jueves, 10 de noviembre de 2016

Sustainability reporting standards: Compete or collaborate to compete?

There is nothing worse than a sharp image of a fuzzy concept.
Ansel Adams, photographer.

The question posed in the title may seem to some to be rhetorical.  No, there can be no competition between sustainability reporting standards (SASB, GRI, IIRC, etc.).  Even though their products cater to the same market, sustainability information providers, the end users are different. Nevertheless some, particularly SASB and GRI, behave as if in competition with each other, which does not help either of them, nor the providers nor the final users.  Time would be better invested in cooperation.

Is there competition?

In an analysis of this competitive situation, in her post Trump versus Clinton or SASB versus GRI Elaine Cohen, reports that SASB, in the comments sent about the draft GRI standards, suggested that “Perhaps GRI efforts are better place in providing a forum for stakeholders to voice their concerns………rather than codifying standards……”.   Looks as if SASB was telling GRI “get out of the way”. I do not think this should be seen as a dismissal by SASB of the notable contribution of the GRI framework to sustainability reporting, but it is indicative that there is a sense of “competition” between both sets of standards (not as nasty and consequential as the competition between Trump and Clinton).

Sustainability information is still a “fuzzy concept”, but by using the terms “standards” SASB and GRI want to convey a “sharp image”, after all the connotation of the word “standards” is that of something very well defined, with consensus among users. Both are guilty of abuse of sharpening a fuzzy concept.  And it all started with the creation of the SASB, partly fueled by perceived weaknesses in the GRI “framework”.  Even the name was meant to recall the true and tried financial standards of the FASB and provide instant credibility by association.  By being “standards”, they would certainly be superior to a “framework”.  GRI must have felt threatened as, shorlty aftert he introduction of G4 framework moved speedily the process of converting the guidelines for the “preparation of sustainability reports” into “sustainability reporting standards”.  This was achieved by changing some of the language and rearranging the content of the framework to look more like “standards”.  It convened a group of experts under the competitive name of Global Sustainability Standards Board, GSSB to guide the process, although this is far from a standard setting institution.  Now both institutions have standards.  FASB, SASB, GSSB, any others SBs? Let’s hope that the IIRCouncil does not change its name to IRSB, Integrated Reporting Standards Board, to enter the “competition”.  

This had led both SASB and GSSB (GRI) to rush their dissemination campaigns, aided by the legion of consultants that make a living providing training and advice on the use of the standards, with providers and users of sustainability information as interested onlookers. This rivalry has helped the dissemination of their products and stimulated the interest of providers and users, although it has also caused unnecessary confusion as they are different products for different final users.

Sustainability information vs. sustainability reports

Some of this confusion is the result of assuming that sustainability information must be compiled in a sustainability report.  The preparation of these reports has been heavily promoted by GRI as it means a growing market for its product.  It has contributed to develop a vast industry of advisors, writers, graphic designers, photographers, specialized printers, etc. which are now strong supporters of the adoption of the GRI standards, of the continuity and indispensability of preparing sustainability reports, and of the updating of the standards so that the market continues to need their training and advisory services (disclosure: the author of this article does not provide these services). They have significant intellectual capital invested in the GRI framework/standards that needs to be preserved.

But what stakeholders need is sustainability information, not necessarily complied in a formal, quasi-standardized report.  And this is where the difference between SASB and GRI is stark.  SASB supports the preparation of information for a very narrow set of users of sustainability information: providers of financial resources.  As such their concerns are that the information be of interest to the users and be material, defined as having a direct or indirect impact, preferably tangible, on the financial condition and operational performance of the company. For SASB the relevant sustainability information is the one that supports the business case. This information can be presented in many ways, which are not specified by SASB, except to suggest quantitative and qualitative (worded as precise as possible) indicators.

The major issue for SASB is the link and the certainty of the link between the indicator and actual impact on financial performance.  They go to some length to show that the action contained in the indicator “should” have a financial impact. But does it?  The key is the transmission mechanism between the action and the impact.  If customers do not care or do not know about the working conditions, or financial analysts do not consider the issue in their recommendations, or if investors do not act on the sustainability of the company, the financial impact may not be realized.  To justify the inclusion of the indicators SASB seeks to provide “evidence of impact”, but the evidence tends to be derived from academic studies on the “aggregate” of many firms and on the efficiency of markets in incorporating sustainability information, not for the particular case of a given company, under its context and its circumstances.  For instance, reduction of emissions “should” reduce risks and affect the cost of capital.  But, it this the case of the specific reporting company?  Does the transmission mechanism work?  The expectation is that the impact will eventually be realized, hence in a long term view, the sustainability action is material.

GRI takes a broader view of stakeholders and includes all of them, and prompts the identification of the issues that affect or are affected by them (very different definition of materiality from SASB).  But the criterion for issue inclusion is the interest of stakeholders in knowing the information and potentially acting on it, not necessarily on the potential financial impact as is the criteria of SASB.  Even though the GRI standards call for prioritization of material issues, it wants to serve all needs of all users, calling for the preparation of (extensive) sustainability reports that, in general, serve none of them.  But by now the “sustainability market” has come to expect the publication of a sustainability report under GRI framework/standards and not doing so is considered a lack of respect for stakeholders or even an indication of poor sustainability performance.  Actually one of the most used indicators for the progress of sustainability is the number of reports published or the fact the reporting is being extended to SMEs (even though it may not be cost effective for these firms), among others.  And it has become a must, as sign of responsibility, of “compliance”, of prestige, to follow GRI framework, now standards.

And what is the value added of the Integrated Reporting framework?  It overlays both SASB and GRI standards, supporting and expanding them.  It promotes the preparation of reports with an expanded set of financial and non-financial information (that includes sustainability), by proposing to report the contribution of the company in the advancement of the six capitals (Financial, Manufactured, Intellectual, Human, Social and Relationship and Natural capital), not just the impact on financial capital as in the case of SASB or the scattered reporting, with non-explicit impacts, of GRI.  It one could overcome the problems of measurement of impact on the six capitals, it would be the ultimate report on the contribution of the company to society.  This shows the direction of financial and non-financial reporting, even if the measure of this contribution is still in its infancy.

Compete or “collaborate to compete”? [i]

Contrasting the approaches to sustainability information of the targeted SASB information to a set of stakeholders with the all-inclusive (in spite of its efforts to focus on material issues) dispersed requirements of GRI, in the wider but focused context of the contribution to the six capitals of the IIRC one could conclude that effectiveness, in the long run, suggests that efforts should be directed at producing and disseminating targeted information to the different stakeholders along the lines of the six capitals, i.e. “six SASBs”, one for each capital.  In our previous article Is competition between sustainability reporting standards healthy?  we argued for the availability of sustainability information to fill the needs of stakeholders.  With the cooperation and integration of …

“….these standards companies could prepare information, almost like a “universal report” in a comprehensive online information dataset which would allow each stakeholder to pick and choose the information that is material to them and let the software compile the report, including qualitative descriptions and quantitative data or indicators. From all of that WE, the stakeholders, will determine what is material to us in our decision making, which is the materiality that matters.” 

And if the information were to include the impact on the capitals, it would significantly enhance its usefulness.  So far the indicators and the narrative, even if standardized, leave a lot of the work in the hands of the users. Eventually companies will move to make this impact more explicit.

In the meantime the proliferation of “standards” is not helping to advance the cause of sustainability, distracting the scarce resources within companies and the limited capacity of the users in information processing and understanding its implications. [ii]

[i] In Latin, CUMPETERE, the name of my consulting firm.
[ii] And in the confusion many institutions are proposing other models for sustainability information, the latest of which is the proposal of BSR in Triangles, Numbers, and Narratives: A Proposal for the Future of Sustainability Reporting.