US SIF stated that while they support the IIRC’s efforts to develop an integrated reporting framework with both financial and non-financial data (environmental, social and governance (ESG) data), their primary interest is the disclosure of the most robust ESG data possible.
Because of this, US SIF would prefer to see a separate and comprehensive ESG report rather than an abridged version in an integrated report. They acknowledge the fact that there is often a division of labor between Investor Relations and sustainability departments, which results in conflicting messages and absence of internal knowledge. Further, an integrated reporting framework would force companies to understand how sustainability issues relate to every day business practices, as well as long-term strategies. It’s important that ESG data and performance progress should be made known to all types of equity and alternative investment analysts.
US SIF made five broad points in regard to the discussion paper:
Ensure integrated reporting doesn’t diminish the quality of good ESG reporting that currently exists
Reconsider the mandate that only senior management determines what are the most material issues to an organization
While US SIF would prefer to see a separate ESG report, they ask the IIRC to broaden its definition of what must be provided in integrated reports
Less input from accountancy firms and more input from sustainable and responsible investors (who are the primary users of these reports)
Greater synergies between the integrated reporting process and the GRI reporting framework
Statement from the most senior decision-maker of the organization about relevance of sustainability to the organization and the organization’s strategy for addressing sustainability
Name of the organization
Primary brands, products, and services
Location of organization’s headquarters
Number of countries where the organization operates, and names of countries with significant operations or that are specifically relevant to the sustainability topics covered in the report
Nature of ownership and legal form
Scale of the reporting organization
Total workforce by employment type, employment contract, and region, broken down by gender
Percentage of total employees covered by collective bargaining agreements
Description of the organization’s supply chain
Significant changes during the reporting period regarding organization's size, structure, ownership, or supply chain
Whether and how the precautionary approach or principle is addressed by the organization
Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses
Memberships in associations and/or national/international advocacy organizations
Entities included in the organization consolidated financial and nonfinancial reports
Process for defining report content
Material aspects identified in the process for defining report content
For each material aspect, the aspect boundary within the organization
For each material aspect, the aspect boundary outside the organization
Explanation of the effect of and reasons for any restatements of information provided in earlier reports
Significant changes from previous reporting periods in the scope and aspect boundaries
List of stakeholder groups engaged by the organization
The basis for identification and selection of stakeholders with whom to engage
The organization’s approach to stakeholder engagement, including frequency of engagement by type and by stakeholder group, and an indication of whether any of the engagement was undertaken specifically as part of the report preparation process
Key topics and concerns that have been raised through stakeholder engagement, and how the organization has responded to those key topics and concerns, including through its reporting. Report the stakeholder groups that raised each of the key topics and concerns
Date of most recent previous report
Contact point for questions regarding the report or its contents
‘In accordance’ option and GRI Content Index
Policy and current practice with regard to seeking external assurance for the report
Governance structure of organization, including committees of the highest governance body
The organization’s values, principles, standards, and norms of behavior such as codes of conduct and codes of ethics
Disclosure on Management Approach for Aspect
Coverage of the organization’s defined benefit plan obligations.
Financial assistance received from government.
Significant indirect economic impacts, including the extent of impacts.
Total number and rates of new employee hires and employee turnover by age group, gender and region.
Average hours of training per year per employee, by gender and by employee category.
Percentage of employees receiving regular performance and career development reviews, by gender and by employee category.