Reporting Sustainability Dr Ruth Bender Intended learning outcomes By the end of the session and the related work students will: 1. Have an appreciation of the reasons why companies choose to report their progress on sustainability issues, and the key choices they have to make in such reporting. 2. Understand some of the main international frameworks used in sustainability reporting, including some of the detail behind the Global Reporting Initiative (GRI) and the work of the International Integrated Reporting Committee (IIRC) 3. Understand the practical difficulties companies face when adopting sustainability reporting. 4. Be familiar with the political arguments surrounding the ways in which companies make their sustainability reports. 2 Social and environmental reporting (SER) “SER is the predominantly voluntary, self-reporting of an organisation’s social and environmental interactions. Such reporting is increasingly undertaken in stand-alone reports – some in hard copy, many on the organisation’s website – and represents an organisation's understanding of what it is to be environmentally and/or socially responsible and (potentially at least) sustainable.” Social and Environmental Reporting and the Business Case. ACCA Research report #98, 2007 3 SER ≠ CSR Good How good are the company’s CR practices? Bad Bad Good How good is the company’s CR reporting? Source: Ruth Bender 4 For the rest of the session… Addressing the questions Standards and regulations What next? 5 Addressing the questions 6 Why How Who Sustainability reporting Where What When 7 Why? Issues surrounding voluntary disclosures (Is CR reporting still ‘voluntary’) Reason for reporting? 9 An institutional theory explanation We do things because other companies do them and they seem to work… Coercive isomorphism Results from pressures, formal and informal, exerted on organisations by other organisations on which they are dependent, and by cultural or regulatory expectations in society. Mimetic isomorphism Uncertainty is a powerful force that encourages imitation - when you don't know that to do, do what someone else is doing, apparently successfully. So organisations model themselves on other organisations. Normative isomorphism Stems from professionalism - the collective struggle of members of an occupation to define the conditions and methods of their work, and to establish a cognitive base and legitimation for their occupational autonomy. DiMaggio, P.J. and Powell, W.W. (1983) The Iron Cage Revisited: Institutional Isomorphism and Collective Rationality in Organizational Fields American Sociological Review … and doing these things legitimises the company and makes it easier to get resources 10 Costs of disclosure Information costs Costs of collection, processing, auditing and dissemination Litigation costs Costs associated with allegations of incomplete, inaccurate information Competitive disadvantage E.g. via disclosure of technological and managerial innovation strategies and tactics, and operational information 11 Some benefits of disclosure Legitimacy Compliance with perceived ‘best practice’ and improved transparency to improve trust and confidence in the organisation Branding & positioning Attract customers and employees through clear sustainability stance Operational improvements Changing the organisational culture to make people more aware of the strategy, and of ways to improve inputs, waste, emissions Risk management Allows a fuller view of the organisation and its environment (in the broadest sense), including strategic and internal threats Taken in part from IRC of South Africa Integrated Reporting Guide 12 Who? Who will be involved in production? Who will the report affect? Who, if anyone, will verify the data? Who is involved in preparation? $$££$$€ €££ Diversity environment Fairness 14 Who will the report affect? http://www.mystickfigurefamily.com/?gclid=CKTb8N6xyKwCFZQhtAodd0RBGA 15 Who, if anyone, should provide assurance? How? On what? 16 What? Carbon neutral Nuclear power Climate change Biodiversity Pollution Resource usage Environment Child labour Water Outsourcing Diversity Corruption Product Responsibility Transparency Health & Safety What? Human Rights Energy Work-life Community programmes balance Financials Responsible restructuring Communication Waste control Learning organization Workers’ rights Customers Stakeholders Philanthropy Animal testing Recycling Supply chain policies Equal opportunities 18 What does our report cover? ?Our whole organisation and supply chain ?Our whole organisation ?Divisions within the organisation ?Geographies within the organisation http://www.fine.com/blog/wp-content/uploads/images/erp-supply-chain-vancouver.jpg ?And what aspects of sustainability 19 How? When? Where? Some guiding principles? Sourced from: The Evolving Nature of Financial Reporting: Disclosure and Its Audit Implications. (2011) [Original source - IASB Conceptual Framework , Chapter 3 Qualitative characteristics of useful financial information. (2010)] 21 How do you report? http://blogs.law.harva rd.edu/corpgov/2011/ 04/26/what-boardmembers-shouldknow-aboutcommunicatingcorporate-socialresponsibility/ Based on a Conference Board Director Note by Du, Bhattacharya & Sen 22 23 24 25 Seeing through the greenwash… Extract from review by Elaine Cohen [Beyond Business] http://www.corporateregister.com/reviews/item/?n=74 26 In summary… http://www.domini.com/common/pdf/howtoreadsocialreport.pdf In general, good reports: “Go beyond documenting community relations activities Provide details on both policies and actual practices Report data that is company-wide and systematic, accompanied by illustrative anecdotes Set goals for future social and environmental performance Confront failures as well as promote successes Address the most difficult issues a company faces, particularly those relating to business models Integrate CSR reporting with financial reporting and analyze the materiality of CSR issues to daily operations Readers will find a CSR report credible when it discusses thoroughly and honestly those issues that most deeply impact a company’s business model and its implications for a just society and sustainable environment today and tomorrow” 27 Standards and regulations 28 Laws Standards 29 UK, Companies Act 2006, s.417 30 Coming soon… Companies Act 2006 (Strategic Report and Directors' Report) Regulations 2013 Quoted companies will be required to disclose, in a standalone strategic report, a description of the company's business model and strategy; the gender split, in number, for its directors, managers and employees; a consideration of human rights issues, alongside social and community issues Legislation expected October 2013 31 Coming soon… “All businesses listed on the Main Market of the London Stock Exchange will have to report their levels of greenhouse gas emissions from the start of the next financial year under plans announced by the Deputy Prime Minister at the Rio+ 20 Summit today. The UK is the first country to make it compulsory for companies to include emissions data for their entire organisation in their annual reports. The introduction of the reports, following consultations with leading businesses, will enable investors to see which companies are effectively managing the hidden long-term costs of greenhouse gas emissions. The majority of businesses responding to the consultation support the change and government plans are also backed by leading employer and environmental organisations including the CBI and the Aldersgate Group. The new regulations will be introduced from April 2013. They will be reviewed in 2015, before ministers decide whether to extend the approach to all large companies from 2016.” DEFRA press release, June 2012 http://www.defra.gov.uk/news/2012/06/20/greenhouse-gas-reporting/ 32 Guidance on reporting (i) Greenhouse gas emissions, (ii) Transport emissions, (iii) other environmental impacts Separate guidance for small businesses https://www.gov.uk/measuring-and-reporting-environmental-impacts-guidance-for-businesses 33 Countries all have different regulations Danish Financial Statements Act Companies must either have to state that they don’t do CSR, or say what they are doing. Applies to largest companies in Denmark, since 2009. 34 Coming soon? Proposed EU Directive on non-financial reporting (April 2013) “Certain large companies to disclose a statement in their Annual Report including material information relating to at least environmental, social, and employee-related matters, respect of human rights, anti-corruption and bribery aspects. Within these areas, the statement will include (i) a description of its policies, (ii) results and (iii) risk-related aspects.” “Large listed companies to provide information on their diversity policy, including aspects concerning age, gender, geographical diversity, and educational and professional background.” http://ec.europa.eu/internal_market/accounting/docs/non-financial-reporting/com_2013_207_en.pdf 35 Laws Standards 36 Integrated Reporting Global Reporting Initiative 37 “<IR> is a process that results in communication, most visibly a periodic “integrated report”, about value creation over time. An integrated report is a concise communication about how an organization’s strategy, governance, performance and prospects lead to the creation of value over the short, medium and long term. An integrated report should be prepared in accordance with the International <IR> Framework. While the communications that result from <IR> will be of benefit to a range of stakeholders, they are principally aimed at providers of financial capital.” 38 39 Integrated Reporting in South Africa In 2010 IR was made mandatory for companies listed on the Johannesburg Stock Exchange The IR report should be independently assessed https://www.saica.co.za/Tech nicalInformation/Sustainability andIntegratedReporting/TheI ntegratedReportingCommitte eIRC/tabid/2371/language/en -ZA/Default.aspx http://www.sustainabilitysa .org/Default.aspx 40 41 Examples of Integrated reports… http://examples.theiirc.org/home 42 Why did the auditor cross the road? 43 Global Reporting Initiative (GRI) Started 1997/8 – first Guidelines issued in 2000 By 2010 about 2000 organisations registered as issuing under GRI Latest Guidelines (G3.1) issued March 2011 www.globalreporting.org G4 expected some time in 2013 (draft available) Current and past reports available via http://www.corporateregister.com/ 44 GRI reporting: Principles & Guidance Reporting Guidance helps decide what to report on, and interpret the Framework. Reporting Principles re Content: Materiality, Stakeholder inclusiveness, Sustainability context, Completeness, Reporting Principles re Quality: Balance, Comparability, Accuracy, Timeliness, Clarity, Reliability 45 G3.1: Standard Disclosures Strategy and Profile 1. Strategy and Analysis 2. Organizational Profile 3. Report Parameters 4. Governance, Commitments, and Engagement 5. Management Approach and Performance Indicators Economic 9 indicators Environmental 30 indicators Social: Labor Practices and Decent Work 14 indicators Human Rights 11 indicators Society 8 indicators Product Responsibility 9 indicators G4 is a lot more complex As well as the indicators there are disclosures in each category relating to management approach, goals and policies 46 External assurance is encouraged It’s external, done by demonstrably competent people who are independent, and state their relationship with the organisation It’s done systematically, evidence-based, and properly documented, to defined procedures It assesses the extent to which the organisation has applied the GRI Reporting Principles It results in an publicly-available opinion or conclusions The external assurance report assesses whether the report provides a reasonable and balanced presentation of performance, taking into consideration the veracity of data in the report as well as the overall selection of content. 47 BUT… “GRI’s vision is that reporting on economic, environmental, and social performance by all organizations is as routine and comparable as financial reporting.” “GRI’s main challenge is how to mainstream an international standard common practice. Not just developing sustainability practices, nor even developing sustainability reporting, but developing common practice.” “No harmonisation. Not even harmonising EU regulatory information requirements. Or the requirements of ratings agencies’ questionnaires.” Nelmara Arbex (GRI) JustMeans conference on integrated reporting, 2011 48 To summarise so far… External forces: Institutional theory - mimicry Regulatory – eg King III, UK Business Review UN-PRI Other Stakeholders Why produce sustainability accounts? Internal forces: Stakeholders – eg employees Need for management information, eg re Carbon Reduction initiative Institutional theory Stakeholder input Mimicry, regulation, consultants Content and format of sustainability accounts Cost-benefit analysis GRI, IIRC etc 49 What next? 50 World’s first environmental P&L account http://about.puma.com/ http://safe.puma.com/us/en/2011/05/puma-announces-results-of-unprecedented-environmental-profit-loss/ http://www.guardian.co.uk/sustainable-business/puma-completes-environmental-profit-and-loss?CMP=twt_gu 51 Some other resources on sustainability reporting • • • • • Large reports covering the whole field Best practice in sustainability reporting Standards and proposed standards Investors’ requirements and reports Other stuff 52 Large reports covering whole field This 334 page book gives a great view, from many different authors, of all aspects of integrated reporting. Published 2010, some aspects will be out of date. http://hbswk.hbs.edu/item/6532. html 142 page report issued June 2012, after Rio. Chapters written by different experts, covering all aspects of sustainability reporting Available via http://www.unep.fr/scp/publicatio ns/details.asp?id=WEB/0169/PA 3,400 companies representing the national leaders from 34 countries around the world, including the 250 largest global companies http://www.kpmg.com/Global/en/I ssuesAndInsights/ArticlesPublica tions/corporateresponsibility/Pages/2011survey.aspx 53 Large reports covering whole field “This report explores and documents the extent to which corporate ESG information tracked and managed internally by companies is consistent with analogous information sought by external parties, and in particular, by ESG investors and the research companies that serve them.” 79 pages. System to identify key KPIs by industry sector, with the goal of creating a regulatory regime with concise, comparable metrics… Applies this method to five sample industries to demonstrate how such a system might hypothetically be implemented within a US reporting context. http://hausercenter.org/iri/wpcontent/uploads/2010/05/IRI_Transparency-toPerformance.pdf http://www.irrcinstitute.org/projects.php?project=55 54 Examples of reports via… http://database.globalreporting.org/ http://www.corporateregister.com/ Search 47,458 reports across 9,898 companies “Winners will be announced Spring 2013” http://www.corporateregister.com/crra/ 55 Standards and proposed standards From the initial summary of responses to the G4 exposure draft https://www.globalreporting.org/resourcelibrary/G4-PCP1-Full-Report.pdf 56 Standards and proposed standards http://www.sasb.org/ “The Sustainability Accounting Standards Board™ (SASB™) is a registered 501(c)3 non-profit organization engaged in the development and dissemination of industry-specific sustainability accounting standards. SASB is establishing an understanding of material sustainability issues facing industries and creating sustainability accounting standards suitable for disclosure in standard filings such as the Form 10-K and 20-F. SASB addresses the unique needs of the U.S. market, establishing standards for integrated reporting that are concise, comparable within an industry, and relevant to all ~13,000 publicly listed companies in the U.S.” 57 The AA1000 series http://www.accountability21.net/ Principles-based standards that provide the basis for improving the sustainability performance of organisations in all sectors. Relates to processes rather than levels of performance AA1000 Framework Provides guidance to users on how to establish a systematic stakeholder engagement process that generates the indicators, targets, and reporting systems needed to ensure to ensure greater transparency, effective responsiveness to stakeholders and improved overall organisational performance. AA1000 Assurance standard Provides a methodology for assurance providers to evaluate and provide conclusions on: the nature and extent of adherence to the AA1000 AccountAbility Principles, and the quality of the information publicly disclosed on sustainability performance (1999) (AA1000AS - 2008) AA1000 Accountability principles standard Provides a better framework for an organisation to use in order to better identify, understand, prioritise and respond to its sustainability challenges (AA1000APS - 2008) AA1000 Stakeholder Engagement Standard (AA1000SES – Provides a framework to help organisations ensuring stakeholder engagement processes are robust and deliver results. 2011) 58 Investors’ requirements “This report from the Professional Accountants in Business Committee considers trends in investor demand for and use of environmental, social, and governance (ESG) information, and recommends how professional accountants can better support their organizations in responding to these demands, and ultimately improve the management and reporting of ESG performance.” http://www.ifac.org/publicationsresources/investor-demand-environmentalsocial-and-governance-disclosures http://www.ceres.org/resource s/reports/incr-listingstandards-draftingcommittee-consultationpaper-proposedsustainability-disclosurelisting-standard-for-globalstockexchanges/at_download/file “…legislative and regulatory, legal, reputational, and operational ESG risks and opportunities Shareholders will need to consider to fully understand the Companies in which they invest.” http://www.cfapubs.or g/doi/pdf/10.2469/ccb .v2008.n2.1 59 UN-PRI “The Principles for Responsible Investment aim to help integrate consideration of environmental, social and governance (ESG) issues by institutional investors into investment decisionmaking and ownership practices, and thereby improve long-term returns to beneficiaries.” The Principles (launched 2006) apply across the whole investment business and are not designed to be relevant only to SRI products Over 1,000 institutional signatories in 50 countries (2012) 60 ESG (environmental, social and corporate governance) 1. Incorporate ESG into investment decisions 2. Be active owners and incorporate ESG into ownership policies 3. Encourage ESG disclosure in investee companies 4. Promote these principles in the investment community 5. Work together to enhance our effectiveness in implementing these principles 6. Report our activities and progress in their implementation 61 3 We will seek appropriate disclosure on ESG issues by the entities in which we invest. Possible actions Ask for standardised reporting on ESG issues (using tools such as the Global Reporting Initiative) Ask for ESG issues to be integrated within annual financial reports Ask for information from companies regarding adoption of/adherence to relevant norms, standards, codes of conduct or international initiatives (such as the UN Global Compact) Support shareholder initiatives and resolutions promoting ESG disclosure 62 A great resource Elaine Cohen is a consultant and author on sustainability reporting. Her blog is http://www.csrreporting.blogspot.com/ Her own company’s awardwinning sustainability report http://www.byond.biz/en/sub_page.asp?sp=3 23&p=16 And she tweets a lot about CSR reporting at www.twitter.com/elainecohen Her tweets are downloadable as a complete eBook at http://www.byond.biz/en/news.asp 63 www.twitter.com Ruth999 (and see my CSR list) elainecohen GRI_Secretariat davidcoethica DoughtyCentre Justmeans theIIRC 64