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

Item 05 – GSSB Due Process
Adherence Report for the review of
the GRI Universal Standards
For GSSB [information]
Date[Day Month Year]

Meeting

10 June 2021

StatusTo be submitted to the DPOC for review

Project

GRI Universal Standards

Description

GRI Standards and related Interpretations are to be developed and issued in the
public interest and according to due process as defined in the GSSB Due Process
Protocol.
The GSSB Due Process Adherence Report (DPAR) presents an explanation and,
where applicable, evidence of how the Due Process Protocol has been followed
for the review of the GRI Universal Standards.
The DPOC is requested to review the GSSB DPAR and to conclude whether or
not due process has been followed for the review of the GRI Universal Standards.
Password protected resources
Resources to support the evidence of adherence that have not been published in
the public domain have been made available to you via links to an evidence
folder. The evidence folder contains sub-folders, whose titles reflect each Due
Process step sub-heading and are numbered in the order these appear in theDPAR.
Due to personal information contained in these resources, they have beenprotected with a password. T The password to access these resouces will be
provided separately.
Para 15 and 17-34 cover how the Due Process Protocol has been followed forboth the review of the GRI Universal Standards and for the review of GRI’s humanrights-related Standards.

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 2021

The following requirements are not applicable to this project:
Para 9 to 13 (see Formation of Technical Committees and Project Working
Groups).

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1

Adherence with due process
Project

Description

Review of GRI’s
Universal Standards

The GSSB initiated a project to review the GRI Universal Standards, which consist of GRI 101: Foundation 2016, GRI 102:
General Disclosures 2016, and GRI 103: Management Approach 2016.
The primary driver for revising the Universal Standards was to address the recommendations arising from the review of
GRI’s human rights-related Standards. Feedback received from reporting organizations and other stakeholders, as well as
information gathered through reviews of sustainability reports using the GRI Standards, provided further areas of the
Universal Standards to be addressed.
Overall, the project aimed to:
•
•
•
•
•
•
•

integrate the expectation of due diligence into the GRI Standards;
provide greater clarity on key concepts, reporting principles and disclosures in the Universal Standards and ensure
they are aligned with recent developments in the area of responsible business conduct;
assist reporting organizations in understanding the reporting requirements and how they demonstrate compliance ina transparent way;drive consistent application of the GRI Standards;
encourage more relevant and comprehensive reporting for experienced reporting organizations;enable first time reporters and SMEs to more easily apply the GRI Standards;
improve overall usability of the GRI Standards.

The project was split into four work stream areas:••••

Work Stream 1: Human rights and due diligence related disclosures
Work Stream 2: Reporting Principles
Work Stream 3: ‘In accordance’ criteria
Work Stream 4: General disclosures

More information about Work Streams 1 to 4 can be found on pages 3-4 of the project proposal. The project proposal canbe found here.

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Evidence of adherence

Resources

Q3 2018

Project identificationand prioritization

The GSSB agreed in its September 2018 meeting tocommence the review of the GRI Universal
Standards.

Refer to lines 39-41 of the ‘Summary 25-26
September 2018 meeting’.

Para 6 (Basis ofidentification ofpotential new projects)

DPOC assessment
Y N Issue Note

Stakeholder input‘Item 02 – Input for Discussion on GSSB Work
Program 2017-2019’ sets out feedback from thepublic comment process and GSSB members to
inform the finalization of the GSSB Work Program for2017-2019. Item 02 was discussed during the
October 2016 GSSB meeting.
Ahead of this meeting, GSSB members were asked
to provide their individual opinions on priority
Standards to review/ develop, as well as the relative
priority of other work areas for 2017-2019. The GSSB
members prioritized the in accordance criteria andthe materiality concept for review.

During the transition from the GRI Guidelines to the
GRI Standards, the GSSB identified the Reporting
Principles and sections of GRI 102: General
Disclosures, as well as the ‘in accordance’ criteria as
areas that should undergo a revision once themodular structure was in place and experience had
been gained with the implementation of the GRI
Standards.

Refer to lines 12-46 of the ‘Summary 27
October 2016 meeting’.

For comments on the in accordance criteria,
refer to lines 299 (# 6) and 305 (# 1 and # 2)
in ‘Item 02 – Input for Discussion on GSSBWork Program 2017-2019’.
For comments on the materiality concept,
refer to line 305 (# 5) in ‘Item 02 – Input for
Discussion on GSSB Work Program 20172019’.
Refer to the ‘Project background’ section on
page 2 of the ‘Review of GRI’s universal
Standards: Project Proposal’.

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DPOC assessment
Y N Issue Note

The human rights Standards have been prioritized forrevision by stakeholders, the GRI Stakeholder
Council, and the GSSB when they were consulted on
the draft GSSB Work Program 2017-2019.

Refer to the DPAR for the review of GRI’s
human rights-related Standards for
information about stakeholder input on
human rights.

International considerations
The review of GRI’s human rights-related Standards
has been informed by developments in the field ofresponsible business conduct.

Refer to the ‘Project background’ section on
page 2 of the ‘Review of GRI’s universal
Standards: Project Proposal’.

Since 2018, a GRI Technical Committee has beendeveloping recommendations on how to update
GRI’s human rights-related Standards in light ofthese developments, including how thesedevelopments may impact core concepts, principles
and disclosures in the GRI Standards.
The developments in the field of responsible
business conduct and the recommendations arisingfrom the review of GRI’s human rights-relatedStandards resulted in the need for revisions to the
Universal Standards.

Q1 2019

Project
commencement

Para 8 (Development
and approval of a
project proposal)

The GSSB agreed in its September 2018 meeting tocommence the review of the the GRI Universal
Standards. The GSSB requested the Standards
Division to prepare a proposal with the schedule andscope for the Universal Standards.

Refer to lines 39-41 of the ‘Summary 25-26
September 2018 meeting’.

The Standards Division prepared a draft project
proposal for the review of the GRI Universal
Standards, which was discussed and approved

Refer to ‘Item 09 – GSSB Project Proposal
for the Review of GRI’s Universal Standards’
and lines 90-107 of the ‘Summary 7 February
2019 meeting’.

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DPOC assessment
Y N Issue Noteduring the February 2019 meeting. The GSSB did notrecommend any changes during the meeting.

The draft project proposal was shared with the GRI
Board and GRI Stakeholder Council for theircomments. The GRI Board did not recommend anychanges to the proposal. The GRI Stakeholder
Council made a comment specifically in respect ofhuman rights disclosures, but did not provide any
specific feedback on the Universal Standards project.

Refer to the description on the cover page of‘Item 08 – Final Project Proposal for the
Review of GRI’s Universal Standards’, lines
201-202 of the ‘Summary 25-26 March 2019
meeting’, lines 67-71 in ‘Item 02 –Stakeholder Council response to the GSSB’s
Sector Standard Proposals and Proposal for
Review of Universal Standards’, and the
Evidence folder.

The Standards Division presented the GSSB with thefinal project proposal during its March 2019 meeting.
The Standards Division presented the objectives andscope of the project for the review of the GRI
Universal Standards, along with an overview of the
proposed work streams.

Refer to ‘Item 08 – Final Project Proposal for
the Review of GRI’s Universal Standards’
and lines 182-211 of the ‘Summary 25-26
March 2019 meeting’.

The GSSB approved ‘Item 08 – Final Project
Proposal for the Review of GRI’s Universal
Standards’ during its March 2019 meeting.
Notapplicable

Formation ofTechnical
Committees

Not applicable. A Technical Committee was notformed for the review of the GRI Universal
Standards.

Para 9 (Appointmentof TechnicalCommittee)

However, experts have been engaged to provide
technical advice on the:••Refer to lines 203-204 of the ‘Summary 2526 March 2019 meeting’ and listen to minutes
1:36:14-1:37:17 of the recorded Livestream.

labor-related disclosures in GRI 102;
governance-related disclosures in GRI 102;

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Due process stepPara 10 (Advice fromTechnical Committee)

Para 13 (Engagementwith the GSSB)

Evidence of adherence•

Resources

DPOC assessment
Y N Issue Note

incorporation of a required management‘sign-off’ statement into the GRI Standards.

Labor-related disclosures in GRI 102
During its 24-25 September 2019 meeting, the GSSB
advised the Standards Division to organize an expert
group to assess the requirements in Disclosures 1028 and 102-41. The expert group comprised the GSSB
members from the labor constituency andrepresentatives of the ILO and BusinessNZ.

Refer to lines 274-275, 278-279, and 303 ofthe ‘Summary 24-25 September 2019
meeting’.

Governance-related disclosures in GRI 102
During its 24-25 September 2019 meeting, the GSSB
advised the Standards Division to contact
governance experts to assess the need for any
significant changes to the governance-related
disclosures: Disclosures 102-18 to 102-39.

The Standards Division reached out to theInternational Corporate Governance Network (ICGN)
who participated in the review and provided their
feedback.
The Standards Division has incorporated the ICGN
feedback into the proposed amendments to thegovernance disclosures (see ‘Item 04 – Draft GRI
102 Governance disclosures’).

Refer to lines 292-295 and 304-305 of the‘Summary 24-25 September 2019 meeting’.

Refer to lines 67-70 of the ‘Summary 6
February 2020 meeting’.

Refer to lines 78-80 of the ‘Summary 6
February 2020 meeting’ and refer to ‘Item 03– ICGN letter’ for the ICGN feedback.

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Management ‘sign-off’ statement

Not
applicable

Formation of ProjectWorking Groups

Para 11 (Appointmentof Project Working
Group)

Para 12 (Multistakeholder
composition)

During its 24-25 September 2019 meeting, the GSSB
suggested further investigation on the feasibility of arequired management ‘sign-off’ statement into the
GRI Standards.

Refer to line 329 of the ‘Summary 24-25
September 2019 meeting’.

The Standards Division has therefore interviewed arange of stakeholders including those representing
regulators, stock exchanges, the accountancy andaudit profession, and policymakers and performed
further research. Based upon this input theStandards Division made proposals to the GSSB for
the consideration of incorporating a management
statement (see ‘Item 04 – Universal Standards:
management statement’).

Refer to lines 6-9 of ‘Item 04 – Universal
Standards: management statement’.

Not applicable. A Project Working Group was notformed for the review of the GRI Universal
Standards.

However, a sub-committee of four GSSB members
was convened to provide overall advice and direction
on all areas of the project, with the GRI TechnicalCommittee on Human Rights Disclosure providing
specific input for:••

Refer to lines 58-60 in ‘Item 08 – Final
Project Proposal for the Review of GRI’s
Universal Standards’ and lines 407-408 in the‘GRI Universal Standards public comment –Explanatory memorandum for the exposure
draft’.

Work Stream 1: Human rights and due
diligence related disclosures
Work Stream 2: Reporting Principles

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Q1 2019 toQ2 2020

Due process step

Evidence of adherence

Para 13 (Engagementwith the GSSB)

A balance of multi-stakeholder constituencies is not
required for a GSSB Sub-Committee, but it should be
noted that the labor, business enterprise, andmediating institutions were represented, along with
the Vice-chair of the GSSB.

Development ofproposed Standards

Public forum, roundtable, consultation paper,
field test

Para 14 (Public forum,roundtable,
consultation paper,
field test)

The Standards Division conducted two field tests togather feedback from stakeholders before the revised
content was exposed for public comment:••

Resources

DPOC assessment
Y N Issue Note

Revisions to GRI 102 – between 22
November and 4 December 2019.
Revisions to GRI 101 and GRI 103 –between 24 February and 9 March 2020.

The Standards Division informed the GSSB about
these field tests during its November 2019 andFebruary 2020 meetings. The GSSB made nocomments about the field tests.

21 November 2019 – listen to minutes
21:03-23:51 of the recorded Livestream.

In addition to sharing the draft content with external
stakeholders, the content of GRI 101 and GRI 103
was also submitted to the GSSB for its review.

6 February 2020 – refer to lines 41-43 of the‘Summary 6 February 2020 meeting’ andlisten to minutes 14:31-15:44 of the recorded
Livestream.
Refer to the Evidence folder for this item.

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DPOC assessment
Y N Issue Note

The Standards Division gathered results via email
from eight stakeholders and seven GSSB memberson the revisions to GRI 101 and GRI 103, and fromsix stakeholders and the GSSB sub-committee on
the revisions to GRI 102.

During the May 2020 GSSB meeting, the Standards
Division explained its proposed approach toengagement during the public comment period. This
included the public comment survey, webinars, andregional engagements.

Refer to lines 194-202 of the ‘Summary 20
May 2020 meeting’ and listen to minutes
1:43:05-1:47:27 of the recorded Livestream.

The engagement included:••

Regional workshops held in Africa, Greater
China, Hong Kong, Latin America, North
America, Singapore, and Taiwan in July andAugust 2020.
Public webinars held on 24 June and 9 July
2020.

Interaction with the GSSB on the exposure draft
The proposed revisions to the Universal Standards
were discussed by the GSSB during its in-person
meeting in September 2019, and during public andprivate sessions organized between August 2019and April 2020.

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DPOC assessment
Y N Issue Note

The exposure draft was submitted for GSSB approvalin its 20 May 2020 meeting.

Refer to lines 404-406 of the ‘GRI Universal
Standards public comment – Explanatory
memorandum for the exposure draft’.

Ahead of this meeting, the Standards Division shared
the exposure draft with the GSSB for their review by
email on 6 May 2020. The GSSB members wereasked to send any questions, concerns, or feedbackon the exposure draft by email by 15 May 2020.

Refer to the cover page of ‘Item 02 –Exposure draft of Universal Standards: GRI
101, GRI 102, and GRI 103’.

The Standards Division addressed the questions andcomments regarding the proposed changes to the
Universal Standards shared by GSSB members prior
to the meeting, and circulated a summary among
GSSB members. Some comments had beenaddressed with a written explanation, others wereopen for discussion in the meeting, and some had
prompted the Standards Division to propose
additional changes to the exposure draft.

Refer to lines 57-61 of the ‘Summary 20 May
2020 meeting’ and the Evidence folder.

The Standards Division presented the proposedchanges to the exposure draft made in response to
GSSB feedback during the May 2020 meeting, andinvited further discussion from the GSSB. The
Standards Division responded to the discussion
points raised in the meeting and suggested to makesome additional changes to the exposure draft before
the launch of the public comment period.

Refer to lines 73-174 and 208-215 of the‘Summary 20 May 2020 meeting’ and listen
to minutes 08:40-1:33:19 of the recorded
Livestream.

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Voting on the approval of the exposure draft

Para 15 (Voting on theapproval of an
exposure draft)

Q1 2019, andQ2 and Q3
2020

Interaction with the
GRI Board and the
GRI Stakeholder
CouncilPara 16 (Interaction
with the GRI Board
during thedevelopment andfinalization of aStandard)

The Standards Division presented the exposure draftof the GRI Universal Standards to the GSSB during
its May 2020 meeting for approval. The GSSB
approved ‘Item 02 – Exposure draft of Universal
Standards: GRI 101, GRI 102, and GRI 103’ forpublic comment during that meeting.

Refer to lines 175-184 of the ‘Summary 20
May 2020 meeting’ and listen to minutes
1:34:17-1:35:30 of the recorded Livestream.

Proposal to start a new project
The GRI Board and GRI Stakeholder Council wereinvited to comment on the draft project proposal forthe review of the GRI Universal Standards. The GRI
Board did not recommend any changes to the
proposal. The GRI Stakeholder Council did notprovide any specific feedback on the Universal
Standards project. However, they did make acomment specifically in respect of human rights
disclosures.

Refer to the description on the cover page of‘Item 08 – Final Project Proposal for the
Review of GRI’s Universal Standards’, lines
201-202 of the ‘Summary 25-26 March 2019
meeting’, lines 67-71 in ‘Item 02 –Stakeholder Council response to the GSSB’s
Sector Standard Proposals and Proposal for
Review of Universal Standards’, and the
Evidence folder.

Development and finalization of Standards
Para 17 (Commentsought from the GRI
Board and the GRI SC
on proposals to start
new projects, andduring development
and finalization of aStandard)

The GRI Board and GRI Stakeholder Council werealso invited to provide feedback on the exposure
draft of GRI Universal Standards.

Refer to the Evidence folder for these items.

The GRI Board and the GRI Stakeholder Council did
not provide feedback during the public comment
period.

Para 18 and Para 19(Consideration ofcomments from thePage 12 of 17

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DPOC assessment
Y N Issue Note

The exposure draft of the Universal Standards: GRI
101, GRI 102, and GRI 103 was published for publiccomment on the GSSB website. Any interested party
was able to submit comments on the exposure draft
using an online public comment survey. The survey
contained questions about the draft for stakeholders
to respond to, and included a space for providing
other comments.

Refer to ‘GRI Universal Standards: GRI 101,
GRI 102, and GRI 103 – Exposure draft’ andthe Evidence folder for screenshots of thewebsite during the public comment period,
and a copy of the exposure draft and thesurvey questions.

An explanatory memorandum was posted alongside
the exposure draft. The explanatory memorandum
set out the objectives for the review of the GRI
Universal Standards, the significant proposals
contained in the Universal Standards exposure draft,
and a summary of the GSSB’s involvement andviews on the development of the exposure draft.

Refer to ‘GRI Universal Standards publiccomment – Explanatory memorandum for the
exposure draft’ and the Evidence folder for a
copy of the explanatory memorandum.

The Standards Division proposed an exposure periodof 90 days for the exposure draft of the GRI Universal
Standards. The GSSB asked why the exposure
period is longer than the minimum requirement of 60days. The Standards Division explained that a 90-day
public comment period would be appropriate for thefollowing reasons:

Refer to lines 194-195 of the ‘Summary 20
May 2020 meeting’ and listen to minutes
1:39:38-1:39:56 and 1:47:39-1:50:13 of therecorded Livestream.

GRI Board and the
GRI SC)Q2 and Q3
2020

Public exposure
Para 20 (Public
exposure andexplanatory
memorandum)

Para 21 (Exposure
period)•Give potential respondents the time toimmerse themselves with the content andcomplete the survey questions, considering

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DPOC assessment
Y N Issue Notethe large volume of content, and summer
period in the northern hemisphere.
Have the opportunity to do moreengagements over a sustained period.

The GSSB raised no further comments regarding thelength of the exposure period.

The public comment period ran from 11 June to 9
September 2020.

Comments on the exposure draft
Para 22 (Commentson the exposure draft
are public)Q3 2020 toQ2 2021

Consideration of
respondents’comments on an
exposure draft

Para 23 (Analysis ofcomments on
exposure draft)

Public comment feedback was posted on the GRI
website, together with the name of the respondent,
the organization, the country, and the stakeholder
group. It is also indicated whether the representationis personal or organizational.

The full set of public feedback for the publiccomment is available here.

The Standards Division reviewed and analyzed every
comment made on the exposure draft.
The draft version of the GSSB Basis for Conclusions
for the public comment, with a summary of significant
issues raised by respondents, and an explanation of
why significant changes recommended by a
respondent(s) were, or were not accepted, wasshared with the GSSB in advance of its meeting on
10 June 2021.

The draft version of the GSSB Basis forConclusions for the public comment isavailable here.

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Para 24 (GSSB
consideration ofcomments on
exposure draft)

The Standards Division presented a summary of
public feedback and resulting changes to the draft
Universal Standards to the GSSB over the course of
11 meetings between October 2020 and April 2021.
The GSSB provided directional advice to address the
public comment feedback or changes to the draft
Standards.

Refer to:
•
•
•
•
•
•
•
•
•
•

DPOC assessment
Y N Issue Notelines 92-102 of the ‘Summary of 22
October 2020 meeting’ and listen to therecorded Livestream.
lines 11-126 of the ‘Summary of 5
November 2020 meeting’ and listen to therecorded Livestream.
lines 29-135 of the ‘Summary of 19
November 2020 meeting’ and listen to therecorded Livestream.
lines 19-121 of the ‘Summary of 3
December 2020 meeting’ and listen to therecorded Livestream.
lines 18-116 of the ‘Summary of 10
December 2020 meeting’ and listen to therecorded Livestream.
lines 29-63 of the ‘Summary of 21
January 2021 meeting’ and listen to therecorded Livestream.
lines 55-63 of the ‘Summary of 25
February 2021 meeting’ and listen to therecorded Livestream.
lines xx-xx of the ‘Summary of 04 March
2021 meeting’ and listen to the recorded
Livestream.
lines xx-xx of the ‘Summary of 23 March
2021 meeting’ and listen to the recorded
Livestream.
lines xx-xx of the ‘Summary of 25 March
2021 meeting’ and listen to the recorded
Livestream.

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Q2 2021

Approval ofStandard andconsideration of theneed for re-exposure

DPOC assessment
Y N Issue Notelines xx-xx of the ‘Summary of 29 April
2021 meeting’ and listen to the recorded
Livestream.

Section to be finalised after the approval of the GRI
Universal Standards

Para 25 (Revised
content of the
exposed Standard)Para 26 (Advice of the
Head of the Standards
Division on due
process)

Para 27 (Voting on theapproval of the final
revised content of an
exposed Standard)Para 28 (Voting on theneed for re-exposure)

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Para 29 (Explanatory
memorandum
accompanying the reexposure draft)

Para 30 (Effective
date for theapplication of the final
Standard)

Para 31 (GSSB basis
for conclusions)
Q2 2021

Withdrawal of aStandard

Section to be finalised after the approval of the GRI
Universal Standards

Para 32 (Withdrawal
of a Standard)
Q3 to Q4
2021

Release of the final
Standard

Section to be finalised after the approval of the GRI
Universal Standards

Para 33 (Reporting on
due process)Para 34 (Conclusion
DPOC on due
process)

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