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

Item 05 – GSSB Work Program
2020-2022 – Public comment feedback
For GSSB approval
Date

1 September 2020

Meeting

15 September 2020

Description This document presents the comments received on the exposure draft of the
GSSB Work Program 2020-2022. The exposure draft was made available forpublic comment from 23 April to 23 June 2020

This document has been prepared by the GRI Standards Division. It is provided as a convenience toobservers at meetings of the Global Sustainability Standards Board (GSSB), to assist them infollowing the Board’s discussion. 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 20201

1

Comments received from:2

Institutions

3

Email

Page

4

1. Deakin University

35

2. Engineers Without Borders Canada

106

3. FBRH Consultants

13

7

4. Fundacion Once

25

8

5. Indorama

28

9

6. Institution of Occupational Safety and Health (IOSH)

29

10

7. IUCN (International Union for Conservation of Nature)

37

11

8. Metagas

3912

9. Norges Bank Investment Management (NBIM)

42

13

10. PricewaterhouseCoopers (PWC)

45

14

11. r3.046

15

12. Sustainability Accounting Standards Board (SASB)

52

16

13. Schiphol Group58

17

14. SECH

59

18

15. Social Responsibility Asia (SR Asia)

60

19

16. Tata Consultancy Services

61

20

17. World Benchmarking Alliance64

21

Private

22

Email

Page

23

18. J Robert Gibson

68

24

19. Alodia Ishengoma

112

25

20. Ignatius Kauvee

113

26

21. Ertan Kucukyalcin

114

27

22. Jeff Wright

115

2

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Email 129

From:

Ella Robinson, Deakin University

30

Sent on:

Tuesday June 23, 2020

31

To:

Standards

32

Cc:

Gary Sacks; Sally Mackay; Ana Renker-Darby

33

Subject:

Public Comment Revised GSSB Work Program 2020-2022

34

Dear Barbara Strozzilaan,

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36
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Please find attached a document outlining a submission to the ‘Draft GSSB Work Program 20202022’ on behalf of INFORMAS (International Network for Food and Obesity / Non-communicable
Diseases (NCDs) Research, Monitoring and Action Support) and the Global Obesity Centre(GLOBE), Deakin University.

39
40
41

In this submission, we make the case for the GSSB to prioritise the ‘Food Processing’ sector(currently in Priority Group 2) in the implementation of the Sector Program and outline proposed
domains to be included within the sector standards.

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43
44
45
46
47

This proposal is in line with strong evidence demonstrating the high impact of the Food Processing
sector on population health, as well as the Food Processing sector’s links with overconsumption andproduction. We note that sector disclosures for Agricultural and Fishing have recently been
established, and, as part of examining the important role of food systems, the Food Processing
sector is the next logical step to consider. Prioritising the Food Processing sector as the next focus
area is a sensible progression in the scheme of the GSSB work program.

48
49
50
51
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We see the GRI’s role in promoting disclosure and transparency from the Food Processing sector as
fundamental to increasing corporate accountability and improving corporate performance withregards to nutrition and health issues. This is likely to have wide ranging implications for populationand environmental health and will encourage progress in achieving targets within the United Nations
Sustainable Development Goals.

53

Yours sincerely,

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55

Ella Robinson, Sally Mackay, Ana Renker-Darby and Gary Sacks, on behalf of INFORMAS and
GLOBE

3

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

RE: Submission to the “Draft GSSB Work Program 2020-2022”
Prioritising the ‘Food Processing’ sector within the implementation of the GRI Sector Program
INFORMAS (International Network for Food and Obesity / Non-communicable Diseases (NCDs) Research,
Monitoring and Action Support) is a global network of public-interest organisations and researchers thataims to monitor, benchmark and support public and private sector actions to increase healthy foodenvironments and reduce obesity and NCDs and their related inequalities (www.informas.org). The
Global Obesity Centre (GLOBE) is a World Health Organization Collaborating Centre for Obesity
Prevention, situated within the Institute for Health Transformation at Deakin University, Melbourne,
Australia. Our vision is to catalyze improvements in population health, with a focus on obesity, throughinnovative research that empowers people and enables healthier environments(www.globalobesity.com.au).
In this submission, INFORMAS and GLOBE make the case for the GSSB to prioritise the ‘Food Processing’sector (currently in Priority Group 2) in the implementation of the Sector Program and outline proposed
domains to be included within the sector standards.
Justification
Unhealthy diets and related non-communicable diseases are some of the most pressing issues facing theworld’s population. Recent research has indicated that unhealthy diet is the primary risk factor for
global mortality and morbidity, overtaking other key risk factors such as tobacco and alcohol (1). At thesame time, low- and middle-income countries (LMIC) are faced with a complex double burden of
malnutrition whereby undernutrition and stunting co-exist with rising rates of obesity and related NCDs
(2).
The dominant driver of unhealthy diets and related non-communicable diseases are unhealthy foodenvironments. Over the past several decades, food environments have become increasingly dominatedby processed and packaged foods which are often high in energy and risk nutrients like sodium,saturated fat and added sugar (3). This increasingly unhealthy and energy dense food supply is directly
correlated with a rise in average body weight in global analyses of low, middle and high income
countries (4). Moreover, processed foods may also contribute to undernutrition and stunting throughreplacing more nutritious food options, particularly in low- and middle-income countries where theconsumption of these foods is common in young children and infants (5). The Food Processing sector isalso responsible for significant food loss and waste at multiple stages along the food supply chain,including production, handling and storage, processing and packaging, and distribution of marketing.

4Reducing food loss and waste can contribute to the alleviation of food insecurity and over-production
globally (6).
Food Processing companies play a key role in driving unhealthy food supplies and associatedmalnutrition, and also contribute to poor environmental outcome through the overconsumption andover-production of food. Overconsumption is associated with environmental degradation, unsustainable
water use and land use, waste and carbon emissions (7). Reducing food loss and waste can contribute tolowering greenhouse gas emissions, air and water pollution and improving biodiversity while continuing
to feed the world’s population (8). Furthermore, highly processed foods are dependent on anabundance of cheap raw materials, which are often farmed for exportation rather than for consumption
locally, and are typically reliant on emission heavy transportation (9). These factors contribute to climatechange and present a serious threat to sustainable development.
Investors are also aware of the risks associated with investment in Food Processing companies (10, 11).
These include growing regulatory risks associated with intervention from governments in the area ofmarketing to children, labelling and taxation (particularly for sugar-sweetened beverage companies).
Reputational risks to food processing companies also exist, with public advocacy and healthorganizations increasingly shaming companies for their poor performance in the area of health (12).
Furthermore, changing consumer trends and demand for healthier products may be a risk for a numberof Food Processing companies that are ill-equipped to adapt.
As the manufacturers and producers of food, the Food Processing sector clearly has an important role inshaping the health of the food supply, reducing over-production and improving the healthiness of foodenvironments. To help improve population diets, the World Health Organization recommends the Food
Processing sector implement policies and actions to limit saturated fat, trans fat, free sugars and salt inexisting and new products, develop and provide affordable, healthy and nutritious products, provide
consumers with adequate nutrition information and practice responsible marketing (particularly tochildren and adolescents) (13). Whilst companies in the food sector have taken steps to acknowledge
their role in addressing unhealthy diets and obesity, there is strong evidence demonstrating that foodindustry policies and actions related to nutrition have been weak and inadequate to date (14-19).
As part of progressing health and environmental goals within a sustainable development agenda, it isessential that the Food Processing sector has robust sustainability reporting standards that are sector
specific. Considering the wide uptake of the GRI, we see sector specific standards for Food Processing
companies as playing an important role in improving company performance in the area of nutrition andhealth and sustainable practices.
We note that sector disclosures for Agricultural and Fishing have recently been established, and, as partof examining the important role of food systems, the Food Processing sector is the next logical step toconsider. Prioritising the Food Processing sector as the next focus area is a sensible progression in thescheme of the GSSB work program.
The need for reliable and widely applied sustainability reporting
There is currently a lack of consistent disclosure around nutrition and health related metrics for foodprocessing companies. The GRI’s previous G4 sector standards for the Food Processing sector included anumber of disclosure indicators related to nutrition (labelling, reformulation, marketing); however,these were superseded by the GRI standards and so the sector specific disclosure indicators no longer
apply. Providing a sustainability reporting framework for food processing companies to disclose theirpolicies and practices with regards to nutrition and health in a way that has wide uptake across the5sector will be central to increasing corporate accountability in addressing these issues. There are
initiatives that are currently working to increase nutrition related disclosure and accountability of foodsector companies, notably the Access to Nutrition Initiative (21) and the BIA-Obesity (Business Impact
Assessment – Obesity and population nutrition) tool (20), led by INFORMAS, which benchmarks major
food and beverage manufacturers (and supermarkets) on their nutrition related policies and practices.
However, the lack of agreed international standards on corporate reporting regarding nutrition andhealth may encourage other initiatives to emerge, which is likely to lead to confusion and dilution of key
messaging around nutrition and health. This is also likely to be cumbersome for Food Processing
companies. We see the GRI sector standards as an opportunity for a reporting framework that has wide
adoption across companies, meaning sustainability reporting in the area of nutrition and health iscomparable across the Food Processing sector.
Proposed disclosures for the Food Processing sector
We propose a set of Food Processing sector standards in line with those developed by INFORMAS as
part of their BIA-Obesity tool and broader program of work to monitor the food industry 1. These areheavily informed by the methodology used by the Access to Nutrition Initiative, a global benchmarking
initiative that assesses food and beverage manufacturer policy and practice with regards to nutrition(21). Additionally, the disclosure areas are based on World Health Organization recommendations (13,22, 23) and other relevant public health evidence (24-28).
Six key domains are identified by INFORMAS as having the maximum impact on nutrition and health. A
description of the domains and their key indicators are provided in the table below.
DomainCorporate strategy

Description
Overarching policies andcommitments to addressing
obesity and improving populationlevel nutrition

Product formulation

Policies and commitments
regarding product development
and reformulation to reduce
nutrients of concern (i.e., sodium,
free sugars, saturated fat, transfat) and energy content/portion
size
Policies and commitments
regarding the disclosure andpresentation of nutrition
information product packaging
and online

Nutrition labelling

Key indicators- Commitment to nutrition and health incorporate strategy- Reporting against nutrition and healthobjectives and targets- Alignment with key international healthpriorities- Targets and actions related to reduction of
sodium, free sugars, saturated fat, transfat, and portion size/energy content
where relevant across the portfolio- Position in relation to government
policy/initiatives on product reformulation-

Commitment to implement front-of-packand back-of-pack nutrition labelling
Provision of online nutrition information
Responsible use of nutrition and healthclaims1

We note that the GRI universal standards already include topics related to Waste, Water and Effluents,
Biodiversity, Emissions, Packaging and other environmental issues affecting the Food Processing sector
and thus focus our proposed standards on health topics.

6

Product and brandpromotion

Product accessibility

Policies and commitments for
reducing the exposure of children(aged <18) and adults topromotion of ‘less healthy’foods/brands
Policies and commitments related
to the availability and affordabilityof healthy compared with ‘lesshealthy’ foods-

Broadcast and non-broadcast media policy
Use of marketing techniques that appeal
to children (e.g., cartoon characters)-

Increasing proportion of healthy products
across portfolio (e.g., % change in volumeof health compared with ‘less healthy’
products)
Increasing availability of healthy products,
across the portfolio or in certain settings(e.g., schools)
Position in relation to a tax on sugar
sweetened beverages
Disclosure and transparency of relevant
relationships
Accessibility of relevant information-

Relationships withother organisations

Policies and commitments related
to support provided to externalgroups (e.g., professional
associations, researchorganisations, researchorganisations, community, andindustry groups) related to healthand nutrition-

Within each domain, companies should be asked to provide specific, measurable and time bound details
on policies and actions where appropriate.
Other changes
We also suggest that as part of the development of ‘Food Processing’ sector standards, the name ischanged to ‘Food and Beverage Processing’ to better reflect the sector as a whole.

7

References1.
Afshin A, Sur PJ, Fay KA, Cornaby L, Ferrara G, Salama JS, et al. Health effects of dietary risks in
195 countries, 1990&2013;2017: a systematic analysis for the Global Burden of Disease Study 2017. The
Lancet. 2019;393(10184):1958-72.
2.
World Health Organization. The double burden of malnutrition. Policy brief. Geneva: WHO;
2017.
3.
Swinburn B, Sacks G, Hall K, et al. The global obesity pandemic: Shaped by global drivers andlocal environments. The Lancet. 2011;378(9793):804-14.
4.
Vandevijvere S, Chow CC, Hall KD, Umali E, Swinburn BA. Increased food energy supply as amajor driver of the obesity epidemic: a global analysis. Bulletin of the World Health Organization.
2015;93(7):446-56.
5.
Swinburn BA, Kraak VI, Allender S, Atkins VJ, Baker PI, Bogard JR, et al. The Global Syndemic of
Obesity, Undernutrition, and Climate Change:The Lancet Commission report. The Lancet.
2019;393(10173):791-846.
6.
Lipinski B, Hanson C, Waite R, Searchinger T, Lomax J, Kitinoja L. Reducing Food Loss and Waste:
Creating a Sustainable Food Future (Installment two). Washington D.C.: World Resources Institute; 2013.
7.
Willett W, Rockström J, Loken B, Springmann M, Lang T, Vermeulen S, et al. Food in the
Anthropocene: the EAT-Lancet Commission on healthy diets from sustainable food systems. The Lancet.
2019;393(10170):447-92.
8.
Shafiee-Jood M, Cai X. Reducing Food Loss and Waste to Enhance Food Security andEnvironmental Sustainability. Environmental Science & Technology. 2016;50(16):8432-43.
9.
Ministry of Health of Brazil. Dietary guidelines for the Brazilian population 2nd Edition. Brazil:
Ministry of Health of Brazil; 2014.
10.
Credit Suisse Research Institute. Sugar: Consumption at a crossroads. Credit Suisse; September
2013.
11.
Access to Nutrition Initiative. Access to Nutrition Initiative Investor Statement 2020. Available
from: http://accesstonutrition.org/investor-signatories/.
12.
Ethical Investment Research Services (EIRIS). SEE risk briefing: Obesity concerns in the food andbeverage industry. London: EIRIS; 2006.
13.
World Health Organization. Global Strategy on Diet, Physical Activity and Health. Geneva: WHO;
2004.
14.
Moodie R, Stuckler D, Monteiro C, Sheron N, Neal B, Thamarangsi T, et al. Profits andpandemics: prevention of harmful effects of tobacco, alcohol, and ultra-processed food and drink
industries. Lancet (British edition). 2013;381(9867):670-9.
15.
Sacks G, Robinson E, for INFORMAS. Inside our Food and Beverage manufacturers: assessmentof company policies and commitments related to obesity prevention and population nutrition.
Melbourne: Deakin University; 2018.
16.
Sacks G, Robinson E, for INFORMAS. Inside our Quick Service Restaurants: assessment ofcompany policies and commitments related to obesity prevention and population nutrition. Melbourne:
Deakin University; 2018.
17.
Sacks G, Robinson E, for INFORMAS. Inside our Supermarkets: assessment of company policies
and commitments related to obesity prevention and population nutrition. Melbourne: Deakin
University; 2018.
18.
Kraak VI, Swinburn B, Lawrence M, Harrison P. An accountability framework to promote healthy
food environments. Public Health Nutrition. 2014;17(11):2467-83.

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19.
Kraak VI, Rincón-Gallardo Patiño S, Sacks G. An accountability evaluation for the International
Food & Beverage Alliance's Global Policy on Marketing Communications to Children to reduce obesity: A
narrative review to inform policy. Obesity Reviews. 2019;20(S2):90-106.
20.
Sacks G, Vanderlee L, Robinson E, Vandevijvere S, Cameron AJ, Ni Mhurchu C, et al. BIA-Obesity(Business Impact Assessment—Obesity and population-level nutrition): A tool and process to assessfood company policies and commitments related to obesity prevention and population nutrition at thenational level. Obesity Reviews. 2019;0(0).
21.
Access to Nutrition Initiative. Access to Nutrition Index: Global Index 2018. Available from:https://www.accesstonutrition.org/sites/gl18.atnindex.org/files/resources/atni_report_global_index_20
18.pdf.
22.
World Health Organization. Global Action Plan for the prevention and control of noncommunicable diseases 2013-2020. Geneva: WHO; 2013.
23.
World Health Organization. Set of recommendations on the marketing of foods and nonalcoholic beverages to children. Geneva: WHO; 2010.
24.
Sacks G, Mialon M, Vandevijvere S, Trevena H, Snowdon W, Crino M, et al. Comparison of foodindustry policies and commitments on marketing to children and product (re)formulation in Australia,
New Zealand and Fiji. Critical Public Health. 2015;25(3):299-319.
25.
Sacks G, et al. A proposed approach to monitor private-sector policies and practices related tofood environments, obesity and non-communicable disease prevention. Obesity Reviews. 2013;14 Suppl
1:38-48.
26.
Kraak V, Englund T, Misyak S, Serrano E. Progress Evaluation for the Restaurant Industry
Assessed by a Voluntary Marketing-Mix and Choice-Architecture Framework That Offers Strategies to
Nudge American Customers toward Healthy Food Environments, 2006–2017. International Journal ofEnvironmental Research and Public Health. 2017;14(7):760.
27.
Charlton EL, Kähkönen LA, Sacks G, Cameron AJ. Supermarkets and unhealthy food marketing:
An international comparison of the content of supermarket catalogues/circulars. Preventive Medicine.
2015;81:168-73.
28.
Cameron AJ, Sayers SJ, Sacks G, Thornton LE. Do the foods advertised in Australian supermarket
catalogues reflect national dietary guidelines? Health Promotion International. 2017;32(1):113-21.

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56

Email 257

From:

Jeff Geipel, Engineers Without Borders Canada

58

Sent on:

Tuesday, June 23, 2020

59

To:

Standards

60

Cc:

Kyela de Weerdt

61

Subject:

Public Comment Revised GSSB Work Program 2020-2022

62

Hello,

63

Please see our attached submission regarding GSSB's Work Program for 2020-22.

64

Please do not hesitate to reach out if you have any questions or if you feel we can be of any help.

65

Best,

66

Jeff Geipel

10June 23, 2020
Dear Global Sustainability Standards Board,
We at the Mining Shared Value initiative of Engineers Without Borders Canada greatly appreciate theopportunity to provide input on the GSSB's revised Work Program for 2020-2022.
For your background information, we are a non-profit initiative that works to improve the development
impacts of mining activity through increasing local procurement of goods and services by the sector in
the host countries and communities that choose to host mineral extraction. In most cases procurement
spending is the single largest payment that an operating mine will make over its life cycle – often morethan taxes, salaries, wages and community investment combined. We believe in the power of reportingto drive sustainability performance in corporations. With the German development agency GIZ wecreated the Mining Local Procurement Reporting Mechanism (LPRM), to standardise how mining
companies report on their local procurement efforts and results. In terms of the GRI, we have been incontact with the Secretariat for several years now, and most recently have been in touch with Pamela
Carpio and her team providing feedback on the Oil, Gas and Coal Sector Standard.
Our comments on the GSSB's revised Work Program for 2020-2022 are brief, but focus on the need toensure mining is one of the first Sector Standards to be updated. We understand that with limited
resources, not every sector mentioned in the Work Program’s four priority groups can be addressed
immediately. However, we would like to lay out the case for mining to be one of the first sectors that
the GSSB prioritises in its Sector Programme.
First, since the launch of the last Mining & Metals Sector Supplement, other reporting systems in use bymining companies have arrived or expanded in scope. The Extractive Industries Transparency Initiative(EITI) launched its 2019 Standard last year which has expanded to include issues such as genderdisaggregated employment data, and environmental impacts. In addition, the Sustainability AccountingStandards Board (SASB) now has a Metals and Mining Standard, launched in 2018. There are also othersustainability frameworks gaining prominence such as the Initiative for Responsible Mining Assurance(IRMA) Standard, and the Responsible Mining Index (RMI). The Responsible Mining Foundation, whichmakes the RMI, relies heavily on public reporting in its assessment of companies. For these reasons,
there is a real need for the GRI to both adjust its mining standard to meet current sector developments,
but also to ensure it is collaborating with other institutions guiding reporting to avoid a scattered set of
conflicting standards. As the most commonly used reporting framework across the mining industry,
there is a genuine risk that if the GRI waits too long to update its reporting guidance in mining,
opportunities to harmonise reporting across so many standards and industry associations will be missed.

365 Bloor Street East, Suite 2000
Toronto, ON M4W 3L4
CanadaPhone +1.416.481.3696
Web www.miningsharedvalue.com
Twitter @ewb_msv

11In addition, the impact of the COVID-19 pandemic will position mining to become an even greater
proportion of the economic activity of many developing countries, particularly in Africa. Regrettably, thenegative economic impacts of the pandemic and the travel restrictions that have come with it, meanthat sectors like tourism will have reduced activity for years. As such, mining as a sector should beprioritised due to its disproportionate importance in many of the world’s least developed countries atthis challenging time.
Finally, while the world is currently focussing on one crisis above all else, the climate crisis continues toescalate. While reducing consumption needs to be the ultimate goal, minerals are required in large
volumes for the production of technologies required in the green transition. These technologies include
power generation such as wind power, and batteries. The World Bank’s report “Minerals for Climate
Action: The Mineral Intensity of the Clean Energy Transition” provides useful background on the scale ofmining that will be required for this transition.
For all reasons listed here, we argue that mining as a sector should be one of the most prioritised
sectors in the GSSB’s workplan. Finally, having also provided feedback on the Oil, Gas and Coal standard,
we would also like to reiterate the position that if the coal standard is to be focused on the extraction ofcoal, rather than its burning for electricity, or use in steel manufacturing for example, that this miningspecific aspect of coal activity should be covered in a general mining standard, rather than a separate
coal mining standard. Because the mining process for coal is similar to that of other minerals, creating aseparate standard would cause confusion.
Thank you for the chance to contribute to this important work and we look forward to hearing about thenext steps in finalising the Work Program. Do not hesitate to reach out if we can provide further
information, or suggested contacts. We look forward to hearing from you.
Sincerely,

Jeff Geipel
Managing Director – Mining Shared ValueEngineers Without Borders Canada
jeffgeipel@ewb.ca

365 Bloor Street East, Suite 2000
Toronto, ON M4W 3L4
CanadaPhone +1.416.481.3696
Web www.miningsharedvalue.com
Twitter @ewb_msv

12

67

Email 3

68

From:

Simon Pitsillides, FBRH Consultants

69

Sent on:Wednesday, May 13, 2020

70

To:

Standards

71

Cc:

Shivani Rajpal; Training and Coaching72

Subject:

Proposed focus for GSSB - Accelerating positive change

73

Dear GRI Standards Division Team,74
75

Thank you for inviting me to help determine the areas that the Global Sustainability Standards Board(GSSB) should focus on over the next three years.

76
77
78
79
80

My name is Simon Pitsillides of FBRH Consultants, a GRI Certified Training partner for the UK.
Besides sustainability I have a strong background in strategy and I am a Fellow of the Chartered
Institute of Marketing. The reason I mention this is because I firmly feel that the GSSB should take astrategic approach with the GRI Standards to help tackle the many serious challenges we are facingin our world.

81

What is material for every company/ organisation in our world today?

82
83“Around 90% of global economic activity is the result of small and medium enterprises, so we know
we cannot achieve our goal of sustainable development without them”.

84

Tim Mohin, GRI’s new Chief Executive, Interview - SustainCase

85
86

In view of the above percentage we should all focus on ensuring that the SMEs start taking solid
focused sustainability action.

87

Proposed solution - GRI should provide a reporting option that Accelerates Positive Change (ACP)

88
89
90

A GRI Standards reporting option that is designed to accelerate positive change will go a long way inhelping companies understand and take action on the broader issue of sustainability outlined above.
Focusing on what is of paramount importance in our world today is material.

91
92
93
94

For example, reporters using this option would be required to report and take action using the two
GRI Assessment Standards (308, 414) which will have a multiplier effect. Furthermore a requirement
to report using 201-1 and 203 will help reporters demonstrate the actions they are taking tosupport the societies they rely on for growth and profit.

95
96
97
98

Most importantly, I propose that this reporting option is named "The GRI-ActionPlus reporting
option". A GRI-ActionPlus logo on a report cover will enable businesses/organisations todemonstrate, through their GRI Sustainability Report and subsequent communication, that they arepart of a positive chain reaction that is accelerating positive change around the globe.

99

Attached is a short interactive presentation that details my proposals.

100

I remain at your disposal.

101

Kind regards

102

Simon

13

May 2020

years

June 201919

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

Presentation: Simon Pitsillides (FIEMA, FCIM, MBA)

Materiality and the Sustainability
Challenges of Today
Accelerating positive change through a new
GRI Action Plus Reporting Option

ENTER

EXIT

Full Screen

www.fbrh.co.uk

www.sustaincase.com
14

2“Around 90% of global economic activity is theresult of small and medium enterprises, so weknow we cannot achieve our goal of sustainable
development without them”(1).

years

May 2020

19

June 2019

Tim Mohin,
GRI’s Chief Executive

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk(1) https://sustaincase.com/an-exclusive-interview-with-tim-mohin-gris-new-chief-executive/

www.sustaincase.com
15

3

Materiality priority:years

May 2020

19

June 2019

Small and medium enterprises must begin to takesolid focused sustainability action.
They are taking little or no action to address huge
issues like climate change or their impacts on theeconomy and society.

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
16

4

Evolving the GRI Standards and creating a reporting
option that Accelerates Positive Change (APC):

years

May 2020

19

June 2019

GRI Action Plus Reporting Option

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
17

5

years

May 2020

19

June 2019© FBRH Consultants Ltd

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
18

6Companies, in addition to their material topics,
will be required to report on:

years

May 2020

19

June 2019

1) Four very important standards (descriptions below):a) GRI Disclosure 201-1 Direct economic value generated
and distributedb) GRI Standard 203 Indirect Economic Impactsc) GRI Standard 308 Supplier Environmental Assessmentd) GRI Standard 414 Supplier Social Assessment
2) At least one positive impact on society, using any of the
GRI Standards but, more specifically, GRI 201 and 2033) How they implemented GRI’s Reporting Principles, which help
them demonstrate that they are not greenwashing

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
19

7
GRI Standard 203 Indirect Economic Impacts
Disclosure 203-1 Infrastructure investments and services supported
Disclosure 203-2 Significant indirect economic impacts
What does this mean for the person in the street?

years

May 2020

19

June 2019

These are both marvellous GRI Standards that companies can use to report on theirpositive impacts. Business must use their strengths to tackle, head-on, the problems thatseem to be always in the headlines or have been identified by their countries in their yearly
Sustainable Development Goals (SDG) reports(2). Imagine a world where most businesses
are finding solutions for the important issues in the societies they operate and rely on for
profit/growth. Issues related to infrastructure, unemployment (most importantly, youth
unemployment), support for local suppliers and economic development in areas of highpoverty, or the availability of their products and services for those with low incomes.

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)(2) https://sustainabledevelopment.un.org/vnrs/

FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
20

8
Increasing supply chain pressure to get the smaller companies tomeasure-manage-changeyears

May 2020

19

June 2019GRI Standards 308 and 414 supplier assessment (environment and social),
used in combination with any of the other environmental or social standards, will
accelerate positive change (multiplier effect). Smaller companies wishing to be part ofthe supply chain of larger companies will, as a matter of fact, have to provide theinformation required by these standards. Most importantly, SMEs will not be
required to produce a full-scale report, as they will only be reporting on whatmatters (materiality) with a GRI referenced report.

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
21

9
How the GRI Principles can help companies avoid being accusedof greenwashing
I believe that businesses might hold back from implementing positive change, in fearof being accused of greenwashing.

years

May 2020

19

June 2019

The GRI Reporting Principles go a long way in helping companies demonstrate thatthey are not greenwashing. By requiring companies to report according to theseprinciples, GRI helps them create a first-class report regarding both content andquality, and demonstrate that they are taking solid, focused action (materiality) on
their most important impacts.

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
22

10

Could it all be in the name?
The GRI-ActionPlus reporting option

GRI

years

May 2020

19

June 2019

Imagine how, through the GRI-ActionPlus reporting option, sustainability reporters
will empower communication/ marketing/ PR departments of companies around theworld. A GRI-ActionPlus logo on their Sustainability Report cover will enable themto demonstrate, through their GRI Sustainability Report and subsequent
communication, that they are part of a positive chain reaction that is accelerating
positive change around the globe.

Certified Training Partner of the Global Reporting Initiative (GRI) and the Institute of Environmental Management & Assessment (IEMA)FBRH GRI Standards Certified,
IEMA & CIM Recognised Course

www.fbrh.co.uk

www.sustaincase.com
23

11

Simon Pitsillides FIEMA, FCIM, MBA
Expert in Sustainability Strategy & Marketing
Teaches the FBRH GRI Certified, IEMA & CIM Recognised Course
venue London School of Economics (LSE)simon@fbrh.co.uk
www.fbrh.co.uk

ENTER

https://www.linkedin.com/in/simon-pitsillides
EXIT

Full Screen

24

103

Email 4

104

From:

Carla Bonino Covas, Fundacion Once

105

Sent on:

Tuesday, June 23, 2020

106

To:

Standards

107

Subject:

Public Comment Revised GSSB Work Program 2020-2022

108

Dear GRI Standards team,

109
110

Please find attached Fundación ONCE’s contribution to 'Public Comment Revised GSSB Work
Program 2020-2022'

111

Thank you and best regards to all,112

Carla Bonino

25

1. General background.
The 2030 Agenda and the SDGs, the UN Convention on the Rights of Persons with Disabilities(ratified by the EU and all EU member states), together with EU non-discrimination legislation1
including the European Accessibility Act, the European Disability Strategy and the European
Pillar of Social Rights, among others, lead us to consider that diversity and more specificallydisability and accessibility need to be present in the coming developments and regulations of nonfinancial reporting. Therefore disability, as part of a wider concept of diversity should be partof a discussion point in the GSSB Program 2020-2022.
2. Disability, CSR, Sustainability and Non-financial information

The renewed EU Strategy 2011-14 for Corporate Social Responsibility explicitly recognized,
for the first time, disability as part of the CSR agenda. The disability dimension in CSR has beenfurther reinforced in the European Parliament resolutions of 6 February 2013 on CSR.

2030 Agenda for Sustainable Development explicitly recognized people with disabilities (1billion people in the world) as a vulnerable group. Different SDGs also refer to people withdisabilities, such as SDG 8 on Decent Work and Economic Growth, SDG 10 on Reduced
inequalities or SDG 11 on Sustainable Cities and Communities (with a specific mention ofaccessibility). Also, SDG 4 on Quality Education and SDG 17 on Partnerships for the Goals referto people with disabilities.

In the context of business and human rights, the Guiding Principles on Business and Human
Rights implementing the UN ‘Protect, Respect and Remedy’ Framework (UNGPs) or the OECD
Guidelines for Multinational Enterprises include disability and so do other Commission
instruments2. Other reference institutions have underlined the link between business, humanrights and disability, as is the case of the 2017 “Guide for business on the rights of persons withdisabilities” by ILO and Global Compact.

Furthermore, disability should be recognized as an element of diversity, and people withdisabilities as a source of talent, growth, innovation and market opportunities. The potential
of inclusive businesses is being increasingly identified by companies, institutions and thematic
initiatives around the world3. The potential of the 360º approach to business and disability4
must be underlined, where people with disabilities are seen as stakeholders from a wide

1

Disability is one of the discrimination grounds addressed by EU’s non-discrimination legislation (Directive 2000/78/EC
establishing a general framework for equal treatment in employment and occupation) and it is also recognized by the EU
Treaty together with age, gender, racial or ethnic origin, religion or belief, or sexual orientation (article 10), as well as in the
EU Charter of Fundamental Rights (article 21 and 26).
2 Such as the Sector Guides for implementing the UNGPs as well as in the Guide for SME “My business and human rights”,

and various references to disability are included in the 2015 EC staff working document on implementing the UNGPs. In
addition, the recent EU Action Plan on Human Rights and Democracy 2020-2024 refers specifically to people withdisabilities, in relation to many areas, including accessibility to infrastructure, transport and ICT as well and employment.
3 Relevant international examples are the ILO Global Business and Disability Network (ILO GBDN), the Valuable 500

initiative and Disability Hub Europe, counting with GRI as partner, in the EU. At national level, there are other examples,such as the Inserta Responsible Forum in Spain, the UK Business and Disability Forum, the Austrian Disability Business
Forum, The UnternehmensForum in Germany, or the Come CloSeR to Disability Task Force in Poland.
4 A concept created within Disability Hub Europe.

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perspective, valuing their roles as employees, consumers (including their families seeking foraccessible products and services), providers, employers, investors and part of the community inwhich a company operates.
Regarding the Directive 2014/95/EU on disclosure of non-financial and diversity information, thetopic of disability was included in the EU institutions’ discussions prior to approval5. Also,
the EC guidelines on non-financial reporting adopted in June 2017 do contain specific andvarious references to people with disabilities in relation to employee and board diversity,
accessibility of products and services, and human rights, including examples of key performanceindicators67.



It is relevant to mention here, the Guide on “Disability in Sustainability Reporting”, published by
GRI and Fundación ONCE in the framework of Disability Hub Europe, that highlights theimportance of the disability dimension in non-financial and sustainability reporting. The guidecontains specific guidance and indicators related to business and disability.

2. Call for action to consider diversity and disability in the GSSB Program 2020-2022.
Considering the important steps taken by the EU during the last 10 years to include disability andaccessibility as part of the corporate social responsibility (CSR), diversity, sustainability, business &human rights, and non-financial reporting agendas, Fundación ONCE calls to consider in GSSB
Program 2020-2022 the following:

Prioritization of the revision of the following GRI Standards:oo

GRI 405: Diversity and Equal Opportunity 2016
GRI 406: Non-discrimination 2016

In order to include new GRI relevant indicators for people with disabilities, employment,
equality and accessibility from a 360º approach. Fundación ONCE claims to consider adding
disaggregated data on disability. This is essential to ensure systematic and effective followup and to reveal neglected areas of discrimination which need to be redressed.
Consideration of including a wider approach in the next revision of the GRI 412: Human Rights
Assessment 2016 in order to include explicit indicators for vulnerable groups, including people
with disabilities.

5

Disability was particularly considered by almost all European Parliament Committees involved in the process, anddisability was included in the final Report by JURI Committee voted on 17 Dec 2013 Report A7-0006/2014 of 08.01.2014.
6 References are included in the guidelines’ sections 4.6 Thematic aspects: b) social employee matters and c) respect tohuman rights; and 6 Board diversity disclosure – footnote. Examples of indicators included are: the number of people withdisabilities employed or how accessible companies’ facilities, documents and websites are to people with disabilities
7 An interesting example can be found in the case of Spain where Directive 2014/95/EU transposition, by means of theLaw 11/2018, did include specific reference to disability and accessibility. 2019 Guide on Disability, SDG and non-financial
reporting (in Spanish only), by the Spanish Committee of Representatives of People with Disabilities, Fundación ONCE
and Fundación Bequal, analyses this milestone from a disability perspective

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113

Email 5

114

From:

Avinash Chandra, Indorama

115

Sent on:Friday, April 24, 2020

116

To:

Beth.Elliott; Standards

117

Subject:

FW: ENERGY CONSUMPTION WITH IN THE ORGANISATION.

118

Dear Sir,

119
120
121
122
123
124

In my opinion we should review the energy consumption due to the following as well in our GRI
reporting for energy consumed. Compressed air and nitrogen accounts, Cooling water accounts forat least 30 to 40% of the electricity consumption of the total utilities in the plants. Many times theseutilities are purchased from outside the plant and many times the plants are generating these utilities
in house. To have a proper comparison in between plants we should increase these energy sources
under Scope 2 energy used in addition to PURCHASED OF HEAT AND STEAM.

125
126
127

Since heat purchased and steam purchased is accounted under Scope 2 than what is the whycompressed air purchased / nitrogen purchased is not getting accounted. Need your thoughts on
the same.

128

Regards

129

Avanish28

130

Email 6

131

From:

Richard Jones, Institution of Occupational Safety and Health (IOSH)

132

Sent on:

Tuesday June 23, 2020

133

To:

Standards

134

Subject:

Public Comment Revised GSSB Work Program 2020-2022

135

Dear Sir / Madam,

136
137

We are pleased to attached IOSH comments to the Draft GSSB Work Program 2020-22 and Project
Schedule 2020. I would be grateful if you could acknowledge receipt of this submission.

138

We hope you find our comments helpful and don’t hesitate to contact us if you have any questions.

139

Kind regards,

140

Richard29

Draft GSSB Work Program 2020-22
and Project Schedule 2020
Institution of Occupational Safety and Health response to
GRI’s Global Sustainability Standards Board consultation
on its draft work program and project schedule

Submission

23.06.20
30

Introduction
The Institution of Occupational Safety and Health (IOSH), is the Chartered body for OSH professionals,
with around 48,000 members in over 130 countries.

IOSH welcomes the opportunity to comment on this important Global Reporting Initiative Draft Global
Sustainability Standards Board (GSSB) Work Program 2020-2022 and the accompanying Project
Schedule 2020. We have been pleased to be represented on the GRI Stakeholder Council and on the
GRI 403: 2018 Project Work Group and to respond to other GRI consultations.
In the submission that follows, we are pleased to share our views on GRI’s standard-setting activities
and priorities, addressing GSSB’s three consultation questions:

1. Which existing GRI Standards should the GSSB prioritize for review until 2022?
2. Which topics should the GSSB prioritize for the development of new GRI Standards until 2022?
3. Which sectors in Priority Group 1 and 2 should the GSSB prioritize in the implementation of the
Sector Program?

In summary, as well as updating GRI 401, 402, 403, 408, 409, 412, 414 and 416, we propose four new
standards: Modern slavery and human trafficking; Human capital; Gender-based violence andharassment; and Artificial intelligence and ethical use of data. We close with references, further reading
and more information about IOSH. As with GRI 403, IOSH would offer our assistance regarding thedevelopment and improvement the OSH-related content of GRI standards.

Background
IOSH, as an international NGO, influences strategic decisions that affect the safety, health and wellbeingof workers worldwide. We collaborate with governments, advise policymakers, commission researchand set standards, and run high-profile campaigns to promote workplace safety, health and well-being
issues. We advocate that OSH is a fundamental right for all workers and improved transparency anddue diligence can ensure this is a reality.

IOSH is a thought leader for sustainability and corporate social responsibility. We have a long-standing
relationship with the Center for Safety and Health Sustainability (www.centershs.org) as a founding
member. CSHS provides over 100,000 OSH professionals across the world with a stronger voice inshaping sustainability policies. Officially launched in June 2011, the body commits to advancing the
OSH and sustainability of the global workforce.

As a Chartered body and largest membership organisation for OSH professionals, we support them inproviding assistance to organisations on improving OSH performance and protecting human capital andsocial sustainability. We act as a champion and advocate for people at the heart of sustainability, withworkplace OSH integral to sustainable corporate performance.

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IOSH responses to the GSSB consultation questions
1. Which existing GRI Standards should GSSB prioritize for review until 2022?
GRI 401: Employment 2016 and GRI 402: Labor / Management Relations 2016
People reporting (sometimes defined as ‘workforce reporting’) describes the way by which people datais shared with key external stakeholders to help them to make better decisions. The trend oforganisations, public and private to improve their transparency in annual reports (in particular for publicly
listed organisations), has risen quickly up the agenda. We suggest this should be formally reflected inexisting standards. There are some encouraging indications of a growing appetite among socially
responsible investors for workforce data. It is reported that such investors want information about ESG,
including on diversity, labour relations and workers’ OSH.1 We note that GRI is committed to 4-yearly
updating of its standards and so suggest that these two should both be prioritised.

GRI 403: Occupational Health and Safety 2018

IOSH was pleased to help develop GRI 403: Occupational Health and Safety 2018, supporting reportingthat is meaningful and comparable and drives better occupational safety and health (OSH) performance– benefiting individuals, businesses and societies. IOSH believes that public reporting of OSH
performance helps organisations and their stakeholders to have a better view of when and where
attention and resources should be focused for improvement.

IOSH advocates high-quality OSH performance data in internal and public annual reports using both
leading and lagging indicators, as a lever for continual improvement and sustainability. As members of
the ISO Technical Committee 283, we are currently supporting a new work item package on OSH
performance evaluation, which is planned to become ISO 45004.

We note that GRI is committed to 4-yearly updating of its standards and suggest that this one should beprioritised.

GRI 408: Child Labor 2016, GRI 409: Forced and Compulsory Labor 2016 and GRI 412: Human
Rights Assessment 2016
Protecting human rights and tackling forced labour remains a global priority in today’s world andeliminating all forms of child labour by 2025 is part of the UN Sustainable Development Goal 8.7. We
note that GRI is committed to 4-yearly updating of its standards and suggest that these three should all
be prioritised.

GRI 414: Supplier Social Assessment 2016

IOSH advocates extending corporate OSH risk management into supply chains. This is an importantpart of ISO 45001: 2018 Occupational health and safety management systems: Requirements with
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guidelines for use, which IOSH helped to develop. We believe good management of supply chains canhelp prevent work-related injury and illness and support responsible employment and business
continuity. We note that GRI is committed to 4-yearly updating of its standards and suggest that this one
should be prioritised.

GRI 416 Customer Health and Safety 2016

IOSH advocates that this standard should include the need for organisations to prevent the spread ofcommunicable diseases, such as COVID-19, to their customers when they access the organisation’s
products and services. We note that GRI is committed to 4-yearly updating of its standards and suggestthat this one should be prioritised.

2. Which topics should GSSB prioritize for the development of new GRI
Standards until 2022?
Modern slavery and human trafficking reporting

Regrettably, modern slavery is a global scourge with an estimated 40.3 million people in some form ofslavery.2

There have been welcome developments on transparency in many countries. However, all have scopefor improvements and a standardised approach could both simplify and clarify requirements for
multinationals.

At a European level the Commission is planning to articulate due diligence mandatory requirements in
2021 in the form of legislation to require corporate governance and due diligence. However, despite
existing and expected progress in this field, OSH across all tiers of supply chain remains a challenge
for businesses to address.

IOSH has been actively involved in anti-modern slavery work to help eradicate these crimes hidden inplain sight. We argue that transparency and high-quality reporting are crucial to the multi-faceted
response. For that reason, we launched a White Paper ‘Tackling modern slavery together: the roles ofgovernments, employers, professionals and the public’, encouraging governments and businesses toreport on actions to prevent slavery and human trafficking.

We consider ourselves a key stakeholder in the fight to eradicate modern slavery and human trafficking
and help achieve the UN Sustainable Development Goal 8.7. For that purpose, transparency and highquality reporting are essential tools. Standardising and harmonising them through a GRI standard could
facilitate better benchmarking and comparability at the business level. A specific reporting standard
could help customers and investors to make informed choices driving improvement on corporate action
to prevent modern slavery.

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33

IOSH welcomes standards to improve global supply chain management. The existing ISO 20400: 2017
– Sustainable procurement – Guidance provides a good starting point for achieving better transparency
and due diligence on preventing modern slavery in supply. IOSH is also on a British Standard Institute(BSI) committee looking at developing a national or international standard on modern slavery to improve
corporate-level prevention.

IOSH has recommended inclusion of the UN Guiding Principles on Business and Human Rights in ourwork to improve non-financial reporting and OSH transparency on modern slavery, human trafficking
and supply chains.

Human Capital reporting

Research has shown that human capital reporting by FTSE 100 companies increased by 9% between
2015-17. However, while on wellbeing issues it increased, worryingly, on employee engagement andflexibility, it decreased. Overall, the analysis raises concerns that while quantity of information isincreasing, there is lack of consistency and low-quality data.3 To successfully achieve their strategic
goals, we believe organisations may benefit from manage and leverage these intangible organisational
aspects. Responsible businesses can lead on measuring, evaluating and sharing their performance onhuman capital issues, such good OSH, as well as the knowledge, skills and abilities that workers bringto create value for their organisations and communities.

International and national standards on this are welcome, such as ISO standard ISO 30414: 2018
Human resource management – Guidelines for internal and external human capital reporting and ISO
30409: 2016 Human resource management – Workforce planning, together with BS 76000: 2015
Human resource – Valuing people – Management system – Requirements and guidance. However,while these are all useful, we believe more work needs to be done to improve the provision and use ofhuman capital data transparency levels of companies.

IOSH, together with like-minded bodies such as the Chartered Institute for Personnel and Development,
is leading in the call for enhanced human capital management disclosure through the inclusion of OSH
leading indicators. IOSH hosted the Human Capital Workshop Global Summit on Human Capital andSustainability together with the CSHS.

Gender-based violence and harassment

Gender-based violence and harassment (GBVH) is a serious global issue with impacts acrossworkplaces, services and communities. For example, GBVH can occur within companies among
workers and supply chains; between workers and community members or service-users; and amongusers of company services or infrastructure. Investors should seek assurance that GBVH risks are being
tracked and managed and that such risks (which may change over time) are regularly re-assessed. Key
performance indicators and monitoring-data can help identify where improvements, for example, togrievance mechanisms or response procedures, are needed.

434

Artificial intelligence and ethical use of data

As the use of artificial intelligence and the collection of corporate performance data increases, wesuggest that a reporting-standard covering the important ethical and data management requirements,
including the need for privacy, security and accuracy of such data, would be helpful. This could be
included in GRI 102: General Disclosures 2016, under ethics and integrity.

3. Which sectors in Priority Group 1 and 2 should GSSB prioritize in theimplementation of the Sector Program?
We note that GSSB is developing a sector programme, which it intends will cover 40-45 high-impact
sectors, and that it currently lists these in four priority groups (1 – Basic needs and basic materials, 2 –Foods, medicines, manufacturing and insurance, 3 – Transportation, tourism, tech and real estate and
4 – Retail, services and manufacturing).

Generally, IOSH would advocate that the high-hazard sectors and industries should be prioritised on
the basis of the need to provide stakeholders with assurance that OSH risks are being well-managed.
Such sectors include agriculture, construction, extraction and manufacturing. GSSB may also wish toreview its priorities in the context of COVID-19 and what are considered essential products and services.

References
1. CIPD. Investor perspectives: people data and reporting (Literature Review, p.11). London: CIPD,
2019. www.cipd.co.uk/knowledge/strategy/governance/investors-people-data
2. International Labour Organization and Walk Free Foundation. Global estimates of modern slavery:
Forced labour and forced marriage (p.9). Geneva: ILO, 2017.
www.ilo.org/global/publications/books/WCMS_575479/lang--en/index.htm
3. CIPD. Hidden figures. How workforce data is missing from corporate reports (Executive Summary,p.7). London: CIPD, 2018. www.cipd.co.uk/Images/hidden-figures_2018-how-workforce-data-ismissing-from-corporate-reports-executive-summary_tcm18-45152.pdf

Further reading•

CSHS. Human Capital Workshop Global Summit on Human Capital and Sustainability. Chicago:
CSHS, 2019. www.centershs.org/assets/pdf/CSHS_report_April_2019.pdf•

IOSH. Tackling modern slavery together: the role of governments, employers, professionals andthe public. Wigston: IOSH, 2019. www.iosh.com/modernslaverywhitepaper•

IOSH. Response to the review of GRI’s Universal Standard – online survey. Wigston: IOSH, 2019.
[available on request from IOSH]

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About IOSHFounded in 1945, the Institution of Occupational Safety and Health (IOSH) is the largest body for healthand safety professionals in the world, with around 48,000 members in over 130 countries, including over
13,000 Chartered Safety and Health Practitioners. Incorporated by Royal Charter, IOSH is a registeredcharity, and an ILO international NGO. The IOSH vision is“A safe and healthy world of work”

The Institution steers the profession, providing impartial, authoritative, free guidance. Regularly
consulted by Government and other bodies, IOSH is the founding member to UK, European andInternational professional body networks. IOSH has an active research and development fund andprogramme, helping develop the evidence-base for health and safety policy and practice. Summary andfull reports are freely accessible from our website. We have also developed a unique UK resource
providing free access to a health and safety research database, as well other free on-line tools andguides, including resources for business start-ups; an occupational health toolkit; and a resource pageon COVID-19 at www.iosh.com/coronavirus.

IOSH has 41 Branches worldwide, including the Caribbean, Hong Kong, Isle of Man, Oman, Qatar, theRepublic of Ireland, Singapore and UAE, 18 special interest groups covering aviation and aerospace;broadcasting and telecommunications; construction; consultancy; education; environment and waste
management; financial services; fire risk management; food and drink industries; hazardous industries;
health and social care; logistics and retail; offshore; public services; railway; rural industries; sports
grounds and events; and theatre.

IOSH members work at both strategic and operational levels across all employment sectors. IOSH
accredited trainers deliver health and safety awareness training to all levels of the workforce from shop
floor to managers and directors, through a professional training network of over 2,000 organisations.
We issue around 180,000 certificates per year.

For more about IOSH, our members and our work please visit our website at www.iosh.com. Our fiveyear strategy WORK 2022 can be viewed at www.ioshwork2022.com and our resources specificallytailored for business can be found here www.iosh.co.uk/ioshmeansbusiness.

Please direct enquiries about this response to:Richard Jones, Head of Policy and Regulatory Engagement; or
Dr Ivan Williams Jimenez, Policy Development Manager
The Grange, Highfield Drive
Wigston
Leicestershire
United Kingdom
LE18 1NN
Tel: 0116 257 3114
Email: consultations@iosh.com

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36

141

Email 7

142

From:

Giulia Carbone Khodabakhsh, IUCN (International Union for Conservation of Nature)

143

Sent on:Wednesday, June 10, 2020

144

To:

Standards

145

Subject:

Public Comment Revised GSSB Work Program 2020-2022

146
147

Thank you for the opportunity to comment on the GSSB Work Programme 2020-2022. Please see
attached for my recommendations.

148

Kind regards

149

Giulia Carbone37

1. Which existing GRI Standards should the GSSB prioritize for review until 2022?
Please to see that the “… GSSB has identified the review of GRI 304: Biodiversity 2016 as apriority project if further budget becomes available.” Given the critical role biodiversity plays insupporting societies in many different ways, I really support this decision. A stronger GRI 304
will help push businesses in all sectors to take more relevant and effective actions to mitigate
their footprint.
2. Which topics should the GSSB prioritize for the development of new GRI
Standards until 2022? It would be interesting to explore a reporting framework for
Nature based Solutions enabling companies to properly report back on the effectiveness of
their NbS inspired interventions. This could complement IUCN’s Global Standard for
Nature based Solutions (https://www.iucn.org/theme/ecosystem-management/our-work/aglobal-standard-nature-based-solutions ).
3. Which sectors in Priority Group 1 and 2 should the GSSB prioritize in theimplementation of the Sector Program?
In group 1: prioritize Agriculture; Renewable energy utilities
In group 1: not clear why you would have a separate sector programme for construction
materials as many are related to mining (including cement raw materials); wood; aluminium
and steel.
In group 2: prioritize asset management as the sector with the biggest leverage potential
In group 3: Transportation infrastructure

38

150

Email 8

151

From:

Juan Vera, Metagas

152

Sent on:Friday, May 29, 2020

153

To:

Standards

154

Subject:

Public Comment Revised GSSB Work Program 2020-2022

155

Good evening!

156

According to the invitation to revise the information, we provide our opinions and comments.

157

Thanks for everything and we shall wish to participate in next projects.

158

We look forward to seeing you.

159

Sincerly160

Juan Vera

39

40

41

156

From:

Severine Neervoort, Norges Bank Investment Management

157

Sent on:Thursday, June 18, 2020

158

To:

Standards

159

Subject:

Public Comment Revised GSSB Work Program 2020-2022

160

Dear Sir or Madam,

161
162

Please find attached Norges Bank Investment Management’s response to your consultation on yourwork program 2020-2022.

163

Thank you for the opportunity to contribute our perspective.

164

Kind regards,

165

Severine

42

Global Sustainability Standards Board
Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands

18 June 2020

GSSB public consultation on work programme 2020-2022
We refer to the Global Sustainability Standards Board (GSSB)’s public consultation on thedraft work programme for 2020-2022, published on 23 April 2020. We welcome theopportunity to contribute our perspective.
Norges Bank Investment Management (NBIM) is the investment management division of theNorwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian
Government Pension Fund Global. We work to safeguard and build financial wealth for future
generations.
We have an inherent interest in how companies manage their use of natural and social
resources, as this can have a bearing on their ability to create financial value. Moreover, as along-term, global investor, we consider our returns over time to be dependent on sustainable
development in economic, environmental and social terms. We published recently adocument on corporate sustainability reporting 1, sharing our perspective as global asset
manager. We recommend that companies look at the industry-specific standards developedby the Sustainability Accounting Standards Board (SASB) and base broader social andenvironmental disclosures on the GRI Standards. Our public expectations of companies on
selected sustainability topics provide further guidance.
We welcome the GSSB’s draft work programme and its decision to review all existing GRI
standards every four years (line 16). Such revisions will help ensure that the standards
remain relevant and reflect evolving disclosure practices, as well as users’ needs.
In particular, we welcome the GSSB’s decision to revise the human rights-related standards
and complete phase 1 of the project in 2020 (line 89). We also support the ambition to
integrate human rights in the Universal Standards and align these with the UN Guiding
Principles on Business and Human Rights and the OECD Guidelines for Multinational
Enterprises. As current reporting on human rights due diligence tends to be insufficient, it
would be helpful for the GRI Standards to include indicators on whether and how companies

1 Norges Bank Investment Management, Asset Manager Perspective on Corporate Sustainability Reporting, 2020

Norges Bank Investment Management is a part of Norges Bank – The Central Bank of Norway
Queensberry House, 3 Old Burlington Street, London, W1S 3AE, England

Tel. +44 20 7534 9000

Fax. +44 20 7534 9010

Web www.nbim.no43

conduct such due diligence, as well as quantitative and qualitative indicators on theoutcomes and effectiveness of companies’ efforts to address negative impacts.
Another topic-specific standard which could be revised, as a priority, is the GRI 205 anticorruption standard. In accordance with our expectations on anti-corruption 2, companies
should identify and manage corruption risks. Based on our observations, companies do notreport comprehensively on corruption risk in accordance with Disclosure 205-1. As investors,
we also expect companies to report on how they measure the effectiveness of the anticorruption programme. Our expectations state that “performance reporting should, whereappropriate, use metrics that enable year-on-year comparison, in line with applicableinternationally accepted reporting standards or initiatives.” In our view, Disclosure 205-2 areindicators of activity and implementation of the anti-corruption programme but do not address
outcomes and effectiveness of anti-corruption efforts. Although some of the indicators under
Disclosure 205-3 point to past performance, these are not indicative of future behaviour, norof the effectiveness of preventive anti-corruption measures. These indicators could be
revised to strengthen the focus on performance and effectiveness.
Then, the GSSB could consider amending its standards for climate change-related reporting,in order to ensure closer alignment with the recommendations of the Taskforce for Climaterelated Financial Disclosures (TCFD).
More generally, over time, we hope to see further alignment of reporting frameworks andstandards. We encourage GSSB to continue working with other standard-setters towards thisgoal and suggest adding this important objective to its work programme. As a starting point,
we recommend that standard-setters, including GSSB, seek agreement on a set of widely
accepted industry-specific and financially relevant metrics. This could be used as a core in allreporting frameworks, including the GRI Standards. Beyond this common core disclosures,
GRI could continue to propose a broader set of disclosures in its standards, relevant for awider range of stakeholders than just investors.
We appreciate your willingness to consider our perspective.
Yours sincerely

Carine Smith Ihenacho
Chief Corporate Governance Officer

Severine Neervoort
Senior Analyst, Corporate Governance

2 Norges Bank Investment Management, Expectation Document on Anti-Corruption

Page 244(2)

172

Email 10

173

From:

Shweta Mathur, PWC

174

Sent on:

Tuesday June 23, 2020

175

To:

Standards

176

Subject:

Views on the GSSB's Work Program for 2020-2022

177

Dear team,

178
179
180
181
182

By way of introduction, I am Shweta Mathur, a CPA by profession and work in the field of
Sustainability Assurance and Integrated Reporting. Thanks for sharing "Recommendations of the GRI
Technical Committee on Human Rights Disclosure". It's a well drafted and detailed document aroundhuman rights disclosure. Please find below some comments/ clarifications that can help me getmore insight.

183
184

Line no. 68 - 70: Does this means changes in this document will be incorporated in the universal
standards i.e. 101,102,103

185
186

Line 197 a ii: Won't it be a good idea to also disclose the date when the policy was framed and last
reviewed

187

Line 350 - 353: Companies can also have provision of Human rights SPOCs at their top tier partners

188
189

Line 438 a: Is this not as repetitive as Disclosure XXX1? If not, then how is this different and what are
the reporting expectations

190
191

Line 438 d: Is this not same as disclosure 5 b iii? If not, then how is this different and what are thereporting expectations

192

Line 690 - 694: I think more clarity on the kind of mechanisms to be adopted can be provided here

193
194
195

Line 712 a: Before reporting upon this, the company should identify internal (depts., work streams,etc) or external partners, suppliers where the risk of these human right topic is higher. Therefore,
first question could be - Methods to identify high risk areas of HR topics internally and externally.

196

Looking forward to the the responses as well as the final document.

197

Regards

198

Shweta45

199

Email 11

200

From:

Bill Baue, r3.0

201

Sent on:

Tuesday, June 23, 2020

202

To:

Standards

203

Subject:

Public Comment Revised GSSB Work Program 2020-2022

204

Dear GSSB,

205

Please find attached my Public Comment on the Revised GSSB Work Program 2020-2022.

206

Please confirm receipt.

207
208

And I would welcome engaging with GSSB on this issue, or supporting its movement on this front
from the sidelines.

209

Best,

210

Bill

46

To: Global Sustainability Standards Board
From: Bill Baue, Senior Director, r3.0
Re: Public Comment Revised GSSB Work Program 2020-2022
Date: 22 June 2020
Sustainability requires contextualization within thresholds. That’s what sustainability is allabout.
Allen White, Co-Founder, Global Reporting Initiative, 20131
I respectfully write with a simple request: issue robust guidance on applying the Sustainability
Context Principle. I do so in compliance with lines 78-84 of the Draft GSSB Work Program 20202022 under the section entitled “Issuance of FAQs, Guidance and authoritative interpretations.
I submit the following simple rationale:
1. The Global Reporting Initiative (GRI) introduced the Sustainability Context Principle in its
second generation of Sustainability Reporting Guidelines (G2) in 2002. The essence of
the Principle guided reporting organisations to discuss
the performance of the organisation in the context of the limits and demands
placed on economic, environmental, or social resources at a macro-level.2
2. The Sustainability Context Principle has remained fundamentally unchanged for nearly
two decades.
3. GRI has provided insufficient guidance on implementing the Sustainability Context
Principle throughout this entire period, until the present.
4. Evidence of this fact is contained in exhaustive empirical research by Anders Bjørn et al,
who “systematically reviewed references to ecological limits in 40.000 CR reports”
issued from 2000-2013. This research found only about “5% of companies referred to

1 Bill Baue, "#SustyGoals 2: A Dialogue with Allen White of GISR, the Godfather of Sustainability Context (Part 2),"

Sustainable Brands, 8 November 2013. https://sustainablebrands.com/read/new-metrics/sustygoals-2-a-dialoguewith-allen-white-of-gisr-the-godfather-of-sustainability-context-part-2
2 Global Reporting Initiative, Sustainability Reporting Guidelines, 2002. https://www.r3-0.org/wpcontent/uploads/2020/03/GRIguidelines.pdf (As a side note, I would request that GRI follow best practice and post
all of its Guidelines on its own Website, so that its stakeholders can readily access its historical development).

47

ecological limits in any year,” and of these 5%, “only 31 companies planned to alignperformance or products to limits.”3
5. A 2019 United Nations Research Institute for Social Development report on Sustainable
Development Performance Indicators did the math: the research database used by
Bjørn et al covered 12,000 companies, so 31 companies represents a mere 0.258% ofreporting companies who “planned to align performance or products to limits.”4 See
Figure 1 for visual perspective on how this percentage compares to its reference
universe.

Figure 1: Lack of Sustainability Context in Corporate Responsibility Reporting 2000-2013.5
6. So, after the Principle existed for a decade, essentially no companies applied
Sustainability Context in the way intended – to discuss “the performance of theorganisation in the context of the limits and demands placed on economic,
environmental, or social resources at a macro-level.”

3 Anders Bjørn et al, “Is Earth recognized as a finite system in corporate responsibility reporting?” Journal of

Cleaner Production, Volume 163, 1 October 2017, Pages 106-117.
https://www.sciencedirect.com/science/article/abs/pii/S0959652615019204
4 Bill Baue, Compared to What? A Three-Tiered Typology of Sustainable Development Performance Indicators: From
Incremental to Contextual to Transformational, United Nations Research Institute for Social Development, Working
Paper 2019-5, October 2019. http://www.unrisd.org/baue
5 Ibid, p 24.

48

7. In the Public Comment Period for G4, 66 prominent sustainability experts in the
Sustainability Context Group submitted a Public Comment asking GRI to “undertake
improvements to the Sustainability Context Principle in G4.”6 The Comment continued:
Although GRI’s Guidelines currently do advocate for the inclusion of
Sustainability Context in organizational reports, they fail to provide specificguidance for how to do so…
Rather than devise a specific procedure for how to implement Sustainability
Context in organizational reporting, we believe GRI should provide related
guidance in the form of functional specifications, or criteria, for how to do so, in
keeping with its charge of providing broad, non-prescriptive direction.7
Signatories of the Comment included Alan AtKisson of The AtKisson Group, Jan
Bebbington of the University of St. Andrews, Stephanie Bertels of Simon Fraser
University, Ecological Economics Co-Founder Bob Costanza, John Elkington of Volans
Ventures, B Lab Co-Founder Bart Houlahan, Deborah Leipziger of the Sustainability
Lexicon Project, Ralph Thurm of r3.0, Mathis Wackernagel of the Global Footprint
Network, GRI Co-Founder Allen White, and The Big Pivot Author Andrew Winston.
8. GRI opted against acting on this input, and instead, left the Sustainability Context
essentially untouched, with no further guidance provided then, or since.
9. In 2017, after Alyson Slater of GRI spoke at the r3.0 Conference in Amsterdam, r3.0
engaged with her to propose collaborative Research and Training on Sustainability
Context, and on the Global Thresholds & Allocations Council.8 The ultimate result of this
proposal was, again, inaction from GRI, either in collaboration or on its own.
10. During this nearly two-decade period between 2002 and the present, the Stockholm
Resilience Centre has introduced research finding that humanity is overshooting 4 of the
9 Planetary Boundaries,9 and Kate Raworth has built upon that research base todemonstrate the humanity is shortfalling on all 12 of the Social Foundations

6 Sustainability Context Group, Statement to GRI on the Need to Enhance Treatment of the Sustainability Context

Principle in G4, 24 September 2012. https://www.r3-0.org/wp-content/uploads/2020/03/SCG-GRI-G4-CommentSubmitted-9-24-12.pdf
7 Ibid.
8 Email attached in Appendix.
9 Johan Rockström, Will Steffen, et al. “A safe operating space for humanity,” Nature, Volume 461, pp 472–475,
2009. https://www.nature.com/articles/461472a; Will Steffen, Katherine Richardson, Johan Rockström, SarahCornell, et.al. “Planetary boundaries: Guiding human development on a changing planet,” Science 347: 736,
1259855, 2015. http://science.sciencemag.org/content/347/6223/1259855;

49encompassed in what she calls the Doughnut.10 So all told, humanity is transgressing 16
of 21 critical sustainability thresholds. See Figures 3 & 4:

Figures 3 & 4: Planetary Boundaries11 and the Doughnut12
11. Organizations that use GRI Guidelines and Standards clearly play a decisive role inthese sustainability threshold breaches.
12. As a provider of Guidance and Standards, GRI also can choose to play a decisive role inaddressing these threshold breaches.
13. GRI cannot do so by continuing to cleave to the status quo.
14. Therefore, GRI will need to shift significantly, by providing robust guidance on its
Sustainability Context Principle.
15. I will end by quoting climate activist Greta Thunberg:
If you really understood the situation and still kept on failing to act, then you
would be evil. And that I refuse to believe.13

10 Kate Raworth, A safe and just space for humanity: Can we live within the doughnut? Oxfam Discussion Paper,

February 2012. https://www-cdn.oxfam.org/s3fs-public/file_attachments/dp-a-safe-and-just-space-for-humanity130212-en_5.pdf; Kate Raworth, “A Doughnut for the Anthropocene: humanity's compass in the 21st century,” The
Lancet: Planetary Health, Volume 1, Issue 2, PE48-E49, 1 May 2017.
https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(17)30028-1/fulltext
11 Op cit, Steffen et al 2015.
12 Op cit, Raworth 2017.
13 NPR Staff, “Transcript: Greta Thunberg's Speech At The U.N. Climate Action Summit,” NPR, 23 September 2019.
https://www.opb.org/news/article/npr-transcript-greta-thunbergs-speech-at-the-un-climate-action-summit/

50Appendix
From: Bill Baue bbaue@verizon.net
Subject: GRI / Reporting 3.0 collaboration: Research, Training, Thresholds & Allocations Council
Date: September 14, 2017 at 12:04 PM
To: Alyson Slater slater@globalreporting.org
Cc: Ralph Thurm r.thurm@reporting3.org, Allen White awhite@tellus.org
Dear Alyson,
I hope you had a relaxing time on vacation, and that you’ve settled back in to your work smoothly.
As promised, I’m writing now to follow up on our August call around R3 / GRI collaboration, specifically providing a next level of specificity on
the areas we discussed (Research & Training), and also adding another that has come up in the intervening time through discussion with
Allen White (a Reporting 3.0 Advocation Partner who offered to be cc’ed in this thread in case his perspective helps): a Thresholds &Allocations Council. So, below we provide a first-pass fleshing out of our ideas on how GRI & R3 can collaborate to move forward on these
agendas (which are all tied to the GRI Sustainability Context Principle).
Research: We believe that SustyContext is a ripe area for research, following up on the research to-date (such as the Danish study
cited in the most recent installation of our 10-Part Sustainable Brands series), the Article 13 research cited in your R3 Conference
Presentation (and their 2017 refresh), etc... In addition to documenting the Context Gap, it would be important for the research to also
focus on emerging solutions, including methods for integrating context.
Proposal: GRI & R3 establish a joint research project on implementation of the Sustainability Context Principle, focusing
both retroactively on uptake to date, and proactively on what additional recommendations, guidance, case studies,
methodologies, and data sources could help spur more robust implementation.
This research stream could tap into the Reporting 3.0 Academic Alliance that is starting to take shape, and also
could feed into the new GRI program starting this fall that you described in our call, on "developing guidance on
issues that we don’t have standards on or inadequate standards.” It also ties into your recommitment to impact
reporting, and research on the impacts of reporting, as we discussed in the call.

Training: As we discussed on our call, this area is particularly ripe for collaboration, as building out training on how to measure,manage and report on Sustainability Context is likely the most effective means of upping implementation of the Principle. And R3 is
uniquely positioned to design curricula and deliver training on this front, given our connection to the Sustainability Context Group,
many of whom are now in the R3 ecosystem.
Proposal: GRI & R3 establish a joint training project on implementation of the Sustainability Context Principle, building on
the research outlined above. R3 would focus on curriculum development and training implementation (tapping into our
Advocation Partner Program), while GRI would provide branding and promotion / communications.

Thresholds & Allocations Council: It is generally agreed that the lack of generally validated, systems-level thresholds acrossdiverse areas of social, ecological, and economic impacts, framed for implementation by companies, hinders implementation of the
SustyContext Principle. As well, the lack of similarly validated, “off the shelf” methodologies for allocation of “fair share” /proportionate responsibility for collective impacts on the "common" capitals hinders uptake. Revisiting an idea Allen first proposed inabout 2013 or so, we see value in establishing a Thresholds & Allocations Council comprised of global experts in physical and social
sciences / academia, NGOs, companies, multilaterals, governments, etc..
Proposal: GRI & R3 serve as the lead partners collaborating with other key players (eg Stockholm Resilience Center,
UNGC, etc.) to convene such a council, with a primary objective of providing neutral & actionable guidance on thresholds &allocations for implementation by companies in particular
You could consider the Science-Based Targets Initiative as a kind of example focused just on GHGs / climate,though as a member of their Technical Advisory Group, I think a stronger governance structure makes sense.
Of course, additional funding (beyond existing institutional support from both GRI & R3) will be instrumental for actualizing each of theseideas, so it makes good sense to jointly and individually seek funding, leveraging materials we jointly produce and some kind of MoU
memorializing our partnership.
We welcome your feedback on these ideas, and would look forward to an opportunity to discuss next steps in a follow-up call, perhaps in theweek of Sept 25 when Ralph returns to his office.
Best,
Bill

51

211

Email 12

212

From:

Sonal Pandya Dalal, Sustainability Accounting Standards Board (SASB)

213

Sent on:

Tuesday, June 23, 2020

214

To:

Standards

215

Cc:

Sustainability Accounting Standards Board (SASB)

216

Subject:

Public Comment Revised GSSB Work Program 2020-2022

217

Dear Ms. Kuszewski:

218
219
220
221

Thank you for the opportunity to comment on the Draft GSSB Work Program 2020-2022. The
Sustainability Accounting Standards Board (SASB) supports The Global Reporting Initiative’s (GRI)
commitment to review all existing GRI Standards to guarantee that they reflect global multistakeholder consensus and continue to promote the public interest.

222

We offer the attached comments for your consideration for the Work Program.

223
224

We would be happy to answer any questions or further discuss any of the ideas presented in the
consultation response.

225

Warm regards,

226

Sonal

52

Janine Guillot
CEO
1045 Sansome Street, Suite 450
San Francisco, CA 94111 (USA)+1 (415) 830-9220
sasb.org

23 June 2020
Re: Public Comment Revised GSSB Work Program 2020-2022
Dear Ms. Kuszewski:
Thank you for the opportunity to comment on the Draft GSSB Work Program 2020-2022. The Sustainability
Accounting Standards Board (SASB) supports The Global Reporting Initiative’s (GRI) commitment to review
all existing GRI Standards every four years to guarantee that they reflect global multi-stakeholder
consensus and continue to promote the public interest.
Standards provide a comprehensive solution
Sustainability reporting standards are a powerful tool to ensure decision makers have access tocomparable, consistent, and reliable information. By demonstrating transparency, reporting organizations
create trust with their stakeholders. By facilitating accountability, they enable benchmarking of performance
among peers.
Globally, there are two sets of widely used sustainability reporting standards that together ensureaccountability to stakeholders. The GRI Standards focus on the economic, environmental, and social
impacts of the activities of a company, and hence its contribution—positive or negative—toward sustainable
development. It is the underlying assumption that if not already financially material at the time of reporting,these impacts may become financially material over time. SASB’s industry-specific standards identify thesustainability-related risks and opportunities most likely to affect a company’s financial condition (i.e. itsbalance sheet), operating performance (i.e. its income statement), or risk profile (i.e. its market valuationand cost of capital).

Figure 1. GRI and SASB: Complementary Standards
Sustainability Accounting Standards Board

53

As demonstrated by the large and rapidly growing number of companies around the world that use both
SASB and GRI standards, they are complementary. When used in combination, SASB and GRI standards
meet the EU’s double materiality1 continuum and help reporting organizations be accountable to multiple
stakeholders. They also support the needs of a broad range of users for information, including informationthat is industry-agnostic and industry-specific (See Figure 1). As both our organizations noted in
Accountancy Europe’s June 2020 paper2, our standards form the basis for a “unifying system in which a
combination of principles, frameworks, metrics, and platforms can serve providers of capital andstakeholders more widely.” Indeed, such a system could provide for international consistency and be
tailored for regional needs across the double materiality continuum.
With our two organizations committed to collaborating to make it easier for companies to use both the GRI
and SASB standards, we believe a key mechanism to achieve this would be for the GSSB to consider
using SASB’s Sustainable Industry Classification System (SICS®) to operate its Sector Program[per line numbers 41-77 of the Work Program].
A classification system to support action and impact:
SASB established the Sustainable Industry Classification System® (SICS®) in 2012 to organize industries
using a combination of traditional classification factors and sustainability risks and opportunities.
Commonly used industry classification systems, such as the Global Industry Classification Standard(GICS®) and the Industry Classification Benchmark (ICB), use sources of revenue as their primary basis
for classifying companies into specific sectors and industries. They establish hierarchies and layers ofindustries based on economic variables, providing less visibility for certain industries with greater
sustainability risks or opportunities but smaller economic footprints.
These traditional classification systems, while useful, were not designed to support understanding of anindustry’s shared sustainability risks and opportunities. As a result, they were not well equipped to facilitatesustainability standard-setting aimed at providing comparable information among industry peers. SASB
developed SICS® to build on and complement traditional industry classification systems. Within a SICS ®
industry, companies tend to have similar business models, face similar growth and innovation opportunities,
operate in similar legal environments, rely on similar resources, and produce comparable products andservices, as well as comparable impacts on society and the environment.
For example, where GICS® identifies five industries related to electronics hardware, SICS® includes justone. Although the five GICS® industries—including communications equipment, computers andperipherals, and office electronics—may differ in terms of key financial characteristics, they produce similar
products and face similar regulatory environments from a sustainability perspective. Separating them would
therefore create overlap and repetition among industry-based sustainability disclosure standards.

1

The double materiality concept was developed by the European Commission and noted that on one side, there is information that isfinancially material, and thus primarily of interest to investors and other providers of capital.
On the other side, there is information that is environmentally and societally material, and thus of interest to a broad range ofstakeholders, including customers, employees, communities, civil society, policy makers, and investors.
2
Accountancy Europe, Follow-Up Paper: Interconnected Standard Setting for Corporate Reporting – Feedback Analysis (June2020); available at https://www.accountancyeurope.eu/wp-content/uploads/200615-Follow-up-paper-Interconnected-standardsetting.pdf

254

Conversely, where GICS® identifies a single Oil, Gas and Consumable Fuels industry, SICS® includes two
industries—one focused on oil and gas exploration, and another on oil and gas refining and marketingcompanies. In sustainability terms, these industries face significantly different risks and opportunities, so
companies and their stakeholders are likely to benefit from different disclosure requirements. Table 1
outlines the SICS® categorization of oil and gas3 industries, their industry descriptions, and the metrics
intended to measure performance on a financially material topic, water management.
Table 1. Industry Description of Oil & Gas-Related Industries in SICS® and industry-specific metrics
associated with the financially material topic of water management.
SICS®
Industry

Industry Description

Financially Material
Management

Oil & Gas –Exploration &Production

E&P companies explore for, extract, or
produce energy products such as crude
oil and natural gas, which comprise theupstream operations of the oil and gas
value chain. Companies in the industry
developconventional
andunconventional oil and gas reserves;these include, but are not limited to,shale oil and/or gas reserves, oil sands,
and gas hydrates. Activities covered bythis standard include the developmentof both on-shore and off-shore
reserves. The E&P industry creates
contracts with the industry to conduct
several E&P activities and to obtainequipment and oilfield services.

Associated Metrics:

R&M companies refine petroleum
products, market oil and gas products,
and/ or operate gas stations andconvenience stores, all of which
comprise the downstream operations of
the oil and gas value chain. The typesof refinery products and crude oil inputs
influence the complexity of the refining
processused,withdifferent
expenditure needs and intensity ofenvironmental and social impacts.

Associated Metrics:

Oil & Gas –Refining&
Marketing













Topic:Water(1) Total fresh water withdrawn, (2) total
fresh water consumed, percentage ofeach in regions with High or ExtremelyHigh Baseline Water Stress
Volume of produced water and flowback
generated; percentage (1) discharged,(2) injected, (3) recycled; hydrocarbon
content in discharged water
Percentage of hydraulically fractured
wells for which there is public disclosureof all fracturing fluid chemicals used
Percentage of hydraulic fracturing sites
where ground or surface water quality
deteriorated compared to a baseline(1) Total fresh water withdrawn, (2)percentage recycled, (3) percentage inregions with High or Extremely HighBaseline Water Stress
Number of incidents of non-complianceassociated with water quality permits,standards, and regulations

Please note that the SICS® recognizes that there may be both “pure-play” and integrated oil and gas companies conducting
upstream operations as well as activities in the distribution and/or refining or marketing of products. SASB has separate standards for
the Oil and Gas Midstream (EM-MD) and Oil and Gas Services (EM-SV) in addition to O&G - Exploration & Production and O&GRefining and Marketing. Companies with substantial business in multiple SICS® industries can consider reporting on these additional
industry standards.
3

3

55

Using SICS®, SASB has been able to systematically assess the relevance of ESG topics and the potential
for financially material impacts on companies in each industry. This ensures that topics recommended fordisclosure are included in the standards based on evidence amassed in a relevant industry context as wellas on input from a balanced group of market participants with suitable industry expertise. Using asustainability-based industry classification helps SASB surface the disclosure topics that are reasonably
likely to impact the typical company in an industry. Globally, SICS® is used by 64 organizations that license
SICS® totaling over $35 Trillion in assets under management. Thus, use of SICS® to develop GRI’s sector
standards would ensure that data providers and investment managers could easily aggregate both SASB
and GRI metrics, facilitating the integration of ESG considerations into investment processes in a rigorous,
scalable manner.
Value for standard-setting analysis:
For GRI, SICS® offers a well-tested and widely utilized system that can support the development of GRI
Sector Standards. SICS® would enable GRI to develop sector standards based on common sustainability
characteristics of each sector or industry, allowing GRI to develop standards that identify and describe a
sector’s impacts and stakeholder concerns from a sustainable development perspective. Using SICS® canalso facilitate focus on the positive/negative externalities most likely to be generated by each industry.
Utilizing SICS® also creates an important opportunity for GRI and SASB to demonstrate their complimentary
approach and interest in making it easier for companies to use both sets of standards. The SASB standards
have identified the ESG factors (disclosure topics and metrics) that impact financial performance and longterm enterprise value of the typical company in each SICS® industry. GRI Sector Standards will enable
understanding of the incremental societal impacts. By using the same industry classification system,companies, investors, civil society organizations, and others will more effectively and efficiently understandthe issues and disclosure requirements that demonstrate the economic, environmental, and social impactsof activities of a company (vis a vis GRI) and the issues that impact a company’s financial condition andoperating performance (vis a vis SASB). Such an approach can support the development of a globally
accepted system of standards that provide for international consistency and be tailored for regional needs,
while also meeting the double materiality continuum.
The following provides an example of SICS® classifications per the priority Group 1 sectors outlined in the
GRI Work Program [Line 63].
GRI’s Priority Group 1 sectors:

SASB SICS®

Agriculture

Agricultural Products

Banking

Commercial Banks; Investment
Brokerage; Mortgage FinanceChemicals

Chemicals

Construction Materials

Construction Materials

4

Banking&56

Forestry, paper, and rubber

Containers & Packaging; Industrial Machinery &Goods; Biofuels; Forestry Management; Pulp &Paper Products

Iron, steel, and aluminium processing

Iron & Steel Producers

Mining

Metals & Mining

Oil, gas, and coal

Coal Operations; Oil & Gas – Exploration &Production; Oil & Gas – Midstream; Oil & Gas –Refining & Marketing; Oil & Gas – Services

Textiles and apparel manufacturing

Apparel, Accessories & Footwear

Utilities

Electric Utilities & Power Generators; Gas Utilities& Distributors; Water Utilities & Services

We would be happy to make our resources and research available to GRI/GSSB to facilitate yourWork Program.
Conclusion
In the context of increasing market and regulatory pressures to harmonize the sustainability disclosure field,
GRI’s sector program presents a unique opportunity to realize practical alignment for the users andpreparers of sustainability information. Using SICS® as a common framework, GRI and SASB can enhance
the complementarity of their standards, create valuable efficiencies for reporting organizations, andconverge around a key piece of infrastructure (i.e. an industry classification system) that is increasingly
embedded in mainstream financial and economic research and analysis. Indeed, this shared approach
would significantly strengthen the foundational layer GRI and SASB seek to establish for an internationallyaccepted system of sustainability disclosure standards.

Sincerely,

Janine Guillot, CEO

5

57

227

Email 13

228

From:

Roshnie van der Zwan-Ramautarsing, Schiphol Group

229

Sent on:

Tuesday, May 26, 2020

230

To:

Standards

231

Subject:

Public Comment Revised GSSB Work Program 2020-2022

232

Dear GSSB,

233

Please find below the feedback on the GSSB Work Programme 2020-2022.

234

Pre-determined questions

235

1. Which existing GRI Standards should the GSSB prioritize for review until 2022?

236
237
238
239
240

412: Human rights Assessment. I feel that generally (not specifically at GRI) there is more focus on
the green sustainability topics and less on social topics. Therefore developing clear standards thatalign with e.g. OECD and guiding principles could help in this imbalance. Additionally it would be
helpful if all standards (but especially Environmental Standards) are reviewed for alignment with the
EU Taxonomy/TCFD.

241

2. Which topics should the GSSB prioritize for the development of new GRI Standards until 2022?

242

No input, there are currently plenty standards that cover a variety of topics.

243
244

3. Which sectors in Priority Group 1 and 2 should the GSSB prioritize in the implementation of the
Sector Program?

245

Not applicable, as airport operators are not included in the sector program.

246

Other feedback

247
248
249
250
251

o
Line 63: The previous airport operators sector disclosure still largely suffices in my opinion, I
do however not see the airport operator sector included in the GRI sector Program. If the aim is tocover 40-45 high-impact sectors, I do believe that airport operators should be included ultimately. As
the previous airport operators sector disclosure content is still largely valid and applicable to ourorganization, it can be placed in a lower priority group.

252
253
254
255

o
Line 90: Regarding the 101 foundation standards; I’ve had lots of discussion internally andexternally as how to interpret the horizontal axis of the materiality matrix. Perhaps some moreelaboration on how ‘’impact’’ should be interpreted is welcome. E.g. does impact refer tofootprint/contribution or influence or perhaps something else?

256Good luck with the review process.

257

Best regards,

58

258

Email 14

259

From:

Cavassa Paola, SECH

260

Sent on:Friday, April 24, 2020 2:37:27 AM

261

To:

Standards

262

Subject:

Public Comment Revised GSSB Work Program 2020-2022

263

Good afternoon dear All,264

I do hope that my message finds you well.

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266

As a customer service representative of a container terminal, I firmly believe that one of the sectorsthat should be prioritized next, besides the ongoing pilot projects, are shipping and logistics.

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270

These days we had tangible proof of how these two intertwined sectors are of the utmost
importance to keep the country systems functioning during the pandemics and, at the same time, I
believe that a more sustainable drive in these two sectors is needed, so as to steer them towards
more sustainable practices.

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Thanking you in advance for the opportunity of submitting our feedback with regard to the GSSBWork Program, please accept my Best regards

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273

Email 15

274

From:

Sumaya Rashid, Social Responsibility Asia (SR Asia),

275

Sent on:Friday, April 24, 2020

276

To:

Standards

277

Subject:

Public Comment Revised GSSB Work Program 2020-2022

278

Dear Concern,

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From my point of view that if there is any future project plan on plastic, leather or light engineering
sector would be effective for south asian region.

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Thank you.

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282

Email 16

283

From:

Girish P Ramachandran, Tata Consultancy Services

284

Sent on:

Tuesday May 26, 2020

285

To:

Bastian Buck

286

Cc:

Judy Kuszewski; ANAND SAMPATHRAMAN; PALLAVI ATRE

287

Subject:

For Consideration

288

Dear Bastian289

Trust you are doing safe and well during these testing times

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294

We had a suggestion for consideration. Since the world is moving a lot towards digitization andmore so, post Covid times, we felt it may be appropriate to consider “Technology metrics”, as ahorizontal constituent, as part of GRI reporting disclosures which shall form basis to understand an
Organizations ability to embrace risk, enable resiliency and improve adaptability. My colleagues
Annd and Pallavi have worked on a concept and elaborate further if there is interest from your end

295

Enclosing a short document on this.

296

For your consideration

297

Warm regards

298

Girish61

GRI Reporting
Environment | Economics | Social

An approach note to consider“Technology metrics”

Version 1.0
September 202062

All Technology in the last century was aimed at managing and maintaining system of records. People were supposed
to learn how to use that Technology. The effort in the last decade had been to design systems that understand thetypical human behavior and are designed so that systems learn about humans. In the future, Technology is designed
to be so non-obvious that it will only manifest as experiences rather than tools to be learnt or to be used.
Now, in the age of Consumers, we may see Business and Technology go hand in hand, as technology moves from backend to center stage helping Organizations in differentiation and to reimagine innovative Products and Services. While
Sustainability reporting, is known for triple bottom line, and emphasizes on.,
•
•
•
•
•

Future orientation
Wider Sustainability metrics
Intangible
Non-financial
Stakeholders

It may be appropriate to consider “Technology metrics”, as a horizontal constituent, as part of GRI reporting
disclosures which shall form basis to understand an Organizations ability to embrace risk, enable resiliency andimprove adaptability.
The technology levers that provides maximum impact on such outcome, for an Organization, which may be considered,
are.,
•
•
•
•
•

Infrastructure strategy, Hybrid Cloud
Humanizing Technology
Intelligence, Analytics, Automation, Machine first considerations
Remote management, Bringing Life to Things, Internet of Things
Location independent agile, Change management

Technology disclosure in line with the above, with due importance to Data privacy, can help base line and have timely
access to relevant and reliable information, which can enable better decision making.
While the Technology metric shall be applicable to different sectors, scale of Organization and in all geographicalcontext, the role of technology is seen to be one of equalizer and harbinger for Innovation.
The recent COVID times, is seen to further pronounce the need for Organizations to embrace and leverage technology.
We feel this complements the GRI’s Vision and Mission. GRI may appropriately strategize, evangelize and execute.

2
63

299

Email 17

300

From:

Charlotte Hugman, World Benchmarking Alliance

301

Sent on:

Tuesday June 23, 2020

302

To:

Standards

303

Subject:

Views on the GSSB's Work Program for 2020-2022

304

Dear GRI Standards Division & GSSB,

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306
307
308

The World Benchmarking Alliance (WBA) welcomes this opportunity to comment on GRI’s RevisedWork Program 2020-2022 as well as further dialogue on any of the responses provided to thequestions in the consultation. GRI is a WBA Ally and GRI and WBA work closely together, in particular
as members of the Structured Network of the Impact Management Project.

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315

WBA has identified seven system transformations (Social – including Gender and Corporate Human
Rights; Digital; Circular; Food & Agriculture – including Access to Seeds and Seafood Stewardship;
Decarbonisation & Energy; Urban; and Financial) it believes are vital to put our society, planet andeconomy on a more sustainable and resilient path to accomplish the 2030 Agenda. This is a basis forhelping companies to measure and disclose what matters most to society and the planet. By 2023,
we will have made publicly available and free rankings of the performance of 2,000 of the world’s
most impactful companies – many of whom report using GRI.

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322

All WBA benchmarks build on existing frameworks, standards and norms. Before developing any
methodology, WBA undertakes a detailed internal mapping, as well as extensive consultations withkey stakeholders, to explore and better understand what content exists in the GRI Standards (andother relevant standards and frameworks) and how to incorporate this into our work. We always
seek to align with and build on the work of GRI wherever possible. Further content is only developed
by WBA if expert and other stakeholder feedback identifies a gap in existing content that is needed
to hold the private sector accountable on the SDGs.

323

Please note that this response is based on the GRI Standards content as at 31 May 2020.

324

1. Which existing GRI Standards should the GSSB prioritize for review until 2022?

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327

•
WBA is supportive of the proposal to review GRI 304: Biodiversity – this is an important issue
on the UN agenda and has relevance to the Food and Agriculture and Circular systems
transformations work of the WBA.

328
329
330

•
GRI 301: Materials has content relevant to the Circular system transformation. Our research
to date and consultations on the system have highlighted that it is a rapidly evolving space. WBA
would therefore recommend reviewing this Standard.

331
332
333
334
335
336

•
WBA has published a detailed Gender Benchmark Methodology - in seeking to map against
GRI, we did not always find enough content to reflect what we believe is current global best practicein measuring gender equality and women’s empowerment. Gender could be captured more
explicitly in certain places in the GRI Standards; for example, in GRI 204: Procurement Practices;
Disclosures 401-2, 401-3 (e.g., breakdown by primary / secondary caregiver for comparability with
the ILO convention and recommendation; other family leave including elderly care; gender-

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301
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304
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306

responsive health care); 403-1, 403-2 and 403-6 (e.g., gender-responsive health topics/risk
screening); 412, and 414-2. There are also opportunities to require or recommend the collection of
sex-disaggregated data (ideally including by other intersectional elements like race/ethnicity) in, forexample, GRI 404: Training and Education and Disclosure 406-1. Disclosure 405-2 is commendable as
one of the few existing gender pay gap standards but could be more granular for further clarity andconsistency in reporting. WBA would therefore recommend reviewing the GRI Standards on the
topic of Gender, and/or prioritizing Gender for the development of new Standards content (please
see the response to question 2 below).

307

2. Which topics should the GSSB prioritize for the development of new GRI Standards until 2022?

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313

•
Human Rights: Noting the GRI Universal Standards review project, which brings human rights
disclosures into the Universal Standards – and to which consultation WBA will respond separately –WBA supports universal human rights disclosure (by all companies). WBA recommends developing
GRI Standards content relating to alignment of purchasing/procurement decision with human rights(CHRB indicators D.1.2. and D.2.2). Noting the ongoing work of GRI’s Sector Program, WBA also
recommends developing content, either in the GRI Topic Standards or Sector Standards, on:

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o

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316

o
For Extractives companies: transparency and accountability in nature resource wealth, rights
of indigenous peoples, land rights, and water and sanitation.

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321
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325
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327

•
Living wages: While there are numerous definitions of living wage, the core concept is toprovide a decent living for a worker and his or her family (in line with ICESCR Article 7) based on aregular work week not including overtime hours. A living wage is sufficient to cover food, water,
clothing, transport, education, health care and other essential needs for workers and their entitledofficial dependents and provide some discretionary income, including provision for unforeseen
events. Living wages are enablers. They can contribute to the direct and indirect fulfilment of a rangeof fundamental human rights of both the workers and their dependents (such as the rights to food,water, health, adequate housing, education and family life). Companies paying a living wage can also
contribute to the achievement of the SDGs, including SDG 1, 2, 3, 4, 5, 6, 8 and 10. WBA
recommends that the concept of living wage is drawn out clearly across GRI standards, rather thanconcepts such as minimum wage, legal wage and industry wage.

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329
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331

•
Social protection: A living wage is inextricably linked to working hours – as a wage would
not be considered a ‘living wage’ if it relies on exploitation through extreme hours of work. WBA
recommends that working hours as an element of social protection be prioritised in thedevelopment of new GRI Standards.

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333
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336
337
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339
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341

•
Digital Inclusion: Digital Inclusion supports SDGs 3, 4, 5, 8, 9, 10, 16 and 17. WBA’s Digital
Inclusion Benchmark Methodology makes an explicit reference and points companies to the GRI
Standard on data security and privacy, including indicators on reporting the number of customer
data privacy breaches and losses experienced by an organisation (GRI 418: Customer Privacy); andon transparency about global economic value generation and distribution (GRI 201: Economic
Performance). Further areas relevant to Digital Inclusion from our consultations and expert review
process include access, skills, use and innovation. Therefore, WBA recommends prioritizing
development of new GRI Standards content on these topics or through a Sector Standard forTechnology and Communications as we believe there is a gap in this area, which is also evolving
rapidly (please see the response to question 3 below).

For Agricultural Products companies: land rights and water and sanitation; and

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300
301
302
303
304

•
Gender: Gender equality is a standalone SDG (SDG 5) but the topic of Gender supports all
SDGs, particularly SDG 10, 12, 8, 1, 16, 17, 2, 3, 4, 6, 9, and 11 when considering the company
context. WBA notes and has built on and explicitly mapped to the existence of GRI Standards on
Gender relevant to various aspects of governance and strategy, representation, compensation andbenefits, health and wellbeing, and violence and harassment in its Gender Benchmark Methodology.
However, other areas are relevant to Gender, such as:305othe provision of flexible working options; and306othe prevention and remediation of violence and harassment; and307osupporting gender-responsive procurement; and308

onon-discriminatory marketing and advertising practices; and309

oassessment of controversies.

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311

Therefore, WBA recommends prioritising development of new GRI Standards content on these
topics.

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316

•
Nutrition: Providing healthy and nutritious food is a critical element within thetransformation of the global food system. Companies contributing to the affordability andaccessibility of healthy and nutritious food play a key role to the achievement of the SDGs, inparticular SDG 2. WBA recommends prioritising the issue of nutrition in the development of new GRI
Standards content.

317
318
319

•
Access to Energy: Per SDG 7, access to affordable, reliable and sustainable energy is crucial
to achieving many of the SDGs. Therefore, WBA recommends prioritising development of new GRI
Standards content on this topic.

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321

3. Which sectors in Priority Group 1 and 2 should the GSSB prioritize in the implementation of the
Sector Program?

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323
324
325
326

WBA notes that important work is already being done on two on priority sectors: Agriculture andFishing, and Oil, Gas, and Coal. Rik Beukers, Lead Research Seafood Stewardship Index at WBA is amember of the GRI Agriculture and Fishing Project Working Group, and the WBA Climate & Energy
team has been in discussion with GRI on the Oil, Gas, and Coal project, noting that this includes
useful content on the GHG emissions, climate resilience and transition, and the just transition.

327

WBA suggests the following sectors should be prioritized by the GSSB:

328•

From Priority Group 1 (line 63):329oBanking

330

oChemicals

331oTextiles and apparel manufacturing332oUtilities333oMining334•

From Priority Group 2 (line 67):

335

oAsset management

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299

o

Automotive

300

oFood Processing

301

oInsurance

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303
304
305
306
307
308
309

o
Technology hardware manufacturing; although WBA suggests that this sector group is
combined with Media and communication services and Software and services (Priority Group 3, line70) and Electronics manufacturing (Priority Group 4, line 73) into one priority sector ‘Technology andCommunications’. The latter is the SASB sector term and has been used by WBA to identify
companies in the Digital Inclusion Benchmark, as it unites these industries for analytical purposes.
Furthermore, within the UN ISIC classification the ICT sector consists of manufacturing,telecommunications and IT software and services. A number of companies have activities spanning
digital manufacturing, hardware, and services, e.g., Apple.

310
311

Please do not hesitate to contact us if WBA can provide clarification or if further dialogue would be
helpful.

312

Best regards,

313

Charlotte

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314

Email 18

315

From:

J Robert Gibson

316

Sent on:

Tuesday May 12, 2020

317

To:

Standards

318

Subject:

Views on the GSSB's Work Program for 2020-2022

319

Dear Sir/Madam,

320
321

Thank you for your 11th May invitation to provide views on the GSSB’s Work Program for 20202022.

322

KEY POINT

323
324
325

Why doesn’t the GSSB Work Programme mention working on the Corporate Reporting Dialogue
https://corporatereportingdialogue.com/ and the proposals on page 29 of its September 2019
‘Better Alignment Report’? Namely to:

326
327

1.
Develop a common taxonomy and encourage all standard/framework setters to use thesame language.

328
329

2.
Provide an online interactive tool to allow report preparers/users to quickly see what eachstandard says on the same topic/issue.

330
331

3.
Get the standard/framework setters to work together so future changes increase
harmonisation. A key issue being to get a common set of Reporting Principles.

332
333
334

I appreciate these are initiatives which involve SASB, TCFD, <IR>, etc but believe GSSB should be
guiding GRI to embrace them. They should, therefore, be mentioned and prioritized in GSSB’s work
programmed.

335
336

I particularly believe GRI needs to embrace this initiative so it remains ‘mainstream’ as SASB and
TCFD rise in importance.

337

DETAILS

338
339
340
341

I’m just finishing my sixth year of teaching a University course on ESG Management and Reporting in
Hong Kong. Each year my students have compared the Sustainability Reports of eight leading listedcompanies with ‘best practice’ peer companies from around the world. They then discussion theirfindings with the these companies’ staff who prepare the reports.

342
343

Sadly, while GRI remains the most followed standard it is losing ground. Several companies are
drifting away from using GRI. One ‘best practice’ company is actively evaluating switching to SASB.

344

I say ‘sadly’ as I believe there is great merit in GRI Standards. Specifically:

345
346

1.
GRI’s Principles of Report Content and Report Quality plus its Management Approachprovide an excellent ‘Principles Based Framework’ for meaningful sustainability reporting.

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314
315
316

2.
The flexibility of being able to start with a ‘GRI Cited’ report where you follow GRI for yourmost important Topics only. From this position you may later progress to a being ‘In accordancewith GRI Core’ in later years.

317
318

3.
The flexibility in to present the report in whichever way you like just as long as people canfind the items from the GRI Index.

319

4.

320
321
322

5.
GRI’s well written standards form the core of my teaching ESG Management Reporting. I
also feel that it should link to <IR>’s Framework for providing information for Financial Capital
Providers.

323
324

So it is sad that instead of GRI advancing from its leading ‘market share’ it now looks like it will
gradually wither with SASB and TCFD taking leading roles.

325
326
327
328
329

In this context GRI should focus on making what it does better rather than adding more reporting
requirements. Further it should recognize that SASB and TCFD will be widely followed and strive tobuild a common language. The Corporate Reporting Dialogue
https://corporatereportingdialogue.com/ was set up to do this and reporting last year that it would
work to:

330
331

1.
Develop a common taxonomy and encourage all standard/framework setters to use thesame language.

332
333

2.
Provide an online interactive tool to allow report preparers/users to quickly see what eachstandard says on the same topic/issue.

334
335

3.
Get the standard/framework setters to work together so future changes increase
harmonisation. A key issue being to get a common set of Reporting Principles.

336

TWO SPECIFIC ACTION RECOMMENDED

337
338

Please see below for my 27th April email with more specific recommendations for strengthening
GRI. (Thank you for acknowledging this when it was sent.)

339

FURTHER SPECIFIC RECOMMENDATION: GRI Content Index

340
341
342
343

Please can GSSB arrange ‘good practice’ examples on the extent to which companies put
information into their GRI Index . I believe it is appropriate to do this when the information (a) is notpart of their main Sustainability Story; and, (b) can be briefly stated. The advantages of thisapproach include:

344

1.

345
346

2.
The information does not clutter up the Sustainability Report. Thus the Sustainability
Report can provide better clarity in reporting the company’s material issues.

347
348

I attach the GRI Index for Hong Kong Electric Investments Ltd which follows this approach towelcome if, perhaps excessive, extent.

349

J Robert Gibson

The many companies following GRI makes their data comparable and thus more useful.

The information is made immediately available to someone going to the GRI Index to find it.

69

HKEI’s Sustainability Report 2019 – GRI Content Index[Verified independently as “in accordance with” the Core option of GRI’s Sustainability Reporting Standards, andhaving addressed a significant number of material disclosures required under the Comprehensive option.]

Cross-Reference / Information

GRI 102 (Ver. 2016): General
Disclosures(WEB – our website; SR – our Sustainability Report;
AR – our Annual Report; INFO – direct / supplementary information;
Figures may not add up to the total due to rounding.)

ORGANIZATIONAL PROFILE
102-1

Name of the organization

SR: Sustainability at HKEI – Our Business

102-2

Activities, brands, products, andservices

SR: Sustainability at HKEI – Our Business

102-3

Location of headquarters

INFO:
Hong Kong.

102-4

Location of operations

INFO:
Hong Kong.
SR: Sustainability at HKEI – Our Business

102-5

Ownership and legal form

INFO:
Share stapled unit(s) jointly issued by HK Electric Investments (the Trust) and HK Electric
Investments Limited (the Company) (collectively HKEI) (Share Stapled Unit(s)) are listed on
the Main Board of The Stock Exchange of Hong Kong Limited (the Company and its
subsidiaries, collectively the Group). The Trust is a listed business trust (the trustee managerof which is HK Electric Investments Manager Limited (the Trustee-Manager)), and theCompany is wholly owned by the Trust.
SR: Sustainability at HKEI – Our Business

102-6

Markets served

INFO:
Please refer to Disclosure Item EU3.

SR: Sustainability at HKEI – Our Business; Key Statistics and Targets – Summary of
Statistics
102-7

Scale of the organization
AR: Consolidated Statement of Profit or Loss; Consolidated Statement of Financial Position;
Consolidated Statement of Changes in Equity; Notes to the Financial Statements

SR: Report Overview; Sustainability at HKEI – Our Business; Working with Partners –Building Strong Relations with Employees; Managing our Supply Chain
INFO:

102-8

Information on employees and otherworkers

Age
Age 30 or below
Age 31-40
Age 41-50
Age 51 or above
Total

Senior staff (%)
0.0
0.2
2.3
5.4
7.9

General staff (%)
19.8
19.4
19.5
23.4
82.1

Workman (%)
0.1
0.3
2.0
7.6
10.0

Total (%)
19.9
20.0
23.8
36.3
100.0

GenderFemaleMale
Total

Senior staff (%)
0.9
7.0
7.9

General staff (%)
17.0
65.2
82.1

Workman (%)
0.7
9.3
10.0

Total (%)
18.5
81.5
100.0

Female (%)
17.2
1.4
18.5

Total (%)
93.5
6.5
100.0

Employment typeMale (%)
Permanent
76.3
Contract
5.1
Total
81.5
Notes: 1. We have around 1,900 employees in total.
2. Our operations are based in Hong Kong.

Page 1 of 25
70

SR: Working with Partners – Managing our Supply Chain – Responsible Procurement
102-9

Supply chain

INFO:
The core business of HK Electric is to supply electricity. Our supply chain includes the supplyof fuels, goods and services in order to facilitate the supply of safe, reliable and clean
electricity to our customers.
SR: Sharing our Planet – Taking Action on Climate Change – Transitioning from Coal to Gas

102-10Significant changes to theorganization and its supply chain

INFO:
There were no movements in the Share Stapled Units, as well as in the share capital of theTrustee-Manager and the Company during the year.
No significant changes in our operations and our supply chain that caused significant
economic, environmental, and social impacts were recorded.

102-11

102-12Precautionary Principle or approach

External initiatives

SR: Sustainability at HKEI – Sustainability Governance – Challenges and Strategies; Sharing
our Planet – Management Approach

INFO:
Low Carbon Charter; The Manifesto on Energy Efficiency in Buildings; Green Event Pledge;
Carbon Reduction Charter; Food Wise Charter; Energy Saving Charters; 4Ts (Target,
Timeline, Transparency and Together) Charter; Charter on External Lighting; Occupational
Safety Charter; Workplace Hygiene Charter; Charter on Preferential Appointment of OSH
Star Enterprise; Joyful@Healthy Workplace Charter, Sustainable Procurement Charter, Good
Employer Charter, etc.
All the above charters and principles we subscribe to are voluntary.

102-13

Membership of associations

INFO:
It is important for us to keep updated on developments in our industry, as well as provide
thought leadership where appropriate, so we actively support and participate in various
professional associations and organisations, including the Business Environment Council(BEC); the Asia Pacific Customer Service Consortium (APCSC); Hong Kong Institute ofMarketing; the Hong Kong Call Centre Association (HKCCA); the Hong Kong RetailManagement Association (HKRMA); the Hong Kong Federation of Restaurants and Related
Trades (HKFORT); The Institute of Dining Art (IDA); The Institute of Purchasing & Supplyof Hong Kong; the Asian Sub-Bituminous Coal Users’ Group (ASBCUG); and Data
Protection Officers’ Club under the Office of the Privacy Commissioner for Personal Data
(PCPD), Hong Kong.
We also encourage our employees to contribute to their professional sectors. Some of themhold leading positions in major associations, such as The Hong Kong Institution of Engineers(HKIE), American Society of Mechanical Engineers (ASME), Hong Kong Section and The
Institution of Engineering and Technology Hong Kong (IET Hong Kong).

EU1

Installed capacity, broken down byprimary energy source and by
regulatory regime

SR: Key Statistics and Targets – Summary of Statistics

INFO:

EU2

Net energy output broken down byprimary energy source and by
regulatory regime

Electricity sent out (GWh)
Gas
3,287
Coal & oil
7,601
Renewable energy
2
Notes:
1. Electricity sent out refers to the electricity sent out from our grid, which includes the sent out from ourpower plants and RE systems, and also from our customers’ RE systems under Feed-in Tariff.
2. Electricity sent out from customers’ RE systems under Feed-in Tariff is insignificant compared withthe total sent out.

The total electricity sent out was 10,890 GWh.

Page 2 of 25
71

EU3

Number of residential, industrial,
institutional and commercial
customer accounts

INFO:
Customer accounts
Residential
468,000
Commercial
108,000
Industrial
5,000
Total
581,000
Almost all points of connection were of distribution type.
The number of customers who are also producers, i.e. customers who produce electricity to
the grid, is insignificant compared to the total number of customers.

INFO:

EU4

Length of above and undergroundtransmission and distribution lines byregulatory regime

Circuit length (km)Above/Underground breakdown
Voltage breakdown
Transmission (275 kV
441& 132 kV)
Above ground 37
Distribution (22 kV &3,918
11 kV)
Underground
6,499
Low voltage
2,176
Total

6,536

Note: Circuit length is different from conductor length in that one or more conductors may be
employed to form a circuit. For instance, a 1-km long three-phase grounded LV
interconnection between two points which is built with one conductor per phase plus one
neutral conductor has a total of 4 km of conductor; however, it is only a 1-km long circuit.
Multiple, independently-switched circuits, e.g. feeders, may be attached on the samestructures or located in a common trench along a route. In such instances, the length of eachcircuit will be counted.
The length of underground circuit included the length of submarine circuit.

EU5

Allocation of CO2e emissions
allowances or equivalent, broken
down by carbon trading framework

INFO:
Not applicable to Hong Kong.

STRATEGY102-14

Statement from senior decisionmaker102-15Key impacts, risks, and opportunities SR: Sustainability at HKEI – Sustainability Governance – Challenges and Strategies

SR: A Word from our CEO

ETHICS AND INTEGRITY
WEB: Vision, Mission and Core Values; Code of Conduct102-16

Values, principles, standards, andnorms of behavior

SR: Sustainability at HKEI – Sustainability Governance
AR: Combined Corporate governance Report

WEB: Code of Conduct102-17

Mechanisms for advice and concerns
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices
about ethics
AR: Combined Corporate Governance Report

GOVERNANCE
102-18Governance structure

AR: Combined Corporate Governance Report

Page 3 of 2572

102-22

Composition of the highest
governance body and its
committees

102-23INFO:
The positions of the Chairman and the Chief Executive Officer of the Company are held by
Chair of the highest governance body
separate individuals. The Trustee-Manager does not appoint a Chief Executive Officer due toits specific and limited role to administer the Trust.

102-24

Nominating and selecting the highest AR: Combined Corporate Governance Report
governance body102-25

Conflicts of interest

AR: Combined Corporate Governance Report102-32Highest governance body’s role insustainability reporting

SR: Report Overview

AR: Combined Corporate Governance Report; Boards of Directors and Senior Management

STAKEHOLDER ENGAGEMENT
SR: Sustainability at HKEI – Stakeholder Engagement102-40

List of stakeholder groups

102-41

Collective bargaining agreements

102-42

Identifying and selecting
stakeholders

INFO:
Please refer to “Table for General Disclosure Items 102-40, 102-42 and 102-43” at the end of
this Content Index.
INFO:
Not applicable, collective bargaining agreements are not required by law in Hong Kong.

SR: Sustainability at HKEI – Stakeholder Engagement
INFO:
Please refer to “Table for General Disclosure Items 102-40, 102-42 and 102-43” at the end of
this Content Index.
SR: Sustainability at HKEI – Stakeholder Engagement; Serving Hong Kong – Serving ourCustomers – Excellent Service, Connecting with our Customers; Working with Partners –Building Strong Relations with Employees; Key Statistics and Targets – Summary of
Statistics

102-43

INFO:
Please refer to “Table for General Disclosure Items 102-40, 102-42 and 102-43” at the end of
this Content Index. Following are examples of HK Electric’s engagement activities with
Approach to stakeholder engagement various stakeholder groups in 2019:
A Customer Liaison Group meetingSafety, Health and Environment Day for our business partners
Home visits to Lamma villages (three rounds)
Joint Consultation (JC) meetings (20 meetings)
Focus group meetings with employees (16 meetings)

Local community events (throughout the year)
Corporate visits (about 260 visits)

SR: A Word from our CEO; Sustainability at HKEI – Stakeholder Engagement102-44

Key topics and concerns raised

INFO:
Please refer to “Table for General Disclosure Items 102-44, 102-46 and 102-47” at the end of
this Content Index.

REPORTING PRACTICE

102-45

Entities included in the consolidated
financial statements

SR: Report Overview; Sustainability at HKEI – Our Business
AR: Notes to the Financial Statements

Page 4 of 2573

SR: Report Overview; Sustainability at HKEI – Sustainable Development Goals, Stakeholder
Engagement; Working with Partners – Managing our Supply Chain
102-46

Defining report content and topic
Boundaries

INFO:
Please refer to “Table for General Disclosure Items 102-44, 102-46 and 102-47” at the end of
this Content Index.

SR: Report Overview; Sustainability at HKEI – Stakeholder Engagement102-47

List of material topics

102-48

Restatements of information

INFO:
No re-statements.

102-49Changes in reporting

INFO:
No significant changes from the previous report.

102-50

Reporting period

SR: Report Overview

102-51

Date of most recent report

INFO:
The most recent report was issued in April 2019 for the calendar year 2018.

102-52

Reporting cycle

INFO:
Annual.

102-53

Contact point for questions regarding INFO:
the report
Back Cover

102-54Claims of reporting in accordancewith the GRI Standards

SR: Report Overview

102-55

GRI content index

INFO:
This GRI Content Index.

102-56External assurance

SR: Report Overview; Verification Statement

INFO:
Please refer to “Table for General Disclosure Items 102-44, 102-46 and 102-47” at the end of
this Content Index.

Cross-Reference / Information
Material Topics(WEB – our website; SR – our Sustainability Report;
AR – our Annual Report; INFO – direct / supplementary information;
Figures may not add up to the total due to rounding.)

GRI 201 (Ver. 2016): Economic
Performance
SR: Sustainability at HKEI – Sustainability Governance
GRI 103 (Ver. 2016): Management
Approach

AR: Chairman’s Statement; CEO’s Report
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 5 of 2574

201-1

SR: Sustainability at HKEI – Our BusinessDirect economic value generated anddistributed
AR: Consolidated Statement of Profit or Loss; Consolidated Statement of Financial Position

WEB: HK Electric’s Response to the Long-term Decarbonisation Strategy Public
Engagement
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices; Sharing ourPlanet – Taking Action on Climate Change
INFO:
Risks due to physical changes associated with climate change on our operations includes:
1.

2.
3.

201-2

Extreme weather conditions could cause extensive damage in generation or network
facilities and lead to a prolonged and extensive power outage. The loss of cash flow
resulting from supply interruption, and the cost of recovery from damages to
network and generation assets could be considerable.
Increased fuel cost due to decreased plant efficiency under elevated ambient
temperature.
Fuel price may become unstable under the influence of adverse weather conditions
and hence affect the cost.

We make strategic investment to maintain our world-class supply reliability, enhance the
Financial implications and otherintegrity of our assets and reduce air emissions for better ambient air quality. All theserisks and opportunities due to climate
contribute to addressing the risk of climate change or the relevant impact on our operations.
change
The future business of HK Electric would hinge on the Government’s plan on decarbonisationand climate change mitigation, and their associated policy decisions in the coming decade.
With reference to HK Electric’s response submitted for the Hong Kong’s Long-term
Decarbonisation Strategy Public Engagement in September 2019, the energy sector would
have to determine suitable proposals to help achieving a more decarbonised Hong Kong. Afterall, uncertainties associated with the Government’s long-term plan on decarbonisation would
introduce the following risks to HK Electric:Unpreparedness of risks associated with the Government’s long-term plan on
decarbonisation or climate change mitigation could result in significant impact on HK
Electric’s long-term business development.



Any significant changes to the existing plan of HK’s decarbonisation / climate change
mitigation would adversely impact HK Electric’s operation, earning and businessstrategies.

HK Electric will continuously engage with the Government and stakeholders to solicit theirviews to make sensible and advance adjustments to our business strategies as necessary.

201-3

Defined benefit plan obligations andother retirement plans

AR: Notes to the Financial Statements

201-4

Financial assistance received fromgovernment

INFO:
No material financial assistance from the HKSAR Government.

GRI 203 (Ver. 2016): Indirect Economic
Impacts

GRI 103 (Ver. 2016): Management
Approach

SR: Sustainability at HKEI – Sustainability Governance; Sustainability at HKEI – Sustainable
Development Goals; Sharing our Planet – Management Approach; Serving Hong Kong –Management Approach; Key Statistics and Targets – Status of Targets in 2019, Looking
Ahead
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 6 of 2575

203-1

203-2

Infrastructure investments andservices supported

SR: Sustainability at HKEI – Sustainability Governance – Governance Practices;
Sustainability at HKEI – Sustainable Development Goals; Sharing our Planet – Improving Air
Quality – Drive EVs · Charge Easy; Serving Hong Kong – Serving our Customers – Excellent
Service; Serving Hong Kong – Smart Power Services; Working with Partners – Health &SafetySignificant indirect economic
impacts

SR: Sustainability at HKEI – Sustainability Governance – Governance Practices;
Sustainability at HKEI – Sustainable Development Goals; Sharing our Planet – Improving Air
Quality – Drive EVs · Charge Easy; Serving Hong Kong – Serving our Customers –Excellent Service; Serving Hong Kong – Smart Power Services; Working with Partners –Health & Safety

GRI 204 (Ver. 2016): Procurement Practices
WEB: Code of Conduct
GRI 103 (Ver. 2016): Management
Approach

INFO:
All local and foreign suppliers are treated equally and no preference is given in our purchasedecision.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

204-1

Proportion of spending on local
suppliers

INFO:
Natural gas, limestone and ultra-low sulphur diesel are supplied by companies with bases in
China or Hong Kong while coals are sourced mainly from Indonesia and Russia.
For other goods and services, about 70% were procured from “local suppliers” who aredefined as companies in China including Hong Kong and Macau.

GRI 205 (Ver. 2016): Anti-corruption
WEB: Code of Conduct
SR: Sustainability at HKEI – Sustainability Governance

GRI 103 (Ver. 2016): Management
Approach

INFO:
We prohibit any form of bribery/corruption, fraud or money laundering, and do not tolerateanyone committing fraud or breaking the law. Accepting or offering advantages in any
manner from or to clients, suppliers, or any person in connection with the Company’sbusiness is prohibited. We also strictly prohibit any fraudulent activities, such as theft ofcompany resources, use of misrepresentation, dishonesty or deceitful conduct. We will not
condone, facilitate or support money laundering. We strictly observe the standards, rules orregulations in regard to this aspect, such as Prevention of Bribery Ordinance.
Anti-bribery risk assessment is performed by business units twice a year andbribery/corruption statistics and incidents are reported by business units to Internal Audit
Department quarterly.
A Fraud Awareness & Prevention Policy is in place to ensure adequate deterrent measures aretaken to minimise exposure to fraud risk and to promote a fraud-free culture within the Group.
A Fraud and Whistle-Blowing Reporting and Investigation Procedure is developed tosupplement the Code of Conduct on the process workflow of investigation, investigation
protocols, roles and responsibilities in handling violations of the Code and ethical allegations.
Head of Internal Audit is the central point of all reporting and investigation of violations of
the Code.
A whistleblower hotline, connected directly to the Head of Internal Audit, is set up to
centrally receive from employees and external parties all reports of possible improprieties,
actual or alleged violations, including fraud, bribery and illegal acts. Any employee who is inbreach of the Code of Conduct is subject to disciplinary actions, including summary dismissal.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 7 of 25
76

205-1

Operations assessed for risks related
to corruption

INFO:
All 13 business units were accessed for risks related to corruption.

INFO:
We have communicated our anti-corruption policies and procedures to all our board members,
employees and business partners.
205-2

Communication and training aboutanti-corruption policies andprocedures

In particular, HK Electric's anti-corruption policies and procedures were communicated to allcontractors and suppliers via the Conditions of Tendering/Bidding in the enquiry document
and the Code of Practice for Suppliers in the application of Recognised Tenderers Register.
All our board members and employees have received training on anti-corruption.

205-3

Confirmed incidents of corruption
and actions taken

SR: Sustainability at HKEI – Sustainability Governance

GRI 206 (Ver. 2016): Anti-competition
behavior
GRI 103 (Ver. 2016): Management
Approach

206-1

Legal actions for anti-competitive
behavior, anti-trust,and monopoly practices

INFO:
We have established a Competition Compliance Policy and relevant approach and framework
to guide us making our own decisions independently.

INFO:
No relevant legal actions in 2019 were recorded.

AVAILABILITY AND RELIABILITY
SR: Sustainability at HKEI – Sustainability Governance; Sustainability at HKEI – Sustainable
Development Goals; Sharing our Planet – Taking Action on Climate Change; Serving Hong
Kong – Reliable and Affordable Power – World-class Power System
INFO:
HK Electric has been adopting a diverse power portfolio to deliver cleaner, more efficient andreliable electricity supply to meet our customers’ demand on both long and short-term bases.
HK Electric will carry out regular review of our load forecast and planning criteria to suit theever-changing socio-economic environment and to meet the tightening environmental
requirements. All these forecast parameters will be subject to Government’s scrutiny.

GRI 103 (Ver. 2016): Management
Approach(to ensure short and long-term electricity
availability and reliability)

Under the 2019-2023 Development Plan, HK Electric are investing HK$16.2 billion inprojects related to power generation, which accounts for 61% of the total investment. A largepart of it is set aside to build the new gas-fired units and associated facilities required toreplace the retiring coal-fired units. These new gas generating units are to further improve air
quality and help combat climate change.
To ensure reliability, a comprehensive Maintenance Regime for generating plants has been
established. Periodic maintenance is arranged for all the machineries in order to maintain its
reliability. The frequency of the periodic maintenance is determined by the recommendations
from the original equipment manufacturer, 'Reliability-Centered Maintenance' study and plantownership scheme. In between periodic maintenance, condition of the equipment is monitored
to determine its “healthiness” in order to secure the availability of the plant.
Health indexes of transmission and distribution equipment and apparatuses are being
established to determine priority of maintenance.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 8 of 25
77

WEB: Approved 2019-2023 Development Plan - Presentation
SR: Sustainability at HKEI – Sustainable Development Goals; Serving Hong Kong – Reliable
and Affordable Power – World-class Power System

EU10

Planned capacity against projected
electricity demand over the longterm, broken down by energy source
and regulatory regime

INFO:
The 2019-2023 Development Plan was approved by the Executive Council in July 2018.
Under this plan, five coal-fired units and one converted gas-fired unit is to be retired
progressively. As a replacement, three new gas-fired combined-cycle units, L10 to L12, areplanned to be commissioned by 2023. By then, the total installed capacity of HK Electric will
be lower than that of now.
L10 was synchronised in October 2019 and commissioned in February 2020. Construction of
L11 and L12 is on schedule, planned for commissioning in 2022 and 2023 respectively.

DEMAND-SIDE MANAGEMENTGRI 103 (Ver. 2016): Management
Approach(and description on demand-side management
programs including residential, commercial,
institutional and industrial programs)

SR: Sustainability at HKEI – Sustainable Development Goals; Sharing our Planet – Education
and Awareness – Happy Green Campaign; Serving Hong Kong – Management Approach,
Smart Power Services
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

RESEARCH AND DEVELOPMENT

GRI 103 (Ver. 2016): Management
Approach(and description on research and development
activity and expenditure aimed at providing
reliable electricity and promoting sustainable
development)

SR: Sustainability at HKEI – Innovation; Sharing our Planet – Taking Action on Climate
Change – Building Climate Resilience; Sharing our Planet – Responsible Resource
Management – Energy Saving; Serving Hong Kong – Serving our Customers – Excellent
Service
INFO:
We continue to keep track of the latest technology development related to our business.
Research and development activities are carried out by relevant business units.
Most of these studies would involve in-house experts whilst some projects would be done incollaboration with local universities. There were no significant additional costs compared with
our overall expenditure in 2019.

SYSTEM EFFICIENCY
SR: Key Statistics and Targets – Summary of Statistics

EU11

Average generation efficiency ofthermal plants by energy source andby regulatory regime

INFO:
Gas
Coal & oil
Overall

Thermal efficiency (%)
42.8
33.0
35.5

SR: Key Statistics and Targets – Summary of Statistics
EU12

Transmission and distribution losses
as a percentage of total energy

INFO:
Transmission losses: 1.3%
Distribution losses: 2.1%
Note: Non-technical losses are assumed to be insignificant.

GRI 300: Environmental
WEB: How We Care for our Environment; Enhancing Supplier Partnership

GRI 103 (Ver. 2016): Management
Approach

SR: Sustainability at HKEI – Sustainability Governance – Challenges and Strategies;
Sustainability at HKEI – Sustainable Development Goals; Sharing our Planet – Management
Approach; Working with Partners – Management Approach, Managing our Supply Chain;
Key Statistics and Targets – Status of Targets in 2019, Looking Ahead
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 9 of 25
78

GRI 301 (Ver. 2016): Materials
SR: Key Statistics and Targets – Summary of Statistics
301-1

Materials used by weight or volume

INFO:
No materials are present in our final product as our product is electricity and no materials
containing polychlorinated biphenyl are used.

SR: Sharing our Planet – Responsible Resource Management – Water Resources, Waste
Management; Key Statistics and Targets – Summary of Statistics
301-2

Recycled input materials used
INFO:
The amount of plant effluent and rain water collected and recycled at Lamma Power Station
represented 5.1% of the Station’s total consumption of town water.

301-3

Reclaimed products and theirpackaging materials

INFO:
There are no reclaimed products and packaging materials due to the nature of our product, viz.
electricity.

GRI 302 (Ver. 2016): Energy
302-1

Energy consumption within theorganization

SR: Key Statistics and Targets – Summary of Statistics

302-3

Energy intensity

INFO:
1.92 kWh per unit sold was needed to be consumed by HK Electric in the course ofgeneration, transmission and distribution of electricity, excluding the energy sold.

302-4

Reduction of energy consumption

SR: Sharing our Planet – Responsible Resource Management – Energy Saving

GRI 303 (Ver. 2018): Water and Effluents
SR: Sharing our Planet – Responsible Resource Management – Water Resources; Key
Statistics and Targets – Summary of Statistics
303-1

Interactions with water as a sharedresource

INFO:
Freshwater is provided by the Water Supplies Department of the HKSAR Government.
Seawater is withdrawn for cooling of plant equipment at Lamma Power Station and returnedto the sea after proper treatment. All our discharge complies with legislative requirements.
No water sources were significantly affected.

SR: Sharing our Planet – Responsible Resource Management – Water Resources; Key
Statistics and Targets – Summary of Statistics
303-2

Management of water dischargerelated impacts

INFO:
Our water discharge is governed by licenses granted by Environmental Protection Department(EPD) under Water Pollution Control Ordinance (WPCO). EPD would carry out regularinspections on our water treatment/ discharge facilities.

SR: Sharing our Planet – Responsible Resource Management – Water Resources; Key
Statistics and Targets – Summary of Statistics

303-3

Water withdrawal

INFO:
Town water is provided by the Water Supplies Department of the HKSAR Government.
Seawater is withdrawn for cooling of plant equipment at Lamma Power Station and returnedto the sea after proper treatment.
The amount of plant effluent and rain water collected and recycled at Lamma Power Station
represented 5.1% of the Station’s total consumption of town water.

Page 10 of 25
79

SR: Sharing our Planet – Responsible Resource Management – Water Resources; Key
Statistics and Targets – Summary of Statistics

303-4

Water discharge

NFO:
The wastewater after treatment for removal of oil, grease, suspended solids and heavy metals
was discharged to natural water body and was not used by other parties.
No significant impact on the water bodies and related habitats is caused.
No discharges to water bodies and related habitats that are designated as protected areas.

SR: Sharing our Planet – Responsible Resource Management – Water Resources; Key
Statistics and Targets – Summary of Statistics
303-5

Water consumption

INFO:
The amount of plant effluent and rain water collected and recycled at Lamma Power Station
represented 5.1% of the Station’s total water consumption.

GRI 304 (Ver. 2016): Biodiversity

304-1

Operational sites owned, leased,
INFO:
managed in, or adjacent to, protected
No land was owned, leased, managed in or adjacent to, protected areas and areas of highareas and areas of high biodiversity
biodiversity value outside protected area.
value outside protected areas

304-2

Significant impacts of activities,
products, and services on
biodiversity

INFO:
No land was owned, leased, managed in or adjacent to, protected areas and areas of highbiodiversity value outside protected area.

304-3

Habitats protected or restored

INFO:
No land was owned, leased, managed in or adjacent to, protected areas and areas of highbiodiversity value outside protected area.

EU13

Biodiversity of offset habitats
compared to the biodiversity of theaffected areas

INFO:
No land was owned, leased, managed in or adjacent to, protected areas and areas of highbiodiversity value outside protected area.

GRI 305 (Ver. 2016): Emissions

Direct (Scope 1) GHG emissions

SR: Report Overview; Sustainability at HKEI – Our Business; Key Statistics and Targets –Summary of Statistics

305-2

Energy indirect (Scope 2) GHG
emissionsINFO:HK Electric is a vertically integrated power utility responsible for the generation,transmission, distribution and supply of electricity and our electricity consumption comesfrom our own generation. Hence, the Scope 2 emission is included in the Scope 1 emission
which has been reported in Disclosure Item 305-1 in accordance with the ISO 14064-1
requirements as verified by a qualified independent assessor.

305-4

GHG emissions intensity

SR: Key Statistics and Targets – Summary of Statistics

305-5

Reduction of GHG emissions

SR: Sharing our Planet – Taking Action on Climate Change

305-6

Emissions of ozone-depleting
substances (ODS)

INFO:
Amount of emission of ozone-depleting substances was 305.7 kg of R22. A programme forphasing out this HCFC refrigerant in our air-conditioning systems is in place.

305-1

Page 11 of 2580

305-7

Nitrogen oxides (NOX), sulfur oxides
SR: Sharing our Planet – Improving Air Quality – Emissions from LPS; Key Statistics and(SOX), and other significant air
Targets – Summary of Statistics
emissions

GRI 306 (Ver. 2016): Effluents and Waste
SR: Key Statistics and Targets – Summary of Statistics
306-1

Water discharge by quality anddestination

306-2

Waste by type and disposal method

SR: Sharing our Planet – Responsible Resource Management – Waste Management; Key
Statistics and Targets – Summary of Statistics

306-3

Significant spills

INFO:
No significant spills were recorded.

306-5

Water bodies affected by water
discharges and/or runoff

INFO:
The wastewater after treatment for removal of oil, grease, suspended solids and heavy metals
was discharged to natural water body and was not used by other parties.

INFO:
The effluent was properly treated for removal of oil, grease, suspended solids and heavy
metals before being discharged, and would not cause significant impact on the water bodies
and related habitats.
No discharges to water bodies and related habitats that are designated as protected areas.

GRI 307 (Ver. 2016): Environmental
Compliance
307-1

Non-compliance with environmental SR: Sustainability at HKEI – Sustainability Governance – Governance Practices
laws and regulations

GRI 308 (Ver. 2016): Supplier
Environmental Assessment
308-1

New suppliers that were screenedusing environmental criteria

INFO:
All new suppliers as described in Disclosure Item 308-2.

SR: Working with Partners – Managing our Supply Chain – Responsible Procurement

308-2

Negative environmental impacts inthe supply chain and actions taken

INFO:HK Electric's Code of Practice for Suppliers is included in the application for admission to
Recognised Tenderers Register (RTR) for screening purpose. In 2019, 11 new RTR
applications were processed and 42 existing suppliers were evaluated, and no significant
actual or potential negative environmental impacts were identified.

GRI 400: Social








GRI 103 (Ver. 2016): Management
Approach (forGRI 401 (Ver. 2016): Employment;
GRI 405 (Ver. 2016): Diversity and Equal
Opportunities;
GRI 406 (Ver. 2016): Non-discrimination)

GRI 103 (Ver. 2016): Management
Approach (forGRI 403(Ver. 2018): Occupational Health and
Safety;GRI 416 (Ver. 2016): Customer Health and
Safety)WEB: CSR Policy; Our People and Values; Equal Opportunities
SR: Sustainability at HKEI – Sustainability Governance; Working with Partners –Management Approach, Building Strong Relations with Employees
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.
SR: Sustainability at HKEI – Sustainability Governance; Serving Hong Kong – Management
Approach; Working with Partners – Management Approach, Showing that We Care, Health& Safety; Key Statistics and Targets – Status of Targets in 2019, Looking Ahead
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 12 of 25
81WEB: Equal Opportunities; Enhancing Supplier Partnership






GRI 103 (Ver. 2016): Management
Approach (forGRI 407 (Ver. 2016): Freedom of Association
and Collective Bargaining;
GRI 408 (Ver. 2016): Child Labor;
GRI 409 (Ver. 2016): Forced or Compulsory
Labor;GRI 414 (Ver. 2016): Supplier Social
Assessment)

SR: Sustainability at HKEI – Sustainability Governance; Working with Partners –Management Approach, Managing our Supply Chain
INFO:
Collective bargaining is not applicable (collective bargaining agreements are not required bylaw in Hong Kong).
Major suppliers are required to follow an established procedure for admission to ourRecognised Tenderers Register (RTR) in which our Code of Practice for Suppliers is included
for their compliance. Review of suppliers in our RTR including labour relations and relevant
compliance is conducted on a periodic basis during which the suppliers are required to submit
their CSR performance for evaluation.
Please also refer to General Disclosure Item 102-46 for the topic boundary.



GRI 103 (Ver. 2016): Management
Approach(for other topics under GRI 400: Social)

INFO:
Please refer to the corresponding disclosure items.

GRI 401(Ver. 2016): Employment
SR: Working with Partners – Building Strong Relations with Employees
INFO:
Overall Gender breakdownMale

New hires rate
(%)
401-1

New employee hires and employee
turnover6.1

8.9
Female2.7

Age 30 or below

5.4

Age 31-40

2.0

Age 41-50

0.7

Age 51 or above

0.7

Notes: 1. We have around 1,900 employees in total.
2. Our operations are based in Hong Kong.

Genderbreakdown
Average length of tenureof the employees leaving
employment (Year)

401-2

Age breakdown

Male

12

Female7

Age breakdown
Age 30 or below
Age 31-40
Age 41-50
Age 51 or above

2
6
10
32

INFO:
Benefits provided to full-time
Performance bonus, year-end bonus, gratuity for contract employees, medical benefits,
employees that are not provided
electricity allowance, travel allowance, Group Life and Personal Accident Insurance are not
to temporary or part-time employees
provided to temporary or part-time employees.

INFO:

401-3

Parental leave

Total no. of employees that tookmaternity/parental leave
Rate of return to work of employees who tookmaternity/parental leave
Rate of retention of employees who tookmaternity/parental leave

Male

Female

32

20

100%

100%

97%

95%

Note: All eligible employees were entitled to maternity/parental leave.

Page 13 of 25
82

INFO:Overall

Retire in the next 5 years (%)

EU15

Percentage of employees eligible toretire in the next 5 and 10 years
broken down by job category and byregionRetire in the next 10 years (%)

Employee type breakdown
Staff

14.3

Workman

3.6

Staff

29.8

Workman

6.5

17.9

36.3

Notes: 1. We have around 1,900 employees in total.
2. Our operations are based in Hong Kong.

EU17

Days worked by contractor andsubcontractor employees involved inconstruction, operation &maintenance activities

EU18

Percentage of contractor and
INFO:
subcontractor employees that have
All relevant employees of our contractors working at our work sites have undergone relevant
undergone relevant health and safety
health and safety training.
training

INFO:
The total man-days worked by contractors were 543,000 of which 368,000 man-days weredevoted to construction activities and 174,000 devoted to operation and maintenanceactivities.

GRI 403 (Ver. 2018): Occupational Healthand Safety
SR: Working with Partners – Management Approach, Health & Safety, Managing our Supply
Chain
INFO:
The Corporate Health & Safety Manual covers all Divisions/Departments of HK Electric andit defines the health and safety management system of the company. It is enforced through the
Health & Safety Board chaired by the Managing Director or his delegate as well as the Health& Safety Committees/Sub-committees at various levels.

403-1

Occupational health and safety
management system

Under the Health & Safety Policy, HK Electric is committed to protecting the health andsafety of our employees, customers, contractors and the public by conducting our business ina safe and socially responsible manner. We aim to excel in occupational health and safety
performance and achieve an accident-free operation. To accomplish this, we will comply fully
with all applicable laws and regulations and strive to integrate health and safety considerations
into all aspects of our business activities. In addition, we cultivate a culture that promotes
employee wellness and raises health and safety awareness; adopt and maintain management
systems designed to eliminate health and safety hazards and support continuous performance
improvement; provide necessary information, instruction, training and supervision to ouremployees and also a healthy and safe working environment to them; ensure commitmentsfrom all employees and all levels of management; require our business partners to meet thesame health and safety standards as ours. An Alcohol and Drugs Policy is established toensure a safe and healthy workplace which is free from the effects of alcohol and drugs.

Page 14 of 2583

SR: Working with Partners – Health & Safety, Managing our Supply Chain
INFO:
Our Health & Safety Policy is in place and we adopt and maintain management systems
designed to eliminate health and safety hazards and support continuous performance
improvement. We also provide necessary information, instruction, training and supervision to
our employees and also a healthy and safe working environment to them. We promote
employee wellness and raise health and safety awareness through promotion activities. In
order to heighten safety awareness of working personnel, safety briefings and pre-job risk
assessments are conducted prior to work and when there are changes to the working
environment or work procedures.

403-2

Hazard identification, risk
assessment, and incident

The control of the risk from a hazardous substance/environment, like any other risk, is best
tackled from a risk management perspective. The risk management process includes all
factors related to an activity involving potential hazards, to make a judgement about theassociated risks and implement appropriate controls. Existing substances/materials/work
process/plants are regularly reviewed by the Division/Department Head or his/her specificallydesignated deputy whenever it is known that there is possible hazard.
Employees are encouraged to report any work-related hazards and hazardous situations totheir supervisors, safety professionals, Section/Department Heads or even senior management
through any means including verbal report, phone, email, messages, mobile apps, etc. Theirreports will be followed up immediately by appropriate persons. These measures help tolower overall risk and reduce accidents.
To protect employees against reprisals, a whistleblower hotline connected directly to the Headof Internal Audit is in place to receive any reports of possible work-related hazards andhazardous situations from employees and external parties.
In general, we investigate work-related incidents by gathering information through exploring
all reasonable enquiries; analysing the information by identifying the sequence of events andconditions that led to the incidents, immediate causes, underlying causes and root causes;
identifying the risk control measures; and formulating and implementing action plans.

SR: Working with Partners – Health & Safety
INFO:
Depending on the operational nature, Divisions/Departments have developed their training
plans/schedules. The Division/Department Head is responsible for provision of information,
training and knowledge as necessary to ensure, so far as is reasonably practicable, the safety
and health at work of employees of the Division/Department. Division/Department Heads
regularly review the adequacy of the training program. Induction training/orientation sessions
are given to all new recruits. Effectiveness of the training is evaluated and training records
are maintained.

403-3

Occupational health services

Moreover, we have developed, implemented and maintained a hazard control program as well
as a personal protective equipment (PPE) program. An approved equipment guide is in place
to ensure proper equipment items are provided to employees. Where special safety and healthhazards are present, the Division/Department Heads will arrange to provide adequate andsuitable training for employees to cope with such hazards. The training shall include
providing them information about the safety and health hazards, the safety precautions and theproper use of the protective equipment. Refresher courses shall also be conducted regularly.
Legal requirements on provisions of training to employees and the appointment of competentpersons to carry out certain tasks are defined in the Factories and Industrial Undertakings
Ordinance, Occupational Safety and Health Ordinance and its subsidiary regulations. The
Division/Department Heads must identify the area of training and appoint competent persons
to satisfy the legal requirements. In addition, The Division/Department Heads also regularly
review the adequacy of the divisional/departmental safety promotion and education
programmes and draw up an annual programme for implementation.

Page 15 of 25
84

SR: Working with Partners – Health & Safety

403-4

Worker participation consultation,and communication on occupational
health and safety

INFO:
At HK Electric, different Health & Safety Committees at various levels have been established.
The committee members review the circumstances surrounding work-related injuries, workrelated illnesses and work related dangerous occurrences; advise the management the review
results and make recommendations for improvement; advise the management any proposedchange to the workplace, or plant or substances used in the workplace, that affects, or may
affect, the health and safety of persons in the workplace; They organise/assist health andsafety promotional activities, review the adequacy of health and safety communication andpublicity in the workplace; and report/feedback the comments/suggestions of the employee
group he or she represents on health and safety aspects.
Communication meeting and sessions are organised. Relevant information is circulated via
emails and posted on the notice boards. To facilitate employees to obtain the Health & Safety
Information, a “Health & Safety Information” corner is set up on Corporate Intranet Portal.
The Health & Safety Board, chaired by the Managing Director or his delegate, oversees healthand safety matters. At least half of the members of the Board are responsible for advising on
relevant matters raised by the employees through Committees and Sub-Committees. The
Board shall meet at least once every 3 months. Under the Health & Safety Board, there are
four Divisional Health & Safety Committees. The Divisional/Departmental Health & Safety
Committee should meet at least once every three months. Under the Divisional Health &Safety Committees, there are departmental Health & Safety Committees. Health & Safety
Subcommittees were formed for staff/frontline employees/contractors.

SR: Working with Partners – Health & Safety; Key Statistics and Targets – Summary of
Statistics

403-5

Worker training on occupational
health and safety

INFO:
We provide various occupational health and safety training to employees. The
Division/Department Head is responsible for provision of information, training andknowledge as necessary to ensure, so far as reasonably practicable, the safety and health atwork of employees of the Division/Department. He/she shall identify and regularly review
the training needs of the employees under his/her control in consideration of their operational
activities. Induction training for new recruits and for new works, special hazard training andstatutorily required training are provided.
For example, Newcomers Induction Training, Natural Gas Safety Training, Demonstration on
Use of Life Jackets, Safety Briefing for Safe Handling of Chemicals, Environmental
Awareness Training, Safety Rules briefing training for Competent Person, Mandatory Basic
Safety Training (Full) Course, Safety Training Course for Competent Persons in ConfinedSpaces Operation (Competent Person Full Course), Adult Cardio Pulmonary Resuscitation
Certificate Course, Road Safety Training Course, Training Course on Safe Use and Inspectionof Lifting Appliances and Lifting Gear, Training for Work Safe Behaviour, Manual Handling
Operations and Prevention of Back Injuries, and Health Talks etc.
Please also refer to Disclosure Item 404-1 for the health and safety training hours for our
employees.
SR: Working with Partners – Showing that We Care, Health & Safety
INFO:
Our employees are covered by Hospitalisation and Outpatient schemes and they can accessthe information of the schemes via corporate intranet and hotline provided by service
providers.

403-6

Promotion of worker healthFemale employees with one year's service or more are eligible for an annual gynaecologicalexamination subject to a maximum claim amount. Meanwhile, employees aged 45 or above
with one year’s service or more are eligible for Biennial Medical Check-Up. Employees notmeeting the requirements may join the Medical Check-up plan on a self-financed basis atpreferential rates.
Injection of Quadrivalent Vaccine is arranged for registered employees at 4 office locations
and at designated clinics on an annual basis.
Meanwhile, we provide lactation rooms in our workplaces for breastfeeding mothers.

Page 16 of 25
85

SR: Working with Partners – Management Approach, Health & Safety
INFO:
We adopt an Enterprise Risk Management Framework to deal with top strategic corporaterisks. Health & Safety is considered to be one of our strategic corporate risks. Our Enterprise
Risk Management Framework includes detailed mitigation actions for the risks.

403-7

Prevention and mitigation of OHS
impacts directly linked by business
relationships

To prevent significant negative occupational health and safety impacts, the following actions
are taken:
Formulate and implement Safety Management System (SMS) Audit Plan and Safety
Promotion Plan;
Comply with H&S regulations by implementing and updating various guidelines,
standards and instructions and conducting compliance reviews regularly;
Inform employees of existing and emerging legal and other obligations that apply totheir job responsibilities;
Bring in independence & expertise by calling in external auditors for SMS Audits;
Ensure that all employees of contractors are properly briefed, adequately trained,
and provided with adequate safety information and PPE;
Implement Competent Person system for contractors working on or near ourfacilities
Organise regular safety sharing meetings among contractors, and invite Labour
Department and other safety organizations to promote H&S awareness;
Eliminate hazards caused by material issues by identifying these issues andcompiling a guideline for selecting proper materials;
Integrate hazard identification & risk assessment early during the design of work
procedures & work processes, and introduction of new apparatus & tools; andReview the existing substances/materials/work process/plant whenever it is known
that there is possible hazard.

SR: Working with Partners – Management Approach, Health & Safety

403-8

INFO:
Workers covered by an occupational The Corporate Health & Safety Manual covers all Divisions/Departments of HK Electric andhealth and safety management
it defines the health and safety management system of the company. Our Safety Management
systemSystems (SMS) conform to the ISO 45001 standards for all major operations.
All our employees and those contractor personnel working for us are represented in therelevant committees.

Page 17 of 25
86

SR: Working with Partners – Health & Safety; Key Statistics and Targets – Summary of
Statistics
INFO:
For our employees:

403-9

Work-related injuries

Number of fatalities
Number of lost time injuries
Lost Time Injury Frequency Rate (LTIFR)(per 200,000 employee-hours)
Numbers of days lost/charged(no. of employee-days)
Lost Time Injury Severity Rate (LTISR)(per 200,000 employee-hours)Longest period without a lost time injury(no. of calendar days)
Number of reported traffic accidents(no. of cases)
Number of high-consequence work-related
injuries
Rate of high-consequence work-related injuries(per 200,000 employee-hours)
The main types of work-related injury
The number of employee-hours
For contractor workers engaging in HK Electric’s jobs:
Number of fatalities
Number of lost time injuries
Lost Time Injury Frequency Rate (LTIFR)(per 200,000 contractor-hours)
Number of days lost/charged(no. of contractor-days)
Lost Time Injury Severity Rate (LTISR)(per 200,000 contractor-hours)
Number of high-consequence work-related injuries
Rate of high-consequence work-related injuries(per 200,000 contractor-hours)
The main types of work-related injury
The number of contractor-hours

Male
0
1

Female00Overall
0
1

0.07

0

0.05

19

0

19

1.26

0

1.02

213

365

213

6

0

6

0
0
Hit by moving object
3,715,041
013
0.6
1,421.5
65.48
4
0.18
Trip and fall
4,341,459

Notes:
1. Minor injuries not causing lost day were not included.
2. 'Days' referred to 'scheduled workdays'.
3. Our operations are based in Hong Kong
4. “High-consequence work-related injuries” refer to work-related injury that results in a
fatality or in an injury from which the worker cannot, does not, or is not expected to recover
fully to pre-injury health status within 6 months.
SR: Working with Partners – Health & Safety; Key Statistics and Targets – Summary of
Statistics

403-10Work-related ill health

INFO:
No employees with high incidence or high risk of diseases related to their occupation wereidentified.
In 2019, the sick leave rate of our employees was 3.7. (N.B. Sick leave rate is the workday
lost due to sickness x 2,000 per total number of employee hours. Sick leave due to workrelated accidents is not counted.) No cases of occupational diseases were reported in 2019.

GRI 404 (Ver. 2016): Training and
Education
WEB: Our People and Values; Learning & Development

GRI 103 (Ver. 2016): Management Approach
2016

SR: Sustainability at HKEI – Sustainability Governance; Working with Partners –Management Approach, Nurturing Talent
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 18 of 25
87

SR: Working with Partners – Nurturing Talent – Opportunities for Growth
INFO:
Genderbreakdown
Averagetraining
hours
404-1

Average hours of training per year
per employee

Male

32.2

Female26.0

Employee category
breakdown
Senior staff
29.6
General staff

Overall average training
hours

33.1

31.0

Workman
14.6
Total
58,695training
hours
Remark:
The training hour figures in the above table exclude those employees who left the company in2019.
Total training hours of the employees who left the company in 2019 = 1,544
The total health and safety training hours for employees was 17,047 and 64.6% of ouremployees participated in health and safety training as at end 2019.

404-2

404-3

Programs for upgrading employee
skills and transition assistanceprograms
Percentage of employees receiving
regular performance and careerdevelopment reviews

WEB: Learning & Development
SR: Working with Partners – Nurturing Talent – Opportunities for Growth

INFO:
100%

GRI 405 (Ver. 2016): Diversity and Equal
Opportunity
405-1

405-2

Diversity of governance bodies andemployees

Ratio of basic salary andremuneration of women to men

SR: Working with Partners – Building Strong Relations with Employees
AR: Boards of Directors and Senior Management; Combined Corporate Governance Report
INFO:
Senior staff: 92%
General staff: 83%
Workman: 61%
Overall: 80%
Note: Our operations are based in Hong Kong.

GRI 406 (Ver. 2016): Non-discrimination
406-1

Incidents of discrimination andcorrective actions taken

INFO:
No incidents of discrimination were recorded.

GRI 407 (Ver. 2016): Freedom of
Association and Collective Bargaining
SR: Working with Partners – Managing our Supply Chain – Responsible Procurement
INFO:
Collective bargaining is not applicable (collective bargaining agreements are not required bylaw in Hong Kong).

407-1

Operations and suppliers in which
the right to freedom of associationand collective bargaining may be atrisk

No operations identified in which the right to exercise freedom of association may be violated
or at significant risk. We have dialogue with the Trade Union through written communicationor telephone calls whenever required. Meeting with employees participating in the Union isconducted on an as-needed basis and two hoc meetings with some of their representatives
were held during the year.
HK Electric's Code of Practice for Suppliers is included in the application for admission to
Recognised Tenderers Register (RTR) for screening purpose. In 2019, 11 new RTR
applications were processed and 42 existing suppliers were evaluated, and no suppliers inwhich the right to exercise freedom of association may be violated or at significant risk wereidentified.

Page 19 of 25
88

GRI 408 (Ver. 2016): Child Labor
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices

408-1

INFO:
All recruitments through Human Resources Division are coupled with proper checking of theage of the employees to ensure full compliance with the Employment Ordinance of Hong
Operations and suppliers at
Kong. In addition, no operations identified as having significant risk with incidents of childsignificant risk for incidents of childlabour.
labor
HK Electric's Code of Practice for Suppliers is included in the application for admission to
Recognised Tenderers Register (RTR) for screening purpose. In 2019, 11 new RTR
applications were processed and 42 existing suppliers were evaluated, and no suppliers having
significant risk with incidents of child labour were identified.

GRI 409 (Ver. 2016): Forced or Compulsory
Labor
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices

409-1

Operations and suppliers at
significant risk for incidents offorced or compulsory labor

INFO:
No operations identified as having significant risk for incidents of forced or compulsory
labour.
HK Electric's Code of Practice for Suppliers is included in the application for admission to
Recognised Tenderers Register (RTR) for screening purpose. In 2019, 11 new RTR
applications were processed and 42 existing suppliers were evaluated, and no suppliers having
significant risk with incidents of forced or compulsory labour were identified.

GRI 412 (Ver. 2016): Human Rights
Assessment
SR: Sustainability at HKEI – Sustainability Governance
GRI 103 (Ver. 2016): Management Approach

INFO:
We support human rights consistent with the Universal Declaration of Human Rights.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

412-1

Operations that have been subject tohuman rights reviews or impact
assessments

INFO:
All 13 business units were subjected to human rights reviews and impact assessments.

GRI 413 (Ver. 2016): Local Communities
SR: Sustainability at HKEI – Sustainability Governance; Sharing our Planet – Management
Approach; Serving Hong Kong – Management Approach; Working with Partners –Management Approach; Key Statistics and Targets – Status of Targets in 2019, Looking
Ahead
GRI 103 (Ver. 2016): Management Approach

INFO:
Our Public Affairs Department arranges annual meeting with a number of business units forreviewing their work on communication with stakeholders.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

413-1

Operations with local community
engagement, impact assessments,
and development programs

INFO:
CSR considerations as described in this report are integrated in all our operations.

413-2

Operations with significant actualand potential negative impacts on
local communities

INFO:
No operations would cause significant actual or potential negative impacts on local
communities as our operations are integrated with effective CSR initiatives as described inthis Report.

Page 20 of 25
89

Number of people physically or
economically displaced andEU22compensation, broken down by typeof projectGRI 414 (Ver. 2016): Supplier Social
Assessment
414-1

New suppliers that were screenedusing social criteria

INFO:
No projects involved displacement of people or compensation.

INFO:
All new suppliers as described in Disclosure Item 414-2.
SR: Working with Partners – Managing our Supply Chain

414-2

Negative social impacts in the
supply chain and actions taken

INFO:HK Electric's Code of Practice for Suppliers is included in the application for admission to
Recognised Tenderers Register (RTR) for screening purpose. In 2019, 11 new RTR
applications were processed and 42 existing suppliers were evaluated, and no significant
actual or potential negative social impacts were identified.

GRI 416 (Ver. 2016): Customer Health and
Safety416-1

Assessment of the health and safety
impacts of product and service
categories

INFO:
All of our significant product and service have undergone health and safety impact assessment
for improvement.

416-2

Incidents of non-complianceconcerning the health and safety
impacts of products and services

SR: Sustainability at HKEI – Sustainability Governance – Governance Practices

Number of injuries and fatalities tothe public involving company assets
including legal judgments,
EU25
settlements and pending legal casesof diseases
GRI 417 (Ver. 2016): Marketing andLabeling

INFO:
One minor injury case was recorded and settled.

WEB: Quality Policy; Supply Rules; Guide to Connection of Supply; Privacy Policy
GRI 103 (Ver. 2016): Management Approach

SR: Serving Hong Kong – Serving our Customers – Excellent Service
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices; Serving
Hong Kong – Serving our Customers – Excellent Service

417-1

Requirements for product andservice information and labeling

417-2

Incidents of non-complianceconcerning product and service
information and labeling

INFO:
Our product is electricity and the sustainability issues in our operations are covered in all
sections of this Report and other GRI disclosures. The marketing mechanism described in thisdisclosure has little relevance to us as our product is electricity.
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices

GRI 418 (Ver. 2016): Customer Privacy
WEB: Privacy Policy; Code of Conduct
SR: Sustainability at HKEI – Sustainability Governance – Governance Practices; Serving
Hong Kong – Serving our Customers – Excellent Service

GRI 103 (Ver. 2016): Management Approach

INFO:
We have published a Privacy Policy Statement on personal data privacy, which governs thehandling of personal data and ensures compliance with the Personal Data (Privacy)
Ordinance. The Policy complies with the regulatory requirements in direct marketing under
the Personal Data (Privacy) Amendment Ordinance.
Guideline on Handling Customer Personal Data is also in place.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 21 of 2590418-1Substantiated complaints concerning INFO:
breaches of customer privacy andNo substantiated complaints regarding breaches of customer privacy or losses of customer
losses of customer data
data were recorded.

GRI 419 (Ver. 2016): Socioeconomic
Compliance

GRI 103 (Ver. 2016): Management Approach

SR: Sustainability at HKEI – Sustainability Governance; Serving Hong Kong – Management
Approach; Working With Partners – Management Approach
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Non-compliance with laws andregulations in the social andeconomic area
TOPIC: DISASTER / EMERGENCY
PLANNING AND RESPONSE
419-1

SR: Sustainability at HKEI – Sustainability Governance – Governance Practices

SR: Sustainability at HKEI – Sustainability Governance; Working with Partners – Health &Safety – Contingency Preparedness
INFO:
Our Crisis Management Plan (CMP) is aimed at giving a broad outline at the macro level of
HK Electric’s response to an emergency affecting several Divisions, which could cause
potential damage to HK Electric’s long-term business plans. The plan covers all
Divisions/Departments of HK Electric. In order to secure the best interests of HK Electric andrestore good order as soon as possible in the event of crisis, a Crisis Management Team
(CMT) may be formed on the direction of the Managing Director.
At the micro level, individual Divisions/Departments prepare their own instructions tomaintain the continuity of their business and have comprehensive plans to deal with
contingency.
GRI 103 (Ver. 2016): Management
Approach(and description on contingency planningmeasures, disaster/emergency management
plan and training programs, andrecovery/restoration plans)

The CMP will be reviewed and revised as and when necessary. A drill to test the effectivenessof the formation of CMT has been staged once a year. The drill scheduled for 2019 was
postponed to 2020, due to the busy erection and commissioning activities related to theerection and commissioning of a new gas-fired unit L10.
We have contingency plan for handling of power interruption. Contingency Plans for
Significant Events are in place.
Significant Events include:
Earthquake
Failure of Main Energy Management System / Distribution Management System or
System Control Centre becomes inoperativeBoth System Control Centre and Remote System Control Centre are not available

System blackoutExtensive damage to generation facilityExtensive damage to transmission facility
We regularly conduct drills to ensure the effectiveness and robustness of these plans andprocedures.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 22 of 25
91

TOPIC: ACCESS
WEB: Concessionary Tariff Schemes; Caring Services; Smart Power Care Fund; Relief
Measures
GRI 103 (Ver. 2016): Management
Approach and description on programs,
including those in partnership withgovernment, to improve or maintain access toelectricity and customer support services

SR: Serving Hong Kong – Management Approach; Serving Hong Kong – Reliable andAffordable Power – Alleviating Economic Hardship; Serving Hong Kong – Smart PowerServices
INFO:
We supply electricity to Hong Kong Island and Lamma Island which are generally highly
urbanised areas and well-covered by our supply network.
Please also refer to General Disclosure Item 102-46 for the topic boundary.

EU26

Percentage of population unserved in INFO:
licensed distribution or service areas 0%

EU27

Number of residential
disconnections for non-payment,
broken down by duration of
disconnection and by regulatory
regimeINFO:
Sufficient notice would be communicated to customers with ample time to settle the nonpayment, before executing the disconnection. In fact, the no. of non-payment cases which leadto disconnection is very small as compared to the customer base of 581,000 accounts. In 2019,
there were 945 residential accounts (0.2%) being disconnected due to non-payment while wehave acceded to 1,404 accounts for payment deferral from residential customers. In
accordance with our service pledge, supply will be re-connected on the same day as payment
is received. In addition, we provide energy efficiency advice to customers, and are willing tolisten to customers with difficulties in bill settlement to see what we can help.

EU28

Power outage frequency

INFO:
SAIFI = 0.066

EU29

Average power outage duration

INFO:
SAIDI = 0.01

EU30

Average plant availability factor byenergy source and by regulatory
regime

SR: Key Statistics and Targets – Summary of Statistics
INFO:
The plant availability broken down into gas and coal & oil are 90.7% and 91.0% respectively.

TOPIC: PROVISION OF INFORMATION
WEB: Caring Services; Smart Power Care Fund
GRI 103 (Ver. 2016): Management Approachand description on practices to address
language, cultural, low literacy and disability
related barriers to accessing and safely using
electricity and customer support services

SR: Serving Hong Kong – Serving our Customers – Excellent Service; Serving Hong Kong –Serving our Customers – Smart Power Services; Serving Hong Kong – Caring for theCommunity – Caring for an Ageing Population; Working with Partners – Health & Safety –Contingency Preparedness
INFO:
Please also refer to General Disclosure Item 102-46 for the topic boundary.

Page 23 of 25
92

Table for General Disclosure Items 102-40, 102-42 and 102-43
Stakeholder groups
Customers

Why are their views important?
Electricity is a daily necessity for our customers.

Common engagement channels
1, 2, 3, 4, 5, 6, 7

Shareholders

We are accountable to our shareholders.

1, 2, 6, 7

Employees

We have a responsibility to care for our employees who devote much of
their time to us and we depend on them for our success.

1, 2, 3, 4, 5, 6, 7

Business partners

Having common CSR values is important in business relationships.

1, 2, 5, 6, 7

Local communities

We care for the communities we serve.

1, 2, 3, 4, 6, 7

NGOs and professional
institutions

They are our key CSR and industry partners.

1, 2, 3, 4, 6, 7

Education sector

We support green education particularly for students.

1, 2, 3, 4, 5, 6 , 7Authorities and legislators Authorities and legislators have a regulatory role in our utility business.

1, 2, 4, 6, 7

Media

1, 6, 7The media is an important partner in our communications with the public.

Remarks
1 Meetings, conversations and enquiries
2 Visits, talks, seminars, workshops and exhibitions
3 Advisory services and community programmes
4 Consultation panels, focus groups and liaison teams
5 Surveys and suggestion schemes
6 Mobile apps, intranet, website, YouTube channel and Facebook pages
7 News, reports and other publications

Page 24 of 25

93

Table for General Disclosure Items 102-44, 102-46 and 102-47
A specialised stakeholder engagement exercise was conducted in end 2018. Questionnaires were issued to a number of representatives of the key
stakeholder groups to collect their views on HKEI’s sustainability reporting. After a review in end 2019, it is considered that the findings arestill relevant for 2019.
Making reference to the GRI Standards, a total of 35 relevant sustainability topics have been identified by HKEI based on their relevance to its
business. Material sustainability topics are defined as those with rounded overall rating above “6”. After conducting the materiality assessment,
30 out of the 35 relevant sustainability topics identified were found material. The remaining 5 topics which are not material are shaded in thetable below.
Sustainability Topic

Stakeholders’ Rating(0-5 scale)

HKEI’s Rating(0-5 scale)

Overall Rating(0-10 scale)1

Corporate governance

4.2

5

9

2

Compliance*

4.3

5

9

3

Stakeholder engagement

4.1

4

8

4

Innovation**

4.0

5

9

5

Economic performance*

4.3

5

9

4.0

2

6

4.2

3

7

3.8

3

7

6
7
8

Market presence - contribution to local economic development*(in particular local hiring)
Indirect economic impacts*(including energy infrastructure investments and affordable energy)
Procurement practices*(in particular proportion of spending on local suppliers)

9

Anti-corruption*

4.3

5

9

10

Anti-competition behaviour*

4.2

4

8

11

Operation performance*(including supply reliability and generation efficiency)

4.5

5

9

12

Sustainable use of resources and materials*

4.2

5

9

13

Energy consumption and saving*

4.3

5

9

14

Water resources conservation*

4.2

5

9

15

Biodiversity conservation*

4.0

4

8

16

Climate change, clean energy and emissions*

4.2

5

9

17

Effluent and waste management*

4.2

5

9

18

Employment practices**

4.0

4

8

19

Employee consultation and communication practices for significant
operational changes**

4.1

2

6

20

Occupational health and safety*

4.3

5

9

21

Training and development**

4.2

4

8

22

Non-discrimination, diversity and equal opportunity*

4.1

4

8

23

Freedom of association and collective bargaining*

3.8

3

7

24

Child and compulsory labour*

3.8

3

7

25

Security practices with due respect for human rights*

4.1

2

6

26

Rights of indigenous peoples*

3.8

2

6

27

Human rights assessment*

3.9

3

7

28

Contribution to and impact on local communities*

4.4

4

8

29

Supplier CSR assessment*

4.1

3

7

3.9

2

6

4.2

5

9

4.3

5

9

4.1

4

8

30
31
32
33

Participation in public policy development*(including political contributions)Customer health and safety*
Customer services*(including access to electricity and emergency services)
Product and services information and labelling, and marketing
communications*34

Customer privacy*

4.3

5

9

35

Emergency preparedness*

4.4

5

9

Topic boundary:*Inside and outside organisation; **Inside organisation only

Page 25 of 25

94

Recommendation for the GRI-101 review to improve coverage of
GRI’s PRINCIPLES FOR REPORT CONTENTThis file has extracts from GRI’s current Standards GRI-101 17 - 19; GRI-102 pages 33 – 35
plus pages 32 to 40 of the 2013 version of the G4 Implementation Manual.
GRI’s current standards made good changes from G4 in (a) dropping ‘Aspects’ so we justtalk about ‘Topics’. (b) Having a clear description on GRI-101 pages 7 to 12 of each of thefour principles including the ‘tests’ for whether a principle is met.
GRI-101 Section 2 on pages 17 to 19, however falls well short of the useful way in which
G4 described how to apply the Principles for Report Content.
Specifically GRI standards dropped Fig 2, 3, 4 and 5 together with the narrative on how toapply the Principles of Report Content by going through for four steps of ‘Identification,
Prioritisation, Validation and Review’? I have found this very helpful and continue to
use it when I teach ESG Management & Reporting. Please can GRI add it to Standards aspart of its update of GRI-101. A good starting point is page 40 of G4.
J Robert Gibson 27 April 2020

GRI Standards GRI-101 page Downloaded Feb 2020

95

GRI Standards GRI-101 page 18 Downloaded Feb 2020

96

GRI Standards GRI-101 page 19 Downloaded Feb 2020

97

GRI Standards GRI-102 page 33 Downloaded Feb 2020

98

GRI Standards GRI-102 pages 34 and 35 Downloaded Feb 2020

99

100

101

102

103

104

105

106

107

Harmonisation?

Paul Druckman, CEO, IIRC: “IIRC acknowledges:• IFAC’s work on corporate reporting to support a more sustainable global economy.”• IFRS Foundation, through IASB, develops financial reporting standards.
• GRI’s develops sustainability reporting guidelines and standards .”The reporting capstone
MEMORANDUMS OF UNDERSTANDING TO:“promote the global harmonization and clarity of corporate reporting frameworks”“proactively engage with each other”“strive for complementarity in the ongoing development thereof”“We support the IIRC’s vision of theevolution of corporate reporting, andthrough this agreement we will
cooperate on important areas ofmutual interest.” Hans Hoogervorst,
Board Chairman, IASB

“Traditional financial reporting alone “GRI commits to develop and maintain its
is no longer enough for investors andguidelines and standards with the intent
stakeholders. A more complete picture that these will be (to the extent reasonable
is needed, and the work of the IIRC will
and practicable) compatible with andhelp guide organizations to achieve
supportive of <IR>” Ernst Ligteringen,this.” Ian Ball, CEO, IFAC
Chief Executive, GRI

108

Harmonisation?

Corporate Reporting Dialogue
Report September 2019https://corporatereportingdialogue.com/publication/drivingalignment-in-climate-related-reporting/109

2

Harmonisation?

CRD: Better Alignment Project Sept 2019 findings
GRI, SASB, CDP and TCFD objectives are aligned but they use
different terms which confuses report preparers/users.
Actions therefore:• Develop a common taxonomy and encourage allstandard/framework setters to use the same language.
• Provide an online interactive tool to allow report
preparers/users to quickly see what each standard says on
the same topic/issue.
• Get the standard/framework setters to work together sofuture changes increase harmonisation. A key issue being to
get a common set of Reporting Principles.
1103Comparison between the GRI Reporting Principles and <IR> Guiding Principles

Full overlap

Partial overlap------------------------------------------------------------ GRI Reporting Principles --------------------------------------------------------------------Principles for defining report content

Main differences:
1) The primary purpose an <IR> to explain to providers of financial
capital how an organisation creates value over time. GRI aims tomeet the reasonable expectations and interests of all stakeholders.
2) <IR> discusses the creation of value over the short, medium andlong term for six capitals. GRI discusses economic, environmental &social performance and impacts.

The organisation
should identify its
stakeholders, andexplain how it has
responded to theirreasonable
expectations andinterests.

The report shouldpresent theorganisations
performance in thewider context ofsustainability

Principles for defining report quality

The organisation should
The report should
The report should
The organisation
select, compile and reportcover Aspects that (a)include coverage ofshould gather, record,
information consistently.
Reflect thematerial Aspects and
The report should
The organisationcompile, analyse and
The reporting information
The reported
The organisation
organisation's
their Boundaries,
reflect positive andshould makedisclose information
should be presented in a information should be should report on asignificant economic,
sufficient to reflect
negative aspects of theinformation available and processes used inmanner whtat enables
sufficiently accurate
regular schedule soenvironmental andsignificant economic,
organisation'sin a manner that is preparation of a reportstakeholders to analyseand detailed forthat information issocial impacts, or (b) environmental and social performance to enable
understandable and in a way that they canchanges in thestakeholders to assess available in time for
Substantively
impacts, and to enablea reasoned
accessible tobe subject toorganisation's
the organisation's
stakeholders to makeinfluence thestakeholders to assess assessment of overall
stakeholders using the examination and that
performance over time,
performance.
informed decisions.
assessments andthe organisation's
performance.
report.
establishes the quality
and that could support
decisions of
performance in theand materiality of theanalysis relative to otherstakeholders.
reporting period.
information.
organisations.

GRI coverage<IR> Guiding Principles

Stakeholder
inclusivenessSustainability context

Materiality

Completeness

BalanceComparability

Accuracy

Timeliness

Clarity

Reliability

Strategic focus and future orientation: An integrated report
should provide insight into the organization’s strategy, and howthat relates to its ability to create value in the short, medium andlong term and its use of and effects on the capitals.

Only covered 'implicitly.

Connectivity of information: An integrated report should show,
a holistic picture of the combination, inter-relatedness anddependencies between factors that are material to theorganization’s ability to create value over time.

Only covered 'implicitly.

Stakeholder relationships: An integrated report should provide
insight into the quality of the organization’s relationships with its
key stakeholders and how and to what extent the organization
understands, takes into account and responds to their legitimate
needs and interests.

Only covered 'implicitly.

Materiality: An integrated report should disclose information
about matters that substantively affect the organization’s ability
to create value in the short, medium and long term.

IR has value focus
whereas GRI talks about
impacts.

Conciseness: An integrated report should be concise.

GRI doesn't ask for
concise but it does ask
for reports to beunderstandable andaccessible.

Reliability and completeness: An integrated report should
include all material matters, both positive and negative, in abalanced way, without material error.

Yes

Consistency and comparability: The information in an integrated
report should be presented on a basis that is consistent overtime and in a way that enables comparison with otherorganizations to the extent it is material to the organization’s
own ability to create value over time.

Yes<IR> coverage

Yes: Covered by
Stakeholder
Relationships

Yes1) IR has value focus
whereas GRI talks
about impacts.
2) GRI doesn't ask for
conciseness but it does
ask for reports to beunderstandable andaccessible.

Yes

Yes

Yes

Yes

Not mentioned by<IR>

IR asks for concisenessrather than than
Only covered implicitly
making reports to be
by <IR>
understandable andaccessible.

111

350

Email 19

351

From:

Alodia Ishengoma

352

Sent on:Monday, June 22, 2020

353

To:

Standards

354

Subject:'Public Comment Revised GSSB Work Program 2020-2022'

355

Dear Sir/Madam,

356

Thanks for your trust and I take this opportunity to congratulate you for the work done so far.

357

1. Lines numbers 54 – 73; Sec Line number 41: Sector program

358
359
360

For me, all (Standards, topics, sectors in priority groups, etc.) are so important that it is difficult toprioritize. Can it be true that the review of some GRI standards is more expensive than others? If
that is the case then prioritize the cheapest one and review it in accordance with funds available.

361

2. Line numbers 80 – 81; Sec line number 78: Issuance of FAQs,………

362

How are the persons with disability accommodated in the application of GRI Standards?

363

Best Regards

364

Alodia112

365

Email 20

366

From:

Ignatius Kauvee

367

Sent on:

Tuesday June 23, 2020

368

To:

Standards

369

Subject:'Public Comment Revised GSSB Work Program 2020-2022'

370

Dear Sir/Madam,

371
372

I would herewith like to extend my sincere gratitude for the opportunity to provide this comments
regarding the subject line.

373
374

6 Consider the enlargement of the stakeholder base by assuming pilot projects from environmental
assessments and environmental management and reporting;375

17 consensus, adaptability and relevance376

19 inclusive research both geographical and time-bound377

43 GRI sector program tend to be too simplistic

378
379

46 sector-specific impacts information can be derived from selected pilot environmental
assessments and environmental management planning reporting

380

55, 63 sectors of oil, gas and coal can include mining

381

67 fishing can both be an extractive upstream priority 1 sector and a priority 2 sector

382

Best regards,

383

Ignatius Kauvee

113

384

Email 21

385

From:

Ertan Kucukyalcin

386

Sent on:Sunday, April 26, 2020

387

To:

Standards

388

Subject:'Public Comment Revised GSSB Work Program 2020-2022'

389

Dear GSSB Members;

390
391

I would like to thank the GRI in giving me the opportunity to share my thoughts on the GSSB Work
Program.

392

I would like to share my suggestion below;

393
394
395

•
The coronavirus impacted the environment positively, which is good in terms ofsustainability (https://www.bbc.com/future/article/20200326-covid-19-the-impact-of-coronaviruson-the-environment )

396
397

•
The coronavirus impacted the companies negatively, which is bad in terms of sustainability(https://www.bbc.com/news/business-52114414 )

398
399

•
The coronavirus impacted employment negatively, which is bad in terms of sustainability(https://www.bbc.com/news/business-52199888 ) .

400
401
402
403

The spread (or the fear of spread) of the virus has positive impact on sustainability at macro level(environment), but the same event has negative impact at micro level (company/employee).
Therefore, I suggest making this distinction explicit and revising definition of "sustainability" as toadress macro-sustainability and micro-sustainability.

404
405

Note: Indeed, I believe this ambigiouty is not limited to the recent events, but may arise in various
moments where there is a conflict between different stakeholders' interests.

406(Line number: 34 and "Key Terms" in the Standards)

407

Kind Regards;

408

Ertan Küçükyalçın

114

409

Email 22

410

From:

Jeff Wright

411

Sent on:Thursday, April 23, 2020

412

To:

Standards

413

Subject:'Public Comment Revised GSSB Work Program 2020-2022'

414

I feel that GRI needs to work on Priority Group 1, Forestry, Paper and Rubber.

415
416

While there are a number of certification schemes there is no single agreed to sustainability
reporting system or format. GRI needs to develop this.

417

As an SC member I am able to assist.

418

Jeff Wright Dphil Oxon

115