Sustainability Reporting Guidelines 2002

How many years do you think is optimal for a revision cycle?

The revisions timeline is acceptable to move from two years to three, although it could be considered too slow for those (few) pioneer organisations who are highly advanced in reporting practices.

Please comment on the overall ordering of Parts A/B/C/D within the Guidelines. Is it logical?

If you answered "not logical" please indicate suggestions for improvements:

Overall, the ordering of Parts A/B/C/D is logical, although it should be noted that the illustration on p13 Box point 4 tends to suggest a A/C/B/D ordering (it advises on structure followed by principles).

Do you find "in accordance" reports better meet your needs?

Please explain your answer. Do you have specific comments on the conditions associated with "in accordance"?

It certainly makes sense to include this requirement into the Guidelines. The standardisation achieved by the 'in accordance' element facilitates comparability between and within sectors (but the reports still often lack depth in information).

How important is independent external assurance to the credibility of a report?

Please explain your answer, including your policy (reporter) or understanding (user) of report assurance?

Independent external assurance is crucial to the integrity of any report because it increases its credibility. Requiring and/or promoting standards for such assurance will help sustainability reports be valued and used with the seriousness and importance of financial reports.

Successful standardisation would satisfy those currently critical of unsatisfactory attestation.

To what extent did GRI address the most important reporting principles?

If you answered "low" or "very low", what important concept is not captured in the principles and needs to be elaborated either within existing principles or as a new principle:

Although adequate, it is felt that the concept of 'materiality' could be individually listed.

The GRI Guidelines incorporate the principles "completeness", "relevance", "inclusiveness" and "sustainability context" as principles to help ensure that reported information is material to the reporting organisation. To what extent does the combined application of these principles to Part C address the needs of defining what information is material to a report?

If you answered "low" or "very low", please explain:

The Guidelines need to discuss the issue of materiality directly instead of it remaining implicit in the principles. Materiality could be first addressed as a note early in the report e.g. at the end of the introduction followed by a second section on materiality when the principles are discussed. Other Guidance, such as AA1000AS, explicitly state the principle of materiality and it is being used by some companies as GRI does not, according to these companies, cover this adequately.

How well do the existing categories and aspects cover your information interests?

If any, please indicate what categories and aspects are unnecessary and please indicate which topics/issues are missing:

Reference to overarching topical issues such as climate change (maybe in the policy section?), are missing.

The performance indicators in the various categories differ. Some are more quantitative (esp. in the economic and the environmental categories), while others are more qualitative (mainly in the social categories). Please comment on this balance by selecting one answer per line:

Please explain your answers above:

Overall, the indicators are well balanced. ACCA recognises that social indicators are more qualitative in their nature and the economic/environmental indicators more quantitative in theirs (although this need not always be the case).

Design of indicators in general terms:

On a scale from 1 (absolutely unsatisfactory) to 10 (absolutely satisfactory), how would you rank the following criteria:

Do you want to add specific comments?

Do you want to add specific comments?

Do you want to add specific comments?

Do you want to add specific comments?

How do you perceive the balance between input-related indicators (focusing on actions) and output-related indicators (focusing on results)?

Please add any further comments on the further direction:

Assuming that the GRI retains its policy on using the Guidelines (recognizing incremental reporting and allowing "in accordance" reporters to omit and explain), do you think the number of indicators should:

If you think changes should occur, where should they occur:

The number of indicators in the 2002 Guidelines is considered appropriate for both the scope and complexity of subject. Any increase should be the increase in indicator quality - not quantity.

The Guidelines follow the triple bottom line approach as the most used way to commonly structure the thinking around the broad variety of issues within sustainability. One effect is a reduced ability to highlight linkages and the integrated nature of sustainable development topics. Do you think there are ways to overcome this and how should that be applied in the reporting framework?

ACCA supports the use of the triple bottom line approach. In these early days, there needs to be a period of experimentation as integrated reporting grows and evolves: we therefore encourage the Guidelines to remain as flexible as possible.

One way to report the integrated nature of sustainability is to include such integrated issues within the Policy section (NB. Investors will often look here for current development on key issues). Another way is to use the web, as reporting using this media type makes integration and linkages possible.

Other comments on Part C?

The annexes offers more supporting material. Please rank the quality and usefulness by using the table below.

Do you think that the annexes should remain in the Guidelines or should they be kept separately (e.g. on the website or in other forms)?

What additional annexes are needed in 2005?

None - although it may be necessary by 2005 to provide an overview about the GRI website and include a summary of the information that can be found on it, e.g. a list of GRI reporting organisations.

Other comments on Part D?

Is it possible to develop general guidance on disaggregation within the Guidelines or should this be dealt with primarily in the sector supplements on an industry-by-industry basis?

Sector supplements.

A regular debate is that aggregated information loses context and therefore parts of its meaning. GRI currently recommends disaggregation where feasible, of value and in consultation with others.

What do you think is a useful basis for disaggregation?

If you ticked "other", please specify. If you ticked geographic regions, please indicate ideal level of disaggregation (if possible).

There is no clear-cut answer to this. It really depends on each business and/or each sector. Some reporters may eventually wish to report on themes or impacts (in the future) such as climate change and water respectively.

Reporting should ideally be at the consolidated level, with segmental information (on geographic and business lines) being provided as supplemental information. To ease the report preparers task, GRIs segmental recommendations should be closely aligned with the segmental reporting approach required b y the International Accounting Standards Board. Different segment definitions will impose an extra cost on preparers and may hinder take up of the guidelines.

Another debate is around reporting boundaries. This refers to decisions about which entities should be included when measuring performance (e.g. joint ventures, subsidiaries, suppliers, etc.)

When reading reports written using the Guidelines, do you typically understand the reporting boundaries applied by the report preparer?

In general, most reporters do not clearly state their boundaries, although more have begun to do so recently. ACCA has been encouraging reporters to state their boundaries for many years now. We encourage GRI to take forward the work on boundaries previously carried out by Roger Adams and Robert Langford.

What is your most common use for reports? Please explain:

Practical teaching tool whether to business people or students. Trend spotting.

How useful are the GRI Guidelines for helping to organize your thinking about and assessment of sustainability reports?

Please explain:

The Guidelines are a helpful step by step guide.

How comparable are reports from your point of view? Please indicate the level of comparability to:

Reports written using the Guidelines:

Reports NOT written using the GRI Guidelines:

What changes to the GRI Framework could enhance comparability of reports:

Probably increased implementation and practice supplemented by an increased number of sector specific GRI supplements.

How do the following general aspects enhance your willingness to use GRI as your major assessment tool for the sustainability performance of a report preparer:

How could GRI make the GRI Framework more useful for your purposes (either through changes in the Guidelines/Supplements/Protocols or publication of additional supporting material)? Please explain:

Do you submit feedback to report preparers?

If yes, how? If no, why not?

ACCA is often invited to provide feedback and recommend changes in future reporting practice by companies. Meetings are usually face-to-face. ACCA is also starting to provide limited feedback to each reporting awards entrant, if requested.

What do you think GRI has to do to increase the use and acceptability in your constituency within the next three to five years?

This will differ depending on geographical location and stakeholder group, but in general things that could be done to improve its use and acceptability could be: obtaining governmental backing, more media coverage, achieve higher public profile, link to other initiatives more clearly, communicate better (although GRI have begun to do this with their monthly newsletter and re-design of the website).

Priority improvements: Drawing from all comments you have provided, what in your view are the three most important changes GRI should consider in revising the 2002 Guidelines?