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

Item 05 – Public comments on GRI 102:
About the Organization in the Universal
Standards exposure draft
For GSSB discussion
Date

06 November 2020

Meeting

19 November 2020

Project

GRI Universal Standards Project

Description This document contains an extract of public comments related to GRI 102:
About the Organization received on the Universal Standards exposure draft,which was made available for public comment between 11 June and 9 September
2020.
The document presents the comments received via the online survey and via
letters, for GSSB reference. It does not present an analysis of the feedback – theanalysis will be presented by the Standards Division directly at the meeting.
The GSSB is kindly asked to review the document ahead of the meeting and toshare any questions about the comments or highlight any comments fordiscussion, with the Standards Division by 17 November.
Note to reading the comments:
Comments have been included verbatim. Where a respondent has raised several
distinct points in one comment, each point has been numbered and presented ina separate row. The point number is indicated in brackets before the verbatim
comment. In addition to this, comment numbers have been included in the firstcolumn to help facilitate the discussion during the meeting on 19 November.

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 2020

1

Contents
1. General comments to GRI 102 ......................................................... Error! Bookmark not defined.
2. Organizational details and reporting practices ........................................................................................... 9
3. Organizational activities.................................................................................................................................. 14
4. Governance ....................................................................................................................................................... 23
5. Responsible business conduct ....................................................................................................................... 74
6. Stakeholder engagement ................................................................................................................................ 96

Page 2 of 100

2

Public comments

3

1. General comments to GRI 102
No. Line
number(whereprovided)12

Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Every year I find that the statements in GRI 102 not really are of added
value, they are merely a copy paste of last FY. Can this section bereconsidered? Only substantial changes are interesting. For my clients
this sections feels like a burden.
(1) The DIHR finds that elements of the structure are not entirely clear
at a first glance. E.g. what is the relationship or potential overlap between
RBC requirements in GRI 102 RBC 1-7 and material topic requirements
in GRI 103, as material topics should also be the focus of cross-cutting
RBC processes. Further, it is unclear from a first glance why the due
diligence process is not part of the disclosures under RBC requirements
contained in GRI 102, as they are so central to them. While we agree
that it makes sense to disclose due diligence information in relation to
the different material topics, some processes are also corporate-wide or
crosscutting in nature, so only being able to disclose those at the level ofmaterial topics can lead to the risk of companies including a lot of
copy/paste generic information across the material topics.
We note that RBC-3 to some degree will allow for disclosing this type of
information. (2) However, to make it clearer that information on bothhorizontal (across functions) and vertical (across regions and countries)
integration of RBC in the organization is sought after, the DIHR
recommends changing RBC-3-a-ii to: ‘how the organization integrates

Bondt
Communicatie

Netherlands

No response

No response

DanishInstitute for
Human Rights

Denmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

Page 3 of 100

3

908

4

911-913the commitments into organizational strategies and operational policies
and procedures and ensures compliance across functions andgeographies’ and that the guidance given to RBC-3-a-ii is adjusted tobetter reflect the need for horizontal and vertical integration of humanrights or RBC due diligence by companies as well as the need formonitoring efforts. Relatedly, we have some recommendations to how
this dimension is better reflected in the material topics requirements (seeour response to question 10 in relation to MT-2).
(1) The GRI should consider reflecting the importance of sector-specificreporting as opposed to emphasising the generalisability of reporting. The
standards now should reflect the two sides of reporting: general andsector-specific to better achieve transparency. Re-consider statements
such as 'regardless of sector'.
(2) 911-913: I suggest removing the 'either' because the choice does notproduce the same result. One is a GRI report, and another is a reportreferencing GRI but not complied.

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

Academic

As anindividual

5

Yes I agree with the structure, but for its contents, the existing GRI 102
is still relevant.

Eko
Sukoharsono

Indonesia

6

The requirements of several of the GRI 102 disclosures seem to havebecome more stringent and demanding for organizations to meet, such as
ACT-2, RBC-2 and RBC-4. We ask GRI to provide more information
about why these are more strict than past versions.

ERM

United States Consultant

7(2) However, the points on bargaining for remuneration may conflict with Fridah
the stated terms and conditions.
Mashandi

ZambiaNo response

On behalf ofanorganization,group orinstitution
As anindividual

Page 4 of 100

8

9

10

245

(6) • Line 245: we welcome the requirement to report on organisational
context, which we suggested in our earlier response, but would also
advocate inclusion of corporate culture (e.g. shared attitudes, values,
managerial practices and beliefs)

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution(2) However, GRI may want to consider reducing the requirement of
GRI 102 and allow each country, bourse or professional body to regulate
in their own turfs. GRI's status in sustainability reporting is widely
recognize as best practice. To avoid turf war with the financial and HR
domains, GRI should keep the focus on sustainability, to avoid
unnecessary confusion to the market, if regulators and professional
bodies start turf wars to protect their domains.
(3) One area that GRI might include is the funding of NGOs by reportingorganization. Or GRI can consider having a special set of guidelines forNGOs to report their sources of funds. Many sustainable-themed NGOs
are funded corporations who can be environmental perpetrators. If suchreporting requirement exist in GRI, then greater transparency and beachieved.

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

AlliedEnvironmental
Consultants

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

Removed disclosures
11"102-44 focuses more on the reporting entity's response to those topic(as opposed to the ""identification"" of topics). Would 102-47 (List of
material topics), 103-2 (management approach on material topic), or
relevant disclosure be refined to address to ""response""? Can be""Change in location"" type?
For reference:
102-44:i. how the organization has responded to those key topics and concerns,
including throughPage 5 of 100

its reporting;ii. the stakeholder groups that raised each of the key topics andconcerns."
12

Current disclosure 102-53 requires a contact point. The Exposure draft
omits this. I believe this is a necessary part of reporting - as an invitation
to dialogue, a sustainability report must make it easy for people tocontact relevant company representatives and engage. Please bring thecontact point back, and if possible, make it a requirement to include
named individual.
Reports should be required to publish the publication data as part of thegeneral disclosures about the report. Too many companies publish
reports a year or even more after the end of the reporting period. If thisis the case, then there should be transparency about this. Plus the time of
publication is critical to understanding some of the disclosures - did a
company report on something that happened after the publication date?
It goes to transparency and credibility of reporting.
The deleted disclosures should be maintained. They provide relevant
information to the reader.

13

14

15

omitted;
195

GRI 102: General Disclosures 2016 102-12 External initiatives
GRI 102: General Disclosures 2016 102-15 Key impacts, risks, andopportunities
GRI 102: General Disclosures 2016 102-44 Key topics and concerns
raisedGRI 102: General Disclosures 2016 102-51 Date of most recent report
GRI 102: General Disclosures 2016 102-53 Contact point for questions
regarding the report.
(1) The stakeholder process is already the weakest part of most reports.
It is done superficially and with limited resources. When omitting 102-44of the 2016 standards and reshaping he materiality matrix (not showing

BeyondBusines Israel
s LtdConsultant

On behalf ofanorganization,group orinstitution

BeyondBusines Israel
s LtdConsultant

On behalf ofanorganization,group orinstitution

ISOS Group

United States Consultant

On behalf ofanorganization,group orinstitution

SchweryCade

Switzerland

On behalf ofanorganization,

Consultant

Page 6 of 100

the results of the stakeholder consultation process) then the wholeconcept of SE will be weakened.;
16

omitted;
600

17

18

19

330
Explanatorymemorandum for the
exposure
draft

group orinstitution

This information is very important for report readers. Nobody wants tocheck on the website to find the contact person for this report. This
principle should not be renamed. Keep the old wording "Reliability". This
term is clearly defined in social research and 10x more often used (seegoogle research)
put THE CONTACT POINT BACK

SchweryCade

Switzerland

Consultant

On behalf ofanorganization,group orinstitution
As anindividual

DanielaWinickiChile

Consultant

With so many governance and stakeholder disclosures - would
recommend to keep the point of contact for comments about the report.
Even if there aren't too many emails or phone calls going that way,
forcing companies to think about where those questions should go is agreat internal catalyst for good governance.
This indicator is important because their membership in certain
initiatives such as the Global Compact may lead companies to report
some information related exclusively to each initiative, for example, inthe case of the UNGC on their Ten Principles. Some, such as Principle 4
or 5, may not be material to companies, but because of their membershipin the initiative they should report it. Therefore, getting to know which
initiatives they are part of on an specific indicator and not along withothers or in the explanation of materiality analysis can help to understandcertain information included in company reports. On the other hand, itwould be good to include in the new guides the connection of indicatorswith the SDGs, the Global Compact Principles and other international
initiatives and standards.

Marjolein
BaghuisNetherlands

Consultant

As anindividual

UN Global
Compact
Network
Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 7 of 100

20Line 331

Disclosure 102-15 Key impacts, risks, and opportunities; This disclosure
consists key element for reporting organization from the viewpoint ofdescribing "key impacts", should be kept in new 102.

International
Development
Center of
Japan

Japan

No response

No response

Page 8 of 100

4

2. Organizational details and reporting practices
No. Line
number(whereprovided)Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure REP-1 Organizational details
1986-988

This disclosure could be improved by providing additional guidance on
what constitutes a 'significant operation'.

ICMM

UnitedKingdom

Trade orindustry
association

2987

Include in guidance that also include locations that may be insignificant
but have significant impacts in material topic areas. This provides context
for later reporting on impacts.

KPMG

Australia

Consultant

3973

Please provide more guidance on the definition of "significant operations",
e.g. by size of revenue, number of employees? This has implications on
many disclosures in the rest of the Standards.

Paia
Consulting

SingaporeConsultant

Disclosure REP-2 Organization’s entities included in its sustainability reporting
4

Using principles derived from the accounting standards, companies canconsolidate reporting entities that are under their scope of financial
and/or operational control.

Bursa Malaysia

Malaysia

Stockexchnage

On behalf ofanorganization,

Page 9 of 100

If the company is a large conglomerate, it would not be feasible to list
down each entity.
5993-997

Entities used in financial accounting are sometimes set up for legal or
accounting purposes (e.g. for specific projects). It may not be relevant or
helpful for stakeholders to know all legal entities that are part of thereporting scope. Instead focus should be placed on the relevant business
units that are included as part of the report (i.e. report based on theorganisation’s structure, not its legal entities).
Good additional clarity on scope and timing of the report vs financial
statements.

6989-907991(1) Disclose any entities not included- Providing details about whether the entities included in the financial
reporting and sustainability reporting align is an important addition.

8991(2) - It would be valuable to require the organisastion to report any
entities that form a part of the organisation and are not included in thesustainability reportinggroup orinstitution
CLP Holdings
Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)
Network for
Sustainable
FinancialMarkets CIC

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

UnitedKingdom

Nongovernmentorganization

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure REP-3 Reporting period and frequency

Page 10 of 100

9

1029

10

11

1026

12

989- 1042

While I understand the pressure from the financial communities to havealignment on reporting cycles - this should be optional and I do notbelieve companies should have to explain why they selected a different
reporting cycle for sustainability reporting. The timescale required forsustainability reporting may not align with financial accounting for manyand varied reasons. As long as a company is reporting consistently, andon a regular frequency, and within a reasonable time-frame after theclose of the reporting period, this should be enough for everyone to getwhat they want from reporting. Why force-fit sustainability frameworks
into financial calendars? And what's the value in forcing companies to
explain why they didn't align?
We believe reporters should be required to include a date of publicationin their report.

BeyondBusines Israel
s LtdConsultant

On behalf ofanorganization,group orinstitution

Deloitte

United States Consultant

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure about whether the reporting periods of the financial andsustainability reports is very important- This disclosure is important, particularly the requirement for an
organisation to provide details and reasons where the reporting periods
for financial and sustainability reporting is not aligned.
We believe that the reporting frequency should generally be aligned
between financial and non-financial information.
To the extent that the frequency is not aligned, entities should specify thereporting period for its financial reporting and provide an explanation of
why it does not align with the period for its sustainability/non-financial
reporting (lines 1030 -1031).

Disclosure REP-4 Restatements of information

Page 11 of 100

131026 1075

141046-7

Restatements: GRI should add a requirement that organizations shallrestate information (including statements, representations, assertions ordata) when it has learned that the previously-reported information isincorrect, and that the correct information would be relevant and ofinterest to stakeholders reading the sustainability report. GRI should
also provide guidance that organizations should establish ad document
criteria for making restatements. This should be mandatory for allmaterial topics, at a minimum. The Guidelines require that theorganization shall explain any restatements of information from previous
reporting periods. The Guidelines do not specify or provide guidance on
the criteria for when such restatements should be made. Prior reports
may have included glowing statements or data about performance andaccomplishments in sustainability topics (material or otherwise), withstakeholders relying on these representations to make decisions
regarding investments, employment, or other stakeholder relationships.
Without such guidance, organizations may set their materiality thresholdextremely high, so as to avoid restatements, impairing the concept oftransparency and potentially providing an opportunity for fraud.
Agree with restatements but organizations should explain their reporting
principles/ criteria (including consolidation boundary, how they deal withacquisitions/disposals and restatements) in the report, that they follow
consistently. Restatements should not be random, risking it being basedon whether it is beneficial or not.

DouglasHilemanConsulting
LLC

United States Consultant

As anindividual

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

United States Consultant

On behalf ofanorganization,

Disclosure REP-5 External assurance
15

Deloitte welcomes the Principle of verifiability and the importantconnection with assurance in the Reporting Principles. This reflects theincreasing importance of high-quality information on impacts that can be

Deloitte

Page 12 of 100

examined to establish credibility and it increases the desire for assurance
to enhance confidence in the information.
161085-717(1076 –
1106)

18

1076-1106

19

1076 ff.

group orinstitution

Agree with updates to External assurance, however some of therequirements are in the assurance statement, not in the client's report(b.ii.). Do explanations from b.ii. need to be in both the statement andthe report? Does this create requirements for assurance providers
regarding content in the statements which may conflict with assurance
standards? How do you report what is NOT assured? This could be"everything else".
Under “2. Organizational details and reporting practices (963-1106)
Ø Disclosure REP-5 External assurance (1076 – 1106)• FPP asks that GRI clarifies aspects relating to independent verification

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

Please include guidance on what comments are expected with respect torequirement REP5-b.iii. ‘describe the relationship between theorganization and the assurance provider’. For example, is this meant tocomment on the specific independence requirements/framework
applicable to the assurance provider?
Our recent study on sustainability reporting of major German companies
found that in the reports claiming external assurance in GRI 102-56 thepercentage of topic-specific disclosures examined varied between 0 and
100 percent. Therefore we recommend to establish a minimum
requirement when claiming external assurance

PwC

UnitedKingdom

Assurance
providerTransparency
International
Deutschlande.V.

Germany

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 13 of 100

5

3. Organizational activities
No. Line
number(whereprovided)Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Consultant

On behalf ofanorganization,group orinstitution

Disclosure ACT-1 Activities, value chain, and other business relationships
1

Partly agree.
More concentrated on organizational background in terms of main
business.

21164 1177

However, it will be protective to the companies since they don’t need todisclose the controversial business to the public (102-2), and in addition
with the revised of the requirement “only reporting the organization’s
main business”, the reader can’t see the whole picture of the company(e.g.business ethic problem).
Disclosure ACT-1 Activities, value chain .. Guidance to ACT-I-b-ii: The
exposure Universal Standards provide many examples of information
pertaining to the supply chain. GRI should add content to the guidance
to the effect that GRI acknowledges that some information may be CBIand that organizations – and those supporting them (contractors,
auditors, etc.) – take care not to divulge this. Many organizations may
regard this as Confidential Business Information (CBI). It is routine fororganizations to require their employees, contractors and business
partners to agree not to disclose CBI. Although Line 1167 says “ .. theorganization can … “ the implication here (and throughout theStandards) is on increased reporting and disclosure. On the whole, thisAlliedEnvironmental
Consultants

Hong Kong

DouglasHileman

United States Consultant

As anindividual

Page 14 of 100

is commendable – but not at the expense of an organization’s proprietary
information.
31164-1177

41119 1123;
1164-1191

5(1112 –
1126)

61155-1159,
1179

The guidance for ACT-1-b-ii is really strong, particularly for asking forthe monetary value of payments made to suppliers. Payments to suppliers
are a huge potential lever for sustainable development that is often notthought about as much as direct employment or taxes for example. One
suggestion that is linked to our comment on RBC-1 below, is that inaddition to an organisation describing the types of business relationship it
has with its suppliers, it should also explain its approach to supporting
suppliers close to where business activity takes place. A bullet here in theguidance could read something along the lines of "describe their strategy
and efforts to support suppliers close in geographic proximity to theirbusiness activities".
The indicators b ii/iii, especially in the guidance, require a too detailed
description of the value chain; such disclosure is not feasible for large
corporations operating in different businesses and different geographicallocations.

Engineers
Without
Borders
CanadaNo response

No response

1164-1177

Eni SpA

Italy

Business

Under “3. Organisational activities” (1107 – 1111)

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

Fundación
ONCE

Spain

Foundation

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Ø Disclosure ACT-1 Activities, value chain, and other business
relationships (1112 – 1126)• Include clear reference to indirect/third party suppliers
REFERENCE I:
Universal Exposure draft: Line 1155 to 1159
Suggestion coming from page 44 of the Guide "Disability in Sustainability
Reporting" by GRI and Fundación ONCE.
SUGGESTION I:"When describing its products and services, the organization should:"•report the quantity of products and services that include ‘design for all’Page 15 of 100

or ‘universal design’ considerations .

71160 to
1163

8

1125

REFERENCE II:
Universal Exposure draft: Line 1179
Suggestion coming from page 44 of the Guide "Disability in Sustainability
Reporting" by GRI and Fundación ONCE.
SUGGESTION II:"When describing the characteristics of the entities downstream fromthe organization and the activities they carry out in relation to theorganization’s products and services, the organization can:"• Report the positive impacts that the products and services forvulnerable customers and beneficiaries (e.g. people with disabilities) havegenerated.
(Please consider Fundación ONCE's contribution provided by email tosupport this response).
REFERENCES:
Universal Exposure draft: Line 1160 to 1163
Suggestion coming from page 43 of the Guide "Disability in Sustainability
Reporting" by GRI and Fundación ONCE.
SUGGESTION:"When describing the markets served, the organization can:"• report the markets it serves with characteristics of ‘design for all’ or‘universal design’ and describe the type of products and services provided
to this market.
(Please consider Fundación ONCE's contribution provided by email tosupport this response).
Details of any changes within the reporting period should also be
disclosed- We appreciate the focus on comparability between two reporting
periods.
- We would like to underline that reporting changes within the last

Fundación
ONCE

Spain

Foundation

On behalf ofanorganization,group orinstitution

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 16 of 100

reporting period are also relevant and suggest the drafting should beclarified to ensure these changes are also captured.

Disclosure ACT-2 Employees and other workers
9(1) ACT-2-a-iv: Enable stakeholders to know the major nature of
employment in corresponding geohraphical operating locations

AlliedEnvironmental
Consultants

Hong Kong

Consultant

10(2) ACT-2-b: Guide the reporting organizations ("the org") to explain
the figures disclosed under ACT-2-a. However, they are not required to
explain all of the figures but according to their preferences only.

AlliedEnvironmental
Consultants

Hong Kong

Consultant

11(3) ACT-2-c: In the current GRI 102-8d, the org are only asked to state
whether a significant portion of the org's activities are performed byworkers who
are not employees, which is a merely yes-no question. Given thedefinition of "significant" is not provided, there might be some org which
didn't disclose any relevant figures at all. The recommended requirement
is believed to address this issue. It enables understanding of the org's
reliance on the workers in their operations.
(4) ACT-2-d: May need to define "significant" in a clearer manner.

AlliedEnvironmental
Consultants

Hong Kong

Consultant

AlliedEnvironmental
Consultants

Hong Kong

Consultant

12

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 17 of 100

13

1205

We support the revision of this disclosure and the recognition of theright to collective bargaining is a fundamental right at work in theStandards. The presence of a collective bargaining agreement in theorganisation demonstrates a respect for this fundamental right.

AustralianCouncil ofTrade Unions

Australia

Labor
representative

14

We support this revision to require data on workers who are not
employees - many organisations utilise workers who are not classified as
employees; reporting on these workers this is important tounderstanding the sustainability impacts of the organisation.

AustralianCouncil ofTrade Unions

Australia

Labor
representative15

To report workers who are not employees and whose work is
controlled by the organisation, we need to implement appropriate
tracking measures to determine their level of involvement, scope ofwork, number of employees and time spent on the projects. This can bechallenging for companies with many service providers, vendors andcontractors. Investments are needed in HR monitoring systems toeffectively monitor these workers and their involvements over time.
Workers who are not employees, but whose work environment is
controlled by the organisation could include facilities management andsecurity workers of suppliers, who work directly at the offices, factories
or buildings of the organisation. Their headcount are accounted forunder the facilities management companies under formal employment.
Perhaps some countries don't consider these workers as part of formal
employment, hence the need for this requirement. Increasingly, facilities
management contracts are contracted not based on headcount but by
the output/deliverable. It would be difficult to track and normalise thenumber of workers going in and out of the building.
The DIHR recommends that ACT-2-c is strengthened by requiring
reporting organisations to disclose number of workers that are not
employees by gender and region in a manner similar to requirement
ACT-2a i and ii. This is to stimulate tracking of these numbers bycompanies, which is not always the case today as well as allow for

Bursa Malaysia

Malaysia

Stockexchnage

City
Developments
LimitedSingapore

Business

On behalf ofanorganization,group orinstitution

DanishInstitute for
Human Rights

Denmark

National
human rights
institution

On behalf ofanorganization,group orinstitution

16

1214

17

1214-1218

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 18 of 100

external scrutiny around number of workers that are not employees e.g.
in regions where there are known labour and human rights issues for thisvulnerable group.
182344-2351

19

1214 1218

20

1224-1226

21(1) 2344-2351: The categorise listed as examples of what forms of labour
you work are vague and gives companies a chance to obscure
exploitative labour conditions. It is important that the organization
provides the reader necessary context so the reader can judge if theorganizations impact is positive or negative. Are they using non-unionizedlabour in a country or region where most labour is unionized, or using an
uncommon form of employment in a certain country or region (i.e. gig
economy workers as a form of regulatory arbitrage)?
The indicator c requires a too detailed description on workers, especiallythe information regarding the number of workers who are not
employees; the disclosure of the number is not feasible for large
corporations operating in different businesses and different geographicallocations. A more qualitative description would be feasible.
While providing companies flexibility to determine the appropriate
headcount methodology, GRI should specify that companies need to use
the same methodology each year to enable YOY comparability andcomparability to other employee data in the report.

Enact
Sustainable
Strategies

SwedenConsultant

On behalf ofanorganization,group orinstitution

Eni SpA

Italy

Business

ERM

United States Consultant

REFERENCES:
Universal Exposure draft: Line 1208
Suggestion coming from page 40 of the Guide "Disability in Sustainability
Reporting" by GRI and Fundación ONCE.

Fundación
ONCE

Spain

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

SUGGESTION:"The organization shall:"X. report the percentage of employees with disabilities.
X. report the total number of employees with disabilities, and provide abreakdown of this total by:Foundation

Page 19 of 100

22

1279

23

1208 1220

24

1205-1226

i. employment contract (permanent and temporary), by gender;ii. employment contract (permanent and temporary), by region;iii. employment type (full-time and part-time), by gender;
iv. employment type (full-time and part-time), by region;(Please consider Fundación ONCE's contribution provided by email tosupport this response).
Add item on how performance measurement /oversight is provided toassess outcomes rather than inputs (e.g. resourcing)]

GIB Asset
Management

UnitedKingdomBusiness

The additions and revisions are significant and will be very challenging for ICMM
members to fully comply with. The new requirements may well provide
more context to employee numbers but require a significant increase in
the amount of information that needs to be reported, especially thedescription of work they perform and fluctuations. The larger mining
sector organizations use large numbers of different types of employees
and contractors and systems are generally set up to report a level ofdisaggregated information but many mining organizations simply don’t
have the level of sophistication in their HR reporting systems that isrequired to fully report on this requirement. Therefore, more flexibility is
recommended for reporting this information. We suggest that 102-c. ii.
and 102-d are changed to ‘guidance’ to allow for more time to develop
the sophistication in systems to fully report on this.
The revision of the disclosure to require data on workers who are not
IndustriALL
employees is welcome. There are a large number of businesses that use a Global Unionhigh proportion of workers who are not employees but whose work
they nevertheless control. This is a key feature of the business andimportant to understanding the sustainability impacts of the company.

UnitedKingdom

Trade orindustry
association

Switzerland

Labor
representative

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution(Note that this comment should be taken as applying to all repetitions of
the similar structure.)

Page 20 of 100

25

1209

IOSH supports the collecting of data on gender to provide clarity andhelp support reporting on the management of gender-related OSH
issues.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

261205-1226

International
Trade Union
Confederation

Belgium

Labor
representative

27

1218

The revision of the disclosure to require data on workers who are not
employees is welcome. There are a large number of businesses that use ahigh proportion of workers who are not employees but whose work
they nevertheless control. This is a key feature of the business andimportant to understanding the sustainability impacts of the company.
The approach is predominately quantitative with this indicator. Could
there be a qualitative, contextual overlay (as there is at 1213) that asks
for the organisation to account for what vulnerable worker groups it has
identified in its supply chain.

KPMG

Australia

Consultant

28

1208

(1) Disclosure about the organisation's relationship with employees
within the region is important.
- This disclosure about gender, region, employment contract, and typeare an important addition.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

29

1208

(2) - It would be beneficial and reasonable for the organisation to provide
a breakdown by operational centre within each region (eg office, site,
factory) to provide a more complete picture of the contractual
relationship and gender diversity of the workforce.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

30

1286-1287

For joint ventures, are GRI's guidelines for worker statistics to bereported based on equity share?

Paia
Consulting

SingaporeConsultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 21 of 100

31

1213

32

1213

(1) We recommend that you clarify the definition of ‘worker’. It is notclear when a non-employee contractor should be considered (e.g. where
they dedicate above a certain percentage of time in the year working forthe company). Where significant judgement is required to determine thescope of the ‘workers’ of an entity, an entity should disclose the basis of
the determination.
(2) While the reporting on ‘employees’ should be required, reporting
information on ‘other workers’ (non-employees) should berecommended but not required due to the difficulty in obtaining suchinformation. Requiring non-employee reporting could have implications
for the verifiability of information and therefore implications both for thereporting entity and its assurance provider. We also suggest that you
include the concept of ‘significant’ in line 1307 (‘all significant
fluctuations’) and consider some guidelines on what percentages might besignificant in various examples in line 1314-1316. We recognize that‘significance’ may not be determined as a defined percentage in all cases
and therefore the guidance may need to consider both quantitative andqualitative factors.

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

PwC

UnitedKingdom

Assurance
providerOn behalf ofanorganization,group orinstitution

Page 22 of 100

6

4. Governance
No. Line
number(whereprovided)Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

On behalf ofanorganization,group orinstitution
As anindividual

All governance disclosures
1

All of the governance disclosures are important; however as unions are amajor stakeholder, GOV-4 on stakeholder consultation with the highest
governance body is particularly important

AustralianCouncil ofTrade Unions

Australia

Labor
representative2

describe the internal resources and process that the organization has for
managing sustainable development topics, especially for disputes andtrade-offs

Hui XuChina

Nongovernmentorganization

3(2) The governance disclosures should be reduced to those which
directly and significantly relate to sustainability governance, or corporate
governance's role in sustainability. Other corporate governancedisclosures should be part of financial/corporate reporting, notsustainability reporting.
In general, I believe these governance disclosures are overly burdensome
for sustainability reporting. Corporate governance is widely addressed inother forms of corporate disclosure, and required by legislation in mostjurisdictions. Sustainability reporting should be concerned specificallywith the elements of governance that are not addressed by othercorporate disclosure frameworks, and should focus on the differentialthat a sustainability lens adds to the governance of an organization. These
disclosures should be significantly reduced and some are unnecessary for
In Accordance Reporting. If it is felt that they should be retained (maybe

BeyondBusiness Ltd

IsraelConsultant

BeyondBusiness Ltd

IsraelConsultant

4

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 23 of 100

as a framework for private companies who do not disclose extensively
on governance - although, it' unlikely they would if they are not publicly
traded), then as a minimum, many of these these disclosures should NOT
be part of the In Accordance requirement, but optional additional generaldisclosures.
I would consider to completely skip this information.

5
6

7

8

9

1359 1362

The disclosures are ok but they are very demanding if we consider amedium size company or a first reporter. It increases the barrier to use
the standards. The restricted obbligation of reporting only one disclosre(could be 2) from Core option was more reasonable.
(4) Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
We are supportive of these proposed governance disclosures as they
seem to be more stringent than previous version. We also like the moveto a disclose default and reporting on non-disclosure.

• It is positive that any company reporting “in accordance with the GRI”
must report on all 15 disclosure topics, which provide an overview of theorganization’s governance structure, composition, roles, andremuneration; however, it brings up (again) the issue with having two
possible ways for companies to report and whether the claims ultimately

Bondt
Communicatie

Netherlands

No response

No response

BSD
CONSULTING

BrazilConsultant
and certified
trainer

No response

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

EuropeanAccounting
Association's
Stakeholder
ReportingCommittee
Forest Peoples
Programme

CanadaAcademic

On behalf ofanorganization,group orinstitution

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 24 of 100

made by companies are clear enough for those who do not know thenuance of the GRI standards (e.g. for an uninformed reader there will belittle difference or alarm bells between reading that a company isreporting “in accordance with the GRI” or “in reference to the GRI” yetin reality these are significantly different reporting requirements).
• As commented below, the GRI 102 needs to be strengthened withvarious additions related to Free, Prior and Informed Consent (FPIC).
This addition is necessary and should not be optional. FPIC is a right
related to the rights to self-determination and to lands and resources ofindigenous peoples and local communities. It is a procedural right that is
an important mechanism for protecting and furthering the substantive
rights of indigenous peoples. Businesses are expected to report on how
they have incorporated the right to FPIC and adhered to this coreinternational standard for responsible business conduct. Further, thissection should highlight that when it comes to indigenous peoples andlocal communities, engagement and ‘consultation’ alone are not often not
sufficient. The core principle that FPIC processes can result in FPIC being
withheld should also be recognised. The GRI should reference the bodyof international jurisprudence on the right to FPIC, including thedecisions, general recommendations and concluding observations of the
10UN human rights treaty bodies, including the CERD, the CESCR, andthe Human Rights Committee; the UNDRIP; ILO169, and the FAO
Guidelines.
• GRI guidelines must also include wording and reference to human rights
specifically, not only mention of “sustainable development”, which canhave varied interpretations whilst human rights can be traced back tointernationally agreed standards.

Page 25 of 100

10

Top management performance reviews allow timely decisions to be madeto correct possible deviations in time

Angel Castillo

EcuadorConsultant

As anindividual11

The proposed disclosure is extremely detail. This could pose a burden
for companies in meeting these demands. What is missing is the need forthe company to share their existing governance policies and structure inplace, and they intention to elevate it.
IOSH has proposed a focus on tackling gender-based violence andharassment and so welcome that the gathering of data on gender issues is
included here and in the definition of vulnerable group (Line 3177: Note
2: Vulnerabilities and impacts can differ by gender).

Choon Kiong
Ting

Malaysia

Business

As anindividual

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

This section seems to present governance only with regard to sustainable
development topics. This is a potentially narrow perspective. Whilesustainable development is critical there is more to governance than thatalone. At least from an investor perspective, this framework would be
most robust if it focused on all aspects of governance, not just thoserelated to sustainable development.
We appreciate that GRI’s focus is on a multi-stakeholder audience, notjust investors, and that in this context investors are regarded as one ofseveral material stakeholders. There is a strong recognition in theinvestor community of the importance of positive stakeholder relations
in long-term company success. However, in this multi-stakeholder
context we are concerned that the distinct role played by shareholders
can be obscured in the GRI standards. As providers of financial capitaland as bearers of residual risk shareholders have important ownershiprights including voting rights, and also have fiduciary duties calling for
stewardship and company engagement. Perhaps it is axiomatic within the
GRI framework that this distinctive role of the shareholder is not given
greater priority relative to employees, customers and other stakeholders.

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

12

13

14

3177

On behalf ofanorganization,group orinstitution

Page 26 of 100

But if that is the case the GRI approach may have less traction thanother sustainability standards.
15

16

17

18

19

20

1345-1425

Genral comment on COV1-COV15;GRI102;existing Genral
Disclosure102-18 to 102-39,are more conprehensive and appropriate interms of Clarity,Feasibility,Relevance . Sould consider reuse of existing
GRI102 Governance section with minimum change, as existing GRI102 is
more user friendly.
No Comments. GOV 1 -15 are clear and pertinent.

International
Development
Center of
Japan

Japan

No response

No response

Tang Lien

Malaysia

Consultant

As anindividual

For privately listed companies, are they allowed to choose which
disclosures (structure, composition and experience of governance body)they will report on and which disclosures (such as compensation) they
can skip?
Governance report should be detached from the general disclosures

Aldo Joson

Singapore

Business

As anindividual

SchweryCade

Switzerland

Consultant

These disclosures make only sense for larger organisations. As aconclusion SMEs would only go for a GRI referenced report (option B).
Therefore, the "Governance" section should not be mandatory. Why not
reinventing the "+" again for the section on "Governance"?

SchweryCade

Switzerland

Consultant

These are low-priority, contextual questions.

Sustainability
Advantage

CanadaNo response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response

Page 27 of 100

21

22

23

24

1338 ff.

The set is so detailed, this is a report in itself. Some accountants do
require all of the content to be in the report itself (rather than allowing
references to financial reports and the website) - making reportappendices extremely long and illegible.
GOV 1-15 are important disclosures that highlights the governancestructure in the organization. However, for SMEs the scope in thissection might become an obstacle.

Marjolein
BaghuisNetherlands

Consultant

As anindividual

Trossa AB

SwedenConsultant(2) We particularly note that involvement of the governing body is
critical to driving rigor and performance improvements.

UNDP - SDG
Impact Team

United States UN body

The revised GRI Standards contents on governance are the mostcomprehensive (in comparison with other reporting frameworks) that
the WBA is aware of. Thanks to the revisions, it is has become clearer
that reporting on governance is key to understand to what extent
sustainability is integrated into the organisation's business structure andstrategy.

World
Benchmarking
Alliance

Netherlands

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Benchmarking
foundation

It is very useful that the link to "sustainable development" has beenemphasized, as this better captures the topics in question and clearly
relates to the SDGs.
The clarity appears to be helpful. The selection of governance-related
disclosures to be reported is very comprehensive and appears relevant. If
an organisation reports on all the identified disclosures, it should bepossible to assess how far an organisation is in embedding sustainability
into its structure. This assessment can be used in WBA benchmarks.

Page 28 of 100

251339 1341

ERM
Certification
andVerification
Services (ERM
CVS)
AlliedEnvironmental
Consultants

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

Bonava AB

SwedenBusiness(2) vi. under-represented social groups, not legal to register information
about in Sweden

Bonava AB

SwedenBusiness

29

There is a need to include geographical diversity in addition to age
diversity

Nazish Shekha

PakistanNongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual30

We covered this several years ago. See:
https://creativeinvest.com/SPI_Finance_2002.pdf andCreative
Investment
Research

United States Impact
investing26

Governance structure - ERM CVS notes that this now only applies togovernance of sustainable development topics – what about overall
governance (e.g. for business strategy, operational management etc.)
which is key to integration of sustainability in the business and its
operations.
The spectum of "sustainable development topics" could be very board any further guidance and/or examples for reference to be provided by
GRI as a way to draw the boundary?

27

1356-1360

28

1356-1360

For reference:
102-18: governance structure EES decision-making committees
102-22: compsition of committees(1) iv. significant positions and and commitments leaves room for
subjectivity

Government of Hong Kong. Comments on the Environmental, Social andOn behalf ofanorganization,group orinstitution

Page 29 of 100

Governance Reporting Guide. September 18, 2015.
https://www.creativeinvest.com/HongKongESGReporting.pdf
31

1348

Need to be assured by 3rd party

DUOPHARM
A BIOTECHBERHAD

Malaysia

Business

32

1359 1362(1)Requests vi; vii; viii are not feasible for italian legislation in which therules for the election of the BoD is strictly defined by applicable laws.
As such we propose to eliminate vi; vii and viii as not comparable among
different Countries.

Eni SpA

Italy

Business

33

1359 1362(2)Requests vi; vii; viii are not feasible for italian legislation in which therules for the election of the BoD is strictly defined by applicable laws.
As such we propose to eliminate vi; vii and viii as not comparable among
different Countries.

Eni SpA

Italy

Business

34

1359 1362(3)Requests vi; vii; viii are not feasible for italian legislation in which therules for the election of the BoD is strictly defined by applicable laws.
As such we propose to eliminate vi; vii and viii as not comparable among
different Countries.

Eni SpA

Italy

Business

35

1360-1361

We agree with the requirement to disclose Board competencies related
to sustainable development and the sector in which it operates.

ERM

United States Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 30 of 100

36(13451362)

Under “4, Governance” (1338- 1565)

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Fundación
ONCE

Spain

Foundation

On behalf ofanorganization,group orinstitution

GlobalCompact
Networking
Japan

Japan

Generalincorporated
association

On behalf ofanorganization,group orinstitution

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,

Ø Disclosure GOV 1 Governance structure and composition (13451362)

37

1352

38

1365-1375

39

1362

• Under “vi. membership of under-represented social groups” FPP
recommends inserting “such as indigenous representatives”.
REFERENCES:
Universal Exposure draft: Line 1352
Suggestion coming from page 34 of the Guide "Disability in Sustainability
Reporting" by GRI and Fundación ONCE.
SUGGESTION:"Describe the composition of the highest governance body and its
committees by:(...)"
vi. membership of under-represented social groups (including people withdisabilities).
(Please consider Fundación ONCE's contribution provided by email tosupport this response).
A statement regarding whether and how “diversity is considered" isrequired when selecting the highest governance body members. Pleaseconsider adding examples or supplements to the list of what exactly ismeant by "diversity" that should be considered when nominating andselecting the highest governance body members (e.g., diversity withrespect to age, gender, expertise, etc.).

In general, these revisions clarify responsibility for overseeing SD topics
and the new focus on better demonstrating SD competencies will notpose any risk to our members. However, the Standards could be- Study
Committee on
Corporate
Reporting
ICMM

Page 31 of 100

improved by clarifying, by way of more guidance, what is meant by GOV1-c-viii ‘stakeholder representation’.

group orinstitution

40

1360

IOSH supports this requirement to report on governance competencies,
which we recently advocated in our response to the EU consultation on
Reviewing the Non-Financial Reporting Directive.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

41

1360-1361

Next Level
Sustainability

Australia

GRI Certified
Training
Partner

421359

I will provide supporting points on the need for professional/ accredited
GRI Standards training to be addressed at different points in the revised
Universal Standards elsewhere in the survey. At this point, I’ll note theneed for professional GRI Standards training within Governance because
learning about how to use the GRI Standards in a governance process
does not occur through osmosis. It is a competence gained through skill
development. It is not enough to have GOVERNANCE -1 c vii on‘competencies relating to sustainable development’, there is also a needfor a new clause GOVERNANCE -1 c viii Competencies on “how to use
the GRI Standards in a sustainability reporting process” gained throughprofessional GRI Standards training. [Accordingly Line 1362 stakeholder
engagement now becomes GOVERNANCE -1 c ix]. There needs to be a
specific sub-item on professional GRI Standards training (viii), along thelines of: “…competencies in using GRI Standards in a sustainability
reporting process as demonstrated by the number of members who havetaken the GRI Certification Exam and are qualified as GRI Certified
Sustainability Professionals”.
A better definition for other strands of diversity should be provided
within the definition of ‘under-represented social groups’. The definitionin the text of ‘under-represented social groups’ is not clear and it’s linkto stakeholders, which might not be diverse themselves. We would
recommend the GRI refers to age, disability, gender reassignment,
marriage and civil partnership, race, religion or belief, sex and sexual

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 32 of 100

orientation – this is taken from the UK Equality Act 2010, but the GRI
can refer to similar legislation in other jurisdictions to create a morecomprehensive list of diversity characteristics.
43

1356

44

1350

45

46

47

Definition of significant should be provided.; the definition should also
include representation on a government committee or organisation, andany position at a lobbyist organisation/ industry association or anotherorganisation that is a recipient of funds from the company, as this is notalways clear.
This could be expanded to report whether a committee, a specific board
member or the entire board is responsible.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

1359, 1362

(1) 1359 – clarity: the inclusion of examples would help to understandthe concept of under-represented social groups.

REPSOL

Spain

PrivateCompany

1359, 1362

(2) 1362 – clarity, relevance: stakeholder representation. What’s theinformation required? A percentage? How different stakeholders are
represented in the different governance bodies?. Additionally, thisinformation should be part of the description of the process to identify
material topics. It is not relevant for the governancecorporate governance structure and committees, index and also howmeasure them should be recognized in them

REPSOL

Spain

PrivateCompany

RPMRG

Hungary

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 33 of 100

48

1356

"other significant position" is not clear.

DanielaWinickiChile

Consultant

As anindividual

49

1348

It is better if the reporting organization will show its governancestructure through a graph rather than describing it in a narrative form.

Phlippines

Assurance
providerOn behalf ofanorganization,group orinstitution

50

1352

It is better to use "Identify the composition of the highest governancebody... according to"

University ofAsia and thePacific Center forSocialResponsibility
University ofAsia and thePacific Center forSocialResponsibility
BeyondBusiness Ltd

Phlippines

Assurance
providerOn behalf ofanorganization,group orinstitution

IsraelConsultant

On behalf ofanorganization,group orinstitution

SwedenConsultant

On behalf ofanorganization,group orinstitution

51

These three disclosures should be combined and reduced in terms of theamount of detail mandated for in accordance reporting. they should avoid
repeating disclosures that are commonly made (by law) through otherforms of corporate reporting. Otherwise this becomes too burdensome
for sustainability reporting and creates unnecessary extra work fororganizations.

Disclosure GOV-1 Governance structure and composition
52

1367-1368

It is welcomed that GRI wants the reporting organization to become
more transparent, certainly regarding the nomination and selection
process of the highs governance body and its committees. For someorganisations, e.g. family owned companies, it might be difficult andsensitive to provide full transparency regarding this matter.

Enact
Sustainable
Strategies

Page 34 of 100

53

1369

(1) b) i b) iv are not feasible for italian legislation in which the rules forthe election of the BoD is strictly defined by applicable laws.
As such we propose to eliminate bi) and biv) as not comparable among
different Countries.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

54

1374

(2) b) i b) iv are not feasible for italian legislation in which the rules forthe election of the BoD is strictly defined by applicable laws.
As such we propose to eliminate bi) and biv) as not comparable among
different Countries.

Eni SpA

Italy

Business

55

1367-8Nominating and selecting the highest governance body - Would this topic
now refer only to sustainability Governance?

Netherlands

Assurance
provider56(13631375)

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

57

1374-1375

Ø Disclosure GOV 2 Nomination and selection of the highest
governance body (1363-1375)• Human rights needs to be mentioned explicitly here instead of just
"sustainable development" which can be very broad. Companies need tohave Human Rights experts at as an essential part of decision making andgovernance bodies.
Nomination and selection of the highest governance body should expect
one or more members to have been trained in the use of the GRI
standards. How can they be effectively implemented without formal
training on how to use them in a reporting process? Recommend: Add“…including training in GRI Standards” to sub-clause iv as follows:“…expertise and experience relating to sustainable development topics
are considered, including accredited training in GRI Standards”.

ERM
Certification
andVerification
Services (ERM
CVS)
Forest Peoples
Programme

Next Level
Sustainability

Australia

GRI Certified
Training
Partner

On behalf ofanorganization,group orinstitution

Page 35 of 100

58

1372

Diversity should refer to the characteristics or identities that makes anindividual and presence of difference within a given setting. We would
recommend the GRI refers to age, disability, gender reassignment,
marriage and civil partnership, race, religion or belief, sex and sexual
orientation – this is taken from the UK Equality Act 2010, but the GRI
can refer to similar legislation in other jurisdictions to create a morecomprehensive list of diversity characteristics.
For stakeholders there should be an explicit comment on working withexecutive search firms and making sure these are working towards thecriteria defined by the company when appointing members to the highest
governance body from outside the organisation.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

59

1371

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

1371

Different items of criteria for selecting members, should be examples andnot a list. (this way the list is shown as a 4 items requirement)

DanielaWinickiChile

Consultant

On behalf ofanorganization,group orinstitution
As anindividual

60

61

1372

The degree to how much diversity and independence are considered
could put the organisation in an awkward position. This is because thetwo concepts require careful consideration.

FridahMashandi

ZambiaNo response

As anindividual

62

1374

This requirement may not be necessary to other members of the highest
governance body, but only to the person-in-charge of managing thecompany's sustainability performance.

University ofAsia and thePacific Center forSocialResponsibility

Phlippines

Assurance
providerOn behalf ofanorganization,group orinstitution

Disclosure GOV-2 Nomination and selection of the highest governance body

Page 36 of 100

63(1) GOV-3-a to c: It requires the org to report on their sustainability
governance and describe how the seniors delegate responsible parties inmanaging sustainability topics to ensure the internal agenda of the org's
sustainable development is disseminate at all working levels.

AlliedEnvironmental
Consultants

Hong Kong

Consultant

64(2) GOV-3-d: Do "internal resources" refer to no. of responsible staff/
no. of training sessions/ amount of money/ others?

AlliedEnvironmental
Consultants

Hong Kong

Consultant

The existence of this section would preclude the need for a requirementof the highest governance body or most senior executive of theorganization to include a statement acknowledging their responsibility for
preparing the reported information. This section would identify theappropriate body/individual to make that statement.
The DIHR recommends that explicit reference is made in the context of
GOV-3 requirements to the desired link between an organisation’s‘sustainable development topics’ and the material topics identified andreported on in the context of GRI reporting. This is to avoid use
delinking the sustainable development agenda from that of managing
material topics, including negative impacts on human rights and to avoid
encouraging ‘cherry picking’ of sustainability topics. We note that GOV3, the Glossary or the Key Concepts section currently do not include any
language on what (should) constitute an organisation’s sustainability
topics and as such suggest instead using material topics term which iswell-defined. As a minimum we suggest the relevance of material topics ismade clearer in guidance for GOV-3 or ideally directly embedded in
GOV-3 requirements, noting the responsibility of the highest governing
body to approve material topics (see line 2594).

JosiahMcClellan

United States Business

DanishInstitute for
Human Rights

Denmark

65

1380-1389

66

1378-1389

National
human rights
institution

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

On behalf ofanorganization,group orinstitution

Page 37 of 100

671376-1389

68

1376-1565

69

1376 1389

Disclosure GOV-3 Responsibilities … and delegation. As noted
elsewhere, the Standards place more roles, responsibilities and tasks on
the HGB as the reporting standards unfold. The HGB’s role is to govern,
not to manage. Reconsider the Requirements and the Guidance as they
pertain to the HGB, notably in light of other entities (including Internal
Audit) that routinely play a key role in design, implementation, andconfidence in compliance, risk management and financial reporting.
Disclosure GOV-3 Responsibilities … and delegation: One comment
about the Governance section of the Standards: This is one of 10
sections (of 15) that has no guidance for the Requirement. Governanceis important. It is also not universally understood or applied. The
Universal Standards should provide Guidance on each GOV reporting
requirement.
We propose to merge GOV3 and GOV10 to give an high level overview
of how the highest governance body oversees and manages sustainable
development topics explaining role and responsibility with an overview of
how the management is delegated to deal on these topics.
b-c: the disclosure is feasible but in companies where sustainability isalready integrated in the different functions (Risk management,
governance, planning) could be difficult to explain.
d: in such organization where the sustainability is integrated, internal
resources should manage the different processes also with a sustainability
lens view; as such could be difficult to describe in details.
If it is not possible to merge GOV3 and GOV10, we suggest to merge atleast b-c-d describing how sustainable development is managed also withregard to the organizational structure.

DouglasHileman

United States Consultant

As anindividual

DouglasHileman

United States Consultant

As anindividual

Eni SpA

Italy

On behalf ofanorganization,group orinstitution

Business

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different

Page 38 of 100

70

1384-1389

71

1384-5 and1386-772

stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
While we agree with the disclosures, many companies don't have a welldefined sustainability governance structure, so this requirement will
discourage less mature companies from using the GRI Standards.
Delegating authority – In requirement c. ERM CVS suggests that the levelof detail that is required of organizations to include is outlined moreclearly. If not, this could pose problems for external assurance providersin evaluating the completeness of disclosures.
In requirement d. ERM CVS suggests that ‘Organization's resources’
needs to be defined clearly. For example, economic, talent, staff,
investment resources or an additional example or explanation isincorporated.
Describing the resources available to govern and implement sustainability
in the organization increasingly becomes impossible and increasingly any
reporting would create a skewed Picture and leading to more invalidity:
as organizations progress to embed sustainability in all functions (sales,
monitoring, risk, purchasing, in products and service offerings, in cliente
acceptance etc), you will find fewer dedicated sustainability resources in
the organization, and many many resources (people) that have a role insustainability, or even the absence of resources, since sustainability isembedded in processes, templates, automated systems etc. it is
impossible to enumerate them. What should be reported however who
is responsible for the sustainable development Governance, the formalorgans involved in setting and discussing policies, monitoring etc. So
please make explicit WHAT organs, resources, activites should be
described.

ERM

United States Consultant

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOlaf Brugman

BrazilGRI Board

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

As anindividual

Page 39 of 100

731386 1387

74

1376-1389

75

13,861,387

76

1376-1388

77

1380-1381

With regards to the new requirement, GOV-3-d, the Standards could be
improved by providing more guidance or examples around the type of
information required when describing internal resources for managing SD
topics. More information is needed for the newly added requirement todescribe internal resources, i.e. do internal resources also include
specialist consultants assigned to augment existing employees in the SD
function?
As some of the key concepts has been revised to include considerations
related to sustainable development, due diligence process and humanrights, please consider clarifying in the requirements how relevant
functions are involved in the decision-making process at the highest level
and their respective level of expertise and/or knowledge in relation torecent developments in those areas
The description of internal resources would technically degrade certain
organisations because they might not have competitive advantage.

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

On behalf ofanorganization,group orinstitution

FridahMashandi

ZambiaNo response

As anindividual

For many companies, I suspect these responsibilities do not formally exist
i.e. responsibility for sustainable development topics will not be specified
in role descriptions of terms of reference. Whilst consideration ofsustainability topics will be impacting governance decision making, I
expect it will be challenging for those who are delegated responsibility
for reporting to have a clear view of sight over the responsibilities anddecision making processes.
We welcome the requirement for the highest governing body to provide
information on its role and responsibility with regards to decision-making
for sustainable development issues.

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

UNDP - SDG
Impact Team

United States UN body

On behalf ofanorganization,group orinstitution

Page 40 of 100

78(linesShould have a requirement stating, “The organization shall describe the1376-1389) specific sustainable development topics discussed by the highest
governance body on sustainable development topics and any resulting
decisions made.”This section could also better specify “internal resources.” For instance,
does “internal resources” refer to financial resources, human resources –or other resources?

WBCSD

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure GOV-3 Responsibilities for sustainable development topics and delegation
79

1390

80

81

1390 1398

Related to the comment above; GOV-10 is particularly important interms of the role of stakeholders in the identification of impacts

AustralianCouncil ofTrade Unions

Australia

Labor
representative

Unnecessary. Who cares how many stakeholders the Board has engaged
with. Why is this a matter for public disclosure and how does it affectsustainability development? Suggest deleting this one.

BeyondBusiness Ltd

IsraelConsultant

We propose to eliminate such disclosure. In fact, in large organization,
the stakeholder engagement activities are delegated to many functions
and the Board is involved only when critical. Often is directly the CEO
who is engaged in answering to critical stakeholder in a timely manner.

Eni SpA

Italy

Business

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for a

Page 41 of 100

transparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
82

1390-1398

83

1394-1395

84(13901398)

85

The disclosure appears to suggest that Boards of Directors proactively
consult stakeholders, which from our experience is not the case.
Stakeholders/shareholders are provided a method to contact the Boardof Directors, but it is not typical to complete proactive engagement. We
ask GRI to clarify the purpose of this disclosure and guidance for thereporting organization.
Do Boards or Executive committees actually undertake stakeholder
engagement?
Suggest changing this to 'Describe how is the highest governance bodyinformed about the views on stakeholders (or key stakeholder groups)
on material SD topics' or similar.

ERM

United States Consultant

On behalf ofanorganization,group orinstitution

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Ø Disclosure GOV 4 Stakeholder consultation on sustainable
development topics (1390-1398)

ERM
Certification
andVerification
Services (ERM
CVS)
Forest Peoples
Programme

UnitedKingdom• GRI needs to define “consultation” in this context before it can provide
full feedback; however, it is clear that an addition should be made toinclude “consultation in relation to indigenous peoples and local
communities includes their free, prior and informed consent (FPIC),
which is a core standard that upholds that engagement is not sufficientwhere business operations or investments may directly or indirectly
affect community rights or interests in general. Compliance with thisstandard and respect for FPIC includes respecting a community decision
to withhold consent.
Stakeholder consultation is certainly positive, and it is important to havethe board involved with stakeholder engagement. But as noted above,
we think this section of the standards mmay betoo narrow and notreflect the importance of the specific role of shareholders as providers ofNongovernmentorganization

On behalf ofanorganization,group orinstitution

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,

Page 42 of 100

capital with important ownership rights. Also, we believe the focus on
engagement should certainly include, but not be limited to, sustainable
development topics.

group orinstitution

86

1397

Companies should be providing examples of how feedback isincorporated/what changes are made to policy and processes to be auseful measure.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

87

1394-1398

Stakeholder 'engagement' (i.e. stakeholder relationship management)
rather than stakeholder consultation as defined elsewhere in the
exposure draft e.g. line 2018 6. Stakeholder Engagement - onwards.

Shelley
AndersonAustralia

Consultant

881390-1398

In most instance this responsibility will be delegated, findings
incorporated into materiality assessments and report development. I
would expect that only the output is typically provided to the highest
governance body, not the detail around specific stakeholder feedback.

Think Impact
Pty Ltd

Australia

Consultant

89

Line
number1394- 1395

Include not only process but also frequency

UN Global
Compact
Network
Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure GOV-4 Stakeholder consultation on sustainable development topics
90

1390

Related to the comment above; GOV-10 is particularly important interms of the role of stakeholders in the identification of impacts

AustralianCouncil ofTrade Unions

Australia

Labor
representative

On behalf ofanorganization,group orinstitution

Page 43 of 100

91

92

1390 1398

93

1390-1398

94

1394-1395

Unnecessary. Who cares how many stakeholders the Board has engaged
with. Why is this a matter for public disclosure and how does it affectsustainability development? Suggest deleting this one.

BeyondBusiness Ltd

IsraelConsultant

We propose to eliminate such disclosure. In fact, in large organization,
the stakeholder engagement activities are delegated to many functions
and the Board is involved only when critical. Often is directly the CEO
who is engaged in answering to critical stakeholder in a timely manner.

Eni SpA

Italy

Business

ERM

United States Consultant

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

On behalf ofanorganization,group orinstitution

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
The disclosure appears to suggest that Boards of Directors proactively
consult stakeholders, which from our experience is not the case.
Stakeholders/shareholders are provided a method to contact the Boardof Directors, but it is not typical to complete proactive engagement. We
ask GRI to clarify the purpose of this disclosure and guidance for thereporting organization.
Do Boards or Executive committees actually undertake stakeholder
engagement?
Suggest changing this to 'Describe how is the highest governance bodyinformed about the views on stakeholders (or key stakeholder groups)
on material SD topics' or similar.

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 44 of 100

95(13901398)

96Ø Disclosure GOV 4 Stakeholder consultation on sustainable
development topics (1390-1398)• GRI needs to define “consultation” in this context before it can provide
full feedback; however, it is clear that an addition should be made toinclude “consultation in relation to indigenous peoples and local
communities includes their free, prior and informed consent (FPIC),
which is a core standard that upholds that engagement is not sufficientwhere business operations or investments may directly or indirectly
affect community rights or interests in general. Compliance with thisstandard and respect for FPIC includes respecting a community decision
to withhold consent.
Stakeholder consultation is certainly positive, and it is important to havethe board involved with stakeholder engagement. But as noted above,
we think this section of the standards mmay betoo narrow and notreflect the importance of the specific role of shareholders as providers ofcapital with important ownership rights. Also, we believe the focus on
engagement should certainly include, but not be limited to, sustainable
development topics.
Companies should be providing examples of how feedback isincorporated/what changes are made to policy and processes to be auseful measure.

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
As anindividual

97

1397

98

1394-1398

Stakeholder 'engagement' (i.e. stakeholder relationship management)
rather than stakeholder consultation as defined elsewhere in the
exposure draft e.g. line 2018 6. Stakeholder Engagement - onwards.

Shelley
AndersonAustralia

Consultant

901390-1398

In most instance this responsibility will be delegated, findings
incorporated into materiality assessments and report development. I
would expect that only the output is typically provided to the highest
governance body, not the detail around specific stakeholder feedback.

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,

Page 45 of 100

group or
institution
91

Line
number1394- 1395

Include not only process but also frequency

UN Global
Compact
Network
Spain

Spain

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure GOV-5 Chair of the highest governance body
92

1404

We agree with the rationale for this requirement. However, GRI is likely
to experience resistance from U.S. companies, as it is more common in
the U.S. to combine the roles of CEO and Chair.

ERM

United States Consultant

93

1404-6(1) Chair of the highest governance body – are the conflicts of interest
that need to be disclosed only in the sustainability field?

ERM
Certification
andVerification
Services (ERM
CVS)
Principles for
Responsible
Investment

Netherlands

Assurance
providerUnitedKingdom

Trade orindustry
association

94

The company should clarify if the chair is also a senior executive, how it
ensures independent oversight of management and which other board
member may be responsible for engagement with shareholders and otherstakeholders. For example, companies may appoint a lead or seniorindependent director to counterbalance the power of a combined
Chair/CEO and grant them additional responsibilities such as being analternative contact point for investors.

On behalf ofanorganization,group orinstitution

Page 46 of 100

95

14,021,403, The points seem like a repetition, it could possibly be deleted and140,414,00 compressed in Gov-2
0,000

FridahMashandi

ZambiaNo response

As anindividual

96(linesCan be integrated into GOV-3 (point b.) rather than be an entirely
1300-1406) separate disclosure element.

WBCSD

Switzerland

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Disclosure GOV-6 Conflicts of interest
97

This is irrelevant for sustainability reporting. Conflict of interest is aprinciple of good governance and covered by other disclosures.

BeyondBusiness Ltd

IsraelConsultant

981416-1417,
1322(1) iii meaning of controlling shareholder unclear in the Swedish stockmarket context

Bonava AB

SwedenBusiness

991416-1417,
1322(2) iv. unclear boundaries on what to refer to as related parties, theirrelationships, transactions and outstanding balances

Bonava AB

SwedenBusiness

100

1415

This is already covered in Singapore’s Code of Corporate Governance2018. For non-listed companies, it may be too onerous.

City
Developments
LimitedSingapore

Business

Page 47 of 100

group or
institution
101

1407 1417

As these details are already required in other mandatory reports, there
would be a proliferation of information. In fact such details are more
relevant for a governance report rather than a sustainability report.
Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
(2) Additional explanations on how conflicts of interest are managed in a
separate disclosures (GOV-6) might be too much to require at this point
for organizations currently reporting in accordance with Core Option.

102

1404-6103(1407 –
1417)

Ø Disclosure GOV-6 Conflicts of interest (1407 – 1417)

1412

It is unclear whether an organization can choose to not disclose thisinformation. It appears that an organization can indeed choose to notdisclose to stakeholders. In this event the subsequent minimum
requirements would become not applicable and may be better presented
as ‘guidance’. This needs further clarification.

104• Add (c) where the conflicts of interest are disclosed in GRI reporting
itselfEni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)
Forest Peoples
Programme

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

UnitedKingdom

Nongovernmentorganization

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 48 of 100

105

1407-1431,
1491-1565

106

Governance disclosures are important but these seem overly complex.
What relevancy is there to sustainability in regards to the external
impacts of the organization? This is a disclosure listed in other corporate
reports such as the SEC's 10K report. Please don't overburdenorganizations unnecessarily as this will just create distraction for the info
user on relevant subjects and topics. Recommendation to remove or
make clear that reference to a report wherein this info exist is allowed.
Overall comment for these governance disclosures is to limit them tothose that have to do with the overview of the highest governance bodywithin the organization and those that include discussions on sustainable
development topics and delegation.
This is irrelevant for sustainability reporting. Conflict of interest is aprinciple of good governance and covered by other disclosures.

University ofDenverUnited States No response

No response

BeyondBusiness Ltd

IsraelOn behalf ofanorganization,group orinstitution

Consultant

Disclosure GOV-7 Role of the highest governance body in setting purpose, values, and strategy
107

108

1424-1447

This is unnecessary. The sustainability report requires a message fromthe CEO or other senior leader, and there is a later disclosure GOV-11
that covers the Board's role in sustainability reporting. Quite unnecessary
to have another disclosure that describes in detail how the Board has
been involved insetting purpose values etc.
Disclosure GOV-7 Role of HGB: Revisit GOV-7 and re-orient theStandards that align to the more common approach to governance andmanagement. As noted elsewhere, the role of the HGB is to govern, notto manage. Many of the requirements of GOV-7 place management
responsibilities on the HGB – or imply as much. These overlook roles,
responsibilities, and value provided by management departments

BeyondBusiness Ltd

IsraelConsultant

DouglasHileman

United States Consultant

On behalf ofanorganization,group orinstitution
As anindividual

Page 49 of 100

(environmental, supply chain, etc.), “second line of defense” audit
activities (health & safety, environmental, IT) and Internal Audit.
109

1441-1443

110

1428

111

1425

GOV-7 The Standards require the organization to describe the process
for evaluating the performance of the HGB. This begs the question of
how this would be done. In my role as VP of Advocacy for my local
chapter of the Institute of Internal Auditors, I have attended many
meetings of National Association of Corporate Directors for several
years, as well as reviewed many NACD publications and guidance. The
topic of performance reviews for directors in performing their core
responsibilities is rarely (if ever) covered; as such, there is no obvious
foundation for evaluating performance of individuals on the HGB for
sustainability reporting. This goes to two points made throughout mycomments on the draft Universal Standards: First, they should reflect
common practice in organization governance (notably that the HGB’s
mission is to govern, and not to manage). Second, GRI should provide
guidance for each GOV disclosure topic. If GRI can cite internationallyrecognized standards or frameworks for evaluating HGBs, then theseshould be cited as reference. If GRI cannot cite a widely-accepted
standard, consider deleting this requirement. As a possible alternative,
see comment at Line 2607 et seq on HGB actions on shareholder
proposals.
Not clear whether it is only goals relating to sustainable developmentthat need to be considered, or mission, vision etc. We believe thatsustainable development should be considered across the whole strategy
rather than only strategic goals.

DouglasHileman

United States Consultant

As anindividual

GIB Asset
Management

UnitedKingdomBusiness

IOSH supports the focus on the role of governance in setting corporate
values and the GRI June 2019 survey, we also called for more emphasis
on setting a corporate culture (e.g. shared attitudes, values, managerial
practices and beliefs).

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 50 of 100

112

1425-1447

These are medium priority questions.

Sustainability
Advantage

CanadaNo response

113

1424-1447

Disclosure GOV-7 Role of HGB: The role of the Highest Governing
Body (HGB) is to govern, not to manage. Many of the requirements of
GOV-7 place management responsibilities on the HGB – or imply as
much. These overlook roles, responsibilities, and value provided bymanagement departments (environmental, supply chain, etc.), “secondline roles” audit activities (health & safety, environmental, IT) and internal
audit. The IIA suggests GRI revisit GOV-7 and reorient the Standards
that align to the more accepted approach to governance andmanagement.

The Instituteof Internal
Auditors

United States Standard
setterNo response

On behalf ofanorganization,group orinstitution

Disclosure GOV-8 Collective knowledge of the highest governance body
114

115

"For most companies, ""experience on sustainable development"" maynot be the most relevant in the highest governance body?

1436-7

For reference:
102-27: Measures taken to develop and enhance the highest governancebody’s collective knowledge of economic, environmental, and social
topics"Collective knowledge of highest governance body – suggest including thelevel of detail that is required to be in accordance.

AlliedEnvironmental
Consultants

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Page 51 of 100

116

Additional reporting on board SD topics training is now required. This
will drive the establishment of board training on relevant SD topics
where it is not already implemented. Again, adequate implementation
timing is required to ensure implementation prior to reporting.

ICMM

UnitedKingdom

Trade orindustry
association

117

This disclosure item comes across as vague, and again seems to isolate
sustainable development from overall governance.

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

118

GOVERNANCE -8 a states that “The organization shall (a) reportmeasures taken to develop the collective knowledge, skills, andexperience of the highest governance body on sustainable development
topics”. This collective knowledge won’t be effective for sustainability
reporting unless the highest governance body also has members trainedon how to apply the GRI Standards in a reporting process. The highest
governance body needs to report demonstrated competence in
Sustainability Reporting not just assume it exists because of anunderstanding of a sustainable development topic or their seniority in theorganisation. One can understand a topic without understanding thereporting requirements. Recommend amend (a) to include training asfollows: “The organization shall (a) report measures taken to develop
the collective knowledge, skills, and experience of the highest governancebody on sustainable development topics as well as to develop skills
through accredited GRI Standards training on how to apply the GRI
Standards in a sustainability reporting process”.
For training / capability building, often assumed "sustainable development"
topics are "sustainability" topics. When in fact, topics such as Risk &Compliance, Anti-bribery & Corruption, Data Protection &Cybersecurity etc are sustainability-related especially if it correlates/inline with material topics identified by an organisation.

Next Level
Sustainability

Australia

GRI Certified
Training
Partner

RHB Bank
BerhadMalaysia

Business

119

1432 1437

1436-1437

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution

Page 52 of 100

120

1432-1437

121

1436-1437

There needs to be more clarity about what this means - training on
specific sustainable development topics? I expect that most governancebody members are appointed due to their expertise and experience in
relevant areas and doubt training of this nature would be provided.
Further, an assessment of the collective knowledge of a governance body
would be challenging for those delegated with responsibility for thereport. If it is to be included, the clause should be amended to specify'material' sustainable development topics for the organisation.
Enhancing board skills with regard to identifying sustainable development
risks and opportunities and incorporating them into decision making is
critical to the change required to achieve the SDGs and for long term
value creation for the organisation and society.

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

UNDP - SDG
Impact Team

United States UN body

On behalf ofanorganization,group orinstitution

Disclosure GOV-9 Evaluation of the performance of the highest governance body1221446 1447

As these details are already required in other mandatory reports, there
would be a proliferation of information. In fact such details are more
relevant for a governance report rather than a sustainability report.
Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Page 53 of 100

123

1442-3 and
1446-7

Line: 1442-3 & 1446-7
This requirement may be too much for organizations to report at the
moment, especially if people with experience and skills in sustainability
are chosen for governance bodies in the first place, and if the promotionof knowledge is explained in GOV-8. This should be fully or partiallydescribed in other legal requirements on financial reporting thatorganizations could potentially refer to. Anything above those disclosures
is usually very hard to get approved for public disclosure.

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure GOV-10 Identification and management of impacts
124

1448

The remuneration disclosures at GOV-13,14,15 are important inestablishing the transparency within the organisation and focusing
attention on the growth or mitigation of income inequality within andbeyond the organisation

AustralianCouncil ofTrade Unions

Australia

Labor
representative

125

1451-1458

The highest governance body (usually a board committee) should be
providing strategic direction on sustainability issues. We opine that it is
not feasible to expect a board-level committee to play an active role inthe due diligence processes and the active management of sustainability
topics.
Deloitte believes that GOV-10 should go further and require reporters
to disclose how the board assesses impacts, and related mitigation, in
relation to the implications for the corporate strategy and businessmodel that arise from addressing or reducing those impacts. The
reporting organization should be required to disclose how it has taken its
impacts into consideration over the reporting period. This ultimately
would strengthen the Board’s decision making. This could also beemphasized further in GOV-7.

CLP Holdings
Ltd.

Hong Kong

Business

Deloitte

United States Consultant

126

Page 54 of 100

1271448 1465

128

1451-3 and1463-5129(1448 –
1465)

We propose to merge GOV3 and GOV10 to give an high level overview
of how the highest governance body oversees and manages sustainable
development topics explaining role and responsibility with an overview of
how the management is delegated to deal on these topics. All the details
requested seem to be a step back in terms of process integrations; mostof the companies already have an integrated risk management system, anintegrated internal control process. To better clarify the requests, wesuggest to rephrase a. focussing more on the risk management process,explaining if ESG risks are integrated, and if it is in place an internal
control system.
Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
Effectiveness of risk management processes – Requirements a. and d.
potentially overlap with the MT disclosures required for each topic andGOV-3, where the actual responsibilities with respect to sustainability
management have been described. GRI might be asking the company toduplicate the information, unless this can be referenced in the content
index to be responded individually for each topic disclosure (e.g. review
of effectiveness of the organization’s processes).
Ø Disclosure GOV-10 Identification and management of impacts (1448 –1465)• The means and methods of demonstrating the outcomes related to the
management of impacts should be disclosed

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Page 55 of 100

1301448 1465

131

1450

132

1449-1465

133

275-280

These revisions emphasize the role of the highest governance body.
There appears to be potential for repetition of information that isrequired for GOV-3 around roles and responsibilities of the highest
governance body related to SD topics - that may have to be revisited by
the GRI.
The additional requirements to specify the frequency of reviewing theeffectiveness of its processes to identify and manage SD topics and theirrelated impacts, will require more information to be reported, however
this should provide more context to the reader and will therefore behelpful. The same can be said for the new requirement to specify thefrequency of reporting to the highest governance body on theorganization's processes as described in GOV-10-a.
Disclose the process and governance bodies involved in identifying andmanaging sustainable development topics and their related impacts- As more than one governance body may be responsible for different
aspects of sustainable development topics and their impacts, we suggest
organisations disclose the entire process and the governance bodies
involved. Where more than one governance body has responsibility thendetails be provided about all relevant governance bodies.
GOVERNANCE -10 Identification and management of impacts is about
the roles of the highest governance body and stakeholder consultation to
identify and manage impacts, but it also needs to be about competency
within the organization to identify and manage impacts consistent with
the GRI Standards. Include also new clause “e” “…report whether
accredited GRI Standards training is used to train staff and the highest
governance body in identifying and managing impacts in accordance with,or with reference to, the GRI Standards.
It would be more feasible for this requirement to align with risk
management processes that are reviewed by highest governance body.
Enhancing the established practice of identifying and managing enterpriserisks so that the process incorporates broader topics of sustainability will

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Next Level
Sustainability

Australia

GRI Certified
Training
Partner

On behalf ofanorganization,group orinstitution

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,

Page 56 of 100

support the objective and I expect it will be more palatable togovernance bodies.
134

1448 ff.

135

1448-1565

Consider adding reference (perhaps in guidance) to companies
developing a “resilience approach”, which has been raised in several
discussions on governance for sustainability during the COVID-19
pandemic. These discussions suggest that organisations need to be clear
in demonstrating the resilience of their strategy and thus how they areplanning to create value in the long-term and adapt to certain
circumstances and shocks (e.g. climate change, or, indeed, a pandemic).
Resilience needs to be addressed at every level of the organisation andthe board has the responsibility to oversee this process.
These are high priority questions, especially GOV-13.

group orinstitution
World
Benchmarking
Alliance

Netherlands

Benchmarking
foundation

On behalf ofanorganization,group orinstitution

Sustainability
Advantage

CanadaNo response

No response

Disclosure GOV-11 Role of the highest governance body in sustainability reporting136

1478-1482

It seems unrealistic that the Board or senior executives will be qualified
to make this statement. We recommend keeping the requirement for the
Board/senior executive to reivew and approve the reporting, per lines
1473-1475.

ERM

United States Consultant

137

1469

The disclosure gov-11 is not necessary if the statement of use (see line353) is confirmed as requested

EY S.p.A.

Italy

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 57 of 100

138

How do and know that how document it .

RPMRG

Hungary

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

139

1478-1482

I wouldn`t make it mandatory

UN Global
Compact
Network
Spain

Spain

Nongovernmentorganization

140

lines 14721475

WBCSD

Switzerland

Nongovernmentorganization

141

1469 ff.

World
Benchmarking
Alliance

Netherlands

Benchmarking
foundation

On behalf ofanorganization,group orinstitution

142

1448-1565

This section should also focus on the highest governance body thatformally validates the outcomes of the materiality assessment. The
current wording is not clear. One way to address this would be to put afull stop after “sustainability reporting” and make point b. “Theorganization shall report the committee of the highest governance bodyor senior executive position that formally reviews and approves theorganization’s materiality assessment process and outcomes.”
This disclosure appears helpful to understand the role of the highest
governance body or senior executive in sustainability reporting. It may be
helpful to clarify in the guidance (around line 1480) that if the reported
information has been prepared in accordance with the GRI Standards
that the responsibility of the highest governing body or most senior
executive position extends to the materiality assessment having been
properly undertaken.
These are high priority questions, especially GOV-13.

Sustainability
Advantage

CanadaNo response

No response

Disclosure GOV-12 Communication of critical concerns

Page 58 of 100

143"The spectum of ""critical concerns with regard to sustainable
development topics"" could be very board - any further guidance and/or
examples for reference to be provided by GRI as a way to draw theboundary?

AlliedEnvironmental
Consultants

Hong Kong

Consultant

On behalf ofanorganization,group orinstitution

For reference:
102-33: Process for communicating critical concerns to the highest
governance body102-34:a. Total number and nature of critical concerns that were communicatedto the highest governance body.
b. Mechanism(s) used to address and resolve critical concerns"
Would suggest to drop “report the total number and nature of criticalconcerns that were communicated to the highest governance bodyduring the reporting period”.

City
Developments
LimitedSingapore

Business

JosiahMcClellan

United States BusinessOn behalf ofanorganization,group orinstitution
As anindividual

144

1488

145

1488-1489

Not relevant for governance disclosures. This is more appropriate in themain report content where the issues can be adequately discussed.

1461485-1489

The Universal Standards should reflect common practice in organizational Douglas
governance (notably that the HGB’s mission is to govern, and not to
Hilemanmanage), acknowledge existence and roles of other activities commonly
involved in governance (including Internal Audit – which reports directly
to HGB); and that GRI should provide guidance for each GOV disclosure
topic. Disclosure GOV-12 (Communication of critical concerns) requires
the organization to “ .. describe the processes for communicating criticalconcepts to the HGB ..” and to report the total number and nature of
critical concerns communicated to the HGB. This does not incorporate
many other aspects of good corporate governance for “criticalconcerns.” Some are included elsewhere in the Standards (grievance

United States Consultant

As anindividual

Page 59 of 100

1471486-1487

148

1483 1490

process, whistleblower program). Others are not – such as robustinternal topical councils or committees, internal reporting andmonitoring, 2LOD audit programs, 3LOD Internal Audit activities,
implementation of a speak-up culture, and many others.
Clarity and usability would increase if GRI could provide the reportingorganisation with guidance and examples of what a critical concern withregard to sustainable development topics could be, or how suchjudgement can be done. This would also support the reportingorganisation in determining what to report on disclosure GOV-12 b: thetotal number of and nature of critical concerns that were communicated.
We deem the current definition of "critical concern" is too vague; wethen suggest to better define it: for example it could be expressed interms of relevant ESG risks identified by the Risk Management process.
Generally speaking, we suggest to cancel this indicator because it is toovague and not comparable among companies. It is impossible to define aboundary to critical concerns (they could be concerns raised by the
stakeholders or issues in terms of strategy, i.e. climate changes
adaptation and mitigation).

Enact
Sustainable
Strategies

SwedenConsultant

On behalf ofanorganization,group orinstitution

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.

Page 60 of 100

149

1483-1490

We ask GRI to clarify: what is the definition of "critical concerns"? The
language of this standard is vague.

ERM

United States Consultant

150

1486-1490

Not sure 'critical concerns' is defined sufficiently to ensure consistent andassurable disclosure

Netherlands

Assurance
provider151(14831490)

Ø Disclosure GOV-12 Communication of critical concerns (1483-1490)

ERM
Certification
andVerification
Services (ERM
CVS)
Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

152

1486

What is the definition of "critical concerns"? And whose "criticalconcerns"? Are they similar to grievances in RBC-4? Would be helpful for
GRI to clarify/define "critical concerns" in the guidance/glossary.

Paia
Consulting

SingaporeConsultant

1531488-1489

No omission is allowed for Governance. However, reporting on total
number and nature of critical concerns that were communicated tohighest governance body is a high expectation. Organisations may not be
willing - for any of the reasons outlined in line 294 exposure draft.

RHB Bank
BerhadMalaysia

Business1541483-1490

It is very difficult for the companies to respond about the "criticalconcerns". Maybe it is better to talk about material impacts, or material
topics.

Sustenia

Argentina

Consultant• GRI must define “critical concern”

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 61 of 100

1551485-1489

156

1483-1490

157

1486, 1488

158

1448-1565

Disclosure GOV-12 (Communication of critical concerns) requires theorganization to “ ... describe the processes for communicating criticalconcepts to the HGB ...” and to report the total number and nature of
critical concerns communicated to the Highest Governing Body (HGB).
This does not incorporate many other aspects of successful corporate
governance for “critical concerns.” Some are included elsewhere in theStandards (grievance process, whistleblower program). Others are not –such as robust internal topical councils or committees, internal reportingand monitoring, internal audit activities, implementation of a speak-up
culture, and many others. The Universal Standards should reflect
common practice in organizational governance (notably that the HGB’s
mission is to govern, and not to manage), acknowledge existence androles of other activities commonly involved in governance (includinginternal audit – which reports directly to the HGB); and that GRI should
provide guidance for each GOV disclosure topic.
Board papers and reports are confidential, it would be challenging for
those delegated responsibility for the report to access such information.
Surely the disclosure in the report of the process to identify, prioritise
these critical concerns (i.e. material topics) and what they are and how
they are managed, and sign-off of this content by the highest governancebody, would be sufficient?
GRI should define what "critical" is, or provide criteria in order toconsider a concern as critical.

These are high priority questions, especially GOV-13.

The Instituteof Internal
Auditors

United States Standard
setterOn behalf ofanorganization,group orinstitution

Think Impact
Pty Ltd

Australia

Consultant

On behalf ofanorganization,group orinstitution

University ofAsia and thePacific Center forSocialResponsibility
Sustainability
Advantage

Phlippines

Assurance
providerOn behalf ofanorganization,group orinstitution

CanadaNo response

No response

Page 62 of 100

Disclosure GOV-13 Remuneration policies
159

160

1496-1503

Remuneration ifor Board and execs is extensively covered in corporate
disclosures - annual reports and proxy statements. What's the need for it
here? How does this impact sustainable development? Of course, due
process in remuneration programs should be observed by any company,
but to force this as part of sustainability disclosure is unnecessary andtoo burdensome for reporters and for report users. If not removed thenthese disclosures should not be a mandatory part of In Accordance
Reporting but can be retained as "optional extras"
In general for all parts of the requirement, very detailed - and theguidance also indicates the explanations needed to comply to be overly
extensive, risking to make sustainability reports too detailed and long
beyond the interest of most target groups (risk hindering integrated
reporting in for example annual reports)

BeyondBusiness Ltd

IsraelConsultant

On behalf ofanorganization,group orinstitution

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

iv. the meaning of clawbacks are difficult to comprehend in an
European/Swedish context

161

1491 1506

v. the scope for this part of the disclosure seams very broad, reporting
according to this requirement would get very long - as it includes
comparison with all other employees
All these information are already published on remuneration reportpursuant to national regulation. The relevant disclosure in non-financial
reporting should be focus only on short term and long term
remuneration linked to sustainability objectives.
Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governance

Page 63 of 100

162

1492-1565

163

1491-1523

164

1500

165

1491-1523

as such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
Disclosures under this category could pose many challenges to SOEs.
Thus, it is not clear how the companies that do not disclose thisinformation will be able to comply with the GRI 102.
Additionally, GOV-14 requirement c (1531-1532), is almost impossible tobe applied as many of the highest governance bodies in SOEs and othercompanies in regions such as the Arabian Gulf are appointed. In addition,
my research pointed that governance disclosures, particularly for nonlisted companies, have the lowest rate; thus, under the new conditions, it
is not clear how these companies will be able to report under the GRI.
Not applicable to all companies; some companies might not be legallyrequired to disclose such information; please consider better clarifying
the relevance of these disclosure requirements in relation to thecompany's overall contribution toward the goal of sustainable
development
Instances when clawbacks were used in a given year, particularly in
relation to ESG related incidents, should be reported.

Remuneration policies and procedures may not be of high relevance.
Reporting organization may opine that GRI is merely interested incollecting data for statistical analysis like other research entities. Thisshould not be in a standard but may be more relevant in separate survey
exercises.

Dr Aljaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 64 of 100

Besides, too much work will be required to meet a requirement that may
have limited relevance.
166

1494

This requirement are ok for stated owned companies or traded
companies, but is a too high requirement for a closed or SME company.
This information can be strategic for them. For not traded companies, allthis requirement are absurd.
Besides In many companies, Directors remuneration is stated on the
General Assembly by law. In that case, all this requirements of info are
not applicable. Reason for ommisions should be aplicable.
Gov-13, - 14, -15 are quite demanding for SMEs. This is for advanced
reporters.

167

DanielaWinickiChile

Consultant

As anindividual

triple innova

Germany

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

168

1494-1503

From personal experience, public companies in Indonesia may object a
detailed remuneration policies. It may be better to provide leniency on
the details (i-v).

Trisakti
Sustainability
CenterIndonesia

Consultant

169

1494

It is also ideal to include "Others" as an additional item under Gov-13a
for companies to report on other incentives or benefits that the highest
governance body receives.

Phlippines

Assurance
provider

170

1504

The requirement is more closely related to Gov-9 Evaluation of theperformance of the highest governance body.

University ofAsia and thePacific Center forSocialResponsibility
University ofAsia and thePacific Center for

Phlippines

Assurance
providerOn behalf ofanorganization,group orinstitution

Page 65 of 100

SocialResponsibility
1711483-15-6

Would be beneficial to include how senior executives are selected.
Above certain grade levels within most multi-national companies internal
HR policies related to selection do not apply.

University ofSouthern
Queensland

Australia

No response

No response

Business

On behalf ofanorganization,group orinstitution
As anindividual

Disclosure GOV-14 Process for determining remuneration
172

1533-1536

Reporting the results of votes and whether remuneration consultants
have been involved can hardly be of relevance for any external
stakeholder

Bonava AB

Sweden173

1534-1536

More clarity is needed to define "relationships" that consultants have with Josiah
the organization. How is this different from acknowledging their
McClellan
involvement?

United States Business

174

1527-1536

Most of the disclosure requirement are covered under the rules andregulation of local bourse.

DRB-HICOMBerhadMalaysia

Business

175

1524 1536

All these information are already published on remuneration reportpursuant to national regulation. The relevant disclosure in non-financial
reporting should be focus only on short term and long term
remuneration linked to sustainability objectives.

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isPage 66 of 100

1761531 1536

177

1524-1536

already required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
The relevance of the new requirements is questioned for Sustainability
Reporting by some members since these add to the reporting burden andtypically belongs in a Remuneration Report as part of an organization’s
Annual Reporting. Consider the need for reporting this in the SD Report,
or consider providing guidance for referencing to the Annual Report.
Same comments as above

178

1525

Disclose directors' conflicts of interest- It is positive to ask for disclosure about any relationships that the
remuneration consultants have with the organisation, its highest
governance body, or senior executives.

ICMM

UnitedKingdom

Trade orindustry
association

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution- To ensure all relevant information is disclosed, it would be prudent toexpand this to require disclosure of all conflicts of interest.
- Further, sometimes independent directors also have conflicts of interestand therefore disclosure on conflicts of interest of directors overseeing
the remuneration process is also important.

Page 67 of 100

179

1529

A description of discretion applied by the committee to remuneration
decisions during the financial year should be included.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

180

1524-1536

Same as above

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

181

1517-1523

From personal experience, public companies in Indonesia may object a
detailed remuneration policies. It may be better to provide leniency on
the details (1517-1523)

Trisakti
Sustainability
CenterIndonesia

Consultant

182

1448-1565

These are high priority questions, especially GOV-13.

Sustainability
Advantage

CanadaNo response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
No response

LebanonNo response

No response

Disclosure GOV-15 Annual total compensation ratio
183

1537-1565

clarity - is it a lump sum amount we are seeking to report on ascompensation?

Bank Audi sal

feasibility - in some countries, this is a matter of discretion
relevance - not identified

Page 68 of 100

184

185

1540-1547

186

1540

Who cares? I care bout how much employees are paid. I really don't careabout how much more the exec are paid, as long as the company is wellrun, ethical, operates with integrity, transparency and accountable.
Making this a mandatory in accordance disclosure is an own-goal - and I
doubt anyone will know what to do with this information if it is reported
anyway.
In theory relevant disclosures, but in reality not - as it would take way
too detailed explanations to understand what is actually behind the ratio
in a certain country. For example if different types of competences, theheadquarter, reasearch centers aso are located in certain countries.
Would make more sense if the payment ratio could also be tied to for
example gender or ethnic background, but that on the other hand wouldin several countries not be data legal to register for example in payrollsystems.
How is ‘significant operations’ being defined? What is the purpose of
disclosing by country? If the CEO oversees operations of a multiple
countries but he/she is based at one country, would the ratio by country
still make sense and be useful? For listed companies in Singapore, CEO’s
annual compensation is required to be disclosed in the annual report.

BeyondBusiness Ltd

IsraelConsultant

On behalf ofanorganization,group orinstitution

Bonava AB

SwedenBusiness

On behalf ofanorganization,group orinstitution

City
Developments
LimitedSingapore

Business

On behalf ofanorganization,group orinstitution

CLP Holdings
Ltd.

Hong Kong

Business

On behalf ofanorganization,group orinstitution

Unless HR systems are integrated, it would be challenging to obtain
median staff compensation for companies with global footprint.

187

1540-1547

Suggest to provide alternative metrics. E.g. CEO's compensation overaverage employee's compensation.
Requiring companies to disclose annual total compensation ratios does
not provide an indication of unfair or inequitable compensation. Instead
focus should be on metrics that measure equal pay for equal work.

Page 69 of 100

188

1540-1547

Making salary mandatory to report on (ratio and increase) would makethe use of GRI Standards difficult for smaller companies. It would
discourage SMEs to use GRI as it is a lot of information that they may notwant to disclose.

Enact
Sustainable
Strategies

SwedenConsultant

189

1537 1547

It is not feasible and relevant to publish the indicator in each country ofsignificant operations. The ratio should be publish only in the country ofthe quarter. Also b. is unecessary as you can already appreciated theinformation in the trend of previous indicator.

Eni SpA

Italy

Business

ERM

United States Consultant

On behalf ofanorganization,group orinstitution

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

On behalf ofanorganization,group orinstitution

190

1540-1547

191

1539-1547

Reporting from GOV1 to GOV15 in details would imply publishing asustainability governance or remuneration report. In Italy for example isalready required by law to publish a dedicated document on governanceas such we suggest to revise the request to not overlap the informationand to select the really important information for the different
stakeholders. Too detailed reports are counterproductive for atransparent and clear disclosure with the stakeholders and difficult forcompany who wish to integrate non-financial and financial information todemonstrate the value creation.
We agree with the rationale for these disclosures, but it may be overly
burdensome for multi-national companies that operate in dozens ofcountries to complete this requirement without substantiallly adding todecision-useful information for stakeholders. Reporting both the ratio
and percentage increase by each country of significant operations seems
challenging, at least for many U.S. companies.
This level of detail will be extremely challenging for many organisations
and many with claim confidentiality to avoid disclosure. consider
alternatives for reporting this topic

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 70 of 100

192

1540

193

194

1537-1565

195

1540

The old 102-39 / new GOV-15 requires reporting 'report the ratio of theannual total compensation for the organization’s highest-paid individual ineach country of significant operations to the median annual totalcompensation for all employees (excluding the highest-paid individual) in
the same country. Take, for example, an airline with 'Outports' in many
countries. In each of these companies it may employ a senior manager inan ambassadorial role to handle government relationships together with anumber of low skilled staff handing clerical work, check-in, etc. There
will be a large differential between the senior managers salary and that of
the other staff. The same is likely to apply to the operations of somebanks. What is the value to sustainability of disclosing this? What is a
the risk that the need to disclose such information will become a reason
companies stop following GRI.
Pay ratios can help to identify instances of extreme imbalances, but theyalso have limitations and can be abused. Limiting the comparative ratio of
pay to employees within one organisation also limits the comparability
from firm to firm. A retailer will have a much different pay ratio than apharmaceutical firm, for example, given the nature of the employment
base. While pay ratios within one organisation can provide some insights,
we think a more robust ratio would be to compare the top pay of a CEO
to the average median income of the country in which he or she isresident. That would remove some of these sectoral distortions andenable more meaningful comparisons from company to company.
Same comments as above

Hong Kong
University of
Science andTechnology

Hong Kong

No response

No response

International
Corporate
GovernanceNetwork

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution

MSC
Mediterranean
Shipping
Company S.A.

Switzerland

Business

It would be more useful to have indicators on: changes in the ratio
compared to the previous year, the rationale for changes, and any
observations on how this ratio compares with peer organizations in thesame industry.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Page 71 of 100

group or
institution
196

disclosure about remuneration and its mechanism

RPMRG

Hungary

Consultant

197

Include gender pay parity for the various levels of management or roles

SAICA

South Africa

Nongovernmentorganization

198

1537-1565

Same as above

Society ofCertified Risk
Professionals

Malaysia

Nongovernmentorganization

199

1540

DanielaWinickiChile

Consultant

200

1537-1565

What happens when the company, does not have the practice, or for
confidential or security reason the company cannot publish theinformation; Example, in Colombia, sharing the remuneration ofmanagers, can be dangerous. In this case, for example, the answer
cannot be "NO" because there is no "NOT EXIST" reason. In this case,companies that do not calculate or cannot show this gaps, must have aspace to explain. (some of governance requeriment are not a "HAVE or
NOT HAVE" question, but they ask for numbers.)
Should include actual salary - USD conversion applied to highlight thesignificant disparage that is present across the globe with respect tosalaries within the same organisation.

University ofSouthern
Queensland

Australia

No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

No response

Page 72 of 100

201

1540-1547

202

1448-1565

This is disclosure 102-38 and 102-39 in the current standard. I neverquite understood what these ratios are telling readers, and how do these
relate to sustainable development or sustainability. I suggest to remove
these reporting points altogether, or else explain clearly why are these
metrics important in the context of sustainability.
These are high priority questions, especially GOV-13.

Simeon Cheng

Hong Kong

Business

As anindividual

Sustainability
Advantage

CanadaNo response

No response

7

Page 73 of 100

8

5. Responsible business conduct
No. Line
number(whereprovided)Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Disclosure RBC-1 Statement on sustainable development strategy
11566 ff.

2

1602

3

1587-1610

Our recent study on sustainability reporting of major German companies
found that some of the reporting organizations did not answer GRI 415
Public Policy 2016 and only half reported on lobbying (Management
approach disclosure 1.2.). Political contributions and lobbyism arefundamental issues for democracy, therefore we urge GRI to make these
topics a requirement by transfering them to GRI 102 as a new disclosurein section 5.
in challenging times such as these, in addition to global issues, our local
challenges may not allow for 3-5 years planning...

Transparency
International
Deutschlande.V.

Germany

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Bank Audi sal

LebanonNo response

No response

The element of local benefits is notably absent from this important topic.
For example, a mine or forestry operation could conduct itself ethicallyin every way possible, but choose to have all employees brought in fromother countries, and to purchase all of its goods and services fromsuppliers in other countries. Sustainable development inherently tends toentail local economic benefits (hiring and procurement for example), andcorporations who approach this topic without this understanding are
likely to face social and environmental challenges. It is difficult to imagine
any business where it would not be advantageous for all stakeholders ifthey were to prioritise local benefits. As such, a bullet could be added
here along the lines of "policies and procedures to contribute toEngineers
Without
Borders
CanadaNo response

No response

No response

Page 74 of 100

sustainable development in the areas closest to the organisation's
business activities".
41583 1610

5(15811586)

6

1598

7

1595

A synthetic statement of the CEO in support of the sustainable
development it is very important to include in the report but theguidance of the indicator RBC1 requires a lot of details already includedin the report and it doesn't make sense to repeat them in the CEO
statement. CEO should focus on the most important/material aspect of
the year.
Under 5. Responsible Business Conduct (1566-2017)
Ø Disclosure RBC-1 Statement on sustainable development strategy(1581-1586)• Add “…and human rights”. As per points above, effective reportingmust be more specific than board information on sustainable
development. The UN SDGs affirm that business respect for humanrights underpins their goals.
The use of words such as 'failures' has a negative connotation particularly
for businesses. Suggested wordings: areas for improvements? challenges,
obstacles? overdue?

Eni SpA

Italy

Business

On behalf ofanorganization,group orinstitution

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

IOSH would suggest that social trends should also be included, so that
this reads as follows: "Broader trends (e.g. macroeconomic, social orpolitical) affecting the organization's strategy for contributing tosustainable development". This is because developments in human capitalmanagement; safety, health and wellbeing at work; and demographics arealso vital considerations.

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution

Disclosure RBC-2 Policy commitments

Page 75 of 100

8

1612

(1) Disclosure of specific targets is also required- Adding disclosure of policy commitments to internationally recognised
instruments and to respect human rights is relevant.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

9

1612

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

10

1614

(2) - Even with this specification however, the reporting may still remainvague.
- We propose that the organisation also disclose the specific targets andmilestones and contribution to the SDGs that relate to their policy
commitments for responsible business conduct and to respect humanrights.
Organisations are required to provide their KPIs and targets for material
topics and the same approach should be adopted here.
We ask GRI to define “policy commitments.” Does a company need todescribe all policy commitments, or those for all material topics? Does
the company’s code of conduct count as a policy commitment?

ERM

United States Consultant

11

1615

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

12

1617

The policy should take into account national and 'internationally'recognised instruments. The significance of national frames tosustainability is equally important and probably more relevant thanmerely following international instruments. This could lead to better
contextualisation of sustainability reports.
Part of the precautionary principle ‘requirement’ has been changed to‘recommendation’, albeit quite a small change: 'how the organization
applies the Precautionary Principle or approach'. What is still a‘requirement’ under RBC-2 is: ‘describe its policy commitments forresponsible business conduct, including: (iii) whether the commitments
stipulate applying the precautionary principle.

ICMM

UnitedKingdom

Trade orindustry
association

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

On behalf ofanorganization,group orinstitution
As anindividual

On behalf ofanorganization,group orinstitution

Due to the risk of misinterpretation, further clarification is suggested.

Page 76 of 100

13

1623

14

1611 1787

15

1611
onwards

161611
onwards

171611-1618"provide links to the policy commitments if publicly available, or, if thepolicy commitments are not publicly available, explain the reason for this"Don't think it is necessary to explain why certain policies are not publicly
available. Some policies are for internal audience, i.e. staff and uploaded
to staff intranet.
We suggest to merge RBC 2&3 and keep the disclosure to a more highlevel about policies and the related organizational and management
systems.
Moreover, current amount information is excessive for a sustainability
report, especially if it is mandatory by law and included into an Annual
Report.
Finally, many companies already issue ad-hoc reports on such topics
where they include most of this information requested.
(1) While we agree with the requirements on disclosures of policy
commitments, on human rights, we also believe GRI should go further
and explicitly reference climate policies, including commitments that are
made in line with the Paris agreement.
We are concerned that the omission of climate mitigation could sendreporters the wrong message about responsible business conduct. We
believe climate commitments and targets, including (potentially) sciencebased targets should be included in the scope of responsible business.
(2) We also note that the reference in line 1655 to the UN declaration
on environment in connection with health and the environment does notinclude an explicit linkage to the Paris agreement.

City
Developments
LimitedSingapore

Business

Eni SpA

Italy

Business

Deloitte

United States Consultant

On behalf ofanorganization,group orinstitution

Deloitte

United States Consultant

Anti-corruption should be one of the topics that is explicitly listed here
as one of the policy commitments that should be described. Corruption
is an issue of responsible business conduct that affects all others, and is arisk in literally every country in the world.

Engineers
Without
Borders
CanadaOn behalf ofanorganization,group orinstitution
No response

No response

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 77 of 100

181611-1635) Ø Disclosure RBC-2 Policy commitments (1611-1635)• Can add: how external inputs are reflected in the policy• Under (f) detail indigenous peoples and local communities and the needfor this to be available in a language understandable to them

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

19

1612-1632

RHB Bank
BerhadMalaysia

Business

20

1614-8Netherlands

Assurance
provider21

1614-8(2) RBC 2 & 3 are quite extensive in their requirements. The objective isgood but could be a high burden for companies that already have theirpolicies described on reference sites.

Netherlands

Assurance
provider221617 1664

Lines 1617, and 1654 – 1664 (p. 60 – 61): Precautionary principle. GRI
should require some reporting on how the organization considers anduses the precautionary principle, and where there have been incidents or
impacts from its incomplete or ineffective implementation. The Universal
Standards should add guidance on the precautionary principle. The
precautionary principle is a foundation of environmental laws, regulations,and treaties. The Montreal Protocol is a classic example of this; theworld didn’t wait until the ozone layer was destroyed to change practices
via law, regulation and other practices to prevent the adverse impact. It
is positive that the Standards mention the precautionary principle.

ERM
Certification
andVerification
Services (ERM
CVS)
ERM
Certification
andVerification
Services (ERM
CVS)
DouglasHilemanConsulting
LLC

Human rights is very wide – from right to live to freedom of speech. A
policy commitment potentially may be a very high expectation. Propose,to loosen to include policy commitment, position statement, guideline or
any along these lines as well to take into account companies who areembarking on this journey as well.
(1) Policy commitments – Requirement a. overlaps with that of theindividual topic disclosures for the material topics identified by theorganization. Requesting this two-fold, though in a slightly different
context seems unnecessary. This could be specifically about human rights
only.

United States Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual

Page 78 of 100

231706-1713

24

1710-1711;
1712-1713

Organizations commonly claim to adopt some type of precautionary
principle(s), either in general or for specific topics. Organizations may
disclose via several mechanisms, including Management Discussion andAnalysis of risk management in 10-K filings to the SEC, sustainability
reports, or other external reporting mechanisms. Organizations mayreport or disclose information (policies, procedures, assertions, or data)
pertaining to the precautionary principle that affect sustainability topics
directly. Organizations may have reported or disclosed on the
precautionary principle in prior reporting periods, and learn later thatthey were ineffective (or not precautionary at all). Workplace
occupational health and safety is a timely example. Workers havecontracted COVID-19 and become seriously ill (or died) in many
workplaces – including in some organizations that have previously
reported positive information about occupational health and safety.
Further, their customers may issue glowing reports of their practices on
the topic relative to their supply chain. A fundamental premise ofsustainability reporting is transparency on organizations’ role inenvironmental and social/ personal/ human rights issues – including
prevention of irreparable harm. What may not be material as aggregatedacross a large organization may be very material in a localized operation.
Five deaths from 10,000 employees can be statistically small; if they are allat one location with 100 employees, it indicates incomplete or ineffective
implementation of the precautionary principle for a critical issue.
We recommend changing “can” to “shall” or “should” to requirecompanies—at least in certain industries—to describe procurement orinvestment policies and practices
The guidance should require such disclosures, as evedience is pointing to
the marginalisation of non-English speaking communities.

ERM

United States Consultant

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

On behalf ofanorganization,group orinstitution
As anindividual

Page 79 of 100

25

1612

(1) Disclosure of specific targets is also required- Adding disclosure of policy commitments to internationally recognised
instruments and to respect human rights is relevant.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Charteredbody for OSH
Professionals

On behalf ofanorganization,group orinstitution
As anindividual

Disclosure RBC-3 Embedding the policy commitments throughout the organization
26

1761

27

1758 1759

IOSH suggests that reference is made to other international standards
covering responsible procurement, such as ISO 45001:2018 Occupational
health and safety management systems – Requirements with guidance foruse (Clause 8.1.4) and ISO 20400:2017 Sustainable procurement –Guidance.
Disclosure RBC-3 Embedding Policy Commitments throughout
organization. GRI should state that audit activities – both (3LOD)
Internal Audit (reporting to HGB) and (2LOD – environmental, health &safety, supply chain, etc.) topical audit activities can be useful inmonitoring compliance with commitments across its activities andbusiness relationships. If these functions are used, organizations areencouraged to describe them in their sustainability reports. Guidancesays the organization can describe … the systems it uses for monitoring
compliance with commitments across its activities and business
relationships. Organizations commonly implement systems and controls
for internal management reporting. It is also common practice fororganizations to have an Internal Audit function – a “third line ofdefense” activity authorized by, and reporting to, the HGB. Internal
Audit monitors risks of all types across the enterprise and performs
audits (assurance and advisory engagements) to documented criteria.
Organizations also have “second line of defense” audit activities forhigher-risk areas, such as IT, environmental, health and safety, and supply
chain. These 2LOD audit functions can be useful in monitoring

Institution of
Occupational
Safety and
Health (IOSH)

UnitedKingdom

DouglasHilemanConsulting
LLC

United States Consultant

Page 80 of 100

28

1758-1759

compliance, performance, and progress on sustainability topics andreports. Even though many 2LOD audit functions have corecompetencies that would be useful for sustainability reporting – andwould provide value to stakeholders relying upon it – it is not common
for them to have sustainability reporting in their charter or scope.
Disclosure RBC-3 Embedding Policy Commitments throughout
organization. Guidance says the organization can describe … thesystems it uses for monitoring compliance with commitments across its
activities and business relationships. Organizations commonly implement
systems and controls for internal management reporting. It is also
common practice for organizations to have an internal audit function – a“third line role” activity authorized by, and reporting to, the Highest
Governing Body (HGB). Internal audit monitors risks of all types acrossthe enterprise and performs audits (assurance and advisory engagements)
to documented criteria. The IIA recommends the GRI should edit line
1759 to add at the end: including the existence of an internal audit
function reporting to the HGB.
If this function is used, organizations are encouraged to describe it intheir sustainability reports.

The Instituteof Internal
Auditors

United States Standard
setterOn behalf ofanorganization,group orinstitution

Disclosure RBC-4 Grievance mechanisms and other remediation processes
29

1723

The relevance of this disclosure could be reduced as the reporter is
asked to include the 'significant' aspects of the organisation in the scopeof the report. How does the less significant parts of the organisation thathave significant human rights impacts come to be reported on? Should
this require not just those areas of the organisation that it considers
most significant but also those where the risks are highest of impacts on
people?

KPMG

Australia

Consultant

On behalf ofanorganization,group orinstitution

Page 81 of 100

30

1793

31

(1957 –
1970)

32

1788-1909

In addition to the negative impacts the organization has caused orcontributed to, the disclosure should also reflect that it is expected thatcompanies provide remedy for negative impacts it is linked to. This link
could be through its own operations, products or services or business
relationships.
(1) Ø Disclosure RBC-4 Grievance mechanisms and other remediation
processes (1788-1805)• Require that companies report on how they define “caused”,“contributed” and “linked”

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

To the Global Sustainability Standards Board:

AccountabilityCounselUnited States Nongovernmentorganization

As a legal non-profit organization that advocates for direct lines ofcommunication between investors and the communities affected byinvestments, Accountability Counsel submits this comment on the draft
Global Reporting Initiative Universal Standards. We write to encourage
greater specificity on the fourth disclosure requirement for responsible
business conduct (RBC-4), “Grievance Mechanisms and Other
Remediation Processes.”

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Preliminarily, we commend Global Reporting Initiative for recognizing in
the guidance for RBC-4 that effective grievance mechanisms are anecessary feature of responsible business conduct under the UN Guiding
Principles on Business and Human Rights (UNGPs) and the OECD
Guidelines for Multinational Enterprises. Effective grievance mechanisms
are crucial to understand whether investments and organizational
activities do not impinge upon human rights or contravene the social andenvironmental policies of businesses to the detriment of communities.
There is no better way for organizations to know the impacts of theirprojects than to hear from the individuals and communities most affectedby them.

Page 82 of 100

Reading RBC-4, we agree that organizations should describe theircommitments to remedying adverse impacts caused or contributed to by
their operations. We further agree that organizations should disclose
their respective approaches to identifying and addressing grievances, aswell as stakeholder engagement in the design and operation of grievancemechanisms.
The fourth requirement under RBC-4 (RBC-4-d), however, can benefit
from greater specificity and guidance with respect to reporting on theeffectiveness of grievance mechanisms. The requirement asks
organizations that have grievance mechanisms to “describe how [they]
track[] the effectiveness of the grievance mechanism and otherremediation processes and provide examples of their effectiveness,
including stakeholder feedback.”
While the guidance mentions the eight principles that underpin theeffectiveness of a grievance mechanism, as articulated by Principle 31 of
the UNGPs, it can be improved by more clearly tracking the principles tospecific disclosures meant to demonstrate and assure effectiveness.
Moreover, the framing of the guidance reads as if effectiveness can beshown by demonstrating adherence to any one of the principles as
opposed to demonstrating adherence to each and every principle. This
would be a mistake; to truly demonstrate effectiveness, each principle
must be abided.
Further, the guidance softly recommends that “contextual information
should be provided to aid in understanding and interpreting . . .
quantitative information” related to the effectiveness criteria. We agree.
We therefore recommend the following changes.
CURRENT LANGUAGE [lines 1884-1900]

Page 83 of 100

“Guidance to RBC-4-d
According to UN Guiding Principle 31, effective grievance mechanisms
are legitimate, accessible, predictable, equitable, transparent, rightscompatible, and a source of continuous learning. In addition to thesecriteria, effective operational-level grievance mechanisms are also basedon engagement and dialogue. It is acknowledged that it can be moredifficult for the organization to assess the effectiveness of grievancemechanisms that it participates in compared to those it has establisheditself.
The organization can report:• whether and how the intended users are informed about the grievancemechanisms and remediation processes and trained on how to use them;• the accessibility of the mechanisms and processes, such as the total
number of hours per day or days per week that they are available andtheir availability in different languages;• how the organization seeks to ensure that users are treated withrespect and protected against reprisals (i.e., non-retaliation for raisingcomplaints or concerns);• how satisfied users are with the mechanisms and processes or the
resulting outcomes, and how the organization assesses users’ satisfaction;• the number and types of grievances filed during the reporting period,
and the percentage of grievances that were addressed and resolved,
including the percentage that were resolved through remediation;

Page 84 of 100

• the number of grievances filed during the reporting period that are
repeated or recurring;• changes made to the mechanisms and processes in response to lessons
learned about their effectiveness.”
Quantitative information, such as the number of grievances, is unlikely tobe sufficient on its own. For example, a low number of grievances could
indicate that few incidents have occurred, but it could equally signal thatthe mechanisms are not trusted by their intended users. For this reason,contextual information should be provided to aid in understanding andinterpreting the quantitative information.”
SUGGESTED LANGUAGE“According to UN Guiding Principle 31, effective grievance mechanisms
are legitimate, accessible, predictable, equitable, transparent, rightscompatible, and a source of continuous learning. In addition to thesecriteria, effective operational-level grievance mechanisms are also basedon engagement and dialogue. It is acknowledged that it can be moredifficult for the organization to assess the effectiveness of grievancemechanisms that it participates in compared to those it has establisheditself.
Using each of the eight effectiveness criteria outlined by UN Guiding
Principle 31, the organization shall report on the considerations it uses toassure the effectiveness of grievance mechanisms:• Legitimacyo Whether the organization has created an independent governancestructure, separate from day-to-day operations that may be the source ofgrievances, to ensure that the grievance mechanism is fair andPage 85 of 100

trustworthy.
o Whether the mechanism has sufficient authority to handle grievancesand make redress decisions objectively.
o Whether and how the intended users are informed about the grievancemechanisms and remediation processes and trained on how to use them;• Accessibility of the mechanisms and processeso The total number of hours per day or days per week that themechanism is available.
o Policies and practices for making the mechanism known to all
potentially affected people.
o Whether the mechanism provides adequate assistance to help
potentially affected people overcome barriers to accessing it, including
language, literacy, costs, physical location, and fears of reprisal.
• Predictabilityo Whether the mechanism’s policies and procedures are publicly
available and easily accessible.
o Whether the mechanism’s procedures are clearly articulated with
timeframes for each stage of the process.
o Whether the mechanism is equipped to monitor that the process andparties involved respect articulated timelines.
• Equitabilityo Whether the mechanism provides information on the process and therights of parties to consult with and be accompanied by counsel and/or
advisors at any time during the process.
o How satisfied users are with the mechanism and its processes or the
resulting outcomes, and how the organization assesses users’ satisfaction.
• Transparencyo Whether the mechanism maintains a publicly available case registry,

Page 86 of 100

including an online version, in addition to any other culturally appropriate
means of disseminating the information.
o The number and types of grievances filed during the reporting period,
and the percentage of grievances that were addressed and resolved,
including the percentage that were resolved through remediation;o The nature of complaints, the issues considered, and the generalgeographic locations of complaints during the reporting period.
o The number of grievances filed during the reporting period that are
repeated or recurring.
• Rights Compatibilityo Whether the mechanism protects the identity of any party thatrequests confidentialityo Whether the mechanism’s policies protect the rights of parties
afforded to them under national and international law.
o How the organization ensures that users are treated with respect andprotected against reprisals (i.e., non-retaliation for raising complaints orconcerns).
• Continuous Learningo What changes were made to the mechanisms and processes during thereporting period in response to lessons learned about their effectiveness.
o How the organization identifies and uses lessons from the grievanceprocess to instruct institutional improvements.
• Created and Evaluated through Dialogue and Engagemento Whether the organization held consultation about the design,
performance, and monitoring and evaluations of the mechanism.
Quantitative information, such as the number of grievances, is unlikely tobe sufficient on its own. For example, a low number of grievances could
indicate that few incidents have occurred, but it could equally signal that

Page 87 of 100

the mechanisms are not trusted by their intended users. For this reason,contextual information must be provided to aid in understanding andinterpreting the quantitative information.”
33

1792-1805;
1792-1793;
1873-1877(1) (a) Lines 1792-1805 – Other – The order of these requirements
should be reversed, so companies first cover the grievance mechanisms
in place to raise concerns, then the company describes how they
remediate grievances.

ERM

United States Consultant

34

1792-1805;
1792-1793;
1873-1877

ERM

United States Consultant

35

1792-1805;
1792-1793;
1873-1877(2) (b) Lines 1792-1793 – Feasibility – Rather than having the company
identify grievances, recommend having grievances be identified byanother entity (e.g., NOVs, fines). A company won’t identify grievances
because that might be to admit liability. If the requirement is to list actual
NOVs, fines, lawsuits, etc., and then describe what the company is doing
to remediate, U.S. companies would be more likely to include thisinformation.
(3) (c) Lines 1873-1877 – Clarity – We believe this is both too granularand vague. We ask GRI to clarify: How is a customer service desk not agrievance mechanism?

ERM

United States Consultant

36

1794-6(1) Grievance mechanisms - Are negative impacts strictly related to
Human rights or overall? Guidance to RBC-4 can be misleading. Believeenvironmental remediation a grievance mechanism, as it can have very
negative impacts on health of local communities if not resolved.
Furthermore, the fact that an issue has to be raised by a stakeholder inorder for it to be considered a negative impact and worth developing agrievance mechanism for, does not seem reasonable. Lastly, this iscurrently addressed individually in each topic disclosure (Management
Approach) and organizations already struggle to disclose this.
Remediation on negative impacts is discussed in MT-3 for each topic.
Clarity on how this is different would be helpful for users.

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 88 of 100

3718001805; 1879
-1909

We suggest not to require c) and d). We suggest to include them amongrecommendations.

Eni SpA

Italy

Business

38

1831-1871

Guidance with respect to the second requirement under RBC-4 (RBC-4b-i), which requires organizations to “describe the grievance mechanismsthat the organization has established or participates in,” states thatorganizations can do so by describing, among other things, “how themechanisms operate and who administers them (the organization and/or
another party).”

AccountabilityCounselUnited States Nongovernmentorganization

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

We agree that descriptions of grievance mechanisms are critical. Missing
from the list of ways that an organization can describe its grievancemechanisms is an express reference to governance. Features of good
governance, such as report lines that best promote an organizational
response to concerns relayed through grievance mechanisms, andpolicies that protect the independence of mechanisms, are criticallyimportant to the integrity of a grievance redress framework andachieving successful remedial outcomes. We therefore recommend that
guidance on RBC-4-b-i expressly reference the need to report on
governance, by modifying bullet point two as follows:
CURRENT LANGUAGE [lines 1855-1856]
The organization can describe:[. . .]• how the mechanisms operate and who administers them (theorganization and/or another party);

Page 89 of 100

SUGGESTED LANGUAGE
The organization can describe:[. . .]• how the mechanisms are operated and governed, and who administers
them (the organization and/or another party);
Disclosure RBC-5 Mechanisms for seeking advice and raising concerns
39

1937

The guidance to RBC-5-a should include that the organization should also
report on how the board oversees the mechanisms and addresses theireffectiveness, and whether these mechanisms are audited by internal
or/and external parties.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association40

1910-1956

Since this covers ethics hotlines, which are more common than otherstakeholder grievance mechanisms, we recommend placing RBC-5 before
RBC-4. That would also be a logical follow-up to RBC-3, embedding
policy commitments.

ERM

United States Consultant

41

1915-1917(2) 1917 - in my view, the item is missing on how and where report themain matters of the raised concerns

Sulema Pioli

BrazilConsultant

42

1915-7

Mechanisms for advice and concerns about ethics - Perhaps a need forfurther requirements in the ethical communications side to evaluate
effectiveness of RBC measures?

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
As anindividual
On behalf ofanorganization,group orinstitution

Page 90 of 100

Disclosure RBC-6 Compliance with laws and regulations
43

1958

44

(1957 –
1970)

45

1957 2006

Report all instances of non-complianceTransparency about an organisation's non-compliance with laws or
regulations is very important. To require only significant fines to bereported undermines the value of this disclosure. In particular, thesignificance of a fine may be influenced by the size of the organisation
leading to larger organisations not disclosing fines disclosed by smallerorganisations. For example, disclosure of circumstances where anorganisation has repeated small fines.
(2) Ø Disclosure RBC-6 Compliance with laws and regulations (1957 –1970)• Add (c) report on supplier non-compliance to laws and regulations
Lines 1957 – 2006 (p. 69 – 70) Disclosure RBC-6 Compliance with Laws
and Regulations: The Standards require organizations to report various
aspects of non-compliance with laws or regulations for which fines or
non-monetary sanctions were incurred during the reporting period. GRI
should re-orient Disclosure RBC-6 towards a more holistic, balanced
description of the organization’s compliance program. This can include
any or all of: description of the compliance organization (organization,
structure, reporting relationships, resources); how sustainability/ ESG
compliance issues are managed [the compliance piece is not explicitly
mentioned in Disclosure RBC-3 (Lines 1714 – 1787]; the sustainability/
ESG expertise used to adequately understand and achieve compliancerequirements; and monitoring efforts (including internal auditing – 2LOD
and/or 3LOD); and whether the monitoring efforts focus on processesor test compliance – or both. The scope of “compliance” as described

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

DouglasHilemanConsulting
LLC

United States Consultant

On behalf ofanorganization,group orinstitution
As anindividual

Page 91 of 100

here [it is not defined in the Glossary – see Line 2943] do not convey theextent of compliance requirements relevant to governance, theenvironment, or people/ human rights. This is a very limited view ofcompliance, providing an incomplete and often distorted view oforganization’s commitment to compliance. Moreover, the limited natureof this disclosure can have the unintended consequence of creating
incentives to fight compliance. The definition of “compliance” adopted bymany internationally-accepted frameworks for compliance management(such as ISO) include contractual requirements, industry standards (ULstandards for electrical safety, for example), and binding obligations.
Many of these are relevant for governance, the environment, and people/
human rights. The Standards should encourage reporting on compliancefor a complete range of topics, using a definition of “compliance” asadopted by the organization – with guidance suggesting that the definition
be included in the sustainability report. The payment of significant fines(or non-monetary sanctions) is not well-suited for the objective oftransparency in sustainability reporting. First, there is the matter oftimeframes and reporting periods. The time between identification of asituation, initiation and completion of enforcement activities, andincurring the penalty can span several reporting periods. Organizations
can expend substantial resources negotiating away fines and penalties –or get creative in fighting the underlying alleged non-compliance – on ascale that far outweighs the eventual penalty, but without reducing theadverse impact of the non-compliance (including on the environment,etc.). This creates an incentive to avoid perceived embarrassment ofreporting non-compliance, and diverts resources from corrective actions
and improved programs to prevent future harm and improve future
performance. Stakeholders seeking to evaluate companies’ commitment
to compliance need more – and more relevant – information than theamount of fines paid. They need information to assess the organization’scommitment to compliance, and commitment to correcting non-Page 92 of 100

compliance when it is detected. Fortunately, there are many standard
elements of compliance programs that are amenable to reporting.
46

1957 and
1964-5(1) Non-compliance with environmental laws and regulations – ERM CVS
agrees that RBC-6 should be reported by all. It would be good to include
a % recommendation or explain that significance can be monetary but
could also be very impactful and not have a huge fine or non-monetary
sanction, like a spill. Is this considered in this definition?

ERM
Certification
andVerification
Services (ERM
CVS)
ERM
Certification
andVerification
Services (ERM
CVS)
Eni SpA

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

47

1957 and
1964-5(2) Additionally, the requirement refers to “incurred in the period”. If theorganization has been fined but is recurring should this also be disclosed?
These definitions are very important for assurance.

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

48

1959 1970

Most of the details asked are already required in other mandatory
reports, there would be a proliferation of information.

Italy

Business(1) (a) We ask GRI to define “significant” for comparability acrossreporting organizations.

ERM

United States Consultant(2) (b) We ask GRI to define “incurred” so that companies knowwhether they should include fines levied during the year or paid during
the year.

ERM

United States Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution49

1960-196150

1960-1961

Page 93 of 100

51

1966 and1968 1970

52

1966 and1968 1970(1) The nature of each instance may be subject to legal privilege in someterritories and not available for reporting. It is suggested that thisrequirement is changed to require an explanation where the nature of an
instance cannot be disclosed. Alternatively, the ‘nature of an instance’
reporting requirement can be changed to ‘guidance’.
(2) Inclusion of specifications of what would be significant fines (Dow
Jones defines significant as amounts above US$ 10 million) is
recommended for inclusion in the form of ‘guidance’. We would suggest
breaking the question RBC-6-a-ii in a) 'total number of significant fines
issued to company' (see) and b) the amount of significant fines paid during
the cycle. This will differentiate between fines applied and payed.
Depending on the number of cases, it would be a challenge to describe
the nature of each instance of non-compliance for which a significant fineor non-monetary sanction was incurred. In this case, we suggest that thereporting be done along categories, e.g: implementation of binding
agreements made with regulatory authorities; penalties related to theenvironment or ecological issues; or tailings issues; penalties related toair emissions, among others.

ICMM

UnitedKingdom

Trade orindustry
association

ICMM

UnitedKingdom

Trade orindustry
association

Eni SpA

Italy

Business

ERM

United States Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure RBC-7 Membership associations
53

2009 201754

2007-2017

It's not possible to report the entire list of the membership associations
and the advocacy organizations in a non-financial report especially for big
corporation; it would be better to describe the approach through which
the corporation relates to these organizations and focus on themembership related to the most critical aspects for example for an Oil &Gas company the climate advocacy organizations.
(a) We believe this a strange placement of the disclosure relative toother RBC disclosures.
(b) If under Responsible Business, GRI should require organizations to
discuss how their policy positions align with those of the organizations

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,

Page 94 of 100

55

2010-2011

they belong to.
(b) If listing memberships where the company plays a significant role,
GRI should require the company to list the role it plays in thatorganization
Advocacy groups can push for their collective benefit even without avisible role of the reporting organisation. Reconsider ' 'a significant role'.

group orinstitution
Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

Page 95 of 100

9

6. Stakeholder engagement
No. Line
number(whereprovided)Comment

Name oforganization
or individualCountry

Stakeholder
group

Submission
type

Disclosure SE-1 Approach to stakeholder engagement
1

2022

2

2026

3

2050

4

2070

Increase the requirements for specific information about stakeholder
engagement- It is a valuable addition to require an organisation to provide details
about how it ensures meaningful engagement with stakeholders.
- Transparency about the way in which an organisation engages withstakeholders is a very important aspect of the organisation's approach tosustainable development topics.
- We recommend that an organisation be required to provide details
about the type and frequency of engagement with each category of
stakeholder rather than it forming part of the guidance.
Suggest to change the requirement to " whether the engagement
identified actual and potential negative impacts, or determined prevention
and mitigation responses to potential negative impacts." Reason beingorganisations tend to seek feedback that has positive impact to theorganisations themselves instead of on the society/environment.
(1) 2050: the frequency should be a compulsory information as constantengagement with stakeholders will determine how effective the company
is incorporating feedback.

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

Paia
Consulting

SingaporeConsultant

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

On behalf ofanorganization,group orinstitution
As anindividual(2) 2070: it should be a critical part of the planning of Stakeholder
Engagement as evidence on marginalisation exist.

Dr Aljiaohra
Altuwaijri

Saudi Arabia

Academic

As anindividual

Page 96 of 100

5

6

7

8

9

(20182139)

Under 6. Stakeholder Engagement (2018-2139)

Forest Peoples
Programme

UnitedKingdom

Nongovernmentorganization

On behalf ofanorganization,group orinstitution

SchweryCade

Switzerland

Consultant

If there is not indicated the specific need to interact with stakeholders
for reporting preparation, then the organizations can adjust any
information about interaction with stakeholders that is in no way related
to the assessment of the organization impact or reporting process. Thereis a lack of standardization of stakeholders’ engagement into the report
preparation. It could be right to recommend to have dialogues withstakeholders exactly about the report each year.
(1) We believe SE-1i should be reordered to align with the naturalprocess of stakeholder engagement: how they identify stakeholders, andthen the selected categories for engagement

Da-Strategy

RussianFederation

Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Deloitte

United States Consultant

2) In addition, we believe it would be beneficial for SE-1 to requireorganizations to report information on the outcome of the engagement
and what decisions were made or influenced as a result.

Deloitte

United States Consultant

This section needs revision on a number of fronts (many of which havebeen detailed already):- Inclusion of “rights-holder” terminology (not just stakeholders)- Definition of consultation and demonstrative understanding of thedifference between engagement and consultation- Need to add “Disclose SE-3” on Free, Prior and Informed Consent(FPIC) with guidance
Stakeholder engagement and results should be explicit. Reference toOECD DD process

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 97 of 100

10(7)• Section SE-I: Approach to engagement with stakeholders assumes
the organization engages with all stakeholders. This will create doubts on
disclosure for companies that have identified more stakeholders thanthey engage with at present. ERM CVS suggest separating therequirements to list and explain the process for identifying stakeholders,from the descriptions regarding forms and frequency of engagement, inorder to create further clarity.

ERM
Certification
andVerification
Services (ERM
CVS)

Netherlands

Assurance
providerOn behalf ofanorganization,group orinstitution

Australia

Labor
representative

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Disclosure SE-2 Collective bargaining agreements
11

2083

Relevant

AustralianCouncil ofTrade Unions

12

2083

Collective bargaining for me is not stakeholder engagement. It's humanresources practice. It should be part of the materiality assessment andpart of the employment disclosures. It doesn't fit here.

BeyondBusines Israel
s LtdConsultant

13

2084

Clear

Network for
Sustainable
FinancialMarkets CIC

UnitedKingdom

Nongovernmentorganization

14

2084

The requirements should also include:- a statement or policy commitment on freedom of association andcollective bargaining in direct operations,- how the company encourages freedom association among its workforce
and how it upholds these rights in countries where fundamental rights
are not guaranteed

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

Page 98 of 100

- how the company assesses the position of industry initiatives or bodies
toward freedom of association and collective bargaining when it
considers joining as a member
15

2086

The indicator of percentages of employees covered by collective
bargaining agreements should also include a comparison to the industry
average.

Principles for
Responsible
Investment

UnitedKingdom

Trade orindustry
association

16

2083-2091

IndustriALL
Global Union

Switzerland

Labor
representative

17

2083-2091

International
Trade Union
Confederation

Belgium

Labor
representative

On behalf ofanorganization,group orinstitution

18

2088-2090

This is a key disclosure and it is good to see its retention and modest
expansion in this Review of the Universal Standards. The right tocollectively bargain at work is a fundamental human right and, while theabsence of collective bargaining in a workplace does NOT of itself
establish any denial of that right, its significant presence in an organization
does demonstrate respect for that right.
This is a key disclosure and it is good to see its retention and modest
expansion in this Review of the Universal Standards. The right tocollectively bargain at work is a fundamental human right and, while theabsence of collective bargaining in a workplace does not of itself establish
any denial of that right, its significant presence in an organisation does
demonstrate respect for that right.
We suggest including an additional point (c) to explain, in those cases
where points (a) and (b) are not applicable, how the company determines
the working conditions of those employees.

PwC

UnitedKingdom

Assurance
provider192088-2091;
2110-2111

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution(1) (a) Lines 2088-2091 – Feasibility – This disclosure should be expanded ERM
so companies can explain why collective bargaining agreements are notneeded.

United States Consultant

On behalf ofanorganization,group orinstitution
On behalf ofanorganization,group orinstitution

Page 99 of 100

20

2088-2091;
2110-2111(2) (b) Lines 2110-2111 – Other – This falsely assumes collective
bargaining is always positive. In the U.S., many companies seek to avoid
collective bargaining agreements by providing positive working
environments and they believe this is better for the business over the
long-term.

ERM

United States Consultant

On behalf ofanorganization,group orinstitution

Page 100 of 100