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GRI 12: Coal Sector 2022
Frequently Asked Questions (FAQs)

GRI 12: Coal Sector 2022 is a reporting Standard directed at organizations with activities in the coalsector. Sector Standards have been introduced to the GRI Standards as part of the revised Universal
Standards 2021.
FAQs on the the Universal Standards 2021, the updated system of GRI Standards, and how to use
Sector Standards are available here.

© GRI 2022

ContentsGRI 12: Coal Sector 2022 ........................................................................................................ 1
Frequently Asked Questions (FAQs) .................................................................................................. 1
What was the process to develop GRI 12? ..................................................................................... 3
If I am still using the Universal Standards 2016, am I required to use GRI 12? .............................. 3
When will GRI 12 come into effect? ................................................................................................. 3
To what organizations does GRI 12 apply? ..................................................................................... 3
As a coal organization, do I need to use any GRI Standards other than GRI 12? .......................... 4
Why did GRI develop a Standard for coal? ..................................................................................... 5
Does GRI 12 align with other relevant instruments and guidance for the Coal sector? .................. 5
What’s the difference between GRI 12 and SASB’s Coal Operations Industry Standard? ............. 6
What is meant by just transition and why do coal companies need to report on that? ................... 7
Why does GRI 12 include reporting on Scope 3 emissions even though the use of coal is often byother sectors? .................................................................................................................................. 7
Why should coal companies report on assets that they have divested from?................................. 7
Why are there public policy and lobbying disclosures outside of the likely material topic 12.22
Public policy? ................................................................................................................................... 8
Is GRI 12 available in other languages? .......................................................................................... 8

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What was the process to develop GRI 12?
The development process of GRI 12: Coal Sector 2022 was overseen by the Global Sustainability
Standards Board (GSSB), GRI’s independent standard setting body, following the Due Process
Protocol.
The Standard was developed in the public interest through a transparent and inclusive process. A
multi-stakeholder working group developed the content with expertise in the coal sector, with regard
to authoritative intergovernmental instruments and widely held expectations of organizations relating
to social, environmental, and economic responsibilities.
Between May and July 2021, an exposure draft of the Standard was made available for publiccomment. Around 30 submissions were received from organizations across business, investment
institutions, civil society, labor, and mediating institutions. For more information about thedevelopment process of GRI 12, please visit the project page.

If I am still using the Universal Standards 2016, am I required to use
GRI 12?
The GRI Sector Standards are an addition to the updated system of GRI Standards. This means thatthe requirement to use the Sector Standards is only included in the Universal Standards 2021
(released in 2021). Reporters using Universal Standards 2016 are not required to use GRI 12,
however it may be useful for the organization when determing its material topics and what to report on
those topics
An organization reporting in accordance with the GRI Standards is required to list in the GRI content
index all the disclosures it has reported. In the case the organization does report additional sector
disclosures from GRI 12, these are to be listed in the GRI content index.

When will GRI 12 come into effect?
The effective date for GRI 12: Coal Sector 2022 is 1 January 2024, which means its usage is requiredby coal companies from that date onwards. This effective date allows sufficient time for coalorganizations to incorporate GRI 12 into their materiality considerations and start collecting data forany topics and/or disclosures they may not be reporting on yet.

To what organizations does GRI 12 apply?
GRI 12: Coal Sector 2022 applies to organizations involved in exploration, mining, and processing ofthermal and metallurgical coal. It also includes organizations that supply equipment and services tocoal mines as well as transportation and storage of coal.
Different Standards will cover related sectors, such as manufacturing of steel and cement, and energy
utilities.

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The full description of the scope of the sector covered by this Standard can be found on page 5 of
GRI 12.

As a coal organization, do I need to use any GRI Standards otherthan GRI 12?
The GRI Standards are structured as a system of interrelated standards organized into three series:
GRI Universal Standards, GRI Sector Standards, and GRI Topic Standards.
A coal organization reporting in accordance with the GRI Standards will use all three series in theirreporting.
The Universal Standards 2021 apply to all organizations and comprise three Standards: GRI 1:
Foundation 2021, GRI 2: General Disclosures 2021, and GRI 3: Material Topics 2021. The Universal
Standards guide reporters on how to report with the GRI Standards, and contain disclosure
requirements and reporting principles that all organizations must comply with to report in accordancewith the GRI Standards.
GRI 12: Coal Sector 2022 outlines the topics that are likely to be material for coal organizations andlists disclosures relevant to these topics. The disclosures come from the GRI Topic Standards, andcan be supplemented with additional disclosures from other sources.
When a disclosure from a Topic Standard is listed, the organization needs to consult the relevant
Topic Standard for the content of the disclosure, including requirements, recommendations, andguidance.
Diversified mining companies with coal in their portfolios are expected to use two Sector Standards todetermine their material topics and reporting disclosures, GRI 12 and the Sector Standard for mining(expected to be released in 2023).

Why was coal separated from oil and gas when initially they werepart of the same project?
In 2019, a multi-stakeholder working group was established to develop a Sector Standard for oil, gas,and coal, as they share key characteristics as producers of energy. These commodities were also
found to have shared impacts on sustainable development on areas such as climate change,
communities, financial transparency, and the environment.
The Global Sustainability Standards Board (GSSB) received a number of stakeholder submissions
from the oil and gas sector raising concerns about addressing oil, gas, and coal in one GRI Sector
Standard. The majority of working group members and input collected through external engagements
confirmed that due to differences in sources of impact, low-carbon transition paths, and organizations
undertaking the activities, addressing oil and gas, and coal in separate Standards would befavorable .
Therefore, the GSSB decided to separate the coal contents from the oil and gas contents. A separate
Sector Standard for oil and gas, GRI 11: Oil and Gas Sector 2021, was launched in 2021.

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Why did GRI develop a Standard for coal?
Even in the most ambitious scenario as forecasted by the International Energy Agency (IEA) – aiming
for net zero by 2050 – coal will still be mined well until the 2040s. The largest producers, including
India and China, have made public ambitions to reach net-zero only by 2060s or 2070s and the use ofcoal in power and electricity production is expected to continue to steadily fall. But even so, coal islikely to still be used as a raw material for other industries, such as steel and cement.
Coal mining has significant impacts on the environment and people beyond climate change, and moretransparency and accountability is needed over these impacts. While the transition to a low-carbon
economy will lead to an accelerating pace of coal mine closures, this will have significant impacts on
workers via decreased employment opportunities and diminished income for local communities reliant
on coal. How this transition is managed is a further consideration requiring public scrutiny.
Finally, the Standard also includes forward-looking disclosures on coal organizations’ plans andactions to align their business models with the low-carbon transition, including setting targets to
reduce GHG emissions; closing operations or divesting from assets; and investing in newtechnologies to remove carbon from the atmosphere. This information is essential for governments,
investors, and other stakeholders in order to meaningully engage with coal organizations and makeinformed decisions.

Does GRI 12 align with other relevant instruments and guidance for
the Coal sector?
GRI 12: Coal Sector 2022 describes topics identified as likely material for organizations in the coalsector, based on the sector's significant impacts on the economy, environment, and people. These
impacts have been identified based on available evidence, authoritative international instruments, andexpert and stakeholder input.
This means that authoritative instruments that shape the expectations of the responsible businessconduct of the coal sector also shape the content of GRI 12. For example, expectations related toclimate change have been established by the Paris Agreement; the right to free, prior, and informed
consent recognized in the United Nations Declaration on the Rights of Indigenous Peoples;
expectations on the use and management of security personnel established by the Voluntary
Principles on Security and Human Rights; and reporting on tailings facility integrity is based on the
Global Industry Standard on Tailings Management.
Similarly, this principle extends to transparency related initiatives that are of key relevance to thesector, such as the Task Force on Climate-related Financial Disclosures and the Extractives Industry
Transparency Initiative. Where appropriate, disclosures that do not come from the GRI Topic
Standards are based on these established external instruments and frameworks. In some cases, torelevant external instruments and frameworks are directly referenced for additional guidance.

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What’s the difference between GRI 12 and SASB’s Coal Operations
Industry Standard?
The GRI Standards and SASB Standards are complementary because of the approaches they take tomateriality. The likely material topics listed in GRI 12: Coal Sector 2022 are based on the significant
impacts the coal sector has on the economy, the environment, and people, including their humanrights. SASB’s industry-specific standards identify the sustainability-related risks and opportunities
most likely to affect a company’s financial condition, operating performance, or risk profile.
Because of these different perspectives, GRI 12 identifies different disclosures than SASB’s
corresponding standards. For example, while SASB identifies reporting on direct (Scope 1) GHG
emissions as relevant for coal operations, GRI 12 also lists indirect (Scope 2) and other indirect(Scope 3) GHG emissions as relevant for the reporting by the coal sector.
SASB’s coal standard was a valuable input into the development of GRI 12, and a SASB
representative participated as a member of the working group. Coal organizations can use bothstandards simultaneously to report their sustainability impacts.
GRI and SASB published joint guidance, A Practical Guide to Sustainability Reporting Using GRI and
SASB Standards, which further explores experiences of companies that use the two sets of standards
together to fulfil their reporting needs.

Why is there an emphasis on climate change and low-carbon
transition in GRI 12?
The role of coal in causing climate change is well understood and scientifically proven. Leading
bodies such as the Intergovernmental Panel on Climate Change (IPCC) and International Energy
Agency (IEA) call for a rapid end to coal use to maintain a narrow possibility to halt global warming to
1.5°C.1 Furthermore, close to 200 countries have committed to phase down coal use in power
generation in COP26. The focus on climate change and transition in GRI 12 is considered reflective of
the current environment and critical for reporting organizations and information users.
Transition planning has emerged as an expectation for organizations in GHG emissions-intensive
sectors, including coal. GRI 12 includes an additional sector disclosure to report on the existence of atransition plan and whether it is a scheduled resolution item at Annual General Meetings. Other
disclosures aim to extract information over the resilience of business models, including disclosure
over investments and divestments, reserves, goals and targets to recuce GHG emissions, andscenarios used to assess climate risks and opportunities. Both thermal and metallurgical coalproducers are expected to report information on climate and transition.

1 Intergovernmental Panel on Climate Change (IPCC), Climate Change 2021: The Physical Science Basis, 2021; International

Energy Agency (IEA), Phasing out unabated coal, 2021.

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However, the Standard acknowledges that the low-carbon transition has different timelines in different
parts of the world due to individual dependencies and national circumstances related to the lowcarbon transition – with many developing countries continuing to use coal longer than developed
countries. The Standard allows organizations to disclose information that is considered as the mostessential for their business and stakeholders.

What is meant by just transition and why do coal companies needto report on that?
GRI 12 draws on the definition of the term as used in the Paris Agreement and by the International
Labor Organization (ILO), which aims to consider environmental, social, and economic angles and tofind solutions that benefit workers and communities alike, leaving no one behind. This is seen as ashared responsibility with governments, employers, employees, and communities. Just transition
aspects are integrated into relevant topics in GRI 12, including 12.3 Closure and rehabilitation, 12.8
Economic impacts, and 12.15 Employment practices.

Why does GRI 12 include reporting on Scope 3 emissions eventhough the use of coal is often by other sectors?
GRI 3: Material Topics 2021 clarifies that an organization should consider actual and potential
negative impacts that it causes or contributes to through its activities, as well as those directly linked
to its operations, products, or services by its business relationships.
While customers of coal organizations use much of the coal extracted to produce energy andmaterials, there is also a firmly established stakeholder expectation that organizations extracting andproducing coal take action to reduce emissions from the use of their products and to disclose therelated GHG emissions (Scope 3 GHG emissions).
Scope 3 emissions from the coal sector represent the single largest source of global CO 2 emissions.
Disclosure 305-3 Other indirect (Scope 3) GHG emissions contains guidance on disclosing Scope 3
emissions and links to further resources, as do the resources listed in GRI 12.

Why should coal companies report on assets that they havedivested from?
Organizations divesting their coal assets to reduce the GHG emissions intensity of their productportfolios is an important emerging issue. This practice can be detrimental to broader climate change
mitigation efforts: shifting coal mining operations to another entity does not decrease global
emissions, and can even drive increases. Responsible closure and a just transition can also becompromised if the responsibility of eventual closure is transferred to a less experienced operator.

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Many diversified mining organizations in particular, are divesting away from coal but have an ongoing
responsibility to solve the problem they historically contributors to.2
While the reporting organization does not cause negative impacts that arise from actions of the new
operator, the organization may be considered as contributing or being directly linked to those impacts
with the responsibility to take due diligence steps, including exercising leverage over the buyer toprevent or mitigate the impacts it is causing or contributing to.

Why are there public policy and lobbying disclosures outside of thelikely material topic 12.22 Public policy?
Public policy has been identified as a likely material topic for the coal sector (topic 12.22), which
includes reporting on general public policy and lobbying activities. Topic 12.2 Climate adaptation,
resilience, and transition also incorporates disclosures that deal with public policy advocacy andlobbying, but with a focus on policy development on climate change. In addition, GRI 2 lists
Disclosure 2-28 Membership associations to extract information about an organization’s affiliations
with industry or other associations.
The disclosures included in the two likely material topics in GRI 12 aim to reveal differences between
an organization’s public policy advocacy and its stated policies, goals or other public positions, or
example, when an organization has publicly committed to reducing their GHG emissions aligned witha low-carbon transition while lobbying against more ambitious climate policies. These differences canoccur via an organization’s individual public advocacy initiatives or via the support they provide forother associations, for example, by participating in specific projects or committees (on anorganizational or individual executive level), or by providing funding to the association.
Should a company determine both topics 12.2 and 12.22 as material and report information thatapplies to both topics, this information does not have to be repeated. The organization can report thisinformation once, with a clear explanation of all the topics it covers.

Is GRI 12 available in other languages?
The authoritative text of the GRI Standards is English, but GRI will release authorized translations of
GRI 12: Coal Sector 2022 in key languages at the end of 2022. Please consult the GRI Translations
page or contact translations@globalreporting.org for more information on the upcoming translation
schedule.

2

UN Human Rights, A Safe Climate, 2019.

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