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

Comment Constituency Region Reporting
Relationship
64
756 to address the issues identified. __CORE G4 6 __ Percentage of existing suppliers and
CORE G4 6
Comment
Content Comment
difficulty of comparability, because there are different methodologies for environmental impact assessment and depending on the
depth and quality of the evaluation, the results can be different
64
756 to address the issues identified. __CORE __ G4 6 Percentage of existing
CORE
Comment
Content Comment
This entire supply chain reporting requirement would be impossible to implement in a cost effective manner for a global operation
with thousands of suppliers located globally. Reviewing Environmental Impact Assessments to determine which of a company’s
numerous suppliers could have a “potential” impact is far beyond the economic capability of even the largest companies. Listing
these supplies by location would be cumbersome and the cost of monitoring and reporting on their performance as indicated would
be prohibitive. This reporting requirement as written requires a reporting company to report on the sustainability performance of
all of its suppliers (again, these could number thousands), which should be the responsibility of the supplier, not the reporter.
One example would be a site which operates in Australia may receive parts from a small to medium- sized manufacturer in Germany
that may have a contract to make the parts with a factory in Turkey that had an environmental incident which could have a shortterm
or long-term impact on the environment. The relationship between the site in Australia and the manufacturer in Germany is
not managed at the global level and neither the site nor the global organization would have enough resources to try to track such an
incident if it occurred. If there were legal proceedings in Turkey regarding the environmental incident, then the reporting
organization could incur legal liabilities for public reporting the incident pending the outcome of the legal process. Companies can’t
publically report what other companies are doing without incurring some legal risk.
Business Latin america Reporter
Business Africa Reporter
Reporting on the location of the supplier would be extremely time consuming and potentially very expensive.
64
756-757 __Percentage of existing suppliers and other business partners identifie...
Percentage of existing suppliers and other business partners identified as having actual and potential adverse impacts
Comment
Content Comment
; the wording ‘ suppliers and other business partners identified as having actual and potential adverse impacts on the environment’.
The same wording is used later in the document regarding labour practices, human rights, and society-based aspects. This wording
seems very open tot interpretation; on the one hand it is every supplier, all organisations have some sort of adverse impact,
especially on the environment. On the other hand it could read like only having to report on high likelihoods or occurrences where
laws are breached, e.g. systemic pollution. As this is something that could very well not be in line with local legislation, we feel
Civil Society
Organization
Europe
Report Reader
Second G4 Public Comment Period: Submissions
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