With the recent publication of the much-anticipated “Report on US Sustainable, Responsible and Impact Investing Trends 2018” issued by US SIF showing that ESG has hit the capital markets’ mainstream, with $1-in-$4 in the US (by professional investment managers now incorporating ESG), and the recent petition seeking mandatory ESG reporting submitted to the Securities & Exchange Commission by institutional investors, the need to develop a standardized framework for Corporate ESG Reporting is more pressing than ever before.
A recent discussion paper — “Investor Agenda For Corporate ESG Reporting” — with inputs from the CFA Institute, ICGN, PRI, CERES, GSIA, GIIN, and the UNEP-FI — further highlights this.
Among other things, the discussion paper emphasizes the need for participants of the Corporate Reporting Dialogue (participants include reporting standard setters – GRI, SASB, CDP, IIRC,CDSB, ISO, FASB, and IFRS) to deliver on their promise to work together to develop a more unified agenda on ESG reporting.
As part of our company’s role as the GRI Data Partner in the USA, UK and Republic of Ireland, G&A Institute’s Sustainability Report Analyst-Interns analyze thousands of sustainability reports each year to help contribute the information to the GRI’s Sustainability Disclosure Database. This is the largest publicly-accessible sustainability disclosure database in the world (with now over 50,000 sustainability reports included, dating back to the start of the GRI).
Many of the corporate reports the G&A analysts processed have been using the GRI Standards — and a number have now started to implement aspects of the SASB Standards in their disclosure and reporting process, depending on their industry categories.
G&A’s Sustainability Report Analyst-Interns recently have been comparing the two standards for disclosure in specific industries of interest to them as they carefully examine the two standards’ alignment, similarities and differences.
In this series G&A’s Sustainability Report Analyst-Interns share their perspectives.
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We begin our series of shared perspectives with the perspectives of Minalee Busi, looking at the Software and IT Services Industry.
Comments by Minalee Busi – G&A Sustainability Report Analyst-Intern
While discussion regarding sustainability reporting is usually more focused in context of resource intensive industries, the Software and IT Services sector is often left out.
With sustainability being a major factor in competitive advantage and investor decision-making, Software and IT Services companies need to re-think their sustainability reporting strategies, if they are not already at that point.
SASB identifies a limited number of material issues for the industry for corporate reporting, such as:
• environmental footprint of hardware infrastructure,
• data privacy and freedom of expression,
• data security,
• recruiting and managing a diverse skilled workforce, and
• managing systematic risks from technology disruptions.
The disclosure suggestions set forth by both the SASB and GRI Standards are in fact quite comparable today, and in alignment with each other for some topics.
For example, in terms of energy consumption, both standards suggest companies to report on the energy consumed (both renewable and non-renewable) — but with different reporting boundaries.
SASB suggests reporting consumption within the organization — and the GRI Standards ask to additionally include consumption outside of the company.
However, GRI also includes disclosures in terms of energy reduction due to conservation and efficiency initiatives — which SASB disclosures do not include suggest. These are some of the differences we have observed.
Similarly, though both the disclosure frameworks require information about water withdrawal and consumption, GRI also expects detailed reporting on water discharge into different water bodies, with information such as whether water was treated before discharge and whether they follow international standards on discharge limits.
Another GRI Standards environmental disclosure is related to recycling — which although not very comprehensive, is completely non-existent in SASB disclosures.
Given the increasing e-waste generated by the IT industry, both GRI and SASB could consider including more detailed disclosures in this area for addressing material risks companies face.
Addressing Data Security/Privacy
In terms of data security, both standards include suggestions of disclosures related to data breaches and the number of users affected. But since SASB disclosures are designed to be industry-specific standards, more detailed reporting requirements in terms of data privacy and freedom of speech are found in SASB — including information on secondary usage of user data and monetary losses as a result of legal proceedings associated with user privacy.
Other such additional detailed areas of sector-/industry-specific disclosures by SASB which are not specified in the GRI standards are topics under managing systematic risks — such as performance issues, downtime and service disruptions due to technological impediments; and, activity metrics related to data storage, processing capacity and cloud-computing.
Further, disclosures with respect to monetary losses due to legal proceedings around intellectual property protection and competitive behaviour can be found in the SASB Standards — which can loosely be aligned with the GRI disclosures under non-compliance with laws in the socio-economic arena.
With respect to the “S” (social domain) of corporate ESG reporting, both of the standards suggest reporting on employee diversity, with GRI focusing on categories such as age, gender and minority representation and SASB additionally suggesting reporting on data related to the percentage of employees that are (1) foreign nationals and (2) located offshore.
Interestingly, although SASB disclosures are industry specific standards and the IT industry is in the main dependent on human and intellectual capital, there is no specific suggestion of reporting on training and education of employees.
GRI Standards appear to be filling this gap with suggestions of detailed disclosures on average training hours, upskilling and transition assistance programs and information related to employee performance reviews.
Sustainability Reporting Criteria
The GRI Standards have extensive sustainability reporting criteria, of which a major portion of the disclosures fall under the “General Disclosures” — which include materiality, measurement approaches, consistency and comparability of reporting, external assurance, supply chain, sustainability strategies, ethics and integrity. This to me is seemingly more transparent as compared to the SASB Standards.
Another such area is stakeholder engagement, which exists in the SASB Standards only in the form of percentage of employee engagement.
The category of Discussion and Analysis under SASB Standards does require reporting on strategic planning about each of the material topics identified, which can be mapped to the Management Approach (DMA) disclosures recommended under each material Topic-specific disclosure area of the GRI Standards.
Alignment – and Gaps
With the above overview, the SASB disclosures and GRI Standards can be seen in alignment with respect to some material topics while having some gaps in others.
However, since both the standards are developed to address the needs different stakeholders – with GRI aiming a broader set of stakeholders and the SASB majorly targeting mainstream U.S. investors — they should not be seen by report preparers as being in competition with each other.
I believe that the efforts of the CDP and important sustainability reporting standards-setters such as GRI and SASB will certainly be welcomed by companies and other stakeholders now struggling to keep up, but the question remains if such collaborations can ultimately lead to the desired standardised sustainability reporting framework that many investors actively seek.
First in a Series
The Software / IT Services Industry
GRI and SASB Standards In Focus – Perspectives on Alignments and Differences
Introduction: GRI and SASB In Focus – Perspectives on Alignments and Differences
by Minalee Busi – Analyst-Intern, G&A Institute
The full and original article can be viewed on Governence and Accountability Institute (GA-Institute.com)
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