From: Mark W. McElroy
Subject: Re: Status of Process?
Date: December 27, 2013 11:22:48 AM EST
To: Bastian Buck
Cc: Bill Baue, Simon Longstaff, Salama Tekle, Nicola Huijzer, Ernst Ligteringen
Thanks again for your detailed response, which Bill and I agree touches on important elements -- acknowledgements of current shortcomings, due process, TAC & GRI Board involvement leading to changes in the Guidelines, etc.
What most interests us comes near the end, in the "immediate fix" paragraph. We wholeheartedly agree that a research publication that advances the guidance discussion ("to inform practitioners and members of a potential future Working Group") makes perfect sense. What doesn't make any sense to us is the idea of waiting. You mention that next steps on this front can be taken after a larger review of reports, but we are not convinced such a review is even needed.
For our part, we see absolutely no reason to wait, as the review will provide no further insight on the "missing link" in the existing guidance than is already known. Indeed, the fatal flaw in G4 was very clearly revealed when you first sent us your research findings on October 21st. The fact that you had to create your own Assessment Criteria beyond the 4 Tests otherwise included in the G4 Implementation Manual was precisely because of the inadequacy of those Tests. As you may also recall, I subsequently asked you about this in an email I sent on November 2nd (copy attached), to which I never received a response.
To be even clearer about this, the second Assessment Criterion you created in October included the crucial terminology from the Sustainability Context Principle that is conspicuously missing from the Tests: "Report presents a discussion of the performance of the organization in the context of the limits and demands placed on environmental or social resources at the sector, local, regional, or global level." Not only is that language missing, but so, too, is guidance of any kind about how to comply with it. Expanding the size of the sample we look at will not change the fact that the guidance we are talking about is missing, so why bother?
This point proves two things:
• First, further guidance is unquestionably necessary, starting with the inclusion of the core terminology that defines Sustainability Context in G4 ("limits and demands placed on environmental or social resources"), followed by new and sufficient guidance for translating the concept into practice (i.e., a methodology or general specification for how to operationalize or implement the Principle, as earlier proposed to you by the Sustainability Context Group in September of 2012);
• Second, the expanded review you propose is unnecessary because it will either:
◦ a) rely, once again, solely on the Tests, which have already shown themselves to be inadequate, in which case any instances we find of addressing "limits and demands placed on environmental or social resources" in reports are liable to be in spite of, and not because of, the existing guidance (i.e., reporters would need to willfully disregard the Tests, going above and beyond them, in order to report their performance in Sustainability Context);
◦ b) rely on additional Assessment Criteria as you already did before, in which case we would, once again, be tacitly admitting that the existing guidance is inadequate by relying, instead, on guidance that is not included in G4.
In conclusion, then, we think the research we have already performed is sufficient to conclude that the guidance in G4 for how to implement the Sustainability Context Principle in reporting is demonstrably inadequate. To expand the scope of the sample we looked at will only waste valuable resources and time.
So, we welcome the opportunity to take you up on your invitation to work together on a research publication on guidance for implementing the Sustainability Context Principle, and without delay. As well, the parallel steps of due process you propose for launching and carrying out the development of new guidance also make sense to initiate immediately.
We look forward to hearing back from you on this matter.
Mark and Bill