Exposure Draft of GRI Universal Standards

Submissions received during the public comment

About this Document

The Global Sustainability Standards Board (GSSB), GRI's independent standard-setting body, started a project to
102: General Disclosures 2016 and GRI 103: Management Approach 2016. The revisions seek to improve the qua
to disclose their impacts on the economy, environment, and people. A 90-day public comment period on the expos
exposure draft can be accessed here: https://www.globalreporting.org/standards/media/2605/universal-exposure-d

This document includes the full set of comments received via the online survey or letter during the public commen
Standards Board for their consideration.

Letter submissions are linked in column B in Tab 2. Responses submitted via the public comment form are listed v
your reference.

The GSSB will publish a separate Basis for Conclusions document following the approval of the Universal Standar
addressed.

Disclaimer
The Global Sustainability Standards Board (GSSB) is authorized by its Terms of Reference to develop and issue t
documents are to be developed and issued in the public interest and according to due process.

The GSSB Due Process Protocol requires public consultation on the exposures drafts and states that comments m
posted on the GSSB website after the end of the exposure period.

As part of the process to submit comments on the exposure draft, express permission has been secured from thos
constituency group and, if submitting comments on behalf of an organization, the organization’s name.

These comments are published on the GRI website for public record, in line with the GSSB Due Process Protocol.
other party. Neither Stichting Global Reporting Initiative (GRI) nor the GSSB can assume responsibility for any con
alteration of anything contained in this document.

The GSSB Terms of Reference can be accessed here: https://www.globalreporting.org/media/fk1lyhvp/gssb-terms

The GSSB Due Process protocol can be accessed here: https://www.globalreporting.org/standards/media/2099/gs

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Standards
comment

d-setting body, started a project to review GRI’s Universal Standards, which consist of GRI 101: Foundation 2016, GRI
revisions seek to improve the quality and consistency of reporting and to improve how organizations use the Standards
ublic comment period on the exposure draft of the Universal Standards ran from 11 June to 9 September 2020. The
s/media/2605/universal-exposure-draft.pdf

or letter during the public comment period. These comments have also been shared with the Global Sustainability

e public comment form are listed verbatim in columns G-T in Tab 2. The online survey questions are included in Tab 3 for

approval of the Universal Standards, summarizing the main themes from the public comments and how they have been

Reference to develop and issue the GRI Sustainability Reporting Standards and related Interpretations. These
to due process.

drafts and states that comments made by respondents to an exposure draft are a matter of public record and are to be

ission has been secured from those participating to publish comments and some personal data - name, country,
e organization’s name.

the GSSB Due Process Protocol. They should only be used for this purpose and should not be altered or shared by any
n assume responsibility for any consequences or damages resulting directly or indirectly from the dissemination and/or

ing.org/media/fk1lyhvp/gssb-terms-of-reference-2018.pdf

rting.org/standards/media/2099/gssb-due-process-protocol-2018.pdf

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 SUBMISSION PROFILE

No. FORMAT TYPE OF SUBMISSION

48 Survey & Letter On behalf of an organization, group or

institution
53 Survey & Letter On behalf of an organization, group or
institution
56 Survey & Letter On behalf of an organization, group or
institution
82 Letter On behalf of an organization, group or
institution
97 Letter On behalf of an organization, group or
institution

144 Letter As an individual

SUBMISSION PROFILE

NAME COUNTRY CONSTITUENCY

Ethical Trade Norway Norway Mediating Institution

Forest Peoples Programme United Kingdom Civil Society Organization
Fundación ONCE Spain Civil Society Organization
NBIM Investment Institution
R 3.0 Mediating Institution

Carlo Diener No response

 KEY CONCEPTS IN THE GRI STAND

Question 1. Please provide any comments on these revisions

To be aligned with UNGP and the OECD Due Diligence Guidance for Responsible Business Conduct impacts on
• “Material topic” (lines 137 - 171) there should be a note to say that although a company may identify a mater
other material topics may come to light during due diligence that are raised by rights-holders themselves as well
internationally. _x000D_
_x000D_
• It is recommended that in line 153, the following sentence be added: "In assessing the significance of its hum
the priorities raised by rightsholders themselves as well as by informed civil society organisations on the ground,
_x000D_
• At line 204, it is recommended that this is replaced with the following text: “While not all interests are of equa
and organizations should bear in mind that human rights are interrelated and interdependent.”_x000D_
_x000D_
• Line 209 should also point out that the relationship between corporate conduct and human rights impacts ma
lands, waters, natural resources, livelihoods, cultural integrity, health and security can be impacted indirectly by a
activities are not located on their lands._x000D_
_x000D_
• Line 218 should add: “…this includes securing the consent of indigenous peoples and local communities to
representatives.”_x000D_
_x000D_
• Language use (lines 119-136 & 196- 229): a note here should be added to explain that some “stakeholders”
wherever “stakeholders” are mentioned this is coupled with rights-holders in appropriate places. Further “local co
communities” in line 200 and throughout the full GRI standards document (GRI 101-103)._x000D_
 USING THE GRI STANDARDS FOR SUSTAINABI

Question 2. Please provide any comments on these revisions

• When disclosing which the company has used, it must be made very clear that a company choosing to repor
and that this is a far lesser reporting requirement than Option A, which is to report "in accordance with GRI stand
_x000D_
• Further clarification is needed in this section on how the company is expected under “reporting in accordanc
present or potential future harmful impacts linked to its business, investments, operations and supply chains (inc
described briefly in 103 under “disclosures” (lines 2726-2729) but does not come across strongly enough in this s
grievances, conflicts or risks of future potential harmful impacts on human rights in its business operations or sup
GRI rules make these entities more accountable?
 STATEMENT OF USE

Question 3. Do you agree that the GRI Standards should require the highest
governance body or most senior executive of the organization to include a
statement acknowledging their responsibility for preparing the reported information
in accordance with, or with reference to, the GRI Standards?

Question 3.a. If your answer is yes, please explain.

Question 3.b. If your answer is no, please provide suggestions on alternative
statements.

Yes, this acknowledgement in the statement of use should be required

This is important for commitment.

Yes, this acknowledgement in the statement of use should be required

• Provide a statement of use (lines 353-358): It is correct that the highest governance
body or most senior executive of the organization needs to include a statement
acknowledging their responsibility for preparing the reported information in accordance with,
or with reference to, the GRI Standards. This is because it serves to:_x000D_
1. Embed human rights into company's systems management and "culture". _x000D_
2. Affirm that ultimately this person/group are responsible for the impacts that business
operations, and/or purchasing has on the human rights of people and communities.
_x000D_
3. Reporting can help identify where the company needs to invest more resources and
GRI reporting can be used as part of their internal monitoring system that also instigates
action where required._x000D_
_x000D_
For these reasons, FPP considers that the acknowledgement in the statement of use
should be extended to the quality and veracity of the reported information; however, we
have not offered exact wording for consideration._x000D_
ATEMENT OF USE

Question 4. If your answer to question 3 is yes, should the acknowledgement in the

statement of use be extended to the quality and veracity of the reported
information?

4.a. If your answer is yes, please provide suggestions on how to amend the
statement.
4.b. If your answer is no, please provide an explanation.
Yes
 GOVERNANCE

Question 5. Please provide any comments on the proposed governance disclo

 Overarching comments

(1076 – 1106) Disclosure REP-5 External assur

(1112 – 1126) Disclosure ACT-1 Activities, valu

NEW TOPIC REQUIRED

(1345- 1362) Disclosure GOV 1 Governance st

(1363-1375) Disclosure GOV 2 Nomination and

(1376-1389) Disclosure GOV 3 Responsibilitie

(1390-1398) Disclosure GOV 4 Stakeholder con

(1407 – 1417) Disclosure GOV-6 Conflicts of int

(1448 – 1465) Disclosure GOV-10 Identificatio

(1483-1490) Disclosure GOV-12 Communication

(1581-1586) Disclosure RBC-1 Statement on s

1611-1635) Disclosure RBC-2 Policy commit

(1957 – 1970) Disclosure RBC-6 Compliance with laws and regulations

(2018-2139)
1160 to 1163 102-6 (ACT-1)

1155-1159, 1179 102-7 (ACT-1)

1208 102-8 (ACT-2)

1352 102-22 (GOV-1)

1372 and 2891 102-24 (GOV-2)

 GOVERNANCE

ease provide any comments on the proposed governance disclosures (GOV-1 to GOV-15).
• It is positive that any company reporting “in accordance with the GRI” must report on all 15 disclosure topics
which provide an overview of the organization’s governance structure, composition, roles, and remuneration;
however, it brings up (again) the issue with having two possible ways for companies to report and whether the
claims ultimately made by companies are clear enough for those who do not know the nuance of the GRI
standards (e.g. for an uninformed reader there will be little difference or alarm bells between reading that a
company is reporting “in accordance with the GRI” or “in reference to the GRI” yet in reality these are significantl
different reporting requirements).
• As commented below, the GRI 102 needs to be strengthened with various additions related to Free, Prior an
Informed Consent (FPIC). This addition is necessary and should not be optional. FPIC is a right related to the
rights to self-determination and to lands and resources of indigenous peoples and local communities. It is a
procedural right that is an important mechanism for protecting and furthering the substantive rights of indigenous
peoples. Businesses are expected to report on how they have incorporated the right to FPIC and adhered to this
core international standard for responsible business conduct. Further, this section should highlight that when it
comes to indigenous peoples and local communities, engagement and ‘consultation’ alone are not often not
sufficient. The core principle that FPIC processes can result in FPIC being withheld should also be recognised.
The GRI should reference the body of international jurisprudence on the right to FPIC, including the decisions,
general recommendations and concluding observations of the UN human rights treaty bodies, including the CER
the CESCR, and the Human Rights Committee; the UNDRIP; ILO169, and the FAO Guidelines.
• GRI guidelines must also include wording and reference to human rights specifically, not only mention of
“sustainable development”, which can have varied interpretations whilst human rights can be traced back to
internationally agreed standards.

Under “2. Organizational details and reporting practices (963-1106)

 Disclosure REP-5 External assurance (1076 – 1106)
• FPP asks that GRI clarifies aspects relating to independent verification
Under “3. Organisational activities” (1107 – 1111)

 Disclosure ACT-1 Activities, value chain, and other business relationships (1112 – 1126)
• Include clear reference to indirect/third party suppliers
 Recommended additional disclosure topic. As GRI states, “The disclosures in this section provide an overvie
of the organization’s activities and its employees and other workers. This contextual information helps informatio
users better understand the nature of the organization and its impacts on the economy, environment, and people
However, under this topic there is no disclosure in relation to which rights-holders are potentially affected by the
business; therefore, FPP recommends a new important additional Disclosure ACT-3, which specifies the
disclosure of rights-holder mapping identifying people and communities affected or potentially impacted by
company operations and supply chains. This mapping should give emphasis to indigenous peoples and local
communities in addition to identifying rights holders in the workplace (Disclosure ACT-2 Employees and other
workers, lines 1206-1226).

Under “4, Governance” (1338- 1565)

 Disclosure GOV 1 Governance structure and composition (1345- 1362)

• Under “vi. membership of under-represented social groups” FPP recommends inserting “such as indigenous
representatives”.
 Disclosure GOV 2 Nomination and selection of the highest governance body (1363-1375)
• Human rights needs to be mentioned explicitly here instead of just "sustainable development" which can be
very broad. Companies need to have Human Rights experts at as an essential part of decision making and
governance bodies.
 Disclosure GOV 3 Responsibilities for sustainable development topics and delegation (1376-1389)
• Add a point (f) “describe external expertise drawn on in relation to human rights”
 Disclosure GOV 4 Stakeholder consultation on sustainable development topics (1390-1398)
• GRI needs to define “consultation” in this context before it can provide full feedback; however, it is clear that
an addition should be made to include “consultation in relation to indigenous peoples and local communities
includes their free, prior and informed consent (FPIC), which is a core standard that upholds that engagement is
not sufficient where business operations or investments may directly or indirectly affect community rights or
interests in general. Compliance with this standard and respect for FPIC includes respecting a community decisio
to withhold consent.

 Disclosure GOV-6 Conflicts of interest (1407 – 1417)

• Add (c) where the conflicts of interest are disclosed in GRI reporting itself
 Disclosure GOV-10 Identification and management of impacts (1448 – 1465)
• The means and methods of demonstrating the outcomes related to the management of impacts should be
disclosed
 Disclosure GOV-12 Communication of critical concerns (1483-1490)
• GRI must define “critical concern”
Under 5. Responsible Business Conduct (1566-2017)

 Disclosure RBC-1 Statement on sustainable development strategy (1581-1586)

• Add “…and human rights”. As per points above, effective reporting must be more specific than board
information on sustainable development. The UN SDGs affirm that business respect for human rights underpins
their goals.

 Disclosure RBC-2 Policy commitments (1611-1635)

• Can add: how external inputs are reflected in the policy
• Under (f) detail indigenous peoples and local communities and the need for this to be available in a language
understandable to them
 Disclosure RBC-4 Grievance mechanisms and other remediation processes (1788-1805)
• Require that companies report on how they define “caused”, “contributed” and “linked”

 Disclosure RBC-6 Compliance with laws and regulations (1957 – 1970)

• Add (c) report on supplier non-compliance to laws and regulations

Under 6. Stakeholder Engagement (2018-2139)

This section needs revision on a number of fronts (many of which have been detailed already):
- Inclusion of “rights-holder” terminology (not just stakeholders)
- Definition of consultation and demonstrative understanding of the difference between engagement and
consultation
- Need to add “Disclose SE-3” on Free, Prior and Informed Consent (FPIC) with guidance
REFERENCES:
Universal Exposure draft: Line 1160 to 1163
Suggestion coming from page 43 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.
SUGGESTION:
"When describing the markets served, the organization can:"
• report the markets it serves with characteristics of ‘design for all’ or ‘universal design’ and describe the type of
products and services provided to this market.
(Please consider Fundación ONCE's contribution provided by email to support this response).

REFERENCE I:
Universal Exposure draft: Line 1155 to 1159
Suggestion coming from page 44 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.
SUGGESTION I:
"When describing its products and services, the organization should:"
•report the quantity of products and services that include ‘design for all’ or ‘universal design’ considerations .

REFERENCE II:
Universal Exposure draft: Line 1179
Suggestion coming from page 44 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.
SUGGESTION II:
"When describing the characteristics of the entities downstream from the organization and the activities they carr
out in relation to the organization’s products and services, the organization can:"
• Report the positive impacts that the products and services for vulnerable customers and beneficiaries (e.g.
people with disabilities) have generated.
(Please consider Fundación ONCE's contribution provided by email to support this response).
REFERENCES:
Universal Exposure draft: Line 1208
Suggestion coming from page 40 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.

SUGGESTION:
"The organization shall:"
X. report the percentage of employees with disabilities.
X. report the total number of employees with disabilities, and provide a breakdown of this total by:
i. employment contract (permanent and temporary), by gender;
ii. employment contract (permanent and temporary), by region;
iii. employment type (full-time and part-time), by gender;
iv. employment type (full-time and part-time), by region;
(Please consider Fundación ONCE's contribution provided by email to support this response).

REFERENCES:
Universal Exposure draft: Line 1352
Suggestion coming from page 34 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.
SUGGESTION:
"Describe the composition of the highest governance body and its committees by:
(...)"
vi. membership of under-represented social groups (including people with disabilities).
(Please consider Fundación ONCE's contribution provided by email to support this response).

REFERENCES:
Universal Exposure draft: Line 1372 and 2891 (Glossary)
Suggestion coming from page 34 of the Guide "Disability in Sustainability Reporting" by GRI and Fundación
ONCE.
SUGGESTION:
The suggestion is to include in the glossary a definition of diversity which considers disability.
(Please consider Fundación ONCE's contribution provided by email to support this response).
 IDENTIFYING MATERIAL TOPIC

Question 6. Please provide any comments on these revisions.

GRI 103 (lines 2206 – 2890)_x000D_
_x000D_
Section 2: Identifying material topics: _x000D_
_x000D_
• In the guidance a note needs to be added to highlight that although the company may identify its material top
impacts identified by rightsholders themselves, as well as by CSOs, NGOs and local organisations with informati
material topic should not only be deemed as such by a company alone – it is not acceptable that a company is th
Where a company does not feel it is contributing to a particular material topic, yet it is a material impact well-know
why they do not believe this impact is related to their business and supply chains. Useful overview._x000D_
_x000D_
 Clarification needed (line 2302) "This section describes the steps that the organization should go through in
requirement." _x000D_
_x000D_
 Under the bullets (2316 - 2322) insert a bullet that says: consult with stakeholders, rights-holders and indepe
must be underscored)_x000D_
_x000D_
 Under "Assessing context" (2363 - 2379): there should be an additional bullet that states that they should be
those of suppliers' (e.g. via a stakeholder mapping process to identify which indigenous communities, local comm
_x000D_
 Box 1 (2394): Engaging with relevant stakeholders and experts: add reference to Indigenous peoples consid
_x000D_
 Rethought is required around the idea that where the organisation is unable to “identify actual and potential n
example, because it has diverse or multiple global operations or because its value chain comprises a large numb
prioritise. Due to high-level nature of scoping itself, and the various forms this could take, it is necessary that sco
of potential and actual impacts, contrary to sentence 2442, which outlines that "The organization can then identif
areas". External parties and the use of independent information sources and evidence should be drawn upon an
_x000D_
• Saliency (lines 2380- 2490): The very concept of “scale” that makes up the definition of “severity” (along with
what is deemed as most salient will be different to another who is looking at the same picture or situation from a
_x000D_
• lines (2485 - 2490) This is a useful element - please add to line 2485: "...positive contribution to sustainable
line 2489 - replace "historical and cultural lands" with "customary lands and territories"; line 249 add word remed
_x000D_
• Prioritisation (2491 – 2599): it therefore follows from the two above points made, that prioritisation should no
The suggestion is to include in a new Guidance to MT with references to complementary documents and guidan
topics. In the case of disability, we would suggest to include the Guide "Disability in Sustainability Reporting", by
'REFERENCES:_x000D_
Universal Exposure draft: Line 2742_x000D_
Suggestion coming from pages 36, 41, 44, 46 and 49 of the Guide "Disability in Sustainability Reporting" by GRI
(Please consider Fundación ONCE's contribution provided by email to support this response)._x000D_
 REPORTING ON MATERIAL TOP

Question 7. If there are topics listed in a GRI Sector Standard that an organization
in that sector does not deem to be material, should the organization be required to
identify these topics and explain why they are not material? Please explain your
answer.

Yes, this information should be required Because it's essential information

I don't know/other Section 3: Reporting on material topics:_x000D_
_x000D_
 FPP affirms that if there are topics listed in a GRI Sector Standard that an organization
in that sector does not deem to be material, the organization should be required to identify
these topics and explain why they are not material. This is because the process
implemented to understand what the material risks and impacts are, and who is assessing
them will heavily determine what is considered a material risk. The material impacts per
sector in Sector Standards have been developed by a group of experts and identified as the
minimum number of material impacts that a business should be aware of and potentially
reporting on; however, this does not make them full-proof. Furthermore, businesses may
not be at the point of understanding the issues in each sector and by having to report on
why they are not reporting they will have to consider these and in the process learn more
about these material impacts, and in some cases probably discovering that they actually do
need to report on them._x000D_
NG ON MATERIAL TOPICS

Question 8. In the absence of an applicable Sector Standard, if there are topics that
are commonly associated with the sector(s) in which an organization operates that it
does not deem to be material, should the organization be required to identify these
topics and explain why they are not material? Please explain your answer.

Yes, this information should be required

Yes, this information should be required  FPP affirms that in the absence of an
applicable Sector Standard, if there are topics that are commonly associated with the
sector(s) in which an organization operates that it does not deem to be material, the
organization should be required to identify these topics and explain why they are not
material. This is because the process implemented to understand what the material risks
and impacts are, and who is assessing them will heavily determine what is considered a
material risk. A bit of research online will bring up NGO reports, media stories etc that will
highlight the concerns within different sectors - unacceptable to argue that information is
not available, at least in terms of understanding what the material impacts are likely to be.
 STRUCTURE OF THE UNIVERSAL STANDARDS

Question 9. Please provide any comments on the proposed structure of the

Universal Standards.

For SMEs the standards are, in our experience, too complex. Simplistic versions could be
of good use. See e-mail on suggestions and inspiration on SME reporting using Ethical
Trade Norway's reporting framework (also based on UNGP and OECD).
References (2140 – 2205)_x000D_
To begin should refer to and add:_x000D_
- Body of international human rights jurisprudence, including decisions, general
recommendations, and concluding observations of CERD, CESCR, Human Rights
Committee, CEDAW, among others; decisions of regional human rights courts and
commissions, including IACHR/IACTHR and ACHPR/ACTHPR_x000D_
- UNDRIP_x000D_
- ILO169_x000D_
- Akwé: Kon Guidelines _x000D_
- FAO Guidelines_x000D_
- Danish Institute of Human Rights, Respecting the rights of indigenous peoples: a due
diligence checklist for companies._x000D_
_x000D_
Other queries for GRI:_x000D_
_x000D_
 Is there any provision within the GRI standards to allow indigenous peoples and local
communities, their organisations and allies to contribute their own reports? _x000D_
 Why has GRI decided to have two approaches to using the GRI Standards for
sustainability reporting and ultimate claims making? As detailed above this is of deep
concern._x000D_
 It seems that there is an over emphasis on identifying material impacts and risks whilst
not enough on detailing how they will be addressed and remediated and, in the case of
future potential harmful impacts, prevented._x000D_
 Is more guidance required under what is meant by “a minority interest” in order to
ensure that gaps in reporting do not occur?_x000D_
 Is there enough nuance around investor role and reporting?_x000D_
_x000D_
_x000D_
FPP welcomes GRI responses and would be keen to understand, per point, how this has
been addressed in the final text of the GRI Universal Standard._x000D_
 OTHER COMME

Question 10. Comments about remaining sections or disclosures.

 OTHER COMMENTS

ining sections or disclosures.

Survey questions for the Universal Standards e
GRI 101: Using the GRI Standards
Section 2. Key concepts in the GRI Standards
The following key concepts have been revised in order to enable organizations to more effectively report on thei

• The definition of ‘material topic’ has been revised to focus on impact. In the exposure draft a material topic is d

‘topic that reflects the organization’s most significant impacts on the economy, environment, and people, includin

Engagement with relevant stakeholders forms part of identifying an organization’s impacts, and so informs the p
assessments and decisions of stakeholders’ is no longer a standalone factor that determines whether a topic is
memorandum and lines 137-171 in the exposure draft of the Universal Standards.

• The definition of ‘stakeholder’ has been aligned with the Organisation for Economic Cooperation and Developm
Conduct. In the exposure draft, a stakeholder is defined as follows:

‘individual or group that has an interest that is, or could be, affected by the organization’s activities and decision

For more information, see lines 121-129 in the explanatory memorandum and lines 196-229 in the exposure dra

Question 1. Please provide any comments on these revisions.

Section 3. Using the GRI Standards for sustainability reporting

The GRI Standards consist of the following three sets of Standards:
• Universal Standards;
• Sector Standards;
• Topic Standards.

There are two approaches to using the GRI Standards for sustainability reporting:
• Option A: reporting in accordance with the GRI Standards;
• Option B: reporting with reference to the GRI Standards.

These revised approaches are intended to improve the quality and consistency of reporting andincrease transpa
information, see lines 130-175 in the explanatory memorandum and lines 230-438 in the exposure draft of the U

Question 2. Please provide any comments on these revisions.

Statement of use
Both approaches to using the GRI Standards include a requirement for organizations to provide a statement of u
GRI Standards, and Requirement B-2 in Option B: reporting with reference to the GRI Standards). For more info
the exposure draft of the Universal Standards, see lines 353-375 for option A and lines 407-430 for option B.

Question 3. Do you agree that the GRI Standards should require the highest governance body or most senior ex
responsibility for preparing the reported information in accordance with, or with reference to, the GRI Standards?
required / No, this acknowledgement in the statement of use should not be required.]
3.a If your answer is yes, please explain.
3.b If your answer is no, please provide suggestions on alternative statements

Question 4. If your answer to question 3 is yes, should the acknowledgement in the statement of use be extende
4.a If your answer is yes, please provide suggestions on how to amend the statement
4.b If your answer is no, please provide an explanation.
4.a If your answer is yes, please provide suggestions on how to amend the statement
4.b If your answer is no, please provide an explanation.

GRI 102: About the Organization

Section 4. Governance
Section 4. Governance contains fifteen disclosures, which provide an overview of the organization’s governance

An organization reporting in accordance with the GRI Standards is required to report all disclosures in this sectio

Information required by the disclosures in the exposure draft of GRI 102 cannot be omitted. If the organization is
disclosure because the item, e.g., a committee, policy, practice, or other process, does not exist, it can meet the
disclosure does not require the organization to implement the item, such as the process, but to report if it does n

For more information, see lines 270-284 in the explanatory memorandum and lines 1338-1565 in the exposure d

Question 5. Please provide any comments on the proposed governance disclosures (GOV-1 to GOV-15). Pleas
Consider feedback on the clarity, feasibility, and relevance of the disclosures.

GRI 103: Material Topics

Section 2. Identifying material topics
Section 2 of the GRI 103 exposure draft clarifies how to identify material topics, based on the expectations conta
existing GRI 101: Foundation 2016. The section provides further guidance for identifying impacts, assessing the
see lines 351-366 in the explanatory memorandum and lines 2300-2599 in the exposure draft of the Universal S

Question 6. Please provide any comments on these revisions.

Section 3. Reporting on material topics

Disclosure MT-1 (Identification of material topics and related impacts) in the GRI 103 exposure draft recommend
have not been identified as material, and why.

The GRI Sector Standards will provide information on the most likely material topics for organizations in a given
applicable Sector Standard(s), where these are available, when identifying its material topics. The Universal Sta
state whether any of the topics in the applicable Sector Standard(s) have not been identified as material, and wh
the Universal Standards and in the GRI Sector Program information sheet.

Question 7. If there are topics listed in a GRI Sector Standard that an organization in that sector does not deem
topics and explain why they are not material? [Yes, this information should be required./ No, this information sho
Please explain your answer.

Question 8. In the absence of an applicable Sector Standard, if there are topics that are commonly associated w
deem to be material, should the organization be required to identify these topics and explain why they are not m
should only be recommended./ I don’t know/other.]
Please explain your answer.
Additional comments
Structure of the Universal Standards
The content of the Universal Standards has been restructured for clarity:
• The first Standard (GRI 101: Using the GRI Standards) introduces the system of GRI Standards and explains h
• The second Standard (GRI 102: About the Organization) contains disclosures for contextual information about
• The third Standard (GRI 103: Material Topics) includes guidance for identifying material topics, and contains d
how it identifies its material topics, and how it manages each material topic.

The new structure aims to clarify the elements of the GRI Standards and their use, and to group contents in a m
explanatory memorandum and lines 69-92 in the exposure draft of the Universal Standards.

Question 9. Please provide any comments on the proposed structure of the Universal Standards.

Comments about remaining sections or disclosures

Question 10. For any comments on the remaining sections or disclosures of the Universal Standards exposure d
number and line numbers. Consider feedback on the clarity, feasibility, and relevance of the disclosures.
al Standards exposure draft

o more effectively report on their contributions toward the goal of sustainable development:

posure draft a material topic is defined as follows:

nvironment, and people, including impacts on human rights’.

’s impacts, and so informs the process of identifying material topics. However, ‘influence on the
at determines whether a topic is material. For more information, see lines 100-113 in the explanatory
s.

omic Cooperation and Development (OECD) OECD Due Diligence Guidance for Responsible Business

nization’s activities and decisions’.

nes 196-229 in the exposure draft of the Universal Standards.

g:

of reporting andincrease transparency in the way that the GRI Standards are used. For more
38 in the exposure draft of the Universal Standards.

tions to provide a statement of use (Requirement A-7 in Option A: reporting in accordance with the
e GRI Standards). For more information, see lines 176-185 in the explanatory memorandum, and in
d lines 407-430 for option B.

vernance body or most senior executive of the organization to include a statement acknowledging their
eference to, the GRI Standards? [Yes, this acknowledgement in the statement of use should be
ired.]

the statement of use be extended to the quality and veracity of the reported information? [Yes/No]
ement
ement

of the organization’s governance structure, composition, roles, and remuneration.

eport all disclosures in this section, as well as all other disclosures in the exposure draft of GRI 102.

be omitted. If the organization is unable to report the required information about an item specified in a
s, does not exist, it can meet the requirement by reporting this to be the case. In such cases, the
process, but to report if it does not exist.

nes 1338-1565 in the exposure draft of the Universal Standards.

ures (GOV-1 to GOV-15). Please use the forms below and indicate the disclosure and line numbers.

based on the expectations contained in the Reporting Principles for defining report content in the
entifying impacts, assessing their significance, and prioritizing them for reporting. For more information,
exposure draft of the Universal Standards.

I 103 exposure draft recommends (but does not require) reporting whether any sector-specific topics

pics for organizations in a given sector. The reporting organization will be required to use the
aterial topics. The Universal Standards exposure draft does not, however, require organizations to
en identified as material, and why. For more information, see lines 2635-2653 in the exposure draft of

on in that sector does not deem to be material, should the organization be required to identify these
equired./ No, this information should only be recommended./ I don’t know/other.]

that are commonly associated with the sector(s) in which an organization operates that it does not
and explain why they are not material? [Yes, this information should be required./ No, this information
 of GRI Standards and explains how they are to be used.
for contextual information about the organization.
g material topics, and contains disclosures about the organization’s material topics and related impacts,

se, and to group contents in a more coherent way. For more information, see lines 54-72 in the
Standards.

versal Standards.

Universal Standards exposure draft, use the forms below, indicating the Standard or disclosure
vance of the disclosures.