Qualitative Online Feedback: Supply Chain Disclosure - Global ...

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Comment Constituency Region Reporting Relationship see comments for question 6. Do you have other general comments related to the Supply Chain Disclosures? See my responses above. Mediating Institution Civil Society Organization Europe Northern America Consultant Report Reader Consultant Report Reader R&D in reporting See question 1. Business Europe Reporter Separation between supply chain and value chain partially unclear. Supply chain only relates to the first half of value chain. Business Europe Reporter Some of the guidance terms are too vague. For example, it is not clear whether auditing of suppliers includes corrective-action auditing or informal review. For the certification question, is it appropriate for the certification to be self-certified, or does this need to be third-party certification? Terms such as “small” and “medium” need to be clarified. Are foreign and domestic suppliers held to the same standards? To what extent should screening be performed and what are the required attributes of screening? These are just a few of the areas in which the guidance should be clarified. Ultimately, EPRI agrees with the increased emphasis on supply chain and would welcome the opportunity to engage further on this subject with GRI. The guidance does not fully address how an organisation should group and prioritise suppliers. This could be problematic for larger organisations that have many suppliers who are often very small or provide a low volume of goods or services. Furthermore, the nature of the goods and services being supplied is not addressed which may hold some significance. The relative importance of suppliers will also need to be linked to the materiality process. The guidance is appropriate, however the location and structure of the information within the G4 is a little bit confusing. There are a lot of indications about new things to report, and in some cases the demand of information exceeds a lot the information companies have about their suppliers (for example in all the new inclusions in the labor DMA). It will be very helpful to concentrate all the indicators and information about supply chain in one aspect. In cases where this information may not be material, it is easy to not take into account the requirements if all the requirements are concentrated. The information is fragmented and many find it hard to follow. Supply Chain (SC) matters have expanded considerably. It would be helpful to have a concentrated section on Procurement and Value Chain. The is one of the biggest and most important changes it warrants a guidance document of its own. Certified Training Partner materials need careful consideration. Webinars for Supply Chain and Value Chain are also needed a long with case studies all i n due course We like the fact that supply chain is becoming better incorporated but have spoken to others who find G4 Supply Chain provisions over bearing and onerous, we feel that the amount of disclosure could be reduced whilst delivering good information to drive the company forward an keep stakeholders informed. There are also areas that are over detailed; see Technical comments which go through many of these. However overall the outcome is worth the effort if it provides the visibility that can drive sustainability into the suppy chain and develop greater responsibility amongst large reporting organisations. Supply chain satisfaction surveys may be a source if difficulty as suppliers are likely to be reluctant to comment adversely upon the hand that feeds them. Mediating Institution Northern America Report Reader Research Business Europe Reporter Mediating Institution Mediating Institution Europe Europe Reporter Consultant Report Reader Reporter Consultant Report Reader GRI Certified Training Partner Second G4 Public Comment Period: Submissions Document 8 of 12 – Qualitative Online Feedback: Supply Chain Disclosure Page 1283 of 2491
Comment Constituency Region Reporting Relationship The proposed Disclosure DI 12 asks companies to “Describe the organization’s supply chain” (line 99). The guidance for this disclosure is extremely broad, including numerous criteria and sub-criteria that will make comprehensive reporting particularly onerous and unfeasible. For example, the requirement to report on “Total number of suppliers” using the new definition of suppliers provided in the G4 glossary may require companies to gather data on new classes of individuals and organizations than are currently tracked. The sub-criteria presented in lines 102-110 also pose a significant reporting burden for large companies with complex and variable supply chains, potentially requiring many pages listing numerous materials, products, services, and global locations. We suggest: that the GRI revisit the language of this disclosure to address how information could and should be aggregated in the case of large companies with large, complex supply chains. One particular issue to be addressed is how to define the term “Total number of suppliers”—i.e., whether this term reflects only direct (Tier 1) suppliers, or suppliers throughout the value chain. The proposed guidance calls for too many elements in too much detail. It might be more effective to suggest that a company should disclose material elements throughout its supply chain in the context of how it creates and preserves value. The provided guidance isn't clear on Core Disclosures G4 6, HR2, and other similar supplier-related disclosures, as they relate to reporting of suppliers and other business partners having adverse impacts on sustainability. It isn't apparent who would determine that such suppliers have adverse impacts other than the reporter itself, raising questions on subjectivity and overall reporting consistency. Mediating Institution Mediating Institution Business Northern America Asia Northern America Reporter Consultant Report Reader Reporter Consultant Assurance Provider Report Reader Reporter Disclosure Core G4 2 appears to include an assumption in stating that a high turnover of suppliers quantifies the stability of an organization's supplier base, thereby implying ineffective management of the relationship between the organization and its suppliers. In complex businesses, a multitude of reasons may cause a high turnover of supplies, such as market uncertainty and a recession disproportionately impacting particular sectors. Additionally, publicly held companies are in business to make a profit, and one of the tools that enable them to do so is to use competitive bidding to reduce the cost of their supplies. This disclosure should be removed. The references to Under-represented / Underrepresented groups, Vulnerable groups, Indicators of Diversity (suggested change to Diversity Groups), Marginalized Groups and “Economic Inclusion” (suggested change to Social and Economic Inclusion) and the definitions included at Glossary level should be unified along the GRI G4 guidelines. The disclosure of accessibility of workplace environment or acquired disabilities should be considered among the issues to report under Labor Practices and Decent Work category. Also, guidance that provides references of appropriate “institutional and legal frameworks” for a particular topic could be of great Civil Society Organization Europe Report Reader Work to promote and enhance the disability disclosure in sustainability reports Second G4 Public Comment Period: Submissions Document 8 of 12 – Qualitative Online Feedback: Supply Chain Disclosure Page 1284 of 2491
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G4 DEVELOPMENT Second G4 Public Com
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Documents Contents Page Second G4 P
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As defined in the GRI Due Process,
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process consisted of (1) a map of t
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The proposed revisions included:
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8.3 QUESTIONS FOR GENERAL COMMENT:
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