employees within the past calendar year.

Practice Goal E3-F
Sub-Goal E3-F#1
Organization offers evidence-based
Offer evidence-based behavioural-health services at the same level ofbehavioural-health services at theaffordability and access as physical-health services to 100% of employees.
same level of affordability and accessas physical-health services to 100% of
employees.

Theme E4-B
Practice Goal E4-B
Performance
100% of employees receive
Feedback andperformance feedback
Review
E5: ENGAGEMENT AND SATISFACTION
Theme E5-A
Practice Goal E5-A
Turnover, Inclusion Measure the turnover rate (voluntary& Engagement
and involuntary) and have 3rd party
confirm average inclusion score of
8.0 and 70% engagement rate.

E4: DEVELOPMENT
Theme E4-A
Training and
Education

Theme E3-F
Employee Mental
health andwellbeingPractice Goal E5-B
Organization offers 100% of
employees flexible work options.
Practice Goal E5-C
100% of employees are empoweredwith the freedom of association.
Practice Goal E5-D
Employee stock ownership plans areavailable and accessible to all
employees within an organization.

E6: HUMAN RIGHTS
Theme E6-A
Practice Goal E6-A
Human Rights
Fair and transparent reporting of all
Reportingincidents of discrimination, or humanrights violations, with zero (n=0)
incidents related to discrimination or
human rights violations within theprevious 12 months.
Theme E6-B
Practice Goal E6-B
Human Rights
Corrective actions taken with clear,
Corrective Action
transparent actions set in place for100% of any recorded violations ofhuman rights within the past 12
months.

Theme E5-C
Freedom of
Association
Theme E5-D
Employee
Ownership

Theme E5-B
Flexible Work

Sub-Goal E6-B#1
Corrective actions taken with clear, transparent actions set in place for100% of any recorded violations of human rights within the past 12
months.

Sub-Goal E6-A#1
Fair and transparent reporting of all incidents of discrimination, or humanrights violations.
Sub-Goal E6-A#2
Organization has had zero (n=0) incidents related to discrimination or
human rights violations within the previous 12 months.

Sub-Goal E5-D#1
Employee stock ownership plans are available and accessible to 100% of
employees within an organization.

Sub-Goal E5-C#1
100% of employees are empowered with the freedom of association.

Sub-Goal E5-A#3
Organization achieves an engagement rate of 70% or higher (on the Net
Promoter Score scale) from the result of survey or research study by anindependent third party.
Sub-Goal E5-B#1
Offer 100% of employees flexible work options.

Theme E6-C
Human Rights
Training

Practice Goal E6-C
The operation, training, andinvestment to improve human rightsthat a firm implements. Measured
by the total number or percentage ofactions related to human right
impact assessments, total number ofhours and percentage of security
personnel and other employees
trained regarding human rights, andthe total number or percentage ofinvestments a firm makes regarding
human rights.

Sub-Goal E6-C#1
100% of employee provided with human rights training.

NATURE

Practice Goal N1-B
All non-GHG air emissions aremonitored, measured, and reported
on with net zero impacts. These areaudited and confirmed by anindependent, objective 3rd party

Practice Goal N1-C
Reduce petroleum-based plastic use
to zero, and recycle or reclaim allplastics used/created by a company.

Practice Goal N1-D

Theme N1-B
Zero non-GHG airemissions

Theme N1-C
Zero Plastic
Pollution

Theme N1-D

N1: WASTE AND POLLUTION
Theme N1-A
Practice Goal N1-A
Carbon Neutral
All GHG emissions are monitored,measured, and reported on andorganization achieves carbon
neutrality. These are audited andconfirmed by an independent,
objective 3rd party.

Sub-Goal N1-B#3
Non-GHG emissions are audited and confirmed by an independent,
objective 3rd party.
Sub-Goal N1-C#1
Reclaim and recycle 100% of plastics.
Sub-Goal N1-C#2
Reduce disposable plastics to zero. Initiatives to do so can include:- Develop alternative materials, re-design products and boost innovation
for a more circular plastics lifecycle.
- Develops safe product as demonstrated before market introduction andtest product groups instead of individual substances.
- Increases awareness and precautions about plastic waste.
- Simplifies reporting across the plastic value chain for greatertransparency.
Sub-Goal N1-D#1

Sub-Goal N1-A#2
Organization achieves carbon neutrality within the calendar year.
Sub-Goal N1-A#3
Organization achieved carbon certification (independently verified by third
party i.e. Carbon Trust Standard, Planet Mark or equivalent) within thecalendar year.
Sub-Goal N1-B#1
All non-GHG air emissions are monitored, measured, and reported on
Sub-Goal N1-B#2
Organization achieves net zero non-GHG air emissions within the calendar
year.

Sub-Goal N1-A#1
All (100%) of GHG emissions are monitored, measured, and reported on.

Theme N2-B
Water usereporting

Practice Goal N2-A
Organization outlines the details of
100% of its water infrastructure
across its entire value system(suppliers, customers, distribution
partners, etc.).
Practice Goal N2-B
Organization reports on 100% of its
water usage and interactions, which
are audited and confirmed by anobjective external 3rd party.

Practice Goal N1-E
Zero Sound and Light disturbances .

Theme N1-E
Zero Sound andLight disturbances

N2: WATER
Theme N2-A
Overall Water
infrastructureinteraction
strategy

100% waste stream is reported,
reclaimed or recycled in anenvironmentally friendly way.

100% Waste
reclamation &recycling

Sub-Goal N2-B#1
Organization reports on 100% of its water usage and interactions,providing evidence through:- Reporting on Water Use by Company.
- Total Water Use (in thousands of cubic meters).
- Volume of groundwater consumed.
- Volume of surface water consumed.
Sub-Goal N2-B#2
Organization reports on 100% of its Water conservation/recycling practices,
including information such as:- Water harvested on-site or from recycled sources (in percentage).
- Total volume of water recycled/reused by the organisation (as percentage
of total water).

Sub-Goal N2-A#1
Organization Reports on 100% of its water infrastructure information
across its entire value system.
Sub-Goal N2-A#2
Organization reports on its Actual reduction of water impacts.

100% of organization's entire waste stream is monitored and reported
upon related to its operations within the last calendar year.
Sub-Goal N1-D#2
100% of organization’s entire waste stream is reclaimed and recycled
related to its operations within the last calendar year.
Sub-Goal N1-E#1
Reduction of noise pollution to zero to match surrounding environment,
measured through transparent reporting on decibels and duration of noise
at site of impact.
Sub-Goal N1-E#2
Reduction of light pollution to zero to match surrounding environment,
measured through transparent reporting on lumens and duration of light atsite of impact.

N3: ENERGY
Theme N3-A
EnergyConsumption
Reporting

Theme N2-C
Discharge water
quality

Practice Goal N3-A
Organization provides clear reportingon 100% of its energy consumption
across its operations (1)inputs/sourcing, (2)manufacturing/operating, (3)distribution/selling, and (4) the use of
its products/services that is auditedby an objective outside 3rd party.

Practice Goal N2-C
Water discharge from organization’s
operations is 100% matched to water
input quality, or of higher quality
than when it was withdrawn.

Sub-Goal N3-A#1
Organization provides clear reporting on 100% of its energy consumption
across its inputs/sourcing which is audited by an objective outside 3rdparty.
Sub-Goal N3-A#2
Organization provides clear reporting on 100% of its energy consumption
across its manufacturing/operations that is audited by an objective outside
3rd party.
Sub-Goal N3-A#3
Organization provides clear reporting on 100% of its energy consumption
across its distribution (sales) channels s that is audited by an objective
outside 3rd party.
Sub-Goal N3-A#4- Total volume and breakdown of water (in megalitres) discharged to allareas, including areas with water stress i.e. surface water, groundwater,seawater, third-party water.
- Disclosure of priority substances of concern of treated discharge:# How priority substances of concern/international standard.
# Authoritative list or criteria used.
# Approach for setting discharge limits for priority substances/concern.
# Number of incidents of non-compliance with discharge limits).
- Provides contextual information (i.e. standards, methodologies andassumptions used).
Sub-Goal N2-B#3
Organization reports on 100% of its Value System Water Impacts:- Supply Chain Water Management.
- Supply Chain Water Improvement.
Sub-Goal N2-C#1
100% of water used by organization is returned at its same or better quality
when it is released, measured by PH levels, and other substances (e.g.
nitrates, phosphates, heavy metals and chemicals) in the percentage of
inputs vs. outputs.

Practice Goal N3-C
Renewables or their equivalents
comprise 100% of energy consumed
by a company across its operations(inputs/sourcing, manufacturing/
operating, distribution/selling) and
100% of Renewable Energy Credits(REC’s) are acquired using VPPA andare sourced in the same grid andhave to be the same vintage year ofuse.
Theme N3-C
Practice Goal N3-C
Carbon Neutral
Organization reduces energy carbon
Products
footprint and using carbon offsets toachieve carbon neutrality
requirements for 100% of its
products/services, and theorganization empowers 100% of its
customers to generate carbon neutral
product/services.
N4: PRODUCTS AND SERVICES
Theme N4-A
Practice Goal N4-A
Transparently
Organization clearly andReported Producttransparently reports on all societal
Impactand environmental impacts for 100%of the products/services that it
creates that are then audited andconfirmed by an independent 3rdparty.
Theme N4-B
Practice Goal N4-B

Theme N3-B
Renewable Energy
Use

Sub-Goal N4-A#1
Organization clearly and transparently reports on all societal impacts for
100% of the products/services that it creates that are then audited andconfirmed by an independent 3rd party.
Sub-Goal N4-A#2
Organization clearly and transparently reports on all environmental
impacts for 100% of the products/services that it creates that are thenaudited and confirmed by an independent 3rd party.
Sub-Goal N4-B#1

Sub-Goal N3-C#1
Organization reduces energy carbon footprint and using carbon offsets toachieve carbon neutrality requirements of its products/services.
Sub-Goal N3-C#2
Organization empowers 100% of its customers to generate carbon neutral
product/services.

Sub-Goal N3-B#2
100% of Renewable Energy Credits (REC’s) are acquired using VPPA and aresourced in the same grid and have to be the same vintage year of use.

Sub-Goal N3-B#1
Renewables or their equivalents comprise 100% of energy consumed by acompany across its operations (inputs/sourcing, manufacturing/operating,
distribution/selling).

Organization provides clear reporting on 100% of its energy consumption
across the use of its products/services that is audited by an objective
outside 3rd party.

N5: BIODIVERSITY
Theme N5-A
Biodiversity Impact

Theme N4-E
EfficientTransportation

Theme N4-C
Products with
Positive Societal
and Environmental
Impact
Theme N4-D
Efficient Packaging

Sustainable
Sourcing of Raw
Materials

Practice Goal N5-A
No measurable negative impact on
Biodiversity on sites owned, leased,or managed as well as those adjacent
to areas of high biodiversity value,
and the organization offsets all(100%) of its negative NetZero
biodiversity impacts.

Raw materials or inputs fororganization’s operations are sourced
from 100% sustainable sources, and100% of all non-compliance issues
within the past calendar year aretransparently reported.
Practice Goal N4-C
Achieve 100% cradle to cradle
efficiency or its equivalent for all
products/services created by acompany/organization.
Practice Goal N4-D
Reduce packaging to zero, in cases
when a company/organization
cannot, then trace, collect, andrecycle 100% of all packaging.
Practice Goal N4-E
100% of products/services
distributed by organization are done
so using efficient transportation,
Renewable or net positive Carbon
technologies, which is audited by anobjective outside 3rd party.
Sub-Goal N5-A#1
No measurable negative impact on Biodiversity on sites owned, leased, ormanaged as well as those adjacent to areas of high biodiversity value.
Sub-Goal N5-A#2
Organization offsets all (100%) of its negative NetZero scores using the
National Themes, Outcomes and Measures (TOMs), as follow:- Offsets or mitigation initiatives on biodiversity delivered.
- Donations or investments towards initiatives aimed at environmental andbiodiversity conservations and sustainable management projects for both

Sub-Goal N4-E#1
100% of products/services distributed by organization are done so using
efficient transportation, Renewable or net positive Carbon technologies,
which is audited by an objective outside 3rd party.

Sub-Goal N4-D#2
Organization traces, collect, and recycles 100% of all packaging.

Sub-Goal N4-D#1
Reduce packaging to zero.

Sub-Goal N4-C#1
Achieve 100% cradle to cradle efficiency or its equivalent for all
products/services created by a company/organization.

Sub-Goal N4-B#2
100% of all non-compliance issues within the past calendar year aretransparently reported.

Raw materials or inputs for organization’s operations are sourced from
100% sustainable sources.

Practice Goal N5-C
100% use of Sustainably sourced
Palm Oil in the organization’s
operations or in its supply chain.

Theme N5-C
100% Sustainable
Sourced Palm Oil

Theme N6-B

Practice Goal N6-B

N6: BUILDINGS AND LAND
Theme N6-A
Practice Goal N6-A
Transparently
The organization conducts
Reported Building
transparent reporting on 100% of
and Land Usebuildings and 100% of land used thatare audited by an independent 3rdparty.

Practice Goal N5-B
100% of the operations of anorganization and the
products/services it offers do notlead to the harmful or abusive
treatment of animals certified by anoutside, independent organization.

Theme N5-B
Humane,Compassionate
Treatment of All
Animals

Sub-Goal N6-A#1
The organization conducts transparent reporting on 100% of buildings usedwithin the previous calendar years that are audited by an outside 3rdparty.
Sub-Goal N6-A#2
The organization reports on 100% of land used within the previous
calendar years, which is audited by an independent 3rd party.
Sub-Goal N6-B#1

marine and terrestrial ecosystems.
- Donations or investments towards expert designed sustainable
reforestation or afforestation initiatives.
- Volunteering with environmental conservation initiatives or engagementin multi-stakeholder.
- Plastic recycling rate on the contract.
Sub-Goal N5-B#1
Organization does not participate (0% of activities) in the harmful orabusive treatment of animals, including animal testing, animal
experimentation and factory farming practices.
Sub-Goal N5-B#2
The product received cruelty-free certification by 3rd party animal-cruelty
investigator (i.e. Leaping Bunny).
Sub-Goal N5-B#3
NetZero impact on IUCN Red List species and national conservation list
species with habitats in areas affected by operations.
Sub-Goal N5-C#1
100% palm oil are sourced and certified through the Roundtable on
Sustainable Palm Oil (RSPO) via four different supply chain models:- Identity Preserved.
- Segregated.
- Mass Balance.
- Book & Claim.

SOCIETY

Practice Goal S1-B
Zero issues of legal or regulatory noncompliance.

S2: LOCAL COMMUNITY DEVELOPMENT

Theme S1-B
Appropriate Taxes
Paid

Achieve LEED (Platinum), BREEAM (5Star) or their equivalent certification
for all buildings operated, leased orowned .
Theme N6-C
Practice Goal N6-C
100% of new
100% of new buildings built by anbuildings areorganization are certified as carbon
carbon neutral
neutral in terms of (1) materials used,(2) job site, and (3) the supply chain
used. This is confirmed by anindependent, objective, outside 3rdparty.
S1: APPROPRIATE TAXES
Theme S1-A
Practice Goal S1-A
Transparent tax
Transparently reporting on approachreportingto taxes (in terms of governance andcontrol), payments for all
jurisdictions, that is audited by anoutside objective 3rd party.

100% certified safe
& accessiblebuildings

Sub-Goal S1-A#1
Reports approach to tax:
- To include tax strategy, governance body/executive-level position,
approach to regulatory compliance, approach to tax linked to sustainable
development strategies.
- Description of the tax governance and control framework (governancebody that's accountable for compliance with tax strategy, approach to tax isembedded with org, approach to tax risks, how compliance with tax andcontrol framework is evaluated).
- Description of mechanisms for reporting concerns about unethical or
unlawful behavior related to approach to tax.
- Description of the assurance process for disclosures on tax.
Sub-Goal S1-B#1
Organization has not identified any violations in the business or supply
chain, capital from investors who require transparent and effective
governance, and compliance with local laws.

Sub-Goal N6-C#1
100% of new buildings built by an organization are certified as carbon
neutral in terms of (1) materials used, (2) job site, and (3) the supply chain
used. This is confirmed by an independent, objective, outside 3rd party.

Achieve LEED (Platinum), BREEAM (5-Star) or their equivalent certification
for all buildings operated, leased or owned .

Practice Goal S2-B
Organization identifies and allocates
10% of capital spending to sectorsthat disproportionately benefit
women, the poor, and vulnerable
groups, or focuses on other issues
outlined in SDG Goal #3, including
the reduction of maternal mortality
rates, ending epidemics,
etc. However, these can besuperseded by more pressing issues
that are being focused on within local
communities or by municipal
governments.

Practice Goal S2-C
Organization has a written policy
related to social reporting.

Theme S2-B
Benefit-based
capital spending

Theme S2-C
Transparent Social
Reporting

S3: LOCAL EMPLOYMENT AND ENGAGEMENT
Theme S3-A
Practice Goal S3-A
Local Employment

Practice Goal S2-A
Organization provides 2.5% or moreof revenues to poverty reduction
programs, essential services, safe
driving, homelessness, roughsleepers, health interventions, and/or
wellbeing initiatives. Overall, its
community-based efforts lead to an
NPS score of 8 or higher fromrandomly sampled population.

Theme S2-A
Safe, Resilient
Community

Sub-Goal S3-A#1>50 % of full-time employees hired locally.

Sub-Goal S2-C#1
Organization has a written policy related to social reporting.

Sub-Goal S2-B#1
Organization identifies and allocates 10% of capital spending to sectors that
disproportionately benefit women, the poor, and vulnerable groups, or
focuses on other issues outlined in SDG Goal #3, including the reduction ofmaternal mortality rates, ending epidemics, etc. However, these can besuperseded by more pressing issues that are being focused on within local
communities or by municipal governments.

Sub-Goal S2-A#2
Community-based efforts lead to an NPS score of 8 or higher fromrandomly sampled population.

Sub-Goal S2-A#1
Organization has invested in society’s infrastructure at 2.5 % or more ofrevenues to poverty reduction programs, essential services, safe driving,homelessness, rough sleepers, health interventions, and/or wellbeing
initiatives.

Practice Goal S3-C
At least 10% of all goods purchased
are from certified Minority and
Women-Owned Businesses(MWOBEs), Service-Disabled
Veteran-Owned Businesses (SDVOBs),or worker cooperatives.
Practice Goal S3-D
Impacts on local businesses acrossthe entire lifecycle of 100% of
products/services created by acompany are mapped, with clear
insights on the number of residents
employed through a company’s
activities. Organization has purchased
locally at least 30% fromindependent, locally owned andoperated businesses.
Practice Goal S3-E
Clear evidence of (1) enhancing theskills of younger employees, and (2)outreach from >50% of the workforce
to local jr. high, high schools anduniversities.

S4: CHARITY AND VOLUNTEERISM

Theme S3-E
Supporting Local
Youth

Theme S3-D
Local Value Chains

Theme S3-C
Equitablepurchasing

Theme S3-B
Local Ownership>50% of full-time employees hired
locally, >50% of senior management
hired locally.
Practice Goal S3-B
>50% of shareholders are local.

Sub-Goal S3-E#1
Clear evidence of (1) enhancing the skills of younger employees from >50%of the workforce.
Sub-Goal S3-E#2
Clear evidence of outreach from >50% of the workforce to local jr. high,high schools and universities.

Sub-Goal S3-D#1
Impacts on local businesses across the entire lifecycle of 100% of
products/services created by a company are mapped, with clear insights on
the number of residents employed through a company’s activities.
Sub-Goal S3-D#2
Organization has purchased locally at least 30% from independent, locallyowned and operated businesses.

Sub-Goal S3-B#1
At least 50% of all shareholders are local, ensuring a close connection
between the company’s owners and the local community.
Sub-Goal S3-C#1
At least 10% of all goods purchased are from certified Minority and
Women-Owned Businesses (MWOBEs), Service-Disabled Veteran-Owned
Businesses (SDVOBs), or worker cooperatives.

Sub-Goal S3-A#2>50% of senior management hired locally.

Practice Goal S4-A
Organization provides 24 hours of
paid volunteer time per year forvolunteering purposes at anorganization of the employee’s
choice.

Practice Goal S4-B
Organization donates 1% of grosssales or 3% of net profits tocharitable organizations that
employees choose.

Theme S4-A
Community
volunteering

Theme S4-B
Charitable giving

Sub-Goal S4-B#1
Organization donates 1% of gross sales or 3% of net profits to charitableorganizations that employees choose.

Sub-Goal S4-A#1
Organization provides 24 hours of paid volunteer time per year forvolunteering purposes at an organization of the employee’s choice.

FIRM

Theme F1-B
Government
relationship

Practice Goal F1-B
Organization transparently reports
100% of all financial assistancereceived from the government,

F1: TRANSPARENT FINANCIAL REPORTING
Theme F1-A
Practice Goal F1-A
Transparent
Organization reports on its financial
reporting on
performance including direct andfinancial
indirect economic impacts which is
performance
independently audited by an outsidetrusted 3rd party.
Sub-Goal F1-A#1
Cash Flow Statement that summarizes the amount of cash (or cash
equivalents) entering and leaving an organisation.
Sub-Goal F1-A#2
Income statement that reports an organisation's financial performance(profit and loss).
Sub-Goal F1-A#3
Balance Sheet that reports a company's total assets including
debt/liabilities and shareholder equity.
Sub-Goal F1-A#4
Financial Ratio that evaluates the overall financial condition of anorganization and its ability to generate income.
Sub-Goal F1-A#5
Reporting currency
Sub-Goal F1-A#6
Revenue and Net Income: 1 year and 2 years prior.
Sub-Goal F1-A#7
Direct economic value generated and distributed (EVG&D) for theorganization’s global operations on an accruals basis, which includes thefollowing basic components:- Direct economic value generated.
- Economic value distributed.
- Economic value retained.
Sub-Goal F1-A#8
Examples of significant identified indirect economic impacts of theorganization, including positive and negative impacts.
Sub-Goal F1-B#1
Organization transparently reports 100% of all financial assistance received
from the government financial or non-financial in nature.
Sub-Goal F1-B#2

Theme F2-B
Governance
Reporting

Practice Goal F2-B
100% of basic governance structure
and practices reported on and

F2: GOVERNANCE AND FIRM STRUCTURE
Theme F2-A
Practice Goal F2-A
Mission Driven
Published mission with nodissonance between mission andreported behaviors (in the News)
within the last 12 months.

political contributions made, and any
fines or sanctions related to noncompliance with any laws and/or
regulations, financial or non-financial
in nature.

Sub-Goal F2-A#1
Report the following information:- Statement from senior decision-maker related to sustainability.
- Key impacts, risks, and opportunities.
- Values, principles, standards, and norms of behavior.
- Mechanisms for advice and concerns about ethics.
Sub-Goal F2-A#2
Provide the following:- Level of Impact Focus.
- Mission Statement Characteristics.
- Mission Statement.
- Social and Environmental Decision-Making- Stakeholder Engagement.
- Management of Material Social and Environmental Issues.
- Identification of Material Issues.
Sub-Goal F2-A#3
Address the issue of what has the organisation done to legally ensure thatits social or environmental performance is a part of its decision-making
over time, regardless of company ownership.
Sub-Goal F2-A#4
No dissonance between 3 sub-goals above and reported behaviors (in theNews) within the last 12 months.
Sub-Goal F2-B#1
100% of basic governance structure and practices reported on and audited
by outside 3rd party to confirm on an annual basis.

Organization transparently reports 100% of all political contributions madeto the government, financial or non-financial in nature.
Sub-Goal F1-B#3
Organization transparently reports 100% of all fines or sanctions related to
non-compliance with any laws and/or regulations, financial or non-financial
in nature.

Sub-Goal F2-C#1
Board composition matches 100% with surrounding community relative togender diversity.
Sub-Goal F2-C#2
Board composition matches 100% with surrounding community relative to
ethnic diversity.
Theme F2-D
Practice Goal F2-D
Sub-Goal F2-D#1
Outside Director
Board composition matches +/- 5% or Board composition matches +/- 5% or less with industry standard on ratio
Ratio
less with industry standard on ratioof outside directors as a percentage of overall board membership.
of outside directors as a percentageof overall board membership.
Theme F2-E
Practice Goal F2-E
Zero Corruption
Organization has zero incidences of
Sub-Goal F2-E#1
corruption within the last 12 months, Organization has zero incidences of corruption within the last 12 months,
audited by an outside, objective 3rd
audited by an outside, objective 3rd party.
party.
F3: MANAGEMENT CAPABILITY
Theme F3-A
Practice Goal F3-A
Sub-Goal F3-A#1
Positive EVA
Calculation of Economic Value Added Calculation of Economic Value Added (EVA) over Average EVA of Industry.
(Firm)/EVA(EVA) over Average EVA of Industry.
(Industry) ratio

Theme F2-C
Board Composition

audited by outside 3rd party toconfirm on an annual basis.
Practice Goal F2-C
Board composition matches 100%with surrounding community relative
to gender and ethnic diversity

CUSTOMER C1: TRUTH IN COMMUNICATIONSTheme C1-A
Practice Goal C1-A
Truth in Labelling
100% of products/services offered by
a company have clear labelling that is
assessed by a relevant 3rd party
related to their components, content,
safe use, and disposal, and theorganization has zero incidences of
non-compliance with regulations
and/or voluntary codes concerning
product and service information andlabelling.
Theme C1-B
Practice Goal C1-B
Truth in
100% of advertised products haveAdvertising
been reviewed and certified by anobjective 3rd party or accreditation
body. Amongst these, 0% of
products/services advertised or
promoted by a company have had
incidents of non-compliance withregulations and/or voluntary codes
concerning marketing
communications.
C2: PRIVACY
Theme C2-A
Practice Goal C2-A
Data Security
Zero (0) data breaches within thecalendar year.
Sub-Goal C2-A#1
Organization experiences zero substantiated complaints (from regulatory
bodies and outside parties) or incidents regarding data breaches, data
leaks, thefts/attacks, or losses of customer data; OR
if there is a record of incidents, the organization shall report the total
number of data breaches, percentage of data breaches, and the total
number of unique users who were affected.
Sub-Goal C2-A#2

Sub-Goal C1-B#1
100% of advertised products have been reviewed and certified by anobjective 3rd party or accreditation body.
Sub-Goal C1-B#1
Amongst these, 0% of products/services advertised or promoted by acompany have had incidents of non-compliance with regulations and/or
voluntary codes concerning marketing communications.
Sub-Goal C1-B#1
Organization has a significant suppliers (on currency basis) that are subject
to regular quality assurance reviews or audits at 100%.

Sub-Goal C1-A#2
Organization has zero incidents of non-compliance with regulations and/or
voluntary codes concerning product and service information and labelling;
OR If there is a record of incidents, organization shall report the incidents
of non-compliance with regulations resulting in a fine or penalty, warning,and voluntary codes.

Sub-Goal C1-A#1
100% of products/services offered by a company have clear labelling that is
assessed by a relevant 3rd party related to their components, content, safe
use, and disposal.

Theme C2-B
Customer Privacy

Practice Goal C2-B
Zero (0) breaches, leaks or thefts ofcustomer data within the calendar
year.

Organization describes its approach to identifying vulnerabilities in its
information systems that pose a data security risk and addressing data
security risks and vulnerabilities it has identified.
Sub-Goal C2-A#3
Organization Complies 100% with cyber security legislation and principles
related to the country (countries) within which it operates, such as the U.S.
SEC’s Commission Statement and Guidance on Public Company
Cybersecurity Disclosures or an external standard or framework and/or
legal or regulatory framework for managing data security.
Sub-Goal C2-B#1
Organization Describes the nature, scope, and implementation of its
policies and practices related to user privacy, with a specific focus on how it
addresses the information collection lifecycle (i.e., collection, usage,
retention, processing, disclosure, and destruction of information) and how
information-handling practices at each stage may affect individuals’ privacy.
Sub-Goal C2-B#2
Organization Complies 100% with privacy legislation and principles (i.e. theU.S. Guidance for Implementing the Privacy Provisions of the EGovernment Act of 2002) including the use of Privacy Impact Assessments(PIAs).
Sub-Goal C2-B#3
Organization follows practices related to privacy of user information that
addresses children’s privacy, which at a minimum includes the provisions of
the U.S. Children’s Online Privacy Protection Act (COPPA), or its equivalent.
Sub-Goal C2-B#4
Organization discloses 100% of unique users whose information is used forsecondary purposes.
Sub-Goal C2-B#5
Organization follows the cross-industry Self-Regulatory Principles for Online
Behavioral Advertising.

Theme C3-B
Customer Health &SafetyPractice Goal C3-B
100% of products/services areassessed for their impacts oncustomer health and safety auditedby an outside, independent 3rd party,
and have achieved 0% negative
impacts on customer health or safety
within the calendar year.

C3: HEALTH, SAFETY & SATISFACTION
Theme C3-A
Practice Goal C3-A
Customer
Customer satisfaction with products
Satisfaction
and/or services offered as measured
by Net Promoter Score, with anaverage rating of 8 or higher auditedby an outside, independent 3rd party.
100% of customer complaints andreturns are recorded.

Sub-Goal C3-B#1
Organization has achieved 0% negative impacts on customers health within
the calendar year. If there is an incident, the organization shall disclose thepercentage of significant product and service categories for which healthand safety impacts are assessed for improvement.
Sub-Goal C3-B#2
100% of products/services are assessed for their impacts on customer
health and safety audited by an outside, independent 3rd party.
Sub-Goal C3-B#3
Organization has zero (n=0) non-compliance cases with regulations and/or
voluntary codes concerning the health and safety impacts of products andservices by incidents of non-compliance with a fine or penalty/ warning/
voluntary codes.

Sub-Goal C3-A#1
Organization has a channel (grievance mechanisms, hotlines, dialogue
processes or other means) opened for customer returns, concerns orcomplaints.
Sub-Goal C3-A#2
Customer satisfaction with products and/or services offered as measured
by Net Promoter Score, with an average rating of 8 or higher audited by anoutside, independent 3rd party.
Sub-Goal C3-A#3
100% of customer complaints and returns are recorded.

PARTNER

P1: SUPPLY CHAIN AND DISTRIBUTION CHANNEL REPORTING
Theme P1-A
Practice Goal P1-A
Sub-Goal P1-A#1
Report on
100% of supply chain and distribution Provide a list of 100% of stakeholder groups (supply chain and distribution
Stakeholder
channel partners are reported on and channels) engaged by the organization, including the basis for identification
Structure in theconfirmed by an objective outsideand selection of stakeholders with whom to engage.
Supply Chain and
3rd Party.
Sub-Goal P1-A#2
Distribution
Organization reports on 100% of its approach to stakeholder engagement,
Channelincluding:- Frequency of engagement by type and by stakeholder group, and an
indication of whether any of the engagement was undertaken specificallyas part of the report preparation process.
- Key topics and concerns that have been raised through stakeholder
engagement, and how the organization has responded to those key topics
and concerns through its reporting and the stakeholder groups that raised
each of the key topics and concerns.
Sub-Goal P1-A#3
Organization reports on 100% of its Supply Chain and distribution channel
management, including :- Description and disclosure of a 100% of original producers, subcontracted
services, distributors or/and suppliers (Tier 1 and Tier 2) that werescreened/monitored, held accountable to code of conduct or independent
contractor practices and/or Undergone programs to improve impact. This
information is supported by transparent reporting, verification and goal
setting.
- Description of purchases/ distribution choices (e.g. low income
communities or social/environmental purchase).
- Description of supply chain channel monitoring mechanism (i.e.
compliance topics, risk assessment and mapping, and tracking andtraceability).
Sub-Goal P1-A#4
Organization reports on 100% of its Supply chain and distribution channel
poverty alleviation programs.

Theme P2-B

Practice Goal P2-B

Practice Goal P1-B
Organization provides a complete
report on the diversity, equity andinclusion practices within 100% of
suppliers and distributors, confirmedby an objective outside 3rd party.
P2: SUPPORTING MSMES AND VCSES
Theme P2-A
Practice Goal P2-A
Supporting
Proven support for local Micro, Small,
MSMEs, VCSEs,
Medium Enterprises (MSMEs),
MWOBEs, and/or
Voluntary, Community and Social
SDVOBs throughEnterprises (VCSEs), Minority andbusiness
Women-Owned Business Enterprises
partnerships(MWOBEs), and/or Service Disabled
Veteran Owned Businesses (SDVOBs)
with 1% or more of businessconducted through them.

Theme P1-B
Report on Supply
Chain Diversity,
Equity andInclusion

Sub-Goal P2-B#1

Sub-Goal P2-A#1
Organization conducts 1% or more of business across the partners within
this subgoal. Specifically this sub-goal focuses on the provision of support
for micro-franchises:- Percentage of business/sales derived from small and medium microfranchises (i.e., low Income, poor, or very poor micro-franchises).
- Describes innovative microfranchisng.
- Describes microfranchise model characteristics.
- Income growth tracking for micro-franchises.
Sub-Goal P2-A#2
Organization conducts 1% or more of business across the partners within
this subgoal. Specifically, this sub-goal focuses on the provision of support
for micro distributors:- Percentage of business/sales derived from small and medium micro
distributors (i.e., low Income, poor, or very poor micro-franchises).
- Describes innovative micro distribution.
- Describes micro distribution model characteristics.
- Income growth tracking for micro distributors.
Sub-Goal P2-A#3
Organization conducts 1% or more of business across the partners within
this subgoal. Specifically this sub-goal focuses on the provision of support
for micro entrepreneurs:- Number of micro-entrepreneur individuals served.
- Number of microenterprises served.

Sub-Goal P1-B#1
Organization provides a complete report on the diversity, equity andinclusion practices within 100% of suppliers and distributors, confirmed byan objective outside 3rd party.

Education and training programs
Education and training programs developed for local Micro, Small, Medium
developed for local Micro, Small,Enterprises (MSMEs), Voluntary, Community and Social Enterprises
Medium Enterprises (MSMEs),(VCSEs), Minority and Women-Owned Business Enterprises (MWOBEs),
Voluntary, Community and Social
and/or Service Disabled Veteran Owned Businesses (SDVOBs) that help
Enterprises (VCSEs), Minority andimprove their own business acumen and skills, verified through
Women-Owned Business Enterprises benchmarking performance and exhibiting 10% or higher performance(MWOBEs), and/or Service Disabled
gains.
Veteran Owned Businesses (SDVOBs)
that help improve their own businessacumen and skills, verified throughbenchmarking performance andexhibiting 10% or higher
performance gains.
P3: ENVIRONMENTALLY & SOCIALLY RESPONSIBLE PARTNERS
Theme P3-A
Practice Goal P3-A
Sub-Goal P3-A#1
Suppliers and100% of an organization’s suppliers
100% of an organization’s suppliers report on their social andDistributor Impact and distributors (a) report on theirenvironmental management approaches, which are audited by an
Reportingsocial and environmental
objective external 3rd party.
management approaches, and (b)Sub-Goal P3-A#2
have documented processes
100% of an organization’s suppliers have documented processes programs
programs in place to improvein place to improve sustainability practices within supply chain, which aresustainability practices within supply audited by an objective external 3rd party.
chain and/or distribution channel, (c) Sub-Goal P3-A#3
with evidence of termination ofOrganization provides evidence of termination of relationships with 100%
relationships with suppliers andof suppliers who have been identified as having negative environmental
distributors who have been identified and/or social impacts which is audited by an objective external 3rd party.
as having negative environmental
Sub-Goal P3-A#4
and/or social impacts all of which are 100% of an organization’s distributors report on their social andaudited by an objective external 3rd
environmental management approaches, which are audited by anparty.
objective external 3rd party.
Sub-Goal P3-A#5

Supporting
MSMEs, VCSEs,
MWOBEs, and/or
SDVOBs througheducation andtraining

Theme P3-C
Supply Chain
CarbonCertification

Theme P3-B
Environmental andSocial operating
requirements

Practice Goal P3-C
Company/organization has achieved
certification by a reputable, industrystandard certification organization for
100% of its supply chain anddistribution channel partners acrossfactors including carbon, water andPractice Goal P3-B
Social & environmental screening of
suppliers and distributors with 100%of suppliers and distributors
contracts include: (a) sustainableprocurement and distribution
requirements and certifications; (b)require contractors to operate low orzero emission vehicles.

100% of an organization’s distributors have documented processes
programs in place to improve sustainability practices within the distribution
channel which is audited by an objective external 3rd party.
Sub-Goal P3-A#6
Organization provides evidence of termination of 100% of relationships
with suppliers who have been identified as having negative environmental
and/or social impacts, which is audited by an objective external 3rd party.
Sub-Goal P3-B#1
Social & environmental screening of suppliers with 100% of suppliers
contracts including; sustainable procurement and supplier requirements
and certifications.
Sub-Goal P3-B#2
Social & environmental screening of distributors with 100% of distributors
contracts including; sustainable procurement and distributors
requirements and certifications.
Sub-Goal P3-B#3
Social & environmental screening of suppliers with 100% of suppliers
contracts including ; require contractors to operate low or zero emission
vehicles.
Sub-Goal P3-B#4
Social & environmental screening of distributors with 100% of distributors
contracts including; require contractors to operate low or zero emission
vehicles.
Sub-Goal P3-C#1
Company/organization has achieved certification by a reputable, industrystandard certification organization for 100% of its supply chain relative to:- Carbon emissions.
- Water usage.
- Waste management by an objective 3rd party (e.g. Carbon Trust’sStandard, Higg Index or its equivalent).

SHAREHOLDER

SH1: SHAREHOLDER ECONOMIC VALUE ADDED (EVA)
Theme SH1-A
Practice Goal SH1-A
Positive EVA
Positive EVA

Sub-Goal P1-A#1
Positive EVA

Sub-Goal P3-C#2
Company/organization has achieved certification by a reputable, industrystandard certification organization for 100% of its distributors relative to:- Carbon emissions.
- Water usage.
- Waste management by an objective 3rd party (e.g. Carbon Trust’sStandard, Higg Index or its equivalent)
P4: SUPPLY CHAIN & DISTRIBUTION CHANNEL FAIR LABOR PRACTICES
Theme P4-A
Sub-Goal P4-A#1
Audited Fair labor
Practice Goal P4-A
100% of supply chain partners reports on Fair labor practices which arepractices
100% of supply chain & distribution
audited by objective 3rd party.
throughout supply partners reports on fair labor
Sub-Goal P4-A#2
chain andpractices which are audited by
100% of distribution partners reports on Fair labor practices which are
distribution
objective 3rd party.
audited by objective 3rd party.
channels
Theme P4-B
Practice Goal P4-B
Sub-Goal P4-B#1
Living wage paid by Living wages (>250% of national
Living wages (>250% of national minimum wage) paid by 100% of suppliers.
all suppliers andminimum wage) paid by 100% of
Sub-Goal P4-B#2
distributors in
suppliers and distributors.
Living wages (>250% of national minimum wage) paid by 100% ofpartner network
distributors.

waste management, or theirequivalent.