r3.0 Public Comment Letter to I?SB: Nonsensical Definition / Definitional Cooptation and Sociopathic Materiality

Bill Baue, Senior Director; Ralph Thurm, Managing Director; r3.0 (Redesign for Resilience & Regeneration), Alexanderstrasse 7, 10178 Berlin, Germany

Emmanuel Faber, Chair
Suzanne Lloyd, Vice Chair
International Sustainability Standards Board
IFRS Foundation
Columbus Building
7 Westferry Circus,
Canary Wharf
London E14 4HD
UK

29 July 2022

r3.0 Public Comment Letter on International Sustainability Standards Board Draft Standards

Dear Chair Emmanuel Faber and Vice Chair Suzanne Lloyd,

We address you directly by name, in hopes of appealing to your humanity and encouraging you to transcend the sociopathic nature of your initiative (which we clearly document below).

We also preface this Public Comment Letter with an explicit acknowledgement of the utter futility of this Consultation exercise, as historical precedent[i] — combined with toothless Due Process[ii] — essentially ensures that you will ignore Public Comments that identify the fatal flaws in your ideological reasoning and predetermined outcomes. We submit this Public Comment purely for the record, without an ounce of faith that the strength of its case will hold sway. Of course, we wish it were otherwise, and would be glad to eat our words if you prove us wrong.

We believe that the International Sustainability Standards Board in general, and its Sustainability Disclosure Standard Exposure Drafts on General Requirements for Disclosure of Sustainability-related Financial Information (S1) and Climate-related Disclosures (S2) in particular, are all fatally flawed for two essential, intertwined reasons: 1) Nonsensical Definition / Definitional Cooptation; and 2) Sociopathic Materiality. These fatal flaws are all-encompassing, mooting the need to respond to your detailed questions. We will address each of these fatal flaws in turn.

Nonsensical Definition / Definitional Cooptation

The International Sustainability Standards Board and the Sustainability Disclosure Standard Exposure Drafts use the term “sustainability” in ways that clearly contravene its core essence, in two primary ways:

• Thresholds: first, they fail to integrate normative thresholds, which are definitional to sustainability;[iii] and
• Outside-in / Inside-out: second, they focus only on effects of the external operating environment on the enterprise (ie outside-in), not the enterprise’s effects on its external operating environment (ie inside-out) .

In practical terms, I?SB (we use this acronym in recognition that this Board lacks any legitimate claim to use the term “sustainability”) obfuscates its definition of “sustainability,” and thereby seeks to co-opt the term “sustainability” for use in ways that actually counteract the achievement of sustainability.

The first step I?SB takes is to refuse to provide its definition of sustainability, both on the Frequently Asked Questions (FAQ) Landing Page on the I?SB Website, and in the Sustainability Disclosure Standard Exposure Drafts (S1 in particular).

The closest the FAQ comes to defining sustainability is the vague mention of “significant sustainability matters”; “important sustainability topics (environmental, social, governance — ESG)”; and “effects of sustainability.”[iv]

• “significant sustainability matters”: This term tells us absolutely nothing about what specific matters this might entail, and tells us absolutely nothing about the definition of sustainability being employed.
• “important sustainability topics (environmental, social, governance — ESG)”: This formulation inaccurately (and dangerously) conflates sustainability with ESG, on two levels: first, ESG is a purely incrementalist doctrine, whereas sustainability is a normative doctrine,[v]predicated on respecting sustainability thresholds; second, ESG is solely concerned with the outside-in impacts of environmental, social and governance elements on the enterprise, and not at all with the inside-out impacts of the enterprise on the health of its external operating environment (in environmental, social, economic, and governance elements).
• “effects of sustainability”: This formulation is particularly telling, as it conceives of sustainability as something that creates outside-in “effects” on an enterprise; the formulation elides that fact that enterprises are also the cause of sustainability — or unsustainability — in their external operating environments through inside-outimpacts.
• In other words, I?SB inhabits not a “cause-and-effect” reality, but rather simply an “effects” reality, as if causes (if they originate from reporting enterprises) do not exist.

To underscore these points, we quote Allen White, Co-Founder of the Global Reporting Initiative, one of the foremost thinkers on sustainability reporting:

“an initiative that purports to be a sustainability initiative could not simply frame its work along the lines of, shall we say, incremental performance assessment. That is, companies that were improving each year in regard to water management, energy management, living wages and occupational health and safety should be recognized in the evolving … framework. But incrementalism alone, at the end of the day, [is] insufficient to be faithful to a sustainability reporting framework. [One] would have to take a further step and include [guidance] that would call for assessing — in addition to disclosures on backward-looking benchmarks, peer group comparisons, and improvements against a company’s own goals — performance against thresholds and limits.”[vi] [Emphasis added]

“ESG does not, by nature, carry a true sustainability gene. A company may rate very highly on an ESG score, but do so just because it has performed well against its own internal goals or against a peer group. But to say this company is an excellent sustainability performer is a very fundamentally different statement. It means that the company is positioned to prosper for the long-term and in a way that respects limits, thresholds, and norms that are externally defined, not simply defined by peer group comparison or internal targets and goals. Sustainability requires contextualization within thresholds. That’s what sustainability is all about.”[vii] [Emphasis added]

Given that “sustainability requires contextualization within thresholds,” surely a framework claiming to be a Sustainability Disclosure Standard would have to integrate thresholds, seeing as “that’s what sustainability is all about.”

Unfortunately, the Sustainability Disclosure Standard Exposure Draft (S1) mentions the term “threshold” only twice, neither in the sustainability context.[viii]

Indeed, as with the I?SB FAQ, S1 fails to define sustainability at all. Appendix A: Defined Terms neglects to define “sustainability” as its own term, but instead includes the word “sustainability” in two of the terms it defines:

• Sustainability-related financial disclosures: Disclosures about sustainability-related risks and opportunities that are useful to users of general purpose financial reporting when they assess an entity’s enterprise value, including information about its governance, strategy and risk management, and related metrics and targets.
• Sustainability-related financial information: Information that gives insight into sustainability-related risks and opportunities that affect enterprise value, providing a sufficient basis for users of general purpose financial reporting to assess the resources and relationships on which an entity’s business model and strategy for sustaining and developing that model depend.

By defining “sustainability” only within the bounded space of “financial disclosures” and “financial information,” S1 shrinks the definitional scope in ways that eliminate key vitalizing aspects of “sustainability” — namely, its focus on internal and external environmental, social, and economic impacts.

“Sustainability performance is totally analogous to financial capital measurement — profitability is a threshold that measures sustainability…” states Cabot Creamery Cooperative Director of Sustainability Jed Davis in a report on the pilot testing of thresholds-based sustainability performance indicators issued recently by the United Nations Research Institute for Social Development (UNRISD).[ix]

According to this analogy, S1 seeks to account for the “income” that enterprise value draws from the external operating environment, but ignores the “expenses” that enterprise value creation accrues to the external operating environment. In other words, the I?SB seeks to contravene basic accounting principles in measuring sustainability exclusively at the enterprise value level, by only applying one side of the equation (income, not expenses) for assessing companies’ status vis-à-vis the profitability (ie sustainability) threshold.

Digging a layer deeper, it is illuminating to notice that three-quarters of the time S1 uses the term “sustainability” (268 of 364), it is represented as “sustainability-related,”[x] attempting to end-run around the essential meaning of “sustainability” by diluting its denotation through hyphenation.

Digging yet another layer deeper, S1 further bounds its application of “sustainability” to the scope of “enterprise value,” which is nonsensical, seeing as the ability to sustain enterprise value creation depends upon the sustenance of value in the systems within which the enterprise is nested.[xi] In other words, the enterprise relies on vital capital resources drawn from outside its own boundaries, so its ability to sustain its own value creation (enterprise value) is, by definition, interdependent with its ability to do its part to sustain that system value creation.[xii] And by extension, enterprise value cannot be sustained if it depletes system value beyond critical thresholds — ie, if the enterprise impedes the continual regeneration vital capital resources in its internal and external operating environment below sufficiency levels.

You need look no further that to your own body. Go ahead, glance at it now: it is a set of nested systems within systems, all interdependent on each other for sustenance. Your body cannot sustain itself if you brain does not sustain itself; your brain cannot sustain itself outside your body. And if your brain drains vital capital resources from the body within which it operates — if it nurtures a cancer that attacks the organs outside itself — it cannot sustain itself. If the body dies, the brain dies — it cannot survive without a body to sustain it.

So too with an enterprise.

The notion of enterprise value, divorced from the notion of system value, is nonsensical.

This much is clear to anyone who takes the notion of sustainability seriously — there is no such thing as a sustainable enterprise in an unsustainable system — an economic system, a social system.

Clearly, the I?SB does not take the notion of sustainability seriously, but rather approaches the notion opportunistically, seeking to co-opt the “sheen” of sustainability to lend life-support to the dying ideas of ESG (inaccurately conflated with sustainability) and isolated enterprise value.

Shifting our attention to the Climate-related Disclosures Standard (S2), we do note that S2 includes a single reference to a sustainability threshold, related to climate change:

“The ‘latest international agreement on climate change’ is defined as the latest agreement between members of the United Nations Framework Convention on Climate Change (UNFCCC). The agreements made under the UNFCCC set norms and targets for a reduction in greenhouse gases. At the time of publication of the Exposure Draft, the latest such agreement is the Paris Agreement (April 2016); its signatories agreed to limit global warming to well below 2 degrees Celsius above pre-industrial levels, and to pursue efforts to limit warming to 1.5 degrees Celsius above pre-industrial levels. Until the Paris Agreement is replaced, the effect of the proposals in the Exposure Draft is that an entity is required to reference the targets set out in the Paris Agreement when disclosing whether or to what degree its own targets compare to the targets in the Paris Agreement.” [Emphasis added]

While we appreciate this reference to “norms,” its presence in S2 only serves to spotlight the conspicuous absence of sustainability thresholds at the general specifications level in S1. While we would expect the integration of thresholds to be a rule in S1, that is then followed on all subsequent thematic Standards, this introduction of a threshold in the subordinate S2 amounts to an exception to the rule, veering from the broad guidance of S1.

And upon closer scrutiny, S2 does not actually require enterprises to set their own GHG emissions targets in ways that comply with the Paris Agreement norms and targets; the S2 Draft Standard merely requires enterprises to disclose “whether or to what degree its own targets compare to the targets in the Paris Agreement.” [Emphasis added] So an enterprise could fulfill the S2 Standard by answering the “whether” question with an unapologetic “no.” Or, the enterprise could disclose that its target does not in the slightest comport with the Paris Agreement, and this would meet the requirements of the Standard. In this sense, S2 could accurately be described as an Unsustainability Disclosure Standard as much as it could be characterized as a Sustainability Disclosure Standard: in other words, there’s nothing in the Standard that requires, compels, or incentivizes the enterprise to perform sustainably, in conformance with the sustainability norm / threshold.

Finally, this focus on GHG emissions highlights the inherent inside-out aspect of climate impacts; while climate change will almost certainly impact enterprise value (ie exert outside-in impact), an enterprise’s GHG emissions primarily impact the value of the earth’s climate regulatory system, which has maintained an incredible Goldilocks-like balance for the past 10,000 years, a period of climatic stability that is anomalous in the geologic record, enabling the emergence of human civilizations. In other words, an enterprise’s GHG emissions impact system value, not so much its own enterprise value, precisely because GHG emissions are an inside-out impact.

Framing climate-related disclosure standards — particularly those focused primarily on GHG emissions — exclusively around enterprise value is utterly nonsensical. The attempt to bound the scope of climate change to the enterprise value level reveals a fundamental miscomprehension of basic physics. The fact that S2 requires disclosure of GHG emissions — which by definition impact the enterprise’s external operating environment — makes it impossible to square the enterprise value boundary with any intelligible understanding of reality. It is almost as if the I?SB is actively trying to insult our intelligence by even proposing to limit a Climate Change Standard to the enterprise value level — which only amplifies the absurdity of limiting its proposed Sustainability Disclosure Standard to the enterprise value level.

For these reasons, it is clear that I?SB is by no means employing the term “Sustainability” in good faith, but rather is seeking to co-opt the term in ways that undermine the goal of achieving sustainability, by prioritizing enterprise value over system value. If I?SB respected the term Sustainability, it would be able to structure a Sustainability Disclosure Standard that enabled discernment of sustainable creation of enterprise value in the context of the sustainable creation of system value. We would welcome such a Standard, and would be glad to support its development and propagation.

Sociopathic Materiality

Wikipedia asserts that sociopathy is characterized by “a long-term pattern of disregard of, or violation of, the rights of others,”[xiii] as well as “manipulative self-serving behaviors with no regard for others” and “a selfish world view that precludes the welfare of others.”[xiv]

We will demonstrate how I?SB’s approach to materiality precisely fits this definition of sociopathy, warranting the labeling of its approach as “Sociopathic Materiality.” We propose, in contrast, a form of “prosocial” materiality that shows “regard” for “the welfare of others,” not only for a snapshot in time, but sustainably over time.

First, let us establish the sociopathic nature of I?SB’s approach to materiality. In S1, I?SB states:

“Sustainability-related risks and opportunities arise from an entity’s dependencies on resources and its impacts on resources, and the relationships the entity maintains that may be positively or negatively affected by those impacts and dependencies. When an entity’s business model depends, for example, on a natural resource — like water — it is likely to be affected by changes in the quality, availability and pricing of that resource.” [Emphasis added]

Let’s pause for a moment here: if the enterprise depends on water, then, by definition, it impacts the water that others — natural systems, other living beings, other enterprises, etc… — also depend upon. The enterprise’s own impacts on water — which impacts all these others — is utterly elided by this
I?SB formulation; the focus is exclusively on the how the enterprise is “likely to be affected” by these others. The bi-directionality of impacts is ignored by
I?SB, reflecting “a selfish world view that precludes the welfare of others.”

“But wait,” you may say, “read on to the next sentence — we address others there!” Indeed, let’s see:

“When an entity’s activities result in adverse, external impacts — on, for example, local communities — it could be subjected to stricter government regulation and consequences of reputational effects — for example, negative effects on the entity’s brand and higher recruitment costs.”

Let that sink in. Re-read it. In fact, we will repeat it here, to reinforce experiencing the sociopathic nature of it:

“When an entity’s activities result in adverse, external impacts — on, for example, local communities — it could be subjected to stricter government regulation and consequences of reputational effects — for example, negative effects on the entity’s brand and higher recruitment costs.”

In this example, a local community experiences adverse impacts at the hands of the reporting entity, and the I?SB’s concern — its scope of materiality for disclosure — is the “negative effects on the entity…” The I?SB literally does not give a damn about the welfare of the local communities, which we know has experienced adverse impacts.

Indeed, these adverse impacts perpetrated by the reporting enterprise could be so severe as to place the sustainabilityof the vital capital resources that those local communities rely on for their wellbeing at risk. Yet to the I?SB, this is utterly immaterial — it does not factor into the

I?SB’s so-called “Sustainability” Disclosure Standard.

What does qualify as material information in the I?SB Draft Sustainability Disclosure Standards?

“Material sustainability-related financial information provides insights into factors that could reasonably be expected to influence primary users’ assessments of an entity’s enterprise value. The information relates to activities, interactions and relationships and to the use of resources along the entity’s value chain if it could influence the assessment primary users make of its enterprise value.” [Emphasis added]

This scope of materiality is by definition sociopathic: it advances “a selfish world view that precludes the welfare of others” and endorses “self-serving behaviors with no regard for others.”

When the welfare of others is clearly impacted, the I?SB “Sustainability” Disclosure Standard enacts a classic narcissistic move, shifting attention from the primary adverse impact the enterprise has caused for the victim, to the secondary adverse impact that the enterprise has brought onto itself. It is as if the I?SB is writing a script for gas-lighting.

What is perhaps most troubling is that the I?SB lives in a world where it conceives of its primary users exclusively as sociopaths. We have no doubt that a significant percentage of I?SB’s intended audience are, indeed, certifiable sociopaths, given that they operate in the sociopathic economic system of late stage monocapitalism.

However, we just as strongly believe that a significant percentage of I?SB’s audience — providers of capital — are actually loving, caring, moral human beings. Indeed, we believe that the “reasonable” investor should, by definition, be concerned with material issues that extend well beyond the scope of enterprise value. We assert that it is unreasonable to conceive of “primary users” as exclusively a kind of caricature of homo economicus. To conceive of users as only those with narrow pecuniary interests shows a kind of contempt for humanity that we find depressing — we feel sorry for the I?SB for its stunted imagination and inability to appreciate the value and beauty of humanity and the miraculous natural world we are blessed to inhabit.

Many have characterized the I?SB approach as “single materiality” (focused exclusively on “outside-in” impacts and risks — ie, how the world impacts the enterprise) as compared to “double materiality” (focused on both outside-in and inside-out impacts and risks , which adds how the enterprise impacts the world), in the terms coined in 2019 by the European Commission in its Sustainable Finance Taxonomy workstream. While we appreciate the value of this coinage, we note that the interrelated concept of outside-in and inside-out impacts and risks dates back much further than 2019 — the concepts appeared in Global Reporting Initiative Sustainability Reporting Guidelines as early as their third generation (G3) in 2006.

Indeed, G3 called for sustainability reports to include two distinct sections:

“Section One should focus on the organization’s key impacts on sustainability and effects on stakeholders… Section Two should focus on the impact of sustainability trends, risks, and opportunities on the long-term prospects and financial performance of the organization.”[xv]

In fact, GRI G3 includes the best, most concise definition of materiality we’re aware of, which we would encourage the I?SB to adopt and embrace.

“In financial reporting, materiality is commonly thought of as a threshold for influencing the economic decisions of those using an organization’s financial statements, investors in particular.

“The concept of a threshold is also important in sustainability reporting, but it is concerned with a wider range of impacts and stakeholders.

Materiality for sustainability reporting is not limited only to those sustainability topics that have a significant financial impact on the organization.

Determining materiality for a sustainability report includes considering economic, environmental, and social impacts that cross a threshold in affecting the ability to meeting the needs of the present without compromising the needs of future generations.

These material issues will often have a significant financial impact in the near-term or long-term on an organization.

They will therefore also be relevant to stakeholders who focus strictly on the financial condition of the organization.”[xvi] [Emphasis added]

On this final point, we would go further and assert that — even looking through a purely pecuniary lens — inside-out impacts that have absolutely no discernible financial implications on the entity’s own enterprise value, are nonetheless material, because they can aggregate to financially significant impacts on other entities’ enterprise value. This dynamic — sometimes known as systemic risk — is of particular interest to universal owners, who have stakes in enterprises across the entire economy, essentially.

So Enterprise A’s inside-out impacts on the world may be immaterial, in the sense employed by I?SB in S1 and S2, but they are absolutely material to these universal investors, who care less about idiosyncratic risks and impacts that affect a single holding in their portfolio (Enterprise A), and more about systemic risks that impact holdings across their entire portfolio (Enterprises B through Z and beyond). Stated slightly differently, universal investors have shifted from chasing alpha (or individual stock outperformance) to reinforcing beta (or the stability of the overall market.)

The proposed I?SB definition of materiality (ie Sociopathic Materiality) therefore undermines the information needs of universal investors, focused as it is on enterprise value exclusively.

Now, returning to the beginning of the GRI materiality definition, we appreciate the bridging between the notion of materiality thresholds in traditional financial reporting, and the materiality of thresholds in the sustainability realm, which delineate economic, environmental, and social resource sufficiency for meeting current and future needs. This thresholds-based approach aligns with GRI’s Principle of Sustainability Context, introduced in its Second Generation (G2) of Sustainability Reporting Guidelines in 2002.

“…sustainability reporting draw significant meaning from the larger context of how performance at the organisational level affects economic, environmental, and social capital formation and depletion at a local, regional, or global level.

…simply reporting on the trend in individual performance (or the efficiency of the organisation) leaves open the question of an organisation’s contribution to the total amount of these different types of capital.

…placing performance information in the broader biophysical, social, and economic context lies at the heart of sustainability reporting

…reporting organisations should consider their individual performance … in the context of the limits and demands placed on economic, environmental, or social resources at a macro-level.”[xvii] [Emphasis added]

GRI is by no means alone in asserting a thresholds-based approach to materiality; the United Nations, which has long supported thresholds-based sustainability reporting,[xviii] has recently thrown its weight behind thresholds-based materiality. In late 2019, the United Nations Research Institute for Social Development (UNRISD) released a report entitled Making Materiality Determinations: A Context-Based Approach. The report, which was part of UNRISD’s four-year Sustainable Development Performance Indicators (SDPI) Project, laid out an implementable framework for applying thresholds-based materiality that, of course, encompasses not only outside-in impacts and risks (“Single Materiality”), but also inside-out impacts and risks (“Double Materiality”).[xix]

Accordingly, while we support the notion of I?SB extending its definition of materiality from what some call “Single Materiality” (and we call “Sociopathic Materiality”) to what some call “Double Materiality,” we believe that this only gets us part-way to the definition required for a true Sustainability Disclosure Standard. We believe that any standard claiming to be a Sustainability Disclosure Standard would need to take a context-based (ie thresholds-based) approach to materiality — precisely because “contextualization within thresholds [is] what sustainability is all about,” as Allen White established.[xx]

The last question is: can such a thresholds-based approach to materiality — and sustainability reporting more broadly — actually be done?

The answer is an unequivocal “Yes”!

UNRISD, in the same SDPI Project mentioned immediately above, developed a set of thresholds-based sustainability indicators covering economic, environmental, social, and institutional areas, and pilot tested them at a couple dozen enterprises globally.[xxi] Organizations that participated in the pilot testing project included large multinationals such as Anglo American and Manulife, and smaller social & solidarity economy enterprises, such as two Mondragon cooperatives and Vancity, as well as key multilaterals and intermediaries such as the Impact Management Project, World Bank and World Benchmarking Alliance.

One pilot company (GLS Bank) started implementing the Indicators even before the end of the pilot testing, integrating them into its 2020 Integrated Sustainability Report.[xxii].

The Synthesis Report summarizing the results of the pilot testing project documented two key outcomes:

• First, the pilot testing companies were able to implement essentially all of the indicators, demonstrating the feasibility of thresholds-based sustainability measurement and reporting;
• Second, the pilot testing companies embraced a context-based approach to materiality.

“Context-based materiality is fundamental — traditional materiality actually undermines a context-based approach to materiality,” said Jed Davis of Cabot Creamery Cooperative.[xxiii]

In conclusion, we encourage the I?SB to shift from its nonsensical, coopting, sociopathic approach to Sustainability Disclosure Standards, and adopt a sensible, cooperative, prosocial approach. While we may not have faith in I?SB doing so, we do believe we have laid out a water-tight case, and trust that the field (and history) will judge I?SB accordingly.

Sincerely,

Bill Baue, Ralph Thurm

Endnotes:

[i] In 2013, the Sustainability Accounting Standards Board (which has been subsumed into the International Sustainability Standards Board) conducted a Consultation process for its Conceptual Framework, and subsequently published a Record of Public Comments, in which it included a column for the “SASB Response.” A common response was “Comment noted” accompanied with an explanation of how the comment’s substance did not align with the boundaries of SASB’s mission / objective, justifying its dismissal of the substance of the comment.

Sustainability Accounting Standards Board. 2013. Conceptual Framework of the Sustainability Accounting Standards Board. October 2013. https://web.archive.org/web/20141202194709/http://www.sasb.org/wp-content/uploads/2013/10/SASB-Conceptual-Framework-Final-Formatted-10-22-13.pdf

Sustainability Accounting Standards Board. n.d. Conceptual Framework: Record of Public Comments. https://web.archive.org/web/20141202194905/http://www.sasb.org/wp-content/uploads/2014/01/Conceptual-Framework-Public-Comments-Table_-Rev-1-6-14.pdf

[ii] According to the November 2021 IFRS Foundation Constitution, the International Sustainability Standards Board could publish an Exposure Draft that claimed that the earth is flat, receive Public Comments that overwhelmingly point out the scientific evidence that the world is, in fact, round, and yet proceed to publish a Sustainability Disclosure Standard asserting a flat world, accompanied by a Basis for Conclusions explaining why its flat-world assertion aligns with its self-definition, justifying it to ignore the Public Comments. While this may sound hyperbolic, we see nothing in the Constitution on an ombuds function or complaint mechanism, so there is essentially no Due Process whereby the public (that the International Sustainability Standards Board ostensibly serves) can hold it accountable for taking such an outlandish position; its decisions, be they reasonable or nonsensical, are beyond appeal. IFRS Foundation. 2021. Constitution. https://www.ifrs.org/content/dam/ifrs/about-us/legal-and-governance/constitution-docs/ifrs-foundation-constitution-2021.pdf

[iii] “Sustainability is regarded as a ‘normative concept’.” Wikipedia. n.d. Sustainability: Current Usage. https://en.wikipedia.org/wiki/Sustainability#Current_usage

[iv] International Sustainability Standards Board. n.d. ISSB: Frequently Asked Questions. https://www.ifrs.org/groups/international-sustainability-standards-board/issb-frequently-asked-questions/

[v] “Sustainability is regarded as a ‘normative concept’.” Wikipedia. n.d. Sustainability: Current Usage. https://en.wikipedia.org/wiki/Sustainability#Current_usage

[vi] Bill Baue. 2013. #SustyGoals 2: A Dialogue with Allen White of GISR, the Godfather of Sustainability Context (Part 1). Sustainable Brands. 7 November 2013. https://sustainablebrands.com/read/new-metrics/sustygoals-2-a-dialogue-with-allen-white-of-gisr-the-godfather-of-sustainability-context-part

[vii] Bill Baue. 2013. #SustyGoals 2: A Dialogue with Allen White of GISR, the Godfather of Sustainability Context (Part 2). Sustainable Brands. 8 November 2013. https://sustainablebrands.com/read/new-metrics/sustygoals-2-a-dialogue-with-allen-white-of-gisr-the-godfather-of-sustainability-context-part-2

[viii] Line 25 on Page 29 of S1 states: “an entity shall disclose … the process, or processes, it uses to identify sustainability-related risks for risk management purposes, including when applicable: how it assesses the likelihood and effects associated with such risks (such as the qualitative factors, quantitative thresholds and other criteria used)…” Clearly, this reference pertains to thresholds of risk posed to the enterprise, not sustainability thresholds.
Line 58 on Page 35 states: “This [draft] Standard does not specify any thresholds for materiality or predetermine what would be material in a particular situation.” Clearly, this reference pertains to materiality thresholds, not sustainability thresholds.
International Sustainability Standards Board. 2022. Exposure Draft — IFRS Sustainability Disclosure Standard: [Draft] IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. IFRS Foundation. March 2022. https://www.ifrs.org/content/dam/ifrs/project/general-sustainability-related-disclosures/exposure-draft-ifrs-s1-general-requirements-for-disclosure-of-sustainability-related-financial-information.pdf

[ix] Bill Baue with Ralph Thurm. 2022. Thresholds of Transformation: UNRISD Sustainable Development Performance Indicators Pilot Testing — Synthesis Report. United Nations Research Institute for Social Development. 20 July 2022. https://www.unrisd.org/en/library/publications/thresholds-of-transformation-unrisd-sustainable-development-performance-indicators-pilot-testing-syn

[x] International Sustainability Standards Board. 2022. op cit.

[xi] The nested nature of sustainability is well established. Wikipedia. n.d. Sustainability: Dimensions of sustainability — relationship of dimensions to each other. https://en.wikipedia.org/wiki/Sustainability#Dimensions_of_sustainability

[xii] “System value” is a term coined by Geoff Kendall of the Future Fit Foundation.

Future Fit Business Benchmark. 2019. Methodology Guide. Release 2.1. April 2019. https://futurefitbusiness.org/wp-content/uploads/2019/04/FFBB-Methodology-Guide-R2.1.pdf
See also: Bill Baue. 2020. From Monocapitalism to Multicapitalism: 21st Century System Value Creation. r3.0. December 2020. https://www.r3-0.org/wp-content/uploads/2020/12/r3-0-White-Paper-1-2020-From-Monocapitalism-to-Multicapitalism.pdf

[xiii] Wikipedia. n.d. Antisocial Personality Disorder. https://en.wikipedia.org/wiki/Antisocial_personality_disorder
“Other names: sociopathy”

[xiv] Wikipedia. n.d. Psychopathy. https://en.wikipedia.org/wiki/Psychopathy
“Psychopathy [is] sometimes considered synonymous with sociopathy…”

[xv] Global Reporting Initiative. 2006. Sustainability Reporting Guidelines. Version 3.0 (G3). https://www.yumpu.com/en/document/read/21417169/g3-guidelines-global-reporting-initiative

[xvi] Ibid.

[xvii] Global Reporting Initiative. 2002. Sustainability Reporting Guidelines. Version 2.0 (G2). https://www.r3-0.org/wp-content/uploads/2020/03/GRIguidelines.pdf

[xviii] See United Nations Environment Programme. 2015. Raising the Bar: Advancing Environmental Disclosure in Sustainability Reporting. https://wedocs.unep.org/bitstream/handle/20.500.11822/9807/-Raising_the_Bar_-_Advancing_Environmental_Disclosure_in_Sustainability_Reporting-2015UNEP_Raising_the_Bar_2015.pdf.pdf?sequence=3&amp%3BisAllowed=

[xix] Mark McElroy. 2019. Making Materiality Determinations: A Context-Based Approach. United Nations Research Institute for Social Development (UNRISD). 6 Dec 2019. https://cdn.unrisd.org/assets/library/papers/pdf-files/wp2019-6-mcelroy.pdf

[xx] Baue. 2013. op cit.

[xxi] Baue &Thurm. 2022. op cit.

[xxii] GLS Bank. 2021. Integrated Sustainability Report 2020. https://nachhaltigkeitsbericht.gls-bank.de/files/About-GLS-Sustainability-Report-2020_English.pdf

[xxiii] Baue &Thurm. 2022. op cit.