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

Item 03 – Public comments on the use of
Sector Standards collected during theexposure periods for the Universal
Standards and the Oil and Gas Sector
Standard
For GSSB discussion
Date

25 November 2020

Meeting

3 December 2020

Project

GRI Universal Standards Project

Description

This document contains an extract of public comments related to using the Sector
Standards in the system of GRI Standards when reporting on topics that have notbeen identified as material by the organization’s own materiliaty assessment. This
includes feedback on requiring reporting on a selected number of topics based onan organisation’s sector/s (and specified in the applicable Sector Standard/s), andthe provision of explanations on why topics that are likely to be material for theorganization based on their sector/s are not material for the organization (either
because they are included in the applicable Sector Standard or because they arecommonly associated with the sector/s of the organization).
These comments were collected during the public comment periods for the
Universal Standards exposure draft, which was made available for publiccomment between 11 June and 9 September 2020, and the GRI Sector Standard:
Oil and Gas exposure draft, which was made available for public comment
between 8 July and 6 October 2020.
The document presents the comments received via the online surveys and via
letters, for GSSB reference. It does not present an analysis of the feedback – theanalysis will be presented by the Standards Division directly at the meeting.
The GSSB is kindly asked to review the document ahead of the meeting and toshare any questions about the comments or highlight any comments fordiscussion, with the Standards Division by 1 December.
Note to reading the comments:
Comments have been included verbatim. Where a respondent has raised several
distinct points in one comment, each point has been numbered and presented in a
separate row. The point number is indicated in brackets before the verbatim
comment. In addition to this, reference numbers have been included in the firstcolumn to help facilitate the discussion during the meeting on 3 December.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.
© GRI 2020

1

Contents
Public comments ..................................................................................................................................... 3
1. Identify and explain if topics listed in a Sector Standard are not deemed material by theorganization ......................................................................................................................................... 3
2. Identify and explain why topic is not material in the absence of an applicable Sector Standard .. 41
3. Require reporting on selected topics based on the sector of an organization .............................. 64
4. Other comments on the Sector Standards .................................................................................... 77

Page 2 of 79

2

Public comments

4

1. Identify and explain if topics listed in a Sector Standard are not deemedmaterial by the organization

5

The following comments were submitted during the public comment period for the Universal Standards, between 11 June and 9 September 2020.

6
7Survey question: If there are topics listed in a GRI Sector Standard that an organization in that sector does not deem to be material, should the organization
be required to identify these topics and explain why they are not material?

8

Please refer to page 91 in the Universal Standards exposure draft.

9

Table 1. Responses to question 7 in the online survey to the Universal Standards exposure draft

3

No.

Surveyresponse

Name oforganization orindividual

Comment

Country

Stakeholder
group

Submission
type

Yes, this information should be required1

Yes

No comment provided

ABB

Switzerland

No response
provided

No response
provided

2

Yes

As defined and analysed by sector group that all of identified topics
should be material, and is reazonable to explain why that topic is notmaterial. Is similar as reasons for omision concept. Also could betabulated or incluide some examples of answers regarding this.

AG Sustentable

Argentina

Consultant

On behalf ofanorganization,group orinstitution

3

Yes

The organisation needs to explain however briefly why
acknowledged sector items will not be included in the report. GRI
may use the input to then after a period of time, evaluate whether

Aldo Joson

Singapore

Business

As anindividual

Page 3 of 79

those items need to be removed in the list of sector topics that are
required/suggested for disclosure.
4

Yes

The non-materiality explanation is a valuable exercise to stimulate areflection within the company, especially if stakeholder engagement
process is at a starting stage.

Alessandro
Mantini

Italy

Business

As anindividual

5

Yes

Providing an explanation will help show the process the organisation
has gone through and potentially provide additional context to thereader. This can easily be slotted into the Content Index.
It will be interesting to see how mandatory reporting on e.g. Climate
Change, Diversity etc affect materiality assessments and decisions.
These topics are becoming business-as-normal reporting, which
may affect materiality assessments

Alexandra
McKay

UnitedKingdom

Consultant

As anindividual

6

Yes

No comment provided

AlliedEnvironmental
Consultants

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

7

Yes

No comment provided

Ana María
González Ruiz

Colombia

Consultant

As anindividual

8

Yes

Impacts on employee lives and safety. Ive lived the bad casescenario. I expect all issues addressed.

Anna McBee

CanadaLabor
representative

As an
individual9

Yes

If an organisation determines topics to not be material, they should
identify these topics and explain why they are not material rather
than simply omitting them.

AustralianCouncil of Trade
UnionsAustralia

Labor
representative

On behalf ofanorganization,group orinstitution

10

Yes

We present an example for biodiversity as a material topic.
Historically, the business case for nature has not been effectively
integrated into decision-making. Biodiversity impacts are howeveroften difficult to assess and quantify, with a lack of uniform industry

BirdLife
International

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,

Page 4 of 79

datasets, indicators and frameworks, meaning that many companies
are not robustly assessing biodiversity risks and impacts as part oftheir operations (e.g. in preventing the exploitation of biodiversity inareas of global ecological significance). Therefore, biodiversity risks
are often overlooked or not adequately detailed as part of company
reporting.

group orinstitution

Where material risks are likely present for certain industries,
biodiversity should be appropriately addressed and reported on,
with adequate justification for the exclusion of biodiversity related
topics where appropriate. Where reporting does not justify theexclusion of biodiversity reporting to a satisfactory degree, queries
and challenges should be made. We therefore strongly believe thatorganizations should be required to identify these topics and explain
why they are not material.
11

Yes

It would demand that companies improved their materiality
assessments.

BSD
CONSULTING

BrazilNo response
provided

No response
provided

12

Yes

We would agree that it is beneficial for organisations to disclose theoutcome of their process for identifying material non-financial
information, including providing explanation where topics that would
typically be expected to be material for organisations in their sector
have not been deemed material. This would help to support thedecision-usefulness of disclosure for users, and in particularinvestors, by enabling them to compare information between
organisations within the same sector on a consistent, but
appropriately contextualised, basis.

CDSB

UnitedKingdomStandard
setterOn behalf ofanorganization,group orinstitution

13

Yes

Having the explain why these topics are not considered material to
the report, provides context to analysts/investors when they do
sector analysis using GRI Standards.

City
Developments
LimitedSingapore

Business

On behalf ofanorganization,group orinstitution

Page 5 of 79

14

Yes

This follows the “comply or explain” requirements under many stock
exchange guidelines and would enhance comparability andcompleteness.

CLP Holdings
Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

15

Yes

The material topics for sector standards are defined on the basis ofdue process and the deviation from these topics should be required.

Corporate Social
Responsibility
Centre Pakistan

Pakistan

Consultant

On behalf ofanorganization,group orinstitution

16

Yes

We covered this in Comments on the Environmental, Social andGovernance Reporting Guide. Government of Hong Kong.
September 18, 2015. See:
https://www.creativeinvest.com/HongKongESGReporting.pdf

Creative
Investment
Research

UnitedStates

ImpactInvestingInnovator

On behalf ofanorganization,group orinstitution

17

Yes

Introducing a ‘comply or explain’ logic will help drive active reflection
on the relevance of topics listed in GRI Sector Standards and willallow externals insight into why a particular topic was deemed
relevant or not by the organisation thereby enabling externals toengage in dialogue with the organisation around thereasonableness of those decisions.

Danish Institutefor Human
RightsDenmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

18

Yes

The organization should report or explain the reasons of notreporting the information.

Da-Strategy

RussianFederation

Consultant

On behalf ofanorganization,group orinstitution

19

Yes

Companies have the burden of proof in this case. If they conduct arobust and data-driven materiality assessment they will be able todemonstrate why certain topics included in the Standards are notmaterial to them.

Datamaran

UnitedStatesDigitalplatform

On behalf ofanorganization,group orinstitution

Page 6 of 79

20

Yes

Deloitte believes that reporters should be required to report topics
that are listed in a Sector Standard that they do not believe to bematerial within the GRI Content Index and provide an explanation of
why they are not material to the entity in question. We believe this isimportant information for stakeholders to enhance their ability tomake an assessment of the organization’s performance on topics
that are commonly deemed to be relevant to the sector concerned.

Deloitte

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

21

Yes

As described more fully in other comments ["not elsewhere
specified"], the concept of Materiality can be more complicated thanpresented in the exposure draft Universal Standards. Topics may
not be material at the [aggregated] organizational level, but may bematerial at the level of a business unit or a facility. Consider theexample of a facility with 50 production facilities, and two of them
use substantial quantities of water in water-stressed areas. This
could be material in these areas (say, Portugal and Arizona), but not
to the larger organization. The Universal Standards should provide
flexibility for organizations to report on material topics with different
scope boundaries, so long as those scope boundaries are identified
in the report.

Douglas Hileman

UnitedStatesConsultant

As anindividual

22

Yes

No comment provided

Dow Inc

UnitedStatesBusiness

On behalf ofanorganization,group orinstitution

23

Yes

No comment provided

DQS CFS

Germany

No response
provided

No response
provided24

Yes

This is important particularly in the early stages of integrating Sector
disclosures into the GRI system as well as for companies juststarting to report or have limited GRI support in their location. This
exercise will allow companies to reflect on the topics and better
assess their standing towards these topics. For this to be fruitful,
updates are needed to align with global sustainability agendas. The
GRI must consider more inclusive geographical representation to

Dr Aljaohra
Altuwaijri

Saudi
ArabiaAcademic

As anindividual

Page 7 of 79

take into account different perspectives in setting the boundaries of
the topics.
25

Yes

Because it is better to have higher coverage of data for GRI andcompanies can look into it for better feasible use of the GRI
Standards.

DUOPHARMA
BIOTECH
BERHAD

Malaysia

Business

On behalf ofanorganization,group orinstitution

26

Yes

To support comparability across organizations.

ELEVATE

Hong Kong

No response
provided

On behalf ofanorganization,group orinstitution

27

Yes

There needs to be standardisation between reporting by different
companies in the same sector. Currently many companies in theextractive industries in which we work, claim topics to be notmaterial that are in reality, material.

Engineers
Without Borders
CanadaCanadaNo response
provided

No response
provided28

Yes

This information should be required if one topic is not material. We
suggest to better specify that companies have the responsibility toselect the most appropriate disclosures and that they don't have toprovide explanation/ reasons for omission shall one or moresuggested disclosures be not appropriate.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

29

Yes

We believe Report or Explain (in GRI Content Table) is an importantelement in ensuring completeness of material topics which supports
third party assurance

ERM
Certification andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

30

Yes

Ideally companies should disclose it - in reality they can opt not to
do so and the data user should be made aware that this has been
omitted so that it can be reflected in the company’s assessment/
valuation model.

Eszter Vitorino

Netherlands

Investor

As anindividual

Page 8 of 79

31

Yes

Because it's essential information

Ethcial Trade
NorwayNorwayMSI

On behalf ofanorganization,group orinstitution

32

Yes

Because it allows for greater comparability between businesses inthe same sector. This information can also be collated by the GRI to
monitor the effectiveness of their sector standards and form thebasis for any subsequent revision. Similarly, the GRI should monitor
additional material impact disclosures which are not included in theirsector standards.

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

CanadaAcademic

On behalf ofanorganization,group orinstitution

However, we wonder how an organisation in a given sector “deems”
a topic material (or immaterial) and are concerned about
subjectivity. At the very least such evaluation should be thoroughly
explained. Also, sector reporting should not allow any loopholes.
33

Yes

Due to the Digitalization of the Industry, the "term" material isperhaps confusing. I think of Green IT.

FOM Universityof Applied
Sciences

Germany

No response
provided

No response
provided

34

Yes

Logical

Fraser Paterson

UnitedKingdom

No response
provided

As anindividual

35

Yes

To better explain and let information users know how their businesshas little impact on those topics/ how those topics has little impact
on them and to make clear that the topic was not overlooked.
As a reference to future development of sector standard;understanding why companies would consider certain topics notmaterial and look for updates to improve the sector standard.

Fuji Xerox (HongKong) Limited

Hong Kong

No response
provided

No response
provided36

Yes

This information should be required to prevent companies fromsectors with high materiality of certain topics from hiding negative
impacts related to these topics.

Gazprom Neft
PJSC

RussianFederation

No response
provided

No response
provided

Page 9 of 79

37

Yes

Different stakeholders may have other views about what is material;
this allows them to form their own judgement

GIB Asset
Management

UnitedKingdomBusiness

On behalf ofanorganization,group orinstitution

38

Yes

Otherwise it will defeat the purpose of the Sector Standards thatwould have been developed on the basis of materiality for theparticular sector. It will demonstrate due consideration for sectoralmaterial issues. Also, please note the comment under 8 below.

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

39

Yes

Reporting organizations must justify any assumption of nonmateriality. In fact, only stakeholders (including labour) have themoral authority to determine what is material, and what is not.

IndustriALL
Global Union

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution

40

Yes

IOSH believes this will help ensure that the materiality assessment
process is working as intended and reassure stakeholders andreport-users that the topics concerned have been considered andnot overlooked.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution

41

Yes

The GRI Sector Standards largely do not exist yet, but it isunderstood that these will identify the most common and significant
topics in each industry sector. If an organisation in such sector
deems such topics to be not material, they should explain whyrather than simply omit the topic.

International
Trade Union
Confederation

Belgium

Labor
representative

On behalf ofanorganization,group orinstitution

42

Yes

To assure stakeholders that the organization is not overlooking thematerial topics.

Izzaty Khaleda
IsmailMalaysia

Consumers

As anindividual

43

Yes

Reason being that what is deemed material can vary based on
external and internal (the organisation's) perspective. Hence, certain
topics which may be deemed relevant to an organisation industry or

Joshua Rayan
Communications

Malaysia

Sustainability
Report Writer

On behalf ofanorganization,

Page 10 of 79

subsector should be included, irrespective if the organisation deems
it material.

group orinstitution

44

Yes

Provide a threshold so as not to make it difficult for preparers ofreports.

Justina
Callangan

Philippines

Business

As anindividual

45

Yes

It would be unusual that if a material topic for a sector did not apply
to every organisaiton in that sector, therefore the information as towhy it's not should be required.

KPMG

Australia

Consultant

On behalf ofanorganization,group orinstitution

46

Yes

No comment provided

Laurence
Vigneau

UnitedKingdomAcademic

As anindividual

47

Yes

No comment provided

Manuela HuckWettstein

Switzerland

Consultant

As anindividual

48

Yes

Better explain to demonstrate that the organization's leaders reallydid gone through a thoughtful process to decide the omission.

Marcus Chau

Hong kong

Consultant

As anindividual

49

Yes

Otherwise might be too easy to avoid tough topics

Marjolein
BaghuisNetherlands

Consultant

As anindividual

50

Yes

I think either a report or explain approach should be used. this will
give clarity and completeness to the report.

Nazish Shekha

PakistanNongovernmentorganization

As anindividual

51

Yes

It is very valuable to increase the consistency of reporting within the
sector and allow comparison of organisations within the sector.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

52

Yes

Yes, this information should be required to address ESG investor
disclosure information requests and as a general matter of
disclosure and performance reporting; and as a matter of historical

Next Level
Sustainability

Australia

GRI Certified
Training

On behalf ofanorganization,

Page 11 of 79

record on performance. More detailed reporting should be required
if the topic was a major news item covered by the media in the last
five years (eg scandal or accident).

Partner inAustralia

group orinstitution

53

Yes

If we do not do so, we can think it is practical for an organization to
overlook one topic. Or just to forget it if they are in a hurry.
Adressing extensively all material sector topics one by one avoids
confusion.

Not applicableFranceNo response
provided

As anindividual

54

Yes

Not every business is the same, some sector criteria may bestrongly linked to specific Market or cliente segments and if theorganization does not serve those, a certain topic may not be
relevant. For example, a specific bank may only lend to small
companies and private persons and not to large or multinational
companies. As a result, this bank may not be implied in several
large scale risks. Or a company may operate in a country wherecertain human rights risks are imaterial, based on living standards,
or national legislation. Even the best list of materially relevant topics
cannot capture the real life variety unless it is so comprehensive
and finegrainded that it is unworkable. Keep thinking about what
every requirement means for a repórter, since most of the people
involved in standard setting have no skin in the game in setting upreporting processes, data collection and transforming that into
reports.

Olaf Brugman

BrazilStandard
setterAs anindividual

55

Yes

Since organizations are required to use GRI Sector Standards (GRI
101 A-3-b, lines 268-269), disclosures on how Sector Standards areused in determining material topics should be commensurate withthe requirements of using Sector Standards. When Sector
Standards are used in determining an organization's material topics,
a significant part of the organization's own process for identifying
material topics is determining which topics in the Sector Standards
are not material, and hence the disclosures on these decisions
should be required. Otherwise, there is no way for readers tounderstand the outcomes of using Sector Standards.

Paia Consulting

SingaporeConsultant

On behalf ofanorganization,group orinstitution

We would also like GRI to clarify if an explanation is required forPage 12 of 79

each topic or can one explanation be provided for all topics that are
not deemed as material? The latter will help reduce reporting
burden.
56

Yes

Yes, the organization should explain why the topics in the Sector
Standard are not applicable as an investor will be looking forcomparable information within a sector and should be given a
reason as to why the information is not present.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

57

Yes

We recommend requiring an explanation of why a topic is notconsidered material for an entity in a particular sector, but limiting
the requirement to those cases where a topic is excluded that would
reasonably be expected by a user to be included (i.e. where it is not
obvious why it would be excluded).
We believe that a ‘disclose’ or ‘explain’ approach will put additional
focus on the determining appropriate metrics and therefore lead toincreased quality of reporting and improved ability to obtain external
assurance on the information.
In addition to the common material topics for an industry, the Sector
standards also include a list of appropriate disclosures to report on
those topics. Therefore, it might be considered to include at least a
recommendation in GRI 103 to also explain if an organization does
not consider a specific disclosure indicated in the Sector Standard
as appropriate.

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

58

Yes

It is important for stakeholders to know that the company has
considered these topics even if they are not material to them.

R&A Strategic
Communications

South
AfricaNo response
provided

No response
provided59

Yes

If not, the sector standards would lose their usefulness.

SAI Global Italias.r.l.

Italy

No response
provided

No response
provided60

Yes

It would be good to understand why a topic is not consideredmaterial, or why something that once was material is not any longer
or to even understand why two companies in the same sector have

SAICA

South
AfricaNongovernmentorganization

On behalf ofanorganization,

Page 13 of 79

different material topics- this will enhance comparability to a certain
extent.

group orinstitution

61

Yes

For auditing and transparency, the reporter should demonstrate thateach of the material topics in the sector standard have been
evaluated and describe the reasons for any omissions, especiallyfor reporting In Accordance.

Shelley
AndersonAustralia

Consultant

As anindividual

62

Yes

for the purpose of clarity, it is a reasonable expectation.

Sime Darby
Property Bhd

Malaysia

Business

On behalf ofanorganization,group orinstitution

63

Yes

This would ensure completeness of transparency of evaluation
process. As GRI reporting is important to investors and otherstakeholders, it would allay concerns that the reporting organization
may have missed this topic or that.

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

64

Yes

No comment provided

Sulema Pioli

BrazilConsultant

As anindividual

65

Yes

In different sectors as material coverage differs it needs to be
informed

Sushil Pattanaik

India

Academic

As anindividual

66

Yes

(See above)

Sustainability
Advantage

CanadaNo response
provided

No response
provided67

Yes

Unrelated, but what happens if there is an appropriate topic for an
organization, but not covered in both sector and topic standard? If
the situation is possible, how should we report?

Trisakti
Sustainability
CenterIndonesia

Consultant

On behalf ofanorganization,group orinstitution

68

Yes

For comparability reasons this is important.

Trossa AB

SwedenConsultant

On behalf ofanPage 14 of 79

organization,group orinstitution
69

Yes

The sector standards represent considered input as to what topics
are material and relevant to a particular sector. Therefore, nondisclosure of such topics should be explained.

UNDP - SDG
Impact Team

UnitedStatesUN body

On behalf ofanorganization,group orinstitution

70

Yes

Oftentimes companies do not disclose on what they consider to belegal compliance issues, which presents a gap as far as children's
rights impact assessments are concerned. A good example ismaternity leave provisions: a recent UNICEF global study showedthat the length of maternity leave provided by businesses typicallyfollows standards defined by national legislation. Businesses incountries with low legislative requirements typically reported lower
rates of maternity leave provision. This is problematic as, according
to the ILO, only just over half of the countries that have ratified ILO
Convention 183 on maternity protection meet the ILO minimum
standard requiring at least 14 weeks of maternity leave.

UNICEF

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

See: UNICEF Global Survey of Business Policy.
<https://www.unicef.org/media/65011/file/UNICEF%20 Familyfriendly-global-survey-business-policy-2020.pdf>
71

Yes

Standard should provide a concrete framework and tools while
being flexible to assess all internal and external elements that could
affect the performance of the organization. This is importantmeasures to avoid under-reporting factors.

Universiti Malaya
Sustainability &Living Labs
Secretariat(UMSLLS)

Malaysia

No response
provided

No response
provided72

Yes

Yes, because there may be instances when the company identifies
the topic as not material because they do not want to report their
negative impacts or they fear receiving criticisms from stakeholders.

University ofAsia and thePacific - Center
for Social
Responsibility

Philippines

Assurance
providerOn behalf ofanorganization,group orinstitution

Page 15 of 79

73

Yes

Yes, this information should be required because each of the
proposed 40 new sector standards have and will go through arigorous vetting and public comment process before publication.
GSSB and their working group of stakeholders have already
decided to create these standards for up to 40 high impact
industries in addition to address "likely material" topic standards. If a
topic standard is not deemed material, an organization should be
required to report reason for omission because that enhances thetransparency of its sustainability reporting, strategy and progress. It
also enhances consistency in how organizations report bycommunicating the right issues to the right stakeholders.

University ofDenverUnitedStatesNo response
provided

No response
provided74

Yes

The assessment should be made available or point to where thisinformation is - for example in an application etc.

University ofSouthern
Queensland

Australia

No response
provided

No response
provided75

Yes

No comment provided

ValoraSwitzerland

No response
provided

No response
provided76

Yes

Yes, the organisation should define their context and explain theapplicabilities of it's boundaries as it relates to the GRI standard.

VertAfrika
LimitedNigeria

No response
provided

No response
provided77

Yes

For consistency and comparability, if something is likely to bematerial, the burden should be on reporters to explain why they
have omitted it if they have used a sector-specific standard.

WBCSD

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Information should be required to increase transparency andaccountability. This would help ensure that topics aren’t excluded forreasons other than significance (256). Including information on why
a topic has been excluded would help demonstrate how no
significant actual or potential impacts were identified relative to othertopics.
However, this will need to be streamlined, as the explanations may
become cumbersome for report preparers and users.

Page 16 of 79

No, this information should only be recommended78

No

If an GRI topic is not material no explanation is required. Why
should this be the case for Sector Standards? Also it is an sector
standard it does not mean it fits on the business model of anindividual company. But of course if the company follows therecommendation to explain it, it is more transparent.

akzentekommunikation
und beratung
gmbh

Germany

Consultant

On behalf ofanorganization,group orinstitution

79No

Organizations that are heading to elaborate sustainability reports
already carry out a cause analysis to determine their material issues
and it does not generate added value trying to report why they havenot been included this topics

Angel Castillo

EcuadorConsultant

As anindividual80No

if the topic is not relevant to the reporting organization, how can they
identify?

Bank Audi sal

LebanonNo response
provided

No response
provided81

No

Companies are asked to report on what's material. If they also haveto address everything that's NOT material, they will never get to theend of the reporting process. In any case, sector standards bynature are rather generic for the sector, many companies operate
only in part of a sector, or in specific activities.

BeyondBusiness Ltd

IsraelNo response
provided

On behalf ofanorganization,group orinstitution

82

No

No comment provided

Bipart,Italy

No response
provided

No response
provided

SwedenBusiness

On behalf ofanorganization,group orinstitution

CesvorParlamentary
Antimafia
Commission
83

No

Ideally that should of course be explained. However, as thestandards are constantly growing in number and requirements fordetailed information most likely the sector standards will as well - inthat case it is better to put effort and quality into describing andexplaining what is material than explaining what is not of relevance.

Bonava AB

Page 17 of 79

84

No

To state universal material topics for sector seems a bit unlikely.

Bondt
Communicatie

Netherlands

No response
provided

No response
provided

85

No

No comment provided

BSI Group

Italy

No response
provided

No response
provided

86

No

Setting thresholds for qualitative impacts can be abstract in nature.
Suggest to provide further guidance to enable consistent thresholdsetting process across companies. This can include providing
quantitative scales for stakeholders impacted, whether it is local,
national, regional, global impacts or identifying impacts created by
the companies' within their respective radius of control vs radius of
influence.

Bursa Malaysia

Malaysia

Stockexchange

On behalf ofanorganization,group orinstitution

87No

reporting organisation should just state certain topics are notmaterial to the operation and state it is irrelevant to the organisation
with explanation why they ar enot relevant.

Choon Kiong
Ting

Malaysia

Business

As anindividual88

No

No comment provided

CrevalItaly

No response
provided

No response
provided89

No

No comment provided

CSRWorks
International

Singapore

No response
provided

No response
provided90

No

No comment provided

Daniela Winicki

Chile

Consultant

As anindividual91

No

The justification on non-material topics should be already explainedin the process of materiality assessment.

DRB-HICOMBerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

92

No

For me, Sector Standards are as only additional standards. If thesector standards are considered not material, of course it isnecessary to be stated in the report.

Eko
Sukoharsono

Indonesia

Academic

As anindividual

Page 18 of 79

93

No

an explanation of the method to select material topics is already
requested in MT-1 (is already recommended)

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution

94

No

There is no need for further details to be given by organisations
since the listed topics would not be material in the first place, listingthem would make the organisations to divert from key issues toreport on .

Fridah Mashandi

ZambiaNo response
provided

As anindividual95

No

Based on the following background and reasons, we would like you
to consider that it is not needed to state a reason for not identifying
a topic listed in the Sector Standards as material.

Global Compact
Networking
Japan

Japan

Generalincorporated
association

・Currently, the Sector Standards cover only certain sectors, andthe Sector Standards are expected to ‘assist’ in identifying material
topics. In other words, a reason for not identifying the topic as amaterial is preferably presented in explanatory scenarios from the
manager at the time of engagement.

- Study
Committee on
Corporate
ReportingOn behalf ofanorganization,group orinstitution

Hong kong

Professional
Accountancy

On behalf ofan

・In Japan and also in many countries, integration of ESG
disclosure with management and sufficient engagement are still in
the process of maturation. When disclosing sector-specific topics
described in the Sector Standards, if the purpose of the disclosure isto promote understanding between issuing companies and investors(readers), it would be desirable to include a supplementary
explanation as the reason for the disclosure.
・For most of companies In Japan, the workload for disclosure
reporting is high, and more efficiency is required in the future.
Therefore, in order to reduce the burden of description, we would
like you to consider deeming it as "unnecessary".
96

No

To do so would be to go too far and may affect clarity of reporting.
The focus should remain on the organisation having to identify andHong Kong
Institute of CPAs

Page 19 of 79

report material topics and not justifying why other topics are notmaterial.

Body(including
regulator andstandard
setter)organization,group orinstitution

97

No

No. It should be left to reporting organisations to decide whether togive reasons. Adding the requirement increases the length of thereport and reduces its clarity.

Hong Kong
University of
Science andTechnology

Hong Kong

No response
provided

No response
provided98

No

Key information may change over time

Hui XuChina

Nongovernmentorganization

As anindividual99

No

No comment provided

ICR Systems &Management
SRL

Bolivia

No response
provided

No response
provided100

No

I think it is important to let them know that all companies and sectors
are different and companies in general have different priorities, butordaining to report something that doesn't have an impact in acompany for me is senseless.

Ilunka,Estrategia
Sustentable

MexicoConsultant

On behalf ofanorganization,group orinstitution

101

No

As Sector standard can be general for the sector. As everyorganization may have some different scale for setting materiality
according to each organization's position, this information should
only be recommended.

International
Development
Center of JapanJapan

No response
provided

No response
provided

102

No

Approach should be similar to Universal Standards.

ISOS Group

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

Page 20 of 79

103

No

The sector standards continue to be very broad and not always
completely applicable to individual companies. There are many
examples of square-peg-in-round-hole approaches to how
companies apply the sector standards. Until the sector standards
become more applicable (i.e., develop more specialized sector
standards), this should remain a recommendation and not arequirement.

Josiah McClellan

UnitedStatesBusiness

As anindividual

104

No

No we are trying to make the reports concise and relevant tostakeholders. If the topic is not material and the company needs toreport on it then it would bulk up the report. While on the other end if
it actually is material than stakeholder pressure will force thecompany to report on it or risk reputational / operational damage…

Liberty Holdings
LimitedSouth
AfricaNo response
provided

No response
provided

105

No

This information might be already included in the "materiality
section" (for example when explaining the methodology used to
identify material topics and relevant impacts) . Additionally, it
ensures more flexibility and clarity in reporting material topics,
especially for companies having complex supply chains and/or
operating in complex regulatory frameworks.

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

On behalf ofanorganization,group orinstitution

106

No

if some topics are not material for the organization, it is completely
useless to explain why; the organization doesn't have info on those
topics because they are not relevant for the stakeholders and they
are not monitored.

Prysmian GroupItaly

No response
provided

No response
provided

107

No

GRI reporting is based on a materiality assesment, what implies that
only material topics are reported. An explanation about a topic not
being material can generate misunderstandings by the users of thedisclosures. No sector-specific materiality assessment can replace
the specific materiality assessments developed by companies. As
an example, many companies within the energy sector (includingO&G) are in a transition process that is leading them to diversify
their business, which is why they cannot be classified within one
sector only. This may result in certain material sector-specific issues
not applying 100% to a given company.

REPSOL

Spain

PrivateCompany

On behalf ofanorganization,group orinstitution

Page 21 of 79

108

No

To reduce over-reporting on matters within a report. It has beenstated that where available GRI Sector Standards MUST beconsidered in the course of identifying material topics. This issufficient to know that organisations have considered and postassessment, all material topics identified are significant.

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

109

No

No comment provided

RPMRG

Hungary

Consultant

On behalf ofanorganization,group orinstitution

110

No

No comment provided

SancroftInternational

UnitedKingdom

Consultant

On behalf ofanorganization,group orinstitution

111

No

For some businesses several sector standards might be applicable.
Therefore, they should use the topics which are material only. No
need to justify why not others. Many businesses touch different
sectors

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

112

No

No comment provided

SGS

China

No response
provided

No response
provided

113

No

It may not have a relationship with the organization and not from its
competence, and it is not essential and does not affect the interestof the work, so there is no point in identifying it

Sharjah City for
Humanitarian
Services

United ArabEmirates

Non-profit
organization

On behalf ofanorganization,group orinstitution

114

No

No comment provided

SM Investments
Corporation

Philippines

Business

On behalf ofanorganization,

Page 22 of 79

group or
institution
115

No

Regardless of the sector to which the company belongs, thematerial topics are selected based on other variables such as its
stakeholders, or the location where it operates. Therefore, it can beunderstood if the sector material issue is not material for thecompany.

Sustenia

Argentina

Consultant

On behalf ofanorganization,group orinstitution

116

No

Organisations will go through a materiality assessment to determine
their material issues. Referencing sector standards material issues
is a way to benchmark relevant issues but sector standards should
not be the 'end all'.

Tang Lien

Malaysia

Consultant

As anindividual

117

No

It just makes for a tedious report - we should be supporting
reporters to tell a story about their impact, not provide disclaimers
about things that are not significant to them. Focus on providing
more clarity about the material assessment process and then trustin that process.

Think Impact Pty
LtdAustralia

Consultant

On behalf ofanorganization,group orinstitution

118

No

Too subjective and if the organization and it's stakeholders alreadyfeel that it's not material... it doesn't need to be included

Toronto Pearson
AirportCanadaBusiness

On behalf ofanorganization,group orinstitution

119

No

this would contradict GRIs approach to focus on material topics,(and would have the look and feel of G.3)

triple innova

Germany

Consultant

On behalf ofanorganization,group orinstitution

120

No

Too many unnecessary information would make the reader orinvestors confused

wei shane low

Malaysia

Business

As anindividual

I don’t know/other comments

Page 23 of 79

121

I don't know/other

In principle this is good as it pushes companies to discuss,reason internally and explain externally why they have chosen
to not include certain topics that would make sense to include.
But given that we do not know what the Sector Standards will
look like (currently only one Sector Standard available forpublic comments) we argue that it would be dangerous to put
this as a requirement. A future Sector Standard could include
a vast number of topics. Forcing an organisation to put time,
resources and space in their report to motivate why they havenot deemed these topics as important could be the wrong
approach. There could be a value to develop the Sector
Standards with the ambition of being inclusive rather than
exclusive, meaning that the Sector Standards would include
several topics that could potentially be material topics for an
organisation in a certain sector. If the list ends up being very
long, this could be useful as an inspiration but difficult if theorganisation then needs to motivate why only five out of e.g.
20 potentially material topics are relevant.

Enact
Sustainable
Strategies

SwedenConsultant

On behalf ofanorganization,group orinstitution

122

I don't know/
otherWhile we do not think that addtional disclosure adds decisionuseful informaiton for stakeholders to the extent that it should
be required, we believe this decision should be made by thereporting company.

ERM

UnitedStatesConsultant

On behalf ofanorganization,group orinstitution

123

I don't know/
other

Section 3: Reporting on material topics:

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Ø FPP affirms that if there are topics listed in a GRI Sector
Standard that an organization in that sector does not deem to
be material, the organization should be required to identify
these topics and explain why they are not material. This isbecause the process implemented to understand what thematerial risks and impacts are, and who is assessing them will
heavily determine what is considered a material risk. The
material impacts per sector in Sector Standards have beendeveloped by a group of experts and identified as theminimum number of material impacts that a business should

Page 24 of 79

be aware of and potentially reporting on; however, this does
not make them full-proof. Furthermore, businesses may not beat the point of understanding the issues in each sector and byhaving to report on why they are not reporting they will have toconsider these and in the process learn more about thesematerial impacts, and in some cases probably discovering thatthey actually do need to report on them.
124

I don't know/otherNo comment provided

Han Wei Ho

Malaysia

Consultant

As anindividual125

I don't know/other

I would say that if a sector standard is done well, there
shouldn't be too many topics deemed material by the sector
standard but immaterial by the organisation in that sector.

Simeon Cheng

Hong kongBusiness

As anindividual126

I don't know/otherNo comment provided

Transparency
International
Deutschland e.V.

Germany

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

127

I don't know/other

Due to the multiple reporting formats and ways of reporting towhich entities must respond, when using the GRI guidelines
you should focus on getting companies to talk about theirmaterial aspects and focus their strengths on what is
important, trying not to overburden companies and getting
their reporting to serve different needs of the entity. If entities
are already obliged to describe in detail how they have carriedout their materiality process, this description should also
include the process of detecting material aspects according to
the sectoral guides. If this is not the case, I would expand on
this point in the description of material aspects and theirprocess in order to avoid giving further explanations.

UN Global
Compact
Network Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Another option is that the sectoral guides indicate basic andimportant material aspects for all companies in the sector as
they are common to all entities and secondary information. In

Page 25 of 79

this case, if the entity has not included a basic material aspect
for the sector, the cause should explained.
128

I don't know/
otherSince there would be a free and publicly available GRI
Standard listing likely material topics in the given sector, it
seems reasonable to expect an organisation to refer to this inperforming its materiality assessment and thus have an
understanding of why each topic is or is not material to it. Thisrequirement would likely drive organisations to use the Sector
Standards at the materiality assessment stage, which could be
helpful for consistency and well as the organisations’ own
processes/thinking. It would be useful for a benchmarking
organisation such as WBA to have this information publicly
available and free to inform our benchmark assessments andprovide transparency to all stakeholders.

World
Benchmarking
Alliance

Netherlands

Benchmarking
foundation

On behalf ofanorganization,group orinstitution

ZENITH BANK
PLC

Nigeria

No response
provided

No response
provided

Notes of caution: this requirement may lead organisations tothink that the material topics in the Sector Standards are
exhaustive and miss out on assessing for and identifying othertopics. If the Sector Standards provide a wide range of topics,
this risk of missing out crucial topics is limited. However,providing a very wide range of topics could increase thereporting burden (especially for smaller companies).
In any event, WBA is supportive of the continued efforts foralignment in approaches to reporting, to ensure thatcompanies do not face an undue burden of reporting
differently across multiple platforms. Our work together with
GRI through the Impact Management Project supports this
aim.
129

I don't know/otherNo comment provided

Page 26 of 79

1011

The following comments were submitted during the public comment period for the GRI Sector Standard: Oil and Gas, between 8 July and 6
October 2020.

12
13

Survey question: If there are topics listed in a GRI Sector Standard that an organization in that sector does not deem to be material, should the organization
be required to explain why these topics are not material? Please explain why.

14

Please note:

15
16
17
18

1. The question posed in the public comment survey for the GRI Sector Standard: Oil and Gas exposure draft did not include the option to respond to thequestion using a ‘yes/no/ I don't know/ other’ selection, only a free text response was requested. As such, the following are not grouped according tothese categories.
2. Where a respondent submitted a relevant comment in response to another question, this has also been included, long with the corresponding question.

19

Table 2. Responses to question 4 in the online survey to the Oil and Gas Sector Standard exposure draft

Comment

Name oforganization orindividualCountryNo.

Stakeholder
group

Submission
type

1

Yes. The topics cover the basic information every company in the oil and gas
sector can report on (often readily available internally). If a company decides
to skip certain topics, it should provide a justification for doing so.

Institutional
Shareholder
Services (ISS)

UnitedStatesProvider ofcorporate
governance &responsible
investment
solutions

On behalf ofanorganization,group orinstitution

2

Yes, because it provides insight into the thought process / approach /methodology that the organization used to determine materiality. Even if aparticular topic is not currently considered material, the explanation also
should provide insight into the key leading and lagging indicators that should
be monitored going forward to determine if / when the topic becomes material.

Jeanne-Mey Sun

UnitedStatesConsultant

As anindividual3

Yes is needed

Enric Nebot

Spain

Conformity
Assessment
body

As an
individual

Teixidó

Page 27 of 79

4

Yes

Raymond Colvin

United ArabEmirates

Government

As anindividual

5

Yes, require to explain

Prospect
Institute (PTArjuna Wijaya
Karya)

Indonesia

Consultant

On behalf ofanorganization,group orinstitution

6

Yes, because this would provide better quality data to stakeholders andinvestors, and reduce the risk of 'cherry-picking'.

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

Fuji Xerox (HongKong) Limited

Hong kongBusiness

On behalf ofanorganization,group orinstitution

AECOM Asia
Company
LimitedHong kong

Consultant

On behalf ofanorganization,group orinstitution

I do not however think that every topic should require an omission statement,but only those that are considered material for a sub-sector.
If a table or matrix could identify the likely material topics for organisations
with certain activities (e.g. refining, storage, E&P), then this could be the basis
for determining what organisations SHOULD report on, at a minimum, or haveto provide an omission statement if they still do not see these specific topics
as material.
7

Yes, the organization should be required to explain why these topics are notmaterial.
It can better explain and let readers know how their business has little impact
on those topics or how those topics has little impact on them, and to ensurethat the company do not overlook the material topics.
It can also act as a reference to future development of sector standard tounderstand why companies would consider certain topics not material andlook for updates to improve the sector standard.

8

Yes, the organization should explain why such topic is not deemed material.
This could avoid companies from not disclosing data that may be ofstakeholders' concerns.

Page 28 of 79

9Yes, the companies should be required to provide justification in areas thatthey do not deem material. Leaving justification optional gives the company
open to “pick and choose” which topics it wants to discuss.

As You Sow

UnitedStatesInvestor

On behalf ofanorganization,group orinstitution

10

Yes, need a better understanding and transparency.

Dr. Marius
GavrilaLuxembourg

Academic

As anindividual

11

Yes. Most topics listed in this Sector Standard are supposed to be material foroil & gas organizations, even if all of them are not applicable for everyorganization in the sector. If there are topics that an organization deems notmaterial, GRI should require a justification to avoid cherry picking.

Ceres

UnitedStatesNongovernmentorganization

On behalf ofanorganization,group orinstitution

12

Yes the organisation should be required to explain why the required topics are
not material. This should improve transparency and reporting. In our view
most of the topics will be material.

AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

13

Yes, it should up to the proponent to demonstrate that one or more topics are
not material to their activities. Such demonstration could include technicalconsiderations as well as historical and projected data and/or statements fromstakeholders confirming that a topic is not material.

Pembina
Institute

CanadaNongovernmentorganization

On behalf ofanorganization,group orinstitution

14

Yes the organisation should be required to explain why the required topics arenot "material" (See previous objections). This should improve transparency
and reporting.

Joint submisionfrom IndustriALL
Global Unionand International
Transport
Federation (ITF)

Switzerland

Global Union
Federations

On behalf ofanorganization,group orinstitution

Page 29 of 79

15

Yes, organizations should be required to explain why a topic is not material.
If a reporting organization determines that a likely material topic is in fact notmaterial for their situation, they should be able to provide the details that led
them to that determination. This will provide more transparency for thoseorganizations. In contrast, it will help ensure that reporting organizations aren’t
able to claim a topic as immaterial or ignore it altogether simply because they
do not have sufficient data, or do not want the information to become public.

Waste Analytics
LLC

UnitedStates

ESG
Research/Data
ProviderOn behalf ofanorganization,group orinstitution

16

Yes, the organisation should be required to explain why the required topics
are not material. This should improve transparency and reporting. In our view
the vast majority of the topics will be material.

AustralianCouncil of Trade
UnionsAustralia

Labor
representative

On behalf ofanorganization,group orinstitution

17

Yes, just to demonstrate that topics listed have been considered. Need not
create additional burden - just a statement.

Shelley
AndersonAustralia

Consultant

As anindividual

18

Yes, companies should be able to justify why they are not reporting on any
material topic. This will clarify it to the information user about the missing
reporting avoiding confusion or wrong judgement.

Vigeo SAS

UnitedKingdom

Rating agency

On behalf ofanorganization,group orinstitution

19(1) Yes, organisations should absolutely be required to explain why these
topics are not material (see response above). There appears to a lack ofcoherence and disconnect with the narrative preceding the topic lists in thissection, the narrative in the topic descriptions – which is a robust descriptionof the problems of the oil and gas sector and the feeling that all is optional.
We currently get the impression that the company has all the discretion not todisclose much or anything without a requirement to justify it (e.g. Shell andIndigenous Rights in Niger Delta – they chose to not disclose this, as this wasarguably not material in their global operations but the local eco-destruction /human rights abuse was definitely material to the delta communities). There isambiguity in the scale (or context as we identified in previous responses) for
determining materiality. As we read this draft, the company materiality

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

Page 30 of 79

assessment processes seem to trump the standards and are allowed toremain black boxed and opaque.
We also find that the text in Section 3.2 confusing and misleading – “anorganization to which the exposure draft applies needs to review each topic
described and determine whether it is material for itself” – to us, materiality isbased on external impact on others and ecosystems, not “for itself”.
20

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to
conduct its own materiality assessment process. Is it clear that the list of likely
material topics is not a) exhaustive or b) applicable for every organization in
the sector? If not, please explain what could be improved.”(2) No, we find that there is a significant lack of clarity about materiality. We
find that there is a lot of scope for misinterpretations (i.e. the need to switch
between different documents) – confusing logics and nested conditionality.
This section could be more prescriptive. For example, the default assumptioncan (should) be that an item is deemed material and impose a rationale andexplanation as to why it is not material. Overall, and in contrast to the draft on
universal standards (although we pointed this out), there seems to be a switch
towards allowing non-disclosure and making all topics voluntary. We werecertainly not clear on what organisations had to disclose.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

21

Yes, they should be required to explan why these topics are not material.
This would allow for a level playing field in terms of the reporting of data.
There may also be some management teams who are just not abreast of theclimate science and have failed to see the importance/relevance of aparticular data point. This may highlight this to them and therefore be
educative.

ShareAction

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

22

Yes. Also there needs to be clarity on how and why an organization considers
a topic material if it is not using sector standard

Shazia Naik

India

Investor

As anindividual

23

Yes. As we’ve seen from voluntary reporting in the US, companies abuse theleeway given by the ability to choose which topics are material to omit swathsof relevant and necessary information. As such, at the very least, theomission of any topics should be accompanied by an explanation for why theUnion ofConcerned
Scientists

UnitedStatesNongovernmentorganization

On behalf ofanorganization,

Page 31 of 79

company doesn’t consider the topic material. A better solution would be to
make some topics, such as GHG emissions and trade association
memberships, mandatory for all activities in the sector.

group orinstitution

24

Yes, this should be explained so that we have standardisation acrossreporting and it helps prevent companies from claiming topics are not material
when they really are.

Engineers
Without Borders
CanadaCanadaNongovernmentorganization

On behalf ofanorganization,group orinstitution

25

Yes. For transparency/misleading/corrupt behavioral purposes.

Troy Carter

Australia

Trade orindustry
association

As anindividual

E.g. A company could publicly announce (for goodwill purposes) that they arereporting voluntarily to the GRI, but purposely leaving out relevant material
topics (they do not wish to disclose) that should in fact be included with theirreporting.
26

I agree is important to have full commitment to record its analysis on the topic
and formal disclosure.

Pedro Caemiro
Magalhaes Jr

BrazilConsultant

As anindividual

27

Yes, because some companies only have exploration activities, or refining
activities, but others have the complete process related to oil and gas
industry. Also, in some cases, the exploration and production is not
significative, because the company import the crude.

EMPRESANACIONAL DEL
PETRÓLEO(ENAP,NATIONAL OIL
COMPANY)

Chile

Consultant

On behalf ofanorganization,group orinstitution

28

Since there would be a free and publicly available GRI Standard listing likely
material topics in the given sector, it seems reasonable to expect anorganisation to refer to this in performing its materiality assessment and thus
have an understanding of why each topic is or is not material to it. Thisrequirement would likely drive organisations to use the Sector Standards at
the materiality assessment stage, which could be helpful for consistency andwell as the organisations’ own processes/thinking. It would be useful for abenchmarking organisation such as WBA to have this information publicly

World
Benchmarking
Alliance

Netherlands

Benchmarking
Foundation

On behalf ofanorganization,group orinstitution

Page 32 of 79

available and free to inform our benchmark assessments and provide
transparency to all stakeholders.
Notes of caution: this requirement may lead organisations to think that thematerial topics in the Sector Standards are exhaustive and miss out on
assessing for and identifying other topics. If the Sector Standards provide awide range of topics, this risk of missing out crucial topics is limited. However,providing a very wide range of topics could increase the reporting burden(especially for smaller companies).
In any event, WBA is supportive of the continued efforts for alignment inapproaches to reporting, to ensure that companies do not face an undue
burden of reporting differently across multiple platforms. Our work together
with GRI through the Impact Management Project supports this aim.
29

There are a variety of cases that need to be clearly stated by the organisation

MicheleDASSISTI

Italy

Academic

As anindividual30

It is to identify and assess the potentiality of using efficiently in the process formeasuring sustainability

Dr Sushil Kumar
Pattanaik

India

Academic

As anindividual

31(1) For Oil & Gas companies, it should be clear that a number of topics cannot
be deemed immaterial--GHG emissions in particular, should be reported on by
all companies of the sector.

Publish What
You Pay

UnitedStatesNongovernmentorganization

On behalf ofanorganization,group orinstitution

The standard should require that companies disclose their materiality
assessment process, in addition to the actual reporting. It should detail whichsustainability issues have been considered material by the companies, andimportantly - which have been not.
As the definition of non-financial materiality encompasses the way companies’
activities impact non-financial stakeholders, companies should meaningfully
consult with those stakeholders such as their own employees, sub contractors
and suppliers, unions, CSOs including representatives of marginalised groups
and indigenous populations. This is particularly important for extractive
companies given the specificities of their impacts and operations. The
consultation process should be clearly described. Companies should also
disclose whether the outcomes of grievance mechanisms were taken into
account in high risk sectors such as natural resource extraction, it is essential

Page 33 of 79

to ensure inclusive multi-stakeholder assessment processes that enable
meaningful participation of affected communities, with due regard for gender
dynamics and the views of minority and marginalized groups, in particularindigenous communities.
Minorities’ and indigenous peoples’ legal and customary rights must be
protected throughout the assessment and management plan implementation
process, including free, prior and informed consent (FPIC) where applicable. It
is key, therefore, that companies disclose their policies surrounding FPIC.
Finally, disclosure on the materiality assessment process should also clearly
outline the approval process followed by companies: executive committee
approval and board endorsement in particular.
32

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to
conduct its own materiality assessment process. Is it clear that the list of likely
material topics is not a) exhaustive or b) applicable for every organization in
the sector? If not, please explain what could be improved.”

Publish What
You Pay

UnitedStatesNongovernmentorganization

On behalf ofanorganization,group orinstitution

CIRS Srl

Italy

Consultant

On behalf ofanorganization,(2) Yes. This is clear.
However, for the oil and gas sector, materiality determinations by eachcompany should be explained, including if materiality of topics is reassessed
each reporting year. Given the long timespan of the industry (contracts ofmultiple decades), and multi-decade and even generational impacts of oil andgas production, it would be important for reporting organizations to describe
the time horizon of materiality assessments for given topics and if materiality
shifts on topics included in the standard. There has been historic efforts bycompanies in this industry simply to avoid disclosure of uncomfortable topics such as project payment disclosure - using the rationale of ‘materiality’. Given
this history, GRI should clarify that organizations should be transparent with
their materiality assessment procedure and how it is validated each year especially as it concerns topics for which annual performance may have multiyear and generational impacts (eg climate change, pollution).
33

The guiding principle "is comply or explain", though in my opinion every
business has a specific identity so it is quite obvious that urgency andpriorities may differ fron one to another.

Page 34 of 79

group or
institution
34

Not for each issue. It should possibly explain the process for deciding that a
set of sector specific topics were considered to be non-material.

Paul Davies

Australia

Consultant

As anindividual

35

It may not be necessary to explain why some topics are not material if theorganisation has provided sufficient information on its routine activities in apreamble / preliminary part of the report.

ShailandGunnooMauritius

Civil Society

As anindividual36

This is a grey area and may have to be overcome by time and iterations of thereports by sub-sectors. Some firms may not report on an important material
topic and it’s important to know why they chose not to. For other firms,
however, because they have unique circumstances, simply don’t have thatmaterial topic. Requirements to explain in both cases could end up with an
N/A response (or N/R – not relevant) even for the ones that were relevant but
just not reported on.

FactSet

UnitedStatesEconomic,
Financial,
Operating, andESG Data
AggregatorOn behalf ofanorganization,group orinstitution37(1) If one of the 6 themes is not relevant for a company, the company should
provide a brief explanation. Instead, if a single topic or disclosure, especiallyamong the countless "appropriate disclosures", is not relevant for a reporting
company, such company should not be required to provide such detailed
explanation.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Moreover, we suggest to better specify that companies have the responsibility
to select the most appropriate disclosures and that they don't have to provide
explanation/ reasons for omission shall one or more suggested disclosures be
not appropriate.
38

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to
conduct its own materiality assessment process. Is it clear that the list of likely
material topics is not a) exhaustive or b) applicable for every organization in
the sector? If not, please explain what could be improved.”(2) It is clear that is not exhaustive or applicable to all the organizations.

Page 35 of 79

To make it clearer though, we suggest to invert the process, as alreadycommented in Question 1a. on materiality.
As the sector standard already mentioned the most relevant impacts for thesector, companies should be clearly asked to start the materiality processfrom the list of topics provided, and then add what is relevant and eliminate
what is not through stakeholders feedbacks, internal review or integrated risk
management results.
Moreover, we deem necessary to further explain the "appropriate disclosure"concept. It should be clear that it is up to the company to define what is
appropriate or not. As such if one of the 6 themes is not relevant for acompany, the company should provide a brief explanation. Instead, if a single
topic or disclosure, especially among the countless "appropriate disclosures",is not relevant for a reporting company, such company should not be required
to provide such detailed explanation.
See our detailed comments in separate spreadsheet/document.
We do not believe that the current draft standard achieves the focus that isrequested by stakeholders but potentially leads to more proliferation ofdefinitions and KPIs, and rather confuses than sharpens company profiles toenable better comparability. In addition, regulatory requirement will increase inmany countries and companies need to ensure compliance with those first.
Also, we find that this question is basically contradicting the purpose of thestandard: we believe that guidance for reporting will likely not be able tobecome “complete”, as companies must define their materiality not within the“boundaries” of such guidance.

39

No. The sector standard is intended to encompass a large variety ofbusinesses, from global to local, upstream and downstream, working with
offshore and onshore, and including both energy producers and the large anddiverse number of service companies in the industry. Thus, for mostorganizations a significant number of topics will not be relevant, due to thenature or size of their business and/or the geographies in which they operate.
This will in most cases be obvious to the reader, and to require an additional
explanation will render the reporting less useful.

HitecVision

NorwayInvestor

On behalf ofanorganization,group orinstitution

Page 36 of 79

40

Companies should not be required to comment on topics that they have not
identified as relevant or material. Companies should be given discretion to use
their own process for prioritizing topics for reporting and for explaining this to
stakeholders in their reporting.

AmericanPetroleum
Institute (API)UnitedStatesTrade orindustry
association

On behalf ofanorganization,group orinstitution

41

No; a reporting organisation should be able to indicate that standard does not
apply.

International
Petroleum
Corporation

CanadaBusiness

On behalf ofanorganization,group orinstitution

42

No

Marisport
Calçado Lda

Portugal

Business

On behalf ofanorganization,group orinstitution

43(1) We believe that companies should not be required to comment on topics
that they have not identified as material. The “suggested” list of GRI will
always be a list that may not be comprehensive. How far shall companies
go to describe what is not relevant for them?

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Companies should be trusted to identify what topics should becommented on even not identified as material.
44

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to
conduct its own materiality assessment process. Is it clear that the list of likely
material topics is not a) exhaustive or b) applicable for every organization in
the sector? If not, please explain what could be improved.”(2) We do not find it useful to abandon the concept of core andcomprehensive reporting – however, definitions may need to be updated incontext of the development of the non-financial reporting, particularly in
regulatory terms.

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Page 6, Section 1.5 (Using this Standard): in the 4th paragraph in this section,
GRI allows the reporting company to use its own process for identifying
material topics:“Using this Standard is not intended to substitute the organization’s own
process for identifying material topics. Not all topics listed in this Standard
may be material for all organizations in the oil and gas sector, and other topics
may be material that are not listed in this Standard. An organization istherefore still required to identify material topics according to its unique
circumstances.”
However, once material topics have been identified, the ‘Identifying what toreport’ section requires the company to “. . . report appropriate disclosuresfrom the corresponding GRI Topic Standard for each material topic.” There
does not appear to be any discretion allowed for the reporting company todetermine which disclosures they can report from the Topic Standard.
Suggest allowing the reporting company to determine which Topic Standards
are appropriate for their circumstances. For instance, the following language
from the IPIECA Sustainability Reporting Guidance would be a suitable
addition to the GRI Sector Standard:“In instances, where you do not report against a core reporting element, you
should provide an explanation of why it has not been included. This may be
because:• There are confidentiality, commercial or legal constraints;• The element is not applicable or material to your business; or• Currently, information is not available or data quality is not sufficiently
mature.”(IPIECA Sustainability Reporting Guidance, section 1.5)
We do not see GRI in a position to ask for an “comply or explain” approachagainst the GRI suggested “potentially material topics”. Companies need toconsider a number of mandatory requirements for their ESG reporting in somecountries, and the number of those is growing. GRI needs to acknowledge
explicitly that regulation and companies´ individual assessments are thedefining factors for non-financial reporting aspects.

Page 38 of 79

45

No, they should not be required to explain. As pointed out in previous
questions, not all topics would be applicable to every organization in the
sector. A ‘non-applicable’ response should be sufficient.

Plains All
AmericanPipeline

CanadaBusiness

On behalf ofanorganization,group orinstitution

46(1) We believe that companies should not be required to comment on topics
that they have not identified as material. The “suggested” list of GRI will
always be a list that may not be comprehensive. How far shall companies go
to describe what is not relevant for them?

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

Companies should be trusted to identify what topics should be commented oneven not identified as material.
47

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to
conduct its own materiality assessment process. Is it clear that the list of likely
material topics is not a) exhaustive or b) applicable for every organization in
the sector? If not, please explain what could be improved.”(2) Page 6, Section 1.5 (Using this Standard): in the 4th paragraph in thissection, GRI allows the reporting company to use its own process for
identifying material topics:“Using this Standard is not intended to substitute the organization’s own
process for identifying material topics. Not all topics listed in this Standard
may be material for all organizations in the oil and gas sector, and other topics
may be material that are not listed in this Standard. An organization istherefore still required to identify material topics according to its unique
circumstances.”
However, once material topics have been identified, the ‘Identifying what toreport’ section requires the company to “. . . report appropriate disclosuresfrom the corresponding GRI Topic Standard for each material topic.” There
does not appear to be any discretion allowed for the reporting company todetermine which disclosures they can report from the Topic Standard.
Suggest allowing the reporting company to determine which Topic Standards
are appropriate for their circumstances. For instance, the following language

Page 39 of 79

from the IPIECA Sustainability Reporting Guidance would be a suitable
addition to the GRI Sector Standard:“In instances, where you do not report against a core reporting element, you
should provide an explanation of why it has not been included. This may be
because:• There are confidentiality, commercial or legal constraints;• The element is not applicable or material to your business; or• Currently, information is not available or data quality is not sufficiently
mature.”(IPIECA Sustainability Reporting Guidance, section 1.5)
We do not see GRI in a position to ask for an “comply or explain” approachagainst the GRI suggested “potentially material topics”. Companies need toconsider a number of mandatory requirements for their ESG reporting in somecountries, and the number of those is growing. GRI needs to acknowledge
explicitly that regulation and companies´ individual assessments are thedefining factors for non-financial reporting aspects.
48

The explanation should not be required, since it depends on the nature of thecompany this would apply

Grupo Ecopetrol

Colombia

Business

On behalf ofanorganization,group orinstitution

20

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22

2. Identify and explain why topic is not material in the absence of an applicable
Sector Standard

23

The following comments were submitted during the public comment period for the Universal Standards, between 11 June and 9 September 2020.

24
25

Survey question: In the absence of an applicable Sector Standard, if there are topics that are commonly associated with the sector(s) in which anorganization operates that it does not deem to be material, should the organization be required to identify these topics and explain why they are not material?

26

Please refer to page 91 in the Universal Standards exposure draft.

27

Table 3. Responses to question 8 in the online survey to the Universal Standards exposure draft

21

No.

Surveyresponse

Name oforganization
or individual

Comment

Country

Stakeholder
group

Submission
type

Yes, this information should be required1

Yes

No comment provided

AlliedEnvironmental
Consultants

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

2

Yes

No comment provided

Ana María
González Ruiz

Colombia

Consultant

As anindividual3

Yes

The organization is responsible for all aspects in which its
business generates a possible impact and must maintain directcontrol aimed at sustainability

Angel Castillo

EcuadorConsultant

As anindividual

4

Yes

Again, workplace death rate.

Anna McBee

CanadaLabor
representative

As anindividual

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5

Yes

Given that the development of GRI Sector Standards are in theearly stages, until there is a substantial body of Sector Standards,
organisations should be expected to include as material topics
those impacts that are commonly associated with their sector, or
explain why they are not material (as above).

AustralianCouncil ofTrade Unions

Australia

Labor
representative

On behalf ofanorganization,group orinstitution

6

Yes

In line with the response to question 7, there needs to be fulltransparency and accountability in company reporting. There
should be no difference in the absence of an applicable Sector
Standard.

BirdLife
International

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

7

Yes

No comment provided

BSI Group

Italy

No response
provided

No response
provided8

Yes

Please refer to our response to question 7.

CDSB

UnitedKingdomStandard
setterOn behalf ofanorganization,group orinstitution

9

Yes

The company would need to explain why they are not relevent tothem while it is relevant to the sector.

Choon Kiong
Ting

Malaysia

Business

As anindividual

10

Yes

The deviation from those topics shall undermine the quality andusefulness of the report.

Corporate
SocialResponsibility
CentrePakistan

Pakistan

Consultant

On behalf ofanorganization,group orinstitution

11

Yes

We covered this in Comments on the Environmental, Social andGovernance Reporting Guide. Government of Hong Kong.
September 18, 2015. See:
https://www.creativeinvest.com/HongKongESGReporting.pdf

Creative
Investment
Research

United States

ImpactInvestingInnovator

On behalf ofanorganization,group orinstitution

Page 42 of 79

12

Yes

No comment provided

CSRWorks
International

Singapore

No response
provided

No response
provided

13

Yes

The organization should report or explain the reasons of notreporting the information, especially if this information seems tobe publicly important.

Da-Strategy

RussianFederation

Consultant

On behalf ofanorganization,group orinstitution

14

Yes

Same as above

Datamaran

United States

Digitalplatform

On behalf ofanorganization,group orinstitution

15

Yes

The Sustainability Accounting Standards Board (www.SASB.org)
has identified "material topics" as the result of a thoughtful,comprehensive, open process that included evaluating andclassifying industry sectors according to sustainability relevance,
and applying the US Supreme Court's concept of "materiality."
SASB, GRI and others all have the goals of moving towards
preparation of reports that stakeholders can compare to assist in
their decisions - whatever those decisions may be. If there is nocontent regarding topics commonly regarded as "material" in asector - whether it is material to the specific organization or not this impairs the ability of stakeholders to compare companies'
sustainability reports.

DouglasHileman

United States

Consultant

As anindividual

16

Yes

As per the answer provided in (7).

Dr Aljaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

17

Yes

It is always good to have a standard that is friendly for allcompanies.

DUOPHARMA
BIOTECH
BERHAD

Malaysia

Business

On behalf ofanorganization,group orinstitution

Page 43 of 79

18

Yes

It would be good if GRI could provide a position statement or
recommendation for this.

ELEVATE

Hong Kong

No response
provided

On behalf ofanorganization,group orinstitution

19

Yes

Yes, for the same reason as above in terms of standardisationand ensuring companies do not falsely claim topics are notmaterial.

Engineers
Without
Borders
CanadaCanadaNo response
provided

No response
provided20

Yes

Although the application of this approach will not be sostraightforward.

Eszter Vitorino

Netherlands

Investor

As anindividual

21

Yes

No comment provided

Ethcial Trade
NorwayNorwayMSI

On behalf ofanorganization,group orinstitution

22

Yes

Because it allows for greater comparability between businesses
in the same sector. This information can also be collated by the
GRI to monitor the effectiveness of their sector standards andform the basis for any subsequent revision. Similarly, the GRI
should monitor additional material impact disclosures which are
not included in their sector standards.

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee

CanadaAcademic

On behalf ofanorganization,group orinstitution

FOM
University ofGermany

No response
provided

No response
provided

However, we wonder how an organisation in a given sector“deems” a topic material (or immaterial) and are concerned about
subjectivity. At the very least such evaluation should bethoroughly explained. Also, sector reporting should not allow any
loopholes.
23

Yes

Impact can be positive or negative. In case of positive impact, it
can make sense for a company to focus on its non-material
impact. A company that help to dispatch green innovations with

Page 44 of 79

the aim to accelerate the sustainable development has a positive
non-material impact.

AppliedSciences24

Yes

Ø FPP affirms that in the absence of an applicable Sector
Standard, if there are topics that are commonly associated withthe sector(s) in which an organization operates that it does notdeem to be material, the organization should be required to
identify these topics and explain why they are not material. This isbecause the process implemented to understand what thematerial risks and impacts are, and who is assessing them will
heavily determine what is considered a material risk. A bit ofresearch online will bring up NGO reports, media stories etc thatwill highlight the concerns within different sectors - unacceptable
to argue that information is not available, at least in terms ofunderstanding what the material impacts are likely to be.

ForestPeoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

25

Yes

For sore purposes of ensuring the organisation does not remain
behind in the trends of the sector it operates in.

FridahMashandi

ZambiaNo response
provided

As anindividual

26

Yes

As above

GIB Asset
Management

UnitedKingdomBusiness

On behalf ofanorganization,group orinstitution

27

Yes

From a mining sector perspective, as for 7 above, this will be in
the interest of comparability between organizations in the mining
sector and will demonstrate due consideration of sectoral material
issues. However, we cannot speak to the challenges faced inother sectors with identifying a group of consistent material
topics. This may be challenging for sectors that experience morevariability in material issues. One solution is to specify withineach Sector Standard whether specific disclosures should be‘required’ or ‘recommended’, and whether reporters should
explain if certain topics are not material.

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Page 45 of 79

28

Yes

I think it is really important to let them think about future risks,
looking at other bigger companies and preparing themselves for
those risks.

Ilunka,Estrategia
Sustentable

MexicoConsultant

On behalf ofanorganization,group orinstitution

29

Yes

As GRI Sector Standards are largely a work in progress,
IndustriALL Global Union reiterates that only the important
stakeholders in a sector - particularly labour - have the moral
authority to determine what is "material", and what is not.

IndustriALL
Global Union

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution

30

Yes

IOSH believes the reporting organisation would need to explain
why it differs from the rest of its sector (the sector norm) in
deeming any common sector topics to be immaterial. This would
help reassure stakeholders and report-users that the topics
concerned have been considered and not overlooked, and thatthe reporter has a rationale for its judgement, rather than a failure
to recognize the significance of the topic concerned.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for
OSH
Professionals

On behalf ofanorganization,group orinstitution

31

Yes

As sector standard can be general for the sector, if organizationconsider the topics to be deemed material, the organization
should be required to identify these topics and explain.

International
Development
Center of
Japan

Japan

No response
provided

No response
provided

32

Yes

The development of GRI Sector Standards is in its early days andit will be many years before there is a substantial body of sector
standards covering many industries. Until there is that substantial
body of sector standards, sustainability reporters should be
expected to include as material topics those impacts that arecommonly associated with their sector, or explain why they are
not material. To do otherwise is to facilitate poor reporting.

International
Trade Union
Confederation

Belgium

Labor
representative

On behalf ofanorganization,group orinstitution

33

Yes

To ensure that the organization does not overlook the possibilityof the topics to be material

Izzaty Khaleda
IsmailMalaysia

Consumers

As anindividual

Page 46 of 79

34

Yes

No comment provided

Joshua Rayan
Communications

Malaysia

Sustainability
Report Writer

On behalf ofanorganization,group orinstitution

35

Yes

In this respect, certain topics become relevant and material
perhaps because of the surrounding environment but may not be
a part of the sector standard: social norms in the surrounding
communities, specific topography or environmental needs, evencertain issues related to finances and governance relevant to asector in particular country. Again this will give a complteness to
the report.

NazishShekhaPakistanNongovernmentorganization

As anindividual

36

Yes

Yes, this information should be required to address ESG investor
disclosure information requests and as a general matter of
disclosure and performance reporting; and as a matter ofhistorical record on performance. More detailed reporting should
be required if the topic was a major news item covered by the
media in the last five years (eg scandal or accident).

Next Level
Sustainability

Australia

GRI Certified
Training
Partner inAustralia

On behalf ofanorganization,group orinstitution

37

Yes

It is important for stakeholders to know that the company has
considered these topics even if they are not material to them.

R&A Strategic
CommunicationsSouth Africa

No response
provided

No response
provided38

Yes

No comment provided

RPMRG

Hungary

Consultant

On behalf ofanorganization,group orinstitution

39

Yes

See above.

SAICA

South Africa

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 47 of 79

40

Yes

It would benefit the organisation to explain all omissions forauditing purposes, transparency, and understanding andknowledge base within the organisation.

Shelley
AndersonAustralia

Consultant

As anindividual

41

Yes

Yes, as above, getting the reporting organization to disclose all
the topics they have considered would also help readers evaluate
if the organization have been competent in carrying out
materiality assessment.

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

42

Yes

No comment provided

Sulema Pioli

BrazilConsultant

As anindividual

43

Yes

(see above)

Sustainability
Advantage

CanadaNo response
provided

No response
provided

44

Yes

Sector supplements are very important and should be expanded
to include other industries

TorontoPearsonAirportCanadaBusiness

On behalf ofanorganization,group orinstitution

45

Yes

The organization is required to disclose how it has identified
material topics. This should include material topics for its sector.
It should then explain why any topics so identified are notdisclosed.

UNDP - SDG
Impact Team

United States

UN body

On behalf ofanorganization,group orinstitution

46

Yes

Across several business sectors, children's rights issues tend tobe very salient, but companies rarely disclose (seehttps://www.unicef.org/csr/css/UNICEF_Working_Paper__Reporting_161213_Web.pdf). For sector-specific child rights
impacts, see:

UNICEF

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

ICT: UNICEF, Child Online Protection Guidelines<https://www.unicef.org/csr/css/COP_Guidelines_English.pdf>

Page 48 of 79

Mining: UNICEF, Child Rights and Mining Toolkit<https://www.unicef.org/csr/files/FINAL_Child_Rights_and_Mining_Toolkit_060217.pdf>
Apparel and Footwear: UNICEF, Children’s Rights in theGarment and Footwear Supply Chain: A Practical Tool for
Integrating Children’s Rights into Responsible Sourcing
Frameworks < https://www.unicef.org/media/70126/file/Networkon-childrens-rights-in-the-garment-and-footwear-sector-summary2020.pdf>
Food and Beverage:<https://www.unicef.org/csr/foodandbeverage.html>
47

Yes

Standard should provide a concrete framework and tools while
being flexible to assess all internal and external elements that
could affect the performance of the organization. This is importantmeasures to avoid under-reporting factors.

Universiti
MalayaSustainability& Living Labs
Secretariat(UMSLLS)

Malaysia

No response
provided

No response
provided48

Yes

If a an organisation deems a standard material to the sector it
operates in as immaterial to it, this should be explained to avoid
evasion of standards an organization is not willing to report on

ZENITH BANK
PLC

Nigeria

No response
provided

No response
providedNo, this information should only be recommended
49

No

Although it should be encouraged that an organization explains
why a topic that may be seen as material is omitted, it is notpractical to require so if you don't have a reference to 'topics
commonly associated with a sector'.

Marcus Chau

Hong Kong

Consultant

As anindividual50

No

The industry in different countries might be different, even thestakeholder culture and backgrounds are different. I believe thewei shane low

Malaysia

Business

As anindividual

Page 49 of 79

organisation should only require to disclose those topics that tothem are important and keep it simple.
51

No

In the event that a company is active across multiple sectors, it ismore relevant to identify which topics are material and why.
Identifying and discussing potentially related but not material
topics could result in unnecessary extra work, diluting themessage and diverting the focus from the important, which are
the actually applicable and material topics.

ABB

Switzerland

No response
provided

No response
provided

52

No

The idea is ok, but who defines that a topic is commonly
associated with the sector? There is no formal identification.

AG
Sustentable

Argentina

Consultant

On behalf ofanorganization,group orinstitution

53

No

In the absence of an actual Sector Standard, the organisation
cannot be asked to second guess which topics are commonly
associated with the sector. This should then be merely arecommendation and not a requirement.

Aldo Joson

Singapore

Business

As anindividual54

No

In this case there is too much discretion in the application of thisprinciple. Basing on which assumption one entity can say that acertain topic is commonly associated with the sector?

Alessandro
Mantini

Italy

Business

As anindividual55

No

I think this could be very subjective - explanation of the inclusionand exclusion of topics should be included in the content on themateriality assessment.

Alexandra
McKay

UnitedKingdom

Consultant

As anindividual56

No

No comment provided

Bank Audi sal

LebanonNo response
provided

No response
provided57

No

Too complicated. Better for GRI To get its skates on and develop
the sector standards. I a company is approaching materiality
correctly and seriously, these issues will probably come up
anyway.

BeyondBusiness Ltd

IsraelNo response
provided

On behalf ofanorganization,

Page 50 of 79

group or
institution
58

No

No comment provided

Bipart,Italy

No response
provided

No response
providedCesvorParlamentary
Antimafia
Commission
59

No

Hard to identify without a sector standard. Too subjective.

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

60

No

This is topic of debate between the company and its assurance
provider and stakeholders

Bondt
Communicatie

Netherlands

No response
provided

No response
provided

61

No

No, I think there has to be a sector material topics list so thatcom0anies could justifythe abscence of topics in thair materiality.
Otherwise it would be justifying against benchmark which is more
subjective.

BSD
CONSULTING

BrazilNo response
provided

No response
provided62

No

In the absence of a sector-specific standards, it would be difficult
for companies to predict which issues are commonly discussed.
Resources need to be deployed to perform market scans before
such observations can be made. This would be highly challenging
for diversified companies that have multiple footprints across theworld.

Bursa
Malaysia

Malaysia

Stockexchange

On behalf ofanorganization,group orinstitution

63No

Because GRI has not recommended the topics for that sector.
Onus should be on the reporter, in the absence of sector
standards by GRI.

City
Developments
LimitedSingapore

Business

On behalf ofanorganization,

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group or
institution
64

No

In the absence of the sector standards, the material topics
covered should be left to the company’s materiality assessment
process. Otherwise, it is difficult to determine which topic list
should the reporter refer to and provide explanations on any
discrepancies; if any 3rd party standard is deemed suitable forthe purpose (e.g. GRESB for the real estate sector), it should beconsistently applied and not for GRI to develop a separate sector
standard.

CLP Holdings
Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

65

No

No comment provided

CrevalItaly

No response
provided

No response
provided

66

No

No comment provided

DanielaWinickiChile

Consultant

As anindividual

67

No

Deloitte does not believe an organization should, in the absenceof Sector Standards, identify all potential sector materials topics
and report reasons for exclusion. We believe this proposed
practice would not serve the intended objective of greatertransparency, but rather would result in inconsistent andpotentially confusing additional disclosure.

Deloitte

United States

Consultant

On behalf ofanorganization,group orinstitution

68

No

In the absence of an applicable Sector Standard, reporting on thisrequirement could be inconsistent. Reporting MT-1 a. i and ii,
how material topics were identified, should be sufficient.

Dow Inc

United States

Business

On behalf ofanorganization,group orinstitution

69

No

The disclosure of the process of identifying material topics should
be a strong justification to explain why any particular topics
associated to the sectors was not classified as material.

DRB-HICOMBerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

Page 52 of 79

70

No

The organisation reporting should not be required to identify andto explain the topics, because the topics are considered notmaterial.

Eko
Sukoharsono

Indonesia

Academic

As anindividual

71

No"Commonly associated topics" is too broad and unspecified tomake as a requirement.

Enact
Sustainable
Strategies

SwedenConsultant

On behalf ofanorganization,group orinstitution

72

No

As topics commonly associated with the sector might be hardly
identified for a sector, we suggest to recommend only (and not torequire) an explanation.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

73

No

The focus of disclosures on material topics should be on what ismaterial and why. The term “commonly associated” is also toovague to be useful.

ERM

United States

Consultant

On behalf ofanorganization,group orinstitution

74

No

because in absence of a clear reference it is too much subjective
to identify topics “commonly associated with the sector”

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution

75

No

To let information users know that the company has notoverlooked these topics, and utilize the opportunity to explain
how low/insignificant the outward impact these topics havebrought, thus immaterial.

Fuji Xerox(Hong Kong)
LimitedHong Kong

No response
provided

No response
provided

To better clarify how their operations different from common

Page 53 of 79

practices of the sector, that topics considered common
associated with the sector are not material.

The Sector Standard aims to clarify the common disclosure
information of the specific sector. If a Sector Standard is missingin the sector, it reveals the fact that either those topics are notimportant to stakeholder, or the professional bodies like GRI,
think that sector- specific impacts are insignificant. With this,reporting organizations may not have the ability to identify andexplain. Putting it in a recommended approach would allow
flexibility to issuers.
76

No

Commonly associated may be a little subjective

Gazprom Neft
PJSC

RussianFederation

No response
provided

No response
provided

77

No

Based on the following viewpoints, we would like you to consider
that it is not needed to state a reason why an organization does
not identify some topics as material even though they arecommonly considered as material in the sector concerned.

GlobalCompact
Networking
Japan

Japan

Generalincorporated
association

On behalf ofanorganization,group orinstitution

・If each company does not know what ‘generally acceptedmaterial topics’ are, and these topics are not sufficiently
integrated or incorporated with management, an explanation of
the reasons for this should not be required. Rather, it should be atheme of dialogue during the engagement.

- Study
Committee on
Corporate
Reporting・However, we would like to ask you to consider a
supplementary note such as "if there are topics that can benoted, it is recommended that they are noted," to raiseawareness of integrating “material topics" with management in
the future.

Page 54 of 79

78

No

As for 7 above.

Hong Kong
Institute of
CPAs

Hong Kong

Professional
Accountancy
Body(including
regulator andstandard
setter)On behalf ofanorganization,group orinstitution

79

No

No. It should be left to reporting organisations to decide whether
to give reasons. Adding the requirement increases the length of
the report and reduces its clarity.

Hong Kong
University of
Science andTechnology

Hong Kong

No response
provided

No response
provided80

No

Key information may change over time

Hui XuChina

Nongovernmentorganization

As anindividual81

No

No comment provided

ICR Systems&
Management
SRL

Bolivia

No response
provided

No response
provided82

No

Same as #7

ISOS Group

United States

Consultant

On behalf ofanorganization,group orinstitution

83

No

This is a difficult ask of a company when there is no applicable
Sector Standard. Significant guidance would need to be provided
on what would constitute a material topic "commonly associatedwith the sector."

JosiahMcClellan

United States

Business

As anindividual84

No

it is not material and it is only a topic by association.

Justina
Callangan

Philippines

Business

As anindividual

Page 55 of 79

85

No

Commonly associated is a lower standard than a sector standard,
therefore recommended rather than required.

KPMG

Australia

Consultant

On behalf ofanorganization,group orinstitution

86No

No comment provided

Laurence
Vigneau

UnitedKingdomAcademic

As anindividual87

NoNo - the core of the GRI Standards is reporting on material topics
and if it's not included in the universal standards then why reportit? i.e. If the sector standards/ commonly associated topics arewell represented than chances are that organisation will report onit.

Liberty
Holdings
LimitedSouth Africa

No response
provided

No response
provided

I don't want companies thinking that they need to keep justifying
why they have not reported something, a well written reportfocusing on the actual material impacts will be enough.
88

No

No comment provided

Manuela
HuckWettstein

Switzerland

Consultant

As anindividual89

No

It might be useful for awareness-raising purposes. However, it
might require to disclose sensitive information and/or it might beconsidered not relevant to raise this point forcommercial/strategic reasons. Therefore, we believe that thecompany should have the flexibility to decide whether this can be
an important information to be shared publicly.

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

On behalf ofanorganization,group orinstitution

90

No

It is too vague and an additional burden on organisations todetermine which topics are commonly associated with the sector
which may not increase certainty as organisations may decidedifferent topics are commonly associated with their sector.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 56 of 79

91

No

The number of possibles in that case make the information non
relevant and useless to analyze I think. Either there exists a
sector standard or not, we should consider that the generalstandards are the reference in the absence of sector standards

Not applicableFranceNo response
provided

As anindividual

92

No

Well, reporters do not know what to report if the Standards are
not telling what to report on. "Commonly associated" is not
something a reporting can work with. Common in what way?
Associated by whom? this is very very diferente per region,
country, culture. "Commonly Associated" cannot be a
replacement or a fix for not having a sector standard, and assoon as you stipulate what is commonly associated, you lose
rigor, sector knowledge, facts, and open yourself up to lobbyists
and activists who want to push their agendas without thereporters and sectors present in the process. That is a multiple
stakeholderapproach fail. If there is no Sector Standard, then the
only logical approach would be to let the repórter indicate what hedefines as materially relevant and make sure he or she reports
those. After this disclosure, any one making a judgement canmake that judgement from what he or she "commonly associates"with that sector and determine whether the report was goodenough or not. So what is subjectively associated with a sector iswith the judge on the basis of the objective report and cannot
enter as a kind of pseudo sector approach that has not passed
full construction and approval of a standards. Commonly
Associated is prone to subjectivity and conflicts of interest,
opening doors of stealth agenda pushing.

Olaf Brugman

BrazilStandard
setterAs anindividual

93

NoSome organisations may not be aware of the topics commonly
associated with the sector

Paia
Consulting

SingaporeConsultant

On behalf ofanorganization,group orinstitution

Page 57 of 79

94

No

The Sector Standards should have the minimum requirements forthat sector, and it would make it too lengthy and cumbersome ifan organization had to explain why the topics are not material.

Principles for
Responsible
Investment

UnitedKindgom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

95

No

for the same reason above

Prysmian
Group

Italy

No response
provided

No response
provided96

No

We think such information would be useful and therefore wewould recommend it be provided. However, where there is not anapplicable Sector Standard we believe it is difficult to gather the‘commonly’ utilised topics. To the extent that an entity does
explain such matters, they should comment on the scope of theiranalysis (i.e. what peer group was considered and whether any
analogy was drawn to other sector standards).

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

97

No

Topic Standards are applicable to all sectors, the rule shouldn't
apply differently across them. Moreover, materiality assessment
applies also to Sector Standards, what means that sector
requirements that are not material don,t need to be disclosed

REPSOL

Spain

PrivateCompany

On behalf ofanorganization,group orinstitution

98

No

To reduce over-reporting on matters within a report. Difficult todetermine or assume which topics it is that GRI or others regard
as commonly associated with the sector(s) unless it is outlined in
the GRI Sector Standards. Until then, in the course of identifying
material topics, companies engage with stakeholders and would
do research/reference, such common topics would appear and if
deemed significant, would appear as identified material topics.

RHB Bank
BerhadMalaysia

Business

On behalf ofanorganization,group orinstitution

99

No

Topics that are "commonly associated with the sector(s)" are notuniquely identified.

SAI Global
Italia s.r.l.

Italy

No response
provided

No response
provided100

No

No comment provided

SancroftInternational

UnitedKingdom

Consultant

On behalf ofanPage 58 of 79

organization,group orinstitution
101

No

Same as above. Not clear what topics are commonly used.

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution

102

No

No comment provided

SGS

China

No response
provided

No response
provided

103

No

Since it has no influence on the organization, it does not need to
be claimed. Information can be provided for information only, or it
is not necessary

Sharjah Cityfor
Humanitarian
Services

United ArabEmirates

Non-profit
organization

On behalf ofanorganization,group orinstitution

104

No

If an organisation has a proper materiality assessment, andexplained the process, the organisation should only be required
to report on the topics deemed material. Explaining topics thatare immaterial seems contradictory to the purpose of a materiality
assessment and will introduce unnecessary content to the report.

Simeon Cheng

Hong Kong

Business

As anindividual

105

No

No comment provided

SM
Investments
Corporation

Philippines

Business

On behalf ofanorganization,group orinstitution

106

No

Not that to explain always and sector wise it is to be clarrified

SushilPattanaik

India

Academic

As anindividual

107

No

Regardless of the sector to which the company belongs, thematerial topics are selected based on other variables such as its

Sustenia

Argentina

Consultant

On behalf ofanorganization,

Page 59 of 79

stakeholders, or the location where it operates. Therefore, it canbe understood if the sector material issue is not materialgroup orinstitution

108

No

as above.

Tang Lien

Malaysia

Consultant

As anindividual

109

No

No, if there is not a Sector Standard available, then this is out of
GRI's remit.

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

110

No

When having applied properly the "Sustainability Context" and"comparability", it shouldn't be necessary to explain, whysomething is not in the report.

triple innova

Germany

Consultant

On behalf ofanorganization,group orinstitution

111

No

Avoid unnecessary detail/too many requirement. It may also be
hard to define whether the topics are "commonly associated" withthe sector(s).

Trisakti
Sustainability
CenterIndonesia

Consultant

On behalf ofanorganization,group orinstitution

112

No

No comment provided

Trossa AB

SwedenConsultant

On behalf ofanorganization,group orinstitution

113

No

It should not be required as long as the company has beentransparent with the process and results of its materiality
assessments.

University ofAsia and thePacific Center forSocialResponsibility

Philippines

Assurance
providerOn behalf ofanorganization,group orinstitution

Page 60 of 79

114

No

Based on the description of the process in the choosing andvalidation that GSSB and participating stakeholders have gone
through to identify these 40+ Sectors, I don't think this should bea requirement once the Sector Standards are finalized. Based on
the fact that organizations have had the option to utilize the GRI
G4 Guidelines Sector Disclosures (which were not updated in thetransition to GRI Standards as we know) as a useful tool fororganizations when considering their materiality process and forwhat to report. If it's high impact and likely material enough for an
organization to need to explain why it does not deem it material,
there should be a Sector Standard for that organization's
industry. Otherwise, the organization may just be adding fluff andprovide little to no value to the information user.

University ofDenverUnited States

No response
provided

No response
provided

115

No

There is no need to discuss beyond the scope of applicability.

VertAfrika
LimitedNigeria

No response
provided

No response
provided

116

No

If there isn’t a specific document/guideline to refer to, theorganization should not be required to explain why it has notincluded a specific topic among the most material ones. The term“commonly associated” is too vague to form the basis of thisrequirement.

WBCSD

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

I don’t know/other comments
117

I don't know/otherNo comment provided

FraserPatersonUnitedKingdom

No response
provided

As anindividual118

I don't know/otherWe even would not recommend it, as "commonly associated" isnot an objective term. Who decides what is commonly
associated.

akzentekommunikatio
n undberatung
gmbh

Germany

Consultant

On behalf ofanorganization,group orinstitution

Page 61 of 79

119

I don't know/other

In principle yes, but this will be harder to require in the absence ofan authoritative list of issues commonly associated with thesector(s), so we are not convinced of practical feasibility.

DanishInstitute for
Human Rights

Denmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

120

I don't know/other

The Problem is that "commonly associated" will be hard todemonstrate. And if they are really "commonly associated", would
this not be reflected in Stakeholder Engagement processes?

DQS CFS

Germany

No response
provided

No response
provided121

I don't know/other

If the company has identified its impacts and material topics fully
then this should not be required. Of course an assurance provider
may use lists of sector impacts from other standards to test theveracity of the materiality process and quiz the company on any
topics not included in the report.

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

122

I don't know/otherNo comment provided

Han Wei Ho

Malaysia

Consultant

As anindividual123

I don't know/otherNot sure how this would work - how would a company know what
"list" to use? What would be the status of such lists? Perhaps turnit around and ask them to state any lists they have used in theirprocess of defining material topics.

Marjolein
BaghuisNetherlands

Consultant

As anindividual124

I don't know/otherNo comment provided

Prime ProjectInternational
Dubai

United ArabEmirates

No response
provided

No response
provided125

I don't know/otherNo comment provided

Sime Darby
Property Bhd

Malaysia

Business

On behalf ofanorganization,group orinstitution

Page 62 of 79

126

I don't know/otherNo comment provided

Transparency
International
Deutschlande.V.

Germany

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

127

I don't know/other

In the absence of a guide it would be difficult to indicate whichaspects are common or not, unless there are some minimum
sectoral requirements until the guides are developed, as essential
basic material aspects.

UN Global
Compact
Network Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

128

I don't know/otherNo comment provided

University ofSouthern
Queensland

Australia

No response
provided

No response
provided129

I don't know/other

How would that work? That would require a standardized peeranalysis.

ValoraSwitzerland

No response
provided

No response
provided130

I don't know/other

It would be useful to assessors such as WBA to have a publicly
available statement of what an organisation does not deemmaterial, to enable an understanding of the organisation’s
position on such topics. However, in absence of a list of topics
that would be expected to be material in that sector, that appears
to be quite an aspirational ask, so this could be better suited torecommendation level.

World
Benchmarking
Alliance

Netherlands

Benchmarking foundation

On behalf ofanorganization,group orinstitution

28

Page 63 of 79

29

3. Require reporting on selected topics based on the sector of an organization

30
31

The following comments were submitted during the public comment period for the GRI Sector Standard: Oil and Gas, between 8 July and 6
October 2020.

32
33
34

Survey question: While developing the exposure draft, it was suggested that reporting on some topics listed in a Sector Standard should be mandatory fororganizations in that sector (e.g., GHG emissions for the oil and gas sector). What value or challenges do you see in requiring reporting on some topics
included in a Sector Standard?

35

Table 4. Responses to question 6 in the online survey to the Oil and Gas Sector Standard exposure draft
Name oforganization
or individualCountry

Stakeholder
group

Submission
type

The information is often readily available internally, and should be disclosed fortransparency reasons.

Institutional
Shareholder
Services (ISS)

United States

Provider ofcorporate
governanceandresponsible
investment
solutions

On behalf ofanorganization,group orinstitution

2(1) Yes, certain topics should be mandatory, but with the option of an omission
statement, so as to avoid risk of 'cherry-picking'. I would struggle to find examples
of an O&G company where GHG emissions and H&S are not highly material
topics, for example.

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

3

The following comment was made in response to the survey question “Pleaseprovide any additional comments below.”

Lundin Energy

Switzerland

Business

On behalf ofanorganization,group orinstitution

No.

Comment

1(2) The new sector standard for O&G is quite helpful in setting the context aroundthe material topics for the sector, but in general it is not particularly authoritative,
which could increase risk of cherry-picking on topics. I recommend considering amatrix of material topics to report on per sub-sector/type of activity (e.g. E&P,
refining, etc.) with a minimum requirement and then a mandated omission
statement if the minimum requirement is not met. This would add credibility to the

Page 64 of 79

Sector standard which presently feels much more like 'guidance' than a'standard', which would be a missed opportunity.
We need more standardization in the sector. Therefore, I would also recommend
a very clear alignment between the SASB standards for O&G, and the TCFD
requirements. Where SASB and TCFD require certain information, this should bestandardized in this Topic standard as well from GRI. For example, there is somereference to emissions from reserves or scenario analysis, but not enoughlinkages with the equivalent datapoints required by TCFD and SASB.
4

It is vital that there is standardisation in what should be reported and so reportingon the appropriate topics for each sector should be mandatory. Many companies
claim particular topics are not material when they actually are.

Engineers
Without
Borders
CanadaCanadaNongovernmentorganization

On behalf ofanorganization,group orinstitution

5

If mandatory disclosure is applied on some material topics (e.g. GHG emission), it
will encourage companies to disclose the material topics that are very muchconcerned by the general public as their industry peers are disclosing suchrequirements. However, it should also allow flexibility for companies to explain thereasons for not disclosing the mandatory requirements.

AECOM Asia
Company
LimitedHong kong

Consultant

On behalf ofanorganization,group orinstitution

6

This would make sense, as most topics in the Sector Standard are supposed tobe material for oil & gas companies and some of them will apply to allorganizations whatsoever. This being said, Ceres considers that requiring ajustification in case an organization deems a topic not material should be enough(see Question 4 on Sector Standards in general).

Ceres

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

7

Some topics may be more or less relevant and material for a company depending
on its exact role within the oil and gas sector. We recommend that all topics berequired, noting that any company that wishes to exclude a topic must explain
why that exclusion could be justified.

As You Sow

United States

Investor

On behalf ofanorganization,group orinstitution

8

We fully support the requirement to report on specific topics of the standards,
including that related to climate, governance, and lobbying. Such a requirement
will allow for the disclosure of information that will enable both accountability andPembina
Institute

CanadaNongovernmentorganization

On behalf ofanorganization,

Page 65 of 79

comparisons across the oil and gas sector. The availability of such information,
combined with the right amount of pressure from investors and civil society, could
spur more ambition on those issues and in some cases generate a race to thetop.

group orinstitution

9

Yes, reporting on topics such as GHG emissions should be required for this
sector. Stronger reporting and transparency should lead to better planning and abetter transition.

AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

10

Yes, reporting on topics such as GHG emissions should be required for this
sector. Stronger reporting and transparency should lead to better planning and abetter transition.

AustralianCouncil ofTrade Unions

Australia

Labor
representative

On behalf ofanorganization,group orinstitution

11

It appears it would be logical to make reporting on GHG emissions andEmployment practices mandatory, as these are highly likely to be material to alltypes of Oil & Gas organizations and foundational to sustainable andsocioeconomic development. As an information user, the WBA underlines thevalue of having Oil & Gas company data on these two topics. The WBA Climate &Energy Benchmarks assesses companies in high-emitting sectors such as the Oil& Gas sector using the ACT methodology to measure companies' performanceon GHG emissions (reductions) and to assess alignment to low-carbon economy.
In addition, the WBA assesses all 2,000 companies in its benchmarks fromvarious sectors on core social indicators including employment.

World
Benchmarking
Alliance

Netherlands

Other(pleasespecify): Benchmarking Foundation

On behalf ofanorganization,group orinstitution

Empresa
Nacional Del
Petróleo(Enap,

Chile

Consultant

On behalf ofanorganization,group orinstitution

Making some topics mandatory would also enhance the value of the sector
standard, as it increases the volume of reporting. Besides, it delivers a stronger
message to companies in terms of the accountability for their impact.
12

Emissions, water and energy consumption should be mandatory, but the
breakdowns of the current GRI indicators (to water by cource, for example) are
too complex still. Thos topis could be simplified.

Page 66 of 79

National Oil
Company)
13

Requiring the mandatory reporting of payments to governments would be a goodstep in discouraging corruption, corporate tax avoidance/evasion andmismanagement of resources. It would also aid in increasing transparency
related to these issues

Troy Carter

Australia

Trade orindustry
association

As anindividual

14

Yes, reporting on any topic related to workers' rights or labour relations, as well
as GHG emissions should be required for this sector. Stronger reporting andtransparency should lead to better planning and a Just Transition.

Joint
submisionfromIndustriALL
Global Union
andInternational
Transport
Federation(ITF)

Switzerland

Global Union
Federations

On behalf ofanorganization,group orinstitution

15

Emissions, wastewater and waste are main environmental impacts in oil and gas
sector. These inevitable impacts have to managed according to local orinternational standards. Reporting about managing of these impacts can increase
reliance and transparency.

VASIF VALI

TurkeyTrade orindustry
association

As anindividual16

We believe that making certain topics mandatory is reasonable, and will result in
more uniform and comparable reports. For example, nearly all companies within
the sector produce some form of process waste, whether it be drilling mud anddrilled cuttings for upstream operations, sludges from midstream operations, orvarious wastes created during the refining process. These wastes should bereported. For companies that do not generate wastes, it should not be overly
burdensome to simply report that no wastes were generated. This would be thesame for GHG emissions, Air emissions, Water and effluents, Closure anddecommissioning, etc. We believe there is a significant difference between notreporting on a topic (omitting it completely from the report) vs. reporting a value ofzero or explaining why a topic is immaterial.

Waste
Analytics LLC

United States

ESG
Research/
Data
ProviderOn behalf ofanorganization,group orinstitution

Page 67 of 79

17(1) As mentioned before, many companies in the industry approach disclosure
with a loose definition of “material”. Requiring reporting on some topics in the
sector standard would not only allow for better comparisons of GHG
management, in that it would allow investors and the public to compare apples toapples, but it would even the playing field across countries and local disclosure
requirements. Making topics like GHG emissions and trade association
membership reporting mandatory would not be burdensome to companies, as
they are already keeping close records of these particular metrics and data. We
strongly recommend that the GRI make some topics from this sector standard
mandatory.

Union ofConcerned
Scientists

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

18

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to conduct its
own materiality assessment process. Is it clear that the list of likely material topics
is not a) exhaustive or b) applicable for every organization in the sector? If not,please explain what could be improved.”

Union ofConcerned
Scientists

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution(2) This is clear, but would benefit from some topics to be mandatory (ex GHG
emissions) as they are applicable across all sector activities. The industry hashistorically skirted around the edges of disclosure requirements and had a looseinterpretation of “material”, which mandatory disclosures would rectify.
19

Better information

Marisport
Calçado Lda

Portugal

Business

On behalf ofanorganization,group orinstitution

20

Ok

Prospect
Institute (PTArjuna Wijaya
Karya)

Indonesia

Consultant

On behalf ofanorganization,group orinstitution

Page 68 of 79

21

There is great value in requiring reporting on specific topics. This promotes global
consistency and complements existing efforts to produce public information.

Publish What
You Pay

United States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

GHG emissions should be considered material and mandatory for all companies,
given their specificities.
22

The oil and gas industry is facing increasing demand to clarify the implications of
the energy transition on their operations and to report on what they're doing to
reducing GHG emissions and fight climate change. Mandatory reporting on some
topics would provide a more accurate overview on how companies are working to
improve their processes and operations, reducing the negative impact on theenvironment, the community and other stakeholders. In addition, it is easy forcompanies in this sector to adjust their reporting style and they have alreadyobligated to do it on a national level. However, in some cases as seen in
biodiversity, the presentation of what to report is unclear and not exactly precise.
This is one aspect of sustainability reporting that has been under-reported
quantitatively despite its relevance and subsequent risks posed. The various
context of biodiversity practices makes it hard for us information users to havecomparable data from company reporting.

Vigeo SAS

UnitedKingdom

RatingagencyOn behalf ofanorganization,group orinstitution

23

Add value to clear information with data as far as the legal terms

Enric nebot
teixidó

Spain

Conformity
Assessment
body

As an
individual

24

Value:

Jeanne-Mey
Sun

United States

Consultant

As anindividual••

Build consistency in sustainability reporting for oil and gas companies
With data available on an ongoing basis, facilitate continuous improvement atcompany, geographic, sub-sector, and overall sector level

Challenges:••

Cost of compliance for companies that don't already report the required
metrics
To the extent that using GRI is not required by regulation, requiring reportingof certain metrics might lead certain companies to stop using GRIPage 69 of 79

25

Value:••

It can foster better performance comparability across the industry to draw
meaningful comparison and encourage higher quality reporting among peers.
It can also boost investors’ confidence by disclosing more ESG informationand performance.

Fuji Xerox(Hong Kong)
LimitedHong kongBusiness

On behalf ofanorganization,group orinstitution

Raymond
ColvinUnited ArabEmirates

Government

As anindividual

ShareAction

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Challenges:
•

•

26

ESG reporting might be new to some jurisdictions, mandatory reporting on
specific topics might be challenging for them to report in accordance with GRI
standards, as they may encounter difficulties in gathering information
required to report; management effort and time would be needed in order tovisualize these disclosures. Since the size of companies and their regional
exposures are different, the mandatory data may not be an apple-to-applecomparison to stakeholders.
Another challenge would be reporting quality downgrading as some
information in the mandatory disclosure topics might be unavailable. Making
up some false claims and disclosures would lower the reliability of the report,
if no assurance adopted.

Value:•

Greater emphasis on impacts in the value chain and how the organization
manages these.

Challenges:•
27

Updating current reporting

Value:•

Clearly identifies leaders and laggards, encourages greater ambition,highlights data blindspots in organisations

Challenge:•

Some companies have better access to data than others and have in-house
expertise to achieve this. It might make sense to have all data externally

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audited as there are likely to be errors made, particularly by companies who
are disclosing this data for the first time.
28

Value:•

Data on GHG emissions compiled by organisations can eventually be sharedwith regulators and policy makers at national / international levels. In fact,
countries around the world are called upon to compile GHG data for
producing Inventories, Reports (BUR) etc. thus the GRI O&G Standard would
add value to the data reporting system.

ShailandGunnooMauritius

Civil Society

As anindividual

ShailandGunnooMauritius

Civil Society

As anindividual

Challenges:•

29

All organisations may not have adequate capacity / resources / staff /knowhow, etc. allowing them to report on topics.

The following comment was made in response to the survey question “After
reviewing the topics listed in this section, an organization still needs to conduct its
own materiality assessment process. Is it clear that the list of likely material topics
is not a) exhaustive or b) applicable for every organization in the sector? If not,please explain what could be improved.”(2) For instance, there may be no indigenous people impacted by the activities ofa particular organisation and the latter would not have anything to report on. It
may be worth keeping the material topics as optional.

30

The value is in collecting standardised data on a topic of global importance i.e.
GHG emissions. The challenges are data quality and data uncertainty, including
for Scope 3 emissions. However, organisations may already report thisinformation to government regulators (such as the NGER scheme in Australia).
The standard could accept a level of confidence in information prepared for andaccepted by a recognised authority.

Shelley
AndersonAustralia

Consultant

As anindividual31

If the sector standards asks for much more information than required by otherstandards then companies may not be too eager to adopt them owing to costs
and time considerations.Having said that, requirements/ metrics which areuniversally accepted as key material information for a sector across various
standards and exchange requirements can be made mandatory.

Shazia Naik

India

Investor

As anindividual

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32

Making it mandatory may result in less companies adhering to the GRI standards.
Different companies are in different stages as to their reporting maturity and may
require more time and resources to commit to reporting on each applicablestandard.

Plains All
AmericanPipeline

CanadaBusiness

On behalf ofanorganization,group orinstitution

33

The main challenge is to drive the organisation to rethink its own businessapproach, because referring to measures always change the mindset

MicheleDassisti

Italy

Academic

As anindividual34

It might not be compulsory

CIRS Srl

Italy

Consultant

On behalf ofanorganization,group orinstitution

35

We believe it should not be mandatory to report on some topics so that the Sector
Standard applies to a wide range of organisations within O&G value chain, whichhave a large variety of activities.

International
Petroleum
Corporation

CanadaBusiness

On behalf ofanorganization,group orinstitution

36

GRI is not in a position to mandate any reporting items. We support an ambition
to agree a small set of indicators that may be generally adopted (in principle,
what WEF is currently working on). GRI should acknowledge that governments
are also issuing regulations and guidance and companies will greatly benefit from
eliminating duplication and striving for simplification.

IPIECA

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

37

GRI is not in a position to mandate any reporting items. We support an ambition
to agree a small set of indicators that may be generally adopted (in principle,
what WEF is currently working on). GRI should acknowledge that governments
are also issuing regulations and guidance and companies will greatly benefit from
eliminating duplication and striving for simplification.

IOGP

Belgium

Business

On behalf ofanorganization,group orinstitution

38

In Europe, the Directive on non-financial reporting sets the expectations forcompanies, and the application into national laws sets specific obligations for

TOTAL S.E.

FranceBusiness

On behalf ofanPage 72 of 79

companies. GRI should acknowledge that governments are also issuing
regulations and guidance and companies will greatly benefit from eliminating
duplication and striving for simplification.. GRI should remain a voluntary
framework.
39(1) We agree on the need to increase comparability among peers' sustainability
performances. Still we believe it would be more effective among the recognized
topics to introduce "strong recommendations" rather than requirements.

organization,group orinstitution

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

AmericanPetroleum
Institute (API)United States

Trade orindustry
association

On behalf ofanorganization,

As such, instead of defining a list of mandatory topics, it could be better to directly
define a small set of KPIs strongly recommended (such as GHG emissions,
TRIR, etc.).
40

The following comment was made in response to the survey question “Are thedisclosures listed for each topic in the exposure draft complete, relevant andaccurate so as to help understand and communicate an oil and gas organization's
most significant impacts and how it addresses them? If not, please explain which
topics can be improved and how.”(2) Generally speaking, we fret that information requested in the listed disclosuresin the "what to report" section is still too much, with the possible consequence ofmaking non-financial reports too long and articulated, especially when they areincluded in the Annual Reports, as the revised European Directive might require
for the Non-Financial Information. Considering that, we would suggest not todiscard completely the Core/Comprehensive option of the current version of GRI
Universal Standards: indeed a Core option, possibly built on the small set ofmandatory KPIs of the previous question, might be useful for companies when
preparing mandatory Non-Financial Information, whereas a Comprehensive
option might be adopted for other Non-Financial reporting documents.
With the aim to increase performance comparability among peers, we believe thata small set of KPIs - to be accurately defined – might be strongly recommended
for companies to report on (such as GHG emissions, TRIR, etc.), while the rest
just labeled as additional information (like the IPIECA guidelines).

41

Companies’ use of GRI as a reporting framework is voluntary; GRI can
acknowledge those governments that issue regulations and guidance forsustainability reporting.

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Again, GRI should reference the oil and natural gas industry’s own guidance forsustainability reporting [accessible at https://www.ipieca.org/ourwork/sustainability-reporting/sustainability-reporting-guidance/] for those topics
that are typically most relevant for reporting by companies in our sector.

group orinstitution

42

I think GRI could be guided on this by any industry norms for that sector. For
example if a textiles sector industry body or professional body has an expectationthat all its members must report on modern slavery then that would suggest GRI
should follow suit to support that sector on critical accountability issues. The
same could be said for the minerals sector on certain ethical transparency
issues. It should not be that difficult for GRI to identify these existing topic-related
reporting expectations on a sector by sector basis.

Paul Davies

Australia

Consultant

As anindividual

43

A mandatory topic may not be as relevant as one might think (or potentially more
so also) because of product mix or lack of vertical integration. Perhaps more
importantly from GRI's standpoint is that firms may ignore as much as possible
standard makers that mandate answers.

FactSet

United States

Economic,
Financial,
Operating,and ESG
Data
AggregatorOn behalf ofanorganization,group orinstitution

44

The difficulty depends on scope of company collecting GHG data that may
include JV, subsidiary or only main operation.

PTT PublicCompany
LimitedThailandBusiness

On behalf ofanorganization,group orinstitution

45

It is a key point for the sector. Double reporting is not good practice, but it is a
specific for the sector, maybe these info should be only in the Sector doc, withreference in main one.

Pedro
CaemiroMagalhaes Jr

BrazilConsultant

As anindividual

46(1) As indicated in our response in the previous section, there appears to a lackof coherence and disconnect with the narrative preceding the topic lists in thissection, the narrative in the topic descriptions – which is a robust description of
the problems of the oil and gas sector and the feeling that all is optional.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

We currently get the impression that the company has all the discretion not todisclose much or anything without a requirement to justify it (e.g. Shell andPage 74 of 79

Indigenous Rights in Niger Delta – they chose to not disclose this, as this wasarguably not material in their global operations but the local eco-destruction /human rights abuse was definitely material to the delta communities). There isambiguity in the scale (or context as we identified in previous responses) for
determining materiality. As I read this draft, the company materiality assessment
processes seem to trump the standards and are allowed to remain black boxed
and opaque.
We also find that the text in Section 3.2 confusing and misleading – “anorganization to which the exposure draft applies needs to review each topic
described and determine whether it is material for itself” – to us, materiality isbased on external impact on others and ecosystems, not “for itself”.
47

The following comment was made in response to the survey question “Are the'What to report' sections useful in helping to understand what is appropriate toreport on a topic for an organization in the sector? If not, please explain how they
could be improved.”(2) No, we find that there is a significant lack of clarity about materiality. We findthat there is a lot of scope for misinterpretations (i.e. the need to switch between
different documents) – confusing logics and nested conditionality. This section
could be more prescriptive. For example, the default assumption can (should) bethat an item is deemed material and impose a rationale and explanation as towhy it is not material. Overall, and in contrast to the draft on universal standards(although we pointed this out), there seems to be a switch towards allowing nondisclosure and making all topics voluntary. We were certainly not clear on whatorganisations had to disclose.

48

The following comment was made in response to the survey question “Are thedisclosures listed for each topic in the exposure draft complete, relevant andaccurate so as to help understand and communicate an oil and gas organization's
most significant impacts and how it addresses them? If not, please explain which
topics can be improved and how.”(3) Yes, we believe that they are complete and potentially relevant, but not able todetermine whether they are accurate, this is something for assurance todetermine. The main issue is the level of discretion for non-disclosure which isdependent on company internal materiality assessment choices.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

Page 75 of 79

49

The following comment was made in response to the survey question “Are there
disclosures included in any ‘What to report’ section that are not relevant or clear,or that would be challenging to report? If so, which disclosure(s)? Please explain
why and how they could be improved.”(4) No, we believe that all should be disclosed if material. They all appear to bereasonable and measurable. We would like to push back against ‘challenging’criteria – if the topic is relevant and relates to a negative external impact, then thecompany should be required to disclose it and be accountable for it. We
understand that the GRI is not based on a ‘minimum compliance’ philosophy, but
on as full accountability as possible and containing provision for additional
disclosures if necessary – explaining these challenges, limits in the information
provided and developing how things get reported.

EuropeanAccounting
Association
Stakeholder
ReportingCommittee

Belgium

Academic

On behalf ofanorganization,group orinstitution

50

When organizations seek to distinguish themselves as competitors in a market for
responsible businesses, accountability for organizational disclosures is important.
The best proven way to verify that reporting is accurate is through mechanisms
for stakeholder feedback. To that end, disclosure requirements concerning theavailability, structures, and use of effective grievance mechanisms are essential
to ensure the accuracy of organizational reporting on material topics and,correspondingly, the integrity of the GRI Standards. We therefore recommend
expressly requiring disclosures under RBC-4 ("Grievance Mechanisms and Other
Remediation Processes") and RBC-5 ("Mechanisms for Seeking Advice andRaising Concerns"), from GRI 102 (About the Organization), across all sector
standards.

AccountabilityCounselUnited States

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

51

Rreporting on employee training,education etc

Dr Sushil
Kumar
Pattanaik

India

Academic

As anindividual

Dr. Marius
GavrilaLuxembourg

Academic

As anindividual

No assessment scale and why they are feeling low level energentic , somepoints be discussed on outcome based evaluation and reward
52

Need to understand the numbers and the impact.

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36

4. Other comments on the Sector Standards

37

The following comments were submitted during the public comment period for the Universal Standards, between 11 June and 9 September 2020.

38
39

These additional comments fall beyond the scope of the Universal Standards and will be considered as part of the public comment analysis for the GRISector Standard: Oil and Gas.

40

Table 5. Responses to question 10 in the online survey to the Universal Standards exposure draft
Name oforganization orindividualCountry

Stakeholder
group

Submission
type(2) Sector standards are good but from the 1st one I read we cannot see a
specific topic relevant for the sector, it is mainly a previous materiality andaddendum to existing disclosures. I think it would hel to included specific sector
topics and disclosures instead of only prioritizing and complementing existing
topics.

BSD
CONSULTING

BrazilNo response
provided

No response
provided2

I do not agree with Sector Standards included as GRI Standards. It is because
GSSB never set the Sector Standards.

Eko
Sukoharsono

Indonesia

Academic

As anindividual3

The new approach of having companies report on the three types of standards
depending on which sector they are in, is a welcome change and helps toaddresses the concerns of companies who have to report on topics that are not
relevant for their circumstances. Two points: 1) with this approach it will be all themore urgent to update sector standards to ensure they take into account all of
the relevant issues, and 2) there should be no leeway for companies to notreport everything in the sector standards. It should be required to report on all
topic standards listed for each sector - not simply recommended.

Engineers
Without Borders
CanadaCanadaNo response
provided

No response
provided4(3) Sector standards identify and describe a sector’s impacts and stakeholder
concerns from a sustainable development perspective. To the reportingorganizations, it would provide more guidance on the material topics forreporting.

Fuji Xerox (HongKong) Limited

Hong Kong

No response
provided

No response
providedNo.

Comment

1

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5(2)Hope there will be many sector standards soon - as this will help/force
companies to select a more meaningful set of topics

Marjolein
BaghuisNetherlands

Consultant

As anindividual

6(2) Both the Topic and the Sector Standards should be developed taking into
account existing and expected developments in regulatory frameworks andrelated expectations from regulatory bodies and the financial community.
As an illustration, the international shipping sector is one of the most regulated
sectors at a global scale. Therefore, compliance with relevant requirements,
regulations and international standards developed by both the private and public
actors, including national authorities, regulatory bodies and the United Nations,for its sector, represents an expectation of responsible business practice. This isrequested as a prerequisite to obtain and maintain the company’s licence tooperate and it is included in due diligence processes by a wide range ofstakeholders (including by commercial banks/Multilateral Development Banks)
assessing social/environmental risk management systems. Also, in relation toregulatory framework related to the protection of Human Rights, the international
shipping sector is also expected to comply with the ILO MLC, 2006. In
developing sector-specific guidance for the transportation sector, pleaseconsider the above-mentioned point as one of main elements differentiating theinternational shipping sector from other sectors, including the logistics sector.

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

On behalf ofanorganization,group orinstitution

7(6) Generally speaking, this section makes sense. However, it is again slightly
misleading: admitting that a company cannot report on all issues it identifies
seems pointless if the company is then asked to identify issues it has notreported on and why those were not reported on. Essentially this means
reporting on these issues as well, just following two different set of standards forthe ‘reporting’ issues and the ‘non reporting’ issues.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Paia Consulting

SingaporeConsultant

On behalf ofanorganization,

This would be great information indeed, but in reality, there will again be the needto determine a cut-off point. The complete picture that is implied in the phrasing
in lines 2635 (and several times at different places) is not realistic and an
impression that it can be achieved and can therefore be misleading to users of
the report.
8

GRI provides guidance on how organizations can use existing internationalclassification systems to identify the sector(s) they are in and expects
organizations to use GRI Sector Standard(s) that apply to their sectors.

Page 78 of 79

However, it's unclear each Sector Standard (Oil and Gas Sector Standard forexample) applies to which category in the suggested classification systems e.g.
UN ISIC. Suggest GRI to provide a mapping table to match various internationalclassification system with upcoming GRI Sector Standards.

group orinstitution

9

Having been involved with the creation of event organiser sector supplement
there was limited engagement with the sector to encourage uptake so I would
advise this is part of the strategy when deciding what sector standards to focus
on.

Positive Impact
EventsUnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

10(2) 2. More specific information and examples should be given regarding the useof ‘other frameworks’ in order to make appropriate disclosures when there is no
GRI Topic Standard that covers a particular topic i.e. SASB, GRESB, others.

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

3. A targeted list of industry sectors for which industry standards will be released,
as well as their tentative time frame should be provided, including information onwhen they are to be effective. In particular, in the case of high carbon-emission
industries, we would encourage ample time to be provided for transition.
Providing this information would enable additional comparability and discourage
competitive disadvantages arising between sectors.
11(1) The sector standards is highly commendable and reduces subjectivity andunders-statement or overlook of a material topic. The outward focus on impact
on stakeholders is game-changing.

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

12(3) 4) Not having sector standards yet, but already including them soprominently, is really confusing. What happens to the old sector supplements?

ValoraSwitzerland

No response
provided

No response
provided

13

Regarding the sector standards, we consider that they should be developed assoon as possible since in our case as Retail we could give a more correct
approach to the GRI report, as is the case of the SASB methodology that isdelimited by sector.

Walmart deMéxico yCentroamérica

MexicoBusiness

On behalf ofanorganization,group orinstitution

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