Comments from ACCA to the Global Reporting Initiative, 19 March 2013.
ACCA welcomes the opportunity to respond to the GRI Focused Public Consultation on the Revised Proposal for 'In Accordance' Model in G4. Our response only addresses the particular areas of the consultation that are most relevant to ACCA.
In summary, ACCA believes that:
1. Do you agree that the proposed revised ‘in accordance’ model will assist beginners and experienced reporters alike to prepare sustainability reports focused on material Aspects? Please provide reasons for your answers.
ACCA welcomes GRI’s efforts to assist reporters to prepare sustainability reports that are more focussed on material aspects, but feel that significant clarification and guidance is needed if this is going to be achieved.
In the first instance, guidance on materiality needs to be improved, as the current guidance is not fit for purpose.
Also, the current terminology used by the guidance can lead to confusion. Specifically, the definitions of a company’s ‘aspects’, ‘impacts’ and ‘categories’ should be revised.
The current model does not make reference to the sector supplements, which are critical in the materiality analysis.
In order to help ensure that that the proposed revised ‘in accordance’ model assists reports to prepare more focussed reports, ACCA suggest that GRI conducts the following research:
2. Does the “core” model, in your view, contain the essential elements of a sustainability report?
No. The ‘core’ model is missing two fundamental elements: strategy and indicators. Both of these elements are crucial when looking to prepare a sustainability report, and should therefore be included within the “core” model.
3. Do you have any preferences about names to be assigned to the “core” and “comprehensive” models?
We do not support the use of the terms “core” and, to a lesser extent, “comprehensive”.
Alternatives to “core” could be “elementary” or “primary”, whilst “fundamental” or “advanced” could serve as good alternatives for “comprehensive”.