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

Item 04 – GRI Sector Standards
Project for Oil, Gas, and Coal – input
on GRI Topic Standards
For GSSB information
Date

11 June 2021

Meeting

1 July 2021

Project

GRI Sector Standards Project for Oil and Gas

Description

This document summarizes the input relevant to GRI Topic Standards collectedduring the development of GRI 11: Oil and Gas Sector 2021. This document
includes the preliminary opinion of the Standards Division based on the outcomesof the Oil, Gas, and Coal Project to date. However, recommendations to the
GSSB work program will be made by the Standards Division on the basis of
cumulative input from multiple Sector Standards projects.

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

© GRI 2021

1

Contents
Item 04 – GRI Sector Standards Project for Oil, Gas, and Coal – input on GRI Topic Standards ......... 1
For GSSB information ......................................................................................................................... 1
Contents .................................................................................................................................................. 2
Background ............................................................................................................................................. 3
Input on Topic Standards ........................................................................................................................ 3
Based on the Sector Standard ............................................................................................................ 3
Further feedback from the Working Group .......................................................................................... 4
Input received during public exposure ................................................................................................. 4
Preliminary opinion .................................................................................................................................. 4
Appendix 1. Public comments on Topic Standards collected during the exposure period for the Oil and
Gas Sector Standard ............................................................................................................................... 5

Page 2 of 16

2

Background3
4
5

Along with the developing GRI Sector Standards, as outlined in the Program Description, the GRISector Program is to support the enhancement and expansion of the GRI Standards by surfacing
issues not previously covered in the GRI Standards.

6
7
8

The Standards Division will make proposals to the Global Sustainability Standards Board (GSSB) for
the development of new or the revision of existing Standards, which the GSSB will consider andprioritize during the regular reviews of the GSSB work program as per the Due Process Protocol.

910

Feedback on GRI Topic Standards was collected throughout the GRI Sector Standards Project for Oiland Gas from the following sources:

11•

Research activities, including for the project proposal and the Standard;

12•

Project working group discussions and input; and13•

Responses received during public exposure.

14
15
16
17

This document summarizes this feedback and also includes the preliminary opinion of the Standards
Division based on the outcomes of the Oil and Gas Project. Recommendations to the GSSB work
program will be made by the Standards Division on the basis of cumulative input from numerous
Sector Standards projects.

18

Input on Topic Standards

19

Based on the Sector Standard

20
21

GRI 11: Oil and Gas Standard 2021 contains four topics for which no dedicated (or closely related)
Topic Standard exists, namely:

22
23
24
25

•
•
•
•

26
27

In addition, to achieve complete reporting for the sector, the Working Group identified disclosure gaps
for the following topics which necessitated some degree of additional sector reporting:

28
29
30
31
32
33
34
35
36
37
38
39

•
•
•
•
•
•
•
•
•
•
•
•

40
41
42

Of these, the additional reporting included for anti-corruption, local communities and rights ofindigenous peoples is highly relevant but does not appear to be unique to the sector. It is not yet clear
if the additional reporting for the other topics will be relevant for other sectors.

Asset integrity and critical incident management
Climate adaptation, resilience, and transition
Closure and rehabilitation
Land and resource rights

Air emissions
Anti-corruption
Biodiversity
Conflict and security
Economic impacts
GHG emissions
Local communities
Payments to governments
Public policy
Rights of Indigenous peoples
Waste
Water and effluents

Page 3 of 16

43Further feedback from the Working Group

44
45
46
47

The Working Group has consistently advocated for enhanced reporting related to climate change, inparticular on the topic of climate resilience, adaption, and transition. It was concluded that climatechange, in particular the transition to a low-carbon economy, is the single most important issue for thesector, and the existing reporting under the GRI Standards was identified as insufficient.

48
49
50

The Working Group specified there is a stakeholder expectation to see reporting on aspects such asboard responsibility for climate change, the setting of emissions targets, investment in emissionsintensive activities, climate change-related lobbying, and consideration of a just transition.

51
52
53
54
55

The Working Group flagged that GRI 411: Rights of Indigenous Peoples 2016 is potentiallyinadequate to report on the rights of indigenous peoples and, in particular, they noted the lack ofreporting on free, prior and informed consent (FPIC). This is of key relevance for the sector but ispertinent to any sector engaging with indigenous peoples or when activities may affect the rights ofindigenous peoples, including via land and resource use.

56
57

The Working Group maintained throughout the project that GRI 304: Biodiversity 2016 is outdated
and needs updating urgently.

58
59
60
61

Gaps were also identified in relation to payments and contractual arrangements between
organizations and governments. These areas will continue to require additional sector reporting for atleast the three Standards for the extractive sectors. It is unclear as yet how relevant this type ofreporting will be for other sectors.

62
63
64

Thought not identified as a likely material topic for oil and gas, on the basis of a comment received
during public comment, the Working Group confirmed that cybersecurity and data privacy are likely tobe relevant to several sectors and that it should therefore be the subject of a Topic Standard.

65

Input received during public exposure

66
67

Some responses received during public exposure are directly relevant to Topic Standards. The
complete comments are listed in Appendix 1 and will be logged on the GRI website.

68

Key feedback received from respondents includes the following:

69
70

•

GRI 304: Biodiversity 2016 needs to incorporate clearer guidance and disclosures to report
more accurately on environmental performance.

71
72
73

•

Disclosures to report specifically on the organization’s adherence to the right to ‘free, prior,and informed consent’, as well as practical guidance on the concept, needs to beincorporated in GRI 411: Rights of Indigenous Peoples 2016.

74•

Further guidance is needed on how to assess indirect economic impacts.

75

Preliminary opinion

76
77
78

The four topics without a dedicated or closely related Topic Standard - asset integrity and criticalincident management; climate adaptation, resilience, and transition; closure and rehabilitation; andland and resource rights – all appear to have high potential for being likely material for other sectors.

79
80
81
82

Consistent reporting on climate change is increasingly critical and there appears to be growing
consensus on how this issue should be reported on across constituencies. The GRI Standards wereconsidered to lack a structure for reporting on the full scope of climate change related considerations
which presents a risk of making the necessary reporting unclear or abstract.

83
84
85

In addition, biodiversity, local communities, rights of indigenous people, and the Topic Standards
related to local economic impacts were considered insufficient or difficult to interpret. It is anticipatedthis input will arise again in the future development of Standards for other sectors.

Page 4 of 16

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

86

Appendix 1. Public comments on Topic Standards

87

collected during the exposure period for the Oil and Gas

88

Sector Standard

89
No.

Comments (incl. extracted from more detailed responses received)

Topics with no corresponding Topic Standard or relevant disclosures
1
Disclosures are missing any mentions of cyber security and data privacy as
this is a key risk in our industry.
Indirect economic impacts
2[…] "Induced" could be calculated by GRI, or at least a methodology
proposed (a syndication of indicators?), as the money poured in theeconomy through wages is used for the rest of the economy (education,care, housing, ...) and produces additional growth and economic
diversification (i.e. Keynesian multiplier effect).
INDIRECT: […] To be noted though that portion of investments linked toindirect impacts are more difficult to calculate and difficult to compare andcannot be reduced to monetary impacts.

Name oforganization
or individualCountry

Stakeholder group

Submission type

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

TOTAL S.E.

FranceBusinessenterprise

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

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

© GRI 2021

Local communities
3
GRI 413: Always find this tough as a service provider. Aimed again at the big
companies. Again should have a 'project' size associated maybe?

IPIECA

UnitedKingdomBusinessenterprise

4

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterprise

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterprise

Provide clarity on what includes development programs, would that include
all the social investment initiatives or also local content? From the exposure
perspective this should be clear for our sector.
5[…] On disclosure 413-1: Here companies should be encouraged to disclose
their societal management processes and describe positive outcomes. On
this, has GRI developed a methodology to calculate or disclose positive
impacts (social scorecard to assess relevance and efficiency?)
Diversity & equal opportunity and non-discrimination
6[…] for a global organization it is difficult to establish what is diverse. Needs
to be on a regional basis perhaps to be truly reflective. Also should take into
account local content requirements rather than just diversity as this caninfluence diversity in a workforce depending on which countries you operatein7[…] among key resources missing:
Convention on the Elimination of All Forms of Discrimination against Women,
Gender Dimension of the UNGP
https://www.ohchr.org/Documents/Issues/Business/BookletGenderDimensio
nsGuidingPrinciples.pdf, Unlocking Opportunities for women and business: A
Toolkit of Actions and Strategies for Oil, Gas, and Mining Companies
Market presence8[…] It could be suggested to enlarge slightly GRI 202-2 to not only focus on
recruitment and suggest to reformulate to ’Proportion of employees from thelocal community hired on senior management positions and/or holding asenior management position’.

Page 6 of 16

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

Procurement practices
9
Disclosure 204-1 Proportion of spending on local suppliers needs to provide
an indication of what "local" may mean. Local from the direct area ofinfluence or local as in national?
Employment practices
10
Suggest including the following metrics in this section:
Total Workforce #% of Contractors to Employees
Gender- male to female.
Gender % male female in management
11
New employee hires and employee turnover numbers are not very helpful
without the context of activity level or phase (i.e., development vs.
operations).

12

13

Employee turnover is a hard metric given the up and downs in our industry –needs breaking out into routine turnover and industry related issue turnoverin some manner. The latter is driven by issues beyond our control
Benefits vary across the globe driven by different regulatory requirements.
Need something about regulatory compliant vs additional ‘attractive’ benefits

Some topics need to be more specific and sharp to provide a valuable
information to society. [...] Employment - Seems there is a gap to cover info
on effectiveness in harassment management through grievance systems. It
is not clear how proactive schemes of training, improve awareness andclaims of discrimination is followed to solution and independent judgement
and management. A good opportunity may be would be incorporate new ILO
convention concerning the elimination of violence and harassment in theworld of work doc, set on Geneva, in 108th ILC session (21 Jun 2019). Thatmove forward to new understanding and ways to face harassment andviolence in world of Work.
Rights of indigenous peoples
14(i) Disclosure 413-2 Operations with significant actual and potential negative
impacts on local communities (ii) Disclosure 411-1 Incidents of violations
involving rights of indigenous peoples can be challenging to report.
If such impacts are reported, there may be reprisals, enquiries, and further
impacts which can cause harm to the image of the organisation. In case ofpress or social media coverage of such impacts, matters can worsen.
[…]

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

Pedro
CaemiroMagalhaes Jr

BrazilMediatinginstitution

On behalf of anorganization, groupor institution
As an individual

ShailandGunnooMauritius

Civil society
organization

Page 7 of 16

As an individual

15

Seeking the FPIC is somehow an incomplete way to describe how thisshould be done. There may be lots of difficulties prior to such a consent fore.g. communication/language barriers, technological/scientific disconnect
between the 2 groups, whom to address within the indigenous groups(hierarchy issues), approach for understanding and convincing, intervention
from third parties like local authorities, NGOs, etc. The approach to be usedby the O&G organizations should be explained in an appropriate way. Allmeans to arrive to the consent should be fair, transparent and free frommalpractices.
free, prior, and informed consent' There is a confusion between consultationand consent.

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

The distinction between Consultation and Consent may not be very relevantin some regions, where, for example, indigenous peoples' ownership ofnatural resources is recognized and, therefore, the question of being
consulted loses relevance in the face of the need to have the consent of theresource owners to operate. But in those regions where the State reserves
ownership of natural resources (despite the fact that such appropriation may
be contrary to international standards), prior consultation is an important step
before reaching consent or an important moment of negotiation between theState and community. In these regions, as much as companies want torespect the consent of the community, the State plays a decisive role in theexercise of both consultation and consent.
[…] suggest GRI consider the additional clarification on the word “consent”
that is included in the Equator Principles 4 (EP4). Note 3 in the definition of
FPIC on page 57 of the GRI Sector Standard defines “Free”, “Prior” and“Informed” but they have not defined “Consent.” […] EP4 attempts to help
clarify what would constitute consent.
Tax
16

The country-by-country tax reporting standard is incredibly detailed andcomplex, is there any guidance for companies on how to go about thiseffectively? To our knowledge, only one company in the industry currently
reports like this, we would appreciate any input on how to effectively report,
i.e. if there are certain indicators that are more important than others.

Page 8 of 16

Occupational health and safety
17
Some topics need to be more specific and sharp to provide a valuable
information to society. [...] Occupational H&S - From pandemic reality,
important to focus how companies (not specific to oil &gas) are supporting
home office schemes (ergonomic and additional expenses) for employees
and the contractors.
18
Disclosure 403-1: we don’t see the interest of the dichotomy between i. andii. We do believe that reporting is a necessary effort but our will to ask always
more data from the field must be balanced with the real adding value of what
we obtain. We believe that what is important is the number of site/affiliatesthat apply the company standard and how this standard company is made,updated and its international references. Legal requirement are going on topof that. Moreover we think that it is unfeasible to disclose “a list of therequirements” and a “list of the standards and guidelines” of the system, thiswould be far too heavy, at least for a big international company.

Pedro
CaemiroMagalhaes Jr

BrazilMediatinginstitution

As an individual

TOTAL S.E.

FranceBusinessenterprise

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

AustralianCouncil ofTrade Unions
AustralasianCentre for
Corporate
Responsibility(ACCR)

Australia

Labor

Australia

Civil society
organization

Disclosure 403-5: On the same idea, we don’t believe it is relevant to provide“a description of any occupational health and safety training provided toworkers”. The purpose of a disclosure is to provide clear view on
performance no to be flooded by information. At least, this is not adapted toa big international O&G company.

19

Disclosure 403-9: although it is feasible to calculate it, we are not familiar
with the high-consequence work-related injuries rate. We believe that there
is an interest to stay on Lost time Injury Rate instead of this new KPI as it ismore widespread among the industry and international standards andregulation. Maturity and benchmark on LTIR performance is higher.
Given the significant hazard of fatigue in the industry, in the ‘Occupational
health and safety’ topic we suggest:• Companies disclose the number of workers working more than 168 hours
over two weeks (12 hour shifts over 14 days) […]. Workers on oil and gas
platforms and supply vessels routinely work this many hours over 14 days,
but they must subsequently be given a substantial rest period.
• Companies must also disclose if they have any workers on the ships intheir supply chains who have been working for longer than 9 months, themaximum length of time at sea according to the Maritime Labour
Convention […]Page 9 of 16

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

Security practices
20[…] GRI 410 Security Practices only includes a disclosure on training, whichis quite limited given the range of angles from which the topic can beapproached. As such, it does not fully address security and human rightsrelated issues. We propose incorporating additional disclosures. A disclosure
on relations with contractors (private security companies) and third parties(government security forces and stakeholders including civil authorities)
would be useful.

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterpriseEni SpA

Italy

Businessenterprise

IPIECA

UnitedKingdomBusinessenterprise

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterpriseEni SpA

Italy

Businessenterprise

IPIECA

UnitedKingdomBusiness
Enterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

The disclosure could cover topics such as: due diligences, MoU procedures,
implementation of security management systems, procedures for dealing
with risks, security incidents and impacts on human rights, as well as how
companies influence the implementation of good practices among private
security companies, government security forces and other stakeholders.
Waste
21

22

New GRI 306-X standards look far more challenging compared with the 2016
version. The evaluation of impacts of waste management, extended to thewhole value chain as required by 306-1, is very difficult since it is something
beyond the battery limits of the organization - moreover the waste are often
given to environmental suppliers’ management, for recovery or disposal, andit might be very difficult to have available reliable data about the impacts.
[…] In disclosure 306-4, the category preparation for reuse seems
inappropriate since only a step before reuse. The term Reuse should
preferably used as is "Recycling". It is then the responsibility of the company
to ensure that the reuse actually occurs. More generally, the pertinency ofthe split between onsite and offsite is questionable. […]Water and effluents
23[…] The indicators should be useful to monitor the efforts of companies indecreasing negative impacts to the environment and decreasing their
exposure to water risk. For this reason, a distinction and monitoring ofpractices with different environmental impacts, according to an agreed
hierarchy is needed.
This is particularly important when dealing with produced water management
as a water discharge. According to the current proposal, produced water
injected into wells (for oil recovery or for disposal), discharged to the ocean,discarded to non-point sources on land or delivered to third parties (e.g. toPage 10 of 16

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

local communities, after treatment) are all summed-up and contribute to givea total water discharge volume.
While we understand the usefulness of an aggregate value for comparability
reasons, as stated in the CDP technical note on water accounting 2020, a
separate accounting useful to highlight the efforts of companies to pursue
environmental sound practices would support the decision making process
towards environmental stewardship.

24

25

Therefore, in the development of the standard, we strongly recommend thedefinition of indicators with a sufficient granularity, useful to monitor anddistinguish practices characterized by different environmental impacts.
We think the disclosure process should be approached in order to help
companies to enhance their environmental performances […]GRI 303. A water metric that tracks exposure to water stress or scarcity
seems to be missing.
In disclosure 303-3 reference to 1000 mg/l TDS is not appropriate andprobably too low (many mineral drinking water are exceeding this threshold)- we recommend using 2000 mg/l. Same applies to 304-4.

Anti-corruption
26
Ideally GRI 205 Anti-Corruption 2016 will eventually be updated to ensurethat it explicitly asks companies to report on how they avoid corruption in
procurement processes.
27[…] it is not presently feasible to gather such detailed information; it is indeed
challenging to provide:- a reliable percentage, as it implies to have an accurate andcomprehensive view of the payroll, which is not so easy with around
100 000 employees- details (category, region...) on the employees/partners to whom
policies have been communicated as communication actions aretarget a very large scope of employees

IPIECA

UnitedKingdomBusinessenterprise

IPIECA

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusinessenterpriseEngineers
Without
Borders
CanadaIPIECA

CanadaCivil society
organization

On behalf of anorganization, groupor institution

UnitedKingdomBusinessenterprise

TOTAL S.E.

FranceBusiness
Enterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

Page 11 of 16

On behalf of anorganization, groupor institution
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On behalf of anorganization, groupor institution

-details (category, region) on the employees trained as it would betime consuming to compile all these data for the different kind of
trainings in place while presenting little interest

Disclosure 205-3: a) "Total number and nature of confirmed incidents ofcorruption": It is important to acknowledge that the definition of corruption(below) includes fraud as it is sometimes difficult to distinguish between
fraud and corruption incidents and therefore it is more relevant to report bothfraud and corruption incidents on an aggregate basis.
b) "Total number of confirmed incidents in which employees were dismissed
or disciplined for corruption": It is easier to report on the number ofdisciplinary actions than on the number of incidents in which employees
were disciplined, as several disciplinary actions can be taken for a single
incident.
c) "Total number of confirmed incidents when contracts with business
partners were terminated or not renewed due to violations related tocorruption": There is no reporting on these cases which are quite rare.
28
Disclosure 205-3: Some disclosures would be considered confidential andoften legally-privileged. Should include a more clear definition of “nature.”
Additionally, we often focus on violation of policy, and don’t reach adetermination of “corruption.” For item d, we'd limit to legal actions with afinal, non-appealable legal determination that we engaged in corruption
Biodiversity29
In 304-1 the reference to subsurface and underground land should refer tothe effective part that is actually used (produced) since the blocks surface
area is more than often much greater than the area where biodiversity
impacts could occur.

30

Regarding disclosure 304-4, a mention to Environment Impact Assessment
should be done. Actually possibly impacted species will not evolve muchduring time and refer more to pre-existing species as listed in the frame of
the EIA. Thus this reporting could be a one shot reporting during a project lifetime.
In reference to GRI 304:

IPIECA

UnitedKingdomBusiness
Enterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusiness
Enterprise

TOTAL S.E.

FranceBusiness
Enterprise

On behalf of anorganization, groupor institution
On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusiness
Enterprise

The Sector Standard doesn’t introduce significant changes in the reportingthat we are currently doing and the same criticalities identified in applying the
GRI 304 topic standard remain still valid. These include:

Page 12 of 16

On behalf of anorganization, groupor institution

-

-

31

lack of clear definitions (such as of "operational site", "adjacent","significant impact" etc) which make impossible to have a consistentand comparable reporting between different Companies of the same
sector.
fail of measuring environmental performance of the company. Someof the GRI 304 disclosure requests appear to be not applicable ascompany's environmental impacts are overestimated such as“Disclosure 304-4 IUCN Red List species and national conservation
list species with habitats in areas affected by operations”.

We would be very interested in participating in the revision of the GRI 304(2016) in order to provide specific comments for each disclosure requestfrom this Topic Standard.
As stated in the Explanatory memorandum for the exposure draft, the Sector
Program was expected to support the enhancement and expansion of the
GRI Standards, including surfacing issues not previously covered in the GRI
Standards.
In this regard, and in order to help companies’ decision making process, aclearer identification and monitoring of practices characterized by different
environmental impacts is needed.
The indicators should be useful to monitor the efforts of companies indecreasing negative impacts to the environment and decreasing their
exposure to water risk. For this reason, a distinction and monitoring ofpractices with different environmental impacts, according to an agreed
hierarchy is needed.

Eni SpA[...]
In reference to GRI 304:
The Sector Standard does not introduce significant changes in the reportingthat we are currently doing and the same criticalities identified in applying the
GRI 304 topic standard remain still valid. These include:- lack of clear definitions (such as of "operational site", "adjacent","significant impact" , etc.) which make impossible to have aconsistent and comparable reporting between different Companiesof the same sector.
- fail of measuring environmental performance of the company.

Page 13 of 16

Italy

Businessenterprise

On behalf of anorganization, groupor institution

Some of GRI Standards disclosure requests appear to be not applicable ascompany's environmental impacts are overestimated, or do not correctly
picture company's performance, such as:
-

32

33

areas affected (we report number of operational sites)
number of habitats protected or restored
number of IUCN Red List species based on IBAT database

We would be very interested in participating in the revision of the GRI 304(2016) in order to provide specific comments for each disclosure requestfrom this Topic Standard.
[...]"Disclosure 304-1 Operational sites owned, leased, managed in, or adjacentto, protected areas and areas of high biodiversity value outside protectedareas". […] The 304-1 metric would be more meaningful if the percentage ofthe area within protected areas etc. would be reported rather than number ofsites.
- "Areas of high biodiversity value" needs to be defined- 304-1: it is not clear that this all protected areas, all those in the
WDPA or just some protected areas. Those which should bereported need to be listed- 304-1: could include whether the company has a no-go commitment
and what areas are covered by no-go (see ipieca reporting
guidance)- What categories of protected areas are included here? WHS? IUCN
categories I, II, etc? Ramsar sites? Is there further guidance
expected or is this purposefully left vague?
- 304-2: significant impacts needs to be defined- In what level of depth will we have to report on plastic pollution? Are
there key metrics to watch? With additional plastics value chain, theimpact here will only grow, but Borealis has issues determining how
to report this too.

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

Question: Does GRI mean to report on specific ecosystems and habitats thathave been impacted by activities, products, and services?

Page 14 of 16

34

35

"Disclosure 304-2 Significant impacts of activities, products, and services on
biodiversity". There is no widely used or generally accepted definition of what
is considered a significant impact and how it can be measured.
How has "significant" has been defined. Would it be a mortality event, if so
how many? Would there need to be a population-level impact?
Disclosure 304-3: The disclosure results confusing in several aspects,
considering the mitigation hierarchy (note: the mitigation hierarchy isdescribed as an approach of the oil and gas sector):i. any restoration of habitats should fall directly in the mitigation category“when impacts occur, rehabilitate or restore”, with the potential exception of
offset restoration projects.
ii. Any habitat protection aims to “avoid impacts”, although it could always be
said that habitat protection aims to both avoid and/or minimize impacts.

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

IPIECA

UnitedKingdomBusinessenterprise

On behalf of anorganization, groupor institution

Therefore, further detail or examples should be provided to clarify how to do
the referred breakdown of protected or restored areas.
iii. Additional conservation actions can always be fit within the four categoriesof mitigation, but may also be detailed as a long list of non-standard items.
This situation could lead to not having a standardized reporting.
To avoid this potential situation, a list of additional conservation actions orfurther guidance to define them should be provided. It is also suggested that
this actions, should be provided as an additional breakdown within the
mitigation hierarchy.
Disclosure 304-3: Does GRI mean to indicate habitat areas avoided? Or
what are they looking for in terms of the mitigation hierarchy?
36

Disclosure 304-4: this is impractical as the IUCN red list includes all species,
including those which are least concern, even reducing down to just globallythreatened species would cover 90% of the globe. - Suggest this should becritical and natural habitat, as defined by IFC PS directly impacted byoperations
Suggest that the need for key partnerships outside the sector be
acknowledged and recommended - both for implementation and reporting of
biodiversity action.

Page 15 of 16

Very few actual measures of biodiversity suggested for reporting. Where are
the baseline measures and derivatives?
37[…] in some cases as seen in biodiversity, the presentation of what to reportis unclear and not exactly precise. This is one aspect of sustainability
reporting that has been under-reported quantitatively despite its relevanceand subsequent risks posed. The various context of biodiversity practices
makes it hard for us information users to have comparable data fromcompany reporting.

Vigeo SAS

Page 16 of 16

UnitedKingdom

Investment
institution

On behalf of anorganization, groupor institution