Draft Linkage Document

Using the Global Reporting Initiative (GRI) Sustainability Reporting

Guidelines with the ISO 26000 ‘Guidance on Social Responsibility’ Standard

ISO and Reporting

ISO’s first ever Guidance Standard on Social Responsibility – ISO 26000 – is on track for
public launch in 2010. While, as its Annex shows, ISO 26000 is not the first or only
international instrument to provide guidance on the social responsibilities of business
and other organizations, it represents an important new level of international
attention to the issue.

In considering how to use the new Standard, readers will probably have many
questions. Among them; How can I communicate my use of the standard to my
stakeholders? What should I communicate? How can I optimize the value of my
reporting?

As the Standard recognizes (see below), part of being socially responsible involves
reporting on social responsibility performance to stakeholders, whether these are
internal parties (e.g. employees) or external (e.g. local communities, investors,
regulators, customers).

‘An organization should … report about its performance on social responsibility to

affected stakeholders. A growing number of organizations report to their
stakeholders on a periodic basis about their performance on social responsibility.’

ISO 26000 Committee Draft (CD), Communication on social responsibility, Box 14

Led by the corporate sector, an increasing number of organizations are issuing

‘sustainability’ or ‘corporate social responsibility’ reports in addition to-- or as part of-
- their annual financial reports. A 2008 survey by the company KPMG found that 80%
of the Fortune Global 250 companies now issue a separate report on non-financial
aspects of their performance. CorporateRegister.Com, a UK company which specializes
in tracking such reports, has a data base of over twenty thousand CSR reports across
more than five thousand companies. Some countries, including Denmark and Sweden,
have even mandated CSR reporting in some respect.

The main reasons leading companies are communicating their social responsibility
performance are identified in the ISO Standard. They include:

1. Demonstrating accountability and transparency (openness)

2. Addressing legal and other requirements

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 3. Showing how the organization is meeting its social responsibility commitments
thereby enhancing its reputation for responsible action
4. Raising awareness on its strategies, objectives and performance, and the
impacts of its operations and activities
5. Engaging and motivating employees to support the organization’s social
responsibility
6. Helping engage stakeholders
7. Facilitating the benchmarking of performance among peer organizations

Other reasons often cited by reporting organisations include:

1. Driving constructive change in the management of economic, social and

environmental issues (performance reporting is critical part of a management
systems process)
2. Aligning the organization internally on areas of needed improvement
3. Identifying problems for resolution before they magnify

ISO and GRI: Complementary Tools

ISO 26000 addresses the implementation of social responsibility by organizations,

including public reporting on it. But while the ISO standard is often general in its
guidance on reporting, GRI is specific. Where ISO 26000 is silent, GRI provides helpful
detail. For example, ISO’s concept of social responsibility does not address an
organization’s economic performance, an important element of sustainability covered
by GRI. In short, GRI provides the practical help for those charged with actually
preparing a report of the type the ISO Standard promotes, while addressing other
stakeholder concerns as well.

Like ISO 26000, the GRI Sustainability Reporting Guidelines were developed and
refined in an international, multi-stakeholder process involving thousands of
participants, including those from the business, labour, NGO and intergovernmental
organization sectors. Since its launch in 1997, the GRI reporting framework has been
developed and refined several times to respond to evolving experience and needs.
Recognized by the United Nations and the UN Global Compact, and referenced in many
national CSR policies and investor initiatives (such as the UN Principles for Responsible
Investment), the GRI is a freely available voluntary tool for all organizations to use in
preparing their social responsibility reports. More information on GRI is available at:
www.globalreporting.org

The most widely recognized and used international sustainability reporting framework,
the GRI has participated actively in the ISO 26000 process since its inception. Based on
the current ISO Committee Draft, GRI offers the following observations on how ISO
26000 users might employ the GRI framework to prepare a report on their
implementation of the ISO standard. These observations focus on the three main
challenges reporting organizations face: (1) selecting the issues to be covered; (2)
identifying what aspects performance related to those issues to report (performance
indicators, etc.); and (3) ensuring the quality of reported information.

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Determining What Issues to Report

ISO 26000 recognizes that social responsibility reports should not only be responsive to
stakeholder concerns, but to be most credible, should address the “relevant and
significant issues of the organization” (Clauses 7.5.2 and 7.6.3). The document also
provides some general guidance on this. GRI, expanding upon a term used in financial
reporting, captures a similar approach under the reporting principle of “materiality.”
Under GRI, issues are material if they pose significant economic, environmental or
social impacts, or would substantially influence the assessments and decisions of
stakeholders about the organization. The GRI Guidelines provide useful tests that can
help a reporter decide whether an issue is material. In addition, the guidelines offer
tips on stakeholder involvement in the reporting process under a principle on
“stakeholder inclusiveness.”

The ISO standard also says that social responsibility reports should “present the
organization’s operational performance … in a broader sustainability context,” (Clause
7.5, Box 14). Further explanation of this is presented under GRI’s principle on
“sustainability context”. GRI also recommends more specific types of contextual
information be reported under its guidelines provisions on Disclosure on Management
Approach (DMA).

Likewise, ISO calls for reports to present a “complete picture of the organization’s
social responsibility performance” (Clause 7.5, Box 14; Clause 7.6.3) and GRI’s
principle of “completeness” provides meaning for that.

Taken together, GRI’s reporting principles of materiality, stakeholder inclusiveness,

sustainability context, and completeness, along with its Reporting Boundary Protocol,
present an approach that can help a reporter identify and prioritize its economic,
social and environmental issues for reporting. This also makes it convenient to fulfill
the ISO provision calling for reports to explain how the issues were selected (Clause
4.5, Box 14).

Identifying Performance Indicators and Other Specific Disclosures

ISO 26000 acknowledges that to be most credible, a social responsibility report must
cover the organization’s social responsibility objectives and performance, and says
that one of the most common methods of measuring performance is with indicators
(Clause 7.5, Box 14, Clause 7.7.2). Indicators are specific qualitative or quantitative
information about performance results or outcomes associated with the organization
that are generally comparable and demonstrate change over time. Again, ISO does not
provide guidance on specific indicators, nor any other framework for comparing
performance either year-on-year or with other comparable organizations. In contrast,
GRI offers several widely used specific indicators dealing with a range of economic,
social and environmental topics. The Table below identifies how the specific GRI
indicators and other disclosures offered in its G3 Reporting Guidelines can capture the
performance on specific social responsibility subjects and other provisions listed in ISO
26000.

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Recognizing the limitation of generic guidance, GRI also offers more customized
indicators and other disclosure guidance under specific sector supplements. These
cover sectors such as apparel & footwear, automotive, electric utilities, financial
services, food processing, logistics & transportation, mining & metals, public agencies,
and telecommunications. Several others, including for construction & real estate, oil
&gas and NGOs are under development. In addition, GRI is developing national annexes
to provide specific guidance to reporters in certain countries.

Besides reporting on performance, the ISO standard also calls for communication on
social responsibility objectives, achievements and shortfalls (Clause 7.5, Box 14). This
is consistent with GRI’s Disclosure on Management Approach under its reporting
guidelines, which asks for information on goals and performance, successes and
shortcomings and other contextual information.

Ensuring the Quality of Reported Information

ISO 26000 briefly explains that social responsibility reports and other communications
should be understandable, accurate, balanced, and timely (Clause 7.5.2), while GRI
goes further in providing more specific guidance on the principles of clarity, accuracy,
balance, and timeliness, as well as the principles of comparability and reliability.
These principles all go to helping assure the quality of reported information.

ISO also notes that the credibility of reports and other communications about social
responsibility can be enhanced through third party verification or assurance, but
doesn’t provide the type or extent of guidance on that like GRI does in its guidelines.

The Future of Reporting

The rise of ‘sustainability’, ‘corporate responsibility’ or ‘non-financial’ reporting

reflects trends that seem set to grow further. Its drivers include:
• The desire of organizations to use information better to improve performance
• The interest of regulators, employees, the media and the public in what an
organization is doing to contribute to global sustainable development
challenges such as climate change and human rights;
• The need of managers, investors or donors to assess how well an organization is
managing risks and exploiting opportunities to advance its goals; and
• The rising interest of governments in encouraging all organizations to play their
part in implementing public policy.

The ISO 26000 Standard can be expected to bring both a heightened level of awareness
about social responsibility, but also a new breadth and depth of understanding of the
issues. In turn, it seems likely to encourage wider attention to what the policies and
practices of organizations are, and to the issue of reporting. By using the GRI
framework in tandem with the new ISO Standard, users will have a practical set of
tools to measure and report on their social responsibility policies and practices.

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The GRI secretariat has prepared this paper to assist potential users of the ISO 26000
Standard. For reasons of length, it does not seek to cover or represent all elements
covered by either the draft ISO Standard or the GRI Guidelines. Readers are
encouraged to examine those documents for authoritative text. As the ISO draft
further evolves, GRI intends to further refine its guidance on the complementary
features of the two instruments. Any comments or suggestions for improvement on
this Draft Linkage Document should be sent to Sean Gilbert, Technical Director, GRI
(gilbert@globalreporting.org).

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 Table. Comparison of GRI G3 Reporting Guidelines with ISO 26000 CD

Social Responsibility Subject ISO 26000 GRI G3 Guidelines

Clause Disclosure No.
(DMA=Disclosure on
Mgmt Approach)
Organizational governance 6.2 1.1, 1.2, 2.3, 4.1-
4.14; All DMAs
Human Rights 6.3 HR1-9; HR DMA
-Due diligence 6.3.3 HR1,2,5,6,7
-Human rights risk situations 6.3.4 HR5-7
-Avoidance of complicity 6.3.5 HR1-3, 5-8
-Resolving grievances 6.3.6 HR4,9*
-Discrimination and vulnerable groups 6.3.7 HR4,6,7,9; LA13-14
-Civil and political rights 6.3.8 HR5,9
-Economic, social and cultural rights 6.3.9 PR1,2; SO1; EC9
-Fundamental rights at work 6.3.10 HR4-7
Labour Practices 6.4 LA1-14; LA DMA
-Employment and employment relationships 6.4.3 HR4,5; LA1-5,13,14
-Conditions of work and social protection 6.4.4 LA3-5,14; EC5
-Social dialogue 6.4.5 HR4,5; LA4,5
-Health and safety at work 6.4.6 LA6-9
-Human development & training in the 6.4.7 LA10-12
workplace
The Environment 6.5 EN1-30; EN DMA
-Prevention of pollution 6.5.3 EN19-24
-Sustainable resource use 6.5.4 EN1-10; EN16-8,26,27
-Climate change mitigation and action 6.5.5 EC2; EN16-18
-Protection & restoration of the natural 6.5.6 EN11-15,25
environment
Fair Operating Practices 6.6 SO2-8; SO DMA
-Anti-corruption 6.6.3 SO2-4
-Responsible political involvement 6.6.4 SO5-6
-Fair competition 6.6.5 SO7
-Promoting social responsibility in the sphere of 6.6.6 EC6,9; HR1,2,8 PR1,2;
influence EN 26,29; Guidance
on Boundary Setting
-Respect for property rights 6.6.7 EC9; SO8*
Consumer Issues 6.7 PR1-8; PR DMA
-Fair marketing, factual and unbiased 6.7.3 PR6,7
information and fair contractual practices
-Protecting consumers’ health & safety 6.7.4 PR1-5
-Sustainable consumption 6.7.5 PR1-5; EN26,27
-Consumer service support and dispute 6.7.6 PR3-7,9*
resolution

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-Consumer data protection and privacy 6.7.7 PR8
-Access to essential services 6.7.8 PR1,5; EC9*
-Education and awareness 6.7.9 PR5-7
Community involvement and development 6.8 SO1; SO DMA,
EC1,5-9
-Community involvement 6.8.3 EC1,8; SO2-6; LA8,
Stakeholder
inclusiveness principle
-Education and culture 6.8.4 EC8*h
-Employment creation and skills development 6.8.5 SO1; EC1,6,8,9
-Technology development and access 6.8.6 EC7*
-Wealth and income creation 6.8.7 EC1,6-8
-Health 6.8.8 LA8
-Social investment 6.8.9 EC1,8

* Indirectly relevant

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SUMMARY LIST OF GRI INDICATOR TOPICS

(1) Environment
Conserving Materials
EN 1: material usage
EN2: use of recycled materials
Reducing Impacts on Energy Resources
EN3, 4: energy consumption
EN5: energy conservation
EN6, 7: energy-efficiency and renewable-energy initiatives
Reducing Impacts on Water Supplies
EN8: water usage
EN9: effects on water sources
EN10: water recycling and reuse
Protecting Biodiversity
EN11: areas of high biodiversity
EN12: effects of activities, products and services on areas of high biodiversity
EN13: habitats protected or restored
EN14: managing biodiversity impacts
EN15: threatened species in areas affected by operations
Reducing and Controlling Emissions, Effluents and Waste
EN16, 17: greenhouse gas (GHG) emissions
EN18: GHG emission reduction
EN19: emissions of ozone-depleting substances
EN20: emissions of other air pollutants
EN21: wastewater discharges
EN22: waste generated and disposed of
EN23: significant environmental spills
EN24: hazardous waste managed
EN25: effects on biodiversity from impact on water bodies
Reducing environmental impacts of products and services
EN26: reducing environmental impacts of products and services
EN27: reclaiming products sold
Achieving and Maintaining Compliance
EN28: fines and other penalties for environmental violations
Reducing Environmental Impacts from Transport
EN29: environmental impacts of transporting products, materials and people
Assuring Appropriate Resources Devoted to Protecting the Environment
EN30: expenditures on environmental protection

(2) Human Rights

Furthering Human Rights through Investment and Procurement Practices
HR1: screening investments for human rights concerns
HR2: screening suppliers and contractors for human rights concerns
HR3: training employees on human rights
Preventing Discrimination
HR4: actions taken to address incidents of discrimination

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Protecting Freedom of Association
HR5: actions to support freedom of association in areas where it may be in
significant threats to this freedom
Preventing Child Labor
HR6: actions to prevent child labor in areas where there is a significant risk of
it occurring
Preventing Forced and Compulsory Labor
HR7: actions to prevent forced and compulsory labor in areas where there is a
significant risk of it occurring
Assuring Security Practices Respect Human Rights
HR8: security people trained on human rights
Protecting the Rights of Indigenous People
HR9: actions taken to address violations of the rights of indigenous people

(3) Labour Practices

Providing Good, Non-discriminatory Employment
LA1: number of employees by type and region
LA2: employee turnover
LA3: employee benefits denied to temporary and part-time workers
Assuring good labour-management relations
LA4: percentage of unionized workers
LA5: minimum period of notice to employees about significant changes
affecting them
Protecting the health and safety of workers
LA6: workers represented in safety and health committees
LA7: statistics on injuries, occupational diseases, absenteeism
LA8: employee, family and community programs to address serious disease
LA9: health and safety topics covered in collective bargaining agreements
Developing employees through training and education
LA10: amount of employee training
LA11: programs to assist employees at career end (retraining, retirement, etc.)
LA12: percentage of employees receiving regular performance and
development reviews
Fostering diversity and equal opportunity among employees and within the
organization’s governance bodies
LA13: diversity of organization’s governance body
LA14: ratio of men’s to women’s salaries for workers and for management

(4) Organizational Governance

4.1: governance structure within organization
4.2, 4.3: independence of oversight governing body (board of directors, etc)
from management personnel
4.4: mechanisms for providing stakeholder (employees, investors) feedback to
the governing body
4.5: linkage between executive compensation and performance
4.6: processes within the governing body for avoiding conflicts of interest
4.7: process for securing necessary expertise within the governing body on
social, environmental and economic matters

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4.8: the organization’s mission, values, code of conduct and principles related
to social, environmental and economic matters
4.9: approach by the highest governing body for overseeing the organization’s
identification and management of social, environmental, and economic matters
4.10: processes for evaluating the performance of the governing body relative
to social environmental, and economic matters
4.11: organization’s approach to the precautionary principle
4.12: external codes, standards, charters, guidelines, etc. adopted by the
organization
4.13: associations in which the organization is a member

Disclosure on Management Approach for each category: (covers strategies,

goals and performance, policies, responsibilities, training, monitoring, and
management systems for that category)

(5) Fair Business Practices

Corruption
SO2: business units analyzed for corruption risk
SO3: employees trained in anti-corruption policies
SO4: actions taken in response to incidents of corruption
Responsible advocacy of public policy
SO5: participation in development of public policy; positions taken on issues
SO6: political contributions
Avoidance of anti-competitive behavior
SO7: outcomes of lawsuits concerning anti-competitive behavior
Complying with law
SO8: fines paid and other sanctions for violations of law

(6) Community Involvement/ Society Development

Assessing and managing impacts on communities
SO1: programs to assess and manage the impacts of operations on communities
EC9: indirect economic impacts on community
Contributing to the economic well-being of the community
EC1: wages, taxes, donations and other financial contributions to the
community
EC5: ratio of standard wage to local legal minimum wage
EC6: spending on locally based suppliers
EC7: hiring locally based managers
EC8: commercial, in-kind and pro-bono contributions to community services
and infrastructure

(7) Consumer Issues

Protecting customer health & safety
PR1: percentage of products and services subject to life-cycle evaluations for
health and safety impacts
PR2: compliance with laws and voluntary codes concerning the health and
safety impacts of products and services
Satisfying customer needs, including needs for product and service information
PR3: product and service information provided

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PR4: compliance with laws and voluntary codes concerning product and service
labelling and information
PR5: customer satisfaction survey results
Responsible marketing
PR6, 7: compliance with laws and voluntary codes concerning marketing
communications
Respecting customer privacy
PR8: complaints regarding breaches of customer privacy and losses of customer
data
Assuring products and services conform to law
PR9: fines for violations of laws concerning products and services

(8) Economic Performance

EC2: Financial implications of climate change
EC3: Coverage of the defined benefits retirement program
EC4: Significant government financial assistance received

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