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

GRI Sector Standards Project Oil,Gas, and Coal
Basis for Conclusions for GRI 11: Oil and Gas
Sector 2021

© GRI 2021

Contents
GRI Sector Standards Project Oil, Gas, and Coal .................................................................................. 1
Basis for Conclusions for GRI 11: Oil and Gas Sector 2021............................................................... 1
Contents .................................................................................................................................................. 2
About this document ............................................................................................................................... 3
Introduction ............................................................................................................................................. 3
Objectives for the development of GRI 11: Oil and Gas Sector .......................................................... 3
Scope of the public comment .............................................................................................................. 3
Overview of submissions ..................................................................................................................... 4
Methodology for analyzing comments ................................................................................................. 4
Significant issues and GSSB responses................................................................................................. 5
I.

Issues regarding the proposed implementation model of Sector Standards .............................. 5

II.

Issues regarding the oil and gas sector specific content of the exposure draft .......................... 8
Cross-cutting issues......................................................................................................................... 8
Oil and gas likely material topic-specific issues ............................................................................... 9

Appendix 1. Participation in regional events and webinars .................................................................. 18
Appendix 2. Public comment submissions by stakeholder constituency and region ............................ 19

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1

About this document234This document summarizes the significant issues from comments received on the exposure draft of
the Oil and Gas Sector Standard during the public comment period from 8 July 2020 to 6 October
2020.

5
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This document incorporates comments received through the public comment form hosted on the
Sector Standards Project for Oil, Gas, and Coal webpage and feedback submitted by email. Where
relevant, it also references comments made at stakeholder workshops held during the publiccomment period.

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All comments received, together with an analysis of the issues raised, were considered by the Oil,Gas, and Coal Working Group. The recommendations of the Working Group were shared with the
Global Sustainability Standards Board (GSSB) for review and approval.

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13This document provides a summary of the GSSB responses to the significant issues raised during the
public comment period.

14

The full set of received comments can be downloaded from the project page on the GSSB website.

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GRI 11: Oil and Gas Sector 2021 can be downloaded here.

16

Introduction

17

Objectives for the development of GRI 11: Oil and Gas Sector

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The project proposal for an Oil, Gas, and Coal Sector Standard was approved by the Global
Sustainability Standards Board (GSSB), GRI’s independent standard setting body, at its meeting heldon 25 and 26 March 2019. During the course of the project, in April 2020, the GSSB decided toseparate coal from the oil and gas contents. GRI 11: Oil and Gas Sector 2021 is the first Sector
Standard to be published under GRI’s Sector Program.

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The GSSB initiated the GRI Sector Program in 2019 to develop standards that are specific to certain
sectors and increase consistency by focusing sustainability reporting on the impacts that matter most.
As outlined in the GRI Sector Program description, Sector Standards aim to identify and describe thesectors’ significant impacts and stakeholder expectations in terms of sustainable development. At thesame time, they aim to provide evidence and authoritative references for the impacts. As the first pilot
project, the style, format and implementation approach were also developed throughout the course of
the development of GRI 11.

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The project followed the GSSB Due Process Protocol. Proposed revisions to the exposure draft of the
Oil and Gas Sector Standard were discussed with the Working Group over the course of two
meetings and several targeted conversations with individual members. Proposed revisions were also
discussed with the GSSB over the course of four meetings in 2020 and 2021 – two focused on thegeneral implementation approach of Sector Standards and two focused on oil and gas.

35

Scope of the public comment

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The exposure draft of the Oil and Gas Sector Standard was open for public comment from 8 July to 6
October 2020.

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As this was the first GRI Sector Standard to be released for public exposure under the GRI Sector
Program, the public comment period served a dual purpose: to test the completeness and relevanceof the content on oil and gas; and to seek feedback on value, clarity, and feasibility of the proposed
concept for Sector Standards.

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A range of outreach activities were carried out during the public comment period, including webinars
and stakeholder consultation, both group and one-on-one targeting key regions and constituencies.

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Comments collected during these activities, though not considered official public comment
submissions, were also taken into account when they aided understanding of the official submissions,or when they flagged a significant issue that was not raised in the official submissions. This series ofengagements reached approximately 1,000 participants.

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Any comments outside the scope of this public comment were compiled and directed to theappropriate team. Along with the developing Sector Standards, the GRI Sector Program supports theenhancement and expansion of the GRI Standards by surfacing issues not previously covered by the
GRI Standards. Feedback on Topic Standards received during public comment has been collated
separately for consideration by the GSSB.

53

Overview of submissions

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Respondents were asked to submit comments on the exposure draft using an online survey. The linkto the survey was made available on the oil and gas project page. Respondents could also submit
additional feedback via email to oil@globalreporting.org.

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A total of 60 public submissions from individuals and organizations was received on the exposure
draft. This consisted of 10 submissions solely concerning Sector Standards in general and 50
submissions concerning the Sector Standards in general and the oil and gas-specific content. Six
survey respondents submitted additional information offline. The submissions came from all fivestakeholder constituencies represented by the GSSB: business enterprise, civil society organization,
investment institutions, labor, and mediating institutions.

63

For more detail, see:64•

The full set of received comments available to download from the oil and gas project page.

65•

Appendix 1 for a list of stakeholder events and overview of participation.

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67

•

Appendix 2 for a breakdown of public comment submissions by representation, stakeholder
constituency, and region.

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Methodology for analyzing comments

69

All comments submitted by respondents were collated by the Standards Division.

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Each comment was categorized according to the public comment objective it responded to, therelevant section of the Standard, and an overarching theme if relevant. If a respondent raised several
different points in one comment, the points were separated as distinct comments.

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The qualifiers in Table 1 are used to indicate the percentage of respondents who provided feedback
on a significant issue. Because the survey asked mostly open questions to encourage respondents toprovide feedback on sections of interest to themselves, not all respondents provided comments on all
sections of the exposure draft. Consequently, certain sections or disclosures have a lower number ofcomments relative to the overall number of respondents.

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Table 1. Qualifiers indicating the percentage of respondents who provided feedback
QualifierRespondents

Majority> 50 %

Many

30-50%

Some

10-30%A few< 10 %

One

1

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Significant issues and GSSB
responses
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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents during the public comment, outlines proposed changes to the exposure draft of the Oil
and Gas Sector Standard, and explains why changes suggested by respondents were or were notaccepted by the GSSB.

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Identified significant issues have been organized into the following sections:

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I. Issues regarding the proposed structure and implementation model of Sector Standards
II. Issues regarding the oil and gas sector specific content of the exposure draft

85

Notes for the reader:

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•

Only topics for which significant issues were identified have been included in this document.
Other comments received on air emissions, employment practices, forced labor, freedom of
association and collective bargaining, land use and resource rights, and anti-competitive behavior
have not been included in this document.

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•

This document includes references to the exposure draft of the Oil and Gas Sector Standard andthe final version of GRI 11: Oil and Gas Sector 2021. When referring to the content in the
exposure draft, the names of the sections and topics as they were in the exposure draft are used.

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References to GRI 1: Foundation 2021 and GRI 3: Material Topics 2021 are made throughout thisdocument. These new Standards are as a result of the recently completed review of the Universal
Standards and are available here.

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I. Issues regarding the proposed implementation model of Sector
Standards

9899a) Identifying topics as material for a sector and requiring reporting on these fromorganizations in the sector

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Many respondents expressed support for identifying topics that are material for all organizations in asector and therefore requiring reporting on them. Respondents suggested that this model can:

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107

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•

Increase transparency by inducing a better quality or volume of information;
Increase consistency in reporting, building comparability across a sector;
Decrease likelihood of organizations cherry-picking or evading reporting on material topics;
Contribute to organizations’ ambition to manage impacts related to those topics, leading toaccelerated action;
Increase the credibility and authority of Sector Standards.

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110

A few respondents considered requiring reporting on all or most topics in a Sector Standard to
be reasonable given that Sector Standards reflect consensus on what is considered material for a
sector.

111
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A few respondents, who expressed support for requiring reporting on topics identified as material forthe sector, also specified that there should be the option of making a statement of omission in thecase an organization does not report on a topic.

114
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116

In relation to the exposure draft of the Oil and Gas Sector Standard, some respondents indicated that
GHG emissions, in particular, should be considered mandatory for reporting by all organizations in theoil and gas sector.

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A few respondents expressed opposition to identifying topics that are material for organizations in asector without consideration of an organization’s unique circumstances. They stated that this model
does not:Page 5 of 19

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Take into account the wide variety of activities organizations in a sector undertake;
Allow for flexibility for those organizations with varying levels of reporting experience;
Ensure quality of information (e.g., when data is not available or is difficult to accessorganizations may feel pressure to fill gaps with less reliable information);
Encourage use of GRI Standards, due to the increased time, resources, and costs associatedwith meeting a higher threshold set by requiring reporting on some topics.

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A few respondents suggested it would be instead preferable for Sector Standards to identify a small
set of indicators required for reporting by organizations in a sector.

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133

GSSB response: Material topics represent an organization’s most significant impacts on the economy,
environment, and people, including impacts on their human rights. In the GRI Standards, impact
refers to the effect an organization has or could have as a result of the organization’s activities orbusiness relationships. The topics an organization determines as material may vary according to its
specific circumstances, such as its business model; sectors; geographic, cultural, and legal operating
context; ownership structure; and the nature of its impacts.

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136

Determining material topics based solely on the characteristics and shared impacts of a sector would
limit the ability of organizations to consider their own specific circumstances and disregard theinfluence these could have on impacts in which it is involved and the severity of these impacts.

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The approach of identifying likely material topics for organizations in a sector, based on the sector’ssignificant impacts, has been maintained for Sector Standards. This means that all topics listed in a
Sector Standard are considered likely to be material for an organization in the sector. However, any
topic from the applicable Sector Standard that the organization has determined as not material isrequired to be listed in the GRI content index, along with an explanation of why it is not material. Thisis specified in Requirement 3-b in GRI 1: Foundation 2021.

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b) Providing an explanation if topics listed in a Sector Standard are not deemed material by
the organization

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Many respondents expressed support for requiring an organization to provide an explanation when a
topic listed as likely material in the applicable Sector Standard is determined as not material by theorganization. Some respondents opposed this approach.

148

Respondents suggested this approach is of value because it can:

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Increase transparency by inducing better quality reporting;
Increase consistency in reporting, enhancing the ability of information users to evaluate andcompare organizations’ performance;
Decrease the likelihood of organizations cherry-picking or evading reporting on material
topics;Demonstrate that the topics included in applicable Sector Standards have been considered,substantiating the credibility of an organization’s process for determining material topics
and avoiding incorrect assumptions about why topics were not reported on.

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One respondent suggested that organizations clearly identifying which topics included in a Sector
Standard have been determined as not material can provide insights useful for improving the Sector
Standard in the future.

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Being required to provide an explanation for topics listed in an applicable Sector Standard but notdetermined as material by the organization, was not favored as an approach for the following
reasons:

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170

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The list of likely material topics in a Sector Standard may not be comprehensive or applicable
to all organizations in the sector;
Such a requirement fails to acknowledge the growing number of regulatory requirements
related to sustainability reporting, which should define what is reported;
Organizations should be given discretion to identify which topics should be reported on;
In most cases, the reason will be obvious to the reader based on the nature of
the organization. A better option is to require explanation of the process for
deciding which topics are not considered material.

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171
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A few respondents expressed concern that it was unclear to what degree an organization would haveto describe why a topic is not material.

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Some respondents suggested a number of variations of this approach could be considered,including an aggregated explanation that applies to a group of topics. One respondentsuggested that an organization should demonstrate why a topic is not material by outlining technicalconsiderations, as well as historical and projected data and statements from stakeholders confirmingthat a topic is not material.

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GSSB response: An organization reporting in accordance with the GRI Standards will be required
to determine whether each topic in the applicable Sector Standards is a material topic for theorganization. Any topic from the applicable Sector Standard that the organization has determined as
not material is required to be listed in the GRI content index along with an explanation of why it is notmaterial. This is specified in Requirement 3-b in GRI 1: Foundation 2021. An example table andguidance about how to prepare the GRI content index has also been added to GRI 1.

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Note: this response also takes into account public comments collected on the exposure draft of the
GRI Universal Standards.

186c) Role of Sector Standards in focusing sustainability reporting

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A few respondents indicated that Sector Standards, based on the example of the exposure draft of
the Oil and Gas Sector Standard, include too many topics and/or request too much information. They
expressed concern that the format and approach fail to respond to stakeholders’ desire to streamline
and simplify reporting and instead can potentially contribute to a proliferation of reporting
requirements. A few respondents expressed similar concerns regarding the alignment of Sector
Standards with sector-developed guidance and likely future regulatory requirements.

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A few respondents suggested that agreeing to identify a small set of indicators would be a better
approach than the currently suggested format of the Sector Standards.

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On the other hand, a few respondents noted that they considered the topics listed reasonable forreporting on by the oil and gas sector.

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GSSB response: The aim of Sector Standards is to increase the quality and completeness ofreporting by organizations. Sector Standards do this by articulating the topics that are likely to bematerial for most organizations in that sector and the reporting considered relevant for an organizationfrom the sector for each of those topics. These topics and the associated reporting are identified
based on available evidence, authoritative international instruments, and the recommendations of amulti-stakeholder working group. Guidance and frameworks developed by the sector and otherstandards setters are considered in the development of Sector Standards.

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If topics or disclosures are not relevant for an organization, on the basis of its unique
circumstances, the organization is not required to report them.

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207

II. Issues regarding the oil and gas sector specific content of the
exposure draft

208

Cross-cutting issues

209d) List of topics likely to be material to the oil and gas sector

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The majority of respondents confirmed that the exposure draft was representative of the oil and gas
sector’s most significant impacts and considered it useful for identifying topics likely to be material toorganizations in the sector. No clear objections were raised to any topic currently included as likely to
be material, but a few respondents indicated that some topics were not material to some types oforganizations or activities.

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Individual respondents suggested including the following additional topics as likely material:

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•

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MethaneEmissions to sea
Soil pollution
Cyber security and data privacy

Individual respondents also suggested the following modifications to the current list of topics:
•
•

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Merge closure and decommissioning1 with waste because of similar impacts;
Merge employment practices with freedom of association and collective bargaining becauseof overlapping contents.

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GSSB response: Specific recommendations for reporting on methane have been maintained and areference to the Oil and Gas Methane Partnership (OGMP) has been added under the topic GHG
emissions. Impacts from emissions to sea and soil pollution have been further detailed in water andeffluents, and waste.

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The topic of cyber security and data privacy was not considered to rise to the threshold of being likely
material to most organizations in the sector.

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Merging the topics suggested by respondents could have resulted in excluding important elements
described in each topic.

232e) Scope of the Standard

233

A few respondents requested further detail on which organizations GRI 11 applies to.

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GSSB response: The description of the sector the Standard applies to has been revised for clarity. Oiland gas trading activities have also been listed explicitly in the scope.

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In addition, a sector key has been included, mapping the scope of the sector as defined for theStandard to prominent classification systems, i.e., the Global Industry Classification Standard®
(GICS®), the Industry Classification Benchmark (ICB), the International Standard Industrial
Classification (ISIC), and the Sustainable Industry Classification System® (SICS®).

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f)

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Some respondents expressed concern that the exposure draft had a negative bias towards the oil andgas sector. These respondents stated that the exposure draft:
•
•

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Perceived negative bias

Contains negative language; andPrimarily describes negative impacts, with minimal recognition of positive impacts.

GSSB response: In instances that were identified as having the potential to be interpreted as
unnecessarily negative, the wording has been revised. Where appropriate, further descriptions ofpositive impacts have been included, for example in relation to access to energy.

1

The title of this topic has been updated to Closure and rehabilitation in GRI 11: Oil and Gas Sector 2021.

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A Sector Standard outlines the significant impacts of a given sector, these can be negative or positive.
The Sector Standards approach the identification of a sector’s significant impacts in the same way as
defined for all GRI Standards. The way that impacts are managed, including improvements oreffective actions taken to address negative impacts, can be disclosed by the organization as part oftheir reporting.

253g) Impacts on vulnerable groups

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A few respondents remarked that the Sector Standard failed to describe how women and indigenous
peoples are likely to be disproportionately affected by some of the sector’s impacts. Revisions weresuggested across non-discrimination and equal opportunity, local community impacts, land use andresettlement, and rights of indigenous peoples. Respondents suggested the following:

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Describing impacts that affect women more specifically;
Mentioning that some sector activities and working arrangements can exacerbate pre-existing
gender disparities;
Including specific reporting regarding the equitable and safe participation of women in project
consultation and decision-making processes.

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GSSB response: Non-discrimination and equal opportunity, local communities, land and resourcerights, and rights of indigenous peoples have been revised to expand on the sector’s impacts on
women and indigenous peoples, including in relation to existing gender disparities. The additional
sector recommendations for the topics of local communities, land and resource rights, and rights ofindigenous peoples have been revised to include explicit reporting on how organizations seek toensure safe and equitable participation of vulnerable groups in stakeholder engagement processes.

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Oil and gas likely material topic-specific issues

270h) GHG emissions

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In addition to suggesting methane emissions should be a standalone topic, a few respondentssuggested discussing methane emissions in more detail. The following revisions to the reporting of
methane emissions were also suggested:

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Further disaggregation of methane emissions by net equity base, absolute emissions, andintensity ratio, while applying adequate global warming potential (GWP20) for this greenhousegas (GHG);
Adding guidance for reporting methane emissions for service providers;
Aligning methane emissions measurement on the Oil and Gas Methane Partnership’s newmethane reporting framework (OGMP 2.0) to enable more credible estimates of methane
emissions for the sector.

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A few respondents suggested detailing energy efficiency and energy saving measures as part of abroader discussion describing GHG emissions reductions. These respondents also suggested thatorganizations be asked to provide more disaggregated information on sources of flaring and venting,namely whether it is by organizations or service providers, and the type of intervention it resulted
from, for example, preventive actions versus corrective actions.

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Some respondents recommended that the Sector Standard clearly acknowledge that other indirect(Scope 3) GHG emissions (scope 3 emissions) result from consumer use and are not within an
organization’s direct responsibility or control. These respondents suggested to further emphasize thatgenerating or tackling scope 3 emissions involve all organizations throughout the value chain as wellas customers (e.g., organizations involved in transportation, plastics, utilities, agriculture).

291

A few respondents suggested the following revisions to reporting on scope 3 emissions:

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•
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Further disaggregation of emissions per segment of the business, operational control(operators versus service providers), or category of scope 3 emissions;
Further guidance on the process for calculating, coordinating, and resolving overlaps between
value chain organizations for reporting scope 3 emissions.

A few respondents also disagreed with the inclusion of reporting on scope 3 emissions because it
would risk producing inaccurate data on the basis of assumptions and inconsistencies between
reporting organizations.

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GSSB response: Specific recommendations for reporting on methane have been included under the
topic of GHG emissions. A reference to the Oil and Gas Methane Partnership (OGMP 2.0) has also
been included in the resources for this topic. Further details on energy efficiency have been included.

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The disclosures on direct (scope 1) GHG emissions and energy indirect (scope 2) GHG emissions aswell as for emissions related to flaring and venting have been retained. Organizations can provide
contextual information on operations, business partners or entities flaring and/or venting using
Disclosure 3-3 Management of material topics in GRI 3: Material Topics 2021.

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311

No additional recommendations have been added to report GHG emissions on an equity or
operational control basis. Organizations can clarify on which basis they are reporting using thedisclosures included under this topic, based on the guidance outlined in GRI 305: Emissions 2016.
GRI 11 describes business relationships of particular relevance to assessing the impacts oforganizations in the oil and gas sector, such as joint ventures, for additional consideration by reportingorganizations.

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318

Reporting on scope 3 emissions has been maintained as it is considered that this information isessential for organizations in the oil and gas sector to report. Scope 3 emissions from the oil and gas
sector represent a large majority of GHG emissions attributable to oil and gas but no further
disaggregation on reporting scope 3 emissions has been added. Disclosure 305-3 Other indirect(Scope 3) GHG emissions requires organizations to report all or specific categories of scope 3
emissions. This disclosure also contains guidance and links to resources for reporting thisinformation, in addition to the resources listed in the Sector Standard.

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Reporting GHG emissions reduction efforts has been strengthened and moved to Topic 11.2 Climate
adaptation, resilience, and transition. GHG emissions reduction efforts are of specific relevance totransition efforts so grouping this reporting under this topic is considered to reflect establishedreporting practice.

323

i)

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This topic received comments from the majority of respondents. A few respondents expressed
concern that the description included negative language or disproportionally focused on risks rather
than opportunities related to climate change.

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328

Individual respondents suggested changes to enhance the completeness and accuracy of the topic
description, including:

Climate resilience and transition2

•

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335

•
•

Removing or reframing the mention of carbon budgets for organizations, which were seen as
highly subjective measures and of little use for reporting.
Stating clearly that a phase-out of fossil fuel energy production is needed without carbon
capture and storage, as raised in authoritative references from e.g. the United Nations
Environment Programme and the Intergovernmental Panel on Climate Change.
Emphasizing the risks related to advocacy by organizations or membership organizations that
undermine climate science.

336
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338

A few respondents considered the ‘what to report’ sub-section hard to follow. One respondent foundthat the listed disclosures did not enable understanding of an organization’s business modeland viability under various climate-constrained scenarios.

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One respondent suggested clarifying the implications of reporting on just transition for organizations,arguing it is a concept intended to apply to governments as signatories of the Paris Agreement3.

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A few respondents provided suggestions aimed at clarifying additional sector recommendations linked
to Disclosure 201-2 Financial implications and other risks and opportunities, including:
•

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345

Requesting information on the carbon pricing assumptions used (e.g., internal shadow pricing
or other prices used, whether they have been applied to all emission scopes, different
scenarios, and the corresponding analysis of business impacts);

2

The title of this topic has been updated to Climate resilience, adaptation, and transition in GRI 11: Oil and Gas
Sector 2021.
3
United Nations Framework Convention on Climate Change (UNFCCC), Paris Agreement, 2015.

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351
352
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354

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Requesting information on investment and revenue related to low-carbon technology, beyond
just renewable energy, to better demonstrate portfolio diversification and progress towards
GHG emission reduction targets;
Requesting information on the level of planned investment tied to petrochemicalplastic feedstocks to demonstrate decisions to invest in activities with high climate and otherenvironmental impacts;
Including a description of an organization’s efforts to promote research and development oftechnology that contributes to more sustainable business models (e.g., through innovation
partnerships).

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357

A few respondents supported the inclusion of disclosures related to public advocacy and suggested
clarifying reporting related to discrepancies between organization’s stated positions and their policies
on the same topic.

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360

A few respondents disagreed with the inclusion of additional sector recommendations for reporting on
projections related to production volumes, energy produced from renewables, and investments inrenewables and reserves. They raised the following concerns:

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369

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•
•

Reporting on this risks producing inaccurate information, given the variables for determining
such projections (e.g., oil price and demand, regulatory context, project approvals and costs,
available technology);
Providing this information could lead to inaccurate assumptions about the organization andundermine comparison within the sector;
Requesting this information is inappropriate given its possible confidential nature and could
represent a breach to European competition law;
Reporting oil and gas volumes for the reporting year, and projections for the next five years, isredundant as it is already disclosed in financial reporting.

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373
374
375
376
377

A few respondents disagreed with the inclusion of the additional sector recommendation on budget
allocation or on the formulation of this recommendation. Those opposing its inclusion considered it
unrealistic, too detailed, or confidential when related to decisions on mergers and acquisitions. Other
respondents suggested replacing it with a broader recommendation on how climate-related risk isembedded in business strategy and in internal decision-making and oversight.

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381

GSSB response: The decline in oil and gas demand has been further expanded on in Topic 11.2
Climate adaption, resilience, and transition with references to the International Energy Agency’s (IEA)‘Stated Policies Scenarios’ and ‘Net Zero by 2050’ report added. Opportunities for positive
contributions to the transition to a low-carbon economy have been further described.

382
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384
385
386
387
388
389
390

Most of the proposed additional sector recommendations have been maintained, as they are
considered to be of key relevance for reporting on this topic. Those that have been revised include theadditional sector recommendation on just transition, which now requests organizations report policies,
commitments, and actions to mitigate impacts of transition to a low-carbon economy. Similarly, therecommendation on budget allocation and oversight processes to enable effective actions to manage
the impacts has been removed to avoid duplication with the requirements of Disclosure 3-3
Management of material topics. The recommendation on decisions not to invest in new oil and gas
developments and project divestments has been replaced by a recommendation to report on CapEx
allocation.

391
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393
394
395
396

Some recommendations, linked to Disclosure 201-2 Financial implications and other risks andopportunities, have been grouped to clarify how to report impacts on operations or revenue andCapEx allocation. An additional sector recommendation to report on climate change-related scenarios
used to assess the resilience of the organization’s strategy, including a 2°c -or-lower scenario has
been added and aligned with the TCFD Recommendations. Content on scenarios has also been
added to the description.

397
398
399

Reporting on forward-looking information has been maintained. Despite possible challenges, thisinformation is considered crucial to understanding an organization’s resilience to climate-change
related risks. Resources have been added in the bibliography to assist this type of reporting.

A few respondents suggested the topic of climate resilience and transition should be mandatory toreport on by all organizations in the sector.

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401
402
403

Disclosure 305-5 Other indirect (Scope 3) emissions has been placed under Topic 11.2 Climate
adaptation, resilience, and transition, along with the recommendations related to goals and targets for
reducing GHG emissions. This grouping is considered more logical and reflective of establishednormative reporting practice.

404
405
406

No further edits have been undertaken regarding end-of-life emissions of plastic feedstocks. Specifictopics that fall outside of the scope of the Standard will be catalogued and considered as part of therelevant Sector Standard project.

407
408
409

In cases where information is subject to confidential constraints, an organization may provide therelevant reason for omission. Requirement 6 in GRI 1: Foundation 2021 contains more information onreasons for omission.

410

j)

411
412

A few respondents suggested including the biodiversity mitigation hierarchy in the description of the
topic.

413
414
415

A few respondents suggested aligning the additional sector recommendations with existing oil andgas reporting tools for more clarity and to enhance reporting consistency. These respondents
recommended the following:

416
417
418
419
420
421

Biodiversity•

Adding an additional sector recommendation linked to Disclosure 304-1 Operational sites
owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity
value outside protected areas, which asks organizations to report whether they have acommitment to ‘no-go’ zones and what areas this commitment covers;
Clarifying the overlap between Disclosure 304-3 Habitats protected or restored and themitigation hierarchy, as well as what ‘additional conservation actions’ refers to.

422
423
424

GSSB response: An additional sector recommendation on commitments to no net loss or a net gain tobiodiversity on operational sites (as well as what areas and operations they cover) has been added
and linked to Disclosure 3-3 Management of material topics.

425
426
427
428
429

An overview of the mitigation hierarchy has been added to the description of the topic. The additional
sector recommendation presented with Disclosure 304-3 Habitats protected or restored has beenadjusted to provide linkage a between reporting the protected or restored areas and the relevantmeasures of the mitigation hierarchy. The additional sector recommendation refers to avoidance
rather than no-go zones for better alignment with the mitigation hierarchy.

430k) Waste431

A few respondents suggested revisions to the topic including:

432
433
434
435
436
437
438
439

•
•
•
•

Avoiding the use of the term ‘toxic’ to qualify types of waste and instead refer to ‘hazardous’and ‘non-hazardous’ waste;
Clarifying whether produced water and flowback from fracking should be reported under this
topic or under the topic of water and effluents;
Emphasizing that tailings are a significant liability which justifies the need for aggressive
treatment and reclamation activities;
Emphasizing the importance of management measures for discharge, treatment andcircularity opportunities.

440
441

One respondent suggested that oil and gas organizations involved in the plastics value chain shouldbe held accountable for impacts linked to end-of-life emissions of plastic feedstocks.

442
443
444

A few respondents disagreed with the inclusion of the additional sector recommendations for reporting
information on waste composition or they found it too extensive. These respondents suggested a
breakdown be requested only when a waste stream is significant.

445
446

GSSB response: The description has been revised to include management measures such as reuseor recycling measures and their role in avoiding or minimizing impacts related to waste.

447‘Toxic waste’ has been replaced by ‘hazardous waste’, which is also defined in the GRI Glossary.

448
449

Produced water has been moved to Topic 11.6 Water and effluents. This configuration is more closelyaligned with the inclusion of produced water in GRI 303 Water and Effluents 2018.

Page 12 of 19

450
451
452
453

The additional sector recommendation to provide a breakdown on the composition of waste has beenrevised to support reporting on waste streams that are significant for different organizations and, forconsistency, has been included for all relevant disclosures: Disclosure 306-3 Waste generated,
Disclosure 306-4 Waste diverted from disposal, Disclosure 306-5 Waste directed to disposal.

454
455

Impacts related to tailings have been further detailed in this topic as well as in Topic 11.8 Asset
integrity and critical incident management.

456
457
458

No further edits have been made regarding end-of-life emissions of plastic feedstocks. Reporting on
scope 3 GHG emissions is already included in Topic 11.1 GHG emissions. Relevant comments
regarding plastics will be catalogued and considered as part of the relevant Sector Standard project.

459

l)

460
461
462
463

A few respondents suggested clarifying that produced water should be considered and reported under
this topic rather than the topic of waste. It was also raised that produced water was not the only typeof wastewater that may be relevant to report on, for example while oil sands mining does not involve
produced water, it does discharge process-affected water.

464
465
466
467
468
469

A few respondents suggested including the option to report separately on produced water andmethods of calculating water discharge. This was considered useful for highlighting the efforts oforganizations in pursuing environmentally sound practices and for supporting the organization’s
decision-making process towards environmental stewardship. One respondent suggested clarifying
how to report hydrocarbon discharged within produced water as included in the additional sector
recommendation presented with Disclosure 303-4 Water discharge.

470
471

A few respondents suggested describing best practices, such as water efficiency andother management options for water rather than focusing on negative impacts.

472

GSSB response:

473
474
475

The management of produced water and other process wastewaters has been described in moredetailed in the topic, including references to reusing, recycling, discharge and treatment ofwastewater.

476
477

The additional sector recommendations to report on the volume of produced water discharged
separately have been maintained and expanded to include other process wastewater.

478
479
480
481
482
483
484

A recommendation to report the concentration of hydrocarbons in the produced water and processwastewater discharged has been added. While no specific guidance has been included anorganization can provide any contextual information necessary to understand how the data has been
compiled, as per Disclosure 303-4 Water discharge. In addition, Disclosures 303-1 Interactions withwater as a shared resource, and 303-2 Management of water discharge-related impacts, offer theopportunity to describe the organization’s interactions with water, impacts, how those impacts are
addressed, associated goals and targets, and the management of effluents.

485m) Closure and decommissioning

486
487
488

A few respondents suggested outlining the circularity measures organizations may use during thisphase, namely, the practice of recycling materials from dismantled structures or repurposing disused
structures.

489
490
491
492
493

A few respondents suggested describing practices organizations may use to save costs associatedwith closure and rehabilitation, for example, the practice of offloading, where organizations sell nearly
depleted assets to smaller and sometimes less solvent organizations. Respondents argued that thiswas a growing trend and may constitute a strategy from organizations to avoid costs associated withclosure and rehabilitation and poses liability issues for many jurisdictions.

494
495
496
497
498

Other respondents suggested to specify that international conventions require organizations todecommission and remove offshore structures and that leaving them in place also leaves in placematerials, such as plastics, chemicals and metals that are potentially harmful to marine ecosystems
and species. As such, it was suggested that in cases where organizations leave structures in place, arationale and justification for this decision should be reported.

499
500

GSSB response: A reference to the possibility for extending the life of disused assets have been
included. Offshore decommissioning requirements of international conventions have also been

Water and effluents

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501
502
503

highlighted, as has details on the complexity associated with decommissioning offshore structures.
Further research on the practice of offloading was inconclusive and it has therefore not described in
the topic.

504
505

Reporting on the plans and financial provisions for closing the fields and facilities owned by anorganization has revised and re-organized for ease of understanding and more coherent reporting.

506n) Asset integrity and process safety4

507
508
509
510

One respondent suggested including an option to report on quality assurance and maintenance. This
respondent argued this would balance the reporting which was focused on emergency preparedness
and response and seemed to exaggerate the value of responding to critical incidents over the value of
preventing them.

511
512
513
514

GSSB response: Content on effective process safety management systems has been added toreinforce its importance for asset integrity and preventing critical incidents. Information on process
safety management can be disclosed using Disclosure 3-3 Management of material topics so has notbeen added as an additional sector recommendation or disclosure.

515
516
517

An extended explanation of the potential impacts of oil sand tailings related to waste, asset integrity,and critical incidents has been added to the topic and an additional sector disclosure for organizations
with oil sands mining operations has been included.

518o) Occupational health and safety

519
520
521
522
523
524
525

A few respondents suggested including a disclosure on the number of workers who worked more than
168 hours over a two-week period (i.e., 12 hour shifts over 14 days). These respondents raised thepoint that workers on oil and gas platforms and supply vessels routinely work under this arrangement
but must subsequently be given a substantial rest period. These respondents also suggested
including a disclosure on whether organizations have any workers on vessels in their supply chains
who have been working for longer than nine months, as this is the maximum length a worker can beat sea according to the Maritime Labour Convention.

526
527
528
529

GSSB response: The topic has been revised to include a reference to the risk of insufficient rest time
for workers, and to highlight that remaining at sea for excessive periods of time can result in fatigue
and impact physical, psychological, and social health. The Maritime Labour Convention has also been
listed in the bibliography.

530p) Diversity and non-discrimination5

531
532

A few respondents raised the concern that the barriers to women working in the sector were notsufficiently covered, including the impact of inadequate parental leave.

533
534
535
536

GSSB response: The topic has been revised to more explicitly describe the barriers for women andcaregivers to working in the sector, including limited parental leave arrangements. Additionally,
Disclosure 401-3 Parental leave from GRI 401: Employment 2016 has been included as a relevant
disclosure.

537
538

Content on the role of training to address discriminatory practices has been included. This can bereported using Disclosure 3-3 Management of material topics.

539q) Economic impacts

540
541
542

Some respondents found that the role of procurement, both in relation to benefits generated andchallenges for local suppliers, was not sufficiently covered in this topic. They suggested revisingcontent and disclosures to explicitly refer to procurement.

543
544
545

A few respondents suggested clarifying that training can benefit local workers. It was also suggested
that reporting on training be included in order to indicate that organizations in the sector are expected
to provide local workers with training.

4

The title of this topic has been updated to Asset integrity and critical incident management in GRI 11: Oil and
Gas Sector 2021.
5

The title of this topic has been updated to Non-discrimination and equal opportunity in GRI 11: Oil and Gas
Sector 2021.

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546
547
548
549

GSSB response: The topic description has been revised to expand on impacts from the sector related
to local procurement. The additional sector recommendations have been revised to explicitly coverprocurement and training in local communities, as well as to avoid duplication of disclosures alreadycovered in existing Topic Standards.

550

r)

551
552
553

One respondent raised the concern that the role of effective grievance mechanisms was not clearly
covered in this topic and suggested making explicit reference to grievance mechanisms in thedisclosures.

554
555

One respondent suggested adding a disclosure on agreements reached with local communities,
including confirmation of the communities’ consent.

556
557
558

GSSB response: The topic has been revised to specify the role of effective grievance mechanisms
and other remediation processes in addressing community impacts. The additional sector disclosure
has been revised to focus on the effectiveness of grievance mechanisms.

559
560
561
562
563

The role of processes to reach agreements with local communities has been addressed through theaddition of an additional sector recommendation requesting information on how the organization
seeks to ensure meaningful engagement and safe and equitable gender participation. A similar
recommendation has also been included in Topic 11.16 Land use and resource rights, as well as
Topic 11.17 Rights of indigenous peoples.

564s) Rights of indigenous peoples

565
566
567

One respondent suggested including a disclosure on the mutually accepted process between theorganization and affected indigenous communities for obtaining free, prior, and informed consent andpublic documentation of agreements reached under such processes.

568
569
570

GSSB response: The additional sector disclosure has been revised to explicitly cover whether any
processes in which the organization has been involved for seeking free, prior, and informed consent
are mutually accepted.

571
572
573
574
575

As outlined in the ‘cross-cutting issues’ section, this topic has been revised to further describe thesector’s impacts on indigenous peoples, including consideration of gender disparity. The additional
sector recommendations for this topic have been revised to more clearly request reporting on howorganizations seek to ensure safe and equitable participation of indigenous peoples and, including
indigenous women in stakeholder engagement processes.

576

t)

577
578
579
580
581
582

A few respondents raised concerns that the disclosures for this topic were limited and would not elicit
information on the relationship of the organization with private and public security providers, or
relevant risk management approaches, for example, due diligence, memorandum of understanding
procedures, implementation of security management systems, or how companies influence theimplementation of good practices among security forces. They also suggested aligning the content
with the Voluntary Principles on Security and Human Rights.

583
584
585
586
587

GSSB response: The topic has been revised to clarify the role of risk assessments in avoiding or
managing impacts related to conflict and security and the interaction with security providers. An
additional sector recommendation on how the organization works with security providers has been
included and the Voluntary Principles on Security and Human Rights and other relevant resources
have been listed in in the bibliography.

588u) Anti-corruption

589
590

A few respondents suggested including details and reporting on corruption risks related to
procurement through local content arrangements, transfer pricing activities, and shell companies.

591
592
593

One respondent suggested clarifying that organizations are not always just exposed to corruption, but
can be actively involved. This respondent argued that several examples of active involvement were
demonstrated by documented cases where organizations have been found guilty of corruption. One

6

Local community impacts6

Conflict and security

The title of this topic has been updated to Local communities in GRI 11: Oil and Gas Sector 2021.

Page 15 of 19

594
595

respondent also suggested to clarify that corruption occurs equally in developed and developing
countries.

596
597
598
599
600

One respondent suggested that a disclosure regarding whistleblowing mechanisms appeared to belacking. While one respondent disagreed with the inclusion of a disclosure on beneficial owners andconsidered it unreasonable as it is beyond an organization’s control. This respondent also argued thatmaking this information available should be a matter of law governing the stock markets on whichorganizations are listed rather than a matter for voluntary reporting.

601
602
603

GSSB response: The topic has been adjusted to refer more equally to the potential for corruption to
occur in developed and developing countries. Corruption risks and schemes related to procurement
have also been described on the basis of documented cases.

604
605
606
607
608

An additional sector recommendation to report on the approach of the organization to avoiding
corruption in procurement processes has been added. Another additional sector recommendation
regarding whistleblowing mechanisms has also been added as it is considered a common reporting
expectation for this sector in relation to this topic. These are expansions of the reporting alreadyrequired under Disclosure 3-3 Management of material topics.

609
610
611
612
613

The additional sector disclosures on whether contracts and licenses and beneficial owners have been
maintained. However, the additional sector recommendation to report the stock exchanges whereorganizations have made filings that include beneficial ownership information and a link to thosefilings has been removed. A more precise reference to the relevant EITI Requirements7 has been
included in place of these additional disclosures.

614v) Payments to governments

615
616
617
618
619

One respondent suggested emphasizing the proven prevalence of corporate tax avoidance andevasion within this sector as a key source of impacts. Another respondent recommended
emphasizing that country-level and project-level payment information are not interchangeable, andboth are needed for disclosures to be maximally useful and to enable further transparency inresource-rich countries.

620
621

A few respondents provided comments on the additional disclosure based on EITI requirement 4.2(c),including the following:
•

622
623
624
625
626

•

The EITI requirement encourages but does not require supporting organizations to reportoil and gas purchases from states;
Reporting this information is not normative for the sector nor an appropriate request given
the commercial confidentiality that could be involved, or that this information could be
subject to competition law.

627
628
629

One respondent suggested that reporting Disclosure 207-4 Country-by-country reporting should be
mandatory while another respondent suggested replacing this disclosure with EITI requirements toreport payments to governments for upstream oil and gas operations.

630
631

GSSB response: Tax avoidance and the rational for country-level and project-level information havebeen given additional emphasis in the topic.

632
633
634
635

The additional sector disclosure for state-owned enterprises (SOEs) has been maintained and aclearer reference to the relevant EITI Requirement included. Transparency challenges for SOEs havebeen confirmed as being of key relevance and a clear reporting expectation for organizations in the
sector reporting on this topic.

636
637
638

An additional sector recommendation for reporting payments to governments by project, based on
EITI Requirements has been added. This takes into account the reporting required by Disclosure 2074 Country-by-country reporting and references payments made to governments at the project level

7

These additional sector disclosures are based on Requirement 2.4.Contracts and Requirement 2.5.
Beneficial ownership c,. d., and f. in the EITI Standard 2019. Extractives Industries Transparency
Initiative (EITI), The EITI Standard, 2019.

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639
640

only. This type of reporting is widespread for this sector as a result of the EITI Standard 2019 and a
related European Union directive.

641

Page 17 of 19

642

Appendix 1. Participation in regional

643

events and webinars
Event

Date

Number of attendees

GRI live webinar and Q&A

23 July

188

GRI live webinar and Q&A

23 July158

GRI Community Universal
Standards & Sector webinar

18 August80

GRI live webinar and Q&A

20 August156

GRI live webinar and Q&A

20 August313

Business consultation sessionin collaboration with IPIECA

3 September

27

15 September

13

17 September

32

22 September

12

23 September

29

Investor consultation session incollaboration with FTSE
Russell
Regional workshop Latin
America
Regional workshop Africa
Civil society consultation
session in collaboration with
Publish What You Pay
Total participants

1008

Page 18 of 19

644

Appendix 2. Public comment

645

submissions by stakeholder

646

constituency and region

647
648
649

A total of 60 submissions from individuals and organizations was received on the exposure draft ofSector Standard: Oil and Gas. The names of these individuals and organizations are listed in the tableof comments, p.1 (note: zooming in may be required).
The charts break down submissions by stakeholder constituency and region. All constituencies wererepresented, with business and mediating institutions being the most represented. Submissions camefrom 25 countries, predominantly in North America, Europe, and Asia.

650

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