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

Comment Constituency Region Reporting
Relationship
o Strengthen information requested on remediation of supply chain issues found and how companies are supporting suppliers to
resolve issues
These are clearly some of the areas of most profound change. Caution is therefore urged. Structurally, it takes considerable effort
to understand the hierarchy from general to to specific disclosure and therefore how considerations of materiality are factored in
the select of detail and level of focus. Taken to its fullest, there is potentially a proliferation of data without a clear understanding of
where and how behaviour is shaped. The central point MAY be at the DM&A and Procurment Practice level, but this is not apparent.
In these terms the Part 4 Technical Protocol wooks in well with the Guidelines generally, but less so when it comes to determining
what supply chain material ought be disclosed. Likewise the Screening, Assessment and Remediation disclosures will for some
entities be very important, though the criteria for their use should be made more clear, otherwise there is risk of volume of
disclosure withour real gain.
This is a changing definition depending on how far the company looks up and down its value chain. The text provides flexibility to
adapt to the varying viewpoints of companies.
This is a welcome development to include indicators on the supply chain. It should be much clearer what the difference is between
the “value chain” and the “supply chain” as mentioned earlier. One general way that the indicators could be improved would be to
account for opportunities rather than simply covering risk monitoring. A more holistic view of the supply chain including both
inbound and outbound logistics should lead companies to recognize the supply chain as a key source for improving not only their
environmental impacts by working with suppliers but also cost-savings opportunities through more efficient environmental
practices throughout their entire supply chains.
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More specifically, there are some details in the indicators that are unnecessary and would likely provide more burden on the
companies than benefits for the end-users of the data. Core G4 3 should be deleted for this reason (the results are unlikely to be
meaningful). The indicators relating to screening and assessment are important, but they should be simplified. Core G4 6 needs to
be significantly simplified / clarified. The terms “society-related” is extremely vague in indicators Core G4 12-14 and should be
clarified and / or clearly defined.
There are several instances where the difference between short and long-term supplier relationships is emphasized under the
assumption that long-term relationships are more sustainable. However, many of these differences will be driven more by the
nature of the industry, sector and business model rather tan anything having to do with sustainability performance. Rather tan
focusing on the length of the supplier relationship, the issue can and should be addressed more directly by asking companies to
disclose information about the content of their ESG supplier policies as well as programs that may exist to educate and train their
suppliers on sustainability issues. While the screening and assessment indicators are important, they should be consolidated and
shortened in order for answers to be more focused on the most essential aspects of sustainability performance.
Too granular. Too complex for companies to practically report on. Business Northern
America
Reporter
Second G4 Public Comment Period: Submissions
Document 8 of 12 – Qualitative Online Feedback: Supply Chain Disclosure
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