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

3

Item 03 – GRI Sector Standard
Project, Agriculture, Aquaculture andFishing – GSSB basis for conclusions

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For GSSB review

1
2

Date

April 2022

Meeting

28 April 2022

Project

GRI Agriculture, Aquaculture, and Fishing

Description

This document summarizes the significant issues from comments received on the
exposure draft of the Agriculture, Aquaculture, and Fishing Sector Standard, during
the public comment period from 19 May 2021 to 30 July 2021. It also outlines thedraft GSSB responses to the significant issues based on Working Group discussions
and recommendations.
As outlined in the Due Process Protocol, this document is not subject to voting
approval, does not constitute part of the final Standard, and is non-authoritative. The
draft is circulated for review and comment. This document is a draft and will be
updated as needed following the GSSB approval of GRI 13: Agriculture,
Aquaculture, and Fishing Sectors 2022.
The full set of comments can be downloaded from the project page.

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 2022

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Contents

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About this document ............................................................................................................................... 3

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Introduction.............................................................................................................................................. 3

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Objectives for the development of GRI 13: Agriculture, Aquaculture, and Fishing Sectors 2022 ... 3

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Scope of the public comment .......................................................................................................... 3

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Overview of submissions ................................................................................................................. 4

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Methodology for analyzing comments ............................................................................................. 4

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Significant issues and GSSB responses ................................................................................................. 5

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Cross-cutting issues......................................................................... Error! Bookmark not defined.

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Agriculture, Aquaculture, and Fishing likely material topics – significant issues ............................. 6

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Aquaculture and Fishing issues ....................................................................................................... 6

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About this document
This document summarizes the significant issues from comments received on the exposure draft of
the Agriculture, Aquaculture, and Fishing Sector Standard, during the public comment period from 19
May – 30 July 2021. This document incorporates comments received through the public comment
form hosted on the Sector Standards Project for Agriculture, Aquaculture, and Fishing webpage andfeedback submitted by email. Where relevant, it also references comments made at stakeholder
workshops held during the public comment period.
All comments received, together with an analysis of the issues raised, were considered by the
Agriculture, Aquaculture, and Fishing Working Group. The recommendations of the Working Group
were shared with the Global Sustainability Standards Board (GSSB) for review and approval. This
document provides a summary of the GSSB responses to the significant issues raised during the
public comment period. The full set of received comments is available for download on the project
page. GRI 13: Agriculture, Aquaculture, and Fishing Sector 2022 presented for approval can be
downloaded here.

Introduction

33

Objectives for the development of GRI 13: Agriculture, Aquaculture,and Fishing Sectors 2022

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The project proposal for an Agriculture, Aquaculture, and Fishing Sector Standard was approved by
the Global Sustainability Standards Board (GSSB), GRI’s independent standard setting body, on 10
December 2019.

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The GSSB initiated the GRI Sector Program in 2019 to develop standards that are specific to certain
sectors and increase consistency by focusing sustainability reporting on the impacts that matter most.
As outlined in the GRI Sector Program description, Sector Standards aim to identify and describe thesectors’ significant impacts and stakeholder expectations in terms of sustainable development. At thesame time, they aim to provide evidence and authoritative references for the impacts. The project
followed the GSSB Due Process Protocol. Proposed revisions to the exposure draft of the Agriculture,
Aquaculture, and Fishing Sector Standard were discussed with the Working Group in full WG
meetings, subgroup meetings, and several targeted conversations with individual members.

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Scope of the public comment

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The exposure draft of the Agriculture, Aquaculture, and Fishing Sector Standard was open for publiccomment from 19 May to 30 July 2021.

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The public comment period tested the completeness and relevance of the content on agriculture,
aquaculture, and fishing. A focus of the public comment process was also to ensure feedback wascollected specific to aquaculture and fishing. This was achieved by the outreach targeting these
sectors and two dedicated webinars on aquaculture and fishing,

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A range of outreach activities was carried out during the public comment period, including webinars,
group, and one-on-one stakeholder consultations, targeting key regions and constituencies.
Comments collected during these activities, though not considered official public comment
submissions, were also taken into account. Particularly when comments aided understanding of theofficial submissions or flagged a significant issue that was not raised in the official submissions. This
series of engagements reached approximately 500 participants, mostly through participation in the
public webinars. See Appendix 3 for a list of stakeholder events and an overview of participation.
Any comments outside the scope of this public comment were compiled and directed to theappropriate team. Along with developing Sector Standards, the GRI Sector Program supports theenhancement and expansion of the GRI Standards by surfacing issues not previously covered by the32

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GRI Standards. Feedback on Topic Standards received during public comment has been collated
separately for consideration by the GSSB.

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Overview of submissions

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Respondents were asked to submit comments on the exposure draft using an online questionnaire
published on the project webpage (see Appendix 1 for the full list of questions). Respondents could
also submit additional feedback via email to agriculture@globalreporting.org.

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A total of 53 public submissions from individuals and organizations were received on the exposure
draft.

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Submissions came from all five stakeholder constituencies represented by the GSSB: businessenterprises, civil society organizations, investment institutions, labor, and mediating institutions.

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For more detail, see:
• The full set of received comments available for download from the agriculture, aquaculture,and fishing project page.

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Appendix 2 for a breakdown of public comment submissions by representation, stakeholder
constituency, and region.

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Methodology for analyzing comments

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The Standards Division collated all comments submitted by respondents.

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The qualifiers in Table 1 indicate the percentage of respondents who provided feedback on asignificant issue. Because the survey mostly asked open questions to encourage respondents toprovide feedback on sections of interest to themselves, not all respondents provided comments on all
sections of the exposure draft. Consequently, certain sections or disclosures have a lower number ofcomments relative to the overall number of respondents.

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Table 1. Qualifiers indicating the percentage of respondents who provided feedback
QualifierRespondents
Majority>50 %Many
30-50%
Some
10-30%
A few
<10 %
One
1

Each comment was categorized according to the public comment question it responded to, therelevant section of the Standard, and the likely material topic it was relevant to. If a respondent raised
several different points in one comment, the points were separated as distinct comments.

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Significant issues and GSSB

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responses

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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents during the public comment, outlines proposed changes to the exposure draft of theAgriculture, Aquaculture, and Fishing Sector Standard, and explains why changes suggested byrespondents were, or were not, accepted by the GSSB.

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Identified significant issues have been organized into the following sections:

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I.
II.

Cross-cutting issues related to the sector standard
Issues related to likely material topics.

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Notes for the reader:

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Only topics for which significant issues were identified have been included in this document.
This document includes references to the exposure draft of the Agriculture, Aquaculture, and Fishing
Sector Standard and the final version of GRI 13: Agriculture, Aquaculture, and Fishing Sectors 2022.
When referring to the content in the exposure draft, the names of the sections and topics are thesame as those used in the exposure draft.

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Feedback relating to the general concept or format of the Sector Standards, the GRI Topic Standards,
and the GRI Glossary is not included in this document unless necessary to understand othercomments or proposed changes. Nor does the document include minor editorial comments, whichwere considered and implemented directly by the Standards Division.

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I.

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a) List of likely material topics for the agriculture, aquaculture, and fishing sectors

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Most respondents confirmed that they considered all listed topics to be likely material for agriculture,
aquaculture, and fishing organizations. Respondents found that the included topics wererepresentative of the sectors’ most significant impacts and considered the draft Standard useful for
identifying material topics.

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The majority of respondents agreed that the draft Standard provides a balanced view of the impacts ofthe sectors. Some respondents commented that some topics were not material to some types oforganizations or activities. For example, topic 13.6 Pesticides use is only relevant to the agriculture
sector. Concern was also raised about the feasibility of small organizations reporting on all topics.
One respondent commented that the fishing sector should be treated in a different way because it iswater-based.

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One respondent commented that the disclosures included in the draft are more applicable todeveloping countries and that local and regional contexts should be better recognized.

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One respondent suggested that impacts described under topic 13.22 Economic inclusion were
sufficiently covered under the topic 13.21 Living income and living wage.

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GSSB response:•

Cross-cutting issues

A Sector Standard describes topics identified as likely material for organizations in the given
sectors. However, the material topics for an organization are determined based on the specificcircumstances of that organization. Consideration is given to aspects such as business model;
geographic, cultural, and legal operating context; ownership structure; and the nature of theorganization's impacts. This means that not all topics listed in GRI 13 may be material for allorganizations in the agriculture, aquaculture, and fishing sectors. An organization only needs toreport on the topics it has determined as material. This way, small organizations or fishingorganizations, for example, will report only on the topics that are material for them.

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•

Similarly, if any of the Topic Standards disclosures listed for a topic the organization has
identified as material are not relevant to its impacts, the organization is not required to report
them.

•

In some cases, additional sector reporting relevant to the impacts of only one or two sectors is
included to provide information specific to its impacts so that information users can makeinformed assessments and decisions about the organization. When this occurs, it is clearlymarked in the reporting sub-section of the topic.

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•

The GRI Standards apply to organizations in all locations. Individual organizations can recognize
the local and regional contexts in their reporting.

128b) Balanced representation of positive and negative impacts

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The majority of respondents agreed that the draft Standard provides a balanced view of the negativeand positive impacts of the sectors. One representative of the agrochemical sector ‘disapproved’ ofthe draft Standard because it does not promote innovative agricultural practices and instead focuseson negative impacts, which reflects badly on the state of the sector.

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Many respondents provided suggestions of other positive impacts that could be included in the draft
Standard or ways the sectors contribute to positive outcomes. For example, comments mentioned
positive impacts from regenerative practices and circularity measures. Some respondents highlighted
the positive impacts of crop inputs on agricultural productivity and suggested this should be more
prominently recognized.

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GSSB response:

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• A Sector Standard outlines the significant impacts of a given sector, these can be negative or
positive. Where identified as significant, descriptions of positive impacts have been included.
What is described in a topic description does not limit an organization from reporting on any
positive impacts related to that topic. For each material topic, under Disclosure 3-3 Management ofmaterial topics in GRI 3: Material Topics 2021, organizations describe both the negative andpositive impacts. The way that impacts are managed, including improvements or effective actions
taken to address negative impacts, is also disclosed by the organization as part of their reporting.

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• Regenerative practices and practices that result in higher crop resilience were given more
prominence across several topics, i.e., topic 13.9 Food security and topic 13.2 Climate adaptation
and resilience. Topic 13.6 Pesticides use incorporated content on integrated pest management(IPM), culture-specific controls, and the positive impacts of crop protection provided by pesticides
on yields.

151c) Sector activities and business relationships

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Most respondents agreed that the business relationships in the exposure draft were the most relevant
ones to identifying significant impacts per sector.

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Some respondents commented that sourcing animal or fish feed and inputs, such as fertilizers,
pesticides, and seeds, can result in significant impacts for reporting organizations, so reportingorganizations need to consider their business relationships with these entities when identifying
impacts.

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GSSB response:

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• Animal and fish feed suppliers and suppliers of agricultural inputs were included in the business
relationships sub-section.

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Aquaculture and fishing

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Several respondents commented on the presence of content related to fishing and aquaculture,suggested the following should receive further attention:

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Impacts from sourcing and use of animal and fish feed were not sufficiently described andshould be considered across the topics 13.11 Animal health and welfare, 13.3 Biodiversity,and 13.4 Natural ecosystem conversion;

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•

Impacts of different types of fishing methods on biodiversity and emissions should be
explained in more depth;
Biodiversity impacts from using fish seeds should be included;
Impacts related to employment terms and working conditions aboard fishing vessels should
be better articulated;
More prominence should be given to the topic of illegal, unreported, and unregulated fishing(IUU).

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GSSB response:

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The following were additions to GRI 13:

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• Reporting on fishing products' use in feed and the use of juvenile seed stocks was included in
topic 13.3 Biodiversity (see item e. below).

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• The additional sector recommendation in topic 13.4 Natural ecosystem conversion was revised toinclude a reference to sourcing feed for terrestrial animals and fish produced in aquaculture.

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• Reporting related to employment terms and working conditions aboard fishing vessels wasincorporated into topics 13.15 Non-discrimination and equal opportunity and 13.19 Occupational
health and safety (see item k. below).

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II.

Likely material topics

184c) Topic 13.1 Emissions

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Some respondents suggested including disclosures to report energy used from non-GHG emitting
sources, specifically a disclosure on clean energy percentage.

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Other respondents commented on the issue of carbon release into oceans as a result of bottom
trawling. They underlined this as a novel and understudied issue and that it is currently unclear theextent to which CO2 is ultimately released into the atmosphere or how to quantify it.

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A few respondents also suggested including more guidance on how to report on land-use change
emissions and biogenic emissions. One respondent noted that it is unclear how and where land-use
change and biogenic emissions are reported. They confirmed that biogenic emissions from soil,
ponds, and enteric fermentation are highly relevant to food production but may be difficult to measure.
The challenge of reporting Scope 3 emissions from production is linked to a lack of understanding ofsoil sequestration and manure management practices, especially in smallholder supply chains.

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GSSB response:

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• Topic 13.1 Emissions reporting already captures different scopes of emissions, including thosewhich result from energy use, so no further disclosure on energy use was added. Organizations
can report additional information on energy use when deemed relevant.

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• There is no consensus to which extent sea bottom trawling can be a significant source of CO2
emissions nor an established methodology for measuring associated emissions. Therefore, thedescription of trawling-related emissions was removed, and no reporting was added.

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• No change has been made for reporting on land-use change and biogenic emissions. Land-use
change emissions and biogenic emissions are reported under the relevant GHG emissions scopes
using the GRI 305: Emissions 2016, which contains instructions for compiling information. GRISector Standards do not include detailed guidance on compiling relevant information fordisclosures. Relevant sectoral methodologies, including the WBCSD-WRI GHG Protocol
Agricultural Guidance, are listed as a resource in the bibliography.

209d) Topic 13.2 Climate adaptation and resilience

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One respondent commented that the Disclosure 201-2 Financial implications and other risks andopportunities due to climate change in GRI 201: Economic Performance 2016 is related to financial
materiality and is misaligned with GRI’s focus, considering that reporting using the GRI Standards ison the impacts a business generates rather than impacts on a business.

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Some respondents commented that positive impacts from climate adaptative technologies,
regenerative practices, and nature-based solutions were not sufficiently described in the topic.
Another respondent suggested quantitative metrics on climate-focused/climate-smart livestock andagricultural practices and other types of GHG reduction practices.

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GSSB response:

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• The focus of topic 13.2 Climate adaptation and resilience is on adaptation. However, topic 13.1
Emissions was revised to describe GHG reduction practices more extensively. No changes toreporting were made as GHG reduction is sufficiently covered by Disclosure 305-5 Reduction of
GHG emissions in topic 13.1. The suggested metrics on climate-smart agriculture or climate-focus
livestock practices were also not added under this topic. Such quantitative metrics were notconsidered to be universally accepted or standardized in the reporting practice. Organizations canreport any actions to prevent or mitigate potential negative impacts of climate change using
Disclosure 3-3 Management of material topics.

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• ‘Regenerative practices’ refer to various practices and is a term often used to indicate analternative to conventional production practices. However, there are no consistent criteria todetermine if a practice is regenerative. Examples of regenerative practices like rotating crops orplanting at optimal times for higher agricultural productivity were retained in topic 13.9 Food
security. Though not necessarily referred to as ‘regenerative’, practices and technologies that build
resilience was described in more detail in topic 13.2 Climate adaptation and resilience.

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233e) Topic 13.3 Biodiversity

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Some respondents suggested that the additional sector disclosure for fishing organizations on thevolume of aquatic organisms caught should be reported in the context of national or regional stock
sustainability status. A few respondents commented that the disclosure should also include bycatchand non-target species, such as whales, dolphins, or seals.

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One respondent suggested including an additional sector recommendation on the use of juvenile
seeds in the aquaculture sector, highlighting it as a source of significant impact on fish stocks.

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Some respondents highlighted that the use of fish products in feed for aquaculture operations could
be associated with significant impacts on biodiversity and suggested organizations should berequested to report feed composition. It was suggested that the fish-in-fish-out (FIFO) ratio or forage
fish dependency ratio (FFDR) might be appropriate indicators, ensuring an organization reports thequantity of live fish used to produce fishmeal or fish oil in comparison to the quantity of farmed fish or
seafood produced.

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Some respondents highlighted that aquaculture could have an impact on local biodiversity as a resultof escapes from aquaculture farms, leading to introduced species establishing themselves andcompeting with an area’s native species.

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GSSB response:250• An additional recommendation to report on escapes was added.

251• An additional sector disclosure was added to report on the impacts of using juvenile seed stocks.

252• An additional sector disclosure to report on fishing products used in fish feed was added.

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• Neither FIFO nor FFDR was included as sector disclosures, as neither ratio is considered toindicate whether the use of wild catch fish in feed has any direct impact on biodiversity. Other
factors, such as whether the fish is sourced from responsibly managed fisheries or whether the
species refers to whole fish or fish waste (trimmings, offcuts, and offal), are unclear when reporting
using these ratios. Using these ratios to report on performance related biodiversity could create amisleading impression about the actual impacts. For example, these ratios can show efficient useof feed inputs, but the species used may be fished at unsustainable levels.

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• To enable the information user to understand the impact of fish used in feed, reporting on the stock
status of species used was added to the additional sector disclosure on aquatic organisms caught
for organizations in the fishing sector; to the additional sector disclosures for aquacultureorganizations on juvenile seed stocks and the use of fishing products in feed.

264f) Topic 13.5 Soil health

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A few respondents suggested adding a disclosure to capture information on fertilizer-use intensity. It
was suggested that the amount of nitrogen and phosphorus applied should be reported separately
and that there should be reporting on organic-versus-mineral products applied.

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These respondents suggested revising the additional sector recommendation on soil management
plan to request a more detailed description of what should be included in such plans. Other commentssuggested that a reference be made to the Food and Agriculture Organization (FAO) soils portal toprovide guidance on the main soil qualities: nutrient availability, workability, oxygen availability toroots, nutrient retention capacity, toxicity, salinity, and rooting conditions.

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Some respondents were concerned that singling out fertilizers in the topic description and additional
sector recommendations is not suitable because fertilizer is not the only input in nutrient
management. It was also suggested that the important role of crop inputs and their positive impacts
on soil health should be recognized in the description.

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GSSB response:

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• The additional sector recommendation on a soil management plan was revised to set out whichelements of the plan should be described, including identified threats to soil health and theapproach to crop inputs optimization. The reference to fertilizers was expanded to recommend
reporting on the approach to optimizing all inputs.

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• No reporting on fertilizer intensity and other types of quantitative indicators relevant to soil health
was added. It was considered not to provide information that is an indicator of impacts of soil
health at organization level and is not comparable between reporters. Organizations may operate
multiple farms in different locations with different types of soils. Different soils have different needs,
and fertilizer applications could vary accordingly. As such, aggregating this information into one
organization-level figure would not derive meaningful conclusions. External factors, such as
droughts, could also affect crop production and the calculation without relation to fertilizer use
efficiency. The soil management plan was considered the most appropriate reporting that captures
the information needed to assess an organization’s practices regarding soil health.

291g) Topic 13.6 Pesticide use

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A few respondents suggested that the toxicity of pesticides can vary depending on their intended
purpose and that general statements on toxicity should be avoided. For example, naturally derived
pesticides and other biological crop protection products are not considered toxic.

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One respondent commented that the positive impacts of pesticides should be recognized more
prominently in the topic. Pesticides protect crops, increase yields, and help meet the world’s growing
demand for agricultural products while limiting land conversion. Another respondent stated that only
improper application or management of pesticides contributes to adverse environmental impacts.

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A few respondents commented that reporting by the agricultural sector should also include measures,
initiatives, or plans to reduce the use of chemical-based pesticides and switch to organic pesticide
solutions.

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GSSB response:

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• The description of the use of pesticides in aquaculture was removed. The use of chemical
substances in aquaculture and the related impacts are covered in the topic 13.11 Animal healthand welfare. This allowed for a strengthened focus on topic 13.6 Pesticides use on the mostsignificant impacts related to the use of pesticides in agriculture.

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• Positive impacts of pesticides on production yields were recognized in the topic more prominently,
such as a decrease in diseases and pests, an increase in production yields, and a potential limit in
the need to convert more land.

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• The additional sector disclosure on volume and intensity of pesticides used was revised to request
the information broken down by hazard levels.

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• Two additional sector recommendations were added to respond to expectations of progressive
reduction of the use of extremely and highly hazardous pesticides, where possible, in line with theinternational instruments by the Food and Agriculture Organization (FAO) and the World HealthOrganization (WHO).

316h) Topic 13.8 Waste and food loss

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Many respondents commented on the grouping together of waste and food loss. Respondents foundthe pairing confusing or disagreed with the format. Respondents found that there are aspects of foodloss that go beyond waste impacts and align better with the topic 13.9 Food security.

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321

Some respondents highlighted challenges in reporting the additional sector disclosure on food loss
percentage by product and made the following comments:

322•

Suggestion to reframe the issue as ‘production loss’, which would cover all sectors' products.

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325

•

Total weight of food loss and food loss percentage is difficult to calculate in palm oil, because
not all produce becomes food, so not all losses are food loss. Organizations producing palm
oil may not know how much of the product will be used as food or other non-edible products.

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•

Respondents expressed concern over the feasibility of reporting on the metric at the individual
product level. For example, fishing organizations deal with many species, and at productlevel, this could amount to more than 1000 products.

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GSSB response:

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• The additional sector disclosure on food loss was retained but moved to topic 13.9 Food security,and the topic name was updated to topic 13.8 Waste.

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• The focus is on food loss rather than broadening it to ‘production loss’. Food loss has a unique
impact on food security. Furthermore, the definition of waste in GRI 306: Waste 2020 covers any
loss of product that must be handled as waste.

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• In response to the points raised about the challenges of reporting food loss, the disclosure was
updated to report food loss broken down by the ‘main products or product category’, allowing for
aggregation of products where appropriate. Organizations with limited data availability can explain
the methodology they use to make estimates and improve the accuracy over time.

339i) Topic 13.9 Food security

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Two questions on Food security were included in the Public Comment questionnaire to gather input
on the relevance and practicality of reporting on food security. Most respondents commented on this
topic and indicated their support for its inclusion. They also highlighted that food security has various
definitions, finding an explanation of food security impacts helpful and the delineation between local,
regional, and global food security important. However, other feedback raised concern about theusefulness of the topic – in their view, businesses can hide the negative impacts of their activities
under the guise of solving the food security problem. In many instances, the combined impacts of anorganization (such as on land, economic inequality, biodiversity, discrimination, etc.) could mean thata company actually has a net negative impact on global food security.

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Some respondents suggested this topic will only be relevant to some organizations as food security isa macro issue. It was recommended that the topic focus on how individual organizations can directly
impact on food security.

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Some respondents commented that they would like to see more specific quantitative information
reported. For example, a disclosure on percentage of land or production under organic orregenerative agriculture practices.

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One respondent commented that food security did not have sufficient reference of productivity, yet the
impact of increased productivity is significant to many other material topics.

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Some respondents commented that protein diversification is vital in achieving global food security,
zero hunger, and improved health and urged GRI to emphasize the importance of fish products tomeet protein needs. As a counterpoint, other respondents stated that consumption of animal protein,including fish products, should decrease, and the phrasing of the description around this issue shouldreflect this.

362

GSSB response:363• The topic was retained.

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• The impacts of crop inputs on productivity were recognized more prominently in the topic 13.6
Pesticides use, while the focus of the topic 13.9 Food security remained on actions and programs
to strengthen food security.

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• The additional sector disclosure on food loss was moved to the topic from 13.8 Waste and foodloss (see item h) above).

369j) Topic 13.11 Animal health and welfare

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One respondent proposed considering aquatic animals as sentient individuals with their own welfare
concerns. They also requested that the reporting be in the number of fish rather than tonnage.

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Some respondents called for the inclusion of disclosure on quantitative animal welfare assessment,
and one respondent proposed including enrichment techniques for fish welfare.

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Additionally, some respondents proposed that the volume of usage of antibiotics is a critical piece of
information and should be reported separately from other treatments due to global concerns regarding
the emergence of antimicrobial resistance.

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Some respondents indicated that the use of marine ingredients in feed is one of the areas of highest
risks for negative impacts in the aquaculture sector.

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GSSB response:

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• In response to points raised about the challenges of attaining information on total volume oftreatments administered to animals from suppliers and the potential loss of value when thisinformation is aggregated across sits, the additional disclosure to “Report the veterinary carerecord outlining the total volume of anesthetic, antibiotic, anti-inflammatory, hormone, and/or
growth-promotion treatments administered, by species and breed” was replaced with an additional
sector recommendation to report the organization’s commitments to responsible and prudent useof antimicrobial agents. Concerns regarding antimicrobials are primarily related to antimicrobial
resistance, so it is crucial that treatments in animals, especially antibiotics, are used prudently.

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• Inclusion of the reporting on targets for the reduction of antimicrobials was not consideredappropriate as it does not in and of itself indicate good practice. Reporting needs to demonstrate
how organizations assess if antimicrobials are being used responsibly. The new additional sector
recommendation asks for a description of how the organization assesses compliance with thecommitments to responsible and prudent use of antimicrobials. Hence, a description of theapproach to animal health planning and involvement of veterinarians, including the approach tousing an anesthetic, antibiotic, anti-inflammatory, hormone, and growth-promotion treatments by
species, is included in sector specific recommendations. Organizations can also report any
available quantitative data on targets using the Disclosure 3-3 Management of material topics.

397
398
399
400
401

• An additional sector disclosure for the aquaculture sector on the survival of farmed aquatic animals
was added to address the issue of quantitative information on animal health in aquaculture. Other
quantitative fish welfare indicators were not found to be commonly used. The reporting on the topic
asks for the results of animal health and welfare assessments and audits, which aid inunderstanding how animals are treated.

402k) Topic 13.15 Non-discrimination and equal opportunity

403
404
405
406
407

Some respondents highlighted that migrant workers are frequently employed in these sectors, andreporting of some disclosures should be on the basis of migrant status. Some respondents called forthe issue of equality of treatment as it relates to employment terms (based on nationality and forms of
employment) to be further addressed in the topic description and for the reporting to include
disclosure of different rates of pay based on nationality (“pay gap”).

408
409
410

Some respondents commented that gender should be recognized more prominently in the reporting toaddress gender-based discrimination and gender wage gaps, and increase equality and inclusion
throughout the organization and its business activities.

411

GSSB response:

412
413
414

• An additional sector disclosure on the equal treatment of migrant workers was added. This
disclosure also includes the approach to compensation to report any different rates of pay (“paygap”) based on nationality.

415
416
417

• Reporting by gender is also included across the topics 13.14 Rights of indigenous peoples, topic
13.15 Non-discrimination and equal opportunity, and the topic 13.21 Living income and living
wage.

418

l) Topic 13.19 Occupational health and safety

419
420
421
422

Some respondents commented that there is often a lack of safety norms, oversight, inspection, andintervention mechanisms in the fishing sector. There are differences in how occupational healthservices and medical care are facilitated for workers aboard fishing vessels compared to thoseworking onshore.

423

GSSB response:

424
425

• An additional sector disclosure on the occupational health services’ functions that specificallyaddress the occupational health and safety risks for workers aboard fishing vessels was added.

426
427
428

• In addition, another sector recommendation on the maximum working hours and minimum hours ofrest for workers aboard fishing vessels was added, recognizing excessive working hours as one of
the key risk factors for worker safety and health in the fishing sector.

Page 12 of 17429m) Topic 13.20 Employment practices

430
431
432

One respondent commented that the percentage of migrant and non-migrant employees per
employee category should always be reported to understand the scale of impact of employment
practices on migrant workers.

433

GSSB response:

434
435
436
437
438
439
440

• The definition of ’a migrant worker’ can be more expansive than those working in farming or fishing
operations and may include workers in other parts of an organization, such as corporate functions.
As such, the inclusion of reporting on the proportion of migrant workers could lead tointerpretations of the metric. For example, a high number of migrant workers could be seen as
problematic, but it is not necessarily the number, but equal treatment of migrant workers that is ofsignificant concern. Instead, an additional sector disclosure on differences in treatment of migrant
workers was added to topic 13.15 Non-discrimination and equal opportunity (see item k. above).

441
442
443
444
445

• The additional sector recommendation on ethical recruitment was expanded to include theelements outlined in the International Labour Organization (ILO) and International Organization on
Migration (IMO) instruments (in particular, the IOM’s flagship initiative IRIS: Ethical Recruitment topromote ethical recruitment of migrant workers), which contain provisions on key issues
associated with the recruitment of workers, including migrants.

446
447
448
449

• The additional sector recommendation on compensation was moved from the topic 13.21 Living
income and living wage to the topic 13.20 Employment practices to enable reporting oncompensation aspects beyond whether it provides for a living wage. This provides overall
transparency on the different forms of compensation used in the sectors.

450n) Topic 13.21 Living income

451
452
453

A few respondents made comments about the definition of ‘living income’ and that it needed to be
distinct from ‘living wage’. ‘Living wage’ is a well-understood term; wages are among the mostimportant conditions of work, so it needs to be mentioned in the name.

454

GSSB response:

455
456
457
458
459
460

• In the initial assessment, the term ‘living income’ was considered to include ‘living wage’. A clearerdelineation between these terms was made to align with international instruments and to recognize
different methodologies, regulations, and actions to address the issue of living income and theissue of living wage separately. The topic name was also updated to topic 13.21 Living income andliving wage. The topic statement and the description of impacts were updated to reflect thedistinction between living wage and living income.

461o) Topic 13.23 Supply chain traceability

462
463
464

Some respondents commented that organizations should disclose supply chain mapping that clearly
identifies the location of suppliers, the name of the factory/hatchery/mill, the number of employees,
and products being sourced by weight.

465

GSSB response:

466
467
468
469
470
471
472
473
474

• Additional sector disclosure on supplier mapping was not included. It is acknowledged that this canprovide an additional level of transparency. However, the feasibility of collecting and reporting thisinformation, along with the issues around commercial sensitivities are likely to undermine complete
and consistent reporting of this type of information.
The additional sector disclosure describing the level of traceability in place, including up to specificpoints of origin where possible, was confirmed to deliver sufficient information to understand anorganization’s performance on supply chain traceability while avoiding commercial sensitivity
issues. The Disclosure 2-6 Activities, value chain and other business relationships also provide
insight into the value chain entities.

Page 13 of 17

475

Appendix 1. Questionnaire questions
Sector profile

Yes (with No (with nono further further
comments) comments)

Left comment /proposed changes

6

20

25

7

23

Total
Left
responses blank

Question 1: Are the business
relationships described in thissection such that present thehighestrisk of significant negative46
impacts for the agriculture,
aquaculture, andfishing sectors, based on theimpacts’ severity and likelihoodof occurrence?
The sector and sustainable
development
Question 2.1 Does the section
accurately reflect theagriculture, aquaculture, andfishing sectors’ sustainability
context and the key societal
44
expectations towards thesectors as set out ininternational instruments andagreements?
Question 2.2: Does the
mapping of likely material
topics to SDGs help tocontextualize the agriculture,
aquaculture, and fishing41
sectors’ activities in light of the
global sustainability agenda? If
not, please suggest what could
be improved.

0

16
2

10

18

0

23

12

29

0

10

9

12

0

30

8

16

1

27

List of likely material topics
Question 3.1: Are there any
topics listed that you do notconsider as likely material
39
for agriculture, aquaculture, andfishing organizations? Please
explain why.
Question 3.2: Are there
significant impacts that are notdescribed in any of the42
topics? Please explain which
impacts are missing and forwhich topic.
Question 3.3: Are the topic
descriptions – including how
they are named – complete andaccurate in terms of capturing 44
the sectors’ most significant
impacts? If not, please explain
for which topics this is not the

Page 14 of 17

case and suggest
improvements.
Question 3.4 Is
there a balanced representationof impacts related to each of
the sectors – agriculture,
aquaculture, and fishing? If not, 37
in which topics do you think
there is inadequate
representation of a sector’ssignificant impacts.
Reporting section
Question 4.1: Are theadditional disclosures orrecommendations listed
40
understandable and feasible toreport on? If not, please explain
why and suggest any revisions.
Question 4.2: Are the listed
disclosures critical and usefulfor sustainability report
information users to understand39
an organization’s impacts
related to each topic? If not,please explain what could be
improved.
Question 4.3: Are thedisclosures formulated correctly40
to produce valuable andconsistent information?

14

22

2

13

11

19

0

21

13

18

0

21

21

12

0

28

15

27

1

8

19

16

1

15

Food security
Question 5.1: Is this topic
useful for understanding theorganization’s significant
impacts on food security?

36

Question 5.2: Are thedisclosures adequate and will
they produce useful informationin relation to 'food security'? If 32
not, please explain what could
be improved.

Page 15 of 17

476

Appendix 2. Public comment

477

submissions by stakeholder

478

constituency and region

479
480
481

The Standards Division received 53 submissions from individuals and organizations on the exposure
draft. A full record of these submissions, including names of individuals and organizations, can befound in this document.

482
483
484
485

The charts below show the breakdown of submissions by constituency group and region. Most
responses came from mediating institutions (22), followed by businesses (15). Ten responses camefrom civil society organizations. Labor made four submissions. Investment institutions submitted two
responses.

486

Below is a breakdown of the submissions received by constituency and geographic region:

487

Page 16 of 17

488

Appendix 3. Participation in regional489

events and webinars
Event

Date

Attendees

Global launch webinar 1

26 May144

Global launch webinar 2

27 May105

Regional promotion webinar Latin America

1 June20

Regional consultation Latin America

16 June10

Aquaculture & fishing webinar 1

28 June34

Aquaculture & fishing webinar 2

6 July22

Regional consultation Africa

8 July9

Joint regional consultation ASEAN (Grow Asia and UN Global
Compact Network Singapore)

15 July140

GRI Community webinar

22 July

10

Page 17 of 17