illiam lackburn onsulting Ltd 2012 2010 William Blackburn

Background q Global Reporting Initiative Sustainability Reporting Guidelines = the international gold standard for public sustainability/CSR reporting— env. , social, econ. (Currently G 3 or G 3. 1) q G 4= the 4 th edition, to be finalized May 2013 q GRI seeks stakeholder input on G 4: § Online survey (Nov 2011) § GRI Working Groups § September 25 Feedback on draft q NAEM letter (major/common issues) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Developments Influencing G 4 q q q GRI 2015 Goal: q All large and medium companies from OECD (developed) and large emerging countries (BRICS, etc. ) should publicly report their sustainability (soc. , env. , econ. ) performance or explain why not (“report or explain”) Mandatory integrated (financial + sustainability/ESG) reporting (S. Africa, UK, France, Denmark, Sweden, et al. ) Voluntary integrated reporting § § Voluntary reporters (AEP, United Technologies, Southwest Air, et al. ) International Integrated Reporting Comm. (IIRC) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

G 4 Objectives 1. Create user friendly guidance 2. Improve clarity 3. Harmonize with international standards 4. Strengthen “materiality” guidance 5. Link with integrated reporting (IIRC) (to be done later) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

G 4 Objectives 6. Address needed improvements (with Working Groups) a. Application levels b. Disclosure on Management Approach (DMA) c. Boundary/materiality d. Supply chain e. Governance & remuneration f. GHG and anti-corruption (coming in a few weeks) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Application Levels A, B, C Levels replaced with single “in accordance” criteria requiring: 1. All Profile Disclosure Items (now includes supply chain info) 2. DMAs and Core Indicators for all material Aspects (can group) 3. Material Aspects identified per Technical Protocol 4. All applicable Sector Supplement indicators 5. CEO statement on GRI conformance plus “report or explain” 6. GRI content index illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Defining Report Content and Boundaries Step 1. Map Value Chain (entities and relationships where there may be significant sustainability impacts). E. g. , : Upstream Elements Downstream Elements Local Communities Suppliers Transportation Customers Company Recycling Facilities Transportation Etc. illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Defining Report Content and Boundaries Step 2. Identify Relevant Topics and Their Boundaries § Show which value chain elements may have which sustainability issues (a) with important impacts or (b) which may influence the decisions of the organization’s stakeholders § At a minimum, consider all GRI Aspects in G 4 and applicable Sector Supplement as relevant illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Defining Report Content and Boundaries Step 3. Prioritize Aspects (for materiality and depth of disclosure) § Material issues= • Significant economic, social and environmental impacts, or • Substantively influence the assessments and decisions of stakeholders § More in-depth disclosure for Aspects with greatest impacts on organization or its stakeholders § Need consistent, systematic, documented process illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Defining Report Content and Boundaries Step 4. “Validation” …to check the completeness of the material Aspects to assure the report will provide a reasonable and balanced picture of the organization’s positive and negative performance illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Question 1: Core Indicators for “In Accordance” Status ___A. The number and scope of Core Indicators (66 vs 49 for G 3, plus sector supplements) are appropriate given the materiality process for prioritization and selection. ___ B. To make G 4 less intimidating and more user friendly, Core Indicators should be trimmed based on an analysis of actual use and by abbreviating sector supplements. (Probably needed for integrated reporting anyway? ) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Question 2: Postpone G 4 to Identify List of Core Indicators for Integrated Reporting ___A. We recognize that G 4 may be further revised to add content for the International Integrated Reporting Committee project but believe G 4 should be issued on schedule even if that content is not available. ___ B. To minimize confusion from repeated GRI revision, GRI should postpone issuance of G 4 until after simplified list of Core Indicators is identified for integrated reporting. illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

DMAs q Generic DMA and some category- and indicatorspecific DMAs q Generic DMA content for material topics 1. “Topic” (aspect, multiple aspects or category) and why it’s material 2. How impacts are managed § Policies, commitments, goals § Responsibilities, resources § Specific actions § Challenges and Dilemmas 3. How effectiveness of approach is monitored and evaluated; results from approach and related adjustments to it illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

DMAs q Poor DMA conformance under A and B reports for G 3 and G 3. 1 (300+ data points) q New DMA rules for added flexibility: 1. Only report for material topics 2. Can group by multiple Aspects or Categories if manage on broader basis (e. g. , ISO 14001 for multiple environmental Aspects) 3. Less information for less significant material items q Need examples? illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Question 3: DMA Number and Scope ___A. The number and scope of DMA provisions are appropriate, even though DMAs are now required for “in accordance” status, because the new rules provide sufficient flexibility in trimming and grouping them. ___ B. DMA content should be trimmed because DMA guidance is still too long, complicated and intimidating. (Suggestions of items to cut: ___________________) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Question 4: Examples of Good Reporting ___A. G 4 Guidance is sufficiently clear such that examples of good reporting text would not add much value and might reduce reporting innovation. ___ B. GRI should provide sample text of good reporting on: __DMAs; __Materiality/prioritization process __Supply chain reporting __Other (specify: ____________) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Significantly Increased Content q Profile q Governance & remuneration q Supply chain q Boundary/value chain mapping (revised tech protocol) q Screening and assessment; remediation (added under several categories) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com

Question 5: Overall Burden and Complexity ___A. The increased content of G 4 improves the user friendliness and clarity of the guidance and offers reporters more choices, including more flexibility in selecting report content through the materiality process and DMA application rules, etc. ___ B. G 4 is too long and complicated, and the way it is presented may well be intimidating to new and current reporters, alike. (Suggestions about content to cut or simplify: ______________) illiam lackburn onsulting, Ltd. © 2012 © 2010 William. Blackburn. Consulting, Ltd. WRB@WBlackburn. Consulting. com www. WBlackburn. Consulting. com