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Frequently asked questions about the G4 Exposure Draft and the second G4 Public Comment Period

Frequently asked questions about the G4 Exposure Draft and the second G4 Public Comment Period

1. What are the main differences between G3.1 (G3) and the G4 Exposure Draft?

Fundamental changes proposed were to:

Application Levels - 100 percent change. The new proposal is based on “in accordance” criteria. The A, B and C (and +) levels are not part of the G4 Exposure Draft. The core of the current proposal is that GRI reporters are required to: a. report on all general Disclosure Items; b. report on Management Approach and Indicators related to the Aspects selected as material aspects for the organization’s value chain.

Defining Report Content Protocol 25 percent change. As in G3.1 (G3), the proposal emphasizes the importance of the process to select material aspects to be reported on, by using the Reporting Principles. The new element here is the concept of identifying in which part of the organizations activitieschain that aspect is material”. So, in the G4 context, the disclosure on a material Aspect has to be linked to the part of organization’s activities chain (value chain) where the Aspect is material.

Disclosure for Management Approach - 100 percent change. In G3.1 (G3) the Disclosure on Management Approach (DMA) guidance had a variety of forms. In the G4 Exposure Draft there is one general format to disclose DMA information at any Category, Aspect or even Indicator level. The DMAs should be disclosed only for material Aspects/Indicators.

Supply Chain Disclosure 100 percent change. The current proposal includes a complete description of supply chain. There are new disclosure items (required type of information for all reporters) as well as Indicators (to be selected during the process to define report content).

Minor or technical editorial changes:

The Reporting Principles minor changes were made for clarity in the presentation of the text of all Principles or to align it with the proposals related to the Boundaries of the reported information.

Indicators and Indicator Protocols: Around 10 percent of the existing Indicators were considered DMA disclosures, so are now covered in the DMA guidance. All other existing Indicators and Protocols have been technically reviewed and editorial changes have been proposed. In the Indicator Protocols there is new separation between “Standard Disclosure” and “Guidance”.

2. Is there special guidance for SMEs or beginners in reporting? In the G4 Exposure

2. Is there special guidance for SMEs or beginners in reporting?

In the G4 Exposure Draft, the proposal for discussion is that the same “in accordance” criteria apply to all types of reporters. But this doesn’t mean that small and large companies will have to make similar efforts to prepare a GRI report. For instance, in the current proposal for discussion the “in accordance” criteria define that all Disclosure Items are to be reported by organizations. But many of these Disclosure Items are not applicable for SMEs. This and other features should also result in a much more simple description for SMEs than for larger organizations as, in general, SMEs operations are less complex.

There is also no lower limit for the number of material aspects that should be disclosed in a GRI report. If the process to select material topics is well described, a simple or small organization can focus its report on a limited number of Aspects, and this will probably be preferable for SMEs. In the G4 Exposure Draft says that extra guidance will be provided for beginners and SMEs with the final G4 Guidelines.

3. Is the content in the G4 Exposure Draft the content that GRI’s network and governance bodies are proposing to be adopted as the G4 Guidelines?

Not yet. The content presented as ‘G4 Exposure Draft” was created by the Working Groups and discussed by the Technical Advisory Committee as a proposal for discussion as defined by GRI’s Due Process. The content is proposed in order to collect feedback on specific and important parts of the GRI Reporting Guidelines. Negative and positive feedback will be collected and concrete proposals for change will be discussed by GRI’s governance bodies in the next round.

Based on the network’s proposals for improvement, GRI’s governance bodies will then prepare the final version to be proposed to be adopted as the G4 Guidelines.

4. Can GRI wait for the launch of Integrated Reporting Framework (IRF) and then launch G4 already linked to its final format?

The timeline for developing G4 was established three years ago. Behind it, there are not only the defined steps of the Due Process to be followed but also limited resources to be used for this project in this period.

Only the Board of Directors can decide to delay or change the agreed timeline.

5. Why was the proposal for the GRI Content Index not exposed for discussion?

This will appear in the final version only as it will have to reflect the final decision on Application Level/ In Accordance criteria. If the current proposal for In Accordance criteria is accepted, the Content Index

will ask organizations to prepare a table where all Disclosure Item locations are displayed, as

will ask organizations to prepare a table where all Disclosure Item locations are displayed, as well as a list of material aspects and related Indicators disclosed, with their locations. The GRI Content Index is always a direct expression of the Application Level or In Accordance criteria.

6. Why GRI has proposed to move from the current Application Levels to “in accordance” criteria?

There are two main reasons:

a) The negative feedback from the network: Over the last five years, GRI has received feedback from stakeholders that signal that the current system presents many problems, particularly related to the misuse of the Application Levels as a rating system of organizations’ performance. Other feedback included comments on the requirement for Level A reporters to display the decision on material/ non material to all indicators, and others are concerned because the (+) can express many different types of external verification, making comparison between the (+) marked reports impossible.

b) GRI’s Board of Directors is discussing the future of sustainability reporting, and the implications of a potential move for the GRI Guidelines to become standard-ready. Other international standards use ‘in accordance’ type models, and this would give GRI greater choice in the future.

With these reasons in consideration, and with the input of experts in the Application Level Working Group, the TAC developed the proposal, which tries to tackle these points in a technical way. Standards are generally defined by “in accordance” criteria.

As with all content in the G4 Exposure Draft, this is a proposal for discussion. An important question when defining the “in accordance” criteria is: what is the minimum disclosure acceptable for a report to be considered a GRI report? And how will the answer help GRI achieve its objectives of more reports and better reporting? The feedback submitted during the second Public Comment Period should help GRI re- design the current proposal in a direction that stakeholders consider best.

7. How will current and future sector reporting guidance be used with G4?

There are two main work streams related to this point.

The first one:

In the “in accordance” criteria presented for discussion in the G4 Exposure Draft, it is defined that an organization has to report on all disclosure items described in the relevant available sector guidance document in addition to the material Aspects, DMAs and Indicators identified by the organizations.

As in previous revisions, the ten existing Sector Supplements will be adjusted to match the structure and content of G4. A Technical Editing Task Force is working on technical improvements to the content for

example, making the text clearer, and separating ‘ guidance ’ from ‘ disclosure requirements ’.

example, making the text clearer, and separating guidancefrom disclosure requirements’. This exercise will improve the technical quality of existing Sector Supplements and will change the format but not the content.

When G4 is launched in May 2013, the existing Sector Supplements will also be re-launched in the new format. It is important to remember that the existing Sector Supplements and the G3.1(G3) Guidelines are likely to be valid for a transition period, which is yet to be defined.

The second one:

To build future sector guidance, GRI is carrying out a global study on material topics by sector/industry. This research project has two main objectives:

1. Make available for the public a list of already identified material topics to be used as a global

reference for disclosure on sustainability impacts by sector/industry

2. Prepare the basis for the next generation of GRI sector reporting guidance for a much wider range of


The advisory committee for this project includes SAM, S&P, Goldman Sachs, MSCI, Thompson Reuters, and other experts. Business associations, labor and civil society organizations, research and consulting institutions, financial market institutions and data users will all be invited to offer their input to this research. The results will be published in May 2013.

GRI’s sector guidance is likely to become more prescriptive in future, as already signaled by GRI’s Board of Directors and the results from the first PCP.

8. What does harmonizationmean?

GRI has committed to refer to internationally accepted complementary reporting/disclosure guidance documents in the Guidelines. This makes it easier for organizations and information users to understand how complementary guidance can be used together, helping them prepare reports in a shorter time. GRI’s TAC and Secretariat have defined a set of criteria to define if a document can be included as a reference in the G4 Guidelines.

References should be recent and useful documents that can assist organizations in either understanding more about the topics listed in the Guidelines, or help them to manage and report on topics.

GRI has defined criteria for assessing if a reference should be listed in its Guidelines:

• The organization provides publicly-available information about the development process of this reference

• The reference was developed using a collaborative, representative, robust, and transparent process; or developed

• The reference was developed using a collaborative, representative, robust, and transparent process; or developed in an inter-governmental setting

• The reference is generally applicable

• The reference is applicable to all organizations regardless of size or sector

• The reference is available in English

• The reference is available free of charge

• The reference is current and in use

References to documents must comply with these criteria to be considered for inclusion in the G4 Guidelines. GRI is still collecting proposals for references during the second G4 PCP.

Related to the harmonization effort, GRI has also developed linkage documents. These are documents that are of specific interested for different groups of reporters. The linkage documents offer guidance on how to use or refer to a specific document in the GRI reporting process. They can be for a local tool (such as Ethos Indicators, in Brazil) or for a specific topic (such as CDP disclosure guidance).

There is some previously identified internationally accepted complementary reporting/disclosure guidance, such as the UN Global Compact Principles and the OECD Guidelines. GRI also has an agreement of complementarity with ISO on the ISO 26000 guidelines on management for sustainable performance (which are not for reporting but can help organizations when designing management approach to sustainability related topics).

9. Will there be a transition period from G3.1 (G3) to G4?

This is a decision to be made by GRI’s Board of Directors at the end of the G4 approval process. Because organizations have to adjust processes and systems to the new reporting recommendations, a transition period is always discussed. A transition period of two years was approved for the transition from G3 to


10. Will GRI offer services to check the “in accordance” criteria?

It is too early to say. No decisions have been made on this yet.

11. How can the GRI Guidelines help to ensure better and more reports?

For GRI, good reports are those which offer material and useful information for report users and stakeholders; present a clear description of how material aspects were selected; and explain how the organization monitors its performance related to those material aspects. The content of the GRI Guidelines was created to support organizations to prepare such reports. This is the reason for the existence of the GRI Reporting Principles, Technical Protocol, Disclosure n Management Approach and Indicators (Protocols).

The G4 development process was designed to involve the sustainability reporting network in a global

The G4 development process was designed to involve the sustainability reporting network in a global debate on how to improve the current content of the Guidelines to help organizations further in this direction. We are not yet at the end of the designing process. The proposals presented in the G4 Exposure Draft were developed to promote this discussion. The second PCP and next round of decisions around the final format of G4 will reveal the conclusions of this global debate.

The G4 development process was also designed to involve the network in a discussion about how to support the scaling up trend of sustainability reporting, promoted by regulators, investors, rating agencies, auditors and other players. This trend means that more organizations around the world will have to start reporting their sustainability impacts, and the GRI Guidelines should help them in this phase, particularly understanding what a good report is, and also offering tools to help them get started.

Whether and how G4 will accommodate this need will also be defined in the next stages of development.

12. How will G4 relate to new topics on the sustainability agenda?

The G4 development process was designed to review the list of topics in the Guidelines and also to update current content. The G4 development has only started addressing this point so far. After the G4 launch GRI will announce how this work will be continued.

So far, GRI has included the following steps in the G4 Due Process:

a) In the first PCP, GRI invited individuals and organizations to suggest new topics for inclusion in the Guidelines as well as topics to be updated. Suggested topics were shortlisted and from a total of 17 topics analyzed

b) The Secretariat concluded that eight of them (eco-innovation, remuneration and performance based pay, plastics, packaging and waste, high impact event management and preparedness, supply chain sustainability management and performance, green building practices, community impacts and development and animal rights and welfare) are either sector-specific, or will be covered by current G4 related work being done by existing Working Groups.

c) The international level of agreement around reporting metrics on the other nine topics was investigated and, after consultation with GRI’s Technical Advisory Committee and Board of Directors, the Secretariat started to recruit new members for four Working Groups. The topics were: Anti-corruption, Biodiversity, Occupational Health and Safety and Greenhouse Gas (GHG) Emissions. Calls for nomination for these four Working Groups were open in May 2012.

d) Unfortunately the Secretariat was not able to form all four of them following the requirements of the GRI Due Process. The Anti-corruption and Greenhouse Gas (GHG) Emissions WGs were formed and their proposals approved by the TAC and presented in the topics PCP, as part of the second PCP.

e) The five other topics not yet covered by G4 work life cycle analysis (LCA), chemicals of concern, water, disabled persons’ rights and children’s rights – will continue to be investigated

in order to access the international knowledge and agreement on reporting metrics around them. The

in order to access the international knowledge and agreement on reporting metrics around them. The specific content development for reporting on these topics will be discussed by GRI governance bodies during 2012 and 2013. To this list GRI has now added Biodiversity, Occupational Health and Safety.

13. How will G4 help improve external verification practices?

It is an objective of G4 to improve the technical definitions in the Guidelines. By improving the clarity of definitions the external verification of reported information should become easier, as less space for interpretations is allowed.