r3.0 Urges GRI’s Global Sustainability Standards Board to Provide Robust Guidance on Sustainability Context

r3.0 Senior Director Bill Baue submitted r3.0’s response to the GRI Global Sustainability Standards Board’s call for public comment on their Draft GSSB Work Program 2020–2022 on June 22nd, 2020.

Sustainability requires contextualization within thresholds. That’s what sustainability is all about.

Allen White, Co-Founder, Global Reporting Initiative, 2013[1]

I respectfully write with a simple request: issue robust guidance on applying the Sustainability Context Principle. I do so in compliance with lines 78–84 of the Draft GSSB Work Program 2020–2022 under the section entitled “Issuance of FAQs, Guidance and authoritative interpretations”.

I submit the following simple rationale:

  1. The Global Reporting Initiative (GRI) introduced the Sustainability Context Principle in its second generation of Sustainability Reporting Guidelines (G2) in 2002. The essence of the Principle guided reporting organisations to discuss

the performance of the organisation in the context of the limits and demands placed on economic, environmental, or social resources at a macro-level.[2]

2. The Sustainability Context Principle has remained fundamentally unchanged for nearly two decades.

3. GRI has provided insufficient guidance on implementing the Sustainability Context Principle throughout this entire period, until the present.

4. Evidence of this fact is contained in exhaustive empirical research by Anders Bjørn et al, who “systematically reviewed references to ecological limits in 40.000 CR reports” issued from 2000–2013. This research found only about “5% of companies referred to ecological limits in any year,” and of these 5%, “only 31 companies planned to align performance or products to limits.”[3]

5. A 2019 United Nations Research Institute for Social Development report on Sustainable Development Performance Indicators did the math: the research database used by Bjørn et al covered 12,000 companies, so 31 companies represents a mere 0.258% of reporting companies who “planned to align performance or products to limits.”[4] See Figure 1 for visual perspective on how this percentage compares to its reference universe.

Figure 1: Lack of Sustainability Context in Corporate Responsibility Reporting 2000–2013.[5]

6. So, after the Principle existed for a decade, essentially no companies applied Sustainability Context in the way intended — to discuss “the performance of the organisation in the context of the limits and demands placed on economic, environmental, or social resources at a macro-level.”

7. In the Public Comment Period for G4, 66 prominent sustainability experts in the Sustainability Context Group submitted a Public Comment asking GRI to “undertake improvements to the Sustainability Context Principle in G4.”[6] The Comment continued:

Although GRI’s Guidelines currently do advocate for the inclusion of Sustainability Context in organizational reports, they fail to provide specific guidance for how to do so…

Rather than devise a specific procedure for how to implement Sustainability Context in organizational reporting, we believe GRI should provide related guidance in the form of functional specifications, or criteria, for how to do so, in keeping with its charge of providing broad, non-prescriptive direction.[7]

Signatories of the Comment included Alan AtKisson of The AtKisson Group, Jan Bebbington of the University of St. Andrews, Stephanie Bertels of Simon Fraser University, Ecological Economics Co-Founder Bob Costanza, John Elkington of Volans Ventures, B Lab Co-Founder Bart Houlahan, Deborah Leipziger of the Sustainability Lexicon Project, Sustainability Context Group Co-Founder Mark McElroy, Ralph Thurm of r3.0, Mathis Wackernagel of the Global Footprint Network, GRI Co-Founder Allen White, and The Big Pivot Author Andrew Winston.

8. GRI opted against acting on this input, and instead, left the Sustainability Context essentially untouched, with no further guidance provided then, or since.

9. In 2017, after a GRI representative spoke at the r3.0 Conference in Amsterdam, r3.0 engaged with GRI to propose collaborative Research and Training on Sustainability Context, and on the Global Thresholds & Allocations Council.[8] The ultimate result of this proposal was, again, inaction from GRI, either in collaboration or on its own.

10. During this nearly two-decade period between 2002 and the present, the Stockholm Resilience Centre has introduced research finding that humanity is overshooting 4 of the 9 Planetary Boundaries,[9] and Kate Raworth has built upon that research base to demonstrate the humanity is shortfalling on all 12 of the Social Foundations encompassed in what she calls the Doughnut.[10] So all told, humanity is transgressing 16 of 21 critical sustainability thresholds. See Figures 3 & 4:

Figures 3 & 4: Planetary Boundaries[11] and the Doughnut[12]

11. Organizations that use GRI Guidelines and Standards clearly play a decisive role in these sustainability threshold breaches.

12. As a provider of Guidance and Standards, GRI also can choose to play a decisive role in addressing these threshold breaches.

13. GRI cannot do so by continuing to cleave to the status quo.

14. Therefore, GRI will need to shift significantly, by providing robust guidance on its Sustainability Context Principle.

15. I will end by quoting climate activist Greta Thunberg:

If you really understood the situation and still kept on failing to act, then you would be evil. And that I refuse to believe.[13]


Key proposals in 14 September 2017 email from Bill Baue to the Global Reporting Initiative.

  • Research: We believe that Sustainability Context is a ripe area for research, following up on the research to-date (such as the Danish study cited in the most recent installation of our 10-Part Sustainable Brands series), the Article 13 research cited in your R3 Conference Presentation (and their 2017 refresh), etc… In addition to documenting the Context Gap, it would be important for the research to also focus on emerging solutions, including methods for integrating context.

Proposal: GRI & R3 establish a joint research project on implementation of the Sustainability Context Principle, focusing both retroactively on uptake to date, and proactively on what additional recommendations, guidance, case studies, methodologies, and data sources could help spur more robust implementation. This research stream could tap into the Reporting 3.0 Academic Alliance that is starting to take shape, and also could feed into the new GRI program starting this fall that you described in our call, on “developing guidance on issues that we don’t have standards on or inadequate standards.” It also ties into your recommitment to impact reporting, and research on the impacts of reporting, as we discussed in the call.

  • Training: As we discussed on our call, this area is particularly ripe for collaboration, as building out training on how to measure, manage and report on Sustainability Context is likely the most effective means of upping implementation of the Principle. And R3 is uniquely positioned to design curricula and deliver training on this front, given our connection to the Sustainability Context Group, many of whom are now in the R3 ecosystem.

Proposal: GRI & R3 establish a joint training project on implementation of the Sustainability Context Principle, building on the research outlined above. R3 would focus on curriculum development and training implementation (tapping into our Advocation Partner Program), while GRI would provide branding and promotion / communications.

  • Thresholds & Allocations Council: It is generally agreed that the lack of generally validated, systems-level thresholds across diverse areas of social, ecological, and economic impacts, framed for implementation by companies, hinders implementation of the SustyContext Principle. As well, the lack of similarly validated, “off the shelf” methodologies for allocation of “fair share” / proportionate responsibility for collective impacts on the “common” capitals hinders uptake. Revisiting an idea Allen first proposed in about 2013 or so, we see value in establishing a Thresholds & Allocations Council comprised of global experts in physical and social sciences / academia, NGOs, companies, multilaterals, governments, etc..

Proposal: GRI & R3 serve as the lead partners collaborating with other key players (e.g. Stockholm Resilience Center, UNGC, etc.) to convene such a council, with a primary objective of providing neutral & actionable guidance on thresholds & allocations for implementation by companies in particular. You could consider the Science-Based Targets Initiative as a kind of example focused just on GHGs / climate, though as a member of their Technical Advisory Group, I think a stronger governance.


[1] Bill Baue, “#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

[2] Global Reporting Initiative, Sustainability Reporting Guidelines, 2002. https://www.r3-0.org/wp-content/uploads/2020/03/GRIguidelines.pdf (As a side note, I would request that GRI follow best practice and post all of its Guidelines on its own Website, so that its stakeholders can readily access its historical development).

[3] Anders Bjørn et al, “Is Earth recognized as a finite system in corporate responsibility reporting?” Journal of Cleaner Production, Volume 163, 1 October 2017, Pages 106–117. https://www.sciencedirect.com/science/article/abs/pii/S0959652615019204

[4] Bill Baue, Compared to What? A Three-Tiered Typology of Sustainable Development Performance Indicators: From Incremental to Contextual to Transformational, United Nations Research Institute for Social Development, Working Paper 2019–5, October 2019. http://www.unrisd.org/baue

[5] Ibid, p 24.

[6] Sustainability Context Group, Statement to GRI on the Need to Enhance Treatment of the Sustainability Context Principle in G4, 24 September 2012. https://www.r3-0.org/wp-content/uploads/2020/03/SCG-GRI-G4-Comment-Submitted-9-24-12.pdf

[7] Ibid.

[8] Email attached in Appendix.

[9] Johan Rockström, Will Steffen, et al. “A safe operating space for humanity,” Nature, Volume 461, pp 472–475, 2009. https://www.nature.com/articles/461472a; Will Steffen, Katherine Richardson, Johan Rockström, Sarah Cornell, et.al. “Planetary boundaries: Guiding human development on a changing planet,” Science 347: 736, 1259855, 2015. http://science.sciencemag.org/content/347/6223/1259855;

[10] Kate Raworth, A safe and just space for humanity: Can we live within the doughnut? Oxfam Discussion Paper, February 2012. https://www-cdn.oxfam.org/s3fs-public/file_attachments/dp-a-safe-and-just-space-for-humanity-130212-en_5.pdf; Kate Raworth, “A Doughnut for the Anthropocene: humanity’s compass in the 21st century,” The Lancet: Planetary Health, Volume 1, Issue 2, PE48-E49, 1 May 2017. https://www.thelancet.com/journals/lanplh/article/PIIS2542-5196(17)30028-1/fulltext

[11] Op cit, Steffen et al 2015.

[12] Op cit, Raworth 2017.

[13] NPR Staff, “Transcript: Greta Thunberg’s Speech At The U.N. Climate Action Summit,” NPR, 23 September 2019. https://www.opb.org/news/article/npr-transcript-greta-thunbergs-speech-at-the-un-climate-action-summit/



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